ML19353A882
| ML19353A882 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/01/1989 |
| From: | Latta R, Livermore H Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19353A878 | List: |
| References | |
| 50-445-89-71, 50-446-89-71, GL-88-17, IEB-85-003, IEB-85-3, NUDOCS 8912080035 | |
| Download: ML19353A882 (20) | |
See also: IR 05000445/1989071
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APPENDIX B
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
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NRC Inspection Report:
50-445/89-71
Permits: CPPR-126
50-446/89-71
CPPR-127
. Dockets: 50-445
Construction Permit
50-446
Expiration Dates:
Unit 1: August 1, 1991
Unit 2: August 1, 1992
Applicant:
TU Electric
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas
75201
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Facility Names
Comanche Peak Steam Electric Station (CPSES),
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Units 1 & 2
Inspection At:
Comanche Peak Site, Glen Rose, Texas
Inspection Conducted:
October 4 through November 7, 1989
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//Are F'7
' Inspector:
R. M. Latta, Resident Inspector
Date
(Electrical) (paragraphs 2, 3, 4, 5, 6, 7 and 8)
Consultants:
W. D. Richins, Parameter (paragraph 6)
J. L. Taylor, Parameter (paragraphs 2, 3, 4, 5,
and 7)
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Reviewed by:
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!!. B. Livermore, Lead Senior Inspector
Date
8912000035 891201
KDR
ADOCK 0500Qg5
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Inspection Sunsnary:
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Inspect:.on Conducted: October 4 through November 7 1989 (Report
50-445/09-71
50-446/89-71)
Areas Inspected: Unannounced, resident safety inspection of the
- applicant's actions on follow-up to violations / deviations,
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10 CPR 50.55(e) deficiencies identified by the applicant, allegation
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follow up, electrical components and systems, safety-related.
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mechanical components, and Ceneral plant area tours.
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.Results:
Within the areas inspected, a weakness was identified in
the applicant's procurement program in that it failed to provide
adequate receipt inspection criteria for vendor procured thermolag
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material (paragraph 3.1).
Additionally, during this inspection
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. period, two violations were identified which involved the
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-applicant's response to SDAR CP-89-25, " Site Fabricated Thermo-lag
Material."
The first violation concerned the applicant's failure to
follow procedures during the dry film thickness measurements of site
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fabricated thermolag in that defective material was inspected and
accepted by the applicant's QC organization (paragraph 3.1).
The
second violation involved the applicant's failure to properly
identify the required corrective measures associated with defective-
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site fabricated thermolag in that the identification of the cause of
the condition adverse to quality, the generic implications, and the
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establishment'of measures to preclude repetition were not adequately
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addressed in the response provided in TU Electric's letter TXX-89737
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(paragraph 3.1).
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DETAILS
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1.
Persons Contacted-
- M.
Axelrad, Newman and Holtzinger
- J.
L.: Barker, Manager, ISEG, TU Electric
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'*D.'P. Barry, Senior, Manager, Engineering, Stone and Webster
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Engineering Corporation (SWEC)-
- J. W. Beck, Vice Prosilent. Nuclear Engineering, TU Electric
- J.LE. Bentham, President, The Bentham Group, Inc.
- 0.
Bhatty, Issue' Interface Coordinator, TU Electric
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- M.
R. Blevins, Manager of Nuclear Operations Support,
TU Electric
,
- H. lD. 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
Manager, CECO
- W.
G. Counsil, Vice Chairman, Nuclear, TU Electric
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- C. G. Creamer, Manager, Unit 1 Completions-Engineering,
MNJ Electric
- B.
S. Dacko, Licensing Engineer,'TU Electric
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- R.
J. Daly,. Manager, Startup, TU Electric
- G.
G. Davis, Nuclear Operations Inspection Report Item
' Coordinator, TU Electric
- N.
M. Eifert, Chief Engineer EA, SWEC
- J.
C. Finneran, Jr., Manager, Civil Engineering,
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TU Electric
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- C.
A. Fonseca, Deputy Director, CECO
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- S.-P.
Frantz, Newman and Holtzinger
- J.
L. French, Independent Advisory Group
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- B '. .P.
Garde, Attorney, CASE
- J.
Greene, Site Licensing,1NJ Electric
.
- W.
G. Guldemand, Manager of Site Licensing, TU Electric
- T.
L. Heatherly, Licensing Compliance Engineer,
.TU Electric
'*J.
C.' Hicks, Licensing Compliance Manager, TU Electric
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- C.
B. Hogg, Chief Manager, TU Electric
- R. T. Jenkins, Manager, Unit 1 Operations Support Engineering,
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TU Electric
- J.
J. Kelley, Plant Manager, TU Electric
- 0. W. Love, Director of Engineering, TU Electric
- F. W.' Madden-, Mechanical Engineering, Manager, TU Electric
- S.
G. McBee, NRC Interf ace,1NJ Electric
- J. W. Muffett, Manager of Project Engineering, TU Electric
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- S. S. Palmer, Project Manager, TU Electric
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- W.
O. Porter,-Operations Suyr. ort Engineering, TU Elect +ic
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- P.
Raysircar, Deputy Director / Senior Engineer Manager. CECO
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- 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
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F. Streeter, Director,-QA,:TU Electric-
- C. L. Terry, Manager of Projects, TU Electric
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- R'.
