IR 05000445/1989027

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Insp Repts 50-445/89-27 & 50-446/89-27 on 890405-0502.No Violations Noted.Major Areas Inspected:Actions on Previous Insp Findings,Followup on Violations/Deviations,Actions on 10CFR50.55(e) Deficiencies & Piping & Pipe Supports
ML20247G861
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 05/18/1989
From: Livermore H
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20247G841 List:
References
50-445-89-27, 50-446-89-27, NUDOCS 8905310089
Download: ML20247G861 (19)
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION NRC Inspection Report: 50-445/89-27 Permits: CPPR-126 50-446/89-27 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 Peek Site, Glen Rose, Texas Inspection Conducted: April 5 through May 2, 1989 Inspection conducted by NRC consultants: J. Birmingham, RTS (paragraphs 2.g, 2.h, and 4.d) K. Graham - Parameter (paragraph 3.b and 4.e) P. Stanish - Parameter (paragraphs 2.a thru 2.f, 3.a, 4.c, 5, and 6) Reviewed by: 9 F LNa.uwJe NHL 5//$9 H. H. Livermore, Lead Senior Inspector Da'te 

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8905310089 890518 PDR ADOCK 05000445 O PDC ___ _ _ _ _ _ _ _ _ _ _ _ _

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l 2 l Inspection Summary: Inspection Conducted: April 5 through May 2, 1989 (Report 50-445/89-27; 50-446/89-27) Areas Inspected: Unannounced, resident safety inspection of applicant's action on previous inspection findings, follow-up on violations / deviations, action on 10 CFR Part 50.55(e) deficiencies identified by the applicant, piping and pipe supports, mechanical components and equipment, and plant tour Results: Within the areas inspected no significant strengths or weaknesses were identified. During the inspection one unresolved item concerning the lack of locking devices on threaded fasteners (paragraph 6) was identifie _ _ _ - _ _ _ _

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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
 *O. 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
 *C. A. 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. McAfee, Manager, QA, TU Electric
 *S. McBee, NRC Interface, TU Electric
 *J. Muffett, Manager of Engineering, TU Electric
 *E. Ottney, Program Manager, CASE
 *S. Palmer, Project Manager, TU Electric
 *P. Pellette, Operations, TU Electric
 *D. Reynerson, Director of Construction, TU Electric
 *A. Saunders, EA Evaluations Manager, TU Electric
 *A. 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. Skaggs, CPE, Mechanical, TU Electric
 *P. Stevens, Manager, Electrical Engineering, TU Electric
 *J. Streeter, Director, QA, TU Electric
 *C. Terry, Unit 1 Project Manager, TU Electric  ]

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   *M. Thero, CASE Intern
   *0. Thero, QTC Consultant to CASE
   *T. Tyler., Director of Projects, TU Electric
   *R. Walker, Manager of Nuclear Licensing, TU Electric
   *R. Withrow, EA Systems Manager, TU Electric The NRC inspectors also interviewed other applicant employees during this inspection perio * Denotes personnel present at the Mcy 2, 1989, exit meetin . . Applicant Action on Previous Inspection Findings (92701) (Closed) Open Item (445/8514-0-15): During reinspection for Instrumentation Equipment Installation Verification Package I-E-ININ-066, Evaluation Research Corporation (ERC) identified the following to the NRC inspector as subject to evaluation as potential deviations:
    (1) The required color code (traceability requirement)

was missin (2) The maximum allowable distance between color code marks was exceede The noted discrepancies were documented on Deviation Reports (DRs) I-E-ININ-066-DR1 and DR2 which were subsequently-transferred to Nonconformance Report (NCR) I-85-102025, Revision The missing color code was dispositioned "use-as-is" since the current revision of Specification CPES-I-1018 states that color coding is not required after the tubing system is accepted by Q For the excessive distance between color code marks, the disposition was to rework the tubing in accordance with the dispositio The NRC inspector reviewed the DRs, the NCR, and the inspection reports (irs) associated with the rework performed. Based on the above, the NRC inspector concurs that this issue has been adequately addressed. This open item is close (closed) Open Item (445/8514-O-27): During reinspection for Small Bore Piping Configuration for Verification Package I-M-SBCO-061, ERC identified the following conditions to the NRC inspector as subject to evaluation as potential deviation _ _ _ _ _ - - _ - _ _ _ _ _ _ _ _ _ _ . _ _ - _ _ _ _ _ 

