IR 05000445/1987029
| ML20237D744 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/16/1987 |
| From: | Hale C, Livermore H NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20237D723 | List: |
| References | |
| 50-445-87-29, 50-446-87-21, NUDOCS 8712240161 | |
| Download: ML20237D744 (14) | |
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APPENDIX B
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NUCLEAR REGULATORY COMMISSION.
OFFICE OF SPECIAL PROJECTS NRC Inspection Report:
50-445/87-29 Permits: 'CPPR-126-50-446/87-21 CPPR-127 Dockets: 50-445 Category: A2 50-446 Construction Permit Expiration Dates:
Unit 1: August 1, 1988 Unit 2: Extension request'
submitted.
L, Applicant:
TU Electric Skyway Tower 400 North. Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name:
Comanche' Peak Steam Electric Station (CPSES),
Units 1 & 2 Inspection At:
Comanche' Peak Site, Glen Rose, Texas Inspection Conducted:
November 4 through December 1,.1987 b
Inspector:
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C. J.(Hgle~, Reactor Inspector Date Consultants:
EG&G - V. Wenczel (paragraphs 3 and 4)
Parameter - J. Birmingham.(paragraph 2)
Reviewed by:
R F IL) d 4
/2-A-F7 H. H.
Livermore, Lead Senior Date q
Inspector
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B712240161 871216 PDR ADOCK 05000445 G
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Inspection Summary:
Inspection Conducted: November 4 through December 1, 1987 (Report 50-445/87-29; 50-446/87-21)
Areas Inspected: Nonroutine, unannounced inspection of the Comanche Peak Response Team (CPRT) issue-specific action plan (ISAP),VII.a.9, allegations, the CPRT deviation reporting program, and general plant areas (tours).
Results:
Within the four areas inspected, no violations and one deviation (CPRT inspector error during inspection of turbine driven auxiliary feedwater pump, paragraph 2.b) were identified.
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- DETAILS 1.
Persons Contacted
- R.
P. Baker, Engineering Assurance (EA) Regulatory Compliance Manager, TU Electric
- R.
D. Best, Nuclear Operations Inspection Report Item Coordinator, TU Electric
- D.
N. Bize, EA Regulatory Compliance Supervisor, TU Electric J. D.
Christensen, Deputy Review Team Leader, Evaluation Research Corporation
- J.
T.
Conly, Lead Licensing Engineer, Stone & Webster Engineering Corporation
- C.
G.
Creamer, Instrumentation & Control Engineering Manager, TU Electric
- R.
D. Delano,-Licensing Engineer, TU Electric
- P.
E. Halstead, Manager, Quality Control (QC), TU Electric
- T.
L. Heatherly, EA Regulatory Compliance Engineer, TU Electric
- D.
A. Hodge, CPRT Interface, TU Electric
- R.
T. Jenkins, Manager, Mechanical Engineering, TU Electric
- J.
J. Kelley, Manager, Plant Operations, TU Electric
- J.
J. LaMarca, Electrical Engineering Manager, TU Electric
- O. W. Lowe, Director of Engineering, TU Electric
- D.
E. Noss, QA Issue Interface Coordinator, TU Electric G. R. Purdy, Site QA Manager, Brown & Root (B&R)
- D. M. Reynerson, Director of Construction, TU Electric
- M.
J. Riggs, Plant Evaluation Manager, TU Electric
- A. B. Scott, Vice President, Nuclear Operations, TU Electric
- C.
E.
Scott, Manager, Startup, TU Electric H. M. Sigrest, Engineering Assurance Supervisor, CPRT
- J.
C.
Smith, Plant Operations Staff, TU Electric
- J.
F.
Streeter, Director, QA, TU Electric
- C.
L. Terry, Unit 1 Project Manager, TU Electric
- T.
G.
Tyler, Director of Projects, TU Electric C. W. Vincent, Issue Coordinator, CPRT The NRC inspectors also interviewed other applicant employees during this inspection period.
