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Insp Repts 50-445/88-46 & 50-446/88-44 on 880608-0706. Violations Noted.Major Areas Inspected:Followup on Violations/Deviations,Nrc Compliance Bulletin 87-002 & Stated Team issue-specific Action Plans
	ML20151F292
Person / Time
Site:	Comanche Peak
Issue date:	07/22/1988
From:	Livermore H; NRC OFFICE OF SPECIAL PROJECTS
To:	;
Shared Package
ML20151F278	List: ML20151F276; ML20151F284; ML20151F292;
References
	50-445-88-46, 50-446-88-44, IEB-87-002, IEB-87-2, NUDOCS 8807270018
	Download: ML20151F292 (10)
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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

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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)

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Reviewed by: NML l-12-8 6

H. H. Livermore, Lead Senior Inspector Date

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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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l. 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

b Corporation, (SWEC).

W. G. Counsil, Executive Vice President, TU Electric

G. G. Davis',-Nuclear Operations Inspection Report Item

. Coordinator, TU Electric

D. E. .Deviney, Deputy Director, QA, TU Electric

W. G. Guldemond, Executive Assistant, TU Electric .

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

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

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The NRC inspectors also interviewed other applicant employees

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 L

j 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

l Section IX Code.

l 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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demonstrated a similar reject rate, resulted in the issuance

of this NRC compliance bulletin..

The bulletin required the applicant to provide a description

i 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

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supporting information and~any safety-significance evaluations

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that were required, were to be reported to the NRC.

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-

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related applications are receipt inspected, controlled, stored

! and issued from stock in accordance with applicable codes,

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

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. .

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

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manufacturer of the t*?ves in question explaining the basic

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differences in the manufacturing process and of material

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. No

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further NRC inspection is plant.ed for this reference item.

i The unresolved item will be closed upon receipt of the

! 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

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Technical Bulletin 87-01 into procedures for installing

manway covers and similar closures on vessels supplied by

the NSSS vendcr. -

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

by Procedure STA-612.

r . Compliance with housekeeping requirements

established by procedure STA-607.

. proper completion of work order and quality control

inspection documentation.

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. Compliance with installation requirements

established by the NSSS vendor.

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The NRC inspector noted that MMI-904, Revision 3,

i 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.

3 The NRC inspector questioned project personnel concerning

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

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Technical Bulletin or common industry practice and may

cause leakage around the gasket sealing surface. Common

3 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.

! 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

! inspected and accepted by QC. Listed below are the

supports that were inspected:

l IN-C04G31220-51

C13K14134-08

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C14K06416-02

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l IN-C13OO7898-52

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IN-C15B10771-51

IN-C02011932-06

2N-C13G16982-51

IN-C12G13056-10

IN-C14Y11219-20

l 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' -

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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