IR 05000445/1989022

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Insp Repts 50-445/89-22 & 50-446/89-22 on 890405-0502.No Violations or Deviations Noted.Major Areas Inspected: Applicants Action on Previous Insp Findings,Followup on Violations/Deviations & Followup on Bulletins
ML20247L009
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 05/22/1989
From: Latta R, Livermore H
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20247K976 List:
References
50-445-89-22, 50-446-89-22, IEB-77-01, IEB-77-1, NUDOCS 8906020068
Download: ML20247L009 (13)
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGUTNITON 

 , NRC Inspection Report:  50-445/89-22 Permits:. CPPR-126-50-446/89-22  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 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: April-5 through May 2, 1989 q Tnspector: Wf R. M. Latta, Resident Inspector ODate MNM7 (Electrical) (paragraphs 2, 3, 4,5,6,7, 8, 9, and 10) Consultants: J. Dale, EG&G (paragraphs 6 and 7) 

   . Graham - Parameter (paragraphs 6 and 7)

W. Richins, Parameter (paragraphs 6 and 7) J. L. Taylor - Parameter (paragraphs 2, 3, 5, and 8) 

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Reviewed by: ( (UGWIv(AE b 11 f H. H. Livermore, Lead; Senior Inspector Date 8906020068 890522 ADOCK 05000445 ! l PDR Q PDC 

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Inspection Summary: Inspection Conducted: April 5 throuch May 2, 1989 (Report 50-445/89-22; 50-446/89-22) Areas Inspected: Unannounced, resident safety inspection of applicant's actions on previous inspection findings, follow-up on violations / deviations, follow-up on Bulletins, Corrective Action Program (CAP), reactor coolant system (RCS) hydrostatic testing, hot functional testing, and plant tour g Results: Within the areas inspected, no significant strengths or weaknesses were identifie During the inspection, two open items were identified regarding: (1) the applicant's commitment to provide a supplementary response to violation EA 86-09, Appendix B, Item I.B.5, consolidating final Corrective Action Request (CAR) 055/SWTU-9306 actions (paragraph 3.b), and (2) further NRC inspection of the calibration of pressure gauges used for the RCS hydrostatic test (paragraph 6).

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3 i DETAILS Persons Contacted 

 *R. W. Ackley, Jr., Director, CECO
 *G. K. Afflerbach, ASM Startup, TU Electric
 *M. Axelrad, Newman and Holtzinger
 *J. L. Barker, Manager, Engineering Assurance, TU Electric
 *D. P. Barry, Senior Manager, Engineering, Stone and Webster Engineering Corporation (SWEC)
 *J. W. Beck, Vice President, Nuclear Engineering, TU Electric
 *0. Bhatty, Issue Interface Coordinator, TU Electric
 *M. R. Blevins, Manager, Technical Support, TU Electric
 *H. D. Bruner, Senior Vice President, TU Electric
 *J. H. Buck, Senior Review Team, IAG
 *J. T. Conly, APE-Licensing, SWEC
 *R. J. Daly, Manager, Startup, TU Electric
 *J. W. Donahue, Operations Manager, TU Electric
 *D. E. Deviney, Deputy Director, Quality Assurance (QA),

