IR 05000445/1988037

Insp Repts 50-445/88-37 & 50-446/88-35 on 880504-0607.No Violations or Deviations Noted.Major Areas Inspected: Applicant Actions on Previous Insp Findings,Followup on Violations/Deviations,General Plant Areas & Mgt Meeting

ML20196L574
Person / Time
Site:	Comanche Peak
Issue date:	06/24/1988
From:	Livermore H NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20196L571	List: IR 05000445/1988037 ML20196L570
References
50-445-88-37, 50-446-88-35, NUDOCS 8807080014
Download: ML20196L574 (16)

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS NRC Inspection Report:

50-445/88-37 Permit: CPPR-126 50-446/88-35 CPPR-127 Docket: 50-445 Category: A2 50-446 Construction Permit Expiration Dates:

Unit 1: August 1, 1988 Unit 2: Extension request submitted.

Applicant:

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

Comanche Peak Steam Electric Station (CPSES),

Unit 1 & 2

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Inspection At:

Comanche Peak Site, Glen Rose, Texas Inspection Conducted:

May 4 through June 7, 1988 Inspection conducted by NRC consultants:

J. Dale - EG&G (paragraph 4.b, 5)

K. Graham - Parameter (paragraph 2.a, 3, 6)

P. Stanish - Parameter (paragraph 2.b, 2.c, 4.a)

Reviewed by:

FAW/d?14 >

(.o-2M-S-H. H. Livermore, Lead Senior Inspector Date 8807080014 880624 ADOCK 05000445 PDR PWR

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Inspection Summary:

Inspection Conducted:

May 4 through June 7, 1988 (Report 50-445/88-37; 50-446/88-35))

Areas Inspected: Unannounced, resident safety inspection of applicant's actions on previous inspection findings, follow-up on violations / deviations, allegation follow-up, Comancho Peak Response Team (CPRT) issue-specific action plans (ISAPs), Corrective Action Program (CAP) for piping and pipe supports, general plant areas (tours), and management meeting.

Results:

Within the areas inspected, the NRC inspectors identified no violations or deviations and no significant strengths or weaknesses during this incpection perio.

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DETAILS 1.-

Persons Contacted

• R.

P. Baker, Licensing Compliance Manager, TU, Electric

• M.-R.

Blevins, Manager,- Technical Support, TU-Electric

• J. T. Conly, Lead Licensing Engineer, SWEC

• W.

G. Counsil, Executive Vice President, TU' Electric

• M.

D. Gaden, CPRT, IT Corporation

• T.

L. Heatherly, Licensing Compliance Engineer, TU Electric

• J.

E. Krechting, Director of Technical Interface, TU Electric

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

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• J. W. Muffett, Manager of Civil Engineering, TU Electric

• L.

D. Nace, Vice President, Engineering & Construction, TU Electric

• D.

M. Reynerson, Director of Construction, TU Electric

• C.

E. Scott, Manager, Startup, TU Electric

• S.

L. Stamm,. Project Engineering Manager, SWEC

• M.

R. Steelman, CPRT, TU Electric

• C.

L. Terry, Unit 1 Project Manager, TU Electric The NRC inspectors also interviewed other applicant employees during this inspection period.

• Denotes personnel present at the June 7, 1988,. exit meeting.

2.

Applicant's Action on Previous Inspection Findings (92701)

a.

(Closed) Unresolved Item (445/8706-U-01; 446/8705-U-01):

This unresolved item involved NRC inspectors contacting the CPRT statistical consultant to review documentation of the results of his review as committed to in TXX-4819 (i.e., a review of population definition, sample selection, etc. to identify errors in the ISAP sampling process).

The statistical consultant stated he was unaware of the commitment and that the review he and the Results Report Review Committee performed prior to submittal of Revision 3 of the CPRT Program Plan was primarily cf methodology and did not encompass detailed verification of the adequacy of specifics of population definition and sample selection for the action plans.

Accordingly, the NRC inspectors were unable to establish from available documentation that actions have been taken which would identify the existence of errors, e.g.

Deviation 445/8513-D-01, in other action plan populations.

On May 4, 1987, the NRC inspector contacted the CPRT statistical consultant to discuss the completeness and adequacy of the committed sampling techniques review for

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CPRT ICAP populations.

The NRC inspector reviewed CPRT Letter 1136 dated March 31, 1988, which documents the status of verification of sampling techniques and noted that all reviess were complete.

