IR 05000445/1988070

Insp Repts 50-445/88-70 & 50-446/88-66 on 881005-1101. Violations Noted.Major Areas inspected:post-const Hardware Validation Program,Comanche Peak Response Team issue- Specific Action Plans & General Plant Tours

ML20206B703
Person / Time
Site:	Comanche Peak
Issue date:	11/10/1988
From:	Livermore H, Runyan M NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20206B696	List: IR 05000445/1988070 ML20206B693 ML20206B697
References
50-445-88-70, 50-446-88-66, NUDOCS 8811150538
Download: ML20206B703 (12)

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APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL-PROJECTS

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NRC Inspection Report: 50-445/88-70 Permits: 'CPPR-126 .

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50-446/88-66 CPPR-127 -

Dockets: 50-445 -Category:,A2

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50-446

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Construction Permit Expiration Dates:

Unit 1: Extension request '

submitte Unit 2 ' Extension request submitte Applicant: TU Electric Skyway Tower

400 North Olive Street Lock Box 81 Dallas, Texas 75201 I Facility Name

Comanche Peak Steam Electric Gtation (CPSES),

Units 1 & 2

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, Inspection Att Comancho Peak Site, Glen Rose, Texas t

Inspection conducted: October 5 through November 1, 1988 '

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Inspector: haw ti lOh  ;

M. F. Ruhyah, Resident Inspector, Date  !

Civil Structural P

Consultant W. Richins, Parameter (paragraphs 2, 3, and 4) [

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Reviewed by: tA m. vt t_ - " /'C /88 H. H. Livermore, Load Senior Inspector Dato  ;

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Inspection Summary:

Inspection conducted: October 5 throuch November 1, 1988 (Report 50-445/88-70; 50-446/88-66)

Areas Inspected: Unannounced, resident safety inspection of Post-Construction Hardware Validation program (PCHVP), Comanche Peak Response Team (CPRT) issue-specific action plans (ISAPs), and general plant tour Results: Within the areas inspected, one open item was identified concernIng use of the turn of the nut method for tightening bolts in drilled and tapped holes (paragraph 2), another open item was identified concerning an inspection report which states that cotter pins were deformed while no cotter pins are called for by the design drawings (paragraph 2), one violation was identified for a gouge in an embedded plate (paragraph 2), and a strength was identified in regards to the applicant's efforts to correct problems with the Damage Study Program (paragraph 3).

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DETAILS Persons Contacted

• R. W. Acklef, Jr., Director, CECO ,

• R. P. Ba).or, Licensing Compliance Manager, TU Electric

• J. L. Darke7, Manager, Engineering Assurance, TU Electric

• D. P. B r. r r v , Manager, ESG, SWEC

• J W . Bcek, Vice President, Nuclear Engineering, TU Electric

• M. R. P~evins, Manager, Technical Support, TU Electric

• H. D Bruner, Senior Vice President, TU Electric

• ';.* . J. Cahill, Consultant, TU Electric M. R. Clem, CAP Structural, Stone and Webster Engincoring Coporation (SWEC)

• J. T. Conly, APE-Licensing, SWEC

• G. G. Davis, Nuclear Operations Inspection Report Item Coordinator, TU Electric

• R. D. Delano, Licensing Engineer, TU Electric

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

TU Electric

• G. L. Edgar, Attorney, Newman and Holtzinger

• G. E. Grabruck, QA, Impell

• W. G. Guldemond, Executive Assistant, TU Electric N. D. Hammett, Engineering Assurance, Brown & Root (B&R)

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

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

• C. B. Hogg, Engineering Manager, Bechtel C. R. Hooten, Civil Engineering Manager, TU Electric

• R. T. Jonkins, Manager, Mechanical Engineering, TU Electric

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

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

• F. W. Maddon, Mechanical Engineering Manager, TU Electric

• G. M. McGrath, TS/SP Manager, Startup, TU Electric

• J. C. Miller, Site Manager, TENERA

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

• L. D. Nace, Vico President, Engiacering & Construction, TU Elo tric D. Noss, Licensing Complianco, Daniel

