IR 05000445/1988040
| ML20151D572 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/15/1988 |
| From: | Livermore H, Phillips H NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20151D547 | List: |
| References | |
| 50-445-88-40, 50-446-88-36, IEB-78-04, IEB-79-28, IEIN-85-024, NUDOCS 8807250164 | |
| Download: ML20151D572 (11) | |
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S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS NRC Inspection Report:
50-445/88-40 Permits: CPPR-126 50-446/88-36 CPPR-127 Dockets: 50-445 Category: A2 50-446 Construction Permit i
Expiration Dates:
Unit 1: August 1, 1988 Unit 2t 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 & 2 Inspection At:
Comanche Peak Site, Glen Rose, Texas Inspection Conducted:
June 8 through July 6, 1988 i
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i Inspector:
2A 484 N JL.
7 - i f-86 H.
S.
Phillips, Senior Resident Inspector Date Constructica
Reviewed by:
LLW4 6 7-/f-86
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H. H. Livermore, Lead Senior Inspector Date
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88072{Q[g4 Ob45 K
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Inspection Summary:
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Inspection Conducted: June 8 through July 6, 1988 (Report 50-445/88-40s 50-446/88-36)
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Areas Inspected: Unannounced, resident.salety inspection oft (1) applicant's actions on IE Bulletins, (2) general plant i
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inspections, (3) fire prevention / protection, (4) safety-related
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piping / components, and (5) QA controls and administration.
Results:
Within the areas inspected, no violations, deviations, or
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unresolved /open items were identified.
This inspection was mainly
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a continuation of the inspection of the.arvice water system piping
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and coating removal.
Follow-up inspection was performed on a number of unresolved and open items (documented in the last NRC Inspection Report 50-445/88-34, 50-446/88-30).
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DETAILS 1.
Persons Contacted
- R. P. Baker, Licensing Compliance Manager, TU Electric
- J. L.. Barker, Manager, Engineering Assurance, TU Electric
- M. R. Blevins, Manager, Technical Support, TU Electric
- J. T. Conly, APE-Licensing, Stone and Webster Engineering
Corporation (SWEC)
- W. G. Counsil, Executive Vice President, TU Electric
- G. G. Davis, Nuclear Operations Inspection Report Item s
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Coordinator, TU Electric
- W. G. Guldemond, Executive Assistant, TU Electric i
- T. L. Heatherly, Licensing Compliance Engineer,
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TU Electric
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- R. T. Jenkins, Manager, Mechanical Engineering, TU Electric
- S.
D. Karpyak, CPRT, TU Electric
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- J. J. Kelley, Manager, Plant Operations, TU Electric.
- 0. W. Lowe, Director of Engineering, TU Electric
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- J. W. Muffett, Manager of Civil Engineering, TU Electric
- D. M. Reynerson, Director of Construction, TU Electric
- M. J. Riggs, Plant Evaluation Manager, operations, TU Electric
- C.
E. Scott, Manager, Startup, TU Electric
- J.
C. Smith, Plant Operations Staff, TU Electric
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- S.
L. Stamm, Project Engineering Manager, SWEC
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- P.
B. Stevens, Manager, Electrical Engineering, TU Electric t
- C.
L.
Terry, Unit 1 Project Manager, TU Electric
- J.
R. Waters, Licensing Compliance 'ngineer, TU Electile I
- C.
E. Watters, QA Program Manager, SWEC t
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The NRC inspectors also interviewed other applicant employees during this inspection period.
- Denotes personnel present at the July 6, 1988, exit
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meeting.
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2.
Applicant Action on IE Bulletins (92701)
The NRC inspector reviewed the status of IE Bulletins (IEBs)
inspected in NRC Inspection Reports 50-445/88-12,
40-446/88-10; 50-445/88-17, 50-446/88-14; and 50-445/88-34, 50-446/88-30.
The IEB packages presented to the NRC for
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- l closure were withdrawn after the NRC inspector identified a large number of packages that needed additional information.
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During this inspection period, the following IEB actions were
taken by TU Electric to close the following IEBs.
