ML20147G767
| ML20147G767 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/02/1988 |
| From: | Livermore H NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20147G651 | List: |
| References | |
| 50-445-88-05, 50-445-88-5, 50-446-88-04, 50-446-88-4, NUDOCS 8803080311 | |
| Download: ML20147G767 (22) | |
See also: IR 05000445/1988005
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APPENDIX C
U.
S. NUCLEAR REGULATORY COMMISSION
OFFICE OF SPECIAL PROJECTS
NRC Inspection Report:
50-445/88-05
Permits: CPPR-126
50-446/88-04
CPPR-127
Dockets: 50-445
Category: A2
50-446
Construction Permit
Expiration Dates:
Unit 1: August 1,
1988
Unit 2: Extension request
submitted.
Applicant:
TU Electric
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas
75201
Facility Name:
Comanche Peak Steam Electric Station (CPSES),
Units 1 & 2
Inspection At:
Comanche Peak Site, Glen Rose, Texas
Inspection Conducted:
January 5 through February 2, 1988
Inspection conducted by NRC Consultants:
J. Dale - EG&G (paragraph 6.c)
K. Graham - Parameter (paragraphs 2.e, 4, 5, and 6.a)
P. Stanish - Parameter (paragraphs 2.a-d, 3, and 6.b)
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Reviewed by:
144(#7tM
$-2-- V
H. H.
Livermore, Lead Senior
Date
Inspector
8803000311 880302
ADOCK 05000445
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Inspection Summary:
Inspection Conducted: January 5 through February 2, 1988 (Report
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50-445/88-05; 50-446/88-04)
Areas Inspected: Unannounced, resident, safety inspection of
applicant actions on previous inspection findings; follow-up on
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violations / deviations; assessment of allegations; Comanche Peak
Response Team (CPRT) issue-specific action plan (ISAP) V.a; and the
corrective action program (CAP) for small bore piping and pipe
supports, conduit supports for A and B trains and C train greater
than 2 inches, and HVAC.
Results:
Within the areas inspected, the NRC inspectors identified
no significant strengths or weaknesses during this inspection.
One
violation failure to identify a minimum wall violation, paragraph
6.c) and one deviation (failure to trend a nonconformance report
(NCR), paragraph 2.0) was identified.
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DETAILS
1.
Persons Contacted
- J.
C. Aldridge, Engineering Assurance (EA), Stone & Webster
Engineering Corporation (SWEC)
- J.
L. Barker, Manager, EA, TU Electric
- D. P. Barry, Manager, ESG, SWEC
- M. R. Blevins, Manager, Technical Support, TU Electric
- J.
C. Finneran, CPE-PSE, TU Electric
- K.
M. Fitzgerald, HVAC Program Manager, Ebasco
- P.
E. Halstead, Manager, Quality Control (QC), TU Electric
- T.
L. Heatherly, EA Regulatory Compliance Engineer,
TU Electric
- C.
R. Hooten, CPE-Civil Engineering Unit Manager, TU Electric
- J. J. Kelley, Manager, Plant Operations, TU Electric
- 0. W. Lowe, Director of Engineering, TU Electric
- F. W. Madden, Mechanical Engineering Manager, TU Electric
- D.
M. McAfee, Manager, Quality Assurance (QA), TU Electric
- D.
E. Noss, QA Issue Interface Coordinator, TU Electric
- E.
Odar, Project Engineering Manager, Ebasco
- M.
D. Palmer, Plant Evaluation, Nuclear Operations,
TU Electric
- B.
L. Ramsey, Project Manager Civil / Structural, TU Electric
- D.
M. Reynerson, Director of Construction, TU Electric
- M.
J. Riggs, Plant Evaluation Manager, Operations, TU Electric
- A.
B. Scott, Vice President, Nuclear Operations, TU Electric
- C.
E. Scott, Manager, Startup, TU Electric
- J.
C. Smith, Plant Operations Staff, TU Electric
- M.
R. Steciman, CPRT, TU Electric
- P. B. Stevens, Manager, Electrical Engineering, TU Electric
- J. F.
Streeter, Director, QA, TU Electric
- C
L. Terry, Unit 1 Project Manager, TU Electric
- R.
D. Walker, Manager of Nuclear Licensing, TU Electric
The NRC consultants also talked to other applicant and
contractor employees during this inspection period.
- Denotes personnel present at the February 2, 1988, exit
meeting.
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2.
Applicant Action on Previous Inspection Findings (92701)
a.
(Closed) Open Item (445/8601-0-03):
This item involves
an apparent error on Drawings GHH-CC-1-SB-027,
Revision 6; GHH-CC-1-SB-040, Revision 12; and
2323-MI-0229, Revision CP-4.
