IR 05000445/1989028
| ML20246H392 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/09/1989 |
| From: | Livermore H, Norkin D Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20246H373 | List: |
| References | |
| 50-445-89-28, 50-446-89-28, NUDOCS 8905160080 | |
| Download: ML20246H392 (46) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION
NRC Inspection Report:
50-445/89-28 Permits: CPPR-126 50-446/89-28 CPPR-127 Dockets: 50-445 Category: A2 l
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 10 through April 21, 1989 Inspecto :
EAdddl 6 h~- 5'-6 on D. P. Norkin, Team Leader, Fire Protection Date NRC Consultants:
J. Birmingham, Quality Assurance J. Dale, Heating, Ventilation, Air-conditioning (HVAC), Cable trays / cable tray supports K.
Graham, Mechanical / Piping W. Richins, Civil Structural P. Stanish, Mechanical, Instrumentation and Controls (I&C), Conduit / conduit supports J. Taylor, El ctrical, I&C
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Reviewed by:
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5~ - 5'-- S H. H. Livermore, Lead Senior Inspector Date 8905160080 890509 PDR ADOCK 05000445 Q
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I Inspection Summary:
Inspection Conducted: April 10 through April 21, 1989 (Report 50-445/89-28; 50-446/89-28)
Areas Inspected: Team inspection of the
"Y" final acceptance attributes; i.e.,
those requiring physical validation under PCHVP.
For each Y attribute sampled, the NRC inspection team performed independent walkdowns and inspected the Field Verification Method (FVM), Attribute Evaluation Form (AEF) and associated documentation to: (1) confirm that the PCHVP validation properly implemented CPRT recommendations, (2) confirm that acceptance criteria have satisfactory design bases, (3) independently verify the accuracy of
data resulting from PCHVP engineering walkdowns and QC inspections,
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(4) confirm the acceptability of technical dispositions for
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Y attributes, and (S) determine whether PCHVP identified discrepancies were properly documented and resolved.
In addition, the NRC team performed a generic inspection of matters involving the appropriateness of choices between QC inspections vs.
engineering walkdowns and the adequacy of the training and qualifications of personnel conducting the PCHVP walkdowns and inspections.
Results:
Within the areas inspected, no violations or deviations were identified except for items identified prior to the Apri? 1989 NRC team inspection and documented in other NRC inspection refwrts.
For additional summary remarks, see paragraph 2.c.
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DETAILS 1.
Persons Contacted
- R. W. Ackley, Jr., Director, CECO
- L.
A. Ashley, Project Manager, Brown and Root (B&R)
- D.
P. Barry, Sr., Manager, Engineering, Stone & Webster Engineering Corporation (SWEC)
- J. W. Beck, Vice President, Muclear Engineering, TU Electric
- H.
D. Bruner, Senior Vice President, TU Electric
- H. M. Carmichael, Senior Project Quality Assurance (QA)
Manager, CECO, SWEC
- R.
A.
Cummings, Jr., Supervisor, Engineering Surveillance, TU Electric
- G.
L. Edgar, Attorney, Newman and Holtzinger
- J.
C. Finneran, Jr., Acting Manager, Civil Engineering, TU Electric
- C.
A. Fonseca, Deputy Director, CECO
- G.
E. Grabruck, Coordinator, (QA), Impell
- W.
G. Guldemond, Manager of Site Licensing, TU Electric
- J.
C. Hicks, Licensing Compliance Manager, TU Electric
- C. B. Hogg, Engineering Manager, TU Electric
- T. A. Hope, Licensing Supervisor, TU Electric
- 0. W. Lowe, Director of Engineering, TU Electric
- D.
P. Lowry, Senior Engineer, TU Electric
- F. Maggio, Manager, Systems Completion, SWEC
- S.
G. McBee, NRC Interface, TU Electric
- J. W. Muffett, Manager of Engineering, TU Electric
- E.
F. Ottney, Program Manager, CASE
- W. J. Parker, Project Engineering Manager, SWEC/ CECO
- S.
Palmer, Project Manager, TU Electric
- D. M. Reynerson, Director of Construction, TU Electric
- S.
F. Sawa, Assistant Project Manager, TU Electric
- P.
B.
Stevens, Manager, Electrical Engineering, TU Electric
- W. Syfrett, CPE-Elec., TU Electric
- C.
L. Terry, Unit 1 Project Manager, TU Electric
- W.
T. Tucker, Manager, Construction Support, CECO /SWEC The NRC inspectors also interviewed other applicant employees during this inspection period.
- Denotes personnel present at the April 13, 1989, exit meeting.
2.
Introduction and Summary a.
Background The PCHVP is the portion of TU Electric's Corrective
Action Program (CAP) which verifies that the safety-j related systems, structures and components are in compli-
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ance with the validated design.
This is accomplished by
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identifying final acceptance attributes for safety-related hardware and validating that those attributes meet design requirements.
Procedure ECE 9.04, " Control of the Post Construction Hardware Validation Program Manual," defines a final acceptance attribute as "an attribute that provides the basis, either in part or in i
whole, for the assurance that the installed hardware has satisfactorily implemented the design."
The input to the PCEVP is contained in the installation specifications which implement the licensing commitments i
and design criteria of the Design Basis Documents (DBD),
which were developed during the-CAP design validation process.
Final acceptance inspection requirements identified in the validated installation specifications were used to develop the PCHVP Commodity / Attribute Matrix (CAM), a set of final acceptance attributes identified for installed hardware.
The PCHVP, by either physical validations or through an engineering evaluation methodo-logy, assures that each of the attributes defined in the attribute matrix is validated.
Physical validation is performed by QC inspection or engineering walkdowns for accessible components.
The decision regarding the need for physical validation is based on whether:
(1)
The attribute was recommended for reinspection by the Comanche Peak Response Team (CPRT).
(2)
Design validation resulted in a change to design or hardware final acceptance criteria that are more stringent than the original acceptance criteria used by the CPRT, or the CPRT did not inspect the attribute.
(3)
Design validation resulted in new work, including modification to existing hardware.
If the CPRT made no recommendation for reinspection and items 2 or 3 above do not apply, the attribute under consideration is accepted without reinspection.
If any of the three statements above are true, a determination is made as to whether the attribute is accessible.
If the attribute is accessible, a field validation of the item's acceptability is performed and documented in accordance with an approved FVM.
If the attribute is inaccessible, an engineering evaluation is conducted by technice.1 disposition of available information.
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b.
Method of Review NRC Inspection Report 50-445/89-14; 50-446/89-14 focused on attributes that were not physically validated either due to satisfactory CPRT findings or generic inaccessi-bility of the attribute (N and N-TD attributes).
The inspection also evaluated installation specifications and design related documents to determine whether all required attributes were identified by the CAM.
The current inspection focused on the Y final acceptance attributes; i.e.,
those requiring physical validations under PCHVP.
The NRC team inspection occurred during the April 10 through April 21, 1989, time period.
However, prior to that period, individual team members had separ-ately inspected Y attributes and FVMs.
These inspections are covered in NRC inspection reports which are refer-enced in subsequent sections of this report.
Significant violations identified in these prior inspection reports are summarized in the current inspection report.
Details from the earlier inspections pertaining to FVMs and attributes are included in the below statistics for the number of Y attributes sampled.
The team reviewed a sample of approximately 42% of the Y attributes.
The sample is broken down as follows:
Total No.
Ys Reviewed Commodity of Ys by NRC Mechanical / Fire Pro-tection Equipment 194
Piping / Pipe Supports 183
Civil / Structural
64 Electrical 108
Electrical Raceways / Supports 188 162 Total 1157 488 For each Y attribute sampled, the NRC team performed inspections in order to verify the accuracy of data resulting from PCHVP engineering walkdowns and QC inspections.
In addition, the NRC team inspected FVMs
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and AEFs and associated documentation in order to confirm that PCHVP walkdowns'properJy implemented CPRT. recommend-
.ations and that acceptance criteria had satisfactory design bases.
The NRC team evaluated technical disposi-tiens pertaining to Y attrib 2tes for which some portion of.the population was not physically validated either due to inaccessibility or on the basis of satisfactory results for the portion of the population that was physically. validated.
The NRC team also reviewed noncon-formance reports (NCRs) and associated documentation to determine whether PCHVP identified discrepancies were documented and resolved adequately.
In addition to the above inspection items for each attribute, the NRC team performed a generic inspection pertaining to the decision process for QC inspections vs.
engineering walkdowns; i.e., which is more appropriate for ensuring that a specific attribute is properly validated.
The generic inspection also addressed the training and qualifications of personnel conducting the PCHVP walkdowns and inspections.
c.
Summary of Results This NRC team inspection resulted in no open items or unresolved items pertaining to the PCHVP.
However, the report summarized significant violations and unresolved items pertaining to PCHVP which are documented in previous NRC inspection reports.
These issues may be grouped in the following general categories:
(1)
Failure of PCHVP inspections to be performed properly or to identify nonconforming conditions.
(2)
Failure to document nonconforming conditions with an
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NCR or to properly evaluate NCRs or to ensure that
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NCR dispositions were properly implemented.
(3)
Failure to document inaccessible attributes (e.g.,
with an NCR) or to perform technical dispositions for inaccessible attributes in accordanra with appropriate procedures.
Given the magnitude of NRC inspections of PCHVP, the above categorized violations and unresolved items do not indicate any adverse trends.
