IR 05000445/1987027

Safety Insp Repts 50-445/87-27 & 50-446/87-20 on 871007-1103.Violations Noted.Major Areas Inspected: Interviews & Discussions W/Managers,Supervisors,Engineers & Craftsmen & Special Meetings

ML20236Q603
Person / Time
Site:	Comanche Peak
Issue date:	11/12/1987
From:	Phillips H, Warnick R NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20236Q597	List: IR 05000445/1987027 ML20236Q595
References
50-445-87-27, 50-446-87-20, NUDOCS 8711200164
Download: ML20236Q603 (12)

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l U. S. NUCLEAR REGULATORY COMMISSION l OFFICE-OF SPECIAL PROJECTS' H i

NRC Inspection Report: 50-445/87-27 Permits: CPPR-126 i 50-446/87-20 CPPR-127 I

Dockets: 50-445 Category: A2 :I 50-446 Construction Permit'

Expiration Dates:

Unit 1: August 1, 1988 Unit-2: Extension request l submitted )

Applicant: TU Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201

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Facility Name: Comanche' Peak Steam Electric Station (CPSES),

Units 1 and 2 Inspection At: Comanche Peak Site, Glen Rose,' Texas ,

l Inspection Conducted: October 7 through November 3, 1987 i

Inspector: /Ms) //- 4 - F 7 N. 3."Phfllips, ' Senior Resident Date  ;

Inspector, Construction- j

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Reviewed.by: [FdJdMMW8 MW77 l R. F. Warnick, Assistant Director- /Date for Inspection Programs .

Comanche Peak Project' Division j L Office of Special Projects j i

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8711200164 B71112 i PDR ADOCK 05000445 '

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Inspection Summary Inspection conducted: October 7 through November 3, 1987 (Report 50-445/87-27; 50-446/87-20)

Areas Inspected: Routine, unannounced safety inspection including:

(1) interviews and discussions with managers, supervisors, engineers, and craftsmen; (2) special meetings; (3) follow up on previous inspection findings; (4) AFW pump motor design, ,

procurement, installation, and testing; (5) follow-up on applicant i identified construction deficiencies; and (6) general plant inspection I Results: Within the areas inspected, four apparent violations were identified (failure to identify and correct a deficient condition and take corrective action, paragraph 4.a; failure to follow procedure, paragraph 4.b; failure to provide appropriate i instructions, paragraph 4.c; and failure to translate design l

requirements into specifications, drawings, procedures and instructions, paragraph 4.d). On October 28, 1987, a meeting was held to discuss the AFW pump motor fan being installed backwards and the related inspection findings considered significant by the NR j i

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DETAILS Persons Contacted

• R. W. Ackley, Project Manager, Stone & Webster Engineering Corporation (SWEC)

• R. P. Baker, Engineering Assurance (EA) Regulatory Compliance Manager, TU Electric l

• J. Barker, Engineering Assurance Manager, TU Electric

• R. D. Best, Nuclear Operations, Inspection Report Item Coordinator, TU Electric

• W. H. Benkert, Staff Assistant Manager, Operations Quality Assurance (QA), TU Electric

• R. D. Delano, Licensing Engineer, TU Electric

• D. E. Deviney, Manager, Operations Quality Assurance (QA),

I TU Electric

• T. L. Heatherly, EA Regulatory Compliance Engineer,

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TU Electric l ***M. G. Janssen, Electrical Engineer, TU Electric

• J. J. Kelley, Manager, Plant Operations, TU Electric

• O. W. Lowe, Director of Engineering, TU Electric  ;

• • • M. L. Lucas, Engineering Supervisor, TU Electric

• D. M. McAfee, Manager, QA, TU Electric

• • • G. M. McGrath, Startup Supervisor, TU Electric

• L. D. Nace, Vice President, Engineering and Construction, TU Electric

• D. E. Noss, QA Issue Coordinator, TU Electric

• D. M. Reynerson, Director of Construction, TU Electric

• M. J. Riggs, Plant Evaluation Manager, Operations, TU Electric i

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R. J. Scanlan, Engineering Supervisor, Operations, TU Electric

• A. B. Scott, Vice President, Nuclear Operations, TU Electric

• C. E. Scott, Manager, Startup, TU Electric

• • J. D. Skelton, Startup Engineer, TU Electric

• J. C. Smith, Plant Operations Staff, TU Electric

• P. B. Stevens, Manager, Electrical Engineering, TU Electric

• J. F. Streeter, Director QA, TU Electric I. R. Thompson, Startup Engineer, TU Electric

• T. G. Tyler, Director, Projects, TU Electric

• • J. R. Waters, EA Regulatory Compliance Engineer, TU Electric The NRC inspector also interviewed other applicant employees during this inspection perio * Denotes personnel present at the November 3, 1987, exit i intervie ** Denotes personnel present at the exit and the October 28, 1987 meetin *** Denotes other personnel present at the October 28, 1987 .

