ML20244C780

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Safety Insp Repts 50-445/89-19 & 50-446/88-19 on 890308- 0404.Violations Noted.Major Areas Inspected:Applicant Actions on Previous Insp Findings,Followup on Violations/ Deviations & Action on 10CFR50.55(e) Deficiencies
ML20244C780
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 04/14/1989
From: Livermore H, Runyan M
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20244C772 List:
References
50-445-89-19, 50-446-89-19, NUDOCS 8904200412
Download: ML20244C780 (17)


See also: IR 05000445/1989019

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APPENDIX B

U.

S. NUCLEAR REGULATORY COMMISSION

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OFFICE OF NUCLEAR REACTOR REGULATION

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NRC' Inspection Report:

50-445/89-19

Permits: CPPR-126

50-446/89-19

CPPR-127

Dockets: 50-445

Category: A2

50-446

Construction Termit

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Expiration Dates:

Unit 1: August 1, 1991

Unit 2: August 1, 1992

Applicant: .TU Electric

Skyway Tower

400 North Olive Street-

Lock Box 81

Dallas, Texas

75201

Facility Name:

Comanche Peak Steam Electric Station (CPSES),

Units 1 & 2

Inspection At:

Comanche Peak Site, Glen Rose, Texas

Inspection Conducted: March 8 through April 4, 1989

Inspector:

NVctf-E -

I-/ /- 83

g M. F. Runyan, Resident Inspector,

Date

Civil Structural

(paragraphs 2, 4, 5, 6, and 7)

Consultants: W. Richins, Parameter (paragraphs 2, 3, 5, and 6)

J. Dale, EG&G (paragraphs 2, 5, and 6)

J. Birmingham, RTS (paragraph 3)

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Reviewed by:

Auf.A.udtr2P ,

V- /Y'- 8S

H. H. Livermore, Lead Senior Inspector

Date

8904200412 890414

PDR

ADOCK 05000445

O

PDC

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Inspection Summary:

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Inspection Conducted:

March 8 through-April 4,

1989 (Report

50-445/89-19; 50-446/89-19)

Areas' Inspected:: Unannounced, resident safety inspection of the

applicant's actionsfon previous. inspection findings, follow-up on

. violations / deviations, action on 10 CFR 50.55 (e) deficiencies

identified by.the applicant, Post-Construction Hardware Validation

Program (PCHVP),-and. general plant areas (tours).

Results: . Within the' areas inspected,.a weakness was identified

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regarding QC measurement' techniques (paragraph ~2.g).

One violation.

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.was identified regarding methods used by QC to measure valve stem;

orientation andLincore instrument tubing dimensions within the

PCHVP (paragraph.2.g)..

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DETAILS

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Persons Contacted

  • R. W. Ackley, Jr., Director, CECO
  • J. L. Barker, Manager, Engineering Assurance, TU Electric
  • D.

P. Barry, Senior Manager, Engineering, Stone and. Webster-

Engineering Corporation (SWEC)

  • J. W. Beck, Vice President, Nuclear Engineering, TU Electric
  • M. R. Blevins, Manager, Technical Support, TU Electric
  • H. D. Bruner, Senior Vice President, TU Electric
  • W.

J.

Cahill, Executive Vice President, Nuclear, TU Electric

M. R. Clem, CAP, Structural, SWEC

  • J. T. Conly, APE-Licensing, SWEC
  • C.'G.

Creamer, Instrumentation & Control (I&C) Engineering

Manager, TU Electric

H. M. Crockett, Engineering, TU Electric

  • G.

G. Davis, Nuclear Operations Inspection Report Item

Coordinator, TU Electric

  • J.

C.

Finneran, Jr., Manager, Civil Engineering,

TU Electric

  • C.

A. Fonseca, Deputy Director, CECO

  • W.

G. Guldemond, Manager of Site Licensing, TU Electric

N. D. Hammett, Engineering Assurance, Brown and Root (B&R)

  • T.

L. Heatherly, Licensing Compliance Engineer,

TU Electric

  • J.

C. Hicks, Licensing Compliance Manager, TU Electric

  • C.

B. Hogg, Engineering Manager, TU Electric

  • A.

Husain, Director, Reactor Engineering, TU Electric

  • S.

D. Karpyak, Nuclear Engineering, TU Electric

  • J.

