IR 05000445/1987010
| ML20236H026 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/31/1987 |
| From: | Phillips H, Warnick R NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20236G968 | List: |
| References | |
| 50-445-87-10, 50-446-87-08, 50-446-87-8, NUDOCS 8708050035 | |
| Download: ML20236H026 (15) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS NRC Inspection Report:
50-445/87-10 Permits: CPPR-126 50-446/87-08 CPPR-127 Dockets: 50-445 Category: A2 50-446
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Construction Permit Expiration Dates:
Unit 1: August 1, 1988 Unit 2: August 1, 1987 Applicant:
TU Electric l
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:
May 10 through July 7, 1987 Inspector:
< /M/
7/3M87
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H. S.'Phillips," Senior Resident Reactor Date l
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l Inspector, Construction
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i Reviewed by: }?F/ )
7/3//77 l
l R. T. Warnick, Assistant Director for
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Inspection Programs l
Comanche Peak Project Division Office of Special Projects 870B050035"B70731 i
PDR ADOCK 05000445 i
G PDR
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f Inspection Summary Inspection Conducted: May 10 through July 7, 1987 (Report Nos.
50-445/87-10; 50-446/87-081 Areas Inspected:
Routine, unannounced safety inspection including (1) significant meetings; (2) applicant action on previous inspection findings; (3) applicant action on 50.55(e) deficiencies; (4) applicant action on IE Bulletins; (5) general plant inspections; and (6) saftey-related components.
Results:
Within the areas inspected, no violations or deviations were identified.
A management meeting was held on June 24, 1987, to resolve the NRC's concern with the lack of timely evaluations to determine deportability under 50.55(e) (paragraph 2).
A meeting was held on June 25, 1987, to resolve the NRC's concern Uith site control of system cleanliness (paragraph 2).
One unresoAved item was identified regarding the applicant's failure to report motor fans being installed backwards on auxilliary feedwater pump motors (paragraph 7).
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DETAILS
1.
Persons Contacted
- R.
P. Baker, Regulatory Compliance, Manager, TU Electric (TUE)
- J.
L. Barker, Engineering Assurance Manager, TUE
- M.
Blevins, Technical Support. Manager, TUE
- W. G. Counsil, Executive Vice President, Nuclear Engineering i
and Operations (NEO), TUE
- R.
D. Delano, Licensing Engineer, TUE j
- D.
E. Deviney, Operations Quality Assurance (QA) Manager, TUE i
- T.
L. Heatherly, Regulatory Compliance Engineer, TUE
- J. Hicks, Licensing, TUE
- J. J. Kelley, Plant Operations Manager, TUE
- 0.
Lowe, Engineering Director, TUE f
- L.
D. Nace, Vice President, Engineering and Construction, TUE
- D.
Noss, QA, TUE j
- D. M. Reynerson, Director of Construction, TUE
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- J.
Redding, Executive Assistant, TUE
- C.
E. Scott, Startup Manager, TUE
- J.
C. Smith, Plant Operations Staff, TUE
- P. B. Stevens, Electrical Engineering Manager, TUE
- J. F. Streeter, Director of QA, TUE
- B. Taylor, Maintenance Manager, TUE
- C.
L. Terry, Executive Assistant, TUE
- R. D. Woodlan, Licensing Supervisor, TUE The NRC inspectors also interviewed other' applicant employees during this inspection period.
- Denotes personnel present at the July 7, 1987, exit interview.
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- Denotes personnel present at June 25 meeting and July 7, 1987, exit.
- Denotes personnel present only at the June 25, 1987, meeting..
2.
Management Meetings (30702)
a.
On June 24, 1987, C.
I. Grimes, R. F. Warnick, and H. S. Phillips met with W. G. Counsil, L. D. Nace,
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J. F. Streeter, and other TUE staff to discuss the NRC's concern with the applicant's lack of timely initiation of
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the evaluation to determine the deportability of a
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deficiency per the requirements of Part 10 CFR 50.55(e).
As a result of this discussion the applicant and the NRC agreed to the following:
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Deficiencies in ongoing work will be prcmptly
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screened for deportability per 50.55(e),
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(2)
Deficiencies in old work will be categorized by existing generic 50.55(e) reports, and j
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Deficiencies in old work that do not fall under existing generic 50.55(e) reports will be categorized into new 50.55(e) reports as appropriate.
This program will constitute the basis for a request for an exemption to 50.55(e).
b.
