IR 05000445/1992051
| ML20126J374 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/30/1992 |
| From: | Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20126J328 | List: |
| References | |
| 50-445-92-51, 50-446-92-51, NUDOCS 9301060130 | |
| Download: ML20126J374 (27) | |
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APPff1DlX B U.S. f40 CLEAR REGULATORY COMMISS10f REG 10f4 IV ,
inspection Report: 50-445/92-51 ;
50-446/92-51 Operating License: f1Pf-87 Construction Permit: CPPR-127 Expiration Date: August 1, 1995
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I licensee: 1U Electric '
Skyway Tower 400 fiorth Olive Street Lock Box 81 Dallas, Texas 75201 ,
facility flame: Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 Inspectton At: Glen Rose, Texas !
Inspection Conducted: October 25 through December 5, 1992 -
Inspectors: D. fl. Graves, Senior Resident inspector R. M. Latta, Resident inspector R. J. Evans, Resident inspector ;
T. Reis, Project Engineer ,
W. M. Mctioill, Reactor inspector P.-A. Goldberg, Reactor Inspector Accompanying Personnel: C. A. Hrabal, Acting Project Engineer-Approved: O d O 30 9 E- '
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L. i. Yande 1. Chie C Projeti Section 8 Datd Division of Reactor Projects-Inspection Summary Areas inspected (Unit 21:~ Routine, unannounced inspection of onsite activities including plant status, preoperational test program implementation verification, preoperational test witnessing, followup on corrective actions for violations, followup on previously identified inspection items, and followup involving licensee actions on construction deficiencie Inspection activities were limited to the review o Areas Ln_sye_cted (Unit 1): .
. testing of lERMI-PoltiT connections in-the solid state protection syste Results-(Unit'2):
- -- General plant housekeeping had improved over conditions identified in previous inspection' reports (Sections 2.4 and 2.9).
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9302060130 921231 PDR- ADOCK 05000445-G PDR:
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- Security response to potential breach was good (Section 2.1.1).
- Radiological protection controls for contaminated material in Unit 2 were good (Section 2.1.2).
- Electrical maintenance and cable grip installation progiams were good (Secttons 2.2 and 2.3).
- The area and system turnover process was effective in turning over rooms and systems with few deficiencies outstanding (Sections 2.4 and 2.5).
- Potentially deficient performance of the diesel generator was identified r during testing, and it was not evident that a nonconformance document ,
would have been initiated without inspector prompting (Section 2.8).
- Integrated safeguard testing was well controlled and performed i (Section 3). j i
e in general, the packages provided by the licensee for closure of :
violations, construction deficiencies, and other followup items continue- ;
to be of high quality, ;
Results (Unit 1): i e A violation of Criterion XVI to Appendix B of 10 CFR Part 50 was .
identified relating to deficient 1ERMI-PolN1 connections in the solid state protection system (Section 6.1).
lummary of Inspection Fi.3djnns
- Violation 445/9251-01 was opened (Section 6.1).
- Inspection followup Item 446/9251-02 was opened (Section 2.7),
- 1hree Mile Island Action items.!!.E.4.2.6 and ll.K.3.9 were closed _
(Sections 4.1 and 4.2).
- Violations 446/9203-01, 446/91201-03, and 446/9223-01 were cl.osed (Sections 5.1, 5,2, and 5.3).
- ' Inspection followup. Item 446/9216-03 was closed (Section 6.1).
.CP-88-041, CP-89-021, CP-91-001, CP-91-002, CP-92-001, CP-92-006, CP-92- ;
007, and CP-92-017 were closed (Section 7.0).- !
Attachments:
- - Attachment - Persons Contacted and Exit Meeting-
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1 PLANT STATUS (71707) ;
At the beginning of this inspection period, preparations were being made for "
integrated safeguards system testing, which was subsequently complete he circulating water intake structure related to Unit 2 was accepted by the nuclear operations organization. fifty of the 77 Unit 2 systems had been accepted by operations. At the end of this inspection period, preoperational program activities were continuing with the majority of these tests either completed or in various stages of the review and acceptance proces PREOPERATIONAL TEST PROGRAM IMPLEMENTATION (71302,92701)
The inspectors evaluated the licensee's management control program to determine if jurisdictional controls were observed for system turnovers, that systems and components undergoing testing were properly controlled, that maintenance activities and preoperational tests were adequately performed, that test discrepancies were properly identified, and that test procedures and operational verifications were satisfactorily conducte l Unit 2 Tours Routine tours of the Unit 2 facility were conducted to assess general plant conditions, access controls, housekeeping, and equipment protectio . Security Response to Potential Security Dreach As a result of routine perimeter walkdowns, the inspectors identified an unsecured storm drain cover inside the protected area, which potentially represented a breach of the protected area boundar Subsequent to the identification of this conditior, the licensee's security organization .
immediately initiated compensatory measures pending the evaluation of the storm drain access, Additionally, the licensee performed a review of-the controlling facility drawings and the installed physical security. measures associated with the storm drain. Based on the review of this documentation and discussions with site security representatives and facility engineering personnel, the inspectors determined that the subject storm drain was properly controlled and that no unsecured access existe .
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Throughout this event, the. licensee's security organization responded in an-exemplary manner and the resolution was timely and thorough, 2.1.2 Control of Radioactive Material-in Unit 2 During.the conduct.of routine plant tours,_the inspectors evaluated the implementation of radiological' protection controls used to-segregate low __
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specific activity material temporarily stored on:the 905-foot elevation of the Unit 2 reactor building. This material, which consisted of seven metal
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storage boxes, contained tooling and equipment designated for use during the removal of a reactor vessel head stud which was mechanically bound in the reactor vessel head flang Specifically, the inspectors examined the temporary lay-down area for proper radiological posting and labeling requirements. The inspectors also reviewed the associated survey results, which were conducted in accordance with Instruction RPI-602, Revisia 12, " Radiological Surveillance And Posting."
Based on the results of these reviews, it was determined that the subject containers were properly posted and controlled and that the removed container-covers, which were stored outside the posted area, had been properly surveyed -
with no detectable activity recorde i 2.1.3 Batch Plant Roof The inspectors questioned the structural integrity of the corrogated roofing on the abandoned batch plant located west of the switchyard which did_not appear to be securely attached to the structure. Given the frequer.cy of hig a wind activity and thunderstorms in the area, the possibility eined for the roofing material to become dislodged from the batch plant and carried into the a switchyard, which is located approximately 200 yards awa In response to these inquiries, the licensee inspected the structure and concluded that the 4 roofing material was not securely attached and that--it was not required for future use. Accordingly, the roofing was removed from the structur .1.4 Clearance Deficiency s While performing a review of clearance tags on the Unit 2 main control board, the inspectors observed that a caution tag was incorrectly placed on the~
handswitch for Valve 7010C, "BTRS No. 3 Demineralizer Isolation Valve," when the narrative' description on the tag indicated thatsit.should have been placed on the handswitch for Valve.70100, As determined by the inspectors, Valve 70100, "BTRS'No. 4 Domineralizer Isolation Valve," did have a= caution tag-properly attached that had the same' number as the tag attached to Valve 70100. Subsequent to this observation, the cognizant reactor operator
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informed the unit supervisor and the _ duplicate tag was removed. As a result of this observation, the inspector examined a sample of 20 additional clearances tags, and no additional deficiencies were noted. -' Additionally, the ,
licensee performed a routine monthly audit of existing' clearances with no additional deficiencies identifie .2 ~ Electrical Cable Support Grips The inspectors also evaluated the installation'of Class IE electrical cable support grips as controlled by Electrical Installation
- Specification CPES-E-2004, Revision'l'. In particular, the inspectors conducted 'a walkdown of approximately 50 safety-related cable supports in electrical raceways installed in the auxiliary, safeguards, and reactor
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i containment buildings. The inspectors also reviewed the results of the- '
licensee's evaluations, which were documented in Procedure 2-EAP-15, l
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" Electrical Cable Supports," and Quality Assurance Surveillance i Report QAS-91-001, " Surveillance of Walkdown Activities." l As a result of these inspection activities and documentation reviews, no ,
discrepancies were identified and it was generally concluded that the !
