ML20151U932
| ML20151U932 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/22/1988 |
| From: | Livermore H NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20151U907 | List: |
| References | |
| 50-445-88-20, 50-446-88-17, NUDOCS 8805020204 | |
| Download: ML20151U932 (24) | |
See also: IR 05000445/1988020
Text
_ _ _ _ . - _ _ _ _ . _ _ _ _ _ _ . _ _ _
_
__
_ _ _
_
_ _ _
-__
_ _ _ ___ _ __
_ _ _ -
_ _ .
.
' '.
.
.
.
4
APPENDIX B
U.
S. NUCLEAR REGULATORY COMMISSION
OFFICE'OF SPECIAL PROJECTS
NRC Inspection Report:
50-445/88-20
Permits: CPPR-126
50-446/88-17
CPPR-127
Dockets: 50-445
Category: A2
50-446
,
l
L
Construction Permit
Expiration Dates:
L
Unit 1: August 1, 1988
Unit 2: Extension request
submitted.
!
Applicant:
TU Electric
l
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas
75201
!;.
.
Comanche Peak Steam Electric Station (CPSES),
Facility Name:
Units 1 & 2
Inspection At:
Comanche Peak Site, Glen Rose, Texas
.
Inspection conducted:
March 2 through April 5, 1988
l
'
Inspection conducted by NRC consultants:
J. Dale - EG&G (paragraph 2a, 3a, and Sc)
K. Graham - Parameter (paragraph 3b, 5b, 7a and 7b)
P. Stanish - Parameter (paragraph 2b, 4, Sa, and 7c-7f)
l
l
Reviewed by:
FA4((8L 6
M
E
H. E. Livermore, Lead Senior Inspector
'Dat6
,
4-
yDR805020204 880422
ADOCK 05000445
l
g
,
<
,
, ..
<
.
'
<
t
'
.,
.
.
,
,
'
.
.
'
2
t
4
'
~ Inspection SummarN:
'
-
'
Inspection Conducted:
March 2 through April 5,
1988 (Report
'
-
'
50-445/88-20; 50-446/88-17)
,
,.
Areas ~ Inspected:
Unannounced, resident safety inspection of
applicant's actions on previous inspection findings; follow-up on
violations / deviations; Comanche Peak Response Team (CPRT)
issue-specific action plans'(ISAPs); Corrective Action Program
(CAP) for instrumentation and controls, mechanical, and cable tray
and cable tray supports; general plant area (tours); and piping
systems and supports.
Results:
Within the areas inspected, the NRC inspections
identified a relatively strong inspection and design verification
program in place for cable tray supports.
During the inspection,
three violations (failure to control nondestructive examinatica
processes, paragraph 5.b; failure to comply with procedural
requirements, paragraph 5.b; and f ailure to identify and verif:r
undersized welds, paragraph 5.c) and three unresolved iteme were
identifed, paragraphs 7.c, d, and e.
i
e
L
1
i
.
4
.
3
.
.
DETAILS
1.
Persons Contacted
- R.
W. Ackley, Project Manager, Stone & Webster Engineering
Corporation (SWEC)
- R. P. Baker, Licensing Compliance Manager, TU Electric
- D. N. Bize, Licensing Compliance Supervisor, TU Electric
- M. R. Blevins, Manager, Technical Support, TU Electric
- J.
T. Conly, Lead Licensing Engineer, SWEC
- W.
G. Counsil, Executive Vice President, TU Electric
- C. G. Creamer, Instrumentation & Control (I&C) Engineering
Manager, TU Electric
- G.
G. Davis, Nuclear Operations Inspection Report Iteri.
Coordinator, TU Electric
- R. D. Delano, Licensing Engineer, TU Electric
- M. D. Gaden, CPRT, IT Corporation
- T.
L. Heatherly, Licensing Engineer, TU Electric
- R. T. Jenkins, Manager, Mechanical Engineering, TU Electric
- J. J. Kelley, Manager, Plant Operations, TU Electric
- J.
J. LaMarca, Electrical Engineering Manager, TU Electric
- O.
W. Lowe, Director of Engineering, TU Electric
- J. W. Muffett, Manager of Civil Engineering, TU Electric
- L. D. Nace, Vice President, Engineering & Construction,
TU Electric
- D. M. Reynerson, Director of Construction, TU Electric
- M. J. Riggs, Plant Evaluation Manager, Operations, TU Electric
- A.
B. Scott, Vice President, Nuclear Operations, TU Electric
- C.
E. Scott, Manager, Startup, TU Electric
- J.
C. Smith, Plant Operations Staff, TU Electric
- M.
R. Steclraan, CPRT, TU Electric
- J.
F.
Streeter, Director, QA, TU Electric
- T.
G. Tyler, Director of Projects, TU Electric
- R. D. Walker, Manager of Nuclear Licensing, TU Electric
The NRC inspectors also interviewed other applicant employees
during this inspection period.
- Denotes personnel present at the April 5, 1988, exit
meeting.
2.
Applicant Action on Previous Inspection Findings (92701)
a.
(closed) Unresolved Item (445/8513-U-01):
NRC inspection
of cable tray supports identified a generic concern with
'
Richmond insert bolting.
Gaps were detected between the
head of the bolt and the structural angle used es base of
'
the support.
Procedure QI-QP-ll.lC-2 requirce contact
between faying surfaces on bolted connections.
l
i
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ . _ _ _ _ _ _ _ _ _
_
. - _ _
_
.
.
<
.
.
.
..
,
.
.
4
The NRC inspector reviewed QI-QP-11.10-2, Revision 29
'
.
,
dated July 9,
1985, "Cable Tray Hanger Inspection," and
NQI-3.09-M-001, Revision 0 dated October 1,
1987,
'
'
"Modification Rework and 'As-Built' Inspection /
Verification of Cable Tray Hangers in Unit
1."
The
inspector also performed a visual inspection of Cable
Tray: Supports 1-6057, 1-6058, 1-5995 and 1-1973 along
with the related documentation with the following
results:
While QI-QP-11.10-2 requires contact between faying
surfaces, it also gives the acceptance criteria for bolts
that do not have full contact.
