IR 05000445/1989004
| ML20235X575 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/01/1989 |
| From: | Latta R, Livermore H Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20235X559 | List: |
| References | |
| 50-445-89-04, 50-445-89-4, 50-446-89-04, 50-446-89-4, NUDOCS 8903130531 | |
| Download: ML20235X575 (18) | |
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S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION NRC Inspection Report:
50-445/89-04 Permits: CPPR-126 50-446/89-04 CPPR-127 Dockets: 50-445 Category: A2 50-446 Construction Permit Expiration Dates:
Unit 1: August 1, 1991 Unit 2: August 1, 1992 Applicant:
TU Electric Skyway Tower 40011 orth Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name:
Comanche Peak Steam Electric Station (CPSES),
Units 1 & 2 Inspection At:
Comanche Peak Site, Glen Rose, Texas Inspection Conducted:
January 11 through February 7, 1989 Inspector:
244 92 6 L-L-6 h
R. M. Latta, Resident Inspector Date-g s (paragraphs 3.a-b, 4.e, 4.g, 5.a-c, 6, 7, 8, 10, and 11)
Consultant:
J.
L. Taylor - Parameter (paragraphs 2.a-b, 4.a-d, 4.f, 6, 8, and 9)
Reviewed by:
EAs4Rb 3-l-6 H. H. Livermore, Lead Senior Inspector Date 8903130531 890301 PDR ADOCK 05000445 O
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Inspection Summary:
Inspection Conducted: January 11 through February 7, 1989 (Report 50-445/89-04; 50-446/89-04)
Areas Inspected: Unannounced, resident safety inspection of applicant's actions on previous inspection findings, follow-up on violations / deviations, action on 50.55(e) deficiencies identified
.by the applicant follow-up on NRC Bulletins, the Corrective Action f
Program (CAP) including electrical components and electrical cable work, instrument components and systems, allegation follow up, and plant tours.
Results:
Within the areas inspected, program weaknesses were noted within the electrical training area in that craft personnel installing safety-related power cables did not appear to be familiar with installation specification requirements, paragraphs 6.a, 6.b(1), and 6.b(2).
Two unresolved items were identified relative to cable pulling aids that were left in conduits, paragraph 9.c; and attribute inspection, paragraph 6.a.
During the inspection, no significant safety matter, violation, or deviation was identified.
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DETAILS 1.
Persons Contacted
- R.
W.
Ackley, Jr., Director, CECO
- M.
Alexander, Manager of Materials Management, TU Electric
- J.
L.
Barker, Manager, Engineering Assurance, TU Electric
- D.
P. Barry, Sr., Manager, Engineering, SWEC
- J. W. Beck, Vice President, Nuclear Engineering, TU Electric
- H.
D. Bruner, Senior Vice President, TU Electric
- J.
Buck, Senior Review Team
- W.
J.
Cahill, Executive Vice President, Nuclear, TU Electric
- J.
T. Conly, APE-Licensing, SWEC
- W.
G.
Counsil, Vice Chairman, Nuclear, TU Electric
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- C.
G.
Creamer, Instrumentation & Control (I&C) Engineering Manager, TU Electric
- G.
G.
Davis, Nuclear Operations Inspection Report Item Coordinator, TU Electric
- D.
E. Deviney, Deputy Director, Quality Assurance (QA),
i TU Electric
- J.
C.
Finneran, Jr., Acting Manager, Civil Engineering,
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TU Electric
- C.
A. Fonseca, Deputy Director, CECO
- W.
G.
Guldemond, Manager of Site Licensing, TU Electric
- T.
L.
Heatherly, Licensing Compliance Engineer, TU Electric i
- J.
C.
Hicks, Licensing Compliance Manager, TU Electric I
- C.
B. Hogg, Engineering Manager, TU Electric
- S.
D. Karpyak, Nuclear Engineering, TU Electric
- J.
J.
Kelley, Manager, Plant Operations, TU Electric
- J.
J.
LaMarca, Electrical EngineeLang Manager, TU Electric
- O."W.
Lowe, Director _of Engineering, TU Electric
- J.
W.
Muffett, Manager of Engineering, TU Electric
- W.
E. Nyer, Consultant, TU Electric
- E.
