ML20236M401
| ML20236M401 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/17/1987 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20236M375 | List: |
| References | |
| FOIA-87-446 NUDOCS 8708110050 | |
| Download: ML20236M401 (73) | |
See also: IR 05000445/1987002
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U.S. NUCLEAR REGULATORY COMMIS$10N -
RE0viRED DE Liv ERv O AYE
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4/17/87
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REQUEST FOR PREMlUM COST MAIL SERVICE
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BRIEF DESCRIPTION OF ARTICLE
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Draft Inspection Report
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MF."^f4?i fli&47'Chfef, Region IV, U.S. Nuclear Regulatory Coeurfssi$it Parkway Central
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Plaza Building, 611 Ryan Plaza Drive, Suite 1000. Arlington, Texas 76011
JUSTIFICATION F OR SE RVICE REQUESTE D
Draft Report Corrections
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RETAIN THE REQUESTER COPY, AND M All THE BLUE COPY TO: CHIEF,M All AND MESSENGER BRANCH, FOS, ADM. FOR Mall ROOM USE ONLY.
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APPROVE D-M AIL AND MESSENGE R AUTsORIZE D OF FICI AL
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8708110050 870007
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FDIA
P'DR
BAUMAN87-446
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0001.0.0
In Reply Refer To:
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Dockets:
50-445/87-02
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60-446/87-02
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TV Electric
ATTN:
Mr. W. G. Counsil
Executive Vice President
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400 North Olive Street, L.B. El
Dallas, Texas
75201
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Gentlemen:
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This refers to the inspection conducted by Mr. I. Barnes and other members of
the Regicn I" Comanche Peak Group curing the period January 1 through
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February 28, 1987, of activities authorized by NRC Construction Permits
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CPPR-126 and CPPR-127 for the Comanche Peek Steam Electric Station, Units 1
and 2, and to the respective discussions of our findings with you and other
members of your staff during and at the conclusion of the inspection.
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Arees examined during the inspection were principally Comanche Peak Response
Team activities.
Within these areas, the inspection consisted of selective
examination of procedures and representative records, interviews with
personnel, and observations by the inspectors.
These findings are docu.nented
in the enclosed inspection report.
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0002.0.0
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During this inspection, it was found that certain of your activities appeared
to deviate from commitments made to the NRC.
These items and references to the
comitments are identified in the enclosed Notice of Deviation.
You are
requested to respond to these deviations in writing.
Your response should be
based on the specifics contained in the Notice of Deviation enclosed with this
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letter.
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We have also examined actions you have taken with regard to previously
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identified inspection findings.
The status of these items is identified in
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paragraph 2 of the enclosed report.
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The responses directed by this letter and the accompanying Notice are not
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subject to the clearance procedures of the Office of Management and Budget as
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required by the Paperwork Reduction Act of 1980, PL 96-511.
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0003.0.0
TU Electric
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Should you have any questions concerning this inspection, we will be pleased to
discuss them with you,
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Sincerely,
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E. H. Johnson, Director
Division of Reactor Safety and Frojects
Enclosures:
1.
Appendix A - Notice of Deviation
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2.
Appendix B - NRC Comanche Peak Response Team Activities Inspection
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Report
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50-445/67-02
50-446/87-02
CC:
TV Electric
ATTN:
G. S. Keeley, Manager,
Nuclear Licensing
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas 75201
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0004.0.0
Juanita Ellis
President - CASE
1426 South Polk Street
Dallas, Texas
75224
Renea Hicks
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Assistant Attorney General
Environmental Protection Division
P.O. Box 12548
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78711-2548
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0005.0.0
TV Electric
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Administrative Judge Peter Bloch
U. S. Nuclear Regulatory Commission
Washington, D.C.
20555
Elizabeth B. Johnson
Administrative Judge
Oak Ridge National Laboratory
P.O. Box X, Building 3500
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Cak Ridge, Tennessee 37830
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Dr. Kenneth A. McCollom
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1107 West Knapp
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Stillwater, Oklahoma 74075
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Dr. Walter H. Jordan
881 Outer Drive
Oak Ridge, Tennessee 37830
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Anthony Roisman, Esq.
Executive Director
Trial Lawyers for Public Justice
1000 P. Street, N.W., Suite 611
Washington, D.C.
20036
Texas Radiation Control Program Director
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0006.0.0
bec to DMB (IE01)
bec distrib. by RIV:
- RFB
- MIS System
- RRI-OPS
- RSTS Operator
- RRI-CONS
- R&SPB
- T. F. Westerman, RSB
DRSP
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R. Martin, RA
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- RSB
- RIV File
J. Taylor IE
- D. Weiss , LFMB ( AR-2015)
4.= Konkt s n;11E=-.
- I. Barnes, CPG
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APPENDIX A
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NOTICE OF DEVIATION
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TU Electric
Dockets:
50-445/87-02
50-446/87-02
Comenche Peak Steam Electric Station,
Permits: CPPR-126
Units 1 erd 2
CPPR-127
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Based'on the results of an NRC inspection conducted on January 1 through
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February 28, 1987, two deviations from commitments were identified. The
deviations consisted of several concrete pours not being identified on the
Population Items List and documents missing from the Issue-Specific Action Plan
(ISAP) VII.c project files.
In accordance with the " General Statement of Policy
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anc Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C (1986),
the deviations are listed below:
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A.
ERC document QA/QC-RT-1628, Revision 1, " Population Items List Concrete
Placement." states, in part, that the list ". . . includes all
safety-related concrete pours in Unit 1, 2 and areas common to both units."
Attachment 6.3 of ERC Procedure CPP-005, Revisicn 3, states, in part, "The
responsible QA/QC Discipline Engineer . . . Provides the basis for
accepting the list as valid."
In addition, "The QA/0C Lead Discipline
Engineer and the OA/QC Engineering Supervir,ar review Population Items Lists
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to ensure that they are complete, accurate, and consistent with the
requirements of this procedure."
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In deviation from the above, NRC inspection of the Population Items List
for concrete placement revealed the followino discrepancies:
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1.
Pour Nos. 205-9810-039 through 205-9810-056 are shown as block-out
type pours in the east diesel generator foundation, Unit 2, on Drawing
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SSB-20655, Sheet 1, Revision 5.
Pour hos. 205-9810-040 and
205-9810-048 through 205-9810-056 were not on the Population Items
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List and no corresponding pour cards could be obtained in the TV
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Electric Records Center.
Pour hos. 205-9810-039 and 205-9810-041
through 205-9810-047 were on the Population Items List but were
assigned on drawings at least twice and are shown, for example, on
Drawings 55B-20605, Sheet 1, Revision 7, and 55B-20618, Sheet 1,
Revision 2 to be concrete curbs, removable slabs, etc.; not
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block-outs.
2.
Pcur No. 205-4822-003 is shown as a shielding wall for the Primary
Sampling room on Drawings SSB-20605, Sheet 4A, Revision 0, and
SSB-20605, Sheet 4, Revision 0.
This pour number was not on the
Population Items List.
The above discrepancies indicate that the Population Items List is not
entirely complete and accurate and does not include all safety-related
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0009.0.0
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The ERC review of the Population Items List to ensure
concrete pours.
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accuracy and completeness was inadequate (445/8702-0-02; 446/8702-D-02).
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Section 5.3.1 of Revision 2 to ERC Procedure CPP-004, " Project Working
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Files " dated December 17, 1985, for ISAP VII.c states, in part, "The
Records Administrator shall review each document received for filing fer
physical quality (e.g., reproducibility, legibility, condition) and
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completeness (e.g., number, file location, sequence of attachments, etc.)."
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In deviation from the above, NRC inspection of the Population Items List
for electrical cable, revealed that the records administrator failed to -
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identify that pages 813 and 814 of the Electrical Management System cable
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population listing and the list of Essential and Emergency Lighting
circuits were missing from the cable population listing (445/8702-D-03;
446/8702-D-03).
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TO Electric is hereby requested to submit to this office within 30 days ot' the
date of the letter transmitting this Notice, a written statement or explanation
in reply, including for each deviation:
(1) the reasons for the deviations if
admitted, (2) the corrective steps which have been taken and the results
achieved, (3) corrective steps which will be taken to avoid further devi6tions,
and (4) the date when full compliance will be achieved. Where good cause is
shown, consideration will be given to extending the response time.
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Dated at Arlington, Texas
this _, day of
. 1987
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APPENDIX B
NPC COMANCHE PEAK RESPONSE TEAM ACTIVITIES INSPECTION REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-445/87-02
Permits: CPPR-126
50-446/87-02
CPPR-127
Dockets: 50-445
Category: A2
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50-446
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Construction Permit
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Expiration Dates:
Unit 1: August 1, 1988
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Unit 2: August 1, 1987
Applic6nt: .TV Electric
Skyway Tower
400 North Olive Street
Lock Box 81
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Dallas, Texas
75201
Facility Name:
Comanche Peak Steam Electric Station (CPSES),
Units 1 & 2
Inspection At:
Glen Rcse, Texas
Inspection Conducted: Jariuary 1 thrcugh February 28, 1987
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Inspectors:
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L. E. Ellershaw, Reactor Inspector, Region IV
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CPSES Group
(paragraphs 2.a-h, 2.j-n, 2.p, 2.u, 3.b, 4.a. and 4.b)
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C. J. Hule, Reactor Inspector, Region IV.
Date
CPSES Group
(paragraphs 2.1, 2.c, 2.s-t, 3.a
3.c, and 5)
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E Wagner, Reactor Inspector, Region IV
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CPSES Group
(paragraphs 2.q-r and 4.a)
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EG&G - J. Dale (paragraphs 2.a. 2.d-h, 2.j ,)2.1-n, and d.b)
Consultants:
A. Maughan (paragraphs 2.q-r and 4.a
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W. Richins (paragraphs 2.p and 4.a)
V. Wenczel (paragraph 5.)
Parameter - J. Birmingham (paragraphs 2.i, 2.0, 2.s-t, 3.a. and'
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K. Graham (paragraphs 2.b-c, 2.k. 2.u, and 3.b)
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D. Jew (paragraph 4.a)
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Feviewed By:
R. L. Spessard, Deputy Director Division of
Date
Inspection Programs, Office of,. Inspection and Enforcement
Approved:
I. Barnes, Chief, Region IV CPS $5 Group
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Inspection Sumary
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Inspection Conducted: January 1 through February 28,1987 (Report 50-445/87-02;
50-446/87-02)
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Areas Inspected:
Nonroutine, unannounced inspection of applicant actions cr.
p*evious jnspection findipgs, Comanche Peak Response Team (CPRT) Issue-Specific
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Action Plans (ISAPs), assessrnent of VII.c populations, and the ISAP sample
selection pr'ocess.
