IR 05000445/1989048
| ML20247C599 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/19/1989 |
| From: | Livermore H, Runyan M Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20247C581 | List: |
| References | |
| 50-445-89-48, 50-446-89-48, NUDOCS 8907240393 | |
| Download: ML20247C599 (12) | |
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S.. NUCLEAR REGULATORYLCOMMISSION.
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OFFICE OF NUCLEAR REACTOR REGULATION-NRC Inspection Report:
50-445/89-48 Permits: CPPR-126
- 3 50-446/89-48
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CPPR-127
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Dockets:.50-445
' Category: A2
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50-446 j
Construction Permit Expiration Dates:.
Unit 1: August 1,.1991.
Unit.2: August ~1, 1992
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Applicant:
TU Electric j
Skyway Tower j
400 North Olive Street i
Lock Box 81 Dallas, Texas 75201 Facility Name:
Comanche Peak Steam Electric Station (CPSES),-
Units 1 & 2
.a Inspection At:
Comanche Peak Site, Glen Rose, Texas'
Inspection Conducted:
June 7 through July 5, 1989 i
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Inspector:
_dd Wa %_
7-I9-89 M. F. Runyah, Resident Inspector,.
Date Civil Structural (paragraphs 3, 4, 5, and 6)
i Consultant: J. Dale, EG&G (paragraphs 2, 6, and 7)
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Reviewed by:
FM E-7"/9-bi H. H. Livermore, Lead Senior Inspector Date
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l Inspection Summary:
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Inspection Conducted:
June 7 through July 5, 1989 (Report 50-445/89-48; 50-446/89-48)
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Areas Inapected: Unannounced, resident safety inspection of f
applicant's actions on previous inspection findings; action on
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10 CFR Part 50.55(e) deficiencies identified by the applicant; i
assessment of allegations; nondestructive testing of containment liner welds; heating, ventilation, and air conditioning (HVAC);
structural steel platforms; and plant tours.
Results:
Within the areas inspected, no strengths or weaknesses were identified.
An open item was identified regarding a replacement structural calculation for the service water intake structure (paragraph 3).
An unresolved item was identified regarding the procedural controls regulating the mechanical manipulation of plant hardware to achieve weld fit-up (paragraph 6)..
An open item was identified to investigate QC fit-up inspections in areas where non-specified welds were applied (paragraph 7).
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j DETAILS 1.
Persons Contacted
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L. Barker, Manager, ISEG, TU Electric
- R.
A. Berry, Licensing' Manager, CECO
- 0. Bhatty, Issue Interface Coordinator, TU Electric l
- M. R. Blevins, Manager of Nuclear Operations Support, j
TU Electric
- H. D. Bruner, Senior Vice President, TU Electric
- W.
J.
Cahill, Executive Vice President, Nuclear, TU Electric j
- H.
M.
Carmichael, Senior-QA Program' Manager, CECO j
- D.
J.
Chamberlain, Licensing Lead Engineer, Unit 2, CECO
- J.
T.
Conly, APE-Licensing, SWEC
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- W.
G.
Counsil, Vice Chairman, Nuclear, TU-Electric
- G.
G.
Davis, Nuclear Operations Inspection Report Item
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Coordinator, TU Electric
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- D.
E. Deviney, Deputy Director, Quality Assurance (QA),
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TU Electric
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- J.
C.
Finneran, Jr., Manager, Civil Engineering,
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TU Electric
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- J.
L. French, Independent Advisory Group
- E. H. Gant, Executive Assistant, TU Electric l
- J.
Greene, Site Licensing, TU Electric
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- 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 j
- C. B. Hogg, Chief Manager, TU Electric l
- J.
J. LaMarca, Electrical Engineering Manager, TU Electric I
- F.
W.
Madden, Mechanical Engineering Manager, TU Electric
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- S.
G. McBee, NRC Interface, TU Electric
- E.
F. Ottney, Program Manager, CASE
- S. S.
Palmer, Project Manager, TU' Electric
- W.
J. Parker, Project Engineering Manager, SWEC/ CECO
- P.