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i 4 1 Special Meetings (30702)

On October 28, 1987, R. F. Warnick and H. S. Phillips of the j NRC met with TU Electric (TUE) staff members R. J. Scanlan, .

C. Smith, G. M. McGrath, J. D. Skelton, M. G. Jansen, M. j Lucas, D. E. Noss, J. R. Waters, and T. Heatherly. A i previously identified unresolved item concerning auxillary feedwater pump motor fans being installed backwards  !

(Unresolved Item 445/8710-U-01; 446/8708-U-01) was the subject of the meeting. The purpose of the meeting was to discuss the facts of the matter, the NRC concerns, and changing the unresolved item to a violatio See paragraphs 3 and 4 belo )

i Follow-up on Previous Inspection Findings (92701) '

(Closed) Unresolved Item (445/8710-U-01; 446/8708-U-01):

Auxiliary feedwater (AFW) pump motor fans installed backward During an inspection (Inspection Report 50-445/8710; 50-446/8708) of the plant on May 19, 1987, the NRC inspector noticed that the auxiliary feedwater (AFW) pump motor for Unit 2 had been disassembled. The inspector 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 written by TUE Startup identified the deficient condition, .

namely, the cooling fans on the two motor driven AFW pump  !

motors were installed backwards. (The fan would be sucking air across the motor rather than blowing air across the motor when run in this condition). The report also noted that the same condition could exist in Unit 1 motor The NRC inspector inquired as to why the item was not reported per 10 CFR Part 50.55(e) procedure The NRC inspector found that the TDR was transmitted to a project discipline supervisor and to engineering on a TDR review and transmittal for Gibbs and Hill, Inc. letter (GHCP-1814) reviewed the proposed corrective action described in TDR 4870 and evaluated the deficiency for deportability. The NRC inspector was informed that the deficiency had been dispositioned on July 11, 1986, and that the engineer had determined that the item was not reportable because the deficiency could not go undetected because it would have been discovered during i

preoperational testing. When the NRC inspector inquired about Unit 1 (which had completed preoperational testing), the applicant found the Unit 1 AFW pump motor fans were also J installed backward )

The NRC inspector determined that the original evaluation was inadequate and resulted in a failure to notify the NRC of a j potentially reportable 10 CFR Part 50.55(e) deficiency. No i justification was provided by engineering to show that the deficiency was not significan There was no information on l

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i the evaluation form to show that Westinghouse or the motor manufacturer had been contacted to determine if this '

deficiency could cause motor failure and adversely affect the safe operation of the nuclear plant during the expected lifetime of the plan Following identification of the problem with the Unit 1 AFW l pump motor fans, maintenance removed the fans, installed them correctly, and balanced the motor TUE Engineering Assurance issued Deficiency Report C-87-2585 on June 23, 1987. A deportability form (serial No. 268) was issued on June 17, 1987, and the evaluation was to have been ,

completed by July 17, 198 On October 29, 1987, TUE verbally i notified the resident inspector that the evaluation had determined pump performance would not have been degraded, even during worst case condition l This item was previously documented as an unresolved item pending the outcome of the TUE 10 CFR Part 50.55(e) evaluation and further NRC review. NRC follow-up inspection of this item is documented in paragraph 4 below. Several apparent violations of NRC requirements were identified and they will '

i be followed up by the violation tracking numbers. This

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unresolved item is considered to be close . AFW Pump / Motor Design, Procurement, Installation, and Testing (50071, 50073, 50075) -

The NRC inspector documented the above item (discussed in paragraph 3.0) as unresolved pending the completion of the TUE '

and Westinghouse (W) review of the deficient conditio During this inspection period, TUE concluded its evaluation of the deficient condition for deportability in accordance with 10 CFR Part 50.55(e) requirements. Based on the evaluation, TUE concluded that the fans which were installed backwards would not have degraded pump performance or resulted in inoperable AFW pump On July 8, 1987, in response to inquiries from the NRC inspector, TUE notified the NRC that the AFW pump motor fans i installed backwards were being reported to the NRC under