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Pesults: Within the four areas inspecte.d. two dev1ations (several concrete
pours were not included on the Population Items List, aragraph4.a.[3]: and
documentsmissingfromthe'ISAPVII.cpro.jectfiles, paragraph 4.a.[43)were
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identified.
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DETAILS
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Persons Contacted
- J. M. Ayres, Quality Engineering (QE) Supervisor, TU Electric
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- R. P. Baker, Regulatory Compliance Manager, TV Electric
- J. L. Barker, Engineering Assurance Manager, TU Electric
- J. W. Beck, Vice Frcsident, TU Electric
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- G. L. Bell, Nuclear Licensing, TU Electric
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P. Boortz, Engineering Assurance Supervisor, Evaluation Research
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Corporation (ERC)
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D. Boultan, Pcpulatior. Engineer, EP.C
D. Boydston, Issue Coordinator, ERC
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- E. J. Brab6 Ion, Deputy Program Mar.eger, CPRT
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T. Braudt, CPRT, TO Electric
- J. A. Buck, Senior Review Team (SRT), CPRT
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- F. G. Burgess, CPRT Project Manager, TV Electric
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R. E. Camp, Unit 1 Froject Manager, TU Electric
- W. G. Counsil, Executive Vice President, TU Electric
- R. D. Delano, Nuclear Licensing Engineer, TV Electric
D. Ferguson, Results P.eport Review Committee Chairman, CPRT
- J. R. Gelzer Issue Coordinator, ERC
- M. R. Gross , Jr. , Staff Member, CPRT
- J. Guibert, SRT, CPRT
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- T. L. Heatherly, Regulatory Cornpliance Engineer, TV Electric
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- G. S. Keeley, Nuclear Licensing Manager,~~ TU Electric
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- J. E. Krechting, Director of Engineer 1 rig, TU Electric
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D. McAfee, Cuality Assurance (Qt.) Manager, TV Electric
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'J. McNally, Populatiun Engineer, ERC
J, R. r5ffett, Executive Assistant, Engineering & Construction,
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D. Nace, Vice President, TV ilectric
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- W. Nyer,'SRT, CPRT
A. Pattersen, Issue Coordinator Eit
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- D. M. Reynerson, Unit 2 Project Manager,,10 Electric
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G. W. Ross, Issue Coordinator, ERC
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R. K. Sanan Issue Coordinator, TERA
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J. Schauf, Construction Evaluation Engineering Group Supervisor, ERC
- C. E. Scott, Startup Manager, TU Electric
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"* J. Smith, Operations Staff TU Electric
- M. R. Steeln.an, CPRT Support, TU Electric
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J. Tableriou, Population Engineer, ERC
T: G. Tyler, CPRT P)ogram Director, TV Electric
C Vincent, Issue Coordinator, ERC
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F. Webster, Engineering Statistics Advisor, CPRT
D. R. Woodlan, Licensing Supervisur, TU Electric
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J. E. Young, Issue Coordinator, EPC
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2111, QA & Personnel Supervisor, ERC
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The NRC inspectors also interviewed other applicant employees during this
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inspection period.
- Denotes personnel pre ent at the February 10, 1987, exit interview.
- Denotes personnel present at the March 3, 1987, exit interview.
- Denotes personnel present at both of the above exit interviews.
Applicant Actions on Previous Inspection Findings
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(0 pen) Open Item (446/8513-0-09):
Potenti61 ceviations were
identified by ERC concerning: (1)weldlocation,(2)undersizewelds,
(3) welding not per weld symbol, and (4) violation of minimum thread
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engagement. These conditions were documented on Deviation Reports
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(DRs) I-S-hVDS-109-DR-1, DR-2, DR-3, and CR-d and incorporated into
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Nonconformance Report (NCR) M86-250134X.
This item will remain oper
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pending disposition of the NCR.
b.
(Closed)OpenItem(445/8513-0-45):
ERC identified the following
conditions to the NRC as subject to evaluation as potential
deviations: (1) clamp bolts did not have locking devices, and
(2) paint was identified or. spherical bearings. The NRC inspector
verified thet a DR was written for each deviating condition.
The DRs
were subsequently documented on NCR k-23284N. The NCR was
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dispositionec: "I-S-LBSN-037-DR-1 and 2 are not nonconforming
conditiens" for the following reasons: (1) Peint is an acceptable
locking device (reference NCR M-23216N R-1) and was verified to exist
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on threaded connections of the subject support, and (2) paint on the
spherical bearings does not impair free gimbaling of the snubber which
is the ecceptance criteria defined by QI-QAP-11.1-28, Revision 34.
Since it was determined that these conditions are not nonconforming,
this item is closed,
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c.
(Closed)OpenItem(44E/P513-0-47):
During an NRC witnessec
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inspection, ERC icentified the following ccnditions to the NRC
inspector as subject to evaluation as pctential deviations:
(1) missing locking devices, and (2) dimensional discrepancies were
icentified during reinspection of I-S-LBSR-029.
The NRC inspector
verified that a DR was written for each deviating condition.
The DRs
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were subsequently doce . anted on NCR M-23135N which was dispositioned:
"I-S-LBSR-029 DR-16 2 are not nonconforming conditions" for the
following reasons: (1) paint is an acceptable locking device
(reference NCR M-23216N R-1) and was verified to exist on threaded
connections of the subject support, and (2) dimensional discrepancies
identified were not a valid deviation. * The note on the drawing
stating all dimer.sions plus or minus 1/4" is applicable for base
plates only; not the location of piping (which was the icentified
diirensionally aiscrepant condition).
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Since these conditions were determined to be not nonconforming, this
item is closed.
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d.
(0 pen)OpenItem(445/8514-0-15):
Potential deviations were
identified by the ERC inspector concerning a missing color cooe and
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the allowable distance between color code marks was exceeded. These
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were identified on DRs 1-E-IN1ti-066 DR 1 and CR 2 and subsequently on
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NCR I-85-102025SX. This populatfori was reinspected at a later date
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for additional attributes and the package designation changed from
I-E-ININ-066 to I-E-1NIN-066R. The reinspection generated one
additional DR, DR I-E-ININ-066R-DR-3, which resulted in the issuance'
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cf hCR I-86-101916X. This NCR also incorporated the previously
identified NCR. This item will remain open pending disposition of the
NCR.
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(0 pen)Openitem(445/8514-0-16):
A potential desiation was
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identified by the ERC inspector concerning location of sending Units
1-LS-6712 and 1-LS-6717 being reversed on the tank for package
I-E-ININ-069. This was subsequently identified on DR
I-E-ININ-069-DR-1, and NCR I-85-101890SX. Because of added
attributes, this population was reinspected and the NCR superseded by
i;CR I-86-101915X. This item will rema'in open pending disposition of
the NCP.
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(C1csed) Open Item (445/8514-0-24):
A potential deviation was
identified by the ERC 1rispector concerning a missing nameplate and an
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actuator spring that could not be located on 1-H-HVIN-043. A
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subsequent inspection located the nameplate anc identified the fact
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that the damper is a fail-safe damper and does not require a spring.
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This item is closed.
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(0 pen)Openitem(445/8514-0-28): A potential deviation was
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identified by ERC concerning an undersize horizontal brace. This
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condition was identified in DR I-S-HVDS-023-DR-4 and incorporated into
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hCR M-86-1003215XRI. This item will remain open pending disposition
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of the NCR.
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(0 pen) Open Item (445/8514-0-29):
A potential deviation was
identified by ERC concerning undersize fillet welds. This condition
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was identified in DR I-S-HVDS-041-DR-4 and incorporated into NCR
M-85-101991XR2. This item will remain open pending disposition of the
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NCR.
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(Closed)OpenItem(445/8516-0-12;446/8513-0-08): The ERC
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ncnconformance evaluation checklists did not provide for the
evaluation of the technical adequacy of NCn dispositions.
This ERC CA/QC RTL and the VII.a.2 iss'ue coordinator has stated that
evaluation of the technical adequacy of NCR dispositions is outside
the scope of ISAP VII.a.2. The applicant has, however, initiated a
program (performed by Stone & Webster Engineering Corporation) to
evaluate the disposition of 300 NCRs with use-as-is or repair
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dispositions for technical adequacy. The evaluations assessed the NCR
dispositions to determine: (1) if the disposition fully addressed the
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nonconformance; (2) if en adequate technical justification was
provided; and (3) whether the disposition block was correctly
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identified.
To provide further assurance, the applicant has decided
to expand its program to assess the technical adequacy of the
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remaining NCRs with these disposition categories. This activity will
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be overviewed by TERA as an independent third party.
NRC inspectier,
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of this process will be reported in a subsequent inbptction period.
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(0 pen) Open Item (445/8516-0-15):
Potential deviations were
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identified by the ERC inspector concerning locknuts missing from clamp
bolts and a bolt hole was incorrectly located. This condition was
subsequently identified in DRs I-S-0S42-25-DR-1 and CR-2 and
incorporated into NCRs M-25216HR1 and P-25338N, respectively.
This
item will remain open pending disposition of the NCRs.
,
k.
(Closed) Deviation (445/8516-D-35):
The ERC inspector failed to
record the presence of eristing additional field welds to those
specified on the drawing for Verification Package I-S-LBSR-041 and did
'
not provide objective evidence of reinspection. The deviation
resulted from inspection personnel not'being able to distinguish
vendor welds from field welds on vendor supplied components.
Qt.ality Instructions (QIs) QI-019,01-027, and QI-029 were revised to
incorporate inspection requirements for these welds. Weld inspections
performed prior to the procedure change were reviewed and supplemental
4
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__ _
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0021.0.0
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inspection instructions were issued on a case-by-case basis to assure
compliance with revised procedural requirements.