installed cable supports properly reflected the requirements of the governing installation specification and that the inspection criteria directed by :
Construction / Quality Procedure CAP-El-206, Revision 1. " External Cable Supports," had been effectively implemente .3 Class IE_ Breaker Refurbishment i Additionally, the inspectors witnessed selected portions of the refurbishment of Class IE Electrical Breaker 2EAl-16-BKR. This work activity, which was !
precipitated by a test discrepancy associated with the inability of the breaker to close on demand, was directed by Startup Work Package Z-21651. The ;
inspectors witnessed the disassembly and inspection of the breaker as well as the reassembly of specific components. These work activities were effectively-performed and the subject breaker was properly tested in accordance with Procedure MSE-S0-6301, Revision 2, "6.9KV Air C_ircuit Breaker Inspection And Cleaning," prior to its return to servic No discrepancies were noted during these maintenance activities and the personnel involved demonstrated good work practices and a thorough knowledge of the governing procedures.- ,
2.4 finit 2 Emeraency Diesel Generator RDG) Room / Area Turnover The inspectors performed walkdowns. of the Unit 2 EDG rooms which-had been .;'
turned over to nuclear operations on October 6, 1992. Tha areas' inspected were-Rooms 2-084 and 2-085 at the 810-foot elevation, Rooms 2-099A and 2-0998 at the 844-foot elevation, and the roof of the diesel generator building at the 865-foot elevation, lhe inspectors reviewed.the punchlist for the diesel
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-generator rooms, which contained a list of items _not completed at the time of The punchlist contained-15_ items which were minor.in nature.-
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room turnove including door labels not attached, temporary filter material installed, and ,
other similar items. During this evaluation, the inspectors did not identify '
- any deficiencies that had not already been identified by- the licensee. The-housekeeping was considered good,.although it was noted that_both of the Unit 2 diesel generators had numerous fuel oil or lubricating-oil leaks, and .
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absorbent rags used to soak. up the leaks were found around both, diesel .5 Unit 2 Residual Heat Removal- System Turnover Walkdowg _
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- The inspectors also walked.down major portions' of- the Unit 2 -residual heat-
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removal system which had been turned over to nuclear operations. The~ system drawings, i.ncluding the pipe support isometrics,:were compared with the actual:
pipe and support installations. during the walkdown. Additionally, the 17 punchlist items 1not completed pr_ior to turnover _were reviewed, Based'on:
- this-review, it was determined that these items were minor in nature andi
! generally consistent with the observed system configurations - Two minor
. discrepancies were -identified during the walkdown which the licensee had not.
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previously identified. Specifically, Valve 2RH-0018 did not have a label !
plate, and a section of piping insulation was missing inside the containment l building between a penetration and relief Valve 2-87080. These two :
deficiencies were identified to the licensee and appropriately incorporated i into the system punchlis j 2.6 Water latrusion in Termination Cabineh !
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occurrences which involved the intrusion of water into Class lE electrical l cabinets in the Unit 2 cable-spread room. Specifically, on October 26 and- l again on October 28, 1992, electrical termination cabinets in Room 134 were :
inadvertently wetted down by water from a fire protection header which was-undergoing preoperational test flushing. Subsequent to the documentation of these events on Operations Notification Event (ONE) forms 92-1048 and 92-1067, the licensee conducted walkdowns of the fire protection deluge system in the .
cable-spread room in order to identify any damaged or faulty sprinkler head ;
Additionally, the licen.2e evaluated the operational effects of the reported !
water intrusion into the electrical termination cabinets, including the potential impact of the treated fire water on the associated electrical i connections.
The inspectors examined the interior of Termination Cabinets CP2-ECPR10-01, I-02, -15 -17, -19, -41, and -42 immediately following each of these events -
and reviewed the technical dispositions of the-referenced ONE forms. Based on the results of these inspection activities, it was' determined that the licensee had taken appropriate corrective actions to clean and dry the )
interior of the affected cabinets and that the potential detrimental' effects -
of-the treated fire water on the termination points had been properly addressed in the technical resolution of the referenced ONE- form .
Additionally, the inspectors determined that the licensee's field inspections
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of the fire protection system sprinkler heads had been accomplished, ;
Therefore, it was concluded that the licensee had implemented appropriate ;
corrective'and preventive actions to address _the identified deficienc ,
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2.7 Reactor Vessel Stud Hole Deficienc y Two separate discrepancies associated with the threaded closure on the reacto ,
vessel head were also evaluated during this reporting _ period. The first~ issu :
involved damaged threads in Reactor Vessel flange Hole 28. Specifically; as documented on 10 Evaluation (TUE) form 92-6418, Revision 0, the stud in-Hole 28 was reported to be mechanically bound. Subsequent to the destructive ,
removal'of the stud, the licensee, in conjunction with representatives from i
= Westinghouse, evaluated th'e existing thread damage._ Based on the extent'off !
the. thread damage, which.was attributed to the accumulation of moisture under
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the guide pi_n adaptor sleeve, the licensee effected repairs by installing a
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threaded insert in Hole 28. As determined by the inspectors, this work was in 1 accordance with the recommendation contained in Westinghouse Letter MED-PCE- i
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12658 dated November 1,1992, and.was performed by Babcock and Wilcox: Nuclear?