F. Ottney, Program Manager, CASE
- S.
S.
Palmer, Project Manager, TU Electric
- W. J. Parker, Project Engineering Manager, SWEC/ CECO
- A.
Pereira, Assistant to Deputy Director, QA, Ebasco
- D. M. Reynerson, Director of Construction, TU Electric
- A.
B.
Scott, Vice President, Nuclear Operations, TU Electric
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- C.
E.
Scott, Manager, Startup, TU Electric
- J.
C.
Smith, Plant Operations Staff, TU Electric
- C.
L. Terry, Unit 1 Project Manager, TU Electric
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- D.
R. Woodlan, Docket Licensing Manager, TU Electric l
The NRC inspectors also interviewed other applicant employees during this inspection period.
- Denotes personnel present at the February 7, 1989, exit meeting.
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2.
Applicant Action on Previous Inspection Findings (92701)
a.
-(Closed) Open Item (445/8603-0-01; 446/8604-0-01):
Electrical penetration assembly (EPA) vendor splices not on field drawings.
As stated by the applicant,-the vendor installed splices in EPA lE78 were considered an integral part of the EPA and were not required to be specifically identified in the facility drawings.
A determination of the adequacy of this practice
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precipitated the establishment of this open item.
Subsequent to the identification of this issue, other EPA problems resulted in the replacement of the Bunker Ramos units with.Conax units.
This replacement eliminated the splices in question and is documented by SDAR CP-86-10 (see paragraph 4.b) which also addresses Unit 2 EPAs.
This item is closed.
b.
(Closed) Open Item (445/8853-0-01; 446/8849-0-01):
Stick-on tie wrap mount replacements.
This open item involved the lack of programmatic controls pertaining to the use of screw attached cable tie mounts which were used to replace adhesive attached mounts.
In response to this item, the applicant issued deficiency report (DR)
C88-03582.
The NRC inspector reviewed the technical disposition of this DR including the eight nonconformance reports (NCRs) and design change authorization (DCA)
78713, Revision 0, which were referenced in the disposition of this DR.
Based on these reviews, the NRC inspector determined that the above noted DCA revised the controlling electrical specification, ES-100, to include QC inspection criteria which effectively documented the existence of the specified screw attached cable tie mounts.
In order to confirm the implementation of the revised requirements of ES-100, selected Class 1E electrical panels in Unit 1 were inspected by the NRC inspector.
The inspector determined that the observed ty-rap mounts were installed in accordance with the revised screw attachment requirements of ES-100 and that the programmatic controls appeared to be effective.
This item is closed.
3.
Follow-up on Violations / Deviations (92702)
I a.
(Closed) Violation (EA 86-09, Appendix A, Item II.A.2):
This violation concerned the failure to adequately control drawing design change revisions in that as-built conditions were not properly reflected on electrical diagrams.
Specifically, six cables, five of which were safety related, were not terminated in accordance with
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drawings effective at the time of the inspections.
The applicant's committed corrective actions were performed under the auspices of issue-specific action plan
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(ISAP) I.a.4.
The NRC inspector reviewed ISAP I.a.4 and supporting documentation and concluded that the applicant's corrective actions taken to recolve the issue and avoid. future recurrence were adequate.
Details of the NRC review are contained in Comanche Peak Supplemental Safety Evaluation Report 20, page 14. -This item is closed.
b.
(Closed) Violation (445/8518-V-01):
Excessive length of conduit between end device and junction box.
As previously documented in NRC Inspection Report 50-445/86-26; 50-446/86-22, Appendix C, paragraph 2.ac, this violation involved two conduits associated with Unit-1 primary coolant sample supply and return isolation valves 1HV-4631 A and B.
These conduits were approximately 15 feet longer than the controlling drawing allowed.
In order to identify the root cause of this violation.and l
prevent reoccurrence the applicant issued NCR E86-102718 j
and completed plant walkdowns to identify any deviations l
from the installation requirements of drawing
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2323-El-1701, detail 18, as part of Corrective Action l
Request (CAR)-63.
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The NRC inspector determined that NCR E-86-102718 had been' transferred to NCR CE-87-3226 which reworked the subject valves to be in compliance with the controlling drawing.