J. Kelley, Manager, Plant Operations, TU Electric

  • O. W. Lowe, Director of Engineering, TU Electric
  • D.

M. McAfee, Manager, Quality Assurance (QA), TU Electric

  • S.

G. McBee, NRC Interface, TU Electric

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

D. Noss, Licensing, Daniel

  • E.

F. Ottney, Program Manager, CASE

  • J.

D. Redding, Executive Assistant, TU Electric

  • D.

M. Reynerson, Director of Construction, TU Electric

  • M.

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

  • A.

H. Saunders, EA Evaluations Manager, TU Electric

  • A.

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

  • C.

E. Scott, Manager, Startup, TU Electric

  • J.

C.

Smith, Plant Operations Staff, TU Electric

  • M.

R. Steelman, Licensing, TU Electric

  • P.

B.

Stevens, Manager, Electrical Engineering, TU Electric

  • J.

F. Streeter, Director, QA, TU Electric

  • C.

L. Terry, Unit 1 Project Manager, TU Electric

  • T.

G.

Tyler, Director of Projects, TU Electric

  • R.

D. Walker, Manager of Nuclear Licensing, TU Electric

  • R.

G. Withrow, EA Systems Manager, TU Electric

  • D.

R. Woodlan, Docket Licensing Manager, TU Electric

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  • J.

E. Wren, Assistant Director QA for Administration,

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TU Electric

The NRC inspectors also interviewed other applicant employees

~during this inspection period.

  • Denotes personnel present at the April 4, 1989, exit

meeting.

2.

Applicant Action on Previous Inspection Findings (92701)~

a.

(Closed) Open Item (445/8514-O-18):

'During'an NRC

inspection, the CPRT inspector identified bent flange

bolts, oversized flange bolt holes, and missing corner

. welds on a duct flange.

These items were reported on

out-of-scope No. 199 and Deficiency Report (DR)

I-M-DUPL-021-DR-1 and subsequently on Nonconformance

Reports (NCRs) CM-87-5820-X and M-85-101718-SX.

Due to

the implementation of TU Electric's Hardware Validation

Program and Corrective Action Request (CAR)-111, this

duct piece was scrapped and a new duct piece installed.

The new duct piece was as-built, detailed, and inspected

(See Inspection Report B-1-756-196-01) by EBASCO and

found acceptable.

The NRC inspector reviewed the above listed out-of-scope,

DR, NCR, and inspection reports.

The NRC inspector also

reinspected the duct piece and found it to be acceptable.

No further violations or deviations were found.

This

open item is closed.

b.

(closed) Open Item (445/8514-O-28):

During an NRC

inspection of duct support package I-S-HVDS-023, the CPRT

inspector identified possible deviations dealing with

incorrect member size and undersized welds.

These items

were addressed on DRs I-S-HVDS-023-DR-1 thru DR-11 and

subsequently on NCR M86-100321SX.

The items were then

corrected per CAR-111 and verified through the

implementation of TU Electric Procedure CPE-FVM-CS-029.

The NRC inspector reviewed NCR M-86-100321SX and

Construction Operation Traveler DH-1-1701-830-1N-1R and

verified by field inspection that all rework had been

correctly implemented and the open item resolved.

No

further deviations or violations were identified.

This

open item is closed.

c.

(Closed) Open Item (445/8514-O-31):

This item addressed

potential deviations regarding incorrect member size and

undersized welds for structural steel member

AFCO-MK-C182-7-RB.

This member is part of a platform

structure located in the Unit 1 Reactor

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building.

These conditions were identified by CPRT

duringian inspection of Verification Package I-S-STEL-88

witnessed by the NRC inspector, documented on'CPRT DRs

I-S-STEL-88-DR1 and I-S-STEL-88-DR2, and incorporated

into NCRs M86-100295SX, Revision 3, and M89-01030,

Revision 0.

These NCRs were subsequently dispositioned

"use-as-is" based on review.of calculation

16345-CS(B)-215, Revision 0, and comparison of member and

weld stresses.

The NRC inspector reviewed the

calculation and the above NCRs and concurs with the

use-as-is dispositions.

This item is closed.

d.

(Closed) Open Item (445/8615-0-11):

Tais item addressed'

an heating, ventilation, .and air-conditioning (HVAC)

chiller foundation anchor bolt,which was not. bearing a

load due to a 1/4-inch gap between the nut and the mating

surface.