Raysircar, Deputy Director / Senior Engineer Manager, CECO
- H.
C.
Schmidt, Director of Nuclear Services, General Division, TU Electric
- 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 K. W. Van Dyne, Engineering Assurance, Southern Technical Services The NRC inspectors also interviewed other applicant employees during this inspection perio. _ - _ _
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- Denotes personnel present at the July 5, 1989, exit j
meeting.
2.
Applicant's Action on Previous Inspection Findings (92701)
(Closed) Open Item (445/8875-o-03):
During an inspection of HVAC, the NRC inspector observed welding that had been performed on duct flanges while the EDPM rubber gasket was still in place.
During the ensuing documentation review, the NRC inspector was unable to determine that the question of heat input to the gasket during the welding process had been addressed.
However, after saveral discussions and subsequent j
document reviews, the NRC inspector determined that:
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The HVAC. systems will require air balancing and all
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unacceptable leaks will be detected and gaskets will be replaced with new ones if necessary in order to obtain the required balance.
A review of travelers was initiated to identify those
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travelers where welding was involved with HVAC flanged connections.
Evaluation and testing was performed on various flange
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configurations of various air handling units, plenums,
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and duct work that would allow welding on flanges without the removal of gasket material.
TU Electric Procedure CHV-101 (HVAC Detailing,
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Fabrication, Installation, Rework, and Repair) has been
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revised and precludes welding activities that can damage
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installed gasket material.
Those engineers responsible for HVAC construction were
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trained to the new procedure.
The NRC inspector has reviewed the above information and documents, performed field inspections, and agrees that those actions taken by TU Electric should preclude any problem with i
This open item is closed.
3.
Action on 10 CFR Part 50.55(e) Deficiencies Identified by the
Applicant (92700)
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(Closed) Construction Deficiency (SDAR-CP-88-23):
" Design Groundwater Elevation:"
By letter TXX-88124, dated February 4, 1988, the applicant informed the NRC that a deficiency involving the design basis groundwater level was a reportable event.
Piezometer readings l
indicated that perched groundwater levels exceeded the j
design basis groundwater level of 775 feet and some j
leakage into Category I structures had been observed.
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Initial proposed corrective actions included waterproofing of Category I. structures and the installation of design modifications to improve leakage
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detection.
The applicant issued a supplemental report to l
this issue (TXX-89203, May 8, 1989) wherein the proposed corrective actions were deemed no longer necessary.
Supporting this change, the applicant stated that no significant groundwater seepage into Category I structures had been observed in the previous year.
All previous seepage was considered to be attributable to incomplete construction or ongoing construction activities.
The applicant claimed that existing floor drains and temporary pumps could sufficiently handle the
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small amounts of.ceepage anticipated over the life of the plant.
The other major concern resulting from the high groundwater levels is the structural integrity of Category I structures.
The applicant completed a series of analyses that validated the design of all Category I structures (includes 21 calculations referenced in the SDAR file).
The NRC inspector questioned the use of an assumed groundwater elevation of 780 feet for the service
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water intake structure whereas an assumed level of.
810 feet (plant grade) was used for all other Category I
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structures.
Piezometer readings in the vicinity of the j
service water intake structure indicated groundwater
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levels of approximately 783 feet, or 3 feet above the assumed level.
The applicant concurred that the l
calculation was in error and would be revised.
I The NRC inspector reviewed file correspondence and concurred with the applicant's disposition of this issue in all aspects other than the service water intake structure assumed groundwater elevation.. This construction deficiency will be closed and an open item (445/8948-0-01; 446/8948-0-01) will track the design validation of the service water intake structure.
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(Closed) Construction Deficiency (SDAR-CP-84-29):
" Control Room HVAC."
By letter TXX-4350 dated November 5, 1984, the applicant informed the NRC that a deficiency involving a flawed safe shutdown analysis was not a reportable event.
This evaluation failed to consider a potential fire affecting habitability of the control room and alternate shutdown capability,.