The inspector also reviewed DCA 21912 and performed field inspections of valves 1HV-4631 A and B l
and determined that the committed actions had been accomplished.
Additionally, the inspector reviewed I
CAR-63 and concluded that the plant walkdowns and document searches to identify any deviations in Class 1E,
detail 18, splices and pigtail extension installations in Unit 1 and common areas were documented per field verification method field verification method (FVM)-022.
The above noted corrective actions completed by the applicant are regarded as adequate to prevent future reoccurrence; therefore, this item is closed.
4.
Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant (92700)
a.
(Closed) SDAR CP-86-49, " Adaptor Modules and Electric Penetrations":
The applicant reported a deficiency in j
which 11 Conax electrical penetration assembly (EPA)
adaptor module end sealants were damaged by contact with polyorganic solvents.
The applicant replaced the damcged modules and revised construction protective coating j
(painting) procedures to prevent future reoccurrence.
The NRC inspector reviewed the NCRs and QC inspection
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reports (QCIRs) pertaining to the module replacement and reviewed the revised painting. procedures.
Additionally, the NRC inspector reviewed four equipment manuals concerning the EPAs and adaptor modules and physically inspected the seven Unit 1 modules and four Unit 2 modules which were replaced.
No discrepancies were identified during these inspections; therefore, this SDAR is closed.
b.
(open) SDAR CP-86-10, " Electrical Penetration Assemblies (EPAs)":
The NRC initial inspections of this SDAR were documented in NRC Inspection Reports 50-445/86-04, 50-446/86-03; 50-445/86-32, 50-446/86-26; 50-445/87-03, 50-446/87-03; and 50-445/87-07, 50-446/87-06.
To evaluate the completion of Unit 1 EPA replacements, the NRC inspector randomly selected and reviewed eight of the Unit 1 NCRs that were listed in Stone and Webster's letter, SWTU-9709 to TU Electric dated July 29, 1988, which directed EPA replacement.
Of these eight NCRs, six were not available at the record's vault.
One NCR, E86-10116 was closed by an unsatisfactory QCIR.
The QCIR led to NCR E86-15402 of which Revision 1 was transferred to NCR CE87-1727 which referred to NCR CE87-5172Rl.
The NRC inspector was unable to determine from a records review that the affected EPA was satisfactorily replaced and terminated.
Further reviews indicated that several NCRs had been transferred to construction deficiency reports (CDRs) which were incomplete.
Only one package was found with sufficient documentation to verify that an EPA had been satisfactorily replaced; therefore, this SDAR remains open pending further NRC review.
c.
(Closed) SDAR CP-86-32, "Thru Wall Embedded Conduit Sleeves":
The applicant reported a potential problem involving the failure to identify certain conduit sleeves by numbers which in turn may have resulted in the effected sleeves being overfilled.
In evaluating this issue for deportability, the applicant performed FVM-023,
" Acquire Data for Cable Percent-Fill Calculations and Identification of Thru-Floor and Thru-Wall Embedded Conduit Sleeves."
Additionally, the applicant directed the performance of Bisco Test 748-225 dated October 8, 1987, "Three-Hour Fire Test of Five Conduits with Cable Fill Exceeding 50%."
The NRC inspector reviewed FVM-023 as well as the results of the above mentioned fire test and performed inspections of rooms 200, 201, and 205 utilizing the completed FVM-023 packages for those rooms.
During the performance of these room inspections, a discrepancy was identified between documentation and actual conduit number for non-Class 1E conduit C14K16415 at sleeve No. 1009 in room 200.
The error was reported to applicant personnel for correction of documentation.
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This condition was determined to be an isolated case.
The NRC inspector also noted that the applicant's final report, letter TXX-88012 dated January 5, 1988, states that FVM-023 is continuing for Unit 2; however, Revision 4 of the FVM dated July 14,-1988, indicates the scope is limited to Unit 1 and Common only.
Subsequently, the NRC inspector determined that DCA 21464 revised electrical specification ES-100 sleeve identification requirements which is applicable to Unit 2.
Based on the above reviews and room inspections, the NRC inspector regards the applicant'ss determination of nonreportability for this SDAR as acceptable.
This item is closed.
d.
