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Insp Repts 50-445/88-59 & 50-446/88-55 on 880803-0908. Violation Noted.Major Areas Inspected:Applicant Action on Previous Insp findings,follow-up on Violations & Deviations, Action on 10CFR50.55(e) Repts & Allegation follow-up
	ML20155B597
Person / Time
Site:	Comanche Peak
Issue date:	09/29/1988
From:	Livermore H; NRC OFFICE OF SPECIAL PROJECTS
To:	;
Shared Package
ML20155B563	List: ML20155B559; ML20155B593; ML20155B597;
References
	50-445-88-59, 50-446-88-55, IEIN-87-008, IEIN-87-8, NUDOCS 8810060357
	Download: ML20155B597 (9)
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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION-

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OFFICE OF SPECIAL PROJECTS

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NRC Inspection Report: 50-445/88-59 Permits: .CPPR-126 '

50-446/88-55 CPPR-127

Dockets: 50-445 Category: A2 r

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50-446

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Construction Permit

i Expiration Dates:

Unit 1: Extension request -

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submitted.

Unit 2: Extension request

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Applicant: TU Electric !

! Skyway Tower !

l 400 North Olive Street

Lock Box 81

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Dallas, Texas 75201

Facility Name: Comanche Peak Steam Electric Station (CPSES),

Units 1 & 2

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Inspection At: Comanche Peak Site, Glen Rose, Texas '

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Inspection conducted: August 3 through September 8, 1988 l

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Consultant: J. L. Taylor - Parameter

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Reviewed by: 4tW/ OL L

] H. H. Livermore, Lead Senior Inspector Date

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Inspection Summary: .

Inspection Conducted: August 3 through September 8, 1988 (Report [

50-445/88-59; 50-446/88-55) l

Areas Inspected: Unannounced, resident safety inspection of

applicant's actions on previous inspection findings, follow-up on ,

violations and deviations, action on 50.55(e) reports, allegation ;

follow-up, Comanche Peak Response Team (CPRT) issue-specific action ,

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plans (ISAFs), the corrective action program (CAP), plant tours,

and significant meetings. [

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Results: Within the areas inspected, one violation was identified.

No significant strengths or weaknesses were noted. l

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DETAILS

1. Persons Contacted

R. W. Ackley, Jr., Project Manager, Stone & Webster

Engineering Corporation (SWEC)

M. Axelrad, Attorney, Newman and Holtzinger, P. C.

R. P. Baker, Licensing Compliance Manager, TU Electric

J. L. Barker, Manager, Engineering Assurance, TU Electric

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H. D. Bruner, Senior Vice President, TU Electric

W. J. Cahill, Consultant, TU Electric

, *J. T. Conly, APE-Licensing, SWEC ;

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

J. C. Crnich, Project General Manager, Ebasco

G. G. Davis, Nuclear Operations Inspection Report Item

Coordinator, TU Electric

S. H. Freid, Chief Mechanical / Nuclear Engineer, Bechtel

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

T. L. Heatherly, Licensing Compliance Engineer, l

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TU Electric

C. B. Hog, Engineering Manager, Bechtel

! *R. T. Jenkins, Manager, Mechanical Engineering, TU Electric

J. J. Kelley, Manager, Plant Operations, TU Electric

J. E. Krechting, Director of Technical Interface, TU Electric i

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

F. W. Maddon, Mechanical Engineering Manager, TU Electric :

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

J. C. Miller, CPRT, Tenera

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

L. D. Nace, Vice President, Engineering & Construction, ,

. TU Electric

E. Ottney, Representativo, CASE

S. S. Palmer, Project Manager, TU Electric

*J. D. Redding, Executive Assistant, TU Electric >

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D. M. Reynorson, Director of Construction, TU Electric

M. J. Riggs, Plant Evaluation Manager, Operations, TU Electric ,

E. J. Schmidt, Radiation Protection Manager, TU Electric i

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

C, E. Scott, Managor, Startup, TU Electric '

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

P. B. Stevens, Manager, Electrical Engineering, TU Electric !

! "J. F. Strooter, Director, QA, TU Electric

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

l *T. G. Tyler, Director of Projects, TU Electric i

R. D. Walker, Manager of Nuclear Licensing, TU Electric i

*K. C. Warapius, Project Director, Impell

J. R. Waters, Licensing Complianco Engincor, TU Electric

The NRC inspectors also intervicWod other applicant employees :

during this inspection period.

