IR 05000445/1989076
| ML19332C811 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/22/1989 |
| From: | Livermore H, Runyan M Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19332C807 | List: |
| References | |
| 50-445-89-76, 50-446-89-76, NUDOCS 8911290032 | |
| Download: ML19332C811 (24) | |
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S.- NUCLEAR REGULATORY COMMISSION m OFFICE OF NUCLE.AR REACTOR REGULATION $',
- NRC Inspection Report:
50-445/89-76 ' Permits: CPPR-126 ' .50-446/89-76 CPPR-127
. Dockets: 50-445'- Construction ~ Permit.
50-446- . Expiration Dates: , Unit 1: August 1, 1991 e4 Unit 2: August 1, 1992 , , Applicant: TU Electric.
Skyway Tower ,
- M.
400 North Olive ~ Street Lock: Box 81 Dallas, Texas 75201 > . Facility;Name: Comanche Peak Steam Electric Station (CPSES), > ! Units 1 & 2 . Inspection-At: Comanche Peak Site, Glen Rose, Texas inspection Conducted: October 4 through November 7, 1989 , , , l 22 87
Inspector: . ww o_ Runyan,i esident aspector, Date M.'F.
R H Civil Structural (paragraphs 2, 3, 4, and 5) Consultant: W. Richins, Parameter (paragraphs 3, 6, and 7) , P. Stanish, Parameter (paragr;1ph 2) ! ' i-r Reviewed by: W/2)& G _Uf22k9 H. H. Livermore, Lead Senior Inspector /Datef _ If 8911290032 891122
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- Inspection Summary:
, Y,> l Inspection' Conducted: October 4 thr'ough November 7, ~ 1989 (Report
5_0-445/89-76; 50-446/89-76)
' Areas Inspected: Unannounced, resident safety inspection of- ', ' applicant's actions on previous l inspection findings; follow-up on ' , Lviolations/ deviations;1 action on 10 CFR.50.55(e)-deficiencies, ' a
- identified by-:the' applicant; assessment of allegations; HVAC design.
. reconciliation;:; evaluation of. room /al.ea completion walkdowns;--and-.
- plant. tours.-
L[ iRecultsi Within the areas. inspected, a continuing weakness in the ' ~' applicant's, room and. area turnover-program was observed.. A team of NRC' inspectors discovered numerous deficiencies in Rooms 54 and 77N, - .both.of which had;been turned'over to' operations.
Several of the ' i ' deficiencies probably resulted from ongoing construction-work thoughi , others were. clearly missed during'the original turnover-inspection.
NRC inspection of this activity will continue (paragraph 7).
. "A1 review of the design reconciliation of HVAt. ducts.and supports was: conducted during this report period.- The NRC inspector concluded.
' lthat-the HVAC. reconciliation. process was adequate (paragraph 6)~. H A violation was identifled~for imp)cper adjustment of two snubbers.
-t l: Thel discrepancies resulted trom'fa. ling to follow the installation-
-procedure (paragraph.2.1).. A violation was identified.for ins f Gt.ient thread engagement of a ,, h stud on'a flange in a' Class I piplag nystem (paragraph 5.a~). L Recommendations were made concernfng the trending of room
- temparatures and H7AC surveillance testidata sparagraph 4.c)'and.
L concerning a generic review of room and arca turnover programs ! (paragraph 7).- j , (
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i , ' DETAILS-
/ 'T l b Persons Contacted
- M.jAxelrad, Newman and Holtzinger
- ,'4 ' *J. iL.1 Barker, Manager, ISEG, jNJ Electric ' "g
- D.
P.-Barry, Senior, Manager, Engineering, Stone and Webster , ' ' Engineering Corporation (SWEC) ' . *J. W. Beck,' Vice President, Nticlear Engineering, TU Electric
'
- J.
E. Bentham,' President, The Bentham1 Group, Inc.
- O. Bhatty, Issue Interface Coordinator, TU Electric
- M.
R. Blovins, Manager of Nuclear Operations. Support, l' TU Electric
- H.-D.=Bruner, Senior Vice President, TU Electric
- A.
R.,Buhl,.IAG
- *W.
J. Cahill, Executive Vice President, Nuclear, TU Electric . *H. M. Carmichael, Senior Quality Assurance (QA) Program J" Manager, CECO
- W.
G..Counsil, Vice Chairman,. Nuclear, TU Electric '
- C.
G.
Creamer, Manager, Unit 1 Completions Engineering, T1 Electric
- B.
S. Dacko, Licensing Engineer, TU Electric.
- R.
J..Daly,' Manager, Startup, TU Electric
- G.
G.' Davis, Nuclear Operations Inspection Report Item Coordinator, TU Electric
- D.
E. Deviney, Deputy Director, QA, TU Electric '
- N.
M.- Eifert, ; Chief Engir.eer EA, SWEC.
- J.
C.
Finneran, Jr., Manager, Civil Engineering, TU Electric
- C.
A. Fonseca, Deputy Director, CECO ., !
- S.cP. Frantz, Newman and Holtzinger
- J..L.-French, Independent Adv.'sory Group-
- B.
P. Garde, Attorney, CASE
- J.
Greene, Site Licensing, TU Electric .*W.
G.
Guldemond, Manager of Site Licensing, TU Electric
- T..L.
Heatherly, Licensing Compliance Engineer, TU, Electric
- J.
C. Hicks, Licensing Compliance Manager, TU Electric
- C.
B. Hogg, Chief Manager, TU Electric
- R.
T.
Jenkins, Manager, Unit 1 Operations Support Engineering, TU Electric
- J.-J. Kelley, Plant Manager, TU Electric
- 0. W. Lowe, Director of Engineering, TU Electric
- F. W. Madden, Mechanical Engineering Manager, TU Electric
- S..G.
McBee, NRC Interface, TU Electric
- J. W. Muffett, Manager.of' Project Engineering, TU Electric
- S.
5. Palmer, Project _ Manager, TU Electric !
- W.
O.
Porter, Operations-Support Engineering, TU Electric
- P. Raysircar, Deputy Director / Senior Engineer Manager, CECO
- A.
