IR 05000445/1988063

Insp Repts 50-445/88-63 & 50-446/88-59 on 880909-1004.No Violations or Deviations Noted.Major Areas Inspected: Applicant Actions on Previous Insp Findings & Deficiencies Identified by Applicant

ML20205M516
Person / Time
Site:	Comanche Peak
Issue date:	10/25/1988
From:	Hale C, Livermore H NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20205M513	List: IR 05000445/1988063 ML20205M509
References
50-445-88-63, 50-446-88-59, NUDOCS 8811030132
Download: ML20205M516 (9)

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS I NRC Inspection Report: 50-445/88-63 Permits: CPPR-126 50-446/88-59 < CPPR-127

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Dockets: 50-445 Category: A2 '

50-446 t

Construction Permit t Expiration Dates: [

Unit 1: Extension request l

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submitte t Unit 2: Extension request i

submitte '

Applicant: TU Electric

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Skyway Tower 400 North Olive Street t Mck Box 81

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11as. Texas 75201 Facilit*/ haws: Comanche Feck Steam Electric StatJ.on (CPSES),

Units 1 & 2

. Inspection Att Comanche Peak Site, Gion Rose, Texas e Inspection Conducted: September 9 through October 4, 1988

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Inspoctor: ) /O/;;Lg[qq

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C. J. Glado, Reactor Inspector Dato' ~

Consultants: J. Birmingham, Paramotor (paragraph 3.) !

Reviewed by: O /OM f H. kj ermore, y&d Senior Inspector 'ITate 8011030132 001026

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t Inspection Summary:

Inspection Conducted: September 9 through October 4, 1988 (Report 50-445/88-63 50-446/88-59)

Areas Inspected: Unannounced, resident safety' inspection of applicant actions on previous inspection findings and deficiencies identified by the applican Results: Within the areas inspected,'one unresolved item (failure

.to take prompt action on what appears to be violation of requirements, paragraph 2.b) was identifie .

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DETAILS Persons Contacted

• R. W. Ackley, Jr., Project Manager, Stonc & Webster Engineering Corporation (SWEC)

• R. Baker, Licensing Compliance Manager, TU Electric

• J. Barker, Manager, Engineering Assurance, TU Electric

• J. Beck, Vice President, Nuclear Engineering, TU Electric

• G. Bell, Nuclear Licensing, Dallas, TU Electric

• H. Bruncr, 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, Project Gonoral Manager, Ebasco

• D. L. Davis, Nuclear Operationc, Results Engineer Manager, TU Electric

• G. G. Davis, Nuclear Operations Inspection Report Item ,

Coordinator, TU Electric

• D. E. Devincy, Deputy Director, Quality Assurance (QA),

TU Electric

• S. H. Froid, Chief Mechanical / Nuclear Engincor, Bechtel

• B. P. Gardo, Attorney, CASE

• W. G. Guldemond, Executive Assistant, TU Electric

• P. E. Halstead, Manager, Quality Control (QC), TU Electric

• T. L. Heatherly, Licensing Compliance Engineer, TU Electric

• C. B. Hog, Engineering Man 1get, Bechtel

• R. T. Jenkins, Manager, Mcchanical Enginecting, TU Electric

• J. J. Kelley, Manager, Plant Operations, TU Electric

• 0. W. Lowe, Director Of EnJineering, TU Electric

• F. M. Madden, Mcchanical Engincoring Manager, TV Electric '

• D. M. McAfco, Managor, QA, TU Electric

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

• L . D. Nace , Vice P .v.sidon';, Engineering & Construction, TU Electric

• E. F. Ottnoy, Reproscatativo, CASE  :

*S. G. Palmer, Pro]cct Manager, TU Electric

• J. D. Rodding, Executivo Assistant, TU Electric

• D. M. Reynorson, Director of Construction, TU Electric '.

• M. J. Riggs, Plant Evaluation Manager, Operations, TU Electric

• A. B. Scott, Vice President, Nuclear Operations, TU Electric

• C. E. Scott, Manager, Start-up, TU Electric

• J. C. Smith, Plant Operations Staff, TU Electric .

