IR 05000445/1989073

Insp Repts 50-445/89-73 & 50-446/89-73 on 890906-1003. Violations Noted.Major Areas Inspected:Applicant Actions on Previous Insp Findings,Followup on Violations & Deviations, Action on 10CFR50.55(e) Deficiencies & General Plant Tours

ML19325E820
Person / Time
Site:	Comanche Peak
Issue date:	10/30/1989
From:	Latta R, Livermore H Office of Nuclear Reactor Regulation
To:
Shared Package
ML19325E817	List: IR 05000445/1989073 ML19325E815 ML19325E818
References
50-445-89-73, 50-446-89-73, NUDOCS 8911090072
Download: ML19325E820 (27)

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Appendix B

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U. S. NUCLEAR REGULATORY COMMISSION

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OFFICE OF NUCLEAR REACTOR REGULATION

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NRC Inspection Report:

50-445/89-73 Permits: CPPR-126

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50-446/89-73 CPPR-127 l Dockets: 50-445 Construction Permit 50-446 Expiration Dates:

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-Unit 1: August 1, 1991 Augu't 1, 1992 Unit 2:

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Applicant:

TU Electric Skyway Tower r'

400 North Olive Street Lock Box ~81

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Dallas, Texas 75201

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Facility Names Comanche Peak Steam Electric Station (CPSES),

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Units 1 & 2 s

Inspection At:

Comanche Peak Site, Glen Rose, Texas

. Inspection Conducted:

September 6 through October 3, 1989

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Inspector:

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N!,27/g7 IP t-

,c R. M. Latta, Resident Inspector Date

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(paragraphs 2, 3, 4,

5, 6, 7, 8, 9, and 10)

l Consultant:

J. Dale - EG&G (paragraph 5)

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W.

D. Richins - Parameter (paragraph 7)

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L. Taylor - Parameter (paragraphs 4, 6, and 8)

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Reviewed by:

u-EAAuCL- (

/6/30/

H. H. Livermore, Lead Senior Inspector tate /

g1090072391030 fJ,T G

ADOCK 05000445 PNU

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I Inspection ~ Summary:

Inspection Conducted:

September 6 through October 3, 1989-(Report 50-445/89-73: 50-446/89-73)

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Areas Inspected:-Unannounced, resident safety inspection of the applicant's actions on previous inspection findings; follow-up on

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violations / deviations; action on 10 CFR 50.55(e) deficiencies identified by the applicant; allegation follow-up; electrical.

components and systems;' safety-related mechanical components; and

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general plant tours.

. Results:

Within the areas inspected no significant strengths or

- weaknesses were identified.

One open item was identified regarding

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the failure of check valves during reverse flow operability testing.

Eleven additional open items resulting from the NRC Augmented Inspection' Team (AIT) evaluation of nultiple check valve f ailures experienced during hot functional testing (HFT) are also-identified in

- this report (paragraph 7).

During this inspection period, three violations were identified'concerning welding deficiencies and the applicant's failure to take prompt corrective. action associated with HVA,C system welding allegations (paragraph 5.b).

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, DETAILS

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Persons Contacted

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• J.

L. Barker, Manager, ISEG, TU Electric l

• D.

P. Barry, Senior, Manager, Engineering, Stone and Webster

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Engineering Corporation (SWEC)

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• 0.

Bhatty, Issue Interface Coordinator, TU E3ectric

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• M.. P.. Blevins, Manager of Nuclear Operations Support, TU Electric

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• R.

C. Byrd, Manager, Quality Control (QC), TU Electric

• W.

J.

Cahill, Executive Vice President, Nuclear, TU Electric

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• H. M. Carmichael, Senior Quality Assurance (QA) Program Manager, CECO

• J.

T..Conly, APE-Licensing. SWEC

• W.

G. Counsil, Vice Chairman, Nuclear, TU Electric

• B.

S. Dacko, Licensing Engineer, TU Electric i

• R.

J. Daly, Manager, Startup., TU Electric

• G.

G. Davis, Nuclear Operatiens Inspection Report Item Coordinator, TU Electric

• S..L.

Ellis, Performance and. Testing, TU Electric

• J.

C.

Finneran, Jr., Manager, Civil Engineernag,

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TU Electric

• J.

L. French, Independent Advisory Group

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• W.

G.

Guldemond, Manager of Site Licensing, TU Electric

• T.

L. Heatherly, Licensing Compliance Engineer, TU Electric

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• J.

C. Hicks, Licensing Compliance Manager, TU Electric

• A.

Husain, Director, Reactor Engineering,-TU Electric

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• J.

J. Kelley, Plant Manager, TU Electric

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• J.

E. Krechting, Director of Technical 7.nterface, TU Electric

• 0.

W.

Lowe, Director of Engineering, TU Electric

• D.

M. McAfee, Manager, QA, TU Electric

• S.

G. McBee, NRC Interfacn TU Electric e

• J.

W.

Muffett, Manager of Project Engineering, TU Electric

• E.

F. Ottney, Program Manager, CASE mO

• S.

S.

Palmer, Project Manager, TU Electric

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• P.

Raysircar, Deputy Director / Senior Engineer Manager, f

CECO

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• M.

J.

Riggs, Plant Evaluation Manager, Operations,

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TU Electric u

• J.

C.

Smith,. Plant Operations Staff, TU Electric

• R.