B. Scott, Vice President, Nuclear Operations, TU Electric
- J.
C. Smith, Plant Operations Staff, TU Electric
- R.
L. Spence, TU/QA Senior Advisor, TU Electric , ..I ' , . . . . ., _. -. _... . _ _ - .. -
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- J. F. E Streeter, Director, QA, TU Electric E
,
- C, L cTerry, Manager of Prvjects,_TU Electric
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- R.
D; Walker,' Manager oftNuclear Licensing, TU Electric s
- J. E.,WoodF,7 Assistant Project Engineer,,SWEC/ CECO
= The NRC inspectors 'also interviewed other applicant. eraployees: ' during'this inspection period.
- Denotes personnel present at the November 7, 1989, exit meeting;
. , 2.; Applicant's' Action on Previous Inspection Findings (92701)
- '
+ a.
(Closed) Unrcsolved Itca (445/8965-U-02): This unresolved.
item, which involved snubbers with loose dust covers, is 'being elevated to a violation for the failure of the . applicant's-construction personnel to follow the
- installation procedures established in ACP-11.5,
" Component Support Fabrication and Installation."
During th'e NRC room and area walkdown inspection in Room 198, the NRC. inspectors observed a snubber, mark No. CC-1-043-010-A43K -1and subsequent to this walkdown an l additional snubber, mark No. CC-1-051-006-A43K - on which- ' .the_ dust cover or position indicator-tube could. rotate - . relative to the_ snubber body.
Pacific Scientific, the ' ' L manufacturer of.the base unit, provides installation instructions:which detail a procedure for orienting the ' end cap relative.to the body _of'the snubber, if necessary, which would' ensure that the end cap remained firmly , attached to'its mating part.
[ In response to this item, the applicant contacted Pacific ' i= Scientific who confirmed that the cauce of the condition- - was that the end cap of the snubber had been rotated' " .. by untorquing the end cap without loosening the . housing retainer ring in accordance with proper end cap alignment procedures."
Pacific Scientific also stated that the probable end cap rotation was at most one turn in order to facilitate alignment of the end cap to its attcchnent point.
With che end cap rotated one full turn, the Safety Factor for the threads attaching the end cap to the snubber is 1.74 and is within Code requirements.
Also, once installed, the attachment points limit the movement of the end cap to plus or minus 12 degrees.
Pacific Scientific's premise, as stated above, in aased on the assumption that the applicant's inspection programs for these units had confirmed that when the snubbers were L put into inventory, and later issued for installation, that they were properly assembled, or had not been I improperly loosened.
!!owever, this was found by the NRC L . & & . .< - ., - - -. .- -
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An inspection pe. formed by-i L
the NRC cf-two of the site warehouses revealed several: - .snubb(2sothat had been' returned.from the field, due_in ' is part to a' snubber reduction program, which-also had loose - '. end caps.
These snubbers were either awaiting inspection
so - or had already gone-back.into stock forffuture ure.
E Discussians}with; warehouse receiving Quality Control (QC) s m - personnel revealed that' they were unawart-of any requirements. relative to inspection of-snubber'end caps to ' ensure proper configuration.- Therefore, because of the , existence of snubbers with loose end? caps in the warehouse- ' r- ' it is not pcssible to make any reasonable conclusion as to how many threads of the,end cap remained engaged on.
- k snubbers. installed in.the plant.
, p ~ h i; - ~Due.to the-above, the' applicant performed a walkdown of 60 L installed snubbers.
Of this sample, five cases were documented in which the snubber dust cover could: rotate , relative,to-the snubber body. ~Further investigation
revealed less than-one turn was required to tighten the
end cap assembly-Therefore,,the applicant concluded that - the. deviations _found.in the sample were not representative ' of a' safety significant condition and.also concluded that _
b ne fuither corrective actions were necessnry.
However, NRC review of-Report PTR-15, Revision 0, " Evaluation of Snubber Rotation" revealed that the root cause-identified by the' applicant, which coincided with Pacific scientific?s assessment,-was "..., lack of proper '
procedure implementation when aligning the snubber. paddle.
, with the' rear bracket The report identified a- " > .... - procedure noncompliance,' hut addressed only the structural __ _ significance.
No effort was made to determine the reason.
-canatruction personnel failed to follow the applicable.
' _ . procedure which provides explicit inctructions for.
FC performing the necessary modificationa.
Additionally, no ' assessment was provided regarding the failure of the ' . e inspection document"to require inspection of this attribute.
This is a violation of Criterion V "" ' s ' -(445/8976-V-01).
-- Not all procedure revisions required to provide the proper p inspection criteria have been accomplished to date; the- ~ revised procedures will be reviewed as part of the follow-up on the actions taken in response to the above-mentioned violation.
. : This unresolved item is closed.
b.
(Closed) Open Item (445/8911-0-03: 446/8911-0-01): This item addressed twc discrepancies identified by the NRC inspector during a tour of the TU Electric weld filler . - _ - -.i -- .
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. . , . material' l controlled : issue ~ ~ point.. Nonsafety-related weld
.. ' S p" ' . rod was:not1 stored ~as. required under separate' lock and key ~~ andiseveral-weld rods,were located in storage issuc-I - containers'without tags. identifying the filler-material type.. The NRC inspector = revisited'the controlled issue.
. point and veritied that.both. discrepancies had been: corrected.
This.openLitem is closed.
'
" c.
.(Closed) onresolved Item (445/8811-U-01): This item ' , identified the1 fact that the galvanized. coatings on heating, ventilution, and air-conditioning (HVAC) support-a t DH-1-854-IN-1DB had'been' removed without'any apparent i .
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authorization for paint removal _in the traveler package.
i $ 131e applicant: issued deficiency report (DR)-C-89-00498 which confirmedEthe cerceived error and provided for the
< reapplication of the coatings; The DR stated that the-l Aupport in question is a' gang support tied in with - > . Supports DH-1-854-IN-lDA and'DH-1-854-IN-lDC.
When ' , authorized.to remove the coatings from welds on the.lDA < support,'the. craft mistakenly also removed weld coatings
on1the 1DB support.