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• S. L. Stamm, Project Engincoting Manager, SWEC

• M. R. Stoolman, CPRT, TU Electric f

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• P. B. Stevens, Manager, Electrical Engincoring, TU Electric

• C. L. Terry, Unit 1 Project Manager, TU Electric

• T. G. Tyler, Director of Projects, TU Electric

• R. D. Walkor, Manager of Nuclear Licensing, TU Electric

• K. C. Warapius, Project Director, Impoll

• J. R. Waters, Licensing Compliance Engincor, TU Electric

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The NRC inspectors also interviewed'other applicant employees

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during this inspection perio ,

• Denotes personnel present at the October 4, 1988, exit meetin . Applicant Action on Previous Inspection Findings (92701) (closed) Open Item (445/8810-0-03; 446/8808-0-03): The paper floa group (PFG) had custody and control of i documents retrieved from the interim records vault (IRV),  !

but were not controlling these documents in accordance i with the 9:cmporary storage requirements of ANSI N45. ;

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In May 19118 the process control organization was formed and impleraented, which climinated the PFG and established several dccument processing clusters. In establishing i the process control clusters, the document packages held j in the PFG were restructured and in so doing, some  ;

completed documents were sent to records management for i vaulting. The majority of the completed documents held  :

by PFG renained a part of the restructured document  !

package ,

An oversimplified description of the change in the  !

document package structure is that in the past, PFG-era, l document packages woro developed along commodity, ,

c:mponent, or system lines. With the establishment of the process control clusters, the document packages are i being developed more along the linos of the work activity l involve ;

i Amendmont 72 to the FSAR dated July 1, 1988, provided a l clear definition of when a document becomes a QA record, f and thus subject to the requirements of ANSI N45. l When the document is submitted to records management, in i accordanco with proceduros, and records managomont has [

reviewed and accepted the document, it hocomes a QA l

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record and the ANSI N45.2.9 rcquirements appl Thoroforo, tho documents that currently are in the ,

various process control clusters are now classified as  ;

in-process documents and subject only to the requirements '

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of Critorion VI, "Document Control," of 10 CFR Part 50, Appendit Based on the foregoing, this item is close l r (closed) Open Item (445/0010-0-08; 446/8803-0-08): [

Inspection of the engincoring review and cortification of  :

the design and construction of the throo records storago i facilitios: Operations Records Contor (ORC), Engincoring I Records Contor (ERC), and Project Records Conter (PRC).

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1 By memorandum dated July 27, 1988-(NE-20285), comanche Peak engineering (CPE) sent the fire protection evaluation of permanent plant records storage facilities to records management. The evaluation was performed by Impell personnel and was documented in Impell report calculation No. 0210-063-0086, "Fire Protection Review of CPSES Records Vaults," dated June 2, 1988. Tho scope and l purpose of this report was stated as being an evaluation of the adequacy of construction and fire protection features of the ORC, ERC, and PRC record vault The NRC inspector reviewed the Impell report and found it

, had boon prepared, reviewed and approved in accordance l with applicable procedures. The Impell report contained l 22 recommendations that included modifications to the facilities (e.g., relocato smoke detectors and change vault doors), location and mounting of fire extinguishers, formalizing surveillance of vault

penetration seals, and restricting activities conducted j inside vault areas.

l For compliance with Critorion XVII, "Quality Assurance l Records," of 10 CFR Part 50, Appendix B, the applicant has adopted the requirements of Regulatory Guido 1.88,

"Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assuranco Records", Revision 2, and ANSI

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N45.2.9, "Requirements for Collection, Storage, and

[ Maintenance of quality Assurance Records for Nuclear Power Plants." Section 5.6 of ANSI N45.l.9.-1974 stator in Part, "Record storage facilities shall be constructed or located as to protect cor>tonts from possible destruction by causes such as tiros, . . ,"

This section of ANSI N45.2.9 further sr.ates, "Records discussed in this standard are appropriately classif for fire protection purposes as National Fire Protection 1 Association (NFPA) Class 1 and as auch should be afforded l the equivalent protection of a NFPA Class A four hour minimum rated facility." The June 2, '4908, Impell report was prepared to establish complianco of the record facilitics with the NFPA standard. Tho NRC inspector notes that the ANSI requirements abovo portain to single record facilitios and that there are throo such facilities on sito, and each of the site facilities contain largo numbers of singlo QA record Since the Impell report identified numerous conditions in each of the storage facilitics that aro potentially in noncompliance with requirements and the majority of the identified conditions remain undispositioned somo four months lator, the NRC inspector had further discussions with the applicant's personnel to dotarmino why more timely action to correct thoso appai-jp noncompliances had not boon taken. The applicant's personnel stated l