TU Electric 

 *D. M. Ehat, Consultant, TU Electric
 *J. C. Finneran, Jr., Manager, Civil Engineering, TU Electric
 * Fonseca, Deputy Director, CECO
 *W. G. Guldemond, Manager of Site Licensing, TU Electric
 *P. E. Halstead, QC Manager, TU Electric
 *T. L. Heatherly, Licensing Compliance Engineer, TU Electric
 *C. B. Hogg, Engineering Manager, TU Electric
 *T. A. Hope, Licensing, TU Electric
 *A. Husain, Director, Reactor Engineering, TU Electric
 *R. T. Jenkins, Manager, Mechanical Engineering, TU Electric
 *J. J. Kelley, Manager, Plant Operations, TU Electric
 *0. W. Lowe, Director of Engineering, TU Electric
 *F. W. Madden, Mechanical Engineering Manager, TU Electric
 *D. M. McAfee, Manager, QA, TU Electric
 *S. G. McBee, NRC Interface, TU Electric
 *J. W. Muffett, Manager of Enginee<*ing, TU Electric
 *E. F. Ottney, Program Manager, CASE
 *S. S. Palmer, Project Manager, TU Electric
 *P. W. Pellette, Operations, TU Electric
 *D. M. Reynerson, Director of Construction, TU Electric
 *A. H. Saunders, EA Evaluations Manager, TU Electric
 *A. B. Scott, Vice President, Nuclear Operations, TU Electric
 *B. J. Sewell, TU Materials Coordinator Manager, TU Electric
 *J. C. Smith, Plant Operations Staff, TU Electric
 *R. L. Spence, TU/QA Senior Advisor, TU Electric
 *M. D. Skaggs, CPE, Mechanical, 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
 *M. A. Thero, QTC Intern
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 *O. L. Thero, QTC Consultant to CASE
 *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 The NRC inspectors also interviewed'other applicant employees during this inspection perio * Denotes personnel present at the May 2, 1989, exit meetin . Applicant Action on Previous Inspection Findings (92701, 51055) (Closed) Unresolved Item (445/8904-U-01): Bent and twisted lugs attribute not specifically documented in FVM-87. In order to further evaluate this issue, the NRC  '

inspector conducted discussions with members of the applicant's electrical engineering staff. The applicant's position relative to this issue was determined to be: 

   (1) that deficiencies in this attribute, though not specifically signed off, wcold have been identified during the conduct of the applicant's inspections for other termination attributes and (2) that startup personnel are specifically trained to the requirements of the controlling Electrical Installation Specification ES-10 u It is noted that this attribute was also addressed in the NRC Inspection Report 50-445/89-28; 50-446/89-28. The NRC inspector reviewed the applicant's revised attribute evaluation criteria which clarified their position relative to inspection for bent and twisted lugs and determined that it was acceptable. Since no deficiencies of this attribute have been identified, to date, during the conduct of numerous NRC inspections, this item is considered close ; (Closed) Unresolved Item (445/8907-U-01): Floor seals missing from Bisco seal ma The NRC inspector reviewed i Design Change Authorizations (DCAs) 46620, Revision 0;  I DCA 81775, Revisions 0 and 1; and applicable change verification checklists (CVCs) submitted by the applican Additionally, the NRC inspector reviewed DCA 46620, Revisions 12 - 16, and Procedure ECE 5.09-01, Revision 2,
   " Design Verification and Interdiscipline Review." The CVCs provided with DCA 46620, Revision 0, revealed that fire protection reviews were required. This review   '

apparently led to initiation of DCA 81775 on January 20, 1989, by Bisco which included updating of the subject seal map drawing AB-810-201-5, sheet 5. The above reviews satisfied the NRC inspector's concerns regarding the adequacy of interdisciplinary reviews; therefore, this item is closed.

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   - (Closed) Open Item (445/8907-0-02): Use of color coding tape on the heated junction thermocouple (HJTC) syste This open item concerned the use of train identification tape on the HJTC system at various points inside the reactor building. Specifically, the NRC inspector questioned the compatibility of this tape with the HJTC stainless steel tubing near the reactor vessel head and the limits to which the identification tape extended into-the reactor internals.. In response to these concerns, the applicant provided technical justification-in the form of Nonconformance Report (NCR) E85-101373, Revision 1, and-DCA 21779, Revision 0. These documents specified the acceptability of the existing "Brady" type B-361-B film tape for use inside containment including its use for color coding of stainless steel jacketed cable. The applicant also revised the controlling Electrical Specification 2323-ES-100 to include the use of Brady film tape for use inside containment as documented in DCA 4913 Additionally, the NRC inspector reviewed the construction traveler documentation for both the termination of the thermocouple cables'and the installation of the HJTC probe assemblies as well as the associated installation inspection reports. These reviews indicated that no provisions were made for the application of color coding tape on any of the HJTC probe assemblies which would

- extend beyond the electrical receptacle at the top of the probe assemblies (located above the reactor vessel head).

