IR 05000445/1989049

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Insp Repts 50-445/89-49 & 50-446/89-49 on 890607-0705.No Violations or Deviations Noted.Major Areas Inspected: Applicant Actions on Previous Insp Findings,Followup on Violations/Deviations & Corrective Action Program
ML20247E551
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/21/1989
From: Latta R, Livermore H
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20247E518 List:
References
50-445-89-49, 50-446-89-49, NUDOCS 8907260219
Download: ML20247E551 (14)
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t U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION NRC Inspection Report: 50-445/89-49 Permits: CPPR-126 50-446/89-49 CPPR-127 Dockets: 50-445- Category: A2 50-446 Construction Permit Expiration Dates: Unit 1: August 1, 1991 Unit 2: August 1, 1992 Applicant: TU Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 & 2 Inspection At: Comanche Peak Site, Glen Rose, Texas Inspection Conducted: June 7 through July 5, 1989 Inspector: /d# R. M. Latta, Resident Inspector-zd//g <> Da'te (Electrical) Consultant: J. L. Taylor - Parameter Reviewed by: ' S PM> - 7~ ~7 H. H. Livermore, Lead Senior Inspector Date 8907260219 890721 FDR ADOCK 05000445 Q FDC _ _ - _ _ _ _ _ _ _ _ _ _ _ . 

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Inspection Summary: Inspection Conducted: June 7 through July 5, 1989 (Report 50-445/89-49; 50-446/89-49 ) Areas Inspected: Unannounced, resident safety inspection of applicant's actions on previous inspection findings, follow-up on v.i.lations/ deviations, action on 10CFR Part 50.55(e) deficiencies ideitified by the applicant, corrective Action Program (CAP), instrument components and systems, significant meetings, and general plant areas (tours).

Results: Within the areas inspected, no significant safety matter, violation, deviation, or unresolved item was identified. A strength was identified relative to the applicant's quicx response to NRC initiatives concerning programmatic issues on the control and use of fuses and on control of calibration standards (paragraph 6).

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4 3 I l DETAILS Persons Contacted 

  *J. L. Barker, Manager., ISEG, TU Electric
  *R. A. Berry, Licensino Manager, CECO 40. Bhatty, Issue Interface Coordinator, TU Electric
  *M. R. Blevins, Manager of Nuclear Operations Support, TU Electric
  *H. D. Bruner, Senior Vice President, TU Electric
  *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, SWEC
  *W. G. Counsil, Vice Chairman, Nuclear, TU Electric
  *G. G. Davis, Nuclear OFerations Inspection Report Item Coordinator, TU Electric
  *D. E. Deviney, Deputy Dir6ct#r, Quality Assurance (QA),

TU Electric , 

  *J. C. Finneran, Jr., Manager, Civil Engineering, TU Electric
  *J. L. French, Independent Advisory Group
  *E. H. Gant, Executive Assistant, TU Electric
  *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 M. L. Lucas, Electrical Production Supervisor, TU Electric
  *F. W. Madden, Mechanical Engineering Manager, TU ulectric
  *D. M. McAfee, Manager, QA, TU Electric
  *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 Opera ions 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 it.terviewed other applicant enployees ;

during this inspection perio * Denotes personnel present at the July 5, 1989, exit meetin i 

