ML20235U771
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| ML20235U771 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/28/1989 |
| From: | Livermore H Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20235U749 | List: |
| References | |
| 50-445-89-06, 50-445-89-6, 50-446-89-06, 50-446-89-6, NUDOCS 8903090367 | |
| Download: ML20235U771 (24) | |
See also: IR 05000445/1989006
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APPENDIX.B ^}
U. S. NUCLEAR REGULATORY' COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION I
NRC Inspection Report: 50-445/89-06 Permits: CPIR-126-
50-446/89-06 CPPR-127 !
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Dockets: '50-445 Category: A2-
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~50-446 ,
Construction ~ Permit
Expiration Dates:
Unit-1: August.1, 1991 3
Unit 2: August 1, 1992 l
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. Applicant:
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-TU' Electric
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Skyway Tower-
400 North Olive Street
,' Lock' Box 81
Dallas,aTexas 75201, ;
' Facility'Name: Comanche Peak Steam Electric ~Statich (CPSES),
Units 1 & 2
Inspection At: Comanche Peak Site, Glen Rose, Texas
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Inspection Conducted: January 11 through February 7, 1989
Inspection conducted by NRC consultants:
J. Dale - EG&G (paragraphs 2.a, 2.g, 3.b, 4.a, and 4 b)
J.. Birmingham - Param5ter (paragraph 3.f) ;
K. Graham - Parameter (paragraphs 2.b - 2.f,'3.c - 3.e, j
6.c, 7, and 8) ;
P. Scanish - Parameter (paragraphs 2.h - 2.k, 3.a, 3.g, l
4.c - 4.g, 5, 6.a and 6.b) i
)
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0903090367 890228 ??? !
PDR ADOCK 05000445 ' i ;
G PNU ;" !
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Reviewed by: NEOL L A~~S-BS
H. H. Livermore, Lead Senior Inspector Date
Inspection Summary:
Inspection Conducted: January 11 through February 7, 1989 (Report
50-445/89-06; 50-446/89-06
Areas Inspected: Unannounced, resident safety inspection of
applicant's actions on previous inspection findings, follow-up on
violations / deviations, action on 10 CFR Part 50.55(e) deficiencies
identified by the applicant, management meetings, Corrective Action
Program (CAP), NRC Bulletins, and general plant areas (tours).
Results: Within the areas inspected no significant strengths were
noted; however, a weakness was identified that was due to
repetitive violations identified for configuration control of
commodities after QC completion. One violation for failure to
follow procedures (paragraph 8) and one open item for a misaligned
pipe clamp (paragraph 6.b) were identified.
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DETAILS
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1. Persons Contacted
*R. W. Ackley, Jr., Director, CECO
*M. Alexander, Manager of Materials Management, TU Electric
*J. L. Barker, Manager, Engineering Assurance, TU Electric
*D. P. Barry, Sr., Manager, Engineering, Stone and Webster
Engineering Corporation, (SWEC)
*J. W. Beck, Vice President, Nuclear Engineering, TU Electric
*H. D. Bruner, Senior Vice President, TU Electric
*J. Buck, Senior Review Team
*W. J. Cahill, Executive Vice President, Nuclear, TU Electric
*J. T. Conly, APE-Licensing, SWEC
*W. G. Counsil, Vice Chairman, Nuclear, TU Electric
*C. G. Creamer, Instrumentation & Control (I&C) Engineering
Manager, TU Electric
*G. G. Davis, Nuclear Operations Inspection Report Item
Coordinator, TU Electric
*D. E. Deviney, Deputy Director, Quality Assurance (QA),
TU Electric
*J. C. Finneran, Jr., Acting Manager, Civil Engineering,
TU Electric
*C. A. Fonseca, Deputy Director, CECO
*W. G. Guldemond, Manager of Site Licensing, TU Electric
*T. L. Heatherly, Licensing Compliance Engineer,
TU Electric
*J. C. Hicks, Licensing Compliance Manager, TU Electric
*C. B. Hogg, Engineering Manager, TU Electric
*S. D. Karpyak, Nuclear Engineering, TU Electric
*J. J. Kelley, Manager, Plant Operations, TU Electric
*J. J. LaMarca, Electrical Engineering Manager, TU Electric
*0. W. Lowe, Director of Engineering, TU Electric
*J. W. Muffett, Manager of Engineering, TU Electric
*W. E. Nyer, Consultant, TU Electric
*E. F. Ottney, Program Manager, CASE
*S.'S. Palmer, Project Manager, TU Electric
*W. J. Parker, Project Engineering Manager, SWEC/ CECO
*A. Pereira, Assistant to Deputy Director, QA, Ebasco
*D. M. Reynerson, Director of Construction, TU Electric
*A. B. Scott, Vice President, Nuclear Operations, TU Electric
*C. E. Scott, Manager, Startup, TU Elwatric
*J. C. Smith, Plant Operations Staff, TU Electric
*C. L. Terry, Unit 1 Project Manager, TU Electric
*R. G. Withrow, EA Systems Manager, TU Electric
*D. R. Woodlan, Docket Licensing Manager, TU Electric
The NRC inspectors also interviewed other applicant employees
during this inspection period.
* Denotes personnel present at the February 7, 1989, exit
meeting.
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2. Applicant Action on Previous Inspection Findings (92701)
a. (Closed) Open Item (445/8513-0-17): While performing a
reinspection, the ERC inspector identified an undersize
companion angle and several undersize welds. These
discrepancies were documented on ERC Deviation
Reports (DRs) I-M-DUPL-019-DR2 and DR3 and subsequently
on nonconformance report (NCR) M-86-100414 SX. However,
during a recent reevaluation performed on or about
February 23, 1988, this duct segment was reclassified
nonnuclear safety and is now being tracked by TU Electric
on Non-Quality Deviation Report U1-00155. The NRC
inspector reviewed the drawings and engineering
evaluation and agrees with the reclassification. This
open item is closed.
b. (Closed) Open Item (445/8513-0-46): During CPRT
reinspection, ERC identified the following conditions to
the NRC inspector as subject to evaluation as potential
deviations for sample I-S-LBSK-047: (1) inadequate thread
engagement for a Richmond insert, (2) undersize fillet
weld, and (3) cotter pin not properly installed.
