ML20149J722
| ML20149J722 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/12/1988 |
| From: | Ellershaw L NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20149J607 | List: |
| 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:
50-445/87-35
Permits: CPPR-126
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50-446/87-26
CPPR-127
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Dockets: 50-445
Category: A2
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50-446
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Construction Permit
Expiration Dates:
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Unit 1: August 1, 1988
Unit 2: Exten= ion requast
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submitted.
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Applicant:
TU Electric
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Skyway Tower
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400 North Olive Street
Lock Box 81
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Dallas, Texas
75201
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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
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L. 2. E21Ershaw, Reactor Inspector
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(paragraphs 2, 3.a o. 4, 5.a-o, 6, and 7)
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Consultants:
EGEG ~ J. tale (paragraph 4)
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Parameter - P. Stanish (parac,ach 2, L a,
3.b, 5.a
and 5.b)
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K. Graham (paragraphs 3.c, 3.d, 0 o, ann
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5.c)
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3900230166 880212
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PDA
APOCM 05000445
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RevitWed by:
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H. H. .'Jverme.re, Lead Senior Inspector
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Inspection Suma g:
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'ns.r,eetive Conducted: December 2, 1987 throuch January 5, 1988
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forQhA45 / 87-5Nijko-44 GJ st1~26 )
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Mys 7nmetert: Unannounced resident safety inspection of
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sppf M t actions on previous inspection findings, assessment of-
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allegations, follov-up on violations / deviations, general plant
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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
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hilow mp on NRC compliance Bulletin 87-02.
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Rosults:
Within the seven areas inspected, one violation (improper
as-built documentation, paragraph 5.a and fallure to implement
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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
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identified.
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DETAILS
1.
Persons Contacted
- W.
H. Benkert, Staff Assistant Manager, Operations Quality
- 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,
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TU Electric
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- 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
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- 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
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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.
This unresolved item involved several apparent inconsistencies
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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
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engineer performing the calculation dated it, and a
calculation summary sheet that appeared to be prepared before
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some of the calculations summarized on this sheet were
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performed.
Upon further investigation into the cause of these
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inconsistencies, Impell stated the case of the checker dating
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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
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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
able to verify that the rework required in the NCR'
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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
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issuance of the appropriate DR and NCR.
Actions to
prevent recurrence included documented discussion of this
finding with all overview inspectors and a documented
discussion between the overview inspector and the initial
ERC inspector of record.
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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
field conditions, and that the committed discussions had
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taken place and been documented.
However, since the
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committed rework had not been completed, this item
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remained open.
In this inspection period, the NRC
inspector verified that the committed rework has been
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completed; therefore, this deviation is now closed.
c.
(Closed) Violation (445/8631-V-01):
This violation dealt
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with the applicant's engineering technical evaluation of
NCR M-83-101128, Revision 0, pertaining to reported
excessive reinforcement (5 deficiencies) and undercut (2
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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
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use-as-is disposition although RT of the weld areas in
question had not been performed.
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In response to the NOV, the nonconforming conditions were
reevaluated by engineering, QA/QC and ERC.
The five deficiencies pertaining to excessive
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reinforc< ment were either not considered valid by the
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,
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ERC and QA/QC.
The two deficiencies pertaining to undercut were
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reinspected by a Level III inspector and the ERC
inspector who initially identified the deficiencies.
No
endercut condition could be loccted that exceeded 1/32".
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Tnis depth is acceptable in accordance with ACI code 359 '
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and the applicable specification (2323-SS-14,
"Containment Steel Liner").
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The NRC inspector reviewed NCR M-85-101128, Revision 2,
and concurs with the reevaluation of the NCR by the
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applicant.
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On March 4, 1986, Corrective Action Request (CAR) 062 was
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initiated and identified, in part, that a generic
deficiency existed concerning inadequate technical
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evaluations for closed NCRs.
Part of the corrective
action to preclude recurrence included training of
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engineers associated with NCR dispositions.
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In addition, 50.55(e) report, SDAR-CP-86-48, was
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transmitted to NRC on July 16, 1986.
The SDAR was
initiated as a direct result of CAR-062 deficiencies and
will be evaluated by the NRC when closing the SDAR.'
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The NRC inspector verified, by review of TU Electric
Letter TUQ-4662, that additional training had been
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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
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Engineering (TNE) provided design information which-
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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,
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dated August 26, 1985.
