IR 05000445/1988039
| ML20196L595 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/24/1988 |
| From: | Bitter S, Burris S, Singh A NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20196L591 | List: |
| References | |
| 50-445-88-39, 50-446-88-33, NUDOCS 8807080039 | |
| Download: ML20196L595 (15) | |
Text
'
o
.
-
.
.
O U.
S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS NRC Inspection Report:
50-445/88-39 Permits: CPPR-126 50-446/88-33 CPPR-127
'
Dockets: 50-445 Category: A2 50-446 Construction Permit
/
Expiration Date:
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),
Units 1 and 2 Inspection At:
Comanche Peak Site, Glen Rose, Texas Inspection Conducted:
May 4 through June 7, 1988 Inspector:
)df S. D.
Bitter, Resident Inspector,
/ Date Operations Inspector:
/[
A. Singh, Reactd'r Operation Engineer, Date Region IV Inspector:
JV ff S.
P.
Burris, Senior Resident Inspector,
/ Date Operations pgg7MsBloo$4'
G
-
_ _ _ _ _ _ _ _ _ _ _ _ _ _,
.
,..
,
-Reviewed b :
JY k
,
at, J.
S. Wiebe, Lead Pn ject Inspector
'Da t'e Inspection summary Inspection Conducted:
May 4 through June 7, 1988 (Report 50-445/88-39; 50-446/88-33)
~ Areas Inspected:
Unannounced resident safety inspection of applicant's action on previous inspection findings, preoperational retesting program, management meeting, monthly maintenance
. observations, NRC Bulletin follow-up, plant tours, and fire protection.
Results:
Within the areas inspected one matter involving failure to formally document deficient conditions was identified as a weakness and as an unresolved item (paragraph 7).
..
...,
-
>
-
- _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
. _ _ _ - _ _ - _ _ - _ _ _ _ _ _ - _ _ _ _ _ _
_ _ _ _ _ _
._
_ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _,
.
'
.
-
DETAILS 1.
Persons Contacted
- R..O.
Bab, Fire Protection Engineer, TU. Electric
- M.
R. Blevins, Manager, Technical Support, TU Electric
- W.
G.
Counsil, Executive Vice President, 10 Electric
- R.
L. Dible, Supervisor, Fire Protection Engineer, Impell
- J.
E. Echternacht, Project Engineer, Impell
- T.
L. Heatherly, Licensing Compliance Engineer, TU Electric
- R.
C. Howe, Electrical Engineer, Engineering, Planning &
Management
'
- R.
T. Jenkins, CPE Manager, TU Electric
- J.
J. Kelley, Manager, Plant Operations, TU Electric
- R.
F. Layton, CPE, Supervisor, Engineer, TU Electric
_
- E.
Margalejo, Manager Fire Protection, EPM
- J.
W. Muffett, Manager of Civil Engineering, TU Electric
- L.
D. Nace, Vice President, Engineering & ConstInction, lli Electric
- D. M. Reynerson, Director of Construction, TU Electric
- A.
B. Scott, Vice President, Nuclear Operations,'TU Electric
- T.
G. Tyler, Director of Projects, TU Electric
- K.
C. Warapius, Project Director, Impell
- J. H. Wawrzeniak, Project Manager, Impell
- T.
L. Wright, CPE Engineer, TU Electric The NRC inspector also interviewed other applicant employees during this inspection period.
- Denotes personnel present at the June 7, 1988,. exit interview.
,
,
- Denotes personnel present at the May 5, 1988, Fire Protection I
exit interview.
l 2.
Applicant Action's on Previous Inspection Findings (92701)
l l
)
a.
(Closed) Open Item (445/8513-0-07):
Retest of l
Valve 1SI-8815.
The inspectors discussed this issue with
!
the inspector who originally identified this concern and found:
<
(1)
Retest of this valve would be accomplished prior to initial criticality when the required plant conditions were available, as outlined in the deferred preoperational test report.
(2)
The applicant intends to test Valve 1SI-8815 during the next plant heatup, in accordance with Initial Startup Procedure ISU-010A.
This item is maintained
.
.
-
_
J
. - - _ - _.