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(Closed) IEB 78-04, "Environmental Qualification of
Certain Stem Mounted Limit Switenes Inside Reactor
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Containment."
This IEB was issued on February 21, 1978, after Westinghouse (W) advised the NRC about Namco switches (D2400X or EA170-302) which were seismically, but not environmentally qualified for applications in a hostile environment.
This IEB was extensively reviewed in NRC Inspection Report 50-445/88-17, 50-446/09-14.
It was left epen pending the receipt of a re't/ sed response to th?" IEB and a presentation to describe the history concerning Numco switch procurement, qualification, and installation /rcinstallation through the present.
Paragraph 6.b describes the closcout of the first issue.
During this inspection period, TU Electric gave a presentation to the NRC to discuss the history of Namco switches.
The chronelogy presented is attached to this report.
This item is closed.
b.
(Closed) IEB 79-28, Possible malfunction of Namco Model EA180 Limit Switches at elevated temperatures:
This IEB was reported by an operating plant because the switch failed.
This IEB was extensively reviewed in NRC Inspection.
Report 50-445/88-17, 50-446/88-14.
This item remained open because the response contained an error and it was unclear as to whether any defective switches were found installed in Unit 2.
In the meeting discussed in the previous paragraph, TU Electric stated that no defective switches (per IEB 79-28) were found in Unit 2 and based this statement on the premise that all switches have been examined for the code number that would have identified defective switches.
TU Electric agreed that the response contained an error, that is, it reported 14 switches when in reality it should have read 14 valves with 2 - 3 switches por valve.
TU Electric requested that this acknowledged error be documented in this NRC report instead of generating a revised response.
The NRC inspector determined that there is no need for a revised response because it is a matter of correcting the record and this report corrects the record.
Although the old response will not be revised, it should be noted that l
the correct number of defective switches were correctly identified on a nonconformance report.
The NRC inspector
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also visually inspected the switches and confirmed that
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the switches were replaced with the proper model switch.
This item is closed.
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c.
(Closed) IEB 79-28, Identification (ID)
Recommendation 49, Namco Switches:
The above items related to ID Recommendation 49 in Enclosure 1 to the Stello Memorandum "Implementation of Recommendations of Comanche Peak Report Review Group" dated April 14, 1987.
These issues dealt with environmental qualification of Namco switches and project installation / reinstallation of switches.
The reviews documented above constitute sufficient basis for the close-out of ID Recommendation 49.
However, this close-out recogni' es
the tact that a NRC audit of the TU Electric Environmental Qualificatian will be performed in late 1988 or early 1989.
In addition, the problem with Namco switch travelers and instructions is related to this issue and is ciscussed in NRC Inspection Reports 50-445/86-20, 50-446/86-17; 50-445/88-17, 50-446/88-14.
The related items in these reports have distinct tracking numbers and will be tracked and inspected until these issued are resolved.
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ID Recommendation 49 concerning defective Namco switches is considered campleted and closed.
No violations or deviations were identified.
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General Plant Inspectipns (50053, 50073, 51063, SP)S3)
At various times during the inspection period, tha NPC inspector conducted general inspections of the U'd ' i reactor containment, safeguards, auxiliary, electrical c76c;al, and diesel generator buildings, the service water intake and the turbine buildings.
Selected rooms in these buildings were inspected to observe current work activities with respect to major safety-related equipment, electrical cable / trays, mechanical components, piping, welding, contings, and Hilti bolts.
Ti'e housekeeping storage and handling conditions inside those buildings and various outside storage areas were also inspected.
Work activities that were selected for more detailed inspections are described in paragraphs 5, 6, and 7.
No violations or deviations were identified.
4.
Fire Protection / Prevention (42051)
The NFC inspector observed plant conditions relative to material and heat source control during the inspections
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described in paragraph 3 above.
The plant was free of
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accumulated combustive materials and fire watch personnel were posted throughout the plant where welding was in P2ccess.