The NRC inspector
reviewed the corrective action taken and concluded that the revised
instructions should prevent recurrence.
,
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1.
(0 pen) Open Item (445/8516-0-38):
Potential deviations were
!
identified by ERC concerning: (1)weldsymbolsandlocations,
i
(2) undersize welds, aho (3) a Hilti Kwik Bolt embed violation. These
i
conditions were documented in DR I-S-HVDS-029-DR-1 and DR-2, and
incorporated inte NCR M-85-102014X. This item will remain open
'
pending disposition of the NCR.
'
(0 pen) Open Item (445/8516-0-39):
Potential deviations were
m.
identified by ERC concerning: (1)incorrectmemberdimensions,
(2) incorrect weld configuration, (3) incorrect weld size.
(4) incomplete fusion in welds, and (5) violation of weld undercut
.
1
criteria. These conditions were documented in DRs I-S-HVDS-089-DR-1,
DR-2, DR-3 DR-4, DR-5, and DR-6.
These DRs were then incorporated
into NCR M85-102027X for DR-1 through DR-5 and NCR M86-103774X for
DR-6.
This item will remain open pending disposition of the NCRs.
(0 pen)OpenItem(445/8516-0-40):
Potential deviations were
n.
identified by ERC concerning: (1) dimensior. violations, (2) incorrect
ductaimension,(3)incorrectorientation,(4)welaswereundersize,
and(5)incorrectweldprofile.
These conditions were documented in
DRs I-S-HVDS-103-DR-1, DR-2, DR-3, DR-4 AND DR-5.
These DRs were then
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,
0022.0.0
incorporated into NCR M85 101991X.
This iten will remain open pending
disposition of the NCR.
(Closed) Violation (445/8518-V-03; 446/8515-V-02):
Item A.1, failure
o.
to certify an inspector in accordance with procedural requirements.
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As corrective action for this violation, the applicant committed to
,
revise Procedure CP-QP-2,1, aTraining of Inspection Personnel, with
date of full compliance by May 21, 1986. The procedural revision was
l
to provide for identification of qualification responsibility and
euthority of Level III personnel invclved in training and
i
certification activities including those areas where a cross-over of
qualification authority existed.
The violation was issued due to the
failure to identify this cross-over authority. The NRC inspector
verified that CP-0P-2.1, Revision 21, dated May 8, 1986, and
essociated nuorandum TUQ 3748 dated May 12, 1986, provide for this
.
identification of cross-over authority. This item is cicsed.
!
Item A.2, failure to follow procedures when justifying waivers of
on-job training (0JT) in the certification of four QC inspectors. ,
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~~
_ . .
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U.1he NRC inspector has reviewed the information provided in the
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supplemental response to this violation. This review and reinspection
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of the files for the fcur QC inspectors verified that justification
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other than ". . . I hours OJT and previous related inspection
4
activity . . ." was included.
The justification on the waivers
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C023.0.0
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included ". . . demonstration of practical field ability to the
satisfaction of a certified Level II."
This demonstration provided
O
. . . assurance that the individual does have comparable' or
e
"
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dequivalent' competence to that which would have been gained . . . ."
Therefore, specification on the waiver of the previous related
i
inspection activity was not required in these cases. Since the
required infonnation was included elsewhere in the certification
files, a violation did not occur in this example and this item is
closed.
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p.
(Closed) Open Item (445/8603-0-15): This open item addressed
'
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inspector certification documentation for fill and backfill
I
placements.
ERC issued DR R-5-FILL-GEN-DR-1 regarding inspector
certification for the safe shutdown impoundment dam construction for
the period Apri's 24, 1976, through April 19, 1977.
Inspector
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certification documentation for Freese & Nichols Consulting Engineers
.
.
(F&N) and Mason & Johnson Associates
Inc. (M-JA) could not be located
during tFc initial ERC documentation reviews.
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TV Electric subsequently requested copies of certification records
from F&N and M-JA.
These documents were obtained and are being
transmitted to the Permanent Plant Records Vault (PPRV). The NRC
inspector reviewed these inspector certification documents and found
that the inspection personnel were qualified to perform the
inspections and/or laboratory tests.
This item is closed.
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0024.0.0
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q.
(Closed)UnresolvedItem(445/8607-U-17):
Incomplete craft
installat1cn procedure instruction. NRC inspector review of
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Revision 5 of construction Procedurc eel-8, " Class IE and non-Class
Cable Terminations," had identified the omission of inst 611ation
I
i
requirements for uninsulated cable splices.
This omission was noted
in NRC Inspection Report 50-445/86-07; 50-446/86-05 during the
evaluation of CPRT committ.ents related to preinsulated environmental
sealed (PIES) splices.
During this report period, the NRC inspector
reviewec Eevision 6 of EEI-8 dated September 23, 1986, ano determined
that adequate provisions for all types of splices had been
incorporated therein.
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r.
(Closed)UnresolvedItem(445/6607-U-18):
Incomplete inspection
,
1
procedure instructions.
In addition to revising eel-8, the CPR1 also
cormitted to having certain inspection requirements for PIES splices
irstalled in control beards incorporated in the QC inspection
,
,
procedure, Ql-QP-11.3-28. " Class 1E Cable Terminations." The NRC
inspector review of Revision 28 of this procedure had indicated that
other types of splices and PIES splices installed in locations other
than control panels were not subjected to the same requirements as the
PIES splices in control panels.
Further NRC inspector review of the
applicable facility commitments and of Revision 31 to QI-QP-11.3-28
found that all of the applicable provisions not previously included
had been incorporated into the procedure.
<
.
.
0025.0.0
s.
(Closed) Violation (445/8615-V-06):
Failure of the Unit 1 PFG to
provide specific instructions for the control of design cocuments
issued for exterded time periods.
The NRC inspector verified that Procedures CP-CPM-7.4 and CP-CPit-7.4A
were revised July 25, 1986, te provide instructions for the control of
design dccuments issued for extended time periods. As stated in the
response, these two procedures were superseded by issuance of
Revision 3 of Procedures CP-CPM-7.1 and CP-CPM-7.1A on December 15,
1986. The NRC inspector verified that a daily review of the Package
Inventory Card for document packages issued for extended time periods
,
was required in these procedures and that the requirement applied to
both 011ts 1 and 2.
These procedural revisions provide the requireo
j
controls. This 4 tem is closed.
I
,
t.
(Closed) Viciation (445/8615-V-07; 446/8612-V-07):
Failure to control
.
the activity by which the onsite fabrication shop provides inspection
traceability of idertical shcp fabricated items.
.
NRC review of Procedures CP-CPM-7.2A, " Material Storage / Identification
for Structural Steel Fabrication," Revision C, LCN #2, dated
August 12, 1986, and QI-CP-11.14-1, Revision ?d, dated July 28, 1936,
verified that these procedures were revised to incorporate methods to
'
control inspection traceability of identical shop fabricated items.
Since the violation was issued for failure to procedurally control the
activity and no hardware deviaticns were noted during the previous
,
u
.
.
CC26.0.0
inspet. tion, the above revisions to the applicable procedures close
'
this item.
(0 pen) Open Item (445/8615-0-11):
During inspection of Verification
u.
Package I-M-MEIM-035, the NRC inspector identified that an equipment
foundation anchor bolt nut was not bearing load and that a 1/4" gap
existed between the anchor nut and the load bearing mating surface.
Subsequent NRC review of ERC overview inspection documentation
revealed that an ERC overview inspector had already identified the
deviating condition and that DR I-M-MEIN-035-DR2 had been issued and
1
validated, resulting in the issuance of NCR M-23094 NR-2.
This item
,
remains open pending disposition of the NCR.
3.
CPRT ISAPs (excluding ISAP VII.c)
OC Inspector Qualifications (ISAP I.d.1)
,
a.
.
During this inspection period, the NRC inspector inspected tha
processing of DRs and the verification of inspector qualifications
hep u
a s gcC.
performedg .1dAP I.<171, personnel for inspectors whose certifications
b
were not found acceptable during ISAP.VII.c review.
This inspection
y
d]
was accomplished by first reviewing the controlling Procedures
1y ~
CPP-025, "QC Inspector Qualification Evaluation," and CPP-010.
" Preparation of Deviation Reports," and then performing a detailed
review of DRs related to inspector certification that were generated
!
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.
0027.0.0
during the VII.c review process. The DR processing was reviewed by
the NRC inspector for the following attributes:
.
!
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(1) Inspector certific.ation related DRs were forwarded to the
ISAP I.d.1 1ssue coordinator in accordance with CPP-10.
(?) The validity of DRs was properly evaluated by the ISAP I.d.1
issue coordinator.
1
t3) The transmittal of CRs was in accordance with (,PP-10.
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.
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(4) The determinations of inspector qualification for the uncertified
1
CC inspectors was proper and the determinations were documented
,
onthefnspectorfertificationfvaluationfmmary(ICES) form.
(5) The determinations to reinspect any previous work of unqualified
inspectors were proper and documented on a memorandum addresse.d
.
.
to the ISAF VII.c file as required by procedure.
(6) Reinspection of any previous work performed by the unqualified
OC inspectors were accomplished in accordance with QI-005,
!
" Evaluation of Inspector Performance."
1
(7) Validated CRs were transmitted to TV Electric for documentation
on an NCR/OR.
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.
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_-
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0028.0.0
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The above procedures were determined by the NRC inspector to provide
the necessary controls for evaluation and processing of the DRs. The
proceduras specified the personnel responsible for performing the
DR evaluations and the actions required for documenting the
evaluations.
The procedures also prcvided guidance for the
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DR evaluations by reference to ISI.P I.d.1
"QC Inspector
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Qualifications," and Q1-005, "Evalustion of Inspector Performance,"
<
which detail the methods to conduct evaluation of QC inspector
)
certification and qualification.
The process by which ERC performs en analysis of file docurrentation to
s
evaluate the qualifications of QC inspecto,rs is being inspected by the
.,
c.
c'
7/c EC C
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hRC under its WpertiorCof ISAP 1.d.1.