Section 3.1.2.9 of
QI-QP-11.10-2, Revision 4 dated July 9, 1985, states, in
part, "Where bolts are used on surfaces having slopes
greater than 1-in-20 with a plane normal to the bolt
axis, beveled olashers shall be provided to give full
bearing to the head or nut."
When the NRC inspector
reinspected the supports in question, he found them to be
within the limits (1-in-20) specified in the procedure.
This item is closed.
b.
(Closed) Open Item (445/8513-0-21):
This item dealt with
Evaluation Research Corporation (ERC) identifying a stud
with loose nuts during the piping flange inspection for
Verification Package I-M-PBOM-048, for flange No. 1 on
Drawing BRP-SW-1-SB-003.
Subsequently, Deficiency Report
(DR) I-M-PBOM-048-DR1 was generated and resulted in the
issuance of Nonconformance Report (NCR) M-23317N dated
May
E.,
1986.
The NCR initially required the reinspection by Brown and
Root (B&R) of the nonconforming condition, loose nuts on
the flange stud.
During the B&R reinspection, the
nonconforming condition identified by ERC and witnessed
by the NRC inspector could not be found;
i.e.,
all of the
nuts on the studs for the applicable pipe flange were
tightened.
The NCR was subsequently voided without
additional action occurring.
The initial NRC review,
documented in NRC Inspection Report 50-445/87-18;
50-446/87-14, of all available documentation associated
with the verification package revealed that there was no
record of work being performed by craft personnel in
which the deficient condition was corrected.
The inspection report in which this open item was
originally identified covered inspections performed
between Augus' 23 and September 30, 1985; and, as stated
above, NCR M-23317N was dated May 8,
1986.
The applicant
reviewed documeatation generated during this time period
and found that ERC had written an out-of-scope
observation on September 6, 1985, reporting this
.
.
.
.
.
'
5
.
.
condition.
In response to the out-of-scope observation,
NCR XI-198 was generated on September 27, 1985,
'
documenting the loose nuts on one stud.
The work
required to correct this situation was performed under a
work order dated October 18, 1985, and inspected on
November 6, 1985.
Therefore, based on the documentation
presented, this nonconforming condition was reported
twice by different inspectors and was closed out properly
'
'
prior to the issuance of NCR M-23317N.
This item is
closed.
3.
Follow-up on Violations / Deviations (92702)
n.
a.
(Closed) Violation (446/8509-V-01):
No identification
number was assigned and no measurement result was
recorded on the QC inspection report for the wall-to-pipe
centerline dimension shown on pipe Drawing
AF-2-006-412-533A dated April 27, 1985.
The applicant's response to this Notice of Violation
stated, in part, "We do not feel that this item is a
violation," and the following reasons were cited.
Section A.2 of Attachment 3 of QI-QAP-11.1-28
(Revision 30 through 32) provides exceptions to the
requirements of Section A.1 which states that "QC shall
assign a number to each dimensional attribute identified
as a specific dimension."
The exceptions are as follows:
"The dimensions related to hanger location / elevation and
angularity dimension related to snubber / sway-strut /
spring-can and structural members shall not be verified
by QCI."
Dimensions related to support location,
elevation, and angularity will be verified by CPSES
engineering per TNE Procedure CP-EI-4.5.1.
The NRC inspector reviewed B&R inspection Procedure
QI-QAP-11.1-28, Revisions 30 through 32,
Drawing AF-2-006-412-533A, reinspected the support
identified on the drawing, and reached the following
conclusion.
The measurement
- entified by this violation is a
location dimens..on relating to the distance from the wall
and, as such, is covered by Section A.2; therefore, this
is not a violation.
This item is closed.
b.
(Open) Deviation (445/8607-D-01):
This deviation
pertains to TU Electric's failure to resolve unacceptable
seismic arrester bracket weld quality on safety-related
Valve 1-FV-2456.
NRC Inspection Report 50-445/88-11;
50-446/88-09 providen additional discussion of this
inspection finding.
'
--
_ _ _ _ _ _ _ _
-.
.
'.
.
6
.
.
NRC management and NRC inspectors met with TU Electric
personnel on March 10, 1988, to discuss resolution of
this issue.
Based upon a review of ASME Code
requirements, the NRC inspection staff believes that
TU Electric's declassification of the pipe support
installations from ASME Section III NF to the current
non-ASME Class 5 designation is inappropriate.
Valve 1-FV-2456 and the piping system in which the valve
is installed are required to meet ASME Section III design
and construction requirements.
Accordingly, the NRC
believes the supports attached to seismic arrestor
brackets on the valve actuators, which also function to
restrain and limit stresses in the piping system, should
be classified as ASME Section III NF component supports.
During this meeting, TU Electric disclosed that during
construction the pipe supports had been inspected to the
requirements of an ASME pipe support installation.
Revision of existing documentation, without performing
any physical rework, would permit the non-ASME supports
to be upgraded to their previous ASME classification.
The NRC inspection staff stated that upgrading these
supports to the ASME classification would resolve any
concern about interpretation of ASME code requirements
for classification of pipe supports.
On March 25, 1988, another meeting was held to discuss
l
the correct classification of the valve supports.
TU Electric stated that a further review of ASME Code
requirements had been performed.
Per paragraph NA-3253 of the 1974 Summer Edition of the
ASME B&PV Code, "The owner either directly or through his
agent, shall establish the code classification of the
items which comprise the nuclear power plant."
,
'
Additionally, several inquiries have been published
regarding the interpretation of jurisdictional
boundaries.
In each of these interpretations the
response has been "the owner is responsible for defining
jurisdictional boundaries of code items."
As applied to
the situation in question, TU Electric has determined the
valve actuator (nonpressure retaining) to be non-ASME.
As such, in accordance with this interpretation, the
rules of ASME B&PV Code.are not applicable, and the
actuator is not considered as an intervening element.
