IR 05000445/1989013
| ML20006E214 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/02/1990 |
| From: | Charemagne Grimes, Williams C Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20006E212 | List: |
| References | |
| 50-445-89-13, 50-446-89-13, IEB-87-002, NUDOCS 9002220312 | |
| Download: ML20006E214 (12) | |
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UNITED STATES
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.8 NUCLEAR REGULATORY COMMISSION a
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U.S. NUCLEAR REGULATORY COMMISSION 0FFICE OF NUCLEAR REACTOR REGULATION
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NRC Inspection Report:
50-445/89-13 Permits: CPPR-126
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50-446/89-13 CPPR-127 Dockets: 50-445 Category: A2 50-446
Construction Permit Expiration Dates:
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Unit 1: August 1, 1991 Unit 2:- August 1, 1992 Applicant:
TV Electric 400 North Olive Street, L.B. 81 Dallas,. Texas 75201 Facility:
. Comanche Peak Steam Electric Station (CFSES)
Units 1 and 2 Inspection At: Comanche Peak Site, Glen Rose, TX
- Inspection Review Period: December 5,1988 thrcugh January 27,,1990 l
..M... dF/C Inspector:
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L Cordell C. Williams, Technical Date
Assistant-to the Director l
Comanche Peak Project Division Office of Nuclear Reactor Regulation l
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Reviewed by:
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h rist pher I.
i s, Director Dde /
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.Co c e Peak Pr et Division d
Offic of Nuclear Reactor Regulation
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9002220312 900202
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[DR ADOCM 05000443
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ggaction.Sumary:
Inspection conducted intermittently:
December 5, 1988 through January 27, 1990 (Report 50-445/89-13;50-446/89-13)
L Areas. Insoai:ted: Announced, special inspections on previously identified ASME Code Inspect on findings, QA/QC program and implementation; Reactor Coolant System Hydrostatic Test issues; ASME Code Section XI, Unit 1 and common system Rerating Program implementation issues; Fastener Material Issues associated with
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NRC Bulletin No. 87-02; Diei;el Starting Air Accumulator Rework; and other construction-related issues.
'Assults: Within the areas inspected, no violations or deviations were identified.
During the course of this inspection, no particularly notable strengths or weak--
nesses in TU Electric's activities were identified. The inspector observed that
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the extraordinarily complex and time-consuming implementation of the Unit 1 and common repair and rarating program was executed skillfully and in complete compliance with the ASME Code, engineering, documentation, QA/QC, and record-maintenance requirements.
t DETAILS 1.
Persons. Contacted W. J. Cahill, Executive Vice President, Nuclear, TV Electric
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G. Bynog, Assistant Chief Inspector, Texas Department of Labor and Standards
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- B. Gard, Attorney, CASE
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- W. G. Guldemond, Manager 40nsite Licensing, TU Electric l
- Roger Ferguson, Engineer, TU tiectric
- T. Heatherly, compliance Engineering, TV Electric
- C B. Hogg, Chief Engineer, TV Electric
- R. T. Jenkins, Manager, Mechanical Engineering, TV Electric j
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- 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 and Standards
- E.'Ottney, Project Manager, CASE
- S. Palmer, Project Manager, TU Electric
- R. Bryan, Inspector, Texas Department of Labor and Standards
- D. A. Ringle, Nuclear Licensing, TU Electric
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- J. F. Streeter, QA Manager, TV Electric l
- B. Walker, Inspection Specialist, Texas Department, Labor and Standards
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- R. Walker, Manager-Nuclear Licensing,_TU Electic
- B. Walker, Senior Inspe'ction Specialist, Texas Department of Labor and i
Standards
- Denotes personnel present at the August 11, 1989 exit meeting, g
- Denotes working meeting conducted at the Texas Department of Licensing and
Regulation, office on October 13, 1989.
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The NRC inspector and the TDLS Chief Inspector also interviewed other applicent empicyees during this inspection period. Subsequently, it was-determined that this reporting pertod would end with the completion by TU Electric of the ASME'Section XI Unit I and Common program and the final
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report of the Bolting Material Investigation which was reviewed by NRC on January 26, 1990.
