ML20151X331

Insp Repts 50-445/88-51 & 50-446/88-47on 880707-0802. Violation Noted.Major Areas Inspected:Applicant Actions on Previous Insp Findings,Followup on Violations/Deviations & Followup on NRC Compliance Bulletin 88-006

ML20151X331
Person / Time
Site:	Comanche Peak
Issue date:	08/19/1988
From:	Livermore H NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20151X318	List: ML20151X315 ML20151X325 ML20151X331
References
50-445-88-51, 50-446-88-47, IEB-88-006, IEB-88-6, NUDOCS 8808250325
Download: ML20151X331 (22)

See also: IR 05000445/1988051

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APPENDIX B

.U. S. NUCLEAR REGULATORY COMMISSION

OFFICE OF SPECIAL PROJ."CTS

NRC Inspection Report: 50-445/88-51 Permits: CPPR-126

50-446/88-47 CPPR-127

f.o Dockets: 50-445 Category: A2

50-446

Construction Permit

Expiration Dates:

E Unit 1: Extension request

submitted.

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

Inspection At: Comanche Peak Site, Glen Rose, Texas

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Inspection Conducted: Ju y 7 through 1.ugust 2, 1988

Inspector:

1. / "E-UM t^ h- - 8 - l #I - 96

H. H. Livermore, Lead Senior Inspector Date

Inspection conducted by NRC consultants:

.. J. Dale - EG&G (paragraph 2.a, 3.a, and 6)

K. Graham - Parameter (paragraph 2.b, 3.b-c, 4, and

7.a)

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P. Stanish - Parameter (paragraph 3.d-g, 7.b and c)

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Reviewed by: '

144 C'? t_ 8-IT- 88)

H. H. Livermore, Lead Senior Inspector Date

0325 880819

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Inspection Summary:

Inspection Conducted: July 7 through August 2, 1988, (Report

50-445/88-51; 50-446/88-47)

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-88-06;

allegation follow-up; Comanche Peak Response Team (CPRT)

issue-specific action plant.(ISAPs) VI.b, VII.b.3 and VII.b 4;

Corrective Action Program (CAP) for piping and pipe supports,

conduit supports Train A and Train B and Train C > 2", and

instrumentation and controls; and general plant areas (tours).

Results: Within the areas inspected, the NRC inspectors identified

no significant strengths or weaknesses during this inspection '

period. One violation (failure to adequately control documents

affecting quality, paragraph 7.b) was identified.

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DETAILS

1. 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

• W .~ J. Cahill, Consultant, TU Electric

• J. T. Conly, APE-Licensing, SWEC

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

• J. Crnich, Project General Manager, Ebasco

• G. G. Davis, Nuclear Operations Inspection Report Item

Coordinator, TU Electric

• J. Donahue, Operations Manager, TU Electric

• D. E. Deviney, Deputy Director, Quality Assurance (QA),

TU Electric

• S..Frantz, Attorney, Newman & Holtzinger, P.C.

• M. D. Gaden, CPRT, IT Corporation

• B. P. Garde, Attorney, CASE

• 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

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

• J. R. Martin, Manager, Ebasco

• S. M. Matthews, Chief Inspector, State of Texas

• D. M. McAfee, Manager, QA, TU Electric

• J. W. Muffett, Manager of Civil Engineering, TU Electric

• E. Ottney, Representative, CASE

• S. Palmer, Project Manager, TU Electric

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

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

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

• J. S. Smith, Plant Cperations Staff, TU Electric

• S. L. Stamm, Project Engineering Manager, SWEC

• J. F. Streeter, Director, QA, TU Electric

! *C. L. Terry, Unit 1 Project Manager, TU Electric

• T. G. Tyler, Director of Projects, TU Electric

l *B. Walker, Senior Inspection Specialist, Texas Department of

Labor and Standards

• K. C. Warapius, Project Director, Impell

• J. R. Waters, Licensing Compliance Engineer, TU Electric

j *C. S. Weary, Engineering, E&C, TU Electric

( *D. R. Woodlan, Docket Licensing Manager, TU Electric

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, The NRC inspectors also interviewed other applicant employees

during this inspection period.

' Denotes personnel present at the August 2, 1988, exit

meeting.

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2. Applicant's Action on Previous Inspection Findings (92701)

a. (closed) open Item (445/8513-0-11): During an NRC

witnessed inspection, an ERC inspector identified the

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following conditions to the NRC' inspector as subject to

evaluation as. potential deviations:

. Pipe clamp parallelism out of tolerance.

. Locking devices for bolting missing.

These findings were identified on Deviation Report

(DR) I-S-PS7N-028-DR1 issued on September 11, 1985, and

subsequently on Nonconformance Report (NCR) M86-23270N

issued March 6, 1986, which was dispositioned as follows:

Craft to install cotter pins where required,-rework pipe

clamp parallelism, and stake threads of pipe clamp bolts

to provide a locking device (work order required).

NCR M86-23270N was signed off complete by TU Electric QC

on December 18, 1986.