However, the valve actuator and snubber are modeled in
the stress analysis of the Class 3 piping system in
accordance with CPPP-7.
This would, therefore, tend to
indicate that the actuator is an intervening element and
the snubbers and brackets should be considered as part of
an ASME piping system.
To classify the snubber and
__
,
.
'.
.
.
.
7
bracket as av ASME Section III NF component supports
I
would require the N-5 data package to be revised and
potentially require a revision of the N-3 certification.
The owner has determined that the clips supplied on the
actuator by the manufacturer as well as the connecting
welds are of indeterminate quality; therefore, the owner
will remove the existing clips.and welds and replace-with
traceable material installed with qualified welders using
approved welding procedures.
The NRC inspection staff has discussed the classification
of these supports with the Chief Inspector, Boiler
Division of the Texas Department of Labor and Standards,
who is the state enforcement authority pertaining to this
issue.
4.
CPRT ISAPs:
Electrical Conduit Supports (ISAP I.c) (48063B)
1
a.
Evaluation Interaction of Nonseismic Train C Conduit
Greater Than 2" (NRC Reference 01.c.01.00)
l
The CPSES Damage Study Program evaluated all Train C
!
conduit greater than 2" in diameter in Seismic Category I
l
areas and the results of this study are contained in
!
ISAP II.d.
Ebasco has been assigned to evaluate the
l
integrity of Train C conduit and conduit supports greater
I
than 2" as part of their efforts in the CPSES Corrective
Action Program (CAP).
The NRC inspector has reviewed
Field Verification Method (FVM) CPE-EB-FVM-CS-033,
i
I
Revision 2, which demonstrates that there is no
difference in design philosophy for Train C conduit and
conduit supports for conduit greater than 2" from the
approach for safety-related Trains A and B.
Therefore,
this design approach precludes any adverse interaction
with safety-related conduit or equipment.
Inspection of
I
this item is complete.
No violations or deviations were identified.
j
b.
Review of Action Plan Item Number II.d (NRC Reference
01.c.01.01)
The NRC inspector reviewed the subject action plan which
was chartered to assure that the control room ceiling,
including anything attached to it or located above it,
met the requirements of Regulatory Guide 1.29 and FSAR
Section 3.7B.2.8; and that nonseismic structures;
i.e.,
Train C conduit, meet the seismic interaction provisions
Procedures used for the damage
,
'
study (TNE-DC-23 and CP-EI-4.0-63) were reviewed.
The
NRC inspector is satisfied that this action plan
.
[4~
4
.
8
adequately addresses Train C conduit greater than 2" in
diameter.
Inspection of this item is now complete.
No violations or deviations were identified.
c.
Review of 2" and Greater Conduits which had Interactions
(NRC Reference 01.c.01.02)
The-NRC inspector has reviewed the following FVMs:
CPE-FVM-CS033, "As-Built Field Verification Method for
-
Design Control of Electrical Conduit Raceways for Unit 1
Installation in Unit 1 and Common Areas," and
CPE-FVM-CS-014, "As-Built Field Verification Method for
Design Control of Electrical Conduit Raceways for Unit 2
Installation in Unit 1 and Common Areas."
These
procedures, developed by Ebasco, guide the walkdown
verification efforts of the Post Construction Hardware
Validation Efforts (PCHVP) of the CAP for Train A and B
conduit and Train C conduit larger than 2".
The walkdown
data obcained through the inspections performed to these
procedures forms the input to Ebasco's design
verification efforts.
The design verification effort of
the CAP insures that this conduit and its supports will'
maintain its integrity during all postulated plant
events.
NRC inspection efforts are closely following the
efforts in this area by Ebasco to ensure compliance with
the applicable CAP procedures.
Therefore, in light of
the fact that the design approach precludes failures.
There will be no adverse interactions between Train C
conduit and safety-related commodities. Therefore,
interactions have been adequately addressed.
Inspection
of this item is completed.
No violations or deviations were identified.
d.
Selection of Random and Engineering Sample of 2" and
under Conduit Runs (NRC Reference 01.c.02.00)
The CPRT has identified 126 conduit runs in their random
sample and 131 conduit runs in their enginaered sample.
The engineered sample was selected from runs with highest
probability for failure (i.e.,
largest diameter, etc.).
The NRC inspector has reviewed the procedures for
selection of the two samples to assure compliance with
the CPRT program plan.
This program has been included in
the CAP and is reported in a separate Project Status
Report (PSR).
Inspection of this item is complete.
No violations or deviations were identified.
.
'
r..
.
w
.
.
9
s
e.
Population and Sample (NRC Reference 01.c.02.01)
The population of 2" Train C conduit and under is
approximately 13,500 conduit runs, which is broken down
as follows:
3/4" diameter - 55%; 1" diameter - 17%;
,
1 1/2" diameter - 19%; 2" diameter - 9%.
A random sample
was. selected from the two larger diameter populations
which represents approximately 3700 conduit runs.
A
sampla plan, consistent with CPRT requirements, selected
126 runs.to be. evaluated with a detection number of 2,
(i.e., The critical region is 3 or more deficiencies
found in the sample.)
In addition, an engineered sample
as discussed above was selected based on specific
"
criteria in an effort to identify those conduit runs
expected to exhibit more limiting behavior during a
seismic event.
Based on the NRC inspector's review of
the sampling procedures presented, the inspector is
satisfied that the sample selected is representative of
the entire population.
Therefore, inspection of this
item is complete.
No violations or deviations were identified,
f.
As-Built Physical Configuration Documentation (NRC
Reference 01.c.02.02)
Field verification of the installed conduit was performed
by Comanche Peak Project Engineering (CPPE) with a
third-party overview, in accordance with Engineering
Instruction CP-EI-4.0-64, "Field Verification of 2"
Diameter and Smaller Train C Conduit Support Systems."
The NRC inspector's review of the procedure revealed that
this procedure-complies with Appendix D of the CPRT
'
program plan, and the inspector is satisfied that the
required attributes are adequately addressed.