The NRC team reviewed these categories as well as others pertaining to PCHVP physical validations, and generally concluded that PCHVP was being implemented effectively.
The scopes of reinspection were consistent with CPRT recommendations when appli-cable.
Applicable acceptance criteria had satisfactory I
design bases.
Independent NRC verifications
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generally confirmed the PCHVP physical validations.
Technical dispositions were acceptable for Y-TD cases where portions of the population were not physically validated.
Discrepancies identified by reinspection were appropriately documented by NCRs.
Finally, the NRC team found that decisions were appropriate regarding the
choices of either engineering walkdowlis or QC inspections a
and that involved personnel were properly qualified and i
trained relative to the specific FVMs.
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Conduit and conduit Supports Train A and B and Train C larger j
than 2" in diameter (48053)
FVM-CS-033:
" Design Control of Electrical Conduit Raceways for Unit 1, Installation in Unit 1 and Common Areas" FVM-CS-014:
" Design Control of Electrical Conduit Raceways for Unit 2, Installations in Unit 1 and Common Areas" i
e Results of the Independent Assessment Program (IAP) performed
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by Cygna Energy Systems (Cygna) and other external source
issues were consolidated into 29 specific issue groups which were required to be addressed for conduit and conduit supports for Train A and B, and Train C conduit greater than 2" in
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diameter.
Also, CPRT had one additional Quality of Construction (ISAP III.c) issue.
The FVMs listed above encompassed the inspection of the following commodities and associated attributes:
No. of NRC No. of Reviewed Commodity Attributes Attributes Conduit supports
41 Conduit system
23 During the course of the NRC inspection efforts, the walkdown t
data collected for all of the attributes listed above were reviewed in detail.
The NRC inspection effort included
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detailed inspection of 60 conduit runs and the associated l
supports.
These inspections are documented in the following
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NRC Inspection Reports:
50-445/87-16; 50-446/87-13
50-445/87-18; 50-446/87-14 50-445/87-25; 50-446/87-19 50-445/87-31; 50-446/87-23 50-445/87-35; 50-446/87-26 50-445/88-05; 50-446/88-04 l
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In Ebasco's performance of the above'FVMs, they identified three inaccessible attributes for which a technical disposition was performed.
These attributes were:
Bolt type.
Bolt embedment length.
Base plate thickness.
Ebasco's technical disposition for these attributes is-documented in a position paper entitled " Position Paper on Design Reconciliation of Seismic Calculation Packages (Train A, B, and Train C > 2" diameter)."
The position paper addresses these attributes by a review of 822 calculation-packages in which 4100 supports were evaluated.
Based on the fact that all the inaccessible attributes within the popula-tion sampled are being resolved by analysis in the most conservative manner in accordance with the design procedures of Appendix K of Procedure SAG.CP35, Ebasco concluded that no condition adverse to safety exists due to the inaccessibility of these specific attributes.
In the NRC inspections, violations relative to the accuracy of the as-built data were identified.
The applicant, in response to the violations, performed a survey of completed work, which identified a low error rate, and concluded that the evaluation methods being used had sufficient conservatism to tolerate the low error rate.
The NRC team concurs with the applicant's conclusions regarding inaccessible attributes and the accuracy of the as-built data, and based on the documented PCHVP inspection feels that these FVMs have been adequately implemented.
4.
Conduit and Conduit Supports Train C (2" diameter and less)
(48053)
FVM-CS-095:
"As-built Field Verification Method for Train C Conduit Program" No. of NRC No. of Reviewed Commodity Attributes Attrihutes Train C Conduit
40 2" diameter and less.
An inspection of the Train C conduit system was conducted as part of the NRC Technical Review Team (TRT) activity in 1984.
The inspection identified an issue (TRT Issue I.c documented in Supplemental Safety Evaluation Reports (SSERs) No. 7 and No. 8) that the support installation for nonsafety-related conduit less than or equal to 2 inches in diameter may be
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The Comanche Peak Response Team.(CPRT)
' developed Issue-Specific' Action Plan (ISAP) I.c to address this, issue and to assess compliance with regulatory. require-ments and' licensing commitments.
The applicant initiated a comprehensive seismic qualification program in order:to bring Train C conduit into compliance with the FSAR and licensing commitments.
The CPRT had nco specific corrective action recommendations for Train'C ecnduit.
This FVM encompassed the inspection of a single commodity (Conduit Train "C" [2" diameter and less]) and 40 individual attributes.
During the course of the its' inspection efforts, L
the NRC reviewed the walkdown data collected by Impell.for all of the individual attributes for Train C conduit 2" diameter and less.
These inspections are documented in the following
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NRC Inspection Reports:
50-445/87-16; 50-446/87-13 50-445/87-18; 50-446/87-14 50-445/87-25; 50-446/87-19
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50-445/87-31; 50-446/87-23
50-445/87-35; 50-446/87-26 50-445/88-11; 50-446/88-09 In the above NRC inspection reports, the NRC inspector identified a concern relative to the adequacy and accuracy of the data being collected by Impell's walkdown personnel.
This concern was documented in several deviations.
The applicant's response to these deviations was to correct the specific deviating conditions and to perform a review of completed walkdowns.
The results of this-review identified a low error rate which had no adverse impact on the overall acceptability of the installed conditions.
The NRC team concurred with the applicant's assessment for this issue.
During the performance of the walkdowns for this FVM, Impell encountered and documented examples of attributes which were inaccessible.
NRC review of the documentation identified that the reasons for inaccessibility were mainly due to the conduit system being covered by fire protection material and/or the existence of physical barriers.
The team also reviewed the methods utilized to resolve these, items.
Typically, the way these items were addressed was to make conservative assump-tions (i.e., structural function of an inaccessible attribute was ignored in the evaluation of the corresponding Train C conduit system, minimum lengths were assumed for Hilti' bolts with inaccessible letter stamp, etc.).
In conclusion, the NRC team is satisfied that FVM-CS-095 has been adequately implemented and will provide reasonable assurance that the installation of Train C conduit and supports will not compromise the safe operation of the plant.
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5.
Cable Trays and Cable Tray supports (48053)
Cable tray and cable tray support issues are identified in Supplemental Safety Evaluation Report No. 15 and the Project Status Report for " Cable Tray and Cable Tray Hangers," and were also addressed in several CPRT ISAPs to assess compliance with regulatory requirements and licensing commitments.
FVM-CS-001:
" Field Verification Method Unit 1 Cable Tray Hanger As-Builting and Design Adequacy Verification Program" No. of NRC No. of_
Reviewed Commodity Attributes Attributes Cable tray and cable tray hangers.
58 The commodity " Cable Tray and Cable Tray Hangers" includes a total of 58 attributes.
The NRC inspector has reviewed a total of 58 of the 58 attributes.
CPRT Recommendations The scope of the cable tray hanger portions of FVM-CS-001 includes the CPRT recommendations for cable tray supports.
The NRC inspector reviewed the attribute matrix and concluded that the CPRT recommendations are correctly implemented for FVM-CS-001.
Acceptance Criteria Acceptance criteria for FVM-CS-C01 are contained in DBD-CS-082 and TU Electric. Engineering Procedure ECS-5101.
The NRC inspector reviewed the acceptance criteria and concluded that these criteria are correctly implemented in FVM-CS-001.
Independent Data Verification The NRC inspection team independently verified the PCHVP walkdowns for all attributes and documented the results of these inspections in the following inspection reports:
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50-445/85-19 50-445/87-06; 50-446/87-05 50-445/87-09; 50-446/87-07 50-445/87-11; 50-445/87-09 50-445/87-13; 50-446/87-10 50-445/87-16; 50-446/87-13 50-445/88-11; 50-446/88-09 50-445/88-20;-50-446/88-17 i
50-445/88-32; 50-446/88-28 50-445/88-81; 50-446/88-77 Discrepancy Resolution Major discrepancies were reconciled in the following four step manner.
This reconciliation also resolved any inaccessible attributes; e.g., by using conservative values in analyses.
a.
Establish the input for the cable tray and cable tray hanger analytical models.
b.
Evaluate the design of cable trays and cable tray hangers including cable tray fittings and cable tray clamps.
c.
Review the results of. step b and identify if the design criteria were satisfied. LIf the analysis results did not satisfy the design criteria, the hardware was modified to conform to the design criteria.
d.
Consolidate analysis, hardware modification and inspection documentation to assure consistency of the cable tray and cable tray hanger design documentation with the hardware installation.
The first step in the design validation process of the cable
tray hanger CAP was to obtain as-built information (design
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attributes) for the cable tray systems at CPSES Unit 1 and i
common.
The as-built information necessary to verify compliance with design criteria was obtained by walkdowns conducted by experienced applicant personnel trained in accordance with walkdown procedures.
The results were used to create as-built drawings of the cable tray and cable tray hangers.
To provide additional assurance of the accuracy of the as-built drawings, TU Electric QC personnel verified these drawings to the as-built hardware in accordance with approved QC procedures.
The cable tray and cable tray hanger as-built inspections provided the necessary data to determine the cable tray layout and cable tray hanger configuration.
As-built inspections identified the length of cable tray spans, cable tray hanger identification numbers, cable tray hanger orientation, and cable tray end locations.
