IR 05000445/1989047

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Insp Repts 50-445/89-47 & 50-446/89-47 on 890607-0705.No Violations or Deviations Noted.Major Areas Inspected: Applicant Actions on Previous Insp Findings,Followup on Violations/Deviations & General Plant Areas
ML20247F136
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/20/1989
From: Livermore H
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20247F109 List:
References
50-445-89-47, 50-446-89-47, NUDOCS 8907270094
Download: ML20247F136 (17)


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NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION NRC1 Inspection.Rercrt:

50-445/89-47 Permits: CPPR-126 50-446/89-47 CPPR-127 Dockets: 50-445 Category:-A:2 50-446 Construction Permit Expiration Dates:

o Unit 1: August 1, 1991 Unit 2: August 1, 1992 h

' 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:

June 7 through July 5, 1989 Inspection conducted by NRC consultant:

p. Stanish - Parameter Reviewed by:

Yk 4 M4hb7'V 7 * 2A ~ h

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H. H. Livermore, Lead Senior Inspector Date l

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6907270094 690721 PDR ADOCK 05000445 PDC g

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Inspection Summary:

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Inspection Conducted:

June 7 through July 5, 1989-(Report 50-445/89-47; 50-446/89-47)

Areas Inspected: Unannounced, resident safety inspection of

. applicant's actions on previous inspection findings, follow-up on

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violations / deviations, applicant action'on 10.CFR 50.55(e)

construction deficiencies, and general plant areas (tours).

Results:

Within.the' areas inspected', no.significant strengths or.

weaknesses were' identified during thisi. inspection period.

No

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~ iolations or~ deviations were identified.

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DETAILS 1.

Persons Contacted

  • J.

L. Barker, Manager, ISEG, TU Electric

  • R.

A. Berry, Licensing Manager, CECO

  • O.

Bhatty, Issue Interface Coordinator, TU Electric

  • M.

R. Blevins, Manager of Nuclear Operations Support, TU Electric i

  • H. D. Bruner, Senior Vice President, TU Electric

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  • W.

J.

Cahill, Executive Vice President, Nuclear, TU Electric

  • H.

M. Carmichael, Senior QA Program Manager, CECO

  • D.

J.

Chamberlain, Licensing Lead Engineer, Unit 2, CECO

  • J.

T. Conly, APE-Licensing, Stone and Webster Engineering Company (SWEC)

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  • W.

G.

Counsil, Vice Chairman, Nuclear, TU Electric i

  • G.

G. Davis, Nuclear Operations Inspection Report Item j

Coordinator, TU Electric

  • D.

E. Deviney, Deputy Director, Quality Assurance (QA),

TU Electric

  • J.

C. Finneran, Jr., Manager, Civil Engineering, I

TU Electric

  • J.

L. French, Independent Advisory Group

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  • E.

H. Gant, Executive Assistant, TU Electric

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  • J.

Greene, Site Licensing, TU Electric

  • W.

G. Guldemond, Manager of Site Licensing, TU Electric

  • T.

L. Heatherly, Licensing Compliance Engineer, TU Electric

  • J.

C. Hicks, Licensing Compliance Manager, TU Electric

  • C..B. Hogg, Chief Manager, TU Electric
  • J.

J. LaMarca, Electrical Engineering Manager, TU Electric

  • F. W. Madden, Mechanical Engineering Manager, TU Electric
  • D. M. McAfee, Manager, QA, TU Electric
  • S.

G. McBee, NRC Interface, TU Electric

  • E.

F. Ottney, Program Manager, CASE j

  • S.

S.

Palmer, Project Manager, TU Electric

  • W.

J. Parker, Project Engineering Manager, SWEC/ CECO

  • P. Raysircar, Deputy Director / Senior Engineer Manager, CECO

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  • H.

C. Schmidt, Director of Nuclear Services, General Division, TU Electric

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  • A.