L. Spence, TU/QA Senior-Advisor, TU Electric

• P. B.

Stevens, Manager of Operations Support, 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

• R.

G. Withrow, EA Manager, TU Electric The NRC inspectors also interviewed other applicant employees during this inspection period.

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• Denotes personnel present at the october 3, 1989, exit

meeting.

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2.

Applicant's Action on Previous Inspection Findings (92701)

(Closed) Open Item (445/8632-0-01):

Heat tracing on containment atmosphere sample line.

This item was opened to track the

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inspection and rework of the electrical heat tracing on a 1-inch

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containment atmosphere sample line.

The damaged heat tracing was

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determined to be loose and the covering tape had been pulled back

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to reveal adhesive material remaining on the pipe in Room 88 of

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the Unit 1 Safcguards building.

The NRC inspector reviewed the associated closecut documentation which included:

DMRC 87-1-049,

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Design Change Authorization (DCA) 61617, and several travelers including JB-1HT0313-153-T1.

Based on these reviews and inspection of the repaired heat tracing in Room 88, the NRC inspector determined that the subject heat tracing had been

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replaced, that the installation appeared complete, and that the

sample lines had been properly insulated. 'Therefore, this open

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item 1.s closed.

3.

. Follow-up on Violations / Deviations (92702)

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(Closed) Violation EA 86-09, Appendix A, Item 1.C.1:

QC inspectors failed to witness butt splices of control and

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instrumentation connections.

In particular, this violation involved the failure of specific QC inspectors to perform required observaticus specified in the controlling Procedure

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QI-QP-11.3-28.

As documented in TU Electric's revised response to this violation cantained in TXX-88792 dated November 30, 1988,

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the applicant's coirective actions included reinspections to ensure that all buct splices have been properly identified on the appropriate desigri drawings.

The scope and methodology utilized by the applicant to verify that all splices were properly i

inspected and to insure that similar conditions did not reoccur

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were delineated in Issue-Specific Action Plans (ISAP) I.a.2 and VII.C respectively.

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The NRC inspector reviewed the results of these ISAPs as well as Corrective Action Request (CAR) 50 which was issued to address the questionable performance of four QC inspectors.

The NRC inspector also reviewed the completea training records for personnel working in accordance with Procedure QI-QP-11.3-28, Class 1E Cable Terminations," as well as Revision 24,

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Procedure CP-QP-2.1, Revisicn 18, " Training of Inspection Personnel," and its current (replacement) Procedure NQA 1.16,

" Introduction and Training of Quality Assurance Personnel."

Based on these reviews and evaluations, the NRC inspector detertained that the applicant's corrective actions which included retraining of all electrical QC personnel appeared adequate to prevent reoccurrence of this violation.

This item is closed.

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4.

Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant (92700)

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(Closed) Construction Deficiency (SDAR CP-87-16):

" Limit Switch Wiring."

This deficiency, which was determined by the applicant.to be reportable, involved the routing of cables / conduits to the wrong limit switches and the termination of cables to the wrong contacts on the limit switches.

As a result of this issue, CAR-049 was initiated to disposition Unit 2 discrepancies.

Field Verification Method:(FVM)-089 as well as Startup Prerequisite Test Instruction XCP-EE-8 have been implemented to address Unit 1 deficiencies.

FVM-089 has been reviewed and accepted as part of the Corrective Action Program (CAP) closecut as documented in previous NRC reports.

Additional corrective actions, initiated by the applicant, included revising-Design Basis Document (DBD)-EE-054 to incorporate terminal board identifications on controlled drawings and the

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development of a new drawing series, 2323-El-0075, to provide-specific limit switch identifications and orientations.

The NRC inspector reviewed the above documentation as well as a sample of 5 out of approximately 55 DCAs/NCRs which had been issued to correct the subject deficiencies.

Based on the above reviews and inspection activities, the NRC inspector determined that the applicant had taken adequate corrective measure for both Units 1 and 2.

This construction deficiency is closed.

b.

(Closed) Construction Deficiency (SDAR CP-87-85):

" Degradation of Class lE Circuits."

This deficiency resulted from the direct connection cf the Safety Systems Inoperable Indication (SSII) panel which is non-Class 1E, to Class 1E circuits.

Additionally, the cables used to make these connections which had been routed with Class lE cables did not have any supporting documentation which established l

cheir qualification to Class lE standards.

Subsequent

justification for this condition was supported by an analysis which determined that the low energy instrumentation signals on the non-Class 1E cables would not

have resulted in the degradation of Class 1E circuits.

This

analysis has becn included in an advance FSAR chLnge submitted to the NRC by letter TXX 89578 dated August 15, 1989.

The NRC inspector reviewed the above documentation,

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as well as the National Electrical Code wiring ratings

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tables for the wiring sizes involved, and concluded that the

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justification for nonreportability was acceptable.

This construction deficiency is closed.

c.

(Closed) Construction Deficiency (SDAR CP-89-006):

"6.9kv Breaker Charging Motor Linkago."

This construction deficiency involved the applicant's reported loss of a connecting pin between the charging motor linkage and the

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breaker' closing springs on several Brown Boveri breakers.

