IR 05000445/1989053

Insp Repts 50-445/89-53 & 50-446/89-53 on 890706-0801.No Violations or Deviations Noted.Major Areas Inspected:Action on Previous Insp Findings,Followup on Violations/Deviations & post-const Hardware Validation Program

ML20245K926
Person / Time
Site:	Comanche Peak
Issue date:	08/14/1989
From:	Livermore H, Runyan M Office of Nuclear Reactor Regulation
To:
Shared Package
ML20245K925	List: IR 05000445/1989053 ML20245K922
References
50-445-89-53, 50-446-89-53, NUDOCS 8908210209
Download: ML20245K926 (11)

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. U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION NRC Inspection Report: 50-445/89-53 Permits: CPPR-126 50-446/89-53 CPPR-127 Dockets: 50-445 Construction Permits 50-446 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: July 6 through August 1, 1989

- Inspector: U vw cw___ 8 -19 - 8 9 M. F. Runyan,(Resident Inspector, Date Civil Structural (paragraphs 3, 4, 5, 6, and 7)

Consultants: J. Dale, EG&G (paragraphs 5 and 7)

W. Richins, Parameter (paragraphs 2 and 7)

Reviewed by: Ct444#12 - E-lY-Sf 3 H. H. Liv'rmore, e Lead Senior Inspector Date 8908210209 890614 PDR ADOCK 05000445 O PDC

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l Inspection Summary:

Inspection Conducted: July 6 through August 1, 1989 (Report 50-445/89-53; 50-446/89-53 )

l Areas Inspected: Unannounced, resident safety inspection of

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applicant's actions on previous inspection findings, follow-up on violations / deviations, action on 10 CFR Part 50.55(e) deficiencies identified by the applicant, Post-Construction Hardware Validation Program (PCHVP), nondestructive testing of containment liner welds, Unit 2 service water system piping coating removal, and plant tour Results: Within the areas inspected, no weaknesses, strengths, violations, or deviations were identifie !

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DETAILS

! Persons contacted i

• J. L. Barker, Manager, ISEG, TU Electric  !

• J. W. Beck, Vice President, Nuclear Engineering, TU Electric l

• 0. Bhatty, Issue Interface Coordinator, TU Electric

• M. R. Blevins, Manager of Nuclear Operations Support, j

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TU Electric

• H. D. Bruner, Senior Vice President, 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 l Corporation (SWEC) l

• W. G. Counsil, Vice Chairman, Nuclear, TU Electric l S. Dacko, Licensing Engineer, TU Electric

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• *D. L. Davis, Nuclear Operations, Results Engineer Manager, TU Electric

• R. J. Daly, Manager, Startup, TU Electric

• G. G. Davis, Nuclear Oper&tions Inspection Report Item !

Coordinator, TU Electric

• G. L. Edgar, Attorney, Newman and Holtzinger

• D. M. Ehat, Consultant, TU Electric

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

TU Electric

• C. A. Fonseca, Deputy Director, CECO

• B. P. Garde, Attorney, CASE

• J. H. Greene, Site Licensing, TU Electric  !

• W. G. Guldemond, Manager of Site Licensing, TU Electric i

• P. E. Halstead, QC Manager, TU Electric l

• J. C. Hicks, Licensing Compliance Manager, TU Electric t

• C. B. Hogg, Chief 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

• D. M. McAfee, Manager, QA, TU Electric l' *S. G. McBee, NRC Interface, TU Electric l

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• W. E. Nyer, Consultant, TU Electric

• G. Ondriska, Startup, TU Electric

• E. F. Ottney, Program Manager, CASE

• S. S. Palmer, Project Manager, TU Electric

• P. R. Raysircar, Deputy Director / Senior Engineer Manager, CECO I l *D. M. Reynerson, Director of Construction, TU Electric i *A. H. Saunders, Quality Surveillance, TU Electric

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

• J. C. Smith, Plant Operations Staff, TU Electric

• J. F. Streeter, Director, QA, TU Electric

• C. L. Terry, Unit 1 Project Manager, TU Electric l

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K. W. Van Dyne, Engineering Assurance, Southern Technical Services

• R. D. Walker, Manager of Nuclear Licensing, TU Electric

• J. R. Waters, Site Licensing Engineer, TU Electric l

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• R. G. Withrow, EA Systems Manager, TU Electric The NRC inspectors also. interviewed other applicant employees during this inspection perio * Denotes personnel present at the August 1, 1989, exit meetin . Applicant's Action on Previous Inspection Findings (92701)

(Closed) open Item (445/8516-0-43): This item addressed potential deviations regarding bolt size, bolt edge distance, bolt hole coverage, and weld locations for structural steel member AFCO-MK-F180-1-RB. This member is part of a reactor cavity platform structure located in the Unit 1 Reactor Building. These conditions were identified by CPRT during an inspection of Verification Package I-S-STEL-59 witnessed by the NRC inspector, documented on CPRT Deviation Reports (DR)