During a review of-DR I-S-PS7N-028-DR1, NCR M86-23270N

and a reinspection of the support in' question, the NRC

inspector found that the rework had been performed as

required by the disposition of the NCR and the applicable-

procedures and was completed in an acceptable manner.

This open item is closed.

b. (closed) Unresolved Item (445/8601-U-16; 446/8601-U-05):

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The NRC inspector questioned the homogeneity and validity

of the small bore pipe support population. Paragraph 4.1

of the CPRT Action Plan for ISAP VII.c required that the

results of the sampling for each population be evaluated

and utilized to provide significant input into the

overall evaluation of construction adequacy.

The NRC inspector noted that all attributes on the

checklist for Verification Package I-S-SDPS-037 with the

, exception of (1) identification, (2) location and

orientation, and (3) clearances had "NA" (not. applicable)

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entered by the Evaluation Research Corporation (ERC)

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engineer. No material (structural steel, anchor bolts,

t U-bolts, snubbers, etc.) or welding was involved in the

reinspection; therefore, only a few attributes on the

checklist were applicable.

! As such, the NRC inspector did not consider the

i population sample to be a valid statistical sample for

generating conclusions about construction adequacy.

In response to the NRC inspector's concerns, the CPRT

stated that although they did not deviate from program

commitments related to sampling techniques, CPRT chose to

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combine reinspection and documentation review results

with those from the other pipe support populations on a

proportional sampling basis to achieve the required

sample size (60) for each attribute in order to assure

that significant inputs concerning construction adequacy

were utilized.

For the small bore pipe support (SBPS) population,

attributes for large bore supports nonrigid (LBSN) and

large bore supports rigid (LBSR) populations were utilized

to achieve the required sample.

The Nhc inspector has reviewed QA/QC-RT-6849, Revision 2,

dated June 24, 1987, "Attribute Count hatrix for Small

Bore Pipe Support Population," and CPRT letter CPRT-821

dated February 3, 1987, "Proportional Sampling." NRC

review determined that CPRT actions discussed above have

resolved this issue. This item is closed.

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

a. (Closad) Violation (445/8601-V-12; 446/8601-V-03): 1

Established procedures for handling of nonconforming

materials, parts, or components were not effectively

implemented as evidenced by the following conditions.

(1) 'DRs generated by ERC to document nonconforming

conditions did not, in all cases, result in the

initiation of NCRs by the TU Electric QA/QC

coordinator.

(2) The TU Electric QA/QC coordinator failed to initiate

NCRs for numerous ERC identified out-of-scope

observations.

(3) A large number of nonconforming items had not been

physically identified with signs, barriers, or hold

tags.

l (4) Numerous instances had been identified where

I deficiency notifications have been used to

improperly document nonconformances and effect the

issuance of work requests and work orders.

(5) Failure to initiate required NCRs impacts on the

validity of the monthly trend analysis report.

The applicant responded to the Notice of Violation (NOV)

with the following information:

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(1) TU Electric reviewed all DRs written by ERC and

found that the requirements of CP-QP-16.3 had not

been impicmented when the component identified fell

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under the scope of the ASME Section XI program. At

the completion of this review, TU Electric issued

NCRs for all DRs not previously documented on NCRs.

(2) CP-QP-16.3, Revision 3, now requires that all

observations be documented on NCRs regardless of the

described condition. All out-of-scope observations

have been reviewed to determine if NCRs were issued

for them. NCRs have now been issued for a21

out-of-scope observations.

(3) TU Electric agreed that the tagging criteria in

CP-QAP-16.1, Revision 25, requires the

identification of all nonconforming items with

signs, barriers, and/or hold tags. However,

CP-QAP-16.1, Revision 27, dated August 13, 1986, was

issued to require the placement of hold tags on

nonconforming items, where practicable. Tagging

criteria now contained in QI-QP-16.0-8, Revision 0,

dated December 22, 1986, requires that "Hold Tags"

be placed on deficient items if:

(a) The item is not installed, or

(b) Correction of the deficiency without QC witness

would preclude proper reinspection.

(4) Contrary to the requirements of N61.1, several DRs

were received from ERC (that were associated with

the N61.1 program) that were processed with

deviatjon notices (DNs) in lieu of NCRs. However,

per CP-QP-16.3, Revision 2, DNs may no longer be

used to process DRs. A review was conducted of

previous Dxs/DNs and those identified were reissued

as NCRs. NCRs are currently used to document

deficiencies regardless of the stage of component

processing.

(5) NCR E86-200637 identified 53 out-of-scope three-part

memos of which 30 were determined to be

nonconforming. The nonconforming conditions

described on the 30 three-part memos have been

documented on individual NCRs and included in the

monthly trend analysis report.

A revision to CP-QP-16.0 (nonconformances) and its

daughter instructions provides nonconformance

identification requirements which includes initial

identification of nonconforming conditions on

construction DRs.