- Denotes personnel present at the December 1, 1987, exit interview.
2.
CPRT ISAPs Adequacy of Purchased Safety-Related Material and Equipment (ISAP VII.a.9) (35065)
During this report period the following activities for ISAP VII.a.9 were reviewed by the NRC inspector.
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a.
Select Material / Equipment to be Reviewed (NRC Reference 07.a.09.01)
Revision 1 of ISAP VII.a.9 stated that the primary objective of the action plan was to evaluate selected safety-related purchased material and equipment installed at CPSES.
The evaluation was to determine to what extent purchased material and equipment at CPSES complied with the procurement requirements and physical design characteristics as specified by TU Electric and/or the vendor.
To accomplish their objective, the CPRT:
(1) identified the vendors of equipment and material addressed in the safety-related procurement design specifications; (2) selected from this group those vendors considered to meet the ISAP criteria described i
below; (3) selected specific material and equipment for evaluation; and (4) developed verification packages containing verification package contents list, reinspection / documentation review checklist, implementing inspection instructions, drawings, and other necessary inspection documents.
Completed verification packages also included letters of memorandum and deviation reports relative to the items inspected.
Additionally, a letter of memorandum was maintained in the working file for each package detailing those attributes intended to be verified and the justification for not verifying attributes excluded from verification; e.g.,
inaccessible items or dimensions for reference only.
The verification packages may have been developed for a single item such as a level indicating switch or for multiple types of the same item such as three types of we2d rods.
A total of 81 verification packages were developed for inspection in ISAP VII.a.9.
The criteria used for the selection of the material and equipment evaluated was provided in Section 4.1.2 of the i
ISAP.
The criteria was designed to provide a reasonable cross section of the safety-related purchased material and equipment installed at CPSES.
The NRC inspector reviewed the criteria of Section 4.1.2 which included items such as: design complexity, method of manufacture, type of equipment, material or equipment identified by CPSES or the NRC to have had past problems, and a requirement that items selected be representative of the time periods that material was procured for CPSES.
The NRC inspector then reviewed the list of items selected by CPRT to be evaluated for conformance to this criteria.
The NRC inspector determined that the list of items selected met the criteria of Section 4.1.2 in that:
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(1)
The items selected were a reasonable representation of the types of material and equipment installed.
15% civil / structural
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30% mechanical
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50% electrical /I&C
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5% welding
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Note:
The Nuclear Steam Supply System provided under the Westinghouse QA program was not included in the scope of ISAP VII.a.9.
(2)
More than half the items selected were the subject of CPSES or NRC reports identifying that the material or equipment had past problems.
This determination was based on the NRC inspector's review of past TU Electric audit reports, corrective action reports, significant deficiency analysis reports; and NRC notices, bulletins, and inspection reports.
(3)
The items selected ranged from those of fairly simple design (i.e., structural rebar, plate steel)
to those of a complex design requiring evaluation by more than one discipline (i.e., the turbine driven auxiliary feedwater pump and the component cooling water chiller).
The NRC inspector deems the inclusion of items of simple design to be appropriate since they were among the earliest items procured for CPSES and since they comprise a significant volume of the safety-related purchased material and equipment installed at CPSES.
(4)
The items selected represent various methods of manufacture; e.g.,
machined valve bodies, cast pump housings, and assembled electrical components manufactured by a variety of physical / chemical processes.
(5)
The items selected were representative of the time frames during which procurement of the material or equipment took place.
This attribute was verified during NRC review of a sample of the verification packages.
i Based on the above, the NRC inspector considers the criteria for the selection of purchased material and equipment, as defined in Section 4.1.2 of the ISAP, to have been appropriate and properly implemented by the CPRT in their selection of items for evaluation.
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No violations or deviations were identified.
No further NRC inspection of this reference item is planned.
b.