The NRC inspector verified by review of NCR-M-23190 that
all conditions identified by ERC were va]idated with ERC
deviation reports and subsequently documented with the
NCR. For conditions (1) and (3), TU Electric issued the
applicable documentation to Ic.mrk the Richmond insert
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and to replace the broken cotter ,,in. For condition (2)
confirmatory inspection of the welu ng revealed that the
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weld was undersize by 1/16-inch, but m nly in an area
5/8-inch long. The total length of the wsld is 9-inches
long. The undersize area is less than 10% of the total
weld length and therefore is not a nonconforming l
condition in accordance with ASME Section III, l
Subsection NF.
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The NRC inspector has reviewed TU Electric's
l documentation, evaluation, and corrective actions for the l
nonconforming conditions and concludes that those actions l
are in compliance with applicable procedures. This open i
item is closed.
I [ c. (Closed) Open Item (445/8513-O-53)- During CPRT 4 '
reinspection of Verification Package I-S-LINR-06, ERC
identified excessive weld reinforcement to the NRC i
inspector as subject to evaluation as a potential
deviation.
1 ( The potential deviation was documented on DR-I-S-LINR- ' 06-DR1 was validated by ERC, and NCR M-85-101324 was i
issued by TU Electric. Subsequently, ERC invalidated the
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DR based upon a review of the containment steel liner
specification (SS-14). Weld seam reinforcement criteria
is applicable to weld joints tested by radiography. For
other weld seams, where no radiographic test was
performed, this attribute of the specification does not
apply. As a result of invalidation of the ERC deviation,
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NCR M-85-101324 was dispositioned "use-as-is." The NRC
inspector concurs with the NCR disposition. This item is
closed.
d. (Closed) open Item (445/8513-0-54): During CPRT
reinspection of Verification Package I-S-LINR-013, ERC
identified excessive weld reinforcement to the NRC
inspector as subject to evaluation as a potential !
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deviation.
The potential deviation was documented on a DR, was
validated by ERC, and NCR M-85-101324 was issued by
TU Electric.
The above DR was written against attribute A.3.c of
QI-031, Revision 0 checklist. The attribute requires
that the weld seam reinforcement shall not be greater '!
than 3/32 inch. During the reinspection, a high-low gage l
was utilized to measure the reinforcement because an
adequate measuring technique was not provided in the
Quality Instruction. However, in Revision 2 of QI-031
and Change Notice 001, appropriate measuring techniques
were provided utilizing a weld contour gage to measure
weld seam reinforcement.
Reinspection of weld seam reinforcement was performed per
QI-031, Revision 2, and CN-001, and the reinforcement in
l the weld seam for joints in above packages were found ; )
acceptable. Therefore, DRs written per QI-031,
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Revision 0, were considered invalid. As a result of
invalidation of the ERC deviation, NCR M-85-101324 was
dispositioned use-as-is. The NRC inspector concurs with 4
the NCR disposition. This item is closed.
e. tClosed) Open Item (445/8513-O-55): During CPRT j
reinspection of Verification Package I-S-LINR-51, ERC
identified unacceptable weld seam surface to the NRC
inspector as subject to evaluntion as a potential
deviation. ]
"he potential deviation was validated by ERC and
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NCR M-85-101324 was issued by TU Electric. The
unacceptable weld seam surface related to the presence of
I ripplAs, grooves, ridges, and valleys on the weld
surface. Spot radiography was performed on the weld J'
joint with satisfactory results, Since the condition of
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c ,U- the weld surface was a prerequisite for radiography,Jand
the radiography was performed satisfactorily, then thei
irregular weld surface is now moot and is therefore
considered acceptable. The NRC inspector concurs with
the use-as-is disposition assigned to the NCR. This item
is closed.
f. (Closed) Open Item (445/8513-O-56): During CPRT
reinspection of Verification Package I-S-LINR-055. ERC
identified excessive weld undercut to the NRC-inspector
as subject to evaluation as a potential deviation. The-
potential deviation was validated by ERC and NCR 89-00862
was issued by TU-Electric to disposition the deviation.
Exploratory. investigation of the NCR condition was
initiated by engineering which consisted of removing
paint'from the area in question. ' Reexamination by QC
concluded that the undercut was less than 1/32 inch which
is acceptable in accordance with the containment steel
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liner specification-(SS-14).. Therefore,- the NCR was
dispositioned use-as-is by engineering. The NRC
inspector.has reviewed QC inspection results and concurs
with the NCR disposition. This item is closed.
19. . (Closed) Open Item (445/8514-0-25): The ERC inspector
identified four bolts attaching an actuator to the
mounting. bracket that did not have full thread.
engagement. This-item was documented on ERC
out-of-scope 1292 and subsequently on NCR CM-87-8897X.
The disposition to this NCR was use-as-is with the
following engineering justification:
Since the length of. thread engagement is greater than one
bolt diameter and the maximum height of a typical heavy
hex nut is equal to one bolt diameter (reference AISC 7t~h
Edition, Section 4-21), the as-built engagement is-
' sufficient to ensure that the structural integrity of the
actuator mounting is acceptable.
The NRC inspector has reviewed both the actuatur and the
AISC code reference and agrees with the engineering
justification. This open item is closed.
h. (Closed) Open Item (445/8514-0-36): ERC reinspection of
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, instrument pipe / tube supports for Verification Package
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I-S-INSP-017, which was witnessed by the NRC inspector,
identified the following as subject to evaluation as {
potential deviations: {
j (1) Support:170 had one bolt without the requir ed one l
thread past the face of the nut. j
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(2) Supports 17I, 17K, 17L, 17M,.17N, and 17Q'had bolts
without the minimum 70% of specified_ torque.