,Th&t process is identical to
E~
.
the process utilized for evaluation of inspectors identified by
'
.;y d
f
ISAP VII.c, with the exception that proper QC inspector certification
g
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is determired by the ERC VII.c inspectors in accordance with VII.c
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inspection / documentation review required in 28 of the 75 QIs used for
reinspection.
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During sample inspection of the document review packages, the NRCet(as_
ed
i
6 den verifytT@ whether a certification exists for the inspector of
record, where required.
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To evaluate the system by which inspector certification / qualification
,
is evaluated, the NRC selected a sample of 32 DRs concerning inspector
certifications that were identified during the VII.c document reviews.
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0029.0.0
All 32 DRs were found to have been transmitted, processed for
validation, and maintained as specified by CPP-10 and CFF-025. The
NRC inspector verified that the results of the I.d.1 issue
coordinator's review of the certifications in question were documented
on inspector certification summary forms and that justification for
the results was provided.
The NRC inspector found that of the 32 DRs selected. 28 were
determined by the issue coordinator to be valid and 4 were determined
to be invalid.
NPC review of the packages for the four invalid DPs
'
found tt.st the certifications had existed for the certifications
,
questioned by the VII.c DRs and that documentation existed to support
i
the certifications.
NRC review of the packages for the 28 valid DRs found that
l
2 inspectors were determined by the I.d.1 issue coordinator to be
unqualified for the inspections performed. Therefore, a I.d.1
.
Phase III reinspection was specified as corrective action.
The
26 remaining inspectors were determined by the I.d.1 issue coordinator
to have been qualified for the inspections performed. The basis for
the disposition of the 28 valid DRs is shown in the following table:
Inspector ovalified under equivalent
'
brown & Root (B&R) certification.
9
Inspector ou61ified under Level II
and all dauchter certifications.
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0030.0.0
]
Inspector qualified under contractor
certification other than B&R
(e.g., R. W. Hunt).
4
-Inspector qualified as determined
by Special Evaluation Team /RTL review.
2
Inspector qualified but
administrative / clerical errors
I
require DR.
5
Inspector qualified under previous
similar certification.
5
,
Total determined qualified.
26
Total determined not qualified and sent
to Phase III for Reinspection.
2
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The NRC inspector verified during review of the validated VII.c DRs
that the I.d.1 determinations of qualifications were supported by
cocumented evidence of comparable prior certification, sufficient
training and examination for the inspection activity, or in the case
of the two inspectors determined by the issue coordinator's review to
be qualified, that previous training and inspection activity was
sufficient and applicable for the certification in question.
,
The NRC inspector verified that the 28 valid DRs were transmitted to
TU Electric and NCRs were prepared.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ - _ _ -
.
4
0031.0.0
As reported in NRC Inspection Report 50-445/86-22; 50-446/86-20, the
NRC inspector reviewed four reinspection matrices utilized for the
ISAP I.d.1 Phase III reinspection of construction inspectors whose
qualifications were determined to be unsupported by file
documentation. The four matrices were found to be in compliance with
QI-005, " Evaluation of Inspector Performance." Additionally, the NRC
'
inspector witnessed two field reinspection which were satisfactorily
performed by ERC inspectors in accordance with these matrices.
flo violations or deviations were identified.
The evaluation of DRs
pertaining to inspector qualifications generated by ISAP VII.c or
.
,
other ISAPs will cortinue to be inspected by the NRC.
b.
Inspection for Certain Types of Skewed Welds in NF Supports (ISAP V.a)
Status of NRC Inspection Activity
'
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The NRC inspector verified compliance with the following ISAP activity
g
connitments:
Chronolooy of Inspection Methods (NRC Reference 05.a.01.00)
.
The methods for QC inspection of type-2 skewed welds and the written
procedures describing the methods and means of documenting the
inspections have changed during the construction of the CPSES project.
/
\\,a
The technical focus of thiTAP is the inspection of the geometric
.
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0032.0.0
and dimensional characteristics of skewed welds at locations where
'
sirrple fillet gauge measurement was not possible.
In order to determine what inspection instructions were applicable for
specific time frames, a chronology of inspection methods documented in
QC procedures was developed to correlate the period of time and
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specific procedure revisions for inspection of type-2 skewed welds.
The inspection techniques used and the methods of documenting the
inspections of type-2 skewed welds involved the following procedures:
.
,
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QI-QAP-11.1-26: which addressed the fabrication, installation and
1
inspection of ASME pipe and attachments welded to the pipe.
I
Ql-QAP-11.1-28: which addressed the fabrication, installation and
inspection of ASME pipe supports except for attachments welded to the
,
pipe.
CP-QAP-12.1: which addressed the final verification of ASME pipe
supports prior to certification (preparation of the ASME N-5 form).
Relevant historical changes affecting these quality procedures are as
follows:
QI-QAP-11.1-28: Revision 12 dated September 3, 1982, and Revision 13
dated September 21, 1982 - Specific criteria for the measurement of
i
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1
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0033.0.0
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type-2 skewed welds using the scribe line technique was incorporated
l
into the procedure at that time.
.
1
Ql-QAP-11.1-28: Revision 16 dated December 15, 1982 - The type-2
skewed wsld inspection methodology was deleted from the pipe support
procedure.
1
CP-QAP-11.1-26:
Revision 9 dated December 16, 1982 - The type-2
skewed weld inspection methodology was incorporated into the piping
procedure.
j
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QCWI-1: Dated February 21, 1983 - This B&R instruction was issued to
inform inspectors to use inspection methodology and acceptance
criteria in piping Procedure QI-QAP-11.1-26 when measuring type-2
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skewed welds on pipe supports.
-
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CP-QAP-12.1: Revision a dated February 2, 1983, and Revision 5 dated
March 18, 1983 - These revisions were issued to initiate reinspection
of all accessible structural welds on ASME pipe supports.
QI-QAP-11.1-26: Revision 13 dated August 4, 1983 - The profile
technique for measuring size of type-2cskewed welds was added to the
piping procedure.
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0034.0.0
QI-0AP-11.1-28: R rision 29 dated January 25, 1985 - The scribe line
f
technique for measurement of type-2 skewed fillet welds was
l
reincorporated into the support procedure,
01-0AP-11.1-28: Revision 30 dated April 15, 1985 - The profile
,
technique for measurement of type-2 skewed welds was incorporated into
the support procedure,
i
Six different methods of documenting the results of type-2 skewed weld
inspections were permitted by procedure at various times. These
methods were:
.
.
(1) HIR
Hanger Inspection Report
(2) CSC
Component Support Checklist
(3) bWDC
Multiple Weld Data Card
(4) WICL
Weld Inspection Checklist
(5) CSF/SWIR
Component Support Fillet and Skewed Welo
Inspection Report
,
N (6) COT
Construction Operation Traveler
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g , ,",/ This activity is complete. NRC inspection of activities listed above
-
!
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I
also provide a basis for completion of activities required by NRC
Reference 05.a.01.01 and 05.a.01.02.
No violations or deviations were identified.
Third-party to Evaluate the Physical significance of any Procedural
Changes (NRC Reference 05.a.02.04)
. .
. .
.
. . . . . .
. . . .
..
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. . .
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0035.0.0
Ntew/>a1.Titzt$5dbt
The NRC inspector questioned ngineering personnel from TERA as to
-fielho L
what was the ir. tent of this-(ey.n
ntsand what actions Wre taken.
i
reme
TERA persunnel stated that their review of procedure changes indicated
that an overall improvement with respect to inspection methodology had
.
- tla ba wul
1
occurred. This trend resulted in improved performance by inspection
1
A
personnel.
.
NRC review of data presented in the results report for this ISAP-
confirms this conclusion. This activity is complete,
ho violations or deviations were identifiec.
,
,
Cocument Centrol (ISAP VII.a.3)
c.
During this report period, the activities identified by NRC Reference
07.a.03.04 and the closecut of related external issues were inspected
..
as follows:
Procedure Evaluation (NRC Reference 07.a.03.04)
This ISAP required an evaluation of the current CPSES document control
The issue coordinator performed the evaluation, conducted
procedures.
and documented the results of the interviews, and completed a
procedure checklist, which in total formed the basis for the
evaluation.
_ _ _ _ _ - - _ _ _
,
.
0036.0.0
The NRC reviewnd the procedure checklist and compared it to the
requirements in Criterion VI of Appendix B to 10 CFR Part 50, and to
the commitments in the CPSES FSAR.
The procedure checklist was found
to address the requirements and commitments concerning distribution
and control of documents affecting quality. Utilizing thic checklist,
the NRC inspected the current controlling Frocedure DCP-3,
Revision 19 "CPSES Document Control Program," to verify that ERC had
implemented the checklist properly and that the procedure met the
above requirements and commitments.
The procedure was found to
properly contain the following attributes: measures to assure that all
documents, and changes to documents, were reviewed and appruved by
,
authorized personnel prior to distribution; and measures to assure
that all documents used for construction or inspection activities were
maintained current and in a controlled status.
Additionally, the
procedure provided for retrieval or identification of superseded
documents and for an ongoing monitoring of document control
, ,
performance of all controlled document files by an independent
monitoring team.
No differences between the NRC and ERC results were
noted in the completed checklists.
In addition, the NRC inspected the implementation of DCP-3 by
requesting a sample of 20 drawings and 10 procedures from the document
control center (DCC) and one satellite. These documents were found to
be at their current revision with all design changes entered when
'
compared to the DCC master list of controlled documents.
,
_ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _
__
_
_ _ _ _ _ - _ _ - - _ - _ _ - _ _ _ _ _ _ _ .
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0037.0.0
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The implementation of the independent monitoring team was inspected by
j
the NRC inspector by interviewing the head of the monitoring tebm,
l
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reviewing monitoring reports and executive suninary reports, and
reviewing the report distribution which included the vice-president,
engineering and construction.
The nionitoring team's reports indicated
,
I
that the document control groups were achieving an error rate of less
than 0.1L
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h ,.4, H ;,
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TheNRCinterviewedtheERCengineersresponsibfefor11ofthe
32 populations in ISAP VII.c to obtain(similar information from the
implementation of the VII.c ISAP.
These engineers stated that of the
,
4,000 drawings utilized during inspection of the 11 populations, they
found 6 document control errors or a 0.15% error rate.