I-S-STEL-59-DR1, -DR2, -DR3, -DR4 respectively and incorporated into NCR M-86-1008595X, Revision 1. The NCR was dispositioned use-as-is for DR1, DR3, and DR4 based on Design Change Authorization (DCA) 64442 which modifies bolt and weld connections. The NCR was dispositioned repair for DR Traveler CE-89-3039-8902 implemented both the repair and DCA 64442. The NRC inspector reviewed the above documentation and concurs with the disposition of NCR M-86-1008595 This item is close . Follow-up on Violations / Deviations (92702)

(Closed) Violation (445/8926-V-03): This violation addressed a configuration control problem which resulted from a routine construction activity. A seal weld was applied to a pipe spool piece such that when the final fit-up was established, a valve stem g (attached to the spool) was rotated beyond the maximum 15 tolerance from the specified angle. The applicant initiated NCR 89-2564 which was dispositioned "use-as-is."

The applicant and the responsible QC inspector considered this incident to involve an isolated case of personnel erro In contrast, the Notice of Violation had identified deficient procedures as the major cause of the error. Despite this point of difference, the applicant initiated a procedural revision which essentially corrected the problem from the NRC inspector's viewpoint. Procedure AQP-11.1, " General Fabrication and Installation Inspection," was revised to describe the QC inspector's responsibility to consider all inspection attributes impacted by rework prior to final acceptance. Additional corrective actions included counseling the responsible QC inspector, training all inspectors on the l

issues that resulted from this violation, and conducting reinspection of other seal weld installations to ascertain l

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whether other similar configuration discrepancies had occurred ;

(None were found). j The NRC inspector reviewed KCR 89-2564, the revision to Procedure AQP-ll.1, the training records, and lesson plans and 1 concluded that the applicant had satisfactorily corrected the identified proble This violation is close . Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant (927001 (Closed) Construction Deficiency (SDAR CP-84-017):

"Flcoding Concerns." By letter TXX-4252 dated August 16, 1984, the applicant informed the NRC of a deficiency involving flooding levels in the Electrical Control Building. The applicant determined that this deficiency was reportable pursuant to 10 CFR 50.55(e). The original deficient condition was identified as a potential for backflooding from Room 113 into Rooms ll5A, B, C, and D through connected drain lines. This would result in an ana.'.yzed unacceptable flooding level under certain plant conditions in Rooms ll5A, B, C, and D and the potential incapacitation of safety-related HVAC water chiller The backflooding potential in these rooms was reduced to an acceptable level by sealing holes in a sump :rb in-Room 113 (DCA 21075) and installing floor drain overs in Rooms 115C and D (DCA 20590). ,

The applicant determined that the failure to consider backflooding through drain lines was a plant-wide concern. Design Basis Document (DBD)-ME-007 (Pipe Break Postulation Effects) was revised to include drain line backflow as a potential source of flood water. New calculations were generated to determine design basis flood levels. Based on these levels, walkdowns were performed by TU Electric to determine adverse interactions with essential equipment. Several plant modifications resulted from this effort, all of which are '

now complet The NRC inspector reviewed the SDAR file, including DCA 21075, DCA 20590, and DBD-ME-007, and concluded that the applicant had satisfactorily addressed this issu (Closed) Construction Deficiency (SDAR CP-86-04):

" Proximity Placement - Richmond Inserts to Embedded Plates." By letter TXX-6260 dated February 13, 1987, the applicant informed the NRC that a deficiency regarding the placement of Richmond inserts in the proximity of loaded embedded plates was a reportable item. This issue was subsequently expanded to include the separation

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criteria used for all types of concrete embedments including embedded plates, Richmond inserts, other anchor bolts and through bolt installations,'Hilti bolts, embedded' pipe sleeves, and embedded structural steel angles. This expansion.in scope included the incorporation of SDAP.s 79-08, 85-18, 86-44, and 86-5 During the investigation of this problem by the applicant, it became apparent that the original process of positioning embedded items in structural concrete had been poorly managed and that an extensive program of corrective action would be necessar The corrective action was divided into two phase Phase I involved the necessary administrative changes to establish control of in-process and future concrete embedments. To this end, 16 procedures and specifications were revised to tighten controls-on embedment spacings and to clarify (and change in some cases) the spacing requirement Phase 2 corrective action was originally scoped as a 100 percent reinspection of concrete embedment installations in Unit 1 (and common) under the Post-Construction Hardware Validation Program (PCHVp). However, after evaluating concrete embedments on 50 plant surfaces and not finding a single analyzed case of overloaded hardware, the applicant concluded that further evaluation was not necessar A considerable portion of the NRC's review of this issue was performed prior to this inspection period. NRC Inspection Report 50-445/89-19; 50-446/89-19 documented the final NRC inspection of the applicant's concrete embedment sampling program and concluded that the program sufficiently demonstrated the adequacy of concrete embedments plant-wide. This NRC review effort included field walkdowns and calculation review The NRC inspector reviewed existing procedures regarding the control of concrete embedment spacings and concluded that revised programmatic controls should prevent a recurrence of the original problem. After reviewing the SDAR closure file, the NRC inspector determined that the applicant had taken complete and extensive corrective action on this issue and had provided adequate assurance that current and future concrete embedments do and will meet design standard This construction deficiency is close (Closed) Construction Deficiency (SDAR CP-87-15): " Air Accumulators for Control Valves." By letter TXX-88009