In cases where cable tray and cable
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. tray hanger design attributes were inaccessible as a result of congestion and/or the presence of fire protection material, these inaccessible design attributes are noted by engineering walkdown personnel as "IA" on the cable tray hanger as-built drawings.
Cable tray hanger modifications resulting from the design validation effort were incorporated into the final as-built j
drawings.
The modified hanger was then reinspected by QC for j
final validation.
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The NRC team concluded that the above discrepancy resolution process provides adequate assurance that the design conforms to design criteria and that the hardware correctly implements the design.
Summary of significant Violations No significant violations were identified by the NRC.
6.
HVAC (50100)
HVAC issues are identified in Supplemental Safety Evaluation
i Report No. 18 and TU Electric CAP Project Status Report for heating, ventilation and air-conditioning, and were also J
addressed in ISAP VII.c to assess compliance with regulatory requirements and licensing commitments.
FVM-CS-029:
" Procedure for Seismic HVAC Duct and Duct Hanger As-built verification in Unit 1 and Common Areas" Commodities / Attributes No. of NRC No. of Reviewed Commodity Attributes Attributes HVAC Ducts
54 HVAC Supports
63 CPRT Recommendation:
FVM-CS-029 was developed to identify violations relating to member size, configuration, weld discontinuities, member attachment, etc.
Between October 1986 and June 1987, TU Electric released both the HVAC engineer of record and the HVAC general contractor.
Subsequently, all engineering calculations were reevaluated and any and all required changes added to the required work packages and drawings.
The scope of FVM-CS-029 addresses the CPRT recommendations and the deficiencies identified by the applicant, the NRC, and the Corrective Action Program.
The NRC inspector reviewed the
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attribute matrix and concluded that the CPRT recommendations were implemented by FVM-CS-029.
Acceptance Criteria Acceptance criteria.for FVM-CS-029 are contained 11n Specification 2323-MS-085 and Design Basis Document (DBD)-CS-086.
The NRC inspector reviewed the acceptance criteria for FVM-CS-029 and conclude?
h these criteria are correctly implemented by FVM-CS-02 Independent Data Verification The NRC inspection team independently verified the PCHVP walkdown for all attributes; the results of these inspections can be found in the following inspection reports:
50-445/87-02; 50-446/87-02 50-445/87-06; 50-446/87-05 50-445/87-13; 50-446/87-10 50-445/87-16; 50-446/87-13 50-445/87-18; 50-446/87-14 50-445/87-25; 50-446/87-19 50-445/87-31; 50-445/87-23 50-445/87-35; 50-446/87-26 50-445/88-05; 50-446/88-04 50-445/88-11; 50-446/88-09
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50-445/88-56; 50-446/88-52 50-445/88-65; 50-446/88-61 50-445/88-75; 50-446/88-71 50-445/89-11; 50-446/89-11 50-445/89-19; 50-446/89-19 Discrepancy Resolution The PCHVP balkdown for HVAC identified.at least two discrepancies of general concern.
The first concerned the use of TREMCO 440 gasket material.
This particular gasket material was found to roll.out from between hem flanges after a period of time; however, this item was satisfactorily
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resolved by removing it from the hem flanges on safety-related material or using a companion angle flange.or a Vanstone flange.
The NRC inspector agrees with this resolution.
The second example (see NRC Inspection Report 50-445/88-75; 50-446/88-71) involves the welding of flanges or parts of flanges with the gasket material installed.
The NRC inspector could find no indication that TU Electric had evaluated the molecular change that takes place when the rubber gasket is subjected to an intense mmount of heat input.
Further, the
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NRC inspector could find no indication of how this change might change the life expectancy of the gasket.
The
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applicant's resolution of this issue is being tracked by NRC Open Item 445/8875-o-03.
Summary of Significant Violations i
No significant violations were identified.
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7.
Civil-Structural (46053, 46055, 46071, 48053 48055)
a.
FVM Number:
CPE-SWEC-FVM-CS-075, Revision 3, July 25, i
1988, " Concrete Attachments in Unit 1 and Common Safety Related Structures."
Commodities / Attributes No. of NRC No. of Reviewed Commodity Attributes Attributes Concrete Anchorage
4 Embedded Bolts Concrete Anchorage
9 Embedded Steel Concrete Anchorage
3 Hilti Bolts CPRT Recommendations FVM-CS-075 was developed to identify concrete attachment spacing violations based on requirements presented in Specification 2323-SS-30.
Concrete surfaces (beams, walls, columns, etc.) were selected and the locations of various concrete attachments were detailed on as-built drawings.
Potential concrete attachment spacing violations were then identified using computer methods and additional field spacing measurements were made.
Confirmed spacing violations were evaluated using actual loading conditions for safety significance.
The scope of FVM-CS-075 includes the CPRT recommendations for ISAP VII.b.4 regarding Hilti bolt spacing and deficiencies identified by the applicant, CYGNA, the NRC, and the Corrective Action Program.
The NRC inspector reviewed the attribute matrix and concluded that the CPRT recommendations were implemented by FVM-CS-075.
Acceptance Criteria Acceptance criteria for FVM-CS-075 are contained in Specification 2323-SS-30 and Design Base Document l
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DBD-CS-015.
The'NRC inspector reviewed the acceptance criteria ~for FVM-CS-075 and concluded that these criteria
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were correctly implemented by FVM-CS-075.
Independent Data Verification / Technical Dispositions /
Discrepancy Resolution FVM-CS-075 evaluated Hilti bolts, Richmond inserts (used and unused), Nelson studs for embedded plates and shapes, grouted-in bolts, embedded bolts, and through-bolts, all referred to collectively as concrete embedments.
The applicant segregated the concrete surfaces population into.two categories:
(1) walls and' slabs consisting of 5265 surfaces, and (2) beams and columns-consisting of 1659 surfaces.
A total of 53 surfaces consisting of 22 walls / slabs and 31 beam / columns were evaluated using 423 field as-built sketches prepared by field engineering personnel.
The sketches identified 9017. concrete embedments.used for 3088 supports-(Category I, II and nonsafety related).
All spacing violations were identified and evaluated in 53 calculations using current requirements and 49 NCRs were generated.
Stone and Webster Engineering Corporation (SWEC) obtained actual loads for each concrete embedment deviating from specification requirements.
The 53 calculations were prepared to document that the factor of safety for each embedment meets or exceeds the requirements of DBD-CS-015.
The applicant issued Project Technical _ Report (PTR)-03, Revision 0, " Evaluation of Seismic Category I and II i
Concrete Embedments" dated February 10, 1989.
PTR-03 summarizes the historical background of deficiencies identified in Specification 2323-SS-30, and the changes made to Specification 2323-SS-30 and DBD-CS-015 to provide controls for in-process and future concrete embedment installation activities.
In addition, PTR-03 describes the implementation and results of FVM-CS-075 which addressed concrete embedments installed prior to the above changes to Specification 2323-SS-30 and DBD-CS-015.
PTR-03 provides the technical justification'for not completing 100% of the FVM-CS-075 activities and concluded that:
"The completed evaluations provide sufficient data to assess the condition of the existing CPSES Seismic Category I and II concrete embedments.
The evaluations performed to date provide a 99% confidence level.
..
that the current design loads for at least 99.8% of the Sejsmic Category I and II concrete embedments in the i
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unexamined balance of the plant will provide the required factor of safety."
Based on the results of FVM-CS-075 from evaluating the c
'53 surfaces sampled, FVM-CS-075 activities were closed by
"
the applicant.
'
The NRC inspector previously performed field inspections of completed as-built drawings for one beam, two columns, and two wall surface packages.
The NRC inspector also reviewed: (1) the calculations for each of-the above.
packages which identified and. evaluated concrete attach-ment spacing violations, (2) the computer program and methods used to identify the spacing violations,=and (3) the conclusions reached by the applicant.
Based on the NRC inspection activity summarized above and review of PTR-03,~the NRC inspector concluded that the FVM-CS-075 program was developed and implemented in an
. effective manner and adequately identified concrete attachment spacing violations.
The NRC inspector also agreed with the technical justification provided in PTR-03 for closing FVM-CS-075 activities.
Summary of Significant Violations No violations were issued for this inspection activity.
References NRC inspections of FVM-CS-075 activities are documented in the following NRC. inspection reports:
50-445/88-42; 50-446/88-38 50-445/88-50; 50-446/88-46 50-445/88-58; 50-446/88-54 50-445/88-76; 50-446/88-72 50-445/88-82; 50-446/88-78 50-445/89-05; 50-446/89-05 50-445/89-11; 50-446/89-11 50-445/89-19; 50-446/89-19 b.
FVM Numbers:
CPE-SWEC-FVM-EE/ME/IC/CS-086, Revision 4, July 15, 1988, " Quality Control Reverification";
CPE-SWEC-FVM-EE/ME/IC/CS-089, Revision 4, July 29, 1988,
" Engineering Walkdowns"; CPE-SWEC-FVM-EE/ME/IC/CS-090, Revision 6, January 20, 1988, " Quality Control Reinspection."
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c
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Commodities /Attributas No. of NRC No. of Reviewed Commodity Attributes Attributes Pipe Whip Restraints
12 Structural Steel-General
23 Structural Steel-Bolting
9 Containment Liner-Overlay
'
Plates and Attachments
4 CPRT Recommendations The scope of the civil / structural portions of FVM-086, FVM-089, and FVM-090 includes the CPRT recommendations for ISAPs VII.c - bolting and VII.c - structural steel.