Inspection
of this item is complete.
l
No violations or deviations were identified.
Seismic Analysis and Acceptance Criteria (NRC Reference
g.
01.c.02.03)
The intent of this analysis is to provide quantitative
evidence that the conduit support system will perform its
'
intended function;
i.e., ensure the conduit does not fall
and cause an adverse intoraction with a safety-related
item.
The analysis method used was the same as was
applied to Seismic Category II support hardware.
The NRC
inspector reviewed the method of analysis and acceptance
l
criteria and is satisfied that the conduit and supports
being evaluated will be adequately addressed to ensure
. . . - ..
. _ _
_
. - -
_ - _ _ - _ _____ _-_ _ - -__ _ -_ _ _ _
-
.,
'
,
.
10
there will be no adverse interactions.with safety-related
equipment.
Inspection of this item is complete.
No violations.or deviations were identified.
h.
Damage Analysis (NRC Reference 01.c.02.04)
All selected runs were considered'for interaction with
safety-related targets due to sway or possible fall when
a run failed to meet support performance requirements.
The NRC inspector has reviewed Impell's project
instructions related to identification of safety-related
targets, establishing zones of influence for a potential
source commodity, and method for determining adverse
interactions and is satisfied that they represent a
comprehensive plan, with several levels of screening for
potential interactions, detailed calculation methods,
detailed ~rowork procedures, and record turnover
instructions that will ensure that all potential
interactions are identified and satisfactorily resolved.
Inspection of this item is complete.
No violations or deviations were identified.
-
1.
Population A'cceptance Criteria (NRC Reference 01.c.02.05)
Acceptance criteria requires that all identified
interactions be evaluated and that any conduit run
predicted t'o cause damage to a safety-related target be
considered deficient.
The NRC inspector reviewed the
method for accepting the entire population in light of
the above definition of a deficient condition and found
that it is consistent with a standard statistical
sampling procedure such as MIL-STD-105D.
Furthermore,
dispositions of deficient conditions are addressed
properly and the proposed corrective actions, rcdesign of
supports or rerouting of conduit are deemed satisfactory.
pection of this item is complete.
'
No violations or deviations were identified.
{
j.
Installation Quality Review (NRC Reference 01.c.02.06)
The NRC inspector has reviewed the varic w projec
instructions written by Impell - ich cover field
verification of the attributes neccssary ror the input to
their design verification efforts.
This data was
partially generated through a revaew of the quality
documentation generated during inspection of the initial
installation.
Based on this review, design verification
methods were established to ensure the integrity of any
Irain C conduit 2" in diameter and smaller which had a
,
_
_
' , .
n
,
. .
.
'
.
.
11^
,
potential adverse interaction with safety-related-
equipment.
Based on the NRC review of Impell's design
verification efforts, the NRC inspector is satisfied that
>
the methods used are conservative with respect to data
.
obtained from quality reviews.
NRC inspection on this
item is complete.
No violations or deviations were identified.
k.
Issuance of Results Report (NRC Reference 01.c.07.00
The Results Report for ISAP I.c has been issued and dated
October 28, 1987.
This report covers the actions
performed in response to NRC concerns relative to Train C
(nonsafety-related) conduit and its potential for adverse
impact on safety-related equipment.
Issuance of the
Rest 11ts Report completes this item.
The Results Report
will be reviewed in detail and reported on at a later
date.
No violations or deviations were identified.
5.
Corrective Action Plan (CAP)
NRC inspections were parformed to verify the applicant's
activities associated with the PCHVP.
The PCHVP was
established to reconcile the design to the appropriate design
bases for satisfying licensing commitments, and to reconcile
the harduare to the design;-i.e., the constructed / installed
systers meet the intent of the design.
The following CAPS
,
were inspected during this report period:
a.
Instrumentation and controls (52053)
t:
In this inspection period the NRC inspector reviewed
'
Procedure CPE-SWEC-FVM-1C-059, Revision 2, "Field
,
Verification Method Safety /Non-Safety Related
i
j
Instrumente.t'.on and Tubing Connected to ASME III Fluid
Systems and ANSI Safety Class Installations."
This FVM
, describes the engineering program for verifying and
l
ensuring that the installation of safety and
nonsafety-related instrumentation, tubing and related
supports connected to ASME III fluid systems, or ANSI
safety-class installations is in accordance with Project
Specification CPES-I-1018, Design Basis Document
DBD-EE-035 and Project Drawings 2323/ECE-I-001 and
2323-I-002 series.
The tasks described will be performed
by SWEC.
The walkdowns performed as part of the design
verif. cation are being performed by teams of engineers
f rom SWEC-CAP Engineering 11echanics Division ( EMD), and
l
!
,
+
-
- -,
- , , - . , . - , . .
_
_ _ _ _
_ _ _ _
'
,
12
.
the SWEC-cap Instruments and Control Division (I&C).
This FVM outlines responsibilities, defines applicable
codes, licensing documents, industry standards, project
specifications, design criteria documents, project
proceduros and. drawings, and design standards.
In
addition, it provides the detailed checklists ensuring
that all attributes necessary for design verification are
adequately addressed.
The NRC inspector selected walkdown Package
1634501-1-LT-932-(IWP)-190, Revision 0 dated December 16,
1987, for System 4800 in order to assess SWEC's
implementation of the above FVM.
This was done by
performing a walkdown/ inspection of this instrument loop
in accordance with FVM-069.
Items inspected by the NRC
inspector included instrument data, tubing data, tubing
layout, location of fittings, support evaluation,
instrument stands and disposition of unacceptable items.
During the NRC walkdown, several items appeared to differ
from the data reported by SWEC's walkdown personnel.
However, further review of project documentation;
i.e.,
NCRs, component modification cards (CMCs), design change
authorizaticns (DCAs), etc., revealed that all
identified, apparent discrepancies, in fact, had been
previously identified and properly dispositioned in
accordance with project procedures.
Immediate
determination that visual discrepancies had previously
been identified was not possible as TU Electric does not
hang tags on discrepant items.