(3) Support 17K did not have.the serrated groove of the
spring nut aligned with the channel ridge.-
(4) Supports 17A, 17J, and 17K had different type
instrument tubing clamps than specified on the
drawing.
The conditions identified were documented on DRs
I-S-INSP-017-DR-2, 3, 5 through 10, 15, and 16. These
DRs-were later transferred to NCRs I-86-102060X,
Revision 1, and I-86-100315SX, Revision 1. .These NCRs
were dispositioned.in accordance with the rework.being
performed in response to Design Change Authorization
(DCA) 70624. The NRC inspector reviewed the DCA to
ensure that all the identified items had been adequately
' addressed. .Further the NRC inspector' reviewed the
construction travelers and inspection reports, as well as.
performed a physical inspection, to ensure that the-
necessary rework-had been satisfactorily perf(rmed.-
Based on the. efforts outlined above, the NRC inspectorc
concurs that this issue is satisfactorily resolved. This:
. item is closed.
1. (Closed) Open Item (445/8516-O-15): During the
reinspection of Verification Package I-S-PS42-25 for pipe
support CT-1-013-11-S22R, ERC identified the following as
subject to evaluation as potential deviations: no locking
devices on clamp bolts and'the location of a bolt hole in
relation to the baseplate edge was incorrect. The lack
of locking devices was documented on DR I-S-PS42-25-DR-1
which was transferred to NCR 23450N. This NCR was
dispositioned as not a nonconforming condition based on a
Code interpretation that an anaerobic adhesive (paint) is
an acceptable locking device. Subsequent to this,
DR C-87-2692 was issued to supersede NCRs dispositioned
in accordance with this Code interpretation and stated
the hardware validation program would " . . . assure that
all supports exhibit the correct locking device . . . , "
this was implemented through DCA 31900, Revision 1._ The
i NRC inspector reviewed the Hardware Valfdation Pipe-Clamp L Checklist for this support, which doctments that the
locking devices'for the clamp bolts on the subject
support are satisfactory.
The resclution for the bolt hole location discrepancy _is
documented in DCA 35259, Revision 1. The NRC inspector
reviewed this DCl. and concurs that the baseplate analyzed
as part of the pipe support calculation is the same as
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the one that was reported to exist as part of the
as-built inspection.
Further, the NRC inspector performed an independent
inspection to ensure that the as-built inspection had
adequately documented the attributes in question. Based
on this' inspection and review of the, documents listed
above,.the NRC inspector concurs that these items have
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been adequately resolved. This item is closed.
j. . (Closed) Open Item (445/8725-0-02): While performing a
walkdown of Impell's work performed for Train C conduit
and; supports in Room 130, the NRC inspector identified a
discrepancy in the span length reported by Impell between
supportsL2-23955 and 2-23956. Impell had recordedithis
span length as 40 inches and the NRC inspector measured
it to be 47 1/2 inches.. Subsequently, Impell stated that
the Level 6 interaction evaluation. determined that there
were no. safety-related equipment, systems or components
in the room. Accordingly, no interactions (either
acceptable or unacceptable) will occur in this room and ~
the conclusions initially arrived at would not be
affected. .In order.to assess the potential impact of
- other walkdown' discrepancies that may' exist, Impell
performed additional walkdowns on previously completed
work. The-results of these walkdowns are documented in
Impell Report 01-0210-1656 entitled " Accuracy and
Adequacy of Walkdown Information for Train C Conduits
(2 inches and less)." The summary of this report shows
the error rate found to be relatively low (1.9%).
Further, when the errors are factored in the analyses,
the resultant stresses do not exceed allowable values;
therefore,.there will be no safety impact due to the
small nmnber of walkdown errors. The NRC inspector has
reviewed this report and concurs with the conclusion.
l This itemLis closed. l.
k. (Open) Unresolved Item (445/8856-U-05; 446/8852-U-02):
-This item documented three examples of deviations from
the requirements of the applicable weld procedure
' specification (WPS). Two examples had unconsumed filler
material and one had an excessively large fit-up gap.
The applicant initiated an evaluation of the extent of
this condition and its safety significance under
Corrective Action Request (CAR) 88-028. In this report i
period,-the applicant presented the engineering and i
L inspection data that would form the engineering report L that would be part of the CAR response. This was
presented as the final draft of the engineering report.
This draft reported that no additional examples of joints
with unconsumed filler material were identified; however,
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seven NCRs were issued to document joints with fit-up
gaps in excess of 1/16 inch without a corresponding
documented increase in their fillet weld leg size as l
required by the WPS. . This was out of a' sample of 60 '
joints-inspected.
An engineering evaluation was performed on each joint
that was documented on an NCR. For the most part, the i
, evaluations were performed without reducing the amount of I
conservatism. However, in order to show no reduction-in j
b a design margin, which would impact the. conclusions of- j
Issue-specific Action Plan (ISAP) V.a, credit was taken i
for the amount.of penetration of weld metal into the '
fit-up gap. A physical-test had been performed on e.
previously sectioned sample, and.this test was being used
as the basis for validating this analysis approach. ,
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When-this analysis approach was initially discussed, the
NRC inspectors were presented with the test specimen
used. It was noted on the sectioned sexple that
determining the actual minimum throat dimension could be i
accomplished easily. However, on an installed tubular l
joint which is welded all around, it was not clear how~ !
the throat dimensions could be determined. The NRC ;
inspector questioned the QC personnel who were involved i
in these weld penetration measurements. They advised !
that the measurements provided were basically estimates j
of the amount of weld metal that existed in the fit-up j
gap.- The method used to arrive at the' estimates was to 1
insert a weld rod into the back of the weld joint through- I
the inspection access hole that had been drilled for the
-initial evaluation. Then, using a boroscope to ensure
that the weld rod was contacting weld metal, QC estimated
the amount of penetration into the fit-up gap.