The NRC inspector reviewed the attribute matrix and concluded that the CPRT recommendations were implemented.
Acceptance Criteria Acceptance criteria for the civil / structural portions of FVM-086, FVM-089, and FVM-090 are contained in Specification 2323-SS-16B.
The NRC inspector has reviewed the acceptance criteria.and concluded that these criteria were correctly implemented by the civil /
structural portions of the above FVMs.
i Independent Data Verification / Technical Dispositions /
Discrepancy Resolution i
The NRC inspector previously performed field inspections of the following PCHVP packages:
Containment liner-overlay plates and attachment packages.
Pipe whip restraints.
Loaded embedments.
j
Watertight doors.
Structural framing for monorails.
Seismic wall angles.
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Removable block wall supports.
Platforms.
During the course of these NRC inspection efforts, the engineering walkdown data and QC inspection of all applicable attributes were reviewed in detail.
In all cases, discrepancies identified by the applicant were addressed on NCRs.
All dispositioned NCRs were reviewed in detail by the NRC inspector.
All specific cases where an attribute was determined by the applicant to be inaccessible during inspection of the above packages were.
verified by the NRC inspector.
Examples of attributes inaccessible for individual components reviewed by the NRC inspector are:
Containment liner overlay
. plates and attachments - location.
Structural steel general - concrete anchorage Richmond inserts, bolt i
'
engagement.
Structural steel general - connection component, edge distance and spacing Structural steel bolting - washers installed where required by drawings.
Structural steel general - welding length.
The NRC inspector concluded that the technical dispositions for the inaccessible attributes for individual components were acceptable.
Based on the NRC activity summarized above and in the NRC inspection reports listed as references, the NRC inspector concluded that the civil / structural portions of FVM-86, FVM-89, and FVM-90 are being implemented in an effective manner.
Summary of Significant Violations and Unresolved Items The NRC inspector identified three violations (currently closed) and one significant unresolved item (currently
!
open) during the NRC field inspections of the civil /
structural portions of the FVM-86, FVM-89, and FVM-90 activities performed to date:
445/8858-V-02:
This violation addressed the failure of PCHVP to inspect a safety-related watertight door for location, orientation, and site-installed weld size, length, and location.
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445/.8870-V-03:
This violation addressed the failure of a PCHVP inspection report to identify a base metal gouge in an embedded plate.
445/8864-V-02:
This violation addressed welds that were not installed in accordance with applicable drawings on the support structure for four pipe whip.
restraints.
445/8905-U-02:
This unresolved item addresses concerns with the adequacy of QC inspection for structural steel platforms.
References NRC inspections of the civil / structural portions of FVM-86, FVM-89, and FVM-90 are documented ~in the
,
following NRC inspection reports:
)
Structural Steel (General and Bolting)
50-445/88-58; 50-446/88-54 50-445/88-64; 50-446/88-60 50-445/88-70; 50-446/88-66 50-445/88-76; 50-446/88-72 50-445/88-82; 50-446/88-78 j
50-445/89-05; 50-446/89-05 50-445/89-11; 50-446/89-11 50-445/89-19; 50-446/89-19
,
Pipe Whip Restraints i
50-445/88-64; 50-446/88-60 l
50-445/88-70; 50-446/88-66
'
50-445/88-76; 50-446/88-72 50-445/89-11; 50-446/89-11 Containment Liner - Overlay Plate s and Attachments 50-445/89-05; 50-446/89-05 8.
Piping and Pipe Supports (49063, 49065, 50090, 500751 FVM Number:
CPE-SWEC-FVM-PS-081, " Hardware Validation and Supplemental Inspection Program," Revision 1, June 28, 1988 The following table identifies commodities requiring PCHVP
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reinspection, the total number of attributes associated with the commodity which are validated by reinspection in accordance with FVM-PS-081, and the total number of attributes I
for which NRC inspectors verified the accuracy of PCHVP reinspection results.
NRC verification of compliance with
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PCHVP reinspection requirements was accomplished by NRC inspectors performing hardware-inspections of the installed commodities and documentation reviews of Construction Operation Travelers which implemented PCHVP reinspection and rework requirements.
No. of Attributes No. of NRC Requiring PCHVP Reviewed commodit?
Reinspection Attributes Pipe Support U-Bolt and Guide
3 Pipe Support Variable /
Constant Springs
11 Piping and Inline Components
6 Pipe Support Bolted Connections
6 Pipe Support Hilti Bolts
5 Pipe Support Pipe Clamps
6 Pipe Support Snubbers
13 Pipe Support Welds
3 Pipe Support General
23 Pipe Support Sway Struts
11 i
Pipe Support Concrete Anchorage-Richmond Inserts
1 CPRT Recommendation The CPRT developed the CPRT Commitment Tracking Report (CTR)
to provide a complete summary of CPRT recommendations.
The CTR identifies the source document (e.g., ISAP VII.c, Appendix 25), a description of the CPRT reinspection that resulted in corrective action requirements, an action statement summary specifying the required corrective action, related documents / commitments, and status of CPRT concurrence with TU Electric's methodology for implementing the CPRT recommendation.
NRC Inspection Report 50-445/88-10; 50-446/88-08 documents NRC inspection of the validity and accuracy of the CTR.
NRC inspection consisted of comparing CPRT recommendations, which l
are documented in the ISAP Results Reports, with
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recommendations documented by'the CTR.
A total of 10 ISAP
' Result Reports were reviewed.
In all cases, the reviewed CTR was found to completely and accurately describe CPRT recommendations.
The NRC inspection team reviewed 20 AEFD to ensure that CPRT recommendations were being implemented by.the FVM.
These AEFs for-which PCHVP reinspection had been~ determined to be required had been approved by SWEC and CPE.
AEFs were reviewed for Attributes 934, 929, 931, 1444, 994, 980, 997,.
950, 947, 955, 1015, 672, 979, 659, 755, 1298, 1300, 1301,.
761, and 792.
The NRC team found that the reinspection requirements were properly implemented by.FVM-PS-081.
Acceptance criteria FVM-PS-081 delineates acceptance criteria for PCHVP reinspection by providing reference to the quality control and engineering procedures.
NRC inspection of the adequacy and appropriateness of.PCHVP reinspection criteria was evaluated during field inspections and documentation reviews of completed PCHVP reinspection results.
This was accomplished by comparing the reinspection criteria with inspection criteria contained in current revisions of Specification 2323-MS-100, " Field Fabrication and Erection of Piping and Pipe Supports," and applicable quality control procedures identified by FVM-PS-081.
NRC inspection did not identify any discrepancies during those reviews.
Independent Data Verification NRC verification of PCHVP' reinspection results consisted of a methodology whereby NRC inspectors obtained copies of completed-PCHVP reinspection results and performed independent field inspection of the installed commodity.
NRC verification of reinspection attributes included, but was not limited to, all attributes for which CPRT recommended mandatory reinspection.
Other reinspection attributes which were necessary for SWEC's Stress Requalification Program were also reviewed by NRC inspectors.
In. addition to the independent field inspections, the NRC inspectors also reviewed the permanent installation records for completeness, accuracy, and compliance with design procedures and specifications, installation procedures and specifications, and quality control' inspection procedures.
Further, NRC plant tours have identified violations which resulted in PCHVP enhancements.
The following table provides descriptions of independent NRC inspections which addressed PCHVP commitments, relative to piping and pipe supports, which were performed between June 1987 and the present:
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NRC Inspection Activity NRC Report No.
Installation inspection / documentation 50-445/87-11 review of large bore and small bore 50-446/87-09 pipe support installations.
Installation inspection / documentation 50-445/87-13 review of large bore pipe support 50-446/87-10 installations; in-process inspection of new support installatlans.
Installation inspection / documentation 50-445/87-18 review of small bore pipe support 50-446/87-14 installations.
Reinspection of coated welds, with and 50-445/87-25 without coatings, to validate CPRT 50-446/87-19 results concerning weld quality.
Review of quality instructions and 50-445/87-31 installation specifications related 50-446/87-23 to piping and pipe supports.
Review of CAP for large bore and 50-445/88-C, small bore piping and pipe supports.
50-446/88-04 Installation inspection of small bore 50-445/88-11 pipe supports, installation inspection /
50-446/88-09 documentation review of piping installation.
Surveillance inspection of ultrasonic 50-445/88-20 testing of pipe bends; review of 50-446/88-17 technical audit program (TAP)
surveillance.
Installation inspection / documentation 50-445/88-32 review of piping installation.
50-446/88-28 Hydrostatic test of replacement piping.
50-445/88-37 50-446/88-35 Review of vendor certified drawing (VCD)
50-445/88-51 control and issuance.
50-446/88-47 Review of welding processes for rework 50-445/88-56 and replacement of pipe support 50-446/88-52 commodities.
Room / area inspection of piping and pipe 50-445/88-65 support installations.
50-446/88-61
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f Review of design calculations for pipe 50-445/88-71 supports.
50-446/88-67 Review of TAP audits; design calculation 50-445/88-75 review.
50-446/88-71 Review of installation specifications, 50-445/88-81 QC procedures, and engineering training 50-446/88-77 records.
Room / area inspection of piping and pipe 50-445/89-06 support installations.
50-446/89-06 Room / area inspection of piping and pipe 50-445/89-12 support installations.