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that the Impell evaluation was based on the 1986 version of the NFPA code, and Regulatory Guide 1.88 referenced the 1975 version of the code. The applicant further stated that their ovaluation of the 22 Impell recommendations found that they were only enhancements and not departures from the NFPA-1975 cod The NRC inspector reviewed the substanco and disposition status of each of the 22 recommendations. Action on five of the items had been completed, but this review identified the following recommendations that are potential violations of NFPA-197 (1) ORC Recommendation: Maintain a minimum of 3" clearance between the bottom of stored records and the floor. This clearance is 1" for the storage of radiograph Records Management (RM) does not concur since it does not relate to the adequacy of fire protection, but has sont this item to CPE for reconsideration (reference CRMP 88-00184, dated August 17, 1988).

The NRC inspector believes the recommendation is valid, since tha actuation of the sprinkler system, the use of a fire hoso, or the failure of these systems could cause flooding in excess of the floor drain capacity (particularly if the floor drain were to becomo clogged from debris) thus damaging or destroying radiographs stored in bins with only 1" clearanc (2) ORC Recommendation: Ecmove *.he radiographin viewirvi equit;,nent f rom the storago area fo- radiograph SM door not concur with tais item on the basis t. hat comoving the film from the environmentallv controlled storage area could have a deln;orious effect on the radim,raphs, but has requeatad CPE to raconsidor this recommendation (ref. CRMP 88-00184).

i The NRC inspector believes the recommendation is valid for at least two reasons: (1) such activitics would subject the vault area and the stored records to unnecessary and potentially adverso exposure, which in part formed the basis for the procedural requirement found in paragraph 6.3.g) of Proceduro RMP 1.2.3, "Control of Permanent Storage Facilitics," that states, "Work not directly rolsted to records storago or retrieval shall not be allowed within the records storage arca"; and (ii)

Section 6.4.3 of Proceduro RMP 1.2.3 pormits the completo lost of the environmental control system

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for up to seven days before an engineering evaluation is required to determine any deleterious effect on the stored fil (3) ORC Recommendation: The hydraulic calculations of the. design density of the sprinkler system in the ORC is 0 19 gallons per minute per square foot (gpm/ft.2) over the area of the ORC based on assumed flowrates, available system pressure, and fire hoso station demands. The type of records stored in the

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storage area for radiographs'2however, requires a l spray density of 0.21 gpm/f RM has requestud CPE to reevaluate this system and 1 modify as necessary (ref. CRMP 88-00184). )

l (4) ORC Recommendation: Relocate and modify tho )

existing spacing of the smoke detector i RM has initiated a facilities work request; however, the work has not boon completed.

l l (5) ORC Recommendations: CPE should complete the design l modification request, initiated in 1987, so work can l

begin to correct the trouble and fire detection i signals so they will alarm at a continuously l occupied locatio CPE's action on the requestod modification has noc h

been completed.

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! (6) ORC, ERC, and PRC Recommendation: Place all vault penetration seals on the schedule for reinspectio RM has requested CPE to initiato a 2esign chango j authorization (DCA) that will include those penetration scals in the ECE-MI-1900, "Ponotration soal Schedulo," which would cause thoso scair to be rainspected against their design critoria and l

establish any necessary routine inservico inspection program for those seals in the futuro. CPE has not responded to this reques (7) ORC, ERC, and PRC Recommendation: Protect all door openings wigh vault doors that have a minimum 2-hour, 350 F rating against fir RM requestod and a purchaso order (P.O.) was issued (P.O. 661-32719) September 15, 1988, for all the required doors. The doors are expected onsite by November 7, 1938, at which timo RM will initiato a fac111 tics work request for their installatio _ _ _ _ _ _ _ _ _ _

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(Note: P.O. 661-32719 wgs issued for six vault doors: four 2-hour, 350 F doors, gne for ORC and three for ERC, and two 4-hour, 350 F doors for the PRC.)