On June 25, 1987, R. F. Warnick, H. S. Phillips, and D.
L. Kelley of the NRC met on site with J. J. Kelley, j
M. Blevins, O. Lowe, D. M. Reynerson, C. E. Scott and
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others on the applicant's staff.
The purpose of this me= ting was to discuss responsibilities and Interfaces i
between operations /startup and construction organizations
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onsite.
Specifically, the discussion concerned fluid system cleanliness, housekeeping as relates to
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controlling material and personnel entering the primary system, and protection of equipment during and after construction is completed while stored in-place in both units.
The protection of equipment in Unit 1 was emphasized and the apparent lack of protection during rework.
Several examples of unidentified material in unmarked containers in Unit 1 were discussed.
(See paragraph 6 of this report.)
TUE staff informed the NRC that based on the utility's review of system cleanliness controls including NRC concerns, a stop work order was issued for Unit 2 on
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June 25, 1987.
The applicant indicated that it's review disclosed some shortcomings in the existing procedure and no overall guiding cleanliness specification.
As a result, the applicant committed to revise the procedure and issue a cleanliness specification.
The stop work remained in effect until June 29, 1987, when an interim
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procedure concerning the protection of the primary system and selected secondary components was issued and in effect.
3.
Applicant Action on Previous Inspection Findings (92702)
The NRC inspector reviewed TUE Engineering Assurance's master open items list and reconciled it with the NRC's tracking system for open items (violations,-deviations, unresolved items, and open items).
Existing errors were corrected.
The following items were selected from this list and were inspected and closed.
a (Closed) violation (446/8309-V-03):
The NRC inspector found that a base metal repair was made adjacent to weld FW2RB-025-SW2Rl(W8) and documented on the back of the weld data card (No. 680'_97).
It was not documented on a i
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noncorformance report as required by site Procedure QI-QAp-16.1-2, Revision 4.
The NRC inspector reviewed the corrective action file and verified that nonconformance report M-6611 was written May 6, 1983 to document the base metal repair.
b.
(closed) Violation (445/8507-V-01; 446/8505-V-01):
Failure to promptly correct problems with RTE-Delta Potential Transfer Tiltout Subassemblies.
The NRC inspector previously performed and documented follow-up inspection of this item in NRC Inspection Report 50-445/86-28; 50-446/86-23.
This item was left open pending the receipt and review of a supplemental response requested by NRC letter, dated December 30, 1986.
The TUE letters (TXX-6211), dated January 28, 1987, and (TXX-6349), dated March 27, 1987, provided information relative to why a nonconformance was not written and the corrective action to preclude this from happening in the future.
The inspector's concerns were adequately addressed in the supplemental responses, c.
(Closed) Violation (445/8507-V-03):
The voltage recorded l
on Westinghouse Quality Release (QR) for hydrogen recombiners was outside the specified range but the
quality control inspector accepted the QR as satisfactory.
The NRC inspector previously reviewed the corrective acrton file; however, documentation was considered incomplete until a supplemental response uas received from TUE.
Two TUE responses (TXX-6211, dated January 28, 1987, and TXX-6284, dated February 20, 1987) provided additional information in the file which shows completed corrective actions by TUE and Westinghouse as described in Westinghouse letter (WPT8751), dated February 13, s
1987.
The revised TUE response indicated the deviation
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was addressed in QR N-41424, Revision 1, and Deviation i
Notice 26961, dated June 8, 1984.
d.
(Open) Violation (446/8509-V-02):
Procedures did not address material / personnel control to prevent contamination with materials such as mercury.
The NRC inspector inspected Unit 2 relative _
material / personnel control during the inspection period l
October 1 through November 30, 1986, which was documented j
in NRC Inspection Report 445/86-28; 446/86-23.
The
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proposed corrective action appeared to be progressing j
satisfactorily at that time.
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During the current inspection, the NRC inspector reinspected this area and identified several concerns related to the above violation.
Paragraph 2 describes a
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meeting to discuss the NRC's concerns.
Paragraph 6 describes examples of improper control / protection of i
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equipment / materials.
This item remains open until the new engineering procedure is implemented and shows that it properly i
controls these areas.
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e.
(closed) Violation (445/8511-V-02):
Failure to acknowledge receipt for Component Modification Card (CMC)
96181 in the Document Ulstribution Log (DDL) at Document Control Center (DCC) 307 and failure to void Design Authorization Change (DCA) 21446 when a later revision was issued.