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The NRC inspector reviewed the DR/NCR log, the

out-of-scope log, and the following TU Electric

procedures:

CP-QAP-16.1 Revision 27

CP-QP-16.0 Revision 26

CP-QP-16.0-8 Revision 0

CP-QP-16.3 Revision 3

The NRC inspector feels that the revisions made to the

above procedures clarify the intent of the procedures

with respect to NCRs and will help prevent a recurrence

of the identified problems. Part three of this violation

was closed in NRC Inspection Report 50-445/87-11;

50-446/87-09, Section 2.e and 3.g. This violation is

closed,

b. (Closed) Violation (446/8602-V-10): Section CC-5521.1.1

of code ACI-359, states, in part: "If the 12-inch

radiograph in the 50-foot long increment of weld does not

meet the acceptance standards, two 12-inch films shall be

taken at other locations within the 50-foot long

increment . . . . If either of the second radiographs

does not meet the acceptance standards . . . the

remaining portion of the 50-foot increment of this weld

shall be radiographed."

Contrary to the above, NRC Office of Special Projects

(OSP) inspectors determined that the required

radiography of the remaining portion of a 50-foot

increment of weld was not performed even though one of

the two second 12-inch radiographs (No. 146T2) at

seam P84 in the Unit 2 containment liner did not meet the

acceptance standards.

TU Electric letter TXX-6285 documents the applicant's

response to the NOV. TU Electric denies the violation

based upon the following reacons:

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The film (146T2) was determined to be acceptable

during the construction phase of the containment

liner by both Chicago Bridge and Iron (CB&I) and a

Brown and Root (B&R) Level III examiner.

. In addition, after issuance of the NOV, other

personnel who were certified Level III

radiolographic examiners by their respective

employers evaluated the linear indications which

appear on film 146T2 and determined that the film

grading was correct and acceptable.

The details section of NRC Inspection Report

50-445/86-03; 50-446/86-02 identifies an open item

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involving the CBI practice of "pickup and reshoot" (i.e.,

depositing weld filler material on previously visual

examination (VT) accepted weld surfaces to resolve

discontinuities which appear on the RT film). While

reviewing RT film and reports of RT examination, the NRC

inspector noted that the term "pickup and reshoot" was

entered in the remarks column for RT report line entries.

On April 29, 1988, NRC and TU Electric management

discussed methodology to resolve the OSP NRC inspector's

determination that film 146T2 was unacceptable in

accordance with the ACI-359 RT film grading standards

committed to in the FSAR. The NRC inspectors had

previously concluded that film 146T2 did not meet ACI-359

requirements due to the excessive length of linear

indications and the cumulative length of linear

indications which were evaluated to appear on the RT

film. As a result of this discussion with TU Electric,

the NRC committed to have the NRC mobile NDE vehicle

personnel independently evaluate the adequacy of CBI RT

film grading and the practice of "pickup and reshoot."

on July 27, 1988, the NRC NDE inspector evaluated the

linear indications to be less that 1/4" in length and

that the group of inclusions which appear on film 146T2

meet aggregate length critoria for acceptance.

Furthermore, the CBI practice of "pickup and reshoot" was

deemed to be acceptable. NRC Inspection

Report 50-445/88-48; 50-446/88-43 will document

inspection activities performed by the NRC mobile NDE van

inspectors.

This violation is closed based upon inspections performed

by NRC mobile NDE van inspectors.

c. (Closed) Violation (445/8422-V-05): The NRC inspector

had identified nine dimensions on the baseplate of pipe

support SI-1-071-002-S32K which were out-of-tolerance

after final inspection by QC.

The NRC inspector reviewed the current installation

status of the subject support and found that the support

was voided. Pipe support engineering letter PSE-3599

dated September 3, 1987, provides instruction to project

personnel to void the support due to the Stone and

Webster Engineering Corporation (SWEC) stress

requalification program which determined that the support

was no longer required.

Actions to preclude recurrence of the violation are

contained in the applicant's CAP for pipe supports. All

pipe support base plate dimensions are an attribute for

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QC reinspection under the CAP. NRC inspection of the

CAP, documented in 50-445/87-16; 50-446/87-13 and in

50-445/87-18; 50-446/87-14 did not reveal any violations

similar to this NOV. This violation is closed.

d. (Closed) Deviation (445/8718-D-10): This deviation

identified five examples of instances where the NRC

inspection data differed from the data collected during

Impell's engineering walkdown phase of the post

construction validation program (PCHVP) for Train C

conduit less than or equal to 2". The applicant agreed

with the deviation in letter TXX-6939 dated December 7,

1987, and issued DR C-87-4800. This DR stated that the

cause of the deficiency was inaccurate recording and

checking of walkdown data. The applicable walkdown forms

and calculations were corrected and the qualification

status of the conduit supports did not change as a result

of the identified discrepancies. The engineers still on

site involved in the walkdowns, as well as all other

personnel involved in the structural integrity group,

have been retrained on the importance of documenting

walkdown data accurately. Also, Impell Train C project

instructions have been reviewed for areas that could be

misinterpreted which could potentially affect the

accuracy of field measurements, and revised accordingly.

