ML20148U302

Forwards Response to Open Items 445/8704-0-12 & 445/8704-0-25 Noted in Insp Repts 50-445/87-04 & 50-446/87-04,per 871218 Commitment & Suppls Info on Open Items 445/8704-0-05,-07,-16,-19 & 24(c)

ML20148U302
Person / Time
Site:	Comanche Peak
Issue date:	01/29/1988
From:	Counsil W, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-88163, NUDOCS 8802030522
Download: ML20148U302 (12)

Text

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.N.mm-P ~--l Log # TXX-88163

-_ .-- Fi1e # 10130

= r IR 87-04 IR 87-04 7UELECTRIC Ref. # 10CFR2.201 I$$SN,U.

l January 29, 1988 U. S. Nuclear Regulatory Comission 1

Attn: Document Control Desk Washington, D. C. 20555 i

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT N05.

50-445/87-04 AND 50-446/87-04

REFERENCE:

TV Electric Letter TXX-6767 from W. G. Counsil to NRC dated December 18, 1987 Gentlemen:

The referenced letter stated that response to Open Items 445/8704-0-12 and 445/8704-0-25 would be provided by January 29, 1988. Accordingly, Attachment 1 to this letter contains these responses.

Additionally, the NRC and TV Electric met January 20, 1988, to discuss several of the responses included in the referenced letter. The meeting concluded with an NRC request for supplemental information on Open Items 445/8704-0-05, 445/8704-0-07, 445/8704-0-16, and 445/8704-0-19. Attachment 2 to this letter supplies that supplemental information.

Our response to Open item 445/8704-0-24(c) stated that the Design Validation Program is serforming a 100% review of safety-related design documents. This statement s1ould read: "The Design Validation Program is validating 100% of the safety-related portions of the CPSES design, with the exception of NSSS bardware (NSSS interf ace is reviewed) and equipment supplier design (design interface is reviewed)."

The referenced letter also addressed two safety-significant evaluation (SSE) review programs performed in 1987. After reviewing the information supplied with this letter, we would like to of fer additional clarificatinn concerning these programs:

The first program, "SSE Continuing Review Program," was performed to (1) provide assurance that the SSEs accurately analyzed the deviating plant conditions and identified construction deficiencies or input to results reports for trend analysis and (2) ensure that the SSEs conformed to the Safety Significance Evaluation Group procedural requirements, such as problem description, completeness, and justification of conclusions, em,w,,, s,,,,, i a n u n. raw n.w $g,ol p%s smjip Ij<

TXX-88163 January 29, 1988 Page 2 This program developed a screening process to determine the SSEs subject to a detailed review. The objective of the screen was to focus the review on those SSEs that could have led to the failure to identify all construction deficiencies or adverse trends. The second program, "VII.c Technical Review,"

was conducted to ensure that the trend analysis process of the Vi!.c program, as implemented, did not fall to identify any adverse or unclassified trends.

To accomplish this task, a technical review of the SSEs, as well as the trend analysis of VII.c, was performed. The Technical Review Pro SSEs and associated calculations, with the exception of (1) gram SSEs forincluded all deviations that are already covered under CPRT recommendations for corrective action (2) deviations that by their nature cannot be safety-significant, and (3) documentation review deviations.

These two review programs resulted in a recommendation that a number of SSEs 4 be revised, primarily fer clarification or completeness. These revisions were completed by December 17, 1987.

.l Very truly yours, i

u).6. O .

W. G. Counsil 6

By:

D. R. Woodlan Supervisor, Docket Licensing ROD /mlh Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) l

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Attachment 1 to TXX-88163

. January 29, 1988

. Page 1 of 3 OPEN ITEM (445/8704-0-12)

, I-M-HVIN-160-0R01 f A OR was written on gravity damper CP1-VADPGC-19 because the counterweight was ,

not installed and the counterweight arm had been secured in the open position with duct tape to an adjacent unistrut. The assessment of the SSE was that the intended function of the dam)er to provide a positive means of stopping backflow was redundant because tie hydraulic parameters of the system always provide for forward flow through the damper. Consequently, the SSE concluded that this damper did not perform a safety related function. However, the CPRT ,

procedure for safety significance evaluations of ors, Procedure CPP-015,  !

specifies that, in assessing safety significance, no credit can be allowed for redundancy. Secondly, the damper provida:d the sole positive means to prevent backflow. The backflow in the case of this damper could involve contaminated air from the post accident sampling modules and possible exposure to personnel in the area who would be conducting the air sample testing.