To evaluate if this method of measurement provided ,
meaningful data, the NRC inspectors reviewed several 1
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sectioned samples of tubular joints. This review
indicated that there was a considerable amount of slag at
the root of the joint which may not be detectable using ;
the measurement method outlined above. The existence of 1
slag in the joint would lead to significantly j
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'unconservative estimates of weld offective throat using i
the measurement techniques presented. This could have a l
significantly adverse impact on the previous conclasion j
that the installed conditions will not reduce the design ;
margin determined and based on the initial design !
calculations. Furthermore, if there is an adverse impact
son the design margin, the conclusions previously
established in IFAP V.a vill be affected. f
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Further, in the meeting held-on January 20, 1989, to ,
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discuss this proposed response, additional concerns were
raised by the NRC: (1) with such a significant number of
deviations from the WPS (excessively large fit-up gaps),
the NRC felt that the sample size should have been
' increased; (2) the fact that reanalysis could prove that
a safety significant defect did not exist in the sample.
surveyed did not alter the fact that there is a
significant weld quality problem as far as fit-up is
concerned which should be addressed; (3) the sample
selected, due to its random nature, may not have been
ideal for resolving these concerns. This was based on
NRC surveillance of the reinspection efforts in response
to this CAR.
As preventive action, the engineering report proposed !
retraining ASME welders and welding supervisors in
adherence to procedural requirements, and revising
Specification 2323-MS-100 to provide for documented
fit-up surveillance inspection. The NRC reaction to
these proposed actions was that in light of the
significant fit-up problem discovered, that QA
surveillance was not sufficient to resolve this concern.
Subsequent to this meeting, the applicant presented
additional details on future actions they intended to
pursue in an effort to resolve the NRC concerns. Their
proposed actions included inspection of twenty additional
joints biased toward joints which would be more
representative of difficult fit-up conditions. Further,
that the NRC inspectors could assist in the selection of
the joint to be inspected. Also, to validate their .
measurement and analysis technique, they would review the j
seven joints which exhibited excessively la'rge fit-up
gaps and determine which of these required that they take
credit for weld metal penetration into the gap to
maintain design margin. Then they would identify the
" worst case" example and remove the joint from the
support for inspection. This inspection would be
performed by sectioning the joint to determine if the
measurement technique used had provided accurate data in i
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light of the NRC concerns. They also committed that, if
necessary, cdditional testing would be performed.
The NRC staff reaction to this proposal was acceptable;
however, it was stated that the size of the additional
sample may not be sufficient to completely resolve the
issue. Additional sampling should be based on results
found.
On January 30, 1989, the NRC inspectors, SWEC, and a QC
inspector identified 22 joints from which the
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20 additional samples would be selected. This item will
remain open pending the completion of the proposed
actions and NRC review and acceptance.
3. Follow-up on Violations / Deviations (92702)
a. (Closed) Violation (EA-86-09, Appendix A, Item I.B.6):
ASME Section III NF-4725 requires that threaded
fasteners, except high strength bolts, be provided with
locking devices to prevent loosening during service'.
Brown and Root (B&R) Instruction QI-QAP-11.1-28,
Revision 25 in Section 3.7.1 requires that exposed
threads be free of extraneous material.
Contrary to the above, measures were not established to
ensure that the standards for locking devices were
specified and included in design documents. TU Electric
issued a memorandum (CPPA 38997) that approved paint as a
locking device. They reasoned that paint when applied to
Unit 1 component supports, including fasteners; and when
set and hardened, would act on bolt and nut threads to
prevent the nut from loosening. In addition, NRC stated
.that suitability testing did not justify the use of paint
as a substitute locking device per the ASME code.
In response to the violation, the applicant stated that- '
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when it was identified that threaded fasteners had not
been locked as required and that they had already been
coated, based on their experience, it was decided that
the coating had already accomplished the locking function
in compliance with the ASME code. Further, extensive
testing was performed which revealed that the epoxy
coating process used resists breakaway torque as well as
or better than upsetting threads. Also, the use of
coating as a locking device was not incorporated into the
design specifications because it was only intended to
justify not doing a backfit mechanical locking effort on
Unit 1 and was not intended to be generically applicable
to Unit 2.
To resolve the issue, the applicant has committed to
mechanically lock all threaded fasteners on component
supports as part of the actions in response to CAR 066X.
The NRC inspector has reviewed the CAR and its
description of the problem and its justification for
closure which states that Specification 2323-MS-100 was
revised to specify the requirements for locking devices
and that Construction Procedure CP-CPM-9.10A and QC ,
Procedure QI-QAP-ll.1-28 were revised to incorporate the j
engineering requirements as specified in 2323-MS-100.
Based on review of the revised procedures including PCHVP
jnspection checklist, which requires verification that
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threaded fasteners be mechanically locked, and NRC
-inspections of numerous pipe support installations, the
NRC inspector concurs that the issue has been adequately
[ L addressed. This violation is closed.
b. (closed) violation (445/8805-V-02): The NRC inspector
identified a depression in a section of 16 gauge duct
that appeared to have been caused by grinding. This
depression exceeded 1/32-inch in depth and was,
therefore, a minimal wall violation per Specification
2323-MS-85. This condition was subsequently rechecked
and verified again by the NRC inspector and TU Electric's
Level III welding engineer. TU Electric attributed this
violation to the failure of the QC inspector to identify
the depression as unacceptable. The QC inspector was
I subsequently informed of this discrepancy and counseled
on the significance. NCR M-88-03838 was generated which
required the removal and replacement of the discrepant
section of duct. The NRC inspector has reviewed the QC
inspectors record, reviewed the NCR (M-88-03838) and
reinspected the section of duct replacement and believes
that this concern has been adequately addressed. This
violation is closed.
c. (Closed) Violation (445/8820-V-01; 446/8817-V-01):
Ultrasonic digital thickness (UT/DT) measurements of site
fabricated pipe bends to verify acceptable post-bend wall
I thickness, a Corrective Action program commitment, were ,
performed through protective coatings (primer and paint)
without consideration of the impact of protective
l coatings on accuracy of the UT/DT measurements. !
