IR 05000445/1988067

Insp Repts 50-445/88-67 & 50-446/88-63 on 880909-1004.No Violations or Deviations Noted.Major Areas Inspected: Applicant Actions on Previous Insp Findings,Followup Insp on Item 59 & Action on 10CFR50.55(e) Deficiencies

ML20205M590
Person / Time
Site:	Comanche Peak
Issue date:	10/27/1988
From:	Livermore H, Phillips H NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20205M588	List: IR 05000445/1988067 ML20205M584
References
50-445-88-67, 50-446-88-63, NUDOCS 8811030157
Download: ML20205M590 (9)

Text

.o .'o G

-

. .

i U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS NRC Inspection Report: 50-445/88-67 Permits: CPPR-126 50-446/88-63 CPPR-127 Dockets: 50-445 Category: A2 50-446 Construction Permit Expiration Dates:

Unit 1: Extension request submitte Unit 2: Extension request submitte Applicant TU Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comancho Peak Steam Electric Station (CPSES),

Unit.s 1 & 2 Inspection At: Comancho Peak Site, Glen Rose, Texas

,

Inspection conducted: September 9 through Ocsober 4, 1988 Inspector: .

-

dM H. S.'Phillips, Senior Resident Inspector

1. / Y Date Construction

,

Rovicwed by: Sfb)ewO $w H. H. Livormore, Lead Senior Inspecter

/0/2 7 ff Cate'

f i

$911010157 GG1027 FOR hDOCK 05000445 PDC Q

__ - . _ _ _ _ _ _ - _

_

+ *

.4 #,

- .

.  ;

2  !

i Inspection Summary:

f Inspection conducted: September 9 through October 4, 1988 (Report 50-445/88-67: 50-446/88-63)

i Areas Inspected: I!nannounced, resident safety inspection o (1) applicant's actions on previous inspection findings, i (2) follow-up inspection on CPRRG Item 59, and (3) action on  !

10 CFR Part 50.55(e) deficiencie .[

Results: Within the areas inspected, no violctions or deviations .

'

were identified. Two previously identified violations discussed in this inspection report remain open pending further TU Electric and NRC action (paragraph 3). t

!

I

[

'

L a  :

1 t

.

.

i >

l

\

l)  :

'

!

i  !

a i 1 i

<

1  :

i i

!  !

,

i t

i i i

,

'

!

!

!

t

'

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

_ _ - _

,.

• * ,

.

.

DETAILS Persons Contacted

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

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

• W. G. Guldemond, Exocutive Assistant, TU Electric

• T. L. Heatherly, Licensing Complianco Engineer, TU Electric

• L. D. Nace, Vice President, Engineering & Construction, TU Electric

• D. M. Reynorson, Director of Construction, TU Electtic

• J. C. Smith, Plant Operations Staff, TU Electric

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

• J. R. Waters, Licensing Compliance Engi 7ccr, TU Eicctric The NRC inspector also interviewed other applicant employces during this inspection perio * Denotes personnel present at the October 4, 1986, exit meetin . Apolicant's Acti7n on Previous Inspection Findings (92701) (Closed) Unresolved Item (445/8715-U-03): Review of inspections performed by an uncertified electrical inspector. The NRC inspector found that TU Electric documented the inspections performed by an uncertified inspector on a Nenconformance Report (NCR) E85-1016395, Revision 1. They dispositioned the NCR (converted to

'

I DR 87-3608, Revision 1) by having a cortified inspector l reinspect about 30% of the hardware that another

! inspector inspected while not certified (1-6-85 to 2-7-85). The NRC inspector reviewed memo TUQ-4922 concerning 7 surveillances of the uncertified inspector's work which were performed to confirm his work was acceptable. A total of 44 attributes were verified for inspections performed in late 1982 and mid-1983 and 1 minor documentation discrepancy was noted. This is close (Closed) Open Item (445/8720-0-01; 446/8716-0-01):

TU Electric's procedures may not be fully implemented and organizational responsibility may not be established to assure that personnel access and materials are controlled and equipment is protected. This item was opened because the NRC had found potentially conflicting shared responsibilitics for the area and equipment in a roo It was not always clear as to who was controlling which

,

activity (equipment).

- ______ _________________ _ _ ._

,o e',

.