Further, to assess the generic implications of walkdown

discrepancies, Impell conducted a study and issued a

report on the accuracy and adequacy of Train C walkdown

data. In this study, 5271 attributes were reinspected

with a discrepancy rate of 1.9% of which 0.7% were

unconservative. However, none of the discrepancies

resulted in disqualification of the Train C conduit

systems.

In this inspection period, the NRC inspector reviewed

DR-C-87-4800 and found that it adequately addressed the

deviation. The revised walkdown forms and calculations

were reviewed to ensure that the qualification status of

the conduit supports was not affected. Training records

were reviewed as well as PICN-009 which provides

clarification to improve measurement consistency when

measuring spans with bends as required by Project

Instruction PI-0210-052-004.

The conclusions of Impell report 01-0210-1671 which

assesses the generic implications of the identified

walkdown discrepancies were presented to the NRC

inspection staff on January 28, 1988, and are discussed

in NRC Inspection Report 50-445/88-05; 50-446/88-04.

Based on the above actions, this item is closed.

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e. (closed) Deviation (445/8731-D-03): This deviation

identified five examples of discrepancies between NFC

inspection data and that collected by Impell's walkdown

engineers. The applicant's response to this deviation

and the NRC ins;;ctors review of the actions taken were

essentially the same as those for deviation 445/8718-D-10

discussed earlier in this report in paragraph 3.d. The

NRC inspector reviewed the revised walkdown forms and

calculations associated with this deviation to ensure

that the correct data had been incorporated and also to

ensure that the qualification status had not changed.

This deviation is closed.

f. (Closed) Deviation (445/8735-D-01): This deviation

identified one instance where a checker dated a

calculation, indicating completion of his review, the day

before the enginaar performing the calculation dated it.

Moreover, a calculation summary sheet appeared to have

been prepared before some of the calculations summarized

on it were performed.

The applicant issued DR-C88-Oll74 to document these

discrepancies. The NRC inspector reviewed this DR and is

satisfied that it fully addresses the deviation. As

corrective steps the calculations in question were

rereviewed and a comprehensive administrative checklist

was implemented to ensure consistency in documentation of

the dates work is performed. The NRC inspector reviewed

the calculations in question to ensure that this review

had been accomplished, as well as Impell's administrative

quality assurance checklist, and concurs that the

committed actions have been completed and that they

adequately address the deviation. This deviation is

closed.

g. (Closed) Deviation (445/8735-D-03): This deviation

identified four errors in walkdown data collected by

Impell. In response to this deviation, the applicant

issued DR-C-88-01191. The corrective actions, other than

correcting the specific walkdown forms and calculations,

are the same as those reported for deviation

445/8718-D-10 discussed earlier in this report and are

considered acceptable. The NRC inspector reviewed the

revised walkdown forms and calculations associated with

the deviation to ensure that the correct data had been

incorporated and that the qualification status had not

changed. This deviation is closed.

4. Follow-up on NRC Compliance Bulletin 88-06 (92703)

(Closed) NRC Compliance Bulletin 88-06, "Actions to Be Taken

for the Transportation of Model No. SPEC 2-T Radiographic

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Exposute Dc' fica": This bulletin is a follow-up to NRC i

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Information Notice 8d-33, "Recent Problems Involving the Model

SPEC 2-T-Radiographic Exposure Device." Certain problems have ,

been identified in the manufacture of this radiographic device  !

which include:

a. The "as built" configu*.ation of some of the devices does a

not conform to the design approved by NRC, and

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b. Source Production and Equipment Company failed to

implement the quality assurance program requirements

specified in Subpart H of 10 CFR Part 71 and in QA

program approval 71-0102.

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The NRC inspector reviewed the applicant's response to the NRC

bulletin dated July 11, 1988, and considers this bulletin to

be nonapplicable due to the fact that all RT examinations

performed on site by B&R and the designated NDE contractor,

are performed with RT exposure devices supplied by other

manufacturers. This bulletin is closed.

i 5. Allegation Follow-up (99014)

l (Cloned) OSP-88-A-00Sl: Subsequent to a Monday morning layoff

of QC inspectors, an allegation was received that stated that

there were no in-plant civil structural QC inspectors

available for the inspection of construction activities. The

applicant was contacted and replied that there was a one day

temporary shortage of personnel due to layoffs, personal time

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i off, and sick leave, but that the lead Level III QC inspector

was available all day for construction calls for inspection.

1 The inspector verified that the in-plant QC call board did

have a notice to call the Level III QC if inspections were

requested. Since an inspector was available and ample

instruction was present to reach him if necessary, this

allegation (OSP-88-A-0051) is considered closed.

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6. CPRT ISAPs (48063)

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, a. Polar Crane Shimming (ISAP VI.b)

1 (1) Inspection of Seat:-ho-Bracket Connections (NRC

, Reference 06.b.01 il)

Third-Party Review of Inspection and Any, Corrective

Action (NRC Reference 06.b.01.03)

The technical review team (TRT), during an

inspection of the Ploar Crane runway system in

August 1984 found that several of the girder seat

connections had gaps that extended into the

projection of the bottom flange of the girder.