(Closed, Unit 1) SDAR CP-87-45, " Reactor Coolant Pump (RCP) Motor Backup Circuitry":
The applicant reported a design deficiency concerning compliance with Regulatory Guide 1.63 in that the primary and backup protective relays for the containment electrical penetrations serving the RCP motors shared common current transformers (cts) and wiring.
Additionally, 125V DC control power for primary and backup circuit breakers was supplied from a common switchboard.
The NRC inspector reviewed various DCAs and work orders which corrected the above deficiencies and verified that the installation of cables, relays, and cts had been accomplished for Unit 1 RCPs No. 11 and 12.
Unit 2 changes have not been implemented; therefore, this SDAR is considered closed for Unit 1 only, e.
(Closed, Unit 1) SDAR CP-87-49, " Solid State Safeguards System Internal Wiring Terminations".
On June 22, 1987, the applicant received notification of a 10 CFR Part 21 reportable event by the supplier of their solid state safeguards (SSS) system.
The notification identified a potential deficiency involving faulty wiring terminations in the load sequencers.
Initial notification to the NRC of this condition was provided by the applicant on July 22, 1987, with interim reports supplied by letters TXX-6674 on August 21, 1987, and TXX-6880 on october 21, 1987.
Deportability of this event was documented on January 11, 1988, by letter TXX-88021 with the final report being issued on March 11, 1988, as delineated in
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letter TXX-88296.
Reviews of the supporting documentation indicated that the deficiencies in the crimped lug electric connections
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in the load sequencers were the result of inadequate manufacturing inspection controls in place at the suppliers facility prior to April 1979.
Additionally, these reviews indicated that the four load sequencers l
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supplied to the applicant were provided during the time period when the manufacturers controls were inadequate.
The NRC inspector reviewed the applicant's corrective actions which included detailed inspections and documentation of deficiencies in the load sequencers
internal wiring as well as extensive rework consisting of determinations and circuit checks.
The inspector also reviewed the completed work documentation contained in startup work packages Nos. 4594 and 4595 for Unit 1 and performed an inspection of both Unit 1 and Unit 2 SSS system cabinets.
These inspections revealed that the stipulated rework had been performed for Unit 1; however, it has not been completed for Unit 2 due to the
applicant's deferral of work on the latter unit.
Therefore, this item is closed for Unit 1 only.
f.
(Closed, Unit 1) SDAR CP-87-51, "480V Containment Electrical Penetration Backup Protection":
The applicant reported a design deficiency concerning compliance with Regulatory Guide 1.63 in that no backup trip signal was provided to the tie breaker when the 480V safeguard buses are being supplied by the tie breaker and when the main feeder breaker was out of service.
The NRC inspector i
reviewed the work packages correcting the above deficiency in Unit 1 and noted that the packages also implemented NCR 88-01886 disposition to correct f
improperly isolated non-Class 1E loads (cubicle space l
heaters and convenience outlets).
The NRC inspector I
verified that the work had.been performed for Unit 1; however, it has not been accomplished for Unit 2.
This SDAR is considered closed for Unit 1 only.
g.
(Closed) SDAR CP-87-97, Flexible conduit inspections:
On September 8, 1987, the NRC was notified of a deficiency involving QC inspection records.
Specifically, Class 1E l
flexible conduits attached betwoun electrical / mechanical equipment and junction boxes had not been inspected by either mechanical or electrical quality control (QC)
inspectors for conformance to maximum and minimum flex length in accordance with applicable procedures and design drawings.
In order to assess the impact of this condition and evaluate deportability, a technical evaluation was performed.
The applicant also initiated CAR-075 to
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document and rectify the deficiency.
Subsequent interim reports were provided by the applicant on October 8, 1987, by letter TXX-6833 and on December 16, 1987, by letter TXX-7003.
On January 11, 1988, the NRC was advised by letter TXX-88047 that the subject deficiency was deemed not reportabl m
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The NRC inspector reviewed the documentation associated with this SDAR including flexible conduit trend evaluation; Impel calculation FC-005, Revision 1,
" Flexible Conduit Slack Evaluation"; Report No. 09-0210-104; and Impell letter 0210-049-031,
" Flexible Conduit Inspections."
