ML20149J722

Insp Repts 50-445/87-35 & 50-446/87-26 on 871202-880105. Violations & Deviations Noted.Major Areas Inspected:Actions on Previous Insp Findings,Assessment of Allegations, Followup on Violation/Deviations & Corrective Actions

ML20149J722
Person / Time
Site:	Comanche Peak
Issue date:	02/12/1988
From:	Ellershaw L NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20149J607	List: ML20149J605 ML20149J632 ML20149J659 ML20149J722
References
50-445-87-35, 50-446-87-26, NUDOCS 8802230188
Download: ML20149J722 (23)

See also: IR 05000445/1987035

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APPENDIX C'  ?

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.U. S. NUCLEAR REGULATORY COMMISSION

OFFICE OF SPECIAL PROJECTS

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NRC Inspection Report:

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50-445/87-35 Permits: CPPR-126  !

50-446/87-26 CPPR-127 1

Dockets: 50-445 Category: A2 , ,

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Construction Permit

Expiration Dates: _

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Unit 1: August 1, 1988  ;

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Unit 2: Exten= ion requast

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submitted.

Applicant: TU Electric ' '

Skyway Tower '

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400 North Olive Street '

, Lock Box 81

Dallas, Texas 75201 .

Facility Name

Comanche Peak Steam Electric Station (CESTS),  ;

Units 1 & 2

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Inspection At: Comanche Peak Site, Glen Rose, Texas

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!' Inspection conducted: December 2, :987 through January 5,~1988 ,

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Inspector: # #/1.hrweA G n

L. 2. E21Ershaw, Reactor Inspector jtpgdq#  !

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(paragraphs 2, 3.a o. 4, 5.a-o, 6, and 7)  ;

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l Consultants: EGEG ~ J. tale (paragraph 4)

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l Parameter - P. Stanish (parac,ach 2, L a, 3.b, 5.a  :

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and 5.b)  !

j K. Graham (paragraphs 3.c, 3.d, 0 o, ann ,

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3900230166 880212

PDA APOCM 05000445

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RevitWed by: . j d d .1,yu d d ___ 2/g/pp '

H. H. .'Jverme.re, Lead Senior Inspector /Date

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Inspection Suma g: .

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'ns.r,eetive Conducted: December 2, 1987 throuch January 5, 1988 * i

j forQhA45 / 87-5Nijko-44 GJ st1~26 ) '

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Unannounced resident safety inspection of

j sppf M t actions on previous inspection findings, assessment of- -

a allegations, follov-up on violations / deviations, general plant

Areas (tours), Ceacoche Pea)c Response Team (CPRT) issue-specific ,

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acticn pir.n (ISAPc) VII,b.04, Corrective Action Program, and  ;

hilow mp on NRC compliance Bulletin 87-02. i

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Rosults: Within the seven areas inspected, one violation (improper

as-built documentation, paragraph 5.a and fallure to implement  ;

i procedural requirementa for HVAC CAP, paragraph 5.c) and two

deviatio.a (improper as-built documentation, paragraph 5.b; and -

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' failure to implement procedur&1 requirements, paragraph 2) were  !

identified.  !

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DETAILS

1. Persons Contacted

• W. H. Benkert, Staff Assistant Manager, Operations Quality

Assurance (QA), TU Electric

• R. D. Best, Nuclear Operations Inspection Report Item

Coordinator, TU Electric

• D. N. Bize, Engineering Assurance (EA) Regulatory Compliance

Supervisor, TU Electric

• M. R. Blevins, Manager, Technical Support, TU Electric

• M. D. Gaden, CPRT, IT Corporation

• P. E. Halstead, Manager, Quality Control (QC), TU Electric

• T. L. Heatherly, EA Regulatory Compliance Engineer, ,

TU Electric -

• 0. W. Lowe, Director of Engineering, TU Electric

• L. D. Nace, Vice President, Engineering & Construction,

TU Electric

• D. E. Noss, QA Issue Interface Coordinator, TU Electric

• D. M. Reynerson, Director of Construction, TU Electric

• M. J. Figgs, Plant Evaluation Manager, Operations, TU Electric

• A. Ei Scott, Vice President, Nuclear Operations, TU Electric

• C. E. Scott, Manager, Startup, TU Electric

• C, R. Smaney, Unit 1 Assistant Project Manager, TU Electric

• M. R. Steelman, CPRT, TU Electric ,

• P. B. Stevens, Manager, Electrical Engineering, TU Electric

• B. B. Taylor, Nuclear Operations, Maintenance Manager,

TU Electric

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The NRC inspectors also interviewed other applicant employees

during this inspection period.

• Denotes personnel present at the January 5, 1988, exit [

interview.  ;

2. Applicant Action on Prevkous Inspection Findings (92701)

(closed) Unresolved Item (445/8731-U-04): This item is being

closed in this inspection period and elevated to a deviation.

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This unresolved item involved several apparent inconsistencies

in the documentation of dates that calculations were performed

and subsequently checked. Two instances were cited, one where

< the checker dated the calculation page the day before the

engineer performing the calculation dated it, and a

, calculation summary sheet that appeared to be prepared before

' some of the calculations summarized on this sheet were

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performed. Upon further investigation into the cause of these

inconsistencies, Impell stated the case of the checker dating ,

the calculation sheet prior to the calculation being performed  ;

appeared to be an error on the part of the checker. For the

summary page, Impell stated that it appeared that some of the

calculations in this package had been added after the summary i

page had been initially prepared and signed off by the ,

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engineer and checker; however, when the information generated

as a result of these additional calculations was added to the

summary sheet, the summary sheet was not revised to indicate

there had been a change.