50.55(e) as being a potentially reportable deficienc Two interim reports (TXX-6629 and TXX-6813) were made to the NRC and the final report is due on December 2, 198 At first, the NRC was mainly concerned with TUE's failure to notify the NRC of a potentially reportable item from July 11, 1986, (when the TUE engineer erroneously concluded that the deficiency did not meet the criteria for notifying the NRC) until it was reported in July 1987. Because of the lack of safety significance of the fans being installed backwards, the failure to report is no longer a concern. However, a detailed L - -- - - - - - - - _ _ - - _

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6 I inspection by the NRC of the documents pertaining to I procurement, installation, testing, deficiency reporting, deficiency evaluation, and corrective actions and discussions s'

with involved individuals has disclosed multiple errors / problems that resulted in this condition existing in both Unit 1 and 2 AFW pump motors. Because of these multiple errors, most of which were either identified by the NRC or because the NRC asked motivating questions rather than by a thorough evaluation by TUE, the NRC considers these findings to be significan J A review of the history of these motors and pumps revealed a ;

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series of problems that caused the AFW motor / pump assemblies to be procured, manufactured, installed on site, and tested without detecting the fans being backwards. The failure to develop adequate design specifications and the programmatic failure to take corrective action when Gibbs & Hill, In (G&H), TU Electric, and Brown & Root, Inc. (B&R) became-aware of the deficiencies were the most significant NRC findings; however, the failure to assure that all prerequisites for

. testing the AFW motors were met and the failure to provide l adequate installation instructions to construction personnel were also significan NRC findings categorized by apparent violation follow:

j Failure to Take Corrective Action on AFW Motors / Pump The NRC inspector determined that G&H, TUE, and B&R failed to take adequate corrective action concerning the deficient AFW motor / pump assemblies for Unit 1 and Starting with the most recent time, the following examples of failure to take corrective action were found:

(1) From June 1986 until June 18, 1987, TUE Operations management and engineering failed to take adequate corrective action on the deficient AFW motors. The NRC inspector found no evidence that the deficiencies were adequately evaluated as requested by TUE Startup Memorandum SU86261 dated June 23, 1986. TUE TDR attached to the memorandum stated that startup testing had found that the cooling fans in Unit 2 AFW motors were installed backwards and would not receive full cooling and that the came conditions could exist in Unit 1 motors. A less than adequate evaluation was performe Operations personnel failed to perform an adequate check of the Unit 1 motors. This condition went undetected and the motors and pumps were accepted for service during operations until the NRC questioned the condition of the motor This failure to identify I and correct the deficient Unit 1 motors is an i

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example of a violation of Criterion XVI of Appendix B to 10 CFR Part 50 (445/8727-V-01A).

(2) After the NRC triggered the identification of the problem, TUE operations generated a Problem Report.>

(PR)87-228 dated June 18, 1987. The NRC inspector reviewed the final report completed on June 22, 1987, and found that the engineering evaluation (Attachment 1 in the Problem Report) failed to adequately determine the cause of the condition and-assure that corrective action was taken to preclude repetition. This report did not. address why the deficiency was not adequately evaluated in 1986, why l no deficiency or corrective action document was generated at that time, and how the condition went undetected when Unit 1 motors went through preoperational testing. .Since the W instruction discusses phase change and the need to reverse the blower fan, the condition should have been detected if the test procedure and W instruction had been followe There was no discussion of the Ingersoll-Rand letter received in 1978 which stated that the motor and pump rotations were opposit I This failure to perform an adequate evaluation of the AFW motor deficiencies precluded adequate j l

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corrective action and is another example of a l

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violation of Criterion XVI of Appendix B to 10 CFR Part 50 (445/8727-V-01B).