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 (1) There was insufficient clearance with three cdjacent pipe (2) A linear dimension measurement was out of toleranc These discrepancies were documented on DRs I-M-SBCO-061-DR1 and -DR2 which were later transferred to NCR M-23461N. The disposition of the NCR required that the drawing BRP-CH-X-FB-006 be revised to reflect the as-measured dimensions and for the instances of insufficient clearances that the insulation be notche The NRC inspector has reviewed the DRs, NCR, construction traveler and the revised drawing as well as inspected the piping clearances and insulation and concurs that this issue has been fully addressed. This open item is close c. (Closed) Open Item (445/8706-O-09): During the implementation of ISAP V.c, CPRT identified two issues related to piping interfaces that were documented on Discrepancy / Issue Resolution Reports (DIRs) E-0349 and D-009 DIR E-0349 entitled " Piping Between Category I and

, non-Category I Buildings," addressed the influence of L nonseismic piping.on the adjoining seismic portion in the l event of an earthquake, and the method of isolating the Category I portion. CPRT's original concern in this area was that the Gibbs and Hill procedure did not contain criteria to consider turbine building structural failure in accordance with Section 3.7B.2.8 of the CPSES FSA DIR D-0098 entitled " Calculation of Pipe Support Loads at Seismic Interfaces," was issued due to a lack of technical justification for the load factor used to account for interface anchor loads from nonseismic piping.

l l SWEC responra to these two issues was that I attachment 4-10 of Procedure CPPP-7 along with the guidelines provided in CPPP-28 addressed the specific concerns. The NRC inspector has reviewed these documents and concurs that the method provided will resolve the i concerns stated in the DIRs. This open item is close d. (closed) Open Item (445/8906-O-01): The NRC inspector l identified a pipe clamp that was rotated on the pipe so that it was no longer parallel with the sway strut on support number VA-X-004-704-A73R. This condition could have caused binding between the sway strut and clamp due to thermal and/or seismic movemen _ _ _ .

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In response to this item, QC reinspected the support and found that the angularity of the sway strut and pipe clamp wgre not within the specified tolerance of plus or minus 2 from the drawing requirements. This was documented on unsat Inspection Report (IR) 1979 and dispositioned so that the support would be reworked to bring it into compliance with the drawin ! The NRC inspector reviewed the unsat IR and is satisfied that the identifind condition is adequately described and that the disposition is reasonable. Also, the construction traveler to implement this IR was also - reviewed, which indicates that the installation of this support is now in compliance with the design drawin Based on the above, this open item is close .e. (Closed) Open Item (445/8920-0-01): The NRC identified two issues concerning pipe supports (use of ASTM-A-307 bolting and side loads on sway struts) which may be indicative of a failure of the vendor to account for all possible. design conditions. While these issues have been adequately addressed at CpSES, a review for deportability under the requirements of 10 CFR Part 21 may not have been considere During this report period, the NRC inspector reviewed a copy of a TU Electric internal memo dated April 6, 1989, 2 with a copy to the vendor, which accurately outlines the NRC's concerns. Since the applicant has notified the f manufacturer that a Part 21 review may be required; we l' will continue to monitor this item to ensure proper vendor evaluation is performed. This item is close f. (Closed) Unresolved Item (445/8856-U-05; 446/8852-U-03): This item documented three examples of deviations from the requirements of the applicable weld procedure specification (WPS). Two examples had unconsumed filler material and one had an excessively large fit-up sa The applicant initiated an evaluation of the extent of this condition and its safety significance under Corrective Action Request (CAR) 88-02 Prevd;2s NRC inspection activities associated with this unresolved item are documented in NRC Inspection Reports 50-445/88-71, 50-446/88-67; 50-445/88-75, 50-446/88-71; and 50-445/89-06, 50-446/89-06. In this inspection period, the NRC inspector received the results of the inspections and analyses of the additional sample selected in response to NRC comments on the initial (draft) engineering repor Twenty additional welds were selected for further evaluation. The selection of these welds was made by a walkdown of various buildings of the

