IR 05000445/1989034
| ML20245F107 | |
| Person / Time | |
|---|---|
| Site: | Byron, Comanche Peak  |
| Issue date: | 06/21/1989 |
| From: | Livermore H Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20245F074 | List: |
| References | |
| 50-445-89-34, 50-446-89-34, NUDOCS 8906280037 | |
| Download: ML20245F107 (13) | |
Text
- _ _ _.
..
'
t.
0l.
.
...
,
j U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION NRC Inspection Report:
50-445/89-34 Permits: CPPR-126 50-446/89-34 CPPR-127-Docke ts: 50-445 Category: A2 50-446 Construction Permit Expiration Datest.
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:
May 3 through June 6, 1989 Inspection conducted by NRC consultants:
P. Stanish - Parameter (paragraphs 2 through 6)
~
Reviewed by:
Odb H. H. Livermore, Lead Senior Inspector Date
8906280037 890621
{DR ADOCK0500jgg5
_-
. _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ - _ _ _ _ _ -
_ -.
_
_
a
.
Inspection Summary:
Inspection Conducted:
May 3 through June 6, 1989 (Report 50-445/89-34; 50-446/89-34)
Areas Inspected: Unannounced,. resident safety inspection of applicant's actions on previous inspection findings, follow-up on violations / deviations, review of applicant's action on 10 CFR 50.55(e) construction deficiencies, piping and pipe supports, and general plant areas (tours).
Results:
Within the areas inspected, no significant strengths or weaknesses were identified during this inspection period.
No violations or deviations were identified.
i
.
...
--
_ _ _ - - _ -__ _ _ - _ _ _.
-
. _ _. _ _ _ -
- - _ _ _ _ _ _
_
_ -
__
_
- _ _ _
j
.
'
.
.
- .:
.
.t
..
&
F;
L..._
~
L M-F(
'
DETAILS
,
-
.i
'
1.
Persons' Contacted
- M.
Axelrad, Newman'and Holtzinger
- D.
P. Barry, Senior., Manager, Engineering, SWEC.
)
.
- D.
Bize, License' Support, TU Electric-
')
- H.
D. Bruner, Senior Vice President, TU Electric
{
- W.
J.
Cahill, Executive Vice President, Nuclear,.TU Electric
- H.
M.LCarmichael, Senior QA Program Manager,' CECO.
- J. T.tConly, APE-Licensing, SWEC
- W.EG. Counsil, Vice Chairman, Nuclear, TU Electric
- S. Ellis,-Performance and Testing, TU Electric
- C..B.
Hogg,< Engineering Manager, TU Electric
- R. T.'Jenkins, Manager, Mechanical Engineering,'TU Electric
- J.~J.
Kelley, Manager, Plant Operations, TU Electric
- *J.
J. LaMarca, Electrical Engineering Manager, TU Electric
- 0.W.
Lowe, Director of Engineering, TU Electric L*S.-G..McBee, NRC Interface, TU Elec.tric i
- B.
Packo, Licens'ing Engineer, TU Electric
- S.
S. Palmer, Project. Manager, 1XJ Electric
- P. Raysircar, Deputy Director, Unit 2, CECO
- D. Real, Dallas Morning News
- D.
M.,Reynerson, Director of Construction, MNJ Electric
- J.
C. Smith, Plant Operations' Staff, TU Electric
- R.
L. Spence, TU/QA Senior Advisor,MEU Electric
- J.
F. Streeter,. Director, QA, TU Electric
- C.
L. Terry, Unit 1 Project Manager, TU Electric The NRC inspectors also interviewed other applicant' employees during this inspection period.
- Denotes personnel present at the June 6, 1989, exit
!
meeting.
2..
Applicant's Action on Previous Inspection' Findings (92701)
a.
(Closed) Open' Item (445/8518-0-24):
During an Evaluation Research Corporation (ERC) reinspection, witnessed by the NRC inspector, for Verification Package I-M-SBCO-083, ERC identified the following as subject to evaluation as potential deviations:
(1)
Required clearance'was not met between the subject pipe and an adjacent pipe.