Develop Reinspection Checklist for Material and Equipment Selected (NRC Reference 07.a.09.02) and Perform Field
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Inspection of Selected Material and Equipment (NRC Reference 07.a.09.03)
This activity was previously reported in NRC Inspection Reports 50-445/86-31; 50-446/86-25 and 50-445/87-11; 50-446/87-09.
At that time, the NRC inspector had inspected seven of the CPRT verification packages for ISAP VII.a.9.
The packages previously inspected were:
I-M-VII.a.9-016 Air Accumulator I-M-VII.a.9-027 Control Valve I-M-VII.a.9-032 Level Indicating Switch I-M-VII.a.9-052 Air Accumulator l
D-W-VII.a.9-084 Weld Filler Material
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D-C-VII.a.9-099 High Density Aggregate D-E-VII.a.9-108 Electrical Cable The results of NRC inspection of Verification Package I-M-VII.a.9-050, " Component Cooling Water Chiller Unit,"
also previously inspected by the NRC, will be reported when activities by the CPRT on this item are complete.
During this report period, one additional verification package was inspected by the NRC, I-M-VII.a.9-082,
" Auxiliary Feedwater Pump."
The results of the NRC inspection of that package follows.
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Verification Package I-M-VII.a.9-082 This CPRT verification package was prepared for a documentation review and field inspection of the Unit 1 turbine driven auxiliary feedwater pump.
This item is identified by the equipment Nos. cpl-AFAPTD-01 (pump and
?ontrol panel) and CP1-MSTDAF-01 (turbine driver).
The pump and turbine were procured on purchase order CP-0007 and received on receipt inspection reports RIR-7948 and RIR-8734.
The procurement requirements were defined in Gibbs and Hill (G&H) Specification 2323-MS-007, Revision 1.
The NRC inspector reviewed the G&H specification and the CPRT checklist for this package.
The NRC inspector determined that the checklist properly included
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l inspection attributes such as:
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(1)
Verification that ASME Section III, " Subsection NF Welds," were of acceptable quality and were in accordance with the applicabic drawing.
(2)
Verification that the structural dimensions of the bedplate and the support pads for the pump and turbine were within the tolerances specified on the applicable drawings.
(3)
Verification that documentation required by the G&H specification was available and acceptable.
(4)
Verification that documentation required by the ASME code for pressure boundary parts (i.e., certified material test reports, hydrostatic test reports, NDE test reports, heat treatment records, and ASME code certification) was available and acceptable.
(5)
Verification that the accessory components such as the oil cooler, pressure switches, thermowells, and the piping necessary to install the accessories were of the size and type required by the specification and the vendor drawings.
l Utilizing the CPRT checklist, the NRC inspector reviewed I
the documentation in RIRs-7948 and -8734 and performed a l
field inspection cf the Unit 1 turbine driven auxiliary feedwater pump.
The results of the NRC inspections were
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the same as the CPRT inspection results with one exception.
The NRC inspector determined that the CPRT had incorrectly verified that a 3/4" NPT opening was provided when in fact a 1/2" NPT opening existed.
The failure of the CPRT inspector to identify this nonconformance has been identified as a deviation (445/8729-D-01).
During review of the checklist for package I-M-VII.a.9-082, the NRC inspector noted that verification of certified performance test results and seismic analyses were not included.
This omission was discussed with the ISAP VII.a.9 issue coordinator.
From this discussion, the NRC inspector determined that the issue coordinator trends the results of the verification package inspections and had noted the same omission.
The issue coordinator stated he was preparing a supplemental inspection to address this attribute.
Pending the completion of the supplemental inspection this is an open item (445/8729-o-02; 446/8721-0-01).
No other violations or deviations were identified for this package.
Except for follow up of the identified I
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1 deviation and open item, no further inspection of this verification package is planned.
c.
Develop Procurement Program Review Checklist (NRC Reference 07.a.09.05)
Section 4.1.3 of ISAP VII.a.9, Revision 1, required the CPRT to evaluate the current CPSES procurement program.