The NRC inspector reviewed the actions of TUE regarding l
this item.
TUE not only addressed the deficiencies found in DCC 307 but also performed reviews at DCC 304, 308, l
DCC Central Drawing File, Unit 2 Paper Flow Group (electrical and mechanical), Hanger Task Force Group, Protective Coating Paper Flow Group, and Nuclear l
Engineering (TNE) Design Group for electrical.
The DDL now shows, based on the recipient's signature, I
that CMC 96181 was received and distributed.
The NRC l
reviewed the training records of four DCC 307 personnel and determined by records (dated April 1, 1986) that the
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individuals had been reinstructed to follow procedures.
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J During the October 1985 inspection, the NRC noted
on-the-spot corrective action concerning DCA 21446.
Comanche Peak project supervision contacted the i
electrician who acknowledged he had mistakenly gotten Drawing 2323-El-1702 with Revision 0 of DCA 21446 instead of Revision 1 but immediately returned it.
Subsequent to i
receiving a violation for this deficiency, a sample of I
drawing packages was reviewed but no other drawings or l
design changes were found to be out of revision.
The NRC
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and determined that training was also provided concerning this subject.
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f.
(Closed) Violation (445/8614-V-01; 446/8611-V-01):
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Failure to identify, tag, segregate and report nonconforming thermocouple.
The NRC inspector identified this finding en June 23, 1986.
TUE letter dated January 16, 1987, provided an acceptable response which described their corrective action.
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During this inspection period (May through June 1987),
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the NRC inspector reviewed File 10130 which included I
nonconformance reports (NCRs) and Material Return To l
Warehouse (MRTW) forms.
Conversations with a Quality j
Control (QC) inspector and review of these documents j
showed that ; oper action was taken to identify, tag, and j
segregate these items.
No violations or deviations were identified.
4.
Applicant Action on 10 CFR Part 50.55(e) Deficiencies (92700)
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i The NRC inspector reviewed the status of the TUE program for l
handling construction deficiencies (50.55[e]).
A TUE task force was formed in response to NRC unresolved Item 445/8516-U-01; 446/8513-U-01 and continues to work on the files to assure that corrective action and documentation in these files is adequate and complete.
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The TUE task force reviewed a sample of 92 items
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(40 reportable and 52 potentially reportable deficiencies that j
dated back to 1975).
The review included evaluating the
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adequacy of corrective action and documentation.
The corrective action documentation for 11 items was found to be incomplete and 10 of these items involved hardware issues.
l Thirty percent of the files for the 92 items gave little or no information relative to hardware correction; i.e.,
a reference t,o the nonconformance, inspection or design document which l
originally identified the deficiency.
The balance (70%) had I
some type information in the file to provide a starting place; that is, reference to a group / person, work traveler, or some type of record.
The task force review did not assess the correctness of evaluations relative to nonreportable items.
l The NKC inspector determined that of the 121 open 50.55(e)
reports, only three were ready for the NRC to inspect.
The inspector decided to postpone the inspection until there was a larger sample ready for inspection.
No violations or deviations were identified.
5.
Applicant Action on IE Bulletins (92703)
NRC Inspection Report 50-445/86-06; 50-446/86-04 summarized NRC inspections of Inspection and Enforcement l
Bulletins (IEBs).
A TUE task force was formed to perform a l
review of IEBs for corrective actions and accompanying documentation.
The TUE task force has reviewed 52 IEBs to date and 63 remain to be reviewed.
The NRC inspector will follow-up on IEBs and will inspect corrective actions relative to hardware during the next inspection period.
No violations or deviations were identified.
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6.
General Plant Inspections, Unit 1 and 2 The NRC inspector performed general inspections during the l
inspection period including three backshift inspections.
j These inspections included plant tours in all accessible rooms of the reactor, safeguards, auxiliary, diesel generator, and
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electrical / control buildings.
During these tours the j
following activities were also selected for more detailed j
inspections:
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Cleaning, Housekeeping, and Storage (50073)
Following the identification of housekeeping and i
cleanliness control concerns in the plant, the NRC inspector reviewed the Final Safety Analysis Report
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(FSAR) Appendix 1A(B) and found that TUE had committed to i
Regulatory Guides (RGs) 1.37, 1.38, and 1.39 plus the appropriate American National Standards (ANSI) for
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cleaning of fluid systems / components, housekeeping, and l
shipping / receiving / storage and handling.
The applicant j
stated that these commitments applied only to operations; the start-up and construction organizations were not committed to these standards.