50-446/89-12 The NRC inspections identified in the preceding table provide a comprehensive evaluation of PCHVP piping and pipe support reinspection activities.
Although NRC inspection of reinspection requirements is not complete, the NRC inspection team concludes that, with the exception of violations which remain open at the end of this report period, PCHVP is being properly implemented and, when completed, should satisfactorily resolve all reinspection requirements for the piping and pipe supports.
Summary of significant violations The following table identifies and summarizes violations of 10 CFR Part 50, Appendix B requirements which were identified by NRC inspectors during verification of PCHVP reinspection requirements in accordance with TU Electric's CAP.
Closure Docket No.
Status Description 445/8716-V-12 Closed A pipe support had missing parts (cotter pins) although PCHVP reinspection was complete.
445/8718-V-08 Closed Nonconforming material was not l
documented with an NCR.
445/8718-V-09 Closed QC inspection failed to document an inaccessible inspection at-tribute with an NCR which pre-cluded a technical disposition of the attribute.
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445/8820-V-01; Closed Methodology for performing 446/8817-V-01 ultrasonic testing (UT) re-sulted in QC inspector's re-cording incorrect dimensions.
445/8820-V-02; Closed QC inspector applied unapproved 446/8817-V-02 material to stainless steel pip-H ing during UT inspection.
445/8832-V-01 Closed Improper evaluation of commodity clearance violations documented by nonconformance reports.
445/8856-V-01 Closed Nonconforming material was not replaced in accordance with NCR disposition; NCR was closed.
445/8871-V-04 Open Procedures controlling process-ing of technical dispositions for inaccessible attributes we e inappropriate.
445/8871-V-02 Closed PCHVP reinspection failed to properly validate thread engage-ment on a spring hanger assembly 445/8871-V-03 Open Design control procedures failed to identify that a commodity (pipe clamp) was not suitable for its intended function.
445/8706-V-02 Open Unauthorized work or inadequate inspection resulted in a pipe support deviating from design documentation requirements.
445/8912-V-01 Open Pipe support snubbers were found to be installed with low strength bolting that could have been overstressed if subjected to the maximum allowable design load.
445/8912-V-02 Open For 20 design calculations, inadequate cesign review re-sulted in uncorrected calcula-tion errors.
445/8912-V-03 Open For 23 pipe supports, inadequate PCHVP reinspection had been performed.
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~9.
Fire Protection (64053)
a.
FVM Number:
CPE-IM-FVM-FP-093, Revision 1, September 23, 1987, " Final As-Built Verification of Unit 1 and-Common Portable Fire Extinguishers Mechanical Commodities."
Commodities / Attributes No. of NRC l
No. of Reviewed.
l Commodity Attributes Attributes Fire Extinguishers
1 CPRT Recommendation-l CPRT did not inspect the attributes for the fire extinguisher commodity.
Acceptance Criteria Section 9.5.1.4.2.2.e of the CPSES Final-Safety Analysis i
Report states that " Portable fire extinguishers are~
provided for fire suppression throughout the plant.
The
quantity and type of extinguishers located in each fire
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area are based on the type, quantity, and specific hazard j
conditions in the respective fire areas.
All extinguishers are in accordance with the guidelines of NFPA pamphlet NO.10."
During design validation, calculation 0210-063-0013, Revision 2, was issued to validate fire extinguisher design ~ aspects against applicable NFPA requirements.
This calculation was based on field data obtained'by
'
l means of CPE-FVM-FP-043, " Fire Hazards Analysis - Fire Protection Features / Deviation Requests Walkdown."
Design requirements such as classification, size, and type of fire extinguisher in each fire area were based on calculated combustible heat release loadings.
Specification 2323-MS-38D, " Portable Fire Extinguishers,"
was revised via DCA 25,348, Revision 2, to provide a baseline for PCHVP activities.
I The NRC team agreed with'the process for establishing the i
portable fire extinguisher acceptance criteria.
I
Independent Data Verification PCHVP walkdowns were conducted and documented in
!
accordance with CPE-IM-FVM-FP-093, which included taking credit for field walkdowns conducted earlier under CPE-FVM-FP-043.
The NRC team independently verified the I
l l
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PCHVP walkdowns for Attribute 493, " classification," in the auxiliary building.
Specifically, the NRC team examined extinguishers in room 207 at locations / mounts EA/7.1A (HSW) and EA/7.1A (Wall) and determined their classifications to be 80BC and 2A:40BC, respectively, as required by the acceptance criteria.
The NRC team, therefore, concludes that the PCHVP walkdowns accurately validated extinguisher classifications.
Discrepancy Resolution The PCHVP walkdown documentation for Attribute 493 indicates that ten portable extinguishers had classifi cations contrary to those specified.
NCR 88-09027 was originated to resolve these discrepancies; two of these ten were later transferred to NCR 88-13320.
Two of the extinguishers were replaced to conform with specified classifications.
Two were reverified in the field to have the specified classification.
For the remaining six, the nonconforming condition was resolved by either correcting typographical errors for the specified classi-fications or determining that the installed extinguishers exceed specified requirements or determining that Class A fire protection (not provided as required) can be pro-vided by adjacent hose stations.
The NRC team concluded that these discrepant conditions were acceptably resolved.
i b.
FVM Number:
CPE-IM-FVM-FP-094, Revision 2, December 1, 1987, " Final As-Built Verification of Unit 1 and Common Fire Suppression Systems Mechanical Commodities."
Commodities / Attributes No of NRC No. of Reviewed Commodity Attributes Attributes FP Halon Equipment
0 l
FP Halon Nozzles
0 FP Hilti Bolts
0 FP Hose Cabinet
1 FP Pipe and Fittings
1 FP Sprinklers and Nozzle
1 l
FP Supply Valves
1
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FP Atmospheric Clean-up Units
0 FP Structural Steel
6 CPRT Recommendation CPRT did not inspect the attributes for the fire suppression systems mechanical commodities.
Acceptance Criteria Attribute 533, " Hose Cabinet - Orifice Plate Size" Section 9.5.1.6.1.E.3.d of the CPSES FSAR states that NFPA 14, " Standpipe and Hose Systems," was used as guidance for the installation of interior manual hose stations.
NFPA 14, Section 4-7.1, states that devices must be installed to reduce the pressure with required flow at the outlet to 100 psi.
This requirement was reflected in Specification 2323-MS-38C, Revision 4,
" Interior Hose Stations."
The actual size for each orifice assembly is shown on the applicable design drawings.
However, due to the provision-of a new fire protection water supply (storage tanks, fire pumps, etc.), the existing orifice plate sizes indicated on applicable drawings are no longer valid.
This was identified during design validation and a calculation is in process to provide revised sizing criteria.
Attribute 540, "FP Pipe and Fittings - Location and Orientation" Specification 2323-MS-98, Section 3.5.2, states that fire protection piping is to be installed in accordance with approved design drawings within tolerances of i 2 inches for piping greater than 2 inches in diameter and i 12 inches for piping less than 2 inches in diameter.
This is in accordance with applicable CPSES interfacing specification tolerances.
Attribute 546, "FP Sprinklers and Nozzles - Temperature Rating" Specification 2323-MS-98, " Design, Fabrication and Installation of Fire Protection Systems," Section 3.5.9, specifies the required temperature ratings for sprinklers i
and nozzles installed in given plant areas (reference j
l DCA 27,926, Revision 1).
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l Attribute 1594, "FP Supply Valves - Presence of Pressure Switch" Section 9.5.1.6.1.E.3.a of the FSAR states that each sprinkler system is required to be equipped with a water flow alarm device.
Accordingly, Specification 2323-MS-98, Revision 1, " Design, Fabrication and Installation of Fire Protection Systems," Section 3.5.6, requires that Grinnel Model B-2 pressure switches (or owner / engineer approved equal) be provided for each sprinkler system.
The applicable sprinkler system drawings show these devices and were utilized in PCHVP walkdowns.
Attribute 1679, "FP Structural Steel - Location" Structural steel is used in safety-related plant areas to mount fire protection components such as hose cabinets and hand switches to the structure.
Applicable civil / structural design drawings depict these support configurations.
Criteria specified in 2323-SS-16B,
" Structural Steel / Miscellaneous Steel," were used in the development of these drawings.
The locations for the fire protection components which were inspected are shown on applicable system drawings.
The NRC team concluded that the processes for specifying acceptance criteria for the above attributes were acceptable.
Independent Data Verification
, Attribute 540, "FP Pipe and Fittings - Location and Orientation" TU Electric conducted as-built walkdowns of suppression system piping in accordance with CPE-FVM-FP-041 to ensure compliance with Specification 2323-MS-98.
For purposes of PCHVP, credit was taken for these walkdowns and documentation was prepared in accordance with CPE-IM-FVM-FP-094.
The NRC team reviewed walkdown document ation of
.
Drawing 101 and inn; pendently verifica J.D. No. 785-X121 in the Auxiliary building (south hall corridor, elevation 810'
6").
The NRC team determined that the PCHVP walkdowns were acceptable for Attribute 540.
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Attribute 546, "FP Sprinklers and Nozzles - Temperature Rating" The temperature ratings for these devices are shown on applicable sprinkler system design drawings which were used for the TU Electric walkdowns.
The NRC team independently verified area protection sprinkger ratings (212 F) and cable tray sprinkler ratings (175 F)-in the Auxiliary building and determined that the PCHVP walkdowns were acceptable for this attribute.