• E. F. Ottney, Representative, CASE

• S. S. Palmer, Project Manager, TU Electric

• J. D. Redding, Executive Assistant, TU Electric

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

• M. J. Riggs, Plant Evaluation Manager, Operations, TU Electric M. E. Shoridan, CAP EMD, SWEC M. R. Steelman, CPRT, TU Electric

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

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

• J. F. Strcctor, Director, QA, TU Electric

• C. L. Terry, Unit 1 Project Manager, TU Electric E. O. Tomlinson, CAP Structural, SWEC

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

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K. W. Van Dyne, Engineering Assurance, Southern Technical Services

• J. R. Waters, Licensing Compliance Engineer, TU Electric The NRC inspector also interviewed other applicant employees during this inspection perio * Denotes personnel present at the November 1, 1988, exit meetin . Post-Construction Hardware Validation Program (PCHVP) (48053) Pipe Whip Restraints (CPE-SWEC-FVM-EE/ME/IC/CS-086, CPE-SWEC-FVM-EE/ME/IC/CS-089, CPE-SWEC-FVM-ME/EE/IC/CS-090)

(1) RC-1 135-904-C47W, pipe whip restraint, Reactor Building, Unit 1: The NRC inspector reviewed the documents in the PCHVP package and inspected the pipe whip restraint. The QC inspector had identified unsatisfactory conditions related to bolting and weldin Bolting size, washer material, and bolting nut engagement were indeterminato due to inaccessibilit In addition, the QC inspector had identified that a portion of a fillet wold was missing on one side of a joint. Nonconformance Reports (NCRs) 88-11470 and 88-11471 had been issued to address these conditions. The NRC inrpc cor concurred with the description of noncone;or aances identified in the NCR The design drawing 2323-S1-0576 specifies drilled and tapped holes for 3/4 inch A325 bolts. The QC inspector had identified unsatisfactory conditions for items A and B 'rcuse of existing bolts and replacement of existii.7 bolts, respectively) on Inspection Report 1-0176.'91 for FVM-086. These conditions worc addressed 7n NCR 88-11470 which states that per engineering c9 quest, the A-325 bolts were unavailable and; therefore, not removed or replaced as required by Specification 2323-SS-16 NCR 88-11470 has not yet been dispositione As further explanation, NCR 88-11470 states that the turn of the nut method of bolt tightening cannot be uacd for bolts installed in drilled and tapped holes and the bolts were therefore inaccessible for

". . . the purposes of accomplishing the required replacement method." The NRC inspector requestod further explanation as to why (1) the bolts woro unavailable, (2) the turn-of-tho-nut method could

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not be used, and (3) the bolts were not replace This is an open item (445/8870-0-1).

(2) RC-1-135-905-C47W, pipe whip restraint, Reactor Building, Unit 1: The NRC inspector review 0d the documents in the PCHVP package and inspected the pipe whip restraint. The QC inspector had identified unsatisfactory conditions related to configuration, bolting, and weld location. Portions of the pipe whip restraint were inaccessible for inspection, unspecified attachments were identified, and additional welding was noted. NCRs 88-11735 and 88 .1.*6898 had been issued to address these conditions. The NRC inspector concurred with the description of nonconformances presented in the NCR Inspection Report 1-0166373 identified that cotter pins were deformed. Cotter pins were not called for on the design drawings. This is an open item (445/8870-0-2). The NRC inspector verified that the remaining attributes were satisfactory as identified in the inspection report b. Structural and Miscellaneous Steel (CPE-SWEC-FVM-EE/ME/

