IR 05000445/1989015
| ML20244B925 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/12/1989 |
| From: | Latta R, Livermore H Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20244B923 | List: |
| References | |
| 50-445-89-15, 50-446-89-15, NUDOCS 8904190487 | |
| Download: ML20244B925 (12) | |
Text
{{#Wiki_filter:_ - _ _.. _ _ _ _ _ _ - _ _ _ . i A Y'* . U. S. NUCLEAR REGULATORY COMMISSION O OFFICE OF NUCLEAR ~ REACTOR REGULATION NRC Inspection Report: 50-445/89-15 Permits: CPPR-126 50-446/89-15 CPPR-127 Dockets: 50-445 Category: A2 , 50-446 ! I
Construction Permit Expiration Dates: Unit 1: August 1, 1991 Unit 2: August 1, 1992 Applicant: TU Electric Skyway Tower 400 North 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: March 8 through April 4, 1989 [c /.? #Ae F'7 Inspector: R. M. Latta, Resident Inspector Date (Electrical) Consultant: J. L. Taylor - Parameter Reviewed by:
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Livermore, Lead Senior Inspector Date { I l l ! l 890419048 {{@$hf45 PDR ADOC PDC Q - - _ _ _ -
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. Inspection Summary: I Inspection Conducted: March 8 through April 4, 1989 (Report 50-445/89-15; 50-446/89-15) Areas Inspected: Unannounced, resident safety inspection of applicant's actions on previous inspection findings, follow-up on violations / deviations, follow-up on action on 10 CFR Part 50.55(e) deficiencies identified by the applicant, Corrective Action Program (CAP), general plant areas (tours), electrical equipment and cables, and instrumentation.
Results: Within the areas inspected, no significant strengths or weaknesses were identified.
During the inspection period, no significant safety matter, violation, deviation, or ur. resolved item was identified.
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. < ~ l i DETAILS 1.
Persons Contacted
- R. W..Ackley, Jr., Director, CECO
- J.
L. Barker, Manager, Engineering Assurance, TU Electric
- D.
P. Barry, Senior Manager, Engineering, Stone & Webster l Engineering Corporation (SWEC)
- J..W.
Beck,.Vice President, Nuclear Engineering, TU Electric
- M. R. Blevins, Manager, Technical Support, TU Electric
- H.
D. Bruner, Senior Vice President, TU Electric '*W.
J.
Cahill, Executive Vice President, Nuclear, TU Electric
- J.
T.
Conly, APE-Licensing, SWEC.
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- C.
G.-Creamer,1 Instrumentation &' Control (I&C) Engineering Manager, TU Electric
- G.
G.' Davis, Nuclear Operations Inspection. Report. Item , Coordinator, TU Electric .*J.
C.~Finneran, Jr.,' Manager, Civil Engineering, 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.
- J.
C.~ Hicks, Licensing Compliance Manager, TU Electric
- C.
B.'Hogg, Engineering Manager, TU Electric
- A. Husain, Director, Reactor Engineering, TU Electric
~*S. D. Karpyak, Nuclear Engineering, TU Electric
- J.'J.
Kelley, Manager, Plant Operations, TU Electric
- 0.lW.-Lowe, Director of Engineering, TU Electric M. L. Lucas,' Electrical Production Supervisor, TU Electric ~
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- D. M. McAfee,-Manager, Quality Assurance (QA), TU Electric i
- S.
G. McBee, NRC Interface, TU Electric
- J.
W.
Muffett, Manager'of Engineering, TU Electric
- E.
F.-Ottney, Program Manager, CASE ,
- J.
D.'Redding, Executive Assistant, TU Electric !
- D. M. Reynerson, Director of Construction, TU Electric
- M.
J. Riggs, Plant Evaluation Manager, Operations, TU Electric .
- A.
H.
Saunders, EA Evaluations Manager, TU Electric
- A.
B.
Scott, Vice President, Nuclear Operations, TU Electric
- C.
E.
Scott, Manager, Startup, TU Electric
- J.
C.
Smith, Plant Operations Staff,-TU Electric
- M.
R. Steelmai., Licensing, TU Electric
- P.
B. Stevens, Manager, Electrical Engineering, TU Electric
- J.
F.
Streeter, Director, QA, TU Electric
- C.
L. Terry, Unit 1 Project Manager, TU Electric '
- T.
G.
Tyler, Director of Projects, TU Electric
- R.
D. Walker, Manager of Nuclear Licensing, TU Electric
- R.
G. Withrow, EA Systems Manager, TU Electric
- D.