B. Scott, Vice President, Nuclear Operations, TU Electric

  • J.

C. Smith, Plant Operations Staff, TU Electric

  • R. L. Spence, TU/QA Senior Advisor, TU Electric
  • W.

L. Stendelbach, Executive Assistant, TU Electric

  • J.

F. Streeter, Director, QA, TU Electric

  • C.

L. Terry, Unit 1 Project Manager, TU Electric

  • T.

G. Tyler, Director of Projects, TU Electric The NRC inspectors also interviewed other applicant employees during this inspection period.

  • Denotes personnel present at the July 5, 1989, exit meetin _.

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1 2.

Applicant's Action on Previous Inspection Findings (92701)

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(Closed) Open Item (445/8914-0-03):

TU Electric stated

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that grouting for base plates will be validated by

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Attribute 474, Maximum Grout Thickness.

However, a revision to the attribute evaluation form (AEF) is

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necessary to indicate that the attribute is applicable to cement grouting.

At the time of the NRC inspection, the AEF was applicable to epoxy grouting only.

j In this inspection period, the applicant provided the NRC I

inspector with a revised AEF for Attribute 474 which indicates that both cement and epoxy grouting have been adequately addressed in the technical disposition for this inspection attribute.

NRC review of this AEF i

determines that this issue is adequately addressed.

This item is closed.

b.

(Closed) Open Item (445/8914-0-04):

During NRC team inspection of the Post-Construction Hardware Validation Program (PCHVP) N-TD attributes, those that do not require reinspection due to the existence of a technical disposition, or justification for not reinspecting, it was noted that in some cases technical dispositions (TDs)

took credit for verifications that were scheduled to occur later in other procedures.

Since these procedures are subject to change, commitments made in TDs must be identified to the appropriate personnel.

To accomplish this, the applicant stated that commitments made in TDs would be added to their commitment tracking system (CTS) and a backfit review of TDs, to identify

I affected procedures, would be undertaken and the necessary commitments would be added to the CTS.

In this inspection period, the NRC inspector received the i

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results of the applicant's review to identify TD commitments and the approved information system request to add TDs as a source document for the CTS.

Based on the NRC review of.this additional information,

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this item is closed.

c.

(Closed) Unresolved Item (445/8927-U-01):

The NRC inspector identified the following items as potential

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concerns:

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(1)

On the Loop 1 steam generator upper lateral ring, l

one of the tie bars had a cotter pin that was not i

spread.

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(12 ). The' tie bars for this ring do not have locking u

devices on the threaded. connections.

In response to' Item.-1 above, the applicant. generated nonconformance report (NCR) 89-04514 to document and evaluate the as-found. conditions;in light of specification and code requirements.

The'NCR reported ~several different conditions, these-ranged from ears bent in the same direction, and one ear

. bent'(at various angles)'.while the other ear remained

' unbent..It was determined by the applicant that the

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cotter. pins, as installed, would'have performed their intended function..However,.to clarify-the installation method and define acceptability, the disposition required that the existing cotter pins be scrapped and replaced by u

new ones bent'as described in the disposition of the.NCR.

For' Item 2 above, Westinghouse has provided the applicant with their position for not having to provide a locking mechanism for the trunnion rods that support the steam

generator upper lateral support.

This position was transmitted in Westinghouse letter WpT-11411 and states that the code-(ASME.Section III, Subsection NF)' requires

. locking devices for'" threaded fasteners," and'

Westinghouse stated the trunnion rods are not1 fasteners

'as defined by ASME.

Further,.these' trunnion rods are.not

.in.the primary load path of the support and should be considered' ancillary. members and, as such, do not fall within the jurisdiction of paragraph NF-4725.

However, to~ prevent inadvertent misadjustment of the ring's proper elevation, the applicant issued Design Change Authorization (DCA)-87322 to have the threads of the

. trunnion rods--staked as a locking device.