D. Walker, Manager of Nuclear. Licensing, TU Electric
- J.'E.
Woods, Assistant Project Engineer, SWEC/ CECO
-The'NRC inspectorsLalso interviewed other applicant employees
during this inspection period.
- Denotes personnel present at the November.7, 1989, exit.
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meeting.
2.
F,ollow-up on Violations / Deviations (92702)
a.
.(Closed) Violation (EA86-09, Appendix A.I.B.1):
Failure
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to satisfy the minimum separation requirements of IEEE
Standards.
This violation involved the applicant's
failure.to properly translate IEEE standard requirements
to instructions and drawings, as well as several examples
n' electrical separation deficiencies which were not in
acecrdance with the controlling drawings.
The applicant performed Issue-Specific Action Plan.
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(ISAP) I.b.1, among others, to address this issue.
Subsequent NRC staff evaluations of the ISAPs-were
reported as satisfactory in SSER 10, Appendix A.
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tionally, as reported in previous NRC Inspection Reports,
the Post-Construction Hardware Validation Program (PCHVP)
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which includod-Field Verification Method (FVM)-088 was
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reviewed and determined to be acceptable.
The NRC
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inspectors also followed the implementation aspects of the
separation portion of-FVM-088 as previcualy documented in
NRC' Inspection Reports 50-445/89-15, 50-446/89-15;
50-445/89-22, 50-446/89-22; and 50-445/89-49, 50-446/89-49
and determined that it was acceptable.
The NRC inspector subsequently examined a sample of 4 out
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of approximately 70 equipment panels and determined that:
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proper inspections had been performed; nonconformance
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reports (NCRs) had been initiated where required; and that
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these NCRs had been properly closed.
The panels selected
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for review were CP1-EPSWEA-02-02, cpl-ECDPPC-03,
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cpl-ECPRCB-06, and cpl-ECPRLV-17.
Based on the above
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reviews and inspection activities, the NRC inspector
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concluded.that the applicant had taken adequate corrective
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action to prevent reoccurrence.
Therefore, this violation
is closed.
b.
(closed) Violation (445/8964-V-01):
Bypassing hold point.
This violation occurred when a Quality Control (QC) hold
point was bypassed and a section of electrical cable tray
was welded prior to a QC inspection of the lifted cables.
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In~ response to this violation,'the applicant issued
'NCR 89-9245, Revision 0, to document the missed hold point
- and to verify that no cable damage resulted from the.
-welding._ Also, the personnel involved were counseled, a
~ memorandum to all craft personnel was issued by the
electrical craft manager, and additional craft training
was conducted.
Based on the above actions, this violation.
is closed.
c..
(Closed) Deviation (445/8964-D-02):
date for Class lE meter replacement.
This deviation
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occurred when the Class lE Unit 1 diesel generator watt
meters were replaced subsequent to Hot Functional Testing.
(HFT) rather than prior to HFT as committed to in.
TU Electric's letter TXX-88294 dated March 25, 1988.
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The applicant's response to this deviation stated that
this occurrence was the result of an error in.the manual
transcription of data to a new commitment tracking system-
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(CTS) database.
The applicant's corrective actions
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included enhancing the procedures regarding the use of the
CTS and' review of the CTS database.
Based on the'above corrective actions delineated in.
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TU Electric's letter TXX-89743 dated October 26, 1989, the
NRC: inspector determined that adequate measures had been
implemented to correct the process which allowed this
deviation.
Therefore, this item is closed.
3.
Action on 10 CFR'Part 50.55(e) Deficiencies Identified by the
Applicant-(92700)
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a.
(Closed - Unit 1 only) Construction Deficiency
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(SDAR CP-86-03):
" Sealing of Class 1E Devices."
This
deficiency initially addressed an apparent failure to
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install Class lE limin switches in accordance with the
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manufacturer's requirements concerning both the applica-
tion of qualified conduit thread sealant and the torquing
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of conduit threads.
Subsequently, the scope of this
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construction deficiency was expanded to include a poten-
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tial design deficiency involving the failure to include
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the required electrical conduit seal assemblies (ECSAs) in
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the applicable Specification 2323-ES-100.
ECSAs are
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necessary to preserve the environmental qualification of
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the equipment when located in a harsh environment.
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In response to this issue, the applicant reviewed
Installation Procedure EEI-21 as well as 20 construction
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travellers and concluded that the initial aspect of the
deficiency was not substantiated in that both the thread
sealant and the torque requirements were addressed during
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the installation'of limit switches.
Corrective Action
Request (CAR)-048 was initiated to address the'second
aspect of this deficiency and it included the following
corrective actions:
clarification between1the specific.
project engineering requirements and the generically
applied manufacturer's instructions, revision.of Specifi-
cation 2323-ES-28 to include-all lE devices requiring-
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qualification,'and the revision of Electrical Specifi-
cation 2323-ES-100 to identify devices by type when ECSAs
are required and to list their inspection requirements.
Additionally, the NRC inspector determined that certain.
aspects of this deficiency were addressed by the Correc-
tive Action Program (CAP).
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. Based on a review of the actions implemented by CAR-048,
the: revision of Electrical Specification 2323-ES-100 and
.the evaluation of the associated = design change authoriza-
tions (DCAs) and NCRs, the NRC inspector determined that.
the' applicant's actions regarding Unit 1 activities-were
acceptable.