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4 l L I Applicant's Action on Previous Inspection Findings (92701) ! i (Closed - Unit 1 only) Open Item (445/8936-0-01): Expired I work in progress (WIP) and nonconformance report (NCR) I waiver tags. This open item was identified during the closure of SDAR CP-87-40 and concerned WIP tags and an NCR waiver tag remaining on a radiation monitor after work was completed and after the applicable.NCR had been close In response to this issue the applicant initiated Deviation Report (DR) P-89-00551 for the WIP tag and DR C89-1596 for the waiver ta The NRC inspector reviewed the dispositions of both DRs and determined that the waiver tag discrepancy was due to an administrative error which occurred when the initial NCR was transferred to another NCR. The WIP tag discrepancy was apparently due to the omission of tag removal instructions in Station Procedure STA-60 However, it is noted that these instructions are included in department level Procedure I&C-108. The NRC inspector reviewed Design Change Notice (DCN) 1 to Procedure NQA 3.05, Revision 2, which addressed the removal of conditional rolease fwaiver) tags, as well as the procedure change notice (PCN) for STA-606 and Instrumentation and Control Procedure (I&C)-108 which addressed WIP tags. The PCN for I&C-108 deleted the reference to WIP tags. The PCN for ETA-606 added a step to remove WIPs if used and changed the use of WIPs to make them optional. The NRC inspector also reviewed the applicant's training records and determined that the required training for the above mentioned procedural changes had been accomplished. Bssed on these reviews, the NRC inspector determined that the applicant's response to this issue was acceptable and that the corrective actions implemented appear adequate. This open item is close (Closed - Unit 1 only) Open Item (445/8914-0-05): The attributes in attachment 6 of field verification method (FVM)-090 were identified as being "for reference only"; however, the inspection of these attributes was determined to be required. This open item resulted from a team inspection of the Post-Construction Hardware Validation Program (PCHVP) and involved a discrepancy between a procedural instruction in the FVM and the related attachment. The instruction required that the attachment be used to track attributes inspected by new work processes rather than separate QC inspection per the FV Instructions on the attachment, however, stated that it 1 was for reference only and it was not included in the FVM instruction The applicant issued a revision to the FVM which deleted the words "for reference only" from the __ _ 

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attachment. This clarified which attributes would be reinspected under the auspices of new work. The NRC inspector reviewed the revised FVM and determined that it adequately corrected the discrepancy; therefore, this open item is close (closed - Unit 1 only) Open Item (445/8922-0-01): Supplemental response to Violation EA86-09, Appendix B,- Item I.B.5. As previously identified in NRC inspection Report 50-445/89-22; 50-446/89-22, this open item involved clarification of information provided by the applicant in letter TXX 88262. The supplemental response was provided by letter TXX 89385 dated June 22, 1989, which consolidated the applicant's corrective actions concerning electrical penetration assembly replacement. The NRC inspector reviewed the supplemental response and determined that it clarified the reference to environmental qualification (EQ) program walkdowns previously identified; therefore, this open item is close . Follow-up on Violations / Deviations (92702) 

(Closed) Violation (445/8711-V-02; 446/8709-V-02): Splices in chiller unit This violation was attributed to the presence of cap type inline splice connectors in safety-related water chillers, contrary to the requirements of Electrical Specification 2323-MS-80B. The NRC inspector reviewed the pertinent NCRs, as well as the work orders which documented the implementation of corrective actions for Unit 1 chillers, and the completed CAR 88-008. The NRC inspector also examined the control panels for chillers CP1-CHC1CE-05 and determined that there were no apparent discrepancie CAR 88-008, Revision 1, was issued on April 25, 1989, addressing correction of Unit 2 chillers which should insure completion of Unit 2 actio Based on these reviews and inspections, the NRC inspector concluded the applicant's cumulative actions to prevent recurrence of this violation were adequate. This violation is close . Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant (92700) (Closed) Construction Deficiency (SDAR CP-85-31):

j " Electrical Raceway Support System." On December 5, 1986, I the applicant provided notification of a reportable event by letter TXX-6138 involving the Unit 1, Class 1E t electrical raceway support system. Specifically, this i issue concerned the additional weight imposed by the installation of separation barrier material (SMB) and radiant energy shield (RES) material without a j comprehensive design review. This failure to provide L_ _ _ _ 

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comprehensive engineering design reviews prior to the , installation of the SMB and RES resulted in the questionable structural integrity of numerous electrical raceways. Subsequent engineering evaluations resulted in o the identification of conduit and conduit support installations which did not meet the seismic design criteria requirements for overloaded conditions for Unit 1 electrical raceway system The applicant's initial response to this issue as stated in TXX-6319 dated March 6, 1987, stipulated the installation of additional conduit / raceway supports to rectify the identified def.tciency. However, the applicant later revised . heir position to direct the removal of all SMB from power cable raceways except where designated for RES purposes in the containment buildin The inspector determined based on document reviews and inspection of selected conduit and raceway installations that the SMB had been removed in accordance with the technical disposition of NCR CE-87-4577. Additionally, the NRC inspector ascertained that RES installations had been evaluated by the applicant and that currently installed configurations are identified by Procedure ECE-M1-1700, titled, "Thermo-Lag and RES Schedule." The inspector further determined that this document receives interdisciplinary review in accordance with Procedure 12CES.09-01 titled, " Design Verification and Interdiscipline Review." This procedure directs that appropriate engineering disciplines are involved in the assessment of design changes and that modifications to electrical raceway supports will be reviewed for completenes Based on the above documentation reviews and insp2ctions, the inspector determined that the applicant's corrective actions appeared adequate. This item is close (Open) Construction Deficiency (SDAR CP-87-101): Class lE cable arrangement. This deficiency involved the 