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addition, the inspector reviewed the resultc of several TU Electric surveillances of plant co.'ditions Nhich included cleanliness and control of combustible.,aterials.
No violations or deviations were identifiec.
5.
Safety-related Piping and Mechanical Components (49063, 50073)
During the previous inspection, the NRC inspector observed work activity and reviewed-the-files concerning Plasite coating deficiencies inside the service water system (SWS).
The record files and the SWEC Corrosion Report were reviewed.
Two unresolved and five open items were identified and documented in NRC Inspection Report 50-445/88-34, 50-446/88-30 dated June 17, 1988.
Additional inspection was performed during the present inspection period and results are discussed below.
a.
(Open) Unresolved Item (445/8834-U-01, 446/8830-U-01):
Procurement and application of Plasite coating inside SWS piping or other components / piping without QA/QC program controls.
The NRC inspector learned that ITT Grinell,
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the offsite vendor, applied the coating under the controls of a QA/QC program but Brown & Root procured and applied coatings at the site without QA/QC controls.
j Jnen, in 1980, the coating was found to be deficient, Gibbs & Hill, Inc., the architect engineer, was asked to evaluate the deficiency and was told of the coating applied without a QA/QC program.
The NRC inspector stated that this is unacceptable as Appendix B to 10 CFR Part 50 and the ASME Boiler and Pressure Vessel Code Section III, Revision 1, require QA/QC program controls which include special process and inspection criteria for j
acceptance.
These controls are required because of possible adverse effects _on the carbon steel ASME III,
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Class 3 piping.
During this inspection period the NRC inspector met with TU Electric, SWEC, and Ebasco personnel.
At various i
times these personnel stated that the requirements of Appendix B do not apply to various coating applications or the removal of a coating such as Plasite.
This philosophy is reflected in Sect. ion 9.2 of the Final Safety Analysis Report as it rsw makes no mention of the coating removal.
From Apr31 1988-until June 1988 the sandblasting was not mon 4;ored by quality control during the flint grit blast orsration or was a final inspection performed for possib?; wall thinning which could violate the minimum wall tP.ckness.
At the end of this inspection period, TU Electric made a presentation and stated that the sandblast activities were under 10 CFR 50 Appendix B program controls.
They also stated that
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minimum wall violations occurred, but were within the design stresses per ASME code.
This item remains open in. order to. review additional information provided in a meeting held on June 27, 1988.
b.
(open) Open Item (445/8834-0-02, 446/8830-0-02):
Inadequate evaluation of INPO SER 6883 and NRC Information Notice (IEN) 85-24.
The NRC inspector'
reviewed TU Electric evaluations of Plasite coating failures that occurred at another site.
The evaluations appeared'to be superficial in that they relied on 1980 G&H evaluation.
This raised questions regarding other TU Electric evaluations.
During this inspection period,.the NRC inspector-met with TU Electric representatives and discussed this item.
They stated that they recognized'that some evaluations prior to 1986 should be reviewed for similar weaknesses.
It is anticipated that this review will'take about six months.
This item remains open pending'the completion of this review.
At that time the NRC inspector will select and review a sample of the industry notices and the applicant's actions.
c.
(Open) Unresolved Item (445/8834-U-06, 446/8830-U-06):
Indeterminate inspection and monitoring of the sand blasting process inside SWS piping.
The inspector learned that the applicant's inspection consisted of entry inside 24 and 30 inch piping after sand blasting and viewing a video tape of-the inside of 10 inch tping.
Approximately June 3, 1988, this inspection criteria was questioned by the NRC relative to possible pipe wall thinning which could violate the minimum wall thickness.
i During this inspection period, the NRC inspector determined that no QC inspections were performed by certified QC inspectors and the monitoring of the rate of blasting and metal removal was not acco'aplished by QC
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during the operation.
However, some monitoring was done by engineering.
Thr NRC inspector also learned that no j
ASME inspectors or inspectors certified to ANSI N45.2.6
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were used to inspect or monitor this operation.