For ecch population, an individual interoffice memorandum documented proof of the review.

Each population'had been reviewed, as commi.tted, to l

determine: (1)-if the working file contained adequate I

documentation describing each step of the sampling process, and 1.2) if the statistical conclusions reached in the results report for the ISAP were correctly substantiated by the sampling data contained in the working file.

The NRC inspector considers the reviews, which were performed by the statistical consultant and concurred with by the ISAP issue coordinator and lead discipline engineers, to be consistent with the commitment identified in TU Electric Letter TXX-4819.

NRC inspection determined these reviews provide a detailed l

verification of the adequacy of specifics of population definition and sample selection for the ISAPs.

This item is closed, b.

(Closed) Unresolved Item (445/8811-U-02):

During a routine inspection, the NRC insp ctor observed a rigid sway strut that was attached to a wide-flange member by welds perpendicular to the longitudinal axis of the beam.

Since there were no stiffener plates to preclude the possibility of weld failure due to localized deformation of the member, the NRC inspectors reviewed the Stone &

Webster Engineering Corporation (SWEC) calculation l

package for the support in question which revealed that the appropriate local stress calculations had not been performed in accordance with the requirements of Comanche Peak Project Procedure CPPP-7 a3d code requirements.

Further, the NRC inspector reviewed two additional calculation packages for similar supports and found that the required local stress evaluations had not been completely evaluated.

In response to this item, SWEC issued DR-C-88-01165, which was reviewed by the NRC inspector and found to adequately address the problem.

To quantify the extent of the problem, SWEC reviewed 1200 support designs.

As a result of this review, SWEC identified four additional examples for which local stresses were not evaluated in accordance with the requirements of CPPP-7.

SWEC revised the deficient calculations for the seven supports identified (three by NRC, four by SWEC), and found that

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no physical modifications were required.

Further, the

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following preventive actions were committed:

(1) to add an attribute addressing flange bending and web crippling checks for open sections to PM-133, the final reconciliation checklist; and (2) to emphasize the local stress check requirement for open structural shapes (CPPP-7, Attachment 4-13, Section 4-7) in the Revision 4 training sessions of CPPP-7 to be given to all SWEC-PSE engineers.

In this inspection period, the NRC inspector reviewed SWEC's training records and outline for the Revision 4 training sessions of CPPP-7 and Revision 7 to PM-133 and confirmed that the committed preventive action had been satisfactorily completed.

This item is closed, c.

(Closed) Open Item (445/8811-0-06):

Brown & Root (B&R)

ASME Construction Procedure ACP 11.5, Revision 2,

"Component Support Fabrication," had what appeared to the NRC inspector to be excessively high torque values specified for the bolts that mount transition kits or forward brackets to mechanical shock arrestors.

Based on review of vendor and related site inspection documentatica (which specified the correct values), this was an apparent typographical error and this item was left open pending a future revision of the subject procedure.

The inspector notes that no bolts could have been installed at the torque values stated in Revision 2 l

of ACP 11.5 because those torques would have caused

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failure of the bolts in question.

In this inspection period, the NRC inspector reviewed Revision 2DCN1 to Procedure ACP 11.5 and verified that the torque values for these bolts are now specified in inch-pounds which agrees with the vendor's requirements.

This item is closed.

3.

Follow-up on, Violations / Deviations (92702)

(Closed) Violation (EA8609 Appendix A Item I.D.3):

i Certain types of skewed welds, those existing at the l

Intersection of curved members used as structural members,

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were not included in the skewed weld reinspection program for component supports.

TU Electric has denied the violation occurred because the Notice of Violation did not accurately describe the inspection program for ASME component support skewed welds.

TU Electric contends that all types of skewed welds, including those existing at the intersection of curved members used as structural members, have been continuously included in the

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skewed weld reinspection program since the inception of the skewed weld reinspection in September 1982.

The'NRC inspection staff agrees with TU Electric's denia) of

'the alleged violation.

An additional basis for this decision is that ISAP V.a has been developed and implemented to fully address any concerns relative to the adequacy and accuracy of quality control inspection of type-2 skewed welds (i.e. those welds existing at the intersection of curved members).

The reinspection performed under this action plan provided reasonable assurance that the type-2 skewed welds.cn1 (B&R)

pipe supports are within the ASME allowable stress levels.

Although, twelve supports were found to contain-undersize.

. welds, none of these welds exceeded ASME stress limits.