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Based on.NRC review of the DCA which provides adequate locking devices for the trunnion rods in question and the disposition of the NCR, this issue is closed.

3.

Follow-up on Violations / Deviations (92702)

a.

(Closed) Violation (EA-86-09, Appendix A, Item I.B.7):

At the time of the Technical Review Team (TRT)

i inspection, engineering criteria defined in Bechtel

Corporation Specification 10466-M-204, Appendix D,

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governing the cold springing of piping systems during i

installation was used at CpSES as the basis for the final design of the piping systems.

However, this criteria was

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never formally identified, documented, or authorized in CpSES TU Electric engineering documents.

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i The applicant has denied this violation.

They felt that

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this violation was caused by a misunderstanding between the TRT and Engineering.

As addressed in Specification 2323-MS-100, designed cold spring may be used if specified by the designer and accomplished under specific controls.

Since designed cold spring has not been used at CPSES, no controls are addressed in the specification.

The applicant stated that it was their intention to convey to the TRT that should designed cold springing be utilized at CPSES, it would be controlled; and the Bechtel specification was intended to be used as an l

example of how such cold springing would be controlled.

Although this was not considered to be a violation by the applicant, questions related to this matter were addressed by the Comanche Peak Response Team (CPRT) in j

the Results Report for ISAP V.e, which dealt with the a

installation of the main steam piping.

j As part of ISAP V.e, the CPRT specifically addressed cold

springing by:

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(1)

Review of procedures and specifications for pipe erection.

(2)

Review of NCRs and piping deviation request forms j

(PDRFs) for similar circumstances in other systems.

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(3)

Interviews'with installation personnel concerning i

piping location adjustments made during fit-up.

d (4)

Review and evaluation of the engineering significance of other sources of residual stresses to piping systems.

Based on the above actions, the CPRT concluded that:

" Springing to achieve fit-up was not permitted and that this was well understood."

It was also concluded that the incident that resulted in the violation was the result of ".

. possibly inadequate temporary

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supports.

As a result, certain aspects of the

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use of temporary supports were strengthened in the applicable specifications.

The NRC inspector has reviewed the Results Report

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referenced, as well as the revisions to the specification concerning the use of temporary supports and the requirements associated with the use of designed cold springing, and concurs with the applicant's assessment and denial of this issue.

This violation is closed.

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b.

(Closed) Violation (EA-86-09, Appendix A, Item I.C.8):

The following deficiencies identified during the TRT inspection _were not identified during the applicant's quality. control inspection process for the following piping supports:

'(1)

Support AF-1-001-001-S33R had porosity, insufficient weld leg', incomplete welds,'and insufficient fill.

(_ 2).. Support CT-1-013-014-S32R exhibited-excessive overgrind of the welds which resulted in notching of thel sway strut rear brackets.

(3)

Support AF-1-002-702-S33R had two more welds than required.

The extraneous welding was not documented on the as-built drawing.

One of the required welds was undercut (1/16-inch - 3/32-inch deep, for a length of 2 inches) beyond the limits of acceptance.

(4)

Support Drawing CC-1-126-013-F33R required a.

1/2-inch fillet weld to connect Item 5 to Item 6.

This weld was omitted'in the field.

(5)

Support CC-1-126-013-F33R had some welds performed with no quality control inspector initials or signature on the corresponding blocks'of the weld data card.for the support inspection package.

(6)

Support CC-X-039-007-F34R had a 5/16-inch all-around fillet weld with an approximately 1/16-inch undersize weld leg.across the top.

.(7)

Support RH-1-006-012-C42R had an all-around 1/4-inch fillet weld connecting Item 5 to Item 7 which was undersized by 1/32-inch to 1/16-inch across the top.

(8)

Support AF-1-037-002-S33R exhibited a 1/16-inch to

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3/32-inch reduction in plate thickness and weld size due to excessive grinding of the weld at the base plate.

Dase material thickness of the support plate was reduced beyond the limits of acceptance in three locations.