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-7-1he inspectors witnessed selected-aspects of this repair activity and reviewed the associated documentation, including Babcock and Wilcox Nonconformance Report 540-003. Based on these observations and documentation reviews, it was determined that this activity was well controlled and the licensee's corrective measures implemented to prevent further thread degradation appeared appropriat The inspectors also evaluated the lack of concentricity on the reactor vessel flange stud holes, which was documented on TUE form 92-6712. As described in this 1UE form, during the licensee's review of the stud hole inspection results, the threads in the reactor vessel flanae wer: determined to be nonconcentric with the holes in varying degrees'around the entire circumference of the vessel flange. Additionally, thread damage was identified on 11 holes, i
The inspectors reviewed the technical disposition of 1UE form 92-6712, including the associated request for information form, Babcock and Wilcox data sheets, and Westinghouse's letter Wpi-15027 dated Hovenber 4,1992. Based on this review, it was generally determined that the repair activities associated "
with the 11 reactor vessel flange stud holes had been aroperly addressed and that the resultant loss of thread engagement of less t1an one thread from each '
of the affected holes was acceptable, flowever, at the conclusion of this reporting period, the acceptability-of the methodology used to evaluate the ,;
effective loss of thread engagement due to the eccentricity in the reactor 3 vessel stud holes had not been completed. Therefore, the technical j acceptability of the licensee's resolution of this deficiency will be documented in a future inspection report. This is considered Inspection followup item 446/9251-0 .8 EDG Deficiencies During a Unit 2 Train D diesel generator synchronization on November 13, a ;
reverse power trip occurred subsequent to closing the generator output breaker. Because this activity was being performed as part of preoperational Test 2Cp-PT-57-05, " Integrated Safeguards Actuation Test," Revision 1, Startup- t Deficiency Report 3334 was generated.-.As determined by the inspectors, the initial disposition was that the' operator did not load the generator:quickly
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enough and the step was: subsequently reperforme The inspectors questioned _ t the-licensee as to the cause for the reverse power trip. Discussions _with the operators determined that they believed the running and_ incoming voltmeters- +
were inaccurate and that utilizing these voltmeters to match generator and bu voltages during synchronization resulted in the-generator being underexcitedL and likely to experience a reverso power trip. ONE form 92-1243 was initiated-following the inspectors' inquiries and, at the conclusion of this reporting
_ period, this condition was being evaluated.- llowever,- based on the information available, it could not- be determined that,- absent the inspector's-inquiries, this ONE form would have been initiate ,
Another potential deficiency observed was that, during the isochronous mode of- -
operation, both engines beganito fluctuate-in speed and frequency and 0
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r continued to oscillate for as long as the engine was running in the *
isochronous mode. 1hese variations were recorded on strip chart recorders during the performance of preoperational testing, and documented on Startup Deficiency Reports 3331 and 3357 for Trains B and A. respectively. No -
degradation in safeguards equipment actuation or operation was observed by the inspectors or by the licensee; however, engineering was evaluating the condition as part of the processing of the associated TUE forms 92-6921 and 92-6922. This evaluation was not complete at the end of the inspection period, and the inspectors will continue to monitor the licensee's activities regarding the diesel generators performanc .9 Conclusions
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An inspection followup item pertaining to the technical adequacy of the licensee's resolution of the reactor vessel stud hole concentricity issue was opene Unit 2 tours, including security, radiological practices, and tag-out controls were determined to be good. The licensee's decision to remove th abandoned batch plant roof was conservative and indicated a commitment to reliable offsito power availabilit General housekeeping had improved as rooms and areas were prepared for turnover to operation The electrical cable grip program was determined to be effectively implemented and the inspected grips were properly installed. The electrical maintenance activities associated with the Class lE breaker refurbishment were determined to be well conducted and controlle The room and system turnover inspections concluded that the licensee was effectively identifying and tracking deficiencies and that the outstanding work items at the time of the turnover to operations were minor in nature and relatively few in numbe The licensee's response to identified deficiencies and events was generally good, liowever, it could not be conclusively determined-that a ONE form'would have been written on the Diesel Generator 2-02 reverse power trip without inspector promptin PREOPERATIONAL TEST WITNESSING (70312,70315,70316) _ :
The Linspectors witnessed _ the performance of portionh of various preoperational testing activities to verify that the testing was conducted in accordance with approved procedures and to verify the adequacy of test program records including.the preliminary _ evaluation of test result .1 . integrated Safeguards Actuation Test During this reporting period,-the inspectors witnessed the: performance of Preoperational Tett Procedure 2CP-PT-57-05 Revision 1, " Integrated Safeguards Actuation Test," which was performed to satisfy the requirements associated-with-final. Safety Analysis Report (FSAR), Table 14.2-2, Sheets 19 and 34. -The purpose-of this test was to demonstrate the proper automatic alignment and
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-9-operation of the engineered safety features equipment and to confirm the electrical independence between redundant Class lE AC and DC power sources by verifying the proper automatic actuation of engineered safety features equipment, including bus stripping and load sequencing, during specified design performance scenarios. Additionally, this test was performed to demonstrate the capability of the EDGs to perform their required design functions by verifying proper performance characteristics and the appropriate response to specified load conditions.-
Specifically, the inspectors witnessed the performance of all major test actuations, including dual train safety injection, train specific losses of offsite power, and safety injections preceded and followed by losses of offsite powe ,
lhe licensee had designated a single team of startup personnel to perform the testing activity, which included startup test engineers and technician Operation's crews continued their normal shift rotation. The procedure author-was the test director for the designated test crew and was responsible for the arimary test coordination and performance, lhe test director conducted artefings prior to the commencement of each major test activity, which were attended by the unit supervisor, control room operators, auxiliary operators, test crew test engineers, the field support supervisor, and a quality assurance representative. The briefings were thorough and identified major activities required to be performed to conduct the test and the requirements for successful completion of the tests. Test steps that were time critical were discussed and all questions raised by the briefing attendees were resolved prior to commencing the tests. Additionally, several operations crews held subsequent briefings pertaining to their specific actions required by the test procedure. The thoroughness of the briefings and familiarity with the procedure by the test director contributed to effective control of- the test performance. The inspector verified that the appropriate prerequisites were completed and signed prior to initiation of each major test actuation,
' Communications between startup and' operations personnel were goo Plant-wide-announcements were made prior to initiation of major actuations, including countdowns to actuation. The' major equipment actuations were intentionally scheduled during off-normal ~ hours, backshifts., o_r on weekends. 'lhis resulted in minimal impact to personnel working-in the fiel The signature sheet and test log were reviewed during performa_nce of the test and found to be satisfactorily _ maintained. -Test procedure chan<1es were-processed and implemented-in accordance with Startup Administration-Procedure CP-SAP-78, "Preoperational Testing ~," Revision 1, . and test- .. -
deficiencies were'promptly-and' appropriately documented in accordance with Procedure CP-SAP-16, " Deficiency and Nonconformance Reporting,".. Revision-1 The inspectors observed the recording of preactuation component positions and the verification of postactuation comp'onent positions, _ The i_ndividuals -
recording the various component positions were observed to be thorough and accurate-in the data collection. Discrepancies between actual and required '
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positions were appropriately documented as test deficiencies and the l appropriate startup deficiency reports were initiate The test sequence was performed, with no observable impact on Unit 1 operations. Ilowever, on November 12, a lack of coordination between Units 1 and 2 operations was observed when the test lineup required starting control room air conditioning Units 3 and The control room air conditioning units are common equipment and Unit I component cooling water supplied the normal cooling to the units. The cooling water supply from Unit I had been isolated '
due to a previously scheduled maintenance activity on Unit 1. Starting '
control room Air Conditioning Unit 3 resulted in an automatic, high-temperature shutdown of the compressor, lhe error was quickly identified and ;
ONE form 42-1223 initiate Unit I component cooling water was subsequently ;
realigned to the air-conditioning units and the test was continue '
Additionally, caution tags were placed on the control room air conditioning unit and the uninterruptible power supply cooling unit's handswitches stating that component cooling water must be verified available, in conclusion, the test was generally well written with procedure changes appropriately implemented when required. Overall, the plant hardware operated well with observed deficiencies documented as required. The testing staff was knowledgeable and coordinated well with operations. Although one instance of a lack of coordination between Units 1 and 2 operations was observed, the overall performance of operations was good. Collectively, the Unit 2 integrated safeguards testing activity, including procedure generation and ,
test conduct, was viewed by the inspectors as a strengt REVIEW 0F TEMPORARY INSTRUCTION 2515/065, "THI ACTION PLAN REQUIREMENT FOLLOWUP" (2515/065)
, Closed) TMI Action item llJ .4.?,6: "Contat!! ment Purge Valves" This item concerned containment purge valves which did not meet the operability criteria set forth in Branch Technical Position CSB 6-4 or the associated Staff Interim Position dated October 23, 1979. 'Specifically, purgo valves were required to be sealed closed during Modes 1, 2, 3, and 4, as defined in Standard Review Plan SRp-6,2.4, item ll.3.f, and'were verified to '
be closed at least every 31 days. As previously documented in NRC Inspection-Reports 50-445/89-17; 50-446/89-17, 50-445/90-02; 50-446/90-02, and 50-445/90-13; 50-446/90-13, this item was reviewed and closed for Unit-I based on a
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commitment in the FSAR, Section ll.E.4.2.6. Additionally, this commitment was reflected in Technical Specification 3.6.1.7, which requires 48-inch containment purge valves to be locked closed, ~and Technical Specifica- ..