The evaluation would determine the extent to which the current program was in compliance with the regulatory requirements of 10 CFR Part 50, Appendix B, and the commitments contained in the CPSES FSAR Sections 17.1.4,
" Procurement Document Control"; 17.1.7, " Control of Purchased Material, Equipment, and Services"; 17.1.10,
" Inspection"; and 17.2.13, " Handling, Storage and Shipping."
To accomplish this task CPRT reviewed the controlling documents for the procurement program and prepared a checklist of 78 attributes for verification.
The documents reviewed were:
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The NRC inspector compared the checklist attributes to the criteria contained in the controlling documents.
The checklist was found to contain attributes such as:
(1)
Does the program define the sequence of actions accomplished in the preparation of procurement documents?
(2)
Does the program require that procurement documents include, as applicable, provisions for source inspection and audit, including access to plant facilities and records?
(3)
Does the program require documentary evidence that material and equipment conform to procurement requirements be available at the plant site prior to installation or use?
By comparison of the CPRT checklist attributes to the controlling documents, the NRC inspector determined that
the CPRT checklist addressed the criteria of the controlling documents.
The CPRT then reviewed the procurement program procedures utilizing the checklist.
Their review results identified l
the implementing procedures in which each attribute was
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The procurement program implementing procedures are those applicable to TU Electric construction, startup, and operations and B&R construction.
In all, over 80 procurement related procedures were reviewed by CPRT.
The NRC inspector reviewed 18 checklist attributes against the procedures in which the attributes were addressed to determine if CPRT had properly conducted their review.
No discrepancies were found during the NRC review.
Based on this review of 18 checklist attributes, the NRC inspector considers the CPRT review to have been properly implemented.
The CPRT evaluation of the results of their procurement program review will be inspected and reported by the NRC inspector when it is completed.
3.
Assessment of Allegations (99014)
(Closed) Allegation (OSP-86-A-153):
An allegation was received that a B&R employee in the document review section should be retested because the original test was conducted improperly.
Concern Specifics This alleger (Individual A) was concerned with the method which was used to administer a multiple choice oral examination to a B&R employee (Individual B).
Specifically, when Individual B gave an incorrect answer, the question was repeated until the correct answer was identified.
It should be noted that the subject testing is one prerequisite to Individual B's certification as an
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ASME pipe and equipment documentation reviewer.
Assessment The NRC inspector's approach to the assessment of this allegation was to: (1) determine the requirements for testing personnel performing documentation reviews (prior to certification), and (2) verify that Individual B was tested in accordance with certification requirements.
To determine the requirements for testing documentation review personnel, the NRC inspector reviewed B&R Procedure QI-QAP-2.1-5, Revision 5, dated January 20, 1984, " Training and Certification of Mechanical Inspection Personnel."
This procedure was applicable during the time frame of the allegation (March to June 1984).
The procedure establishes the minimum qualification, training, testing, and certification
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requirements for personnel performing ASME pipe and equipment documentation reviews.
It was found that
written tests for documentation reviewers included general and specific questions.
A score of 80 percent was required for certification.
Testing requirements did j
not permit nor prohibit oral examination based on the written questions.
Oral exams appear to have been used when certification candidates were intimidated by written exams.
This practice is no longer used; all certification candidates are required to take written exams.
The NRC inspector reviewed the certification file for Individual B and found certification was based on three months of on-the-job training, 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> of classroom training, and a test score above 80 percent.
The subject test was a written exam which was administered orally by the B&R site mechanical Level III inspector and a designee.
The Level III would ask Individual B the test-questions, and the designee would record the answers.
The test answer sheet documented how the exam was administered.
The test included several questions which had more than one correct answer. This may have led to oral exchanges between the Level III inspector and Individual B, giving the impression that questions were being repeated until Individual B identified the correct answer.
From a review of the Individual B's test results, the NRC inspector could not substantiate or refute the claims made by Individual A.
In any event, Individual B was decertified at the expiration of that certification (June 7, 1987) by a written examination and demonstrated proficiency.