The applicant determined that the deficiency was reportable

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and inspections of all affected breakers as well as i

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I revisions to maintenance procedures were initiated to address the deficiency and to prohibit the reuse of the connecting pin snap-ring retainers.- The NRC inspector i

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reviewed the associated: nonconformance reports

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(NCRs) 89-01847, Revision 0, (Unit 1 breakers) and 89-02475, Revision C, (Unit 2' breakers) and determined the disposition of the'NCRs was acceptable.

Additionally, the NRC inspector i

observed the applicant's inspections of several of the 1E

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L breakers, as documented in NRC Inspection i

Report 50-445/89-64; 50-446/89-64.

Based on the referenced

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l nonconformance' report (NCR) reviews and the inspections

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performed on there 6.9kv breakers, the NRC inspector determined that the applicant's corrective measures and maintenance practices including those proposed for Unit 2 were acceptable.

This construction deficiency is closed for both Units 1 and 2.

d.

(Closed - Unit 1 only) Construction Deficiency (SDAR.

o CP-87-135):

" Control Room Air-Conditioning and Primary plant Ventilation Systems."

This issue involved-

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inadequacies in the safety-related control cirec4ts for the

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redundant trains associated with the control room HVAC system which were not designed to meet the single failure

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criteria.

Specifically, as determined by the applicant, the

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control room HVAC system was susceptible to a single failure which could have prevented the automatic isolation of the system under accident conditions.

Additionally, the

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auxiliary, safeguard, and fuel building ventilation supply fans were powered from a non-Class'1E power supply and were.

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I automatically tripped by nonsafety-related pressure switches.

The significance of these inadequacies was that

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the capability to limit the radiation dose received by control room operators during postulated accident conditions

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to within FSAR limits was compromised and.that the post-LOCA offsite dose could have'been increased above the dose levels specified in the FSAR.

The NRC inspector reviewed the applicant's corrective actions stated in TU letter TKX,88013 dated January 29, 1989, which included the modification of the control room HVAC system to incorporate the single failure design

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criteria specified in the DBD EE-054, " Control Circuits parameters / Loading Requirements" and IEEE-323.

The NRC inspector also reviewed the applicant's design change specified in letter TXX-89356 dated July 14, 1989, which j

identified the inclusion of safety-related controls to automatically trip the primary plant ventilation system supply fans.

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Based on these docunent reviews and selected system

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inspections of Unit 1 components, the NRC inspector

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concluded that the applicant's corrective actions appeared

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'to be-adequate.

This construction deficiency is closed for E'

Unit l'only.

e.

(closed - Unit 1 only) Construction Deficiency (SDAR CP-88-08):

" Battery Room Heaters."

As previously

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reported in NRC Inspection Report-50-445/89-64;

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50-446/89-64, this deficiency involved the replacement of

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battery room heaters with Class lE seismically qualified t,

units powered from redundant Class lE power supplies.

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During this reporting period, the applicant subsequently provided the NRC inspector with a list of work packages

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which indicated the status for the completion of this work.

A review of this. work schedule indicated that approximately

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half of the listed packages were identified as being complete.

-The NRC inspector examined the' installation.of two of the bhttery roon heaters and determined that the corrective construction activities for these battery rooms appeared to be complete.

Based on a review of the completed -

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installations and the work packages in place for Unit 1, the NRC inspector determined that the applicant's corrective

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actions and committed completion schedules prior to fuel load for Unit 1 is acceptable.

Therefore, this construction deficiency is closed of Unit 1 only.

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(Closed - Unit 1 only) Construction Deficiency

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(SDAR CP-89-16):

" Turbine Driven Auxiliary Feedwater Pump i

overspeed Trip."

This deficiency involved a potentially

reportable concern relative to the setpoint tolerance on the

turbine driven auxiliary feedwater (TDAFW) pump mechanical

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overspeed trip device which could'have resulted in the overpressurication of the AFW system including the pump casing.

As documented in the applicant's final report contained in letter TXX-89494, the'TDAFW pump was designed to trip if the turbine overspeed reached 125% of the. turbine rated speed.

During uncoupled overspeed testing cf the auxiliary feedwater (AFW) pump turbine, the turbine tripped

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at a speed of 5147 Ievolutions per minute (RFM) which was

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three RPM over the maximum allowable trip speed (including L

setpoint tolerance) of 5144 RPM.

Subsequent review indicated that the maximum allowable trip speed (including setpoint tolerance) was 44 RPM higher-than the maximum speed a

i utilized for the maximum system pressure calculation.

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The inspector reviewed the supporting engineering calculation No. ME(B)022, Revision 4, ar.d determined that the maximum reported RPM was marginally below the value used in the established system design pressures for the AFW during postulated accident conditions.

Moreover:

(1) no equipment damage was incurred during testing in that the

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j turbine overspeed testing was performed with the turbine

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uncoupled and pressures experienced by the turbine during

overspeed testing did not exceed the turbine design

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pressure, and (2) the turbine overspeed setting has been l

reduced from 25% to 16.6% over rated speed and will be'

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tested in the future with the turbine uncoupled.

Based on

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these reviews, the NRC inspector determined that the

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applicant's assessment of nonreportsbility was acceptable.

and that the supporting analysis was adequate.

This

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deficiency is. closed for Unit 1 only.

g.

(Closed)' Construction Deficiency (SDAR CE-89-018):

" Soldering in Elgar Inverters."

The applicant reported finding cracked, broken, or defective solder joints cnu l

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terminal block drive board connections, a transformer to

drive board. connection, and on the drive board connector.

i pins in various Elgar invertecs.

