IR 05000445/1989065
| ML20248C029 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/22/1989 |
| From: | Livermore H, Runyan M Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20248B965 | List: |
| References | |
| 50-445-89-65, 50-446-89-65, NUDOCS 8910030350 | |
| Download: ML20248C029 (16) | |
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APPENDIX B U.
S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION NRC Inspection Report:
50-445/89-65 Permits: CPPR-126 50-446/89-65 CPPR-127 Dockets: 50-445 Construction Permit 50-446 Expiration Dates:
Unit 1: August 1, 1991
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Unit 2: August 1, 1992
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Applicant:
TU Electric Skyway Tower 400 North Olive Street Lock Box 81
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Dallas, Texas 75201
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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:
JuAd4 9'22~Oi M.
F. Runyah, Resident Inspector, Date Civil Structural (paragraphs 3, 4, 5, 6, and 7)
Consultants: J. Dale, EG&G (paragraphs 2, 5, 6, and 7)
W.
Richins, Parameter (paragraphs 4, 5, 6, and 7)
i AD244{922,
$5"W Reviewed by:
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H. H. Livermore, Lead Senior Inspector Date
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8910030350 890922 PDR ADDCK 05000445 O
PNU
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2-Inspection Summary:
Inspection Conducted:
August 2 through September 5, 1989 (Report 50-445/89-65; 50-446/89-65)
Areas Inspected: Unannounced, resident safety inspection of applicant's actions on previous inspection findings; follow-up on violations / deviations; action on 10 CFR 50.55(e) deficiencies identified by the applicant; Unit 2 Service Water System piping coating. removal; evaluation of room / area completion walkdowns; and plant tours.
Results:
Within.the areas inspected, a weakness was identified in the applicant's room and area turnover program.
A team of NRC inspectors discovered numerous deficiencies in walkdowns of two
- rooms which had been turned over-to operations.
'A violation was identified (paragraph 6) involving seven examples of loose conduit fittings and hardware which were not discovered in the applicant's turnover program.
Additiona31y, three unresolved items were identified for the following concerns (paragraph 6):
a dust cover on a snubber which could rotate relative to the' snubber body, use of unspecified washers for Hilti: bolts, and the -validity of the applicant's claim that the upcoming " system walkdowns" would have identified many of the NRC walkdown items.
A strength was identified in the Unit 2 Service Water System plasite removal project (paragraph 5).
The applicant's efforts in this area have been marked by thoroughness, attention to detail, and a quality-first attitude.
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DETAILS 1.
Persons Contacted
- J.
L. Barker. Manager, ISEG, TU Electric
- D.
P. Barry, Director, 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 Prerident, Nuclear, TU Electric
- H.
M.
Carmichael, Senior QA Program Manager, CECO
- Je T.
Conly, APE-Licensing, Stone and Webster Engineering Corporation (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 CompliLnce 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. Krechting, Director of Technical Interface, 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
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- 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
- 0.
L. Thero, QTC Consultant to CASE
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- T.
G. Tyler, Director of Management Services, TU Electric K.
W. Van Dyne, Engineering Assurance, Southern Technical Services
- R.
C. Withrow, EA Manager, TU Olectric The NRC inspectors also interviewed other applicant employees during this inspection period.
- Denotes personnel present at the September 5, 1989, exit meeting.
2.
Applicant's Action on previous Inspection Findings (92701)
(Closed) Open Item (445/8516-O-39):
During a reinspection of heating, ventilation, and air-conditioning (HVAC) duct support Verification package I-S-HVDS-089, the Evaluation Research Corporation (ERC) inspector identified incorrect dimensions and welding abnormalities as being subject to evaluation as possible deviations.
These items were identified on Deviation.
Reports I-S-HVDS-089-DR-001,.-002, -003, -004, and -005, all of which were validated and transferred to nonconformance report (NCR) M85-102027X dated December 13, '985.
These nonconforming conditions will be addressed by Corrective Action Report (CAR)-111 through implementation of field verification method (FVM) CPE-FVM-CS-029.