Also, in this inspection period, on page la of 63, of

calculation A-02151 for Room 148B, entitled "Open Items", the

checker indicated that his work was completed on January 6,

1987; however, the preparer signed and dated this document on

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January 7, 1987. The abovb examples of improper documentation

now constitute a deviation from Appendix A to Project

Instruction PI-0210-053-001 (445/8735-D-01).

3. Follow-up on Violations / Deviations (92702)

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a. (Closed) Deviation (445/8603-D-13):' This deviation dealt

with three cases where pipe to pipe clearances did not

meet the specified criteria of OI-025, but were not'

id6ntified by Evaluation Research Corporation (ERC)

during reinspection of the Verification Package

I-M-LBCO-148. In NRC Inspection Report 50 '445/87-18;

50-446/87-14, the NRC inspector documented that he

reviewed, and concurred, that an appropriate deficiency

report (DR) had been issued and further concurred that

satisfactory disposition of Nonconformance Report (NCR)

M-25340 would remedy the situation; however, at that time

the rework required by the NCR had not been performed, so

this item remained open pending completion of this

rework. In this inspection period, the NRC inspector was

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able to verify that the rework required in the NCR'

disposition had been completed and the pipe to pipe

clearances in question are now in compliance with the

specified criteria. Therefore, this deviation is closed.

b. (Closed) Deviation (445/8607-D-10): This deviation dealt

with OI Package 13-I-M-LBCO-148 not identifying

unsatisfactory decisions made during the course of the

initial ERC reinspection. It dealt with three pipe to

pipe clearance deficiencies identified by the NRC

inspector in the above mentioned deviation

(445/8603-D-13). Corrective action included revision of

the OI checklist to reflect actual field conditions and .

issuance of the appropriate DR and NCR. Actions to I

prevent recurrence included documented discussion of this l

finding with all overview inspectors and a documented  !

discussion between the overview inspector and the initial i

ERC inspector of record. I

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In NRC Inspection Report 50-445/87-18; 50-446/87-14, the

NRC inspector documented his review and finding of

acceptability of the DR and the subsequent NCR, that the

OI checklist had been corrected to reflect the actual i

field conditions, and that the committed discussions had

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taken place and been documented. However, since the

committed rework had not been completed, this item '

remained open. In this inspection period, the NRC

inspector verified that the committed rework has been '

completed; therefore, this deviation is now closed.

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c. (Closed) Violation (445/8631-V-01): This violation dealt

with the applicant's engineering technical evaluation of

NCR M-83-101128, Revision 0, pertaining to reported  ;

excessive reinforcement (5 deficiencies) and undercut (2  !

deficiencies) in containment liner welds. Radiographic

examination (RT) performed by Chicago Bridge and Iron ,

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(CBI) was part of the technical justification for the '

use-as-is disposition although RT of the weld areas in

question had not been performed. ,

In response to the NOV, the nonconforming conditions were

reevaluated by engineering, QA/QC and ERC.

The five deficiencies pertaining to excessive

reinforc< ment were either not considered valid by the

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applicant or the reinforce.nent was in an area of the seam

weld that had not been subj,ected to radiography. This

evaluation and disposition was accepted by engineering, ,

ERC and QA/QC.

The two deficiencies pertaining to undercut were

reinspected by a Level III inspector and the ERC

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inspector who initially identified the deficiencies. No

~~ endercut condition could be loccted that exceeded 1/32".

Tnis depth is acceptable in accordance with ACI code 359 ' '

, and the applicable specification (2323-SS-14,

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"Containment Steel Liner").

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The NRC inspector reviewed NCR M-85-101128, Revision 2,

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and concurs with the reevaluation of the NCR by the  :

applicant.  !

On March 4, 1986, Corrective Action Request (CAR) 062 was

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initiated and identified, in part, that a generic

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deficiency existed concerning inadequate technical

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evaluations for closed NCRs. Part of the corrective

action to preclude recurrence included training of ,

engineers associated with NCR dispositions. l

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l In addition, 50.55(e) report, SDAR-CP-86-48, was

! transmitted to NRC on July 16, 1986. The SDAR was )

initiated as a direct result of CAR-062 deficiencies and

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will be evaluated by the NRC when closing the SDAR.'

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The NRC inspector verified, by review of TU Electric

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Letter TUQ-4662, that additional training had been  ;

provided to project personnel. The NRC inspectors.will

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review the SDAh (which will be tracked by the 50.55(e)

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report number) in a subsequent inspection _ report.-

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d. (Closed) Violation (445/8607-V-02): . TU Electric Nuclear .[

Engineering (TNE) provided design information which- l

delineated the inspection acceptance criteria'for base  ;

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material defects on field fabricated tanks to ERC in a  !

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response to'-Technical-Information Request (TIR) TIR-017, 'l

dated August 26, 1985. TNE's' method-for verifying the _i

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adequacy of the design information was by the use of j

l calculations. Those calculations were incomplete and  !

unapproved on May 13,-1986. .

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j- The applicant reperformed the calculation providing -!

i inspection acceptance criteria for base material defects, , j

i TNE-SY-CA-0000-290,- Revision 1, and determined that no -r

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change to previously issued acceptance criteria was  !

I required. NRC inspectors reviewed the contents of the  :

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calculation and questioned engineering ; personnel  :

j concerning the margins of conservatism '( .3% below the -  !

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allowable stress) for the. boric acid tank wall stress f

j levels. In response to the NRC-inspectors concern over i

j lack of conservatism, Engineering personnel-provided

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copies of the new calculations generated by the Impell .t

Corporation as a part of the Equipment Qualification

y Corrective Action Program. Calculation (

. IMT-CA-EQ-0116-ME-67, Revisi'on 0, "Resolution'of Boric  !