'
.
.
by Results Engineering and will be formally retested to ensurc~the equipment' meets its acceptance
'
criteria at the appropriate plant conditions; i.e.,
pressure, temperature,. system alignment, etc.
This item is not requircd for tracking purposes.
Based on the above, the inspectors consider this item closed.
b.
(Closed) open Item (445/8516-o-10):
Determination of root cause.
The inspectors discussed this issue with the inspector who originally identified this concern and found:
(1)
CPRT ISAP III.a.1, Hot Functional. Testing (HFT) Data Packages has been resolved by subsequent NRC IE Inspection Reports 50-445/85-11, 50-445/85-13, 50-445/87-16, and 50-445/87-21 which will be identified in a Supplemental Safety Evaluation Report to be issued in the near future.
(2)
The applicant's commitment as identified'in the CPRT Program Plan, Appendix E, would provide root cause determination and/or. contributing causes for all deficiencies which came out of the CPRT Review.
Since there were no deficiencies identified by CPRT Review'of ISAP III.a.1, there was no determination of root cause or generic implications required.
Based on the above, the inspectors consider this item closed.
i c.
(Closed)-Open Item (445/8607-O-23):
Procedure compliance l
with FSAR.
The inspectors discussed this item with the l
inspector who originally identified the concern.
This i
item was generated to track moving the review of commitments from ISAP III.b to ISAP III.a.1.
The original inspector found that resolution and closecut of this item had been addressed in the CPRT Final Results Report and will be addressed in the Supplemental Safety Evaluation Report which will be issued in the near future.
The original inspector informed the resident inspectors that they could close out this item in their inspection report.
3.
Preoperational Retesting Program (70301)
During this inspection period, the NRC inspectors reviewed the l
applicant's Unit 1 preoperational retest program.
This review included discussions with preoperational testing supervision,
'
procedure completion review, attending weekly preoperational l
l
.
--.
-.
,-,.
.
- --
.-
.,,,
fi
.
,
~
.
.
.
testing status meetings, review of proposed retesting schedule, and interviews with selected preoperational testing personnel.
Currently, the preoperational test group procedure task force has completed one procedure for use and have approximately 50 procedures issued for comment.
,
The inspectors will continue to review preoperational retesting activities during future inspections.
4.
Management Meeting (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 r
'
without adequately documented justification; (3) recently announced changes in the Office of Special Projects organization were described; and (4) the TU Electric review and approval of preoperational test procedures is not progressing as rapidly as necessary to support the applicant's scheduled hot functional test date.
5.
Monthly Maintenance observation (62703)
a.
The NRC inspector observed portions of selected maintenance activities during this inspection period:
(1)
The boroscopic examination of the Unit 1, Train B, residual heat removal pump motor shaft for oil leakage.
(2)
The calibration of various protective relays for Bus 1EB04.
(3)
The installation, cleaning, and rolling of the tubing for the Unit 1 component cooling water heat l
exchangers.
I No discrepancies were identified during the direct observation of maintenance activities.
However, upon examining issued field drawings associated with changing the setpoints of various protective relays, the inspectors noted that when discrepancies between I
equipment configuration and equipment drawings were l
identified there was no subsequent method being used to
!
document the deficiency.
This is identified as one example in the unresolved item in paragraph 7.e.
l l
l l
.--
-
.-.
.--
,
-
'
I
.
\\
b.
During this inspection period, the inspectors reviewed the applicant's activities associated with the coatings removal on the Unit 1, Train A and B, station service water system.
The applicant performed this coatings removal to prevent similarly identified problems as outlined in IE Information Notice 85-24, "Failures of Prctective Coatings in Pipes and Heat.Exchangers," issued in March 1985.
This IEN identified that a similar plant experienced problems with delamination and peeling of the ingerior applied epoxy lining in three 24 inch diameter
elbows.
Closer examination of the suspected piping system found similar blistered areas in the lining.
'It was subsequently detecmined that separation of the epoxy lining from the piping could lead to flow restrictions in the affected piping system.
CPSES has identified that the station service water system had similar coatings applied :to the interior of the piping.- The original issue, subsequent corrective actions, and new NRC concerns are discussed in NRC IE Report 50-445/8834; 50-446/8830.