The applicant denied examples 5 through 8 of the

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violation for the following reasons:

Example (5) - Wold data cards 18220 and 50325 were voided by Component Modification Card (CMC) 10330, Revision 1, and were not utilized.

Weld Data Cards 04845 and 79412 were used for installation and were properly completed by Construction QC and the Authorized Nuclear Inspector (ANI) and are in the component support packag _

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Example (6)

The weld was reinspected and found to meet I

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Example (7) - The weld was reinspected and found to meet

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the size required by design within procedure and ASME Code allowables.

j Example (8) - The welds and grinding depressions noted were reinspected.

The welds were found to meet the size

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required by the design and the grinding depressions were deter.nined to be superficial.

Visually, without close evaluation and measurement, the welds appear undersize as the fillet weld had consumed the edge of the base material resulting in a full fillet.

The superficial cleaning at the toe of the weld appears to have created the reported depressions; however, the condition was caused by slight pull-in of the material and the section thickness was reduced only four mils by the cleaning which does not violate base material thickness tolerances.

The NRC inspector reviewed the Weld Data Cards (WDCs) 04845, 79412, 18220, and 50325 for Support CC-1-126-013-F33R and CMC 10330, Revision 1, which voided WDCs 18220 and 50325.

The-CMC dated l

November 15, 1979, changed the design to increase the size of the members.

WDC 04845 references CMC 10330 and shows the weld inspection being_ performed on May 16, 1980.

Therefore the NRC inspector concurs with the denial of this part of the violation.

For examples 6 and 7, the NRC inspector reviewed the ERC reinspection reports for the supports in question.

ERC

could not substantiate the NRC findings.

Based on these l

reinspection results the NRC inspector concurs with the

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applicant's denial of these sections of the violation.

For example 8, the applicant performed a reinspection of the affected components.

This reinspection was performed by the site mechanical Level III inspector, and he

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determined that the plate thickness and weld size in

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question were in accordance with drawing requirements and that the apparent deviations were attributable to warpage of the embedded plate.

Based on this reinspection data, the NRC inspector concurs with the applicant's denial.

For the remaining sections of the violation, the applicant concurred with the NRC findings.

Based on the limited number of deficiencies identified during reinspection by external organizations, the applicant

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attributed this violation to isolated human error.

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As corrective steps, the individual items were corrected i

at the time of their identification.

Item 4 was l

determined to be a drafting error and the drawing was

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corrected.

Also, component support welding was addressed i

by the CPRT in ISAP VII.b.3 and VII.c.

ISAP VII.b.3 is a i

comprehensive reinspection of all supports documented in

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the TRT inspections, and ISAP VII.c included a comprehensive reinspection sample of component supports which have been accepted by QC.

Further, an extensive

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requalification of all piping and pipe supports was undertaken.

Part of the requalification effort included an in-depth "as-builting" program with QC verification of all accessible attributes deemed necessary to this

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program.

The NRC has performed extensive inspection of both the CPRT reinspection efforts with a review of the conclusions drawn from these efforts, as well as the applicant's requalification program for piping and pipe supports and is satisfied that this issue has been properly evaluated and addressed.

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This violation is closed.

c.

(closed) Violation (445/8906-V-02):

The NRC inspector i

observed that the jam nuts on a U-bolt which is part of pipe support CS-1-AB-238-010-2 were loose and that the U-bolt was not properly adjusted to allow free axial movement of the piping.

Installation and inspection i

instructions require that pipe clearances shall not be less than 1/32-inch for the subject pipe support design.

This pipe support was inspected and found to be acceptable under PCHVP.

In response to this violation, the applicant stated that this citation, in part, prompted a TU Electric management directed engineering walkdown and review of pipe support installations.

The walkdown began on March 10, 1989, and was completed on March 13, 1989.

This cited example plus the observations noted in the management directed walkdown were documented in Corrective Action Request (CAR)89-004.