Acid Tank Discrepancies", and IMT-CA-EQ-0146-MS-67,  ;

1 Revision 0, "Resolution of-Recycle Hold-up Tank

i Discrepancies", were reviewed by the NRC inspector. Tha.t_ ___Ji

J review concluded that a greater margin of conservatism i

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for tank wall stress levels exists than those documented I

j by ths THE calculation. 14Ht NRC inspector - found the new l

calculations to be correct. i

i The applicant's corrective action for the violation-

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included a review of all other TIRs which had been issued '

1 and supplemental training of engineering personnel. The

i NRC inspector has reviewed the corrective action and

, cor.siders it to be adequately responsive to-the ,

violation.

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e. (Open; Violation (445/8607-V-04)

Field design changes,  !

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pertaining to the installation of stainless steel shims  !

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between the reactor coolant system crossover leg piping  !

] and saddle blocks, were not submitted to the organization i

i that performed the original design for review and l

4 approval. In addition, the traveler which was used to l

j implement the design change did not document all of the  !

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changes that occurred. I

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l The applicant issued DR C-87-866 to address the NRC l

j inspection finding. This DR required a review of shim  !

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installation travelers and the issuance of NCRs for any

deficiencies identified. The NCRs issued as a result of

the DR do not document the conditions noted in the Notice

of Violation. No evidence has been provided to~ determine

if a generic problem exists. The failure to document the

NRC identified conditions precludes the evaluation of

corrective action requirements for other NSSS travelers

where shimming was required. This violation remains open

pending further Applicant action.  ;

4. Allecation Follow-up (99014)

(Closed) Allegation (OSP-87-A-0038): Concerns number one and

two of this allegation were addressed and closed in NRC

Inspection Report' 50-445/87-24, 50-446/87-18. This report ,

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addresses the third concern regarding Hilti Kwik bolt

installation. The alleger claimed that (a) QC inspectors

were verifying Hilti bolts after tensioning instead of prior

to tensioning as required by QC prgcedure, (b) that many Hilti

Kwik bolt installations exceeded 6 from' perpendicular,

(c) that the craftsman had been terminated as a result,of -

having followed instructions, and (d) that the practice of

straightening Hilti bolts was common.

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Review '

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The NRC inspector reviewed the last 10 revisions of .

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QI-QC-ll.2, "Inspection of Hilti Bolts"; Project Specification

2323-SS-30, Revisions 1 through 3, "Structural Embedment

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Inspections"; and the CPRT Results Report for ISAP VII.b.4.

.The NRC inspector interviewed various craft and QC inspection i

personnel, and performed over two hundred inspections of Hilti

Kwik bolt installations at the Comanche Peak Power Plant with

the following results: '

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QI-QC-ll.2 and 2323-SS-30 did not and does not currently

address inspecting Hilti Kwik bolts prior to tensioning.

Inspections are performed after tensioning.

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Due to lack of specificity on the part of the alleger,

the NRC inspector was unable to locate the subject bolts

or to verify that two Hilti Kwik bolts had or had not

been straightened or that the craftsman had been

terminated for straightening bolts. However, during the

NRC inspections of the small bore supports, large bore

supports, HVAC equipment supporta, HVAC duct supports,

instrumentation supports and conduit supports, the i

inspector was unable tog locate any Hilti Kwik bolts with

an angle greater than 6 from vertical. Further, from a

review of the ISAP VII.b.04 and VII.c Results Reports, J

the inspector determined that out of approximately

3000 inspection points for angularity, only 3 resulted in  ;

deviations. All craft and QC personnel interviewed were  :

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fully aware of the correct requirements for Hilti Kwik

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bolt installation. The NRC inspector was unable to

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substantiate this concern. Although chis allegation is

considered closed, the NRC does plan additional  ;

inspections of Hilti bolt installation. '

5. Corrective Action Program (C_AP)

NRC inspections were performed to verify the applicant's

activities associated with che Post Construction Hardwarc

Validation Program (PCHVP). The PCHVP was established to ,

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reconcile the design to the design bases appropriate to

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satisfy licensing commitments, and to reconcile the hardware

to the designs i.e., the constructed / installed systems meet

the intent of the design. The following CAPS were inspected ,

during this report period.

a. Conduit Supports A & B Train and Train C > 2" (48053)

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During this inspection period, the NRC inspector selected

a sample of fifteen conduit walkdown packages to verify

the accuracy and ccrrectness of the Ebasco field

collected data. The following is a list of the NRC

inspected packages:

Conduit Size Room * Area ** Supports

C13005319 1" 56 SG1 6 i

C13G04860 2" 66 SG1 6

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C13G15122 1" 74 SG1 10 -

C14G20243 2" 163/155A RB1 , 3

C14R13875 2" 154 RB1 6

C14G32427 1 1/2" 154 RB1 12

C14030157 1" 154 RB1 3

C14G21444 3/4" 174 AUX 4

C12G07286 1" 179/201 AUX 7

j C13G05991 3/4" 179 AUX 1

C14G11447 3/4" 175 AUX 15

C14B14844 3" 133 ECB 6

C12G19612 3"/2" 133/113 ECB 9

C12G07907 2" 133 ECB 8

C13006609 2" 133 ECB 5 i

• SG1 - Unit 1 Safeguards Buildir.g

• RB1 - Unit 1 Reactor Building

• AUX - Auxiliary Building 1

• ECB - Electrical / Control Building

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• • Number of supports includes conduit, junction box and l

pull box supports. l

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adhering to.the criteria of field verification method

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- (FVM) CPE-EB-FVM-CS-033, Revision 2, and resulted in the

identification of the following discrepancies:

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(1) on conduit Support C13G04860-02, the walkdown

engineer failed to note that there were no washers j

installed under the hex nuts on the Hilti Kwik i

bolts. Because of this, there was no nonconformance  ;

report written as required by the FVM. These  :

washers, provided with the Hilti Kwik bolts, provide  !