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The existing construction and start-up cleanliness j
measures and practices do not provide equivalent controls j
to protect structures, systems and components.
For example, measures to establish housekeeping zones, such as Zones I, II, III, IV, and V described in ANSI N45.2.3 i
were not evident.
This standard is specifically intended
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for construction to prevent contamination, fires, and damage to equipment; yet, TUE did not commit to such controls until the plant is under the control of operations.
Different procedures and requirements exist in Unit 2 for construction and start-up.
In addition, systems may be turned over to operations but rooms may still be under control of construction and the commitments of the two organizations may conflict.
Through discussions with plant personnel, the inspector found that confusion existed among construction, operations, and start-up relative to implementing flushing, storage, protection and cleanliness requirements.
As detailed below, a number of examples were identified where equipment was maintained or disassembled without adequate protection, work was performed without protection of adjacent equipment, foreign materials were permitted in and around safety-related equipment without adequate controls, etc.
These unacceptable conditions and practices were discussed with TUE supervision.
The NRC inspector recognized that construction workers,
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operations personnel, and start-up personnel functioning under different protection and cleanliness controls was a cause of some of the observed problems; therefore, the inspector requested a meeting with management representatives of the three organizations to discuss these concerns.
The reulting meeting is described in paragraph 2.b of this report.
b.
Safety-related Components (50073, 53053)
The following components were pre-selected and inspected for: (1) installation or removal, (2) cleaning of fluid systems, (3) housekeeping zone;, and (4) in-place storage and protection.
Item Identification Location Results Post TCX-GHREEE01 Unit 2 This item was Accident H covered and pro-
recombiner tected from adja-cent activities.
Pump TCX-WPAPRDC1 Unit 2 The equipment flush plan 4103 for turnover 2-4100 was avail-able at the work
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site where the flush was being monitored.
Auxiliary CP2-AF-APM-02 Unit 2 This motor was Feedwater torn down and was (AFW) Pump not protected
& Motor from construction traffic.
Residual TCX-RHAHRS-01 Unit 2 This component Heat was properly Removal protected from (RHR) Heat welding (on part i
Exchanger BRP-AF-2-SB-049)
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RHR Pump TCX-RHAPRH-01 Unit 2 Parts were scat-tered on the floor without protection.
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Containment cpl-CTAPCS-03 Unit 1 Arc gouging per-Spray (CS)
formed'by con-Pump Motor struction contami-
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with foreign mat-erials from the arc gouging.
The equipment was not protected.
Battery CP2-EPBTED-01 Unit 2 Two unmarked plas-Chargers tic containers were found in a carboline bucket.
j The material was not identified.
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Distribu-CP2-EPBCED-03 Unit 2 A hold tag was
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tion Panels applied and NCR
M86101532K was written to iden--
tify and control
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ance.
Steam 842' area Unit 1-A'Matterhorn Generators Glass Cleaner Loops 1 & 4 container which
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contained an un-identified oil was found after
work hours.
Turbine 803' area Unit 1 Powdex (Anion Building Hydroxide) bulk material was open and generally
accessible.
i Diesel CP2-MEDGEE-02 Unit 2 An opened bag of Generator Balcones all pur-pose abrasive was stored on this
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equipment for weeks.
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J Pressurizer TCX-RCPCPR-01 Unit 2 The manway was open for at least
5 days without personnel /materi-al access control.
Other NRC inspectors
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found the steam generators in the same condition.
Reactor, Refueling Unit 2 Protective shoe Internals, cavity area covers, to pre-Refueling clude contamina-
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Cavity tion from enter-
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ing the opened reactor vessel, were not re-quired.
In a corridor adjacent to the open reactor vessel, zinc and halide rich materials which could be tracked into the area were being sprayed.
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Steam 841' area Unit 2 New and used grind-Generator ing wheels were l
Loops 1 & 4 not controlled to preclude using them on both carb-on and stainless steel.
Cable 807' area Unit 1 Welding was in Spread Room progress and Equipment trays were cover-ed with' fire blan-ket plus a fire watch was posted.
A plastic bottle labeled WD-40 (the label had been marked out)
contained an uni-dentified mater-ial.
Electrical No. 61, Unit 1 Work was in pro-Penetration Module A gress in room 83.
Quality control was present and reported results in IRI-0116008.
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Steam-1HV-2400 Unit 1 Extensive modifi-Generator 1HV-2397A cation of the-
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Blowdown 1HV-2398A valves per DCA Valves 1HV-2399A 25170, Rev.0 was being initiated.