The NRC inspector revie /ed TU Electric Procedure EME 3.21-08, Revision 3, dated September 25, 1987, and Cannon Procedure QCP-1, Revision 2, dated April 18, 1988.
Neither of these procedures contained final acceptance criteria to assure that minimum wall thickness was not violated.
This remains unresolved pending further
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inspection of information presented at the meeting held i
on June 27, 1988.
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Quality Programs and Administrative Controls Affecting Quality (92701)
a.
Previously Identified Inspection Items (Closed) Unresolved Item (445/8516-U-02; 446/8513-U-02):.
TU Electric Task Force to review IEB files for completeness and appropriate action..
(This item was also
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identified as ID Recommendations 41, 42 and 43 in-the previously referenced Stello memo in paragraph 2c).. This item was thoroughly inspected and documented in, paragraphs 2.d and 4 of NRC' Inspection Report 50-445/87-36, 50-446/87-27.
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The.NRC inspector's past and present reviews show that TU Electric has established a system to assure that IEB hardware issues are properly addressed and documented in files.
These activities are now adequately controlled by Procedures NEO 4.01, Revision:0, and-ECE 2.29,
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IEBs received since 19861have been. evaluated
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and sufficient files have been maintained..IEBs received prior to 1986 have been rereviewed for applicability and actions needed to satisfy the IEB.-
This-unresolved item and the three recommendations are closed.-
b.
(Closed) Open Item (445/8817-0-01,r446/8814-0-01):
Nonconformance reports (NCRs) for Namco switches conflicted with the response to IEB 78-04.
The NRC inspector found that NCRs on Namco switches stated that the. Class 1E switches were not qualified to Electrical Standard lEEE-323 (1974).
.TU. Electric's response to.-
IEB 78-04 indicated Namco switches were qualified.
On June 6, 1988, TU Electric provided a supplemental response to the NRC.
7.t explained that subsequent to-their initial response (March 22, 1978) they found documentation for.Namco switches to be. inadequate.
This included qualified life problems and other problems such as lack of specific test parameters, questionable LOCA simulation, and lack of certification for seismic tests.
7.
Exit Meeting (30703)
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An exit meeting was conducted July 6, 1988, with the applicant'c 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 i
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~1nspection.
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CHRONOLOGY ON NAMCO LIMIT SWITCHhs Attachment
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Page'l of 3 2/78 IEB-78-04 Feceived R
3/78 TXX-2765 - To NRC - Stating TU position on IEB 78-04.
(1)..Namco Model D 2400X or EA-170-302 snaplock-switches will be used in certain safety related control circuits (2).
It is the applicant's position that any NSSS equipment under W scope will be environmentally qualified by W.
(3) Vendor survey to determine any unqualified Namco= switches were to be supplied by r ptember 29, 1978.
9/78 TXX-2884 - To NRC - for item (#3) - Vendor survey performed'
by C6H determined that only environmentally qualified Namco limit switches are being supplied used on safety-related valves inside containment.
12/79 IEB-79-28 Received s
12/79 TU established EQ grou-on-site - Review of qualification paper work was begun.
1/80 CPP-2513 - Internal letter requesting extension on response to IEB 79-28 due to insufficient qualified life and other qualification documentation issues regarding Namco EA-180 limit switches.
1/80 TXX-3091 - to NRC for extension on response to IEB-79-28, 3/80 GTN-44966 - To TU from C6H identified 14 valves which require replacement of the. top cover gasket per IEB-79-28.
3/80 TXX-3112 - was sent to NRC with TU's response to IEB-79-28.
's2 TU's resptnse was "We are' going to replace top cover gasket on only 14 switches.
We wf11 complete the work by June 30, 1980".
Note:
Due to ongoing Ls fort and discussion with Namco, proposed corrective actions were not completed in accordance with schedule provided in TXX-3112. The EQ effort covered 5 areas of concern identified in CPP-2411.
10/80 NCR-E-80-0088 was written due to the review of qualification papers on various equipment / components (Namco switches included). Documentation on Namco Limit Switches was found to be insufficient.