The NCR dispositioned the dimensional errors "use-as-is" and required that the welding discrepancies be repaired.
These repairs were accomplished through the direction of Construction Operation Traveler (COT) DH-1-810-1N-2BB-01.
The NRC inspector reviewed all of the above documents, completed a field inspection on the HVAC support, and determined that the deficiencies had been adequately corrected.
This open item is closed.
3.
Follow-up on Violations / Deviations (92702)
(Closed) Violation (445/8919-V-01; 446/8919-V-01):
This violation addressed the inability of QC inspectors to properly measure stem angles on valves and tangent points on the incore instrument tubing system.
The applicant's first response to the Notice of Violation (NOV), TKK-89255, stated that the observed examples were isolated instances of QC inspectors failing to apply their knowledge and training properly.
As support for its position, the applicant provided data from the 79-14 as-built verification program, showing that less than three percent of approximately 3600 valves were found to exceed the 15 degree angular tolerance.
As preventive action, the QC inspectors were trained (or retrained) to measure valve stem angles using the triangulation method (which had previously been demonstrated to the NRC by the survey crew to be accurate to approximately il degree).
Following the training, the NRC inspector randomly selected two QC
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inspectors to demonstrate this method.
The demonstrated methodology and results were satisfactory.
The NRC inspector informed the applicant that the issue of QC training had not been sufficiently addressed in the first response to the NOV.
A series of meetings ensued after which the applicant submitted a supplemental response to the NOV (TXX-89459).
The supplemental response summarized an evaluation of QC inspector training and qualification methods, inspector performance records, inspection attributes requiring special methods or increased skill, and the appropriateness and quality of training materials.
The conclusion of this evaluation was that the overall training program was adequate and that the cited examples were isolated.
The NRC inspector reviewed documents related to the applicant's assessment of QC inspector training and determined that the training issue had been satisfactorily addressed.
There appeared to be satisfactory evidence that the cited
examples were isolated and that few other, if any, inspection attributes presented similar levels of difficulty.
The issues
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surrounding this violation have been adequately addressed.
j This violation is closed.
4.
Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant (92700)
a.
(Closed) Construction Deficiency (SDAR CP-80-05):
"Use of Architectural Concrete in Floor Slabs."
By letter TXX-3171 dated August 8, 1980, the applicant informed the NRC that a deficiency involving the use of architectural concrete in floor slabs was a reportable item.
The original structural concrete drawings specified that a 2-inch architectural grout topping be placed on top of floor slabs to facilitate the sloping of the finished surface to f3cor drains.
Because the topping was not placed under the control of the QA program, compressive strength test cylinders were not taken in all areas, leaving in doubt the design integrity of the topping and the quality of the bond between the topping and the parent concrete.
This caused a problem regarding the use of Hilti bolts designed for floor mounted conduit, cable trays, electrical equipment, and pipe supports, in that I
the 2-inch topping was incorrectly used as creditable
embedment length for the bolts.
As a result, many of I
these supports were anchored with Hilti bolts embedded (in structural concrete) two inches less than originally designed.
The seismic integrity of the equipment was, therefore, potentially compromised.
To prevent recurrence of this problem, the applicant revised procedure CEI-20, " Installation of Hilti
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Drilled-In Bolts," to define embedment length as applying to structural concrete only and to provide drawings specifying the locations where the 2-inch topping exists.
To account for existing installations, the applicant conducted a field survey of all Hilti bolts installed in areas having a 2-inch grout topping.
Information regarding the supports, bolt sizes, lengths, and projections was furnished to various groups having design responsibility for evaluation.
The subsequent evaluation resulted in a mix of "use-as-is" and " repair" dispositions.
All NCRs initiated as a result of this effort were closed as of October 20, 1986.
A similar issue was identified in NRC Inspection Report 50-445/88-36; 50-446/88-31.
An NRC-identified violation (445/8836-V-01) was issued for the inadequate embedment of two 3/8-inch Hilti bolts used for a conduit support on a concrete pedestal.