Based on these reviews, the NRC inspector determined that the applicant had adequately demonstrated the acceptability of the as-installed flexible conduit.
The NRC inspector regards the applicant's determination of nonreportability for this SDAR as acceptable.
This item is closed.
5.
Follow-up on NRC Bulletins (92703)
a.
(Closed, Unit 1) NRC Bulletin 76-02:
" Relay Coil Failures - GE Type HFA, HGA, HKA and HMA Relays."
This bulletin concerned failures experienced in GE model 12 HFA 51A42H relays during reactor safeguards system testing.
The failures were attributed to open circuit coil defects of the relay windings caused by a combination of humid conditions and halogens produced from the type of nylon coil spools utilized in the manufacturing process.
The applicant's response to this bulletin contained in TXX-1452 dated March 25, 1976, stated, in part, that none of the referenced relays were in service in safety-related circuits at the time the response was made to the bulletin.
The NRC inspector determined that subsequent to the above response, relays of the HGA type were utilized in safety-related switchgear; however, they were of a later design and were not subject to the failure mode described in this bulletin.
Therefore, this bulletin is closed for Unit 1.
b.
(Closed, Unit 1) NRC Bulletin 76-03:
" Relay Malfunctions
- GE Type STD Relays."
This bulletin identified a malfunction of a GE type 12STD15B5A relay which ultimately resulted in the isolation of the 600 volt load center at the reporting facility.
The applicant's response to this bulletin was provided by letter TXX-1452 dated March 25, 1976, which stated, in part, that relays of the type identified in IEB 76-03 were not currently utilized in safety-related circuits at Comanche Peak.
This position was reaffirmed in late 1988 by the applicant's field walkdowns and design drawing reviews documented in licensing correspondence review, LCR IEB 76-02 and 76-03.
Based on the above stated information and the NRC inspector's reviews, this bulletin is considered closed for Unit 1.
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c.
(Closed) NRC Bulletin 88-03:
" Inadequate Latch Engagement in HFA Type Latching Relays Manufactured by General Electric (GE) Company."
This bulletin was issued subsequent to GE's identification on November 1, 1987, of a potential defect on certain latch-type relays intended for Class 1E equipment applications.
The bulletin questioned the operability of all HFA-151b, -154B, and-154E relays with a manufacturing date code prior to November 1987.and specified mandatory relay inspections.
The subject bulletin also directed inspections of additional latch-type HFA relays which were not purchased as qualified to IEEE-323 by GE, but which were potentially qualified and used by other equipment manufacturers in Class 1E (safety-related) applications.
As documented in letter TXX-88545, dated July 11, 1988, the applicant provided a response to this bulletin stating, in part, that at Comanche Peak Steam Electric Station, HFA relays were not used in Class 1E applications.
The NRC inspector reviewed the above response letter as well as the applicant's program for controlling the application of safety-related relays as described in Procedure EI-2400 titled, " Protective Device Settings and System Index."
Based on these reviews as well as discussions with applicant personnel, the NRC inspector determined that the applicant's response to this bulletin was acceptable.
This item is closed.
6.
Corrective Action Program (CAP)
a.
Electrical Components (51053)
The NRC inspector reviewed FVM-EE-087, " Test Department Verifications" and observed its implementation in the field.
Also, reviewed were FVM-87 references XCP-EE-8,
" Control Circuit Functional Testing"; XCP-EE-20,
" Continuity and Termination Verifications"; PP-040,
" Procedure for Review of Wiring Diagrams"; and CEL-108,
"1E and Non-1E Cable Terminations."
FVM-87 requires verification of various termination attributes per Electrical Specification ES-100, Appendix K,
" Quality Assurance Requirements."
This verification is primarily accomplished by the use of Procedures XCP-EE-20 and XCP-EE-8.
The NRC inspector observed that during the performance of XCP-EE-8 and 20 testing, FVM-87 was not normally present in the field nor are test
engineers / support personnel required to be knowledgeable of the FVM by Procedure TRA-311, " Test Department Qualification."
The NRC inspector determined that the process of meeting the FVM-87 acceptance criteria was
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that the test department would notify engineering in writing that the scope of the FVM had been accomplished including a list of all components / attributes covered by the FVM.