Based on the above inspection activities which included reviews of the installation controls and examination of i- the HJTC probe assemblies, the NRC inspector determined i that the existing color coding tape is acceptable for use I on this system and that electrical train identification tape does not extend beyond the upper thermocouple receptacles of the HJTC probe assemblies; therefore, this item is close . Follow-up on Violations / Deviations (92702) (Closed) Violation (445/8604-V-02; 446/8603-V-02; EA 86-09, Appendix B, Item 1.B.2): Electrical penetration assembly (EPA) drawings with notes / vendor documents not properly controlled by Gibbs & Hill (G&H). These l violations involved handwritten comments on drawings maintained at the site and the implied lack of document L control by the applicant's contractor, G&H. The NRC inspector reviewed various documents submitted by the applicant to resolve the subject violation. This documentation included Corrective Action Report (CAR)-055, Procedure ECE 5.19, " Review of Vendor Documents," and l 

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l l Procedure ECE 2.13-II, " Document-Control Instructions." 1 These procedures appeared to be adequate to prevent i recurrence of the violation. Additionally, it is noted that the original EPAs have been replaced (as documented j

by SDAR-CP-86-10 and NRC Inspection Report 50-445/89-15; 50-446/89-15) with a different vendor's components, which resulted in the supersession of the subject drawing These' corrective actions appeared adequate; therefore, these violations are close b. (Closed) Violation (EA 86-09, Appendix B, Item I.B.5): Nonconformance of EPA heat shrinkable tubing (HSIT) not identified and corrected by rework. Similar to the above violation, a handwritten note indicating a discrepancy between drawings relating to HSIT length was identified ~on a drawing. The note was later resolved with another handwritten note indicating that rework was require This rework was overlooked and was not accomplished. The NRC inspector reviewed CAR 055, Revision 2, which included this violation. The CAR's indicated corrective action of initiating an equipment qualification walkdown was revised by letter SWTU-9306 dated July 12, 1988. The revision indicated that this walkdown was no longer required and that the replacement of the EPAs was the corrective action since this would include replacement of the HSIT. The NRC  ! inspector notified the applicant that the last letter in the NRC's file regarding this issue was TXX-88262 dated March 1,.1988, which referred to a Unit 1 environmental qualification (EQ) verification program to correct the  ; discrepancy. The applicant agreed to provide a supple-mentary response consolidating final CAR 055/SWTU-9306 actions to close the issue within 2 - 3 weeks. Pending the completion of the applicant's commitment to provide a j supplementary response to violation EA 86-09, Appendix B, Item I.B.5, this issue is identified as_an open item (445/8922-0-01). However, due to the replacement of the EPAs as documented in NRC Inspection Report 50-445/89-15; 50-446/89-15 under SDAR-CP-86-10, this violation is

considered closed.

I c. (Closed) Violation (446/8612-V-03): National Electrical l Manufacturers Association (NEMA) type 4 junction boxes installed without covers. This violation involved the improper implementation of a design change by both l engineering and construction personnel. Specifically, site engineering personnel utilized a combination of verbal instructions and the resolution of a nonconformance report to direct the modification of NEMA type 12 covers to upgrade them to NEMA type 4 junction box covers. The i modification which consisted of substituting junction box cover fastener types for use on electrical enclosures inside the reactor building was contrary to the existing l

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:a requirements'of Specification 2323-ES-100 and was  .