As in the previous case, the 3/8-inch Hilti bolts were inadequately embedded into structural concrete due to a 2-inch grout topping on the
concrete pedestal.
The Lepping in this case was used to l
level a large fan unit.
The corrective action in l
response to the violation included a complete plant survey of Hilti bolt embedments in concrete pedestals with an engineering analysis for each identified nonconformance.
The violation described above brings into question the adequacy of the corrective action taken for SDAR CP-80-05.
Evidently, the field survey conducted for the SDAR included only those areas.where entire floor slabs were topped with grout.
For the Auxiliary
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building, this included all floors below the 831'
elevation.
The violation was identified at elevation
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886' in the Auxiliary building.
In addition, it does not appear that the SDAR corrective action included any consideration of the topping placed on concrete pedestals at any elevation in the plant.
The corrective action taken for the violation has resolved the technical issue of grout topping placed on concrete pedestals, but the SDAR omission reflects a past weakness in the applicant's corrective action program to consider all of the generic implications of an identified problem.
The noted weakness applies to the 1980-1981 time frame and should be considered in that light.
The NRC inspector reviewed the SDAR documents and concluded that the combined corrective action provided in the SDAR and the' referenced violation has fully resolved the technical issue of Hilti embedments in areas of grout toppings.
This construction deficiency is closed.
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b.
(Closed) Construction Deficiency (SDAR CP-85-26):
Upper
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Lateral Restraint Embedment Design."
By letter TXX-4532 dated August 9, 1985, the applicant informed the NRC of a
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deficiency regarding the Unit 1 steam generator upper q
lateral restraint embedment design.
The applicant i
determined that this deficiency was not reportable pursuant to 10 CFR 50.55(e).-
The deficiency involved the design and analysis of the steam generator upper: lateral beam anchorage.
The beam end moment contribution to j
embedment pullout forces.was omitted. 'In addition, an I
assumption was made in the analysis that shear friction would resist embedment pullout stresses.
This assumption was unjustified.
The applicant performed confirmatory calculations to E
demonstrate that the upper lateral restraint and the
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concrete structure to which it is connected would perform the required function of supporting the steam generator.
An evaluation of the upper lateral support beam anchor.
bolts and the embedment plate hole threads (damaged i
during fabrication and/or construction) was completed'as part of ISAP V.b,
" Improper Shortening of Anchor Bolts in Steam Generator Upper Lateral Supports."
The required modifications for Unit 1 are complete.
The NRC inspector reviewed the SDAR file, supporting calculations, and the activities addressed by ISAP V.b (see SSER No. 20 and previous NRC Inspection Report 50-445/87-06; 50-446/87-05) and concluded that the applicant had satisfactorily addressed this issue.
c.
(Closed - Unit 1 only) Construction Deficiency (SDAR CP-87-55):
" Containment Spray Pump Recirculating Piping."
By letter TXX-88108 dated January 18,-1988, the applicant informed the NRC that a deficiency involving the containment spray recirculation piping was a'
reportable issue.
The piping and supports were installed
as nonnuclear safety (NNS)'ASME Class 5.-
However, commitments made in the Final Safety Analysis Report (FSAR) pursuant to ANSI B18.2 require that'this piping be j
installed ASME Class 2 with seismic Category I supports.
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l 87-1-088 was generated to replace the. subject Class 5 piping with ASME Class 2 pipe and seismic Category I
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supports.
These hardware modifications are' complete.
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study was conducted and documented in Engineering Report ER-ME-021 (October 21, 1988) to determine whether u
other similar inappropriate uses of NNS piping and i
supports had occurred.
This report concluded that the applicant's NNS piping classification practices are consistent with industry standards inasmuch as no other NNS piping was identified that required upgrading to a
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safety classification.
The applicant stated that future piping / support classifications will utilize Design Basis Document (DBD)ME-028, " Classification of Structures, Systems, and Components," to ensure that components are appropriately classified.