Therefore,.this SDAR is closed.
b.
(Closed - Unit 1 only) Construction Deficiency
(SDAR CP-86-40):
" Application of Non-Qualified Agastat-
Relays."
The applicant verbally reported this deficiency-
on May 20, 1986.
It involved the procurement and use.of
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nonqualified Agastat relays in Class-lE applications,
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The reportability analysis.and the associated corrective
actions were reported by TU Electric letter TXX-6017 dated.
October 10, 1986. LAs stated in this correspondence, the
corrective actions included:
revising.the vendor designed
equipment drawings to require the use of prequalified.
components,.the revision of the. applicable procurement:
. procedures, the updating of the nuclear operations _
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defective items list (NODIL), and the replacement of the
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nonqualified relays.
The NRC inspector reviewed the NODIL, Revision 7;
Procurement Procedure WHS-002, Revision 11, as well as
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various DCAs which replaced the existing relays with
"E"
prefix types; and NCR PE-87-606, Revision 0, which
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implemented the subject DCAs.
The NRC inspector also
randomly inspected 4 out of approximately 14 affected-
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cabinets and determined that the relays involved were the
correct
"E" prefix types.
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Based on the above reviews and inspections, the NRC
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inspector determined that the applicant's actions for
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Unit 1 were acceptable; however, pending the implementa-
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tion of corrective actions for Unit 2, this SDAR is closed
for Unit 1 only.
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,(Closed,. Unit 1 only) Construction Deficiency
(SDAR CP-86-68):
" Weather Protection for Class 1E-
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Components:"
Specifically, this deficiency involved rust-
and. water observed inside the exposed Class 1E terminal
boxes.-
The applicant's corrective actions as delineated in
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TU Electric's letter TXX-88607 dated August 11, 1988,
included the clarification of Electrical Specification
2323-ES-100 pertaining to outdoor conduits / junction boxes
sealing requirements, the performance of walkdowns in.
accordance with FVM-089, and the issuance of 6 NCRs.
The
implementation aspects of FVM-089 have been previously
inspected and accepted as documented in NRC Inspection
Reports- 50-445/88-38, 50-446/88-32; 50-445/88-53,
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50-446/88-49; 50-445/89-36, 50-446/89-36; 50-445/89-15,
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50-446/89-15, and 50-445/89-28, 50-446/89-28.
The NRC
inspector'also reviewed the pertinent changes to
Specification 2323-ES-100 and the 6 NCRs associated with
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Lthis' issue.
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Based on the-above documentation reviews and inspections
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of selected Class 1E terminal boxes, the NRC inspector
= determined-that the applicant's corrective actions.
appeared to have been adequately implemented for Unit 1.
However, in that no work has been performed =on Unit 2,
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_this SDAR is closed for Unit 1 only.
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d.
(Closed - Unit 1 only) Constructicn Deficiency (SDAR
CP-88-09):
" Electrical Penetration Overload Protection."
As. reported by the applicant, this significant deficiency
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involved the potential overloading and lack of backup'
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' protection devices for electrical penetrations.
This
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deficiency involved the following three_ subjects:
backup
protection incomplete or nonexistent, protection devices-
uncoordinated with penetration ~ conductor ratings, and.
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momentary short-circuit currents of module conductors
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exceeding the penetration ratings.
The NRC inspector determined that the applicant's
corrective action included the7 incorporation of the
penetration-protection-design criteria in the Design Basis
Document (DBD)-EE-062.
Additionally, compliance with the
applicable design criteria has been addressed >by the
implementation of hardware changes involving the rerouting
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of cables, the paralleling of penetration conductors, the-
resetting of protective relays, and the replacement or
addition of relays.
The NRC inspector reviewed DBD-EE-062
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and the portions of calculation 16345-EE(B)-048 which were
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related to this issue.
The NRC inspector also reviewed a
sample of the approximately 32 DCA packages including
DCAs 71741, 75070, 78248, and 85145 which implemented
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corrective acticns.
No discrepancies-were_ identified-
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during this review process.
'The NRC inspector also. conducted inspections of the work.
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associated withEDCAs 71741 and 85145 and determined that.
the specified hardware changes appeared-complete.
Based _on-the~above reviews.and inspection activities, the
NRC11nspector determined'that the programa and procedures.
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in~effect appear 1to' adequately control the corrective
actions pertaining to the identified penetration overload 1
_ protection-issues for Unit 1.
This SDAR is considered.
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closed for Unit 1 only.
e.
'(Closed) Construction Deficiency (SDAR CP-88-35):
"M&TE
- Program."
Specifically,;this'SDAR involved deficiencies ~
in-the applicant's calibration' procedures and inadequate /
inaccurate, calibration standards which could have rendered
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the-accuracy of. measuring and' test equipment (M&TE)
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indeterminate.~
In response to these issues, CAR 88-029 and several NCRs
were initiated to address the deficiencies which
originated in-the Brown & Root (B&R) calibration facility-
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on site.
Among other actions, the-CAR discontinued'B&R.
calibration. facility activities, checked /recalibrated
standards'and transferred-them to the applicant's calibra-
. tion facility, and evaluated the effects of calibration'
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-standard inaccuracies on plant hardware acceptance tests.