A CPRT inspector identified the nonconforming

condition during the walkdown of Inspection Package

1-M-MEIN-035.

This deficiency was transferred to NCR

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PM87-00667, Revision 1, and was dispositioned " rework"

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per Specification 2323-MS-101.

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The NRC inspector examined the subject bolt in the field

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and concurred that the nonconforming condition had been

corrected.

This open item is closed.

e.

(closed) Open Item (445/8828-0-02):

This item addressed

the apparent discrepancy between the Technical

Specification (TS) limit of 150 degrees F at the reactor

cavity exhaust and the Final Safety Analysis Report

(FSAR) (9.4A.1.3) limit of 135 degrees F in the neutron

detector well, which is located in the reactor cavity.

The applicant had revised the TS to the higher limit

after demonstrating that by limiting the exhaust

temperature to 150 degrees F, the neutron detector

temperature would not exceed 135 degrees F.

The open

item was based on an understanding that an explanation of

the above would be included in future revisions of both

the FSAR and the TS.

The applicant has since decided

that the revisions are unnecessary.

The NRC inspector

concurs with this position, inasmuch as no real conflict

exists between tho TS and the FSAR.

This open item is

closed.

f.

(Closed) Open Item (445/8905-0-01):

This item addressed

methods used to evaluate the locations of Richmond

inserts located behind baseplates or which were otherwise

obscured.. The concern pertains to the overall effort to

evaluate the r.dequacy of concrete attachments per Field

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Verification Method (FVM)-075.

The item was opened when

the NRC questioned the degree of conservatism employed in

locating the probable location of inaccessible Richmond

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inserts.

-As a result of further review of FVM-075

calculations, the NRC inspector has concluded that the-

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method used to estimate Richmond insert locations was

sufficiently accurate to provide confidence in the

resulting calculated bolt capacities.

Therefore, the

original issue and cause for concern no longer exists.

This open item is. closed.

g.

(Open) Unresolved Item (445/8911-U-01):

This unresolved

item addressed the concern that the method by which QC

inspectors had measured valve stem angles as depicted on-

isometric drawings did not result in the accuracy

required by Procedure AQP-11.5.

The as-built valve stem

orientation is required to be within i 5 degrees of the

angle shown on the isometric; and, thus, the measurement

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technique must attain at least this accuracy.

Valve stem

orientation was checked pursuant to the PCHVP inspection

of piping and in-line components within the Mechanical

Project Status Report.

The example specific to the ~

unresolved item was Valve ICC-692 shown' rotated

13 degrees from vertical on Isometric Drawing

BRP-CC-1-RB-003.

The as-built orientation of this valve

at'the time of the NRC inspection was about 22 degrees

from vertical.

Further information revealed that the

stem orientation of Valve ICC-692 had changed between the

time of the PCHVP inspection and the NRC inspector's

review due to construction activity.

A seal weld was

applied by Traveler CC-1-RB-003. . The traveler did not

specify a verification of the valve stem angle after the

work was accomplished; therefore, the nonconforming

condition escaped QC notice.

This discrepancy was

documented on NCR 89-2564.

The above information

suggests that the subject valve stem orientation

discrepancy was not the result of an inaccurate QC

measurement.

The above scenario suggests a deficiency in

the area of post-modification inspection and testing, and

the unresolved item will remain open pending further

review of this matter.

As part of the investigation of the original issue, a

lead QC inspector was selected to demonstrate his, and

presumably the standard, method of measuring valve stem

angles during the PCHVP walkdowns.. Afterwards, an

engineering survey crew measured two of the same angles.

The table below shows the results along with the angle as

depicted on the isometric.

Angles given are corrected to

the same orientation as measured by the QC inspector.

Valve

OC Inspector

Survey Crew

Isometric

XSF-131

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51.3

51

SFX-085

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N/A

14.3

ICS8382B

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The results of this exercise clearly demonstrated that

the method used by the'QC inspector was not accurate to

within the required tolerance of i 5 degrees.

The QC

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inspector used a protractor with a bubble, centered the

bubble, and then tilted the protractor over to better

align the leading arm to the centerline of the valve

stem. HBy tilting the protractor, he was measuring an

angle in a skewed plane and not the angle' depicted on the

isometric which is in a vertical plane.

