ML20151F292
| ML20151F292 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/22/1988 |
| From: | Livermore H NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20151F278 | List: |
| References | |
| 50-445-88-46, 50-446-88-44, IEB-87-002, IEB-87-2, NUDOCS 8807270018 | |
| Download: ML20151F292 (10) | |
See also: IR 05000445/1988046
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APPENDIX B
U.
S. NUCLEAR REGULATORY COMMISSION
OFFICE OF SPECIAL PROJECTS
NRC Inspection Report:
50-445/88-46
Permits: CPPR-126
50-446/88-44
CPPR-127
Dockets: 50-445
' Category: A2
50-446
Construction Permit
Expiration Dates:
Unit 1: August 1, 1988
Unit 2: Extension request
submitted.
Applicant:
TU Electric
Skyway Tower
400 North Olive street
Lock Box 81
Dallas, Texas
75201
Facility Name:
Comanche Peak Steam Electric Station (CPSES),
>
Units.1 & 2
I'.:spection At:
Comanche Peak Site, Glen Rose, Texas
Inspection Conducted:
June 8 through July 6, 1988
Inspection conducted by NRC consultants:
J. Dale - EG&G (paragraph 3)
K. Graham - Parameter (paragraphs 6.a and 7.a)
P.
Stanish - Parameter (paragraphs 2, 4, 5 and 6.b)
NML
l-12-8 6
Reviewed by:
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H. H.
Livermore, Lead Senior Inspector
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ADOCK 05000445
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Inspectito Summary:
Inspection Conducted: June 8 through July 6,
1988 (Report
'50-445/88-46; 50-446/88-44)
Areas Inspected: Unannounced, resident safety inspection of
applicant's actions on previous inspection findings, follow-up on
violations / deviations, follow-up on NRC. Compliance Bulletin 87-02,
Comanche Peak Response Team (CPRT) issue-specific action plans
(ISAPs) VII.b.2, Corrective Action Program (CAP) for Mechanical and
for Conduit supports A & B Train and C Train > 2",
and general
plant areas (tours).
Results:
Within the areas inspected, the NRC inspectors identified
no significant strengths or weaknesses during the inspection.
Two
violations (failure to provide documented instructions,
paragraph 6.a, and failure to adequately document existing
conditions, paragraph 6.b) were identified.
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DETAILS
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Persons Contacted
- R.
P. Baker, Licensing Compliance Manager, TU Electric
- J.
L... Barker, Manager, Engineering Assurance, TU Electric
- M.
R. Blevins, Manager, Technical Support, TU Electric
- J.
T. Conly, APE-Licensing, Stone and Webster Engineering
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Corporation, (SWEC).
- W.
G.
Counsil, Executive Vice President, TU Electric
- G.
G. Davis',-Nuclear Operations Inspection Report Item
Coordinator, TU Electric
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- D.
E. .Deviney, Deputy Director, QA, TU Electric
- W.
G. Guldemond, Executive Assistant, TU Electric
- P.
E. Halstead, Manager, Quality Control (QC), TU Electric
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- T.
L. Heatherly, Licensing Compliance Engineer,
TU Electric
- R.
T. Jenkins, Manager, Mechanical Engineering, TU Electric
- S.
D.
Karpyak, CPRT, TU Electric
- J.
J. Kelley, Manager, Plant Operations, TU Electric
'*O.
W.
Lowe, Director of Engineering, TU Electric
- J. W. Muffett, Manager of Civil Engineering, TU Electric
- D.
M. Reynerson, Director of Construction, TU Electric
- M. J. Riggs, Plant Evaluation Manager, Operations, TU Electric
- C.
E. Scott, Manager, Startup. TU Electric
- J.
C.
Smith, Plant Operations Staff, TU Electric
- S.
L. Stamm, Project Engineering Manager, SWEC
- P. B. Stevens, Manager, Electrical Engineering, TU Electric
- C.
L. Terry, Unit 1 Project Manager, TU Electric
- J. R. Waters, Licensing Compliance Engineer, TU Electric
- C.
E. Watters, QA Program Manager, SWEC
The NRC inspectors also interviewed other applicant employees
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during this inspection period.
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- Denotes personnel present at the July 6, 1988, exit
meeting.
2.