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meeting.

Denotes personnel present at the September 8, 1988, exit

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Applicant Action on previous Inspection Findings (92701)

(Closed) Unresolved

verification Item (445/8853-U-02): Flex conduit field

method discrepancies.

Further consideration of

this item determined that it was a violation and a

notification of such has been made with this report. This

item is superceded by 445/8859-V-01 (see paragraph 7) and is

closed.

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

(Closed) Violation (445/8514-V-04): Inspector not certified.

As previously reported in NRC Inspection Report (IR)

50-445/88-26; 50-446/88-22,

disposition and closure of Nonconformance Reportthis item remained open pen

(NCR) E85-101639, Revision 1 that was reported on November 7,

1985.

The NCR was transferred to NCR CE-87-9584 and was in

turn transferred to Deviation Report (DR) C-87-3608.

Revision

and closed 1 on

to this

JuneDR29,was dispositioned on February 6, 1988,

1988.

Although an extensive period of time has passed since this

violation occurred and the commodity being inspected (new

installation of plant lighting)

non-1E, the DR disposition is acceptable.has since been

The declassified

inspector in to

c'instion had been previously certified, but through

i;pervisory oversight continued to perform inspections for a

orief period without final sign-off of his annual

recortification.

As part of a review of corrective action to prevent

recurrence, the NRC inspector verified during this inspection

period that computer printouts and updated lists of electrical

inspectors'

supervisors. certifications are available and used by

The inspector considers this violation closed.

4.

Action on 10 CFR part 50.55(e) Deficiencl_es (92700)

(Closed)

Cabic L'nresolved

pulling Item ( 446/8712-U-04 ) and SDAR Cp-86-71:

tension: The applicant verbally notified the

NRC of a potentially reportable deficiency regarding

electrical cable pulling on October 2, 1986. This was

followed by written interim report letter TXX-6065. The

potential deficiency was that allowable cable tension had been

exceeded for some cables because cabic installation procedures

did not address correction factors for vertical cable pulls ae

well previously

with as coef.ficient

pulledofcables.

friction for cable pulls into conduits

The applicant determined the

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issue to be nonreportable and notification was made by letter

TXX-88208. .

The NRC staff reviewed: (1) the historical revisions of the

cable installation procedure, (2) the. evaluation results for

cable pulling tension calculations and/or testing, (3) the

interviews of personnel directly involved with Class lE cable

installation, and (4) quality control inspections. The staff i

- concluded that Class lE cable pulling construction and ,

inspection procedures are consistent with industry practice

and, in general, the related cable pulling operations were

performed satisfactorily with regard to workmanship and

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quality inspections. -The NRC inspector also reviewed: the

revised cable pulling instructions in ES-100,_ Revision 3;

j CAR-93; STIR-CPE-E-002, Revision 0, SWEC cable tension '

calculations; and other documentation provided with the

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SDAR CP-86-71 package. Based on the above evaluations and

staff conclusions, SDAR CP-86-71 and unresolved

item 446/8712-U-04 are closed.

5. Allegation Follow-up (99014)

(Closed) Allegation (OSP-88-A-0050): Required use of test

data sheet originals. ,

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] Concern Details

The alleger reported that he was prematurely removed from the ;

job site for not following a verbal directive. He was told to :

accept an attribute of a nuclear instrumentation triax cable

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inspection based on a copy (not the original) of a required

ongineering approved test data sheet. The alleger belie 'ed ho ,

should have had the original test data shoot in the work -

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! Assessment f

The inspection was to address only the technical aspects of

. the allegation. In order to evaluate the allegation, the NRC

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inspector reviewed applicable procedures / records in effect at !

the time of tho allegation as follows:

a. NQA 3.09-3.05, Revision 3 dated May 13, 1988, and DCN-01 ;

dated June 20, 1988, "QC Inspection of Termination 1

J Activities." Contrary to allegor's statement, applicable l

paragraph 6.2.5 does not specifically require that the i

original test data sheet be present for QC inspection. i

Discussion with QA management disclosed that this ,

practico is acceptable and the NRC inspector concurs.