Also, the angle

was measured from the top rather than the centerline of

the pipe.

The method was, therefore, not only

inaccurate, but also invalid.

The NRC inspector observed

two additional QC inspectors demonstrate valve stem angle

measurements, but their techniques also appeared to be

far less accurate than i 5 degrees.

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A major hardware issue probably does not exist because

all safety-related valves are being' measured by the more

accurate survey method in response to NRC Bulletin 79-14,

which is. essentially a verification of the as-built

condition of the plant.

However, any subsequent

modification or maintenance which changes valve stem

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orientation could be affected by the invalid measurement

techniques.

The failure to train QC inspectors to

properly measure. valve' stem angles is considered a

violation (445/8919-V-01).

A second example to this

violation involving the measurement of incore instrument

tubing is discussed in paragraph'5.c.

These examples are

considered a weakness in QC measurement methods involving

such programmatic issues as techniques, equipment, and

training.

h.

(Closed) Unresolved Item (445/8842-U-01):

This item

addressed concerns regarding the effectiveness of FVM

CPE-SWEC-FVM-CS-075 (FVM-075), part of the PCHVP.

FVM-075 was developed to identify concrete attachment

spacing violations based on requirements presented in

Specification 2323-SS-30, " Structural Embedments."

The

NRC inspector questioned the adequacy of FVM-075.

The applicant issued Project Technical Report (PTR)-03,

Revision 0, " Evaluation of Seismic Category I and II

Concrete Embedments" dated February 10, 1989.

PTR-03

summarizes the historical background of deficiencies

identified in Specification 2323-SS-30, and the changes

made to Specification 2323-SS-30 and Design Base Document

(DBD)-CS-015 to provide controls for in-procsss and

future concrete embedment installation activities.

In

addition, PTR-03 describes the implementation and results

of FVM-075 which addressed concrete embedments installed

prior to the above changes to Specification 2323-SS-30

and DBD-CS-015.

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FVM-075 evaluated Hilti bolts, Richmond inserts (used and

unused), Nelson studs for embedded plates and shapes,

grouted-in bolts, embedded bolts, and through-bolts, all

referred to collectively as concrete embedments.

The

- applicant segregated the concrete surfaces population

into two categories:

(1) walls and slabs consisting of

5265 surfaces, and (2) beams and columns consisting of

1659 surfaces.

A total of 53 surfaces consisting of

22 walls / slabs and.31 beam / columns were evaluated using

423 field as-built sketches prepared by field engineering

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personnel.

The sketches identified'9017 concrete

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embedments used for 3088 supports-(Category I,

II and

nonsafety'related).

All spacing' violations were

identified and evaluated in 53 calculations using current

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requirements andL49 NCRs were generated.

Stone and

Webster Engineering Corporation (SWEC).obtained actual

loads for each concrete embedment deviating from

specification requirements.- The 53 calculations were

prepared to document that the factor of safety for each

embedment meets or exceeds the requirements of

DBD-CS-015.

PTR-03 concluded that:

"The completed evaluations provide sufficient data to

assess the condition of the existing CPSES Seismic

Category I and II concrete embedments.

The evaluations

performed to date provide a 99% confidence

level .

. that the current design loads for at least

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99.8% of the seismic Category I and'II concrete

embedmonts in the unexamined balance of the plant will

provide the required factor of safety."

Based on the results of FVM-075 from evaluating the

53 surfaces sampled, FVM-075 activities will be closed by

the applicant.

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The NRC inspector previously performed field inspections

of completed as-built drawings for one beam, two columns,

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and two wall surface packages.

The NRC inspector also

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reviewed the calculations for each package which

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identified and evaluated concrete attachment spacing

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violations.

These inspections are documented in the

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following NRC inspection reports:

50-445/88-82, 50-446/88-78

50-445/89-05, 50-446/89-05

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50-445/89-11, 50-446/89-11

During this report period, the NRC inspector reviewed

Calculation 16345/6-CS(S)-462, Revision 0, " Qualification

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of IBM Personal Computer Program CES."

The computer

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program CES computes the ' pacing between concrete

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embedments and compares

.le.results with the minimum

spacing requirements of Specification 2323-SS-30 and

DBD-CS-015 (Design Basis Document) to determine if

spacing violations exist.. The calculation package

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contains a description of the' program,-user instructions,

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limitations, explanation of the program output, and.