Based on the foregoing NRC inspections and the favorable comparison
with the results of the ERC inspections, this item has been properly
..
implemented.
No violations or deviations were noted during the
inspection of this area of the document control program.
Closecut of Related External Issues
Two external issues related to document control were identified in
ISAP VII.a.3.
The issue of unauthorized procedures used for
cold-springing of piping was addressed in ISAP V.e and was not
considered further in this ISAP.
The issue that a " Controlled Copy"
stamp was improperly used by B&R ASME QA personnel was addressed.
L----------- - ---- ------ -- --- -- --
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0038.0.0
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The NRC interviewed the current B&R document review supervisor who
l
stated that the document review group does not currently use a ontrolf,A[
~ ~ '
Cc'opy" stamp; however, this supervisor did state that for a short time,a
stamp was used to mark drawings prior to presentation to the
Authorized Nuclear Inspector (ANI) for review. The NRC also
interviewed the B&R QE group supervisor that was involved when this
stamp was used.
This individual indicated that the stamp was used on
copies of small bore typicals before presentation to the ANI for
review.
The practice was stopped and the stamp defaced after'irsuance
of Special Inspection Services (SIS) Report 355, which documented the
ANI's concern about the use of the stamp.
Evidence of the stamp
-
i
defacing was provided by a memo to the QA file dated August 10, 1984,
bearing an imprint of the stamp before and after defacing. The
corrective actions taken appear sufficient to prevent recurrence.
The
i
improper use of the " Controlled Copy" stamp had been previously
,
1
determined by the NRC Technical Review Team (TRT) in SSER 11 to have
. .
had no adverse safety implications.
No further NRC inspection of this
'
item is planned.
,
1
4
Construction / Reinspection (ISAPVII.c)
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a.
Establishing Populations
,
Section 4.3.1 of ISAP VII.c, Pevision 1, required safety-related
hardware to be categorized into populations with homogenous work
l
_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
,
.
0039.0.0
activities (HWAs) and associated quality characteristics (attributes)
from which the required random samples were selected.
It also
required that a description and justification for hornoeneity be
prepared for each population.
Finally, each population was to have a
list of all final CC accepted safety-related items.
The CPRT
guidelines for establishing homogenous populations were contaired in
the project procedure for ISAP VII.c. Procedure CPP-005, Revision 3.
This procedure required the discipline engineers to review equipment
lists from CPSES in order to subdivide the plant into homogeneous
populations that have been constructed using reasonable horrogeneous-
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work processes. The equipment reviewed was limited to that which was
j
safety related, construction complete and final QC accepted.
The
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equipment would be inspected for attributes selected after a corrplete
I
review of engineering documents pertaining to the individual
populations.
,
The generation of a Population Description, Master Population List,
Population Items List, and a Work Process Memorandum are also
procedurally required along with adequate control of subsequent
revisions to each of these documents.
'
The NRC inspectors reviewed tha following six ISAP VII.c populations;
V
[(Large Bore Supports Rigid, large Bore Supports Nonrigid, Small Bore
l
Pipe Supports, Pipe Welds / Material, Concrete Placement, and Electrical
Cable)
ensure that the homogenous populations were correct and
.
- - - - _ _ -
-
(
,
1
8
s
1
0040.0.0
adequate and that ERC procedures, primarily CPP-005, were being
]
adhered to.
,
\\
]
Large Bore Supports Rigid (LBSR), large Bore _ Supports Nonrigid
j
(1)
(LBSN), and Small Bore Pipe Supports (SBPS),
,
1
.
The NRC inspector's review of these three populations was
performed concurrently because the population descriptions are
j
l
similar except for the population boundaries (large bore rigio,
large bore nonrigid, or small bore) and the Population Items
Lists were all derived from the same source document; the Hanger-
I
.
'
l
installation Tracking System (HITS) list.
-
/
'
,
s
(a)
Population Descriptions
NRC inspection verified that the systems listed by the CPRT ~
for inclusion in these three populations were designated in
Section 17A of the FSAR as safety related, either Safety
Class 1, 2, or 3, and Seismic Category I.
Cross checking
from FSAR Table 17A to the three populations, however,
identifiedthattheChilledWaterSystem(CWS)wasomitted
from the CPRT populations. Subsequent review of the
s
Population Items Lists did reveal that this CWS was included
in the population; it was only inadvertently left off the
The NRC inspector
Pcpulation Description lists of systems.
t
concurred with the listed population boundaries and the
- _ - - _ - _ - _ -
-
,
'
o
0041.0.0
'
s
items not to be_ included within the scope of the
populations. All CPRT sign-offs for review and approval as
7
>
%
well as control and vaulting cf the population descriptions
were performsc per procedure.
l
l
l
(b) Master Population List
'
l
NRC inspector review of the original Master Population List
and all subsequent revisions. (one through five) verified
thattheabovethreepopulati$nswereincludedonthelist
<
>
and that review, approval, and control of the documents are
,
per procedure.
1
(c) Population Items List
Each of the three Population Items Lists were derived from
-
.-
..
-
the{ame. Source-document _;;t[e7HITSlist. The CPRT initially
,
'
established the validity and accuracy of the HITS list and
then segregated out the three homogenous pipe support
1
populations (LBSR,LBSN,andSBPS).
To establish validity
and accuracy of the HITS list, the CPRT randomly selected
60 B&R Hanger Location (BRHL) drawings out of the listed
total of 2013 and manually checked to see that all supports
4
listed on the 60 BRHLs were also listed on the HITS list.
To verify the accuracy of the support status listed on the
(
HITS list, 60 supports were re.ndomly selected from the
<
6
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _
.
4
0042.0.0
60 BRHLs and their status individually verified by checking
records in the various vaults and processing areas. This
was required because only final QC accepted pipe supports
were to be reinspected under the VII.c program. No
discrepant conditions were detected by the CPRT.
To assess validity and accuracy of the CPRT verification of
the HITS list, the NRC inspector selected 10 out of the
60 BRHLs that the CPRT had reviewed, and verified that all
supports shown on the BRHLs were included on the HITS list.
To further assess the HITS list, ten additional BRHLs not *
..
l
selected by the CPRT were selected by the NRC inspector and
l
l
checked against the HITS list for support inclusion.
These
ten BRHLs were selected such that a wide variety of
!
safety-related systems were included in the review.
Finally, the NRC inspector reviewed the support status of
,,
10 of the 60 supports that the CPRT had verified by
?
j[9idtct d> ,
..
researching the various records in the various vault
locations.
(d) Work Process Memoranda
.
Revision 3 to Procedure CPP-005 dated May 28, 1986, required
all ISAP VII.c populations to have a Work Process
Memorandum. This memorandum was to identify safety-related
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_
_ - _ _ -- --_ ,
.
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,
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0043.0.0-
h-
l
construction work processes and attributes that can be
Reinspected and/or ver'ified by document review.
j
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During this report period, the Work Proc 0ss Memoranda were
v 3
~
in the final draft stages; therefore, they will be reviewed
at a later date. This is an open item pending completion of
the Work, Process Memoranda (445/8702-0-01: 446/8702-0-01).
O
.
(e) Revisi ns
]
NRC review of all revisions to the Master Population Listi
,
Populat?on Descriptions, and the Population Items L"ist for
the three populations revealed'that the criteria' of
Section5.5ofProcedureCPP-0UPwere~beingadheredtoas
i
.
far as sign-offs for review and approval,' and control and
,
!
thaultinooftheLubsequentrevisions
'
.
,
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3
.
- "
,
't
_
to violatidono*r deviations were identified.
h
1
,
.%
l
(2) Pipe Welds /Matefial (PIWM)
,
'
, :3
- '-
4
s
!
This population was created by combining the two populations
1
a
.
which were previously titled Largg* Bore Pipe Welds /Materiale
%.
(LBWM) and Small Bore Pipe WeldssNaterial (SBWM).
In addition to
'
,'s"
n
.
this combination, mechanical equipment," site-made, pressure
'
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r
,
- t-
.e4
5
-
- y,
g
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,
1
4
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'g
.4
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.
.
0044.0.0
boundary welds were added to the PlWM population, and tubing
welds were organized into a separate pcpulation (TUWM).
(a) Population Description
NRC inspection verified that the systems listed by the CPRT
for inclusion in this population were designated in
Section 17A of the FSAR as safety related, either Safety
Class 1, 2, or 3, and Seismic Category I.
In reviewing
Table 17A, bewever, it was observed that the Boron Thermal
Regeneration System, Combustible Gas Control System, Post -
'
Accident Sample System, and the Plant Gas System were.not
i
listed in the CPRT Population Description, though they
should have been.
Subsequent review of the Population items
List, however, verified that these systems were included in
the population; they were, apparently. inadvertently left
, ,
out of the Population Description.
The hRC inspector cor. curs with the population boundaries,
items not included in the population, and specific
interfaces as listed in the Population Description.
.
(b) Master Population List
.
NRC review of the original Master Population List and all
subsequent revisions (one through five) verified that this
- _ - _ _ _ _ _ _ _ - _ _ _ _ _ - - _ _ _ _ _
4
.
0045.0.0
,
population was included on the list and that review,
approval, and control of the documents were per procedure.
(c)
Population Items List
The source document for the Population Items List was the
B&R Comanche Peak Craig Computer Tracking System (CCTS)
i
Report WEC-C-WE-REPORT issued June 12, 1985. This report
was a computer sort listirg all safety-related and QC'
accepted large and small bore pipe welds and instrument
tubing welds. The weld was considered QC accepted when
-
,
construction was complete and inspection holdpoints had been
accepted by QC as documented by QC signatures on the B&R
Weld Data Card (WDC).
.
)
1he WEC-C-WE-REPORT included a total of approximately 66,000
.
.
safety-related and construction-complete site-made welds.
]
To establish validity of the source document, the CPRT
performed the following reviews:
(1) Verified that the 591 site-made welds listed on the
ASME III N-5 Data Repor.t Index for the Unit 1 Auxiliary
Feed Water system were on the Population Items List.
i
____
_
___._________________m___
_ _ _
_ _ _ _ . _ _
_ _ _ . . _ _ _ _ _
__ _ _ _ _ _ . _ . . _ _ . _ _ _ _ _
_ . . _ . _ _ _ _ _ .