Current corrective acticns include using a
"sand blasting" process to remove this coating.
This is in progress for CPSES Unit 1.
The inspectors obtained the current status of the completion for Unit 1, Train A and B, station service water system from the applicant.
Current completion status for Unit 1 is as follows:
Unit 1 - Train A Large Bore Piping (24" and 30") - 100% coating removed and was accepted by TU Electric as satisfactory.
Small Bore Piping (10") - Approximately 65% removed to date.
Applicant personnel stated that they are experiencing problems removing all of the coating in that some specks of the coating are still on thc pipe interior.
They will evaluate these specks to ensure that
'
there would not be a problem leaving "as is."
Train B coatings removal will be performed after
'
l I
completion of Train A.
The inspectors will continue to follow-up on these activities during future inspection periods.
,
No violations or deviations were noted.
L
!
6.
NRC Bulletin Follow-up (92703)
(Closed) IEB 84-03, (445/IEB 84-03; 446/IEB 84-03):
Refueling water cavity seals.
Additional inspection of this bulletin is l
!
documented in NRC Inspection Report 50-445/88-31; 50-446/88-27.
Unit 1 and Unit 2 both use all metal reactor
.,
.
.
.
cavity seals..Dbring this inspection period, the inspector reviewed the applicant's decision to delete the commitment to visually check the reactor cavity prior to fuel. movement for significant seal leakage after filling the refueling cavity.
The inspectors.also reviewed the applicant's newly revised alarm and refueling procedures and found these documents to be an acceptable alternate method for monitoring the reactor cavity.
This item is closed.
7.
Plant Tours (71302)
The NRC inspectors conducted numerous plant tours during this inspection period.
These tours provided coverage during
'
normal, off-normal', and backshift working hours.
During the tours, inspection activities included reviewing work documentation, witnessing ongoing work activities, observing and interviewing shift operations personnel, reviewing the status of control room construction work, reviewing the status of system and component completion, observing the status of Units 1 and 2 equipment lay up, observing housekeeping activities, and inspecting for general safety compliance.
To support these activities, NRC inspectors attended numerous plan-of-the-day meetings and observed several shift turnover briefings.
In addition, the resident inspector attended the general employee training and radiation worker training courses.
The inspectors findings are discussed below:
a.
During the course of the tours and inspections,'the NRC inspectors noted the following:
(1)
Control room construction appears to be progressing within the applicant's announced schedule.
>
(2)
Housekeeping activities are being adequately implemented.
(3)
The Unit 2 lay up program is being implemented.
Thirty of the 78 major systems are currently in lay up; the remainder are scheduled to be placed in i
lay up during July.
(4)
Radiography activities have been the source of five violations of radiological barriers during the last eight months.
None of the violations involved exposure of individuals to radiation.
These incidents were identified by TU Electric and addressed in a Plant Incident Report, PIR-88-077.
The radiation protection manager in evaluating this incident report identified the root causes of these incidents as being apathy and a lack of concern toward radiation barriers.
A lack of proper
'
i r
>
+
-.
.
-
i training, coupled with a substantial increase in the
'
amount.of radiography, has been deemed a contributing cause.
To prevent a reoccurrence of these incidents,.the utility has instituted several j
measures.
First, all radiographic' operations will be' announced via the in-plant Gaitronics system.
Second, all nuclear operations and engineering and construction personnel will be warned (via a memorandum).of the consequences of-violating radiological barriers.
Finally, site contractcrs have emphasized training: Brown and Root has incorporated radiography safety into its weekly safety meetings, Burns Security (Industrial) has
-
briefed its personnel on radiography safety, and the TU Electric general employee training (which' covers the recognition of radiological barriers) has been initiated for all security personnel.
b.
The inspectors reviewed the applicant's Quality Assurance Surveillance Program (QA Surveillance) to ascertain the l
status of QA surveillance activities.
This review included interviews of personnel, review of procedures, review of previously completed surveillances, and actions required by any identified discrepancies..
The inspectors reviewed all Quality surveillance Reports (QSR) (Nos.
