IR 05000445/1988056
| ML20245D925 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/30/1988 |
| From: | Livermore H NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20245D915 | List: |
| References | |
| 50-445-88-56, 50-446-88-52, IEB-87-007, IEB-87-7, IEB-88-005, IEB-88-5, NUDOCS 8810070308 | |
| Download: ML20245D925 (26) | |
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APPENDIX'B U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS
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NRC Inspection Report:
50-445/88-56'
-Permits: CPPR-126 50-446/88-52 CPPR-127 Dockets: 50-445 Category: A2 50-446 Construction Permit Expiration Dates:
Unit 1: Extension request submitted.
i 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),
l Units 1 & 2 Inspection At:
Comanche Peak Gite, Glen Rose, Texas Inspection Conducted:
August 3 through September 8, 1988 Inspection conducted by NRC consultants:
J. Dale - EG&G (paragraph 2.c, 3.d, 3.f, and 7.a)
K. Graham - Parameter (paragraph 2.a-b, 3.a-c, 3.e.
3.g-h, 4.a, 5, and 7.c)
P. Stanish - Parameter (paragraph 2.d-e, 3.1, 4.b-c, 6, and 7.b)
Reviewed by:
~7 f 44'aot f-
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H. Liv'ermore, Lead Senior Inspector Date 8810070308 881093 PDR ADOCK 05000445
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Inspection Summary:
Inspection conducted: August 3 through September 8, 1988 (Keport 50-445/88-56; 50-446/88-52)
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Areas Inspected: Unannounced, resident safety inspection of applicant actions on previous inspection findings, follow-up on vj olations/ deviations, follow-up on NRC Compliance Bulletins, review of 10 CFR 50.55(e) construction deficiencies, structural
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I steel connections, HVAC ducts and supports, conduit supports, pipe f
support and restraint systems, and general plant areas (tours).
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Results:
Within the areas inspected, the NRC inspections did not identify any strengths or weaknesses.
Two violations I
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(paragraph 2.b and 3.1) were identified which concern the review and approval of design calculations and the dispositioning of i
nonconforming material.
Two unresolved items (paragraph 6 and 7.c)
related to torquing requirements and slugged welds were identified.
One open item (paragraph 7.a) related to NCR dispositions was identified.
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DETAILS 1.
Persons Contacted
- R.
W. Ackley, Jr., Project Manager, Stone & Webster Engineerin1 Corporation (SWEC)
- M.
Axelrad, Attcrney, Newman and Holtzinger, P. C.
- R. P. Baker, Licensing Compliance Manager, TU Electric
- J. L. Barker, Manager, Engineering Assurance, TU Electric
- H.
D. Bruner, Senior Vice President, TU Electric
- W.
J. Cahill, Consultant, TU Electric
- J. T. Conly, APE-Licensing, SWEC
- W. G. Counsil, Executive Vice President, TU Electric
- J.
C.
Crnich, PIoject General Manager, Ebasco
- G.
G. Davis, Nuclear Operations Inspection Report Item Coordinator, TU Electric
- S. H. Freid, Chief Mechanical / Nuclear Engineer, Bechtel
- T.
L. Heatherly, Licensing Compliance Engineer, TL Electric
- C. B. Hog, Engineering Manager, Bechtel
- R. T. Jenkins. Manager, Mechanical Engineering, TU Electric
- J. J. Kelley, Manager, Plant Operations, TU Electric
- J. E. Krechting, Director cf Technical Interface, TU Electric
- O.
W. Lowe, Director of Engineering, TU Electric
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- F. W. Madden, Mechanical Engineering Manager, TU Electric
- J.
C. Miller, CPRT, Tenera
- J. W. Muffett, Manager of Civil Engineering, TU Electric
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- L. D. Nace, Vice President, Engineering & Construction, TU Electric
- E.
Ottney, Representative, CASE
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- S. S. Palmer, Project Manager, TU Electric
- J. D. Redding, Executive Assistant, TU Electric
- D. M. Reynerson, Director of Construction, TU Electric
- M. J. Riggs, Plant Evaluation Manager, Operations, TU Electric
- E. J. Schmidt, Radiation Protection Manager, TU Electric
- A. B. Scott, Vice President, Nuclear Operations, TU Electric
- C. E. Scott, Manager, Startup, TU Electric
- S. L. Stamm, Project Engineering Manager, SWEC
- P. B. Stevens, Manager, Electrical Engineering, TU Electric
- J.
F. Streeter, Director, QA, TU Electric
- C. L. Terry, Unit 1 Project Manager, TU Electric
- T. G. Tyler, Director of Projects, TU Electric
- R. D. Walker, Manager of Nuclear Licensing, TU Electric
- K.
C. Warapius, Project Director, Impell
- J. R. Waters, Licensing Compliance Engineer, TU Electric The NRC inspectors also interviewed other applicant employees during this inspection period.
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- Denotes personnel present at the September 8, 1988, exit meeting.
2.
Applicant Action on previous Inspection Findings (92701)
a.
(closed) Open Item (445/0516-0-34):
During Comanche Peak Response Team (CPRT) reinspection, Evaluation Research Corporation (ERC) identified the following to the NRC inspector as subject to evaluation as potential deviations:
(1) clearances between the pipe and the support were out-of-tolerance, (2) undersize welds were present, and (3) component member lengths were not shown on the design drawing.
The NRC inspector verified that all of the potential deviations were documented on ERC deviation reports (DRs)
and subsequently documented by TU Electric on nonconformance report (NCR) 23119N.
The NCR was dispositioned " Rework" and required the Paper Flow Group (PFG) to issue the necessary documentation for craft personnel to rework the pipe support installation and QC to reinspect per Post Construction Hardware Validation Program (PCHVP) inspection requirements.
The NRC inspector has reviewed the closed NCR and supporting documentation and concurs that TU Electric has properly dispositioned the NCR in accordance with applicable requirements.