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dated January 18, 1988, the applicant informed the NRC that a deficiency involving the air accumulators for air-operated control valves was a reportable item. The deficiency involved the absence of QC inspection records for the location, erection, tolerance checks, and the installation of the subject accumulators. In addition, desiccant materials were found in 12 accumulators and a buildup of rust and scale was observed in 6 accumulator The lack of installation records for the accumulators resulted from inadvertently misclassifying them as instrumentation items instead of mechanical item The failure to remove the desiccant materials was probably due to the absence of QC inspection. The rust formations were attributed to high humidity, a' condition which no longer exists since the accumulators have been charged with dry' air, per desig The applicant concluded that this issue was limited to a total of 22 accumulators. Each of these accumulators was inspected and cleaned, and the desiccant was completely removed. The rust and scale formations were removed by hydrolazing. To effectively recreate the missing QC documentation, the as-built conditions of the accumulators were verified and documented and the, accumulators were inspected to the applicable installation criteri The NRC inspector reviewed the SDAR file which included the relevant NCRs and QC inspection records and concluded that the applicant had satisfactorily addressed this issu This construction deficiency is closed d. (Closed) Construction Deficiency (SDAR CP-87-46):

" Containment Spray Pump Motor Rotor / Stator Gap." By letter TXX-88126, the applicant informed the NRC that a deficiency involving unsatisfactory internal clearances in two containment spray pump motors was a reportable l ite Air gaps measured between the rotor and stator in these two pumps differed from the average of the measured cir gaps by greater than 110 percent. This condition violates site maintenance Procedure EMI-315. It creates a safety significant concern in that excessive variation in the air gap may produce electrical imbalances, circulating currents, and hot coils under certain conditions. The applicant measured the air gaps on the other two containment spray pumps and found them to be in complianc ;

The uneven air gaps resulted from the presence of foreign material (rust, dust, and metal burrs) on the rabbet fit between the end bell bracket and stator fram Apparently during a previous assembly of these pumps, f

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cleanliness and maintenance procedures were not adequately'followed. The applicant cleaned the subject

, . motors and subsequently verified that the air gap dimensions were satisfactor Since~this condition was determined to potentially apply to.all-large open frame motors, the applicant reviewed maintenance work orders.that involved the measurement of internal clearances on these types of motors. From.the:

results of these work orders, the applicant determined-that (plant-wide) the internal clearances were. acceptable and that the two identified discrepancies were isolated.

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The NRCLinspector reviewed the SDAR file,. associated NCRs, and,the documented'results of the work order survey and^ concluded that the applicant had taken adequate

corrective action on this issue. This construction

' deficiency is close .( Closed) . Construction Deficiency (SDAR CP-88-34): "RHR Heat Exchanger Support Design." By letter TXX-88724 dated October 6,.1988, the. applicant' informed the NRC that a deficiency in the cupport configuration of the

. residual heat removal (RHR) heat exchangers was a-reportable item. 'The original purchase specification

indicated:that the RHR heat exchangers would be mounted on? rigid' support However, during design validation of

.the_RHR heat exchangers, the applicant discovered that the final support design and as-built construction were not rigid. This configuration resulted in an over-stressed. condition in the heat exchanger shell at the mid-lug connection. This is a significant safety concern in that the RHR heat.exchangers are utilized to establish and maintain cold shutdown conditions following postu-lated accident The error occurred during the process of translating the purchase specification to the final support design. Any other similar problems would have been discovered by the same design validation process that discovered this error, in that all safety-related systems were design validate The applicant redesigned the supports and implemented the necessary modifications. During design reconciliation, wherein confirmation-required conditions were resolved, the need for additional modifications to the RHR heat i exchanger upper, lower, and mid-level supports was identified. These modifications are now complet The NRC inspector reviewed the SDAR file folder including .

all associated NCRs and work travelers and concluded that

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'the applicant had adequately resolved this issu This