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2.
Action on. Previous.laspection.Findines.(92701)
A.
-(Closed) CPRRG items number 1D-23 (adequate QC procedures for QA/QC inspectors to witness transfer of material identification during construction activities), and ID-63 (verify adequate material identi-fication and traceability program for earlier work) were examined and verified to have been' acceptable during the inspection period documented in NRC. Inspection Report No. 50-445/88-61 and 50-446/88-57.
However,
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they were inadvertently omitted from the report. The examination and closeout of these issues by NRC and the Texas Department of Labor and Standards (TDLS) is documented by NRC memorandum dated February 10, 1989 and TDLS Letter Matthews/Cahill, dated February 27, 1989 which are attached hereto as Exhibits Numbers 1 and 2, respectively.
B.
(Closed) Violation (8432-V-02): This violation involved the " regular
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review of the status of the QA program."
It was subsequently addressed
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in NRC Inspection Report 50-445/86-03; 50-446/86-02.
NRC has reviewed TU Electric Response Letter TXX-6144 and the related examinations by
'CPRT (ISAP VII.a.5 and ISAP VII.a.4).
Based on this NRC examination activity, this matter is considered acceptably resolved.
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(Closed)
violacion(6432-V-03): This issue involved " Failure to
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Establish'and Implement a Comprehensive System of Planned.and Periodic Audits;" the Inspector has reviewed the substance of this issue as documented in the subject report and NRC Inspection Report 50-445/86-03; 50-446/86-02; and TU Response Letter TXX-6144 dated February 2,1987.
This issue was also evaluated in substance in CPRT ISAP VII.a.4.
As a result of this inspector's evaluation, this matter is considered
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closed.
D.
(Closed) Open Item (445/8903-0-02; 446/8903-0-01:. The remaining issue
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of this matter involves TU Electric Corrective Action Report (CAR) No.
L 88-035(fastenermaterials). The details of.TU Electric's activities
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to comprehensively address this issue and provide further assurance that safety-related fasteners are capabl.a of performing their safety-related -
functicn, are outlined in.the engineering report referenced by TU Elec-tric Letter TXX-90049, File No. 903.9, dated January 26, 1990.
NRC staff has examined this TV Electric.Engiteering report and concluded that TU Electric hss adequately demonstrated that the subject fasteners are acceptable.
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As documented in the NRC inspection' reports referenced above in TU Electric corrective action report (CAR) Number 88-35 in response to NRC Bulletin 87-02, a significant number of safety-related and non-safety related fasteners of questionable qu hty and quality documentation were purchased from I.frcom fasteners, Inc. (AIRCOM), a
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fastener distribution company.
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TU Electric tested 96 of the fasten 6rs from AIRCOM which had.not been
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installed in the plant for conformance to specification requirements. _
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As is documented in the TU Electric and NRC documents referenced above,
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minor deviations from specification requirements for chemical and.
physical properties were noted and evaluated. TU Electric determined, as reported in the engineering report referenced above, that, based on the testing and engineering evaluation preformed, there is " reasonable assurance that AIRCOM fasteners which were installed or intended for
installation in a safety-related application wm perform their design j
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functions".
TV Electric. subsequently selected a " representative" sample of 200 fasteners, which were installed in electrical raceway support systems.
TV Electric re>orted that the selection of these additional bolts was biased to'a su) set in which the existence of bolts purchased from Aircom fasteners Inc. was likely to occur. The selection was limited to safety related raceway and control (IAC). support commodities.
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Based on a review by TU Electric of the intended use specified on Aircom Purchase Orders, these were areas where a majority of the-fasteners were installed during the time period of 1979 through.1983.
These 200 fasteners were removed and subjected to physical and chemical testing, as were the Ntial 96 fastenen noted abnve, to,
determine if they met the purchase order and specificction requirements.