This item is closed, b.
(Closed) Open Item (445/8516-O-37):
During CPRT reinspection, ERC 3dentified the following to the NRC inspector as subject to evaluation as potential deviations:
(1) component member identification was incorrect, (2) bill of material items were not within fabrication tolerances, (3) component member location was out-of-tolerance, (4) shear lug to pipe clamp clearances were out-of-tolerance, (5) pipe clamp bolts did not have full thread engagement, (6) locking devices were missing, and (7) one Hilti bolt violated requirements for perpendicularity.
The NRC inspector verified that all of the conditions described above were documented on an ERC DR.
Item A (DR-1) was determined to be invalid due to the fact that individual parts do not have to be marked with the correct pipe support mark number.
In this case, the parts with the incorrect mark number were salvaged from another support.
The Material Identification Log in the pipe support documentation package identifies the correct assembly and installation and confirms that the parts were salvaged from the pipe support mark number which appears on the parts.
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All of the other conditions identified by ERC, items (2)
through (7), were documented by a DR and subsequently documented on NCR M-23438N.
The NRC inspector has reviewed the closed NCR and supporting documentation and concurs that TU Electric corrective actions have resolved the NRC open item.
However, during review of the open item the NRC inspector noted that NCR 23438N, Revision 1, was also used to disposition an ERC DR which was issued to document unacceptable material traceability on the same pipe support.
ERC DR R-S-LBSN-240-DR-3 documents that ERC inspectors could not verify the following material, which exists on pipe support CC-1-040-019-E33S, as being traceable to Certified Material Test Reports (CMTRs):
Item 7, two eyenuts; Item 14, two clevises; and Item 16, two W6 x 15.5 structural shapes.
NCR M-23438N R-1 was dispositioned " Rework" and stated that
. DR R-S-LBSN-240-DR-3 will be eliminated when craft
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reworks support per revised drawing.
The NRC
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inspector reviewed the closed out NCR and the pipe support documentation package and was unable to verify that Items 7, 14, and 16 had been replaced with traceable material.
ASME QC inspection personnel confirmed the NRC inspection finding and issued DR C-88-04217 and NCR 88-14132.
The failure to implement measures which were established to control materials which do not conform to requirements is a violation of Criterion XV (445/8856-V-01).
c.
(Closed) open Item (445/8735-0-04):
During a review of Duct Segment B-1-658-016, the NRC inspector identified several areas on the hem flange between Duct Segments B-1-658-016 and B-1-658-015 where the gasket material, Tremco 440, had been squeezed out from between the flange and was no longer serving its intended function.
This same condition was identified on several more duct segments in the same building.
During discussions with TU Electric, it was determined that Ebasco had identified this problem on Corrective Action Request (CAR)87-079.
Stop Work order (No.
EB-T-6359) was issued by the applicant to stop further installation until the matter was resolved.
The problem, as identified, involved specifically hem flanges on heating, ventilation, and air-conditioning (HVAC) duct for the following reasons:
The hemmed flanges were not always perpendicular to
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the duct, (a tem flange is produced by folding a piece of sheet metal back on itself to form a mating surface).
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The mating flange surfaces were not always parallel
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to each other, The flange faces tended to have uneven surfaces
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(waviness), and Uneven compression occurred on the flange due to the.
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flexibility of the hemmed sheet metal.
Corrective action identified by CAR 87-079, Revision 1 consisted of the following:
Safety-related work packages verified to previous revisions of Construction Procedure CHV-101 are being.
re-reviewed utilizing the current " Construction Engineering Backfit Verification. Checklist."
In the event that Tremco gaskets exist on hemmed flange applications, the checklist is marked unsatisfactory (UNSAT).
Rework will be performed in accordance with the revised specifications and procedural requirements.
project Specification 2323-MS-85, Revision 6 addresses Tremco installation as follows:
Section 9.2.7.C,
. Tremco 440 gasket shall not be
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used in conjunction with any hemmed or. bent sleeve flanges or register collar to main duct
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Section 19.2, "The primary method of reworking hemmed flanges shall be replacement of the hemmed flange with a companion angle flange.
Where replacement of the hemmed flange with a companion angle flange is not feasible, corner brackets and backing bars shall be utilized."
The following procedures were revised to' agree with specification 2323-MS-85:
Construction Procedure CHV-101, Revision 2
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Construction Procedure CHV-106, Revision 4
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Design Change Authorization (DCA) 60803, Revision 1
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The conditions identified with the application of Tremco 440 gaskets on hemmed flanges were evaluated by the applicant for safety significance and determined not to be safety significant.
The NRC inspector reviewed the referenced procedural revisions and feels that they adequately address the Tremco 440 gasket problem.
He also reviewed the safety
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significant evaluation and concurs with TU Electric's conclusion.
This open item is closed.
d.
(Closed) Unresolved Item (445/8607-U-28):
CPRT did not completely address all the ramifications that may result from the f act that the NPV-1 Data Report for valves XSF-179 and 1-7046 were not consistent with the installed valves.
Action taken to resolve concerns for valve 1-7046 are documented in NRC Inspection Report 50-445/86-31; 50-446/86-25.
NCR M-23178NR-1 was issued to document and resolve the concerns surrounding valve XSF-179.
The disposition required that the bonnet in question be removed, scrapped, and replaced with the bonnet ordered per field requisition (FR) 51249.
The NRC inspector reviewed this FR and Purchase Order CPF-14133-S and confirmed that the correct items were ordered and that the correct code class and material grade were specified.
Further, the NRC inspector confirmed that the work required by Work order C880001809 to complete this item had been completed.
By physical inspection of the valve the NRC inspector confirmed that the correct bonnet had been installed.
This item is closed.