This appeared to be an isolated error x;p of negligible safety significance.
This item is closed, j d.
(Closed) Unresolved Item (445/8965-U-03): This-item addressed the1 adequacy of'using Unistrut P1064(ASTM 575)' washers for Hilti. bolt installations.
This condition was . identified on two conduit supports during an NRC plant K inspection.
Although the installation drawing (CSM-37b) -provided authorization for this substitution, the l ' specification (2323-SS-30) did not specifically authorize 'the use of ASTM 575 for this application.
The applicant providedia letter from Hilti stating.that the use of
"a2 ternate steel washerc" with Hilti bclts should not affect the performance of the bolts.
The applicant issued , , Design Change Authorization (DCA) 80568, Revision 8, whica
, , l revised Specification 2323-SS-30 to include ASTM 575 ( washe.rs in the list of permissible substitutions.
The NRC inspector concluded that ASTM 575 washers are acceptable f for this use and that the specification revisien resolves H the issue.
This item is closed.
l e.- (Closed) Unresolved Item (445/8948-U-02): This item involved the use of a hydraulic jack to reshape a ' , 30" x 42" x 21" pup piece to fit over the free end of a p L fire. damper.
iLe concern centered on the lack of an i engineering analysis assuring that this separate work process had not overstressed the members anc welas comprising the pup piece.
The NRC inspector reviewed an informal calculation which analyzed the stres:.es resulting L from the worst-case nrestressed configuration.
The calculation showed that the stresses were not l'_gh enough to demage the pump piece.
Note 3 of Drawing PCI-FD-27 L I', . . . . - . -- .. .. . - - - - -
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, , a , ., m - , &f l d,". .y ' i . NE ! ' '(Additional Notee for Installation of Internal Expnnsionc , t ' Fire Dampers)istatesLthat " common construction.practAces.
using' mechanical means to spread'. .o.
pup pieces... is - acceptable for fit-up."
The use of ~ a hydraulic. jack in.
' this~ case can be considered a common. construction practice since it is proceduralised (ECC 6.08-8,=" Utilization andt
- j Control of' Hydraulic-Jacks").
Based on these facts, this unresolved item'is closed.
- ; 3.
- Follow-up on Violations / Deviations (92702) '
a.: '(Closed) violation.(445/8938-V-06): This violation.
' ~ involved the applicant's-failure to perform radiography . tssting-(RT)'of 75 electrical penetration welds, as-
= required lar the FSAR and Specification 2323-SS-19.
In . ; , - 111eu of-RT, ti.le applicant performed a stress, analysis showing that the completed surface examinations (magnetic , particle.or liquid penetrant) in light of the low stresses " - ' expected.during the service life were adequate to ' ' demonstrate the suitability of the welds.
The NRC nondestructive examination (NDE) specialist did not , consider the stress-analysis to be a technically < acceptable substitute for the required RT examination.
l The-applicant performed ultrasonic testing (UT) of-the welds with the' concurrence of the NRC'NDE specialist.
' Like'RT, UT is a volumetric examination:and was C substituted in this case because the geometric configuration on'the welds were not optimal for RT.
-A licensing document change request (89-561) was submitted.
to revise the FSAR (3.8.1.2.3 and 3.8.2.6) to include the.
acceptability of.UT as a volumetric examination method for electrical-penetration welds.
The UT examinations of the 75 welds did not identify any rejectable indications.
The applicant reviewed other , instances where engineering-analyses were'used in lieu of required NDE examinations, the results of which are > " included in the applicant's response to Violation 445/8936-V-05.
The NRC will review this material in association with the closure of that violation.
The NRC Inspector reviewed LDCR 89-561 and the UT test records of the 75 welds as well as other correspondcnce-asacciated with this violation.
The NRC inspector concluded that the applicant had satisfactorily addressed-this item.
This violation is closed.
b.- (closed)' Violation (445/8926-V-01): This violation involved the closure of two nonconformance reports (NCRs) (88-19673 and 88-18905\\ requiring the application of galvanic coatings to various HVAC welds.
After the NCRs r -
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l k.h'MID?) a,s .. -c H fl[:/ " , 8' e' .had been closed, the NRC inspector discovered that severa)
of^the' welds had not been coated.
The applicant issued
- Deficiency Report (DR)-C89-1581 to assess the questionable
, , ' , NCR: closures.< TheLapplicant stated that the coating > -verification was performed immediately after application.
- and that'while the coatings were-ntill wet, they appeared- ^ - . Lto.be properlycapplied.
Procedure CHV-101, - , E ' '"HVAC-Detailing, Installstion, Rework, and Repair," was , , , revised'to require that coatdngs inspections take place.
l' l; only after the coatings have dried.: NCRs'89-7454 and-7455 - K were' issued to reapply coatings to the welds in question.
, The' applicant explained that HVAC galvanized coatings have- , l been reclassified as nonsafety-related'(per DCA 75357,
- Revision 6)'and that future coatings = inspections will be
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- performed by' construction personnel.
Construction.
7, personnel were._ trained to the new requirements of CHV-101.
B The NRC inspector. reviewed all of the' documentation c - referenced above and concluded that the applicant had adequately-addressed.this concern.
This violation is ' closed- ' .- I I c.
(Closed) Violation (445/8847-V-01c): This violation L; addressed the failure to_ provide adequate inspection of . ' activities associated with the removal'of the internal.
coating from the Unit 1 10-inch Station Service Water-System (SSWS) piping.
A 1/2-inch hole was sandblasted.
'- through the. pipe wall in one location and several other-deep sandblasting indentations were made and were not discovered by the initial remote video inspection process.
i ' ' 1 Additionally, those individuals. reviewing the video tapes had not been formally certified for that process.
' The applicant's response-to this violation is contained in TXX-89070 dated February 8, 1989.
The applicant stated-i that the root cause of the violation was the failure to o identify wall thinning as a-critical inspection attribute.
The section of pipe containing the 1/2-inch hole was [ replaced as were three 20-foot spoolpieces which contained , the most extensive and significant indications of damage.
q e The removed 20-foot spoolpieces were each sectioned and examined.by QC personnel.