Attribute 1594, "FP Supply Valves - Presence of Pressure
!
Switch" TU Electric's walkdown verified that model B-2 (or equivalent) pressure switches were installed, free of damage, and electrically connected.
The NRC team independently verified this attribute for System 785-X121, Drawing 101, Revision 12, switch tag
X-FS-4104-F, and determined that the PCHVP walkdown was acceptable for this attribute.
Attribute 1679, "FP Structural S!; eel - Location" Quality control personnel field verified the location and orientation of this attribute.
CPE-IM-FVM-FP-094 contains Component List 108 which lists components to be field validated relative to this attribute.
The NRC team reviewed the Quality Engineering PCHVP report dated August 2, 1988, for walkdown M05-3 which documents completed walkdowns for fire protection plates and Hilti bolts.
The NRC team independently verified this walkdown for equipment No. X-HS-4110F, a hand switch for the halon system located in the Electrical and Control building.
Based on this review and the process in general, the NRC team found the PCHVP walkdowns acceptable for this attribute.
Technical Dispositions The NRC team reviewed Attributes 1678 and 1680 through 1683 pertaining to the commodity FP Structural Steel.
Collectively these attributes required a total of 416 inspections by the applicant, ten of which could not be performed due to inaccessibility.
For each of these ten cases, the NCR identified the reason for the inaccessibility and the issue was transferred to CPE Pipe Support Engineering for the purpose of performing a civil / structural analysis intended to support the technical disposition.
The NRC team agreed that this planned action was acceptable in lieu of physical validation.
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Discrepancy Resolution Attribute 533, " Hose Cabinet - Orifice Plate Size" Due to the provision of a new fire protection water supply, the existing orifice plate sizes are no longer valid.
Action to redesign and replace orifice plates is being tracked by NCRs 88-13412, -02214, -03294, -13413,
-02767, and -02768.
The NRC team considers this action satisfactory.
Attribute 540, "FP Pipe and Fittings - Location and Orientation" I
NCR-88-14866 documented the locations of nonconforming conditions for five of the eight discrepant systems noted in the walkdown documentation.
Generally, the nonconform-ing conditions involved either damage or out of plum or alignment relative to specified tolerances.
The disposi-tion required construction to issue appropriate documen-tation to rework the items in accordance with Specifica-tion 2323-MS-98, Revision 1.
The NRC team agreed with the planned disposition.
Attribute 1594, "FP Supply Valves - Presence of Pressure Switch" All but one of the systems were found to have the required pressure switch.
NCR-88-10,618 states that pressure switch 1-FS-4113-D identified on flow diagram ECE-MI-0225-03A is not tagged as required by Specifica-tion 2323-MS-98.
The disposition requires a component identification tag to be attached.
The NRC team found this disposition to be acceptable.
Attribute 1679, "FP Structural Steel - Location" The summary for QC walkdown M05-3 indicates that Attributes 1679 and 1682 (orientation) involved a total
'
of 136 equipment items.
Seventy-two (53%) were satisfac-tory and 60 (44%) were unsatisfactory.
The NRC team reviewed NCR-88-10172 pertaining to item X-HS-4110F, a handswitch for the halon system in the Electrical and Control building.
The discrepancy concerned the fact i
that the design drawings provided no data for location
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and details on orientation, contrary to Specification l
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2323-SS-16B.
The NCR resolution indicated that the present location and mounting arrangement of hand station l
X-HS-4110-F is adequate for its intended use.
Dimensions for the location of the subject hand station shall be added to the applicable design drawing as directed in the
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NCR.
The NRC team found this planned resolution to be acceptable.
10.
Electrical (51055, 51065)
-a.
FVM Number:
"CPE-SWEC-FVM-EE-023, " Acquire Data for Cable Percent-Fill Calculations and Identification of Thru-Floor and Thru-Wall Embedded Conduit Sleeves" Commodities / Attributes No. of NF
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No. of Reviewed Commodity Attributes Attributes Electrical Equipment-Sleeves
2 CPRT Recommendation CPRT did not address Attribute 922, " Number and Size of Cables in Sleeve," and Attribute 919, " Color Code," was only partially addressed by CPRT as part of the conduit system co.nmodity.
For Attribute 919, the FVM reinspec-tion was consistent in scope with CPRT's recommendation.
However, Attribute 922 was addressed as a CAR 87-062 commitment.
Acceptance Criteria Data gathered by the FVM was to be reviewed and evaluated against Electrical Specification ES-100, Section 3.3.4.1 and Appendix U.
Independent Data Verification The NRC team independently verified the PCHVP walkdowns as reported in NRC Inspection Reports 50-445/88-72, 50-446/88-68; 50-445/88-59, 50-446/88-55; and 50-445/89-07, 50-446/89-07.
Additionally STIR-CPE-E-005 and the technical disposition for Attribute 919 were reviewed by the NRC team and found acceptable.
b.
FVM Number:
CPE-SWEC-FVM-EE-064, " Engineering Walkdown for Heat Shrinkable Sleeve Installations" l
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Commodity / Attributes No. of NRC No. of Reviewed Commodity Attributes Attributes Cable-Power, Control, and Instrument 1*
- Includes 6 sub-attributes CPRT Recommendation
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CPRT recommendations were based on the results of ISAP I.a.l.
The FVM encompassed the CPRT inspection points as well as those referenced on IE Notice 86-53.
Acceptance Criteria The FVM required data gathering on the attribute for subsequent review and evaluation by engineering.
Independent Data Verification The NRC team verified FVM implementation as reported in NRC Inspection Reports 50-445/88-53; 50-446/88-49 and 50-445/88-45; 50-446/88-41.
The NRC team reviewed the technical disposition for Attribute 131, "Raychem Installation," which reduced the scope of the PCHVP effort, and found it acceptable.
c.
FVM Number:
CPE-SWEC-FVM-EE-086, "Constru': tion / Quality Control Reverification" (attachment 3, electrical commodities)
Commodity / Attributes No. of NRC No. of Reviewed Commodity Attributes Attributes Cable-Power, Control, and Instrument
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l Electrical Equipment-l 120v UPS
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120v AC Dist. Pnis
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-125v DC Charger
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125v DC Dist. Pnis
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460v MCC
0 480v Unit Sub
'O 6.9kv Swgr.
0 Control.Pnis and Racks
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Local. Control' Stations 1-
.l Conduit System
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CPRT Recommendation-CPRT recommended reinspection'of these attributes.
The NRC team found that the FVM correctly implemented the
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CPRT recommendation.
Acceptance Criteria The-acceptance criteria were based upon adherence to
.ES-100, Appendix K requirements.
Independent Data Verification-The NRC team reviewed Attribute 365, " Cover and Gasket Installation - Electrical Equipment, 120 VAC Distribution Panels and Transformers."
The attribute evaluation form indicated that CPRT had recommended reinspection and referenced CAR 87-048.
The NRC. team selected two equipment packages from a listing of components on the engineering QC list which had been inspected by QC to verify in the field.
QC inspection' reports in the packages were properly closed by NCRs and physical equipment condition agreed with inspection;results.
The NRC team noted'that 28% of all components have not been reinspected and that inspections / components were changed from FVM-90 to this FVM.
Several-other attributes of this FVM (such'as Attribute 136) have technical disposi-tions pending.
Routine NRC inspection of this area will continue.
d.
FVM Number:
CPE-SWEC-FVM-EE-087, " Test Department Verifications" l
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L Commodity / Attributes LNo. of NRC No. of-
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L Commodity
'Attributen Attributes-Cable-Power,. Control and' Inst. Termination-
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~ Electrical Equipment-
Valve Solenoids
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Namco Limit' Switches
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Cable-Power, Control
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I and Instrument 1-
J Acceptance Criteria
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.The NRC. team-reviewed Attribute 103 fcr which' acceptance criteria were specified in ES-100, Appendix K, L
Section-5.4.
Independent Data Verification
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Previous NRC inspections of'the FVM were documented in NRC Inspection Reports 50-445/88-83; 50-446/88-79 and
50-445/89-04; 50-446/89-04.
-The NRC team reviewed the-
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evaluation for Attribute 103.
CPRT did not address this attribute.
The NRC team noted a discrepancy in Revision 0-of the evaluation in.that the wrong FVM;was referenced.
However, the applicant subsequently submitted Revision 1 of.the evaluation which had the correct reference. 'The attribute, " Bent-or Twisted Lugs," is being reinspected under the Gtartup Turnover program.
The procedure used for the walkdown of terminations ic XCP-EE-20, " Continuity and Termination Verification.
The AEF states that, even though not specifically addressed in XCP-EE-20, ar.y-lugs found to be-bent or twisted would be identified by Startup personnel based on:
Inspection of every termination for screw tightness,
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at which time bent or twisted lugs would be obvious; and Discussions with Startup personnel that indicate
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that they are trained to the requirements of ES-100..
Since no deficiencies were noted during numerous.NRC inspections,.the NRC team considered this acceptable.
e.
FVM Number:
CPE-SWEC-FVM-EE-088, " Engineering / Quality
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Control Reverification Electrical Separation" i
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Commodity / Attributes No. of NRC No. of Reviewed Commodity Attributes Attributes Cable Tray
0 Conduit' system.
1 Cable-Power, Control and Instrunent
0 Electrical Equipment-General
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' Electrical Equipment-Sleeves <
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CPRT Recommendation CPRT recommended reinspectiontof the two attributes reviewed, Attribute 279, " Separation - NIS" (conduit system) and Attribute 457, " Internal Wiring Separation" (electrical equipment, general).