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plant and was based on complexity of the joint configuration that could cause difficulty in the fit-up process. This selection was not biased toward any particular welder. The welds were examined using the same methodology as the original sampl The results of these examinations revealed no evidence of unconsumed gap-filler material or foreign material in the welds. Ten of the welds exhibited fit-up gaps which exceeded 1/16-inch without a documented increase in the fillet leg size None of the fit-up gaps detected exceed 3/16-inch. Although not documented, it was found that eight out of the ten welds with excessive fit-up gaps had some increase in fillet weld siz An engineering evaluation of the nonconforming welds was performed by SWEC to determine if the as-installed conditions provided a design margin consistent with the as-designed configuration (using the same design loadings). The results of this evaluation determined that there was no deterioration in design margi Therefore, the conclusion was that the existence of fit-up gaps was adequately compensated far by the existing weld size and the size of other welds at the connectio The root cause of this condition was initially attributed to difficult fit-up and not following approved procedures. The results of the investigation confirmed this assessmen In response to the high percentage of excessive fit-up gaps in the population sampled, ASME welders and welding supervisors received training in adherence to procedural requirements, including documentation and resolution of fit-up gap conditions. Also, DCA 79710 to Specification 2323-MS-100, Field Fabrication and Erection of Piping and Pipe Supports, has provided for a documented fit-up of ' all future ASME code welds inspection by quality contro Based on NRC review of the above documents, the NRC inspector concurs that this item has been adequately evaluated. This item is close g. (Closed) Unresolved Item (445/8881-U-01; 446/8877-U-01): This unresolved item concerned the adequacy of corrective actions relative to certain installed expansion joint The NRC inspector reviewed the following documentation: 

 (1) The CpRT recommendations relative to the expansion joints.

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(2) .The corrective actions performed by TU Electric under CAR-071 !
(3) Letter QA/QC-RT-10106 documenting third-party concurrence with the CAR respons (4) FVM-ME-071 and FNM-ME-08 l i

The NRC inspector determined that the documented corrective actions adequately addressed the concerns for installed expansion jointc. Further, the NRC inspector determined that the CAR adequately addressed generic concerns and action to prevent recurrenc Specifically the CAR addressed: (1) the identified expansion joints, (2) all other safety-related expansion joints, and (3) revision of Specification MS-100 and other applicable procedures to provide specific attributes or to require engineering involvement if specific attributes are not identifie Based-on review of the above, the NRC inspector deems the corrective actions and actions to prevent recurrence to have been adequate. This item is close h. (Closed) Unresolved Item (445/8881-U-02): This unresolved item concerned the adequacy of training of personnel to implement FVM-ME-07 The NRC inspector reviewed the content of FVM-ME-071, 

" Field Verification Method to Acquire Data on Safety-Related Expansion Joints." FVM-ME-071 required that an engineering walkdown be performed to gather data for verification of safety-related expansion joint Data, such as overall length, flange offset, dimensions of tie rods, etc., was gathered and documented on data sheets for subsequent evaluation by engineering. The NRC inspector concurs with the choice of walkdown engineers to gather data for subsequent engineering evaluatio A review of the training records for FVM-ME-071 showed that classroom training on the content of FVM-ME-071 was provided to the walkdown engineer Additionally, a review of resumes and qualification records of four walkdown engineers showed them to have been properly qualified in accordance with ECE 1.16-04,  '
" Qualification of Engineering Walkdown Personnel." Based on the review of the content of FVM-ME-071, training provided and background qualifications, the NRC inspector deems the training to have been adequate. This item is closed.

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p 9 Follow-up on Violations / Deviations (92702) (Closed) Deviation'(445/8607-D-01): TU Electric letter 

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TXX-3657' dated April 21, 1983, submitted to the NRC in accordance with 10 CFR Part 50.55(e), identified a-significant condition adverse to quality (no objective evidence'is available documenting acceptable weld quality on seismic arrester brackets) and stated that the corrective actio's:would n be to discard and replace the arrester brackets, and that the corrective action would proceed immediately. However, corrective action did not occur prior to January 198 The reason for this deviation was determined to be caused by the fact that the NCRs documenting the bracket weld deficiencies were revised and dispositioned "use-as-is."