However, the NRC inspector determined that the attribute of bent and twisted lugs is not specifically covered by the XCP procedures.
Further inquiry indicated that the XCPs are performed by test department electricians, who are qualified to ES-100,Section III.2.8 through 11, " Terminations," but not Appendix K, Section 5.4a which is referenced by the FVM.
Though Section III.2.8.16 contains the same attribute requirements as Appendix K, Section 5.4a, the lack of specific documentation of inspection for the attribute required by the FVM acceptance criteria is considered a disconnect in the program and in the engineering-test department interface.
This is an unresolved item (445/8904-U-01).
b.
Electrical Cable (51063)
(1)
The NRC inspector reviewed package DCA 46620 involving cables EG100391 A and B pulls.
The package appeared complete and correct.
The NRC inspector then inspected the pathway of the pull and observed part of the prepull preparations and the initial portion of the pull from room 100 to room 103.
During the raceway inspection, the NRC inspector noted a minor indentation in cable EG100391A where it was bent around a fire system hanger (threaded rod) near tray T13GSCN91.
During work observations, an electrician was questioned by the NRC inspector regarding the requirements for cable protection during pulls.
The electrician stated that he did not know anything about the pulling requirements and was only assigned to help handle the cable.
A foreman involved with the pull was also questioned and expressed uncertainty as to the requirements.
The NRC inspector pointed out the indentation to a QC inspector, who was present for the pull, the indention and the impinging hanger which was accordingly restrained from touching the cable.
During the pull, the NRC inspector noted other unprotected edges, such as tray supports which were occasionally bumped by the cable.
The above appears to be a weakness in the overall program, though the cable was generally handled in a careful manner.
The NRC inspector also observed an i
electrician smoking in the cable trays during l
preparation and found various flammable debris (rags, zinc coating spray cans, etc.) in the trays a day after the cable pull.
Also noted was a severe twist in one of the 500MCM cables.
The NRC
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inspector later determined that NCR 89-1108 had been issued to address the cable twist problem.
Also, NCR 89-01119 was issued-~for cable EG-100391B overtensioning.
Tray platforms installed for the work were noted to be of fire-retardant lumber.
The NRC inspector questioned the applicant regarding a
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tray platform permit form which had been expired for l
several days and was told that the expiration dates
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were only estimated work completion. dates, not required platform removal dates, and that there were no specific requirements for when the platform must be removed after work completion.
The NRC inspector determined that this was in agreement with Procedure ECC 2.32, Revision 4,
" Plant Housekeeping, Access Control and Equipment Protection."
This, along with the'above noted debris and smoking in cable trays, appears to be a weakness in the housekeeping / fire protection area.
(2)
The NRC inspector observed a portion of the cable pulling and reviewed the package for DCA 81011, which revised the auxiliary feedw6ter (AFW) turbine trip circuitry.
The electricians involved discussed making the short pull through conduit C13034529 with a fish tape, but the QC inspector pointed out that this would be contrary to-Electrical Specification ES-100 for pullbys (other cables already in the conduit).
This occurrence, along with that mentioned in the preceding paragraph, indicates a weakness in the training of electricians involved in cable pulls.
These perceived weaknesses will be monitored by the NRC inspector and the results will be documented in future inspections.
(3)
The NRC inspector observed preparations for the pull, inspected the pull path, reviewed package DCA 76754, and observed a portion of the pull of 500MCM cable E0100167 from the starter j
breaker cabinet for safety chiller Nos. 1-05 to
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480 V, Bus 1EBl.
No deficiencies were noted and a subsequent inspection by the NRC inspector revealed that both cable ends had been terminated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the cable pull.
j No violations or deviations were observed.
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7.
Instrument Components and Systems (52053)
The NRC inspector observed selected surveillance and calibration activities of safety-related systems and components to ascertain that these activities were conducted in accordance with NRC requirements, commitments, and approved
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procedures.
The inspector observed portions of the conduct of Procedure INC-7378A, Revision 4,
" Analog Channel Operational Test and Channel Calibration - Neutron Flux Power Range, Channel 44."
In particular, the NRC inspector determined that the latest revision of the applicable procedures were available at the work site, that the measuring and test equipment used was properly calibrated, and that the personnel performing the test were qualified.