As a result of chemical and physical testing of this sampic 9f 200 installed fasteners, it has.been demonstrated that these
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previously(with very minor exceptions) met the requirements of the fasteners specification and are adequate for the intended service. That:is, TU Electric determined that the materials, as tested, have been found j
acceptable for use in their intended function. Deviations from specification as found and' documented in the reference engineering report, are well within the bounds of previous test results and have no-safety significance and do not impact the bolts'-design functional requirements.
Among other activities, as documented by tha NRC inspection reports
identified above, NRC representatives witnessed the testing of a portion of these additional 200 fasteners at Southwestern Laboratories i
on October 30 and November 1,1989 and observed that all testing was
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in accordance with standard industry practices and procedures.
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It is noted that during the installation of Cable Tray and support fasteners, the " turn-of-the-nut" method of fastener tensioning was i
specified and used. This bolt tensioning methodology is such that
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if there were significantly nonconforming fastener materials used
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-during these installations, the fasteners would have most probably_
i failed during tensioning, resulting in their being discarded.
The TU Electric examination of this matter determined that in one
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very narrow nonsafety-related area, carbon steel fasteners were used where stainless steel fasteners were specified. This appears to have been an error. Additionally, in several very limited applications,
'AIRCOM fasteners were used in installations governed by the ASME Code. For each of these cases, the corrective action taken by TU
Electric required the removal of the AIRCOM fasteners and replacement
with fasteners fabricated in accordance with the specified design requirements.
Based on the NRC inspector's review of the foregoing.
TU Electric has adequately demonstrated that there are no identified construction deficiencies resulting from the issues invalving fasteners supplied by AIRCOM. This matter is closed.
E.
(Closed)
Issue concerning ASME Section XI'VT-2 Rydrostatic Test
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and Examinations of Unit 1 Reactor Coolant System:' On December 5, 1989 t
the staff conducted a meeting onsite to establish the connitment and criteria for the subject ASME Section XI VT-2-Hydrostatic Test.
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The-connitment and criteria to perform these tests were established
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by TU Electric Letter Log No. TXX-89007 dated January 11,_1989 and l-L TXX-87150 dated April 10, 1989. This issue is also discussed in
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TU Electric SDAR-88-03. The hydrostatic test was acceptably completed on May 24, 1989.
NRC findings are documented in'the NRC response to the dispute between CASE and TV Electric'regarding this issue dated August 18, 1989 and NRC Inspection Report No. 50-445/89-22; 50-44G/09-22. All areas met the requirements of the ASME Code.
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ASME.Section III.and-Section.XI. Certification. Activities.for Unit.1.and-commun.sy stems On March 21, 1989 TV Electric established an ASME Code task force agenda
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to address the ASME Section III'and Section XI. certification of Unit 1 and Licensing and-Regulation (TDLR)presentative of the Texas Department of common systems. NRC and the re
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discussed the scope of TU Electrics' -
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considerations with'the TU Electric ASME Task Manager, Mr. M. Skaggs.
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issues of concern were identified.
It was noted that comprehensive plans for development of procedures and an adequate organization for their~
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implementation were well under development. The NRC inspector and the-TDLR
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inspectors reviewed and examined the scope and content of the TU Electric
" Project NIS-2" presentation of April'27, 1989 and the various documented
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procedures related to this effort.
-c As a result of these-activities and discussions with TU personnel, NRC and
- TDLR Inspectorc c.oncluded that all ' associated engineering, construction, quality assurance and documentation requirements of 10 CFR Part 50.55.a.
Texas Boiler Law, the CPSES FSAR and the CPSES QA Plan were being appropri-
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ately addressed in this process.
These issues were intermittently examined
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by NRC, TDLR and the authorized Nuclear Inspector throughout their develop-
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ment and' implementation. No process deficiencies requiring NRC action were noted.
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A.
-NRC and the TDLR inspectors reviewed and examined the following
- w.edures and documents
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(1)
Nuclear Engineering Operations Procedure 2.26'"CPSES ASME-Section XI Progras."