(2)
Required clearance was not met between the pipe and an adjacent hanger.
These conditions were documented on Deviation Report (DR)
I-M-SBCO-083-DR1 which was included as part of
- -
_ _ _ _ _ -.
_
_ _
.
.
.
,
.
nonconformance report (NCR) CM87-6071NX, Revision 2.
For item 1 above, the NCR was.dispositioned to "use-as-is" because the existing clearance was sufficient to accommodate all anticipated piping movements.
This evaluation by the applicant considered the movement of both pipes.
For item 2, the disposition of the NCR required that the support (CC-1-211-700-C53A) be reworked in accordance with DCA 73385 to provide the clearance required by Specification CPSES-S-1021.
The NRC inspector reviewed Design Change Authorization (DCA) 73385, Revision 4, which required that the clearance between the pipe (2-inch MS-1-213-1303-2) and the revised support configuration be 4 inches at a minimum.
The NRC inspector also reviewed the anticipated piping movements from analysis MS-1-007 and confirmed that the existing clearances for the pipe to pipe clearance problem identified are indeed adequate.
Based on the above, plus physical inspection of the reworked support by the NRC inspector, this item is closed.
b.
(Closed) Open Item (445/8914-0-02; 446/8914-0-02):
Attribute Nos. 1281, 1282, 1283, 1285, 1286, 1289, and 1828(N) were determined to be acceptable based on CPRT reinspection results documented in the Results Report (RR)
for ISAP VII.c, Appendix 30.
The above attributes are related to welding of the NF Equipment Support Commodity, and were included in the general equipment support population.
Of this total population, 300 equipment supports were selected for inspection under the governing Procedure QI-066; however, no NF equipment supports were selected for reinspection.
The total population of NF equipment supports in Unit 1 and Common is nine.
Since the acceptance standards for ASME NF welding are more conservative than those for non-NF, the NRC inspector felt that based on the data presented the conclusion that reinspection was not required for these attributes was not appropriate.
During this inspection period, the applicant provided revised attribute evaluation form (AEF) supplements which provide further rationale for the acceptance of these attributes.
This rationale was that the ISAP VII.c quality of construction conclusions are, in part, based on the Project's further evaluations performed in response to the findings in the Collective Evaluation Report.
This report determined that further project evaluation of welding was required to fully address all associated issues.
The results of this project study were included in STIR-SWEC-M-002, Revision 1.
In this study, ASME NF welding was sampled as well as welding to AWS standards.
Therefore, the positive conclusions reached, based on I
- - - - - - - - - - - - - - - _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
=
.
-
-
.
..
.
e
'i i
finding no safety significant deviations, directly apply j
'
to the above attributes.
Based on NRC review of this additional information plus receipt of the supplements to the specific AEFs, this item is closed.
3.
Follow-up on Violations / Deviations (92702)
a.
(Closed) Deviation (445/8601-D-19):
During the NRC l
inspection performed on Verification Package i
No. I-M-LBCO-144, the following condition was identified:
Attribute 1.d in Section 5.2.4 of QI-025, Revision 1, was
.
signed off as acceptable by the ERC inspector; however, l
field survey measurements taken by Brown & Root (B&R), in response to an ERC request, showed the distance from the end of the containment penetration at field weld 18-A to
!
the working point of the 76 degree bend as 10 feet 5 7/16 inches with respect to a distance (with a tolerance of +2 inches) indicated on v.he applicable isometric drawing BRP-CC-1-RB-046 as 10 feet 8 1/2 inches.
The applicant determined that the reason for the deviation, which was confirmed by ERC, was that the ERC inspector did not note that the difference between the survey results and the dimension on the isometric drawing exceeded the +2 inch tolerance at the time of his original inspection.
As corrective action DR I-M-LBCO-144-DR2 was prepared to document the tolerance deviation; then based, in part, on this DR, NCR M-23475N, Revision 1, was generated to disposition this condition.