The error concerned the
location of Valves ICC-137 and ICC-145.
The NRC
inspector, during an inspection of the Unit #1 Safeguards
building, noticed that the valves were reversed from the
locations on the piping isometrics.
Since the valves are
identical and will perform their intended function as
installed, the applicant committed to correct the
drawings.
In this inspection period, the NRC inspector
verified that Drawings MI-0229, Revision CP-5; and
BRP-CC-1-SB-027, Revision 6, now accurately depict
existing field conditions.
This item is now closed,
b.
(Open) Unresolved Item (446/8602-U-23):
This unresolved
item dealt with the fact that the stated program did not
appear to provide positive assurance that all required
grouting of conduit support base plates would be
accomplished.
In this inspection period, the NRC
inspector reviewed Brown and Root Procedure Number
CEI-25, Revision 7, which provides instructions for
grouting of base plates, equipment bases, and shear lugs.
This procedure in paragraph 1.2.1.1 states, in part,
determination of which base plates requito
" . . .
grouting shall be made by the .
. craft
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" and in paragraph 3.1.2 states, in part,
support
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epoxy grouting .
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bearing inspection report
Also, a note under
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this paragraph of the procedure appears to imply that an
operational traveler is acceptable in lieu of the QC
inspection report.
This procedure does not address
documentation for base plates which the craft determines
to have adequate bearing area and, therefore, do not
require grouting.
Also, reviewed was TUGCO Instruction
QI-QP-11.0-15, Revision 10, which states in
paragraph 2.2, ".
inspection identified in this
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instruction will be performed only on components that do
not require grout in accordance with References 1-A
and 1-B.
This is indicated by a "SAT" craft bearing
inspection report for that base plate / member .
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Reference 1-A is the general specification for concrete,
and Reference 1-B is Procedure C-25 which, as stated
above, does not specifically require a bearing inspection
report to be generated for a base plate that does not
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require grouting.
Therefore, this item will remain open
until positive assurance is demonstrated that the
inspection of all baseplates will be documented and
satisfactorily dispositioned.
c.
(Closed) Unresolved Item (445-8622-U-05):
This item
dealt with the validity of using an NIS-2 form (a form to
document an ASME Section XI repair / replacement) to
document an as-installed component as stated in the
disposition of NCR M-23175 N, Revision 1.
The NCR in
question was written to document an apparent lack of
traceability for a specific valve bonnet.
This NCR was
subsequently dispositioned based on revised documentation
from the vendor (ITT) which does provide traceability for
the part in question.
As for the generic use of an NIS-2
form as a stand-alone document for this type of problem,
TU Electric has stated in office me,morandum NE-16479 that
the only way to document nonconforming as-installed
components or conditions is through an NCR.
While an
NIS-2 form may have been used in the past as backup
documentation for an NCR, this practice has been
discontinued.
Furthermore, TU Electric indicated that
the NIS-2 form was never used as a stand-alone use-as-is
document.
This item is closed.
d.
(Closed) Open Item (445/8706-0-11; 446/8705-0-05):
This
item addressed the CPRT recommended changes to
Gibbs & Hill Specification 2323-MS-100 and Brown and Root
Procedure CP-CPM-6.9E concerning temporary supports,
specifically limiting or prohibiting the use of certain
materials for temporary supports and "less desirable
temporary support practices."
The NRC jnspector reviewed
Brown and Root Procedure CP-CPM-6.9E, Revision 10, "Pipe
Fabrication and Installation," TU Electric Construction
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Department Procedure CPS-101, Revision 0, and DCA 62786,
Revision 0.
Based on this review the NRC inspector is
satisfied that these items have been adequately addressed
by invoking the requirements of Specification MS-100 for
temporary supports, which through DCA 62786 specifically
prohibits the use of specific undesirable materials and
provides more definitive requirements for temporary
supports; therefore, this item is now closed,
e.
(Closed) Open Item (445/8716-0-11):
While the NRC
inspectors were interviewing craftsmen performing work on
Pipe Support DO-1-067-708-S53R and prior to the
inspector's review of the associated work package, a QC
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inspector arrived ~and reviewed the work package.
Upon~
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completion of.the QC review, work was stopped due to algc
hold point being bypassed on'a repair. process sheet by a
craftsmen.
NCR 87-A00491, Revision 1, was initiated. ~
This situation was documented as an open item pending
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' review of the-applicant's NCR disposition and. processing.
The NRC inspector contacted the TU Electric QA issue'
interface coordinator to evaluate the applicant's NCR
dispositioning and processing.