R. Woodlan, Docket Licensing Manager, TU Electric
- J.
E. Wren, Assistant Director QA for Administration, i TU Electric i - - _ _. - _. _ _ _ - _ _ _
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..- . The NRC inspectors also interviewed other applicant employees during this inspection period.
- Denotes personnel present at the April 4, 1989, exit meeting.
2.
Applicant Action on previous Inspection Findings (92701) a.
(Closed) Unresolved Item (445/8904-U-02; 446/8904-U-02): -" pull Rope in. Conduit Cl4006813."
This issue involved a cable pulling aid left in a conduit.
The NRC inspector had initially informed the applicant of the existence of this pull rope in October 1988.
At this time, the applicant reported to the NRC inspector that the pull rope was left in the conduit due to work in progress ! which was documented in the closure of a previous pulling aid violation 445/8626-V-02 in NRC Inspection Report 50-445/88-83; 50-446/88-79.
As reported in NRC Inspection Report 50-445/89-04; 50-446/89-04, the NRC inspector again questioned the applicant regarding this-discrepancy and w&s advised that further investigation , was underway.
Subsequently, the NRC inspector accompanied by representatives of the applicant's staff traced the pull rope to its end, which was found to be protruding from a conduit.
This end of the pull rope was easily visible from floor level and should have been noted in previous applicant walkdowns.
Additionally, the pull rope was twisted polyethylene rather than the braided nylon type required for cable pulls through conduits with other cables installed.
During this report period, the NRC inspector noted that the pull rope was still in place and questioned the applicant as to its presence.
The following day at the request of the applicant, the NRC inspector accompanied a construction engineer and identified the pull rope.
The construction ' engineer removed the two pull rope sections with minimal effort.
In that the pull rope has been removed and no other discrepancies have been found, this item is considered closed.
However, the applicant's response to this NRC identified item appeared initially inappropriate and was delayed.
The NRC inspector will continue to monitor the applicant's responsiveness to similar issues in subsequent inspection reports.
I l b.
(Closed) Unresolved Item (445/8838-U-01): " Adequacy of NCR Dispositioning."
As noted in NRC Inspection Report 50-445/88-42; 50-446/88-38, the NRC inspector , opened this item to review information regarding the l acceptability of the "use-as-is" disposition of nonconformance report (NCR) 88-02292, Revision 0, and to , evaluate Corrective Action Request (CAR) 88-01.
i NCR 88-02292 involved the use of adhesive wire _ _ - _ _ _ _ _ _
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. i . < . l . identification markers on internal wiring of Limitorque motor operated valve (MOV) assemblies which were not specified'by Electrical Specification ES-100.
The applicant submitted a letter from Limitorque Corporation which stated that the wire markers had been present =during qualification testing of the MOVs and would not impact on MOV' functionality.
Therefore, the NRC inspector considers the subject NCR disposition acceptable.
CAR 88-01 corrective actions were completed on February 13, 1989.
These actions included program procedural revisions and personnel indoctrination.
The NRC inspector determined that the CAR 88-01 actions, as they relate to this unresolved item, appeared adequate; therefore, this item is closed.
c.
(Closed) Open Item (445/8804-0-01): Class 1-E cables installed outside of cable tray.
This condition, which was identified by the NRC inspector during the conduct of plant tours, involved two. safety-related cables which had been incorrectly installed behind the rungs of a ladder type cable tray (T 130ACP55).
This cable tray section was mounted vertically on an internal wall of the safeguards building and the cables were positioned between the wall and the cable tray.
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As documented on NCR 88-01446, the two cables originally identified along with one additional cable, which was also installed outside of the cable tray rungs near the top of the vertical raceway, were reworked in accordance with Electrical Specification ES-100, Appendix E.
The NRC inspector reviewed the completed NCR and conducted a walkdown of the affected cable tray and determined that the subject cables had been reworked and that they were , installed inside the confines of the raceway.
Additionally, the NRC inspector conducted walkdowns of other safety-related cable trays for Unit 1 and common.
These inspections indicate that this deficiency was an isolated case and that the applicant's corrective action was adequate; therefore, this item is closed.
3.
Follow-up on Violations / Deviations (92702) a.
(Closed) Violation (445/8518-V-15): Fire effects on instrument tubing.
Specifically, this violation involved inadequate interface control and coordination between participating design organizations in that a required design change authorization (DCA) affecting Specification 2323-MS-G25 was not properly implemented.