(2)
"ASME Section XI Repair and Replacement Activities," Procedure ECE 2.26-04, Rev. 1.
(3)
"ASME Section XI Repair and Replacement of Component Supports for Unit 1 and Cossnon,"-Procedure ECE 2.26-06, Rev.1.
(4)
Project Procedure No. PP-074. Rev. 1. " Engineering and Design Requirements for ASME Repairs and Replacerents."
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-(5)
ASME NIS-2/N5 (form) Completion Punch Lis'c.
(Exhibit 3, attached).
(6)
Pipe Support Stress Reconciliation NIS-2 documents dated August 3, 1989.
(7)
"ASME Section XI Rerating Activities," Procedure No. ECE t
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.2.26-07, Rev. O.
(Comments by.TDLR and NRC, letter Matthews/Cahill dated February 6 1989).
(8)-
" Procurement of N/NV Stamped Components from Sources Other Than Prime Vendors," Procedure ECE.6,02-01 Rev. 1.-
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NRC and TDLR found these documents to be appropriately comprehensive.
Where comments were identified by the inspectors, the. applicant
resolved each issue satisfactorily.
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B.-
During the period of TU Electric's implementation of these ASME code-related activities, NRC and TDLR regularly reviewed their-progress and its adequacy. No substantive discrepancies were noted during any cf the detailed reviews'and examinations.
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AmongotherTVElectricactivities,-theNRCInspectorexaminedi
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(1)
NIS-2 status by stress problem completion, intermittently -
throughout the course of this work. No problems were noted.
(2)
..Information for Pipe Stress Analysis (IPSA) for the domineralized and reactor water make-up system and the associated Ccnnectivity Diagrams System Nd. 1000,
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As a result of this effort by TU Electric, the NRC inspector noted that more th?n 800 Stress Problems were addressed during the implemen-tation of the ASME Section XI-NIS-2 and related programs. As of August.11, 1989, approximately 75% of this work was t.omplete and a significant percentage by the " packages" were vaulted (placed in
' storage). During discussion with the State of Texas (TDLR) Inspectors, they reported that their independent examination of TU Electric's ASME
Section XI activit;y indicated conformance to the requirements of the ASME Code throughout the implementation of this program.
D.
As indicated above no outstanding issues were identified by NRC during these examinations and this matter is considered complete.
4.
ASME Code. Case.Acceptabt.lity TU Electric Letter Log No. TXX-89802 File No. 10010, dated December 15, 1989 addresses issues conc.erning ASME Code Case acceptability disclosed by
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the implementation of the CPSES Code Control Program. ~ The issues involve
the timing of the inclusion of the subject cases in the'ASME Code.
NRC-staff has reviewed this-letter and agrees with the conclusion that invoking the subject Code Cases is acceptable for Units 1 afid 2.
The Director and Chief Inspector, Texas Department of Labor and Standards has indicated
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that TDLR concurs in TU Electric's reasoning in this regard. NRC has no further questioning regarding this matter and considers the issue closed.
0.
Diesel. Generator Air Start. Receivers On March 23,.1989 the staff and TV Electric conducted a. meeting to discuss the resolution of weld quality issues involving the Diesel Generator Air Start Receivers. This issue was initiated by Construction Deficiency Report (CDR) 87-6845, which documented missing radiographs ~for welds J-1 and J-2 on Diesel Generator Starting Air Receiver CPI-MEATR-01.
Sub-
.i'J sequently, the subject longitudinal weld joints J1 and J2 were radio-graphed. Coincidennily, the circumferential welds intersecting joints J1
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and J2 were noted to contain linear indications of defects. These-circum-ferential welds were not required to be radiographed by the ASME Code during fabrication.
Subsequent to the discussions on February 14, 1989, TU Electric consiitted to radiograph the circumferential welds on all of Diesel Air Start Receivers to verify weld quality and to repair (Rework)-
all girth welds judged to require repair.
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. Subsequently, the NRC inspector monitored the rework of each of the Diesel Air Start Receivers.