IC/CS-086 and CPE-SWEC-FVM-ME/EE/IC/CS-090 (1) CS-090-CGi-844-99A-523, loaded embeddad plate, Diesel Generator Room,. Unit 1: The NRC inspector reviewed the PCHVP package and visually inspected the embedded plato. In accordance with Procedure NQI 3.09-M-005, the only attributo inspected by the applicant QC inspector was base metal damage. The QC inspector determined that this attribute was satisfactory. The NRC inspector concurred with the QC inspection repor (2) CS-090-RB1-812-023-505, loaded embedded plate, Reactor Building, Unit 1: The NRC inspector reviewed the PCHVP package and visually inspected the embedded plate. In accordance with Procedure i NOI 3.09-M-005, the only attributo inspected by the applicant PC inspector was base metal damage. The QC inspector had identified ono 3/8 inch diamotor '

hole and two 9/32 inch diameter holes located within 12 inches of loaded angle clips. These conditions were addressed by NCR 88-12657. The NRC inspector i

concurred with the description of nonconformancos identified in the NCR.

! In addition to the above nonconformancos, the NRC inspector identified a gouge in the base metal l

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approximately 3/16 inch x 5/16 inch x 1/8 inch dee The gouge was located within approximately 1-1/2 inches of a loaded angle clip. This nonconforming condition was not identified on Inspection Reports 1-0240944 or 1-0240242. Specification 2323-SS-30,

"Structural Embedments," Revision 3, Appendix A, Section 13 states, in part:

"Damage / defect is the portion of the plate surface where the reduction of plate thickness . . . shall not exceed . . . 0.070 inch for 1 inch thick plate."

The gouge identified above is approximately 0.125 inch in a 1 inch plat Critorion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 0, of the TU Electric Quality Assurance Manual requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings. The above gouge in the embedded plate is identified as a violation (445/8870-V-3). Applicant Action on CPRT Issue-Specific Action Plans (ISAPs)

(48055)

The following CPRT ISAP II.d activities were inspected during this report period: Review Procedures and Methods for Damage Study (NRC Reference 02.d.05.00), Review Critoria and Acceptability of Category II Interactions (NRC Reference 02.d.06.00),

and Review Criteria for Evaluation of Consequences for Interactions (NRC Reference 02.d.07.001 CPRT evaluated the procedures and critoria associated with the Damage Study Program (DSP*) for compatibility with associated FSAR commitments and accepted engineering practices. This included identification and assessment of Seismic Category II (SCII) critoria. CPRT specifically evaluated the procedures and acceptance criteria addressed in the following documents related to the DSP:

"Control of Seismic & Non-Seismic Componer4t Interaction Evaluations", TUSI Instruction CP-EI-4.0-36, Revision 3, December 9, 198 "Currently referred to as the Systems Interaction Program

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"Maintenance of Damage Study Analyses," TUSI Instruction CP-EI-4.0-53, Revision 1, July 12, 198 "Design Control of Calculations and Failure Mode &

Effects Analysis (FMEA's) for Damage Study", TUSI Instruction CP-EI-4.0-19, Revision 2, September 19, 198 "Comanche Peak Seismic Interaction Criteria Document",

TUGCO memo CPPA 27912, February 18, 198 The CPRT review specifically addressed procedures and criteria that were in effect prior to the TRT actions that initiated this ISAP. The above procedures were superseded during the process of ISAP I implementation. The current procedures were not reviewed in detail by CPRT except as the procedures related to applicant resolution of concerns identified by CPRT. The evaluation by CPRT of the DSP process and the Damage Study Group (DSG) was documented by a series of questions and answers. The details of this review process are contained in CPRT File II.d.4b.2, "CPRT Engineering Evaluation of Seismic Interaction Portions of the Damage Study Program," and summarized in the ISAP II.d Results Repor CPRT based the acceptability of the DSP procedures and criteria on the general FSAR licensing commitments. The FSAR requires that potential source commodities be shown to remain in place during and after a safe shutdown earthquake or, if source commodity failure occurs, that '

no unacceptable damage occurs to adjacent safety-related commoditie The CPRT review of the original DSP procedures and criteria included evaluation of the following:

. Interfaces between the Damage Study Group and other disciplines,

. Potential for omission of generic areas,

. DSP selection criteria for sources and targets including seismic Category II critoria,

. Basis for determining interactions,

. DSP criteria for interaction evaluation, and

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. Method of identifying classified and unclassified rooms.*

Several concerns were identified by CPRT regarding various aspects of the DSp procedures and criteri These concerns were documented in the Results Report for ISAP II.d and in Deviation Information Reports (DIRs).

