ML20207E151
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| ML20207E151 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/10/1986 |
| From: | Barnes I, Ellershaw L, Hale C, Will Smith, Spessard R, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20207E070 | List: |
| References | |
| 50-445-86-07, 50-445-86-7, 50-446-86-05, 50-446-86-5, NUDOCS 8701020074 | |
| Download: ML20207E151 (49) | |
See also: IR 05000445/1986007
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. APPENDIX C'
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NRC COMANCHE FEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT.
I , 'U.S. NUCLEAR REGULATORY COMMISSION
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REGION-IV ,
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l.NRC Inspection. Report: 50-445/86-07 Permits: CPPR-126
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.50-446/86-05' CPPR-127
. Dockets : . 50-445.. Category: A2
lE '50-446 s; ' + .. , y Applicant: Texas Utilities. Electric Company Construction Permit
= Skyway Tower .
Expiration Dates:
400 North Olive ~ Street Unit 1: August 1, 1988
Lock Box'81'. ..
Unit 2: August 1, 1987
. Dallas, Texas 75201-
i Facility Name: . Comanche ~ Peak Steam Electric Station (CPSES), Units 1 & 2
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Inspection At: . Glen Rose, Texas.
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: Inspection: Conducted: April 1 - May 31, 1986
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: Inspectors:-
L. E. Ellershaw, Reactor, Inspector, Region IV Date
s CPSES Group
(paragraphs 2.a. 2.e, 2.j-k, 4.c, 5.e, 5.1, 6.b, and 6.c)
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C. J. haw Reactor lii5pector, Region IV
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CPSES GrdtTp
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(paragraphs 3.a-b, 4.a-b, 5.d. and 5.h-k)
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P. C. Wagner, Reactog Inspector, Region IV Date
CPSES Group
.(paragraphs 2.f-1, 3.c. 5.a-c and 6.a)
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A W. F. Smith, Resident Reactor Inspector Date
Region IV CPSES Group
(paragraphs 2.b-d and 5.f-g)
Consultants: EG&G - J. Dale (paragraph 4.c)
A. Maughan (paragraphs 2.f-1, 5.a-b, and 6.a)
W. Richins (paragraphs 4.c, 5.e, and 6.b)
V. Wenczel (paragraphs 3.a-b and 4.a-b) '
Parameter - J. Birmingham (paragraph 5.d and 5.h-k)
J. Gibson (paragraph 5.c)
K. Graham (paragraphs 2.a. 2.e, 2.j-k, and 6.c)
D. Jew (paragraphs 4.c and 5.1)
Reviewed By: C Nh/!N
R. L.'Spessard,(/ Deputy Director, Director Fate
Division of Inspection Programs, Office of
Inspection and Enforcement
Approved By: 8w /2/ro/p4
I. Barnes, Chief, Region IV CPSES Group Date
Inspection Summary
Inspection Conducted April 1 through May 31, 1986 (Report 50-445/86-07;
50-446/86-05)
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Areas Inspected: Nonroatine, unannounced inspection of applicant actions on
previous inspection findings, assessment of allegations, Comanche Peak Response
Team (CPRT) QA program, and CPRT issue-specific action plans (ISAPs).
Results: Within the four areas inspected, six violations (design basis for
criteria for base metal defect inspections not generated, paragraph 2.e; design
changes nct reviewed by thase responsible for the original design,
paragraph 2.k; temporary modification to cables not properly documented,
paragraph 5.c; terminal blocks not identified, paragraph 5.c; drawing errors
were not identified during reviews and checks, paragraph 5.c; and Corrective
Action Report (CAR) was closed before corrective action was complete,
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paragraph.5.h) and ten-deviations (corrective action not implemented as
committed, paragraph 2.a; error made during reinspection by Evaluation Research
: Corporation (ERC), paragraph 2.i; ERC QA manuals not maintained current,
paragraph 4.a; failure of Senior Review Team (SRT) to assure quality of CPRT
activities, paragraph'4.a; the documented Overview Quality Team (0QT) program
is'not' definitive, paragraph 4.a; ERC audit status and action logs not
-maintained current, paragraph 4.b; five examples of errors made in the overview
inspection function,: paragraph 4.c; failure of CPRT to identify all, authorized '
spliced cables, paragraph 5.a; spare conductors were inappropriately included in
' reinspection sample, paragraph 5.c; no criteria for valve disassembly / reassembly
for five months in 1983, paragraph 5.1) were identified.
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't DETAILS
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1; Persons-Contacted-
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***J. W.'.Audas, Licensing Engineer, Texas Utilities Generating Company,
. (TUGCo)
E. Bajada.-QA' Director, Evaluation Research Corporation (ERC)
*L. B. Barker,-Executive Assistant, TUGCo-
***J.-W.l Beck, Vice President,.TUGCo
***R.'S.-Berk. Licensing Engineer, TUGCo
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*C; T. Brandt, Quality Engineering (QE) Supervisor, (Ebasco)
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., JJ.; Burgess', As-built Verification Supervisor, TUGCo Nuclea'r Engineering
-(TNE) ,
*R. E. Camp, Assistant Project General llanager, Unit 1 (Impell' Corp.)'
, *W. G. Counsil, Executive _Vice President, TUGCo
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S. M. Franks, CPRT Projects (Impell Corp.)
, *P._ E. _Halstead, Site Ouality Control (QC) Manager, TUGCo
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4 F. R. Hodges, Lead Auditor, ERC e ~
.B. Holmes,.QC Electrical Supervisor, TUGCo -
M. Keathley. Lead Electrical QC Inspector, ERC -
**0. Lowe, TNE
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J. Mallanda, CPRT Electrical Review Team Leader
J. Martin, Calibration . Lab Supervisor, Brown & Root s(B&R) < .
**J. T.~ Merritt, Jr. . Assistant Project General Manager,'TUGCo'
C. K. Moehlman, Project Mechanical Engineer, TUGCo
*L.-D. Nace, Vice President, Engineering and Construction, TUGCo
A.- A.1Patterson, Reinspection Engineering Supervisor, ERC
***L. M. Popplewell, Unit 2 Safeguards Building Manager, TUGCo
**P. Reilly, Engineer, TNE
J. E. Rushwick, CPRT Test Programs Review Team Leader
***A. B. Scott, Vice President, Nuclear Operations, TUGCo
B. Shair, Lead Electrical Engineer, ERC
M. Shealy, Lead Mechanical QC Inspector, ERC
R. Sievers, Mechanical Inspection Supervisor, B&R
R. Spangler, Assistant-QA Manager, TUGCo
P. Stevens, Electrical Engineer, TUGCo
*J. F.' Streeter, Director Quality Assurance (QA), TUGCo
*T. G. Tyler, CPRT Program Director, TUGCo
W. I. Vogelsang, Electrical Coordinator, TUGCo
C. H. Welch, QC Services Supervisor, TUGCo
J. R. Wells, CPRT Overv sew Quality Team
**D. R. Woodlan, Licensing Supervisor, TUGCo
'R. Zill, Onsite QA Representative, ERC
* Denotes those persons who attended both exit interviews.
** Denotes those persons who attended the May 8, 1986, exit interview only.
*** Denotes those persons who attended the June 3, 1986, exit interview only.
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iThe NRC inspectors also contacted other'CPRT and applicant employees-during
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this inspection. period.
[" (2. 2 ApplicantActionsonPreviousNCInspectionFindings
[,".+ fa. V (Closed) Unresolved Item (445/8601-U-21): This item dealt with a
v a #, seismic arrestor bracket being welded over raised cast identification
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letters on an the actuator barrel-assembly, resulting in a weld which
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.c iexhibited incomplete fusion and overall poor workmanship.
During the review of.this item, it was identified that TUGCo, by
w~ , letter to the NRC dated April 21, 1983, had reported this condition
. - N- under 10 CFR Part 50.55(e) and had committed to immediately
n discarding and replacing the arrestor brackets. The failure to
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implement the committed corrective actions.is a deviation
(445/8607-D-01).
. - -b. (Closed) Open' Item-(445/8516-0-11): In November.1985, the NRC
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inspector attempted to review documentation related to commitments in
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-ISAP III.d. Sections 4.1.1.3 and 4.1.1.4 of the ISAP committed the
CPRT to review the CPSES document' control program and to interview
system test engineers (STEs) to-help assess the adequacy of existing
procedures and methods of obtaini_ng current design information for
test procedure updates. There were only a few handwritten notes with
no results indicated. The CPRT indicated that the final results
report for ISAP III.d would address these items. The results report
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m was published on March 13, 1986. In Section 5.2.2 and 5.2.4 of the
, results~ report, the CPRT reported having' reviewed the history of the
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Startup Document Control Center (DCC) satellite and the evolution of
the methods.by which the Startup and DCC organizations attempted to
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, provide convenient STE access to current design documents. The
results of thiscreview, as indicated in the results report, revealed
that. prior to April.1983, the control and distribution of design
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; documents-was centralized in the main DCC facility. The STEs found
, the task of obtaining current design.information time consuming, L-
burdensome, and the DCC was> unresponsive to their specific needs. In
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. April 1983, the first satellite of the DCC was established in the
Startup facility. .After about a year, a review was conducted to
- evaluate the control of design information. The review found that
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the system was working; however, it was cumbersome and continued to
, be a burden on the STEs. In April 1984, satellite libraries
it maintained by the DCC were established for various key Startup office
areas. . The'CPRT concluded from (1) their review of the evolution of
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the document control program, and (2) the results of the ISAP random
. . sampling and evaluation, that STEs, after April 1984, were no longer ,
working with a burdensome system and could obtain current design
- information in a timely' manner.~ With regard to STE interviews,
Section 5.2.3 of the results report documented the fact that eight
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1 2 5 0 7 2 % , "STEs 6representingiarious systems 11n the plant, were'. interviewed to
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2% requirements;to useTcurrent' design.dacuments and'to further assess y
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Lthe need 'to upgrade' existing procedures and. methods. . After-
m interviewing 18;of;the;approximatelyz60<STEs. the'CPRT concluded that ~
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t document? review; offered more'usefulfinformation than STE-interviews
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frelativ'e'to^the! issues;beingl addressed.iprincipally o_n the basis'of-
- Nthe unifomity of-interview: responses, and thus discontinued the.
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Linterviews.%The- NRC;inspectorzconducted similar interviews with a
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M fewlSTEsrselected from di. verse. disciplines', and came to a similar:
, conclusion.?Thoseinterviews?weredocumented11nSSER-7,PagesJ-94
ge(c m - T "andi95.s This.. item ~1snclos'ed..
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41nspectorfidentified a concern that STEs were not fully updating the
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, , -l referenced drawing. section of preoperational itests (pts). - The '
3 applicant cossiitted to make administrative. procedure changes which
MN * (would implement. tighter controls.in,this area, because the existing
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f y* ' , . gg ^; controls di.d not providelspecific-instructions on how to document PT
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G< . = procedureiupdates. ; CP.-SAP-7, "Formatzand ' Content of Test
5 L 7 ^ " Instructions / Procedures," was revised andLissued on July 8, 1985.
mgp, 4The new. revision requires :aispecific: prerequisite s.tep to be placed
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. , . jiniall pts for th'e STE to update" test procedure drawings, and then
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+c, the STE must. sign the step off priorito commencing the test.
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y g i(Closed)0 pen 11 tem (445/8518-0-08): . This item was initiated for the
t c'e;,, . purpose of tracking the~_ issuance of a final results report for
:ISAP III.d.,iThe report was issued on March 13, 1986. This item is
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closed.
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. "y' - d e.1 '(Open)f0penItems.(445/8516-0-53and443/8516-0-54): During
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review of.these items pertaining to discrepant weld conditions that
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Dexist on Boric' Acid Storage Tanks, CPS-CSATBA-01 and -02, the NRC
m i,_ ' inspector identified:that TNE provided base material inspection
* acceptance criteria to ERC on a-Technical Information Request (TIR)
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' dated September 25.-1985. The TIR response states,."The maximum ~
e allowable for a material defect for above tanks shall be 1/16" (one f
- > isixteenth of an -inch)."' Discussion with TNE personnel revealed that
,the' basis for base' material inspection acceptance criteria were
' calculations; performed using data obtained from the. original design
.c s s e documentation.' However,'as of May 15, 1986,.the supporting
y ' calculations had not been formally completed and reviewed. The
m^ failure to implement design control measures with. respect to the
w ' delineation of acceptance criteria is a . violation (445/8607-V-02).
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,f. -(Closed)OpenItem(445/8514-0-12): The comparison of ERC's document
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review results,'for Verification Package R-E-EEIN-001 with the NRC's
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-results was completed during this report period with no differences '
L identified. This item is closed. f- <
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L(Closed)T0pEnItem-(445/8516-0-31): The comparison of ERC's document
x 93 ' review results for Verification Package R-E-ININ-016 with the NRC's
N ~. :results was-completed during this report period with no differences
identified. JThis item-is closed.
Lh. (Closed) Open Item (445/8516-0-32): The comparison of ERC's document
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review'results for~ Verification Package R-E-ININ-072'with the NRC's
results was comp 1eted during this report period with no differences
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~ identified._=This item is closed.
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11. . '(Closed) 0 pen Item (445/8516-0-33): .The comparison of ERC's document
R 1 review results for Verification. Package R-E-ININ-079 (for pressure
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-transmitter IPT-4520).with the NRC's was completed during this report
iperiod. The ERC inspector had failed to identify an inspector who
+ -was not certified when he' signed an-Instrumentation Tubing
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. Manufacturing Record Sheet. This item is a deviation
'(445/8607-D-03).
n "N ' fj. '(Closed) Unresolved Item (446/8505-05): This item dealt with the
. unavailability of a site prepared installation drawing and
specification with respect to reactor pressure vessel (RPV)
+: placement.
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The'NRC inspector performed a review of documentation associated with
installation of the Unit'2 RPV. The governing rocedure for
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installation was Brown & Root Procedure MCP-1, p' Installation of
' Mechanical Equipment." Paragraph 4.1.1 in MCP-1 requires that
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equipment installation travelers be prepared in accordance with site
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Procedure CP-CPM 6.3, " Preparation, Approval, and Control of
Operation Travelers." ' Operation traveler ME79-248-5500, Revision 0,
was issued which described the field instructions for installation of
the Uni.t 2 RPV. The operation traveler incorporated the requirements
recommended by Westinghouse Nuclear Services Division (WNSD)
. procedures for this activity;'i.e., " Procedure for Setting of Major
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NSSS Components," Revision 2, dated February 13, 1979, and " General
Reactor Vessel Setting Procedure," Revision 2, dated August 30, 1974.