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b. ECC 2.13-03, Revision 2, dated May 12, 1988, through

CDCN-04 dated August 8, 1988, "Construction Work Package

control" (6.7.4). This procedure provides for the

issuance of red-lined package inventory cards to the

craft for use provided that the required administrative

approvals have been obtained. Exceptions to this

requirement were documented in DRs C80-02537, C88-03551,

and C88-03263; however, review of these DRs indicate that

those examples appear to be isolated and that they do not

represent a programmatic breakdown.

c. ECC 2.13-04, Revision 1 dated April 15, 1988,

construction work package generation allows entries on

documents to be made by reproduction or other means

(6.2.1). This allows for special work package forms to

be produced by "cut and pasto" methods then copied for

uso. Report numbers are then applied to a particular

form to provide controls. The inspector has no problem

with this process.

d. Construction work packages on NIS triax cables:

ER140493 (vaulted) EB140700-Z (inprogress-CE gp.)

ER140493-Z (inprogress at EB140701-2 (inprogress-CE gp.)

Sys. Completion gp.) EW140591 (vaulted)

ER140499,-Y,-Z (vaulted) EW140592 (vaulted)

ER140490-01 (inprogress at

CE gp.)

E4140490,-Z (vaulted)

Review of those packages and interviews with QC/QE

personnel indicate that it is common practice to include

copies of test data sheets in soveral of a common group

of packages while one of the group contains the original.

For examplo, the group of three packages ER140499,

ER140499-Y, and ER140499-Z had the original only in the

base packago ER140499. In group ER140592, the base

package ER140592 has the original whilo EW140592-Z and

EW140592-01 have copics. For a given cablo run, all

packages arc finally consolidated when vaulted. This

practico is acceptable t'o QA and to the NRC inspector.

An allegation that one of the test data shoot copics was

unsigned for ongineering approval at the time of the

incident could not be substantiated.

Additionally, review of SAFETEAM investigation of

Concern 11784, QC Internal Investigation Report CQA0276, dated

July 19, 1988, and corporato socurity reports indicate that

supervision did address the technical concerns previously

raised by the alleger adequately and attempted to s'aooth

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employee relations. - Supervision did hold regular QC inspector

g group meetings to discuss and resolve concerns. ,

Conclusion

Based on these findings, the NRC inspector feels'that the l

allegation of use of an original test data card has no

substance. The inspector could not confirm the allegation of '

.the use of a card not signed by engineering.

1 6. CPRT ISAPs (51051 and 51061)

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The NRC inspector reviewed all electrical ISAPs and previous

applicable inspection reports and continued to provide input

to the Safety Evaluation Report draft.

7. Corrective Action Procram (CAP)

The NRC inspector continued to evaluate implementation of the ,

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Post Construction Hardware Validation Program (PCHVP) by i

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accompanying SWEC engineers during performance of various

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Field Verification Method (FVM) procedures and by review and l

. walkdown of activities previously completed by the walkdown :

engineers. Follow-up on previously reported items and !

additional inspections were performed as detailed below: ,

j Electrical Walkdowns (51063)

(' The NRC inspector witnessed testing of three triax cab.1.es for

NCRs 88-13360, 88-13363, and 88-13400. Packages were in ordor ;

, and current up to the step in the particular traveler that was i

being witnessed. ,

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The NRC inspector accompanied SWEC ongineers on walkdowns for '

FVM CPE-FVM-EE-023, "Acquire Data for Cable Percent-Fill ;

Calculations and Identification of Thru-Floor and Thru-Wall

. Embedded Conduit Sleeves," for rooms 53, 62, and 72 ,

j (package 023-SG-790-72-1). No discrepancies were noted. '

As previously noted in Unrosolved Item 445/8853-U-02 in NRC

Inspection Report 50-445/88-53; 50-446/88-49, a room .

surveillance walkdown ovaluation was conducted by the NRC '

t inspector in rooms 150A and 151A for all completed SWEC

, electrical FVMs. The FVM inspections had been previously l

j completed by quality control inspectors. The NRC inspector ;