The CPRT identified concerns regarding the original DSP procedures and critoria are summarized below DIR Concern D-1841 Failure to identify potential interactions and involving commodities attached to different D-2132 buildings, portions of buildings, or secondary wall ;

D-1843 Failure to identify potential interactions due and to horizontal swaying of suspended lighting D-2183 fixtures. In some cases, cable designed to limit swaying was secured to framcwork that was not seismically qualifie D-1840 Failure to identify potential interactions associated with source commodities attached to largo scismically qualified equipment (primarily cranes) after the equipment was installe D-2200 Failure to identify potential interactions resulting from source commoditics line-mounted on small bore pipin D-1842 The assumptica was made that no adverso impact of potential targets due to horizontal motion of the source commoditics can occur for (1) cablo-restrained piping and Train C conduit greator than two inches in diamator and (2) all small bore pipin The DSP documentation was j

inadequate to support this assumption.

l D-1844 Walkdown personnel were allowed to resolvo l potential interactions in cases where source

! pipes or conduits woro above safety-related ,

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cable trays. The DSP documentation did not provido adequate basis.

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• Classified rooms woro rooms identified as having so many

potential target commoditics that it became practical to l

seismically support largo boro Class 5 piping, Train C conduit, and l nonsafety-related equipment.

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'* 9 D-1845 Lack of guidance for determining support loads for some class 5 large bore piping using a ,

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These concerns were addressed by the new Systems Interaction Program (SIP) procedures and/or by a series of Specific Technical Issuo Reports (STIRS) listed below:

STIR N Title STIR-CPRT-S-008 ISAP I STIR-CPRT-S-009 Commodities Attached to Secondary Walls STIR-CPRT-S-018 Commodity clearance CPRT concluded that a simplo document review was insufficient to readily determine whether the implemented scope of the DSP procedure was consistent with FSAR commitments. The adequacy of the DSP procedures was, in part, evaluated by CPRT during the DSP implementation evaluatio The NRC inspector discussed the above CPRT and applicant activitics with CPRT personnel and reviewed the supporting documentation contained in CPRT Files II.d.4b.2. The NRC inspector also reviewed the conclusions reached by CPRT as stated in the ISAP I Results Report. The NRC inspector concluded that the CPRT review efforts were adequate to assess the DSP procedures and critoria. The NRC inspector also concluded that the CPRT identified concerns were adequately addressed by the current SIP procedures and/or STIR No violations or deviations were identifie This activity is complete and no further NRC inspection is planned for these reference item Review Implementation of Damage Study (NRC Reference 02.d.08.00) and Comparative Damage Assessment in Selected Rooms (NRC Reference 02.d.09.00 CPRT evaluated the implementation of the procedures and critoria contained in the four documents related to the DSP listed in Section 3.a of this repor In addition, CPRT reviewed several discipline-specific calculations which formed the basis for interaction resolutio CPRT prepared an evaluation checklist used for CPRT physical walkdowns and review of documentation related to the implementation of the DSP. The evaluation checklist contains a series of questions under each of five