TNE's' method-for verifying the
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adequacy of the design information was by the use of
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calculations.
Those calculations were incomplete and
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unapproved on May 13,-1986.
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The applicant reperformed the calculation providing
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inspection acceptance criteria for base material defects,
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TNE-SY-CA-0000-290,- Revision 1, and determined that no
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change to previously issued acceptance criteria was
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required.
NRC inspectors reviewed the contents of the
calculation and questioned engineering ; personnel
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concerning the margins of conservatism '( .3% below the -
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allowable stress) for the. boric acid tank wall stress
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levels.
In response to the NRC-inspectors concern over
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lack of conservatism,
Engineering personnel-provided
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copies of the new calculations generated by the Impell
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Corporation as a part of the Equipment Qualification
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Corrective Action Program.
Calculation
IMT-CA-EQ-0116-ME-67, Revisi'on 0, "Resolution'of Boric
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Acid Tank Discrepancies", and IMT-CA-EQ-0146-MS-67,
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Revision 0, "Resolution of-Recycle Hold-up Tank
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Discrepancies", were reviewed by the NRC inspector.
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review concluded that a greater margin of conservatism
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for tank wall stress levels exists than those documented
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by ths THE calculation.
14Ht NRC inspector - found the new
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calculations to be correct.
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The applicant's corrective action for the violation-
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included a review of all other TIRs which had been issued
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and supplemental training of engineering personnel.
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NRC inspector has reviewed the corrective action and
cor.siders it to be adequately responsive to-the
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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
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and saddle blocks, were not submitted to the organization
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that performed the original design for review and
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approval.
In addition, the traveler which was used to
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implement the design change did not document all of the
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changes that occurred.
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The applicant issued DR C-87-866 to address the NRC
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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
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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
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2323-SS-30, Revisions 1 through 3, "Structural Embedment
Inspections"; and the CPRT Results Report for ISAP VII.b.4.
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.The NRC inspector interviewed various craft and QC inspection
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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
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address inspecting Hilti Kwik bolts prior to tensioning.
Inspections are performed after tensioning.
Due to lack of specificity on the part of the alleger,
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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
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inspector was unable to locate any Hilti Kwik bolts with
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an angle greater than 6
from vertical.
Further, from a
review of the ISAP VII.b.04 and VII.c Results Reports,
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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
bolt installation.
The NRC inspector was unable to
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substantiate this concern.
Although chis allegation is
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considered closed, the NRC does plan additional
inspections of Hilti bolt installation.
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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
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to the designs
i.e.,
the constructed / installed systems meet
the intent of the design.
The following CAPS were inspected
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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
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C13G04860
2"
66
SG1
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C13G15122
1"
74
SG1
10
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C14G20243
2"
163/155A
RB1
3
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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
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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
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- SG1 - Unit 1 Safeguards Buildir.g
- RB1 - Unit 1 Reactor Building
- AUX - Auxiliary Building
- ECB - Electrical / Control Building
- Number of supports includes conduit, junction box and
pull box supports.
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The NRC inspector's walkdowns were performed while
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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
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installed under the hex nuts on the Hilti Kwik
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bolts.
Because of this, there was no nonconformance
report written as required by the FVM.
These
washers, provided with the Hilti Kwik bolts, provide
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a hardened surface between'the hex nut and the mild
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steel clamp.- This assures that the torque being
applied to the assembly results in tension in the.
anchor bolt and is not dissipated by deformation in
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the mild steel clamp which could result in less than
the required preload being applied to the anchor
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bolt.
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(2)'
For Support C14G20243-01, the walkdown engineer
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raported,the length of the support bsseplate to be
9 7/8".' During'a subsequent walkdown by the NRC
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inspector, this dimension was found to be 9 1/2".
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An error such as this could result in the
calculation of incorrect baseplate stresses and
anchor bolt loads.
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(3)
on Conduit Support C14G11447-03, the walkdown
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engineer reported several dimensions that could not
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be verified by the NRC inspector during his
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inspection of this' support.
The support in question
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is a 2323-S-0910 Type CA-la support which utilizes
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P5000 Unistrut members with one main member and
three outriggers.
This support is being used to
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support'two 3/4" conduits - conduit numbers
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C14G11447 and C14G11446.
