IR 05000445/1988061

Insp Repts 50-445/88-61 & 50-446/88-57 on 880624-1014.No Violations or Deviations Noted.Major Areas Inspected: Previously Identified ASME Code Insp Findings & Allegations Re Qa/Qc Program & Implementation

ML20196E841
Person / Time
Site:	Comanche Peak
Issue date:	12/15/1988
From:	Charemagne Grimes, Williams C NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20196E829	List: IR 05000445/1988061 ML20196E827
References
50-445-88-61, 50-446-88-57, NUDOCS 8812120099
Download: ML20196E841 (9)

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V. S. NUCLEAR REGULATORY COMMISSION

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0FFICE OF SPECIAL PROJECTS NRC Inspection Report:

50-445/88-61 Permits: CPPR-126 50-446/88-57 CPPR-127 Dockets: E0-445 Category: A2 50-446 Construction Permit Expiration Dates:

Unit 1: Extension request submitted Unit 2: Extension request submitted Applicant:

TV Electric 400 North Olive Street, L.B. 81 Dallas, Texas 75201

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Facility:

Conanche Peak Steam Electric Station (CPSES)

Units 1 and 2 Inspection At: Comanche Peak Site, Glen Rose, TX Inspection Review Period: June 24 through October 14, 1988 b.

kle il //d$b Inspector:

cordell c. Williams, Technical Date Assistant to the Director Comanche Peak Project Division Office of Special Projects Reviewed by:

A).uJL.A 12/5 f %

Christopher I. Grimes, Director Date r

Comanche Peak Project Division Office of Special Projects s

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GS12120099 831205 ADOCK0500g5 DR

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Inspection Sumary:

Inspection Conducted Intermittently: June 24 through October 14,1988(Report 50-445/88-61;50-446/88-57)

Areas inspected: Announced, special inspections conducted jointly with the Texas Departdiit of Labor and Standards (TDLS), Chief Inspector, Boiler Division, on previously identified ASME Code inspection findings and allegations regarding

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QA/QC program and implementation.

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Results: Within the areas inspected, no violations or deviations were identified. During the course of this inspection, no particularly notable strengths or weaknesses in TV Electric's activities were identified. Although many of the adverse issues associated with ASME Code compliance for Unit I were well defined during the 1982-1983 time frame, comprehensive actions to address and correct the root causes of these issues were not initiated until September 1987 in response to questions by NRC and the Texas ASME Jurisdiction.

However, at this time, the inspectors found TV Electric's engineering personnel with direct ASME coordination responsibilities to be well-qualified for the functions they performed. The inspectors founo that the technical evaluations done by these personnel were usually very thorough.

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DETAILS 1.

Persons Contacted:

• G. Bynog Assistant Chief Inspector, Texas Department of Labor & Standards

• J. DeBonis, llechanical Engineer TV Electric

• W. G. Gouldemond, Executive Assistant, Vice President of Engineering and Construction TV Electric

• T. Heatherly, Compliance Engineering, TV Electric

• R. T. Jenkins, Manager, Mechanical Engineering, TV Electric

• 0. W. Lowe, Director of Engineering, TV Electric

• F. W. Madden, Mechanical Engineering Manager, TV Electric S. M. Matthews, Director and Chief Inspector, Texas Department of Labor &

Standards L. D. Nace, Vice President of Engineering and Construction. TV Electric

• E. Ottney, Project Manager, CASE

• S. Palmer, Project Manager, TV Electric G. R. Purdy, QA Hanager, Brown and Root

• D A. Ringle, Licensing TV Electric

• M. Skaggs, ASME Coordinator, TU Electric

• B. Walker, Senior Inspection Specialist. Texas Department of Labor &

Standards The NRC inspector and the TDLS Chief Inspector also interviewed other applicant employees during this inspection period.

• Denotes personnel present at the October 14, 1988 exit meeting.

2.

Action on Previous Inspection Findings (92701);

a.

(Closed)UnresolvedItem(445/8824-U-03):

This unresolved item concerns the sufficiency of the documentation intended to demonstrate that the CPSES Unit 1 Primary System Cold Hydrostatic test satisfied the applicable ASME Code and NRC requirements.

As was previously reported in NRC Inspection Report 50-445/88-24; 50-446/88-21, the acceptability of the Unit 1 Prinary System Cold Hydrostatic Test (as documented in Documentation Package No. PT-55.01, 1982)was which included Pressure Test Data Sheet dated July 31[TDLS).

considered indeterminate by hRC and the Jurisdiction This finding was based in part on the identification of two violations of NRC requirements regarding the adequacy of the applicable procedures and the failure to maintain certain related QC records (NRC Inspection Reports 50-445/88-24;50-446/88-21).