1 These WNSD procedures were not made a part of the traveler package,
in that they are generic and have been used by WNSD at several sites.
.However, the specific guidelines were utilized during the traveler
preparation. All of the necessary installation steps were reviewed
and approved by site QA/QC personnel and by a site WNSD
representative.
While there was no site specific installation procedure, an operation
- traveler was prepared, reviewed, approved, and issued; thus it became
the controlling document.
k. (Closed) Unresolved Item (446/8505-06): This item dealt with no
documented engineering evaluation onsite justifying the final
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tolerances-'of Unit 2 RPV clearances between support brackets and
support = shoes. This item was considered unresolved pending receipt
of documentation validating the final installation tolerances.
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The original tolerances specified on operation traveler ME79-248-5500,
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. Revision 0, were extracted from the WNSD generic procedures. The
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' operation traveler's installation tolerances were subsequently revised
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cto reflect site specific field conditions. Westinghouse concurrence
. with the revised tolerances was documented by signature on the
operation traveler. In addition, . Westinghouse Water Reactors Division
provided the basis for the Unit 2 RPV shin installation tolerances in
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' letter WPT-8148 dated January 10, 1986, which was in response to
'TUGCo's letter CPPA-48113. As a result of the receipt of documentation
-validating the final installation tolerances. This item is resolved.
Concurrent with the evaluation of this unresolved item, the NRC
inspector reviewed documentation for shims installed between the
Unit.1, Loop 2,. reactor coolant crossover leg and crossover leg
restraints.
' Construction operation traveler ME84-4715-5500 references Design
Change Authorization (DCA) 21,116,' Revision 0. This DCA addresses a
. problem with respect to clearance between interior shims and
; crossover piping that occurred during hot functional test. The
solution required the addition of shim stock as necessary to maintain
zero clearance. The listed supporting documentation shows the
acceptance criteria to be a letter from Westinghouse dated April 26,
1984.
Review of the Westinghouse letter revealed that it does not address
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the stated problem in the DCA. Paragraph 2.4.1 in Revision 6 of TNE
Procedure TNE-DC-8-1, " Design Verification of Field Design Changes,"
states, in'part, "If the field design change, had been transmitted to
Gibbs & Hill and Gibbs & Hill has stated that it is not within their
scope of work, then the field design change shall be design verified
as per-this instruction. "If design verification can only be
performed by the vendor . . . , the Verifier shall transmit the
change to the vendor requesting the specific vendor action required.
Resultant documentation from the vendor shall be included as a part
of the design verification documentation prepared by the verifier."
The DCA was submitted to Gibbs & Hill (G&H) for review and approval.
. Subsequently, G&H responded on change verification checklist dated
September 28, 1984, for the above DCA, "G&H documents are not
affected. Vendor review is required." It was determined that the
DCA was not routed to the vendor (Westinghouse) for review and
approval. While the required vendor review and approval was not
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performed, the DCA was implemented by traveler ME84-4715-5500. In
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,7 addition, the trave.ler documented the need to^ shim two locatio'ns
. . fonly. However, observation of,the actu'al assembly revealed that all
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:nine-locations were shimmed..
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_ and approvalsof changes is a violation (445/8607-V-04).
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l 3.L Assessment o'f Allegations
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AQ-159 and AQ-162~(4-85-A-31): ~ Poor Communication Between QA and QC
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, It was alleged that'there;were very few interfaces and little
. communication between the site' surveillance group, the Dallas-QA
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. audit group, and the operations audit group, even though their
'. 'functionsiare basically the same and such interfaces and
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communicationsLwould increase the effectiveness of each of the
_igroups.
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Thsfallegation' lacked any specifics or consequences resulting from
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. alleger's subjective perception of conditions arising from contacts
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Ewith Dallas audit personnel, operations audit personnel, and QA/QC
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; management. -The NRC assessment of.this allegation is based
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~, principally on an evaluation of NRC assessment of other allegations
Land recent inspections in the operations QA, Dallas QA, and
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surveillancelareas. The following are items noted during these
: previous assessments and inspections that are related to this
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allegation.
E During NRC assessment of allegations in the operations QA area, it
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(was noted that the operations QA program is structured in a similar
. manner to other operations QA programs; however, with the CPRT and
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other similar efforts causing numerous modifications to equipment
within the scope of operations responsibility, this QA program is
being forced into' functions and programmatic areas for which the
programLwas not structured to operate in an efficient manner. As a
result, these equipment modifications are being made by the site
, construction force, and in most cases the inspection function is
performed by the construction QC inspection group (both groups
functioning according to the construction QA program), while overview
~is being provided by the operations QA group functioning to a
-different QA program. Even though both the construction and
operations QA programs may be in compliance with regulatory
requirements, there is no assurance that these programs are
compatible and they, of course, are not interchangeable. One example
of incompatibility is the difference in construction's and
operation's treatment and processing of NCRs that was identified in
NRC Inspection Report 50-445/86-01; 50-446/86-01.
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During an inspection of the Dallas-based QA group, it was found that
the internal audit group is the principal interface with the
personnel on-site. Essentially 100 percent of the internal audit
group's efforts consists of audits of onsite activities; however,
under the most ambitious conditions of planning and scheduling these
personnel would be on-site 40 percent of their time. Thus, their
accessibility to site personnel for discussion / interface is limited,
and even then under conditions that exist during the conduct of their
audits. As further noted in NRC Inspection Report 50-445/86-03;
50-446/86-02, the interface between the internal audit group and the
site surveillance group is limited to an informal review of the
surveillance group's monthly report even though this surveillance
group is the one onsite group whose responsibility it is to assess
the effectiveness of the implemented site construction QA program.
NRC Inspection Report 50-445/86-03; 50-446/86-02 provides the results
of thc NRC inspection of the onsite surveillance group. Of note
during that inspection was the absence of any required interface of
the surveillance group with the Dallas QA personnel. Except for a 3
monthly report by the surveillance group to the site QC manager, to
whom this group reports, no other sunmary of surveillance ~ findings
are documented. The QC manager and others in his organization
evaluate these monthly reports and generate trend reports and
initiate corrective action activities, again without formal input
- from the Dallas QA group.
Considering these observations and findings of conditions during
1985-1986, this NRC assessment tends to substantiate the allegation.
Since this allegation was of conditions and an organization that
existed during the 1984 time period, the conditions alleged to~ exist
appear to be plausible and potentially accurate. While a major
change in organization and personnel in mid-1985 did improve these
conditions, interface and communication between these groups is still
lacking, which is consistent with the allegation.
During discussions with QA management concerning these observations
and findings, it was identified that additional changes in the
program and organization have been or are being made which recognize
these weaknesses. On April 29, 1986, the President of TUGCo approved
a major restructuring and reorganization of the TUGCo QA/QC function
that is to be implemented in three phases.
Phase 1 to be implemented by July 1, 1986, includes the following.
(1) Operations QA would report to the Director of Quality Assurance;
this will place all CPSES QA/QC functions in one organization.
(2) The Manager of QA and the Dallas QE staff will L; moved from
Dallas to the site, while the Assistant Manager of QA will
provide continued supervision for the QA staff remaining in
Dallas.
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^. ;(3) 'The si% surveillance group. will begin reporting to the Manager
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" of QA instead-of the Manager of.QC.
<: $ , ' iTh'eLtime prior to July 1, 1986, will be used to relocate. personnel
..
u,
; .and_ revise the: procedures.necessary to accommodate these changes.
, -
,
'
4 Phase 2 will begin July 1,=1986, and be completed by September 1,
r 1987. ;This phase, when fully implemented, will place all QA/QC
p.' , x . personnel and functions on-site and in one organization; i.e., those-
, s
~
-QA personnel not relocated to the site in Phase 1, principally the-
#' <
l internal and externa 1' audits groups, will be moved on-site.
#
' 'e Phase 3 will be implemented at the time of Unit 2 fuel loading and
,
'
will represent the final organizational structure. This structure
,
"
-will. focus on the major QA/QC program areas of development,
< implementation, and compliance. ,
n
r
.
.
'
In summary, conditions that existed in 1984 and to a lesser degree in
1985 tend to substantiate this allegation. -Organization and program
m changes made in 1985 improved these conditions, but changes proposed
-
*
'
for.1986 and 1987 have the elements necessary to resolve conditions
;allegedtohaveexisted.
.
No violations or deviations'were identified during this assessment.
} , b. AQ-139 and AQ-140 (4-85-A-14): Improper Revision of Audit Reports
It was alleged that audit reports were changed to reflect what
management wanted the report to state. Reports identified were
r *
TCP-66 and TCP-76.
The subject of audit findings being rewritten by supervision to
'
change the intent of audit findings was previously assessed by the
NRC. This assessment is documented in NUREG-0797, Supplement 11 in
Appendix 0 beginning on page 0-233. The NRC reviewed 23 TUGCo QA
audits for changes to auditor findings. The purpose of the review
was to determine if initial findings were revised to the extent that
the intent or significance of the finding was no longer the same.
Included in that review was TCP-66. The NRC assessment concluded
,
that audit reports were changed by supervision / management, but the
changes'made were not inappropriate.
.
Since TCP-76 was not included in the previous NRC assessment, it was
reviewed for substantive changes that may have been made by other
than the auditor. Two such changes were identified. The first was
c the deletion of a " comment" concerning a skewed weld. The second
- change was a downgrading of a " deficiency" to a " concern" reprding
..
calibration of a protractor.
No documents or notes were found in the TCP-76 audit file to explain
. the deletion of the skewed weld " comment." The NRC inspector
- -
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-
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e :
N , ~ contacted the Assistant TUGCo QA manager who was a member of the !
'A <
1special review team'that performed the 1983 investigation of TCP-66 '
, . and TCP-76 for TUGCo. This individual stated that their
, investigation had found that this " comment" was deleted by the
-
' auditor after discussions with two QC welding inspectors. On
m ' April 16, 1986, the NRC inspector was able to contact the former
TUGCo auditor by telephone who confirmed the information described
-
P
,
..m '
Labove~and indicated that he was satisfied with its disposition. '
: ,
The revision to the audit finding concerning calibration of
-
protractors was made by QA management which included discussioas with
+ the responsible auditor. The NRC inspector agrees with the be. sis for
the change (i.e..' protractors are instruments not subject to periodic
<
rz calibrat on) and also agrees with the finding as revised. Notes in
the audit file also provided evidence that the auditor was aware of ;
the change and did not disagree with the revision. ;
Based on the documents reviewed and the personnel interviewed, the
NRC inspector found no additional information that would alter the
NRC. conclusion documented in Supplement 11 as stated above.
'
:c. ~4-86-A-031: Alleged Iaproper Electrical Cable Installation
A concern was raised that the electrical cable associated with a
<
. power operated valve had been improperly installed. The valve in
question (2-LV-2478) is a 3-inch, air operated level control valve
which is located in the discharge piping from the Condensate Transfer
> Pump. The' valve is the Domineralized and Reactor Makeup Water System -
, fill control valve'and,is controlled by the Condensate Storage Tank
level transmitter. The expressed concern consisted of two parts:
(1) The flexible conduit for two cables could be pushed into contact
lwith each other, and (2) the outer jacket of one of the cables had
been' stripped bcck, out of sight, into the conduit connected to the
limit switch.
An NRC inspection of the valve installation verified that the
.
flexible conduits connected to the valve limit switches could be
. pushed into contact; however, the conduits (and the enclosed
electrical wiring) are all of the same electrical separation train,
, =and, therefore, no separation needs to be maintained. The limit
switch installation in question was observed to be a closed
(completed) assembly. The NRC inspector did not request that this
assembly be opened for visual inspection based on the review of
, applicable requirements related to cable jacket removal. TUGCo
Quality Procedure QI-QP-11.3-28, TUGCo Installation Procedure EEI-8,
and G&H Electrical Erection Specification ES-100 were all found to
,
contain requirements on the process to be used to strip back the
'
outer jacket, but no requirement on the maximum acceptable length of
the stripping process. Since the electrical cable is en;10 sed in
conduit and the outer jacket is for protection of the conductors
,
during installation of the cable, the removal of the outer jacket
! i
_ _ _ _ _ - - - _ _ - _ - _ _ - _ - _ _ _ -
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m * - back into 'the conduit is not significant from either'an electrical or
i % ' safety' standpoint. _ Accordingly, the allegation of improper
; jelectrical cable installation was not substantiated. '
" -
4. CPRTQAProidam *
- :' ta. 00T Program Establishment and Implementation
[~
'
- '
,
The purpose.of this inspection was to determine *if the 0QT'as-
established was being implemented. In reviewing requirements-
'
"
^
governing the 0QT, the CPRT Program Plan was essentially silent
concerning the 0QT except for Appendix G, Figure-2, an information
flow diagram. No definitive requirements for the.0QT could be found
'
- in any CPRT documents (i.e., Procedures, Guidelines, or Policy
statements). However, in an August 15, 1985,. letter to the NRC,
x .TUGCo described the establishment of the.0QT as a quasi audit
1, ; function. Its purpose was to provide additional assurance to TUGCo's
' '
, ,
'
unagement that the CPRT has achieved CPRT objectives and properly
, responded to and resolved the open items identified. Currently the
-
only document that describes the 0QT" activities is the OQT Program
dated February 20, 1986.
'
~
In a February 28, 1986, letter to the NRC,-TUGCo redefined the
" '
'
description of the'0QT. The scope of the 0QT was limited to
surveillance:of the QA/QC (ERC) and Design Adequacy (TERA) quality
. assurance programs. In lieu of formal 0QT auditing of CPRT
activities, surveillances would be accomplished by reviewing the ERC
.
'
and TERA audit reports and their followup of corrective action
resolution. . Traditional audits by 0QT would be conducted only when
'
di.rected by the SRT.
r Various versions of the 0QT Program were reviewed by the NRC and
' compared to issued 0QT reports and supporting documentation to
-
evaluate the implementation of the 0QT program.