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qualification of the program.

The.NRC inspector reviewed

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the calculation package and performed supplemental

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calculations to verify the results obtained by the

program CES. 'The NRC inspector concluded that the

progrta CES correctly identifies potential concrete

attachment spacing violations.

Based on the NRC inspection activity summarized above and

review of pTR-03, the NRC inspector concluded that the

FVM-75 program was developed and implemented in an

effective manner and adequately identifies concrete

attachment spacing violations.

This item is closed.

3.

Follow-up on Violations / Deviations (92702)

a.

(Closed) Violation (445/8603-V-04):

The disposition of

NCR M-80-00161 failed to address all aspects of the

reported nonconformance.

Specifically, the disposition

of NCR M-80-00161 addressed authorization to cut a single

layer of concrete reinforcing steel at a 2 1/2-inch

depth, but failed to address the cutting of a template

bar (i.e., a construction aid) and the notching of

another bar of reinforcing steel at a 7-inch depth.

The applicant admitted to the violation and performed the

following corrective actions.

NCR M-80-00161 was

transferred to NCR CM-87-4182 and additional

justification for the "use-as-is" disposition was

provided; however, NCR CM-87-4182 still did not address

all aspects of the nonconformance.

Subsequently, the

applicant issued NCR 89-02715 to clarify the disposition

of NCR CM-87-4182.

The NRC inspector has reviewed

NCR 89-02715 and applicable documentation.

The NRC

inspector concurs that the disposition of NCR 89-02715

addresses all aspects or the identified nonconformance.

Effective December 22, 1986, the applicant provided a

revised program for the reporting and control of

nonconformances and deficiencies.

The revised program

has been reviewed by the NRC and determined to require

proper justification of "use-as-is" dispositions.

Further, the applicant has instituted a program to review

NCRs dispositioned prior to the effective date of the

revised program.

The program has been reported to the

NRC as part of SDAR CP-86-48.

NRC inspection of that

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~ program is being performed and' reported as follow-up"to

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.SDAR CP-86-48.

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Since (1).the applicant;has taken' appropriate corrective-

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action:for'the identified violation, (2) the program for

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-nonconformance control has.been revised to preclude-

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recurrence, and.(3) a: program for thefreview'of previous-

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NCR~ dispositions has been established, this. item is

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closed.

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b.-

-(Closed) Violation (445/8882-V-01):

This violation

addressed a weld. size :for a connection on a monorail

structural framework. identified by PCHVP

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Package CS-090-SG1-834-94-S2/I3.

The weld size was

increased from.3/16-inchoto 1/4-inch by Design. Change

Authorization'(DCA)S48, Revision 5,

(issued September

31988).

The. installed weld is a 3/16-inch fillet'.

The

weld was determined by.the NRC inspector to.be undersized

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per DCA'548, Revision.5, and the criteria in

Specification 2323-SS-16B, Revision 2, " Structural

Steel / Miscellaneous' Steel."-

'The applicant stated in response to the violation

(letter 1TXX-89082, dated Februaryf24,11989) that'the

violation occurred due to personnel error.

The engineer

who prepared DCA 548, Revision 5, incorrectly used the

weld size shown on an as-built drawing for.the weld size-

on a typical section used in Revision 5 to DCA 548.

Both

the engineer and the designichange. reviewer made the

assumption that the as-built weld size applied to

numerous.similar connections shown in the DCA.

As

' corrective action, the applicant issued DCAL548,

Revision 6, to correct the weld sizes shown.

In

addition, . t.ne applicant reviewed all other DCAs

originated by the engineer who prepared DCA 548,

Revision 5 and a sample of 15 civil / structural DCAs.

No

other similar instances.were identified.

DCA trend

reports issued during the fourth quarter of 1988 did not

identify an: adverse trend for the civil / structural

discipline.'

The NRC inspector. reviewed the applicant's response,

DCA-548, Revision 6, and the above trend reports.

The

NRC inspector concluded that the applicant had taken

satisfactory measures to correct the original problem and

-provide assurance that a programmatic weakness does not

exist.

This violation is closed.

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4.

Action on 10 CFR.Part 50.55(e) Deficien6ies Identified by the

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Applicant (92700)

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a.