Applicant's Action on Previous Inspection Findings (92701)
(Closed) Open Item (445/8516-0-51):
During a reinspection of
Inspection Package I-S-COSP-046 for Unit 1 Conduit Support
C03G09956-04, which was witnessed by the NRC inspector,
Evaluation Research Corporation identified that there was a
1/8-inch gap between the unistrut base and the wall.
Subsequent to this reinspection activity, it was determined
that conduit C03909956 and its supports had been deleted by
Document Change Authorization (DCA) 21297, Revision 0.
The
NRC inspector reviewed the DCA to confirm that the conduit was
no longer required and inspected Room 173 to ensure that the
action required by the DCA had been completed.
This item is
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closed.
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3.
Follow-up on Violations / Deviations (92702)
(closed) Violation (445/8626-V-08, 446/8622-V-05):
The NRC
inspector identified that, with respect to position limitation
and qualified material thickness ranges, Bahnson Service
Company's welder performance qualification records dated
March 1979, June 1981, and March 1983 certify their welders as
being qualified in more positions and material thickness
ranges than allowed by the reported number of test results.
TU Electric responded to the violation by issuing
Nonconformance Report (NCR) CM-87-3541 which was dispositioned
use-as-is with the following reason:
The contractor of record, Bahnson, did not fill out all
test results on the Welder Qualification Record for bend
test results (i.e.,
2G, 3G, and 4G).
A letter
(BSC-EB-054) from Bahnson states that all test positions
were tested in accordance with ASME Section IX.
The same letter (BSC-EB-054, attached to the NCR)
continues sa to state that welders that qualified in the
4G position are automatically qualified to the
1G position.
This is in compliance with ASME Section IX.
Thickness range should read 1/16" - 1/2" groove welds,
unlimited thickness fillets.
(See QW303.1 in ASME
Section IX.)
In addition, TU Electric states that there
is a new architect engineer and contractor on site, and
all field welds are to be reevaluated and reworked as
required.
The NRC inspector reviewed approximately 50 welders
Qualification Records for the period from 1978 to 1984,
reviewed ASME Section IX, and during the period from March
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1987 to present, interviewed Bahnson's Engineering Assurance
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staff and interviewed several Bahnson welders.
As a result of
the NRC inspector's reviews and interviews, the NRC inspector
feels that both Bahnson's welder position limitations and the
Welder Qualification Records meet the intent of the ASME
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Section IX Code.
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This violation is closed.
4.
Follow-up on NRC Compliance Bu]letin 87-02 (25026)
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(Closed) NRC Compliance Bulletin 87-02 pertains to testing of
f actoners to determine conformance with appl 3 0able material
specifications.
In response to a concern rr.ised by the
Industrial Fastener Institute, NRC had teFUing performed on a
small sample of fasteners collected at various nuclear plants.
Results of this testing indicated that 11 out of 32 fasteners
tested did not meet specification requirements.
This data,
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along with data provided by Baltimore Gas and Electric which
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demonstrated a similar reject rate, resulted in the issuance
of this NRC compliance bulletin..
The bulletin required the applicant to provide a description
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of their program with respect.to receipt inspection and
internal control procedures for fasteners.
Further, it s
required that a minimum sample of 10 safety-related and
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.
These samples were to be selected from current, in
use, stock with the participation of a NRC inspector.
The
testing -was to be perfortaed 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
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that were required, were to be reported to the NRC.
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NRC participation of the selection of fasteners to be tested
in response to Bulletin 87-02 was documented in NRC Inspection
Report 50-445/87-35; 50-446/87-26.
A total of 20 safety-
related f asteners,12 safety-related nuts,- 10 nonsafety-
related fasteners, and 10 nonsafety-related nuts were selected-
with the following material types / grades:
A-193 Grade B7;
A-193 Grade B8; SAE-J429; A-307; A-325; A-325 Type 1, 2,
and 3; A-354 Grade BD; A-490; A-320; A-194 Grade 2H; A-194
Grade 7; A-563;-A-563 Grade C; A-563 Grade D; A-540; and A-453
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Grade 660.
Testing for these fasteners was performed by Southwestern
Laboratories under the applicant's purchase Orders CPF-35104
(nonsafety) and CPF-14524-S (safety-related).