As preventative action, discussions were held with the specific inspector advising him of the error and, based on his previous acceptable inspection record, further actions were deemed to oe unnecessary.
The NRC inspector reviewed the NCR and the disposition of this specific deviation.
The disposition of this section of the NCR was to "use-as-is." this was based on a later survey which found the dimension in question to be within the specification tolerance.
Based on this review and the fact that the difference in the two survey dimensions is only 7/8 of an inch on a dimension that is difficult to quantify, (i.e. measuring to a theoretical working point)
this item is closed.
b.
(closed) Deviation (445/8601-D-20):
During the NRC inspection of Verification Package I-M-LBCO-144, the NRC inspector observed a portion of a support in contact with the insulation of the pipe being inspected.
The ERC inspector had signed off the piping clearances attribute as being acceptable even though a requirement existed that an air gap exists between the pipe (or insulation) and other objects.
The applicant attribu 2d the reason for
!
i
.
L.
,
i
!
the deviation to be inspector error.
As corrective action DR-I-M-LBCO-144-DR-3 was prepared to document the clearanco deviation.
This deviation was included on
,
NCR M-23475N, Revision 1, for disposition of this l
condition and the disposition provided for the insulation to be notched.
As preventative action for cases of inspector error, an overview inspection program was implemented to reinspect a sample of each inspector's work to determine the quality level of the work and determine the necessity for retraining.
The NRC inspector reviewed the NCR to ensure that it adequately described the nonconforming condition and performed an inspection of the rework performed.
The NRC inspector also reviewed the overview inspection results for the inspector in questica and concurs that retraining was not necessary and that this issue has been adequately addressed.
This deviation is closed.
c.
(Closed) Violation (EA 86-09, Appendix A, Item I.c.6):
Quality control inspections were inadequate in that the technical review team (TRT) inspection identified an excessive free gap between the spherical bearing and washers on the sway strut assembly of support CC-1-126-015-F53R.
Other supports with similar bearing gap anomalies identified during the TRT inspections included supports RC-1-052-016-C41K, RC-1-052-020-C41K, and MS-1-416-001-S33R.
Also, TRT inspections identified paint contamination in the bearings of both snubber assemblies on Class 1 component support SI-1-090-006-C41K of the Unit 1 Safety Injection System that severely obstructed the bearing cavities and limited their movement.
A similar condition exist ed on support MS-1-416-002-533R.
The applicant determined the cause of the violation to be ineffective configuration control program for the activities and the amount of work remaining to be completed at the time of this citation.
The applicant further stated that immediate corrective action was not implemented due to the fact that ISAPs VII.b.3 and VII.c would address the generic implications of the identified deficiencies.
Due to the large number of similar deficiencies identified during implementation of the ISAPs, CPRT recommended that a 100% reinspection of various hardware configuration attributes be undertaken.
j Based on this recommendation, the applicant instituted a f
hardware validation program which included piping and pipe l
supports.
The NRC inspector has reviewed the corrective action
,
requests (CARS) generated in response to the CPRT
!
I
. _ - _ - _D
- _ - _ _ -
.
..
.
,
.
recommendations and the applicant's justification for closure.
Based on this, plus extensive inspection of the applicant's efforts in the Corrective Action Program (cap), the NRC inspector concurs that these issues relative to pipe supports have been adequately resolved.
This violation is closed.
d.
(closed) Violation (445/8607-V-04):
Field design changes pertaining to the installation of stainless steel shims between the Reactor Coolant System (ECS) crossover leg piping and saddle blocks were not submitted to the organization that performed the original design for review and approval.
In addition, the traveler which was used to implement the design change did not document all of the changes that occurred.
The applicant denied the first part of the violation because at the time DCA 21116, Revision 0, dated September 27, 1984, was issued Comanche Peak Engineering (CPE) possessed an approved design document which allowed the installation of the subject stainless steel shims.
This document, " Reactor Coolant System Equipment Supports Shim / Gap Acceptance / Criteria," was received by CPE September 18, 1984.