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4/81 CPPA-9697 - was written to the IEB-79-28 file.
Research
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determined that Namco Limit Switches manufactured after February 1980 had extended qualified life per.IEEE-323-1974.
Decision was made to replace all class lE Namco Limit Switches with new switches made after 1980.
Therefore the corrective
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action as indicated per TXX-3112 was not performed.
NCR's E81-106S and E81-113S were written to document the replacement
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of the Class 1E Namco Limit Switches.
7/81 CPPA-11339 - Internal letter concerning change to our response
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to the NRC per TXX-3112 was necessary. The decision was made to replace all switches in the scope of the. bulletin due to l
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Page 2 of 3
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7/81 TXX-3375 - To NRC - Advising them ofLthe change in.our
- ?vrective; action as specified in TXX-3112. As a result all switches within the scope of this bulletin will be totally replaced prior to plant operation.
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5/83 NCR-E81-0113S Rev 3 was closed 6/83 NCR-E81-00106S Rev 5 was closed Note: 'For above referenced NCR's, all DCA's, FCN's, Travellers etc. for the change out o'f Namco switches are available on site.
.11/84 Received IEN-84-57.
"Moisture in safety related equipment at commercial power plants".
TU's position was to ensure
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post work restoration included proper installation of h ousing seals, gaskets, etc.
12,'85 SDAR-85-43 was issued.
This SDAR addressed changes in ambiitnt temperatures. This required a review of the qualification files for qualified temperature limite on comp.onents.
Supplemental'TXX-88423 (5/88) issued stat.ing all corrective action completed.
2/86 SDAR-86-03 was issued.
The problems reported by SDAR-86-03:
were class 1E limit switches were not installed per manuf acturer's requirements shown on. labels affixed to the limit switch houting as follows:
(Ref. CAR-48)
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Apply a thread sealant to conduit threads.
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Applied torque to conduit threads not to. exceed 85 ft-168.
NE-10677 (8/87) Final response to CAR-48.
QIM-88181 (4/88) Internal letter requesting clarificatisn
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on final response to CAR 48.
NE-19175 (5/88) Internal letter clarifying the concerns of QIM-88181. SWEC has revised SDAR 86-03 response.
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(SWTU-8668, 6/88)
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11/86 Under Corrective Action Program (CAP) Impell took over EQ responsibilities.
During the process of design validation Impe11 reviewed IEN-84-57, SDAR-85-43 and.SDAR-86-03.
The result of this review was that Nanco Limit Switches on.
approximately 70 valves required the installation of ECSA's to maintain qualification.
(Ref IMT-3238)
6/87 SDAR 87-16 was issued.
This SDAR was issued in response to CAR-49.
CAR-49 was issued to address conduits which were routed to incorrect limit switches.
(i.e. conduits were installed to open limit switch where design required close limit switch and vice versa).
This CAR was initiated based on 6 NCR's against Unit #2.
It was determined that the CAR should also he reviewed against Unit #1 to address any possible g;ueric implications.
TXX-88156 (1/88) Final response sent to NRC.
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Present/1988 That bring us to our current program.
The response to SDAR 87-16 states that a walk down of all lE Namco Limit Switches will' be performed per FVM CPE-SWEC-FVM-EE/ME/IC/CS-89. This will lxa done as part of the Post Construction Hardware Validation Program (PCHVP). Model numbers and date codes will be recorded.
The model number and date code facilitate traceability to the applicable qualification test report for establishing qualification of the installed limit switches.- Typical limit switch orientation drawings will be prepared.
Each limit switch will be tagged.with a unique identifier. Wiring diagrams-will be revised to show internal destination of each wire.
In order to ensure qualification requirements are met for new and existing designs, qualification parameters have been clearly established / defined for each room and area.
Specification 2323-ES-29 dictates purchase requirements for different plant areas.
Installation and torquing requirements are identified in Erection Specification 2323-ES-100. QC procedure QI-QP-11-3-47 specifies inspection criteria and EEQSP-ES-29 specifies component qualified life and maintenance
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requirements.
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