Therefore, the NRC inspector disagreed with this SSE; this is an open item (445/8704-0-12).

RESPONSE TO 3 (44578704T12)

This gravity damper is located in a system that is safety-related because it handles potentially contaminated effluent from the sample area. To this extent, the damper is also safety-related in that the damper forms a system boundary.

The gravity damper was installed as a positive means of preventing backflow l instead of performing the extensive calculations necessary to determine the l flow characteristics of the duct system. The function of the gravity damper i (i.e., to prevent backflow into the sample room) is not safety-significant as defined by the CPRT Program Plan because a calculation in the SSE demonsW ates that under no design operating conditions does backflow into the sample room .

occur.

f j for this reason, the SSEG determined that this OR is not safety significant.

l Procedure CPP-016 does not allow credit in determination of safety [

1 significance "for redundancy at the component, system, train or structure l level." This restriction is referring to redundancy of the inspected item, which in this case would be another gravity damper. The SSE does not take l credit for another gravity damper; consequently, the SSE i< in compliance with '

! procedure.

The SSE takes credit for the "designed" operation of the PPVS by use of l i redundant components. This does not preclude the SSE from taking credit for l operation of the PPVS; this is not the redundancy to which the CPP-016 .

j definition of "safety-significant" refers.

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Attachment 1 to TXX-88163 ,

January 29, 1988 '

Page 2 of 3 ,

RESPONSE TO  !

(445/8164-0-12) (Cont'd)

Please note that, as stated in the res)onse to 11, final air balancing and  ;

preoperational testing of this system lad not been completed before the CPRT ,

reinspection was conducted. Included in the air balancing procedure is a specific check for gravity damper adjustment that requires verification of (

proper damper operation. Although the damper is not required for proper l operation of the system, its function would have been assured by final air i balancing of the system.

The CPRT inspected all other gravity dampers that were QC-accepted; therefore,  ;

t all deficiencies would have been found. Additionally, the CPRT made a '

l recommendation for improvement (not mandatory) that the CPSES Project j i accepted, calling for reinspection of all gravity dampers. Thus, any other existing deficiencies will be located and corrected before the system is

accepted.

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l Attachment 1 to TXX-88163 ,

. January 29, 1988 1

. Page 3 of 3 i

OPEN ITEM i (44578704 0 25) l l

I-S-EQSP-045-DR04 l l

The OR was written because the torque for the bolts that attach the equipment  !

junction box, 1-LCS-5803, to the unistrut support structure was found to be l 100 in-lbs instead ot'the 228 in-Ibs required. The SSE indicated that the  !

required torque was not achieved because the mounting lugs on the junction box began to bend at 100 in-1bs of torque. The evaluation went on to demonstrate that the existing torque was adecuate to su) port the junction box and to note that a field inspection confirmec that, altlough the lugs were bent slightly, neither the lug welds nor junction box were damaged or cracked. The evaluation concluded the deviation was NSSD. Although the NRC inspector agreed with the SSEG assessment of this specific deviation. the evaluation does raise questions as to: (1) the possibility of damage to the lug welds and/or component in this and other similar ecuipment where the required installation torque of 228 in-Ibs was appliec, and (2) a need for washers on all slotted hole connections of this type to ensure the proper bearing surface between the bolt head and lug. The evaluation did discuss the 16tter issue but no definitive action was specified. 1his is an open item pending recei of information which appropriately addresses these concerns (445/8704 0-25)pt .

RESPONSE TO (4'E/8704-0-25)

1. Damage to the lug welds and/or components in this and other similar equipment would be minimized if shims were installed as required by the existing installation details. While the acceptability of bolted joints nas being evaluated, a determination was made that gaps between the connecting plies and torquing required corrective action. This corrective action stemmed from similar findings in the structural steel and pipe whip restraint populations and was extended to equipment supports due to the similarity of the work processes involved in ensuring an acceptable installation. As this correct.ive action would cover all types of installations similar to the one in question, no further action is required to address this concern.

2. An analysis has been performed for worst case loading of this type of equipment box to determine if the absence of flat washerr, on the slotted holes would adversely affect the seismic qualification. The calculation qualifies the same for use at CPSES.

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Attachment 2 to TXX-88163

. January 29, 1988 Page 1 of 7 OPEN ITEM (445767 DUO 05)

I 1-E-CABL-383-OR01 The minimum bend radius viole. tion for a cable (EQ128190) installed between the ,

Nuclear Instrumentation System cabinet and tha Solid State Protective System t cabinet was evaluated in the SSE. The evaluation concluded, based on the proper operation of the cable to date, and an onsite test, that the cable '

installation was not safety significant and would not result in the inability of the cable to perfom its safety-related function. The NRC inspector noted, however, that a letter from the vendor, Westinghouse Electric Corporation, l dated October 14, 1986, stated that approval of the installed bend raolus could not be granted.