(Closed) Unresolved Item (445/8832-U-02; 446/8828-U-02):
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The ASME Code establishes a design life limit of a maximum of 7000 pressure / temperature cycles for systems which utilize mitered weld joints.
SWEC Procedure CPPP-7 limits all SWEC designed piping to less than 7000 cycles.
Control room personnel informed the NRC inspector that the boron recycle system, part of the Chemical Volume and Control System,,ould experience 20 to 25 cycles per month which would exceed the limitation of 7000 cycles over the life of the plant.
During this inspection period, the NRC inspector reviewed GENX-203, Revision 1; GENX-025, Revision 1; GENX-028, Revision 1; and GENX-114, Revision 1.
These four calculations represent analysis of the chemical and volume control system which demonstrates that this system which undergoes the highest number el pressure temperature cycles meets the code and procedural requirement of less than 7000 full temperature and pressure cycles.
Review of these calculations confirmed that the analysis procedure is consistent with code methodology, and review of the System Information Document (SID), the Design Basis Document (DBD) and the Problem Review Document Package (PRDP) confirmed that the appropriate design inputs were utilized.
Further, review of the operating conditions of the Boron Recovery System reveal that the 20 to 25 cycles per month reported by control room personnel do not represent full temperature / pressure cycles wnen evaluated in accordance
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with code methodology.
The equivalent number of cy:les is well within code limits.
This item is closed.
f.
(Closed) Comanche Peak Report Review Group (CPRRG)
Items 52 and 73.
The subject items were concerns that the past NRC Region IV 2512 Inspection Program was not complete and that appropriate action should be taken to close the gaps where there remains a clear benefit to safety.
The inspector performed reviews of the CPRRG documentation, the Phillips memorandum of July 25, 1985, the March 1987 Assessment Task Group Report, the April 1987 V. Stello memorandum, past and present NRC inspection module statistical data and numerous NRC inspection reports.
The inspector concedes that there were past weaknesses and gaps in the old NRC inspection program.
These were identified in the aforementioned documentation.
But, the inspector notes that the subsequent onsite inspection effort since 1986 by a large number of NRC experts from the Office of Special Projects has more than filled the program gaps and turned weaknesses to strengths.
A site group of approximately fourteen NRC inspectors and consultants have performed real-time audits, surveillance and inspections on past and present on-going work at Comanche Peak.
This effort has been structured by discipline, such as:
Quality Assurance, Civil, Electrical, etc., and is documented by the issuance of five inspection reports each month.
All inspections use the guidance and technique that is presented'in the NRC Inspection Program 2512 modules.
All 2512 module percentage completion rates have been rolled back to follow actual construction completion percentages as published by Texas Utilities.
This method insures that site NRC inspections are timely and follow real-time construction events.
The inspector concludes that this intense and collective overview NRC inspection of ongoing and past work (e.g.
CPRT, VII C, CAP, and PCHVP) has sufficiently addressed
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past NRC inspection program inequities.
The present NRC
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reinspection program also provides a level of NRC inspection greater than that afforded any other site in order to insure plant quality and safety.
These two CPRRG items (52 and 73) are considered closed.
3.
Follow-up on Violations / Deviations (92702)
a.
(Closed) Violation (EA 86-09 Item I.c.5):
Quality control inspections were inadequate in that the Technical
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Review Temn (TRT) discovered at the time of its inspection that the horizontal member of support CC-1-126-010-F33R was three inches lower at its centerline relative to the upper bolthole centerline as'
shown on the vendor-certified drawing.
Other supports with similar hole-location violations included CC-X-039-007-F43R, CC-1-126-Oll-F33R, and CC-1-126-012-F33R.
TU Electric determined that the reason for the deviation between support CC-1-126-010-F33R and the as-built drawing following rerouting of the supported pipe and subsequent to initial installation was failure to identify the deviation during final QC acceptance.
The reason for the cited deviations between the as-installed condition and the as-built drawings on the other supports was also failure to identify the deviations during final QC acceptance.
prior to October 1983, finite dimensional compliance of a component support was not a specific element of the construction QA program.
Although QC verified general configuration, material, and fabrication and installation processes, the verification that dimensional compliance was adequate to satisfy design loads was an element of the Engineering 79-14 As-Built Program.
Upon completion of the Engineering 79-14 Survey, Unit 1 and Common support drawings were re-issued to reflect that the support had been "as-built".
Although the drawing revision may not have included minor dimensional deviations which were determined to be acceptable to the design loads, the drawing revision did indicate that as-installed locations were acceptable to the stress analysis.
The ISAP VII.b.3 and VII.c Result Reports address component supports and provide additional response to this issue.
Although CPRT concluded that all similar dimensional discrepancies identified during CPRT reinspection were not safety significant, TU Electric has chosen to reinspect 100% of these type of dimensions as a part of the Corrective Action Program (CAP) for pipe supports.
This item is closed.
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b.
(Closed) Violation (EA 86-09 Item I.c.7) TRT identified six instances where procedural requirements for the final quality control inspection of pipe supports were not
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followed.
These six instances were documented in the
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following two examples:
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Model numbers of installed snubbers for pipe support
SI-1-090-006-C41K did not match the model number on f
the design drawing.
A similar problem existed with
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pipe support RC-052-020-C41R.
(2)
A replacement part (sway strut eyerod) for pipe support CT-1-013-014-S32R had no apparent material identftication either on the hardware or in the documentation package for the support.
The Material Identification Log did not list a..
identification traceable to the origin of the replacement part.
A similar problem existed with pipe supports CC-1-126-012-F33R, CC-X-039-005-F43R, and AF-1-035-011-533R.
TU Electric denied the violation for the reasons that follow:
Regarding example (1), the model number shown on the design drawing specified type, size, and method of attachment; this number is not used to establish component identification or traceability between the pipe support and the drawing.
The model number shown on the design drawing need not be and is usually not marked on the component as was the case here.