Construction Defi-
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ciency CP-86-35
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had been issued by TUE.
Cable Tray THGSEB39 Unit 1 In room 88, no work authoriza--
tion or noncon-formance tags were applied but-operation proce-dures allow this.
Cable Tray T13QACG75 Unit 1 In room 63, the same condition existed as in i
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room 88.
Conax NCR E86105490 Unit 1 The nonconform-Penetration NCR E86105491 ances were iden-tified 'because of the machine l
surface' finish.
i The NCRs were dis-l positioned on l
'12-22-86 and
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await final cor-rective action.
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Structural Steel and supports (50090, 51053, 50100, and 53053)
The NRC inspector identified pipe / conduit supports, and a l
mechanical penetration joined to a structural steel liner i
and inspected them at various stages.of construction as
noted below:
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Item Identification Location Results Hanger BRP-AF-2-SB-049 Unit 2 This welding i
operation was controlled by weld data card 800336; weld process specifi-cation 11032, Rev. 15; and filler material
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was controlled by material log 2E529A003 and was stored in portable oven I
P240.
l Base Door to Room 16 Unit 2 Workers were
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plate to checking the
concrete seismic gap.
J Hanger RC-1-901-700-C82R Unit 1 This item was inspected and NCR M25344 was affixed.
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Personnel Unit 1 Two NCR's (M85 i
Hatch 101324SX and M85 103473X) were affixed and a review of the i
conditions by the NRC inspector showed proper control.
Pipe CP-AA-033 Unit 1 Conversations support H-DO-1-DG-009B with workers and H-DO-1-DG-009-3 review of paper-work by the NRC inspector confirmed proper controls.
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Electric-C-16R0230-03 Unit 1 A weld made by a al welder (with Conduit symbol CHT) was support observed and a fire watch was posted to monitor the welding.
No violations or deviations were identified.
7.
Auxiliary Feedwater Pump Motors, Unit 1 and 2 (50073)
During an inspection of the plant on May 19, 1987, the NRC inspector noticed that the Auxiliary Feedwater (AFW) pump
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motor for Unit 2 had been disassembled.
The inspector
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inquired as to the reason the pump was disassembled and found that the fans had been installed backwards.
Further NRC inquiry revealed that on June 20, 1986, test deficiency report (TDR) 4870 identified the deficient condition; namely, the ooling fans on the two motor driven AFW pump motors were installed backwards and each motor would not receive full cooling if run in this condition.
The report also noted that the same condition could exist in Unit 1 motors.
The NRC inspector inquired as to why the item was not reported per 50.55(e) procedures.
The NRC inspector found that the TDR was transmitted to a project disciplir.e suparvisor and to
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engineering on a TDR review and transmittal form.
The NRC inspector was informed that the deficiency was dispositioned
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on July 11, 1986, and the engineer determined that this item
was not reportable because the deficiency could not go undetected because it would have been discovered during preoperational testing.
When the NRC inspector inquired about Unit 1 (which had completed preoperational testing) the applicant found the same condition existed for Unit 1 motors.
The NRC inspector determined that the original evaluation was
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inadequate and resultec in a failure to notify the NRC of a
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potentially reportable 10 CFR 50.55(e) deficiency.
No justification was provided by engineering to show that the deficiency was not significant.
There was no information on the evaluation form to show that Westinghouse or the motor manufacturer had been contacted to determine if this
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deficiency could cause motor failure and adversely affect the safe operation of the nuclear plant during the expected lifetime of the plant.
TUE Engineering Assurance issued Deficiency Report C-87-2585 on June 23, 1987.
A deportability form (serial number 268)
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was issued on June 17, 1987, and the evaluation is required to be complete by July 17, 198._
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This item is unresolved pending the outcome of this evaluation (445/8710-U-01; 446/8708-U-01).
8.
Unresolved Items Unresolved items are matters for which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.
An unresolved item identified during this inspection is discussed in paragraph 7.
9.
Exit Interview (30703)
An exit interview was conducted on July 7, 1987, with the.
applicant's representatives identified in paragraph 1 of this report.- During this exit interview, the NRC inspectors summarized the scope and findings of the inspection.
At the time of the exit the applicant had not completed the evaluation of the-deficiency in paragraph 7; therefore, this was discribed as an unresolved item.
Since then the applicant has determined the deficiency to be potentially reportable.
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