In order to evaluate the applicant's actions regarding-
this issue, the NRC inspector reviewed the results of
-CAR 88-29 and Procedure-STA-608, " Control of M&TE," as
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. well as several specific M&TE calibration procedures and
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the completed dispositions of 4 out of approximately
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50 NCRs.
Additionally, the NRC inspector interviewed
selected facility personnel.and observed various activi-
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ties at the current calibration facility, including the
conduct of specific M&TE calibrations.
As a result of the above reviews and inspection related.
activities, the NRC inspector concluded that the appli-
cant's determination of nonreportability was acceptable-
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in that no hardware changes-or invalidated tests resulted-
from the completed NCRs.
The'NRC inspector determined-
that, although seme minor issues involving nenprocedur-
alized administrative handling of M&TE records existed,
they did not adversely impact the results of the M&TE-
calibration program.
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Based' on the . above reviews- and inspection efforts, the- NRC
inspector determined that the applicant.'s actions in
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-response to this deficiency were adequate.
Therefore,
this SDAR is closed.
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f.
(Closed - Unit 1 only) Construction Deficiency
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(SDAR CP-88-41):
"W-2-Type Cell Switches." ' Subsequent to
the issuance of ' NRC Information Notice- 87-61 and its-
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associated supplement-dated May 3',
1988, the applicant
notified the NRC of a deficiency involving Westinghouse
circuit breaker W-2 type cell switches-on' December 2,
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1988.
The applicant's; response to this reportable deficien'cy
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included,the. replacement of-four. deficient switches which-
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were'found during the-performance of: inspections directed _
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by NCR 88-15325, the initiation of DCA-85927 to replace'
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W-2' switches, and~ implementation-of Maintenance-Proce-
dure MSE-PO-6002 which directed-the inspection of cell.
switches at half the Westinghouse recommended interval.
Based on review of the above documentation and program-
matic evaluations, the NRC inspector determined-that the
applicant's actions in response to this issue were
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acceptable.
Therefore, this SDAR is closed.
.g.
(Closed) Construction Deficiency'(SDAR CP-89-03):
'" Gamma-Metrics Neutron Flux Monitoring."
This reportable.
deficiency involved Gamma-Metrics' supplied cable:assem-
blies which are used for post-accident neutron-flux
monitoring.
In particular, Gamma-Metrics issued a 10 CFR-
Part 21 notification that identified potential leaks at
the threads / solder connections of the neutron. flux monitor-
cable assemblies.
As stated in TU Electric's final.
response to this issue contained in their letter TXX-89643
dated September 1, 1989, the applicant had received four
of the subject cable assemblies from Gamma-Matrices.
The NRC inspector reviewed the documentation associated-
with this deficiency including the identifying correspond-
ence from Gamma-Metrics to TU Electric dated February 22
and May 10, 1988, and to the Office of Inspection and
Enforcement dated February 19, 1988.
The NRC inspector
also. reviewed NCR 88-19400, Revision 0, which documented
the potential deficiency involving the soldered joints on
the neutron flux monitors and which directed the return of
these devices to the vendor for repair in accordance with-
CPSES purchase order 665-70037.
The subject cable assem-
blies were subsequently returned to the site and were
installed by the vendor for Unit 1.
The Unit 2 cable
assemblies were similarly repaired and placed in storage
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in the applicant's warehouse.
Concurrently, five of the
detector assemblies (one spare) were returned to Gamma-
Metrics for-inspection, testing, and rework.
The corree-
tive actions associated with the Unit 1 assemblies have-
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been implemented as committed to by TU Electric in their
response to this issue, and the Unit 2 detector assemblies.
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,will be corrected prior to Unit 2 fuel. load.
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Based-on the above documentation reviews, the NRC
inspector determined that the applicant's corrective
actions regarding this reportable occurrence were-
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acceptable.
This SDAR is_ closed for Units 1 and 2.
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h.
(Closed - Unit 1 only) Construction Deficiency-
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-(SDAR CP-89-21):
"Limitorque MOV Spring' Packs."
The
applicant reported a deficiency involving configuration of
limitorque actuator spring packs which was subsequently.
determined.to,be reportable.
In particular, the model
No.60-600'0022-1 spring packs which were being replaced.
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had only 11 of the 12 Belleville washers. required for
proper operating characteristics and the replacement-model
No. 0301-113 spring packs had apparently been supplied.
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with' improper Belleville washer configurations and missing-
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. locknut setscrews.
Based on communications with.
Limitorque, the' applicant was able to obtain sufficientu
.information;to correctly configure the new spring packs.
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Further investigation by the NRC inspector revealed that
the-applicant-had questioned:Limitorque regarding the
possible Part 21 action regarding the-misconfigured spring
packs originally provided.
Limitorque-informed-the
applicant that the "-0022" spring packs had been changed-
to model "-0044," and that there was no safety signifi-
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cance associated with this modification in that the torque-
characteristic of the "-0044" pack was essentially the.
same as the "-0022" pack consequently, no Part 21 action
was contemplated.
As specified in the applicant's closecut documentation,
the corrective actions included the inspection of all-
safety-related MOVs utilizing the "-0022" 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.
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In addition, torque switch setting and operational testing
of safety-related MOVs are continuing in response to NRC
The NRC inspector reviewed NCRs 89-7483, 6320, 6321,
and 2361 involving MOV spring packs.