Upon completion of testing, the NRC inspector determined that the affected nuclear instrumentation was properly returned to service and that the completed test procedure was complete and accurate.
No violations or deviations were identified.
l 8.
Allegation Follow-up (99014)
(Open) Allegation (OSP-88-A-0053):
a.
As previously documented in NRC Inspection Report 50-445/88-83, 50-446/88-79, this allegation involved worker concerns relative to specific installation practices utilized on Conax electrical penetrations in Unit 2 which contain Kapton insulated wiring in various conductor sizes.
Specifically, the issues were that installation practices violated the specified minimum bend radius requirements during the arrangement of conductors in the cable trays and that inappropriate care was exercised in the installation process to protect the conductors from damage.
Also, concern was expressed relative to the applicant's practice of bundling the conductors together and tie wrapping them to the lateral supports in the bottom of the cable trays in that plant induced vibration could then result in chaffing of the Kapton insulation.
This chaffing could result in a direct short, thus affecting both control and instrumentation functions.
Although these concerns were identified in Unit 2, they
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have generic implications for Unit 1 penetrations which also utilize Conax penetrations with Kapton insulated I
conductors.
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In order to assess the installed penetration configurations, the NRC inspectors conducted extensive field walkdowns of both Unit 1 and 2 containment penetration assemblies and the associated cable trays.
During these inspections, several questionable conditions in Unit 1 were identified to the applicant involving installed configurations which appeared to be the result of post-installation construction activities in and around the cable trays.
These conditions included (1) possible minimum bend radius violations associated
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with deformed Kapton wiring in the area of the penetration pigtail / cable splices, (2) chaffing of the exposed Kapton insulated conductors in cable trays, and (3) the presence of foreign material in the cable trays.
In response to the first two items identified by the NRC inspectors, the applicant issued nonconformance reports to address these conditions.
Relative to the third issue, the inspector determined that the affected cable trays will be cleaned in accordance with Specification ES-100 prior to the installation of cable tray covers.
Additionally, the NRC inspectors reviewed the installed applications of Kapton at Comanche Peak for both units with emphasis on areas of concern identified in NRC Information Notice 88-89, " Degradation of Kapton Electrical Insulation."
These reviews included several meetings with the applicant including one conducted on January 26, 1989, which was attended by Mr.
C.
I. Grimes, Director of the Comanche Peak Projects Division and other NRC staff members and Mr. P. B. Stevens, Manager of Electrical Engineering, TU Electric, along with members of his staff.
This meeting provided a synopsis of the design issues relative to the generic concerns over the use of Kapton insulated conductors as well as specific installation configuration conditions at Comanche Peak.
The material covered in this meeting is included as Attachment 1 to this inspection report.
In summary, independent inspections conducted by the NRC inspectors indicate that the applicant has adequately addressed the potential design concerns relative to the design adequacy of installed Kapton insulated Class lE equipment and the conclusions stated in Attachment 1 are generally supported by the NRC inspectors findings.
As stated in Attachment 1, the applicant has identified all applications of Kapton insulation at CPSES and plans no further action in regard to any redesign or replacement of Kapton.
However, the allegation relative to the installation deficiencies will remain open pending completion of detailed inspections to be performed by TU Electric in accordance with Specification ES-100 prior to the installation of cable tray covers in the penetration areas.
The NRC inspector will monitor this effort.
b.
A second facet of this allegation involved contractor management direction to an electrical craft foreman to perform work on components which were administratively controlled by QC hold tags.
This item was also identified to the applicant's SAFETEAM by the alleger.
The applicable SAFETEAM concern reports were reviewed by the NRC inspectors to determine if the responses were in accordance with the applicant's program and that they
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appropriately addressed the issues.
The NRC inspectors determined that the alleger's concerns had been addressed by SAFETEAM in that investigations were performed and documented and the results were provided to the SAFETEAM review committee.
The NRC inspector's examination of these items indicate that the alleger's concerns were partially substantiated in that an electrical foreman was instructed to perform work beyond a QC hold point on a traveler associated with a containment penetration without the proper supporting documentation.