tion 4.6.1.7.1, which requires verification of this condition at least every 31 days during Modes 1, 2, 3, and 4 Technical Specification 3.6.1.7 also required that the 18-inch containment pressure relief discharge isolation valves be operable. In particular, the 18-inch valves were required to be able to close_during a design-basis accident in order to ensure containment isolation. With respect to this
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-11-issue, Supplemental Safety Evaluation Report 23 concluded that the licensee had provided sufficient technical basis to satisfy the NRC that the 18-inch valves were o)erable provided that they were limited to a maximum opening of 65 degrees. 1 elative to Unit 1, the Prerequisite Test Data Record Procedure XCP-EE-ll, Revision 8, page 8 of 8, was reviewed for each 18-inch containment isolation valve and it was verified that the valves were limited to an opening of less than 65 degrees. Therefore, the operability requirements were satisfied and this item was closed for Unit 1 in NRC Inspectten Report 50-445/90-13; 50-446/90-1 With respect to Unit 2, the inspectors reviewed Design Basis Documant (DBD)
DBD-ME-301, Revision 4, which established that the Unit 2 valves are of the same design as the Unit I containment pressure relief discharge isolation valves. Additionally, the inspectors verified that the valves were similarly limited to an opening limit of less than 65. degrees by Prerequisite Test Data Record Procedure XCP-EE-ll, Revision 11, page-8 of 10, for each 18-inch containment isolation valve of Unit 2 as depicted in Drawing 2323-M2-0301, Revision CP- Based on the above documentation reviews and inspection results, it was determined that the licensee had appropriately addressed the NUREG-0737 requirements involving containment purge valve operabilityy criteria for both Units 1 and 2. Therefore, no further review of this action item is required and t_he associated inspection requirements of Temporary Instruction 2515/065 are complete .2 (Closed) IMI Action item II.K.3.9:- " Proportional Integral-Derivative Controller Modification" This item involved modifying the proportional integral derivative controller to remove the derivative function, which was designed to redute.the number of challenges to the power-operated relief valves as a result of spurious, noise-on the pressure signal. As previously-documented in NRC' Inspection Report 50-445/89-67; 50-446/89-67, this item was reviewed and closed for Unit 1 based on.a review of the design change authorizations, which eliminated the derivative function as indicated in~the FSA With respect to Unit 2, the inspectors reviewed! Design Change Authori- ~
zation DCA-97544, Revision 2,'which removed the derivative function for Pressurizer Pressure' Control Channel PX-045 This was-accomplished b removing the jumper that t_les the derivative circuit to the signal flow pat The_ inspectors also reviewed revised Calibration Procedure INC-77228, which reflected this- change- and the ap)11 cable data sheet, which -verified _ that? the-
-design change authorization had seen implemented and that the channel:was operable. Additionally, the inspectors : verified that the asibuilt drawing properly-incorporated Design Change Authorization DCA-85375, Revision 0,-which
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reflected the design change to Westinghouse Dr' awing 88910D35, Sheet-3 Based on the-above-. documentation reviews and inspection'results,-it was-determined that the licensee had appropriately _ addressed the NUREG-0737
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-12-requirements involving the controller modification for both Units 1 and 2; therefore, no further review of this action item is required and the associated inspection requirements of Temporary Instruction 2515/065 are complet FOLLOWUP ON CORRECTIVE ACTIONS FOR VIOLATIONS (92702) (Closed) Violation 446/9201-01: Improp_er Storage of Pressuriter Spray yalves This violation concerned the improper storage of safety-related Pressurizer Spray Valves 2-PCV-455B and 2-PCV-455 Construction Procedure ACP-14.2,
" Hauling, Storage, and Preservation of Code Materials." required that the valves be stored indoors with proper protection from inadvertent damages and ,
the entry of foreign materia Contrary to this requirement, the valves were '
determined to be inadequately stored outdoor i During this reporting seriod, the inspectors reviewed the licensee's response to this violation whici was contained in TO Electric's Letter TXX-92135 dated March 16, 199 As documented in this letter, the licensee initiated TUE form 92-3529 to disassemble, inspect, and repair the spray vrives as necessary. Additionally, the licensee's response concluded that the cause of this event was attributable to personnel error and was linked to the corrective actions which had been instituted in response to Violation 446/91201-03. These corrective actions included the enhancement of '
the programmatic controls for housekeeping and the segregation of materials as ,
well as the assignment of accountability at the superintendent level. Also, enhanced custodial efforts and room and area access control have been implemented throughout the plant as construction nears completio '
In order to verify the implementation of these programmatic enhancements, the inspectors conducted plant tours on November 2 and 3,1992, to assess general r plant housekeeping and the temporary storage of equipment. Based on the results of these tours, no discrepancies were identified. and it was generally concluded that the licensee's corrective actions had been properly implemente + (Closed) Violation 446/91201-03: Failure to Follow Procedures This violation was comprised of the following three examples of failure to follow established procedures:
- Material was stored under uncontrolled conditions; housekeeping and cleanliness standards were not maintained; and a safety-related storage area contained uncovered and unprotected piping, instrument lines, unlabeled equipment, and debris; l
- A welder was observed using an amperage that exceeded the maximum allowed-by the welding procedure specification (i.e., 92 amperage [ amp]
rather than the required 80 amp); and
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- A welder was observed welding without having established the required minimum preheat temperatur Aspects two and three of the violation were reviewed and closed in NRC Inspection Report 50-445/92-26; 50-446/92-26. Item I was also addressed in the referenced report but remained open pending further NRC review of licensee controls and their implementation, prior to the violation, which resulted from an inspection conducted in-November and December 1991, the licensee had identified programmatic problems ~
with the protection of permanent plant equipment and the control and maintenance of temporary storage / staging areas, Specifically, these issues were documented in TUE form 91-1743 dated August 6, 1991, and again in TUE form 91-1671 dated September _27, 199 As determined by the inspectors, the licensee's corrective actions in response to these internal findings included: revising applicable procedures to-facilitate their use by construction personnel; providing specific checklists for ensuring adequate housekeeping and protection of plant equipment; and,_
assigning housekeeping responsibility at the superintendent level for clearly--
specified zones. Corrective actions also included training of the superintendents with respect to regulatory requirements and management's expectations within this are This training was provided by tesson Plan 9039, " Housekeeping and field Storage Requirements," which was completed in P tober 199 As stated in the licensee's response to this aspect of the Notice of Violation, which was contained in TV Electric's letter TXX-92202 dated April 30, 1992, the existing program elements for housekeeping and protection of-plant equipment were enhanced subsequent to the licensee's internal findings, and they would be reemphasized throughout the-remainder of the project. Additionally, the licensee attributed the violation to recently hired workers who were not fully sensitive to management's expectations and requirements, furthermore, the licensee ascertained that the benefit of the corrective actions taken as a result of its internal findings had not been fully realized.-
The . inspectors also evaluated the results of recently conducted quality assurance department audits and surveillances pertaining-to' housekeeping and
_ protection of permanent plant equipment. In particular, the inspectors reviewed Quality Assurance Surveillance and- Audit-Reports QAS-92-009 dated-January 30',11992; QAA-92-005-dated January 30, 1992; QAS-92-229 dated September 8, 199?; and QAS-92-042 dated April 1,.1992. As a result of these reviews, it was' determined that the audit and surveillance report's results generally supported the licensee's conclusion that these programs were being - 1
. effectively. implemente Additionally, on November 2, 1992, the inspectors performed tours of selected portions of the safeguards building to assess licensee performance in this area. The inspectors specifically examined the following areas:
hus i'm em
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Room N Elevation Description 2-070 790' Corridor ..