The component is marked with an ASE2 NPT serial number or equivalent identification which is traceable to the pipe support and the design drawing.
The CPSES Material Requisitions and QC checklists in the pipe support packages document that the proper components are installed and acceptable.
Regarding Example (2), instruction Cp-EI-4.5-1 did not govern the identification and traceability of pipe support material and parts.
The governing instruction for the identification and traceability of pipe support parts and material is instruction QI-QAP-ll.1-28.
In each case mentioned in the example, the information required to establish item identification and traceability was contained in the pipe support documentation package.
The NRC inspector has reviewed historical documentation pertaining to pipe support material traceability and identification and concurs that the installations were in compliance with applicabic installation requirements.
This item is closed, c.
(Closed) Deviation (445/8603-D-14):
NRC inspection identified that clearances which had been correctly accepted by ERC for Verification Package I-S-SBPS-051,
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when inspected to Revision 1 of QI-019, were no longer acceptable to the requirements of Revision 3 of QI-019.
Drawing CP-AA-040, Revision 0, shows a clearance of zero in the gravity direction.
Independent inspection measured a gap of 1/16" in the gravity direction, and thus determined that the changes in Revision 3 did, in fact, affect the previous inspection of Verification Package I-S-SBPS-051.
TU Electric determined that the reason for the deviation was imprecise inspection guidance and ERC inspectors interpretation of that guidance.
Furthermore, ERC Description Memorandum QA/QC-RT-1436, dated February 10, 1986, erroneously stated that no previously issued packages were affected by Revision 3 to QI-019.
Corrective actions consisted of revising QA/QC-RT-1436 to indicate previous inspection results were impacted and reinspecting previously accepted pipe supports to the criteria contained in QI-019, Revision 3, where required.
The NRC inspector verified that Revision 3 contains the following specific instruction, "Where design shows 0" on bottom (in the gravity direction) then it shall be such with no allowable variation."
A total of 32 packages were reinspected by the applicant which resulted in nine DRs regarding clearances in the gravity direction.
The NRC inspector reviewed Verification Package I-S-SBPS-051 and noted that reinspection had been completed on March 15, 1986, to the revised inspection guidance.
The NRC inspector concludes that the TU Electric corrective actions should preclude any further identification of a similar deviation.
This item is closed.
d.
(Closed) Deviation (445/8607-D-12):
Section 4 of ERC Quality Assurance Procedure ERC-QA-28, Revision 2,
" Performance of Overview Inspection," requires that the overview inspector (OI) document the acceptability of each inspection attribute and compare these results with the initial reinspection / documentation review to identify any apparent inconsistencies.
An NRC inspection of Verification Package 38-I-S-PS7N-056 identified that the cotter pins on the load pin were undersized.
The NRC inspector found that Overview Inspection Package 38-I-S-PS7N-056 lists cotter pins and lock washers as four correct decisions.
The standard ERC inspection checklist for the same package also identifies cotter pins as an inspection attribute.
In response to this deviation, the applicant overview Inspection Package 38-I-S-PS7N-056 and Deviation Report I-S-PS7N-DR3 was issued to address the two undersized cotter pins.
This was later reissued as NCR M-86-25339N and dispositioned
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to replace the cotter pins.
This NCR was closed April f
19, 1988.
Quality Instruction QI-037 was revised on
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October 10, 1986, to clarify the cotter pin requirement.
A discussion was also held by the applicant with all overview inspectors to reinforce the procedural revisions.
Further, CAR-065 was initiated to perform a complete reinspection of all ASME pipe support cotter pin installations.
The NRC inspector has reviewed QI-037, Revision 2, NCR M-86-25339N, CAR-65, and the ERC training records.
The NRC inspector feels that the procedural changes and CAR-65 used in conjunction with the inspector training will help prevent a recurrence of the identified problem.
This deviation is closed.
e.
(Open) Deviation (445/8607-D-01):
TU Electric letter TXX-3657 dated April 21, 1983, submitted to NRC in accordance with 10 CFR Part 50.55(e), identified a significant condition adverse to quality (no objective evidence was available documenting acceptable weld quality on seismic arrester brackets) and stated that corrective action would proceed immediately.
TU Electric letter TXX-88526 dated June 22, 1988, which provides a final report for SDAR 83-08, Fisher Control Valve Bracket walding quality, stated that an analysis had been performed to determine if the brackets would have performed their intended safety function during a seismic event.
An as-built inspection of the weld was performed using Nuclear Construction Issues Group (NCIG)
visual weld acceptance criteria (VWAC) and the analysis was based on this as-built data.
On August 11, 1988, the NRC met with TU Electric to identify that NCIG VWAC inspection criteria was not an acceptable inspection standard due to the fact that the existing welds did not have an inspection of record and that the welds were painted.
To resolve this issue, TU Electric committed to perform additional evaluations to resolve the deportability issue.
The NRC notes that although the welding quality was determined nonreportable, TU Electric has committed to replace all of the required seismic arrester brackets under the ASME Section XI program requirements.
The NRC has reviewed the additional evaluations which included additional analytical evaluation of weld stress and performance of a pull test to prove weld strength and concurs that the weld quality issue is nonreportable.
This item remains open pending replacement of the brackets and review by the NRC.
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4 f.
(Closed) Violation (445/8516-V-13):
Established procedures for the inspection of activities affecting quality were not effectively implemented as evidenced by
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the following conditions:
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During an inspcetion of Unit 1 ASME pipe support CC-1-131-010-S41R, the NRC inspector identified several undersize weldt that were undersized by a minimum of 1/16 to 1/8 ir:h.
The applicant responded to the Notice of Violation with the following it.5crmation:
The reason for the violation was inadequate QC
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as-built inspection for the weld size required by the associated design documents.
NCR XI-708 was issued to address the specific
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discrepancies.