.
.
0046.0.0
I
l
(2) Reviewed all 26 Unit 1 BRP drawings for tie Residual
l
l
Heat Removal system and 26 randomly Folmeted Unit 2 BRP
l
drawings were listed on the Population items List.
l
f
(3) A review of 675 WDCs from several Unit 2 systems for
instrument piping welds was performed ano all welds'
were included.
(4) A review of the construction complete (C/I) status of
I
the source document and the review showed that most of
thedieselgenerator(Unit 1andUnit2)pipesite-made
,
welds had not been assigned a complete / incomplete
status under the C/I column. These welds were added to
l
I
the source document to complete the Population Items
j
l
List.
!
I
l
!
.
.
The NRC inspector initially compared the systems listed in
FSAR Table 17-A to the source document to assure
!
consistency. Next, the NRC inspector randomly selected
i
23 BRP drawings for Unit 1 and Unit 2 not previously
selected by the CPRT and verified that the 416 site-made
welds were included on the Population Items List. No
4
omissions were noted,
j
j
l
l
1
.
.
0047.0.0
To further verify accuracy of the CPRT approach,10 of the
52 BRP drawings reviewed t'y the CPRT were compared to the
source document.
No discrepancies were found.
,
(d) Work Process Memorandum
Revision 3 to Procedure CPP-005 dated May 28, 1986, required
all ISAP VII.c populations to have a Work Process
Herrorandum. This memorandum was to identify safety-related
construction work processes and attributes that could be
reinspected and/or verified by document review.
-
'
The Work Process Memorandum for PIWM was in draft form;
therefore, it will be reviewed at a later time. This is
another part of open item (445/8702-0-01; 446/8702-0-01).
.
(e) Revisions
NRC review of all revisions to the Master Population List.
Population Descriptions and the Population-Items List for
the PIWM population revealed that the criteria of
Section 5.5 of Procedure CPP-005 were followed.
No vio'.etions or deviations were identified.
,
(3) Concrete Placement (CONC)
_
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.
0048.0.0
I
The concrete placement population contained 7617 concrete pours
l
identified on a computer printout generated by B&R from concrete
!
pour cards.
)
l
l
(a) Population Descriptions
l
The NRC inspector reviewed ERC document QA/QC-RT-328,
Revision 0, " Population Description for Concrete Placement."
The population boundary included all Categcry I concrete
construction that had been completed and approved as of
August 1, 1985. The Category 1 structures were listed in'
i
1
Attachment A of the Population Description.
The NRC
inspector verified that Attachment A agrees with the FSAR,
Section 3.2.1.1.1, which also lists Category 1 structures.
AsubsequentreviewofthePopulationItemsList(seebelow)
verified that the list contained concrete pours from each of ,
j
,
the Category 1 structures listed in Attachment A.
The NRC
inspector concurred with the population boundary and the
items not included within the scope of the population. The
CPRT review and approval as well as the filing of the
Population Description were performed per Procedure CPP-005.
.
(b) Master Population List
NRC review of the Master Population List, Revision 5,
,
,
verified that the concrete placement population was included
.
.
0049.0.0
on the list.
Review, approval, and control of the Master
Population List was per Procedure CPP-005.
(c)
Population Items List
The NRC inspector reviewed ERC document 0A/QC-RT-1628,
Revision 1, " Population Items List Concrete Placement." The
population source was a 254 page computer printcut generated
)
{
from individual concrete pour cards by B&R. 1his list
j
i
included the ennerete pour number, date poured and a brief
'
description of the area poured for each of the 7617 concrete
,
pours in the population.
According to this document, the
population list " . . . includes all safety-related concrete
l
pours in Unit 1, 2 and areas conrnon to both units."
Attachment 6.3 of ERC Procedure CPP-005, Revision 3, states, .
in part, "The Responsible QA/QC Discipline Engineer . . .
Provides the basis for accepting the list as valio."
In
addition, "The QA/QC Lead Discipline Engineer and the QA/QC
l
'
Engineering Supervisor review Population Items Lists to
ensure that they are complete, accurate, and consistent with
the requirements of this procedure." ERC stated on the
i
Population Items List that the following three steps were
taken to validate the list:
1
)
-
i
0050.0.0
1
1)
Twenty arbitrarily chosen pour numbers identified on
B&R drawings were found to be on the population list.
)
2)
An arbitrary selection of concrete pours from
Inspection Report Logs were reviewed against the
population list and no discrepancies were identified.
3)
A review of the population list confirmed that no time
gaps were apparent in the pour dates.
The NRC inspector reviewed the steps taken by ERC to
-
,
validate the population list for concrete placement. Only
)
l
step 1 above was documented.
A handwritten, unsigne.1 and
undated memo describes the 20 concrete pours (10 from the
,
random sample and 10 from the safe shutdown sample) that
were verified by ERC to be on the population list. This
. .
represents only 0.26% of the total population of 7617. The
NRC inspector verified that the 20 concrete pours selected
1
by ERC were on the population list.
j
The NRC inspector prepared a randomly selected list of
134 concrete pours from 17 B&R drawings and compared this
]
q
list with the Population Items List to determine if the
1
134 concrete pours were included.
The following
j
discrepancies were discovered:
i
.
9
i
0051.0.0
1)
Pour Nos. 205-9810-039 through 205-9810-056 are shown
as block-out type pours in the east diesel generator
l
foundation, Unit 2, on Crawing 558-20655, Sheet 1,
l
Revision 5.
Pour Nos. 205-9810-040 and 205-9810-048
through 205-9810-056 were not on the Population Items
List and no corresponding pour cards could be obtained
in the TU Electric records center.
Pour
Nos. 205-9810-039 and 205-9810-041 through 205-9810-047
were assigned on drawings at least twice and are shown,
for exaniple, on Drawings 558-20605, Sheet 1,
f
Revision 7, and 5S8-20618, Sheet 1, Revision 2, to be-
i
concrete curbs, removable slabs, etc.; not block-outs.
Pour Nos. 205-9810-039 and 205-9810-041.through
205-9810-047 were on the Population Items List.
They
did not, however, represent the block-out pours in the
diesel generator foundation as determined by checking
, ,
the concrete pour cards.
The NRC inspector verified by
field inspections that the block-out pours had been
ir.s talled.
2)
Pour No. 205-4822-003 is shown as a shielding wall for
the Primary Sampling room on Drawings $58-20605,
~
Sheet 4A, Revision 0, and SSB-20605, Sheet 4,
Revision O.
This pour number was not on the Population
Items List.
A pour card for this pour was located in
the TV Electric Records Center. The NRC inspector
1
l
.
'
i
0052.0.0
)
i
!
J
verified by field inspection thet the shielding wall
'
had been installed.
.
The above discrepancies indicate that the Population Items
List is not entirely complete and accurate and does not
include ". . . all safety-related concrete pours in
Unit 1, 2 and areas common to both units," as stated. The
ERC review of the Population Items List to ensure accuracy
and completeness was inadequate. This is a deviation
I
f
(445/8702-D-02;446/8702-D-02).
a
I
(d) Work Process Memorandum
j
1
P.evision 3 to Procedure CPP-005 dated May 28, 1906, required
all ISAP VII.c populations to have a Work Process
i
Memorandum.
This memorandum was to identify safety-related
_
construction work processes and attributes that could be
i
reinspected and/or verified by document review.
]
The Work Process Memorandum for concrete placement was in
draft form; therefore, it will be reviewed at a later time.
This is another part of opencitem (445/8702-0-01;
446/8702-0-01).
'
(e)
Revisions
.
l
1
_ _ _ - - _ _ ___ __
- _ __ _
.
.'
0053.0.0
NRC review of all revisions to the Master Population List,
Population Descriptions and the Population Items List for
the concrete placement' population revealed that the criteria-
of Section 5.5 of Procedure CPP-005 were followed.
No other violations or deviations were identified.
(4) Electrical Populations
.
The NRC inspector reviewed the Population Items List
docurrentation for each of the electrical populations to determine
,
which sources were used to develop the population and the basis
for the CPRT determination that th'e developed popu.lation was
accurate.
The NRC inspector found that the conduit, cable, cable tray,
, ,
electrical equipment and NIS cable termination (CDUT, CABL, CATY,
EEIN, and NIST) population lists were generated'using the
TV Electric Electrical Management System (EMS) as a source.
EMS
was a computerized cable and raceway schedule developed by site
personnel to track the status of Unit 1. Unit 2, and Common
i
cables and raceways.
Cable and receway changes authorized by
designchangeauthorizations'(DCAs)wereenteredintoEMSona
daily basis. The EMS then provided a printout of these daily
changes on a Daily Activities Report.
Since EMS was neither a
required document nor controlled by procedures, the previous EMS
,
_
_
_
.
.
. _ .
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i
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l
0054.0.0
1
1
revisions and Daily Activity Reports had not been retained as
permanent plant records.
The NRC inspector observed that copies
i
of the EMS printouts which had been used by ERC for population
list development, were retained in the QA/QC Review Team fi?es in
the CPRT document control center.
I
The electrical cable (CABL) population was selected for a more
detailed NRC inspection to evaluate the implementation of the
appropriate precedures for establishing and accepting the
population.
l
.
,
(a) Population Description
I
The NRC inspector's review of the Population Description for
cables identified that the population was to include all
Class 1E, safety-related power, control and instrument
l
, ,
cables.
The population boundary for samples selected for
reinspection / documentation reviews was restricted to those
cables which had been installed, terminated on both ends and
QC accepted.
Excluded from the population were electrical
l
conductor seal assemblies, NIS cable connectors, and
unscheduled lighting (except for separation barrier material
inspections).
These three groups were excluded from the
cable population because they were included in other
t
populations.
The NRC inspector concurred with the
population boundary and the items not included within the
i
.
0055.0.0
scope of the population. The CPRT review and approval as
i
well as the filing of the Population D3scription was
performed per Procedure CPP-005.
l
(b) Master Popula' tion List
!
NRC review of the Master Population List, Revision 5,
verified that the electrical cable population was included
i
on the list.
Review, approval, and control of the Master
Population List was per Procedure CPP-005.
- )
!