QSR-85-012, QSR-85-021, QSR-86-025, QSR-86-041, QSR-86-053, QSR-87-019, QSR-87-020, QSR-87-026, QSR-87-042, QSR-87-068 and QSR-88-008) issued from 1985 to the present dealing with temporary modifications.
The inspectors discussed the applicant's handling of the results of the QSRs with QA surveillance. supervision and questioned the methodology used in resolving some of the QA identified concerns.
.It was not apparent to the NRC that some method of formal deficiency identification was used.
One QSR identified that the system test engineer (STE)
was required to provide a copy of the temporary i
modification package to results engineering in accordance l
with STA-602.
This was not accomplished until QA l
discussed the issue with startup supervision.
QA l
suggested that the STEs be given training on this issue.
No training was given the STEs; however, the startup manager issued a memo (STM-87044) reminding STEs of the need to review other organizations procedures they may use prior to performing the activity.
Subsequent i
follow-up of this issue found that although the memo had been issued, the STEs were not on distribution to receive it.
It (the memo) was reissued to the STEs.
This is another example of the unresolved item identified later in this report which deals with formally documenting identified deficiencies.
The inspectors informed the i
t
-
-
_
.
.
.
,
!
,
applicant personnel that they would continue to monitor this program.during future inspection periods.
c.
On May 24, 1988, the NRC inspector observed workers overhauling the steam-driven auxiliary feedwater (AFW)
pump.
The pump was being re-overhauled following a recent overhaul because the gap between the head and the block of the pump was excessive after torquing.
Subsequent follow-up with results engineering revealed that a nonconformance report (NCR) was not written because NEO Procedure 3.05 did not require an NCR to be
'
written if the nonconforming condition could be scrapped, reworked, or repaired.
In this case, the pump could be reworked to meet the original gap specified in the maintenance procedure.
The NRC inspector stated that a nonconformance should have been written on the gasket when it was found to be unacceptable and also to address the improper material (spare part) supplied by the vendor.
The material was too thick and prevented the proper gap between the head and block of the pump.
At a subsequent meeting between the NRC and operations personnel, TU Electric personnel stated that they may issue a NCR.'
Answers to NRC questions concerning procurement and receipt inspection were not available.
Also, no information was available as to whether this gasket material was installed in other equipment.
l d.
Review of the control room. logs revealed that TU Electric personnel had identified that Temporary
'
Modification 85-0573 for Steam Generator Blowdown Valve 1PCV-5180 had been implemented to keep the pneumatic controller in the open position, but the temporary modification did not have the procedurally i
i required tag attached.
This was identified by the inspectors as an example of failure to formally document
,
the problem in a manner that assures "root cause"
'
determination and appropriate corrective action.
e.
Four examples of the applicant's failure to formally document deficient conditions were identified by the NRC l
inspectors (discussed in paragraphs 5.a, 7.b, 7.c, and l
7.d).
All four examples involve nuclear operations l
personnel.
The NRC has identified this as a weakness in
'
the operations area.
Unless deficient conditions are documented in a formal system, there is no assurance the root cause of the problem will be identified or that appropriate corrective action will be taken.
The NRC staff met with TU Electric operations management on June 3, 1988, co discuss these specific concerns.
_
_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _,
2-
.
,
,
TU Electric committed to investigate the NRC concerns.
This is identified as an Unresolved Item-(50-445/8839-U-01), identification and resolution of deficient conditions.
'8.
Follow-up on Previously Identified Fire Protection System Inspection Findings (92701, 67703)
a.
(open) open Item (445/8722-0-01):
Seismic analysis of the reactor coolant pump (RCP) lube oil system.
The NRC inspector had found that the seismic analysis for the-RCPs had not been completed.
By letter dated March 11, 1988, TU Electric stated that the seismic qualification analysis of the RCPs was scheduled for completion by July 31, 1988.
Further, any design modifications necessary to support the seismic qualification of the RCP lube oil collection system will be scheduled for completion by October 1, 1988.
This item will remain open pending completion of the analysis by TU Electric and review by the NRC.
b.
(Closed) open Item (445/8722-0-02):
Unrated steel hatches.