(Closed) Construction Deficiency (SDAR-CP-86-54):

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" Original Design of Control Room Ceiling.". By letter

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TKX-6007 dated October 3, 1986, the applicant informed

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the NRC that a deficiency involving the design and

installation of the control room ceiling was.a reportable

item.

The control room ceiling as originally designed

and installed did not comply with the provisions.of

FSAR 3.7B.2.8, in that evaluations had not been performed.

to assure that the failure of the ceiling would not

adversely affect safety-related components or operator

actions.in the control room.

As a result, a.new ceiling

was designed and installed in accordance with'the FSAR-

requirements.

Previous NRC inspection of this issue, which was

encompassed in the review of ISAP II.d, is documented in

NRC Inspection Reports 50-445/85-13, 50-446/85-09;

50-445/86-01, 50-446/86-01; 50-445/87-11, 50-446/87-09;

50-445/87-13, 50-446/87-10; 50-445/88-64, 50-446/88-60;

and 50-445/88-70, 50-446/88-66.

The NRC staff review is

summarized in NUREG-0797, Supplement No. 20 (SSER 20)

pp. 33-34.

The NRC staff concluded that this issue had

been adequately resolved; consequently, this construction

deficiency is closed.

b.

(Closed) Construction Deficiency (SDAR-CP-87-106):

" Component Design Specification Discrepancy."

By

letter TXX-7127 dated December 29, 1987, the applicant

informed the NRC that a deficiency involving the

configuration of foundation' bolting for safety-related

mechanical equipment was not a reportable item.

The

applicant determined that Specification 2323-MS-101,

Component ~ Design Specification, did not adequately define

equipment foundation bolting configurations which

subsequently resulted in inadequate bolting

installations.

In their investigation performed under

ISAP VII.c, Appendix 17, Mechanical Equipment

Installation, CPRT identified a large quantity of bolting

configuration discrepancies, but determined by

engineering calculations that none of them affected the

safety function of the equipment.

Corrective action for

this issue was performed under CAR S-53.

Specification 2323-MS-101 and associated site procedures

were upgraded and training was conducted for all

responsible QA and QC personnel.

All permanently

installed equipment was walked down by the applicant to

verify foundation bolting configurations and all

deficiencies were identified on NCRs.

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The NRC inspector reviewed file correspondence,' CAR S-53,

and ISAP VII.c, Appendix 17, Results Report, andi

concurred with the applicant's categorization and

disposition of this issue.

This construction deficiency

is closed.

5.

Post-Construction-Hardware Validation Program (PCEVP) (46053,

46055, 46071, 48051, 48053, 48055, 50073)

a.

Concrete Attachments (CPE-SWEC-FVM-CS-075)

The NRC inspector has completed inspection activities

regarding.the implementation and conclusions of FVM-075

(see the closure of unresolved item 445/8842-U-01 in this

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inspection report).

The NRC inspector concurs with the

applicant's conclusion that FVM-075 demonstrates the

adequacy of concrete attachments used for Category I

and II supports.

b.

Piping and In-line Components (CPE-SWEC-FVM-PS-081 and

CPE-SWEC-FVM-EE/ME/IC/CS-089 and -090)

(1)

BRP-CH-X-FB-010, Fuel building, Chilled Water.

This

PCEVP inspection entailed approximately 20 feet of

predominantly 1 1/2-inch piping depicted on

isometric drawing No. BRP-CH-X-FB-010,

Revision CP-1.

The only problem noted by the QC

inspector was a missing handwheel on valve XCH-310.

This discrepancy was documented on NCR 88-07883 and

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the handwheel was replaced.

The NRC inspector walked down all piping relevant to

the isometric drawing and verified that applicable

attributes were satisfactory.

The only variance

with the isometric identified by the NRC inspector

was some temporary flexible hosing installed per

DCA 75933, Revision 0.

This DCA was issued after

the date of the PCHVP inspection.

The NRC inspector

concurred with the results of this PCHVP package.

(2)

BRP-AF-1-SB-009, Safeguards building, Auxiliary

Feeddater.

This PCHVP inspection entailed

approximately 40 feet of 6-inch piping depicted on

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isometric drawing BRP-AF-1-SB-009.

The QC inspector

documented that all applicable attributes were

satisfactory.

The NRC inspector walked dcwn all piping relevant to

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the isometric drawing and verified that all

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applicable attributes were satisfactory.

The NRC

inspector concurred with the results of this PCHVP

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inspection.