The subject NCR had been
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closed based upon rework of the weld repair. area. 1The
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NRC inspector verified, by review of training records
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dated August 14, 1987, that the responsible craft
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personnel had been reinstructed to the appropriate
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procedural requirements for weld documentation usage and
observance of hold points.
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The NRC inspector requested that TU Electric identify the
trend codes assigned to the Revision 1 disposition of
NCR 87-A00491.
TU Electric FSAR Section 17.1.15 requires
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trending of NCRs to identify trends adverse to quality.
NRC inspection revealed that_the NCR had'not been
assigned a trend code.
As a. result of the NRC finding,
the applicant performed a broadness review and issued
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Deficiency Report (DR) P-88-00595 which documented that
between July 11, 1987, and October 5, 1987,.2,024 NCRs
were issued per Project Procedure AAP 16.1 and were not
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trended.
The failure to assign a trend code prevents an
evaluation for adverse trends.
The failure to trend the
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subject NCR 87-A00491 for bypassing a QC hold point is
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considered a deviation from FSAR Section 17.1.15,
Amendment 65 dated November 20, 1987, which states that
procedures shall require trending of deficiencies
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reported on inspection reports, deficiency reports, and-
nonconformance reports in order to identify trends
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adverse to quality (445/8805-D-01).
3.
Follow-up on Violations / Deviations (92702)
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(closed) Deviation (445/8622-D-06):
This deviation dealt with
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the fact that valves supplied by Westinghouse under their
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Purchase Order 546-CCA-191000-XN were certified to the Summer
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1972 Addenda to the 1971 edition of Section III of the ASME
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Code; however, the FSAR in Table 3.2-1, Section 3,
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Amendment 56, requires that Class 2 and 3 valves meet the
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requirements of the 1974 edition of Section III of the ASME
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Code.
TU Electric in their response to this deviation stated
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that the deviation was caused by an error in the FSAR.
The
FSAR commitment failed to recognize that the Westinghouse
Contract No. Q202 invoked an earlier code edition and addenda.
Based on the above, DR C-87 1980 was generated to initiate a
change to the FSAR.
Review of the FSAR by the NRC inspector
revealed that the committed change was included in FSAR
Amendment 64. -Therefore, this deviation is closed.
4.
Assessment of Allegations (99014)
(Closed) Allegation (OSP-87-A-0103):
An allegation was
received by the NRC that contained five concerns relating to
These concerns have been assessed and
documented below.
Two of the concerns were substantiated
resulting in violations issued in a previous NRC inspection
report.
The other three concerns were not substantiated.
All
five concerns are considered to be closed.
Concern No. 1
QC personnel are not technically cognizant enough to identify
potentially nonconforming conditions which are outside the
scope of the inspection procedures.
Review
The NRC inspector interviewed the QC supervisor responsibic
for inspection of HVAC duct segments and seismic duct supports
in order to evaluate the responsibilities of QC personnel.
The QC supervisor stated that HVAC inspection personnel's
scope of responsibility is to identify problems with hardware
and documentation associated with the construction traveler
which has been presented to him for inspection.
Furthermore,
QC inspectors for HVAC, as a part of their training /cortifi-
cation program, have been instructed to identify and document
any nonconforming condition that they become aware of in
accordance with the requirements of project procedures.
Currently, a total of 76 certified QC inspectors are assigned
to inspection of HVAC CAP work activities.
NRC inspections of ISAP I.d.1, "QC Inspector Qualifications,"
have determined that the current QC inspector training /certi-
fication program meets the requirements of ANSI N45.2.6.
The NRC inspector selected the names of 10 of the 76 QC
inspectors who are certified to perform HVAC inspections, from
a list of all certified inspectors, and performed a review of
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each individual's training / certification file.
Evidence of
training and certification for the following procedures and
specifications was evaluated:
NQA-3.09-10.01, Requirements for Visual Weld Inspection
NQA-3.09-M-6.01, QC Inspection of Safety-related HVAC
Systems
NQI-3.09-M-006, verification / Inspection of Seismic HVAC
Systems
NEO 3.05, Reporting and Control of Nonconformances
NEO 3.06, Reporting and Control of Deficiencies
2323-MS-85, Appendix J, Ductwork and Miscellaneous
Details
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2323-MS-85, Appendix K, Quality control Inspection
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Requirements
Based upon a satisfactory review of training / certification
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records, the NRC inspector concluded that QC personnel should
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be technically cognizant enough to identify and document
nonconforming conditions within their scope of responsibility.
Conclusion
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QC inspectors have been trained to identify and document any
potentially nonconforming condition within their scope of
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responsibility.