(3) TDR 4870 dated June 20, 1986, was forwarded to the project discipline supervisor for.the corrective action to be specified by engineering and to perform a review for 10 CFR Part 50.55(e) deportabilit G&H letter GHCP-1814 performed the evaluation and l provided the corrective action to TU Electric l Nuclear Engineering (TNE) on July 11,.198 The TDR was marked as not being reportable under 10 CFR Part 50.55(e) and the corrective action was very narro The engineer indicated that startup should issue a work order to reverse the Unit 2 blower fan The NRC inspector determined that G&H did not contact W to determine what effect this deficient condition would have on the motors in operatio There was no physical inspection of the Unit 1 motors to determine if the condition did exis If the G&H engineer had used the technique used by the Unit 2 startup engineer, he would have learned that the Unit 1 motors were deficien Instead, he indicated that the motors were acceptable because I i

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they had been preoperationally tested and accepte This failure to perform an adequate evaluation and

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I identify and correct the deficiency precluded l adequate corrective action and is another example of i a violation of Criterion XVI of Appendix B to I 10 CFR Part 50 (445/8727-V-OlC; 446/8720-V-OlA). j (4) The NRC inspector found that Ingersoll-Rand Company (IRCo) letter 031-36281 dated June 22, 1978, to G&H identified that the direction of rotation indicated on the motor was opposite that of the pump. A B&R speed letter dated June 28, 1986, transmitted a copy of the IRCo letter to construction for. actio The speed' letter stated that the motors / pumps should be q placed on hold when they are received on site and i should be checked out and corrected as neede G&H, TUE, and B&R failed to take adequate corrective action. This is another example of a violation of Criterion XVI of Appendix B to 10 CFR Part 50 (445/8727-V-OlD; 446/8720-V-OlB).

j b. Failure to Assure That All Prerequisites for AFW Motor Test Were Met The NRC inspector reviewed Prerequisite Test Procedure XCP-EE-9, Revision 6, and the W instruction for'what must be done when the direction of shaft rotation on three phase motors is change Paragraph 6.0 of the test procedure requires a review of the W instruction which

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states that the blower fan must be reversed if the leads are reverse Paragraph 4.15 and 7.7 of the test procedure requires the verification of' correct termination and motor rotation. This failure to follow the prerequisite test procedure is a violation of Criterion V of Appendix B to 10 CFR Part 50 '

(445/8727-V-02).

c. Failure to Provide Adequate Instructions The NRC inspector reviewed construction records to determine if installation instructions for the motor / pump assemblies were adequate. The inspector found.that no procedure, detailed instruction, or drawing contained sufficient information to assure that the motor.was correctly installed; that is, correct motor, pump, and blower fan rotation. Mechanical travelers-were required l for installing the assembly in the safeguards buildings; however, traveler Procedure CP-CPM-6.3 does not address interdisciplinary considerations relative to electrical and mechanical installation requirements.

l The NRC inspector reviewed mechanical travelers ME78-037-3702 and ME-78-038-3702 used to install Unit 1 AFW motors / pump These travelers did not reference

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drawings or describe drawing requirement The travelers did not address the concern stated in the IRCo letter and the B&R speed letter and did not include sufficient information to assure correct installatio Unit 2 Mechanical Packages ID Nos. CP2-AFAPMD-01 (75 pages) and CP2-AFAPMD-02 for AFW motor / pump assembly installations typically contained travelers, i'

nonconformance/ deficiency reports, design change authorizations, and inspection report The inspector found that these packages dealt specifically with setting and aligning the assemblies but did not contain interdisciplinary instructions. The pump and platform ,

were set in early 1979 and the motor was set several months later. Traveler ME79-242-3700 dated March 21, 1979, was developed by mechanical engineering; however, the traveler indicated that no further engineering involvement was necessar There was no apparent electrical engineering involvemen However, paragraph 3.1.1 of traveler Procedure CP-CPM-6.3, Revision 2, required joint engineering review to prepare the travele The inspector reviewed electrical packages for installing Unit 1 and 2 motors, I.D. Nos. EO 100003, EO 104359, EG 100039, EG 104574, and EO 200018, EG 204574, respectivel A review of a typical package (EG 204574)

for pulling power cable, testing, and terminating the cable between Unit 2 motor and pump (CP2-AFAPMD-02) and the 6.9kv switchgear contained 33 pages of records to show how the installation was accomplished. The cable connection card which provided instructions for terminating the motor referred to installation drawing E2-0031-3H40, Revision 3; however, that drawing did not include the special precautions relative to phase changes described on W Drawing 8972D75 or the specific directions contained in the instruction book. This failure to provide adequate instructions for the installation of the AFW pumps and motors is a violation of Criterion V of Appendix B to 10 CFR Part 50 (445/8727-V-03; 446/8720-V-02).