(1) -00T Program
. The current 0QT-Program is described in an uncontrolled document
-
not approved by the SRT. It delineates the 0QT's: charter;
objectivities; general description of methods for performing
activities; and structure for reporting audit and surveillance
results. -Since September 1985, the program has been revised and
reissued approximately five times.
'
,
. (a) Changes to the 00T Program. Originally, the 0QT reported to
the Executive Vice President of Nuclear Engineering and
'
Operations. In November 1985, this was changed to the 0QT
I
reporting to the SRT with their reports going concurrently
to the SRT and the Executive Vice President,
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e,n - -In10ctober 1985,LthelscopeLof-the 0QT review activities was
;gg, . J 4% changed:tooinclude only the.ERC and TERA quality prograns,.
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thus1 eliminating the review of electrical and testing
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'
a cactivities. Other changes included the deletion of the
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'
Tword "shall'.': and . replacing it1with words , such as "may be";
,
4
' ; thus :providing nonmandatory guidelines as opposed to
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4 . establishing requirements; :. Activities relegated to
r-; '
,
'nonmandatory,were- direct observation of work 'in progress; l
g.. , -for example,;rather than performing these activities
-
* : routinely,they will-be performed only when QA activities
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:are in question orLwhen directed by the SRT. Taken
m.,
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'
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collectively, these shortcomings represent a deviation in
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- '
ithat the_SRT is not fully util.izing-one-of the elements
2 available to them for assuring the quality of the CPRT
ZN:
- ,-
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Jeffort:(445/8607-D-05).
,
+ :Other examples of weaknesses that currently exist in the !
r0QT Program description include:
'
;,- f
'
.
,
a ^
1)- Section 3, " Typical Checklist Approach," states that
,
most evaluations by the 0QT will be performed using a ,
n , checklist; however, no criteria exists to identify
.c ,
when a checklist'is required.
" '
2) Section 5, " Reports," does not have clear enforcement
, * ,
-
provisions for findings, observations and open items.
+
y .
. Further,Lno definition exists to correlate the
,. significance of findings (i.e., observations and open
items)'to'the required corrective actions.
' '
'
? ,
Section'4, Task Definition and Assignment", describes
'
- -
3)' -
'
'the OQT review of QA personnel qualifications, QA
-
procedures, and QA work products; however, no
commitment is made to actually perform in process
, audits'(inspections) to verify effective procedural
implementation.
It is not evident nor is there a requirement in the
~
.
4)
., A 0QT program for systematic planning and scheduling of
their activities that is correlated with CPRT
activities. For example, Section 5.3, " Final Report,"
states that~ the final report shall include a matrix
E showing the identification of each QA activity that
b was reviewed and evaluated by the 0QT for compliance
"d '
'
to specific requirements, but no trention is given of a
&, matrix of quality elements to be audited that would
'
O- assure the entire CPRT QA program was evaluated for
implementation.
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4 7
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, ;
.(2) Implementation of- the 0QT Program
In comparing published 0QT reports to the 0QT program for
,
compliance, the following were noted:
'
-
(a)' Sections.2.4 and'2.5 requir'e additional audits or
'l inspections be performed by direct observation of work in
progress when QA activities are in question.
'
.
In January 1986, a stop work order was issued by the SRT to.
a ,
.
ERC for the questionable performance of CPRT reinspections.
'.
The 0QT did not perform any direct observations, audits, or
inspections as required by Sections'2.4 and 2.5 when these
reinspections were identified as. questionable.
' (b) :Section 3 states.that most evaluatione will be. performed
,
,
using checklists which are to be attached to the 0QT
reports.
Of the.six 0QT reports reviewed, two were accomplished
*
' using checklists. A checklist was attached to only one of
the reports.
(c) Section'3 requires followup on the resolution of findings
and open items identified in 0QT reports.
A finding that inspectors had been certified to perform
-
inspections prior to verification of their experience,
training, and education was reported to the SRT on
October.23, 1985; however, as of April 30, 1986, the SRT
has not commented on the acceptability of the corrective
action taken nor has the OQT conducted a followup
inspection of these certification activities.
In summary, the present 0QT program appears lacking in the following
areas: (1) no definitive procedure describing the responsibilities
and authority of the OQT and similar functions; (2) no clear review
and audit responsibility pertaining to CPRT activities, particularly
- those relating to the resolution of those CPRT ISAPs not primarily
-directed.to the construction (ERC) and design (TERA) review team
leaders; (3) no procedural controls for the SRT concerning timely
followup and resolution of identified deficiencies; and (4) no master
schedule of activities related to 0QT reviews and audits that
correlates to CPRT schedules and status.
The' conditions described above have been identified as a deviation
(445/8607-D-06).
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_ .$ . ItL.was noted during this' inspection that the ERC site QA manual was
M ' S not being maintained current. . Controlled copies of this manual had
~'
Jk incorsetrevisionoftwoprocedures. This lack of proper manual'
control-is a deviation (445/8607-D-07).- -
, M,MW y NMyv % .:s .
!
.@ 3 $ / @ !bh ERC Corporate Audit of the Onsite QA/QC Program
,. J, & . ..
, :
Mi
'/ tfW$ .The QA/QC review team's quality program is monitored by ERC using two
methods;;(1) the performance of surveillances'and overview
inspections by onsite representatives of ERC's Manager of Quality,.
and.(2)' periodic; programmatic. audits of the quality program. ,
During:this inspection, the.NRC evaluated the conduct of programmatic
y audits.as governed.by ERC: Procedures ERC-QA-18, Revision 0,
~
'
. ."Adefnistration of Quality Assurance Auditing," and ERC-QA-20,
l Revision' 0, " Conduct' of Programmatic Audits." The five published
<
' audit. reports.and supporting documentation were co.npared to the
- require:nents of the governing procedures to assess the adequacy and .
11mplementation of the audit program. The areas of the audit program '
~
inspected included; scheduling, planning,- personnel, performance,
7 m1 @- -
: reporting,fresponse and follow-up, audit closure, and records.
.
'
-a W. : ,
.' " (,, (1)) Audit Schedules
'
mg * Procedure ERC-QA-18, Revision 0, requires both long'-range
, V (annual) and, quarterly schedules for conducting audits to be
% ' ~
4
~
-
prepared, approved, and issued prior to the beginning of the
year:or quarter covered by the schedule. The 1986 annual and
_
,
first quarter (January through March) schedules were issued :
* ,
January 13, 1986. The issue date of the second quarter (April
through June) schedule was May 20, 1986. Even though the audit
! schedules were issued after the beginning of the respective
,
quarter,'this had-no significance since audits were not
4
,
conducted prior to,the publication of audit schedules. These
schedules were found to be consistant with procedural
requirements for documenting scope of audit, identification of
product oc-system, date of audit, team leader and auditors, and
'
,
applicable remarks.
,
(2) Plannino and Preparation
Procedure ERC-QA-20, Revision 0, requires preparation of a
detailed plan, checklist, or questions and notification to the
organization involved in the audit be accomplished prior to
conducting the audit. E:ch reviewed audit file contained a '
comprehensive plan, checklist, and documentation of advance
notification to the auditee. These documents were found to have
been prepared, reviewed and distributed in accordance with
procedural requirements.
,
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[ , ,. l(3). Personnel-
-
(a) Qualification / Certification: Audit personnel qualification
.and certification files were reviewed and compared against
,
'" - itheLrequirements of: ERC-QA-23, Revision 0, " Personnel
, certification." Auditor files' contained: CPRT objectivity
~
.
-
: questionnaire, education / experience verification summary, .
,
current: qualification / certification data, certifying exam '
with results,-required reading,-training records, past
qualification / certification records, and applicable reading .
p assignments. Their; qualifications were verified to assure '
'
,
'the technical specialists had experience and training'
~
*
F' Y commensurate with the scope, complexity, or special nature
'
*
_'of the to activities being audited. The auditor files were ,
- , .found be in conformance with the requirements of
'
-'-
,,
,
.
ERC-QA-23.
T
'
- (b).: Audit Team Selection: .When teams were used to perform an
'
'--
-
audit, members were independent of the activities being
. .
' audited.. Team leader, auditors,.and technical specialists '
+-
G ~! y were. qualified and certified in accordance with ERC-QA-23.
(4) Performance
~
The NRC, inspected the following elements, relating to audit
.
. performance,.by comparing five published audit reports to the
-
. ' . procedural requirements: >
aa "
,
+
> ' (a) -Preaudit Conference: Preaudit conferences were conducted
in accordance with ERC-QA-20 and documented in each audit
repart. . Subjects covered were audit scope and plan,
-
'
: establishing. lines of communication, access.to
~^
-
organizational areas and personnel, and schedule for the
,
>
postaudit conference.
" '
,
_
(b)' Conduct of Audit': Audits were conducted using audit plans ;
i _ and checklists. ' Objective evidence was examined by the
f, auditors to verify compliance and implementation of
..
' '
,
,
' prescribed requirements and'any deficiencies were
documented.
-
- _
' (c) Postaudit' Conference: At the conclusion of the audit, a
'
postaudit conference was held as required by procedure. An
'
-
-
overall' summary of the audit findings as well as each
individual finding was presented to the audited
'
'
organization. - Clarifications were made where e.ppropriate
'
to prevent any misunderstandings. A request for immediate ,
initiation of corrective action was made where deemed
"
necessary.
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,/ 1(5) . Reportina.
'
,
After the completion.of each audit,'a report was written to the-
~
a .QA/QC_ Review Team Leader to formally communicate audit findings.
, . ,
-
Major sections of the report include:: i
f ._(a) Audit scope. ,
[;m . ^
_ f(b) Personnel - identification of audit' team and persons
contacted during pre and'postaudit activities.
'
-
l .
>
(c) Preaudit conference.- summary statement of audit.
m
, .( d). Finding',s
., '
. .
f & 1): Summary of results - highlight of positive and
-lW ' ~
-
negative findings.
J54 _
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2) Details of findings - findings of conformance and
' deviations; deviations were'also reported on Audit
' x y" ,
.
,- - Action' Requests-(AARs) as an attachaaent to the audit
report (AARs'are used to resolve and track required
,, %, s
~
,'- corrective action items).
-
~
,
_
(e) :Postaudit conference'- summary statement of-audit results.
'
:Y* "
^ -(6)' Response and Followup
., .
.For each AAR,'ERC's management scheduled corrective action and
-
, measures to prevent recurrence, then notified the lead auditor
. in writing'of actions taken or planned. The audit' team
'
<
. evaluated each AAR response of proposed or completed action and
either accepted or rejected with comment the actions planned or
.taken.,
'
Procedurally, follow-up action'.by the audit group included:
<
*
~(a) Maintenance of an Audit Status Log to reflect the current
status of each audit (for example; scheduled, report
issued, responses received, evaluated and approved, and
closure).
4
, (b) Maintenance of an AAR status log indicating the current
status of issued'AARs (open or closed).
'(c) Maintenance of a working file in which documentation
-
g supporting each aud.it was collected.
The maintenance of working files was found to be current;
,' however, the closed date entered on the Audit Status Log for
audit ERC 85-01 was missing. For audits ERC 86-01 and
-
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, .ERC'86-02, the AAR. log was not maintained. Log entries were not-
'made for findings from these audits. Even though these' logs.
'
- '
5 '
.were not.maintaiaed per procedure, the evaluation of. responses
'," '.g to findings, verification of corrective actions taken, and
'
lypropriate audit closures were performed.
The. failure to maintain the audit tracking and AAR legs in
'
-
'accordance with'ERC proceduresjis a deviation-(445/8607-D-08).
c'y'~~ f ?(7)l[ Addit'Closureand'Recordi
.
.e ,
,
#- Following the verification that each identified deviation was
~
corrected..the respective audit was closed and correspondence to
the QA/QC Review Team Leader documented the audit closure. The
Jstatus' logs and working files were updated to-reflect closure of
-
s
q.~~ .y 1the; audit, except as noted above. In reviewing the working
files;for completeness, the files were'found to be in accordance
- 'with the status of;the audit. Closed audit files contained
o Lrequired records. Open and inprocess audit files contained-
-
up-to-datefdocumentation.' Typical records found in the files
were:
' '
'
-
s Audit. schedule-
) '
9~
Notification of audit
. Original of audit plan and check sheets
.y ^-
, ;Preaudit conference
Draft summary and findings
Supporting material from the audit
- , , Audit report and transmittal of request for corrective
-
action
Audit responses
,
Postaudit conference
' Closure statement, disposition
~
, In summary, except as noted above, ERC's corporate QA audits
were planned, scheduled, and performed on a periodic basis to
<
. < evaluate the effectiveness of the QA/QC review team quality
< -
; program. The audits were performed in accordance with written
, . procedures and checklists by personnel who did not have direct
responsibility for activities being audited. Audit results were
documen9ed and reported to and reviewed by responsible
management. Follow-up actions were taken where indicated.
c. -Overview Inspections
,
The-review of the ERC overview inspection (01) activity by NRC
inspectors is based on ERC Quality Assurance Procedure ERC-QA-28,
Revision 2, " Performance of Overview Inspections." OIs are to be
performed on a selected sample of ISAP VII.b.3 and VII.c
reinspection / documentation review packages previously completed by
ERC Inspectors. The OIs duplicate the initial reinspections using
-
,
-
.
_.
M 6-
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.
20
y ,
,
;ERC Quality. Instructions (QIs).and essentially identical verification
,
m : packages (VPs). A comparison of the initial -reinspection with the OI
'
-
'
cis documented on an Overview Inspection ~ Report, which is completed
~
for _each . verification package that is. in the sample.
b NRC inspectors independently inspected the following eleven overview
-
. VPs during this report period:
s . 42-I-S-INSP-033
2-I-S-PS7N-011
'
: 38-I-S-PS7N-056
~
38-I-S-PS7N-060
.24-I-S-PS7N-146
~
:2-I-S-PS7N-163
,
.35-I-5-STEL-140
4-I-S-STEL-146-
- 35-I-S-STEL-164
35-I-S-STEL-197
k 13-I-M-LBCO-148.
~
D'e tails on the NRC review of the ERC initial reinspection for the
'above VPs are identified in the appropriate ISAP_VII.c section of
:this or previous NRC inspection reports.