The applicant also committed to rework the I

specific deficiency as required by the disposition of tha Unsat Inspection Report (IR) 1761 which was written in

response to this violation.

The corrective steps taken to avoid further violations l

included:

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(1)

Training of construction department personnel to l

emphasize the general policy memorandum which l

cautions against damage to installed hardware.

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(2')'

Posting of clearly visible signs highlighting this policy.

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'(3). QA developed a procedure to provide QA involvement.

'in the Room / Area Turnover program and in monitoring commodities to assure they are. maintained in an acceptable condition.

(4)

ASME QA Procedure AQP 11.5, "ASME Component Installation Verification" was revised to include l

verification of the completeness of pipe supports j

within the NIS-1/N-5. boundary prior to finalization of ASME Code certification.

The NRC inspector reviewed the~Unsat IR, the Construction Traveler'(CT)-CS-1-AB-238-010-2 which documents.the

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rework required by the disposition of the IR,' and the training records for construction department personnel.

Also reviewed by the NRC inspector-were Procedures NQA'9.11, " Quality Assurance Tarnover Program" and Revinion 3DCN3 to Procedure AQP-11.5.

The original support that was identified by the violation was inspected by the NRC inspector to verify completion of the necessary rework.

Based on the above action, this violation is closed.

4.

Applicant Action on 10 CFR 50.55(e) Construction Deficiencies (92700)

a.

(Closed - Unit 1 only) Construction Deficiency (SDAR CP-87-23):

Conduits installed in Unit 1 and Unit 2 were found to have loose conduit unions after QC acceptance.

In response to this deficiency, the applicant initiated CAR 87-002.

The root cause of this condition was determined to be

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I lack of procedural requirements governing the tightening of conduit unions.

For corrective action, Field Verification Method (FVM) CPE-EB-FVM-CS-033 was revised to include loose unions.

This revision required that all loose unions be documented on NCRs and dispositioned to.

i be tightened. -Also, Construction Procedures QI-QP-11.3-23 for Unit 1 and QI-QP-11.10-1A for Unit 2 l:

were revised to address tightening of unions.

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preventive action, training was provided and documented on the procedure revisions.

The NRC inspector has reviewed the above documents to confirm that the committed actions have been completed.

The NRC inspector has also performed inspections of conduit unions during the inspections of the corrective i

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l Action Program (CAP) and concludes that this issue has

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been adequately addressed for Unit 1.

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This construction deficiency is closed for Unit 1 only.

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b.

(Closed) Construction Deficiency (SDAR CP-87-119):

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review of AC essential lighting and DC emergency lighting j

systems ~ indicated that support installations may not meet

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FSAR requirements.

Specifically, light fixture and

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battery pack seismic support installations do not meet j

the requirements as stated in the FSAR.

In addition, j

conduit which supplies the battery packs from the AC

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lighting panel is not seismically supported.

j TU Electric letter TXX-88075 states that SDARs CP-85-36 and CP-85-34 encompass the concerns stated in SDAR CP-87-119 and closure of these SDARs will ensure that FSAR requirements will be met.

The NRC inspector

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has reviewed the concerned SDARs and concurs that referenced SDARs do, in fact, encompass SDAR CP-87-119.

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Based on the above, this construction deficiency is closed.

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c.

(Closed - Unit 1 only) Construction Deficiency (SDAR CP-88-15):

Design validation identified a potentially reportable condition involving containment maximum flood levels.

Specifically, the correction of a nonconservative assumption used in the calculation which l

developed the containment maximum flood level resulted in raising the level'10 inches.

A-review of this new flood level indicated that some safety-related equipment could be affected.

The cause of the deficiency was determined to be an apparent failure to correctly determine the position of l

the incore instrumentation door when calculating the i

containment maximum flood level which could have resulted l

in the failure of qualified equipment inside the

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containment during a LOCA.

i For corrective action, design criteria for containment maximum flood level was established in Design Lc. sis Document (DBD)-ME-076, " Postulated Environment for Equipment Qualification."