CPE failed to provide the transmittal letter to the NRC during the inspection.
The NRC inspector reviewed the documentation provided by the applicant and concurs with the fact that sufficient design information was available to qualify the use of'
For the second part of the violation, the applicant determined that the reason for the violation was a lack of clarity in the documentation of completed work on the RCS loop 2 crossover leg, steam generator (SG) side, saddle block shim installations.
During this inspection period, the NRC inspector reviewed all the construction travelers (cts) associated with the shimming operations.
This review plus discussions with the vendor, Westinghouse, indicated that the existing documentation adequately describes all changes and identifies the need for changes.
For corrective action, a review of completed travelers for other shim installations on the RCS loop was performed by the applicant to ensure similar deficiencies did not exist.
Further, CPE personnel have received training to ensure that instructions provided in cts governing field activities adequately and clearly document conformance to design requirements.
The NRC inspector's review of the cts plus the training records for the retraining of the CPE personnel indicate
_ _ _ - _ - _ _ _ _
- _ - - _
_
.
.l.
'
'
.
I'.
-
'
%
,
,
.
at that this violation has been adequately addressed.
This violation is closed.
c.
(closed) Violation (445/8871-V-04):
Post-Construction Hardware Validation Program.{PCHVP) Procedure, Field'
' Verification Method (FVM)-081 and FVM-090 do not provide documented instructions appropriate for performing technical dispositions of inaccessible. attributes exempted from reinspection.by DCA 58252.
Further, the "use-as-is" J
disposition assigned to NCR 87-02743 and other similar NCRs may.not be applicable for the affected components
.
because the required technical justification is dependent on a future evaluation.
The applicant agreed with the violation in that DCA 58252 failed to include instructions that would assure that each of the portions of the piping systems handled generically received a technical disposition as required by ECE-9.04-05 and that better procedural: control should have been' established to assure that the affected attributes which were handled generically by this DCA would be identified and technically dispositioned.
The applicant stated that the disposition of NCR 87-02743 was based on DCA 58252 which establishes that the NCR did
'
identify any deviation from design requirements; therefore, sufficient justification existed for this disposition.
To provide better procedural control, Stone and Webster Engineering Corporation (SWEC) revised Project Procedure.(PP)-208, their implementing procedure for ECE-9.04-05, to clarify the process for assuring and
. documenting that the required engineering evaluations are performed for those portions of PCHVP commodities that are not reinspected.
Also, SWEC PP-222, " Control of Post-Construction Hardware Validation Program Walkdown Documentation," Was revised to clarify the relationship between the FVM process and PP-208 technical evaluations.
Also, a review of installation specifications was performed by the applicant to identify any similar conditions.
The NRC inspector has reviewed the revisions to PP-208 and PP-222 and concurs that the necessary clarification has been implemented.
As for the dispositions to the NCR cited, the NRC inspector feels that with the above mentioned revisions to the procedural control of the technical disposition process that the initial concerns whether specific attributes would be addressed has been resolved.
This violation is closed.
.
---u.--._m____. _.m._ _
_. _ _ _ _
.
.
,
.
-
4.
Review of Applicant Action on 10 CFR 50.55(e) Construction Deficiencies (35960, 92700)
a.
(Closed) Construction Deficiency (SDAR CP-85-51):
A deficiency was identified regarding the improper segregation, control, and application of low sulfur content ASTM-A-588 (A588) steel used in the fabrication of pipe whip and moment restraints This deficiency resulted in a Stop Work Order (SWO)-85-03.
The SWO referred to a lack of a program to control low sulfur A588 steel and resulted in CAR 51.
The specific instances of the use of material which did not meet this specific design requirement (.010% maximum sulfur) were reviewed and properly dispositioned by the Architect Engineer.
As for the generic material control issue, CPRT performed an indepth review of onsite fabrication which was documented in the Results heport (RR) for ISAP VII.b.1 which, in part, dealt with material control.