As determined by the i

applicant, the defective joints were attributable to I

troubleshooting and maintenance activities related to

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Inspection and Enforcement'(IE) Notice 88-57.

This' Notice involved information relative to the proper torquing of

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silicon controlled. rectifiers (SCRs) to circuit boards / heat

sink connections.

The NRC inspector reviewed the f

applicant's corrective actions which include reinspection of

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all Elgar inverters by a factory representative, training of

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maintenance personnel, and issuance of appropriate NCRs

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and/or work orders.

The Elgar trip report dated

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i September-15, 1989 detailed the vendor's findings for both Units 1 and 2 inverters and the training which was provided to the applicant's personnel.

Additionally, the NRC

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inspector reviewed several associsted work orders and determined that the vendor recommendations had been implemented by the applicant.: Based on;the above reviews

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and inspections, the NRC inspector determined that the

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corrective actions were adequate and that the administrative

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programs in place should assure appropriate follow-up of the'

work items on Unit 2.

This construction deficiency is

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closed.

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(Closed - Unit 1 only) Construction Deficiency (SDAR CP-89-22):

" Atmospheric Cleanup Heater Control panels."

This issue involved two of the primary plant ventilation system engineered safety features exhaust filtration unit

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control panels which were determined not to be seismically y

qualified.

In particular, control panels CPX-VAFUPK-Olp and

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-02P were not supplied by the manufacturer with the appropriate documentation to certify that these panels were seismically qualified.

Additionally, as stated in the applicant's letter TXX-89673 dated September 13, 1989, CPSES calculations demonstrated that the specified requirement for an overall natural frequency of equal to or greater than 33 I;ertz had not been met by these panels.

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Subsequent to the applicant's determination that the' subject'

I panels were not qualified for their safety-related application, CAR 88-31 was initiated to. identify and resolve concerns related to the failure of the manufacturer to

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properly' comply with the purchase specification requirements.

The applicant also initiated Field j

Requisition 6R374900 to purchase seismically qualified

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m replacement heater control panels.

The NRC inspector examined the applicant's completed i

corrective actions associated with this issue including NCR 89-8130, Revision 0, P.O.

665-72045, and DCA 75000, i

Revision 4.

Based on these reviews, the NRC inspector determined that the applicant's' actions in replacing the

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subject heater control panels with seismically qualified..

components was acceptable and that this issue was adequately

resolved for Unit 1.

However, pending the implementation of corrective action, this item will remain open for Unit 2.

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5.

' Allegation Follow-up (50100, 55100, 99014)

a.

(Open) Allegation (OSp-88-A-0053):

As previously documented i

in NRC Inspection Report 50-445/89-04; 50-446/89-04 this,

. allegation concerned installation practices utilized on Conax electrical penetrations.

These penetrations contained j

Kapton insulated wiring in various conductor' sizes.

Specifically, the issues were that installation practices L

violated the specified minimum bend radius requirements p

during the arrangement of conductors'in the cable trays and

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I that inappropriate care was exercised in the installation L

process to protect the conductors from damage.

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concern was expressed relative to the applicant's practice I

of bundling the conductors together and tie wrapping them.to

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the lateral Jupports in the. bottom of the cable trays in

that plant induced vibration could then result in chaffing of the Kapton insulation.

This chaffing could result in a

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L direct short, thus affecting both control and instrumentation functions.

Although these concerns were

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identified in Unic 2, they have generic implications for Unit 1 penetrations which also utilize Conax penetrations with Kapton insulated conductors.

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The evaluations conducted by the NRC inspectors and i

documented in the referenced inspection report indicated

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that the applicant had adequately addressed the potential design concerns relative to the functional adequacy of i

installed Kapton jnsulated Class lE equipment.

Additionally, the applicant had identified all applications

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of Kapton insulation at CPSES and did not plan any further action in regard to redesign or replacement of Kapton.

The allegation relative to the installation deficiencies remained open pending completion of detailed inspections to y

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be performed by TU Electric in accordance with Electrical

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Specification ES-100 prior to the installation.of cable tray

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covers in the penetration areas.

During the latter portion of'this reporting period, the L,,

applicant initiated their cable inspection program.which

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included both safety-related and ncnsafety-related Kapton.

insulated penetration termination configurations.

The NRC i

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inspectors witnessed approximately.15 of these inspections L

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and determined that the electrical craft personnel involved I

in the cleaning and preservation activities were sensitive to the special handling requirements associated with Kapton

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and that defects identified by craft personnel were brought

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to the attention of the inspecting organization.

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Additionally, it was obaerved that the inspecting personnel l

(QC for Class lE applications and construction engineering

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i (CE) for non-Class lE applications) were familiar with the

inspection requirements of electrical Specification ES-100

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and that identified deficiencies were properly documented.

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The NRC inspector also attended a scheduled training session Jr

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conducted for the second shift craft personnel and

construction / field engineers regarding inspection cf Kapton.

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wiring and the subsequent installation of cable tray covers.

The training appeared to be very thorough and it emphasized:

I the adherence to Specification ES-100, the. referral of all questionable Kapton configurations to engineering, the-j

. applicable inspection requirements, and the necessity for

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careful handling of the Kapton insulated conductors.