This occurred because it was determined that the ASME N-5 boundary did not include the location of the seismic arrester brackets; ther. fore, documentation, other than the manufacturers certificate of conformance (CofC) of weld quality was not required. It was'also determined that the reason the NRC was not informed of this revision to the disposition of the NCRs was that the governing 

    ' Procedure CP-QAP-16.1, Revision 17, " Control of Nonconforming Items," did not contain provisions to indicate whether or not the nonconforming condition had been judged to be reportabl.o per 10 CFR 50.55(e) or 10'CFR 21. Consequently, the engineer who specified the
     "use-as-is" disposition on the revised NCRs was not aware that.the condition had been reported to the NRC and that TU Electric had committed to replace the subject brackets as part of the corrective action for SDAR CP-83-0 To address the general aspects of this item, SDAR CP-86-48 was issued addressing the conditions described in this deviation and other similar discrepancies. It was determined that to avoid further recurrences of this condition, revision to Procedure CP-QAP-16.1 was require This revision consisted of including a block on the NCR form which identified the evaluations pursuant to 10 CFR 50.55(e). For details of the NRC inspection of the condition that caused this deviation, refer to paragraph The NRC inspector has reviewed the revision to
    .CP-QAP-16.1 and Brown and Root ASME Administrative Procedure AAP-16.1, Revision SDCN1, Controlling Nonconforming Items and concurred that the revision incorporates the necessary evaluation review requiremen The NRC inspector also reviewed the NCRs written to document and evaluate the conditions associated with the subject bracket Based on the above action, the NRC

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inspector concurs that this issue has been adequately " 

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addressed. This deviation is close (closed) Violation (445/8865-V-02): Undocumented work i was performed on a safety-related ASCO solenoid operated i valve (SOV) which controls airflow to the air operated { diaphragm of component cooling water valve 1-FV-453 This condition was evidenced by air supply tubing wall damage and the lack of mounting screws for the SO Further, the-handwheel on 1-FV-4536 was not properly installed and a capscrew was missing from the cover of electrical junction box JBlA1770 which-supplies power to the SOV. Site personnel could not provide documentation for these condition TU Electric admitted to the violation, but uas unable to provide a definitive reason for the violatio Work Requests 50394 and 50396 were initiated upon i identification of the discrepancies noted in the violation. To implement required corrections, Work Orders C88-5847 and C88-6071 were issued to properly secure the ASCO SOV, rework air supply tubing, replace the capscrew in junction box JB1A1770, and tighten the loose handwheel on Fisher Valve 1-FV-453 Regarding the matter of the lack of work process documentation, on December 2, 1988, the Senior Vice President issued a reminder to personnel of the importance of and necessity to adhere to established procedures. While it was not issued to specifically address the work process documentation, adherence to procedures requiring such documentation would preclude recurrence of this matte The NRC inspector has reviewed the referenced work requests and work orders and performed a reinspection of the discrepant conditions. The NRC inspector concludes that the installed hardware is now in compliance with installation requirements and that actions have been l taken which should preclude recurrence of similar violations. This violation is close . Action on 10 CFR Part 50.55(e) Deficiencies Identified by the 

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Applicant (92700) (Closed) Construction Deficiency (SDAR CP-77E). l Twenty-nine mechanical safety-related specifications were in nonconformance with Section 5.2.5, Austenitic Stainless Steel, of the PSAR. The architect engineer evaluated each of the nonconformances and determined that , no problems with adverse safety implications existed.