Design Calculation EPM-p257-152, Revision 4, presented a " Fire Safe Shutdown Analysis" for CpSES which confirmed that for a postulated fire in any of the control room HVAC rooms, credit can be taken for an alternate shutdown using the remotn shutdown panel.
This calculation also confirmed that t e control room HVAC rooms do not contain
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any equipment required for an alternate shutdown.
The i
applicant concluded that no further action was required for this concern.
The NRC staff concluded that this issue has been adequately resolved.
This construction deficiency is closed.
4.
Assessment of Allegations (99014)
(Closed) Allegation (OSP-89-A-0016):
An anonymous allegation I
was received by the.NRC staff that revealed two concerns
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related to:
(1) the lack of job-site procedures for Dixie i
Drilling Company (DCP, Inc.) workers drilling holes for the-installation of Hilti bolts and (2) Dixie drillers'using steel l
instead of masonry bits.
Neither concern was substantiated.
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a.
Concern No. 1
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The alleger stated that a copy of Specification
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'L 2323-SS-30, Revision 3, was used on the job site at a time when Revision 4 was-in effect.
Subsequently, all l
procedures were removed from the work site to the DCP offices outside the power block.
The alleger felt this was the wrong way to correct the revision problem.
Review
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The NRC inspector interviewed the DCP project
superintendent concerning this event.
The superintendent j
stated that the policy of prohibiting work-site
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procedures had been in effect prior to the appearance of the back revision of Specification 2323-55-30.
This outdated copy of the specification was the personal (not controlled) copy of one of the workers and was confiscated at once.
The controlled copies of pertinent specifications and procedures are kept in a separate
" library" inside the protected area where workers may go if they have any questions.
The necessity of having procedures available at the work
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site is a job-specific determination.
In a case where a job involves detailed steps or is an uncommon operation,
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work site procedures should be provided.
Where the job task is simple in nature and is performed repetitively, the ability to immediately reference a procedure is probably not necessary.
In this case, the drilling of
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holes is performed numerous times by each worker and it
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is not a complex process.
The NRC inspector reviewed
Procedure CMP 108, Revision 2, " Core Drilling and Rebar Cutting," along with other relevant procedures and specifications and concluded that the provision of work site procedures for this task is not necessary.
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Supporting this position is the fact that none of the
eight TU Electric QA field surveillance of Dixie
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Drilling have detected any significant problems.
Conclusions The NRC inspector found the alleger's concern unsubstantiated.
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Concern No. 2 The alleger stated that he had " heard" that Dixie drillers were using steel instead of masonry bits.
Review The alleger's concern. appeared to be second-hand information.
A steel bit, as defined by its strict definition, does not have the capability of penetrating
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concrete.
The NRC inspector therefore conservatively
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concluded that the alleger's use of the term " steel bit"
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was in reference to a diamond-tipped core drill bit which has the capability of cutting through reinforcing steel a
(rebar).
A masonry bit is designed to bore through
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concrete, but is incapable of penetrating steel.
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worker intent on expediting his assignment may be tempted
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to use a core drill bit.
This could result in a structural defect wherever rebar was severed.
The NRC inspector reviewed the programmatic controls regarding the issuance of core drill bits.
i procedure cmp 108, Revision 2, establishes the method for
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controlling the issuance, use, and storage of core
drilling equipment and diamond tipped bits.
Core
drilling equipment is-issued only if the following
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conditions are met:
o (1)
A Rebar Cutting Request Card (RCRC) has been approved by engineering.
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The construction traveler designates the use of core drilling equipment and has been approved by the
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mechanical superintendent.
(3)
The equipment is issued only to the foreman responsible for the work.
Other cautions, including the use of drill stops and QC holdpoints, are also required.
The NRC inspector visited the tool shop where the bits are issued and found that the shop attendants were cognizant of the above requirements.
The NRC inspector j
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concluded that the program controlling the issuance of core drilling equipment is adequate.
Conclusion Given (1) the second-hand nature of this concern, (2) the lack of amplifying information, and (3) the tight controls for the issuance of core drill bits, the NRC inspector concluded that the alleger's concern is not substantiated.
5.