This was subsequently transferred to NCR M-25650.
NCR M-25650 was dispecitioned " Accept as is" based on evaluation of the as-built conditions.
Since the initial inspection of the subject welds in
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1979 and the final weld inspection in 1982, a number of revisions to the component support weld program (QI-QAP-11.1-28) have been implemented.
These revisions were aimed at improving the quality of weld inspections and their documentation.
For example: QI-QAP-11.1-28, Revision 16 dated December 15, 1982 required that a Weld Inspection Check List (WICL) be completed by the QC inspector for each pipe support at the time of fabrication completion.
Completion of the WICL required the inspector to measure the actual weld size and record it on the WICL, initial and date the WICL, and sign and date the design drawing and/or CMC.
These requirements provide additional assurance that the inspectors are comparing the deposited weld size to the required weld size.
Revision 24 to QI-QAP-11.1-28 expanded the scope of the Hanger Inspection Report that is completed for each hanger.
In addition to requiring the WICL to be completed for all Unit 2 supports, regardless of the fabrication or installation status, it required objective evidence of the QC verification of each attribute considered relevant by engineering.
The NRC inspector has reviewed the revisions to Procedure QI-QAP-11.1-28, the engineering evaluation of the undersize welds, and the training records and concurs
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that these revisions have resulted in an improved program, and throughout the implementation of these improvements the individuals responsible for implementing the changes have been trained in their application.
The NRC inspector concludes that these procedural changes andL the added training will help prevent a recurrence of the
' identified problem.
This violation is closed.
g.
(Closed) violation (445/8718-V-08):
A nonconformance report (NCR) was not issued when a high strength capscrew (item 15 of pipe support CC-lSB-001-001-3) broke during'
installation before the specified design torque value was achieved.
This precluded an investigation and engineering evaluation of the nonconforming item.
Following identification of this issue by the NRC, the applicant issued NCR M-87-A10852 to address the specific hardware deficiency identified.
The'NCR has been dispositioned "use-as-is" based upon chemical and mechanical tests performed on high strength capscrews with identical heat codes (i.e. PF33) obtained from warehouse scock.
The NRC inspector has reviewed the results of those tests and concurs that the chemical content and mechanical properties of the tested capscrews are within limits and tolerances established by ASTM for SA193 GRB 7 bolting material.
Therefore, the incident of one capscrew breaking is considered to be an isolated case.
To address the programmatic concern that an NCR was not issued by QC, which precluded an investigation and engineering evaluation of the nonconforming item, the applicant initiated deficiency report (DR) C-87-3885.
Engineering evaluation and disposition of the DR determined that inspection Procedure CP-QAP-12.1 did not provide an adequate definition of " flawed" or " failed" material, which resulted in the failure by QC to identify the broken capscrew on a NCR.
To resolve the programmatic concerns CP-QAP-12.1 was revised to expand the definition of " flawed" or " failed" material, and ASME QC inspectors were retrained to the revised procedure.
The NRC inspector has reviewed the revised QC procedure and training records and concludes that the applicant's I
corrective actions should preclude recurrence of the l
violation.
This item is closed.
h.
(Closed) Violation (445/8718-V-09):
The adjacent weld distance attribute for pipe support WP-X-AB-050-003-3 was
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documented as being satisfactory on the associated Adjacent Weld Checklist.
However, this attribute is
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inaccessible due to the presence of Bisco seal material in the penetration that the pipe runs through.
The acceptance of this inaccessible attribute by QC prevented the required engineering evaluation from being performed.
Following identification of this issue by the NRC, the applicant issued NCR M-87-A01921 to resolve the specific issue.
This NCR was subsequent:.y superseded by NCR 87-02093 and dispositioned "use-as-is."
SWEC-PSE performed a review of piping drawing ERP-WP-X-AB-050, Revision 0; support location drawing GHH-WP-X-AB-050,
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Revision 3; CMC-5180, Revision 0; and DCA 49343, Revision 0; and concluded that there is no pipe weld within 3 inches of the pipe support.
Therefore, the inaccessible attribute is acceptable based upon engineering evaluation.
To address the programmatic concern the applicant issued DR C-87-3884 which documented that PCEVP Procedure CP-QAP 12.1 did'not adequately address the required issuance of a NCR for those attributes which are inaccessible for inspection.
Subsequent to the DR issuance, CAR 87-078 was issued to address the cause of the condition, corrective action, and action to preclude recurrence.
The NRC inspector has reviewed the dispositioned CAR and concludes that the corrective action is appropriate and that actions to preclude recurrence provide an adequate basis to resolve the programmatic deficiency.
CP-QAP 12.1 was revised to specifically address the initiation of NCRs for PCHVP attributes which are hidden or inaccessible (paragraph 6.1.2).
A backfit inspection was performed on all packages vaulted prior to the QA program revision, reference Brown and Root (B&R) letter (BRL)403, dated December 17, 1987.
The NRC inspector reviewed B&R training records and concluded that ASME QC inspectors had been retrained to document inaccessible or hidden attributes with a NCR.
This item is closed.
i (Closed) Violation (445/8731-V-01):
Three examples of
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incorrectly documenting existing conditions during the engineering walkdowns performed to Field Verification Method (FVM) CPE-EB-FVM-CS-033 were identified.
In response to the three items identified, the applicant issued DRs C-87-04771 and C-87-05411 to document the discrepancies and their resolutions, retrained Ebasco walkdown personnel, revised the conduit walkdown procedure, and performed a sample reinspection to assess generic implications of the walkdown discrepancies.
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As reported in NRC Inspection Report 50-445/88-05; 50-446/88-04r NRC, TU Electric, Ebasco, and Impell met on January 28, 1988, to discuss the results of Ebasco's and Impell's reinspection effort to evaluate generic implications of the identified walkdown errors.