The,ERC overview inspector and overview supervisor signed the
n Overview Inspection Report.as acceptable for all of the above
. packages, indicating agreement between the OI and the initial
reinspection.' Subsequent NRC inspections identified the following
conditions:
42-I-S-INSP-033: The NRC inspector identified a deviation in NRC
Inspection Report.50-445/85-16; 50-446/85-13 against this initial ERC
reinspection package in November 1985. Subsequent to the NRC
inspection'and prior to the OI, the ERC checklist was changed and a
deviation report (DR) was issued to reflect the NRC identified
-
condition. . When the overview inspector compared the VP with the
initial reinspection package, he found no unsatisfactory decisions on
the part of.the initial ERC inspector. The fact that the NRC had
identified some unsatisfactory decisions against the initial ERC
' inspector was not reflected in OI's VP. The impact of the overview
inspector not identifying these unsatisfactory decisions on the part
of the ERC inspector is not known at this time. This finding is an
, , unresolved item (445/8607-U-09).
13-I-M-LBCO-148: During an NRC inspection, three cases of pipe to
i pipe clearance in violation of Section 5.2.6.2 of QI-025, Revision 3
were identified. However, the initial ERC reinspection as well as
the OI failed to identify these three deviating conditions.
! Specifically, the lines which were in deviation of QI-025 were I- l- i Lm
.
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2-CC-1-61-152-3,I.l-CC-1-62-152-3; and 2-CC-1-60-152-3. <The failure
ofc.both,the initial:ERC and OI' inspectors to identify thes'e
'
'
k m dVl"'~ conditions:is a-~ deviation (445/8607-D-10);
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# 3 @x4 m . og f . . . ,.
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2-I-S-PS7N-011: 7A n'ERC DR'was: issued by the. initial ERC Inspector
cea ^ : for; unsatisfactory pipe' clamp ht alves parallelism. ' Attachment 6.1 of-
yg y:., ' ' 'QI-037. Revision 1, specifies acceptance criteria and states, in
~
,
part,:"S dimensions on'the same side of the elamp,at points 1,l2, and-
' A A* ,
'
f 3 shallgbe4within 1/16" ;of = each other '. ~. . .": Measurements are
, ; ~y% ( - < . recorded;for each side of-the clamp (S1 and S2);on Attachment 6.1 of- -
y% , ,
-
lthe.JP.-
T' '.
-
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. .f : t;> 1 Measurements = for Sl~ recorded by the initial 'ERC inspector show a
.y s , 6 difference'between points 1 and'2:of 5/32", between points 2 and 3 of .
9 y. T> M(1/8", and_between points?l1 and.3 of 1/.4". The overview inspector 1
; R.; $ trecorded measurements,which show: differences between the'above points
JL i , f of 3/32",1/16", and;1/16", respectively. TThe~ initial ERC .
,
M~, . ; reinspection and the overview inspection measurements both indicated
"
'S1 was out of tolerance; however,.the actual measurements showed up
@ - 'toia 1/4" discrepancy:between the two inspections. Similar
s ~ ." ': measurements 1taken during ;the initial .ERC reinspection. .showed S2 to
u s.
M' ' '; , -
. be out _of! tolerance bycthe- same amount identified for Sid The
~ ,
_ overview , reinspection identified -S2 as being within- tolerance. The-
[a
" '
"ERC DR-issued by the initial:ERC inspector concerns only measurements
lp_ " ifor 51 7The overview inspection failed.to identify and resolve these
, fM o 7 discrepancies.- ~
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.
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.
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sTh'eNRCEindependent; inspection showed that measurements for Si and S2 :
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.ff (were within the~ tolerance criteria and.no DR'was warranted.- A
Y subsequent' reinspection by, overview inspectors and th.e(NRC-inspector
'
J Jconcurred with the results of'the NRC independent inspection.. The ' '
" '
1 failure.of,the overview' inspector to identify and resolve;the' above
,' .
c f aeasurement discrepancies -is a deviation l(44,5/8607-D-11). -
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'E" , '38-I-S-PS7N-056:."The.NRC inspector observed that two cotter pins on
*
W :the clamp side of the ' strut were approximately one' half the diameter
m 'that the procedure specifies. A review of the ERC initial -
, W reinspection package and the overview inspection package indicated an
unsatisfactory condition for locking devices; however, no DRs'were
,
'
< U
.: ilisted or written for undersize cotter pins. The failure'of both the_
,
b *
11nitial'ERC and 01 inspectors to identify the presence of undersized
CY J ' cotter pins is a deviation (445/8607-D-12).
zw m 24-I-S-PS7N-146: 'The initial ERC inspector signed off as acceptable
< @p Attribute 3 on the reinspection package regarding spherical bearing
~
-
'g'ap. 'The required measurements were taken on spacer thickness and
G resultant' gap, with the results recorded on Attachment 6.2 of the
_
'
_ reinspection package. The overview inspector also measured the
< >
: spacers and resultant gap, accepted Attribute 3 on the reinspection
- checklist, recorded the results on Attachment 6.2 of the reinspection
,
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l package,Eand noted'no unsatisfactory decisions. The.NRC inspector-
-
.
'
.
'
.was unable to check _ the resultant ' gap and spacer thickness due to the
J1 : amount. of. paint found on the ' spherical -bearing.
<
"
-
Subsequent to discussions with'NRC, a-second OI was performed which
tagreed with-the initial ERC-reinspection. The NRC inspector ~
'
- '
(participated:in a third inspection with a group of overview
~
-
.:
'
sinspectors.and identified that a' quantity of paint had been' removed.
-
The overview ~ inspectors stated that they had removed-a small amount
s
'
of paint in-the course of. reinspection. The NRC! inspector confirmed
.; -some paint had been-. removed but with the' amount of paint remaining,
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~
an accurate measurement, as required by.the procedure, was still
unobtainable. . .The overview inspectors stated that an educated guess
e P .
lwas;made on theseLeeasurements due to the presence of paint. No out
3of scope observations were written by ERC. The absence of an-
'
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;'
'
accurate sphericalEbe'aring gap measurement is a deviation
'(445/8607-D-13).
J 4'-I-S-STEL-146: Gusset plate C10-17 was not installed as shown on
,
Design Drawings 2323-S-0799, Revision 1, and MAB-0799-0C8, sheet 1, ,
'
Revision 3. Connection orientation is delineated as Attribute B3 of
_QI-045, Revision 2. This attribute was accepted by both the original
, -F.RC inspector and the overview inspector. The gusset plate was,
6 *
however,1 incorrectly installed; i.e., installed at the base'of
'
-
member C9-4 instead of at the top. The failure of both the original
or ,
-
.ERC_ inspector.a,nd the overview inspector to identify this condition
i Tis'a deviation (445/8607-D-14).
.
15. .CPRT ISAPs (Excluding ISAP VII.c)
. 3 .
l a. Inspection Reports'on Butt Splices (ISAP I.a.2)
L'
The NRC inspector reviewed ERC menos, NCRs, TUGCo work orders, and
: performed inspections related to this ISAP.
.. Review Inspection Reports on Butt Splices (NRC Reference No. I.a.2.01)
-
As described in NRC Inspection Report (IR) 50-445/86-01;
50-446/86-01, the program proposed by the CPRT for butt splice
' '
inspection consisted of three parts, Phases I, II, and III. The
c -Phase I activity required a-CPRT review of the 12 butt spliced cables
that the NRC's Technical Review Team (TRT) had reviewed to determine
if' addition project inspections were required. Phase II inspection
+
: activities were to be initiated by ERC of splices in panels, if the
result of the Phase I activity determined that additional inspections
- were required. Phase III inspections were to be conducted by TUGCo
of all other essential circuits where the AMP insulated splices may
have been used.
'
,
The NRC inspector verified that the Phase I reviews had been
.,
completed and that, as a result of those reviews by the CPRT, that
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~ Phase ~II! inspections!had1been initiated. Therefore, the requ'irements
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? activity:isicomplete.11No fulfilled or
violations and NRC inspection
deviations were identified of this ' .,
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M;@ g Drawing and Design' Change Reviews'-(NRC Reference'No. 01.a.02.02)
.
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.
4 , . . .. . . .
.
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u ,Sectionl4.'1.2'ofLthis ISAP. required a~ review of 'all drawings and-
H- f' fdesign change docuaents involving butt-splices in safety-related
.,
_ "cablecfto assureithat the splices were documented. During NRC
M - . inspections!ofpanels1toverify:thestatusofbuttsplices,theLNRC' t
gg" :.t in_spector found that; cables A0102707..E0106963, E0106993 'E0111093,
.
6 ; << land E0111179. contained _ splices which were'not shown on the' drawings.-
, ;T < W H
~
~
^
Followupiinspections' for these splices showed they had been authorized
^ ; by DCA :17',762. Revision 2,~.and that irs exist which documented the
'
3
W . 4 splice) installations.'.None of these-' splices were,,however, identified
-
fduring;the:CPRTtreview of drawings and design change! documents. .The ~
c% y . failure of CPRTs to review all' design change documents and identify
1y e .all. authorized' spliced cables is a deviation (445/8607-D-15).
^ '
?- ~ 'In'spection~of.' Cables (NRC Reference No. 01.a.02.03)
<
. f. _
e , The ISAP/ required the initiation of Phase II inspections-for all.of
' ' ~
.
'
.
;the cables identified:in the CPRT documentation reviews discussed
' '
'above. NRC~ inspector review of thesCPRT; irs for 32. compartments
.
'
. located inL11 Motor Control-Centers (MCCs) showed, (1) no splice'
<; staggeringfdeficiencies:we'reidentified,(2).6ofthecompartments
- '
~ - cdid'not contain-the splices that were indicated on drawings, and
- ~> ' ' L(3)L11 compartments;were identified, each of which contained 1
, _
,
' ~ ; unsatis' factory splice. -Of these.it unsatisfactory splices, 4 were
4not shown on' drawings.. Thr_ee of these were removed for pullout s
C
ftestingandradiographicexamination. ~
i - . ,
:NRC Review 'of NCR Dispositions-
. a.
.
*
JA sample 116 NCRs', which were part of a total of 37 NCRs generated as
i *
'
la result of Phase'II inspections, were reviewed by the<NRC to assess
-
' .the final disposition of Phase.II inspection deficiencies.,~The NCRs "
reviewed were: ' >
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'
NCR No.: . STATUS CABINET No'.. -
~
'
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I E85-100059s Closed CP1-ECPRCR-03 ,
.E85-100068s Rev.1. Closed CP1-ECPRCR- 03 ,
i%*.'
E85-100115s. C1osed TBX-ESELSP-01
; E85-100054s - Closed TBX-ESELSP-01
m , 'E85-100117s.- Closed CP1-ECPRTC-04
< , 85-0061(OPS) Open CP1-ECPRTC-04.
.
- , E85-100118s Closed CP1-ECPRTC-17
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' E85-100122s-Rev.4 Closed - CP1-ECPRTC-42
x . E85-100119s Rev.1- C1osed CP1-ECPRTC-15
-
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:E85-100073s .
'
. Open - CP1-ECPRTC-16
~.
E85-100123s Rev.1 Closed CP1-ECPRCR-03.
: Closed
'
-
:E85-100075s. . . CP1-ECPRTC-26
4 :
E85-100121s.Rev.3' Closed: CP1-ECPRTC-41
~
E85-101231sx '_ Open CPX-ECPRTC-03
. E85-100034 Rev.3 Closed- CP1-ECPRCR-27
E85-100058s ' Closed CP1-ECPRCR-03
-
g~ Eight of the!NCRs identified seven conductors with damaged
, .. insulation, six of which have been repaired. Five NCRs identified 44
' :
conds. tors that had' installed butt splices that were.not authorized
*
by design. documents; the drawings for.38 of these conductors had been
updated and_ verified by QC. Three of the NCRs identifled 111
'
>
- conductors as not having the butt splices which were.shown on the
:-' idrawings; the drawings for_these. conductors have been updated by
-
'
- removing the-splices. Seven of the NCRs identified 42 splices that
,
'
have no inspection reports documenting that the installation was
' c~ ~
-
witnessed;^34,of these splices have been reinspected. Four of the
- NCRs identified 34 splices that were found unsatisfactory after
reinspection. 'Three NCRs identified splices for 15 spare conductors
. which were removed.
'
, NRC Inspections.
The NRC inspector performed an inspection of two conductors
2
'
, identified in the CPRT inspection reports as having the splices
'
removed and-then being reterminated without splices. These two
, conductors, EG109862(W) in Unit 1 termination cabinet CP1-ECPRTC-17
>
and E0106204(8) in Unit 2' termination cabinet CP2-ECPRTC-41, were
observed to be-terminated witheat obvious splices; however, the cable
',
bundles containing these conductors were not opened to determine the
>
existence of splices-inside the bundle.
.
NRC inspections were also performed in the following six cabinets,
which had been previously inspected by ERC in Phase II, and which
'
were known to contain butt splices:
CABINET NO. DRAWING NO. REVISION NO.
CP1-ECPRCR-03 2323-El-0155 CP-8
CP1-ECPRCR-04' 2323-El-0156 CP-7
. CP1-ECPRCR-13 2323-El-0158 CP-10
CP1-ECPRTC-16 2323-El-0172-16 CP-5
2323-El-0172-41
# '
CP1-ECPRTC-41 CP-4
CP1-ECPRCR-03 2323-El-0172-42 CP-3
The NRC inspector identified three splices in cabinet CP-ECPRCR-13
which were not shown on the appropriate drawing. These splices were
- ) , in cables E0111179 and E0106993 located in a cable bundle with other
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* ' Tplices ihich had[beenfinspectdd by.ERC. 'ERC_had' inspected-
W .ccable E0106993 and identified only- the white. conductor. as being
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spliced;;however. the black conductor of this cable was.also found to"
~,2be spliced by the.NRC inspector.' ~The ERC inspection procedure _did-
.
g, e 28p7 J gnot require;the opening of: cable bundles, but the~NRC inspection
~
- e s. e sincluded opening the'bundlese '
cd
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( ,1 EInladdit' ion'to the. above :ERC: inspections'. TUGCo' inspectors
' - ,
-
reinspected' cables;E0106993 and-E0111179 as required by CAR-050.
;
. <
o.- W . ~., t 2These inspections were also. performed without opening the cable
m- ; bundles, and TUGCo inspectors also failed to identify these splices.
s_, - "(TheiCAR-050 inspections-were performed to assess;a. previous TUGCo
, _
'
, _ '
! inspector's._ performance in the area of terminations 4and butt
m2 1 splicing.)'
p q ,_
^ ' - - I ?The NRC inspector'also ' identified' that 21tconductors;were terminated
^f '
sin' cabinet CP1 ECPRCR-13 that were not shown'on the drawing. Further-
.