No violations or deviations were identified.
b.
Mechanical (49063)
The CPRT reviewed historical revisions of procedures
related to piping bend fabrication.
The CPRT review
determined that the pipe bending procedure could cause
thinning af the pipe wall thickness to less than ASME
Section III code requirements after completion of the
bending process.
To resolve this issue, all safety-related pipe bends
performed at CPSES are being inspected to verify
acceptable minimum post-bend wall thickness.
Quality
control procedures require an ultrasonic digital
thickness measurement of these site fabricated bends.
The NRC inspector has reviewed the following B&R ASME
quality. procedures which provide the required
verification action for pipe bends:
- s-
..
4
, . -
-
.
.
,
13
.
,
'AQP-ll.5 _ASME Component Installation Verification
.
. .
AQP-l*_.2
Fabrication and Installation Inspection of
Pipe Equipment
AQP-10.9
Ultrasonic Digital Thickness Measurement
.
The NRC. inspector reviewed the training files and records
for two of the B&R QC inspectors involved with. inspection
of-the site-fabricated pipe bends.
Training files and
records were determined to be current and complete.
The NRC inspector witnessed the B&R QC inspection of the
follouing two pipe bends:
Piping Isemetric
Pipe
Drawing No.
Spool No.
Material
Size
BRP-WP-X-AB-041 R/CP-2
lQ3
Stainless Steel
2"
Schd.40
BRP-WP-X-SB-014 R/CP-1
1Q2
Carbon Steel
3/4"
Schd.40-
The NRC inspector reccrded the following measuring and
test equipment (MTE) identification numbers, which were
being used by the QC inspectors daring performance of the
ul*rasonic digital thickness measurement, and determined
that calibration standards and controls were in
compliance with procedural requirements:
calibration
~~
Equipment Description
Serial No.
Due Date
Stress Tel T-Mike
MTE-5006
4/14/88
Carbon Steel Calibration
MTE-2043
4/22/88
Block
Stainless Steel Calibra-
MTE-2054
5/5/88
tion Block
While witnessing the QC inspection of the pipe bend
located on B2P-WP-X-SB-014, the NRC inspector noted that
the ultrasonic (UT, thickness measurement was being
performed through paint which had been previously applied
to the piping surface.
The failure to remove paint prior
to performing the UT inspection creates an error in the
measurements recorded by the QC inspector due to the
differ (nces in UT sound velocity.
Paint and the piping
material (carbon steel) have different UT sound
velocities.
In addition to this error, the thickness of
the paint had not been determined, recorded, and
subtracted from the QC recorded thickness dimension.
The
NRC inspector has determincd that Procedure AQP-10.9 is
inadaquate as implemented in that it does not require the
__
r~ -
. -
Ea
,
f. '
P
14
+
removal of paint from the examined surface.
Furthermore,
the UT calibration process is not representative of
actual field conditions.
The UT calibration block used
by the QC inspector does not have paint applied to its
surface.
Failure to control nondestructive examination
processes is a violation of Criterion IX
(50-445/8820-V-01; 50-446/8817-V-01).
While witnessing the QC inspection of the pipe bend on
Spool 1Q3 of Piping Isometric BRP-WP-X-AB-041, the NRC
inspector observed the QC inspector marking the stainless
steel pipe surface with ballpoint pen ink in order to
identify the areas where UT thickness measurements are
performed.
B&R ASME Quality Procedure AQP-10.7,
"Nondestructive Examination Marking Requirements,"
approves only the use of Nissen ink markers and Marsh
stencil ink markers for temporary marking of stainless
sreel surfaces.
This procedure does not approve the use
of any other type of ink marker.
Adherence to these
procedural requirements is necessary to prevent an
unacceptable stainless steel surface Halogen
contamination level which could change the mechanical and
chemical characteristics of the htateria) .
The failure to
comply with procedural requirements is a violation of
Criterion V (50-445/8820-V-02; 50-446/8817-V-02).
As a result of the NRC inspection findings, the applicant
issued Corrective Action Request (CAR)88-019 dated
March 25, 1988, to document that ASME Quality
Procedures AVP-11.5 and AQP-10.9 do not address UT
thickness measurements through paint.
This CAR resulted
in Stop Wc':k order (SWo)88-008.
NCR 88-05684 was issued
to document the use of an unapproved marker on a
stainless steel pipe surface.
The CPRT is responsible for overviewing the correctivz
actions resulting from CPRT findings.
In order to assure
that corrective actions are being effectively
implemented, CPRT overviews are required to be performed.
Discussions with project personnel indicate that
verification of proper implementation will be
accomplished by performing activity overviews and audits
of the TU Electric Technical Audit Program (TAP) and the
Engineering Functional Evaluation (EFE).
The NRC inspector contacted the TAP supervisor and
obtained a copy of the piping bend fabrication audit,
ATP-87-539, which was performed November 16 to
December 8, 1987.
The audit objective was to evaluate Comanche Peak
Engineering, SWEC, and B&R corrective actions taken in
_
_
_
__-__ __- ___ ._- _
.
-
'
. .
q,
.
15
response to ISAP VII.c, Results Report,. Revision 0,
Appendix 10, "Piping Bend Fabrication."
A checklist
' work' sheet: for the following three objectives was
completed by the auditors:
1.'
_ Verify that an adequate CAP exists for each
commitment audited.
.2.-
Verify that the CAP for the commitment has been
,
effectively implemented.
3.
_ Verify that the corrective action for the commitment
-
-has been properly documented in QA records.
The NRC inspector has reviewed the results of' TAP
'
Audit ATP-87-539 and found that this audit did.not
' identify any concerns relative to performr.nce of the UT
digital thickness measurements through paint primer and
paint, which creates error in the QC recorded thickness
measurements.
The NRC inspection staff will perform
additional evaluations of the effectiveness of the TAP in
a subsequent inspection report.
This activity is an open
item (50-445/8820-0-03).
c.