The SAFETEAM determination that the contractor management had the authority to direct the performance of work around a QC hold point is partially supported in that Procedure ECC 3.05, Revision 6, " Reporting and Control of Nonconformances," does allow for work unrelated to the identified condition to continue, at the discretion of i
i the cognizant supervisor, provided the work would not interfere with subsequent correction of the identified conditions.
This proviFion is intended to allow Work to continue prior to dispositioning the NCR; however, it is arguable that this provision would apply to a component that is to be removed and scrapped.. It was not apparent from the inspector's review that the above mentioned procedural allowance was identified by contractor management personnel to the electrical foreman when the order was given to remove the containment penetration and to this extent a notable lack of management skill is evident.
However, as identified in the SAFETEAM review, the contractor electrical superintendent involved was provided training and personal counseling on the matter.
In conclusion, it was determined that although this incident was an example of poor management controls, the safety significance of this particular event is
negligible in that the containment penetration assemblies removed and scrapped were of a questionable design-(Bunker-Ramos) and were subsequently replaced with
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qualified Conax type penetrations.
Based on the above I
mentioned reviews, the portion of this allegation dealing with contractor management directing an electrical I
foreman to perform work beyond a QC hold point is
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considered closed.
9.
Plant Tours (42051C, 51053, 51063)
a.
The NRC inspector observed full-flow testing of loop supply isolation valve 1HV-4526.
Testing was being a
performed for data acquisition in order to correct a failure to close fully or open under load deficiency as i
reported on NCR 89-031.
Test engineers appeared I
knowledgeable of the test equipment being used and the
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stipulated test data was obtained for further engineering analysis.
b.
During the observation of routine maintenance on the Unit 1 Train A switchgear area sprinkler system deluge valve, the NRC inspector noted some leakage from a fixture on the valve and reported it to applicant's personnel who had been involved in the previous maintenance.
The following day, the NRC inspector observed that the leakage was being captured by bucket and cleanup personnel were engaged in mopping up the area.
Subsequently, temporary tubing was installed to
reroute the leakage to a floor drain pending long-term
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corrective action.
c.
Following the closure of Violation 445/8626-V-02 documented in NRC Inspection Report 50-445/88-83, the NRC inspector observed that a pull rope still remained protruding from conduit C14006813.
On request for document numbers for any work involving this conduit, the NRC inspector was informed that no work was pending or in progress.
The applicant was informed of this condition and indicated that they would extend the search for pending work documentation and further investigate the discrepancy.
This is an unresolved item (445/8904-U-02).
10.
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.a and 9.c.
11.
Exit Meeting (30703)
l An exit meeting was conducted February 7, 1989, 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 appiicant did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
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f During this meeting, the NRC inspectors summarized the scope l
and findings of the inspection.
Attachment:
Handout from TU Electric /NRC meeting on Kapton usage at CPSES.
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Attachment 1
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STONE 6 WEBSTER ENGINEERING CORPORATION
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C, W ASHINGTON, D Mr. Owen W. Lowe E07 February 9, 1989 Director of Engineering J.O. No. 18051 TU Electric SWTU-12,403 Post Office Box 1002 No Response Required Glen Rose, Texas 76043 APPLICATION OF KAPTON CABLE COMANCHE PEAK STEAM ELECTRIC STATION - UNIT 1 TU ELECTRIC-Attached please find Stone & Webster Engineering Corporation's Project Technical Report No. 04, Revision 0, on " Application of Kapton Cable Insulation at Comanche Peak".
This is for your information and use.
If you have any questions please do not hesitate to contact Mr. Steve Hilaman at extension 0191.
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[ A.P.
Barry Senior CECO Engineering Manager Attachment i
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Date: February 9. 1989 Rev. 1 i
Project Technical Reports' (PTR)
Index of Most Current Issue Pm N >2 Description Rev. No.
Issue Date CIN No.
Pm-01 Unit 2 Electrical / Controls O draft 12/2/88
Support for Unit 1
PTR-02 Unit 2 in Unit 1 0 final 12/19/88 CEOO-0071 PTR-03 Evaluation of Seismic 0 draft-1/26/89 Category I & II - Concate Embedments PTR-04 Application of Kapton 0 final 2/9/89 SWrU-12,403 Cable Insulation i
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