Also, the evaluation for Attribute 457 references CAR-091.
The NRC team found that PCHVP properly implemented these CPRT recommendations.
Acceptance criteria
!
Acceptance criteria were based on ES-100, Appendix K, Section 1.5.
Independent Data Verification-NRC inspections of this FVM-were documented in NRC Inspection Reports 50-445/88-66, 50-446/88-62; 50-445/88-45, 50-446/88-41; 50-445/88-38,-50-446/88-32; and 50-445/88-25.
The NRC team reviewed the evaluations for Attributes 279 and 457, and found the evaluations acceptable.
f.
FVM Number:
CPE-SWEC-FVM-EE/ME/IC/CS-089, " Engineering Walkdowns" (attachments 1 thru 7, 9, and 24)
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I Commodity / Attributes No. of NRC No. of Reviewed Commodity Attributes Attributes
Conduit System
1 Cable-Power, Control and Instrument
1 Electrical Equipment-Control Panels & Racks
0 Electrical Equipment-General
0 Namco Limit Switches
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Instruments-Main Control Board & Panel
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Instruments-Control I
Valve Accessory Supports
0 CPRT Recommendation Numerous CPRT recommendations involve the attributes in this FVM.
The NRC team reviewed Attribute 134, " Cable Support Grips" (cable-power, control and instrument), and Attribute 282, " Junction Box Type - Modifications" (conduit system) and found that these were. recommended for reinspection by CPRT.
Attribute 282 also had CAR commitments other than CPRT.
The NRC team found that the l
FVM properly implemented the CPRT recommendations.
Acceptance Criteria Acceptance criteria were based on the electrical (ES-100)
and instrumentation (I-1018) installation specifications.
Independent Data Verification The NRC team independently verified the PCHVP walkdowns as reported in NRC Inspection Reports 50-445/88-83, 50-446/88-79; 50-445/88-53, 50-446/88-49; 50-445/88-45, 50-446/88-41; 50-445/88-38, 50-446/88-32; and l
50-445/89-14, 50-446/89-14.
The technical disposition l
for Attribute 134 indicated that inaccessible components i
l would be documented on NCRs for further evaluation and I
disposition.
The NRC team reviewed NCR 88-16911 and j
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though the work had not yet been completed.
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FVM Number:
CPE-SWEC-FVM-EE/ME/IC/CS-090, " Quality Control Reinspection"
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Commodity / Attribute No. of NRC l
No. of Reviewed Commodity Attributes Attributes Cable-Power, Control and Inst. Terminations
2 Cable-Power, Control and Instrument
2 Electrical Equipment-l 125v DC battery
0 480v unit sub
0 6.9kv Swgr
0 Penetration assembly
2 Elec. Cond. Seal Assembly
0 General
0 CPRT Recommendations Of the attributes reviewed by the NRC team, only Attribute 116, "Weidmuller Termination Blocks" (cable-power, control and instrument termination), was recommended for reinspection by CPRT.
The PCHVP scope for Attribute 116 was consistent with the CPRT recommendations.
As noted below, other attributes were subject to CAR commitments.
Acceptance Criteria Most of the above commodity / attributes were included in FVM-90 for reference purposes only since they were subject to rework and reinspection under normal procedures.
All acceptance criteria are specified by ES-100.
The NRC team had previously noted in NRC Inspection Report 50-445/89-14; 50-446/89-14 that an apparent contradiction existed between Section 2 and attachment 6 of the FVM.
The applicant plans to revise the wording of attachment 6 for clarification which will
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close NRC Open Item 445/8914-o-05.
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_I_ndependent Data Verification For Attributes 101 and 114, technical dispositions that reinspection was not required _were based on the fact that all affected components were subject to rework and inspection to current installation specifications.
These dispositions appeared acceptable.
The AEF for Attribute 130, " Cable Pulling Aids Removed" (cable-power, control and instruments), referenced CAR 87-059.
An NRC inspector had previously reviewed this CAR, as reported in NRC Inspection Report 50-445/88-83; 50-446/88-79, and found the justification to discontinue inspections for this attribute acceptable.
For Attribute 417, " Damage-Cuts, Tears in Jacket" (electrical equipment penetration assembly), the technical disposition indicated no reinspection was
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required since the attribute was subject to rework and i
inspection per current specification requirements.
This a
disposition was found acceptable by the NRC team.
Additionally, the Attribute Evaluation Form (AEF)
referenced CAR 055 and the package contained letters referring to SDAR CP-86-10 which was closed in NRC Inspection Report 50-445/89-15; 50-446/89-15.
The AEF package for Attribute 418 was reviewed by the NRC team and found to be essentially the same as Attribute 417 and therefore was also acceptable.
11.
Instrumentation Components and Systems - Mechanical (52053)
FVM-IC-069: - Safety /Non-Safety Related Instrumentation and Tubing Connected to ASME III Fluid Systems and ANSI Safety Class Installations
CPRT identified several issues relative to Instrumentation and Controls in ISAP VII.c, Appendices 7 and 28 and in Cygna's Electrical Review Issues List.
I This FVM encompassed the inspection of the following commodities and various final acceptance attributes required for physical validation of the commodity-No. of NRC No. of Reviewed Commodity Attributes Attributes I
Instrument flexible hoses
12 Instrument racks
2 Instrument-tubings, Valves, Fittings
11 Instruments
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During the course of the NRC inspection activities, all of the above attributes have been reviewed in detail to verify that the walkdown data being collected by SWEC is accurate and adequate for design verification purposes.
The results of these inspections are documented in the following NRC Inspection Reports:
50-445/88-20; 50-446/88-17 50-445/88-51; 50-446/88-47 50-445/89-07; 50-446/89-07 The NRC team reviewed Attribute 598 for which a technical disposition was performed to justify a curtailment of the walkdown activity for the attribute " Configuration Dimensional
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Tolerances" for the Commodity-Instrument racks.
The technical disposition states that based on the fact that 50 percent of the instrument racks had been walked down for this attribute and no nonconformances were identified, it is reasonable to assume that the remaining instrument racks will be acceptable for this specific attribute.
The NRC inspection team concurred with this assessment.
The NRC team reviewed Attribute 503, " Arc Strikes" (instrument flexible hoses).
CPRT recommended reinspection for arc strikes on instrument flexible hoses.
The FVM refers to Installation Specification I-1018 which requires that there be no arc striker on the flexible hoses.
The NRC team noted that Attribute 1161 covered by this FVM was listed in the matrix as being under FVM-089.
This discrepancy is being corrected by transmittal SW277.
Based on the documented reviews in this area, to date, the NRC inspection team is satisfied that implementation of the FVM is adequate and there is reasonable assurance that the instrumentation is adequately installed.
12.
Adequacy of the Methods chosen for Field Verifications and of Personnel Qualifications and Training (35061)
The field validation of attributes contained in the CAM was accomplished by the implementation of FVMs.
During this team inspection, the NRC inspector reviewed eight FVMs and their associated documentation for the following: (1) that the
choice of performing the FVM by engineering walkdown, QC inspection, or both was appropriate; (2) that engineering walkdown personnel were sufficiently qualified and the quali-fications properly documented; (3) that required training
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appropriate to the scope of the FVM was performed; and I
(4) that site audits and surveillance of PCHVP implementation indicated that the PCHVP had been properly implemented or that appropriate corrective action was performed.
(The site audit
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l-and surveillance programs were previously inspected by the NRC and were determined to be effectively implemented.)
Results of this NRC inspection are as follows.
a.
Qualifications of Personnel
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The qualifications of site QC inspection personnel were extensively reviewed by the NRC during inspection of the
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implementation of ISAPs I.d.1 and I.d.2.
Additionally, NRC inspection of the site QC training program reported in NRC Inspection Report 50-445/88-10; 50-446/88-08 found
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the QC training program to be satisfactorily implemented.
Therefore, the NRC inspection in this area focused on the qualifications of the walkdown engineers.
The qualifica-tions of walkdown personnel are specified in Procedure ECE 1.16-04, " Qualifications of Engineering Walkdown Personnel."
ECE 1.16-04 required that qualification of walkdown personnel be based on a combination of educa-tion, experience, and completion of training.
Further, the procedure provided that qualifications be documented on qualification forms.
The NRC inspector reviewed 40 qualification forms together with the records of training and the personnel records documenting work history and education level.
In all cases, the NRC inspector determined that the records of training, education, and experience adequately supported the qualification of the walkdown personnel.
b.
Appropriate choice of Engineering Walkdown Personnel Vs.
OC Inspection to Validate Hardware The NRC inspector determined that no specific guidance was provided by the controlling procedures of the PCHVP as to whether hardware validation should be performed by QC inspection or by engineering walkdown.
General guidance was provided in that commodities requiring engineering evaluation to determine acceptability should be validated by engineering walkdowns while those commo-dities requiring inspection of the quality of an attri-bute (e.g., weld quality) should be validated by QC inspection.
In all cases, rework of commodities was inspected by QC to current criteria.