Cable Tray and cable Tray supports (48053)
The cable tray / cable tray support portion of the CAP was
initiated with the following objectives:
Demonstrate that the design of safety-related
.
systems, structures and components complies with
licensing commitments.
Demonstrate that existing systems, structures, and
.
components are in compliance with the design
requirements or develop modifications which will
bring systems, structures, and components into
compliance with design requirements.
Develop procedures, an organizational plan, and
.
documentation to maintain compliance with licensing
commitments through the life of CPSES.
The Cable Tray and Cable Tray Hanger Project Status
Por7rt (PSR) describes the validation effort, traces the
updating of design / installation specifications and the
construction /QC procedures.
The NRC inspector has
performed a preliminary review of these procedures and
will evaluate their adequacy during future inspections.
The implementing procedures were evaluated to determine
whether:
,
.-
.
'.
,
'
.
16
Means have been established to ensure that any
.
design and field changes from approved drawings are
controlled and processed commensurate with the
original design control activities.
=
Procedures and instructions have been approved and
.
means established to ensure that quality
requirements are met.
i
The NRC inspector performed documentation reviews and
field inspections of the following cable tray supports to
determine the adequacy of the applicant's installation
and QC records.
The supports had been completed by
construction and bought-off as complete by inspection.
Support
Location
Unit
CTH-1-01336
Reactor bldg.
1
CTH-1-06537
Reactor bldg.
1
CTH-1-06538'
Reactor bldg.
1
CTH-1-06539
Reactor bldg.
1
CTH-1-06544
Reactor bldg.
1
CTH-1-06550
Reactor bldg.
1
I
CTH-1-06555
Reactor bldg.
1
CTH-1-06560
Reactor bldg.
1
CTH-1-12057
Reactor bldg.
1
CTH-1-00820
Safeguards bldg.
1
CTH-1-01317
Safeguards bldg.
1
CTH-1-02008
Safeguards bldg.
1
CTH-1-02470
Safeguards bldg.
1
CTH-1-06974
Safeguards bldg.
1
CTH-1-06978
Safeguards bldg.
1
CTH-1-07129
Safeguards bldg.
1
l
CTH-1-01345
Auxiliary bldg.
1
CTH-1-01616
Auxiliary bldg.
1
CTH-1-01916
Auxiliary bldg.
1
'
CTH-1-01950
Auxiliary bldg.
CTH-1-02804
Auxiliary bldg.
CTH-1-02825
Auxiliary bldg.
1
CTH-1-07279
Auxiliary bldg.
1
CTH-1-01711
Fuel handling bldg.
1
CTH-1-01735
Fuel handling bldg.
1
CTH-1-01741
Fuel handling bldg.
1
UTH-1-01957
Fuel handling bldg.
1
CTH-1-02010
Diesel generator bldg.
1
CTH-1-02013
Diesel generator bldg.
1
CTH-1-02038
Diesel generator bldg.
1
NRC inspection of Cable Tray Supports CTH-1-06537 and
l
CTH-1-12057 identified three undersize welds, weld No. 2NS 7A
and 7B, respectively.
All three welds were undersize by 1/16"
,
to 1/8" for the full length of the weld.
l
l
[
..
.
.
,
17
TU Electric Procedure QI-QP-11.10-9, "Visual Weld Acceptance
Criteria for Structural Welding at Nuclear Power Plants,"
states that a weld can be undersized by 1/16" for 25% of its
length.
AWS Dl.1 criteria states that if member separation is
greater than 1/16", the fillet weld size will be increased by
the amount of-the separation.
The three subject welds were
undersize for 100% of their length.
This failure to identify
and verify the undersize welds is a violation of
Procedure Ql-QP-11.10-9 and its applicable acceptance ;riteria
(445/8820-V-04).
The NRC inspector notes that a total of 408 welds were
inspected for approximately 2500 attributes with only
3 attributes found to be incorrect.
The NRC inspector was
impressed with the quality-of both the documentation and the
physical work he inspected in cable tray supports.
6.
Plant Tours (92700)
The NRC inspectors made frequent tours of Unit 1 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.
7.
gj. ping Systems and Supports (50090)
)
a.
During this inspection period, the NRC inspector
performed tours of various areas of Unit 1 to verify
control of activities related to welding of pipe supports
on the evening shift.
The NRC inspector interviewed five B&R welders, welder
symbols CUX, CUW, BZR, CSU, and BDB, to determine their
knowledge of work control requirements.
All welders
interviewed were cognizant of applicable requirements.
The NRC inspector noted that a copy of the welding
procedure specification (WPS) which defines all welding
parameters was issued with the weld filler material and
attached to the weld filler material storage container
for use by the welder.
The NRC inspector recorded the welder's symbol
designation, weld procedure specification number being
used, heat code of weld filler material being used,
serial number of filler material storage container, and
calibration due date of filler material storage
container.
Weld filler material is not issued to a
welder unless the welder is certified to the WPS
specified in the construction operation traveler, and the
welder's certification is current.
The NRC inspector
compared the recorded information with records which are
,
-
_ __ ____ _______
O
.
.
.
,
.
.
18
maintained at the weld filler material issue location.
NRC inspection determined that the welders interviewed
were certified to the WPS being used and that weld filler
material control was in compliance with project
procedures.
No violations or deviations were identified.
b.
During a CPRT related inspection of the installation of
Unit 1 containment spray system box-frame supports
(reference NRC Inspection Report 50-445/85-14;
50-446/85-11), the NRC inspector observed that clearances
exist between the pipe and the pipe support, indicating
that the pipe support was not supporting the piping
system.
Project inspection procedures permit a maximum
of a 1/8" gap to exist between the bottom of the pipe and
the pipe support.
The gap conditions identified above
increase loading on adjacent pipe supports and increase
stresses on the piping system.
The conditions identified above have been addressed by
SWEC as a part of the design requalification program for
piping and pipe supports.
SWEC has performed
Calculation GENX-255 to determine the effect of
deadweight gap on pipe stresses and pipe supports.
The
SWEC calculation evaluated the potential increase in
piping stress and support loads for various enveloping
cases.