The NRC inspector reviewed the SDAR file, DMRC 87-1-088, Engineering Report ER-ME-021, and DBD-ME-028, and concluded that the applicant had adequately addressed this issue.
This construction deficiency is closed for Unit 1.
d.
(Open) Construction Deficiency (SDAR Cp-87-66):
" Structural Bolting in Tension."
By letter TXX-88173 dated February 4, 1988, the applicant informed the NRC that a deficiency involving structural bolting in tension was a reportable item.
For certain sliding connections, structural drawings specified hand tight bolts locked in place with a jam nut or spoiled threads.
In five instances, the applicant identified hand-tight nuts with threads improperly spoiled, in that the threads nearest the nut remained intact.
This condition could allow the nut to partially back out, thereby reducing the connection's capability of supporting the tensile loads-for which it was designed.
The applicant determined that the root cause of this deficiency was the failure of the design drawings and
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specifications to provide sufficient installation and i
inspection requirements to ensure proper thread spoiling for hand tight bolts.
Corrective action included a revision to Specification 2323-SS-16B, " Structural Steel / Miscellaneous Steel," to provide corrected installation and inspection criteria for hand tight
bolts.
A program to reinspect all applicable installed
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hardware to the revised specification was developed and executed.
NCRs were issued for all necessary rework.
The rework status as of August 24, 1989, indicated that 50 NCRs issued against Unit 1 and common remained open.
The NRC inspector reviewed the SDAR correspondence file, the revision to Specification 2323-SS-16B, and DCA 48417
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(which was issued to delineate the hardware validation
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program for exis?Atg hand-tight connections).
The NRC inspector concluand that the applicant had taken satisfactory action to resolve the technical concern.
This construction deficiency will remain open.pending completion of the field repairs.
l e.
(Open) Construction Deficiency (SDAR CP-87-ll5):
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" Seismic Analysis of Service Water Intake Structure."
By letter TXX-6984 dated November 18, 1987, the applicant I
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informed the NRC of a deficiency regarding the seismic analysis of the service water intake structure.
During design validation, SWEC determined that the soil-structure mass was underestimated and the soil I
subgrade stiffness was overestimated in the original analysis by Gibbs and Hill.
The result was abnormally high calculated natural frequencies of the soil-structure system.
A similar problem was identified for Category 1 concrete tanks, concerning which the NRC was informed by
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letter TXX-88055 dated September 28, 1988.
The applicant developed new seismic analyses and floor response spectra.
An assesament of the effects of the new analyses and floor response spectra was performed for d
the structures, equipment, components, and piping system.
One necessary modification was addressed by DCA 71229 regarding the required. replacement of valve body
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bolts for a valve actuator.
The completion of all piping and pipe support analyses is being performed under j
SDAR-CP-86-36 and SDAR-CP-86-72 as part of final
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reconciliation.
I The NRC inspector reviewed the SDAR file, supporting calculations, and DCA 71229 and concluded that the seismic analysis deficiencies have been adequately addressed by the applicant.
This construction deficiency will remain open pending completion of the activities associated with DCA 71229, SDAR CP-86-36, and SDAR CP-86-72.
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f.
(Open) Construction Deficiency (SDAR CP-88-14):
" Structural Load Verification of Seismic Category I l
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Structures."
By letter TXX-88179 dated February 4, 1988, the applicant informed the NRC that a deficiency
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involving load verification of seismic Category I l
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structures was a reportable item.
During the design validation program, the applicant determined that a final load verification program of adequate scope did not exist for seismic Category I structures.
This condition
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compromised the design integrity of these structures (of l
steel and concrete construction) due to loads placed upon
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them in addition to those in the original design.
The applicant evaluated the root cause of this deficiency as
the failure to provide a formally controlled program for
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load verification and concluded that the scope extended to all seismic Category I structures.
To restore confidence in the capability of seismic
Category I structures to perform their intended safety
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function under seismic conditions, the applicant
developed a final load verification program under Procedure PP-210, " Load verification of Seismic l
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Category I Structures."