Several fire barriers separating redundant trains of safe shutdown equipment had been identified by the NRC inspector as not being 3-hour rated.
Specifically, unrated steel hatches were located in fire area boundaries.
TU Electric presented an analysis which stated that it was not likely that a fire would propagate through the hatches, because of low combustible loading on both sides of each hatch, automatic suppression on at least one side of each hatch, and one-hour fire resistive coating on both sides of each hatch.
The inspector reviewed the l
analysis and found it acceptable.
By letter dated April 29, 1988, TU Electric identified the unrated steel hatches as a deviation from Section D.l(j) of Appendix A to BTP APCS 8 9.5-1.
Based on the inspector's review of the analysis and TU Electric's documentation of the item as a deviation, this item is considered closed.
c.
(closed) open Item (445/8722-0-03):
Penetrations in barriers.
The NRC inspector had expressed concern that i
the method of sealing conduits 4 inches in diameter and smaller was not in accordance with rated configurations and had not been identified as a deviation from staff guidance.
TU Electric stated that the conduits with either suppression or detection on both sides of the penetration would only be sealed on one side, while l
conduits with no detection or suppression on at least one
!
side would be scaled on both sides at the first opening.
The NRC inspector was concerned that this plan would l
l L
.
-
.
.
allow for only one seal.outside of the barrier in locations where there was only detection on both sides of the barrier with no suppression on either side.
TU Electric. agreed to revise their position and committed to seal conduits 4 inches and smaller on both sides at the first opening regardless ef the presence of detection or suppression.
.By letter dated May 3, 1988, TU Electric informed the staff that where suppression and detection are provided on both sides of the barrier, conduits 4 inches and smaller will be sealed on one side or in the barrier.
Where suppression and detection are not provided on both sides of the barrier, the conduit penetration will be sealed on both sides or in the barrier.
The inspector found the commitment in TU Electric's May 3, 1988, letter to be acceptable and; therefore, this item is considered closed.
d.
(Closed) Open Item (445/8722-0-04):
Fire doors.
The NRC inspector had observed a number of modifications to fire doors, primarily for security hardware.
Although the doors and ramps contained labels which demonstrated compliance with testing criteria for Underwriter's Laboratory, the inspector was concerned that these nodifications would degrade the performance of the door under fire conditions.
TU Electric presented the documentation from Underwriter's Laboratory concerning
,
how security modifications could be made without jeopardizing the rating of the door.
However, these guidelines may not have been implemented during modification of the plant fire doors.
TU Electric committed to review all installed fire doors to determine if modifications comply with guidance provided by Underwriter's Laboratory.
Where compliance cannot be established, TU Electric committed to bring the door into compliance or replace the door with one that conforms to the guidelines.
TU Electric also committed to ensure that all future modifications will conform to the guidance established by Underwriter's Laboratory.
By letter dated March 11, 1988, the applicant stated that the guidelines provided in Underwriter's Laboratories, Inc., letter dated September 7, 1984, have been implemented.
Inspection attributes have been provided (
and added to specifications for fire barriers per l
DCA 67208 as a part of the post construction hardware i
validation program to assure compliance with the l
guidelines in safety-related buildings.
The inspector l
found these actions to be acceptable and, therefore, open l
Item 445/8722-0-04 is considered closed.
!
J
?{
o
'
'
'
itT
.
.
.
..
,
e.
(Closed) Open Item (445/8722-0-05):. Emergency _ lighting.
The inspector had observed areas.where additional emergency' lights may be required.
By letters dated March 11 and May 3,1988,1NJ Electric -stated, that Impell Calculation 0210-063-0034 concerning the emergency-lights Twould be revised by May 27, 1988, to address additional
-
lighting required as a result of the: revision of the safe
-
shutdown analysis.
Required changes in emergency lighting will be identified in deficiency reports.
,
.In a letter dated May 3, 1988, TU Electric stated that Deviation Report (DR) P87-05230 was issued to identify a need for an 8-hour battery pack emergency lighting unit at Valve 1-HV-8112,-as discussed in Section 6.1.2 of NRC Inspection Report 50-445/87-22.