accomplished without proper procedures or adequate design documentatio 'The NRC inspector examined the completed corrective and preventive actions implemented in response to this violation including the review of DCA 31429 which revised Specification 2323-ES-100 to allow the.use.of either NEMA type-4 or type 12 junction boxes inside the containment building as well as TU Electric's letter VEC-0072 dated December 9, 1986, which reinforced the requirements for proper implementation of design changes. Additionally, the NRC inspector reviewed the applicant's revised resconse to this violation contained in letter TXX-88736 dated. October 20, 1988, which details the final resolution of CAR 87-026, " NEMA 12 Boxes Modified to NEMA 4," and the issuance of corporate Procedure NEO 3.05, " Reporting and Control.of Nonconformances." Review of these documents, along with inspections related to FVM-089, "PCHVP Engineering Walkdowns," indicate that the applicant has taken adequate programmatic steps to control the design change process. Implementation'of these enhanced-procedural controls along with administrative constraints placed on both engineering and construction personnel to provide design documentation were determined to be acceptable; therefore, this violation is close (closed) Violation (445/8730-V-07): Emergency diesel generator control panel drawings not correct. This violation concerned the applicant's failure'to properly control electrical schematic drawings pertaining to the emergency diesel generator (EDG) control panels. As stated in the applicant's response contained in letter TXX-88325 dated March 18, 1988, the violation was attributed to the maintenance of duplicate information on both vendor drawings and on owner-initiated drawings such that change documents could be written against either or both drawing The NRC inspector examined the corrective actions delineated in the response to the violation including DCA 56137 which revised the applicant's EDG control panel drawings to include vendor wire numbers, as well as DCA 74268 which provided a technical review and disposition for ten additional EDG vendor drawings which were found to have coexisting active informatio Additionally, the NRC inspector reviewed Deficiency Report (DR) C-88-00872 which addressed the generic implications , of this issue in that an examination of drawings, both  ! owner-initiated and vendor supplied, was performed by the applicant to determine the extent of duplicate information. Disposition of this DR was tracked through 

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i audit response TCP-88-13 which did not identify any i i additional discrepancies involving maintenance of duplicate active drawings. The NRC inspector also reviewed Engineering and Construction Engineering Procedure ECE 5.05, " Design Drawings," which was revised and renumbered subsequent to this violation in order to provide additional guidance on the control and incorporation of vendor drawings. Based on the above documentation reviews, the NRC inspector determined that the applicant had taken adequate corrective action to control the inadvertent release of duplicate' active drawings; therefore, this violation.is close . Follow-up on NRC Bulletin (92703) 

 (Closed, Unit 1 only) IE Bulletin 77-01: " Pneumatic Time Delay Relay Setpoint Drift." This bulletin identified operational difficulties associated with set point drift on pneumatic time delay relays used in the control circuitry for selected emergency diesel generators. In particular, the relays involved were identified as ITE Imperial, Catalog Nos. J20T3/J13P20 and J20T3/J13P3 As stated in the applicant's initial response to this bulletin by letter TXX-2414 dated June 14, 1977, no ITE Imperial relays would be used in safety-related systems at Comanche Pea Subsequent to this response, programmatic concerns relative to the procurement and installation of potentially defective relays resulted in a reanalysis and design review of the equipment qualification of 20 ITE Imperial relays which had been installed since the applicant's initial response to this bulletin. The applicant's analysis concluded that the subject relays had only been used in nonsafety-related alarm applications. The NRC inspector reviewed the application of these pneumatic time delay relays as documented in CECO letter 0193 dated February 22, 1989, and determined that the applicant's actions relative to this bulletin are acceptable; therefore, this item is closed for Unit 1 onl . Corrective Action Program (CAP) (51053, 51063, 52053, 52055) The NRC inspector accompanied SWEC engineers on inspections of filter compartments TBX-BRFLRE-01 and TGX-BRFLCN-01 for FVM-EE-88, " Electrical Separation." The NRC inspector determined that proper closed space entry l

procedures were followed by the SWEC personnel and the FVM was properly implemente The NRC inspector also reviewed the Phase I walkdown package previously completed for FVM-EE-88 on Room 18 A subsequent follow-up inspection of the room by the NRC inspector revealed no additional discrepancie _ - _ .