However, DCA 71641 issued after the

PCHVP inspection, appeared to erroneously change a

dimension shown on isometric drawing

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BRP-AF-1-SB-009.

As depicted on p. 12 of 14 of

DCA 71641, the dimensional length of piping

segment 10 at elevation 792'

3" was changed from

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2 - 0 1/8' to l'

- 10 1/8" in response'to .

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DR-P87-00355.

The NRC inspector verified the length

as 2'

0 1/8" and questioned the applicant to' explain

the reason for-the change.

The applicant stated

that the dimensional change was needed to provide

closure for a three-dimension computer aided drawing

(CAD) of the auxiliary feedwater system.

The

specified tolerance of 2 inches between the

isometric drawing and the as-built condition was

maintained and will in this and other similar cases

be verified by QC inspection.

The NRC inspector

determined that this explanation was satisfactory.

(3)

BRP-CS-1-AB-005, Auxiliary building,. Chemical and

Volume Control System'(CVCS) positive displacement

pump discharge.

This PCHVP inspection entailed

approximately 45 feet of predominantly 3-inch piping-

depicted on isometric drawing BRP-CS-1-AB-005,

Revision CP-1.r The only problem noted by the QC

inspector was a single dimensional discrepancy which

exceeded the allowed 2-inch tolerance by 3/4 inches.

This condition was. documented on NCR PM-87-00790 and

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dispositioned "use-as-is."

The NRC inspector walked down all piping relevant to

the isometric drawing and verified that the

dimensional discrepancy described above was the only

unsatisfactory attribute pursuant to this

inspection.

The NRC inspector reviewed

NCR PM-87-00790, agreed with the "use-as-is"

disposition, and concurred with the results of this

PCHVP package.

c.

Incore Instrument Tubing (CPE-SWEC-FVM-EE/ME/IC/ CS-090)

The scope of this PCHVP activity included dimensions and

installation routing of incore instrument tubing as

depicted on drawings FSI-0043 and 1207E02 (sheets 1, 2,

and 3).

The QC inspector documented numerous

unsatisfactory dimensions pertaining to the 58 incore

instrument tubes on NCR 89-1095, which to date has not

been dispositioned.

The specified tolerance for this

inspection is i 2 inches, as required by Procedure

AQP-11.5.

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The NRC inspector attempted to duplicate 10 examples of

the QC inspector's measurements pertaining to dimensions

"C" and "D"'as shown on drawing;1207E02, sheet 2 of 3.

These dimensions' define the linear distance either side

of weld union' coupling to the point where the. tube begins

to form a 12-foot arc.

The measurements.taken by the NRC

inspector differed from those 'ecorded by the QC

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inspector by more than two inches for the seven examples

listed below.

Tube No.

Dimension Checked

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.NRC

34

C

54 3/4"

4' 11 3/4"

24

C

5'

3"

5'

0"

32

C

7'

5 1/16' 7'

2"

38.

C

6' 8 1/2"

'6' 6 1/4"

40

D

l' 3 1/2"

0'

10"

49

D

O' 9 3/8"

0' 5 3/4"

51

C

3' 10 1/4" 3'

6 1/4"

Inasmuch as the NRC inspector's measurements were

consistently shorter than those recorded by the QC

inspector, clarification was requested regarding the'QC

measurement' technique.

The NRC inspector witnessed a demonstration of the method-

used to measure dimensions

"C" and "D" by the same QC

inspector who performed the PCHVP inspection of record.

The QC inspector applied a portion of a straightedge

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flush to the linear portion of the tube and then wedged a

0.01-inch feeler gauge to the point where it stopped.

This point was then marked and used as a measurement

point.

Mathematically, a 12-foot radius bend elevates

0.01 inches in 1.7 inches of horizontal distance.

Thus,

the point marked by the QC inspector was at least

1.7 inches from the actual tangent point.

Since the arc

appears to flatten near the point of tangent, the

horizontal error most probably exceeded 2.0 inches.

Additionally, other sources of error exist, such as not

placing the straightedge directly under the tube.

The

NRC inspector measured the tangent point by observing

where light first passed between the pipe and

straightedge (i.e., no feeler gauge was used).

This

explains why the NRC measurements were consistently

shorter than the QC measurements.

Based on the above

discussion and the NRC measurements, the NRC inspector

determined that the above-mentioned QC measurements

failed to achieve the required tolerance.