The applicant's conclusion of the analysis of the reinspection results was that in light of the low error rate and the fact that none of the errors found were safety significant no further reinspection was warranted.
The NRC inspector concurled with this assessment.
In this inspection period, the NRC inspector reviewed the training records for the retraining of Ebasco's walkdown personnel that took place on January 25, 1988.
The retraining included a discussion of the walkdown errors.
FVM CPE-EB-FVM-CS-033, Revision 3, was also reviewed and it was noted that paragraph 7.7.1.5 was revised to require that dimensions are to be measured to edges and ends of members rather than to theoretical centerlines.
Also reviewed were DRs C-87-04771 and C-87-05411.
The first DR was in response to a walkdown error where the existence of one of the Hilti Kwik Bolts (HKBs) that attached the support to the wall was not documented.
In response to the DR, Ebasco performed a surveillance with a concentrated effort on the checker in question.
This surveillance included 46 similar supportn and found no other discrepancies.
The NRC inspector concurred that this appeared to be an isolated case and that the existence of the additional EKB provides additional support, and in light of the reinspection effort previously documented, no further action is required in response to this deficiency.
This violation is closed; however, DR C-87-05411 addressed two discrepant conditions, the first was a case where the walkdown engineer failed to document the location of a structural tube from the edge of its baseplate.
The NRC inspector agrees with the actions taken in response to this section of the DR.
The statement that "none of the discrepancies required changing the associated calculations" does not appear to be accurate for the second
.crepancy addressed by this DR.
This second discrepancy involved an instance where the walkdown engineer did not report a spacing violation between two HKBs as required by the FVM.
One of the anchor bolts is a 1/4" diameter HKB in the unistrut outrigger of a CA-lb type support, and the other anchor bolt is a 3/8" diameter HKB in an adjacent conduit support.
The response to this discrepancy was that "the separation criteria
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drawing CA-lb (Rev. CP-01) is not required to be compiled
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with between 1/4" diameter Hilti-bolts in outriggers and any other bolts."
Since this statement appeared to be inconsistent with the requirements of specification SS-30
" Structural Embedments," the NRC inspector asked for the
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engineering justification for this note on the drawing.
In response, the applicant provided calculation TNE-CS-CA-CA-la, Revision 6.
The NRC inspector's review of this calculation revealed the following:
(1)
The calculation uses a minimum spacing of 2 1/2" as a design input parameter and the spacing documented in this subject violation is 2 1/4".
Also this calculation was performed and checked three months after the issuance of the violation.
Therefore, this calculation is not valid for the condition cited.
(2)
The calculation cites DBD-CS-015, Revision 2, as the applicable DBD.
Equation 2 on page 14B and 14C of the subject calculation is used to calculate the reduced concrete stress area and is taken directly from the DBD.
The DBD has a restriction on the use of this equation that the spacing between the anchor bolts must be greater than five times the difference between the diameters of the bolts being evaluated.
However, several instances evaluated do not meet this.
(3)
Note 5, on Revision CP-02 of drawing S-0910 Sh. CA-lb exempts all spacing violations involving 1/4" HKBs in outriggers from consideration except those between 1/4" diameter HKBs in outriggers and 1/2" diameter, and 1" diameter Hilti Super Kwik bolts (HSKB).
However, Procedure CCI-113 allows substitution of HKSBs for HKBs and does not require that spacing violations be evaluated even though there are instances where the HSKB with the maximum reduction due to a spacing violation would have a lower allowable tensile load than the corresponding HKB.
The items identified above constitute a violation of Criterion V (445/8856-V-02); 446/8852-V-01).
4.
Follow-up on NRC Compliance Bulletins (92703 and 25056)
(Open) NRC Compliance Bulletin 88-05 requires that a.
applicants submit information regarding materials supplied by piping Supplies, Incorporated (PSI) at Folsom, New Jersey, and West Jersey Manufacturing Company (WJM) at Williamstown, New Jersey, and requests that applicants:
(1) take actions to assure that materials
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comply with ASME Code and design specification requirements or are suitable for their intended service, or (2) replace such materials.
Supplement 1 provides additional information concerning material supplied by PSI and WJM, reduces the scope of the requested materials review to only flanges and fittings, delineates actions applicants are requested to take to identify these materials and to determine whether the materials comply with ASME and ASTM design and material specifications, and clarifies what actions applicants are requested to take once they identify material that does not comply with the above material specifications.
Supplement 2 modifies the schedule for actions addressees were requested to perform in Bulletin 88-05 and Supplement 1 and provides additional information concerning materials supplied by PSI, WJM, and a recently identified affiliated company, Chews Landing Metal Manufacturers Incorporated (CLM).
TU Electric in response to NRC Bulletin 88-05 is preparing an Engineering Report estimated to be complete in October 1988.
Furthermore, CAR 88-027 has been issued to determine cause of the condition, corrective action, and action to preclude recurrence.
TU Electric is participating in the Nuclear Management and Resources Council's (NUMARC) overall effort to coordinate supporting utility action plans and responses to NRC Bulletin 88-05.
Present efforts by NUMARC are centered around assisting utilities to identify applicable heat numbers and establishing testing The testing program proposed by the bulletin programs.
consists of:
Identifying all heat numbers and providing certified
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Material Test Reports (CMTRs) for all heats.
Performing field hardness tests (Brinell) using a
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portable hardness tester to verify results shown on the CMTR for the subject material.
Determining acceptability of material based on CMTR
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and field hardness test results.
TU Electric's proposed site / installed testing plan consists of:
Obtain CMTRs for material available in warehouses
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(e.g., CMTRs for each Heat Number).
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Perform hardness testing for all 88-05 material
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located at CPSES.
Identify acceptable / unacceptable hardness test
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results for all material.
Correlate hardness test results to CMTRs.
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Replace material with unacceptable hardness test
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results.