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These gaps exceeded the acceptance criteria

originally established by Gibbs and Hill (G&H) in

November 1977. A further evaluation performed by a

craft team identified what they perceived as the

four worst cases. However, SWEC calculation

16345-EM(S)-008-CZC, Revision 1, concluded that the

bearing between the girder and the support bracket

seat is not an area of concern. The third party

agreed with this conclusion. NRC evaluation of this

calculation is documented in NRC Inspection

Report 50-445/88-37; 50-446/88-35). NRC inspection

of these items is complete. No violations or

deviations were identified.

(2) Develop Measurement Program, Execute, and Evaluate

(NRC Reference 06.b.02.01)

Determine Cause of Rail Movement, Assess Safety

Significance, and Reccmmend Modifications (NRC

Reference 06.b.02.02)

In February 1985, representatives from TU Electric,

G&H, and the third party performed a walkdown and

review of the Unit 1 polar crane that included an

inspection of the rail during operation of the

crane. From this walkdown/ inspection, a report was

prepared by G&H (see "Polar Crane Study" by G&H

dated May 14, 1986) that detailed findings and

observations. For a detailed NRC review of the

calculations and recommendations, see NRC Inspection

Report 50-445/88-37; 50-446/88-35. Inspection of

these items is complete. No violations or

deviations were identified.

(3) Inspect Rail and Rail Support System to Identify Any

Safety Significant Deviations (NRC Reference

06.b 03.01)

prescribe Corrective Action on Any Found

Deficiencies (NRC Reference 06.b.03.02)

Third-Party Verification of Inspection and Review of

Corrective Action (NRC Reference 06.b.03.03)

A general inspection was performed by TU Electric in

November 1985 under Traveler CE-85-2876-8902.

During this inspection, four findings were

documented:

. Spalling on all 14 rail segments.

. Gaps in the upper bracket connections.

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Ground cables either completely or partially

broken.

. Some rail leveling shims loose or damaged.

The general inspection did not identify any

unsatisfactory conditions that would not have been

corrected by the proposed design modifications

and/or normal repair activities.

The general inspection of the crane rail support

system (initiated in November 1985) was overviewed

by the third party who also reviewed and concurred

with the recommended corrective actions. The NRC

inspector has inspected the ISAP VI.b *iles,

inspection results, third-party files and reports,

VI.b Results Report, and TERA's history of the polar

crane and concurs with the conclusions reached in

the Results Report. Further review of this ISAP ard

related reference items is documentid in NRC

Inspection Report 50-445/88-37; 50-446/88-35.

Inspection of these items is complete. No

violations or deviations were identified.

(4) Review Existing Maintenance and Surveillance Program

(NRC Reference 06.b.04.01)

Third Party to Recommend Any Required Design Chances

(NRC Reference 06.b.04.02)

The maintenance and surveillance program reviewed by

the third party was presented in the Comanche Peak

Steam Electric E'.ation Mechanical Maintenance

Manual, "Containment Polar Crane Inspection,"

Instruction MMI-317, Revision 1. The review

concentrated on the then existing procedures for the

maintenance and surveillance of the runway system.

It was found that this instruction addressed only

the crane structure and its mechanical / electrical

components. It was determined by the third party

that it would be prudent to conduct an inspection of

the runwdy system and that the existir, Instruction

MMI-317 should be revised to include requirements

for this inspection.

The changes to the acceptance criteria recommended

by the maird party were incorporated in Revision 2

to Instruction MMI-317 which was issued in July of

1986. The third party has reviewed and concurred

with Instruction MMI-317, Revision 2. TU Electric

revised Instruction MMI-317, reissued it as

Procedure MMP-317 in April 1988, and included the

runway system. Procedure MMP-317 was issued in

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conjunction with Electrical Procedure EMP-343 (which

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documents electrical maintenance of the polar

crane). The NRC inspector has reviewed the Polar

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Crane Results Report, TERA letter TERA-213,

i Procedure MMP-317 and Procedure EMP-343 and concurs

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.that both the' review and procedural implementation

will assure.that an adequate maintenance and

surveillance program are in place. A further review

of the recommended design changes can be found in

NRC Inspection Report 50-445/88-37; 50-446/88-35.

Inspection of these NRC items is complete. No

violations or deviations were identified.

(5) Review Hist'ory of Crane Support System' Construction

and Performance (NRC Reference 06.b.05.01)

The review of the history of the crane support

system was perfor~'d by the third party with

assistance from the project and documents the design

and installation requirements for the crane support

system, load testing of the crane, and the

installation and inspection history related to the

shim gap and rail motion problems. The results of

this review were documented in the ISAP VI.b Results

Report and TERA letter TERA-213. The NRC inspector-

reviewed the referenced background documents related

to the history of the crane support system

construction and performance and feels that the

history, as outlined, is well detailed and accurate.

Inspection of this item is complete. No violations

or deviations were identified.