'
' . J Lreview showed that these conductors were to1be removed under work..
'q ,
,
icontrolled by Packa'ge Process: Form'(PPF)-158. 'The drawingtwill.be n ,
; updated to; include these.conductorsjin'accordance:with* plant a
'
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a-
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' procedures. -
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' CablelE0111169"was identified'by .E,RC =as not meetingist'aggering .
-
-
. .. requirements and NCR E85-100124s was< written. . The NRC inspector -
1 verified by . inspection: that this ; deficiency had been corrected;asb < -
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'
~
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< documented in operation traveler EE85-11,462-8904 which;placed_ cable; ,
a
-
ijacketing material:between. adjacent splices to keep'them from '
,w ,A. -
: pressing against each other.
-
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.
,
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,
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'
,' 1 Based on th'eLabove NRC. inspector actions, Ahe=CPRT activities to s
4 ' '
.
-
. resolve this^ISAP requirement were'! determined--to be acceptable except- _
?R ' 'V for the-adequacy.of.the methods'.used to determine splice location and
7. . : staggering within cable bundles.- The adequacy of the inspection of
fe
~
' adjacent ~ splices will.be addressed under NRC Reference "
& s; ,No.J01.a.02.09. _The~ adequacy of the above ERC and TUGCo butc splice
v
'
- ; inspections is .ar unresolved item pending clarification from NRR as
ye ~ f
*
to the purpose _of these inspections (445/8607-U-16).
Since'theiCPRT required inspections were performed in accordance with
~
gj ;the:ISAP_ connitments, NRC inspection of this activity is complete.
y_ ; -
n
Ti -No M olations or. deviations were identified.
v ..
. . _
C ' Documentation Review of irs (NRC Reference No. 01.a.02.04)
~
Y '-
~
(TheISAPrequiredtheCPRT,asapartofthePhaseIIinspections,to
perform a. documentation review of spliced cable irs to ensure the
. 9 ,
. splices 'were inspected and reflected on the appropriate drawings. As
-
-
: stated above, the CPRT inspections were acceptably performed with the
.,L~ exception of_ the: deviation described under Reference No. 01.a.02.02. 'i In addition, the NRC_ inspector did not identify any splices which
_
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e
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were either not;already shown on the' appropriate drawing or where the
' drawing _was. not'~ properly revised as-a result of CPRT findings (see
,
,,'
"~ NRC Reference No. 01.a.02.05). Therefore, the NRC inspector has
C i '
; determined that the-requirements under this activity have been
f acceptably implemented and NRC inspection of'this activity is-
: complete.
,
~ ,
.No violations or deviations were identified.
-
s -
Revise Drawings (NRC Reference No.- 01.a.02.05).
p ;
'
. J The ISAP required.that the plant drawings;be revised to show the
@_
~ ~
-actual--butt splice' configurations disclosed during the Phase II
-
inspections. The NRC. inspector selected a sample of the involved
'
,
; plant drawings to ensure that appropriate revisions had been
'
, incorporated. The:NRC. inspector's' review of Drawings 2323-El-0155,
0156, 0158,~0172-16,-0172-16, 0172 41, and 0172-42 verified that all
'
n
required revisions h'ad been completed. Based on the acceptability of
Lthe-NRC inspectors findings, NRC inspection of this activity is
=' '
-
' complete.
b,
~
No violations or. deviations were identified.
'
Replacement of Rejected Splices-(NRC Reference No. 01.a.02.06)
4
The ISAP required butt splices, which are determined to be
~
,,
. unacceptable; be replaced. The NRC inspector verified, by physical
inspection, that the 88 splices, which were rejected by the CPRT,
were removed and had been replaced. NRC inspection of this activity
;is, therefore, complete.
.
:No' violations or deviations were identified.
' Tests of Replaced Splices (NRC Reference No. 01.a.02.07)
:The NRC inspector verified that pullout tests and radiographic
' examinations.were performed for 32 splices. (Twelve of these were
standards for comparison.) The r;csults of the pull testing and
radiographic examinations are documented in a pull test report which
_* .
.was reviewed by the NRC inspector.
Electrical continuity of each splice was measured before and after
- the pullout test. All splices removed from the field were
radiographed prior to pull testing. The pullout tests were performed
in accordance with Underwriters Laboratories (UL) Test
Procedure 486C.'Section 13. If a splice passed the UL test, it was
then pull tested until it failed. Three of the field splices tested
failed the UL test. Two of the failed splices had underinsertion of
'the wire into the wire barrel and continuity could not be measured
prior to the start of the pullout test. The other splice that failed
. - . - - - . _- . - _ . - - - - _ . . - - _ __
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. .had:the wrong size splice connector installed for the wire size. All
,
* , 1the other-field splices passed-the UL test.
'
,
Since the removed splices were tested in accordance with the ISAP
. requirements, NRC inspection of this activity is complete.
~
, -
p.. 1No violations or. deviations were' identified.
~
~
Inspectio'n of Adjacent Splices in Same Wire Bundle (NRC Reference
, No. 01.a.02.09)
,' N :As1 discussed in Reference No. 01.a.02.03 above, the adequacy of the
~ ~ ~
~ inspections performed by both ERC and TUGCo.is under NRC evaluation.
1
' ~
. This activity will be discussed in a subsequent report (see ,
unresolved item 445/8607-U-16).
L - Identification of- Sp1' iced ' Cables (NRC Reference No. 01.a.02.-101
'
'
The ISAP required the identification and Phase III inspe'ction of
other essential circuits where AMP insulated butt splices may have
been used for equipment terminations; e.g., pigtails on solenoids,
electrical devices. The NRC inspector review of the CPRT files
verified thatfappropriate plant drawings and related documents were
reviewed by the CPRT to identify locations in which the AMP splices
may have.been used. Based on this review,-the NRC inspector
; determined that the actions required by this activity were acceptably
-completed. Therefore, NRC inspection of this activity is complete.
Review of NCRs (NRC Reference No. 01.a.02.12)
~
Paragraph 4.1.3 of this ISAP required NCRs be issued to initiate the
~
Phase III inspections of-essential cables that could have the AMP
butt splices installed.- The NRC inspector verified that the cables
identified in the above activity were included in two NCRs. The NRC
inspector further eviewed one of these NCRs (E85-100588s) and found
that TUGCo inspections for 22 of the 25 cables in Unit 2 have been
completed. These 22 cables all contained uninsulated splices covered
with heat shrink tubing. Two of the splices were found to be
unsatisfactory; one splice was in a spare conductor.and was removed,
the other splice was not shown on the drawing. The drawing has been
updated to show this splim ,
Based on the finding that kHs had been issued as required by the
ISAP, NRC inspection of this activity is complete. The results of
the Phase III inspections (NRC Reference No. 01.a.02.11).will be
-discussed in a subsequent report.
, ,
No violations or deviations were identified.
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. -b. Butt-splice Qualification (ISAP'I.a.3)
'
s iRevise Procedure EEI-8 (NRC Reference No. 01.a.03.01)
C-E iThe NRCLinspectors reviewed Construction Procedure EEI-8, " Class IE
.
.
'
' and Non-Class IE Cable Terminations,t' Revision' 5, dated June 13,
% -
-1985.1 The. procedure contains instructions ~for continuity checks and
e ~ .' : staggering ~ attributes for preinsulated environmentally sealed (PIES)
splices while uninsulated splices with heat shrink sleeving are not
included. The acceptability of not including these. attributes for
- uninsulated splices.is an unresolved item (445/8607-U-17).
.
No violation or deviations were identified.
-
<
' Revise Procedure QI-QP-11.3-28 (NRC Reference No. 01.a.03.02)
'
-
'The NRC inspectors also reviewed Quality Inspection
Procedure QI-QP-11.3-28, " Class 1E Cable Terminations," to verify
othat the attributes for splice continuity checks.and staggering were
: included.: A continuity check is only required for PIES splices
installed in control panels. Staggering of splices is only specified
for PIES splices and device pigtails. There is no continuity check
'
cattribute' included for uninsulated splices or PIES installed outside
- of control panels; e.g., in MCCs. .Similarly, there is no requirement
~
>
,
for staggering uninsulated splices'at other than device pigtails; -
-
.
e.g.,' electrical penetration assemblies, control panels, MCCs, etc.
~
Theprocedurelacksinstructionsdescribingtheaccept/ reject
'
. attributes for a_ proper crisp connection for either PIES or
uninsulated splices and instructions for splicing #6 AWG through
1000 MCM cables. This subject is an unresolved item pending
completion of procedure revision and NRC review (445/8607-U-18).
Train Craft Personnel (NRC Reference No. 01.a.03.03)
Section 4.1.2 of.this ISAP required the applicant to train craft and
inspection personnel using the revised procedures. The NRC inspector
verified by review of training records that 43 electrical craft -
personnel have been trained to the appropriate procedure (EEI-8) and
'
that these 43 are the only personnel authorized to install butt
splices. This activity has, therefore, been acceptably implemented
and NRC inspection is~ complete.
No violations or deviations were identified.
.
Train and Certify Inspectors (NRC Reference No. 01.a.03.04)
Training and certification of QC inspectors for butt splicing has
also been completed. Currently, there are 37 inspectors certified to
perform work in accordance with the applicable procedure
(QI-QP-11.3-28). All 37 are certified as Level II inspectors. The
training records for nine of these inspectors were checked to verify
_ - _ - ,_ _ __ _ . . . . - _ _ _ __ . _ . _ _ _
.
_-
, __
$ ):L ~ i
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'
- ,
_
ir R :29-
'
i
9- . _ . .
.
% 'they,were. certified.to QI-QP-11.3-28, Revision 28. Since the NRC
-inspector-has verified that the requirements of the ISAP to train and
, certify the project QC inspectors.have'been completed, NRC inspection
'of.this activity-is complete.
No , violations or deviations were identified.
E' Repair of Adjacent Splices (NRC Reference No.- 01.a.03.05)
'
~
.. The requirement that any splices found during ISAP I.a.2, Phase II
inspections, which are adjacent to and pressing upon one another, be
repaired has been deleted from this ISAP by an Action Plan Change ,
Request (APCR) dated April 16, 1986. Review of the APCR shows that
'all inspection / documentation review activities for splices will be
included in~ISAP I.a.2.. Therefore, no action is now required for
this activity under the ISAP and NRC inspection for this activity is
complete.
No violation's or deviations were identified.
Data Qualification Package'(NRC Reference No. 01.a.03.06)-
'The NRC~ inspectors verified that a data qualification package, which
consisted of AMP's Equipment Qualification Report 110-11004,
Revision A,.and TUGCo's Equipment Qualification Review
Report TNE-DC-15.la, had been prepared.' The TUGCo report is not
included in the ISAP working file, but is in TUGCo's TNE Equipment
Qualification Group's files. The compilation of the required data
completed the CPRT required action for this activity; therefore, NRC
inspection of this activity is complete.
No violations or deviations were identified.
Third Party Review of Data (NRC Reference No. 01.a.03.07)
'
The NRC inspector verified that the data qualification package was
reviewed by a third party engineer for compliance to the following
equipment qualification standards:
IEEE Std.' 383-1974
4 / NRC Reg. Guide 1.131
G&H Electrical Specification 2323-ES-100, Revision 2
IEEE Std. 323-1974
The third party engineering review report of the data qualification
package for PIES splices stated that the splices were qualified for
the service requirements at CPSES. The completion of the third party
review fulfilled the ISAP requirements; therefore, NRC inspection of
this cctivity is complete.
No violations or deviations were identified.
_
'
_ _ _
______ ._ _ __ _ _
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Replacement'of-Unqualified Splices-(NRC Reference No. 01.a.03._03J
,. y .
.
e -
LSincePIES. splices-[havebeendeterminedbyboth'CPRTiandTUGCo'
f, '
-personnel to be qualified.1no splice' replacement is required per this
f ~ s ISAP. nTherefore, no actionis,. required and NRC. inspection of this
'
,
~
J - activity is complete. ~~'~
-
"' ~~
.
~No violations:or deviations were identified.
-
-
,
"
~ >
. Root-CauseandCorrectiveAction(NRCR'eferenceNo.01.a;03.09}
'
. ,
The;ISAP required that'"the results of the: actions.under this' plan
:were to be evaluated to establish root causes and to. identify _
+
. appropriate corrective action,'if required." fAs stated in the
- ~
. 'results report (RR) dated April 29, 1986, for this ISAP, no
safety-significant deficiency was' identified; therefore,'no root
-
' '
~
cause or generic _ implication evaluations were conducted. Based on
.the NRC inspector review of the various activities of this ISAP, no
basis was found to disagree with the above determination.
'
. 'Since the CPRT determined lthat a root cause evaluation was not
required, the' requirements of this activity are moot and NRC
. inspection is complete.
.
c. Agreement Between Drawings and Field Terminations (ISAP I.a.4)
..._
The NRC, inspectors reviewed the CPRT files to evaluate the sample
. selection process and the. inspection activities as well as the
_
'
^
results of these. activities. The NRC inspectors also performed
inspections to evaluate the agreement between drawings and field
terminations.
Establish Sample Plan (NRC Reference No. 01.a.04.01)
-
.
-
Section '4.1.1, " Inspection Prograin," of CPRT ISAP I.a.4, " Agreement
,'
'
between Drawings ~and Field Terminations," Revision 4, dated
. January 24, 1986, states "An inspection program employing random
sampling will be initiated which will enable a determination to be
made with reasonable assurance of whether the essential Class 1E
*
conductors in the control room and cable spreading room which
interface with the Alternate Shutdown Panel are terminated in
accordance with the applicable drawings." Paragraph 4.1.1.2, " Random
- . _ Sampling," of this ISAP states, in part, " Based on the preliminary
determination of a population size of 3812, the minimum sample size
'
according to Appendix D is 300 with-a rejection number of
zero . . . ."
Although the initial field inspections were conducted prior to
Revision 1 of Appendix 0 to the CPRT Program Plan, the NRC inspector
verified that the sample size was determined in accordance with the
requirements and procedures outlined in Appendix D. The NRC
1 r
we :
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mP ' ' l inspector (also verified that: sample ~ size determination of, subsequent
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inspections was injaccordance with: Appendix D. 'The population size
,1 ,
; ;was.. verified to:have teen established by a" review of applicable
' '
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'
ischematic . diagrams:and' panel wiring ~~ diagrams by TNE personnel..