The NRC inspector discussed this SSE with ERC and CPRi personnel and was informed that additional information was being requested frcm the vendor; however, as of the end of this report period, additional information had not been provided. The NRC inspector could nt agree with the NSSO detemination on the basis of the available infomation. The NS50 determination for this condition is an open item (445/8704-0-05).

I RESPONSE TO (445/8704-0-05) l The subject cable is a 16-twisted-pair (32-condector,1 No. 18 AWG cable with an overall shield and jacket. The purpose of the outcr Teflon jacket is additional mechanical protection for the insulated ccaductors. This cable is l l used insida cabinets located in the control rcom.  ;

! The cable vendor disapproved this installation m,d indicated that the Teflon  :

j jacket on the cable may be damaged by the small bend radius. Therefore, i

< damage to the Teflon jacket my atfect the qualitication or tN cable.

1 However, the protective functlpn of the Teflon jacket is not necessary in this  !

i applicatiots because the cal) is located within an enclosed caH net in the control roont. The jacket is presently tri ped to a point approximately 18" from the bend in question to allow for tem', nation cf individual conductors,  !

but the tennnation procedure aliows for trimming the jacket all the way bMt to the cabintet entrance, if nrcessary. There' ore, completo removal of.the ,

l Jacket bey %d the location of the bend is acce.rmble, and any damage to the '

jacket retuiting iron the smaller bend radius would also be acceptable and weJld not af fect operation of the individual conductors. As the individual conductors are not adversely affected by a bend radius of 2-9/16 inches (the radius of the bend in question), the conclu'.lon of 'not saf ety-significant" is i

justified. .

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Attachment 2 to TXX-88163

, January 29, 1988 Page 2 of 7  ;

SUPPLEMENTAL RESPONSE TO (4457B76G635)

The trend analysis performed in the ISAP Vll.c Results Report, Ap)endix 3 identified an unclassified trend concerning cable bend radius. T1e likelihood of a construction deficiency existing in the uninspected portion of the cable population due to similar deviations could not be determined because of the different cable types used in the plant and corresponding different bend radius requirements. Consequently, a CPRT recommendation for corrective action was made to the Project to reinspect installation of those types of  ;

cable that did not have bend radius requirements in the installation )

instructions, and replace cables that do not meet appropriate bend radius criteria.

The Project has committed in Corrective Action Request (CAR)87-035 to replace the deviant cable reported in CPRT deviation report I-E-CABL-383-DR1, reinspect to appropriate bend radius criteria all cable types field installed without appropriate bend radius installation instructions, and correct as necessary. These actions will ensure that the cable is installed in accordance with technical requirements for bend radius.

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Attachment 2 to TXX-88163

. January 29, 1988 Page 3 of 7 OPEN ITEM (445787650~07) 1-E-EEIN-097-DR08 in June 1986, an incorrect Westinghouse AC relay (Model AR 440 SR) was found installed in a panel where a DC relay (Model ARD 440 SR) was required. The SSE and its supporting data suggested that the correct relay type has been present in the panel prior to November 1984. ERC was unable to locate any maintenance or test records to support a relay substitution at the plant site.

1 An extensive analysis was provided in the SSE to confirm that an AC relay >

1 would operate for a brief period af time in the DC circuit. The NRC inspector

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was advised that a 100 percent reinspection was recomended for all auxiliary +

relay panels provided by YEP Industries, Inc. This recomended action was based on the premise that an error had been made by the vendor prior to panel 1 shipment in 1982 and had not been detected by QA/0C inspections, initial l operation of the panel relays, or periodic surveillance tests. This is an open item pending receipt of justification for limiting this reinspection activity to the single vendor (445/8704-0-07).

i RESPONSE T0 (4E7876T6 D/l Recomendations for corrective action are not in the scope of the SSE; they  ;

are found in the ISAP VII.c Results Report. Details of the recomended .

corrective action are found in Appendix 6 of the report for this item. These L recomendations, in sumary form, consisted of reinspection for configuration and evaluating and revising (as necessary) the design control and configuration control programs. TV Electric has determined that the reinspection will be limited to this particular vendor, as justified in CAR l 87-036. The CPRT has reviewed the CAR and agrees that this corre:ctive action is appropriate.