The results of their review, after an evaluation of specific deviations identified, concluded that "the deviations.
. have been evaluated and determined to
.
"
have no safety significant hardware effect.
...
The NRC inspector has reviewed the RR, as well as the actions taken by Gibbs & Hill (G&H) in response to the specific issue identified and the specific deviations such as review of welding procedure specifications (WPSs),
Certified Material Test Reports (CMTRs), and Ultransonic test reports and concludes that this issue has been adequately addressed.
This construction deficiency is closed.
b.
(Closed) Construction Deficiency (SDAR CP-87-04):
During inspection for base metal damage on the embedded channels for the Unit 2 6.9KV switchgear, cracks were found in the area of plug welds in the embedded channels.
These plug welds were made to repair grout holes.
The method of grout hole repair could be generic to other installations.
The applicant identified the cause of the deficiency as an apparent failure of design documents to conform to the requirements stated in the FSAR when providing details for attaching the 6.9KV switchgear to an embedded channel, specifically inappropriate weld details.
For corrective action, attachment of the cabinets in the affected areas have been prohibited by design change documents which were issued to provide revised details for the installation of the switchgear in DCAs 31346, 49086, and 28985.
To prevent recurrence of this deficiency, DCAs 70227 and 70228 have been issued to provide the correct details for attaching the Unit 1 and Unit 2 switchgear.
,
_ _ _
-__- _____-___- - __
- _ _
,-_
.
.
.
.
The NRC inspector has reviewed the NCRs and DCAs associated with this deficiency and concurs that they.-
adequately address the requirements of the FSAR and that this issue has been adequately resolved.
This construction deficiency is closed.
c.
(Closed) Construction Deficiency (SDAR CP-87-30):
As a result of errors identified in the seismic qualification report supplied by the vendor, an evaluation has been performed by the applicant which indicates that the roll-away missile shields (RAMS) are overstressed for the designed seismic conditions detailed in the applicable specifications.
The specific deficiency involves RAMS equipment tag Numbers CP1-MEMEMS-01 and CP2-MEMEMS-02, Specification 2323-MS-036.
Also, the RAMS are supported by the refueling rails on the 860' floor elevation.
These rails were not qualified for seismic and missile impact reaction loads from the RAMS.
A finite element analysis was performed which demonstrated that during the emergency.and faulted conditions, the equipment would have continued to perform their safety function.
However, to reduce stresses in the equipment to be within code allowables, modifications were performed and the design documentation was corrected to reflect the as-built condition.
The NRC inspector has reviewed the NCR PM-87-00565 which documented the nonconforming weld conditions, the cts and DCAs associated with the rework required to bring the stress levels within code allowables.
Based on the above, the NRC inspector concurs with the applicant's assessment that, had this condition gone undetected, no condition adverse to safety would have existed.
This construction deficiency is closed.
d.
(Closed) Construction Deficiency (SDAR CP-87-70):
This item was identified by CPRT and involved the qualification of pipe bending operations.
CPRT's review identified that pipe wall thinning due to the bending process can be as high as 12.3%; however, Procedure CP-CPM 6.9E, " Pipe Fabrication and Installation," allowed the use of piping with a prebend wall thickness as little as 6% thicker than the manufacturer's minimum prebend pipe wall thickness.
This may have resulted in some instances of post-bend pipe wall thicknesses below the manufacturer's minimum requirements.
This finding by the third party resulted in CAR 87-41.
The applicant determined the cause of this condition to be inadequate Piping Fabrication Specification MS-43B and Piping Erection Specification MS-100.
As corrective
______
_ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - - _ - -
,
_ _ _ - _ _ - _
'
i
-
-
.
-
.
{
j
,
action, the' applicant developed a QC verification program per AQP-11.5 for Unit 1 and AQP-11.2 for Unit 2 to perform a 100% reinspection of all pipe bends performed at CPSES.
j For preventive action the piping fabrication and erection specifications and Construction Procedure ACP-11.1 (which replaced Procedure CP-CPM 6.9E) were revised to add bending and documentation requirements.