DCA 64,191 Revision 1,
. scheduled for implementation by July 31, 1988, will include.the new lighting requirements. :Other valves discussed in Section 6.1.2 (1-8808D, 1-FCV-618, 1-HCV-606, ICI-651) are valves requiring operation to achieve post' fire cold shutdown.
In accordance with the NRC guidelines, equipment required to attain cold shutdown does not require emergency lighting, since cold shutdown procedures are less time controlled and may be accomplished using onsite capability such as additional manpower, battery powered portable hand lights, or establishing onsite power.
The.NRC inspector found these actions and commitments to be. acceptable and; therefore,
- Open Item 445/8722-0-05 is considered closed.
f.
(Closed) Ooen Item (445/8722-0-06):
The use of Halon fire extinguishing agents.
The inspector was concerned that the Halon System provided in the Cable Spreading Room may not~be in compliance with NFPA 12A.
TU Electric indicated that the review of the system against the requirements of NFPA 12A had not been performed.
By letter dated March 11, 1988, the applicant stated that l
NCR 87-00748 was. initiated on October 14, 1987, to identify a nonconformance regarding the Cable Spreading
'
Room Halon System.
A design modification has been issued
~
'
to upgrade the Cable Spreading Room Halon System to comply with applicable specifications and sections of the NFPA 12A code.
This work is scheduled for completion by
'
July 15, 1988.
After the modification, a full functional l
Halon concentration test wi.ll be conducted to ensure the I
system operates within the criteria established by NFPA 12A.
The NRC inspector found this commitment acceptable.
Therefore, Open Item 445/8722-0-06 is
considered closed.
'
L
'
g.
(closed) Open Item (445/8722-0-07):
Labeling of valves.
-
The NRC inspector had noted that the emergency air
,
,
--
e p
,--,---*e-t,
-
e.
,
+,,.,.-,r
,
9-.,_.,.#,.,.,,-,,%p.my.
,,,-,--,_,,-..-.,,e---
v--r-w--*---,----
m-------w
-
e-*
, __
_
._
.
__
._
-*
n4
'
.
.
.
supplies to RHR Valves.1-FCV-618 and 1-HCV-606 and Instrument Air Valves ICI-650'and ICI-651 were difficult-to locate and poorly labeled.
By letters March 11 and May 3, 1988, the applicant stated that new signs and labels have been installed for these valves.
The NRC inspector verified that these signs and labels have been-installed; therefore, open Item 445/8722-0-07 is considered closed.
h.
(closed) Open Item (445/8722-0-08):
Gould A25X30 fuse.
The NRC inspector had noted that DCA 61447 was initiated to resolve the consequences of uncoordinated 125 VDC Circuits EG-104509, EG 145211, and EG 130661.
This DCA when implemented, would require the installation of branch circuit fuses or the installation of thermo-lag protection.
By letter dated March 11, 1988, TU Electric stated that NCR.87-02812 was initiated on November 16, 1987, to identify that the installed Gould A25X30 fuses did not comply with the design which. required Bussman BAN-30A fuses.
.As the installed Gould A25X30 fuses are the desired branch circuit fuses needed to resolve the consequences of uncoordinated 125 VDC circuits, TU Electric stated in their March 11, 1988, letterLthat the NCR has been dispositioned "Use-as-is."
DCA 61447 which was originally issued to implement installation of Gould A25X30 fuses will be cancelled.
The NRC inspector finds these actions acceptable.
Therefore, Open Item 445/8722-0-08 is considered closed.
1.
(Open) Open Item (445/8722-0-09):
Associated circuit analysis.' TU Electric identified circuits which were not completely analyzed to account for ampacity effects due to increased operating temperature resulting from thermal-lag wrap.
By letter dated May 3, 1988, TU Electric stated that the associated circuits analysis related to this issue are complete.
This item will remain open pending staff review of the analysis.
j.
(Closed) Unresolved Item (445/8722-U-01):
Stairwell
<
walls.
The inspector had identified six stairwell walls where the provided justification was not adequate to support a two-hour fire rating.
The construction of the six stairwell walls could not be verified to meet the installation criteria established by a recognized approval agency.