. a hardened surface between'the hex nut and the mild i

steel clamp.- This assures that the torque being

applied to the assembly results in tension in the.

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anchor bolt and is not dissipated by deformation in

the mild steel clamp which could result in less than

the required preload being applied to the anchor . l

bolt. l

(2)' For Support C14G20243-01, the walkdown engineer

1 raported,the length of the support bsseplate to be  ;

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9 7/8".' During'a subsequent walkdown by the NRC  !

inspector, this dimension was found to be 9 1/2". l

An error such as this could result in the

calculation of incorrect baseplate stresses and

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anchor bolt loads. .

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(3) on Conduit Support C14G11447-03, the walkdown

j engineer reported several dimensions that could not

1 be verified by the NRC inspector during his i

1 inspection of this' support. The support in question  :

is a 2323-S-0910 Type CA-la support which utilizes f

P5000 Unistrut members with one main member and

three outriggers. This support is being used to ,

support'two 3/4" conduits - conduit numbers  !

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C14G11447 and C14G11446. The first discrepancy is t

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the dimension from the westernmost end of the main

Unistrut member to the centerline of the west  !

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conduit. The walkdown engineer reported this l

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dimension to be'5 1/8"; the NRC inspector found 'this

dimension to be 5 7/8". The second discrepancy was

the dimension reported for the location of the  ;

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center outrigger. The walkdown engineer reported i

7 1/8", and the NRC inspector found this dimension ,

j to be 8 5/8" The third dimensional discrepancy  ;

found on this support was the location of the i

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easternmost outrigger. The walkdown engineer  !

reported it to be located 15/16" from the end of the <

main Unistrut member, and the NRC inspector ~

determined this dimension to be 1 1/4". Errors of  :

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this nature could result in the calculation of  !

incorrect anchor bolt loads and incorrect Unistrut '

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member stresses. i

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(4) on; support C14Gil447-04, which is the same type'of

support as discussed in item (3) above, the

dimension locating the center outrigger was. reported

by the walkdown engineer to be 6 5/8" from the

westernmost and of the main Unistrut member.

HowcVer the NRC inspector found'this dimension to be

7 1/2". Again, an error of thi's nature could~have

-an adverse affect'on the calculated anchor bolt-

loads and Unistrut-member stresses.

(5) For Conduit Support'C14Gil447-14, 2323-5-0910 Type

CA-la support,-the walkdown engineer reported a

' total of eight HKBs - two 1/4" HKBs in each of the

three outriggers and-two 3/8" HKBs in.the main

Unistrut member. During the NRC inspector's ,

walkdown, it was noted that there were,:in fact,

nine HKBs the difference being that there were three

3/8" HKBs in the main Unistrut member not two as-

reported. The additional HKB is located at the

centerline of the center. outrigger and has.the

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letter designation "H" and projects 3/4" from the

surface of the concrete.

These are five examples of incorrectly documenting

existing conditions, a violation (445/8735-V-02) of'

criterion V of Appendix B of 10 CFR 50 and FVM

CPE-EB-TVM-CD-033. Three more examples are in paragraph

5.c ot' this repcTt.

On the remaining conduit runs, the results of the NRC

walkdown revealed certain data that did not match that

recorded by Ebascos however, it was deemed to be

acceptable since the difference in the recorded

dimensions was still within the tolerances specified in

the applicable TVM. These minor differences are not

' considered to be of any significance.

The five examples discussed above were detected in the

walkdown of fifteen conduit walkdown packages. In these

packages, there are in excess of three thousand

inspectable attributes. In light of this data, the

Ebasco walkdown personnel are performing in a reasonably

good manner.

b. Conduit Supports C Train Less than or Ecual to 2" (48053) _

For this inspection period, the NRC inspector performed a

review /walkdown of the total scepe of work Impell

performed for Room 76 of the Unit 1 safeguards building

and Room 148B of the electrical / control building.

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Room 76 Safeouards Buildino

The-following calculation /walkdown packages were included

in the inspector's review of Room 76: l

Calculation No. Title

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I RCO-1-SG-76 . Room Closeout-Calculation

[ L2-5-1-SG-76 Level 2 - Conduit Support  :

1 Evaluation  :

l A-00379 Level 5 support Evaluation ,

A-00383

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Level 5 support Evaluation

i A 00535 Level 5 support Evaluation  ;

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A-00628 Level 5 support Evaluation-

L6-1-sG-76 Train C Conduit Interaction ,.  !

Evaluation

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While performing the review /walkdow'n for Room 76, thefNRC  !

inspector identified the following discrepancies with

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respect to the walkdown

a For RFI-E5-1-0118, Appendix A to Calculation A-00628,  !

i page 4 of 4 of this appendix is the as-built drawing  !

! which forms the basis of this calculation. On this.

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J drawing, the engineer who performed-the walkdown reported  :

that the Unistrut bolts being used to secure the junction l

• box to the Unistrut member were 3/8" in diameters  !

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however, the NRC inspector found these bolts to be,'in '

i fact, 1/2" in diameter. Also, on this same as-built  !

l drawing, the walkdown engineer reported that the NKB on

i the north side of the junction box was located 1 1/2"

j away from the junction box. The NRC inspector determined l'

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the distance to be 1 1/8". I

l Room 1488 Electrical / Control Build (ag  !

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4 The following calculations /walkdown packages were l

j included in the NRC inspector's review of Room 1488: i

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a

3

1

i

i

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-

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-. _ _

=_ -

.- c ,

.