(6) Identify and Categorize Design Requirements in Terms

of Performance of Structural Function (NRC

Reference 06.b.05.02)

A review of the design requirements of the crano

support system was performed by the third party,

with assistance from the project. This review

resulted in the generation of documentation for the

design and installation requirements for the runway

system, load testing of the crane, and installation

and inspection history related to shim gap and rail

motion problems. The design requirements were

identified in the following TU Electric documents:

2323-SS-10 Reinforcing Steel

2323-55-11 Cadwelding Robar

2323-SS-14 Containment Liner Steel

2323-SS-17 Miscellaneous Steel

2323-SS-39 Containment Polar Cranes

L

, . . . . -

- _ _ _ _ . _ _ . . . _ . . .

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L

15

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e

s

(TU Electric documents continued)

KRANCO 7523-CL-1 Clearance Drawing

Bridge Assembly

-

F KRANCO 7523-3

P.RANCO 7523-6 Bridge Wheel Assembly

Bostrom-Bergen 2386-7 Polar Crane Girders

Gibbs & Hill 2323-S1- Polar Crano Support

= 0515 Details

?

The engineering design of the runway system prior to

L': the TRT investigation is documented in G&H

F

Calculation SRB-109C, Set 3, Revisions 0 through 3.

L The interface wheel loads for the various load

P combinations, including seismic, used in the G&H

[ analysis were provided by KRANCO, the crane

manufacturer. Those items that were found not to be

addressed by SRB-109C, Set 3, Revisions 0 through 3

were identified in DIRs ~ ~ resolution by SWEC. In

w

7

addition, G&H completed 'ses of the structural

'

members and connection ds 2As in Calculation

m

SRB-109C, Set 3, Revisions 4 through 10. The NP.C

h inspecter has reviewed the various project

= specifications, KRANCO drawings, and G&H/SWEC

- calculations portaining to the polar cranc design

• requirements. Based on this review, the NRC

- inspector is satisfied that the methods used

adequately cover the design requiremente in terms of

_

2 performance and structural function. NRC inspection

of this item is complete. No violations or

- deviations were identified.

E

b. Hilti Anchor Bolt Installation (ISAP VII,b.4)

Determine Programmatic Implications (NRC

-

Reference 07.b.04.08)

The three primary areas of concern that were

- identified during the CPRT reinspection of

ISAP VII.b.4 were identified as spacing violations,

_-

bottomed-out nuts, and torque violations.

g

1

A review of the spacing violations determined that

spacing violations have occurred in all applications

_

=

that included installed Hilti bolts. Spacing

,

violations do not have implications beyond Hilti

E

bolt installations in that they involve multiple

installations; i.e., distance of one it.stallation to

.

another. Therefore, there are no programmatic

implications to other activities.

,

Root causes for bottomed-out nuts and torque

violations were not determined. However, thesc

_-

.

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

_ _ - .

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violations occurred when setting the bolt, an

operation which is unique to Hilti bolt

installations. Therefore, implications beyond Hilti

bolt installations are unlikely to exist.

The NRC inspector has reviewed the ISAP VII.b.4

Results Report, the ISAP VII.b.4 files, related DRs,

and NCRs, and concurs with the CPRT that no

programmatic implications outside the Hilti bolt

arena exist. This ISAP is closed. Specific

inspection activity on Hilti bolt spacing is

addressed in detail in NRC Inspection Report

50-445/88-50; 50-446/88-46. No violations or

deviations were identified.

c. Pipe Support Inspections (ISAP VII,b.3)

(1) Reinspect Random Sample in Accordance with

ISAP VII.c (NRC Reference 07.b.03.06(

A decision was made by TU Electric to conduct a

separate and broader investigation of the adequacy

of construction of CPSES in accordance with

ISAP VII.c, "Construction Reinspection / Documentation

Review Plan." Included within the scope of

ISAP VII.c was a statistically based reinspection of

pipe supports selected from Unit 1, Unit 2, and

common areas. As a result, the scope of

ISAP VII.b.3 was changed to cover only the

validation of NRC TRT findings. However, the

results of the reinspections conducted by ISAP VII.c

and ISAP VII.b.3 were combined during the collective

evaluation phase of the quality of construction

program.

The NRC inspector reviewed the quality instructions

related to the pipe supports covered by ISAP VII.c

and determined that all attributes covered by ISAP

VII.b.3 were included in the quality instructions

for the inspection of pipe supports in ISAp VII.c. ,

The NRC inspector identified one attribute, "Hilti

Kwik" bolt embedment length that was not included in

the VII.b.3 attributes; however, this attribute was

included as an attribute in ISAP VII b.4 and the

cable tray design adequacy verification program.

The NRC inspector concludes that this item has been

satisfactorily completed. The inspection of this

item is completc. No violations or deviations were

identified.

P~~

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(2) Review ISAP VII.c Inspection Results for Pipe

_

Supports and Identify Valid Discrepancies (NRC

Reference 07.b.03.09)

The NRC inspector has reviewed the Results Reports

and the files for the following ISAP VII.c pipe

supports:

Major

No. of

Appendix Population Attri-

butes

25 Large Bore Pipe Supports - Rigid 14

26 Large Bore Pipe Support - Nonrigid 14

27 Small Bore Pipe Supports 14

During this review, the NRC inspector identified

that a total of 946 valid deviations had been

written by ERC of which 671 were determined to be

insignificant by ERC. These deviations covered all

identified attributes with the exception of QC

inspector certifications. Based on the inspection

findings identified by ERC, recommended actions were

made in the following areas: Components, gaps,

locking devices, pipe clamp spacers, jam nuts,

fasteners, and angularity.