The applicant's actions to prevent recurrence included: revision of the DCA which precipitated the violatior., a l review of installation specifications and related DCAs for additional similar problems, and a change in the l l
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design control administration process to control by Engineering and Construction Engineering (ECE) series procedures.
Additionally, the applicant initiated action { on the separation of stainless steel tubing as related to- ] zinc embrittlement in SDARs 86-16 and 86-19.
The NRC i '
- inspector reviewed the applicable. Design Basis Documents
, (DBDs) EE035 and ME020, Revision 2, and procedures providing guidance for determining the necessity of interdisciplinary reviews (ECES.01-03 and 5.09-01, Revision-2).
ECE-5.01-03,." Design Verification and .Interdiscipline Review," required preparation of a change verification checklist (CVC).
Interdisciplinary review (IDR) organizations are.specified on the CVC'at the
discretion of the responsible supervising engineer, who i ' may also specify performance of the IDR after final design document approval.
Based on these reviews, the applicant's corrective actions appear adequate; therefore, this violation is closed.
b.
(Closed) Violation (445/8607-V-22): Drawings not l appropriately checked / reviewed for accuracy.
This violation concerned the failure to adequately perform required administrative reviews of electrical connection diagrams in that several drafting errors involving incorrect termination identification and/or conductor color coding inconsistencies were identified.
As stated in the applicant's revised response to this violation contained in letter TXX-6426, dated May 1, 1987, the subject discrepancies were the result of i ' unrelated personnel errors by drafting design and engineering personnel.
The NRC inspector reviewed the revised response to the violation as well as the completed corrective actions which included drawing revisions to affected connection diagrams, DCAs,
TU Electric design deficiency reports, and revised administrative procedures.
The NRC inspector determined that the stated corrective actions had been completed including the incorporation of DCAs into the subject i drawings and that subsequent design engineering ' organizational changes have effectively addressed the discrepancies attributed to personnel errors.
'i Additionally, the implementation of enhanced design control procedures contained in Project Procedures ' PP-032, " Preparations Review, and Approval of Project Drawings," and ECE 5.05, " Design Drawings," have effectively corrected the identified design control deficiencies.
This determination was based on a review of recent NCRs involving incomplete reviews which indicated that there have been no similar occurrences in the past year.
Based on the above inspection reviews and evaluations, this violation is close __ . . '
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(Closed) Violation.(445/8859-V-01): FVM-89 walkdown-discrepancies.
This' violation involved the-failure of engineering personnel to properly identify and document actual conduit conditions while performing field verification method inspections.
As previously noted in NRC Inspection' Report 50-445/88-83; 50-446/88-79, the NRC inspector had requested further information regarding the applicant's addressing of the root caus2 of the violation.
A supplemental response we.s issued by the applicant on February' 15, 1989, by letter TXX-89055. The applicant also~ issued additional guidance to site management and supervisory personnel on February 28, 1989, by letter TSL-89-67.
This letter emphasized the need to closely ronitor the performance of individuals conducting. work assignments outside of their normal disciplines.
The above~ mentioned corrective actions appear adequate to preclude future reoccurrence; therefore, this item is closed.
4.
Action on 10 CFR Part 50.55(e) Deficiencies Identified by the-Applicant (92700) a.
(Closed) Construction Deficiency (SDAR CP-86-10): " Electrical Penetration Assemblies."
On February 14, 1986, the applicant.verba?ly informed the NRC of a potentially reportable deficiency involving the electrical penetration assemblies (EPAs) supplied by Bunker Ramo.
The applicant informed the NRC by letter TXX-4774 on April 24, 1986, that the deficiency was deemed reportable.
Subsequently, the applicant notified the NRC that all EPA modules supplied by Bunker Ramo would be replaced with modules supplied by Conax.
As noted in previous reports (indicated below), the NRC inspector had requested additional information and documentation relative to the module change out.
Specifically, the NRC inspector requested work packages, travellers, NCRs, and QC inspection reports documenting that cables and wiring had been properly reterminated to the EPAs, as well as more complete replacement documentation discussed in NRC Inspection Report 50-445/89-04; 50-446/89-04.
Documentation for 15 Unit 1 and 7 Unit 2 EPA replacements (out of a possible 81 EPAs per unit)) were reviewed.
Also, the documentation for additional EPAs were reviewed for closure of related SDAR 86-49 which was documented in NRC Inspection Report 50-445/89-04; 50-446/89-04.
In addition to extensive documentation reviews, the EPAs were also physically inspected over several report periods.