, found soveral errors and omissions where the hardware did not 1

4 agroo with the data sheets. The discrepancies were forwarded i

to the applicant for action. Subsequently, and as a result of I

the NRC findings, a surveillance of 20 other rooms revealed !

several more dj.screpancies in approximately half of the rooms. i

l As a result of the magnitude of this problem, this Unrosolved l

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Item 445/8853-U-02 is changed to a violation (445/8859-V-01). L

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An inspection of trays near penetrations was performed to

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observe Kapton splices. Trays were uncovered. T14BREC19 had

a piece of sandpaper near the splices, apparently from work on

a nearby overhead support weld. Two spare Kapton wires were i

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lodged in a gap between tray sections at the splice plate and

protruded above the tray edge. T14RREA26, T14BEEG01, and

T14REEE02 also had uncovered Kapton splices. Additionally, 1

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non-Class 1E trays T13KECW60 and T14KEDN 34 were observed tor

(1) have no covers, (2) have splices protruding above tray i

wall extensions, (3) have temporary ground cables running

through tray sections, and (4) have some Kapton leads adjacent i

to tray edges. Subsequent discussions with the applicant l

indicated walkdowns were being performed, a-cable expert was ,

being brought in, and recommendations / reports would be

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provided in the near future. Further observations will be

made and tracked by NRC Open Item 445/8852-0-08 (see .

paragraph 9.a).

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8. Plant Tours (51063)

At various times during this report period, the NRC inspector ,

conducted inspections of the Unit 1 and common plant areas,

auxiliary, and electrical / control buildings. These ;

inspections were conducted to observe work in progress, 1

equipment protection and storage, and general housekeeping i

activities. No deviations or violations were observed. !

9. Significant Mootings (30702)

Messrs. R. Warnick, H. Livormore, J. Taylor, S. Phillips, and !

S. Burris mot with Messrs. P. Stevens and J. Waters on

August 18, 1988, to discuss applicant actions /results on

various electrical items as follows:

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a. Kapton insulation: The applicant stated that IE !

Notico 87-08 on Limitorque motors was not applicable to j

the plant because the Kapton in uso is jackotod; whereas, j

the aircraft variety is not. Areas where Kapton is used :

includo electrical penetration assemblics (EPAs), !

olectrical conductor seal assembly (ECSAs), feedwater i

valvo solenoids, Westinghouse hydrogen recombinors, and !

the Gammamotrics neutron flux detector. Applicant ;

walkdowns are in progress to inspect and identify any !

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other areas of Kapton installation. Additionally, '

breakout areas are protected by tray covers por ES-100.

An open item exists to track further results and actions !

in regards to Kapton usage. (Reference 445/8852-0-08).

b. Rofurbishod Westinghouso breakers: The applicant f

investigated and dotermined that they are not on the i

distribution list for affected breakor suppliers. The ;

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l applicant' notes that they also require manufacturer's

certifications and are also_having local suppliers check

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c. The applicant agreed to follow-up on consideration of (

NRC's concern regarding use of relays with nameplate

ratings loss than the required load.

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l d. Lighting separation: The applicant screened

I approximately 1100 NCRs that were originated t

i approximately one month on either side of improperly i

L dispositioned NCR-CE-87-10192 and found no further

discrepancies. The problem was apparently caused by a ,

rush to close out a room' turnover at the time.. !

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e. Panel wiring tyrap support mountsa On closure of l

SDAR CP-36-69 (see NRC Inspection Report 50-445/88-53; !

50-446/88-49) the NRC inspector questioned why the !

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qualification of adhesive-backed plastic mounts inside

l some cabinets was not addressed. Applicant will

i follow-up progress on DR C88-03582. (Reference Open Item

445/8853-o-01). !

10. Exit Meetino (30703) [

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An exit meeting was conducted September 8, 1988, with the

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applicant's representatives identified in paragraph 1 of this ,

I report. No written material was provided to the applicant by

l the inspectors during this reporting period. The applicant

I did not identify as proprietary any of the materials provided l

to or reviewed by the inspectors during this inspection. !

During this meeting, the NRC inspectors summarized the scope l

and findings of the inspection.

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ML20155B597

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