The FVMs inspected by the NRC inspector and the inspection results were:
(1)
FVM Number:
CPE-EB-FVM-CS-001, " Field Verification Method Unit 1 Cable Tray Hangers As-Builting and Design Adequacy Verification Program"
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Audit or Method of Surveillance Activities Validation Reviewed-Detailed as-builting-
. Engineering ATP-88-95'
of cable. tray' hangers walkdown fol-ATP-88-109-including configura-
- lowed by QC CS-88-0620
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tion, weld size, and inspection.
- location with subse-quent QC inspection of
" Preliminary As-Built" The NRC inspector reviewed training records for this FVM and determined that training was adequate for H
the scope of data' acquired.
Results'of the. TAP audits and the construction surveillance were generally satisfactory and did not. indicate that personnel or training of personnel were inadequate.
The:NRC-inspector l agrees.that the choice of engi-neering~walkdown with follow-up by QC inspection was.
appropriate.
J (2)
FVM Number:
CPE-EB-FVM-CS-029, c '.' Procedure. for Seismic HVAC Duct and Duct Hanger As-Built Verifi-cation in Unit 1 and Common Areas" Audit or Method of Surveillance Activities Validation Reviewed Detailed as-builting Engineering ATP-88-119 of HVAC duct hangers walkdown & QC CS-88-0030 and ducts including inspection.
ES-88-0026 configuration, weld size and location.
n The NRC inspector reviewed training records for this FVM and determined that training was adequate for the scope of the FVM.
The NRC inspector notes that inspection of attributes such as weld size,.loca-tion, and quality was performed by QC inspection.
QC inspection of HVAC welds was necessitated'due to'
prior inadequate weld inspection as determined by CPRT.
Results of the TAP audit and surveillance were generally satisfactory and did not identify the choice of personnel nor personnel training to have been inappropriate.
The NRC inspector concurs that the choice of engineering walkdown with inspection by QC was appropriate.
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FVM Number:
CPE-EB-FVM-CS-33, " Design Control of
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Electrical Conduit Raceways for Unit 1 Installation in Unit 1 and Common Areas" i
Audit or Method of Surveillance Activities Validation Reviewed Detailed'as-builting Engineering ATP-88-110 of Unit 1 and Common walkdown.
ATP-88-121 I
l conduit systems in-TCP-87-24 i
cluding routing of CS-87-0099 conduit, conduit sup-ES-87-49
ports, electrical
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fittings and attach-ments.
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The NRC inspector reviewed the activities required for this FVM and compared them to the' training require:aents.
The training was determined to be adequate for the activities within the scope of this FVM.
Further, the NRC inspector concurs with the choice of field validation by engineering walkdown to provide as-built data.
The NRC inspector notes that QC inspection had previously been performed on the conduit raceways and that QC inspection is required for any physical rework of safety-related conduit.
The site audits and surveillance of the
' field validations of this FVM determined them to be satisfactorily performed.
(4)
FVM Number:
CPE-EB-FVM-SI-039, " Environmental Analysis As-Built Walkdown Data" Audit or Method of Surveillance Activities Validation Reviewed Collection of as-built Engineering ATP-88-92
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data to be analyzed in walkdown.
ES-88-20 the form of volumes connected by flow paths.
The NRC inspector concurs in the choice of method used for field validation.
Further, since the walkdown verified such items as direction of door swing and area of openings between rooms, involve-ment of QC is-not required.
Results of the TAP audit and engineering surveillance indicate only minor errors in field documentation.
The NRC inspector determined the required training was adequate.
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(5)
FVM Number:
CPE-SWEC-FVM-IC-069, " Safety /Non-Safety
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Related Instrumentation'and Tubing Connected to ASME Fluid Systems and ANSI Safety Class Installations."
Audit or-Method ~of Surveillance Activities
' Validation Reviewed Field verification of Engineering ATP-88-105 instrument racks, walkdown.
TCP-87-024 stands, wall mount-.
C-87-225 ings, valve manifolds, tubing, tubing runs,.
.i and tubing supports.
H The NRC inspector reviewed the. content of-FVM-IC-069, especially the criteria to be" verified in the walkdown checklists, and determined that-the-checklist. contained both attributes typically verified by QC inspection and attributes requiring.
engineering evaluations.
The NRC inspector. reviewed
'the 'CPRT conclusions that were developed irt regard to. instrumentation and controls (I&C) installation and-acceptance.
The CPRT identified the following deficiencies: (1) a QA/AC program deficiency for use of unapproved thread sealant, (2) a construction i
deficiency for improper installation of flexible metal instrument hose, (3) a. construction deficiency for misaligned spring nuts on Unistrut, (4)~an unidentified trend for incorrect tube clamps on a valve manifold, and (5) an' unidentified trend for thread engagement on Unistrut spring' nuts.
The NRC inspector determined each of the five CPRT identi-fled deficiencies were addressed by the PCHVP.
The CPRT deficiency for installation of flexible
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metal instrument-hose was specifically addressed in-FVM-IC-069.
The use of an unauthorized thread sealant was addressed by. CAR-87-043,'"Rectorseal applied to NPT Threads of Stainless Pipe."
The deficiencies for spring nut alignment, thread engagement, and clamp installation are verified during implementation of FVM-IC-086.
The NRC inspector reviewed the training required for walkdowns performed to FVM-IC-069 and determined that it was appropriate to the walkdown criteria.
Through discussion with the responsible' engineer for I&C and review of FVM-IC-086, the inspector deter-mined that FVM-IC-086 provided appropriate QC inspection of spring nut alignment, thread engage-ment, and clamp installation.
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(6)
FVM Number:
CPE-SWEC-FVM-CS-075, " Concrete Attachments in Unit 1 and Common Safety-Related Structures" Audit or Method of Surveillance Activities Validation Reviewed
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Detailed gathering of Engineering ATP-88-125 as-built data relative walkdown.
PCHV-QA-019 to embedded plates, PCHV-QA-021 attachments to embedded PCHV-QA-053 plates, and spacing re-CS-88-0521 quirements for Hilti bolts, Richmond inserts, embedded bolts, etc.
The NRC inspector reviewed the activities required by the FVM and concurs with the choice of an engi-neering walkdown for field validation.
The TAP audit and the surveillance of FVM-CS-075 indicated the FVM to be satisfactorily implemented and that personnel qualifications and training were adequate.
The NRC inspector concurs with this conclusion based on his review of required training and training records.
(7)
FVM Number:
CPE-SWEC-FVM-PS-082, " Validation of Seismic Category II Large Bore Pipe Support Designs."
Audit or Method of surveillance Activities Validation Reviewed Review of design ade-Engineering ATP-88-111
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quacy of seismic Cate-walkdown CS-88-0209 gory II pipe supports
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by documenting as in-stalled conditions with subsequent evaluation.
The NRC inspector reviewed the activities required for performance of this FVM and concurs in the choice of field validation by engineering walkdown.
Further, the TAP audit and construction surveillance indicate the walkdowns to have been satisfactorily implemented.
The TAP audit did determine that some attributes had not been included in the PCHVP matrix.
This audit deficiency was resolved by the inclusion of additional attributes in the PCHVP matrix with appropriate walkdowns to be performed.
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The NRC inspector deems the resolution to be appropriate.
The NRC inspector's review of required training and training records determined the training to have been proper.
(8)
FVM Number:
CPE-IM-FVM-FP-093, " Final As-Built Verification of Unit 1 and Common Portable Fire Extinguishers - Mechanical Commodities"
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Audit or Method of Surveillance
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Activities Validation Reviewed Verification of at-Engineering ATP-88-102 f
tributes associated walkdown.
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with field installed QC inspection.
portable fire extin-guishers.
The NRC inspector reviewed the attributes requi ed to be verified during performance of this FVM and concurs with the choice of engineering walkdown for attributes such as mounting, locations, and classification.
Also, the NRC inspector concurs in the choice of QC inspection for the attributes associated with Hilti bolt installation.
The subject of TAP audit ATP-88-102 was the integrated fire protection systems.
Because of numerous deficiencies, the audit results for PCHVP were unsatisfactory.
For example, the audit identified certain attributes not listed on the PCHVP matrix.
Also, the procedure used by Impell for the qualification of walkdown personnel was not in agreement with ECE 5.11-01 as to when personnel qualification should be performed and documented.
The NRC inspector reviewed the audit and the responses to the deficiencies.
The responses appeared proper and indicated adequate corrective action would be performed.
The NRC inspector reviewed the subsequently issued
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qualification forms and the resumes of engineering i
walkdown personnel for FVM-FP-093 and determined t
that the walkdown personnel were qualified.
c.,
Summary Based on the review of the above FVMs, the NRC inspector determined: (1) that personnel chosen for engineering walkdowns were sufficiently qualified and their
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required training was performed and was appropriate for L
the scope of the FVMs, (3) that the choices of a field j
validation performed by engineering walkdown or by QC
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inspection or both were appropriate, and (4) that site audits and surveillance indicate that the PCHVP portion of the CAP was satisfactorily implemented or that appropriate corrective actions were implemented for
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identified deficiencies.
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13.
Exit Meeting (30703)
An exit meeting was conducted April 13, 1989, with the applicant's representatives identified in paragraph 1 of this report.
Additional follow-up inspection was performed as late as April 21, 1989.
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
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provided to or reviewed by the inspectors during this inspec-tion.
During the exit meeting, the NRC inspectors summarized the scope and findings of the inspection.
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