One additional EPA was selected by the NRC inspector to follow the documentation recovery process and independently obtain the EPA replacement documents including wiring drawings, a sampling of cables connected - - _ - _ _ _ _ _ - _ _ _ _ _ _ _.
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. .. to the EPA, printouts of data base information on origin / destination designations'for cables, and to obtain copies of documentation for the selected cables final acceptability.
Complications were encountered in the process, such as the test data sheet being missing from the package for' cable EOO28508.
The test data sheet was eventually located in an in-process work package, SWP-Z-4428, in the Startup department.
The test data sheet was properly completed and the overall documentation of the cable installation process appeared adequate.
Otner complications encountered in the documentation review process involved DCAs against EPAs or connecting cables which were developed following the module replacements which were stored in separate documentation packages.
Though the documentation retrieval process was cumbersome and time consuming, the ! NRC inspector did locate, or was provided with, sufficient information to conclude that the EPAs appeared to be. properly replaced and that the required terminations were correctly reperformed.
Determination of Unit 2 EPAs which have not been completed, due to concentration of effort on Unit 1 work, appear to be adequately documented and programs that are in place should assure proper completion prior to Unit 2 fuel load.
This construction deficiency is therefore closed.
b.
(Closed - Unit 1 only) Construction Deficiency (SDAR CP-87-38): Fire Detection System PC Boards."
Cn July 15, 1987, the NRC was notified cf a potentially reportable deficiency involving possible excessive current damage to the annunciator circuitry of the printed circuit (PC) Doards associated with the fire detection system.
Interim reports were provided by the applicant by letters TXX-6651 dated August 14, 1987, and TXX-6863 dated October 16, 1987, with a final report submitted by letter TXX-7070 dated December 29, 1987, which identified this item as nonreportable.
As stated in the final report. this discrepancy was attributed to an internal failure of the indicating lamp sockets and was limited to sockets identified as "CMLW" which are used on the fire detection system PC boards.
These lights provide local alarm and trouble indication for each fire protection zone.
The NRC inspector reviewed the applicant's analysis of the safety implications as stated in Stone and Webster's letter SWTU-4304 dated October 21, 1987, and concluded that the applicant's determination of nonreportability' was acceptable.
TU Electric's determination was based on the existence of unimpaired protection system capability (i.e., sprinkler and halon systems) and the instituted compulsory fire watch provisions.
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, . ., ' reviewed the~ associated.NCR (CE-87-3293) and determined ) that the damaged PC boards had been changed out and that i the defective sockets had been replaced with Underwriters .) Laboratory (UL) approved "Dialco" sockets.
Additionally, j 'the NRC inspector determined that the applicable vendor
drawings had been revised to specify the use of Dialco j sockets for applications not otherwise specified..These corrective actions appear adequate to prevent future recurrence =for Unit 1; however, pending the implementa-tion of similar corrective actions for Unit 2, this item is. closed for Unit 1 only.
c.
(Closed - Unit 1) Construction Deficiency (SDAR CP-88-07): " Reactor. Coo.~.unt Pump Wiring."
On-January 11, 1988, the NRC was notified of a reportable . event involving cable installations within the 6.9 KV switchgear for the reactor coolant pumps which were not installed in accordance with Regulatory Guide 1.75 and Electrical Erection Specification 2323-ES-100.
Specifically, during the design validation process, the following deficiencies were identified: (1) Class lE cables from safety-related trains were identified as being terminated together.
(2) The cable.from both safety trains were terminated with (black) non-Class 1E cables.
(3) Both trains of installed Class lE cable violated the minimum six-inch separation requirement from the non-Class lE terminations.
As identified by the applicant in their correspondence to the NRC by letter TXX-88066, this deficiency was attributed to inadequate cable separation criteria specified in the original design of Class lE circuits within the reactor coolant pump.
Subsequent to this event, the applicant initiated corrective action which included clarification of the electrical separation design criteria as defined in the electrical design basis document (DBD) EE-057, titled " Separation Criteria."
Additionally, the applicant undertook an evaluation of the reactor coolant pump wiring configuration to assure proper isolation and separation of Class lE and non-Class lE circuits, cables, and devices.
Completion of this evaluation was documented by letter TXX-88276.
This letter also established additional corrective action involving the installation of isolation devices on both trains of the Class lE circuits and the rerouting of the subject cables _ _. _ _ _ _ _ _ _ _ _.. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
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as non-Class 1E beyond the isolation devices.
The completion-of this action resulted in only non-Class 1E L cables entering and being terminated in the Train C 6.9 KV switchgear.
