IR 05000445/1989063

Insp Repts 50-445/89-63 & 50-446/89-63 on 890802-0905.No Violations or Deviations Noted.Major Areas Inspected:Actions on Previous Insp Findings,Action on 10CFR50.55(e) Deficiencies & Assessement of Allegations

ML20247R588
Person / Time
Site:	Comanche Peak
Issue date:	09/26/1989
From:	Hale C, Livermore H Office of Nuclear Reactor Regulation
To:
Shared Package
ML20247R583	List: IR 05000445/1989063 ML20247R580
References
50-445-89-63, 50-446-89-63, IEB-89-001, IEB-89-1, NUDOCS 8910020012
Download: ML20247R588 (9)

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION NRC Inspection Report: 50-445/89-63 Permits: CPPR-126 50-446/89-63 CPPR-127 Dockets: 50-445 Construction permit 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: August 2 through September 5, 1989 Inspector: / tActiCid C. J. Hale, Reactor Inspector f"Date U ~f (paragraphs 3.b and 6)

Consultant: J. Birmingham, RTS (paragraphs 2, 3.a, 3.c, 3.d, 4, and 5)

Reviewed by:

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I H. H. Livermore, Lead Senior Inspector Date 8910020012 890926 PDR ADOCK 05000445 Q PDC

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'2-Inspection Summary:

Inspection Conducted: August 2 through September 5, 1989 (Report 50-445/89-63; 50-446/89-63)

Areas Inspected: Unannounced, resident safety inspection of applicant's actions'on previous inspection: findings; action on 50.35(e) deficienci'es,. action on IE bulletins; assessment of allegations; and applicant's meetings.-

Results: Within the areas inspected, no violations or deviations were identified. Applicant. response to NRC initiatives or requests

'for information were timely. Corrective actions, proposed or implemented, appeared to be proper. Applicant actions proposed to improve timely distribution of controlled documents were proper and should result in an improved distribution program. No other strengths or weaknesses were note _ _ _ - - ._ -________ _ __ _ _ -_ _ __ _ _ ___ _ -

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l 3 DETAILS Persons contacted

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

• D. P. Barry, Directer, CECO

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

• 0. 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

*J. T. Conly, APE-Licensing, SWEC

• W. G. Counsil, Vice Chairman, Nuclear, TU Electric

• C. G. Creamer, Instrumentation & Control (I&C) Engineering Manager, TU Electric

• B. S. Dacko, Licensing Engineer, TU Electric

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

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

TU Electric

• S. L. Ellis, Performance and Test Manager, TU Electric

• J. C. Finneran, Jr., Manager, Civil Engineering, TU Electric

• C. A. Fonseca, Deputy Director, CECO

• J. L. French, Independent Advisory Group

• B. P. Garde, Attorney, CASE

• 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 Engineer, TU Electric

• D. L. Hubbard, Technical Training Manager, TU Electric

• A. Husain, Director, Reactor Engineering, TU Electric

• J. J. Kelley, Manager, Plant Operations, TU Electric

• J. E. Krochting, Director of Technical Interface, TU Electric

• D. M. McAfee, Manager, QA, TU Electric

• S. G. McBee, NRC Interface, TU Electric

• J. W. Muffett, Manager of Engineering, TU Electric

• E. F. Ottney, Program Manager, CASE

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

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

• J. D. Redding, Executive Assistant, TU Electric

• D. M. Reynerson, Director of Construction, TU Electric

• M. J. Riggs, Plant Evaluation Manager, Operations, TU Electric

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

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

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

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

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• O. L. Thero, QTC Consultant to CASE

• T. G. Tyler, Director of Management Services, TU Electric

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• R. G. Withrow, EA Manager, TU Electric The NRC inspectors also interviewed other applicant employees during this inspection perio * Denotes personnel present at the September 5, 1989, exit meetin . Applicant's Action on Previous Inspection Findings (92701)

(closed) Open Item (445/8932-0-03): This open item concerned the adequacy of procedural guidance provided for the performance of 10 CFR Part 50.59 safety evaluation The open item also concerned whether the responsible discipline member of the Station Operating Review Committee (SOPC) is represented during 10 CFR Part 50.59 safety evaluations (e.g.,

would the electrical maintenance department be represented during review of a safety evaluation for an electrical issue).

The NRC inspector has reviewed the applicant's actions in regard to the above open item and is satisfied that Procedures NEO 3.12, " Safety Evaluations" and STA-707 " Safety Evaluations" now adequately address the guidance set forth in the NUMARC/NSAC 10 CFR Part 50.59 guidance document. Further, in discussions with the plant manager, the NRC inspector determined that the responsible discipline is adequately represented during safety evaluations. Based on the above reviews, this open item is close . Action on 10 CFR Parc 50.55(e) Deficiencies Identified by the Applicant (92700) (Closed) Construction Deficiency (SDAR CP-85-34):

" Conduit / Support Design Final Validation Report." By letter TXX-4571 dated September 30, 1985, the applicant notified the NRC of a deficiency concerning the adequacy of conduit supports to perform their intended design function. Because of the broad scope of the problem, the applicant addressed the issue as part of the corrective Action Program (CAP). The actions taken to address the issue are detailed in Project Status Report (PSR)

" Conduit Supports Trains A and B and Train C Larger than 2 Inch Diameter."