-
L l
By letters dated March 11 and May 3, 1988, the applicant I
stated that DR No. C-87-414 was initiated on October 14, 1987, identifying the six questionable stairwell walls.
The fire protection program consultant for TU Electric (Impell) dispositioned the DR by requiring field verification of construction by opening the walls.
-.
.-.. _ __ _
-..
-
-.
.
. _
.
.
.
-
~
.
. _ _ _
_
__.
. _ _ _ _ _ - - _ _ _ _ _ _ _ _ __
'
,
.
r i
,
.
-TU Electric initiated revisions tc DCAs to incorporate attributes into design documents and update Specification 2323-AS-36.
Further, the verificaticn of hidden construction attributes and closecut of the 3R will be performed as part of the post construction hardware validation program.
The NRC inspector found this commitment to be acceptable.
Therefore, Unresolved Item 445/8722-U-01 is considered closed.
k.
(closed) Unresolved Item (445/8722-U-02):
Manual actions.
The original issue dealt with the adequacy of those manual actions which must be taken in the same area as the_ postulated fire.
By letter dated May 3, 1988, TU Electric provided revised Calculation 152 which con'.ained a revised listing of all the manual actions required in the same fire area as the postdated fire.
The NRC inspector reviewed the listing and the justifications of the identified manual actions and found them to be acceptable.
Therefore, Unresolved Item 445/8722-U-02 is considered closed.
1.
(closed)_ Unresolved Item (445/0722-U-03):
The inspectors had identified a concern regarding calculations stated to show the pressurizer relief-tank (PRT) rupture disk would rupture at 52 minutes following transient initiation (Case 5 in WCA10 11331, the spurious operation of tne SI System).
The rupture would occur well before operator actions would need to be taken inside containment in response to a postulated fire.
By letter March 11, 1988, the applicant provided the information concerning the PRT rupture.
The applicant l
has revised the methodology concerning the manual operation of the valve SD-8112.
During the May 2-4, 1988, visit at the site the revised methodology and the l
calculations were reviewed by the NRC inspectors.
In order to realign Motor Operrted Valve SD-8112 following a fire in the fire crea, it may be necessary to de-energize
.
the power feeder from the MCC associated with L
MOV SD-8112.
This manual action must be accomplished within three hours following a fire in this area.
The i
NRC inspectors discussed with operations personnel the manual operation of this valve.
Based on the discussions and review of the calculations, the manual operation of this valve is found acceptable.
Therefore, the Unresc1ved Issue 445/8722-U-03 is considered closed.
m.
(Closed) Unresolved Item (445/8722-U-04):
The control circuit for Accumulator Isolation Valves 1-8808A, B, C,
cnd D is not electrically isolated from the control room.
The inspectors had understood that TU Electric intended to use jumpers to maintain control or manually operate
.
.
_ _
-
~_.
.
. _ _ _ _
J
- - - - - - - -
-
O
..
a
,
.
the valves during hot shutdown.
The inspection team considered this action a hot shutdown repair which is not consistent with staff guidelines.
By letter dated March 11, 1988, the applicant stated that CPSES Procedure ABN-803-A provides for manual actions to
close the above mentioned valves.
The manual actions are completed prior to RHR cut-in.
Further, TU Electric stated that the jumpers are not used to close these valves for achieving and maintaining hot shutdown.
Based on this information Unresolved Item 445/8722-U-0a is considered closed.
9.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or deviations.
One unresolved iten disclosed during the inspection is discussed in paragraph 7.e.
10.
Exit Meeting (30703)
An exit meeting for the NRC inspection of the fire protection issues was conducted by Mr.
A.
Singh on May 5, 1988.
This exit was attended by R.
F. Warnick and utility representatives.
An exit meeting was conducted on June 7, 1988, with the applicant's representatives identified in paragraph 1 of this report.
No written material was provided to the applicant by the inspectors during this reporting period.
The applicant did not identify as proprietal any of the materials orovided to or reviewed by the inspectors during this incoccrio...
During this meeting, the NRC inspectors summarite-I the scope and findings of the inspection.
l
>
--
.