The NRC inspector interviewed the B&R site QA manager to obtain the following information.
The work that Individual B performed since initial certification was that of reviewing completed ASME documentation packages prior to their submittal to the ASME Authorized Nuclear Inspector (ANI) for his review.
Each of these ASME
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document packages received a 100% review by the ANI.
l According to the site QA manager, Individual B's immediate supervisor also overviewed work performed by Individual B and found Individual B's work to be satisfactory.
Conclusion The allegation was neither substantiated nor refuted; however, evidence was found that Individual B had been tested and certified in accordance with the requirements of B&R Procedure QI-QAP-2.1-5, Revision 5.
In addition, Individual B has satisfactorily achieved decertification
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based on written tests in accordance with more current procedures and demonstrated proficiency.
This allegation is closed.
4.
Inspection of ERC Deviation Reporting Program (35061)
The purpose of the NRC inspection was to determine whether methods for the processing and control of deviations classified as invalid or cancelled were performed in accordance with Evaluation Research Corporation (ERC)
Procedure CPP-010, Revision 8,
" Preparation of Deviation Reports."
The following is a sumr.ary of CPP-010 deviation reporting process, the method used by the NRC to inspect the deviation process, and the inspection results.
a.
CPP-010 Deviation Reporting Process ERC's QA/QC inspection personnel performed field reinspection of plant safety-related hardware and reviews of associated documents in accordance with specified acceptance criteria.
A deviation report (DR)
was initiated for any apparent difference (deviation) in l
an inspection attribute from that defined as acceptable.
l The initiator of a DR was required to provide, among other things, a description of the deviation observed, the acceptance criteria violated, item effected (hardware or documentation), observation date, and initiator's name.
The DR was then reviewed by the first reviewer (lead inspector or lead engineer, as applicable).
The first reviewer determined if the DRs accurately documented the applicable criteria and the condition which caused the initiation of the DR.
Further, the first reviewer would assure that the DR was complete and consistent with the requirements of CPP-010.
If the first reviewer disagreed with the initiator's assessment of the identified condition, justification was provided for invalidating the DR and concurrence was obtained from the initiator in writing.
Should the originator disagree with the first reviewer's determination, the DR review was escalated in the review chain until resolution of differences was obtained.
The QA/QC review team leader (RTL) was the final arbitrator of any unresolved differences.
Upon completion of the first review, the DR was submitted to the second reviewer (a lead discipline engineer, the Issue Coordinator, or the QA/QC RTL).
The second reviewer provided conformation of the first reviewer's determination or made assessments relative to disagreements between the originator and the first reviewer.
To confirm the first reviewer's determination,
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the second reviewer evaluated the reported deviation for validity based on the following criteria: (1) conformance to the applicable approved design; (2) exemption based on subsequent design changes; (3) the reported condition was previously documented on applicant or contractor deficiency reporting mechanisms (e.g., nonconformance reports [NCRs], deficiency reports, or construction deficiency reports; and (4) conformance with safety analysis reports or regulatory requirements.
Should the condition be determined to be invalid, for any of the above reasons, the second reviewer recorded on the DR the justification which supported the conclusion and obtained written concurrence from Lhe originator and the first reviewer.
Valid DRs were forwarded to, among other recipients: (1) safety significance evaluation group for further evaluation in accordance with CPP-016, " Safety Significance Evaluation of Deviation Reports;" and (2) the applicant to be entered into the applicant's nonconformance reporting system for resolution.
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Deviations related to the qualifications of the inspector of record (applicant inspector) were transferred by the-second reviewer to the ISAP I.d.1 Issue Coordinator for validation processing in accordance with ISAP I.d.1 requirements described in CPP-025, Revision 1, "QC Inspector Qualification Evaluation."
Cancellation of previously validated and issued DRs was provided for should there be documented evioence supporting the DR cancellation.
The cognizant QA/QC discipline engineer assured that the recipients of a valid DR were advised by memorandum of the DR cancellation.