4

' _. 12

S

% l,

Calculation No'. Tikle ,

'

RCO-1-EC-148B Room Closeout Calculation /

Documentation

l L2-S-1-EC-1488 -Level 2 Conduit Support-Evaluation l

i

L4-S-1-EC-1488 Level 4 2 Conduit Support Evaluation  !

L4-JB1-ECB-148B Lovel 4 - Junction Box /CI Box / Light ~'

l Fixture Evaluation' '

A-01357 Level 5 - Junction Box /CI Box / Light i

i Fixture Evaluation  !

i

4

A-01385 Level 5 -' Junction Box /CI Box / Light '

,

'

Fixture Evaluation -

! A-01387 Level 5 - Junction Box /CI Box / Light  !

~

Fixture Evaluation

A-01388 Level 5 - Junction Box /CI Box / Light ,

7

Fixture evaluation ,

j A-01389 Level'-5 . Junction Box /CI Box / Light }

Fixture Evaluation

A-02151 Level 5 - Support Evaluation _

[

j , L6-1-EC-148B Level 6 -. Train C Conduit Interaction

'

, .

Evaluation .

I

While performing the review /walkdown'for Room 1488, the I

NRC inspector identified the following discrepancies with- .:

respect to the Impell walkdown. l

j .

t

i

(1) on the isometric drawn to depict the conduit runs -!

i . being evaluated as part of the calculation' entitle'd

i i

A-0215I7'and shown on page 24 of 43 of this  !

calculation, there'are several errors and omissions. -

l First, the dimensional data and orientation for l

{ conduits C-1PA-CR2 and C-1FD-A180, south of the  !

l Type 6 support tagged NQ-19688/A-02156, have been L

reversed; therefore, the isometries for both conduit  !

!

runs are incorrectly depicted. Also, on_the same

! page of the calculation in question, the dimension e

{

{ northsof the Type 6 support tagged NQ-06005/A-02157

~

[

i to the change in elevation is not shown on the ~

j isometric fr ' conduit run C-1PA-A265. These-two

items, when reviewed with Impelt personnel, appear i

i to be drafting errors because the data for the first  !

! discrepancy appears to be correct on the engineer's i

!

hand sketch generated in the field, and the data was [

1

redrawn incorrectly and this error was not detected  ;

by the checker. For the second discrepancy, even j

though the dimension was missing from the final j

, isometric, it appeared in the engineer's draft copy  ;

so it was included in the evaluation of the  ;

}

!

supports; again this appears to-be an undetected  !

drafting error.

s

l

(2) The second discrepancy found in the NRC inspector's [

i walkdown is the east-west dimension from the Type 6  !

I i

, i

-

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_ - _ _ :__-___-_-________ r - - -

. _ _ , _

-

. ,__- ____ - __ - -_ . - - _ - _ _ __-

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. .

'

.

-

13

support tagged NQ-06004/A-02168 to the-rise in

elevation of the' conduit to the bolted junction box-

tagged NQ-08650. This dimension was reported by the

walkdown engineer to be 22" and the NRC inspector

measured this dimenaicn at 13".

(3) On the Type 7 support tagged NQ-06002/A-02160, shown

on page 26 of 43 for calculation A-02151, the

walkdown engineer reported an overall length of the ,

'

P1001 Unistrut member to b5 10";' this length was

determined to be 8" by the NRC inspector.

The discrepancies above detected in Rooms 76 and 148B ,

constitute a deviation (445/8735-D-03) from the

' 1

commitments of the pI-0210-053-001. . .

The results of the review /walkdown of the remainder of ,

'

,

the' data presented for the above rooms revealed certain-

-

data which did not match that recorded by Impell; '

however, it was deemed to be acceptable'since the

difference in the recorded dimeraions was still within

,

the tolerances specified in the applicable project l

'* instruction (PI) and are not considered to be of any l

significance. -

l

The discrepancies listed above represent a very small '

percentage of the total inspection / review points for the

two rooms inspected. Therefore, the results of the .

Impell walkdown engineers is considered to be adequate.

'c . Heating, Ventilation, and Air-Conditioning (HVAC) (50100)

NRC inspectors performed field inspections and

documentation reviews of the following documentation

packages generated as a result of construction,

engineering, and inspection activities related to HVAC .

'

CAP implementation: i

Seismic Duct Hangers Unit Room

,

DH-1-884-1K-WP13 1 99A  !

DH-1-844-1K-4F 1 99B  !

DH-1-844-1K-1R 1 99B

DH-1-844-1K-WP-12 1 99A

Seismic Duct Segment Unit Room

B-1-658-016 1 99B

i NRC inspection of Seismic Duct Hanger DH-1-844-1K-4F,

Revision 1, identified that a fillet weld. 3/16" x 5/8"

!

long, which exists at the location shown by note 3 on the j

design drawing had been incorrectly recorded by  ;

.

1 '

.. --. .- - -- . . _ =, . .

. . .

,

'

.

.

~ '

14

.

.. "~. .,

~

engineering personnel as a tack weld. This weld is too

large to.be classified as.a tackLweld. FVM' .

CPE-EB-FVM-CS-029, Revision'5 provides the. definition of

a tack weld. The failure tb das-built"Lwelding-in- '

accordance with HVAC CAP. commitments.is a violation of

Criterion V ( 445/8735-V-02) ( 6th exar.iple) .

NRC' inspection of seismic' duct hanger packages,

DH-1-844-1K-WP13, Revision-1,.and DH-1-844-1K-1R,

Revision.1, revealed-that construction had removed *

galvanized coatings from welds to: allow for.a visual

inspection by QC inspectors and.had failed toLreapply the

required galvanized coating in accordance with HVAC: CAP

commitments. The NRC inspector identified that five

welds located on Seismic Duct Hanger.DH-1-844-1K-1R did- ,

not have the galvanized. coating as required by' Comanche

Peak Engineering.(CPE) Specification 2323-MS-85.

5

Engineering personnel confirmed that all planned HVAC ' CAP

I inspections of these items were complete. The CPE. -

specification requires that a galvanized. coating shall be

applied to areas where galvanizing has been removed due-

to welding or other fabrication / installation operations.

Engineering personnal were unable to provide a basis for

.

exemption of the, coating requirements from the identified

welds. This is a violation of Criterion V

(445/8735-V-02) (7th example).

The NRC inspector reviewed the contents of Duct Segment

Package B-1-658-016. A comparison.of forms used in.the

.____ duct segment package with those contained in controlled

Procedure CHV-106, Revision 1, determined;that engineers

performing a qualitative walkdown of duct segments were

documenting results of their activities on a controlled

form, Figure 7.6, on which minor corrections had been.

-

made without a. formal revision of the procedure being

performed. This informal revision of a procedural form

was discussed wit > angiaeering and QC personnel.

Subsequent to that discussion, DR C-87-05093 was issued

by the applicant. Additionally, TU Electric Letter

MC-1461 provides a discussion of the NRC inspection

finding. Project personnel-did not comply with the

requirements of Procedures ECC 1.03 and ECC 1.04 for

3

procedure revision and revision control. The failure to

follow these requirements is-a violation of Criterion V

.

(445/8735-V-02) (8th example).

.

'

NRC inspection of DucC Segment B-1-658-016 revealed

several areas on the hem flange between B-1-658-016 and

,

B-1-658-015 where the gasket material, Tremco 440,'had

+

"

been squeezed out from between the flange and was no

longer serving its intended function. It was determined

that this particular section of gasket material had been

installed with a row on each side of the bolted

1

-. . . . . . ,

, , ,

.. - -

. -__ -____ ______-

'

• , .

. -

15

connection and that in the process of being squeezed out,

the hard rubber core was also expelled. The same

problem, was identified on 12 different duct segments in

the same building. This condition was identified by

Ebasco on CAR 87-079, and is considered an open item

pending further clarification ~and NRC review

(445/8735-0-04).

Assessment

Implementation of the NVAC CAP requires that welding be

as-built to reflect actual field conditions. Although

welding was incorrectly as-built, the error is

conservative in nature. *

'

The HVAC CAP was established to assure that field

installed components meet design requirements. The-

design. specification for HVAC clearly states that a ,

protective coating shall be applied to completediwelding.

The failure to apply protective coatings occurred due to

, a misunderstanding between QC and engineering as to who

was responsible for field verification. The NEC

inspector considers the structural safety significance of

this finding to be low.

Project personnel bypassed the requirements of project l

'

. procedures when revising a form used t'o document

engineering walkdown results. The changes that were made <

to the form were improvements and clarified how to '

document results.

6.. CPRT ISAPs: Hilti Anchor Bolt Installation (ISAP VII.b.4) l

(480638) '

a. Review Specifications / Procedures and Identify

Safety-Significant Attributes (NRC Reference 07.b.04.01) l

L

The following specifications / procedures were reviewed by l

the CPRT: l

Specification / Procedure Revision Title j

Gibbs & Hill Specifica- 1 Structural

tion 2323-SS-30 Embedments

Brown & Root Procedure 9 Installation of j

CEI-20 Hilti Drilled-In l

Bolts  !

1

TU Electric Instruction 18 Installation of l

QI-QP-11.2-1 Hilti Drilled-In l

Bolts l

l

s. .. - \

, -(- n -- e,_ w. _ _-- '

..

7-

. .

. .-

16

.

The CPRT review revealed that the following attributes

were addressed: (1) bolt size, type and quantity,

(2) embedmont depth, (3) spacing, (4) angularity,

(5) concrete damage, and (6) nut engagement and nut

bearing. However, CPRT also identified that the

procedures'did not address the requirement for

maintaining a 1:20 bearing for nuts and washers. In

addition, the installation procedures did not provide

specificity with respect to spacing criteria associated

with penetration sleeves or chamfered concrete corners.

Due to the fact that the reinspections of ISAP VII.b.4

were to be conducted as part of the reinspection of

ISAP VII.c populations, it was necessary to incorporate'

all of the safety-significant attributes into the quality ,

instructions (QI) associated with each of the ISAP VII.c

. populations.

_

The NRC inspectors reviewed the above list'ed

specificationw/ procedures to assure that those safety.

.

significant attributes contained in the specifications / *

procedures had been identified by CPRT in ISAP VII.b.4.

The NRC inspectcrs also reviewed all QIs associated with

the ISAP VII.c. populations bei~ng used for the Hilti bolt

reinspections. This review assured that all safety-

significant attributes (including those identified as not

being addressed in the procedures / specifications) were

included in the QIs.

. Inspection of this reference item is now complete. No

, violations or deviations were identified. ,

b. Review Action Plan ISAP VII.c to Assure Inclusion of

Safety-Significant Attributes (NRC Reference 07.b.04.02) 1

i

The NRC inspectors reviewed the following QIs applicable

to the identified ISAP VII.c population in which

reinspections and documentation reviews were performed

for Hiiti anchor bolt installations:

ISAp VII.c Population QI

Small Bore Pipe Supports QI-019, -020

Large Bore Pipe Supports - Rigid QI-027, -025 i

Large Bore Pipe Supports - Nonrigid QI-029, -030 l

Equipment Supports QI-066, -067 )

Instrumentation Supports QI-055, -056

'

Conduit supports QI-053, -054

Pipe Whip Restraints QI-051, -052

HVAC Duct Supports QI-035, -036 l

Structural Steel QI-045, -046 l

Mechanical Equipment QI-059, -060 l

s

1

%-

. . , . , 7. .. . m w - - m. .

m . . .m. . . . - . -

. 1

• Q . .