Closure of these two violations is discussed in paragraphs 2.b and 2.c of this.eport.

In response to the concerns raised by NRC and TDLS, TV Electric performed an evaluation of the Unit 1 Primary System Colo Hydrostatic Test based on a comprehensive review of all documentary evidence available to them. During an NRC and TOLS meeting on June 16, 1988 TV Electric presented the results of the Unit 1 Primary System Cold

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Hyorostatic Test evaluation identified as Engineering Report No.

l ER-ME-01.

By letter dated June 17, 1988, this engineering report

was transmitted to NRC.

By letter dated July 15, 1988, TV Electric responded to NRC's June 23, 1988 letter which forwarded Inspection

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Report 50-445/88-24; 50-446/88 21 and a Notice of Violation.

On August 4, 1988, NRC and TOLS conducted an interim exit meeting to discuss the findings regarding TV Electric's actions and the results

of further inspection of the subject activities.

Based on actions

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taken by TV Electric, NRC and TDLS concluded during the August 4,

1988 meeting that the Unit 1 Primary System Cold Hydrostatic Test i

met ASME %de requirements subject to additional TV Electric actions

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including supplementing their Engineering Report No. ER-ME-01 to 1.

clarify certain portions of the report.

This supplement was transmitted to NRC by TV Electric letter No. TXX-88636 dated i

August 23, 1988.

NRCandTOLShaveevaluatedthesupplementto TV Electric Report No. ER-ME-01 and have concluded that a sufficient record has been developed from which a judgement of the adequacy of the conduct of the test could be developed.

1 During the August 4, 1988 meeting, NRC and TDLS also requested that TU Electric document their comitnent to perform certain additional J)

examinations during the CPSES Unit 1 system functional testing /heatup activities in order to provide additional assurance that ASME Section XI repairs and modifications have been tested properly.

TU Electric's cocumented response (Letter No. TXX-88709 dated

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September 28,1988) has been evaluated by NRC and TDLS and was found

j to adequately address the commitment.

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I Also, during the August 4, 1988 interin exit meeting, NRC and TDLS l

indicated that further examinations of personnel qualifitation records

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of the quality control and Authorized Nuclear inspection (ANI)

personnel involved in the inspection and record-keeping activities of the Unit 1 Primary Systen Cold Hydrostatic Test were needed. This effort was completed and reported to TU Electric during the October 14, l

1988 exit meeting.

No adverse conditions regarding personnel quali-l fications were identifiec in any of the Unit 1 Primary System Cold j

Hydrostatic Test records exanined.

(See also paragraph 2.d. below).

Based on the above, the NRC and TDLS have concluded that, not with-standing the procedural and record-keeping violations previously

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identified relative to the Unit 1 Primary System Cold Hydrostatic i

Test, the requirements of the ASME Code were met as evidenced by the i

collective record (Package No. CP-PT-55-01 Engineering Report ho.

l ER-ME-01 dated June 16, 1988, and the supplemental clarification dated

August 23,1988).

TV Electric's comitments for additional system examinations during hot functional testing is acceptable.

This item j

is considered closed.

b.

(Closed) liolation (445/8824-V-01; 446/8821-V-01): As was previously reported in NRC Inspection Report 50-445/88-24; 50-446/88-21, procedures associated with reactor system hydrostatic testing were not attquately comprehensive and the "pressure test data sheet" t

lacked provision for requisite ANI signatures.

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l TV Electric acknowledged the weaknesses in the procedural details to

i convert component data to field examination packages and inspection

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points, although they found sufficient evidence that the actual implementation satisfied the applicable ASME Section !!! Code j

requirements.

TV Electric has revised these procedures to clarify

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provide appropriate QC and ANI sign-off.

Based on NRC and TOLS review of TV Electric's response to this violation, this violation l

has been adequately resolved and is considered closed.

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c.

(Closed) Violation (445/8824-V-01): As was previously reported in l

NRC Inspection Report 50-445/88-24; 50-446/88-21 TV Electric

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Procedure No. CP-QAP-12.1 required the establishment of a QC Document titled, "Documentation Status Form." This QC record was not available

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i System Cold Hydrostatic Test package.

The TV Electric response (letter No. TXX-88575 dated July 15,1988)

indicated that, based on their assessment as documented in TU Electric Engineering Report No. ER-ME-01, sufficient corroborative records a

j adequately demonstrated that the requirements of the ASME Code had been met, not withstanding the unavailable Document Status Forms

associated with these records. Although it is the conclusion of NRC

i and TOLS that those records, as prescribed by the governing TV Electric l

procedures at the time, should have been maintained, the existing

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i records adequately demonstrate that the test was conducted in i

accordance with the applicable ASME Code.