The NRC inspector also found that the dispositions

of deficient conditions were addressed and that the

rework and repair is being performed in accordance

with the CAP program. Inspection of this item is

closed. No violations or deviations were

identified.

(3) Evaluate Valid Discrepancies for Safety Significance

in Accordance with Appendix E of the CPRT Program

Plan. (NRC Reference 07.b.03.10)

ERC inspected 42 supports in Unit 1 and common areas

and 92 snubber and strut type supports in Room 77N.

This inspection / verification identified a total of

338 deviations which were evaluated for safety

significance in accordance with Appendix E of the

program plan. During this safety significance

evaluation, no adverse trends and a total of six

construction deficiencies were identified which

consisted of the following:

. No locking devices for threaded fasteners.

. Pipe clearances with support out-of-tolerance.

. Pipe clamp locknut loose.

. Strut misalignment.

.

• .

-

.

18

. Load pin locking device (cotter pin) missing.

. Broken and missing lockwire on snubber adapter

plate bolting.

One unclassified deviation was also identified which

consisted of:

. Loose jam nut on barrel of strut.

The NRC inspector reviewed the methods and

procedures for determining safety-significant items

and the DRs/NCRs initiated as a result of this ISAP.

The NRC inspector also reviewed the ERC inspection

packages and concurs with the methods utilized and

results of safety-uignificance evaluations. NRC

inspection of this item is complete. No violations

or devialtions were identified.

(4) Perform Trend Analysis for all Valid Deviations (NRC

Reference 07.b.03.11)

CPRT reinspected a total of 220 supports for the

purpose of substantiating the TRT findings and

assessing the impacts of the TRT findings on

construction quality. Additionally, more than 300

supports were reinspected under ISAP VII.c for the

purpose of assessing construction quality.

Corrective actions were recommended for construction

deficiencies, program deviation reports, and

unclassified deviations. As a result of this

inspection, a total of 946 valid deviations were

identified with 671 determined to be insignificant.

An analysis by CPRT of the 946 deviations resulted

in no adverse or unclassified trends being

identified for ISAP VII,b.3.

The NRC inspector reviewed the ISAP VII,b.3 files,

Trend Analysis and Results Report and found then to

be consistent with previous inspection results.

Inspection of this item is complete. No violations

or deviations were identified.

(5) Determine Root Cause, Generic Implications and

Programmatic Concerns for any Construction

De,ficiencies and Adverse Trends. (NRC

Reference 07.b.03.14)

CPRT performed reinspections on 220 supports for

ISAP VII.b.3, during this inspection, 946 deviations

were identified of which 275 were determined to be

significant. An analysis was performed on the 946

deviations to determine root cause, generic

implication, and programmatic concern for any

identified construction deficiencies and adverse

___ _ _ - _ _ _

.,

• _;

.

m

19 .

.

trends. During this analysis, no adverse trends

were identified; however, six construction

deficiencies were identified which consisted of the *

following:

.. .No locking devices for threaded fasteners.

,, . Pipe clearance with support out-of-tolerance.

. Pipe clamp locknut loose.

. Strut misalignment.

. -Load pin locking device (cotter pin) missing.

. Broken and missing lockwire on snubber adapter

plate bolting.

With the exception of "strut misalignment," the

"root cause, generic implications and programmatic

concerns" are being addressed by the same findings

and concerns in the following ISAP VII.c populations

Results Reports:

. Large bore pipe supports - rigid.

. Large bore pipe supports - nonrigid.

. Small borc pipe supports.

With respect to the "strut misalignment," it was

determined that because of the long period of time

(early 1983 to late 1985) between the last

documented inspection and the CPRT inspection that

it was-not possible to determine a specific root

cause for this deficiency. However, a QA/QC program

deviation report (PDR-061) was initiated to address '

the preservation of pipe supports in their

QC-accepted configuration.

The NRC inspector reviewed tb9 ISAP VII.b.3 and  ;

VII.c files, Results Reports, and the methodology l

used in reading the aforementioned conclusions and ,

feels that ISAP VII.b.3 has been adequately

addressed and that the facts support conclusions

reached. Inspection of this item and ISAP.is

complete. No violations or deviations were ,

identified.

i

7. Corrective Action Plan (CAPl

e, Pipino and Pipe Supports (50090)

l

l The applicant is currently in the process of issuing

vendor certified drawings (VCDs) for pipe supports with i

respect to the completion of stress reconciliation .

activities related to SWEC's program and procedures which  !

were established to meet the requirements of IEB 79-14.  ;

i

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20

To date, the following six VCDs have been issued by SWEC:

Pipe Support MK. No. Revision

RH-1-014-003-S32S CP-1

RH-1-014-004-S32R CP-3

RH-1-014-005-S32R CP-1

RH-1-014-006-532K CP-2

RH-1-014-007-S32S CP-2

RH-1-014-010-S32K CP-2

The URC inspector exatained SWEC and TU Electric design

control procedures to ascertain that they are consistent

with QA program commitments. The NRC inspector performed

a detailed review of SWEC site Procedure CPSP-11,

Revision 6, "Technical Services Drafting (TSD) Drawing

Preparation Unit 1." Interviews were conducted with the

TSD supervisor and one of the SWEC project engineers

responsible for engineering review of drawing revisions.