-
1
,
1
(c) Population Items List
!
f
A comparison of the items documented in the Cable Population
l
Items List to the items required by CPP-005 was perforrred.
The list was divided into three parts: Population List
, ,
Source; Basis for Accepting the List; and Basis for
Accepting any Additional Items. The NRC inspector
determined that the provided information met the
requirements of CPP-005.
~
The Population List Source contained the listing and
description of the documents used to develop the listing of
applicable electrical cables.
The sources referenced were
'
the EMS cable report (ELE SAFETY RPT) dated June 17, 1985,
and the Gibbs & Hill (G&H) Lighting Panel Schedule, Drawings
l
l
.
'
i
0056.0.0
2323-El-0942-01 through -05 and E2-0942-01 through -03.
NRC
inspector review of these documents disclosso that Drawing
2323-E2-0942-03 does not exist.
The NRC inspector then
reviewed the file applicable to the Basis for Accepting the
List.
While no problems were identified with this file, the
NRC inspector questioned how the EPS was validated es a
complete source of applicable electrical cables. The NRC
inspector was informed that the QA/QC discipline engineer
responsible for the cable population had selected 30 cables
j
'
aach from the raceway schedules for Unit 1 and Unit 2
u
(2323-El-1700 and 2323-E2-1700) and then compared these
-
i
i
cables to the EMS listing he had used.
The NRC inspector
noted that the population included cables whi.ch were
deleted, spared, not yet QC accepted, not yet installed, and
those which may not be accessible, and that the validation
process was not a procedurally required formal process nor
, ,
was it documented.
The NRC inspector determined, however,
that the requirements of CPP-005 had been fulfilled in
,
i
establishing this population.
In an effort to evaluate the acceptability of the cable
population (which containedi ver 14,000 cables) the NRC
o
inspector chose an arbitrary sample of affected cables.
'l
Between 1 and 6 cables from each safety-related plant system
f
!
from the Unit I and the Unit 2 raceway schedules and
$
14 cables from the unscheduled lighting panel drawings were
I
.
.
I
0057.0.0
selected. This resulted in a sample which contained
i
125 cables from 55 systems in Unit I and 122 cables from
51 systems in tinit 2.
These cables were then compared to
the cable population list obtained from the QA/QC Review
Team Records Control Vault to provide assurance that the
population list used by ERC was complete.
The comparison of
l
these lists produced the following findings:
1)
The list of Essential and Emergency Lighting cables was
}
rot in the file,
,
'
i
l
l
2)
Pages 813 and 814 of the EMS listing were missing from
i
the file,
i
3)
Cable E0000425 was not included in the file list, and
4)
Cable E0135036 was shewn as EG135036 in the file list.
f
The NRC inspector then determined that: a copy of the list
of Essential and Emergency Lighting cables was available in
the electrical conduit population files; the missing EMS
pages were available from working copies; DCAs 18,100
and 10.547 authorized a designation change for cable
E0000425 to A0000425; and the improper separation train
designation (G vs. 0) for cable E0135036 was a data entry
error.
The NRC inspector found that the population list was
- _ - _ _ _ _ _ _ _ _
_ _ _ - _ _
.
4
0058.0.0
acceptable. However, the condition of the record files net
being complete as evidenced by 1) and 2) above is a
deviation from ERC Procedure CPP-004, " Project Working
Files," Revision 2, dated December 17, 1985 (445/8702-D-03;
446/8702-0-03).
(d) Work Process Memorandum
Pevision 3 to Procedure CPP-005 dated May 28, 1986,' required
all ISAP VII.c populations to have a Work Process
Memorandum. This memorandum was to identify safety-related
.
i
I
construction work processes and attributes that could be
reinspected and/or verified by document review.
)
The Work Process Memorandum for cable was only in draft
form; therefore, it will be reviewed at a 16ter date. This
.
is another part of open item (445/8702-0-01; 446/8702-0-01).
(e) Revisions
NRC review of all revisions to the Master Population List,
Population Descriptions and the Population Items List for
the cable population revealed that the criteria of
Section 5.5 of Procedure CPP-005 were followed.
.
.. _ . ..
. .
..
.
.
.
.
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.
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0059.0.0
No violations or deviations other than as discussed in (c),
above, were identified.
b.
Reinspection of HVAC Equipment Installation (HVIN)
'
l
Status of CPRT Activity
l
l
A total of 181 HVAC equipment packages were randomly selected and
inspected from a population of 604 packages representing Units 1,
2 and common. A total of 331 DRs were written with 187 determined to
be valid.
ERC has completed all planned HVAC equipment installation'
i
reinspection.
,
Status of NRC Inspection Activity
The NRC inspector reviewed the HVIN population with respect to HVAC
,
fire dampers and their inclusion in the population. The NRC inspector
identified that approximately 30% of the first and second sample were
fire dampers that were statused as " Abandoned In Place." This raised
a question with respect to the inclusion of nonsafety-related
eouipment in the population.
This was discussed with the population
engineer who provided the following inf'ormation.
Fire dampers are not
required for a safe shutdown but were included in the HVIN population
as an accessory connection and were reinspected to verify proper-
mounting and bolting, but not operability.
A visual inspection was
1
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.
- --
-
_ _ _ _ _ _ ,
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,
.
0060.0.0
l
also performed for configuration. This information was subsequently
l
included in a letter to file No. QA/QC-RT-5584 dated February 2,1987.
The NRC inspector found this to be consistent with ISAP VII.c
regarding population items list development.
The NRC inspector has previously witnessed four inspections and
performed five inspections, with no further inspection activity
planned for this population.
1
No violations or deviations were identified.
1
.
,
5.
ISAP Sample Selection Process
'
The purpose of this NP.C inspection was to determine whether the methods
used to select items and related documentation for reinspection or review
was performed in accordance with the requirements of the CPRT Program Plan, .
Appendix 0, Revisions 0 and 1 "CPRT Sampling Policy Applications and
Guidelines." Appendix D prescribes the various applications of sampling
within the CPRT program and defines guidelines for selecting samples
whenever random sampling techniques are used in ISAPs and Design Specific
ActionPlans(DSAPs).
This inspection was restricted to the review of ISAP
sample selections. The scope of the inspection covered electrical,
mechanical and piping, QA/QC, and the Quality of Construction ISAPs.
The
preoperational and testing ISAP sample selection was reviewed in a previous
inspection with results documented in NRC Region IV Inspection Report
50-445/85-18; 50-446/85-15.
Another activity previously inspected by the
(
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NRC fur compliance to Appendix D was the ERC Overview Inspection Program's
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sample selection.
Results of this inspection were documented in NRC
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Region IV Inspection Report 50-445/86-22; 50-446/86-20.
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The NRC approach used to review ISAP documentation and the inspection of
)
samples selected was: (1) to review the requirements identified in
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Appendix 0 and the applicable procedures, and (2) to verify implementation
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of the sample selection prccess by comparing the samples selected to the
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controlling commitments.
Samples were then reviewed to assure that: rancom
number selection and item number calculations were correct; items
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identified for inspection had a valid sample number and a random number
assignment; errors in the selection of items for inspection had been
resolved; departures from the sampling process had been identified;
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populations were clearly defined and segregated; acoitional sampling
,
required to achieve minimum sample size (based on population size increase)
was correct and documented; expansion of sample size, based on identified
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hardware deficiencies, conformed to requirements; and the sample selection
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process w6s suitably documented to provide an auditable trail,
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Of the 19 external source issue ISAPs considered for inspection,
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5 completed and 1 inprocess ISAP were inspected.
From ISAP VII.c, 5 of
31 inprocess populations were inspected.
The following are the results of
this NRC inspection.
a.
QA/QC ISAPs
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(1)
ISAP VII.a.2:
Nonconformance and Corrective Action (inprocess).
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This ISAP contained six populations, each requiring a separate
sample selection that would provide a 95/5 screen to detect
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programmatic or systematic deficiencies.
(The 95/5 screen or
sampling plan provides a 95% confidence that not more than a
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5% deficiency rate exists in the sampled population.) Of the six
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populations, the sample selection for NCRs covering the years
1975 to 1977 was reviewed by the NRC inspector. Twenty-one of
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the sixty-three selected samples were examined.
No errors were
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noted in random number calculations or sample item identification
from the population item list.
It was determined, based on the
NRC inspection, that the NCR sample selection conformed to
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Appendix D requirements.
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(2)
ISAP VII.b.2:
Valve Disassembly (complete).
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During the NRC's inspection of VII.b.2, no errors in the 95/S
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sampling plan were found.
The NRC inspector reviewed 21 of the
111 sample selections and found them to conform to Appendix D;
ERC's implementing Procedure QAI-002, Revision 2, " Sample
Selection"; and CPP-006, " Sample Selection." Prior to completion
and issuance of the VII.b.2 Results Report (RR) on March 19,
1986, ERC's QA/QC surveillance group and the Results Report
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Review Conmittee's (RRRC) review of sample selection identified
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errors in the selection process.
Corrective action by the ISAP
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issue coordinator included revising the Random Sample
Identification List and performing additional hardware
reinspection.
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b.
Electrical ISAPs
(1)
ISAP 1.a.1:
Heat Shrinkable Insulation Sleeves (Revision 1 of
the RR issued December 30,1986).
The NRC inspected 13 of the 111 samples selected for this ISAP.-
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From the CPRT reinspection of the initial 60 items randomly
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selected, provid'ng a 95/5 sampling plan, one was considered to
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be a defect requiring sample expansion.
As required by
Appendix D of the CPRT Program Plan, the sample was expanded by
an additional 35 randomly selected items.
Four of the additional
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thirty-five samples were found to be invalid and were deleted
because they represented locations that did not use heat
shrinkable insulation sleeves.
To reach the required expanded
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sample size, seven addit 1onal items were selected. Thus, the
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total valid samples selected by CPRT for reinspection was 98;
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however, during implementation ofcISAP I.a.2, " Inspection Reports
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on Butt Splices," 146 items were discovered th6t had been
inadvertently excluded from the original heat-shrinkable
insulation sleeve population.
Proportional sampling was used on
this additional population by selecting 12 of the 146.
The CPRT
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advisor on engineering statistics approved the use of this
proportional sampling which was not addressed in Appendix D of
the CPRT Program Plan.