All indications met minimum e wall criteria based on an ASME code stress calculation.
The results of this evaluation were used to calibrate the review process for the remainder of the 10-inch piping videotape, which was rereviewed to more accurately assess the extent of the damage.
A total of 12 indications were discovered which were not bounded by the indications examined in the three 20-foot spoolpieces.
These areas were. determined to be acceptable based on ultrasonde test measurements.
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- Regarding the qualifications of personnel.who' performed i the verification' activities, the applicant explained (and-
g - - the NRC inspector concurred)-that'the~ engineers.who. j y reviewed and evaluated-the. videotapes were-intimately.
' ' Ok involved inLthe definition of the acceptance criteria'and ?!1 techniques. involved and wereEthe most appropriately-qualified personnel to perform-this activity.
+ s > - The'NRC NDE specialist reviewed the SSWSLpipe thinning'
issue, as documented.in NRC Inspection- ' 4, ' m ' . Report-50-445/89-381 50-446/89-38, and concluded that the .; 10-inch-piping issue was closed for Unit 1.
' ' The NRC inspector determined that the applicaut's actions j to address the hardware concerns associated with the SSWS ~ LW . 10-inch piping were satisfactory.
Regarding the administrative problems, the best gauge of the applicant's l . corrective: actions is'the_recently completed program to , remove the -internal coating: in the SSWS Unit 2 10-inch piping. -NRC inspections of this activity determined that the' applicant has-taken significant. precautions to ensure i D that.the remote video inspection of the post-blasted pipe , L , is thorough and precise.- The NRC inspector considers that lm-the applicant's inspection of the Unit 2 coating removal- $ project reliably demonstrates that the corrective actions - . taken for the-Unit 1 effort have been adequate.
This , l . violation is closed.
> [ 'd.- '(Closed) Deviation (445/8626-D-06): This item involved L the apparent failure ofs the Comanche Peak Response Team.
!' (CPRT) to justify excluding welded nuts'and crimps-(used.
' W for attaching various accessories) from a list of
attributes to be inspected-during.HVAC: field walkdowns l under field verification method (FVM) CPE-EB-FVM-CS-066.
' The applicant denied the deviation _ stating that CPRT was . E chartered to inspect only those items specificd by then-current c.esign documents.
Specifications regarding weided nuts and c rimps. had been deleted prior to the FVM ' %' walkdowns on the HVAC' system.- In addition, the applicant stated that during Ebasco's HVAC as-built drawing reconstruction, any inconsistencies between thc installed " ~' hardware and'the latest requirements would have been documented on deviation reports.
These deviation reports, ' E which included installed welded. nuts and crimps, were Ty individually evaluated as to the impact on the structural ' integrity and operability of the system.
The NRC inspector verified that welded' nuts and crimps that were left installed (use-as-is) in the HVAC system were noted on the as-built drawings, thus maintaining adequate.
configuration control.
The NRC inspector concluded that the applicant's. dental of the deviation was valid and that
no further action is necessary.
This deviation is closed.
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. e.
'(Closed); Violation ~(44L/8926-V-02): -This violation-1 addressed inspection' concerns not identified by-QC H
< J J Linspectors during theaPost-construction Hardware ' , Validation Program-(PCHVP) inspection of-five Class 1 and Class'2 structural: steel platforms. :The concerns included-four" incorrect dimensions,'two-incorrect bolt locations, % - twoLincorrect weld types,-and undersized welds in~one ~1ocation.> The applicant' agreed with the violation," stated , that:the' conditions identified resulted from QC inspector H 1 error, and issued NCRs for the specific discrepant-conditions.
The QC inspectors responsible.for structural - inspections rece'ved additional treining to emphasize _ '. accurate verification of. dimensions-and1 configuration:.
- attributes.
-The' applicant also; stated the-belief that the ' discrepancies identified by the NRC inspector were' isolated.
i > n '. . The applicant reinspected 12 Category II platforms in q .. .. l Unit 1 and Common for dimensions, copes, and welding-l . attributes (size, length,'and location).
The NRC D inspector examined each-of the 12 packages and' reinspected
C two of the platforms.
For each platform, specific welds, , b members, connections, etc., were' selected for inspection..
u representing approximately 5 percent of the platform.
Six l' NCRs were subsequently. issued by TU Electric for c' nonconforming conditions identified'by the applicant-during this. reinspection.
All of the NCRs were' , - dispositioned by engineering "use-as-is" based.on the ' minor nature'of the identified nonconforming conditions.
Six additional Category I platforms were ultrasonically . tested to determine if full'or partial weld penetration i l was' achieved.. A total of 46 inspections were performed.
. and-all were~found acceptable.
_[ ' i 'The NRC inspector disagrees with the cpplicant's conclusion that the NRC-identified QC inspection errors ., ' were isolated..QC errors were identified for all five of the structuralistcel platforms inspected by the NRC-inspector.
Subsequently, the applicant issued seven NCRs ' to address these deficiencies.
The applicant identified: 19 additional unsatisfactory conditions (not identified by L the PCHVP QC incpectors) during its sample reinspection of 12: platforms.
A total of 6 NCRs were issued to address the deficiencies for 6 of the 12 platforms.
The NRC inspector notes, however, that all of the deficiencies missed by the initial PCHVP QC inspection aere minor in nature and that no rework was required.
E Based on the above, the NRC inspector concluded that: (1) the QC inspections of the structural steel platforms were not adequate to identify all dimensional and welding l+ t .- l f
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e , , . Monfiguration? deficiencies,_(2);the applican . sample ! inspection of portions of 12 platforms identified' - . additional deficiencies missed during the PCHVP QC , ? ? inspections, (3) the. additional training' appeared to be i E+ thorough and'to address the problem, and (4)-the ., = deficiencies. identified were: not safety significant. and were"dispositioned "use-as-is. AlthoughLthe-PCHVP.
!,; l inspection of structural platforms'was clearly imprecise,- . . '
subsequent analysis of-the identified discrepancies: q ' provides a~ reasonable basis for concludingithat the , L~
- installed platforms are structurally adequate.- This-violation is closed.
j ' ?e E ' 4.
Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant (92700) j , a.- (Closed'- Unit 1 only) Construction: Deficiency L-(SDAR-CP-85-54): " Seismic-Qualification of HVAC Li Supports." - By letter TXX-6460 dated May 22, 1987, the
' ' applicant informed the NRC that a deficiency involving
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discrepancies:in supplier-provided HVAC support documents 'l was a reportable item.
Numerous inconsistencies were- ' , _
- discovered 1between as-built HVAC support drawings supplied
. .by Bahnscn'(the supplier)_and the actual installed.
l conditions.
Since seismic. qualification = calculations were> based on as-built documents, the seismic adequacy of the i ' supports could.not be assured.
. . i The. applicant decided to. discard any reliance on the original: support' drawings and to develop a completely new j-set of'as-built drawings.
The new as-built drawings were i based on PCHVP walkdowns underl field verification methods J (FVM).CPE-EB-FVM-CS-029, CPE-EB-FVM-CS-066, and
CPE-EB-FVM-112..New seismic design calculations were i performed. utilizing the reconstructed as-built ~information
in accordance with Procedures SAG CP-23, -24, -31, and-32.
Some hardware modifications were required to meet
seismic design' criteria and other modifications were necessary for other reasons.
After all~ rework was- ' perftimed, a final. design reconciliation ~was performed to ensure that the seismic integrity of the HVAC system was , still intact.
This' final design reconciliation is now " complete for both Seismic Category I and II HVAC supports (in Unit 1).
The reconciliation did not identify the necessity for any additjonal modifications.- Previous NRC inspections of HVAC support FVM walkdcwns are documented in NRC Inspection Reports 50-445/89-11, 50-446/89-11; 50-445/89-19, 50-446/89-19; and 50-445/89-26, 50-445/89-26.
No discrepancies were identified between the as-built duct support drawings and the installed hardware.
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, i The;NRC-inspector reviewed a' sample of design g . reconciliation calculations (paragraph 6) and concluded- ,', that the~ reconciliation process was satisfactory.
j ' . The.NRC; inspector reviewed the SDAR correspondence file - and1. Procedure' SAG.CP 23 and concluded that the applicant has-. appropriately' addressed this concern and has provided-q . adequate assurance that Unit 1 HVAC supports are capable' l , of! resisting.. design basis earthquake-loads. 'This.
t construction deficiency is closed for Unit 1.
, - b., L(Closed L Unit 1 only) Construction Deficiency (CP-84-27): ' " Ventilation Exhaust Dampers."
By letter TXX-4409-dated-i Parch 6, 1985, the applicant informed the NRC of a reportable deficiency-involving.the design failure' modes _ ;g , of_certain Primary Plant Ventilation System exhaust t Edampers and several other related issues.
After a lengthy
review,-the following four issues were identified ~and-resolved as.follows: (1) Some of-the exhaust dampers in the primary plant ventilation system. fail in the closed position when electrical power.is lost.
In the event of a loss-of-coolant accident concurrent with a loss of offsite power, the closing of certain dampers could . result in airborne radioacti' e -' intrusion -into areas. . ,, where individual-exposures may be significant from an
, ALARA standpoint.: The calculated levels of - ~ ' radioactive gases.did not exceed 10 CFR 100 levels and would not have significantly impaired operator
,- action.
To preclude unnecessary exposures-to plant a,
- j f
workers, certain damperr.were locked.open with ' power / air supplies. disconnected.. " .(2)~ The same closure of primary plant ventilation system . ,, < i dampers upon loss of power could result in high area ' temperatures which-could compromise the operabili'y c of environmentally sensitive safety-related compenents.
Corrective action for this concern also g R involved sealing open dampers or removing them l; entirely along with the addition of insulation, H reductions in various heat loads, and the relocation L' ? q of equipment.
These activities involve the applicant's environmental qualification program and j were originally-based on the assumption that forced.
, L air ventilation could be restored'within 72 hours ' following a design basis accident.
Subsequently, R during tho design validation phase of the Corrective , T b Action Program, a more conservative approach was L taken which did not rely on the assumed restoration L of ventilation.
As a result of this design review, a > , safety-related ventilation system was added to o- .q , I
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- operability of-a motor control center.
No additional ' ' , ~ modifications were deemed,necessary.
m . . (3); The1closurecof ventilation ~ dampers in'the two boron,
' ' recycle holdup. tank'roomsLcould result in explosive- , j g" 3 sconcentrations of hydrogen gas.above the 830 foot-
4 elevationtifothe nonseismically qualified flexible i bladder: located inside.the tank were to: fail.
To' ! . lessen the potential ~ likelihood of a hydrogen . . explosion, the exhaust damper in each room was sealed.
- j-open;to-ensure exhaust flow into the.ductwork.
Also, l the portion.ofJthe fire detection l system-positioned: ! 'above the 830 foot level in both rooms was modified.
I 'y to be explosion-resistant.
( 4) LAn' additional concern was identified involving the-j mounting of' Class 1E limit switches and solenoid j valves,on non-nuclear safety. dampers.
However, the f applicant's review revealed that the non-nuclear ! safety-dampers had been designed to at least seismic
y - Category II, which ensures structural integrity
during a_ design basis earthquake.- Each damper ~and
its attached ClassLlE components were evaluated and '3 found.to be seismically qualified and no further- - corrective action war deemed necessary.
Y The~NRC inspector reviewed:the historical k correspondence record associated with this: issue-H DCA 59761, Revision 5, which added a safety-related 'l P' ventilation system'to Room 100;:approximately 10 !
additional.DCAs which bnplemented several of the f h other corrective measures' described above; and.
! ! Procedure ABV-202A, " Loss'of Non-Safeguards L' Ventilation Systems," which delineated areas where ll' lighting must be secured within 8 hours oflan ' P accident (to-reduce the heat load).
The NRC p,' inspector; concluded that-the applicant had j L aggressively pursued the resolution of this concern
L and had: formulated and executed an effective R corrective action plan.