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routing of Class lE electrical circuits with multiple conductor per phase feeders which may have provided the potential to over heat. In particular, the current in multiple conductor per phase feeders is affected by the cable arrangement in the cable tray If the conductor current is not divided equally, cable overload and subsequent over heating may result. The applicant's corrective actions consisted of: a review of Design Basis Document (DBD)-EE-052, revision of Electrical Specification ES-100, and the documentation on NCRs of those multiple single conductor per phase circuits which were not in agreement with the revised specification. The _- -_ -

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i NRC inspector reviewed the subject DBD, the pertinent revisions to Specification ES-100, and the completed NCR Test data and calculations in the NCRs were determined to be acceptable. However, the NRC inspector questioned the i fact that NCRs 87-02304 and -02305 regarding emergency diesel generator cables did not address the possible 

 . reduction in qualified life of the cable Test results appeared to confirm that no damage had been sustained by the cables from running at above normal temperatures (below emergency temperature limits). The applicant was questioned regarding this aspect of the NCRs disposition and the NRC inspector was informed that the nocessary qualified life consideration had been made. At the end of this report period, the documentation of qualified life considerations had not been located. Therefore, this construction deficiency will remain open pending the review of additional information concerning the qualified life considerations for EDG cables, (Closed - Unit 1 only) Construction Deficiency (SDaR CP-87-121): 6.9kv/480V transformer bus bar clearanc The applicant informed the NRC of a potentially reportable clearance. problem between the 480V bus bars and the housings of the 6.9kv/480V transformers on November ll, 1987. Subsequently, the applicant also reported insufficient slack required to accommodate seismic displacements in the 6.9kv jumper cables between the transformers and transformer cabinet. The applicant initially intended to correct the bus bar clearance problem by modifying all of the affected transformer However, subsequent calculations indicated that only the transformers in the 852' level required modification and that the transformers on the 810' level were satisfactor The cable slack problem was corrected by measuring the jumper cables and replacing those that had insufficient slack. The NRC inspector reviewed the associated Design l  Change Authorizations (DCAs), Westinghouse seismic l  calculations, construction travellers, NCRs, and the QC inspection reports which documented the completion of the modifications and cable work in the Unit 1 transformer The NRC inspector determined that the specified work had been completed and that the supporting documentation appeared adequate. This construction deficiency is closed for Unit 1.

L (Closed) Construction Deficiency (SDAR CP-88-19): Cable insulation resistance-loop accuracy. This deficiency involved failure to consider thermal effects on cable insulation resistance and its subsequent effects on instrument loop accuracy for cables inside the containment which may be subject to loss of coolant accident (LOCA) or main steam line break (MSLB) events. The NRC inspector m______ - _ _ 

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o g a ' ' reviewed. Calculations 16345/6-EE(B)-084 and 16345-IC(B)-071; DCA 86351; Westinghouse setpoint > ! methodology in WCAP-12123; and DBD EE-021, Revision 0; DBD EE-037, Revision 3; and DCA 35471. The calculations appeared. acceptable and indicated that temperature effects on loop accuracy would be negligible. The DBDs w7te 

  : revised to require consideration of cable insulation resistance in determining safety-related loop accuracies and to control nuclear steam supply system (NSSS)

instrument setpoint calculations using the Westinghouse ! methodology. The NRC inspector determined that the ! applicable installation drawings had been revised to ! indicate the requirements for short instrument cable runs ! inside containment and in high energy line break (HELB) l areas outside containment. Based on these reviews, the ! NRC inspector concluded that the deficiency had been adequately addressed. This construction deficiency is close l 