All attachment loads to each Seismic Category I structure were identified and an analysis was performed to verify the design integrity of the existing configuration.
As-built drawings were updated to reestablish a baseline configuration control system.
At the time of the NRC review, the load verification of steel structures was complete.
As a result of this effort, some modifications were installed, mostly stiffener elements on platforms to resolve local bending concerns.
The work on concrete structures was still in process though the applicant did not expect that any concrete modifications would be necessary.
The NRC inspector reviewed Procedure PP-210 as well as other supporting procedures and concluded that the
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programmatic controls governing the load verification program were adequate.
For steel structures, the NRC inspector reviewed several documents including Structural Steel Evaluation Reports (SSAR) 001, 002, 003, 004, 011, 030, 040, 045, 051, 057, 098, 173, 183, and 207; and Structural Steel Design Evaluations (SSDE) 07, 09, 11, 15, and 32.
The SSARs listed the attachments to each structure (many structures had none) and the SSDEs evaluated those structures which bore significant attachments.
Based on this review, the NRC inspector concluded that the applicant's load verification program satisfactorily addressed the previously identified deficient condition.
This construction deficiency will remain open pending completion of the concrete analysis.
g.
(Closed - Unit 1 only) Construction Deficiency (SDAR CP-88-38):
" Steam Generator Relief Capacity."
By letter TXX-88844 dated December 14, 1988, the applicant informed the NRC that a deficiency involving the analysis of the design basis steam generator tube rupture (SGTR)
I event presented in Section 15 of the FSAR was a reportable item.
The analysis was based on an unconfirmed preliminary estimate of 420,000 lb/hr (at 1107 psia) relief capacity of the steam generator j
power operated relief valves (PORVs).
Calculations j
performed to confirm this assumption revealed that the actual PORV relief capacity was 711,469 lb/hr.
Since the accident analysis assumes a stuck-open PORV coincident with a primary to secondary leak, the additional PORV j
relief capacity resulted in higher calculated offsite i
radiological doses.
These doses were conservatively assumed to exceed allowable limits.
To prevent this type of analysis error from occurring again, Reactor Engineering procedures were amended to assure that
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accident analysis assumptions are provided to the appropriate engineering organizations for review.
The applicant revised the design basis SGTR analysis to reflect the increased PORV relief capacity.
The previous analysis had assumed that the PORV block valve could not be closed during this event because the manual operator was in close proximity to the steam discharge stacks.
To permit manual operation of the PORV block valve during this event, a 20-foot valve stem extension was installed (per DMRC-88-1-195) to relocate the handwheel operator to a position outside*the doorway of valve rooms 109A, B, C,
and D.
According to the applicant, this modification should permit the operation of the block valve in order to isolate a stuck-open PORV.
The revised FSAR (Section 15.6.3.3) analysis assumes that the block valve
can be shut within 30 minutes of the identification of a
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stuck-open PORV.
With this assumption, the resulting radiological consequences of this accident are well i
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The NRC inspector reviewed DMRC 88-1-195 and inspected the PORV block valve modification in the field.
The assumption that the block valves could be operated during a PORV blowdown appeared reasonable based on the present configuration.
The NRC inspector reviewed calculation No. BME-CA-0000-650, Revision 1, which calculates the radiological consequences of an SGTR assuming the i
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capability of operating the PORV block valves.
Based on this review, the NRC inspector concluded that the applicant had taken adequate corrective action for this deficiency.
The possibility that similar errors may currently exist in other design basis analyses is lessened by the fact that the process by which this error I
was found (removing a confirmation on a calculation)
would have also identified other similar errors.
This construction deficiency is closed for Unit 1.
h.
(Open) Construction Deficiency (SDAR CP-89-17):
" Control Room HVAC System Damper Leakage."
By letter TXX-89487 dated July 24, 1989, the applicant informed the NRC that a deficiency involving control room HVAC system damper leakage was a reportable item.