'
' 7 - f Although the- population. identification.(list of/ cables) was provided '
~ .
- < lby_the. applicant, the NRC inspector determined that third party
Ng -
'
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,
.-l independence was maintained through CPRT compliance with Appendix D;
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'i.e.,*the;actualLconductors-to be inspected were determined on a=
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-
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iThe'NRCJinspector did not 7 identify' deficiencies in the establishment
k4
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,
'I --
of:the; sampling; plan; however,'the identification of the individual
'N ^ icablesland conductors to be included in the sample,did not appear to-
.
, ' gomply with'the ISAP requirements. 'Specif,1cally.iof the1338'
;u -
J conductors selected for inspection. in accordance. with, Appendix'D,
-p r approximate 1y'50.were " spare" conductors which werefnot-terminated.'
"?, 1As. stated'above,-the conductors to beLinspected,were(to be -
~" essential" conductors for. safe shutdown. Spareiconductors,do not '
.
+ =
f . satisfy this criteria 'and this ~1 tem has been identified as 'a wP
,
-
'
deviation (445/8607_-D-19).,
'
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.
'
..
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.
' ' '.
,It?should be noted-that after identification of'this item by the NRC
.
. .. ,, , .
.
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,
-
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inspectorf theCPRT..: inspected an. additional 34 functioning
;
conductors, ~ selected in accordance.with' Appendix D, to,en.sure"thate
'
.L, ,-
~
Lthe required sample size consisted of " functioning"s conduc ors.
,
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'
~
[ '
Sinc'e the NRC inspector' verified thatithe sample selection was-
' '
_ accomplished inLaccordan'ce with the ISAP~ requirements, except as
~
7 ;i
*, .
> inoted above, NRC inspection of this activity is complete. The NRC ~
, . inspector will follow up on'the applicant actions taken in response '
#
+-.
' to.. deviation 445/8607-D-19.
.~
' >-
Inspection of Terminations.to Design Drawings (NRC Reference No.
m ,y M f . 01.a.04.02)
'
- , ' Review of ERC Inspections
- .:: ~
~ _
The NRCLinspector. verified that the inspections performed by ERC
P, . personnel were ,n accordance with QI-001, " Procedure for Class 1E
, ;
<
o Cable Terminations' Inspection - CPRT Action Item I.a.4," Revision 3
"
' dated December 28, 1984. No special qualifications were required of
~
~
the. inspectors in tha.t termination point and conductor
n, ,
.. identifications were the-only attributes requiring inspection. The
, , , inspection attributes of QI-001 were verified by the NRC inspector to
' '
tsatisfy the requirements of the ISAP.
7, .
Review of the-CPRT inspection reports disclosed that the ERC
L ~" ' _ inspection personnel identified 31 " unsatisfactory" items relative to
~
t agreement between drawings and the "as-built" configuration. A
discussion of the resolution and analysis of these findings is
.
L - -
contained in the following section.
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32
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i ? NRC Inspections for ISAP I.a.4
' ~
. The NRC inspectors performed an inspection during April' 21, 1986,
- . . _
through April 24, 1986,_of all terminations in five control room and
two' cable: spreading room. panels in Unit 1. The drawings utilized and
>'
1 .
the panels inspected were: . 2323-El-0107, Revision CP-1, " Solid State
4 Protection. System Train 'A' Output Cabinet No'.' 2"; 2323-El-0112, ~~
'*
,
~
Revision CP-4, " Solid State Protection System Train 'B' Output
:
Cabinet No.' 1";'2323-El-0139, Revision CP.-3,." Solid state' Safeguards
. Sequencer Cabinet A";.2323-El-0156, Revision CP-7, " Balance of Plant
'
- Auxiliary Relay Rack Nc. 2"; 2323-El-0171-03, Revision CP-6, " Main
- Control Board"; 2323-El_0172-17, Revision CP-4, " Termination Rack
' ~
? s LECPRTC-17"; Land 2323-El-0172-41, Revision CP-4, " Termination Rack.
!ECPRTC-41."'.These inspections resulted in the identification of 52
,
" unsatisfactory" items by the NRC inspectors. Discussion of the
,
'
: resolution and: analysis of these findings is also contained in the
following section.
:During the inspection performed by the NRC inspectors, it was
identified that except for TB-53, 54, and 55, all of the terminal
^
r
. ,
'n blocks in panel CP1-ECPRCR-01, were not identified. A review of
'
7 Drawing 2462-1005, sheet 1, Revision CP-1, showed that identification
~'y is required. adjacent'to the components. The failure of the applicant
9 to follow drawing instructions / requirements is a violation of
1s "
. Criterion _V..of Appendix B to 10 CFR.Part 50 (445/8607-V-20). It
- should be noted that, upon identification of this out-of-scope
'
-
finding by the.NRC' inspector, the applicant initiated NCR E86-101727
- to resolve this issue.
Related Inspection Activities
The NRC inspectors also conducted an inspection of the disposition of
~
.
the'out-of-scope findings germane to ISAP I.a.4, which were
-
- . documented during the CPRT ISAP I.a.2 inspections. An inspection of
-
Unit 1 Cable Spreading Room, Termination Cabinet No. 42
(CPI-ECPRTC-42) showed that the appropriate drawing had been updated
to incorporate a completed design change; however, the inspection
- also disclosed a lugged, but unterminated, white conductor, labeled
! - EG123389, near the No. 4 terminal board. The conductor did not have ! electrical tape covering the ring-tongue terminal lug, nor was the , conductor tagged to indicate the purpose for its not being connected
to the appropriate terminal strip.
- -
i- The NRC inspector discussed this situation with the applicant's QE
representatives to determine the purpose of the unterminated
Lt conductor and if records existed to explain why it had been
disconnected. The applicant subsequently issued NCR E86-102070 dated
May 15, 1936, to evaluate the problem.
The conductor was determined to be an electrical lead to the limit
[ switch on the Safety Injection System to Hot Leg Loops 1 and 4,
"+ ++e.. -s-,-.e-- +e-w-,-----w- -w - , . y .,7w --rw. , cy,y-ym.-y.. . = , , - y y ,r, - - - - - - - ---
mm -
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p_
Containraent Isolation Valve MOV 1-88028. The limit switch provides
the. control room with valve open indication. The applicant had not,
-
las 'of. the end of this report period, provided an explanation on how
or why this conductor was disconnected.
In addition, while evaluating the above condition, the NRC inspector
was informed that a similar condition had been discovered during the-
CPRT inspections required by ISAP I.a.2. . The conductor was
> identified as EG106004(B) located in Unit 1 Relay Rack No. 2; it was
subsequently reconnected.but remained an open item in the CPRT
'
tracking system as of the end of,this. report period. This failure to
. control modifications is a violation of Criterion V of Appendix B to
10 CFR Part 50 (445/8607-V-21).
Conclusion
': .Since the NRC inspector.has verified that the ISAP required
inspections have been performed and documented by the ERC inspectors,
the NRC inspection of this activity is complete. The NRC inspector
will report on the applicant actions in response to violations
(445/8607-V-20'and 445/8607-V-21) in a subsequent report.
Reconciliation of Differences with Drawings (NRC Reference No.
01.a.04.03)
Review of Inspection Finding Dispositioning
a Paragraph 4.5.1, " Inspections," of the ISAP states, in part, "The
acceptance criterion for the termination inspection is that either:
-
The termination is physically in agreement with the
drawing . . .
'
-
The termination is not in agreement with the drawing but is
functionally correct . . . ."
Paragraph 4.3.3 of QI-001, Revision 3, states, in part, "The I.R.
shall be reviewed for legibility, accuracy aad completeness and
approved by the ERC Level III. The completed I.R. shall be submitted
to the Electrical / Instrumentation Review Team Leader for
review / approval of satisfactory items and for evaluation referral of
unsatisfactory items to TUGCo Nuclear Engineering (TNE) for
disposition."
The NRC inspector observed that the following unsatisfactory items
were referred to TNE for disposition:
. For samples 234, 295, and 151, the drawing and tha field
,
installation showed the cables to be E0110638, E0110631, and
l E0110630 in lieu of EG110638, EG110631 and EG110630.
_
- _ . .. . . . . . .. _ .. .. .. . . . . . . . . . . _ _ _ .
s C
34
. For sample 337, the blue coiductor of cable EG113293 appeared to
be greenish gray. The inspector remarked that it was
indeterminate as to color. g
. For sample 290, the blue conductor appeared to be greenish gray.
. For sample 192, cable EG120248 was incorrectly shown on the
drawing as cable EG20248. --
For sample 56, cable EG145725 was incorrectly tagged as
cable EC145725.
( -
Conductors were not terminated in accordance with the current -
design drawings. The conductors were landt.! on poin' that the -
'
drawings showed to be vacant.
Of the 31 unsatisfactory items identified by CPRT, 23 pertained to :
spare conductors. The conditions identified included: conductors il$jf
not landed per the drawing and not tagged; conductors not pl.ysically "
tagged; conductors not present; conductors retired inside a wireway
and therefore, not accessible; and conductors landed but not shown on
N<
the drawings. Of the approximately 50 unsatisfactory items identified
by the NRC inspection, 30 were related to spared conductors. The
response to these findings by THE was that there are no site or
procedural requirements to either tag spare conductors, or to show
them on interconnection drawings. During these inspections, similar
conditions were identified relating to jumper wiring.
Review of Drawing and Design Change Controls '
In addition to the conditions stated above, the NRC inspector also
found that: (1) drawings may be revised by THE and issued plant wide [
with the actual work accomplished at a later date; or (2) an ,.
Engineering Change Notice (ECN) may be issued by TNE to the .
Operations Department (at their request) with the work tracked ana
performed by Operations (Maintenance and Operations Support
~
'
Departments). The drawings are then updated and issued by TNE aftei -
being notified by Operations of the completion of the work. The
various methods of drawing revision appeared to the NRC inspector to .
be directly related to design control at CPSES. To assess this area,
g
_
the NRC inspector began a review of numerous design modification
control procedures.
i
Initial review by the NRC inspector indicated that the design change ;
process was quite complex as result of the number of organizations s
involved, the use of differen change mechanisms, and the numerous I
interfaces. Additional review of this process was performed by the !
Senior Resident Reactor Inspector, Operations, the results of which
are documented in NRC Ir.spection Report 50-445/86-09; 50-446/86-07. _
.
g - ___
pg- r:e .
e -
t _
35
(
R'eview of Reconcilia' t ion'of Differences with Drawings
^
During-tne NRC inspector's review of-the THE response to
unsatisfactory items identified during the NRC inspections, it was
observed that drafting errors were involved on two of seven drawings
utilized by the NRC inspectors. Paragraph 2.1.3 of THE
' Procedure TNE-DC-7, Revision 16, dated' February 14, 1986, -
,
" Preparation and Rev_iew of Design Drawings," states , in part,
"
. . . completed drawings shall be checked for accuracy and
compliance . . . ." . Paragraph 2.1.4 of this procedure also requires
an engineering review for technical accuracy upon completion of the
drafting / design check. Although it cannot be stated that the
. required reviews / checks were not performed, it was apparent that the
drawings were not appropriately reviewed / checked for accuracy'as
indicated by the following NRC inspection findings:
_( 1)
' Drawing 2323-El-0156, Revision CP-7, showed the green conductor
of cable EG118347 landed at terminal block TCA, point 5; the
conductor. physically installed was white with a black stripe.
This drawing also showed the orange conductor of cable EG130012
landed at TCA-7; the conductor physically installed was the
biack conductor of cable EG118347A. The drawing was not
" clouded"'to indicate that this was a design change.
~(2) Drawing.2323-El-0172,' sheet 17, Revision CP-4, did not identify-
the color of the conductor to be landed at terminal block TB-2,
point 31;
,
The following additional findings were identified during the NRC
inspector review of CPRT's inspection per QI-001:
(1) . Drawing 2323-El-0172, sheet 17, Revision' CP-4, identified
cable EG120248 as EG20248.
~(2) Drawing 2323-El-0156, Revision CP-1, did not show the physically
terminated white conductors of cables EG109964, EG109975,
EG109963, and EG109764.
The lack of appropriate reviews / checks of drawings by the applicant
.is a violation of Criterion V of Appendix B to 10 CFR Part 50
(445/8607-V-22).
The NRC inspector, however, did not identify any instances in which
the ERC inspection of sampled terminations disclosed a deficiency as
defined in the ISAP. Therefore, NRC inspection of this activity is
complete.
Root Cause and Corrective Action (NRC Reference No. 01.a.04.04)
. The CPRT results report for ISAP I.a.4, Revision 1, dated March 13,
1986, paragraph 5.4, " Root Cause and Generic Implications," states,
i I
. _ _ _ _ _ _ _ _ _ . - _ _ ,
_
. .
36
"Since the activities carried out during the implementation of this
action plan did not reveal any deficiencies, neither a root cause nor
a generic implications evaluation is necessary."
NRC Inspector Review of the Results Report for ISAP I.a.4 i
The ISAP I.a.4 Results Report, Revision 1, dated March 13, 1986, was
transmitted to the NRC by TUGCo letter dated April 4, 1986.
The NRC inspector review of the RR disclosed that only limited
mention was made of the unsatisfactory findings from the ERC
ISAP I.a.4 inspections and the germane 'indings from ERC inspections
for ISAP I.a.2. The unsatisfactory findings from the I.a.4 '
inspections were discussed under NRC Reference No. 01.a.04.02, above.
NRC inspector review of the CPRT files for ISAP I.a.2 disclosed the
following findings which relate to this ISAP: ,.
Drawing Conductor Unsatisfactory Item jgg
2323-El-0156, EG106004-black conductor lugged but
CP-7 not landed
2323-El-0159, EG145739-blue green conductor spliced
'
to blue conductor
2323-El-0172-42, EG016578-white & drawing deleted these
CP-2 black terminations which were
connected
EG118297-black conductors tagged as
& white E0118297
2323-El-0172-41, E0016586-black deleted on drawing but
CP-3 & white physically landed
SP119728-white and cables not shown on
'
SP119730-white the drawing
E0119690 green conductors not shown
& red on the drawing
.