On February 11, 1988, the applicant issued a notarized
response to this bulletin which documented the CPSES
procedures establish quality requirements and. controls to
ensure that material, parts, and equipment used in safety-
related applications are receipt inspected, controlled, stored
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and issued from stock in accordance with applicable codes,
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standards, specifications, and purchase requirements.
The NRC inspector reviewed procedures for receiving
inspection, storage, identification, control, and issuance of
safety-related as well as nonsafety-related items, and
verified that the necessary characteristics are adequately
reviewed, inspected, and controlled.
As part of the response, the applicant provided the results of
all the tests performed by Southwestern Laboratories.
These
-results indicated that all but se*?en of the fasteners and nuts
met the requirements of the material specifications in effect
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at the time of the test.
Two of the nonconformances were for
deviations in chemical content, and the remainder of the
deviations were for differences in tensile strength or
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hardness (which can be converted to'an approximate ter.sile
strength value).
As required by this bulletin, the applicant
performed an evaluation of-the safety significance for each of
the items found out-of-specification.
The results of these
generic evaluations were that the fasteners and nuts which did
not .9 eat specification would have still been able to fulfill
their function had they been installed.
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The NRC. inspector reviewed the test results and: safety
significance evaluations and finds that the conclusions
arrived at are reasonable and concurs with the stated
conclusions that internal controls are adequate to ensure the
integrity of and operability of safety-related systems.
This
item is closed.
5.
_ Applicant's Action on Issue-Specific Action Plans
(ISAPs)(48063)
The following CPRT ISAP VII,b.2, Valve Disassembly, activities
were inspected during this report period:
Perform an Analysis to Determine the Safety Consequences of
Improperly Assembled Valves (NRC Reference 07.b.02 03)
The Results Report states, in part, "While the potential for
switching non-ASME and ASME code class bonnets did exist,
there is no implication that switching of non-ASME and ASME
valve bonnets could be safety-significant."
The NRC raised questions as to how the results report-
considered the difference between non-ASME and ASME code
requirements with respect to various items which are detailed
in NRC Inspecrian Report 50-445/86-07 and are the subject of
Unresolved item 445/8607-U-27.
The applicant provided
additional information in response to this unresolved item.
This infor.?ation was contained in a letter from the
manufacturer of the t*?ves in question explaining the basic
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differences in the manufacturing process and of material
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certification of non-ASME and ASME code class bonnets.
This
data was reviewed by the NRC inspector and the results of that
review are documented in NRC Inspection Report 50-445/88-32.
It states that the additional ~information presented does not
support the Results Report conclusion relative to safety
significances.
No violations or deviations have been identified to date.
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further NRC inspection is plant.ed for this reference item.
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The unresolved item will be closed upon receipt of the
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applicant's acceptable response.
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6.
Corrective Action Program (CAP)
a.
Mechanical (50073)
CPRT evaluation of reinspection results determined that a
special case exists for the configuration of.manway
covers.
This special case resulted in CPRT recommending
that TU Electric incorporate the guidance and
recommendations, as appropriate, from Westinghouse
Technical Bulletin 87-01 into procedures for installing
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manway covers and similar closures on vessels supplied by
the NSSS vendcr.
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The NRC inspector reviewed the revised installation
procedure for the steam generator secondary side manway
closure installation, Mechanical Maintenance Instruction
(MMI) 904, Revision 3 dated October 21, 1987, and
witnessed installation of the Unit 2 steam generator
No. 4, secondary side manway closure.
NRC verifications
included but were not limited to the following:
Compliance with cleanliness requirements established
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by Procedure STA-612.
Compliance with housekeeping requirements
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established by procedure STA-607.
proper completion of work order and quality control
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inspection documentation.
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Compliance with installation requirements
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established by the NSSS vendor.
The NRC inspector noted that MMI-904, Revision 3,
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requires a three-step torque sequence (i.e., 125 ft/lbs,
300 ft/lbs, and 450 ft/lbs).
After the third sequer,ce,
the MMI requires the removal of one bolt at a time,
relubrication, and retorquing to the second incremental
value.
After all of the bolts have been relubricated and
torquing to the second incremental value, the MMI
requires torquing of'the bolts to the third incremental
value.
The NRC inspector questioned project personnel concerning
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the MMI's compliance with the NSSS vendors recommenda-
tions.
Westinghouse Technical Bulletin NSID-TB-87-01
requires the removal, relubrication, and retorquing of
each bolt after the third incremental torque pass.