The applicant determined that potential unfiltered leakage paths into the control room existed such that, in the event of a loss of coolant accident (LOCA), control room personnel would receive excessive radiation doses.
The deficiency was caused by the use of dampers in lieu of leak-tight butterfly valves to provide isolation of air ducts which connect to outdoor makeup and exhaust.
The dampers permit unacceptable leakage into the control room.
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The applicant determined that this deficiency was unique to the control room HVAC system.
Design modifications
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incorporated in DCAs 28966, 84546, 84696, and 84697 will j
be installed to correct this problem by ensuring that all i
leakage from the makeup system into the control room will be filtered and by maintaining the control room at a positive pressure to prevent in-leakage from the exhaust system.
The applicant plans to bnplement these
modifications prior to fuel load for each unit.
The NRC inspector reviewed the SDAR file and the
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referenced DCAs and determined that the applicant had taken satisfactory action to address the technical concern.
This construction deficiency will remain open until the associated hardware modifications are installed.
5.
Unit 2 Service Water System Piping Coating Removal (49063)
The NRC inspector crawled through approximately 200 feet of Unit 2 30-inch Service Water System (SWS) piping after the i
plasite coating had been removed by sandblasting.
All of the j
plasite had been removed except for a few small " specks" which j
were well within the acceptance criteria for size.
The internal condition of the pipe was excellent showing no signs of damage from the blasting process.
Several small corrosion
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pits were evident, but none of these exceeded the criteria for
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minimum wall thickness.
Based on this review, it appears that
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the Unit 2 30-inch SWS piping coating removal is being l
performed in a quality manner.
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The NRC inspector witnessed the remote rotary spin abrasive blasting of a segment of 10-inch service water piping on the 810 foot elevation.
A video monitor was available for process control purposes, showing the progress of plasite removal and providing a means to monitor the spinblaster's rate of rotation.
A minimum rotation rate is specified to prevent excessive pipe wall thinning in localized areas.
Based on this field observation, the NRC inspector concluded that the-plasite removal of the 10-inch service water pipe is being well controlled and should provide adequate results.
The applicant's final acceptance of the plasite removal in the 10-inch pipe will be based on a detailed videotaping of the pipe interior in conjunction with ultrasonic testing of selected areas.
No violations or deviations were identified.
The overall Unit 2 service water system effort has been excellent and is identified as a strength.
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6.
Evaluation of Room / Area Completion Walkdowns (46053,-48053, 50100, 55100, 51053)
i The applicant is performing room and area completion walkdowns per Procedure ECC 9.11, Revision 4, to verify and document that work activities are completed and to document items which need to be completed on Room / Area Punchlists (RAP).
Items identified on RAP sheets are reworked as necessary and the RAP sheets are reviewed by construction engineers to veriif that all items are closed.
l Six NRC inspectors reviewed the RAP sheets for rooms 74 and q
198 (Packages 1-RAP-074 and 1-RAP-198) and inspected the rooms to evaluate the adequacy of the applicant's room and area turnover activities.
The NRC inspectors identified the following conditions not identified on the RAP sheets which are in violation of Specification ES-100, Revision 6,
" Electrical Installation."
a.
In room 74, conduits C14007913, 13G01422, C1 PAS 11, and C13034061 had loose fittings.
b.
In room 74, an elbow for conduit C13001413 had loose screws.
c.
In room 74, junction boxes JB15-0169, JB1S-177G, and JB1S-165G had loose screws.
d.
In room 74, a mounting bracket for a conduit support near CIMS-S37-25 upper bracket was loose.
I e.
In room 74, emergency light' panel CP1-ELBP-SG-284 had a spring nut off the unistruct channel.
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f.
In room 198, electrical junction box _TC061 had loose
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conduit fittings.
i g.
In room 198, conduits C11G08147 and C11K11273 had loose l
fittings.
The above conditions are a violation of Criterion V of Appendix B to 10 CFR Part 50 (445/8965-V-01).
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l In addition, the NRC inspectors identified abandoned Hilti l
bolt holes that were not patched and some. trash inLa conduit
support.