       ' (Closed - Unit 1 only) Construction Deficiency (SDAR CP-87-139): Unqualified terminal blocks. The deficiency reported by the applicant involved terminal blocks which ,

could allow unacceptable circuit current leakage to ground ! during a LOCA or HELB event. The NRC inspector reviewed 2 NCRs and 4 DCAs selected from a list of approximately 20 items concerning this deficiency. These DCA reviews included the examination of implementation packages which replaced the terminal blocks with splices. Additionally, the NRC inspector conducted field inspections of several junction boxes to verity modification implementation. No discrepancies were noted during the above inspection Based on these inspections and documentation reviews, the NRC inspector determined that the applicant's response to this construction deficiency was acceptable. This construction deficiency is closed for Unit . Corrective Action Program (CAP) (51063) The CAP was developed by the applicant as a follow-up to the Comanche Peak Response Team (CPRT) effort. The primary objective of the CAP was to validate both the design and the implementation of plant installed safety-related systems, structures, and components. As part of a continuing effort to verify the effectiveness of this program, the NRC inspector accompanied Stone and Webster Engineering Corporation (SWEC) engineers during a portion of the Room 174 implementation of (FVM)-88, electrical separation, Phase I walkdowns. The SWEC personnel appeared knowledgeable and well acquainted with the procedure. The separation criteria from Electrical Specification ES-100 were available for reference. Separation discrepancies appeared to be properly determined and recorde No violations or deficiencies were identifie .. . . _- _ _ __-__ __ _ _ 

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.;,   9 x Instrumentation' Components and Systems (52053, 52055)

,Q During this reporting. period, the NRC inspector performed direct observations and independentLevaluations of work performance,,. work in progress, and completed work to' determined if these activities relative to safety-related instrument components and systems were accomplished in accordance with NRC requirements, FSAR commitments, and appropriate applicant procedures. Specifically, the NRC! inspector witnessed the. work in progress and reviewed the work package for the installatio of instrument lpIS-4552 The installation is part of DCA 52539 which adds pneumatic operated control valves, 

 . accessories, and air accumulators to the closed cooling water (CCW) system at safety chillers Cpl-CHC1CE-05 and 06. The'NRC v .

inspector observed that the craft personnel involved appeared well qualified and knowledgeable of the controlling procedure The NRC inspector noted two minor discrepancies on travellers 

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associated with this activity in that the traveller number had not been inserted on a CT-1 traveller.and Traveller lpIS-4552 had a missing designator (W-witness or V-verify) for a.QC-holdpoint at Step 5A. The craft personnel involved weresaware of these discrepancies and had informed the appropriate' parties for correction. The following. day a construction . engineer provided the package to the NRC inspector to verify the corrections. The subject deficiencies were determined to 

 .be minor in nature and they appeared to have been properly resolve The NRC inspector.also reviewed the work package associated with Instrument 2-PIS-4293'and discussed it with applicant personnel. The work packages have been modified for Unit 2 work in that construction travellers are no longer used and work is done to specifications and design drawings included in the package. The NRC inspector observed that the design drawings were stamped on the reverse sides with the applicable DCAs. This process not only allowed for the immediate identification of outstanding DCAs, but also appeared to expedite the design change review and approval process. The Unit 2 work control process, although not fully inspected, appears to be an improvement over the Unit 1 system. During this review process, the NRC inspector noted an NCR in the package, (CI-87-5105, Revision.0), which addressed correction of the low pressure side instrument line which was discovered disconnected.at the root valve without documentation. The technical disposition of this NCR, which directed the replacement of the affected instrument tubing, appeared adequat In response to NRC inquiries regarding previously raised j

! issues, the applicant met with the NRC on June 23, 1989, to 

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t- present actions on programmatic concerns regarding. fuse installation and calibration standards deficiencies. The j applicant presented single line drawing examples which had been j updated to include fuse designations. The estimated completion I date for this first phase of the fuse identification and j control program is-June 30, 1989. A second phase, adding fuse i description lists to the drawings has not yet been schedule Relative to the programmatic concerns regarding the standards ' 