On September 28, 1989, while QC personnel were. performing an inspection of a junction box associated with a containment t

penetration, several of the Kapton insulated conductors at r

L the penetration were inadvertently grounded to a cross brace

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L in the junction box.

The incident resulted in the I

insulation breakdown of two of the conductors and the

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flash-over damage to approximately three adjacent

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conductors.

Based on the available information, it could l

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not be determined if the electrical grounding was caused by

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a previous defect in the Kapton covering or as a result of l

possible wear due to the rubbing of the wire on the structure brace.

The conductors involved provided power to

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F one of the redundant Unit 1 Train A, RHR pump suction L

isolation valves.

The applicant is currently in the process of evaluating the implications of this event including the.

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generic ramifications.

At the conclusion of the inspection period, the applicant's

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implementation of their penetration inspection and cable O

tray installation program was still in progress and no conclusions have been developed regarding its acceptability.

Therefore, this allegation will remain open pending the

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Lf applicant's completion of inspections of Kapton insulated p

penetration configurations for Unit 1.

b.

(Open) Allegation (OSP-89-A-0061):

This allegation involved

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a former worker's concerns relative to safety issues which t

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were identified to members of the NRC resident staff at

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Comanche Peak on July 13, 1989.

The initial concerns relating to plant electrical components-and systems are addressed'in NRC Inspection Report-50-445/89-64; 50-446/89-64.

This report will address the remaining i

concerns which involve welding issues.

The first welding concern identified by the alleger was that during the welding process when the HVAC welding checklist continuation sheet required shielded metal arc welding (SMAW) using welding process No. CHV-501, the craft used the

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gas metal arc welding (GMAW) process in order to speed up the welding process.

The alleger went on to state that up

,a-until January / February of 1989 the procedures had allowed the welder to GMAW all the joints on the duct flanges, but that' subsequent changes in procedures (CSP-FD-HV-501, 502, and 504) mandated the use of E7018 (stick).9 MAW.

The alleger stated that this had been previously identified.to SAFETEAM'and' Corporate Security.

The alleger also expressed.

concerns that the SAFETEAM and Corporate Security would try to cover this up.

h The NRC inspector reviewed the SAFETEAM and Corporate Security reports with the following results:

SAFETEAM

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L reviewed the concerns and found cause for an investigation by Corporate Security thereby relinquishing the concern to l-Corporate Security on or about June 15, 1989.

Corporate-Security interviewed the. alleger for any further information i

he might have.

They then interviewed four additional

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welders and one welding foreman on July 10, 1989, with the following results:

the welders had knowledge of other

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personnel performing GMAW welds in lieu of the SMAW stick

e welds that were specified in the work package weld records.

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The wolders claimed that a significant percentage of the

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L welders currently do this.

The welding foreman, however, q

E claimed to have never witnessed this action and further i

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indicated that it was strictly prohibited.

Corporate

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L Security's investigation concluded that evidence existed

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I that suggested numerous procedural violations had occurred

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in the HVAC welding process and that a significant number of welds that were procedurally required to be SMAW stick welds

were in fact gas metal arc (GMAW) welds in their response to

'

SAFETEAM dated August 14, 1989.

The NRC inspector reviewed the applicant's welding Procedures FD-HV-501, -502, -504, and CSP-CHV-107 as well as

'

DCA 75357, Revision 5, issued January 23, 1989, which

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,e resulted in'the revision of Specification 2323-MS-85 to i

change welding of sheet metal to structural steel from j

AWS D9.1 to AWS D1.1 requirements.

This DCA essentially.

j changed the definition of ductwork such that' subsequent to I

,

the DCA all angle iron reinforcement was classified as

structural steel which res ired SMAW (AWS Dl.1).. The i

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inspector also performed detailed walkdowns of HVAC ductwork in the Unit 1 safeguards building as well:as the fuel

,

' building and conducted interviews with three welders-J currently involved with HVAC ductwork fabrication.

-

Additionally, the NRC inspector reviewed selected samples of j

the welding surveillance check lists performed in accordance i

with process Procedure' CSP-CHV-107 covering the period; between March 23, 1989, and June 6, 1989.

This review indicated that during this time frame their were

,

approximately seven examples of welders performing GMAW l

welds on: square grove butt welds, which is not allowed by

Specification'2323-MS-85.

These examples were identified by welding technicians and were documented on the welding i

surveillance checklists provided by the applicant.

i Based on the review of the above stated DCA and the associated specification, welding procedures, and' welder j

surveillance checklists, combined with the inspections of installed HVAC stiffeners and supports, the documentation reviews of Corporate Security files, and the examination of

construction travelers ~and weld withdrawr.1 slips, the NRC l

inspector concluded that this portion of the allegation was substantiated and that this condition does exist.

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Given that the square grove butt welds on the HVAC companion j

angle flanges are characterized as seal welds which are not

.taken credit for in the applicant's structural / seismic analysis, the impact on the design and adequacy of the HVAC J

!

companion angle flanges is negligible.

However, in that the H

applicant's' program failed to control the application of the j

specified weld process at the subject weld joints and that

'

there is a potential that this practice may have resulted in the misapplication of GMAW welds on other structural weld j

joints which specified SMAW, this example of failure to

follow procedures by the applicant's welding personnel is identified as a violation (445/8973-V-01).

,

The alleger's second welding concern involved the welders use of rod withdrawal slips and weld records for recording the identifications of the welder making the weld.