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The allegation associated with this finding (No. OSP-87-A-0088) is

addressed in paragraph 2.d of this report. This item is closed.

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(Closed) Open Item No. 445/8824-0-04 Allegatio.i No. OSP-87-A-0088,

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ASME Code and personnel qualification issues.

P reported in NRC Inspection Rer, ort 50-445/88-24; i

As previously(paragraph 4.b), NRC received allegations concerning 50-446/88-21 i

the adequacy of procedures, record-keeping and personnel l

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I qualification issues associated with the U nit 1 Primary System Cold

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Hydrostatic Test. The first two items of the subject allegation were addressed and substantiated as previously reported.

The

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l remaining aspect of these allegations questioned the adequacy of l

the qualifications of personnel assigned to observe and certify the

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proper conduct of the Unit 1 Cold Hydrostatic Test of the primary

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system. With respect to the qualifications of TV Electric personnel, J

NRC and TOLS staff examined and verified the personnel qualifications

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of the QA/QC inspectors, engineering personnel, and Authorized Nuclear

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Inspectors associated by signature with the conduct of the Unit 1

Primary System Cold Hydrostatic Test as documented in record package

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i No. PT-55.01.

Based on these examinations, which were completed on

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October 14, 1988, no conditions contrary to the ASME Code or TU i

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i Electric procedural requirements were identified.

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It is the NRC and TDLS finding that itein 3 of the subject allegation, to the extent that it involved TV Electric personnel and activities, was not substantiated and it is considered closed.

Note that items 1 and 2 of the subject allegation were considered substantiated in NRC Inspection Report No. 50-445/88-24; 50-446/88-21 and, for the reasons described therein, are likewise considered closed, e.

(Closed)CPRG(NUREG-1257)IssueNo.4(ID51andID62)-CVCSSpool Piece 301, Appendix A, Page 3-11.

Paragraph 3.4 of NUREG-1257, Recommendation ID 51, ID 62, and other

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NRC documentation, raised the issue of traceability of CVCS spool piece No. 301 and materials in general.

Review of this issue by the j

NRC and TDLS disclosed some apparent confusion relative to the appli-

cability of certain parts of the ASME Code and questions as to

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TV Electric's historical conformance to the procedural requirements.

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For example, the inspectors found that an ASME Code reference in l

NUREG-1257, Appendix A, paragraph 3.4, was incorrect.

NUREG-1257

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referred to Article NA-3766.6 of the Code as applicable code require-j ments for tracebility of the spool piece.

The correct ASME Code reference should have been NA-3361. NA-3363, and NA-4410.

Based on the existing documents and the as-built configuration observable today, the following findings were made:

Adequate procedures regarding material traceability safeguards

are in place today ano were also in place in the past.

Spool piece CVCS (3Q1) was found at the time of this examination

to be uniquely identified and ASME Code paragraph NA-4440 has been met.

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Examination of material traceability for numerous other

installations were verified at random during the c.*urse of this

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inspection and no adverse circumstances were identified.

This issue is considered closed.

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3.

Follow-up in conjunction with TDLS on records and code documentation aiiociated with CP5E5 - Unit 1 Secondary tiydrostatic Test (9/201)

During the course of this inspection, in part, in response to NRC and TDLS l

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findings regarding the Unit 1 Primary System Cold Hydrostatic Test, NRC and TDLS examined record packages and related documentation associated with the l

"Secondary-Side" Cold Hydrostatic Test of Unit 1.

Two relatively minor deficiencies in the location of several records in the packages were noted and immediate remedial action was taken by TV Electric's representatives.

In general, NRC and TDLS found that these records, in terms of clarity and i

comprehensiveness, were acceptable 'o establish that the requirerents of

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the ASME Code and governing proced. es were met during the conduct of these hydrostatic tests. Part o) the specific record packages examined by NRC and TDLS were as follows:

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Test No.1-SE-001 for Steam Generator el and associated systems dated 5/27 - 7/13/82.

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Test No. 1-SE-002 for Steam Generator #2 and associated systems dated 5/27 - 7/13/82.

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Test No. 1-SE-003 for Steam Generator #3 and associated piping dated 5/27 - 7/13/82.

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Test NO. 1-SE-004 for Steam Generator 64 and associated piping dated 5/27 - 7/13/82.

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Test NO.1-MS-005 for Hainstream System Downstream of MSIVs.

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The qualifications of the QA/QC inspectors, engineering staff, and Authorized Nuclear Inspection personnel were examined and verified to have met requirements of the ASME Code and TV Electric procedures.