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The' applicant determined this item was not reportable under:the requirements of 10 CFR 50.55(e). The NRC inspector reviewed'the applicable' correspondence between Gibbs and Hill, Inc. and TU Electric.- 131e most recent 

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letter on this subject, GTN-29335 dated August 15, 1978, states that the FSAR was being revised to remove all nonconformances. This' item is close (Closed). Construction Deficiency (SDAR CP-77F): 'In! , December of 1977 a diesel generator stator winding' failed-at the vendors shop. The stator was subsequentl repaired by DeLaval. TU Electric determined the failure was not. reportable under 10 CFR 50.55(e). The emergency diesel generators have been successfully tested during the preoperationa? test program. This item is close :losed). Construction Deficiency (SDAR CP-83-08): This issue involves the mounting brackets attached to valve operators supplied by-Fisher Contr 1. Due to 

   ' indeterminate weld. quality, the ability of the brackets to perform their' intended safety function during a seismic ~ event could not be assure For certain sizes of Fisher Control valves, the vendor
   ' determined that a' harmonic response was exhibited below 33Hz which could render the valves inoperable during'a seismic event. To correct this condition, Fisher, as-directed by Gibbs and Hill, welded brackets to the valve actuator housings to provide snubber attachment point Four brackets were welded to each actuator to provide a variety of snubber attachment points. Gibbs and Hill sent a letter to Fisher indicating that the brackets did not fall within'the ASME boundary; however, the correspondence did not specify what quality requirements were applicable to the bracket and attachment welds. The'

valves were received at CPSES with a Certificate of Conformance (C of C) and NPV-1 data report for the ASME portion of the assembl Subsequent to installation, the authorized nuclear i inspector (ANI) raised concerns regarding the lack of ASME documentation for the brackets and welds and NCRs ! were generated. Originally, the NCRs were dispositioned to replace the brackets and the condition was deemed

reportable and the NRC was notified pursuant to 10 CFR 50.55(e). This notification indicated that the brackets would be replaced. Subsequent to this notification, the dispositions for the NCRs were revised to "use-as-is" based on the fact that the brackets and welds were outside the ASME boundary. Further, the Fisher supplied C of C was judged to be sufficient documentation for the brackets and welGs. The NRC was

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not informed of the revised evaluation; in addition, based on.the revised disposition this condition was deemed to be not reportable. This was documented in TU Electric letter TXX-6526, dated July 1, 198 In-NRC Inspection Report 50-445/86-01; 50-446/86-01, covering the inspection period of November 1, 1985, through January 31, 1986, an unresolved item was identified, 445/8601-U-21, which documented that thes arrester brackets'were welded over raised cast identification letters on the actuator assembly resulting in welds exhibiting incomplete fusion and overall poo workmanshi In light of this fact, plus the fact that the NRC inspection' staff felt that valve operability had not been. completely evaluated for safety significance, several meetings with applicant personnel were. held to address these concern To resolve the NRC. concerns, TU Electric removed the protective coatings from the welds on selected worst' case valve brackets, reinspected the welds using AWS D. criteria, and reanalyzed the bracket welds. TU Electric also' conducted a load test on a bracket that had been welded over raised lettering on the valve actuator castin The analysis'and testing resulta indicate that the subject brackets would have. performed their-intended function during a postulated seismic event and therefore valve operability would not have been comprise In order to upgrade the workmanship of the welds, TU Electric committed to replace the brackets that were in use as snubber attachment points and remove'the unused brackets to prevent their future use. Further, the replacement would take place as follows: Brackets would be fabricated from ASME Section III materia . The snubbers would meet the applicable design requirements of ASME Code Class . Welding activities, including weld filler material, would. meet the applicable rules of ASME, Section I Welding and weld inspection would be performed and documented per ASME construction and quality procedure . The design of the seismic restraints would meet the requirements of ASME Section III, Subsection N _-____ _ - _ 

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, For the programmatic concerns related to procurement activities, TU Electric outlined the documented improvements made to procurement engineering and quality programs since this effort was transferred from Gibbs and Hill to the applicant in 1980. Further, the CPRT evaluated the current CPSES procurement program and its implementation in the Results Report for ISAP VII. The CPRT conclusion stated that the current program adequately conforms to the requirements of 10 CFR 50, Appendix B, the applicable ANSI N45.2 standards, and the applicable sections of FSAR Chapter 1 The NRC inspector has revie'. m the documentation i referenced above and performed physical inspections of several of the installations and concurs that this issue has been adequately resolved. This construction deficiency is close d. (Closed - Unit 1) Construction Deficiency (SDAR CP-86-82): Improper welds used to splice channel sections on cable tray hangers for Unit 1 and Unit During performance of the as-built program for Unit'l cable tray hangers (CTHs), it was determined that certain welds used to splice channel sections ~were not in conformance with requirements. Specifically, the welds were required to be full penetration welds, but were installed, i.n many cases, as seal welds. Engineering review of this item determined it to be reportabl The applicant attributes the cause of this deficiency to have been a lack of specific directions contained in craft procedure Current procedures have been revised to require craft to fabricate CTHs in accordance with approved design drawings. Design drawings for CTHs specify weld sizes and types. All deviations from existing drawings must be approved by engineering prior to implementation. The NRC inspector verified that craft personnel were trained to the procedural revision The NRC inspector reviewed craft procedures ECP-10, 