Also, future pipe bends require verification of pipe wall thickness by ultrasonic examination.
The NRC inspector verified that AQP-11.5 and AQP-11.2 were established to perform a 100% inspection to verify and document the wall thickness of all pipe bends and that deviations were documented on NCRs.
The NRC inspector reviewed the revisions te MS-100, ACP-11.1 and MS-43B (which was revised by DCA 58803) to ensure that requirements for measurements of pipe bends were incorporated.
Also, the training records for craft personnel to the revised requirements of ACP-13.1, Revision 3 DCN 0 were reviewed by the NRC inspector.
Based on the above reviews as well as inspection of the ultrasonic measurement process, this construction deficiency is closed, e.
(Closed - Unit 1 only)
Construction Deficiency (SDAR CP-87-100):
Relief protection was not provided between containment isolation valves of fluid systems that remain water solid after containment isolation.
Heating of trapped water due to containment temperature post-loca, could have resulted in thermal expansion of the trapped fluid and subsequent overpressurization of the penetration resulting in a potential'for loss of containment integrity.
The applicant identified a total of 17 penetrations that had the potential for overpressurization and proposed the following corrective actions:
(1)
Install thermal relief valves on 13 of the identified containment penetration pipes that have the potent 3al for overpressurization.
(2)
Provide administrative procedures to ensure four containment penetrations are drained during plant operation to prevent overpressurization during an accident.
I (3)
Revise the FSAR to reflect the four drained penetrations.
The NRC inspector reviewed System Operating Procedure (SCP)-506, Revision 2, Spent Fuel Pool Cooling and Cleanup
, - _ -
A
.
.
,
-
.
'12 System and SOP-9(4, Revision 1, Main Water Supply Loop and'
Fire Pumps, which provide the direction to drain the four penetrations.
~,J.so FSAR Amendment 72 was reviewed by the NRC inspector to confirm that Table 6.2.4-1 reflected the proper fluid contained and that it was consistent with the SOPS.
The NRC inspector also reviewed the Startup Work
,
Authorizations (SWAs), the DCAs and the cts associated with the work performed to add thermal relief valves to the remaining affected penetration piping.
Also, Design Basis Document (DBD)-ME-013, Revision 2, containment Isolat3cn System was reviewed by the NRC inspector to ensure that provisions are included which would preclude this type of deficiency in the ft 'ure.
Paragraph 4.1.3.1 includes a requirement for water salid penetrations that, if they are isolable at the time of an accident and protection is necessary, thermal relief valves must be provided.
.
Based on the above reviews, the NRC inspector concurs that this issue has'been adequately addressed.
This construction deficiency is closed.
]
5.
Pipina and Pipe Supports (35960, 50090)
In NRC Inspection Report 50-445/8927; 50-446/89-27, several areas of concern relative to potential binding of pipe support components were identified.
The NRC inspector reviewed the actions taken by SWEC at that time, and the additional actions SWEC committed to perform during Hot Functional Testing.
During this inspection period, the NRC inspector received a report covering the visual observations performed on supports RC-1-007-001-C41R, RC-1-007-002-C41K and RH-1-001-012-C41S which concluded that these supports were found to be functioning well and that there was no evidence of binding or other interferences.
Further, the concern raised by the NRC inspector relative to support RH-1-001-012-C41S had also been identified by startup personnel on thermal expansion testing -
problem sheet No. T-057, which was dispositioned by monitoring the function of the spring in question.
The above actions fully address al.1 of the NRC concerns.
No violations or deviations were identified.
6.
Plant Tours (50090, 50073)
The NRC inspector 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 observed.
7.
Exit Meeting (30703)
An exit meeting was conducted June 6, 1989, with the applicant's representatives identified in paragraph 1 of this report.
No written material was provided to the applicant by the inspector during this reporting period.
The applicant did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
During this meeting, the NRC inspector summarized the scope and findings of the inspection.
l I
l l
lu_