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9 The NRC inspector observed portions of the instrument ' i tubing installation and structural ~embedment work for replacement of containment pressure instruments IPT-936 and 1PT-939. The installing technician appeared knowledgeable and observed activities were acceptable. A subsequent review of documentation packages maintained in the records vault for the instruments revealed no discrepancie i No violations or deviations were identifie . Reactor Coolant System Hydrostatic Test Package 5500 (70362, 70462, 705621 

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Four NRC inspectors witnessed approximately 75% of the reactor coolant system (RCS) VT-2 hydrostatic test 5500, including testing of the RCS Class 1 piping and hardware within the test boundary. The NRC inspectors accompanied four of the five applicant VT-2 certified QC inspectors during the test and verified that the official primary and backup pressure gauges indicated the required pressure of.2340 psig at the start and completion of the test. The NRC inspectors also jointly witnessed the QC inspectors' activities and confirmed that the correct hardware was inspected by comparing valve and/or line identification with drawings contained in the packages, and visually verified by inspection of the hardware that.the results recorded by each QC inspector were correc The portions of the RCS hydrostatic test witnessed and verified by the NRC inspectors included: 

  . Class I insulated and uninsulated piping and hardware in loops 1, 2, and . Cross-over leg . Incore instrumentation tubing beneath the. reactor vesse . Reactor vessel flang . Inlet and outlet legs from the residual heat removal syste . Reactor coolant pump seals for loops 1 - . Piping associated with the pressurizer including the surge line, code safety relief valves, block valves, and the spray lin The applicant issued three condition reports (CRs) as a result of this test:
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CR 89-027 identified a slight weepage emanating from the' top of the reactor coolant pump seal package for loop 4. The technical evaluation determined that the weepage came directly from the Reactor Make-up Water System (Class 5) and not from the RCS pressure boundary; therefore, it was determined that the reported condition did not adversely impact the validity of this tes CR 89-032 identified: (1) body to bonnet leaks on block valves 1-8000A and 1-8000B associated with the pressurizer, (2) the same leakage detailed in CR 89-027, and (3) the presence of hydraulic fluid on RCS piping. The block valves were identified as being slightly wet with no dripping. This condition was determined to be acceptable per the guidance provided in memorandum TIM-890765 dated April 7, 1989, regarding VT-2 leakage evaluation. The hydraulic fluid was attributed to leakage from a snubber and did not mask any potential RCS leak. Consequently, the reported conditions did not adversely impact the validity of this tes CR 89-044 identified a typographical error in Section 3.4 of the teut package regarding the identification of applicable piping isometrics. The correct isometrics were, however, contained in the test package and it was determined that the reported condition did not adversely impact the validity of the tes The NRC inspectors determined that the RCS VT-2 hydrostatic test 5500 field inspections were thorough in scope, were performed in accordance with the controlling procedures, and were correctly documente The NRC inspectors reviewed the completed test packag The review included attachment 11.1 which contained the applicable RCS flow diagrams used to define the test boundaries and attachment 11.2 which contained the corresponding isometric drawings. The NRC inspectors reviewed the Affected Documentation Update Report associated with each drawing to determine the impact of outstanding NCRs and DCAs on the system test configuration. A sample of 4 of the 8 flow diagrams and 20 of the 41 isometric drawings with referenced NCRs and DCAs were reviewed. The NRC inspectors concluded that none of the identified outstanding documents examined would have affected the validity of the RCS hydrostatic tes The NRC inspectors verified by examination of test documentation that: (1) the identification of inaccessible items and provisions used for examining inaccessible items were correct, (2) test prerequisites were signed off by qualified personnel, (3) test configuration (valve line-ups, etc.) and hold time were signed off by qualified personnel, (4) a safety evaluation was performed to address 10 CFR 50.59 applicability, _ _ _ _ _ _ _ _ - _ - - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _

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11 .{ and (5) the RCS was returned to normal condition No documentation concerns were identifie The NRC inspectors verified that the VT-2 QC inspectors involved in'the RCS test were properly certified to perform the inspection. The qualifications of other personnel who signed the test package were also verifie The NRC inspectors confirmed RCS test gauge pressure before and after walkdown of the RCS. Test pressure was determined to be 2340 PSIG at the start and at the end of the test. Subsequent to completion of the RCS hydrostatic test, the official and backup test gauges were identified as being out of calibratio DR P89-00486 was issued to document this condition. This DR has been dispositioned by the applicant and close TU Electric concluded that the minimum test pressure conditions in accordance with ASME Section XI had been met. This is an open item pending further NRC inspection and determination by the applicant of root cause and corrective action (445/8922-0-02).

No violations or deviations were identified during NRC inspection of the RCS VT-2 hydrostatic tes . Hot Functional Testing (70300, 70314) During this reporting period, the NRC inspectors witnessed major portions of the applicant's Unit 1 VT-2 examination which encompassed both the primary system and designated portions of the secondary piping systems. The purpose of these tests was to establish the acceptability of various reactor plant piping systems by performing leak tests in accordance with ASME Section XI Code requirements for testing following repairs and replacements involving the disassembly and reassembly of . pressure retaining mechanical joints for Class 1 and 2 pipin : i Specifically, the NRC inspectors examined selected sections of J the Residual Heat Removal system, the Auxiliary Feedwater i system, the Chemical and Volume Control system, and the Main i Steam system. This sample included approximately 50% of the ) 32 tests completed by the applicant. During the execution of these walkdowns, the NRC inspectors witnessed the conduct of various VT-2 examiners associated with the applicant's quality assurance staff. These examiners were generally found to be knowledgeable and well acquainted with the systems as well as with the leak test criteria specified in the applicant's Procedure NQA 3.09-8.51, Revision 0, "ASME Section XI, Visual Examination VT-2."

Throughout the conduct of this test program, the NRC inspectors attended various preplanning and shift briefings conducted by the applicant. The NRC inspectors determined that the _ _ _ - _ . 

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preparations made for the tests and the coordination of test evaluations were generally accomplished within the confines of the test schedule and that adequate management attention was evident. This was manifested in the normal availability of reactor plant support systems and in operational staff VT-2 test prioritizatio The NRC inspectors routinely verified that required test parameters and prerequisites had been accomplished prior to initiating walkdowns including the availability of qualified VT-2 examiners, the completion of required soak times (when specified), and the execution of system line-ups to support testing. The NRC inspectors also determined, for the observed portions of the system walkdowns, that discrepant conditions were correctly identified, properly documented, and that the subsequent technical dispositions for corrective action appeared adequate. Observations of the VT-2 examiners during these evaluations indicated that their training was adequate and that they were utilizing the correct isometric drawings which were properly annotated and controlle The NRC inspectors concluded, based on programmatic reviews and the above noted in-process inspection observations, that the VT-2 leak check phase of the Hot Functional program appeared adequate in that no substantive deficiencies were identifie No violations or deviations were identifie . Plant Tours (51053) The NRC inspectors 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. No violations or deviations were identified and no items of significance were observe . Open Items

open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or applicant or bot Two open items disclosed during the inspection are discussed in paragraphs 3.b and . Exit Meeting (30703) An exit meeting was conducted May 2, 1989, with the applicant's representatives identified in paragraph 1 of this repor No written material was provided to the applicant by the _ _ _ _ _ _ _ _ _ _ _ _ - - _ - 

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i Un j i :. inspectors'during.this-reporting-period.. The applicant-did not' 1 'k . identify as proprietary any of the materials provided to"or reviewed by the inspectors.during this inspection. During this -{ 

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