Due to errors in the calculation of the random numbers, one item
that should have been inspected in the additional 35 items
selected had been omitted.
This item was, however, inspected and
is referenced in the working files as the " missed sample." With
the inspection of the " missed sample," the total number of valid
randomly selected items inspected was brought to 111 (the initial
98,12fromproportionalsampling,andtheone"missedsample").
i
Based on the review of sample selection documentation, detailed
inspection of 13 sample selections, and a review of other
sampling activities associated with this ISAP, the NRC inspector
determined that the 1.a.1 sample selection process confomed to
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Appendix D.
(2)
ISAP I.a.4:
Agreement Between Drawings and Field Terminations
(Revision 2 of the RR, issued July 23,1986).
Of all the ISAPs and VII.c populations using random sampling,
this ISAP used a 95/1 screen instead of 95/5.
Both screening
techniques are addressed in Appendix 0, Table 1.
As with
ISAP I.a.1, additional population items were discovered during
ISAP implementation.
Proportional sampling was again used and
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approved by the ERC engineering statistics advisor. Based on a
review of sample selection documentation and verifying in detail
the selection process (38 out of 383 selected items), the NRC
inspector determined that I.e.4 sampling conformed to Appendix D.
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c.
Mechanical ISAPs:
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(1)
ISAP V.a:
Inspection for Certain Types of Skewed Welds in NF
Supports (iiiiissuedOctober..
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22, 1986) C
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The NRC inspector examined in detail 16 of the 60 samples
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se'lected and found sample selection conformed to Appendix D;
however, three documentation inconsistencies were.noted between
the Random Sample Identification List (RSIL) and ERC Procedure
QI-006, Attachment 6.5, Revision 2.
Listed on Attachment 6.5
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were the 60 hangers inspected by ERC as taken from the RSIL.
The ,
inconsistency was not with the actual unique hanger number, but
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with the alphanumeric suffix character which indicates the type
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of hanger; i.e., A-anchor, S-spring, R-rigid, or K-snubber.
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Three hanger types were incorrectly coded as "K" instead of "R".
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The suffix characters also identify building, elevation, and code
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class.
From reviewing the actual packages inspected, the NRC
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irspector verified that the correct hangers were selected and
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inspected.
The ISAP V.a issue coordinator is in the prccess of
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correcting the documentation inconsistencies identified by the
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NRC.
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(2)
ISAP V.d:
Plug Welds (Revision 1 of the RR, issued December 18,
h)'.
This ISAP contained four populations.
Sample selection for each
population was based on the 95/5 screen.
The NRC inspector
examined 67 of the 750 sample selections from the 4 populations.
Eleven errors were found by the NRC inspector involving random
number calculations and item selections.
It should be noted that
prior to the issuance of the RR (Revision 1), the statistical
advisor reviewed 100% of this ISAP's sample selection.
Based on
this review,14 of the 250 samples had been identified with the-
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same type errors that the NRC inspector had identified.
These
14 errors included the 11 errors found by this NRC. inspection.
The scope of the statistical advisor's review of sample selection
is further discussed in paragraph e. below.
Based on results
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obtained from ERC inspections, plug weld testing, and bounding
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analysis performed by Ebasco, the statistical advisor determined
the errors found in the sample selection did not impact
inspection results nor was there a need to reopen the inspection
program. Since the errors resulted in a different item being
inspected and the statistical advisor's determination that the
sampling process was not compromised, it was not necessary for
these errors to be corrected.- This conclusion was supported by
referenced documentation which was found in the RR working file.
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d.
ISAP VII.c:
Construction Reinspection / Documentation Review Plan
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(inprocess).
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This ISAP is unique because the VII.c work activities are divided into
32 homogenous populations. On completion of all work activities, a
summary RR will be issued.
Details of reinspection and document
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reviews performed will be addressed as appendices to the summary RR.
At the time of this NRC inspection., the RR and associated appendices
were in their draft form and subject to various CPRT inprocess
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reviews; e.g., RP,RC, ERC engineering assurance and QA.
.
Thirty-one of the thirty-two populations used statistical random
sample selection with the 95/5 screen.
The NRC inspector examined
sample selections fer 5 of the 31 populations that used statistical
sampling.
From these 5 populations, 154 of the 502 sample items
selected were inspected for compliance to Appendix D of the CPRT
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Program Plan and ERC Procedure CPP-006, Revision 3, " Sample
Selection." Procedure CPP-006 was more prescriptive than Appendix D
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in that it provided ERC personnel with details for implementing the
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requirements for sample selection.
The five populations inspected by
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the NRC were: Cable Tray, Nuclear Instrument System Cable Termination,
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Electrical Equipment Installation, Instrumentation Equipment
Installation, and Large Bore Piping Configuration.
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Typical errors encountered were calculation of random sample number,
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use of duplicate random numbers; incorrect population item used;
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deviations from Appendix D not adequately documented; selection of
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items related to safe shutdown; and numbering of inspection work
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packages.
The potenc.ial impact of these errors was that not all items
in a given homogenous population had an equal chance of being selected
fer reinspection review.
Problems encountered that were not
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deviations from Appendix D or CPP-006 but made vtH fication of sample
selection difficult were; inadequate guidance for proportional
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sampling which was necessary when increases in population sizes were
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required methcdofnumberingPopulationItemLists;andinadequate
guidance for the resolution of problems encounter d during sample
selection.
These errors and problems are
rther iscussed below.
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e.
Sample Selection Review by the SRT
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The statistical advisor to the CPRT has conducted and is continuing to
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conduct reviews of ISAP sample selection.
By direction of the SRT,
the statistical advisor was required to conduct reviews of those ISAPs
and VII.c. populations using sample selection to assure conformance tc
Appendix D.
This requirement was delineated in CPRT' memorandum
CPRT-138 dated December 3, 1985, which the statistical advisor stated
is being implemented by a 100% review of the semple selection process
forallISAPsandVII.cpopulationsutilizingstatistjcalsampling.
To date, the statistical advisor has reviewed 100% of the samph
selection process for 9 cf 22 ISAPs and 19 of the 31 VII.c.
populations using statistical san:pling.
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A checklist was developed and used by the statistical advisor to
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perform the reviews and to document the findings and actions required.
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On complet%n of the' review, the issue coordinator or population
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engineer was given a copy of the checklist.
Each finding and the
i
actions required were discussed with the audited group. A formal
tracking mechanism to verify comhletion of actions required had not,
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as yet, beer. ceveloped or implemented.
From interviews with the
statistical advisor, a formal procedure and tracking system will be
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devekped and implemented to assure actions required are completed in
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a timely manner. This activity will be followed by the NRC as an open
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item (445/67C2-0-04; 446/8702+-0-04).
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Each of the errors and problems fcund by the NRC inspector had been
identified ar.o occumented by the statistical advisor.
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ToassurethatnoRRispublishedwyth'cpensampleselectionerrors,
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the RRRC revised its working file check ' list on February 17, 1987, to
require all open sampling errors identified against a RR be resolved
,
prior to RRRC approval of the working file and submittal of the RR to
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the SRT.
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f.
ERC's Review of ISAP brd VII.c Sample Selection
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(1) Engineering Assurance:
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ERC has established an engineering assurance (EA) group to
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perform final review and assembly of records and supporting
documentation (working file) required for ISAP VII.c prior to
turnover to the CPRT central file. This effort h overred by
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Procedure CPP-026, Revision 0, " Final Review of ISAP VII.c
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Working Files." EA had perfonned an initial review of VII.c
sample selection during July and August 1986. A written
checklist was used to direct the review and document findings for
follow-up. Several items remain open.
It should be noted that
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during the EA initial review of sample selection not all sample
selections were finalized.
Work was still inprocess to develop-
,
and complete some populations and perform sample selections.
The
final review by EA for sample selection was scheduled to start in
February 1987, but was contingent on Population Rancom Selection
Identification Lists being completed and approved.
(2) Quality Assurance:
The QA surveillance group had perfortned indepth reviews of sample
selection during surveillance of inprocess activities on ISAPs.
For example, in ISAP VII.b.2, a number of errors were detected by
QA prior to completion ano publication of the RR. The noted
errors were corrected and reviewed by QA for adequacy.
Surveillance report II CS06 documented QA's review of
VII.b.2 sample selection.
Rather than perform a 100% review of
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EA work, QA will review the EA ISAP V!I.c work on a sampling
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basis to assure the proc #s t conformed to procedural requirements.
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In addition to surveillance of ISAP sample selection, the ERC QA
audit group had perfo*wed two programmatic audits of the sampling
process as documer[fid in ERC audit reports ERC-P6-05 and
ERC-86-06.
No findings were noted in those audit reports.
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g.
Overview Qualfty Tecm (00T)
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' Baseheninteviewswith0QT,thesampleselectionprocessforseveral
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ISAPshavebeenoverviewedenacase-by-casebasis;howeser,nc
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indepth prograrratic review of ISAP sample selection was scheduled.
t$e responsibility for ISAP sample selection verification had been
placed with the CPRT statistical aavisor and the RRRC.
!
In sumrtary, of the 50 action plans using sample selection (19 external
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issue ISAPs and 31 VII.c populations), the NRC inspected 11 for conformance
to Appendix D.
From khe 11 action plans, 330 of the 1480 sample .selectione
were examined for erhors by the NRC inspector.
Foi those action plans
l
inspected, the sample selection efforts were found to conform to
s
' ppendix D.f Those errors in the sampling process that were identified by
A
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the NRC inspector had also been identified by the CPRT statistical advisor
_
ar.d action to correct or (Ts(osition the errors had either been taken or
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was being taken.
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0072.0.0
At present, the statistical advisor does not have a system to verify the
completion of action required to correct or disposition idertified errors.
I
A comitment has been made to develop and implement such a system. This
comitment will be followed as a NRC open item.
>
No violations or deviations were identified.
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6.
Exit Interview
Exit interviews were conducted February 10, 1987, ard March 3, 1987, with
the applicant's representatives identified in paragraph 1 of Appendix C of.
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this report. During these interviews, the NRC inspectors sumarized the
scope and findings of the inspection. The applicant acknowl. edged the
findings.
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