, b ! This construction deficiency is closed for Unit 1.
c.
(Closed - Unit 1 only) Construction Deficiency ,. (SDAR CP-89-14): " Cracked Turning Vanes in HVAC Systems."
n ~ L By letter TXX-89736 dated October 9, 1989, the applicant ' informed the NRC that a deficiency involving cracked welds b in. turning vanes in the HVAC system was not a reportable item.
Corrective Action Request (CAR) 89-05 was generated !- due to deficiencies found in several duct segment turning L ' vanes fabricated by Bahnson.
The deficiencies included v Vi , , , - _.. _ ,. . ,, _.. _.... . - . -... . , -
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crackedtwelds,Lcracked and separated vanes,. vanes welded.
1directly to the duct skin, and broken welds. -These - ! , conditions have a potential impact on safety in that a
' dislocated vane could disable an HVAC fan or obstruct.
airflow in a: duct such:that~ adequate cooling would not be-
achieved.
i~ -The applicant' developed engineering assessment' Procedure l CPE-EB-EAP-CS-025 (EAP-025) to delineate a sample field.
- inspe'ction program. ETurning vanes were selected which meti
' one:or more of the-following-five criteria: (1). turning: vanes located in a vertical duct such that broken vanes-
- i could:fallJinto'a fan, (2) turning vanes located within-2:1/2 times' duct diameter from fan discharge, (3)' turning N
vanes exceeding la 15 degree transition angle with a design , l air velocity in' excess of 2000 feet per minute,_ , -(4)' turning vanesLwith unsupported span greater than,36 . inches, and;(5) radiused elbows with splitter-vanes with unsupported span-greater than.12 inches.
The selection ~ , criteria ~ focused on configurations most likely to produce a~ failure or where a failure would have the greatest: safety impact.
The turning vanes in 96 duct elbows met at ~ s least one of;these criteria.
The turning vanes in 27 of i these'96 duct elbows had been refabricated due to other, .. issues and were' excluded from the inspection scope.
The j turning vanes in the remaining.69 duct elbows were field R inspected.
l-E Numerous deficiencies were discovered during the field-L . inspections and were documented on nonconformance reports (NCRs).
The most serious discrepancies were cracks found.
in welds and the base metal.
All of the-cracks were s L repaired in the-field.
The cracks were almost exclusively-associated with. unsupported spans in excess of 36 inches ' and probably resulted-from fatigue due to fluttering of the vanes in a high velocity air flow.
Therefore, all-if
E long vanes were stiffened by reducing the unsupported span R to less than 36 inches (via DCAs).
Other problems, b including underlength and undersized welds,. undercut, L porosity, Jack of fusion, and other deficiencies attributable to installation errors, were either dispositioned repair, rework, scrap, or use-as-is.
( Project Technical Report 11 (PTR-Oll) summarized the scope of the corrective action and presented a safety-significance evaluation.
Despite the considerable number of problems associated with the turning vanes and the corrective-measures taken, the conclusion of PTR-011 was.
L that the turning vane deficiencies were not safety l significant.
The safety analysis stated that even without.
L any corrective action, vane failure would not occur where L, unsupported spans are less than or equal to 36 inches.
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t , t ' Since no' spans exceeding this length are located:in - t . proximity to an HVAC fan,,the report concluded.that fan - ' , damage would not' occur.
The report also concluded that - failed vanes:would not. result in unacceptable flow degradation.
This was basedJon~the conclusion that:due to
the turning vane configuration, the airflow would' tend,to push the failed vane out of the flow path.
In any case, . o' flow' degradation would be a gradual process (postulating a ' " sequential long-term failure of several. vanes) that would.
' . be-detected by Technical Specification surveillance-tests or higher-than-normal room temperatures.
The applicdnt; declared 7that the uninspected turning vanes were acceptable without-further evaluation because (1) the:
identified construction deficiencies were found to be.
acceptable and (2) the shorter span and more favorable configuration made them less likely to fail.
Previous'NRC' field and document inspection of this issue.
' is documented in NRC Inspection Report 50-445/89-48; ' 50-446/89-48.
During this report period, the NRC r inspector reviewed CAR 89-05, PTR-Oll, EAP-025, and numerous-NCRs generated from the applicant's field , inspection effort.
, Based on this review and discussions with the applicant, the NRC inspector concluded that the applicant has._ . sufficiently resolved this problem and provided reasonable assurance that'the operability of the HVAC system will not be compromised by turning vane problems.. This conclusion is based.cn1 (1) none of the original as-found conditions affected the operability.of.the HVAC system, (2)-that-the most-safety significant turning vanes were field inspected and.repsired where necessary, (3) the applicant's safety significance evaluation demonstrating the: negligible impact on' safety, and (4) the fact-that room-temperature logs and Technical Specification surveillance tests should.
be able to indicate any areas where vane failures have caused a measurable disruption of air flow.
The applicant is advised to place extra emphasis on trending room temperatures and HVAC surveillance test data during the first several years of operation.
This construction ' deficiency is closed for Unit 1 only.
Seismic " d.
(open) Construction Deficiency (SDAR CP-86-45): Category II Systems and Components."
By letter TXX-6812 c dated October 16, 1987, the applicant informed the NRC that a deficiency involving the interaction of Seismic Category II hardware with Seismic Category I hardware was a reportable issue.
Contrary to the FSAR commitment to fully analyze non-Category I equipment for its potential L impact on Category I structures during an earthquake, the
applicant identified that some seismic Category II ~ y' y9 y.
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- not in'the main structure.-
A. seismically. inadequate structure could separate and fall on~ Seismic Category I n, equipment even if the anchors held as designed.
'l The' applicant's corrective action began with an . engineering validation to determine the extent of~ Seismic i ' Category II installations which could interact with' .l Seismic Category I installations.
This program was ~ '
entitled the " Systems Interaction Program (SIP)" and was performed-in.accordance with' Procedure ECE 2.24.
A portion.of this program involved various architectural.
features (handrails, gypsum board walls, grating, etc.)
I and was addressed by SDAR CP-85-29.
The SIP included.