The NRC inspector mot with TU Electric's management on this matter. They took action and che NRC observed work operations in these buildings during subsequent inspections from 1987 until the prcsont. No further problems of this nature have been observed. Thorofore, the NRC inspector scos no further need to monitor those activitics. This item is close (closed) open item (445/8628-0-01; 446/8623-o-01):

Revisions to the drawing not specified on Traveler CE-80-032-0200 for electrical panel CPI-ECPRCB-01 and revisions to the traveler were not in accordance with CP-CPM-6.3. The NRC inspector identified those findings after similar findings were documented in NRC Inspection Report (IR) 50-445/86-20; 50-446/86-17. Accordingly, the NRC inspector referred this matter to the applicant for corrective action in response to NRC IR 50-445/86-20; 50-446/86-17. The NRC inspector confirmed that the applicant considered this during their review of actions needed to address traveler issues in NRC IR 50-445/86-20; 50-446/86-17. This item is close The NRC inspector identified other needed clarifications in the same paragraph of NRC IR 50-445/86-28; 50-446/86-23. They do not pertain to travelers and were not intonded to be a part of this open item. They portained to construction deficiency CP-80-03 and they will be addressed when CP-80-03 is reviewed by the NR (Closed) open Item (445/8817-o-05; 446/8814-o-04):

TU Electric plans to review Brown & Root's (B&R)

procedure which controls ASME construction traveler The NRC inspector reviewed B&R ASME Procedure ACP-1 which had been revised as recently as September 8, 198 This procedure replaced the old traveler Procedure CP-CPM-6.3, Revision 1 Some of the ambiguitics were climinated. As requested by TU Electric, B&R letter BRL 625 dated June 22, 1988, addressed this open ite On September 12, 1988, TU Electric advised the NRC that the ASME procedure was to be replaced with the TU Electric's procedures for travelers by october 1, 1988. The NRC inspector previously reviewed TU Electric's non-ASME traveler procedures that were far more acceptable. This item is close . Follow-up Inspection on CPRRG Recommendation Item 59, Traveler System (92702) Introduction Item 59 in Enclosure 1 to the Stello raemorandum,

"Implementation of Recommendations of Comancho Peak

,

o * .

. ,

Report Review Group," (CPRRG) dated April 14, 1987, portains to construction QA issues identified by the CPRR The specific action recommended by Item 59 was to review the construction traveler system and determine the procedural adequacy and the effectiveness of the implomontation controls in Procedure CP-CPM- Previous NRC findings regarding travelers are described in NRC IR 50-445/88-17; 50-446/88-1 In that report, the NRC inspector concluded that between 1979 s6 the NRC identified traveler problems and potential hardware problems caused by travelers. The inspector concluded that comprehensive and effective corrective action on NRC violations during the 1979-1986 time frame was not take TU Electric's response to the traveler violations was to make minor procedural revjsions which never really fixed the problem nor determined the cause. TU Electric's current constructior, management recognized this and have taken additional steps to correct the situatio b. Status of TU Electric's Review of Work Packages During carlier inspections, the NRC inspector learned that TU Electric had taken steps to address the problem of the large size of each work package. This problem affected more than 5000 Unit I work packages. The packages include travelers and associated documents such as drawings, design change authorizations (DCAs),

nonconformance reports (NCRs), inspection reports (irs),

and other miscellaneous rcJords that had been pulled from record storage by the paperflow group to expedite the construction work. TU Electric's construction management found that excessivo documentation in the packages decreased work officiency and that the work packages needed to be simplifie The NRC inspector has performed several inspections over the last six months to determine the status and adequacy of selected work packages. When TU Electric started the package improvement program, the site actually stopped some work for a period of about one week by staggering work shifts to sllow sufficient tima for packages to be reworked prior to restarting wor In addition, to simplifying the work packages, another improvement was to assign constru '.lon engineers to craftsmen in the field to reduce turn-around-time for resolving hardware and documentation problems. In discussions with craftsmen, they stated that these changes had improved the work proces In discussions with t.hc construction uanager, the NRC provid3d negative and positive feedback on these changes. The construction manager was aware of the

_ _ _ _ _ _ _ _ _ _ _

w e

,

o, e .

- .

..

problems that still exist and showed the NRC inspector plans for dealing with each issu c. Inspection of Applicablo Violations and Open Items The NRC inspector reviewed and clesed previously identified violations, unresolved and open items that relate to CPRRG Item 59, in parag raphs 2.c, 2.d above, 3.c(3), and 3.c(4) belcw. However, the NRC inspector found that the violations in paragraphs (1) and (2) below could not be close (1) (opon) Violation (445/8620-V-04b, 446/8617-V-04b):

Travelers for installing Class 1E switches on safety-related valves failed to describe or include at least one of the following: (1) specific torquing requirements for back or top cover screws, and (2) applicable instructions for installing Namco switches as required by paragraphs 3.0, 4.0, or of instruction EEI-2 The basis for kooping this item open is discussed in the next paragrap (2) (Open) Violation (445/8817-V-02): 446/8814-V-02):

This violation concerns the construction traveler system that controls work activitie Generally, it portains to Traveler Procedure CP-CPM-6.3 which states that the purpose of the traveler is to:

(1) provide sequential instructions on how to perform (civil, electrical, and mechanical construction) tasks; (2) reference additional supplemental instructions or other procedures nooded to control the work and moet applicable requirements; (3) identify required inspection, witness, and holdpoints; and (4) specify the documentation for these activitics. The violation pertained to travelers that were u:ed to control the removal and replacement of hundreds of Namco switche The travelers did not provide sequential instructions relative to cicaning threads, installing "O" rings, applying a scalant, and torquing the top, bottom, and hub of Namco switche In addition, craftsmen and QC inspectors did not sign their names and give the date signed in the column opposite the task complete During this inspection, the NRC inspector followed-up to determine if omitting work instructions and. required signatures had any effect

.._ _

..