 " Cable Tray and Hangers Installation Unit 1," Revision 9, and CEL-125, " Cable Tray Hanger Installation and Cable Spread Room Frame Modification," Revision 0. The NRC inspector determined that these procedures did not specifically address splice welds of channel; however, they provide requirements that CTH fabrication must be in accordance with approved design drawings and that all deviations from design require prior engineering evaluation and approval. The NRC inspector also reviewed

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  .DCA 2832, Revision 0 dated May 12, 1975,. which authorized   !

craft personnel to field splice CTHs provided a full penetration weld was utilized. The NRC inspector; believes that inappropriate use of DCA 2832 contributed to the installation of unacceptable splice weld DCA 2832 was voided February 20, 198 Corrective actions,for this deficiency. consisted of: 

  (1) a review of all change paper which may have approved splice welds, (2) a field wclkdown of all Unit 1 CTHs'to   l identify the as-built configuration, and (3) performance of ultrasonic testing on cable tray members found'to be inaccessible for visual examinatio The field walkdown was performed in accordance with Field Verification Method (FVM) CPE-EB-FVM-CS-001, " Field Verification Method Unit 1 Cable Tray Hanger As-Built and Design Adequacy Verification Program." FVM-CS-001 was extensively inspected by the NRC as well as by site surveillance programs and has been determined to have been effectively implemented. The NRC reviewed the results of FVM-CS-001 and the other actions taken and determined that their implementation provided appropriate corrective actio The NRC inspector reviewed 16 NCRs issued to document
  ' unacceptable splice welds. The-NCR dispositions typically: (1) replaced the spliced CTH member, or (2) welded material across the splice. These dispositions were deemed acceptable by the NRC inspecto Based upon a review of the above actions, the NRC inspector concurs with the applicant's closure of this item for Unit 1 only, (Closed - Unit 1 only) Construction Deficiency (CDAR CP-87-103): Limitorque HBC-3 valve drives that utilize cast bronze sector gears were found to have visible defects and cracks in the web area where they bolt to the steel drive sleeves. In one case, two of the bronze sector gear bolt holes had visible casting defects with cracks through the defective casting area. There are a total of ten Limitorque SMB-00 operators with HBC-3 drives in Unit The operability of the ten Un!.t 1 active valves which   ;
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utilize the Limitorque HBC-3 drives could have been compromised by the cracked sector gear, preventing the valve from performing the required safety function. The possible failure of these valves to perform their intended safety function during an accident condition represents a significant, deficiency which, were it to l l L__ .- - - - _ - _ _ - _ _ - . 

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remain uncorrected, could have adversely affected safe operation of the plan TU Electric has replaced the defective gears in the ten Limitorque operators which utilize HBC-3 drives in Unit Unit 2 activities will be conducted in accordance with the general construction schedule. The following table identifies work orders issued and the associated valve number of Unit 1 valve operators: Work Order N Valve N C-88-6135 1-HV-4286 C-88-6136 1-HV-4287 C-88-6137 1-HV-4512 C-88-6138 1-HV-4513 C-88-6139 1-HV-4514 C-88-6140 1-HV-4515 C-88-6141 1-HV-4524 C-88-6142 1-HV-4525 C-88-6143 1-HV-4526 C-88-6144 1-HV-4527 The NRC inspector has reviewed the work orders identified above for which corrective actions have been completed and concludes that TU Electric has adequately resolved this reportable construction deficiency. This SDAR is closed for Unit 1 onl . Piping and Pipe Supports (50090) While performing walkdowns during Hot Functional Testing (HFT), the NRC inspector identified the following areas of concern: A potential interference between crossover leg and a whip restraint structur A potential interference between stret paddle and stiff clamp bracket on Support RC-1-007-001-C41 Snubber transition / extension paddle is jammed against the back of a stiff clamp on Support RC-1-007-002-C41 Spring load column on Support RH-1-001-012-C415 is off center and potentially jammed against the spring housin , SWEC reviewed each of the above concerns and provided the following responses: SWEC Engineering Mechanics Division (EMD) was aware of and had evaluated this interaction. SWEC's evaluation concluded that this interaction will lead to some minor l l l -_ _ _ _ __ l 