Further, for the specific concern, the incore instrument door was modified to allow water to flow into the adjoining area and a revised flood level calculation was performed based on the modified door.

The recalculation was performed based on the modified door.

The recalculated maximum flood level was found to be lower than that assumed in the EQ program;

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therefore, no changes to the EQ program were required to address this item.

The NRC inspector reviewed CT No. CE-88-1197-8902 which documents the replacement of the hollow metal door with a wire mesh door, DBD-ME-076, Section 5.7 which provides

the design basis for calculating flood levels, and Stone and Webster Engineering Corporation (SWEC) Calculation 16345-NU(B)-057, " Containment Flood Level" and concurs that this issue has been adequately addressed.

Based on the above actions, this construction deficiency is closed for Unit 1 only.

d.

(closed - Unit 1 only) Construction Deficiency (SDAR CP-88-16):

Design validation of containment spray (CS) system indicates that the chemical additive tank and associated piping may not provide the specified design life.

Specifically, the corrosion rate developed from National Association of Corrosion Engineers (NACE)

publication " Corrosion Data Survey" provides a maximum life expectancy of the piping exposed to the NaOH solution that may be somewhat shorter than originally assumed due to minimum wall and pipe stress requirements.

The applicant concluded that this issue was reportable o

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and determined the cause of the deficiency to be a failure of the design organization to properly consider the corrosion rate of type 304 stainless steel when exposed to a highly caustic solution.

This could cause undetected thinning of the tank and piping over the life i

of the plant and cause tank or piping failure.- The

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applicant's review determined that the chemical additive system is the only safety system exposed to these service conditions.

For corrective action, the applicant developed an in-service inspection program to monitor tank / piping corrosion rates by periodically measuring component wall thicknesses and reviewing the results against minimum wall and stress requirements.

Also, the appropriate material criteria for the CS chemical additive piping and components have been specified in the CS DBD-ME-232.

Future modifications to this system will utilize the DBD criteria to ensure material compatibility.

The NRC inspector reviewed SWEC Calculation 16345-ME(B)-291 which was performed to confirm that the existing CS system piping has adequate wall thickness for the expected environmental conditions.

This calculation confirms that the remainder of the CS system is adequate for its intended function.

The NRC inspector also

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reviewed the DBD, which calls attention to the chemical additive piping and the need for monitoring corrosion rates and STA-730, " Corrosion Monitoring Program," and i

the special subsection which specifically addresses i

special areas of this program.

This special subsection i

specifically identifies the CS chemical additive system for inclusion in this program.

Based on the above, this construction deficiency is closed for Unit 1 only.

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e.

(closed - Unit 1 only) Construction Deficiency (SDAR CP-88-20):

The FSAR identifies systems for which accident detection and mitigation functions are i

accomplished by nonsafety components.

Specifically, these components are intended to ensure that safety-related equipment located in the vicinity of postulated breaks will not exceed established environmental qualification limits before the break can be detected and mitigated.

In reviewing the methods for

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detecting and mitigating high energy line breaks (HELBs)

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outside the containment for the chemical'and volume

control system (CVCS) letdown line and auxiliary steam (AS) system lines, the applicant concluded that the existing schemes did not satisfy the single failure criteria guidance provided in Branch Technical Position APCSB 3-1 and in the FSAR.

The detection method used in the CVCS letdown line employs a single pressure switch.

Failure of the switch could allow the break to remain undetected for a greater period of time than used in the break analysis.

In the AS, four pressure switches (2 per train) are powered from the same 118V source.

Failure of this source could result in a detection and isolation time in excess of the values in the break analysis.

This deficiency could result in the inability to detect and mitigate HELB accidents outside the containment, and result in safety-related equipment exceeding established qualification limits.

To correct this deficiency, the applicant provided a redundant HELB pressure switch and alarm circuit which will alert the operator of a break in the CVCS letdown

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line.