CAR 88-019 dated March 25, 1988, was issued to document
and resolve the issue of UT/DT through coated carbon
steel pipe surfaces. The disposition of CAR 88-019
requires that carbon steel pipe bends evaluated under
PCHVP prior to March 25, 1988, be reexamined for pipe
wall thickness with protective coatings (primer and
paint) removed. The NRC inspector has reviewed the
closed CAR. As a result of the NOV, a total of 204
carbon steel pipe bends were reexamined after removal of
protective coatings. Eight bends were acceptable per
initial UT inspection, but rejectable after protective
I coatings removal. Five bends were rejectable per initial
inspection and were subsequently found to be thinner
after coating removal. These discrepancies were
documented in accordance with NEO 3.05, " Reporting of ;
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Nonconformances." The NRC inspector concludes that
corrective actions are adequate.
AQP-10.9 " Ultrasonic Digital Thickness Measurement," has
been revised to preclude recurrence of this violation.
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The NRC inspector's procedural review concludes that
preventative actions are adequate. This violation is
closed.
d. (Closed) Violation (445/8820-V-02; 446/8817-V-02): While
witnessing an ultrasonic digital thickness measurement
inspection of a pipe bend on Spool 103 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, which is not an approved ink
marker.
NCR 88-05684 was initiated and dispositioned to resolve
the NRC identified condition. An additional 392 pipe
bends were examined for which seven additional NCRs
pertaining to unauthorized marker usage by the same
inspector were identified. All NCRs issued were
dispositioned " Rework." The subject inspector is no
longer employed by CPSES. These corrective steps taken
by the applicant are documented in CAR-88-019. The NRC
inspector has reviewed dispositioned and closed copies of
NCRs 88-05684 and 88-05685 and concludes that the
applicant has implemented effective corrective actions to
prevent any further use of unauthorized markers. This ;
violation is closed.
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e. (Closed) Violation (445/8832-V-01): NCR CM-87-6087, j
Revision 1, identifies nine potentially nonconforming
commodity clearance violations with respect to
installation of residual heat removal piping and pipe
supports The NCR was dispositioned "use-as-is" by
engineering personnel and approved by quality assurance
personnel, although the basis for technical acceptability
was not provided. Engineering personnel had failed to )
I
establish that the discrepancies would not result in
conditions adverse to safety and that the item could
continue to meet all engineering functional requirements.
New NCRs or NCR revisions, as applicable, have been
initiated for the original NCRs that documented commodity
clearance discrepancies and were dispositioned
"use-as-is" without sufficient technical justification.
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TU Electric has initiated a program to define and
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implement commodity clearance requirements for plant
systems. Specification CPSES-S-1021 " Commodity
Clearance" was developed to provide a clear and
consistent statement of these requirements. Commodity
clearance requirements were removed from other existing
installation specifications, refined, and consolidated in
CPSES-S-1021. Using the guidance provided by
CPSES-S-1021, an engineering walkdown will be performed l
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to systematically evaluate and correct, as necessary,
existing commodity clearance conditions. Upon completion
.of the walkdown, the commodity clearance aspects of
future construction activities are to be controlled by
CPSES-S-1021 or its equivalent.
The NRC inspector verified that NCR 88-11764 was issued
to replace previously dispositioned and closed
NCR CM-87-6087, Revision 1. The NRC inspector has
reviewed CPSES-S-1021 and concludes that a method for
procedurally controlling commodity clearance violations
has been established. NRC inspection of the commodity
clearance program will continue to evaluate the
effectiveness of the program. This violation is closed.
f. (closed) Deviation (445/8513-D-03): During performance
of Reinspection Package I-S-LBSR-047, the CPRT inspector
failed to identify and document the existence of four
drilled holes. The holes were approximately 9/16-inch
diameter and were found in Item 2, the M 4 x 13 I-Beam of
ASME pipe support CT-1-053-436-C52R. The four holes were
not required by the design drawing and should have been
documented as an out-of-scope observation.
The NRC inspector reviewed the following actions
performed by the CPRT and the applicant in response to
this deviation. The responsible inspector prepared
out-of-scope observation No. 126 to document the four
unspecified holes. The project prepared NCR M-23190N to
replace the M 4 x 13 I-Beam. The NCR was verified and
closed December 30, 1988.
The CPRT has recognized the importance of identifying and
documenting observations of out-of-scope deficiencies.
In order to provide the proper control of out-of-scope
observations, the CPRT issued CPRT Project Procedure
CPP-020, "Out-of-Scope Observations." Additionally, the
,
CPRT has instituted an overview inspection program as a
j check on the effectiveness of the CPRT reinspection
packages. The overview inspection included
f l identification of "out-of-scope" observations and was I performed for a sample of all CPRT inspectors' work.
The NRC inspector determined that the actions performed
to correct the identified deficiency and to preclude
recurrence were appropriate. Nonetheless, proper
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treatment of out-of-scope observations continued to be
l inspected during NRC inspection of CPRT activities.
Based on the above actions, this item is closed.
g. (Closed) Deviation (445/8516-D-50): While performing an
independent reinspection of the instrument pipe / tube
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supports in Verification Package I-S-INSP-033 the NRC
inspector noted that the serrated groves of the spring
nut on support 33A did not align with the channel
clamping ridge as required by attribute 4.5 of QI-055.
However, the ERC inspector signed off the attribute as
being acceptable.
In response to this deviation, the applicant stated that
a general training session on spring nut inspection was
given to all inspectors involved in the reinspection of
this attribute. Also, that an overview inspection
program was implemented on a sample of each inspector's
work and the results of these overviews would identify
the need for additional formal training of inspectors.
In addition, that corrective action would be complete
with the final disposition of CAR 72X.