Nondestructive Testing of Containment Liner Welds (55050)
The applicant completed the planned initial sample of magnetic particle tests (MT) of full penetration welds attaching insert plates to the containment liner (see NRC Inspection Report 50-445/89-33; 50-446/89-33 for background).
The testing included the accessible portions of welds on the j
insert plates located below the spring line.
Since all the
welds were shop fabricated and performed in the flat position i
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using the same welding procedure, the applicant considered the welds located below the spring line to be homogeneous with i
those located in the dome.
Based on a fracture mechanics evaluation and consideration of weld joint configuration, materials, stress state, and cyclic loading, a maximum flaw i
size of 1/2-inch (linear indication) was established.
A total of 107 insert plates were examined by the MT method, i
with an average of two linear feet of weld inspected per
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plate.
This sample represents approximately 18 percent of the total length of weld associated with the plates located below the spring line.
A total of three indications were identified j
within this sample, none of which exceeded the established maximum acceptable size.
On the basis of the sample size and inspection results, the applicant concluded that the quality of welds in the uninspected portions of the containment liner were of high quality, and determined that no further testing was necessary.
The applicant intends to submit a licensing document change request to revise the Final Safety Analysis Report (FSAR) to accept the containment liner welds based on the sample MT inspection results. Based on field inspection of the NT process and review of the documented results and analyses, the NRC inspector preliminarily agreed that the applicant had demonstrated a basis for accepting the containment liner l
insert plate welds with no additional evaluation.
However,
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the applicant was asked to clarify QA/QC involvement in the original visual inspection of the welds.
In a draft report, the applicant stated that QC inspected only weld repairs, whereas the welder and a craft supervisor inspected the I
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original work.' The NRC inspector considered the quality of the original visual inspection to be germane to the overall
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acceptability of this program.
The applicant did not respond I
to the NRC's request prior to the end of the inspection
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period.
Inspection of this activity will be continued.
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6.
Heating, Ventilation, and' Air-Conditioning (HVAC) (50100)
l During the reporting period,'the NRC inspector reviewed all past and current documentation for the installation of fire damper CPX-VACRFD-53 and an associated pup piece 30" x 42" x approximately 21" built'from 3/8" steel plate.
From the documents reviewed, the NRC inspector was able to identify a
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separate work process that had taken place during the i
installation of the pup piece.
TU Electric project Specification 2323-MS-84, Revision 2,
page 3 of 27, states, in part:
" Damper sizes shall be
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verified by vendor to match existing penetration sizes and installation clearances.
Discrepancies / installation problems-shall be brought to the attention of the engineer."
Project Procedure CHV-101 "HVAC-Detailing, Installation, Rework, and Repair," Revision 6, dated November 23, 1988, states, in part:
"During the on-going construction process, construction engineers shall provide support to construction in resolving problems arising during installation, rework, repair or scrapping.
This shall be accomplished by work package update.
The work package shall be updated by the CE.
From the
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information available to the NRC inspector it appears that during the installation of the 30" x 42" x 21" pup piece a problem was identified with the ability of the pup piece to fit over the free end of the damper.
Apparently when this problem was identified the construction engineer contacted the manufacturer's representative who directed that a hydraulic jack be used to spread the pup piece apart far enough to slip over the free end of the damper.
The fact that all of this work took place without any change in the construction traveler that would show extra work taking place, without any DCAs, and in apparent disregard of the referenced procedures is an unresolved item (445/8948-U-02).
During routine HVAC construction activities, a series of discrepancies were identified involving HVAC duct segment turning vanes installed by Bahnson and were documented on nonconformance reports (NCRs).
This issue is being tracked as SDAR CP-89-014 and corrective action is delineated in Corrective Action Request (CAR)89-05.
The applicant committed to a sampling inspection of these welds to determine whether additional inspection and/or rework is necessary.
The principal safety concern is that the broken
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parts of a failed vane could be sucked into a safety-related fan and render it inoperable.
The NRC inspector witnessed a portion of this inspection
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effort.
The QC inspector used a six-inch scale to measure the l
1/16-inch fillet Nelds, the only size and type of weld used in l
this application.