I

17 '

I

This review by CPRT determined that all safety- l

significant attributes associated with Hilti bolt l

,

installation had been addressed in the QIs.

NRC inspection of this reference item is complete. No

violations or deviations were identified.

c. Review - Specifications, Procedures, OC Inspections, and

Training Procedures and Records to Determine Commonality

(NRC Reference 07.b.04.03) l

The NRC inspectors reviewed the specifications and ,

procedures associated with inspections, training, and )

record requirements in regard to QC inspector

qualifications. ,

Training of QC inspectors and the generation of records

associated with the training, is governed by_ site

Procedures CP-QP-2.1, "Training of Inspection Personnel,"

and CP-QP-2.3, "Documentation Within QA/QC Qualification

Files." These procedures require that the QC inspectors

be trained in accordance with the applicable procedures '

developed for a given inspection act1vity.

,

The commonality aspect was determined by the NRC l

inspectors to be of no concern, in that regardless of the

population involved, there were just two QC procedures

dealing with Hilti bolts: 1.e., QI-QC-ll.2, "Hilti

Bolts," and QI-QC-ll.2-1, "Installation of Hilti Bolts."

Both of these procedures established the criteria by

which QC inspectors performed inspections of Hilti bolts

and Hilti bolt. installation.

It should be noted that CPRT identified questionable ,

qualifications regarding some QC inspectors involved with  !

Hilti bolt inspections. Evaluations have been performed i

and addressed within the framework of ISAP I.d.1, which l

deals with QC inspector qualifications, l

1

NRC inspection of this reference item is comp 3ete. No <

violations or deviations were identified. l

d. Obtain Results From Action Plan VII.c Inspections (NRC

Reference 07.b.04.04)

The CPRT reinspection of ISAP VII.c populations is

complete and included 517 items containing approximately

3000 Hilti bolts. These reinspections resulted in the

identification of 174 deviations. CPRT evaluation'of

these deviations determined that none were safety-

significant. Fifty-nine deviations were identified as a  ;

recult of documentation review; all dealing with either '

i

.

l

- t

y . . , , _. .a - -- -n- - i

.. .

.-

-

.

_

18

missing or indeterminate documentation for Hilti bolt

torque inspections.-

The results of the ISAP VII.c reinspection effort are

documented in' population reports. These reports are not

entirely complete and data is still being evaluated. At

this time, however, no new issues regarding Hilti bolts

have been' identified by the CPRT. If new issues are

identified, they will be addressed within the context of

the particular ISAP.VII.c population.

P

The NRC inspector's witnessed a minimum of five percent of

CPRT reinspection of the ISAP VII.c populations, and-also

performed inspections of a minimum of five percent of the

ISAP.VII.c populations. Therefore, with respect to ,

ISAP VII.b.4, no further NRC inspection of this activity

will be performed. ;No violations or deviations were

identified. .

>

'

i

e. Assure That Sample Size Chosen J From Action Plan VII.c is

Adequate (NRC Reference 07.b.04.05)

The NRC inspectors have verified that the Hilti bolt  ;

sample wasrrandomly selected from each of the IFAP VII.c

population's containing Hilti bolts. The actual number -

selected from each population was proportional to the  :

number.of items containing Hilti bolts within that

population. The'actu'la ISAP VII.c populations sample

selections were verified by.the NRC inspectors as being

in conformance with Appendix D of the CPRT Action Plan

during this inspection; period.

I

I

NRC inspection of this! reference item is complete. No

violations or deviations were identified.

f. Perform Reinspections in Accordance with Action Plan

VII.c (NRC Reference 07.b.04.06) .

The CPRT inspection of the various ISAP VII.c populations

is complete. The inspection attributes for ISAP VII.b.4

can also.be found in.and are compatible with the

following populations of VII.c.

'

Small Dore Pipe Supports

Large Bore Pipe Supports I Rigid

Large Bore Pipe Supports - Nonrigid

Equipment Supports

Instrumentation Supports

Conduit Supports

Pipe Whip Restraints

HVAC Duct Supports

Structural Steel

Mechanical Equipment

. . . ,. .. .

_,.. - . s. ,

. . _ . _ . _ _

. _ _ _ _ . _ _ _

• s b

_

19

.

The results of the ISAP VII.c inspections are being

evaluated and documented in population reports by CPRT.

At this point in time, however, no new issues have been

identified in VII.c concerning Hilti Kwik bolts. If new

issues are identified, they will be documented ~in the

respective VII.c populations.

The NRC inspectors have verified by witnessing and by

performing inspections that the CPRT inspection' effort of

ISAP VII.b.4 was conducted in accordance with the

requirements of ISAP VII.c.

~

NRC inspection of NRC reference Item 07.b.04.06 is 3

complete. No violations or deviations were identified,

,

7. Follow-up on NRC Compliance Bulletin 87-02 (25026)

NRC Compliance Bulletin 87-02 pertains to the testing of

fasteners to determine conformance with the applicable

material specifications, As a result of concerns expressed by l

the Industrial Fastener Institute over the potential use of

inferior fasteners, the NRC instituted'a limited program which

included the collection and testing of a small sample of

fasteners. The results of NRC testing of fasteners obtained ,

from several nuclear power plants revealed approximately 34%

of the fasteners (11 out of 32) failed to meet material

specification requirements for mechanical and/or chemical

properties. In a separate effort, Baltimore Gas & Electric

tested fasteners following their discovery that commercial

grade fasteners had been used in safety-related applications.