The

'

alleger expressed his concern that some of the welders making the welds were not certified for the welding process being used, for example, SMAW versus GMAW, and that when this was the case a welder that was certified to the process being used would then sign for and claim as his the weld in question.

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During the Corporate Security interview identified in the

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preceding. concern, two of the welders had made specific

. mention of having seen this practice and one of them having

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had this happen to him.

The. welder personally examined the'

weld to determine if it looked good to him.

Corporate

-

Security felt that due to the similarity of events, the alleger may be referring to a previously identified welding foreman who was alleged to have committed similar acts.

.

However, the NRC inspector, during a document review found'

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several weld records that did not coincide with the rod

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withdrawal slips.

These examples included Traveler

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No. B-1-3603-652-040 which contained inspection report (IR)'

i No. B-1-652-040-02, " Welding Checklist Continuation Sheet" which identified Field Weld F17 as having been performed by welder FD-402 using welding process CSP-FD-HV-501 (SMAW)

'

E7018 rod on April 12, 1989.

The NRC inspectors documentation and rod withdrawal review determined that welder FD-402 had not withdrawn any E7018 rod that day.

Additionally, for Traveler.B-1-3603-654-068, IR No.

!

B-1-654-068-02,- the welding checklist continuation sheet.

-

identifies that welder FD-98 made wolds F-49 and F-52 using

- t welding process CSP-FD-HV-501 and E7018 rod withdrawn on i

April'3, 1989.

However, during a document and rod slip i

withdrawal review, the NRC inspector determined that

'

welder FD-98 had not withdrawn any E7018 rod on April 3, 1989.-

!

Based on a detailed review of the welding checklist continuation sheets and the rod withdrawal slips for l

specific welds performed on corresponding days, the NRC l

inspector determined that this aspect of the allegation which dealt with weld record discrepancies was supported by documentation inconsistencies.

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l This failure on the part of the applicant to maintain I

accurate documentation related to weld records which provide L

evidence of activities affecting quality is a violation I

(445/8973-V-02), failure to maintain proper records.

i During the process of reviewing this allegation, the NRC inspector determined that the Corporate Security

,

investigation into these matters appeared to be thorough and timely.

As evidenced by an examination of the SAFETEAM L

files, Corporate Security was provided with concerns 12496 and 12497 relative to HVAC welding concerns on or about June 28, 1989.

Shortly after this date, the NRC inspector met with Corporate Security personnel involved in the investigation and determined that they were actively involved in the investigation.

The NRC inspector also determined that on July 18, 1989, Corporate Security requested an engineering evaluation and response regarding

,

HVAC welding procedural violations.

A response to this

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request for an engineering evaluation was provided by the

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Consolidated Engineering and Construction Organization j

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(CECO) by letter CECO-2284 dated August 9, 1989.

This

<t letter stated in part that Engineering had previously accepted GMAW welds at butt joints that had been specified to be SMAW welded and that they could "still accept work

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-subject to allegations on this issue."

This letter went on to state that CAR 88-39 had addressed welds which had been.

.

made "out of procedure" and that the CAR had determined that.

l there was no impact on the structural integrity of the reinforced duct.

The NRC inspector determined that although these engineering evaluations were technically correct, the t

,

,'

associated significance of craft personnel failing to follow

'

procedures as well as the implications that weld records may L

have,been adversely affected were not adequately addressed by TU-Electric management.

This determination was based on a review of the applicant's documentation contained in the SAFETEAM files, Corporate Security records, and discussions with the applicant's licensing and QA organizations.

Prior to these items being identified to TU Electric's management during the NRC exit conducted on September 5, 1989, there was no' discernible indication that-this issue was being resolved expeditiously or that the adverse implications were

,

being adequately addressed.

The applicant's feilure to take

'

prompt corrective action in pursuing these issues is a i

violation (445/8973-V-03).

1.

'

This allegation will remain open pending the completion of

'.

I inspection activities in the electrical area.

,

6.

Electrical Components and Systems (51051, 51053, 51055, 51061, and 51063)

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During this reporting period, the NRC inspectors performed direct

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' inspections of work performance to determine if the technical L

requirements contained in the applicant's Final Safety Analysis O

Report (FSAR) for safety-related electrical. systems and L

components had been adequately translated into applicable L

drawings, procedures, and instructions.

Additionally, the NRC inspectors evaluated the applicant's work control program to determine if the specified documents and procedures were of sufficient detail to provide adequate work performance and

control.

I In particular, the NRC inspector observed portions of the cable pulling for package CP1-ECPRLV-01.

The cable pull was part of

,'

DCA 72619, Revision 4, which involved Class 1E associated cables A0150553 and AG150554 for the remote shutdown panel.

The NRC

'

inspector observed that QC personnel were present during the pull and that the craft personnel involved handling the cable during the pull correctly implemented the specified requirements.

The

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.the pull site'and determined that there were no discrepancies, q

The NRC. inspector also observed the performance of activities j

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associated with Work order C89-12527 involving motor operated J

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valve'(MOV) 1-HV-4288.

The spring pack for this valve was

.

dimensionally checked by test engineering personnel who recorded i

the required "as found" data and then reassembled the spring pack j

and performed "as-left" preloading tests.

The NRC inspector

determined that the accompanying documentation appeared complete, that QC was present for the required verifications, and that the test personnel were knowledgeable regarding the operation ar.d i

.