Initially, there were problems noted in the repair
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welding which were properly addressed by quality and engineering procedures
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. and' personnel. The NRC Inspector reviewed the final' radiographs of the-welds; qbality documentation associated with those repairs and observed the_ final weldments during the August 9 and 10, 1989 portion of this i
inspection.
No nonconformances or open items were identified. TV Electric-j o
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. evaluated this' matter for reportability (SN-443, references:
NCRs 88-12640 and 88-12708) and concluded that it was not reportable. The NRC staff has reviewed the applicants evaluation and concludes that this matter is resolved.
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6.
Exit Meetino.. (30703):
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During this inspection several interim " working briefings" were conducted '
.withTUElectric'sstaffandmanagement. The formal-exit was conducted 1989 with the subsequent understanding that issuance of this
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August 11,ld be postponed pending the substantial completion of the report wou Section.XI N15-2 documentation reconciliation program and completion of TU Electric's Fastener Material assessment canmitments. The final TU Electric report involving installed bolting material was received by NRC staff January 26, 1990. TU Electric has not identified as proprietary any of
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the materials:provided to or reviewed by NRC inspectors during this inspection.- During these meetings, the NRC inspector sunnarized the scope and findings of the inspection.
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Report 89-13
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Exhibit-1
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Buttet Nos. 50-445/446 l
l MEMORANDUM FOR:
Phillip F. McKee. Deputy Director Comanche Peak Project Division v
Office of Nuclear Reactor Regulation
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L FROM:
Cordell'C. Williams. Technical Assistant Comanche Peak Project Division office of Nuclear Reactor Regulation
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SUBJECT:
STATUS OF Cl.0$E-0UT OF CPRRG RECOM8ENDAT!0NS i
The following CPRRG Recommendations have been examined at the site and closed:
Construction OA !ssues
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A.
10 Number 23 - Adequate QC procedures for QA/QC inspectors to witness j
transfer of material identification duririg construction c
activities.
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10 Number 63 - Verify adequate material identification and traceability j
- program for earlier work.
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Spool Pice Components l
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10 Number 51 - CVCS spool pieces properly identified during construction and currently, t
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10 Number 62 - Inspect other field fabricated spool pieces.
Items A through D above have all been examined and raschad.
Itc=: C cnd D.
l (ID 51 and 62) were specifically closed in Inspection Report No. 50-445/88-61
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and 50-446/88-57.
Items A and B (ID 23 and 63) are closed and will be
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specifically addressed during the next hRC report addressing ASME program l
issues.
Or'fnal Signed by:
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Cordell C. Williams, Technical Assistant Comanche Peak Project Division
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Office of Nuclear Reactor Regulation cc:
C. Grimes j
R. Warnick
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Exhibit-2
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' Texas Lkpartment ofLabor andStandants
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E.O. Thompeen swa ORice Builung
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P.0/ 8es 12157. Ammin, Temas 78711
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Richard L Morgan William P. Clemenu, Jr.
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Gowenor Commissioner
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l February 27, 1989 I 6 589
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W. Executive Vice President
TU Electric
400 North Olive Street, LB-81 o
Dallas, Texas 75201 Ret Comanche Peak Steam Electric Station-(CPSES)
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subject:
CPRG (NUREG-1257) Issue il and #4
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Dear Mr. Cahill:
l This office has reviewed and evaluated the subject items that are further referenced as recommendation ID 21, 23, 51, 62, & 63.
All
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of these items have been evaluated and are considered closed.
Please note that in NRC/TDLS Joint Inspection Report-50-445/88-61, 50-446/88-57-at paragraph 2.e.,
items identified as 51 and 62 were
- l-reported as closed.
l If any' questions arise pursuant to this item, please advise.
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Sincerely, Steven M..Matthews
. Program Manager & Chief Inspector Boiler Section (512) 463-2904 SMNic1g
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Chris-Grimes, NRC/OSP cc:. R.F.Warnick,NRC/Sitej l
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