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sections: (1) source identification, (2) interaction identification, (3) interaction resolution, (4) resolution follow-up, and (5) program maintenanc CPRT completed evaluation checklists for 22 sources for which there were 14 identified interactions. The sources were located in 16 rooms in a variety of location Based on those walkdowns and document review efforts, CPRT confirmed that the DSP correctly identified the targets and interactions. For eight source commodities, no interactions were identified by the DSP. CPRT confirmed that there were no targets within potential interaction zones for these eight source commoditie CPRT concluded that the DSP implementation process provided reasonable assurance that potential source commodities and interactions were identified in accordance with DSP criteria, and that reasonable resolutions were mad The DSP used the Dynamic Impact Damage Criteria (DIC) in many instances as an interaction resolution justification. The DIC consisted of nine assessments that could be made in the process of evaluating a interaction. The assessments were generally qualitative and the criteria specifically indicated that engineering judgement was to be applied. CPRT assessed the acceptability of the DIC as part of the DSP implementation evaluatio CPRT randomly selected 68 samplo interactions resolved by the DSP using the DIC. Each of the selected interactions were verified by CPRT. The interactions were walked down, physical measurements were taken, and independent calculations were completed. CPRT concluded that use of the DIC was an acceptable method of interaction resolution with the exception of Criterion 6 which was applicable to source pipe / conduit over safety-related cable trays. This concern was addressed in DIR D-184 CPRT selected four rooms for a Comparativo Interaction Assessmen The assessment involved an independent identification (by physical walkdowns) of potential interactions and a subsequent comparison with the corresponding interaction matrix previously developed by the DSP. Where CPRT identified a potential interaction not identified by the DSP due to differences in engineering judgement, an assessment was made by CPRT to determine if any unacceptable interaction could occu CPRT concluded that, except for architectural features

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and Train C junction boxos, no significant disparitics were identified by the Comparative Interaction Assessmen In addition, CPRT verified that the i

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architectural features identified as part of this assessment were also identified by the DSP architectural features walkdowns. The Train C junction boxes are addressed STIR-CPRT-00 The NRC inspector discussed the above CPRT and applicant activities with CPRT personnel and reviewed the supporting documentation contained in CP Files II.d.4b.2. The NRC inspector also reviewed the conclusions reached by CPRT as stated in the ISAP I Results Repor The NRC inspector physically inspected the hardware associated with and the CPRT evaluation checklists for the following potential interactions initially identified by the DSP:

Source Description Location Large floor-mounted Room 58, Unit 1, Safeguards vertical tank, building 3-inch diameter conduit Room 206, Unit 1, Auxiliary building 10-inch diameter pipe Room 207, Unit 1, Auxiliary building Floor-mounted gas Room 223, Unit 1, Auxiliary analyzer rack building The NRC inspector also reviewed selected calculations and inspection documents prepared by CPRT to assess the adequacy of the DSP implemortation, the process used for randomly selecting samples, and the Comparative Interaction Assessment of room 170 in the Auxiliary Building, Unit The NRC inspector concluded that the CPRT review efforts were adequate to assess the DSP implomontation. The NRC inspector also concluded that the CPRT identified concerns were adequately addressed by the current SIP procedures and/or STIRS and that the documentation contained in the CPRT Files II.d.4b.2 support the conclusions stated in the ISAP II.d Results Repor Ongoing and recommended corrective actions are part of the SI The SIP is being implemented as part of the TU Electric Corrective Action Program (CAP). NRC inspectors are currently reviewing applicant activitios associated with the CA F ,

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No violations or deviations were identified. This activity is complete and no further NRC inspection is planned for these reference item This completes the NRC review of ISAP II.d. The NRC inspector considered the applicant's efforts to correct problems with the DSP to be a strength within the ISAP progra . Plant Tours (48053, 48055)

The NRC inspector made frequent tours of Unit 1, Unit 2, and I common areas of the facility to observa items such as housekeeping, equipment protection, and in-process work activities. The tours included intermittent observations of QC validation and final close-out of the seismic gap between the Auxiliary Building and Safeguards Unit No violations or deviations were identifie . 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. Two open items disclosed during the inspection are discussed in paragraph . Exit Meeting (30703)

An exit meeting was conducted November 1, 1988, with the applicant's representatives identified in paragraph 1 of this repor 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 inspectio During this meeting, the NRC inspectors summarized the scope and findings of the inspection.