2-064 790' Chemical additive tank room 2-063 790' Valve isolation tank room 2-073 790' Motor-driven auxiliary feedwater pump 2-074 790' Turbine-driven auxiliary feedwater pump _
2-094 831' Corridor 2-088 831' Piping penetration area
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In two of the above locations, Thermo-Lag fire-resistant barrier was being -
installed on conduits and cable tray As such, there was a significant amount of waste, debris, and dust being generated. However, custodial crews were actively engaged in cleaning-and removing the debris _ generated by_the-
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Thermo-Lag installation. Prefabricated Thermo-Lag sections and associated application components were _arpropriately staged and segregated-from the waste. -The inspectors also observed that the staging and storage _of mat _erikis-conformed to Procedure ECC-608-7, " Control of Materials, Parts, and-_
Components"; and Engineering inspection CPES-M-2032, " Procurement-and Installation of Fire Barrier and Fireproofing Materials,"
In other areas which were_ inspected, various rags, gloves and other consumables were encountered, but cleanup crews and the completion-coordinator-were actively engaged in cleanup activities. Two' nonconforming conditions were identified by the inspector in Room 2-088 that were turned over to the i _ area completion coordinator for resolution, Specifically,=an' argon gas
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cylinder was found inadequately ti_ed to a stanchion without any designation of-
! responsible party on the_ installation tag, and an expanded metal cage designed-E to protect Radictio_n' Monitor 2-RE-6293 was not_ secured-in place. . Subsequent L
to the. identification of those items,-the gas cylinder was immediately removed; p and corrective action was initiated for the expanded metal-cage.
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l-Overall, the impectors considered the-licensee's prescribed programs for-
- housekeeping and the protection of installed components;to;be effectively _
L < implemente Segregation and staging of quality and nonquali_ty components -and.:
l materials were appropriately-being performe .3 (Closed) Violation 446/9223-01: Load cells-not-included in the measuring and test equipment program This violation involved the failure to include in the measuring and test'
E equipment program -load cells that were used for_ preoperational testing. -
Specifically, the omitted items were theLload cells'in Clevis ~ Pins TR-2-SI-01,
-02, -03, -04T, -048,_and 7 05,=which had been used during Preoperational Test-2CP-PT-90-02, " Dynamic Transient -Response Testing," and. calibrated by a vendor, Teledyne Engineering Services. As reported by the licensee during
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their initial evaluation, there were at least 40 such load cells-on site which had been used for preoperational - testing of Units' 'I and In response to
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-15-this issue the licensee issued TUE Form 92-5657 dated June 29, 1992, for Unit- 2, and ONE form 92-613 dated July 1,1992, for Unit 1, to -address this issu During this reporting period, the inspectors reviewed the licensee's response, which was delineated in TV Electric's letter TXX-92414 dated September 8, 1992, This correspondence indicated that these load cells were incorrectly classified as permanently installed operating equipment, which resulted in the:
failure of the calibration records of these cells being submitted to the Metrology Laboratory for review and inclusion in the test and measurement program. As corrective actions these load cells were entered into the-measuring and testing equipment program, in addition, a project-wide review was done to assure that no other equipment had been misclassified. it was '
found that a total of 97 safety-related load cells required addition to the measuring and testing equipment progra The measuring and testing equipment program Procedure STA-608 was also revised in order to provide clarification for requirements for temporarily installed instrumentation and training was
. conducted on the revised requirements.- The inspectors reviewed the associated nonconformance documents and corrective actions.that were taken by the licensee and determined that the corrective actions had the appropriate scope and the violation had been resolved by revision of the procedure and inclusion of the applicable load cells in the measuring and testing equipment progra Based on these reviews, the inspectors determined that appropriate corrective actions had been implemented to address the identified violatio FOLLOWUP (92701) (Closed) Inspection followup Item (446/9216-03): TERMI-POINT Connections
This item involved two programmatic weaknesses relative to the licensee's implementation of corrective actions-in response to lessons learned -from industry operating experience.- The first weakness concerned the limited scope
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of the-technical justification used to reconcile Indu e ry Operating; Experience Report followup Assessment-WTB/89-06 associated with:the recommended inspections of TERMI-POINT connections in-the solid state protection syste The second weakness involved the licensee's corrective ~ action process which did not completely address the operatio'nal impact of identified deficiencies in- the control- circuitry of both trains of the solid state protection syste During this reporting period, the inspectors evaluated the results of the-licensee's actions related to these weaknesses.- Specifically, the inspector reviewed the technical disposition of TUE form-92-5393, which documented the: -
- -
- results of the ~TERMI-POINT- connection repair / replacement activities for
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Unit 2. Based on the results of this review and direct observations of-field -
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inspections, it was-determined that the licensee had performed a random pull test of 125 TERMI-POINT connections for both trains of the solid state C protection system in accordance with the recommendations of Westinghouse i- Technical-Bulletin NSP-TB-89-06 and Startup Work Packages SWP-Z-19657 and Z-19658, with no deficiencies identified. '
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-16-s The' inspectors also examined the results-of the licensee's review of!the 31 potentially reportable deficiencies (SNs) generated'from January:1988 through June 1990. Specifically, as requested in;the cover letter of NRC
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- Inspection Report 50-445/92-16;-50-446/92-16, the licensee performed this review in order to confirm the reportability methodology and implementation -of corrective actions for these SNs which _were determined to be not reportabl Although this review process identified three SNs (408, 462, and 472)'which required additional justification / clarification, none of-the re-evaluated SNs' .
were regarded as reportable. Accordingly, based on the inspectors reviews.of-
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the SN re-evaluation forms associated with these items, it was determined that the licensee had properly evaluated the reportability aspects of these ;
deficiencies and that the attendant corrective actions were appropriat .
Correspondingly, the inspectors examined the licensee's actions associated with Technical Evaluation-92-1295 which directed the pull testing of a random sample of 125 TERMI-P0lNT connections in both-trains of the solid state protection system for Unit-1. As a result of the specified pull _ testing,
. which was witnessed by the inspectors, defective connections were identi.fied on both trains of the solid state protection system and the sample size was '
increased to 100 percent as prescribed in the referenced Westinghous technical bulletin. This pull testing activity resulted in the identification a
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of 62 failures on Train A and 69 failures on Train B as documented on ONE forms 92-1253 and 92-1350,- respectivel Given the previously identified programmatic weakness associated with the limited technical justification for not performing the recommended actions of
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Westinghouse Technical-Bulletin NSD-TB-89-06 and the ultimate identification-of multiple deficiencies of TERMI-POINT connections-in both trains of the Unit -1 solid state protection system, this example 'of failure to implement appropriate corrective actions in response to industry operating experience is identified as a violation of Criterion XVI of Appendix B to 10 CFR Part 50 (445/9251-01).
7 FOLLOWUP ON LICENSEE ACTION ON 10-CFR PART 50.55(e) DEFICIENCIES (92700) (Closed) Construction Deficiency-Sionificant Deficiency Analysis Report (SDAR) CP-86-063: " Pipe Support Installations" SDAR CP-86-063 documented the actions associated with a broken cotter pin in a-Unit 1 large-bore pipe support. The scope of'the SDAR was subsequently expanded to include Unit 2. This issue was reviewed and closed for Unit 1 in
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- NRC Inspection Report 50-445/89-75; 50-446/89-7 SDAR CP.-89-Oll, which :
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-identified additional pipe support deficiencies, was reviewed and closed for Unit 1 in NRC Inspection Report 50-445/90-03; 50-446/90-0 Due to the
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similar nature of the deficiencies, TU Electric' combined the ' corrective actions for Unit 2 for the two referenced SDARs and .via TU Electric
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Letter TXX-91403 (ated December 5, 1991, informed the NRC that the correctiv action for both SDARs would be addressed as SDAR CP-89-Ol The combined i
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corrective actions for these SDARs were reviewed and closed in NRC Inspection
. Report 50-445/92-11; 50-446/92-11; therefore, this report documents '
administrative closure of SDAR CP-86-06 '
,
7,2 (Closed) Construction Deficiency SDAR CP-87-055: "
Containment _Sprav Pump Recirculating Piping" This deficiency involved the installation of containment spray pump i recirculation piping and supports which were non-nuclear safety ASME Class 5, a
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instead of ASME Class 2 piping, with seismic Category 1 supports wh!r.h were required by the FSAR. As previously documented in NRC Inspection Report-50-445/89-65; 50-446/89-65, this construction _ deficiency was reviewed and closed for Unit 1 based on a design modification which replaced the _ _
- subject Class ~5 piping with ASME Class 2 pipe and seismic Category I supports, and DBD-ME-028, " Classification of Structures, Systems, and_ Components," was implemented to ensure that components were. appropriately classifie :
- Additionally, the. licensee performed an evaluation to determine if Class 5 *
piping had been inappropriately used to provide and achieve. system safety function in any other safety-related systems. No other cases of inappropriate >
use of Class 5 piping were identifie With respect-to Unit 2, the inspectors. reviewed the licensee's corresponding-corrective actions, which involved replacing the subject piping with Class _2
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material and replacing the. supports with seismic Category IEcomponents. As~
phrt of this effort, the inspector also reviewed a sample 'of the-piping and support drawings used in the. field _ to implement the replacement activity _ J Based on the above documentation reviews and inspection results, no
- deficiencies were identified and it was determined that the licensee had .