For pipe stress, the potential increase due to
the gap was found to be 12 %.
For the specific case of
the containment spray header supports where several
box-frame supports exist adjacent to one another, SWEC
has determined that each support is capable of
withstanding the edditional dead weight of the piping
assuming two consecutive suppcrts are missing.
The SWEC
report found that all the containment spray supports have
a minimum safety factor of three to their designed dead
load without exceeding ASME Code requirements.
Thus, the
safety margin ensures that the 1/8" gap between the
bottom of the pipe and the support will not cause an
overstress of the pipe and pipe supports.
The NRC inspectors have reviewed SWEC Calculation
GENX-255 dated October 26, 1887, and found the evaluation
to be adequate and concur with the conclusions reached.
On a plant tour the NRC inspector observed that there
c.
were no washers under the bolt head on the mechanical
shock arresters which were assembled using high strength
bolting.
Paragraph NF4724 of ASME Section III,
subsection NF, states that high strength structural
bolting will be tightened to a torque value not less than
that given in the design specification; and, further,
that if the tightening is performed by means of a
calibrated wrench that a hardened washer should be used
1
x
Q
',
.4
19
' under the bolt head in'this application. .The code uses
the word "structural" in this paragraph; however, since-
- Subsection NF is-not a structural code, the apparent
implication is that hardened washers should be installed
when utilizing what would normally be considered as a
high strength-structural bolt _within the jurisdictional-
boundaries of this subsection.
Review of the design
m
specification reveals that there are no torque values
given for several of the high strength bolt sizes used in
this particular application.
This_ item was discussed
with the utility and contractor personnel who felt since
these bolts were not being used in a classically defined
structural capacity that NF4724 is not applicable;
however, they committed to request.a code _ interpretation
of this paragraph relative to this particular
application.
This item will remain unresolved pending
receipt and acceptance of the code committee
Einterpretation (445/8820-U-05).
'
u
On one-of two material certifications reviewed by the NRC
d..
inspector in an~ attempt to identify the bolt material
e
<
<
used for' assembling mechanical shock arrester assemblies,
-
Nuclear Power Services, Inc. (NPSI), the vendor for these
units, supplied a certificate of compliance stating that
the bolt material was SA-307-GR.A.
SA-307-GR,A was not
'
added;t'o Section III, via Code Case N-249, until 1985;
1
i
however NPSI's certification was dated in 1981.
Again,
discussing this with the applicant, it was stated that
'
ASTM-A307-GR.A appeared in the code, Code Case 1644-2, in
1975 and in accordance with the requirements in NA-1220
the SA-307-GR.A would be acceptable.
However, NA-1220
states, in part, "Materials produced under an American
Society for Testing and Materials (ASTM) designation may
be accepted as complying with the corresponding ASME
specification provided the ASME specification is
designated as being identical with the ASTM specification
for the grade, class, or type produced and provided that
the material is confirmed as complying with the ASTM
specification by a Certified Mill Test Report or
"
Certification from the Material Manufacturer .
. . .
The code appears to allow substitution of ASTM material
for AGME materials, but the rev nse of this is not
addreseed; further, the certificate of compliance for the
material was supplied by NPSI who is not the material
manufacturer of the bolting material.
This item will-
remain unresolved pending further review by the applicant
(445/8820-U-06).
1
e.
As a result of documentation reviews, the NRC inspector
observed that for structural frames and mechanical shock
arresters the effects of seismic accelerations have been
included in the evaluation of allowable stresses and
>
1
-
-
-
-
-
- -
.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
,
.
.i
.
-
20
loadings.
However, for rigid sway struts this type of
evaluation apparently has not been performed and the NRC
inspector has observed that there are several very long
struts being utilized (installed) in the plant.
Inclusion of the self weight excitation in the evaluation
of these compression members may reduce their rated
capacity.
The applicant has requested that SWEC evaluate
the impact, if any, of this concern on the struts being
used on the site.
This item will remain unresolved
pending completion of SWEC's evaluation (445/8320-U-07).
f.
On March 4, 1988, a meeting was held between members of
NRC Office of Special Projects, TU Electric, SWEC, and
NPSI to discuss concerns relative to snubber
installations and supports in general.
The items
discussed were:
(1)
Clearances on end attachments of snubber.i and struts
The concern is that excessive clearances would
adversely effect the stiffness of these items and
i
that change may impact the piping analysis; also,
that impact loads due to excessive clearances may
impair operability of the snubbers.
TU Electric
presented arguments to show that the existing
conditions are acceptable from a piping analyais
standpoint.
This is based on a parametric study
previously performed which concluded that changes in
,
stiffness have minimal effects on system response
and support loads until the change in stiffness
exceeds an order of magnitude.
The applicant will
provide the NRC with a copy of this study for
further review.
As for the effects of the impact load on the
,
l
snubber, the applicant stated that this is
conceptually similar to the manner in which loads
are applied to a box-frame type restraint assembly.
However, the NRC inspector stated that there have
been instances where mechanical shock arresters have
been damaged (broken' by the impact caused by
dropping the units on end and that this is similar
!
to the loading caused by excessive clearances in the
end connections.
The applicant committed to pursue
this matter further with pacific Scientific, Inc.
(PSI), the manufacturer of the shock arrester base
units to get their concurrence that this condition
is acceptable.
Also, all dual snubbers are being
ir.spected for end clearances per the latest
requirements of NUREG-0800 (SRP), Section 3.9.3.
Those not in compliance will be replaced.
This item
was previously reported in Inspection
.
-
-
_
-,
u
-
[a,
-
.
21
Report 50-445/88-11; 50-446/88-09 and will'be
tracked as 445/8811-U-03.
~
(2)
PSA 35 and 100 snubber adaptors not torqued into
snubber body
The concern is that by not preloading this
connection that the units installed on site are not
representative of PSA qualification units.
The
applicant stated that these units are in compliance
with the CPSES specification and, as above, the
change in stiffness will not have a significant-
impact on the piping analysis.