The NRC inspector reviewed DBD-EE057, Revision 3, and determined that both isolation and separation criteria for. Class 1E to non-Class 1E circuits, cables,'and devices had been incorporated into this document.
The NRC inspector also conducted selected examinations of the installed isolation devices and rerouting of cable as non-Class lE for Unit 1 as well as reviewing coh.;1eted design change authorizations: (DCA)-70613, Revision 4; DCA-71718, Revision 1; and DCA-71719, Revision 2.
Based on the above inspections and documentation reviews, the inspector determined that the stated corrective actions have been completed, including the installation of isolation devices on both trains of the Class 1E circuits and the rerouting of the cables as non-Class 1E e beyond the isolation devices and that these actions appear adequate to prevent reoccurrence for Unit 1.
j Similar corrective measures for Unit 2 are scheduled for l completion prior to Unit 2 fuel load; therefore, this l construction deficiency is closed for Unit 1 only.
(Closed) Construction Deficiency (SDAR CP-88-12): d.. " Class 1E and non-Class 1E Cable Separation."
On January 11, 1988, the NRC was notified of a deficiency by TU Electric letter TXX-88071 involving a violation of ' I electrical separation criteria.
Specifically, Class 1E designated cables E0140291 and EG140305, which did not perform a Class 1E functions were connected to non-Class 1E cables and were routed with Class 1E cables ' at control panels CP1-EIPRCI-01 and -02.
The applicant initiated NCR 87-05564 (later revised to Revision 1) to spare the cables in place, relabel them as such, and to install new cables NK149720 and NK149721.
The NRC inspector reviewed the NCR, physically verified that the
corrective action had been completed, and found no ' discrepancies.
Additionally, the applicant identified field verification method (FVM)-EE-088 as having been implemented to determine if any further deficiencies existed.
As delineated in paragraph 5 of this report, the NRC inspector reviewed the implementation of FVM-EE-088 and determined that this construction deficiency is closed.
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' q . .. ) 5.- Corrective Action Program (CAP)-(51053, 52053)
Electrical Components I The NRC inspector accompanied Post-Construction Hardware Validation Program (PCHVP) electrical engineers on a portion of' Field Verification Method (FVM)-088, " Electrical Separation," performance for rooms 212 and 214.
The engineers appeared knowledgeable of the separation requirements and properly identified several discrepancies.
The NRC inspector also obtained a copy of the FVM-88 electrical separation walkdown package for a follow-up inspection of room 205.
The FVM'was properly accomplished, no discrepancies not already noted by NCR were found, and an out-of-scope finding of the FVM was properly handled by NCR.
No violations or deviations were identified.
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6.
Plant Tours (51063, 42051C) J The NRC inspector conducted routine plant tours during this inspection period which included evaluation of work in progress as well as completed work to determine if activities involving safety-related electrical systems and components including electrical cable were being controlled and accomplished in accordance with regulatory requirements, industry standards, and applicant procedures.
During the conduct of one of these plant tours, the NRC inspector was present when an audible area fire alarm was actuated at a local fire system alarm panel on plant elevation 810.
A plant operator responded quickly to the alarm, silenced it, and reported both of two indicated L possible problem areas to the control room by radio.
Upon acknowledgement by the control room, the operator departed to l check other areas.
The NRC inspector subsequently determined that this alarm was a spurious signal; however, the response was considered prompt and thorough.
No violations or I deviations were identified.
7.
Electrical Equipment and Cables (51063) The NRC inspector observed a portion of the work in progress for the pulling of safety-related cable E0150194.
The cable was being installed per a DCA to add monitor indication to valve HV-5837.
A review of the work package and the cable pulling preparations in the cable spreading room, Room 133, revealed no discrepancies.
Raceway condition was adequate and the cable was protected from sharp edges.
Colled cable was adequately secured and QC inspectors were present during the activity.
No violations or deviations were identified.
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Instrumentation (52053) The NRC inspector observed work in progress on containment spray pump 03 suction pressure gauge.
A review of the package, 1PI-4806, indicated that the latest approved drawings and DCA 77586 were present.
Components were'being installed in the proper location / orientation and correct components / materials were being used.
Required in process inspections had been performed per traveller 1PI-4806.
NCR CI-87-893X regarding tubing supports had been identified and included in the work package.
No discrepancies were noted.
No violations or deviations were identified.
9.
Exit Meeting ~(30703) An exit meeting was conducted April 4, 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 applicant
did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
During this meeting, the NRC inspectors summarized the scope and findings of the inspection.
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