The memorandum provided the basis for the cancellation and was routed for review and approval to the same organizations that performed the previous review and approval, b.
NRC Inspection i
To verify implementation of CPP-010 with respect to processing and controlling those DRs determined to be invalid or cancelled, the NRC inspector selected 405 DRs for inspection.
These DRs were selected from ISAP VII.c because this ISAP deals with the CPRT's reinspection of plant hardware and related documentation.
For VII.c, approximately 13,000 safety-related DRs were written; of which 4905 were classified as invalid or cancelled.
Of the 405 DRs inspected by the NRC 149 DRs were invalidated by first and second reviewers, 105 DRs were invalidated by the ISAP I.d.1 issue coordinator, and 151 DRs were cancelled by the cognizant VII.c discipline engineers.
Valid DRs were excluded from this inspection because they were entered into the applicant's nonconformance
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reporting program which has been inspected by the NRC.
Results of the NRC's inspection of the NCR program were documented in Inspection Reports 50-445/87-13; 50-446/87-10 and 50-445/87-16; 50-446/87-13.
c.
Inspection Results
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The NRC inspector determined that each of the 405 DRs inspected were processed and controlled as required.
For the 149 DRs invalidated by the first or second reviewer, justification for invalidation was either written on the body of the DR or attached.
In each case, concurrence was obtained in writing from the originator.
The 105 DRs invalidated by the ISAP I.d.1 issue coordinator were determined by the NRC to have been properly transferred to the ISAP I.d.1 issue coordinator and processed in accordance with CPP-025.
In each case, adequate justification and documentation were provided to substantiate the qualifications of the inspector in question were valid.
The 151 DRs cancelled by the discipline engineers were determined by the NRC inspector to have been processed in accordance with CPP-010 except for one DR.
This DR was not marked " cancelled" nor was the letter providing the basis for the cancellation attached to the DR.
Further inspection of this matter by the NRC found: (1) the computer generated report, which identifies the status of
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all DRs had properly annotated that this DR was
" cancelled"; (2) the Safety Significance Evaluation file contained the letter providing the basis for the DR cancellation; and (3) the Results Report did not identify this DR as being valid.
The lack of writing " cancelled" on the face of the DR did not impact the conclusions made in the results report since the other methods properly identified the DR as cancelled.
Further, the review by the NRC inspector of the other 150 cancelled DRs disclosed that this condition was apparently an isolated case of a clerical error, which was promptly corrected.
The foregoing inspection of ERC's processing of invalid and cancelled DRs did not identify any significant problems.
No violations or deviations were identified.
5.
Plant Tours (92700)
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The NRC inspectors made frequent tours of the Unit 1, Unit 2, and common areas of the facility to observe items such as housekeeping, equipment protection, and in-process work activities.
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With the increased-activity in Unit 1, the NRC inspector noted numerous pieces of small-equipment 1(snubbers, gages, etc.)
that were not being protected against damage.
This condition was brought to the attention of construction' management and
' personnel were immediately assigned to survey the area and install protection where necessary.
One week later, the NRC-inspector toured the area again and found' improvement in the protection of this small equipment, but progress in this area appeared slow.
On November 23, 1987, a meeting-was. held with construction and operations management to discuss-this concern.
Construction management committed to intensifying
. efforts t-o protect Unit 1 equipment and to increase surveillance and personnel awareness concerning damage to instclled equipment.
During the NRC inspectors' routine plant tours in the future, the protection of installed equipment will continue to be-inspected to assure that proper equipment'
protection is achieved and is being maintained.
6.
Open Items open items are matters'which have been discussed with~the applicant, which involve some action on the part of the.NRC or applicant or both.
One open item disclosed during this inspection is discussed in paragraph 2.b.
7.
Exit Interview (30703)'
An exit interview was conducted December 1, 1987, with the applicant's representatives identified in paragraph 1 of this report.
During this interview, the NRC inspectors summarized the scope and findings of the inspection.
The applicant acknowledged the findings.
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