Based on detailed review of the foregoing documentation and discutsion with TV Electric representatives, no conditions contrary to NRC and ASMF Code requirements were identified.

4.

Follow-up en ASME Open items List (92701)

As previously noted in NRC Inspection Report 50-445/88-13; 50-446/88-13, paragraph 2.C. in response to NRC questions. TV Electric established an Open Items List that addresses all issues current and historical involving compliance to the ASME Code.

Further, NRC and TDLS committed to rereview these issues as appropriate to establish independently if the reported status of the issues on the Open Items List met the appropriate procedural and ASME Code requirementa.

To accomplish this examination, NRC and TDLS staff examined the record packages established by TV Electric which addressed the identification, control and resolution of each of thase issues.

Further, NRC and TDLS conducted interviews with TV Electric QA/QC, engineering and management personnel and where appropriate, inspected as-built configurations.

ThefollowingitemsonTUElectric's open items list were exanined:

ITEM SUBJECT 445/8513-0-13 Pipe clamp parallelism.

445/8513-0-21 Loose flange nut.

445/8622-D-14 Pipe clearance.

445/8622-0-07 Paint on spherical bearings.

445/8622-U-15 Weld inspection of fittings.

445/8631-V-01 NCR No, M-85-1011285.

445/8713-V-01 Torque requirements.

446/8509-V-01 Wall to pipe centerline.

445/8620-0-01 Westinghouse involvement.

445/8513-0-09 Broken cotter pin on pipe support.

445/8513-0-49 Discrepant installation tolerances on pipe suppor _ _ _ _

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ITEM SUBJECT 445/8518-0-25 Clearances between pipes.

445/8607-D-13 Paint on spherical bearing.

445/8615-D-03 Clearances between pipe.

445/8615-D-04 Pipe clamp parallelisms.

445/8713-U-02 Installation of CAP screws.

CP-80-10 Hilti-Kwik concrete anchor bolts.

445/8226-0-05 Expansion affects main steam piping.

445/8226-U-06 Reflections and heat analysis, j

445/8226-U-07 Stresses in pipe supports.

445/8226-0-04 Stability of pipe analysis.

445/8214-0-04 Displacement and local stresses, i

With the exception of one of the items listed above, all apply to past NRC open, unresolved, deviations or violations. The NRC and TDLS review found that TU Electric's record packages for each of these issues

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provided sufficient documentation to support closure of the issue.

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Further, the inspection found as-built configurations supported by the l

Jocumentation.

It should be noted that all the above items have been

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closed in other NRC inspection reports.

The NRC and TDLS plant site reexamination of ASME Open Item '.ist Item No.

446/8214-0-C4 (closed in Insnection Report 50-445/88-17;50-446/88-14),

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noted the documented basis for NRC close out of this item as page 13 of i

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Appendix B of NUREG 0727 SSER 14 dated March 14, 1988.

During this inspection it was determined that the identification of the Component Mootfication Card referenced in SSER 14. Item B.2.3, is in error.

The referenced Component Modification Card No. 63568 is for a Class 5 system and could not be the basis for the close out of the Class 1 item.

The correct Component Modification Card nuinber is CMC No. 53568.

Identifi-cation here acknowledges that error and establishes that NRC has verified the existence of an appropriate basis for the close out of the subject ASME open item. The typographical error noted in SSER-14 will be corrected in the subsequent errata.

This item No. 446/8214-0-04 is considered closed by TDLS and NRC.

Each of the items listed above should be identified as closed on TU Electric's ASME Open Item list. Based on the detailed evaluation of the items described above, the NRC concludes that these issues have been acceptably resolved. Therefore, these issues are considered closed.

5.

Exit Heeting (30703)

During the course of this joint inspection by NRC ano the TDLS Chief Inspector, several interim exit briefings were conducted with TU Electric's management. The final exit meeting was conducted on October 14, 1988.

TV Electric did not identify as proprietary any of the materials provided to or reviewed by NRC inspectors during this inspection.

During these meetingt, the NRC inspector and the TDLS inspection staff surnnarized the scope and findings of the inspection.

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During the exit meeting, the CASE representative presented TV Electric

with a draft report outlining CASE's concerns regarding a number of issues j

associated with the CPSES Unit 1 Primary System Cold Hydrostatic Test.

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NRC has reviewed these issues on site.

TV Electric is preparing a

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I response to the CASE report; itRC and TDLS will review the TV Electric

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response.

In the event that TV Electric's response to these concerns

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identify new or different issues associated with this matter, the NRC

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l will conduct additional inspections and evaluation, as appropriate.

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