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engineering evaluation of margin based on the measured weld size indicates that it is not likely that any of the type-2 skewed welds in the plant exceed ASME limits.

The NRC inspector has reviewed results of the reinspections required by ISAP V.a and concurs with the conclusions reached.

This item is closed.

4.

Allegation Follow-up (99014)

a.

Allegation (Anonymous Letter to TU Electric)

(Closed) Allegation:

It was alleged that SWEC principal engineers knowingly allowed calculations with incorrect allowable stresses and inaccurate anchor bolt interactions to be used in the requalification effort for pipe supports.

a Concern Specifics On December 17, 1987, TU Electric notified the NRC, along with all CPSES employees and contractor organizations, that they had received an anonymous letter outlining four distinct areas of alleged shcrtcomings in SWEC's requalification effort for pipe supports.

The specific concerns were:

(1)

Lower design temperatures were used so that higher allowable stresses could be used to qualify supports.

(2)

Anchor bolt sizes were changed to larger sizes unnecessaril (~

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(3)

Anchor bolt stress interactions were reported as lower than allowable when, in fact, they slightly exceed allowable.

(4)

Skew angles were altered so higher allowabic stresses could be used for weld calculations to qualify supports.

Assessment In response to this letter of allegation, TU Electric contracted Impell Corporation to investigate whether or not each alleged concern existed.

Impell selected a random sample of 300 pipe support calculations in order to provide an objective assessment of all support calculations.

The selected calculations were reviewed by experienced engineers with the aid of written checklists specifically developed to address the allegations.

In addition, a biased sample of 60 pipe support calculations with high reported stresses was also reviewed.

The purpose of the biased sample was to increase the likelihood of identifying the alleged concerns.

The results of the review performed by Impell substantiated two of the allegations: (1) the use of oversized anchor bolts and (2) misrepresentation of anchor bolt interaction ratios.

No evidence of the other allegations was found in the calculations reviewed.

However, the Impell report concludes that confirmation of two of the allegations tends to indicate that the other allegations may also exist.

The applicant requested that SWEC review Impel.1.'s analysis and conclusions and recommend appropriate corrective actions.

SWEC's Letter SWTU-8159 documents the results of its review.

Impell found two instances of oversized anchor bolts and five instances of misrepresented interaction ratios for anchor bolts in their review of 360 pipe support calculations (total of both samples).

SWEC performed a review of the seven calculations in question.

In response to the examples of oversized anchor bolts, SWEC stated that because it can be shown, as demonstrated in their letter, that interaction ratios are very sensitive to small changes in bolt size, a low ratio is not necessarily an appropriate index of "oversize".

Therefore, SWEC stated "there appears to be no basis in the calculation to support the allegation."

For the examples of misrepresented interaction ratios, SWEC revicwed each anchor bolt calculation in detail and pointed out that while the interactions were slightly higher than the allowable of 1.0 there was a significant amount of conservatism in

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each-of the calculations.

When this conservatism is removed from the calculations, it was shown in all five cases that the interaction ratio would be within allowables.

The result of SWEC's review was that "none of the allegations have any technical merit."

However, SWEC acknowledged that in the cited calculations

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. engineering judgements for the specific cases were not properly documented and committed to reinforce their policy.of.providing necessary documentativa to support the designs, f

The NRC inspector performed a review of the report prepared by Impell Corporation in response to the allegations contained in the anonymous letter received by the applicant and found the methodology acceptable and the conclusion consistent with the findings within the charter' outlined in the introduction of the report.

Further, the NRC inspector reviewed SWEC's response to the specific findings and each of the calculations cited and concurs with the conclusion that there is no technical. merit to the allegations.

Conclusions r

Based on the reviews performed which demonstrate that there is no technical merit (or safety significance) to the allegations made, the NRC plans no further action on this item at the present time and considers this allegation closed.

Further, SWEC committed to reinforce the need to fully document design assumptions to provide assurance that designs meet all code requirements and project commitments.

b.

Allegation (OSP-87-A-0087)

(Closed) Allegation:

On October 3, 1987, the NRC inspector was given information by phone concerning the alleged removal of reinforcing steel (rebar) at the

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springline (where the wall meets the dome) of Unit 1

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containment.

The alleger indicated that the size of the section was 3 1/2" x 20' x 30' and that it was removed to facilitate the setting of concrete forms.

Other than the

names of two of the individuals involved, no further specific information was available.