Additionally, the
NRC inspector witnessed the complete configuration testing
of the spring pack for 1HV-4286 on work order C89-12527.
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This testing included parts: measurement, configuration
documentation, and load profiling.
During this process,
it was observed that QC was:present for the required.
portions: of the test and no discrepancies were identified.
Based on these reviews and inspection activities, the NRC
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inspector-determined that.the: applicant's responsesto the.
deficiency was adequate.
In addition, the NRC inspector-
will continue to follow-up MOV' testing and the results of
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these activities will be documented-in a future NRC
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inspection report as part of NRC IE Bulletin 85-03
closure. 'Therefore, this SDAR is closed-for Unit 1 only.
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(Open)z Construction Deficiency (SDAR CP-89-25):
" Site
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. Fabricated.Thermo-Lag Panels."
This issue concerned site-
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fabricated thermolag panels which were inspected and_
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accepted by the applicant's QC organization.
The panels.
were inspected for a,1/2-inch minimum' dry film thickness
(DFT) and were subsequently-determined to be'less than the-
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specified dimension.
As stated in the applicant's
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response to'this reportable' condition in TU E3ectric's
letter-TXX-89737 dated October 12, 1989, this material
deficiency impacted approximately 2,000 square' feet of
thermolag that was-installed on cable trays and conduits-
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in Unit 1 and approximately 11,000 square feet of material
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that was in the-applicant's warehouse.
Also, during'the
' removal'of site-fabricated panels >from Unit 1, it was
determined that some installed 1 configurations were in
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disagreement-with the Installation Specification
2323-MS-38H, Revision-2, " Cable Raceway Fire Barrier
Materials."
Specifically, certain thermolag panels were
identified-as having less than the' required 1/2-inch
thickness in the areas of seams', joints, edges, and bolted
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joints.
Additionally, some of the removed panels had been
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modified to accommodate extended configuration' geometries-
without proper compensation-for the reduced material
thickness.- This issue affected an additional estimatedt
12,000 square feet of installed thermelag.
As stated in
the applicant's final response to this deficiency, had
this condition remained-uncorrected, the potential existed
that a fire could have breached the barrier and adversely
affected-the ability to safely shut down-the plant.
'
In order to evaluate this issue, the NRC inspector
reviewed the associated documentation including NCRs
89-8519, 89-9313, and 89-09314; Construction Hold Notice
-
Form 572; Procedure ECC 10.07, " Application of Fire
.
'
Protection Materials"; Procedure NQA 3.09-1.07, "Inspec--
tion of Fire Protection Cable Raceway and Structural
Steel"; CAR 89-009; Specification .2323-MS-38H, " Cable
Raceway Fire Barrier Materials"; and the subject material.
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These reviews indicated that the applicant's 3.nitial
corrective actions as prescribed-by the-above-mentioned-
NCRs included the scrapping of'the defective: (site .
.
fabricated thermolag) panels in the warehouse.
Also, the
.
.
questionable configurations-installed on cable trays and
L
,
l
conduits in the plant were removed and were'-replaced-with
p
thermolag purchased from an approved vendor-(Thermal-
Science, Inc.).
Additionally, the NRC inspector conductedu
evaluations of work in progress in both the Safeguards and.
the Auxiliary buildings duringrthe removal of defective
thermolag and the subsequent-replacement process where
,
. vendor supplied' material was utilized.
These' efforts were-
H-
generally conductrd'in accordance-with the-insta11ationx
K
specification with-the exception of the deficient condi-
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tions documented on NCR 89-11142, Revision 1.
This NCR
,
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identified discrepancies associated-with the vendor'
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supplied (prefabricated sheets) of thermolag which were
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determined to haveivariations in-thickness ranging from-
3/8. inch to 1L1/4 inch,
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The'NRC inspector reviewed the applicant's technical _
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disposition of NCR. 89-11142, Revision 1,.and determined-
R
that although the basis'for accepting the reported-
l
condition = appeared-adeqcate in that this condition-was
,
l
determined by the supplier to not be detrimental to-the
fire-resistant response'of the' panel, this~ anomaly could
have been avoided-had~the-applicant not deleted-its site
QC inspection requirements for the thickness attribute-
from Verification Plan 89-2092.
Based on discussions with
members of the applicant's QA and QC staff, it was: deter-
mined that these inspection criteria were deleted-from-the
receipt inspection verification plans by-Procurement
Engineering'(Change Order 6C33604).
This action was
reportedly the result of the supplier's status (with no
restrictions) on TU Electric's approved vendor-list.
This decision by-the applicant's procurement Engineering
organization was apparently made in the absence of-histor-
'
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ical information-relative to thermolag discrepancies.
The
applicant's failure to provide ~ adequate receipt inspection
criteria for the vendor procured thermolag material, which
could have detected this deficient condition and averted
the potential for significant rework-, is identified as a
weakness within the procurement program.-
The NRC inspector also examined-the process whereby
site-fabricated-thermolag which did not comply with the
"
required dry film thickness (DFT) had been inspected and
accepted by the applicant's QC staff.
This examination
revealed that the-material in question had been inspected
-
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under.the auspices of Procedure QI-QP-11.20-1 which was in-
effect from- October 1982 through December: 1986. - _ Although--
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this procedure underwent:several revisions during this:
time frame,.the-requirement to verify'a DFT of-1/2-inch.
j
minimum was continuously mandated during-the preapplica-
tion inspection process.
' Additionally, the controlling;
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Specification'2323-MS-38H, Revision-2, " Cable Raceway-Fire'
Barrier- Materials,": stated-, in part, that-Thermelag 330-1
.j
(site; prefabricated sections) shall have-a dry film-
thickness-of 1/2 inch ~-to 3/4' inch.
J
As delineated in NCR 89-8519, the deficiency in the-DFT
.
involving the site-fabricated thermolag was identified on
,
- Julyc28, 1989.
This NCR indicated that several panels-
were examined by engineering personnel and all boards.
selected. were determined to exhibit. a DFT measurement' of-
L
less than the required 1/2-inch minimum.
As described-by
representatives'of the applicant's QC organization'during-
a' meeting.with members'of the NRC Resident-Inspector's
i
staff on October? 26, 1989, the reported' condition was
L
potentially attributable to fabrication techniques util--
,
imed by the applicant during the manufacturing of,thermo-
lag panels on-site which did not provide-for a proper cure:
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time: prior to:DFT measurements,
Thus, subsequent to DFT
measurements, the- site-f abricated panels " settled" produc -
1
ing the nonconforming condition.
As described-by the-
applicant during the referenced meeting, the-recommended.
cure time: for these panels was approximately -20 days;-
however, this consideration was:not factored-into the
inspection verification plan 1and'no mechanism existed-to-
_
'
detect this defect following-the fabrir,ation DFT
- inspections.
Based on the NRC inspector's . review of the associated-
documentation, system inspections, and the-results of
-
- several meetings with representatives of the-applicant's-
QA/QC and licensing organizations, it-was determined that
the dimensional inspections required by the applicant's
Materials Specification 2323-MS-38H, Revision 2, and by
Inspection Procedure QI-QP-11.20-1 to insure a minimum DFT
of 1/2-inch minimum to 3/4-inch maximum were-inadequate
and were not properly performed to insure that the
specified-inspection criteria were maintained.
This example of failure to follow procedures during
QC inspections performed on deficient site-fabricated-
thermolag material is identified as a violation
(445/8971-V-01).
Additionally, during the assessment of SDAR CP-89-25, the-
NRC inspector identified several questionable issues
concerning the applicant's response-to this event.
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particular, the-documented actions relative to this
reportable deficiency contained, in part, in CAR 89-09,
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neglected?to address the inadequate' inspection tech-
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niques/ criteria which allowed the deficient site -
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fabricated thermolag material to be inspected and accepted
for' installation without detection.
As stated in this
..
CAR, the actions to preclude. recurrence simply concluded 1
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-that site-fabricated;thermolag panels would not be used
for future applications. .Furthermore,.the generic
' implications: stated 11n the CAR were. inadequately-addressed:
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in-that the conclusion indicated that there were no
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-generic implications.
This conclusion. ignored-the
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ramifications implicit in a QC program which failed'to
detect a significant deficiency.
The applicant's final response to the issue, contained in
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TU Electric's letter TXX-89737, failed to adequately
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identify _the cause of this significant condition. adverse.
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to quality.in that the conditions which allowed the
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deficient site-fabricated material to be inspected,
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accepted by QC, and subsequently. installed were not
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adequately addressed.
No specificity was provided in this
'
response.to provide assurance that the cause of the
condition.had been-properly determined or that.the
'
' corrective actions to prevent reoccarrence were adequate.
Collectively these deficiencies in the applicant's
response-to this event which represented a1significant
condition adverse to quality are identified as a violation-
!
(445/8971-V-02):
failure to' assure that the cause of the.
condition is detennined and corrective action is. taken to
preclude repetition.
4.[
Allegation Follow-up (99014)
!
a.
(Closed) Allegation (OSP-89-A-86):
This. allegation
involved the termination of a worker subsequent to the
,
incorrect cutting of safety-related. wires associated with.
_l
the heating, ventilation, and air-conditioning (HVAC)
'
system.
The alleger stated his concerns to members of the
NRC. Resident Inspector's office at Comanche Peak on
4, y
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September. 14, 1989.
1
The alleger stated that he had been formerly employed as a.
4
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' journeyman: electrician by an onsite contractor, but that
I
he had been terminated on or about August 15, 1989.
The
alleger went on to state that immediately preceding his
termination he had been performing safety-related work
(Train A) on the 852 foot level in the safeguards build-
ing, room 150, when he was directed by his foreman to cut
specific wires in a pull box.
The alleger also stated
that the work was being performed in accordance with a DCA
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(unspecified)zwhich was associated with the' repair of an
electrical. seal that was out.of service in the room.
The
-alleger stated that an electrical QC inspector was present
,
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below the work area, and that after. confirming with his
r
foreman which wires were to be. cut, he completed the-
.
action by severing the conductors.
Subsequent to this
activity, the alleger was advised by-the QC inspector that-
he had cut the wrong conductors and that an NCR was being
written.
The alleger stated that he had been specifically directed-
by his foreman.to. accomplish this activity and that the-
'
punitive action taken against him was unfair.
The alleger
also stated that he had provided his concerns to SAFETEAM.
The NRC inspector asked the alleger if there_were any
other, witnesses to.this. event or if the QC inspector could-
corroborate his statements regarding the verbal directions--
provided;to'the alleger by'his foreman.
The alleger
stated that there were no other witnesses and that the QC
1
inspector could not substantiate his statements.
Subse-
quent to the alleger's identification of this issue, the
NRC inspector conducted a field walkdown of the associated:
equipment including junction . box JB11A11330 and conduit .
C14021429. -These components 1were the subject of
-NCR 89-8417, Revision 3, which stated, in part, that due
,
to a craf t: error, cable E0146318 had been. cut in JB1A11330
rather than at-the condulet as required in Revision 2 of.
this NCR.
The NRC inspector also examined.the SAFETEAM files
concerning this. issue including Corporate Security's
investigation which appeared to have been. thorough in thats
all persons involved. including the alleger, his foreman,
the general foreman, the -QC inspector. involved in
identifying and reporting this condition, and.a. fellow
worker who was assigned to this work activity were
interviewed.
As. stated in this report, the alleger's
assertion that he had been unfairly terminated for viola-
ting procedures in that he was following his foreman's
instructions was not supported.by the investigation.
Corporate Security's investigation concluded that this
individual was dismissed for negligence.
Although the termination of this individual appears
unnecessarily harsh, given that the technical dispositial
of NCR>89-8417, Revision 3, concluded that the cutting of
cable E0146318 at JB1A11330 had no impact on the disposi-
tion of the. subject NCR, the. statements from the indivi-
duals interviewed indicated that the alleger was instruct-
ed to cut the cable inside the condulet, and then pull
them from the junction box.
The NRC inspector also
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examined the findings of the Termination Review Committee:
,
which reviewed this case and affirmed the recommendation!
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for termination.on August 15, 1989.
'
Based on the above reviews, discussions with the
- applicant'sfSAFETEAM and Corporate Security personnel; and
related inspection activities, the NRC inspector deter-
mined thatLthe alleger had incorrectly cut safety-related
wires associated with the HVAC system at junction box:
JBilA11330 and that his assertion that he was only follow '
ing the. instructions of his foreman.could not be substan--
tiated.. However, given the minimal effect of this appar-
c
ent miscommunication between an electrical foreman and an.
electrician on the system work being performed, the.
termination action. appears to be extreme,
b.
(Closed) Allegation (OSP-89-A-69):
Directed procedure.
violations and.SAFETEAM: conflict of interest.
This.
allegation involved the circumventing of M&TE procedures-
at the direction of a group leader and the associated.
inability"to communicate-these concerns to SAFETEAM in;
that the group leader's spouse.was employed at SAFETEAM.
The NRC-inspector reviewed the M&TE facility, the-
governing procedures, and.in-process calibrations as part.-
of the closure process for.SDAR CP-88-35 (see para-
graph.3.e of-this report).
As noted in.~the closure of.
this item, minor weaknesses were noted in the.M&TE program'
but no additional. allegations or evidence of deliberate-
procedure violations were identified by the NRC inspector.
A review of SAFETEAM records 1 revealed no additional
concern specifically regarding the subject. group leader;
however,.a previous concern, No. 11630, did. involve the.
i
apparent. conflict of interest _resulting from the SAFETEAM
member /M&TE group leader relationship.
The NRC inspector
determined that the. applicant.had addressed;this potential-
conflict by implementation of policy constraints.which
,
specified that-the subject SAFETEAM member involved.would:
remove themselves from any concern related to the group:
leader or CPSES operations in general.
However,'the NRC.
inspector's invcutigation indicates that the current.
allegation supports the perception by plant personnel.that
1
there is a conflict which could. impede.the free flow of
1
information to-SAFETEAM.
In that the NRC inspector was-
unable to substantiate the procedural violation aspects of
'
this allegation, this item is considered closed.
No violations or deviations were identified.
5.
Electrical Components and Systems (51053, 51063, 52053)
During this reporting period, the NRC inspectors performed.
direct inspections of work performance to determine if the
technical requirements contained in the applicant's Final
.
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SafetyiAnalysis Report (FSAR) for safety-related electrical
systems and components.had been adequately translated into.
applicable: drawings, procedures, and. instructions.
Addition-
. ally,- the NRC inspectors evaluated the applicant's work control
program-to ' determine. if the specified documents and procedures:
.were of sufficient detail to provide adequate. work performance:
and. control.
As part of the inspection. requirements for IE Bulletin 85-03,
the NRC inspector observed. dynamic motor operated valve testing:
(MOVAT) of 1HV-2493A, auxiliary feedwater isolation valve. .The
valve performed properly on closing and opening against an
operating differential. pressure of approximately 1515 psig.
Review of the valve signature data revealed no discrepancies of
torques, motor current, etc.
I
The NRC inspector also observed work in progress for package.
ECE-89-01073, " Tag Maintained Space Cables During Train A
~
Outage.89-091."
The NRC inspector determined that this work.
~
was being performed in accordance with DCA 77139 and work order:
~C89-0013439 at the.480v motor control center MCC XEB1-2.
The
NRC inspector observed that the labels identifying " maintained
space" cables were being properly affixed where cables were not
'
already identified.. The NRC inspector's review of the package-
and work. process.didinot reveal any. discrepancies,and it was-
observed that a QC representative was present at-the job site
for the performance of specified witness points.
Within the. instrumentation. area, the NRC inspector observed the
installation of 1PT-3616 in accordance with work. package:
SWP-Z-5714.
This work also involved the implementation of-
DCAs 89836.and 84502 and work packages lLT-3615 A and B in
response to NRC Generic Letter 88-17 regarding reactor coolant
level' monitoring during mid-loop operations.
Additionally, the
NRC inspector _ observed installation.of conduit supports-
.
involving. conduit C14036219.
During the conduct of these
activities, no discrepancies were identified by the NRC
inspector.
No violations.or deviations were identified.
6.
Safety-Related Components, Mechanical (50071, 50073)
Reverse Flow Testing of Borg-Warner Check Valves
As a follow-up to the events which identified multiple failures
'
of Borg-Warner check valves in the auxiliary feedwater system,
previously documented in NRC Inspection Reports 50-445/89-30,
50-446/89-30; and 50-445/89-64, 50-445/89-64, the NRC inspector
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. witnessed the: reverse flow leak testing of the.following.
.Borg-Warner check valvest.
,
lAF-057.
3" pressure seal
Procedure EGT-328A.
lAF-083
4" pressure seal
Procedure EGT-328A
4" pressureiseal
Procedure EGT-328A
- 1AF-167
8" bolted bonnet:
Procedure EGT-165
'
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.The NRC inspector determined that the test personnel involved;
appeared knowledgeable and that they efficiently performed-the
l
. required evaluations.
All reverse flow tests witnessed had~
-
satisfactory results and no: discrepancies were-identified;
j
I
during either the; performance or the documentation phase.of
this program.
,,
The reverse flow testing.of.the 80 Unit 1 Borg-Warner. check-
valves is approximately 65% complete.
The NRC inspector;
,
previously reviewed the applicant's program and procedures form
i
testing the operability of Borg-Usxaer check valves and.
!
witnessed:two additional, tests as-documented in NRC Inspection:
l
I
Report.50-445/89-73; 50-446/89-73.
Due to differences in.
sister- configuration, the availability of drain and test
valves,.etc.,-diverse methods are employed to test the rubject:
i
' valves.
These methods include theLfollowing configuration:
options:
Test Method
No. of
System Valves
Demin Water Pressure Test
37
l
System pressure
9
Radiograph. Test
26
10 CFR 50, Appendix J, Local Leak Rate Test
6
Air Pressure Test
2
,
Total.
80
The NRC inspector has reviewed the film records from several
radiograph tests and determined that they were of good quality
and provided a definitive test methodology.
To date, four valves have required rework following their
initial: failure to pass the reverse flow leak test.
The root
_
cause and corrective action for these valves is summarized:
below:
Valve 1AF-0083;(valve body / bonnet) was rotatively misaligned
,
and the disc-stud was bent.
A new disc-stud assembly was
'
installed, the valve internals were reinstalled, and the
reverse flow leak testing was satisfactory.
Valve ICA-0016 exhibited excessive seat leakage.
The swing arm
"
and bushing were replaced and the valve was blue checked.
The
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. valve internals were reinstalled and the subsequent reverse.
flow leak testing-was satisfactory.
.
Valve 1AF-0057 exhibited . unacceptable valve body / bonnet:
rotational misalignment and incorrect bonnet elevation.
The
valve was disassembled and supplemental measurements'were-
taken, the. valve internals were reinstalled using the new-
height specification, and the valve was successfully testedrin
+
the reverse flow direction.
' Valve 1SW-0048 was determined to have an excessively long swing'
arm bushing.
The bushing length was reduced by 0.08" and
replaced in the disk-stud. assembly.
The valve internals were-
1
reinstalled and.the valve was successfully tested in the-
reverse flow direction.
In conjunction with-the above documented activities,.the.
l
applicant has revised the Borg-Warner check valve reassembly'
procedure and designed a specialized set of tools tx) allow for.
the establishment of more precise rotational alignment of then
bonnet to the valve body. .The NRC inspector witnessed a
t
demonstration of the new tools and technique in the mechanical.
maintenance shop and.the reassembly of valve 1AF-045 in the
plant.
The NRC inspector concluded. that the new procedure will
enhance the rotational. alignment between the valve bonnet and.
body.
L
During the latter portion of this reporting period,
approximately 13 Borg-Warner check valves in the auxiliary
'
feedwater and feedwater cystems were identified by the
applicant as having excessive body to bonnet external leakage.
These valves are presently being: disassembled,. honed to remove-
scratches in the valve body throat and-provide better sealing-
surfaces, reassembled, and leak tested.
NRC inspection of
,
these activities will be continued.:
'.
.
No violations or deviations were identified.
'
7.
Plant Tours (51063)
The NRC inspectors conducted routine plant tours during this
inspection period which included evaluation of work.in progress.
as well as completed work to' determine if activities involving
safety-related electrical systems and components including'
electrical cable were being controlled and accomplished.in.
accordance with regulatory requirements, industry standards,
and the applicant's procedures.
No violations or deviations were identified.
.
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8.
' 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 inspectors during this reporting period.
The applicant'did..
-
not-identify as proprietary any of the materials provided to or.
reviewed by the inspectors during this inspection.
During this.
meeting, the NRC inspectors summarized the scope and findings:
of the. inspection.
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