Their results indicated that approximately 26% of the tested

fasteners (399 out of 1539) failed to meet specification

requirements for mechanical and/or chemical properties.

This data resulted in the initiation and issuance of NRC

Compliance Bulletin 87-02 which requires licensees to provide

a description of their program with respect to receipt

inspection and internal control procedures for fasteners.

Further, it requires that a minimum sample of 10 safety-

related fasteners (studs, bolts, and/or cap screws),

10 nonsafety-related fasteners (studs, bolts, and/or cap

screws), and a like number of nuts which would be used for

each of the sampled fasteners, be selected for independent

testing. The examples are to be selected from warehouse

stock. The testing is to be performed in accordance with the

requirements of the applicable fastener's specification,

grade, and class. The results of all tests, including

supporting information and any safety significance evaluations

which would be required for any fastener found out of

specification, are to be reported to the NRC.

TU Electric conducted an inventory review and determined which

fasteners and nuts existed in stock by material, type, grade,

,

_ .. . , . . . . - . .

_ -

.. -

! a k t

. I

20

'

,

i

and quantities. TU Electric further determined the' i

proportions of installed fasteners and nuts so that the sample

-

I

to be selected would be as nearly representative as possible.

The'NRC inspector participated in the selection process as t

directed by the bulletin which resulted in a' sample consisting '

of 20. safety-related fasteners, 12 safety ^related nuts,.

10 nonsafety-related fasteners, and 10 nonsafety-related nuts. . t

The sample is made up of the following-

i

Safety-Related-Fasteners [

r

' Material Type / Grade Quantity l

A-193 B7 3 ,

j

A-193 B8 2 .

'

SAE-J4$9 'l

A-307 3  !

A-325 2

A-325 Type 1 1

l

A-325 Type 2 1

A-325 Type 3 2  ;

A-354 Grade BD 1 -

A-490 3

'

A-320 1 l

!

,

Safety-Related Nuts  ;

!

Material Type / Grade Quantity .!

t

A-194 Grade 2H 3  !

A-194 Grade 7 1

A-563 Grade C 3 i

A-563 Grade D 1  :

A-563 1 l

A-307 1

l

A-540 1 l

A-325 1

<

l

Nensafety-Related Fastaners i

Material Type / Grade Quantity  :

A-490 2 l

A-453 Grade 660 2

A-193 B7 6

l

• '

, - .. _ r, v ,- 4 . .- - - . . . . -.- . __- - -_.-. _--..

.

-- ~

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21  !

Nonsafety-Related Nuts

Material Type / Grade . Quantity

A-194 Grade 2H 8 ,

A-563 Grade C 1

A-307 ,

1 -

The samples were tagged-(identified) and packaged. .

,

TU Electric placed Earchase Orders CPF-35104.(nonsafety i

related) and CPF-14524-S (safety related) with Southwest

Laboratories to perform independent mechanical testing and

chemical analysis as required by the material specification

and, where applicable, the additional ~ requirements of

Section III of the ASME Code. The nonsafety-related items -

- '

were sent to Southwest Laboratories on December 16, 1987, '

while the safety-related Items were sent on December 18, 1987.

I

The NRC review of the bulletin response will be addressed in a

subsequent NRC inspection report. .

8 '. Plant Tours  ;

The NRC inspectors made frequent tours of the facility and

observed such items as in-process work activities,

housekeeping, and equipment' protection. Protegtion of

equipment was observed to be considerably improved.

No violations or deviations-were identified.  ;

9. Open Items

Open items are matters which have been discussed with the i

licensee, which will be reviewed further by the-inspector, and

'

which involve some action on the part of the.NRC or_ Licensee

or both. Open items disclosed during the inspection are

discussed in paragraph _5.c.

x.

"

10. Exit Interview (30703)

on January 5, 1988, prior to the exit, R. F. Warnick and

H. H. Livermore met with L. D. Nace and A. B. Scott to discuss

the following matters from December:

a. NRC inspection reports for November were issued in under

,

20 days,

b. Following the enforcement conference on December 8, 1987,

a Notice of Violation (three violations) was issued on

December 31, 1987.

l

i

.

i

-

- - -

v -..,,,1 - - - .

"

' '* 6 -

. . l

-

I

22

c. The NRC letter of December 4, 1987, to TU_ Electric

informed the utility that the SALP evaluation process

will be resumed for Comanche Peak.

d. Four additional NRC inspectors.will be transferred to the

site in January.

'

e. OSP has a new Assistant Director for Licensing,

James Wilson. -

. .

f. 'Two nonresident inspections were conducted in December -

U-l preservice and U-1/2 safeguards. Both inspections

resulted in favorable findings,

g. Additional examples of Ebasco and Impell walkdown' errors ' ,

were identified by the NRC in December.>> i

An exit interview was conducted January 5, 1988, with the

applicants representatives identified in paragraph 1 of this

report. During this interview, the NRC inspectors summarized

the scope and findings of the inspection. The applicant

acknowledged the findings.

s.

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.

W

50-445/$f-f$; 50-446/S?-oWo

DISTRIBUTION:

NRC PER

Local PDR i

OSP Reading

CPPD-LA l

CPPD Reading (HQ) *

• Site Reading File

AD for Projects

'

• Sr. Lead Insp. - CONST.

• Sr. Lead Insp. - OPS

• Concurrence '

• MIS System, RIV

• RSTS Operator, RIV

DRP, RIV

'RIV Docket File

• DWeiss, RM/ALF -

l

JTaylor l

SEbneter/JAxelrad

CGrimes *

PMcKee

JLyons

JWilson

JMoore, OGC

JGl.i.liland, RIV

FMiraglia

EJordan -

JPartlow

BHayes

1

• w/766  !

l

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/

,

&*I .

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., . -

.

.-

.