SUPPL.EHENTAl. RESPONSE TO '

4 (4457B76T-FD7) i

The justification provided in Project Corrective Action Recuer.t (CAR)87-036,

, to limit the corrective action to a single vendor, is basec on an in depth

review that determined the root cause to be a vendor related problem and therefore, related only to equipment furnished by this one vendor. ,

Implementation of ISAP Vll.a.9, Adequacy of Purchased Safety-Related Haterial i i

and Equipment, includes reinspection of electrical equipment supplied by l' l several other vendors. These reinspections, which include verification oi installation of proper devices, will provide data for additional vendors. .

l Results of these reinspections, and additional recomendations, if necessary, {

l will be included in the ! SAP Vll.a 9 Results Report. Pesulte from ISAP V11.c i

! concerning installation of prernr 4. ices will be evaluatM m wniunction i with the ISAP VII.a.9 results to determine if additional uniutive action is t required, i I

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Attachment 2 to TXX-88163 January 29, 1988 Page 4 of 7 OPEN ITEM (44578764 T 16)

Cement Grout (GRTC)

R-S-GRTC-GEN-DR01 R-S-GRTC-003-DR01 1-5-GRIC-010-Cl R-S-GRTC-010-DR01 R-S-GRTC-035-DR04 R-S-GRTC-039-DR01 R-S-GRTC-039-SR03 R-5-GRTC-039-DR05 R-S-GRTC-058-DR02 R-S-GRTC-059-OR02 DRs were written because some attributes on cement grout irs were left blank; i.e., not checked "SAT" or "UNSAT". The QC inspectors had, however, signed and dated the irs and had checked "Inspection completed, all applic6ble items satisfactory." 1he Safety Significance Evaluation Group (SSEG) concluded that the missing check marks were inadvertent oversights. Since the irs were signed and the inspection procedure identified, the SSEG judged that the )

grouting work was performed in accordance with project requirements, and the missing check marks v.ere not safety significant.

The NRC inspector discussed this situation with a past concrete grout QC inspector who stated that the signature present on the irs described above does not override the need for each attribute to be checked. The NRC inspector concluded that the above condition is indeterminate as the original QC inspector may have failed to inspect for the attributes that were not checked.

The following ors address attributes on the irs that were left blank:

R-5-GRTC-035-DR04 All attributes regarding curing were left blank.

R-S-GRTC-039-DR01 The attribute verifying that the area to be grouted was vibration free was left blank.

R-5-GRTC-039-DR05 The attribute verifying that the grout was placed continuously and properly consolidated was left blank.

This subject is an open item pending NRC inspector review of additional information (445/8704-0-16).

RESPONSE 10 (445767D1-0-16}

The SSE for R-S-GRTC-035-DR4 he ten revised to base the m ination on physical inspection of the groot platement. This inspectinn inditates that grout placement is satisfactory in that no characteristics that would result from improper curing were evident. Because grout placement is acceptable, the deviation is limited to improper documentation, which in and of itself cannot be safety-significant. Therefore, this deviation is not safety significant.

DRs R-S-GRTC-039-0R1 and R-S-GRTC-039-0R5 have been revised to an indeterminate conclusion in accordance with the procedure described in response to open item 445/8704-0-01.

Attachment 2 to TXX-88163

. January 29, 1988 Page 5 of 7 SUPPLEMENTAL RESPONSE T0 (44578704-0-16)

Issue-specific Action Plan (ISAP) VII.c, construction work category Cement Grout was evaluated by review of grout placement inspection reports. When these contained incomplete or missing information, a Deviation Report (DR) was ,

prepared. A Safety Significant Evaluation (SSE) of the DR was then performed, '

and as appropriate, grout characteristics that indicate proper execution of certain work activities were verified in the field. However, other construction work activities could not be verified by physical examination except at the time of the original inspection.

The SSE for R-S-GRTC-035-DR4 has been revised to base the evaluation on ,

physical examination of the grout placement which indicates that grout placement is satisfactory in that no characteristics that would result from improper curing were evident. Because grout placement is acceptable, the r deviation is limited to improper documentation, which in and of itself cannot  :

be safety-significant. Therefore, this deviation is not safety-significant.

The SSEs for ors R-5-GRTC-039-DR1 and R-5-GRTC-039-DR5 have been revised to an indeterminate conclusion in accordance with the procedure described in the '

response to open item 445/8704-0-01, because the original inspection report i does not indicate that the inspection attributes "grout poured continuously and strapped and rodded for proper consolidation" and "vibration from nearby equipment avoided" were satisfactory. Furthermore, proper completion of these construction activities could not be verified by physical examination except at the time of the original inspection.