'

testing of the hardware.- The inspector also observed a portion e

of the MOVATS static testing of Mov 1HV-2494B related to NRC Inspection and Enforcement Bulletin 85-03 actions.

Further inspections in these areas will be conducted and documented'in subsequent inspection reports.

' '

No violations or deviations were identified within this area.

7.

Safety-Related Components, Mechanical (50072, 50073)

NDE, Reinstallation, and Reverse Flow Testino of Boro-Warner Check Valves The applicant began a program to disassemble the approximately 80 Unit 1 Borg-Warner check valves and perform nondestructive evaluation (NDE) inspection on the swing arms following the failure of.the swing arm for valve 1SW-0048 in the service water system (see NRC Inspection Reports 50-445/89-30, 50-446/89-30; and 50-445/89-64, 50-446/89-64).

The inspection of the swing arms is now complete with 77 valves inspected and 14 rejected a

'

swing arms.

The causes of the rejections are summarized below:

Eight swing arms failed the examination by replication

.

and exhibited hot cracks (i.e., poor casting quality).

Four swing arms failed due to the minimum wall

.

thickness criteria (i.e., insufficient material to perform replications).

Two swing arms failed due to the presence of linear

.

indications discovered during liquid penetrant and/or visual examinations.

In addition, 3 valves were not inspected; thus, the swing arms for these. valves were rejectsd.

The swing arms for two accepted valves were used for off-site materials analysis.

In summary, the swing arms for 19 valves.ere replaced with either Unit 2 swing arms (8 valves) or new swing arms purchased from Borg-Warner (11 valves).

The NRC inspectors are continuing to

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~ documented in a subsequent report.

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The NRC inspector reviewed the applicant's program to reverse

' flow test the.Borg-Warner check valves following reassembly.

'

Procedure EGT-328A, Revision 1 is used for testing of the L'.

pressure seal check valves in the AFW system.

This procedure was previously reviewed by the NRC inspector (see NRC Inspection i

Reports 50-445/89-64; 50-446/89-64) and found to be acceptable, i

Procedure EGT-716A is used to test the six Borg-Warner bolted.

'

i bonnet valves which are designated as containment isolation

'

valvos.

Procedure EGT-165, Revision 0, " Check Valve Reverse Flow Functional Test" is used for the balance of the Borg-Warner pressure seal and bolted bonnet valves.

The NRC inspector reviewed EGT-165 and identified the following concerns to the applicant:

In the statement of purpose, the procedure referenced

,

.

nonsafety valves only.

The procedure was, however, intended to be used for safety-related valves.

The acceptance criteria in paragraph 2.1.1 was vague.

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The pressure of the test source (demineralized water)

.

was not required to be recorded following the test.

Following discussions with the NRC inspector, the applicant amended the procedure with Procedure Change form EGT-165-RO-1

,

.which adequately addressed these concerns.

Additionally, during this report period, the NRC inspector observed the disassembly of valve 1AF-057 and witnessed the reverse flow leak testing of the following valves:

1CC-0713, 8" bolted bonnet, Procedure EGT-716A 1AF-0167, 8" bolted bonnet, Procedure EGT-165 The NRC inspector determined that the test personnel involved l

appeared knowledgeable and that they efficiently performed the subject tests and valve disassembly.

Both tests had satisfactory

!

results and no discrepancies were identified during the test performance or documentation completion.

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The reverse flow testing of the 80 Unit 1 Borg-Warner check valves is approximately 65 percent complete.

Valve 1AF-0057 j;

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failed the reverse flow test apparently due to a combination of l

'

body / bonnet rotational misalignment and incorrect bonnet height.

Valve 1CA-0016 (a containment isolation valve subject to very u

l strict leak rate requirements) failed apparently due to an axial L

play problem between the arm and the disk.

NRC review of the

root cause and generic implications of the failure of Borg-Warner check valves to pass the reverse flow leak test and the adequacy L

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of the inspection process prior to reassembly is identified as an.

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open item pending the applicant's implementation of corrective.

actions (445/8973-o-04).

.

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Additionally, the following open items.were identified'by the NRC'

i AIT subsequent to their inspection concerning the multiple failures of Borg-Warner swing check valves experienced at

,

Comanche Peak during the recent performance of HFT.-

(See NRC i

Inspection Report 50-445/89-30: 50-446/89-30).

They are listed

'

in.this report to insure applicant action and followup and will be evaluated during future inspections.

'

a.

In 1985, Failure Analysis Report FA 85-001, Revision 0,

'

,

correctly identified the root cause of lMS142 check valve

.

failure as the bonnet and retainer incorrectly placed too low in the body.

The applicant revised the root cause af.ter Borg-Warner apparently convinced them that the valve

.

failure was not due to incorrect installation.

This item is

.,,

open pending receipt of additional information from the

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l, applicant regarding documentation.of the 1985 discussions

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i were correctly reinstalled (445/8973-o-05).

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The present design of the AFW system apparently does not

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allow for a thorough flushing of sections of the system

,

using the existing drain valves.

As discussed in the NRC

-

AIT Inspection Report (50-0445/89-30; 50-446/89-30),

numerous drain downs of the AFW piping have been

!

accomplished over the years in order to perform welding

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repairs.

Check valve internals were removed to provide the

'

appropriate drain paths.