The NRC finding was documented on DR I-S-INSP-033-DR2
which was transferred to NCR I-86-100071SX and
dispositioned to be reworked in accordance with the
design drawing. The NRC inspector reviewed the QC
inspection report associated with the required rework and
performed an independent inspection to ensure that the
rework had been completed. The NRC inspector also
reviewed the training records, overview inspection
reports and their conclusions relative to inspector
error, as well as the CAR and its justification for
closure and concurs that this deviation has been
adequately resolved. This deviation is closed.
4. Action on 10 CFR Part 50.55(e) Deficiencies Identified by the
Applicant (92700)
,
a. (Open) Construction Deficiency (SDAR-CP-82-02): This
item involved several horizontal fire-dampers that failed
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to operate. The cause for this appeared to be a
deficient and unacceptable design. This problem was
initially identified and' reported to the NRC by letter
TXX-3523 dated May 28, 1982. However, due to required
,
revisions in the disposition of this SDAR (SDAR-CP-82-02)
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it has been incorporated into SDAR-CP-84-008 (see letter
TXX-6584 and TXX-88352 dated August 17, 1987, and
March 30, 1988) which also deal with fire dampers. This
item will remain open pending a satisfactory disposition
and resolution of SDAR-CP-84-008.
b. (Open) Construction Deficiency (SDAR-CP-83-15): This
item concerned the attachment of the cable tray to
supports with high strength (ASTM-A325) bolts and the
,
subsequent torquing of these same bolts. The specific
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torque value is dependent on bolt size and material.
However, a review of the as-installed conditions revealed
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that in some cases mild steel bolts (ASTM-A307) were used
for bolting. This type of bolting (ASTM-A307) is not
acceptable per the design and detail arrangements. Design
calculations indicate that high strength bolting material
is required for some heavy duty cable tray clamps.
However, due to further design problems related to " Cable
Tray Hanger Design," this SDAR problem has been
incorporated into and will be tracked by SDAR-CP-85-35
which also deals, in part, with bolting. This item will
remain open pending a satisfactory disposition and
closure of SDAR-CP-85-35.
c. (Closed) Construction Deficiency (SDAR-CP-85-41): Errors
had been identified in a computer program used in the
analysis of cable tray and conduit supports. The
program, P-Delta STRUDL, Version 0385, had been observed
to contain errors in the code checking routines involving
the allowable stress factor for axial allowable stresses
and the combination of bending stresses for tubes
(structural tubing). This program was being used in the
analysis of cable trays and conduit supports for Unit 2.
In response to this concern, the applicant performed a
review of the affected calculations. This review
included rerunning the computer routines for 1000 out of
3800 affected analyses on the corrected computer program.
There were no failures detected in the 1000 examples run; ,
therefore, it was concluded that this item was not
! reportable. The NRC inspector has reviewed the
documentation associated with this construction
deficiency and concurs that there is little probability
of a safety significant condition existing due to the
identified computer program error. This construction
deficiency is closed.
I d. (Closed) Construction Deficiency (SDAR-CP-85-42):
Thermolag fire protective coating was installed on Unit 1
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1E electrical conduit raceways consistent with FSAR and
! Regulatory Guide 1.120, Revision 1. In the original
design, the weight of the fire protection was assumed
considering a round configuration of thermolag material
surrounding the conduits. However, to facilitate
construction, thermolag in square configurations had been
substituted in some locations. Engineering evaluation of
this configuration was not performed to verify if the
design assumptions had been violated. Upon review, it
was determined that the shapes used for the thermolag
could have an adverse effect on the qualification of the
conduit and supports; therefore, it was determined that
this issue was reportable.
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In response to this issue, Ebasco performed engineering
walkdowns in accordance with Procedure FVM-CS-010. This
walkdown provided a survey of 329 conduit runs,
141 junction boxes, and approximately 1500 conduit
i supports. The information from the walkdowns and
existing inspection information were incorporated into
revised drawings. Dynamic analyses were performed for
each conduit span incorporating the revised data. This
evaluation resulted in DCAs to resolve conduit support
failures and overstressed conduit runs.
To preclude recurrence of this problem, Impell issued
ECE-M1-1700, "Thermolag and RES Schedule," to identify
those raceways which will have thermolag installed.
Specification 2323-MS-38H, which provides material
requirements and allowable geometric configurations for
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thermolag, was revised to require engineering evaluation
for deviations from typical details. In addition,
ECC 10.07 was revised to require engineering release of
l raceways, indicating the evaluation is complete prior to ! thermolag installation. The NRC inspector reviewed
Impell's calculations for the weights of fire barrier and
radiant energy shield materials contained in Calculation
0210-063-0075, ECE-M1-1700 and the changes to the
specification and ECC procedure and concurs that adequate
) controls have developed to prevent recurrence of this
problem. This construction deficiency is closed.
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e. (Closed). Construction Deficiency (SDAR-CP-85-48): An
internal part in the intake silencer of the diesel
generator may not have been welded in place by the
manufacturer. If the part had in fact not been welded,
it is possible for it to be ingested into the engine on '
start-up. This condition was identified by American Air
Filter (AAF), the manufacturer of the intake silencer, in
a 10 CFR Part 21 report. They recommended that a
physical inspection be made of the interior of the AAF
silencers.
In response to the Part 21 notification, the applicant
issued NCR M-19303 through 19306 and 19652 through 19654
to inspect and document the weld configuration for the
end caps in question. The results of the weld inspection
indicated that, while all the end caps were welded in ;
place, the welds found on the end caps did not conform to i
the manufacturer's design drawing. This inspection
information was forwarded to AAF who advised that this
item is not highly stressed and that the as-found
condition was acceptable. Therefore, the applicant
determined that if this condition had gone undetected, no
condition adverse to safety would have existed. The NRC
inspector has reviewed the NCRs, the drawings, and
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correspondence from the vendor and concurs with'the
applicant's assessment. This construction' deficiency is
closed.
f. (Closed): Construction Deficiency (SDAR-CP-86-05): During
an unrelated review:by the site Civil Engineering Group,
a safety class pipe support was observed mounted.to a
-nonsafety-related embedded' plate. Further evaluation
identified three additional supports mounted.in a similar
i manner. Reanalysis by the applicant concluded that for
three of the systems involved no adverse condition
existed. For the remaining support, a physical test of
the embedded plate was required. The results of this
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test showed that the embedded plate was capable of
carrying two times the. anticipated Level C load on the
hanger.