2323-El-0160, E0118484-blue gray-black spliced to L
CP-8 -black blue-black
2323-El-0150, A0016200-black gray spliced to black :
CP-8
2323-El-0155, E0146397-white gray spliced to white
CP-6
E0146450-white gray spliced to white
'
i
n ,
~ '
i -n
.
i.,'_
"
.
-
N
37
,
-
The NRC. inspector did not, however,. identify any deficiency which
~
would alter the conclusion stated in the RR. Therefore, NRC
~
inspection of this ISAP activity is complete.
, d.L ;QC Insoector Qualifications (ISAP I.d.1)
During this1 reporting period, the ISAP activities identified by NRC'
' Reference Nos.-_01.d.01.03 and 01.d.0LO6 were inspected.
.
'
~ SET-Evaluation of ASME and non-ASME Inspector Qualifications (NRC
Reference No. 01.d.01.03).
-
~During this reporting period, the NRC inspector reviewed ten
inspector qualification files from the ASME group. The ASME group
, . ;had previously been evaluated by the QA/QC Review Team with the
stesult that of 72 ASME related inspectors, 3 shall have their
qualifications further evaluated under Phase III of this ISAP. A
-
; fourth . inspector, whose. qualifications had been questioned by the
. SET, was reviewed and accepted by the QA/QC Review Team. The reasons
for.this acceptance were documented on ERC Memo QA/QC-RT-1791.
The NRC inspector reviewed ten qualification files from those
inspectors found acceptable by ERC. The files were reviewed to
establish acceptable verified education and experience levels,
acceptable examination scores, required reading and indoctrination
completed, sufficient on job training (0JT), completed technical
~ training outline, and passing eye examination. The results of the
, NRC-inspector's review were in agreement with results of the ERC
review;
,
No violations or deviations were identified.
'
_3 Further NRC inspections are planned for non-ASME inspector
qualifications.
,
Evaluation of Results (NRC Reference No. 01.d.01.06)
The NRC-inspector reviewed the Comanche Peak. Project Procedure Manual
for the procedures that required the results of I.d.1 to be factored
into the collective evaluation of the construction QA/QC program, and
the collective evaluation of the quality of ccnstruction. The
procedures which provide this requirement and the details by which it
is to be achieved are CPP-013, Revision 1, " Collective Evaluation of
the Quality'of Construction," and CPP-014, Revision 2, " Collective
Evaluation of Construction QA/QC Program." These procedures require
the QA/QC review team to evaluate the results report from ISAP I.d.1
and to factor its results into the collective evaluation programs.
NRC inspection of the collective evaluation programs will be reported
under a separate heading.
.
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,
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P 38
.
*
'
'No further NRC inspection"is pl'nned a for this item.
No violations or deviations were identified.
e. Maintenance of Air-Gap Between Concrete Structures (ISAP II.c)
LThe following activities for ISAP II.c were reviewed by the NRC
: inspector during this report period: .
Removal of Debris or Rotofoam (NRC Reference No. 02.c.02.00)
.The NRC inspector has witnessed cleaning and repair of both single
and. double walled gaps on numerous occasions. This includes
witnessing the use of a variety of tools used for debris removal and
a review of the overall process.
During this report period, the NRC inspector observed air gap
cleaning along; (1) the LA-AF wall gap between the auxiliary building
, and the fuel. building, (2) the gap between Unit 1 reactor building
and.the fuel building, and (3) the gap between Unit 1 reactor
'
building and the auxiliary building. Activities were observed
primarily by using remote video equipment.
The NRC inspector observed the test of a' high pressure water jet
system, " hydro-laser", operated by Hydro Nuclear Systems. Actual
. conditions in the building air gaps were simulated by placing
. 5000 psi strength concrete in a gap formed by two large concrete
blocks placed 2 inches apart. The concrete was allowed to cure for
approximately 7 days. The water jet used had a nozzle pressure of
approximately 10,000 psi at 22 gpm. No damage occurred to the side
. walls when the concrete in the gap was' removed.
~
>
.The NRC inspector witnessed the use of the hydro-laser system for
concrete removal at the 3A line along the LA-AF wall. A vacuum
system was used for debris and water removal. An air arc system was
used to cut an angle, approximately 2x2x1/4" to allow for removal.
No apparent damage to the side walls of the gap was observed during
inspection.
NRC inspections will continue during subsequent report periods.
, ,
No violations or deviations were identified.
Analyze Final As-Built Condition (NRC Reference No. 02.c.03.00)
The NRC inspector reviewed G&H Calculation LIS-100c, Set 19, "Effect
of elastic joint filler or fire seal at top of secondary walls during
a seismic event." The methodology and assumptions used were found to
be in agreement with the design commitments contained in Section 3.8
:
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of the Comanche. Peak FSAR.' Numerical calcul'ations were spot checked
for accuracy. No numerical errors were discovered. Additional review
will be performed during a subsequent inspection.
;No violations or deviations were identified.
f. Joint Test Group (JTG) Approval'of Test Data (ISAP III.a.2)
'
The NRC inspector reviewed the; central file containing documentation
in support of' actions taken under ISAP III.a.2. Tne followup inspec-
tion of this ISAP was~ closed in NRC Inspection Report 50-445/85-16,.
-dated April 4, 1986; however,'a statement has since been added to the
'M- file indicating that no results report will be issued. (Similar
~
statements were found in the files for ISAPs III.a.3 and III.b)
-Failure to do-so would be a deviation from the CPRT Program Plan,
Section VI which states, "Each ISAP and each DSAP will-produce a
results report."' _When questioned about these statements, the CP(P
-
_
-Program Director stated that the statements were in error and that
r'esults reports would be issued for each of_these ISAPs. The CPRT
Test Programs-Team Leader stated that the erroneous statements were
subsequently removed from the files.
-
This ISAP is closed pending NRC staff acceptance of the results '
report.-
g. Containment Integrated Leak Rate Test (CILRT) (ISAP III.b)
Revision 3 of ISAP III.b contained commitments that were not included
in Revision 4. When questioned by the NRC inspector, the CPRT
-indicated that the items were completed, and thus, it was moot to
commit to actions already completed and followup inspected by the
NRC. This practice is acceptable, because the NRC inspector compared
all revisions of the Test Program ISAPs to ensure previously
committed actions were carried forward and/or continued to be tracked
by the NRC staff. Thus, all previous and current commitments have
o been, or will be verified complete by review of documentation in the
central files maintained by the CPRT.
In ISAP III.b, Revision 3,-Section 4.1.1, the CPRT committed to
compare the FSAR and ANSI N45.4-1972 with CILRT
Procedure 1CP-PT-75-02 to identify any differences, other than the
calculation method, that may have been caused by the unauthorized use
of ANSI /ANS 56.8-1981. The NRC inspector verified by review of
documentation that the review was satisfactorily conducted and
evaluated by the JTG. This issue is closed.
In ISAP III.b, Revision 3, Section 4.1.2, the CPRT committed to
respond to the NRC letter dated August 27, 1984, from NRR to the
applicant, which requested additional information on the CILRT
conducted on CPSES Unit 1. The NRC inspector verified by review of
documentation that the respanse was transmitted to NRR on
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) December l21,1984.-NRRacceptanceoftheresponseis'documentedin
CPSES Supplemental Safety Evaluation-Report No. 12 dated October 1985
,
-(SSER-12). This: issue is closed. ,
m !In ISAP III.b, Revision 3, Section 4.1.3, the CPRT committed to
'
: conduct evaluations to determine whether,PT procedures were designed
=
'
-and performed in a manner-which complies with FSAR commitments.
x .Section-4.1.4 addressed.an evaluation of administrative controls and
procedures utilized at CPSES on the same subject. Sections-4.1.5 and
, '4.1.6 committed to expansion of the reviews if programmatic
. deficiencies or FSAR deviations were found during performance of
-
-Sections 4.1.3 and 4.1.4, respectively. All of the above was deleted
iby ISAP.'III.b, Revision'4, and moved.to ISAP III.a.1, Revision 4.
Actions taken will be inspected concurrent with ISAP III.a.1 followup
reviews by the NRC staff.- For tracking purposes, this is an open
item (445/8607-0-23).
In ISAP.III.b, Revision 4, the CPRT indicated that, based on NRC
acceptance of the CILRT.as. documented in SSER-12, TRT concerns with
CILRT methodology had been resolved. '
.
Based on a satisfactory review of supporting documentation and the
transfer'of FSAR commitment review to ISAP III.a.1, this ISAP is
closed pending-staff acceptance of the results report.
-
-h. Nonconformance and Corrective Action Systems (ISAP VII.a.2.) !
During this report period, the ISAP activities identified by NRC
Reference No. 07.a.02.06 were inspected as follows: i
Review of CAR Implementation (NRC Reference No. 07.a.02.06)
, -_To assess the adequacy of the ERC review, the NRC inspector reviewed
'six TUGCo and six B&R CARS that had been previously reviewed by ERC. l
- This review was conducted using the ERC prepared checklist. The NRC i
j inspector found no discrepancies in the ERC review. During ! '
performance of the NRC review, it was noted that documentation ;
supporting closure or verification of corrective. action completion
-
was not always included in the CAR package. Subsequently, the NRC
inspector reviewed four CARS for this attribute since it was not
included specifically in the ERC checklist. The four CARS were
. chosen because each referred to corrective action not supported by
documentation within the CAR package. It was found that, CAR-049, r
was closed before corrective acticn was completed, which is not in !
compliance with procedural requirements. This is considered a
violation (445/8607-V-24).
The ERC review of CARS is similar to its review of NCRs, except a L . technical review of the adequacy of the disposition as implemented is
$ '
being performed for NCRs. In view of the above violation and noted
similarity between the two systems, an evaluation of the adequacy of
, b.
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t M. 11. Audit Program-and Auditor Qualifications-(ISAP'VII.a.4) '
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, i . :During this-report period,.the ISAP activities identified by NRC
f Reference No. 07.a.04.02 were inspe,cted as follows:
~
.
_~ = Review of Documentation-Related to QA Audit Program (NRC Reference
~ * -
No. 07.a.04.02).
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,
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TheNRC: inspector.. reviewed 27. audit [filesandbackupdocumentation~
;from the Dallas Audit Group's files. This review was iniaddition to
,
the 12 audit files previously-reviewed in January. The reviews were
~
-conducted to establish a basis for verification of~ERC. review- .
,
~
fresults. Items inspected were audit: planning,-audit scheduling,
:
- . ~ ' audit plans and checklists', audit reports, ~ audit deficiency followup,
. audit team makeup, auditor-qualifications, and audit coverage of
'
vendors.
I Following review of: the audit files, the' NRC inspector . inspected the
.
fresults of'the.ERC review ~of' planning and scheduling for~TUGCo
s ' internal' audits. 'The NRC inspecter found audit scheduling to have
n . .been performed-from the.beginning of the internal. audit program. A ,
'- *
calendar matrix of internal audits, training schedules, and vacation
r sche'dules was.used in the early audit program. . This finding agrees
Ewith the ERC' review results.~ The planning'was deficient in its
'
; commitments to ANSI N45.2.12, Draft 3, Revision 0, 1973, because it
failed to. provide information to assure all elements of the QA
{ program were audited to an adequate depth, nor did the audit planning _
,
11dentify all-activities requiring auditing. This area-has been
-
previously. inspected ~and reported.in NRC Inspection
!' Report 50-445/86-03; 50-446/86-02 ao an open item. h_ p The NRC inspector also inspected the results of the ERC review of
audit. plans and checklists for internal audits. The NRC inspector
found from review of audit files that the scope of the audit plans
l was not well defined during the early years of the internal audit p- . program.- The checklists were prepared from the procedures '
controlling the activity being audited; however, no attempt was made
l .
to' assess if applicable QA program commitments were included in the
F. procedure. Audit plans and checklists reviewed for 1985 do reference 'l'
the higher tier documents and indicate what criteria from 10 CFR
Part 50, Appendix B, are. applicable to the performance of the audit.
Results of the NRC inspection agreed with the results of the ERC
. review in this' area.
The NRC review of audit performance substantiated the ERC review
'
results, in that audit checklists were prepared for each audit,
.
n i objective evidence was reviewed to establish compliance, pre and lm postaudit meetings were conducted, audit deficiencies were documented
and submitted to the audited organization.
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V NRC review of:a concern regarding TUGCo's' use of an acting team
leader.found that in all-audits reviewed a qualified lead auditor
,
participated. During NRC. interviews,. audit personnel indicated that
1 p the qualified lead auditor would overview the activities of the
:Y acting team leader, this being a learning experience prior to being
*
certified as~a. lead. auditor. This appraisal is in agreement with the
-
~res41ts of.the ERC review.
. NRC. review of audit deficiency followup found that deficiencies were
< :P identified in the audit reports and copies issued to the audited
,
' organization. . When responses from the audited organization were not-
received in the time specified, letters of " overdue response" were
sent in accordance with procedural requirements. However,
verification of corrective action implementation often did not take
' place for 6 months to a year after the report was first issued. This
finding is in agreement with the ERC review.
-
-It should be noted'that TUGCo QA attempted to address the problem of
closere verification by issuing specific audits, such as TCP-111,
" Closeout of Open_ Construction Audit Findings," conducted in 1984.
TUGCo is continuing to reduce the. tine required to verify
implementation of corrective action. One action being taken is the
, relocation of the Dallas audit group to the Comanche Peak site, which
should increase auditor awareness of site QA status and reduce the
O amount of time required for verification of corrective action.
'
'
The qualifications of current auditors were reported in NRC
Inspection Report 50-445/86-01; and 50-446/86-01. The qualifications
of historic auditors were reviewed by the NRC inspector during this
reporting period. Results of this review agreed with the ERC review
results, in that, the Dailas audit files contained documentation
_ appropriate to commitments at the time of certification
(ANSI N45.2.12, 1973, Draft 3, Revision 0, prior to June 1, 1983; and
ANSI i:45.2.23,11978, after June 1, 1983).
No violations or deviations were identified. Except for followup of
, the identified open items,_no further NRC inspection is planned f
this area.