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deformation'of'the insulation with no deleterious effect on piping thermal expansion and/or operation.- SWEC evaluated this conditionsand determined that 

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sufficient clearance existsito accommodate the predicted 0.5" anticipated piping movement. SWEC engineering 

    . committed, however, to monitor this support at various HFT plateaus and ensure that a. binding condition does not-develo SWEC verified that the condition, as described above, does exist. However, SWEC believes that due to essentially no piping movement (-0.07"/+0.05")-in the direction lateral to the piping that this condition is not detrimental to the piping or the suppor SWEC engineering will also monitor this support at various HFT plateaus to verify proper operation of this support.- SWEC verified that the spring is off center; however, in SWEC's opinion, based on review of the analysis and predicted thermal movements, the spring will function properly. SWEC Engineering will monitor this spring at v      the various HFT plateaus to verify proper. operatio Items b and c above are two cases of potential / actual binding conditions involving Nuclear Power Services, Inc. (NPSI)

hardware and special pipe clamps provided by Western Pipin SWEC Engineering has identified the following: Only fifteen special pipe clamps have been supplied by Western pipin Eleven of these clamps were removed and the supp;tts redesigned during design' validatio Two of these devices are addressed abov The remaining two clamps-were visually inspected by SWEC Engineering with the following results: 

     (1) RC-1-069-001-C41K - The Western Piping clamp has been replaced, due to a design change, with.an NPSI Superstiff clamp. The revised installation has been inspected by SWEC Engineering and found to be consistent with the revised drawing and no potential binding problem exist (2) CC-2-158-411-A43R - This support has been inspected by SWEC Engineering and found to be consistent with the design drawing and no potential binding problem !

exist l 

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The NRC inspector has reviewed the actions taken by.SWEC in response to-the stated concerns and finds that they were prompt and' fully' address-the potential safety concern No violations or deviations were identifie . Mechanical Components and Equipment (50073) During a plant tour, the NRC inspector identified two items of potential concern: On the Loop 1 steam generator upper lateral ring, one of the tie bars has a cotter pin that is not sprea The tie bars for the ring do not have locking devices on-the threaded connection In response to Item a. above, the applicant generated NCR 89-04514 to document and evaluate the as-found condition in light of the requirements of paragraph 6.1.17 of Specification 2323-MS-100. This paragraph states, in part, 

     -
 '"All removable supports and other ASME III, Subsection NF threaded fasteners shall be provided with locking
,

devices . . . . " For Item b. above, the applicant has requested that Westinghouse provide rationale for the tie bars not being_ provided with an approved locking device in accordance with ASME code requirement These items will remain unresolved pending NRC review of the disposition of the NCR and Westinghouse's position on locking requirements for the upper lateral ring tie bars (445/8927-U-01). plant Tours (50090, 50073) The NRC inspectors made frequent tours of Unit 1, Unit 2, and common areas of the facility to observe items such as housekeeping, equipment protection, and in-process work activities. No violations or deviations were identified and no items of significance were observe . Unresolved Items Unresolved items are matters about which more information is [ required in order to ascertain whether they are acceptable l items, violations, or deviations. One unresolved item disclosed during the inspection is discussed in paragraph ] { l l 

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$     18 9. Exit Meeting (30703)

An exit meeting was conducted May 2, 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 inspectio During this meeting, the NRC inspectors summarized the scope and findings of the inspection.

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