The first discrepancy is
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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
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dimension to be'5 1/8"; the NRC inspector found 'this
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dimension to be 5 7/8".
The second discrepancy was
the dimension reported for the location of the
center outrigger.
The walkdown engineer reported
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7 1/8", and the NRC inspector found this dimension
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to be 8 5/8"
The third dimensional discrepancy
found on this support was the location of the
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easternmost outrigger.
The walkdown engineer
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reported it to be located 15/16" from the end of the
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main Unistrut member, and the NRC inspector
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determined this dimension to be 1 1/4".
Errors of
this nature could result in the calculation of
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incorrect anchor bolt loads and incorrect Unistrut
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member stresses.
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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,
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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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.
.
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Room 76 Safeouards Buildino
The-following calculation /walkdown packages were included
in the inspector's review of Room 76:
l
l:
Calculation No.
Title
.
'
.
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
,
i
'
A-00383
Level 5 support Evaluation
-
i
A 00535
Level 5 support Evaluation
2
A-00628
Level 5 support Evaluation-
L6-1-sG-76
Train C Conduit Interaction
!
,.
Evaluation
j
'
,
While performing the review /walkdow'n for Room 76, thefNRC
-
inspector identified the following discrepancies with
-
respect to the walkdown
For RFI-E5-1-0118, Appendix A to Calculation A-00628,
!
a
i
page 4 of 4 of this appendix is the as-built drawing
!
!
which forms the basis of this calculation.
On this.
l
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
!
however, the NRC inspector found these bolts to be,'in
1
'
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
i
the distance to be 1 1/8".
I
'
i-
l
Room 1488 Electrical / Control Build (ag
l
!
The following calculations /walkdown packages were
4
j
included in the NRC inspector's review of Room 1488:
i
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I
I
1
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a
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.
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'
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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
A-01385
Level 5 -' Junction Box /CI Box / Light
4
,
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
(1)
on the isometric drawn to depict the conduit runs
-!
i
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.
l
s
(2)
The second discrepancy found in the NRC inspector's
[
i
walkdown is the east-west dimension from the Type 6
!
I
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,
i
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-
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.
-
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-
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. ,__- ____ - __ - -_ . - - _ - _ _ __-
-
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a
.
.
'
.
.
-
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
'* 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
design drawing had been incorrectly recorded by
j
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14
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.
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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
.
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
procedure revision and revision control.
The failure to
3
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
-. . . . .
,
. ,
,
,
.. - -
. -__ -____ ______-
- ,
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-
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
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)
The following specifications / procedures were reviewed by
the CPRT:
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
QI-QP-11.2-1
Hilti Drilled-In
Bolts
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.
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
Large Bore Pipe Supports - Nonrigid
QI-029, -030
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
Structural Steel
QI-045, -046
Mechanical Equipment
QI-059, -060
s
1
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.
.
,
.
,
7. . . m w - -
m.
.
m . . .m.
.
. .
- . -
.
.
Q
.
.
17
'
This review by CPRT determined that all safety-
significant attributes associated with Hilti bolt
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)
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
and addressed within the framework of ISAP I.d.1, which
deals with QC inspector qualifications,
l
NRC inspection of this reference item is comp 3ete.
No
<
violations or deviations were identified.
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
'
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,
,
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.-
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_
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
J
e.
Assure That Sample Size Chosen 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
The'actu'l ISAP VII.c populations sample
population.
a
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
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,
,
_
.. .
, . . .
. - . .
-
..
-
k
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!
a
.
I
20
'
,
i
and quantities.
TU Electric further determined the'
i
I
proportions of installed fasteners and nuts so that the sample
-
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
'
,
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.
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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.
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6
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.
22
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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.
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50-445/$f-f$; 50-446/S?-oWo
DISTRIBUTION:
NRC PER
Local PDR
OSP Reading
CPPD-LA
CPPD Reading (HQ)
- Site Reading File
AD for Projects
- Sr. Lead Insp. - CONST.
'
- Concurrence
'
- MIS System, RIV
- RSTS Operator, RIV
DRP, RIV
'RIV Docket File
- DWeiss, RM/ALF
-
JTaylor
SEbneter/JAxelrad
CGrimes
PMcKee
JLyons
JWilson
JMoore, OGC
JGl.i.liland, RIV
FMiraglia
EJordan
-
JPartlow
BHayes
- w/766
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