l d. Failure to Correctly Translate Design Requirements Into Specifications (1) The NRC review of the design and procurement documents identified that the G&H motor Specification 2323-ES-1D required motor rotation to be CCW with respect to the outboard end of the pump (the end opposite the pump coupling end). The bid package Specification 2323-MS-7 clearly described CCW from the outboard end but Revision 1 of the l

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specification attached to TUE purchase order CP-0007, dated May 2, 1975, only specified CCW without describing from which end the pump was !

viewed. The motor specification attached to GH letter 6639 dated January 29, 1976, shows that W proposed a CW rotation as viewed from the end opposite the coupling which is the.same as when viewed from the pump outboard end. This discrepancy was not detected until the NRC identified it in October 1987. Drawings, procedures, or instructions did not clearly describe the design motor and pump direction of rotation. This is considered to be an example of failure to correctly translate design requirements into specifications, drawings, procedures, and instructions and is a' violation of Criterion III of Appendix B to 10 CFR Part 50 i (445/8727-V-04A; 446/8720-V-03A).

I (2) After the' blower fans were found to be installed )

backwards, TUGCo Design Request No. 4187, dated October 7, 1986, was. processe This request was for Unit 2 motor / pump assembly CP2-AFAPMD-01. The request described the rotation as clockwise without giving the motor end view. This engineering action 1 was approved on April 1, 1987, and design change authorization (DCA) 34953, Revision 0, including i i

Drawing 2323-E2-0031, SH38, Revision 0, which provided no information relative to motor phase and direction of rotation, was. issue The NRC inspector interviewed the responsible Stone

& Webster engineer, who in response to questions, i stated that there had been no interdisciplinary review and that the specifications were not reviewed !

to verify whether the direction change was ,

consistent with equipment requirements. The DCA block (Equipment / Component Affected) was marked

"no". Changing the phase without changing the blower fan direction did affect the equipment as the Unit 2 blower fans had to be reverse This failure to adequately review field design changes is considered to be an example of failure to correctly translate design requirements into drawings, procedures, or instructions and is a violation of Criterion III of Appendix B to 10 CFR

! Part 50 (445/8727-V-04B; 446/8720-V-03B).

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.j Follow up On Applicant Identified Construction Deficiencies (92700)

]j The NRC inspector. reviewed Construction Deficiency Reports CP-87-110.through CP-87-120.which have been identified as:potentially reportable construction deficiencies in accordance with 10 CFR Part 50.55(e).

Each report submitted during this inspection period was reviewed to assure that the deficiency was fully-identified, described,. evaluated, and that.the NRC was -

j notified in accordance with TUE Procedure:NEO-CS-1,'

Revision 2. .Further NRC review of applicant corrective i actions will be accomplished in subsequent' inspection report ! (Closed) Construction Deficiency (CP-85-05): Diesel i generator (DG) engine control panel. filter bowls rated at I 150 psig at 125. degrees F.not acceptabl The NRC q

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inspector reviewed.TUE File 10110 which included purchase order for replacement bowl,Lmaterial requisition, work-traveler nonconformance report, inspection report, j evaluation of deportability, and a subsequent report'made i per 10 CFR Part 50.55(e).- All necessary' documentation for Unit 1 and 2 DG engine control panel filter bowls was i in the fil I i

The NRC. inspector physically inspected the replacement of j the filter bowl in the control panel of.the Unit 2 DG "A"' '

trai The metal bowl which replaced the polycarbonate .

bowl is now rated for 250 psig at'175 degrees- This l will accommodate the air pressure which will cycle '

between 200 and 250 psig at room temperatur The replacement was necessitated by the vendor's derating the polycarbonate bowl from 250 psig to 150 psi No violations or deviations were identifie ,

! General Plant Inspections (50053,150073, 50090, 55100)  !

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At various times during the inspection-period, the-NRC i'

inspector conducted general. inspections of the Unit 1 reactor containment building. All accessible rooms were inspected to observe current' work activities with respect to major safety-related equipment,. electrical cable / trays, mechanical  !

components, piping, welding, coatings, and Hilti bolt !

Housekeeping, storage, and handling-conditions inside these buildings and various outside storage areas were also inspecte No violations or deviations were identifie l

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7.- Exit Interview (30703'.-)

An exit interview was conducted on November _3, 1987, with the applicant's; representatives identified in paragraph.1 of this report. .During this exit interview, the scope and findings of the inspection were'. summarize i

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