To date, 466 total items (consisting of 74 different types of flanges) from 60 different heat numbers have been identified.
Of the total, 104 are installed in Unit 1.
Chemical and mechanical testing is being performed by an independent test laboratory on material in the warehouses which has not been issued.
Hardness testing is being performed on material installed in the plant and in the warehouses, using an "Equotip Impact Device -
Type D," which provides an equivalent Brinnel Hardness (BHN) rating.
This bulletin remains open pending completion of the applicant's evaluation and further NRC inspection.
b.
(Closed) Supplements 1 and 2 to NRC Compliance Bulletin 87-02 pertain to procurement of safety and nonsafety-related fasteners.
Specifically, licensees and applicants are required to provide a list of the suppliers and manufacturers from which ferrous fasteners 1/4-inch in diameter or greater may have been purchased.
The list shall include the last ten years for safety-related fasteners and five years for nonsafety-related fasteners.
This data was intended to be obtained from a review of the applicant's approved vendor list or qualified suppliers lists for safety-related fasteners, and from a review of available records for nonsafety-related items.
The NRC inspector reviewed the applicant's response (TXX-88560, dated July 22, 1988) and finds that the information provided complies with these supplements to the subject bulletin, This item is closed.
The NRC inspectors have completed all inspections of Compliance Bulletin 87-02 and have used the inspection guidance provided by NRC Inspection Manual Temporary Instruction 2500/26.
This Bulletin and Temporary Instruction (TI) are closed.
The SIMS issue number for this TI is BL-87-02.
c.
(Closed) NRC Compliance Bulletin 82-02 and TI 2515/71, pertains to the degradation of threaded fasteners in the reactor coolant pressure boundary of pressurized water reactor (PWR) plants.
Since the bulletin only requires a
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response from holders of an operating license, no written response is required from the applicant.
However, the applicant has developed and implemented the necessary procedures to meet the requirements of action item 1 of this bulletin.
This Bulletin and TI are closed.
5.
Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant (92700)
The NRC inspector reviewed the files of four iteme identified by TU Electric as potentially reportable.
In eacl. case, TU Electric concluded that none of the items met the deportability requirements of the regulations.
The four files inspected by the NRC were:
(Closed) CP-87-02 Fisher Control Valves:
An evaluation
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of equipment supplied by Fisher Controls was required to assure two anomalies identified by the vendor do not
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create conditions adverse to the safety of plant operations.
(Closed) CP-85-26 Pipe Supports:
An evaluation of an
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inconsistency observed in the application of weld material during installation and the length of weld used in the design process.
(Closed) CP-87-72 Pipe Supports:
An evaluation of a
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deficiency involving inadequate measurement of weld length in weld joints utilizing structural tube steel.
(Closed) CP-87-63 Pipe Weld Inspection Criteria:
An
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evaluation of inspection attributes which were not applied to existing weld installations after 2323-MS-100, Piping Erection Specification, was revised to include criteria for inspection of radial weld shrinkage (RWS).
In every case the NRC inspector found the information in the files supported the nonreportable conclusion; e.g. the potentially reportable deficiency was not safety significant and that safe operation of the plant would not be impacted due to the deficiency.
No deviations or violations were identified and no further inspection of these issues is planned.
6.
Structural Steel Connections (99014)
The NRC inspected bolts in slotted holes that were required to
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be loose enough to allow for differential thermal expansion to see if they were being torqued to levels which may restrict thermal expansion.
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On June 29, 1988, two craft personnel notified the NRC that they had witnessed other craft personnel torquing bolts in connections that had slotted holes.
The connections that they expressed concern over were in pipe whip restraints and structural framing spanning the distance between concrete walls.
The basis of their concern stemmed from the fact thaT".
they had been advised that the reasons that slotted holes were present was to provide clearance for fit-up purposes and, secondly, to allow for differential thermal expansion.
In the case of pipe whip restraints the slotted holes were present to allow unrestricted movement of the piping during normal operation and in the case of steel framing to allow for elongation of steel members, which would be different than the building (concrete) expansion.
Therefore, any torquing of the bolting in these connections could restrict the thermal expansion and have a negative impact on the ability of the specific item to perform its intended function.
The personnel stated that the reason the torquing was being performed was due to Design Change Authorization (DCA) 14813, Revision 3.
This DCA revised a note on Drawing 2323-S1-0581 which dealt with bolted connections in pipe whip restraints.
The note on Drawing 2323-S1-0581 gave specific direction concerning how bolting in slotted holes within pipe whip restraints was to be accomplished ensuring a loose fitup; the DCA required that bolts be torqued unless specified to be hand tight.
Also, the workers had witnessed torquing of platform bolting where slotted holes existed.
In response to the concern, the NRC inspector interviewed the engineers in SWEC's Engineering Mechanics Division (EMD) who originated the revision to the DCA which superceded Note 8 on Drawing 2323-Sl-0581 to determine the rationale for the change.
They stated that SWEC had performed a review of all pipe whip restraint structures and had determined that only specific bolts were required to be hand tightened.
Further, the DCA provided guidance on how these bolts were to be installed and inspected.
The NRC inspector reviewed these requirements and concurs that they provide adequate direction to obtain a hand-tight condition in that the bolts will not disengage.
Further, the NRC inspector inspected several pipe whip restraints where hand-tight connections were specified and found that they were installed in accordance with the DCA.
The connections on the pipe whip restraints where hand-tight bolting for slotted holes was specified were located adjacent to energy absorbing material.
It was observed that several of these restraints had steel beams with slotted holes that spanned the steam generator compartments and, furthermore, that these bolts had been torqued.
When questioned as to whether differential thermal expansion was included in the basic design calculations for these restraints, SWEC engineers stated that it had been considered, but they had determined that it could be discounted for the following reasons:
First,
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the pipe whip restraint is only required to function in the first few milliseconds following a pipe rupture and the significant change in temperature would occur after the restraint had served its purpose; and secondly, the load imposed on the structure due to the potential restraint of thermal expansion is a small percentage of the design load on the whip restraint and can be neglected.