The NRC inspector reviewed the analyses and test results.
generated in. response to this construction deficiency and
concurs that this issue has been fully evaluated and that
no condition adverse to safety exists. This construction
deficiency is closed.
g. (Closed) Construction Deficiency (SDAR-CP-86-73): Rear
brackets supplied by NPSI on ASME snubbers have the
potential for restricted movement and binding-due to:
the use of the wrong bracket, faulty welding, and/or
fabrication tolerances. Based on a. review performed by
Stone and' Webster it was determined that this was a
reportable issue.
As corrective action, 1063 snubbers were identified as
having rear brackets with attributes that could cause
restricted movement and/or binding of the snubbers. A
field inspection-combined with an engineering review
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eliminated all but 165 supports. Further evaluation
identified specific causes for the deficiencies:
(1) assumption of interchangeability of parts may not
have been valid due to manufacturers design changes,
(2) forward brackets for size 3 (SMF) snubbers that are
fabricated;at the minimum specified "c-c" dimension do
not have the' full required 5 degree swing angle when
pinned:to a rear bracket, and (3) size 10 snubbers,
depending on which revision of rear bracket was used and
which fabrication tolerances were used, may not have the
full required plus or minus 5 degree swing. Rework on
the affected supports has been accomplished.
In response to this SDAR and the evaluations performed,
the minimum "c-c" dimensions for size 3 and 10 snubbar
forward brackets were revised. Specification 2323-MS-100
and Construction Procedures CP-CPM-9.10A and ACP-11.5
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were revised to require inspection of size 10 snubbers
during installation to assure an adequate swing angle.
Further, inspection criteria were revised in
Procedures AQP-ll.3, AQP-ll.5, QI-QAP-11.1-28, and
CP-QAP-12.1. The NRC inspector has reviewed the changes
to the specification and procedures and-finds that they {
are consistent and fully address the stated concern.
Based on these reviews as well as physical inspections of
modifications performed in response to this issue the NRC
inspector concurs that this issue has been adequately
resolved. This construction deficiency is closed.
5. Management Meetings (30702B)
On January 17, 1989, a management meeting was held between NRC
headquarters and site staff and the applicant to discuss
actions to be taken by the applicant in response to the
unresolved item (445/8871-U-01) that was previously reported , ,
concerning errors found in SWEC piping and pipe support
calculations. The applicant outlined actions taken since this :
item was initially reported which included, in part, a review
of specific calculations cited by the NRC inspector. This
review judged that the conclusions of the calculations, when
corrected because of the errors found either by the NRC review
or SWEC's review, were unchanged. Further, audits performed
on SWEC's calculations have reviewed in excess of 1000 support
calculations found similar errors to those identified by the
NRC. These also had no effect on the conclusions of the
calculations. Therefore, the applicant has concluded that
there is little probability of a safety significant problem
existing in SWEC's design calculation process. However, the
applicant stated that since the existence of errors is not
consistent with their efforts to strive for perfection, even
though this goal may not be practically attainable, it was
deemed prudent to enhance SWEC's method of review for their
calculations.
This enhancement included training of personnel involved in
performing and reviewing calculations to reinforce the fact
that errors in calculations are not acceptable and to outline
the changes to the manner in which calculations would be
reviewed. Also, supervisors and management would become more
involved in the calculation review process; performing, at a
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minimum, checks of a sample of current calculations and if
errors are detected discussing the types of errors with the
personnel involved in the performance and review of the
discrepant calculation. Further, performance of these efforts
would be reviewed periodically by QA personnel. The applicant
felt by instituting these additional steps into the review
process that the finished product would more closely approach
their goal of perfection.
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On January 19, 1989, the NRC inspector attended two of SWEC's
training programs associated with the enhancements of their
review process. The first session was for the supervisors.
In this session, the changes in the work flow that affected
how reviews were to be performed were discussed. The need for
supervisory input to the review process was emphasized. Also
discussed was the new form that must accompany all
safety-related calculations documenting the method used to
perform'the review. This form has a requirement that if less
than a line by line review is performed then a written
justification must be added to the review form. This session
also emphasized the need for quality, professionalism, and
pride in one's work. The second session attended by the NRC
inspector was for calculation preparers. In this session, the
specific errors found in the sample reviewed by the NRC were
!
discussed to highlight the types of shortcomings that
) currently exist in the pipe support calculations. It was
stressed that the preparer was responsible for the quality of
his work and that it was his responsibility to check his own
work before turning it in to his supervisor for review. In
the opinion of the NRC inspector, these two training sessions
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were well presented and stressed the items that needed to be
( emphasized in an effort to correct a problem of this nature. i This unresolved item remains open pending further review of
the applicant's actions and implementation actions by the NRC
inspector.
6. Corrective Action Program (CAP)
a. Commodity Clearance Program (FVM-068) (50073, 50071)
on January 20, 1989, the NRC inspector attended one of
the weekly training sessions held by SWEC's group that
will be performing the engineering walkdowns and
evaluations for the Commodity Clearance Program. The
walkdowns for this effort, because of schedule
considerations, are planned to be done in two steps. The
first effort will be to walkdown all necessary piping
systems to identify any clearance problems and rework
that could impact hot functional testing. Subsequent to
this walkdown, each individual room would be revisited to
effect a complete commodity clearance review. The
training sessicn attended by the NRC inspector covered
the types of clearance violations being encountered,
proposed methods of resolution, methodology for
performing data collection, etc. This session seemed to
be an effective means of sharing experiences and
promoting an efficient method of processing the required
work.