Generally, the rooms appeared-to.be unfinished with numerous construction activities being-performed..
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l During the room and area walkdown in room 198,'the NRC inspectors observed a snubber, mark No. CC-1-043-010-A43K, cn1 which the dust cover or position tube indicator could rotate
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relative to the snubber body..This condition allows the end
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cap to rotate relative to the body (or housing).
Pacific Scientific (the manufacturer of the base unit)-Installation and Maintenance Manual provides detailed instructions on how to orient the end plug relative to the body if necessary.
These instructions imply that the end cap and snubbar body should rotate as a single unit provided the snubber is manufactured and installed correctly.
This item will remain unresolved pending applicant evaluation and response (445/8965-U-02).
In room 74, the NRC inspectors noted two conduit supports, C13017417-19 and C14015045-1, which had Hilti Kwik Bolts (HKB)
installed using Unistrut P1064 washers.
The applicant stated that these supports are CSM-37b multi-directional supports and installed per design.
However, Specification 2323-SS-30, Revision 4, " Structural Embedments" states, "For installation of Hilti Kwik bolts._.. steel plate and/or standard or hardened steel washers, conforming to ASTM A36, F844, or F436 respectively, may be substituted for the Hilti supplied washers.
The applicant stated that the Unistrut
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washer is made'from ASTM A575 material.
The-inspector notes that this material is not listed in Table I of ASTM A36.
This item will remain unresolved pending applicant review-of this material relative to the requirements of Specification 2323-SS-30 (445/8965-U-03)~.
During the NRC inspections of rooms 74 and 198, the NRC inspectors identified the following deficiencies in system related components:
Room 74 Temporary supports (work in progress)
Pipe leak (work in progress)
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Disconnected snubber (work in progress)
Bent tubing All gland nuts loose on an instrument rack Loose bolt on a valve flange Broken face plate on'I/P control unit Bolt without washer on an HVAC grill Instrument tube support bolts loose Room 198 Connection loose on temperature element j
Unparallel flange faces Leaking valve
Loose nuta on HVAC grill i
Lock washer not bottomed out and bolt without washer-on a valve
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Gasket damaged on power junction box
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Bolt loose on junction box cover
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15-These deficiencies were presented to the applicant along with the deficiencies found in the rooms and areas.
The applicant took actions to have the system related deficiencies corrected, but explained that systems in these two rooms-had not been turned over and that they were not looked at as part of the room / area turnover process.
The. turnover of. systems to Operations is controlled by Operations Procedure STA-802,
" Acceptance of Station Systems and Equipment."
Procedure STA-802 provides for the acceptance of systems, subsystems, and equipment based on three actions.
Those actions are:
(1) review of outstanding work items, (2) a walkdown of systems for operability, maintainability, and identification of any damage, and (3) review of testing status.
However, NRC review of Section 6.4 ("Walkdowns") of that procedure determined that the procedure provided only superficial guidance for the conduct of the system walkdowns, few examples of items to be checked, and little or no acceptance criteria.
Based on the determination that procedural guidance provided for system walkdowns is potentially inadequate and the applicant's explanation that the detailed walkdowns required for rooms and areas are not applicable to systems, the NRC inspector deems that there is no reasonable assurance that system-related deficiencies will be identified and corrected.
Therefore, pending-applicant clarification of.the system walkdown process and NRC inspection of the-adequacy of systems, this issue is an unresolved item (445/8965-U-04).
The combination of these findings (one violation-and three unresolved items) is considered to constitute a weakness in
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the applicant's room and turnover process.
7.
Plant Tours (42051C, 46053, 48053)
The NRC inspectors made frequent tours of Unit 1, Unit 2, and common areas of the facility to' observe items such as housekeeping, equipment protection, and in-process work activities.
No violations or deviations were identified and no items of significance were observed.
8.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.
Three unresolved items disclosed during the inspection are discussed in paragraph 6.
9.
Exit Meeting (30703)
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
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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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