This issue

constitutes the second example of Violation 445/8919-V-01

discussed in paragraph 2.g.

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d.

Heating, Ventilation, and Air-Conditioning (HVAC)

(CPE-EB-FVM-CS-029)

The NRC inspector performed field and document

inspections of the following documentation packages

generated as a result of construction, engineering, and

inspection activities related to'pCHVP:

Seismic Duct Hangers

Unit

Room

DH-1-792-1N-1A

1

127

DH-1-792-1N-1B

1

127

DH-1-792-1N-1C

1

127

DH-1-792-1N-1D

1

127

DH-1-792-1N-1E

1

127

,

DH-1-792-1N-4A

1

127.

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Duct Segments.

Unit

Room

B-1-751-141

1

129

B-1-751-142

1

129

B-1-751-143

1

129

'B-1-751-144

1

129

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Duct segments B-1-751-141, 142, 143, and 144 were

initially identified as Seismic Category II.

Concerning

these duct segments, the NRC inspector identified the

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following discrepancies:

unpainted surfaces, bent access

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door handles, oversized washers on bolts, distorted hem

flanges due to overtorque, loose register bolts, lack of

fusion on welding, and welding over galvanizing.

Subsequent to this inspection, the NRC inspector

determined that the duct segments in question are

actually non-nuclear safety.

The previous classification

was due to a typographical error.

The NRC inspector

questioned this safety classification in that Technical

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specification components (battery chargers) are located

in the same room.

The applicant provided the explanation

that the battery chargers are assumed to fail in the

accident analysis and, therefore, the ventilation of

this space is not essential for the safe shutdown of the

unit.

The NRC inspector concurred with this explanation.

In that the duct segments are not safety-related and the

identified discrepancies are not likely to affect the

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ventilation of this space, correction of the identified

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discrepancies is left to the discretion of the applicant.

No other deficiencies were identified among the items

referenced above.

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e.

Structural and Miscellaneous Steel (CPE-SWEC-FVM-

EE/ME/IC/CS-086 and CPE-SWEC-FVM-ME/EE/IC/CS-090)

FB-271B-01, platform, Auxiliary building, Unit 1:

The

NRC inspector reviewed the PCHVP package'and inspected

the platform.

The QC inspector had previously identified

. unsatisfactory conditions related to:

(1) item size and

length, (2) item location and orientation,

(3) alterations, (4) items not installed, and (5) weld

,

location.

These conditions were generally identified on

'

NCR 88-11162, Revision 0, which has not been

dispositioned.

With the exception of weld location, the

specific details of the above unsatisfactory conditions

are not provided on NCR 88-11162 or the corresponding

inspection reports.

The NRC inspector, therefore, could

not verify the location of'the unsatisfactory conditions.

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The NRC inspector. identified two additional concerns:

(1) The spacing between two bolts on the baseplate shown

in Section A-A on drawing MFB-0803-DCA, Sheet 2,

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Revision 1, is specified to be 14" (1 2").

The actual

spacing is 11.3/8".

(2) The weld type and size for the

installed toe boards are not specified.

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The above. concerns will be addressed as part of.the continuing

review of unresolved item 445/8905-U-02, which identified

similar problems.

6.

Plant Tours (46053, 48053, 42051C, 50100, 55150, 45051, 45053,

46061)

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

common areas of the facility to observe items such as

in-process work activities, equipment protection, and

housekeeping activities.

The NRC inspector' observed work in

progress related to the closure of a temporary access opening

used for cleaning and removal of debris from the seismic air

gap.

The access opening was approximately 8 feet x 8 feet in

the Auxiliary building outer wall.

The closure work was being

performed under Traveler CCE-88-1239-8404A, package

02C-8904A-1855-3 and 02C-8904A-1855-4.

The work included

'

concrete chipping, cleaning, grouting, installation of

concrete forms, cad-welding, and concrete pouring.

The NRC

l

inspector will continue observation of related work during

subsequent inspection periods.

No violations or deviations

were identified and no items of significance were observed.

7.

Exit Meeting (30703)

An exit meeting was conducted April 4, 1989, with the

applicant's representatives identified in paragraph 1 of this

report.

No written material was provided to the applicant by

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During this meeting,ithe NRC inspectors summarized the scope

Land findings'of the inspection.'

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