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used for calibration of measuring and test equipment, the applicant discussed the historical nature of the problem, CAR 88-029 investigation, the responses to the identified deficiency, and the extent of equipment potentially affecte The NRC inspectors found the presentation informative, and considered the timely response by the applicant's Electrical Production supervisor a strength in the staffing / management are No violations or deviations were identifie . Plant Tours (42051C, 51053) The NRC inspectors conducted routine plant tours during this inspection period which included evaluation of work in progress as well as completed work to determine if activities involving safety-related electrical systems and components including electrical cable were being controlled and accomplished in accordance with regulatory requirements, industry standards, and applicant procedure During a plant tour, the NRC inspector noted that fire extinguisher CPX-FPFEXH-08 had no inspection tag and that adjacent extinguisher CPX-FPFEXK-06 had a tag indicating that the last inspection was in May 198 Subsequently, the NRC inspector examined the fire extinguisher control program and discussed these issues with the Fire Protection superviso The NRC inspector was informed that the program was in the process of consolidating different contracts for extinguisher maintenance. The consolidation proceFs included annual inspection updates and 6-year hydrostatic tests of all plant extinguishers. The NRC inspector determined that there was no monthly inspection tags on extinguisher -08 because inspections were tracked utilizing manual data sheets. Annual inspection tags may be found on extinguishers, but many tags were removed due to previous high obliteration rates from construction activities. The NRC inspector reviewed the tracking system and determined that the above extinguishers had been recently inspected and that the system appeared to be functioning adequately. A subsequent reinspection of extinguisher -06 revealed that it had an updated annual inspection tag dated June 1989. During this inspection process, the NRC inspector observed that the Fire Protection supervisor appeared to be _ _ _ _ - _ - - _ _ _ _ _ . 

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. . 11  i I'   knowledgeable, qualified, and aggressively pursuing the updating and consolidation'of the extinguisher inspection / maintenance progra No violations or deviations were identifie . Exit Meeting (30703)

i An exit meeting was conducted July 5, 1989, with the applicant's representatives identified in paragraph 1 of this repor No written material was provided to the applicant by the inspectors during this reporting period. The applicant did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection. During this meeting, the NRC inspectors summarized the scope and findings of the inspection.

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SALP_ FUNCTIONAL AREA A55ES$ MENT AND PRELIMINARY INSPECTOR EV 

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1/1 1 1 11 1 11_I I IV l V 1 Dev IUnitlRatinil l l l l l l l~l l l [ l I I I I l l I l RADIOLOGICAL CONTROL $ l l l l 1 l'l l l l l l l l l 1 1 I I I l l MAINTENANCE l l l l l I I I l l 01 l l l l l Pl l l l 1 1 I I I I I I l l $ SURVEILLANCE l El l l l l l l l l l l Rl l~ l l j TINE PROTECTION l l l l l l l l l 1 1 l I l l Al l l l Tl l~ l l l 1 l l

l EMERGENCY PREPAREDNESS $ 

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    *      l l l l LICENSING ACTIVTilES  l l l l l l    *

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l l l l l EFFECTIVENESS I i 1 1 1 1 I i 1 l l $0lL$ AND FOUNDATIONS l l l l l l l l l l~l l l l 1 1 1 1 1 I I i Cl I CONTAINMENT, SAFETY-RELATED l l l STRUCTURES & MMOR STEEL SUPPORTSI i l l l l l l l

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l__ L CRITERIA FOR DETERMINING CAiEGORY RATING Management involvement in Assuring Qualit . Approach to Resolution of Technical Issues from a Safety $tandpoin j Responsiveness to NRC Inttlative ; Enforcement Histor . Operational and Construction Event . Staffing (includingmanagement).

RAT]NG KEY: (For Categories 2 - Declining and 3, provide narrative basis for conclusion)

Category 1 Category 2 - Declining Category 2 Category 3 l[] Inspector (s) concerns adequately addressed or l~_l Inspection Evaluation Form being processe _ Lead Inspector _ TW/Wakt C Jue G 1 Sect 1on Chie ($1gnature) (Date) Wk iY (figpature) (Date) '/ 4 

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