Also, the power source of one of the two AS HELB pressure switch Trains was reconnected from a diverse AC source such that failure of one power source would not render the HELB detection and mitigation scheme inoperable.

The applicant determined the cause of this deficiency was attributable to isolated design error.

Avoiding recurrence of this deficiency has been ensured

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by the incorporation of appropriate design criteria in DBD-ME-007.

l The NRC inspector reviewed the DCAs that effected the design changes required to complete the corrective actions outlined above.

The DBD was also reviewed by the NRC inspector to ensure that the appropriate design criteria have been included.

Based on the above document reviews, this construction deficiency is closed for Unit 1 only.

f.

(Closed) Construction Deficiency (SDAR CP-88-43):

Safety-related instruments have not been installed in accordance with the installation drawings.

Specifically, mounting bolts for instruments were found that were not the material type and grade specified by the installation drawing,.

This was initially identified during the reinspection being performed to CPE-SWEC-FVM-EE/ME/IC/

CS-086.

Later, the same deficiency was identified on instruments that had been reworked and reinspected as required by the FVM.

This deficiency was documented on NCRs in accordance with the applicable site procedures.

The applicant determined that the existence of these bolts did not represent a reportable condition because the nonconforming bolts, while they may have been overstressed would not have failed due to working stresses anticipated.

However, the NCRs were dispositioned to replace the bolts with the proper material.

The NRC inspector reviewed the installation drawing TNE-Il-0108D, Revision CP-2, which specifies the bolting material (ASTM A-193, Class 2, Grade B8), also reviewed was DCA 76329, Revision 0, which allows alternate materials, and the specific NCRs.

The NRC inspector concurs that the actions taken by the applicant fully address the specific concern relative to this i

bolting material.

For the program deficiency identified, the FVM not being fully effective in correcting the material deficiency identified, the applicant issued CAR-88-040.

The root cause of this condition was determined to be attributable to several factors.

(1)

Construction did not specify the class of the bolts on the material requisition.

.

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(2)

Warehouse personnel misinterpreted requirements specified on material requisitions and issued incorrect material.

(3)

QC did not identify the material substitution at point of issue or after installation.

(4)

Construction substituted material in violation of Procedure CP-CPM-8.1.

To assess' generic implications CECO performed an in-depth review of possible utilization of ASTM-A193, Grade B8

'

bolts and other ASTM bolting material and types, it was concluded that-the CAR condition was limited to the identified condition.

A similar possible misinterpretation of material requirements was identified for one additional material specification (SA 320, Grade B8).

However., review of all purchase orders issued revealed no cases where SA320, Grade B8 were purchased.

The corrective action required the replacement of the subject bolts, as stated above.

For preventive action, retraining of construction, QC, and warehouse personnel was conducted to make them aware of the causes of the problem and ASTM A-193, Grade B8, Class 1 material was purged from the I&C warehouse to preclude inadvertent use.

The NRC inspector has leviewed the corrective action verifications performed in response to this issue and is satisfied that this issue has been adequately addressed.

This construction deficiency is closed.

5.

Plant Tours (50090)

The NRC inspectors made frequent tours of, Unit 1, Unit 2, and common areas of the facility to observe items such as housekeeping, equipment protection, and in-process work activities.

No violations or deviations were identified and no items of significance were observed.

6.

Exit Meeting (30703)

An exit meeting was conducted July 5, 1989, with the applicant's representatives identified in paragraph 1 of this report.

Ne written material was provided to the applicant by i

the inspecturs during this reporting period.

The applicant i

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.

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Responsiveness to NRC Initiatives.

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Enforcement Nistory.

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Staffing (including management).

RATING KEY
(For Categories 2 - Declining and 3, provide narrative basis for conclusion)

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Category 1 Category 2 - Declining Category 2 Category 3 l]l Inspector (s) concern adequately addressed or

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