- implemented appropriate corrective actions- to address -the identified - j deficienc .3 (Closed) Construction Deficiency SDAR CP-88-016: "
Containment Snray Chemical Additive System" During ,the licensee's design validation of the containment spray; system, it was determined that the chemical additive tank and the associated piping might
- not provide the specified design life due.to corrosion. Specifically, the:
corrosion rate _ developed from the National Association of Corrosion Engineers-publication " Corrosion Data Survey" provided a significantly shorter lifei expectancy than originally assumed for the piping exposed to the sodium hydroxide solution. The licensee concluded.that this1 issue was' reportable ~and determined that the cause of. the deficiency was- attributed-to the failure of' .
the design organization to properly _ consider the corrosion rate of Type 304:
- stainless steel when exposed to'a highly caustic _ solution. Ihis construction ,
deficiencyLwas reviewed and closed for Unit 1~in NRC Inspection'
Report 50-445/89-47; 50-446/89-47' based upon the licensee's -corrective; actions. The corrective- actions for the Unit 21 chemical additive tank _and
- piping corrosion concerns included the implementation of an inservice:
inspection plan for1 monitoring corrosion rates by' periodically measuring
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- component wall- thicknesses and the revision of D80-ME-0232 for:the containment
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spray system to specify the appropriate materials for the' tank'and' piping.
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Additionally, as documented in 10 Electric's Letter TXX-89063 dated February 13, 1989, the licensee conducted supplementary laboratory testsLin orderEto . ;
more closely approximate the actual corrosion rate. The results of the tests indicated that the corrosion rate would be substantially lower than the . .
National Association of Corrosion Engineers value. Therefore, the piping and '
tank life would be greater than the 10 years initially estimated by the a license ,
. .. --
The inspectors reviewed the licensee's Corrosion Monitoring Program Monitoring Plan, Revision 4, dated May 15, 1992, which included provisions for-inspections and a statement regarding the minimum wall-thickness criteria for the Unit 2 containment spray additive tank and piping. The inspectors also reviewed Station Administration Manual Procedure STA-730, Revision 2,
" Corrosion Monitoring Program," and determined it properly-addressed-the Unit 2 chemical additive tank and associated piping. Revision 1 of-Calculation ME(B)-291, " Containment Spray System'ASME Piping Wall Thickness,"
was also reviewed and found to contain a statement that corrosion rate
- analysis and testing had been performed and the actual corrosion rate was expected to be much less than originally expected. This calculation _ also- O stated that the actual corrosion rate would be evaluated as part of the
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licensee's corrosion monitoring progra ,
Based on the above reviews, the inspectors determined that the licensee had implemented appropriate corrective actions to address the identified deficienc , (Closed) Construction Deficiency SDAR CP-88-040: "NPSI Swa_y Struts" This deficiency involved the restriction of sway-strut movement to less than ..
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the required degree of swing-angle freedom. . With respect to Unit 1, this SDAR was reviewed and closed out-for NRC Inspection Report 50-445/90-03; 50-446/90-03,- based on the licensee's implementation'of corrective actions, which included revising the appropriate 'installationispecification and ;
procedure to assure that the required swing-angle freedom was provide With respect to lhiit 2, the inspectors reviewed the' licensee's corresponding corrective actions delineated in TV Electric's Letter TXX-89562 datedr August
' 23, 1989. These corrective actions consisted of revising Installationf Specification CPES-P-2018 and Procedure CDP-ME-102-1, as well as reinspection / rework of the~ effected struts' installed at CPSES, to insure compliance with the revised _ installation fand inspection criteria. The .
inspectors also reviewed the Unit 2 Mechanical Specification CPSES-P-2018,
- Revition 0, along with Design Change ~ Authorization?DCA-93620, Revision-13, an determined that specific instructions-were given for the installation and
- modification of sway : struts. in Section IV, paragraph 6.3. L Additionally, Attachments 7.13 and 7.14 of the Unit 2 ASME Procedure ACP-ll.5, Revision 11; .
dated April 14, 1992, were reviewed. Based on this review, it was determined
- . that these attachments contained comprehensive reinstallation instructions for
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-19-sway strut spherical bearings and a detailed sway strut installation checklist, The inspectors reviewed a representative sample'of. Unit 2 sway strut checklists which were' completed as part of the reinspection-and rework-of sway struts for Unit Based on these reviews, no. discrepancies were identified and it was determined-that the licensee had implemented effective corrective actions to address the identified deficienc .5 1 Closed) Construction Deficiency SDAR CP-88-041: "W-2 Tyon Cell Switches" This deficiency involved the failure -of four Unit 1 W-2 type cell switches due to the deformation of the spring retainer and a resultant loss of sprin tension. Specifically, in response to NRC Information Notice 87-62 and.its-associated supplement dated May 3,1988, the licensee notified the NRC by Letter TXX-88880 dated December 28, 1988, of a deficiency involving Westinghouse circuit breaker Type W-2 cell switche As previously-documented in NRC Inspection Report. 50-445/89-71; 50-446/89-71, this ~
construction deficiency was reviewed and closed for Unit 1 based.on the following corrective actions:- replacement of the four. defective switches, ,
issuance of new maintenance procedures, and the implementation of-periodic-inspections of the subject cell switche With respect to Unit 2, the inspectors reviewed the licensee's corrective actions, which were documented in.TU Electric's Letter TXX-90058 dated February 7, 1990. Specifically,-the inspectors examined Design Change Authorization DCA-85927, which promulgated the_ work procedures for replacing- ,
defective-W-2 type cell switches identified.during preoperational testing. -
Additionally, the inspector _ reviewed the-startup work packages-that were-initiated to-replace those switches as a result of Nonconformance'
' Report NCP,-89-06583. The inspectors also reviewed Maintenance
- Procedure MSE-p0-6002, which was developed for maintenance activities on-W-2. type cell switches for completenes Based on theiabove documentation reviews and . inspection results, n ~ deficiencies were identified and it.was determined that the licensee had implemented appropriate' corrective actions to address the identified -
deficienc .6 ..IClosed) Co_nstruction Deficiency SDAR CP-89-021: "Limitorque MOV Spring- u Packs"
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The licensee reported a. deficiency finvolving the configuration.ofl Limitorque actuator spring packs which was subsequently determined to be reportabl Specifically, M_odel- 60_-600-0022-1l spring packs were replaced by the-manufacturer for a 1-year period with Model 60-600-_0044-1- spring packs, which had only 11 Belleville washers instead of the 12 washers, as in '
Model 60-600-0022-'l. .This SDAR was closed for Unit _1_in NRC Inspection:
'ReportiS0-445/89-71;-50-446/89-71,: based-on -an evaluation of the . licensee's
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-20-corrective actions which included: the inspection of all safety-related motor-operated valves (MOVs) utilizing the Model 60-600-0022-1 spring pack, the inspection of at least one of each type of spring pack in all other safety-related MOVs, and the incorporation of baseline spring pack configuration data verified by Limitorque into the appropriate maintenance procedures.