The ARC inspector noted that the throat dimension of the weld could not be measured directly and that i
the concavity of weld profile in some areas suggested that some welds may be undersized in the throat.
The :pplicant
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stated that the QC inspector was well-trained to estimate-throat dimensions based on a combined consideration of the leg dimension and the weld profile.
As a result of these
inspections, the applicant did not perceive a problem with the weld throat dimension.
To further support its position, the
applicant supplied an Ebasco interoffice letter (BOB 216, dated l
Jane 12, 1989)'in which the following points were m.ide:
"1.
A 1/16" fillet weld has a weld throat dimension of.044".
Disposition characteristics of the gas metal arc and shielded metal arc welding processes made fillet welds as I
small as 1/16" extremely difficult to achieve.
"2.
The welding materials employed by Bahnson; AWS A5.18 E70S-2 bare wire and A5.1 E7018 low hydrogen coated electrodes, have a minimum specified yield strength of 60 ksi in as-deposited condition.
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l design calculations are based upon minimum base material l
l yield. strength of 36 ksi.
Therefore, the remote j
i possibility of some degree of weld profile concavity, q
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l metal vs. base metal yield strength differentia 1."
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The NRC inspector determined that these points were legitimate I
and concluded that the applicent had adequately answered the inspector's concern.
Further NRC review of the HVAC turning vane issue will be associated with the closure of l
SDAR CP-89-14.
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7.
Structural Steel Platforms (48053)
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During an inspectica of Platform AB-206-01, the NRC inspector
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identified that in both Sections 5-5 and A-A on DCA-5465, l
Revision 9, page 7, where a total of six single bevel groove i
l welds are required, fillet welds are actually installed.
This was identified in NRC Violation 445/8926-V-02.
TU Electric's response to this violation was as follows:
"Regarding platform AB-206-01, examples 1 and 2, the condition described in these examples is not a required QC inspection
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attribute for PCHVP inspection of structural steel.
NCRs have been initiated to resolve these conditions."
It is the NRC inspectors understanding that the weld inspection attributes for PCHVP are:
Weld Size
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Weld Length I
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Weld Location
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The NRC inspector does not understand why if the welder failed j
to prep (in this case bevel) the 3/8' plate or the J
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10" x 10" x 5/8" tube steel and instead applied weld filler material to the outside edges (the wrong location), the PCHVP inspector was unable to determine the condition.
Further, during a review of the original 1980 work traveler for this same platform the NRC inspector determined that even though TU Electric project Specification 2323-SS-16B, Revision 2, required a fit-up inspection be performed for all welds of this type (and it had been signed off in this case by QC), fit-up inspections for the six welds were apparently noc performed.
This is considered an open item (445/8948-0-03).
8.
Plant Tours (42051C, 50073)
The NRC inspectors made frequent tours of Unit 1, Unit 2, and l
common areas of the facility to observe items such as
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in-process work activities, equipment protection, and housekeeping activities.
The NRC inspectors observed a portion of the Unit 2 Service Water System piping pre-blast remote visual inspection near the discharge structure.
Video tapes of the interior of the large-bore piping will be used as
caseline information for the walkdowns which will take place after removal of the plasite coating.
No violations or deviations were identified and no items of significance were observed.
9.
Open Items Open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or applicant or both.
Two open items disclosed during the inspection are discussed in paragraphs 3.a and 7.
10.
Unresolved Items l
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Unresolved items are matters about which more information is
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required in order to ascertain whether they are acceptable items, violations, or deviations.
One. unresolved item disclosed during the inspection is discussed in paragraph 6.
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11.. Exit Meeting (30703)
An exit: meeting was conducted July 5,-1989,~with. thel
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applicant's representatives identified'in. paragraph 11'of'thisi i
report.
No written material.was provided to.'the-applicant.by
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the inspectors during this reportinJ period.
The applicanti did not identify as proprietary any of-the materials.provided to or reviewed =by the inspectors during.this inspection.
During'this meeting,-the NRC. inspectors summarized.theLscope.
.and findingsfof:-the inspection.
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