The purpose of the NRC inspection was to determine if:

.

SWEC engineering and drafting personnel were

knowledgeable of procedural requirements.

.

Responsibilities were assigned in writing and

properly and effectively performed for these

documents.

. Reproduction of design documents are clearly legible

and in a condftion suitable for their intended

purpose.

NRC inspection of the drawings listed above revealed that

means have been established to assure, through

implementation of approved procedures, that design

drawings, including changes thereto, are reviewed for

adequacy and approved for release by authorized

personnel. No violations or deviations were identified.

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

During a review of tolerances for conduit support members

which are contained in Specification 2323-SS-16B,

Revision 2, "Structural Steel / Miscellaneous Steel

(Category I & II)," it was noted that this specification

has been revised by design change authorization

(DCA) 79249, Revision 2. Procedure ECE 5.02,

paragraph 6.6, allows the use of a DCA to make changes to

specifications. While reviewing this DCA, the NRC

inspector noted the same engineer originated and approved

the reason for change; however, paragraph 6.2.2b of

Procedure ECE 5.01-03, Revision 1, requires that the

reason for chLnge be approved by the responsibic

.

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21

supervising engineer. Further, this specification is a

multidiscipline document and as such was reviewed by the

three engineering contractors on site; however, the DCA

was prepared by Impell and SWEC and was not reviewed by

Ebasco. This did not appear to be in accordance with the

requirements in Procedure ECE 5.01, design control

program and Procedure ECE 5.02, engineering specification

review. This was discussed with applicant personnel who

agreed that the engineer who prepared the DCA should not

have approved the reason for change and that paragraph

6.6.2.j of Procedure ECE 5.02 which gives the review and

approval requiremente for DCAs issued against

specifications is not consistent with paragraph 6.1 of

the same procedure. In response to the questions by the

NRC inspector, the applicant issued DR P-88-03618 in

regard to the originator and approval blocks being signed

by the same individual and DR P-88-03617 to correct the

inconsistency in Procedure ECE 5.02. The two items

detailed above are a violation of Critorion VI and

project procedures (445/8851-V-01).

c. Instrumentation and controls (52053)

In this inspection period, the NRC inspector witnessed a

flexible metal hose assembly inspection by SWEC Quality

Control. The purpose of this effort was to evaluate the

methods used to inspec'. items such as:

. Spatial orientation.

. Twist or torsion within hoses.

.

Location of 3-D clamps on tubing stubs.

. Crimping.

. Crushing.

. Separation of the braid.

The inspectors performed an inspection on a 90

orientation - Configuration II as depicted on

Drawing ECE-I-002-R-10, Revision CP-1. A fixture

consisting of tubing clamps and sections of thick wall

tubing were attached to the hose assembly being inspected

establishing baselines from which critical dimensions

were measured. The information collected was then

compared to acceptance criteria providedThe on NRC inspector

Drawing ECE-I-002-R-13, Revision CP-1.

concurred that the inspection technique utilized is

adequate to evaluate the necessary attributes. No

deviations or violations were identified.

8. Plant Tours (92700)

The NRC inspectors made frequent tours of Unit 1, Unit 2, and

common areas of the facility to observe items such as

__-__

4 .

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,

22

housekeeping, equipment protection, and in-process work

activities. No violations or deviations were identified and

no items of significance were observed.

9. Management Meetings (30702)

c' a. On July 15, 1988, R. F. Warnick and J. S. Wiebe met with

L. F. Nace and A. B. Scott in a routine monthly meeting

to discuss current activities and items of concern.

Significant subjects discussed included:

(1) The joint stipulation signed by TU Electric, CASE,

and NRC.

(2) Postponement of the meeting with Region IV and

TU Electric to allow CASE to attend.

(3) Results of recent operating licensing examinations

(six passed and seven did not pass).

(4) Service water system pipe coating removal

(5) The need to keep the NRC informed of changes

(reductions) in the CAP and PCHVP commitments,

b. On July 21, 1988, R. F. Warnick, H. H. Livermore,

C. J. Hale, and P. Stanish met with L. F. Nace to discuss

NRC concerns with the large number (8000) of DCAs

requiring confirmation, the large number of outstanding

NCRs and DRs, the need to be kept informed of changes to

the CAP and PCHVP, and the recent Impell identified

question regarding the completeness of certain QC

inspections. Mr. Nace agreed to provide the NRC with

additional details regarding all three concerns.

10. Exit Meeting (30703)

An exit meeting was conducted August 2, 1988, with the

dpplicant'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.