The NRC inspector was unable to identify any
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requirement to document nonconforming conditions outside the
scope of the individuals responsibility.
However, project
nonconformance reporting procedures require any individual to
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document concerns about safe operation of the plant or
procedural inadequacios that they become aware of, on a
nonconformance or deviation report.
Based upon the NRC
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inspector's evaluation of procedural requirements,
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training /cortification records, scope of responsibility for QC
personnel, and lack of specifics, this concern could not be
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substantiated and is therefore closed.
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Concern No. 2
Due to conflicting requirements, it is possible that the
documentation packages for safety-related HVAC supports ...ay
incorrectly be designated as non-nuclear safety, thus, not
receiving the required level of inspection.
Review
The NRC inspector reviewed Comanche Peak Engineering
Specification 2323-MS-85, Appendix D,
"Classification
Summary-Ductwork, Louvers, and Accessories," Revision 5 dated
September 15, 1987, and noted that three seismic category
designations, Category I, Category II, and None, were listed.
Project HVAC engineers assign safety class designations based
upon the data contained in Appendix D.
The NRC inspector contacted the senior project engineer
responsible for implementation of the HVAC CAP and was
informed that all non-nuclear safety Seismic Category II
supports are inspected to the more stringent requirements of
Seismic Category I safety-related supports.
The seismic
category "None" is applicable only for nonsafety HVAC systems.
A copy of Ebasco Interoffice Correspondence HV-0409 dated
October 16, 1987, documents Ebasco's decision to inspect
non-nuclear safety supports to the more stringent requirement.
This memorandum was determined to provide adequate instruction
to personnel preparing documentation packages for inspection.
In addition to the above review, NRC inspectors have reviewed
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HVAC documentation packages while performing CAP inspections
and found that the required level of inspection was being
performed.
Reference NRC Inspection Reports 50-445/87-31,
50-446/87-23; and 50-445/87-35, 50-446/87-26.
The NRC inspector interviewed five working level engineering
personnel to determine their knowledge of establishing safety
class designation.
These personnel were cognizant of the
applicable requirements.
Conclusion
Based upon the review of the applicable engineering
specification and review of project correspondence, concern
Nc. 2 was not substantiated.
Furthermore, previous NRC
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inspections of the CAP concluded that the safety class
designation of documentation packages was correct for all
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items inspected.
This concern is closed.
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Concern No. 3
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Procedure CHV-106, Revision 1, has been marked up and used in
the field; however, no formal revision has been made.
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Review
The NRC inspector performed a review of TU Electric frocedure
CHV-106, "Qualitative Walkdown of HVAC Supports and ducts,"
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Revision 1, dated October 12, 1987, and noted that
paragraph 2B.2 of of Figure 7.6 contained wording which could
have created confusion as to what the intent of the
verification step was.
This concern was evaluated as a part of the NRC inspection of
the HVAC CAP. Duct segment documentation package B-1-658-016,
for which final field inspection by QC had been performed, was
reviewed and found to contain a copy of Figure 7.6 on which
the unclear wording had been resolved by a revision of the
form.
Revision of Figure 7.6 had been made outside the scope
of the project procedures which is a violation of Criterion V
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of Appendix B to 10 CFR Part 50.
NRC Inspection Report
50-445/87-35 documents this violation.
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Conclusion
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NRC inspection of the applicants HVAC CAP substantiated that
project engineering personnel were documenting the results of
engineering walkdowns on a form that had been revised without
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a formal revision in accordance with the procedures that
control use of the form.
Notice of Violation 445/8735-V-02
documents the NRC inspection finding.
This part of the
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allegation (Concern No. 3) is closed.
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Concern No. 4
There are inconsistencies identified in construction operation
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traveler instruction, e.g.:
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Status sheets state:
"Remove paint from all
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safety-related welds."
b.
Scope sheets state:
"Remove paint from all welds."
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c.
Construction Operation Travelers state:
"Remove coating
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from existing safety-related welds."
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Review
This concern was previously evaluated during NRC inspection of
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In Inspection Report 50-445/87-35,
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50-446/87-26, the NRC inspector performed field inspections
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and documentation reviews of four HVAC seismic duct support
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construction operation travelers (Cots) which were field
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complete by construction and for which final field QC
acceptance inspection had been performed.
The NRC. inspector
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noted that the alleged inconsistencies existed in the COTS
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reviewed, and it was unclear as to whether or not coatir:gs
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should be removed from nonsafety welds.
NRC inspection of
seismic duct hanger packages DH-1-844-1K-WP13, Revision 1, and
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DH-1-844-lK-1R, Revision 1, revealed that construction work
forces had removed galvanized coatings from both safety and
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nonsafety welding to allow for a qualitative visual inspection
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of welding by QC inspectors in accordance with HVAC CAP
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commitments.
The NRC inspector identified that five welds
located on Seismic Duct Hanger DH-).-844-1K-WP13 and portions
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of welds located on Seismic Duct Hanger DH-1-844-1K-1R did not
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have the galvanized coating required by Comanche Peak
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Engineering (CPE) Specification 2323-Ms-85.
Engineering
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personnel confirmed that all planned HVAC CAP inspections of
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these items were complete and that these bare spots had not
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been identified.
The applicant was cited for this previously
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(example 7 of 445/8735-V-02).
Conclusion
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NRC inspection of the applicants HVAC CAP substantiated that
inconsistencies in instruction for removal of paint do exist.
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These inconsistencies created confusion as to what
construction work requirements were and what QC personnel were
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required to inspect during final acceptance inspection.
As a
result, galvanized coating was not reapplied to several welds.
This was documented as an example of a violation in NRC
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Inspection Report 50-445/87-35.
This part of the allegation
(Concern No. 4) is closed.
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Concern No. 5
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The information/ question request form may be incorrectly used
in lieu of NCRs for documenting nonconforming conditions,
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NRC evaluation of Concern No. 5 revealed that the information
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and question request form is an informkl document provided to
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HVAC engineering personnel as a result of an interoffice
correspondence, HV-C0042, dated October 12, 1987.
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correspondence documents that the form is to be used to
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document procedural questions asked and answers given.
The
respective lead and/or supervisor answers the question and
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returns a copy of the form to the individual asking the
question.
A note on the bottom of the form states, "This form
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is to be used only for requesting clarification of procedural
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intent."
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The NRC inspector interviewed Ebusco engineering personnel
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responsible for the implementation of the HVAC CAP
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requirements and discussed the use of the information and
question request-form.
These individuals were aware of the
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requirement to document nonconforming conditions on an NCR
form.
The NRC inspector reviewed a log book documenting these
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requests for clarification and performed a detailed review of
nine forms which had been completed.
The NRC review
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determined that these forms were being used to ask questions
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about the intent of procedures and were not being used to
document nonconferming conditions.
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Conclusion
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The NRC inspector was unable to substantiate Concern No. S
based upon a review of the usage of the forms by project
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personnel.
The NRC review determined that the information and
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question request form was being used in accordance with the
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intent of Interoffice Correspondence NV-C0042.
This item is
closed,
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5.
CPRT ISAPs
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Inspection for Certain Types of Skewed Welds in NF Supports
(ISAP No. V.a) (57050)
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Third Party to Evaluate the Physical Significance of any
Procedural Changes (NRC Reference OS.a.02.04)
The third party determined that historical revisions to
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inspection procedures for Type-2 skewed welds, QI-QAP 11.1-28
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and QI-QAP 11.1-26, had no physical significance and did not
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impact any previous QC inspection result, with the exception
of those documented by TU Electric Design Deficiency Report
(TDDR) PS-86-1973.
This TDDR describes an error in the scribe
line inspection technique which requires corrective action by
the project and will be overviewed by CPRT in accordance with
Appendix H of the CPRT program plan.
The NRC inspector agrees
with the CPRT conclusions reached during the CPRT review of
procedural changes.
This item is closed.
Determine the Need for Additional Inspection (NRC Reference
05.a.03.05)
The NRC inspector reviewed the results of all inspections and
reviews performed by the third parties that were contained in
the ISAP working file and identified the need to perform a
more extensive evaluation of the need for additional
inspections.
A formal request for additional information (NRC
letter dated September 16, 1987, Grimes to Counsil) was
submitted to the applicant.
The applicant responded
(TV Electric Letter TXX-6858 dated December 30, 1987) with an
additional evaluation of inspection results and design
requirements.
The NRC inspectors review of the additional
information concluded that additional inspection of the Type-2
skewed weld population is not required since design
requirements were met or exceeded for all population items
which were inspected.
This item is closed.
Identify Corrective Actions Required (NRC Reference
05.a.05.03)
The reinspections and documentation reviews performed under
this action plan provided reasonabic assurance that the Type-2
skewed welds located on pipe supports are within the ASME
allowable stress levels.
A third-party evaluation of design
margin based on the measured weld size indicates that the
Type-2 skewed welds in the plant will not exceed ASME limits.
The NRC inspector has reviewed the ISAP working file and
concurs with the third-party conclusion.
The project is
developing a corrective action plan to resolve TDDR-PS1973, an
error in the scribe line inspection technique, which will be
overviewed by the third party in accordance with Appendix H of
the CPRT program plan.
This item is closed.
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Third Party Will Oversee and Verify the Review Program (NRC
Reference 05.a.06.00)
The NRC inspector has reviewed documentation of third party
activities contained in the ISAP working file.
For those
activities performed by the project during tmplementation of
the ISAP (i.e., Historical Chronology of Inspection Procedures
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for Skewed Welds, Sample Selection Criteria, Evaluation of
Inspection Results, etc.), independent third parties (TERA
Corporation and Jack Benjamin and Associates) verified
accuracy and completeness.
Project personnel associated with
implementation of procedural requirements were interviewed by
the NRC inspector and design calculations were verified.
The
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third party issued two discrepancy / issue resolution reports
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(DIRs), D-0130 and D-0133, to document discrepancies in
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project calculations related to the evaluation of twelve
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random sample selections in regard to undersize welds.
These
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by the project based on those calculations were correct.
All
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third-party conclusions are complete and the NRC inspector
considers third-party oversight of project actions to have
been effective in identifying any significant errors.
This
item is closed.
6.
Corrective Action Program (CAP)
a.
Small Bore Piping and Pipe Supports (50090)
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EU Electric has prepared a project status report (PSR)
for small bore piping and pipe supports.
TU Electric
Letter TXX-6846 dated November 2, 1987, formally
submitted this information to the NRC.
The purpose of the project status report is to
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demonstrate that the safety-related small bore piping and
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pipe supports in Unit 1 and Common (portions shared by
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both units) are in conformance with the CPSES licensing
commitments, satisfy the design criteria, and will
satisfactorily perform their safety-related functions.
The small bore piping and pipe supports PSR represents a
road map of the validation effort from the early stages
of design criteria development through the establishment
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and implementation of the detailed design and design
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control procedures.
The report traces the updating of
design / installation specifications, construction and QC
procedures, the implementation of the post-construction
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hardware validation program.(PCHVP)'to validate the
as-built piping and pipe support design, and the
completion of the Unit 1 and Common small bore pipe
stress analysis packages and pipe support calculations.
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The NRC inspector performed a review of the PSR and
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developed an NRC inspection plan to evaluate the CAP for
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small bore piping and supports.
The NRC inspection plan
when implemented is intended to accomplish the following:
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(1)
Determine whether technical requirements have been
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adequately addressed in PCHVP CAP specifications and
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work procedures.
(2)
Detennine through direct observation and independant
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evaluation of work, whether the applicant's work
control system is functioning properly and whether
the installation of safety-related pipe supports and
restraints are in compliance with NRC requirements,
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applicant commitments, and applicable codes.
(3)
Provide assurance that the field installation of
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pipe support hardware is sorrect and will function
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in a manner that will allow safe operation of the
associated plant system.
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This inspection plan will be implemented and reported in
subsequent inspection reports,
b.
Conduit Supports A & B Train and C Train > 2" (48053)
During this inspection period, the NRC inspector selected
a sample of 13 conduit walkdown packages to verify the
accuracy and correctness of the Ebasco collected data.
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The following is a list of the NRC inspected packages:
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TU Electric
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Conduit
Site
Room
- Area
- Supports
C13G10289
1"
174
AUX
-9
CO2G11960
2"
174
AUX
10
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C13G05377
2"
77S
SG1
9
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C13G08392
1 1/2"
100A
-SG1
9
C12G19660
1 1/2"
85D
SG1
14
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C12K12472
3"
95
SG1
6
C13K30712
2"
94
SG1
7
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C13010207
2"
94
SG1
7
C14KCJ106
3"
94/100A
SG1
6
C14020426
3/4"
77S
SG1
10
C15Y15296
1"
133
ECB
3
C13016494
3/4"
155A
art
5
C12008110 1 1/2" ~154/155A
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- SG1 - Unit 1 Safeguards Bu
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- AUX - Auxiliary Building
- ECB - Electrical / Control Building
- RB1 - Unit 1 Reactor Building
- Number of supports includos conduit, junction i a and
pull box supports.
The NRC inspector's walkdowns were performed while
adhering to the criteria of Field Verification Method
(TVM) CPE-EB-TVM-CS-033, Revision 2, and resulted in the
identification of the following discrepancies:
(1)
on Conduit Support C13G10289-05,-the walkdown
engineer reported the location of one of the four
anchor bolts used to attach the support base plate
to the wall, incorrectly.
The location, for the
bolt designated by the letter "A" on the detail
drawing was reported as 1 1/2" up from the bottom
edge of the base plate and 2 1/16" right of the left
edge of the base plate.
The NRC inspector measured
the location to be 2 1/2" up from the bottom edge
and 1 1/2" right of the left edge.
(2)
on Drawing 2323-s-0910 SH.05377 SK01 which is the
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isometric drawn to depict the Conduit Run C13G05377,
the walkdown engineer reported a dimension of
4' 7 3/8" for the "saddle" type section of the
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vertical run.
The NRC inspector measured this
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section of conduit at 3' 3 1/2".
The tolerance for
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this type of measurement is plus or minus
3".
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(3) 'For Conduit Support C13G05377-08, the letter stamp
on one of;the Hilti Kwik bolts (HKB) was' reported,
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by the walkdown engineer, to be'the letter
"E".
The
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NRC. inspector, during his walkdown of this support,
found that the. letter stamp was actually an
"H".
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SinceL he letter stamp on the-HKB designates the
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length of.the bolt, the error outlined above.would
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effect the embedment length and allowable loads used
in the evaluation of the support.
(4)
On' Conduit Support Cl3G05377-01, the walkdown
engineer reported the length of the support base
plate to be 8 11/16".
The NRC inspector measured
this dimension ~at 9 3/4".
Also, on this support the
thickness of the shim plate between the conduit and
the support bracket was reported by the walkdown
engineer as two different thicknesses, in the body
of the sketch it is reported as 3/8" and in the
tabulated data it is reported as 1/4".
The NRC
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inspector found the shim to be 1/4" thick.
(5)
on Conduit Support C13G08392-01, the walkdown
engineer failed to note that there was a violation
of the minimum spacing requirement for HKB.
The NRC
inspector, during his walkdown of this support,
found two 1/2" .9KB that were 4 1/4" apart; the FVM
calls for a minimum spacing of
5".
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(6)
on Conduit Support C02G11960-03, the location of the
HKB, designated as Bolt "E" on the detail drawing,
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was reported by the walkdown engineer as being 2
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3/4" from the edge of the unistrut member.
During
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the NRC inspector's walkdown, this dimension was
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measured at 2 3/8".
Errors such as the six examples cited above while not
individually significant could have a cumulative effect
which could cause the calculation of incorrect stress
levels in the structural members (i.e., baseplates and
unistruts) and, also, incorrect anchor bolt loading and
load interactions.
The above findings (six examples) are similar to other
examples cited in NRC Inspection Reports 50-445/87-31,
50-446/87-23; and 50-445/87-35; 50-446/87-26.
Since the
current six examples occurred in the time period of the
other examples (before corrective actions for the
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previous _ citations were, implemented), a violation will
not be issued.
These examples have been discussed with
Ebasco who has generated DRs to resolve them.
Also,-the-
above findings were detected during the NRC inspector's
walkdown of 13. conduit walkdown packages.
In each
walkdown package there are in excess of 200 attributes
that require inspection / documentation; therefore, the
examples cited. represent errors of less than 1% of the
total. required inspection points.
In regard to the remaining conduit runs, the results of
the NRC walkdown revealed certain data that did not match
that recorded by Ebasco; however, it was determined to be
acceptable since the difference in the recorded
dimensions was still within the tolerances specified in
the applicable FVM.
This is not considered to be a
problem.
On January 28, 1988, meetings were held between
representatives of the NRC, TU Electric, Ebasco, and
Impell to discuss the discrepancies identified as
deviations and violations in recent NRC inspection
reports:
50-445/87-18, 50-446/87-14; 50-445/87-25,
50-446/87-19; 50-445/87-31, 50-446/87-23; and
50-445/87-35, 50-446/87-26.
Both Ebasco and Impell
offered the results of their analysis of discrepancies
found during reinspection of a significant amount of work
previously performed.
Their analysis revealed similar
discrepancy rates with Ebasco reporting 1.8% and Impell
reporting 1.9% which is slightly higher than NRC
findings.
These discrepancy rates were present:ed by both
companies as rates similar or less than those found
throughtout the industry for similar activities.
Impell
took their analysis one step further; they factored the
discrepancies into their design verification calculations
and found that none of the discrepancies caused the
calculated stress to exceed 75% of the allowable.
This
indicates that none of these discrepancies were
significant to the design of either the conduit or the
conduit supports; therefore, there is no adverse impact
on safety.
Also, in performing these reviews, both
Ebasco and Impell determined that certain procedural
changes affecting how attributes are to be evaluated
would reduce the possibility of future discrepancies;
therefore, they have made these changes.