< construction deficiency is close .. post-Construction Hardware Validation Program-(PCHVP)-(49063,-

50073)-

iPiping and'In-line Components (CPE-SWEC-FVM-EE/ME/IC/CS-090 and CPE-SWEC-FVM-PS-081)

(a) BRP-CS-1-AB-237, Chemical and Volume Control System, Unit 1.: This'PCHVP inspection entailed approximately 30 feet.of 3/4-inch piping and all in-line components

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' including-drains, but excluding pipe supports. The PCHVP QC inspector verified sequence of components, dimensions, and configuration from isometric drawing BRP-CS-1-AB-237, Revision'CP-1, as well as other safety-related attributes. The QC inspector documented one discrepancy ~

on NCR 88-06072,- a piping segment 3 feet 3 3/8-inches long versus'3 feet 6 inches as depicted on the drawing (tolerance is 12 inches).

The NRC inspector examined in detail the entire 30 foot length of pipe and. reviewed the inspection report and NCR 88-06072. No discrepancies were foun (b) BRP-AF-1-SB-025, Auxiliary Feedwater System, Unit This PCHVP inspection entailed.approximately 65 feet of 4-inch piping and all in-line components including drains and auxiliary connections, but excluding pipe support The PCHVP QC inspector verified sequence of components, dimensions, and configuration from isometric drawing BRP-AF-1-SB-025, Revision CP-1, as well as other safety-related attributes. The QC inspector documented N one discrepancy on NCR 87-1120, Revision 0, noting a dimension deviation of 3 1/4 inches (acceptance criterion

.is 12 inches).

The'NRC inspector examined in detail the entire 65 foot length of pipe. The following three observations were made:

(a) The QC inspector's NCR item was not evident in the field; however, the applicant was'able to supply the NRC inspector with the necessary documents to show e why the NCR was writte i (b) -Base metal damage possibly due to improper use of a

pipe wrench was found on spools 14Q2 and 1502.

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damage was less that 1/32 inches deep and not a violation of procedur a

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(c) The drawing' dimension of 7' - 2 1/16" between valve 1AF-102 and the tee connection with the turbine driven AFW line was off by approximately 2 3/16", however this discrepancy was covered by an additional NCR that had not been part of the original packag No violations or deviations were identifie I l Nondestructive Testing of Containment Liner Welds (55150) l The NRC inspector had requested confirmation of the statement in tne draft report (J.O. No. 18051), "CB&I Magnetic Particle Examination," that the initial visual inspection of the containment liner hanger attachment welds had been performed solely by the welder and craft supervisor (See NRC Inspection Report 50-445/89-48; 50-446/89-48). The applicant provided original documentation which corrected the draft report on this issue. Chicago Bridge and Iron (CB&I) procedure entitled

" Nuclear Quality Assurance Manual for ASME Section III products" dated April 3, 1975, states that signoffs of.the block " finished joint checked" on the shop check list is to be performed by the welding QA-supervisor. The applicant provided a sample copy of the shop check list showing the signoff in the correct block by the welding QA superviso The acceptability of the applicant's partial MT inspection of the containment liner welds will be documented by the applicant in a proposed change to the Final Safety Analysis Report (FSAR). Unit 2 Service Water System Piping Coating Removal (49063)

During this report period, the applicant initiated abrasive blasting to remove existing coating materials from the interior surfaces of 10, 24, and 30-inch station service water system piping of Unit The NRC inspector witnessed a mock-up demonstration of the method which will be used to perform post-blast remote video inspection of the 10-inch service water system pipin According to Specification CPES-M-2007, Revision 1, this remote inspection must be able to detect all areas where localized wall thinning exceeds 0.05 inches (50 mils) from the pipe baseline contour. The demonstration convincingly showed that a 50 mil depression of any shape and orientation could be easily detected with the proposed video monitoring metho Additionally, the applicant demonstrated the technique whereby areas considered potentially out of specification will be located on the pipe exterior. This method involves the use of a magnet attached to the camera assembly. Ultrasonic testing will be performed on these areas to determine the actual pipe

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wall thicknes The NRC inspector considered this method to be adequat The NRC inspector also witnessed the qualifications of the ;

remote rotary spin abrasive blast cleaning of the 10-inch j station service water system piping. This test was performed in accordance with Procedure SW-TP-ME-03. This test was able to demonstrate an adequate method of removing the existing coating materials while removing a minimum amount of actual piping material. The ERC inspector will continue to monitor the progress in this area. No violations or deviations were identifie . Plant Tours (42051C, 49063, 50073)

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 observe . Exit Meeting (30703)

.An exit meeting was conducted August 1, 1989, with the applicant's representatives identified in paragraph ~1 of this report. 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 inspectio During this meeting, the NRC inspectors summarized the scope and findings of the inspectio !

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