The NRC inspector reviewed Calculation SRB-124C, Set 1, Revision 6 entitled,
" Reactor Building Internal Structure Pipe Whip Restraints" and concurs that the design loads far exceed any load that may be imposed on the structure due to differential thermal expansion, and that this item has been adequately considered.
The review of other steel structures that span between concrete walls, specifically platforms, determined that SWEC had identified all connections requiring that the bolting be installed hand tight.
However, the inspection requirements provided with the DCA 48517, Revision 0 stated, " Verify that the nut on each of the bolts cannot be further tightened or loosened by hand."
This would insure that the bolts are at least hand tight but cannot provide assurance that bolts had not been overtorqued.
This is an unresolved item pending clarification of inspection requirements and determination of whether bolts have been torqued beyond hand tight (445/8856-U-03; 446/8852-U-02).
7.
Corrective Action Program (CAP)
a.
Heating, Ventilation, and Air-Conditioning (HVAC) (50100)
NRC inspectors performed field inspections and documentation reviews of the following documentation packages generated as a result of construction, engineering, and inspection activities related to HVAC CAP implementation:
Seismic Duct Hangers Unit Room DH-1-844-1K-1X
99A DH-1-844-1K-1Y
99A DH-1-844-1K-1AB
99A DH-1-844-1K-1AP
99A The NRC inspector reviewed the contents oi Duct Support Packages DH-1-844-1K-1X and DH-1-844-1K-1AP and identified two NCRs, Nos. CM-87-3410 and CM-87-3275, which listed a total of seven items as being nonconforming.
During a review of the two nonconformances, it was noted that both nonconformances were dispositioned use-as-is.
However, while reviewing the NCR continuation sheets and
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the documentation package construction operation traveler sheets, it became apparent that some rework or repair had taken place in order to' correct the nonconforming conditions identified in the detail section of the NCRs.
The identified rework / repair had taken place subsequent to the initiation date identified on both NCRs in question, but prior to the use-as-is disposition date identified on the NCRs.
This is considered an open item pending further clarification;and NRC review.
No further violations or deviations were identified (445/8856-o-04).
b.
Conduit supports Train A & B and Train C > 2" (48053)
During this inspection period, the NRC inspector selected a sample of eight conduit support modifications to verify the accuracy and correctness of the final QC inspection data.
The following is a list of the NRC inspected supports and the corresponding DCA.
Support DCA C13030584-02 41808, Revision 1 C13015767-02 44877, Revision 1 C14K17566-51 60762, Revision 0 C13K12014-01 60140, Revision 0 C15R10536-51 44892, Revision 0 C13005654-51 52692, Revision 0 C13K07073-51 56620, Revision 0 C13K08216-02 25912, Revision 5 The NRC inspector's review of these supports was performed in accordance with the requirements of the applicable section of Specification 2323-SS-16B and the DCA.
The results of this inspection revealed the recorded data was within the tolerances of the specification.
No violations or deviations were identified.
c.
Piping and Pipe Supports (50090)
During the implementation of the CAP for piping and pipe supports, an example of a slugged weld was detected by TU Electric.
During the salvage process of Component Support SI-1-029-054-S32R, unconsumed filler metal (welding rods) was discovered in a weld joint between two pieces of structural tubing which had an excessive fit-up The unconsumed filler material was approximately 4 gap.
1/2" in length and was hidden by weld buildup over the joint giving the appearance of a good weld.
This support was fabricated in the time frame between August 1981 and March 1982.
This condition was not previously detected
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because.in this application, the ASME Code requires only a visual examination for Class 2 linear member welds.
Site procedures do not allow the use of unconsumed filler metal to correct for~ improper fit up.
Further, fit-up requirements are established in the applicable weld procedure specifications and are consistent with the requirements of the American Welding Society (AWS) and ASME.Section IX.
The applicant has documented this condition on CAR 88-028 to determine whether this
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practice is wide spread (i.e.' pieces of unconsumed weld'
L filler material were found in an excessive fit-up gap).
Subsequent to the above discovery, as a result of. major l
rework on Pipe Support CC-1-057-021-A33A, another slugged
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weld was found.
NCR 88-13571 was issued to document that'
a fit-up gap of up to 3/4-inch was discovered on an existing weld and that it contained foreign material which had been used to fill the fit-up gap.
The excessive fit-up; gaps and unapproved. weld filler material violate parameters of the welding procedure specifications.
This is an unresolved item pending the applicant's evaluation of generic-implications and corrective actions (445/8856-U-05; 446/8852-U-03).
8.
Plant Tours'
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 in-process work activities.
No violations or deviations were identified and no items of significance were observed.
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.
Two unresolved items disclosed during the inspection are discussed in paragraphs 6 and 7.c.
10.
open Items open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or applicant or both.
An open item disclosed during this inspection is discussed in paragraph 7.a.
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11.
Exit Meetino (30703)
An exit meeting was conducted September 8, 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 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/ff-5(,) 50-446/98 -(A
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DISTRIBUTION:
Docket Files'(50-445/446)
NRC PDR LPDR CPPD-LA
CPPD Reading (HQ)
OSP Reading
- Site Reading File R. Warnick-
- J. Wiebe
- H..Livermore.
- MIS System, RIV i
- RSTS'Cperator, RIV DRP, RIV RIV Docket File
- L.
Shea, ARM /LFMB J. Taylor J. Partlow C. Grimes P. McKee
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J. Lyons J. Wilson M. Malloy D. Terao J. Moore, OGC-WF J. Gilliland, RIV F. Miraglia E. Jordan B. Grimes B. Hayes
- w/766
1
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