In TV Electric's Letter TXX-90346 dated October 10, 1990, the licensee stated that they had confirmed the interchangeability of the two spring pack models in Unit I which had similar performance characteristic The affected MOV nameplates were restamped to correctly indicate that Model 60-600-0044-1 spring packs were installed. In addition, a spring pack inspection program for Unit I determined that no unacceptable configurations of spring packs were found out of the 22 which were inspected and tested. Spring pack configuration data was supplied by Limitorque and a Unit 2 setpoint control document, M2-2401, required that the verified configuration data be used to ensure that the spring packs were correctly configured prior to installation in a safety-related MOV. Additionally, as part of the licensee's actions relative to NRC Generic Letter 89-10, each spring pack in Unit 2 will be tested to verify its performance characteristics, preload, and stiffnes The Generic Letter program will also verify that the MOV nameplate correctly specifies the installed spring pack.
Based on the above reviews, the inspectors determined that the licensee's response to the deficiency was acceptable. in addition, the inspectors will continue to follow MOV testing, and the results will be documented in a future NRC inspection report as part of the Generic Letter 89-10 closure. (ClosUl Construction Deficienc_y SDAR CP-91-001: " Potential for Elect 6 cal Penetration Assemblies Overpressurization" This issue! nvolved a design deficiency in the nitrogen pressurization system which coulM have resulted in the overpressurization of the electrical penetration assemblies (EPAs) for Units 1 and 2.
Specifically, as a result of the identification of a noncompliance with FSAR design basis criteria which was discovered in Unit 1, TUE Form 90-233, Revision 0, was initiated to document the potential for overpressurization of the EPAs. This condition, which could have resulted in the loss of containment integrity, was also documented in Licensee Event Report LER 90-039 for Unit 1.
As stated in TU Electric's Letter TXX-91056 dated February 1, 1991, the nitrogen pressurization system was originally provided in accordance with Bunker Ramo recommendations to facilitate the maintenance of the electrical penetrations with a nitrogen blanket to prevent moisture intrusion, which could have eventually resulted in equipment degradation. However, subsequent to the replacement of the Bunker Ramo electrical penetrations with Conax feed-through assemblies, the licensee, in conjunction with the supplier, determined
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-21-that the-nitrogen pressurization system was-not required during normal- orL accident conditions and was, therefore, not required-for the containment EPA to perform their safety functio During this reporting period, the inspectors reviewed the. documentation associated with this issue, including DBD-ME-243-(Revision 0)-and DBD-EE-62-(Revision 5) which specified that the nitrogen supply would be isolated from the EPAs during normal operation. The inspectors also reviewed the applicable Conax- Corporation Design Qualification Report for electrical penetration assemblies and feed-through/ adaptor modules and determined that the nitrogen "
pressurization of the penetrations and modules was not required to maintain equipment qualification during normal and accident conditions. The inspectors evamined implementing Design Change Authorization DCA-100052, Revision 1, which modified the nitrogen pressurization syetem by disconnecting _the nitrogen supply, pressure switches, and associated alarms. Additionally, the- _
inspectors performed-a system walkdown of the containment electrical penetration nitrogen pressurization system and verified that the referenced design change authorization had_ been properly implemente Based on these documentation-reviews and field verification inspections, it.- l
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was determined that the licensee had implemented-appropriate corrective actions to address the identified construction deficienc .8 (Closed) Construction Deficiency SDAR-CP-91-002: " Linear Indications in 3-inch Schedule 160 Piping"
- The licensee reported a deficiency in which linear indications were found in
- 3-inch Schedule 160 piping -installed in.the Unit 2-auxiliary feedwater syste Linear indications had been found.in approximately 70.5 feet of the pipe._ - As determined by the licensee, approximately 15.5 feet of.the piping was installed in the auxiliary feedwater system, a 40-foot section was in the warehouse, and another 15 feet was located in a laydown -area. The licensee ascertained-that the piping was part of.an order of-213 feet manufactured-by-US Steel with Heat Number L83659. Additionally, the licensee determined that a the root cause of the deficiency.was contributable to a manufacturing-defect #
and that several. of the linear indications were found-to have violated the manufacturers minimum wall thicknes The corrective _ actions specified-in TU Electric's Letter _TXX-91197 dated May-20, 1991, included a quality control reviev of the N-5 data reports for Unit l'to determine if_any of the material had been installed, a quality
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control review of' the Unit 2 material database to determine if any additional'
material-of- the specified . heat _ number had been-installed, and a review of purchase orders for pipe to determine if any ' additional pipe of!the -same heat-number-had been sent to CPSES. These corrective actions included the
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requirement for scrapping the piping which was determined to be unacceptabl Based _on the review of the purchase order, the licensee determined that a-total of 213 feet of the specific heat number piping had-been received at-CPSE The licensee also determined that, -based on a review-of the- N-5 data reports, the Unit 1- piping was not affected by this condition. Additionally,-
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the pressure boundary materials data b'ase was-re' vised to prohibit restricted heat numbers from being added to the database. Based on the inspector's l review of licensee Memorandum TSL-92013 dated February 10, 1992,-it was determined that all of the affected piping had been scrapped.-
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Based on these reviews, it was determined the licensee had implemented appropriate corrective actions to address the identified deficiencie .9 LClosed) Construction Deficiency SDAR CP-92-001: " Lack of Weld Penetration on EDG Air Manifold Assembly" This potential deficiency involved a lack of weld penetration on the Unit 2 Train B EDG lef t bank starting- air manifold assembly, which was discovered-during the installation of a valve on the starting air manifold. This indication was subsequently removed to allow proper examination of the deficiency and the component was ultimately replaced with new material. .The licensee's examination of the weld section revealed that the amount of weld reinforcement compensated for the lack of penetration since the weld _ thickness equaled or exceeded-the adjacent' pipe wall thickness and the weld was not-
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required to comply with ASME or ANSI requirements. -Therefore, no code'
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violation existed. The inspectors reviewed the supporting documentation contained in Impell Report 02-0630-1345, " Design Criteria for Diesel Generator
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Large Diameter Piping for Comanche Peak," which concluded that.the welds were-not assumed to contain full penetration. -In addition, the pipe'section with '
the defect was hydrostatically tested to 1.5 times the design: pressure without any leakage. Based on the above information, the licensee determined that the -
weld would not have resulted in loss of function of the EDG and thus was not-reportabl The licensee also determined ~that the Unit 1 EDGs were not impacted by this potential deficiency in that there had been no code violation, the diesel vendor owners group had reviewed the welding issue =and concluded-that the piping'and components were adequate for their-intended safety-function, and-there:have been no indications of leaks during the preoperational testing . :
program or the Technical Specification surveillance test Based on these reviews, the inspectors determined that the licensee's response-to this potential deficiency, including the reportability determination, was acceptabl .10 (Closed Unit 2 Only) Construction Deficiency SDAR CP-92-006: " Class-lE-Battery-Chargers" This deficiency involved a' lack of qualified isolation devices between safet and nonsafety-related components. Specifically, the non-1E undervoltage: relay-and timer could have.potentialla caused blown fuses-in the secondary winding; of the-Class IE battery-charger control transformer, which would have resulted-in-a loss of safety _ function of the affected battery charge The inspectors reviewed'the licensee's corrective actions associated with this issue, which
- were documented in TU Electric's Letter TXX-92339 dated July 24, 199 Thes .