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Assessment In response to this allegation the NRC inspector

contacted the B&R personnel office and determined that of the two individuals identified one had been terminated and one was still working at CPSES.

The NRC inspector

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contacted the alleger three additional times in an effort

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to obtain more specific information relative to.the allegation.

The additional information.that was obtained m

was the time frame that;the rebar removal took place which was approximately November 1,'1978, to March 31,-

-1979, and that it was removed with the use of an oxy-acetylene cutting torch and removed with a trash bucket.- The NRC inspector ~ identified all the crews that could have been associated with the concrete pours and concrete; form work during the time period in question.

From this list, the NRC inspector was able-to identify

four employees that were working on the crews in question

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during the time period identified by the alleger.

The NRC inspector interviewed the four employees in question.

The'four employees that were interviewed had heard'the rumor of the missing rebar but did not have any first-hand knowledge of the alleged event.

In addition, they could p ovide no additional information on the cutting of'rebar and, in fact, could not identify any

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instance in which rebar may have been removed from the containment.

However, they did identi2y three additional employees to the NRC inspector and th.sc employees were

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also interviewed by the NRC inspector.

The_three

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employees were unable to provide any further information

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concerning the allegation.

At the conclusion of these t

interviews, the NRC Office of Investigation interviewed =

the foreman of the crew that had allegedly removed the rebar with the following results:

(1)

The employee stated that his crew had never removed any robar from containment, as it would have been against procedure.

(2)

The employee felt that the removal of such a large section of rebar would necessitate the use of a

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large crane and days to complete.

l The NRC inspector notes that the interviews included both

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the individuals named by the alleger.

Conclusion Based on the interviews conducted by the NRC inspector and the Office of Investigation, the denial of any first-hand knowledge by the individuals interviewed, and the lack of specificity by the alleger and others interviewed, the NRC inspector was unable to confirm the allegation that rebar was cut and removed from the

springline of the Unit 1 containment.

This allegation is closed.

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5.

CPRT ISAPs (48063)

a.

Polar Crane Shimming (ISAP VI.b)

(1)

Third-Party Review of Findings and Assessment of Safety Significance (NRC Reference No. 06.b.01.02)

The inspection of the bearing surface between the polar crane girder and the girder support brackets was performed by a craft team who also identified what they perceived as the four worst cases.

They subsequently mapped out the outline of the bearing area by inserting feeler gauges from the outer edge of the plate towardt the center.

The data obtained from this inspection was subsequently utilized to assess the validity of the assumptions used in the analysis which qualified the bearing areas.

To qualify the existing bearing areas, the CPRT generated a calculation showing that regardless of the bearing configuration between the polar crane girder and the support bracket, the structural integrity of the supporting system will not be affected.

SWEC was responsible for generating this calculation which was titled, "Evaluation of the Bearing Between Polar Crane Runway Girders and their Support Brackets" and referenced as SWEC Calculation 16345-EM(S)-008-CZC, Revision 1.

It was concluded in the Results Report that, "The extent of the bearing alca between the girder and the support bracket seat is not viewed as a concern by the third party.

. enveloping analyses qualify the gir'.or

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seat connection bolts regardless of the actual pattern or location of contact areas at the mating surfaces.

Thus, while the investigation of the girder seat connection confirmed the TRT-observed gaps under the bottom flange of the girder, the subsequent evaluation verified that these gaps are not significant, and that no corrective action is necessary."

The NRC inspector reviewed SWEC Calculation 16345-EM(S)-008-CZC, Revision 1, for its technical adequacy and justification of the conclusions.

It was found that the geometry of the polar crane girder and support bracket accurately depicted what was shown on appropriate polar crane drawings.

Also, the approach taken in the calculations was technically sound and accurately performed.

Allowable stresses were derived from the correct code equations and reflected actual material types.

The NRC inspector also concurs with the CPRT

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conclusion that,

. no failure of the contact

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surfaces or the associated structures could be expected as a result of potential local yielding at the contact surfaces."

Furthermore, based upon the conservative approach taken by SWEC, the NRC inspector concurs that regardless of the bearing surface configuration (up to and including. point contact), the stresses in the associated support bracket bolts will remain within code allowables, other components related to structural integrity (i.e., bending and shear stresses in the sole plate and associated weld stresses) were also adequately qualified and the stresses remained within code allowables.

No safety significant deficiencies were identi.fied by the CPRT so, subsequently, no corrective actions were required.

No violations or deviations were identified.

This activity is complete and no further NRC inspection is planned for this reference item.