These two deviations were further evaluated in Appendix 21 of the ISAP Vll.c ,

Results Report.

In 120 grout placement inspection reports reviewed to verify that the I inspector documented that the area was free of vibration before and during i placement, one deviation was reported in which the attribute on the inspection  !

report was not marked by the inspector. The attribute following this one on the inspection report (grout poured continuously and properly consolidated) i was also not marked, but the remainder were. Review of other inspection i reports completed by the same inspector revealed that they contained both j attributes and that both were marked, indicating they had been inspected. A [

review of this ins pector's certification records showed that he had a valid certification at tie time of the inspection.

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Third-party field verification determined that the item grouted was on top of L the pedestal for a diesel generator and was unlikely to have been subjected to vibration at the time of placement. Thereforo, the conclusion was reached that the grout placement was satisfactory, and the deviation on the vibration inspection attribute was determinmi to be insignificant.

Attachment 2 to TXX-88163

, January 29, 1988 Page 6 of 7 SUPPLEMENTAL RESPONSE TO

~IR57BMWI6)(Cont 'd)

Based on third-party field verification of surface conditions for this placement, as well as the small size and easily accessible location of the '

plates being grouted, the deviation on the continuously poured and properly consolidated inspection attribute was also determined to be insignificant.

As noted in Section 2.3 of Appendix 21 of the ISAP Vll.c Results Report, limited physical reinspection of specific characteristics of grout placement were conducted in two other construction work categories. In the category of Field Fabricated Tanks, no cement grout deviations were found during reinspection of exposed grout surfaces. In the Mechanical Equipment installation category, eight deviations were identified during reinspection for missing or damaged grout. These were determined to be insignificant, and no adverse trend was identified. In addition, many grout placements were physically examined during evaluation of deviations in the Cement Grout construction work category, as noted above. All of these )lacements were found to be sound, with no indications of significant crac ting, crumbling, or other signs of improper placement. These observations and inspections yield  !

additional confirration concerning proper completion of the work activities ,

for grout placement, as documented on the original inspection report. '

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Attachment 2 to TXX-88163 l

,, January 29, 1988 i

. Page 7 of 7 I

OPEN ITEM (4457676U0~19) ,

l-5-INSP-062-0R02  !

The inability of the ERC inspector to verify that the anchor bolt nuts on a

, baseplate had not bottomed out was evaluated in the SSE. The evaluation attempted to show that, based upon the measured length of the thread The worst condition 1 projecting inspected (above the nut, the nut had not bottomed out.1 3/16" of projected thread) the last thread of the bolt; therefore, the SSE concluded that the nut had not bottomed out. Based on this information the NRC inspector concluded that tho evaluation demonstrated that one nut had possibly bottomed out. The NRC l inspector also co'1cluded that the SSE had not established a verifiable basis to conclude that the deviation was not an S50 as required by paragraph -

S.S.2(e) of ERC Procedure CPP-016. Additional information is required to l 1 3 rove more conclusively that the nut had not bottomed out and that the Hilti l l 1ad, therefore, been properly set. This is an open item (445/8704-0-19).

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RESPONSE TO 1 (4B7T704-0-19) i i

The record of torcue verification test performed during CPRT inspection of the support offers adcitional evidence that the nut had not bottomed out. Test ,

results indicate that the bolt and nut in question passed the torque test ,

d acceptance criteria, indicating that sufficient pre-tension is present in the  !

j Hilti bolt to ensure that it is properly set. [

' i SUPPLEMENTAL RESPONSE TO j (4457876E079) l

) Additional deviations of Hilti anchor bolt nuts bottoming out on the bolt i threads are discussed in the Results Report for ISAP Vll.b.4, Hilti Anchor i Dolt Installation. This deviation type was determined to be an unclassified (

trend, since there is insufficient information to determine if a construction l) deficiency is likely to exist in the uninspected portion of the population. [

Consequently, a CPRT recommendation for corrective action was made to the t Project to reinspect all safety related Hilti anchor bolts for bottomed out  ;

i nuts, and rework as required. F The Project has committed in Corrective Action Request (CAR)87-052 to field l verify proper installation of all safety related Hilti anchor bolts to confirm (

each nut is not bottomed out on the bolt threads, and to rework as required.  !

, These actions will ultimately ensure proper installation of Hilti anchor bolt }

! nuts.  !

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