However, the technical bulletin specifies that the
retorquing after relubrication be performed to the third
incremental value.
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The NRC inspector identified to project personnel that
the MMI, as written, allows a release of torquing
compression on the flexatallic gasket when performing
relubrication and retorquing to the second incremental
value.
This is not in accordance with the Westinghouse
Technical Bulletin or common industry practice and may
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cause leakage around the gasket sealing surface.
Common
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industry practice is to discard and replace flexatallic
gaskets after one full compression has been achieved.
The NRC inspector contacted the mechanical maintenance
engineer responsible for Revision 3 of MMI-904 and was
informed that the requirement to retorque to the second
incremental value after relubrication was probably an
oversight during the procedure revision process.
The failure to provide documented instructions
appropriate to the circumstances and ensure work
activities have been satisfactorily accomplished is a
violation of Criterion V (445/8846-V-01; 46/8844-V-01).
As a result of the NRC inspection finding, the applicant
has issued NCR 88-10921, Revision 0,
to document the
nonconforming flange installations and Deviation Report
(DR) P-88-03387 to document the deficient installation
procedure.
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b.
Conduit Supports A & B Train and C Train > 2" (48053)
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During this inspection period the NRC inspector selected
a sample of 12 modifications to conduit supports in
Room 133 - cable spread room - in the electrical control
building.
These supports were modified as a result of
the design verification phase of the post construction
hardware validation portion of the CAP and had been
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inspected and accepted by QC.
Listed below are the
supports that were inspected:
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IN-C04G31220-51
C13K14134-08
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C14K06416-02
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C15R11114-51
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IN-C13OO7898-52
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C13G13637-01
IN-C15B10771-51
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IN-C02011932-06
2N-C13G16982-51
IN-C12G13056-10
IN-C14Y11219-20
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IN-C13020344-05
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These conduit supports were inspected in accordance with
the detail drawing provided with the design change
authorizations that were issued to craft and
NQA - 3.09-2.03, Revision 3.
Results of the NRC
inspection were compared to the inspection criteria in
Specification 2323-SS-16B, Appendix B,Section III,
"Conduit Supports" and Quality Assurance
Procedure NQA 3.09-10.01, "Requirements for Visual' Weld
Inspection."
The NRC inspection for the conduit supports
listed above resulted in the following discrepancies:
(1)
On support No. IN-C04G31220-51, the drawing locates
this support 4'
- 1" south of the centerline of
column No. 3703, the NRC inspector measured this
dimension to be 3'
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8".
The tolerance for this
measurement, provided in SS-016B, is +/- 3" based on
the tolerance for span lengths.
(2)
Also, on support No. IN-C04G31220-51, the design
drawing requires two flare bevel groove welds and
two 1/4" fillet welds between a section of
3" x 3" structural tubing and the existing
structural framing.
This weld connection is
required at both of the support's connections to the
building structure.
However, the NRC inspector's
review revealed that the 1/4" fillet welds were
missing and this condition was not noted by the QC
inspector.
The failure to adequately document existing
conditions is a violation of criterion V
(445/8846-V-02).
7.
plant Tours (92700)
a.
On June 24 and June 25, 1988, the NRC inspector
accompanied Mr. J. Doyle, a representative of CASE, on a
plant tour of CPSES conducted by the Director of Projects
and other site management personnel.
The purpose of
Mr. Doyle's visit was to tour the plant and related
facilities, view corrective actions resulting from design
and hardware validation, and ask questions related to
implementation and adequacy of those corrective actions.
Management representatives from SWEC, Ebasco, and Impell
presented Mr. Doyle an overview and detailed explanation
of their respective site responsibilities.
b.
The NRC inspectors made frequent tours of Unit 1, Unit 2,
and common areas of the facility to observe items such as
housekeeping, equipment protection, and in-process work
activities.
No violations or deviations were identified
and no items of significance were observed.
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8.
Exit Meetino (30703)
An exit meeting was conducted July 6, 1988, with the
applicant's representativeslidentified in paragraph 1 of this
report.
No written material was provided to the applicant by
the inspectors during this reporting period.
The applicant
~ did not-identify as proprietary any of the materials provided
-to or reviewed by the inspectors during this inspection.
During this meeting, the NRC inspecttrs summarized'the scope
and findings of the inspection.
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