. j. Housekeeping and System Cleanliness (ISAP VII.a.7)
During this reporting period, the ISAP activities identified by NRC
Reference Nos. 07.a.07.04 and 07.a.07.05 were inspected as follows:
ERC Overview of Plant Surveillances (NRC Reference No. 07.a.07.04)
The NRC inspector has accompanied ERC in their overview of two TUGCo
plant surveillances in the safeguards building, Unit 2 reactor area,
the millwright shop, paint shop, electrical warehouse, and electrical
and mechanical laydown areas. To assess the implementation of ERC
overview in areas not accompanied by the NRC inspector, the notes and
.
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recorded data from these ERC overviews were inspected. The NRC
Linspector determined that these overviews by ERC were accomplished in
accordance with subparagraph 4.-l.2.4 of this ISAP.
No violations or'.' deviations were identified and no further NRC
[inspectionis_plannedforthisreferencearea.
'
: Review of-Documentation on Housekeeping (NRC Reference No.
, 07.a.07.05)
During this reporting period, the NRC inspector redewed '
documentation' utilized by ERC to assess the effectiveness of the
current:TUCCo housekeeping and system cleanliness program. All of
the.ERC notes and data sheets for this activity were reviewed.
.
-x '
4
Additionally,:the following documentation was reviewed in depth: B&R
audits CP-16,'CP-17, and CP-18; B&R CAR-35; TUGCo surveillance
reports C-85-007, C-85-021, C-85-036, C-85-032, C-85-047, S-85-048,
and S-85-016; flush plans FP-56-09, FP-55-02, and FP-55-08; and swipe
tests J-198 and J-240.
-
:This documentation showed that housekeeping and system cleanliness
for the current program are surveilled frequently and that
deficiencies noted are properly documented. The present surveillance.
"
program requires surveillances to be performed at the determination
ofthe'surveillancesupervisorinresponsetositeactgvities,
previously identified areas of deficiencies, and the Project Trend
.; Report.- The results of the NRC review agreed with the notes and data
sheets of ERC's reviews of performance. ERC's assessment of
-
effect.iveness of the program will be in the results report.
No further NRC inspection activity is planned for this item.
No violations or deviations were identified.
k. Receipt and Storage of Purchased Material and Equipment
(ISAP VII.a.9)
During'this report period, ISAP VII.a.9, Revision 0, was forwarded to
the NRC for staff review. As a result of NRC concerns regarding the
scope of the ISAF, inspection of implementation has been deferred
until after issue of a staff response.
1. Valve Disassembly (ISAP VII.b.2)
Review Construction and QC Procedures to Determine if They Provide
Adequate Controls of Materials During Disassembly / Reassembly (NRC
Reference No. 07.b.02.03)
The CPRT, by virtue of the issuance of the Results Report, Revision 1
on April 3,1986, has completed all planned work on the subject LiAP.
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M .QMU i ,scffs:tiveness'of the"procedurestin effect'at the time'most of the
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L - , Lthe '_ disassembly / reassembly .of valves. .
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ESuperintendent when disassembly or reassembly l of valves occurs. When
:Designichange Notice (DCN) No. 3.was issuad on January 28(1983,
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:SectionT3.14Jwas Tchanged to read, "The Mechanical Superintendent (MS)-
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fshalljdocument the disassembly of all valves . in accordance with
'W . : Procedure CPM-9.18." Procedure CPM-9.18 was approyed'on: June;7, .
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- . ;The:CPRTffailure to identify that B&R did not'have an imp ~lementing '
l, procedure in existence between January and June '1983 1sla deviation "
, 'M i
t -(445/8607-D-26).^ '
,
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.With[ respect to storage of valve parts, the present
A ' Procedure ~CP-CPM-9.18, Revision 0, states the following, " Valve
,
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.
parts shall be packaged-and identified with the ' valve number to
'
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-
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then be securelyLstored by the Millwrights in the field, shop, or the
- ,1
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warehouse."
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'
NRC in'spections of the Millwright shop, Warehouse C, and Unit No.1
m ,
i reactor buildingLindicated that this procedure is being adhered to at ,
- the present time.
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Perform an Analysis to Determine the Safety Consequences of
. -Improperly Assembled Valves-(NRC Reference No. 07.b.02.03)-
(1) . The- results report states, "While the potential for switching -
non-ASME and ASME Code class bonnets did nxist, there'is no
implication that switching of non-ASME and ASME valve bonnets
,
, could be safety-significant."
In that-CPRT has identified a potential for switching non-ASME
'
;and ASME Code class bonnets, the NRC raised the question as to
" -
how'the results report considered the differences between
non-ASME and ASME Code requirements-with respect to material
identification and traceability, welding and weld repairs,
p" - ^
nondestructive' examinations, and personnel qualifications. As
of the.end of this reporting' period, the NRC has not received a
satisfactory' response from CPRT. This subject is an unresolved
item (445/8607-0-27) pending receipt of additional information
_ from the applicant.
(2) The CPRT issued DRs on Valve Nos. XSF-179 and 1-7046 stating
.that valve bonnet identification numbers did not match up with
the numbers specified on the ITT Grinnell NPV-1 form. The
,
.
results report stated that even though documentation was not
.found to identify the pressure / temperature rating and code class
of inaailed bonnet, markings stamped on the bonnet verified it
as an ASME code class component. The bonnet, therefore, must be
equal.to or better than the required ASME Code Class 3 bonnet.
> <
The results report ~does not, however, address what other
ramifications may result from the fact that the NPV-1 Data
-
. Report is not consistent with the installed bonnet. This
subject is an unresolved item pending additional NRC review
(445/8607-U-28). .
6. Construction Reinspection / Documentation Review Plan (ISAP VII.c)
a. Electrical Equipment
Status of CPRT Activity
,
ERC has completed 79 reinspections and 83 documentation review
, packages of sampled electrical equipment as of May 31, 1986.
Status of NRC Activity
'
The NRC inspectors have, as of May 31, 1986, witnessed 14 ERC
reinspections, conducted 5 independent inspections, and performed 15
documentation reviews of sampled electrical equipment. These totals
remain unchanged from the previously reported totals.
A question was raised about the seismic mounting / restraints of
MCCs 1EB3-2 and 1EB4-2. These two MCCs were not part of the sample
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to be inspected by ERC.
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Inspection showed that the MCCs were
-
-
^L 1 attached to two steel plates embedde.d in the floor and that no other
mechanical attachments' existed. A review of the design documents and
-
. equipment qualification review repoics showed that these MCCs were
installed as designed and that the design meets. seismic requirements.
The NRC' inspector had no further questions in.this area.
-
b. Structural Steel-
Status of CPRT' Activity
Reinspection of structural steel is.approximately 80% complete with
l110 of an estimated total of 138 packages reinspected. ERC has
<
identified 278 deviations and processed 262 for validity. To date,
!
234 or approximately 90 percent have been determined to be valid.
: Attributes with 10 or more valid deviations included (1) member
location, (2) location of connections, (3) size of connections,
'
~
(4) weld size, (5) structural bolting material, (6) bolt hole
coverage, (7) bolt / nut tightening,-and (8) bearing between bolt
head / nut and outer. connecting plies. Valid ' deviations are currently
being evaluated for adverse trends and safety significance. ERC
inspectors have reported out-of-scope observations to TUGCo regarding
this population, including numerous observations of deficiencies in
(1) a platform in Room 153 beneath the Unit I reactor vessel,
x~~ (2) monorail supports and base plates, and (3) a jet protection
structure in Room 113 associated with a steam generator blow down
' heat exchanger in Unit 1- .
Documentation review is approximately 65 percent complete with 90
packages reinspected. A total of 106 valid deviations have been
. identi fied. An additional 30 verification packages from the sample
cannot be reviewed at this time due_to the fact that the original
construction and inspection records have not been located.
Status of NRC Inspection Activity
~(1) The NRC inspector has previously witnessed nine reinspections.
In addition, the following four structural steel members were ,
independently inspected by the NRC inspector during this report
period:
Verification Equipment No. Building Unit
Package No. No.
1 I-S-STEL-140 MK C9-22 Auxiliary 1
(MAB-0799-0C5,SH1)
I-S-STEL-146 MK C9-4 Auxiliary 1
(MAB-0799-0C7)
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, ?T .I-S-STEL-197 MK B176-1-SA- Safeguards 1
-(2) During the prior ERCLreinspections, the following conditions
were identified as subject to evaluation as potential .
deviations:
I-S-STEL-140: Member location was out of tolerance and some
Twelds;were undersized.
-
I-S-STEL-146: . Member location was out of tolerance, some welds
-were undersized, and all A-490 bolts lacked required washers '
.under the bolt heads.
w I-S-STEL-164: .Some welds were undersized, weld undercut was
- excessive.for at least three locations, alterations were
~
identified that.were not on the design drawings, bolt material
was not as specified on the design drawings, and the location of
field installed associated details was out of tolerance.
I-S-STEL-197: Excess gap between the base plate and concrete
was identified, and member location was out of tolerance.
.
~ '
Dispositions of the above findings are open items (445/8607-0-29
;_ through 445/8607-0-32).
(3) During the independent inspection of Verification
~
Package I-S-STEL-146, the NRC inspector identified that gusset -
plate C10-17 was incorrectly oriented with respect to
member C9-4, a W10X49 uember. Plate C10-17 provides a
connection between a L3x3x3/8 angle (C9-33, not part of the ERC
reinspection) and member C9-4. As shown on Design
Drawings 2323-S-0799, Revision 1, and MAB-0799-0C8, SH.1,
'
Revision 3, plate C10-17 is to be installed at the top of
member C9-4. As-built, plate C10-17 was installed at the base
of member C9-4. In addition, angle C9-33 and a second gusset
plate at the opposite end of C9-33 were installed incorrectly.
A similar assembly located approximately 5 1/2' north of the
above assembly was also installed incorrectly. Orientation of
connections is delineated as Attribute B3 of QI-045, Revisions 1
and 2. Connection orientation was accepted by the ERC inspector
and no out-of-scope observations were reported. Acceptance of
this condition is a deviation (445/8607-D-14).
NRC is deferring further inspection in the area of structural steel
pending a response from the applicant with respect to the large
number of identified deficient conditions.
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3c ? Inspection of Nonpressure Boundary Welds for a' Supplementary.
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" Evaluation-of Visual Welding Inspection Techniques
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Status of CPRT Activity
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To'date, 62 randomly. selected samples of. weld joint's_ obtained from
,
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-ISAPs'III.b.3 and VII.c. populations _have been inspected before
removal of! coatings. 'Two.of the previously inspected population
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samples were invalidated prior:to inspection afttr removal of
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. coatings for:the following reasons: (1) I-S-NPBW 023, the, weld joint-
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chad pr<mer' paint: coating which was determined by ERC to be of an
.
C ; inadequate thickness; (2)'I-S-NPBW-121, pipe support installation was
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fdeleted and physically removed as a result of the Stone and Webster
i Engineering Corporation piping system stress reanalysis. The
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.following:10 samples weresinspected during this report period:
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': Verification Equipment Tag No. System * Unit
-
,
, : Pkg. No. ho.
LI-S-NP8W-012 .CP11CHCICE-06 Structural- 1
~
I-S-NP8W-115. 'FW-1-019-902-C57W- FW 1-
4
.I-S-NP8W-119 <CS-1-078-013-C42S CS 1
'
-I-S-NPBW-116 .SF-X-034-020-F43K SF 1
*"
I-S-NPBW-102. CP1-VAFNAN Structural 1
I-S-NPBW-112 CT-1-097-402-C52R CT 1
.
I-S-NPBW-078 AB-900-1M-4G .HVAC 2
'I-S-NPBW-120- CPX-VAFNCB HVAC Common (1)
A I-S-NPBW-113 MS-002-903-905-C77W MS 1
- . .
L I-S-NPBW-073 A8-852-1M-4F HVAC 1 .
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*FW-Steam Generator Feedwater; CS-Chemical and Volume Control;
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SF-Fuel-Pool' Cooling and Cleanup; CT-Containment Spray; HVAC-Heating,
Ventilation,,and Air Conditioning; MS-Main Steam
., ~To date, 45 of the randomly selected weld joint samples have been
4 -
inspected _after removal of coatings. The following 18 second phase
Linspections were performed during this report period:
Verification Equipment Tag No. System * Unit No.
:Pkg. No.-
I-S-NPBW-09A B-810-1L-WP23 HVAC 1
I-S-NPBW-066 18" x 14" STR HVAC 1
o --I-S-NPBW-050 FW-1-018-901-C57W FW 1
I-S-NPBW-042 P-18/CMK-D22(SG) Structural 1
_ I-S-NPBW-068 FW-1-017-912-C47W FW 1
'
I-S-NPBW-097 EMD-2 HVAC 1
I-S-NPBW-085 CP1-ELDPEC-05 Structural 1
I-S-NPBW-098 MS-1-RB-036-007-2 MS 1
i I-S-NPBW-033 54" x 38" STR HVAC 1 [.. I-S-NPBW-111 AF-1-101-001-S23K AF 1 ? !
.. - _ , . . - - - . . - . . - . - - - - . . - - - - - - . - - - - - - - . -- . - - - - - - - - - -
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~AB-900-1M-4G ' HVAC 2
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t. I-S-NPBW-071' ' CC-1-RB-004-007-3~ CC- 1
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I-S-NPBW-102. ._
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CP1-VAFNAN- ~ Structural 1
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:I-S-NPBW-092' AF-1-102-031-S43R~ ~ AF . 1 i
JI-S-NPBW-086- EMD-6- 'HVAC 1-
'
x , I-S-NPBW-055 CB-790-2N-1DU : HVAC. 1
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:I-S-NPBW-073: .AB-852-1M-4F- HVAC- -1
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I-S-NP8W-012 CP1-CHCICE-06 - Structural 1
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L*HVAC-Heating, Ventilation, and Air Conditioning; FW-Steam Generator
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. 2Feedwater; MS-Main Steam; AF-Auxiliary feedwater; CC-Component
s
ECooling Water'
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.
.
Status of-NRC' Inspection Activity
,
v - ,. The~NRC"inspectorhaswitnessed100percentof'theinspections
performed, to date, of welds in the coated and uncoated condition.
' '
.
.
. No.NRC violations Lor deviations-were identified.'
..' >
?7. Exit Interview
Exit interviews were conducted on May 8 and June 3, 1986, with the
applicant's' representatives identified in paragraph 1 of this appendix.
During there interviews, the NRC inspectors summarized the scope and
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-findings.ot the inspection. The applicant acknowledged the findings.
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