(2)

Gibbs & Hill to Analyze / Design any Required Modifications (NRC Reference No. 06.b.02.03)

It should be noted that at the time of generation of the N1'C reference items, Gibbs & Hill was responsible for polar crone design modifications but, sabsequently, SWEC ascumed these responsibilities in October 1986; therefore, all rey:1!. red analyses were performed by SWEC.

Based upon the determination of the cause of polar crane rail movement, SWEC designed some minor modifications to alleviate the situation.

The design modifications included new inboard rail clips to provide seismic restraint and maintain the upright rail position during normal operation.

Also, rail splice bars were added to resolve the problem of circumferential rail movement due to crane operation and the associated gap formation between the rail ends.

SWEC concluded that the original design of the polar crane rail hcid down clips was not adequate on the inboard side (i.e., the inboard clips may not adequately restrain the rail movement or all prevalent load conditions); therefore, a new design was performed.

The verification of the adequacy of the new design is under SWEC Calculation 16345-EM(S)-002-CZC, Revision 1, titled "Design of Hold-Down Clips for Polar Crane Rail Unit 1 and Unit 2."

The design called for a more rigid inboard

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rail clip whiM. would beLcapable of restraining-the at the' base of the. rail for-all

overturning fe

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To' preclude circumferential applicable loaa.

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rail ~ movement,~Sh.

d ilgned rail splice: bars which; provided a.frictial

.inection betweenJthe. rail ends-capable of withstr

.sg maximum. axial rail-loads.

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The verification ror this design is SWEC Calculation

'16345-EM(S)-003-CZC, Revision 2 titled "Polar Crane-Rail' Joint Splice Bar~ Evaluation for Units 1 &

2."

The NRC inspector reviewed these two design modifications as well as the associated SWEC calculations justifying the designs.

Upon review of SWEC-Calculation 16345-EM(S)-002-CZC, Revision'1, the'NRC inspector determined that the calculation was technically sound including the use of-appropriate engineering equations, valid: assumptions-were made, troper loadings and allowablo stresses-were utilized, and correct geometric configuration was considered.

Furthermore, use of the-new clips, would preclude any overturning movement of the polar crane rail.

Similar conclusions were. reached by the NRC inspector when reviewing SWEC Calculation

~16345-EM(S)-003-CZC, Revision 2.

Technically, the calculation was sound ~and was performed accurately and proper parameters.were. considered-and used.

Furthermore, the correct installation of'these rail splice bars would preclude-any unnecessary axial movement of the polar crane rail. ' Inspection of these: clips will be. documented in a future y.

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No-violations or'deviat$.ons were. identified.

This activity is complete and no further NRC inspection is planned for this reference item.

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(3)

Third-Party Review of Design and Analysis (NRC

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Reference No. 06.b.02.04)

The third-party has performed a review of the design and analysis of the modifications made on the polar crane.

A description of the engineering calculations that were used for the acceptance of the design analysis can be found in the Results Report for ISAP VI.b.

The conclusion of the third-party review did not identify any unsatisfactory conditions that would not be corrected by the proposed design modifications and/or repair activities.

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The NRC inspector--reviewed the ISAP VI.b.Results Report, referenced calculations and modifications, and is satisfied with the' third-party review of design and analysis.

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No vio1ations or deviations were identified.

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activity is complete and no further NRC inspection

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is planned-for this reference item.

b.

Construction Reinspection / Documentation Review Plan.

(ISAP VII.c)

(1, B&R AWS D1.1 Welding (NRC Reference No.-07.c.36.00)

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The NRC inspector reviewed the Results Report for ISAP VII.c, Appendix 35, "Brown & Root AWS Dl.1

Welding."

The population of AWS Dl.~1 welding (B&R)

consists of a proportional sampling of the following VII.c populations..

Appendix 2 Cable Tray (CATY)

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Appendix 19 Structural Steel (STEL)

Appendix 28 Instrument Pipe / Tube' Supports (INSP)

Appendix 29 Large Bole Pipe Whip Restraints-(PWRE)

Appendix 30 Equipment: Supports (EQSP)

Appendix 32 Conduit' Supports (CoSP)

This appendix provides a combined evaluation of the results of weld inspections and documentation reviews to determine if additional tre'nds exist beyond'those already identified in the individual construction work category appendices noted above.

Three adverse trends and one unclassified trend were identified and are listed below.

These were also listed in their respective appendices.