• .

. - .

on the hardware. The NRC inspector found that TU Electric had ncit developed a correctivo action file on the violar. ion in NRC IR 50-445/88-17; 50-446/88-14, bocalso in responso TXX-88469 they contended no violation occurred. Responso TXX-88469 dated May 31, 1988, is inconsistent with the TU Electric's response TXX-6250 dated February 2, 1987, to NEC Notico of Violation for NRC IR Report 50-445/86-15; 50-446/86-12 which describes an almost identical violation (of CP-CPM-6.3) with which they agree From September 13 to October 4, 1988, TU Electric found no audits, surveillances, corrective action reports, or documented CPRT activity that specifically and comprehensively addressed the implementation of the traveler system described in CP-CPM- On October 3, 1988, the NRC and TU Electric hold a working level mooting to discuss the Stono and Webster Engineering Corporation (SWEC) ovaluation of the craveler ,fstem that was a part of the corrective action in CAR 095. The meeting was the result of the NRC inspector's suggestion that the SWEC evaluation might be used to close this violation if it adequately evaluated the traveler syste SWEC's response to CAR O!'S which described the overtorquing of this component was to review 1400 travelers and narrowly focus on one specific traveler problem instead of evalnat ing the traveler

.

system generically. The NRC's findings were not l factored into SWEC's evaluatio TU Electric has taken steps to improve the traveler I systera in the 1987-88 time fram In fact, the i Namco travelers in the 1986-1988 timo frame includo l

all of the sequential tasks, holupoints, and l

signatures that TU Electric contends were not needed l

in 1982 Uhen the Namco switches were installed.

,

l After the inspection period ended, TU Electric

'

committed to revise their response to the violation I to provide supplemental information.

!

l This item remains open pending the roccipt of the revised response and additional informatio (3) (Closed) violation (445/8620-V-04a; 446/8617-V-04a):

i

'

Failure to describe component loading / transfer minimum base clearance, leveling, and tightening nuts of component to embedded bolts.

l L

(..o-

.

-

l' .. - .

l 8 L

L This finding was part (A.1.c) of c three-part violation. TU Electric's response (TXX-6504) to this violation dated July 13, 1987, provided new information. The new information explained that the travelers did not include the information usually required because the injection tank was mounted a7 top of another tank instead of on a concrete bas The NRC inspector acknowledges no violation of Critorion V (failure to follow procedures) occurre This item is close (4) (Closed) Violation (446/8617-V-06): Failure to maintain traveler package at work area. The NRC inspector reviewed TU Electric's response to this violation and discussed the additional information provided to show that the heat treating operation did not require a traveler. The strip chart of a continuous recorder showed that the special process of heat treating was properly controlled. Since this confirms that no known hardware problem exists, the NRC inspector considers this item close Generic CPRRG Item 59 remains ope . Action on 10 CFR Part 50.55(o) Deficiencies Identified by the Applicant (92700)

,

(Closed) Construction Deficiency (SDAR CP-80-04): This deficiency concerned reactor vessel outlet nozzles with short safe-ends. Westinghouse id) requested TU Electric to acid etch and measure the safe-ends and they found that the nozzles at the 22 and 338 degree positions did not have the required 1/2-inch stainless steel safe ends at the surface between the safe-end and inconel weld. Measurements made by acid etching were 7/16 and 1/4 inches respectively at the above position The NRC inspector reviewed TU Electric's file, SDAR CP-80-0 The file contained 12 correspondence and corrective action documents which describe the identification, evaluation, notification and reporting to NRC, and corrective action concerning the subject deficiency. Based on this zuview, the inspector determined that the deficiency was properly identified, evaluated, corrected, and reported to the NR This conclusion is based on Westinghouse's technical evaluation in a letter (WPT-3534) dated June 20, 1980, and :

TU Electric's review of this matter. All safe-ends with ;

outside diameter (OD) dimensions less than 1/2-inch were to be reviewed by W and combustion engineering who made these vessels. ThTs review was performed and it was determined that nozzles with 1/4-inch minimum CD would be accepted because these lengths facilitate the welding provided the welder is

,

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

4 . ,

,

.

'

. . ,

,

aware of the location of the stainicss/inconel interface. In addition to providing this information to the wolder, nondestructivo examination was required to assure welding did not cause defects at this interface. W also concluded that if this condition had not been detected and cracking occurred, no safety hazard would exist. It was considered not reportabi This item is close . Exit Meeting (30703)

An exit meeting was rionducted October 4, 1988, with the applicant's represercatives identified in paragraph 1 of this repor No written material was provided to the applicant by the inspector durir.g this reporting period. The applicant did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection. During this meeting, the NRC inspector summari cd the scope and findings of the inspection.