As part of the overview of this program, the NRC
inspector accompanied a group of engineers to review the
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data collected in their performance of the walkdowns for
'FVM-068:in the diesel generator room. The walkdown-
engineers explained the process they used to perform the
work, the types of clearance violations'found and the-
proposed resolutions. They also explained the rational
for not considering certain items as potential
violations.
The NRC inspector believes that this program is:well
defined and the NRC inspector will' review implementation
of'the complete program when the effort for individual
roomslis~ underway. No violations or deviations were
identified.
b. . Piping ^and Pipe Supports (50090)
On a plant tour, the NRC inspector identified a pipe
. clamp that was rotated on the pipe so'that it was no
longer parallel with the: sway strut. The clamp in
question was.part of the support VA-X-004-704-A73R.' The
concern was because the clamp was not properly aligned
that a potential exists for the clamp to bind on the
paddle end of the sway strut due to thermal and/or
seismic movement. Review of the documentation for this
support revealed that it had-been accepted by QC and the
fact that the alignment of'the clamp was out-of-tolerance
had not been documented. This condition was. reviewed by
SWEC and they determined that had this condition gone-
undetected the anticipated movement of the piping would
not have caused a binding condition. SWEC also issued
unsatisfactory inspection report (IR) 1979 to document
the out-of-tolerance installation. This will be an open
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item pending NRC review of the disposition of.the IR
(445/8906-o-01).
c. Onsite Design Activities (37055)
The purpose of this inspection was to evaluate onsite
design activity and preparation and control of
construction travelers used to implement design changes.
Control of the design change process relative to the
following was reviewed:
'l
. Drawings and revisions
. Specifications and revisions
. Codes and standards
. Design verification
DCA 62122, Revision 15, and DCA 62123, Revision 15, were
reviewed by the NRC inspector. These DCAs dealt with the
removal of piping from portions of the component cooling ]
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water system and the replacement of that piping with i
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flexible hose installations. For each DCA nine different
spool sections were modified. The design changes
resulted from a SWEC piping stress requalification
effort. The design changes were processed as
" confirmation required" DCAs.
The NRC inspector questioned design personnel as to why
such a large number of revisions (15 each) were required
for these DCAs. Engineering personnel responded that
this occurred due to nine spool pieces being modified by
a single DCA, the difficulty in achieving a configuration
compatible with the close proximity of other components,
and the flex hose vendors stringent installation
requirements. As a result of the approach used, each of
the rine spool piece modifications resulted in
approximately 100 pages of documentation after
installation, that is approximately 900 pages per
construction complete DCA. ,
Discussions with the design engineers and review of
documentation supporting the DCAs revealed that the >
vendor was actively involved in resolution of clearance
problems associated with installation of the flex hoses.
NRC inspection concluded that the person performing the
design review of the DCAs was independent from the
individual who originated the design change. These
design changes were issued with confirmation required.
At the time of NRC review, confirmation had been obtained
and approved in accordance with site procedures.
The DCAs were reviewed for compliance with applicable
codes, standards, and specifications. No discrepancies
were.noted.
The NRC inspector reviewed the construction travelers
used to implement the design changes to evaluate:
. Adequacy of documentation and document control. !
. Adequacy and clarity of installation instructions.
. Compliance with QA program requirements.
NRC inspection concluded that the travelers were properly j
'
prepared, reviewed prior to issue, contained adequate
instruction to craft personnel, and that appropriate
quality holdpoints had been established and completed.
With respect to the large amount of documentation
required for each DCA, the NRC inspector concludes that
TU Electric methodology for implementing these design
changes created an unnecessary amount of documentation
and placed an unnecessary burden on craft and QC
personnel who must interpret those documentation
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requirements. No violations or deviations were
'
identified.
7. NRC Bulletins (92703)
NRC Bulletin 88-05: Nonconforming Materials Supplied by
Piping Supplies, Inc., at Folsom, New Jersey, and West Jersey
Manufacturing Company at Williamstown, New Jersey
NRC inspectors and the Chief Inspector, Department of Labor
and Standards, State of Texas, met with TU Electric management
on January 13, 1989, to discuss the subject bulletin. The
inspectors were presented with an overview of TU Electric
activities and conclusions with respect to material received
from these vendors. TU Electric letter TXX-89005 provides the
applicant's official response and conclusions. At the end of
this inspection period, the NRC inspection staff had not
reviewed TXX-89005. Action on this Bulletin remains open.
8. Plant Tours (50090)
The NRC inspector performed a field tour to evaluate the
status and completion of construction activities in Unit 1 and
common areas. The NRC inspector observed that jam nuts on a i
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U-Bolt which is part of pipe support CS-1-AB-238-010-2 were
loose. Further inspection revealed that the U-Bolt (Bill of
Material Item No. 4) was not properly adjusted to allow free
axial movement of the chemical and volume control system
piping.
QC personnel were contacted to determine the inspection status
of the pipe support. This pipe support was statused as
inspection complete and acceptable under the Post-Construction
Hardware Validation Program.
Installation and inspection instructions require that pipe
clearances within a U-Bolt shall not be less than 1/32-inch
for the subject pipe support design and that jam nuts be snug
tight. It was apparent that the U-bolt had been tightened
down on the pipe thereby negating any clearances and also
loosening the jam nuts. The lack of configuration control !
(clearance) could impair the pipe support design functions. 1
The NRC inspector concluded that either unauthorized work or l
inadequate inspection resulted in the observed condition. NRC ;
Inspection Reports 50-445/88-65, 50-446/88-61 and
50-445/87-16, 50-446/87-13 document similar violations of
configuration control requirements. The example described
above is a violation of Criterion V (445/8906-V-02).
9. Open Items
open items are matters which have been discussed with the
applicant, which will be reviewed further by the inspector,
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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 6.b'(misalignment ofLa
pipe clamp)..
10. Exit Meeting (30703B)
An exit meeting.was conducted February 7, 1989, 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. tThe 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 j
and findings of the inspection.
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