The NRC staff reviewed the applicant's proposed Corrective Action Program and specifically addressed the electrical portion of the CAP in SSER-17. Additionally, the onsite NRC inspection staff have routinely inspected the implementation of the CAP program. NRC assessments of the implementation of the Post-Construction Hardware Verification Program (PCHVP) portion of the CAP were re orted in NRC Inspection Reports 50-445/89-14,

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50-446/89-14; 50-446/89-28, 50-446/89-28; and 50-445/89-61, 50-446/89-61. Those reports determined that the PCHVP portion of the CAP had been implemented in an acceptable manner. Specifically the NRC inspected implementation of CPE-EB-FVM-CS-033, the field verification method developed to address " Design control of Electrical Conduit Raceways for Unit 1, Installation in Unit 1 and Common Areas."

Based on the satisfactory implementation of the above

. identified actions, the NRC. inspector determined that the

' applicant has adequately addressed this issu Therefore, SDAR CP-85-34 is considered close (Closed) Construction Deficiency (SDAR CP-87-03): "6.9kv Switchgear Installation." By letter TXX-6334 dated March 16, 1987, the applicant notified the NRC of a deficiency involving the installation of the safety-related 6.9 kv switchgear. -The 6.9kv switchgear was installed on structural embedments that were not level. As a result misalignments occurred and the operability of the switchgear components could not be assured during normal operating or accident condition The mounting surfaces for the 6.9kv switchgear were required to be level to a tolerance of 3/32 inch. If this level tolerance was not maintained the breaker contacts could become misaligned and breaker failure would result. Such misalignment was observed during operation of these switchgear in 1987. A further assessment found that the floor mounting surfaces varied from level by as much as 3/8 inc TU Electric determined this item to be reportable per the requirements of 10 CFR Part 50.55(e) and on March 16, 1987, provided the required information to the NR TU Electric removed all the 6.9kv switchgear and the cabinets in which they were installed. The concrete mounting surfaces were repaired and refinished to the required level tolerance. The cubicles and the switchgear have been reinstalled and successfully teste The NRC inspection reviewed a portion of the test data and inspected the completed installation of one Train A cubicle and switchgear in both Unit 1 and With the successful repair, reinstallation, and testing of the 6.9kv switchgear, these items have been returned to service satisfactorily. These actions close this deficiency and the NRC inspector plans no further I inspection of this matter at this time.

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- c. .( Closed:- Unit 1 only) Construction Deficiency (SDA CP-87-044): "Unistrut-Tubing Support Bolting."' By .

letter TXX-6644 dated August 17, 1987,' the applicant l c  : notified the NRC of~a deficiency.in Specification CPES-I-1018, " Installation'of Piping / Tubing 1 and Instrumentation" which allows the use of ASTM A-307 l bolting in tubing' support '

The applicant.has analyzed this issue and' determined that the use of ASTM A-307 bolting in tubing supports'results ein unpredictable clamping force and unknown load limits.-

As corrective action for the deficiency the applicant revised Specification CPES-I-1018 to prohibit the use of ASTM A-307-bolting and to require the use of SAE J-429 Grade 2 or better bolts. To identify the. locations of

. ASTM A-307 bolts in tubing supports, Field Verification Method (FVM) CPE-SWEC-FVM-1C-086, "PCHVP Construction / Quality Control: Reverification" was implemente The NRC onsite staff has inspected the implementation of the Post-Construction Hardware Validation-Program (PCHVP)

including FVM-1C-086. Results of the NRC inspections appear in various NRC inspection reports (50-445/89-14, 50-446/89-14; 50-445/89-28,-50-446/89-28; 50-445/89-61, 50-446/89-61) and, in general, have found the PCHVP to be adequately implemented. The NRC inspector specifically-verified: (1) the revision'to Specification CPES-I-1018 and (2) that FVM-1C-086 requires the identification of ASTM A-307 bolts used for tubing supports for follow-up corrective action. The NRC inspector has verified a y ~ sample of the bolt replacements and is satisfied that the process is being implemented adequatel Based on the above actions, the NRC inspector concurs that SDAR CP-87-044 is being adequately addressed and considers this construction deficiency to be closed for Unit (Open) Construction Deficiency (SDAR CP-88-24):

" Instrument Tube Restraints and Supports." By letter TXX 88164 dated January 29, 1986, the applicant notified the NRC that deficiencies related to the installation of instrument tube restraints and supports was a reportable deficienc The deficiencies involved the following:

(1) installation of improper clamp types, (2) installation of mismatched clamp halves, (3) improper installation of tubing clamps (three dimensional restraint type - 3D) and (4) one clamp, required by design, not installe The applicant has implemented the following corrective and preventive actions: (1) revision of applicable i