(1) field walkdowns (per Field Verification Method (FVM) 'CPE-EB-FVM-SI-40) to identify potentially unacceptable
interactions and (2) engineering evaluations to determine seismic acceptability based on ECE 2.24 and design basis > , l document (DBD)-ME-005, " Seismic /Non-Seismic Systems: l Interaction Program."
Those installations not passing the ' DBD evaluation were further examined using earthquake i experience data and specific anchorage design -! calculations.
For any remaining unresolved interactions, I DCAs were issued to make the necessary modifications.
The field walkdowns are complete and a total of 4100
interactions were identified.
At the time the SDAR was submitted to the NRC,,10-DCAs (8893, 48741, 48743, 60731, 82910, 82911, 83053, 83071, 83693, 85854) had been issued.
for modification.
Subsequently, an additional 14 DCAs were issued for a-total of 24.
Three nonconforming condition reports (NCRs) (87-10255, -10257, 89-03055) were
also issued for nondesign-related changes.
q
' The major portion of the NRC review of the SIP is documented in NUREG-0797 Supplement 17, paragraph 4.5.
This review included an extensive field walkdown effort and documentation review and the identification and resolution of a number.of open items.
The report e concluded that the SIP was adequately implemented and that all technical issues had been resolved.
During this reporting period, the NRC inspector reviewed the SDAR file and reviewed the DCAs and NCRs referenced above.
The NRC inspector concluded that the amplicant has adequately resolved the technical issues associated with Seismic Category II/ Category I interaction issue.
Some field work remains on the 24 DCAs that were issued.
This construction deficiency will remain open pending completion of the DCA o ~
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' .s : ~ ) w - 17, > , e.- l(Open)fConstruction Deficiency (SDAR CP-88-14): . m -"Struct' ural Load' Verification-of Seismic Category I -
Structures."
Previous NRC: inspection of this construction
deficiency is documented in:NRC Inspection: - , ' .ReportL50-445/89-65;.50-446/89-65.
The previous review l covered the load verification of-steel structures.
The; ' other portion of the load verification program, involving.
concrete structures,'was reviewed during this report period;- The load verification of concrete structures involved the analysis of_six " worst-case" concreteLelements (4 slabs t.
and-2 columns) to determini whether additional loads applied during the construction of-the plant had invalidated.thel original design.
Field walkdowns were ' conducted _to-base the selection-of these. worst-case elements;and to quantify the relevant attachment loads.
Calculation 16345-CS(S)-638-82K, " Selection of Heavily ' Loaded Concrete Elements for PP-210 Global Load ' Verification"' documented the selection process.
The load verification engineering analysis was documented in.
- Calculation 16345-CS(S)-639-82K.
' The NRC inspector reviewed Project Procedure PP-210, Revision 3, " Load Verification of Seismic Category I Structures as well as Attachment PP-210-A," Engineering Assessment Criteria for Concrete Elements and Structural Steel Members.
The'NRC inspector also reviewed Calculations 16345-CS(S)-638-82K and 16345-CS(S)-639-82K and in ' particular. reviewed the analysis performed.for one column ' and one slab.
Two concerns were identified regarding the ' analysis of the concrete slab.
First, the live (not fixed in place)' load contribution was selected as 100 pounds per square foot.
This is a standard value used for light industrial buildings, but nselear power plants more commonly use the more conservative figure of 125 pounds per square foot.
Second, this live load of 100 pounds per square foot was further reduced to 67 pounds per square foot based on the judgement that only 67 percent of the l slab area was accessible for the application of live loads.
The 67 pounds per square foot was evenly applied over the entire expanse of the slab rather than applying 100 pounds per square foot over the accessible area.
This simplification may not provide the most conservative ~ calculation of shear force and moment.
This SDAR remains f open pending resolution of this concern.
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5.
Assessment of' Allegations '99014) (
-(Open) AllegationL(OSP-89-A-68): An' allegation was received by the NRC staff:that delineated 14 concerns.
Each concern was ' numbered sequentially'in the order it was presented.
The-Lfollowing'six-concerns were addressed during this: report period.
a.
Concern No. 5 ,, The alleger stated that a stud in a flange on~ pipe line
- RC-1-RB-028B had insufficient thread engagement.
Review The.NRC inspector identified the subject flange (under valve 1-8010A near the top of the pressurizer) and-confirmed.that the end of one stud was not (at a minimum) flush with the top of the nut face, as required by-s Specification 2323-MS-100, paragraph 3.ll.c.
The stud was approximatelyL1/8-inch underengaged.
The applicant concurred with this finding and issued Work Request WR00018042 to. rework the stud.
Conclusion The alleger's concern was substantiated.
The failure to meet the stud engagement requirements of Specification 2323-MS-100 is a violation (445/6976-V-02).
, b.
Concern No. 7 The alleger stated that arc strikes were not removed as required from a 16-inch diameter pipe in the Reactor Building, compartment No. 4, at the 880 foot elevation.
Review The NRC inspector did not fir ay 16-inch diameter pipes at the specified location.
luspections of surrounding areas did not disclose any arc strikes.
Conclusion The alleger's concern was not substantiated.
c.
Concern No. 8 The alleger stated that a snubber safety wire was broken in the Safeguards building, Unit 1, rocm 91, about 2 feet off the floor.
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x program 1 dispositions,~and confirmation-required DCAs (DCA-CRs).- , . Each package was then screened using the detailed criteria in.
. SAG.CP40 to determine if the package requires abbreviatedL l reconciliation'(no_ complete-reanalysis of the results'of the ' PDV), or full reconciliation (normally involves a reanalysis).
, The_ initial;117 strings evaluatsdsper' SAG.CP40 did not require any hardware modifications._ At.this-point, the applicant.made: s changes to'the reconciliation' process as described in Calculation HVAC Volume"III-- Book 46, Revision 0, " Supplemental Calculation: " Final Design Reconciliation of - Seismic Category I.HVAC Duct and Duct Supports."
The applicant screened the remaining 52 duct: strings and determined that 12 " critical" strings required full reconciliation.