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-23-actions -involved-installing additional fuses to properly isolate the-undervoltage alarm relay and the disconnection nf the timer circuitry to
- ensure that this nonsafety-related device could not impact the Class lE power supply. Additionally, the inspectors reviewed-TUE Form 92-5053,.-which was-issued to address and correct the as-found condition via work orders which were completed-on August 15, 199 The inspectors also reviewed Design Change Authorization DCA-100739 and a sample of the startup work packages to verify that the aforementioned corrective actions were properly;and fully implemented for Unit 2. During thisTreview process, it was ascertained that a nonconformance document had been initiated to evaluate this. deviation fo impact on Unit The inspector also reviewed the reportability evaluation contained in TU Electric's Letter TXX-92339. In particular, Technical Specifications require that if any of the safety-related batteries a4e left without at least : -
one charger, and at least one charger cannot be restm oJ within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the plant must be placed in a safe-shutdown condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold shutdown within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. As stated by the_-licensee, these. required actions of the plant Technical Specifications preclude the development of-unsafe conditions in the unlikely event of loss of both chargers to a singlei battery. Additionally, as stated by the-licensee, therewis no credible failure mechanism that could.cause a three-phase short in multiple battery chargers simultaneously. Accordingly, the licensee concluded that this deviation did not represent a defect which could create a substantial' safety hazard and was not reportable pursuant to 10 CFR Part 50,55(e) ore 10 CFR'
Part 2 Based on the above documentation reviews _and inspection results, it was determined that the licensee had implemented appropriate corrective actions-to ~
address the identified deficiency and that the reportability aspects of this condition were properly characterize .11 (Closed) Construction Deficiency SDAR CP-92-007: " Quality Assurance Program = Breakdown of Kranco. Inc."
This deficiency involved-the failure of a vendor, Kranco, Inc., who supplied spare and refurbished parts for the Unit 2 polar crane to implementc 10 CFR-
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Part 50, Appendix B, and'10 CFR-Part 21 program. Specifically, therlicensee determined during a tri-annual audit May 12-15, 1992-(QAA-92-313, May'1992),
that, because of an internal reorganization, the1 vendor had ufailed to properly implement Appendix B requirements in-they_had not maintained-the qualification records of personnel and-they had failed to perform' audits and surveillances:
of-sub-tier suppliers. . Processed under-_this condition wereiPurchase Orders 50042066 702 (switch assemblies and new load cells),- 50045051.7D (refurbished load cells), S0045429 702 (short--link), .and S0045783 702L(shackle and chain). In response to this issue, the licensee initiated TL'E
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Form 192-5647 dated June 26, 1992, documenting Kranco's failure to implement. an appropriate quality assurance program.
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With respect to Unit 2, the inspectors reviewed the referenced TUE Form and
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its associated corrective actions. The TUE Form' identified that, although all the components were initially identified as safety-related, only the refurbished load cells (Purchase Order S0045051 702) were safety-related and the components on the remaining three purchase orders were' determined to be '
nonsafety-related. The inspectors reviewed Engineering Analysis CPSES-9218009, dated October 15, 1992, which provided the justification for the acceptance of the refurbished load cells and the remaining purchase order The- inspectors also reviewed the hardness test results performed -to verify material characteristics of the components on the remaining three purchase orders. As a result of this review, the inspectors determined that, in contrast to the_ licensee's final report contained in TV Electric's Letter TXX-92373 dated August.14, 1992, the refurbished-load cell had_not been dedicated; i.e., commercial grade dedication in accordance with the formal established-program found in such procedures as Procedure MMO 6.02-03, " Critical-Characteristics Development," Revision 1; and Procedure MMO 6.02-06,
" Preparation of Verification Plans," Revision _l, for commercial dedication of 1 part However, for the refurbished load cells the inspectors determined there was no need to dedicate these items in that the refurbishment did not change the physical structure of the load _ cells and the. electrical-response of these cells was not used for a safety functio With-respect to the components on the three remaining purchase orders, the inspectors determined that they had been informally dedicated, which was acceptabl Based on'.the above documentation reviews and inspection results, it was determined that the licensee had implemented appropriate corrective actions to-address _ the identified deficiency and satisfied the reporting, evaluation, and review requirement .12 (Closed) Construction Deficiency SDAR CP-92-017:
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" Residual Heat Removal Pump Seal Water Ring" This deficiency involved a defect in the CPSES Unit-2' Train A residual heat-removal _ pump. Specifically, the seal water recirculating ring-was improperlyL positioned on the pump / motor shaft during reassembly of the pump after the replacement of the upper and lower bearings. This_ condition could have caused the required cooling flow to the ' mechanical seal to not-be maintained 1 ,
resulting in the seal overheating,-excessively leaking, o'r failing, which could then lead to shaft seizure and loss of safety function of;the residual heat removal-pump. The inspectors reviewed the licensee's corrective actions-which involved -initiation of TUE Form 92-5899-to address the'as-found'
condition and correct it, which was completed on August 12,-1992. In_' addition
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to correcting the as-found condition, the. inspectors verified that a step had been added to Startup Work Package Z-20255 to visuallyLverify that the sea was properly-positioncd'after mating the motor Jand pump.
, -With respect to Unit 1, the inspectors determined that Technical
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Evaluation 92-1572 had been initiated to notify Unit 1 of the deficiency and-that their investigation found no evidence that this condition existed for Unit . _ _ ,- . _
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Based on.the above documentation reviews and inspection results, it'was determined that the licensee had implemented appropriate corrective _ actions to address the-identified deficienc .
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ATTACHMENT 1 PERSONS CONTACTED- TV ELECTRIC
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J.- Agles, Licensing Engineer
- M. Blevins, Director of Nuclear Overview
- R. W. Braddy, Unit 2 Assistant Project Manager
- H. D. Bruner, Senior Vice President
- J. Cahill, Jr., Group Vice President .
- D. L. Devis,- Manager, Plant Analysis
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- D. C. Dillinger, Event Analysis Engineer B. Green, Measuring-and Testing Equipment Technician
- S. W. Har,*ison, Unit 2 Project Engineering Manager
- T. L. Heatherly, Licensing Engineer
- T. A. Hope, Unit 2 Licensing Manager
- L. W. Hurst, Project Manager W. Huse, Engineer
- J. J. Kelley, Jr. , Plant Manager J. Lebruto, Construction Engineer F. Martin, Measuring and Testing Equipment Supervisor
- D. R. Moore, Transition Manager
- S. S. Palmer, Stipulation Manager
- D. E. Pendleton, Manager - Contracts
- C. W. Rau, Unit 2 Project Manager
- D. J. Reimer, System Engineering Manager K. Robinson, Operations Quality Control Inspector
- J. E. Snyder, Startup Manager
- R. L. Spence, Unit 2 Quality. Control Manager R. Staymates, Procurement Quality Engineer L. F. Tagghrt, Operations Quality Control Inspector
- C, L. Terry, Vice President Nuclear Engineering and Support
- J. E, Thompson, Unit 1 Licensin J. Valle, Startup Testing Engineer
- R. D. Walker. Manager of- Regulatory Affairs for: Nuclear Engineering Organization R. Williams,-Construction Engineer
- J. E. Wren, Construction Quality Assurance Manager R. Wright, Procurement Compliance Engineer B. Zarbo, Startup Testing Engineer 1.2 CITIZENS ASSOCIATION FOR SOUND ENERGY (CASE)
.0. L. Thero, Consultant 1.3 NRC Personne J. I- Tapia, Senior Resident Inspector V. G. Gaddy, Intern
- Denotes personnel that attended the exit meeting. In addition to the personnel listed above, the inspectors contacted other personnel during this-inspection perio .
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-2 2 EXIT MEETING An exit meeting was conducted on December 3, 1992. During this meeting, the inspectors reviewed the scope and findings of the report. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspector ..
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