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l design drawings'and installation documents to clearly identify clamp configurations and required torque values, (2) applicable construction and quality control personnel have been retrained to the revised design and installation documents, and (3) instrument tube supports and restraints for. Unit 1 and common were required to be reinspected to the requirements of CPE-SWEC-FVM-1C-069 and CPE-SWEC-FVM-1C-086. Deficiencies identified by the implementation of the FVMs are resolved in accordance with the FVM requirement The NRC inspector has reviewed the records of training of the applicable construction and quality control personnel to the revised installation documents. These records indicated that the required training had been properly implemented. In regard to the adequacy and implementation of FVM-1C-069 and FVM-1C-086, those FVMs have been routinely inspected by the NRC onsite staff and as part of a PCHVP team inspection. The results of the NRC team inspections appear in NRC Inspection Reports 50-445/89-14, 50-446/89-14; 50-445/89-28, 50-446/89-28; I and 50-445/89-61, 50-446/89-61. Although those NRC inspections determined that the FVMs were being properly implemented, NRC inspection of the completion of FVM-1C-069 and FVM-1C-086 is not complete. Therefore, NRC review of this construction deficiency will remain open pending completion of those FVM . Applicant Action on NRC Bulletin (92703)

(Closed) IE Bulletin 89-01: This IE Bulletin concerned the failure of certain Westinghouse supplied mechanical plugs installed in steam generators. For example, North Anna, Unit 1, experienced a Westinghouse supplied mechanical plug failure on February 25, 1989. The plugs are installed in steam generator tubing that has been determined to be leaking

.to prevent the crossover of water from the primary loop into the secondary loop. The applicant has complied with or made provisions for compliance with all actions requested by IEB 89-0 Specifically, the applicant has verified that none of the suspect plugs have been supplied to CPSES. Further, the applicant has taken actions to ensure that plugs from the suspect heats will be excluded from any future procuremen Additionally, the applicant has provided procedural requirements to require examination of any Westinghouse mechanical plugs removed from steam generators and that the results of the examination be provided to Westinghouse for inclusion in the Westinghouse databas The NRC inspector has reviewed the applicant's response and the appropriate supporting documents. The NRC inspector has l

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determined that the applicant has responded satisfactorily to-IE Bulletin 89-0 . _ Review of Allegations (99014)

(Closed) Allegation (OSP-89-A-0062): This allegation-concerned the qualifications of certain engineering personnel performing work at CPSES. Specifically, the allegation concerned: (1) the qualifications.of personnel performing work for the equipment qualification (EQ) program, and (2) the qualifications of certain engineers performing spectral and finite element analysi The qualifications of personnel performing engineering work at CPSES was recently inspected by the NRC and determined to be satisfactorily implemented as reported in NRC IR 50-445/88-10; 50-446/88-0 To address the specifics of this allegation, the NRC inspector contacted applicant and contract personnel responsible for the areas of concern and reviewed applicable personnel procedures for verification of requirements. Those actions revealed that existing personnel procedures require the verification of education and experience backgrounds for engineering personnel performing safety-related work at CPSE These procedures were determined to satisfactorily address the verification of an engineers basic qualification Regulatory requirements for the area of engineering qualifications allow for management assessment of engineering ability. The quality of engineering output is controlled by a combination of supervisory review, required independent reviews of engineering calculations, and applicant audit The engineering process for CPSES has been inspected by routine NRC inspections and by specific team inspections. In general, results of NRC inspections of engineering calculations have been satisfactory. A violation was issued for the failure of design reviews to identify and correct Stone and Webster calculation deficiencies. Corrective actions for this deficiency have been implemented, reviewed by the NRC, and the violation has been close Based on discussions with applicant and contract personnel, review of applicable personnel procedures, and an NRC inspection of design calculations in the noted areas of concern, the NRC inspector determined that requirements for the verification of engineering qualifications are adequate and that the design control process is satisfactorily I

implemented. Therefore, NRC review of this allegation is close _

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6.. : Applicant-Meetings (92700)

The NRC' inspector, attended applicant meetings concerning site-activities and implementation of-various site program Meetings attended during this reporting period included:

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. Senior QA Overview Committee

. Exit Meeting for: Audit EFE-89-07

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-The Senior QA Overview Committee meeting reflects management's involvement in day-to-day activities and attention to

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potential problems.. Audit EFE-89-07 dealt with the adequacy of certain administrative control procedures, alarm response procedures and test procedures. No audit deficiencies were identifie On August 2, 1989, the NRC inspector met with the supervisor of the document control center (DCC), who described practices that have-been implemented to address the weakness identified in NRC Inspection Report 50-445/89-32; 50-446/89-32 (delays in distribution of issued engineering documents). Of the several changes to the distribution process that were described, one appears to be particularly beneficial. Previously, when engineering' issued a document it was sent to DCC for processing, then distributed to the Operations DCC, who then-had 48' hours to place the document in the control files in the control room. This process at times could take.up to 11 days from issue to placement in the control room. Under the new process, engineering issues the document to DCC and after processing, DCC distributes the document directly to the

control room with a target of two days from issue to placement o in the control room. This process significantly improves the distribution of engineering documents to the control roo No violations or deviations were identifie . Exit Meeting (30703) i An exit meeting was conducted September 5, 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 smnmarized the scope and findings of the inspection.

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