Records of this activity do not appear to be available.

It would appear that this activity

"

may be related to the check valve failures.

This item is open pending NRC review of:

(1) the adequacy of the o

existing AFW drain valves for thorough system flushing, s

(2) applicant action to install additional drain valves in the AFW system, and (3) the applicant's plans to use the Borg-Warner check valves in the AFW system as system drains

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in the future (445/8973-o-06).

.

I c.

Based on reviews of maintenance histories and discussions with personnel, the NRC is concerned that no provisions were made for continued maintenance and system preservation

,

during the period from completion of preoperational testing in 1984 until the recently recompleted HFT.

This item is open pending receipt of information concerning maintenance and system preservation during this period (445/8973-o-07).

d.

The applicant informed the AIT of their intent to administrative 1y isolate the feedwater isolation bypass

,

valves during startup and shutdown conditions except when the valves are actually needed.

This would be done by J

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closing the manual block valves in the feedwater isolation

bypass line.

The applicant'is also considering eliminating

,

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the currently installed interlock between the feedwater

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isolation bypass valves and.the feedwater preheater bypass valves.- -This interlock currently forces one of these two

,

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valves to be open and the other closed at all. times-other than during a feedwater< isolation signal (when both close).,

This item is open pending completion of the applicant's action and subsequent NRC review (445/8973-0-08).

'

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e.

As a result of the AFW backflow events, approximately 70 of the 563 supports, restraints, and anchors used in the AFW

'.

piping system experienced loads in excess of the design

. loads.

In addition

, several areas in the piping i

experienced thermal stresses higher than ASME code.

"

t allowables.. Two areas of concern are the elbow adjacent to

,

the failed support and some instrument connections.

NRC i

,

L review of the completed engineering analysis of the effects

of the AFW backflow events on the AFW piping system is an

-

open item (445/8973-0-09).

f.

There was a perception among those interviewed by the AIT

[' g that'the use of remote valve operators is' prevalent.

The

!

design and placement of some of these operators appears to

.

,

,

have been executed without proper regard to human factors

,

i issues.-

For example, the recirculation. test line' isolation

.

L valve on one motor driven AFW pump has a chain operator, l

i while the equivalent valve on the other pump is manipulated.

'

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with reach rods.

This item is open pending applicant review L,

of the use of these remote valve operators (445/8973-0-10).

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E g.

Immediately prior to.the April. 23, 1989, AFW backleakage i

event, the control room operators sent only one auxiliary j

'

operator, near.the end of the shift, to operate valves 1AF041 and 1AF042.

This reflects a lack of understanding in j

the control room regarding task manpower assignments.

The control room operators should.have been aware of the time required for one individual to operate these valves.

This

>

item is open pending applicant action to ensure the control room operators are aware of the manpower requirements for

required tasks (445/8973-0-11).

h.

The NRC considers the difficulty of operation of valves

1AF041 and 1AF054 to be a contributing cause to the April 23 and May 5 events, but of minor safety significance.

The NRC will review the applicant'a intended actions to make these valves easier to operate.

This is an open item (445/8973-0-12).

i.

Check valve axial play is the total amount of movement within the disk arm socket in the axial direction.

In order to assure that axial play would not adversely affect

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operability of the check valves, Borg-Warner was to establish acceptance criteria f or the n*ximum and minimum axial play..The acceptance criteria and the applicant's review end approval of this acceptance criteria, based on

'

the calculation procedure established for determining the bonnet height. adjustment, is an open item (445/8973-0-13).

j.

The NRC is concerned that the AFW backleakage events reflect negatively on the quality of training received by the plant operators.

The necessity of in-sequence valve operation was apparently not sufficiently emphasized.

Another training-related concern we. the failure of plant operators to document the discovery of three failed AFW check valves on a Plant Identification K' aport (PIR) or an NCR.

The applicant has committed to raising the awareness of plant operators to operational issues by conducting training.

NRC

>

review of this training of operators is an open item (445/8973-0-14).

.

k.

Kalsi Engineering, Inc., is assisting TU Electric in developing and implementing a program based on recommendations contained in SOER-86-03, " Check Valve Failure or Degradation."

NRC review of this program, including TU Electric's comm%tment to either modify the three AFW minimum flow recirculation check valves (lAF-045,

-057, and -069) or to increase the distance between the orifices and the subject check valves prior to fuel load, is an open item (445/8973-o-15).

8.

Plant Tours (51063)

The NFC inspectors conducted routine plant tours during this inspectior. period which included evaluation of work in progress

,

as well as completed work to determine if activities involving i

safety-related electrical systems and components including

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electrical cable were being controlled and accomplished in accordance with regulatory requirements, industry standards, and I

the applicant's procedures.

No violations or deviations were identified.

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9.

,open Iteme i

open items are matters which have been discussed with the L

applicant, which wil?. be reviewed further by the inspector, and

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which involve some action on the part of the NRC or applicant or both.

An open item disclosed during the inspection is discussed

!

l in paragraph 7.

Eleven additional open items which resulted from the NRC AIT evaluation of multiple check valve failure I

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experienced during HF7 are also identified in paragraph 7 of this

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report.

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Exit Meatina (30703)

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An exit meeting was conducted October 3, 1989, with the

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applicant's representatives identified'in paragraph'1 of this

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No written material was provided to the applicant by the

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During this

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