In addition,
both Impell and Ebasco discussed the NRC findings with
their walkdown engineers, reviewed procedures, regularly
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TU Electric
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do independent checks of their walkdown engineers work,
and held training sessions.
TU Electric reported that
the error rates reported were consistent with the error
rate for the Corrective Action Program of a Region III
utility which was calculated to be 1.9%.
Results
Based on NRC inspection and review of the applicant's
walkdown of conduit supports for Trains A.and B and
Train C greater-than 2" diameter and due to the numerical
error rate and the fact.that the findingsLwere not safety
significant, it appears.that the applicant's program in
this area is providing adequate input data for the design
verification phase of the corrective action program.
c.
Heating Ventilating and Air-Conditioning (HVAC) (50100)
NRC inspectors performed field inspections and
documentation reviews of the following documentation
packages.
These packages were generated as a result of
construction, engineering, and inspection activities
related to HVAC CAP implementation.
Seismic Duct Hanger
Unit
Room
DH-1-844-lK-4E
1
99B
Seismic Duct Segment
Unit
Room
B-1-658-015
1
99B
NRC inspection of HVAC Duct Support DH-1-844-lK-4E,
Revision 1, identified a fillet weld as a 3/16" by 3 5/8"
(i.e., Weld 4 nearside documented in the construction
traveler).
CPE-EB-FVM-CS-029, Revision 5, requires that
welding "
. shall be identified for type of weld
. .
. weld length, and weld size."
The NRC inspector
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identified that this weld had been incorrectly documented
by walkdown engineering personnel as a 1/4" fillet weld
and the same had been accepted by QC.
This is another
example of a discrepancy missed by a walkdown engineer.
It is not being cited as a violation for the reasons
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given in paragraph 6.b.
The NRC inspection of RVAC Duct F;gment B-1-658-015
identified a depression which tppeared to have been
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caused by grinding.
This depression exceeded 1/32" in
depth-(a minimum wall violation).
project Specification
2323-MS-85, Revision 5,Section I.6.C, states, in part,
"Depressions produced by grinding-will not exceed the
following: Sheet metal: 1/32"~for 18 gauge sheet metal
An ultrasonic digital thickness
and thicker .
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report indicated that the section of duct with'the
grinding depression was fabricated with 16 gauge sheet
metal which is thicker than 18 gauge metal.
The NRC
inspector could find no indication of an engineering
evaluation or QC identification of this minimum wall
violation.
The preceding example is a violation of Criterion V
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(445/8805-V-02).
NRC inspection of Seismic Duct Segment B-1-658-015
revealed that construction had removed the protective
coating for QC inspection and subsequently the coating
had not been reapplied.
The NRC inspector identified an
additional 10 examples where the protective coating had
not been reapplied.
See paragraph 3, Concern No. 4'in
NRC Inspection Report 50-445/87-35; 50-446/87-26 and
Example 7 of 445/8735-V-02.
NRC inspection of Duct
segment B-1-658-015 also revealed several areas on the
hem flange between segment B-1-658-015 and segment
B-1-658-014 where the gasket material, Tremco 440, had
been squeezed out from between the flange.
This
condition was identified by Ebasco on CAR 87-079 and
subsequently Stop Work order No. 88-02.
This problem was
also previously identified in an NRC inspection and is
being tracked as open item 445/8735-0-04.
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The NRC inspector has identified an increased awareness
by TU Electric and Ebasco management to problems
identified in HVAC and feels that this will help improve
the work efforts in this area.
7.
Exit Interview (30703)
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On January 29, 1988, R.
F. Warnick, H. H. Livermore and
J.
S. Wiebe met with L.
D.
Nace and A. B. Scott to
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discuss January inspection findings and other matters of
interest.
(See NRC Inspection Report 50-445/88-06,
paragraph 5.)
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An exit interview was conducted February 2, 1988, 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 interview, the NRC
inspectors summarized the scope and findings of the-
inspection.
The applicant acknowledged the finding.
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50-445/89-055 50-446/89-0 9
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DISTRIBUTION:
NE5tSIU52$I50IAIO44ih
NRC PDR
Local PDR-
OSP Reading-
CPPD-LA.
CPPD Reading (HQ)
- Site Reading File-
AD for Projects
.
- Sr. Lead Insp. - CONST.
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- Concurrence
- MIS System, RIV
- RSTS Operator, RIV
DRP, RIV
RIV Docket File
- LShea,-ARM /LFMB
JTaylor
SEbneter/JAxelrad
'
CGrimes
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PMcKee
JLyons
.
JWilson
JMoore, OGC
JGilliland, RIV
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FMiraglia
EJordan
JPartlow
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BHayes
- w/766
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