(8) PRC Recommendation: Modify existing smoke detector number and locatio ,

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RM has submitted a facilities work request to

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relocate five detectors and add two detector This work has not been complete (9) ORC, ERC, and PRC Recommendation: That the Operation's procedures for the inspection and maintenance of fire extinguisher, automatic l suppression systems, and automatic detection systems be extended to include the ORC, ERC, and PR ,

RM has requested that the existing programs be revised or programs be developed to implement this recommendation. The requested action has not been take In sumroary, 17 of the 22 recommendations (which includes those discussed above) have not been complete .

The best estimato available to RM personnel is a completion ,

date of lato November 1988, for all items. This translatos to  ;

six months since the issuance of the Impoll report. While none of the deficiencies described above pose an immediate or significant danger to the stored QA records, it has not boon ,

clearly demonstrated to the NRC inspector that an ovaluation  !

of the 22 Impell recommendations has been made to determine  ;

that these recommendations are only enhancements and not violations of NFPA-1975. The NRC inspector will review further the applicant's assessmerit of theso recommendationr ,

i comparing them to the requirements of NFPA-1975. This item ,

i will be considered unresolved pending completion of that  !

review (445/8863-U-01). l r

j Sinco this matter has boon made the subject of an unrosolved [

item, the previously identified open item is being close t f

I 3. Action on 10CFR Part 50.55(o) Deficiencies Identified by the  !

Applicant (92700) .

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The NRC inspector reviewed the following report which had boon '

presented by tho applicant as reportable in accordance with  !

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the provisions of 10 CFR Part 50.55(o). The report was  !

i dotormined to be not reportable following the applicant's  !

l further ovaluatio ;

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(Closed) SDAR CP-85-37: Butt splico deficiencies and questionable QC inspector performance. The applicant's final review of this item vis completed with the issuance of Corrective Action Report (CAR)-05 CAR-050 also references the Results Reports for CPRT Issuo Specific Action Plans I.a.1, I.a.2, and I.a.3, which address the butt splice deficiencies. The concern over the inspection performance of the QC inspectors was addressed in Appendix A of CAR-05 The NRC headquarter's staff has reviewed the available l information relative to the butt splico deficiencios and has I

determined that the inspections performed in accordance with l

the CPRT action plans have satisfied the staff's concerns regarding the extent of pullout testing to be accomplished and the physical identification of butt splicos. Fur' .her , tho l inspections and tests performed by the CPRT provided j

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reasonable assurance that any splicos not identified would j l still perform their safety functions and are, therefore, l acceptabl ;

l The NRC inspector reviewed CAR-050, and specifically Appendix A of CAR-050 which addresses the concern for the l adequacy of the QC inspectors' performance. The NRC inspector l determined that the applicant's method of analyzing the inspectors' orrors was appropriat Further, the applicant's method of performing reinspections of each inspector's work on an expanding basis was also dotormined to be acceptabl Based on the above, the applicant's determination that the concern was not reportable is accentable. Since the correctivo and proventative actions taken by the applicant were also determined to be acceptablo, this SDAR is closed.

l 4. fJnresolved Items Unrosolved items are mattern about which more information in required in order to ascortain whether they are acceptable items, violations, or deviations. One unrosolved item disclosed during the inspection is discussed in paragraph 2.b, j

5. Exit Meeting (30703)

An exit meeting was conducted October 4, 1988, with the applicant's representativos 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 propriotary any of the materials provided to or reviewed by the inspectors during this inspectio During this mooting, the NRC inspectors summarized the scopo and findings of the inspectio _ _ _ _ _ _ _

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• 50-445/81 -6J; 50-446/f? -57 DISTRIBUTION:

5 Docket Files ~(50-445/446)a

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NRC PDR LPDR CPPD-LA CPPD Reading (HQ)

OSP Reading

• Site Reading File R. Warnick

• Wiebe

• H. Livermore

• MIS System, RIV

• RSTS Operator, RIV DRP, RIV RIV Docket File

• L. Shea, ARM /LFMB J. Taylor J. Partlow C. Grimes P. McKee J. Lyons J. Wilson M. Malloy J. Moore, OGC-WF J. Gilliland, RIV D. Crutchfield E. Jordan B. Grimos B. Hayes

• w/766

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