The, respective trends were:

(1)

Failure to address backfit of a generic design change (cable tray).

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(2)

Missing welds (structural steel).

(3)

Missing welds (bumper restraints).

(4)

Weld profile deviations.

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No additional adverse trends were identified as a

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result of the combined analysis of results.

Construction deficiencies, unclassified trends, and adverse trends previously identified in any one

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i construction work category of this population were evaluated by CPRT for extension to other-

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construction work categories.

No additional generic implications were identified.

The B&R AWS D1.1 welding results report stated that

'the suitability of weld inspection through coatings in supporting the objectives of ISAP VII.c will be assessed in the quality of construction section of the Collective Evaluation report.

The Results Report concluded that pending satisfactory implementation of the applicable corrective actions in the Collective Evaluation Report and Appendices 2, 19, 28, 29, 30 and 32, there is reasonable assurance that the welding performed by B&R to AWS D1.1 requirements was properly accomplished.

The NRC inspectors did not identify any additional deviating conditions and feel that all applicable deficiencies and trends have been identified.

The NRC inspections of welds in the coated condition, and the results, can be found in the following reports:

50-445/85-18, 50-446/85-15, 50-445/86-03, SC-446/86-02, 50-445/86-07, 50-446/86-05, 50-445/86-15, 50-446/86-12, 50-445/86-22, 50-446/86-20, 50-445/87-16, 50-446/87-13, 50-445/87-18, 50-446/87-14, 50-445/87-25, 50-446/87-13 All questionc resulting from the NRC inspectors

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review sf th-J.esults Report and CPRT working files L

were a: swered ay the responsible CPRT engineer.

No violations or deviations were identified.

This activity is complete and no further NRC inspection

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is planned for this reference item.

l 6.

Corrective Action Plan (CAP)

Piping and Pipe Supports (50090)

l The NRC inspector conducted an inspection of hydrostatic pressure testing being performed by the applicant in accordance with the requirements of ASME Section XI of the Boiler and Pressure Vessel Code.

The purpose of the NRC inspection was to ensure that engineering, construction, and quality control personnel were cognizant of pressure testing requirements and that pressure testing was being accomplished in accordance with the procedural guidelines established by

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B&R ASME Construction Procedure ACP-12.1, "Pressure Testing,"

and B&R ASME Quality Procedure AQP-12.1, "Pressure Testing Inspection."

The NRC inspector witnessed Pressure Test 1-MS-120B, which was performed on a modified portion of the main steam system.

Verifications included but were not limited to the following:

Prope-completion of the Pressure Test Data Sheet

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Establishment of pressure test boundaries per the

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Pressure Test Data Package Gauge calibration and location

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Overpressure protection

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Valve positions (i.e. open, closed, gagged, tagged)

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Venting of piping high points

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Pressurization of system

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Pressure test acceptance criteric

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The NRC inspector noted that engineering, construction, and quality control personnel were aware of, and in compliance with, procedural requirements.

No violations or deviations were identified.

7.

Plant Tours (92700)

The NRC inspectors made frequent tours of Unit 1, Unit 2, and common areas of the facility to observe items such as housekeeping, equipment protection, and inprocess work activities No violations or deviations were identified and no itenis o * significance were observed.

8.

Management Meetings (30702)

On May 13, 1988, R.

F. Warnick, H.

H.

Livermore, and J.

S.

Wiebe met with L. D. Nace and A. B.

Scott and the following topics were discussed: (1) the closecut of open inspection. items will generally not be made until the changes (as appropriate) are made and the NRC has inspected them, (2) engineering dispositions / decisions are not always sufficiently conservative; for example, UT thru paint and the use-as-is disposition for old CPRT commodity clearance NCRs without adequately documented justification; (3) recently announced changes in the Office of Special Projects organization were described; and (?) the TU Electric review and approval of preoperational test procadures is not

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progressing as rapidly-as necessary to support the applicant's scheduled hot functional test date.

9.

Exit' Meeting'(30703)

An exit meeting was conducted June 7, 1988, wit.' the applicant's representatives identified in paragrcoh 1 of this report. 1k) written material was provided to the. applicant by the inspectors during this reporting period.

The applicant-did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.

During this meeting, the NRC inspectors summarized the scope and findings of the inspection.

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50-445/88-37; 50-4 4 6 /0P - 35 DISTRIBUTION:

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NRC PDR LPDR OSP Reading CPPD-LA

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CPPD Reading (HQ)

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