The results - of the' reconciliation of these-12 strings indicated that"no . hardware' modifications were required.
For the remaining 40 strings, all1 design change documents were reviewed.
The applicant determined-that;these documents in all cases had no impact on the validation of the remaining 40 strings.
Based on
the results of the design change review and the reconciliation - of'the 12 " critical strings," the applicant concluded that no further' reconciliation of the remaining 40 strings.was , required.
The NRC inspectors reviewed the following. items in order to-evaluate the applicant's final design reconciliation of Category I-HVAC. duct and duct supports: The full reconciliation package for String 65, one of the .- 12 " critical" strings.
' Documentation of the design change review performed for . the. remaining 40 strings.
, SAG.CP40, Revision 0, HVAC Structural Design . Reconciliation.
Calculation HVAC Volume III, Book 46, Engineering Report . on Seismic Category II HVAC Duct and Duct Support.
Summaries of the screening results: .. Volume III, Book 32 - Summary of Results for Screen #1 Volume III, Book 33 - Summary of Evaluation for Redline Changes Volume III, Book 34 - Summary of Evaluation for Program Dispositions -.. . . - . . .. - . - --. .. - .. ... .. - -
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f jh. i *[ , . - s ' c. x 3g f 22- ' L ' V', Volume III, Book 35 - Compilation of Affected Document J Update Reports (ADUR) J > , Volume:III, Book-36 - Summary of Evaluation for DCA-CR- ' Closure Volume III, Book 37 ' Summary of Results for Screen #2 U K*. ~ Volume III, Book 47, Revision 0, Technical Review'of 1= Design Change Documents by '; Screening > t Documentation justifying changes in damping values-and-- . acceptable interaction ratio limits: Volume I, Book 42, Revision 0, Evaluation of Usable Design { Margins - Comparison'of F Damping Values , Volume III, Book 38 - Evaluation of Weld Interaction, . Ratios The NRC inspectors concluded that the HVAC Category I duct and duct support final reconciliation process effectively addressed design validation for these systems.
No open items or violations ~were identified.
, 7.
Evaluation of Room / Area and System Completion Walkdowns (46053, 48053, 50100, 55100, 51053) .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 verify that all items are closed.
The. transfer of custody.(turnover) of rooms, areas, and systems: from construction to Plant Operations is performed in accordance with site Procedures STA-802, " Acceptance of Station-g Systems and Equipment" and STA-810, " Acceptance of Rooms, Areas and Structures."
Currently, the applicant has identified that all of the 145 rooms and areas determined to be required for fuel load readiness and all of the 89 systems required for Unit 1 operations have been accepted by Plant Operations.
Additionally, 209 of the 274 rooms required for plant , operations after fuel load have also been accepted.
i Inspectors previously inspected the room and area completion process for Rooms 74 and 198 (NRC Inspection Report ,# _ . _ - _ -. . .
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e dC-445/89-65; 50-446/89-65). _ During._ this report period,: six ,
V NRC inspectors performed inspections of Rooms.54 and 77N to evaluate the adequacy of the room / area and system completion
walkdowns.
A total of 59 potential deficiencies were identified by the NRC inspectors.
Each deficiency was then - o evaluated lar the applicant _ to determine if the deficiency had 'been identified by the room and area or system completion. walkdowns.
The-following conditions had not been identified tar ' the walkdowns and were-detenmined by the applicant to be ' potentially nonconforming conditions.
a.
In Room 54, a spring nut was not in the Unistrut channel ' for-a support for Conduit C14K13443.
b.
In Room 54, a' conduit clamp on containment. spray pump 01 - was removed and not replaced.
..
.c. In Room 54, a Hilti bolt used for conduit support ESB1-1-5-39 had a large arc strike.
'd.
In Room 54, abandoned Hilti bolt holes were-not grouted.
, e.
In Room 54, no washers were installed on Nelson studs for-L conduit C13007483.
f.. In Room 54,Eno washers were installed for conduit ' support ESB1-1-39.
g.
In Room 77N, Valve 1-7138 had no tag.
~ h.
In Room 77N, Valve 1-HV-4777 had a loose bolt.
i.- In Room 77N, an air line for valve 1-HV-2408 was-leaking air and was not well restrained.
f' j.
In Room 77N, on valve 1-HV-2408 a filter was missing and-l an Ashcroft gauge was missing the face plate.
k.
In Room 77N, the connections of conduits C13G12869 and Cl3G12871 to valve 1-HV-2408 were loose.
1.
In Room 77N, the insulation cover on the line from penetration MIV-4 to 1-HV-2408-was separated at the corner, ,o m.
In Room 77N, a nonstructural defect in the concrete (11" x 5" deep x 1/4" wide) was identified.
In addition to the above conditions, the NRC inspectors are evaluating the significance of other potential nonconforming conditions including: (1) springs bottomed out and/or stops - . - - , ~ . . _ . _ _ _-_
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' ~ i ' . stillLinstalled in several spring-can type supports, (2); penetrations-without Bisco seal, and (3) missing washers on conduit supports.- The six NRC~ inspectors each spent:approximately two hours in each of the four rooms' inspected to date.
The number of.
, potentially nonconformingt items missed by the room / area and' system completion-walkdown teams is judged-to be high. -The-NRC i inspectors plan additional inspections in this area-and-recommend'that the applicant perform a generic review of the effectiveness.of:these programs.. This activity is tracked--by a previous unresolved-item-(445/8965-U-04)~.. ' ~8' Plant Tours (420510, 50073) . . The NRC inspectors made frequent tours of Unit 1, Unit 2, and . common areas of the facility to; observe items'such as housekeeping, equipment protection, and in-process work activities.
No violations or deviations were identified and no items of significance were observed.
' .9.
Exit Meeting (30703)- An exit meeting was conducted November 7, 1989, with the applicant's representatives identified in paragraph 1 of.this . report.
No written material was provided to the applicant by the NRC inspectors during this reporting period.
The applicant did not identify as proprietary any of the materials provided , ' to or reviewed by the-NRC inspectors during this inspection.
, During this meeting, the NRC inspectors summarized the scope and findings of the inspection.
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