The same actions
will be taken on this item as in Item 1 above.
This
item was previously reported in Inspection Report
50-445/88-11; 50-446/88-09 and will be tracked as
445/8711-U-04.
(3)
Preloads applied to A307 bolts in transition kits
for mechanical shock arrester
The concern is that the installation procedure for
these units uses the torque values specified by PSI;
however, PSI only uses high strength bolts in this
application.- At these torque values, the induced
tensile stress in the bolt exceeds code allowable at
room temperature and yield strength at design
temperature.
Also, A307 will not hold the preload
which will effect the stiffness of the units.
The
applicant stated that to increase the design margins
for these assemblies the A307 bolts will be replaced
by high strength bolting and will advise the NRC
when this program commences and is complete.
The
response to stiffness concern is similar to the
response in Items 1 and 2.
This item was previously
reported in Inspection Report 50-445/88-11;
50-446/88-09 and will be tracked as 445-8811-U-05.
(4)
Evaluation of local stresses in wide flanges
The NRC inspector had reviewed three SWEC
calculation packages and found that in each case the
engineer did not check all the local stresses (i.e.;
flange bending and web crippling) as required by
CPPP-7, Revision 3.
In response to this item,
DR-C-88-01165- was issued.
SWEC sampled 1200
calcalations; of these calculations, 15 of the
supports had wide flanges.
In addition to the
calculations identified by the NRC, four
calculations had not evaluated both web crippling
and flange bending.
SWEC performed the necessary
calculations and determined that all seven supports
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
'
q_
,
'
.
J*
.
-
'
~
22
.
were-acceptable as designed.
SWEC committed to
emphasize these attributes in'CPPP-7, Revision 4,
training and to add checklist items to the final
reconciliation checklist to cover these items.
Th!.s
-item was previously reported in Inspection Report.
50-445/88-11; 50-446/88-09 and will be tracked as
445/8811-U-02.
- (5)
Sway Strut CS-1-912-001-SS2R which appeared to have
excessive play in the threaded connection
,
Further evaluation by the applicant revealed that
the play was well within the tolerances allowed by
the code.
(6)
Dents in dust cover for the constant support on'
MSl-001-001-c72S
The concern was that the damage caused to the dust
cover may have also damaged the spring coil and was
thus not fully evaluated.
The applicant is in the
'
process of issuing an additional NCR to obtain a
.
complete evaluation.
(7)
Snubber design temperature on NPSI Certified Design
Report Summary (CDRS)
PSI's design reporg for these units lists a design
temperature of 300
Fahrenhgit and NPSI's C'DRS gave
a design temperature of 350
Fahrenheit.
(This was
not a site concern since there are no postulated
g
operating conditions which exceed 300
Fahrenheit.)
NPSI stated that this was the temperature that
appeared on Revisions 0 and 1 of their CDRS (which
PSI does reference in their des?.gn specification,
but limits exposure time to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />).
NPSI stated,
based
n their discussions with PSI, tgeydecidedto
reduce their design temperature to 300
Fahrenheit.
This was done on Revision 2 of their CDRS issued on
J.ugust 1, 1983.
Therefore, the revised CDRS is
consistent with the manufacturer's data and is
considered to be acceptable.
(8)
Preloaded bolts on snubbers with no hardened washers
The applicant's response to this item was that since
the design specification did not require these bolts
to be proloaded that the torque applied is for
workmanship only; therefore, it is not necessary to
use hardened washers.
Also, these bolts are not
"structural" bolts.
However, since the bolts they
are going to install are high strength, the
,
t
-
+
-
. _ - - __
_
. - _ - - -
--
_
- - _ - - - -
a ao
j-
3
,
,.
.
..
23
applicant committed to investigate whether a code
interpretation exists to cover this item. .If not,
they will pursue one and they further committed ~to
abide by the result.
(9)
Material-certification
The concern was that the NRC inspector reviewed two
certificates'of compliance for bolt material and
found apparent inconsistencies in each.
On one, the
bolt material was certified to ASTM-A307-GR.B which
is not in the code.
However, the applicant advised
that NA-1220 allows the use of ASTM materials
provided the ASME specification is designated as
identical to the ASTM specification.
The other
example was bolting that was certified to
SA-307-GR.A in 1981; this material was added to the
code in 1985.
They stated that ASTM-A307-GR.A was
in Code Case 1644-2 in 1975; therefore, the material
was acceptable.
However, since the code allows
going from ASME material to ASTM, it does not
specifically allow going from a code case material
to a ASME material; therefore, the. applicant
committed to do further investigation.
Also, the
applicant will research when SA-307-GR.A was
included in St?'. ion II of the ASME Code.
(10) Side loads on sway struts
i
The NRC inspector-brought up the fact that NPSI has,-
in their CDRs, addressed side loads on snubbers due
to seismic accelerations in the axis perpendicular
to the snubber.
SWEC in their evaluation of
structural members used as pipe supports / restraints
evaluates the effects of seismic acceleration 1 cads
due to the self-weight of the members.
Therefore,
the NRC inspector asked how this was evaluated for
sway struts.
In response to this, the applicant has
requested SWEC to perform an evaluation of whether
this needs to be evaluated for the comanche Peak
Project.
8.
Unresolved Items
Unresolved items are matters abour which more information is
!
rcquired in order to ascertain whether they are acceptable
items, violations, or deviations.
Three unresolved items
disclosed during the inspection are discussed in
paragraphs 7c, 7d, and 70.
.
i
__
L (U\\ ' [
Iil<;
'
~[
s
'
'
,,
"f'.'
g :oi
I*
-
-
,
-
.
24
,
9.
Open Items
open items are matters which have been discussed with the
applicant, which will be reviewed further by the inspector,
and which involve some action on the part of the NRC or
applicant or both,
one open item disclosed during the
inspection is discussed in paragraph 5b.
10.
Exit Meetino (30703)
An exit meeting was conducted April 5, 1988, with.the
applicant's representatives identified 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 inspectors summarized the scope
and findings of the inspection.
.
O
_
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _