IR 05000445/1989019: Difference between revisions

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{{Adams
{{Adams
| number = ML20244C780
| number = ML20247E594
| issue date = 04/14/1989
| issue date = 07/21/1989
| title = 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
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/89-19 & 50-446/89-19
| author name = Livermore H, Runyan M
| author name = Warnick R
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| addressee name =  
| addressee name = Cahill W
| addressee affiliation =  
| addressee affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| docket = 05000445, 05000446
| docket = 05000445, 05000446
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-445-89-19, 50-446-89-19, NUDOCS 8904200412
| document report number = NUDOCS 8907260227
| package number = ML20244C772
| title reference date = 07-14-1989
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 17
| page count = 3
}}
}}


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APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION
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!  OFFICE OF NUCLEAR REACTOR REGULATION L
NRC' Inspection Report: 50-445/89-19 Permits: CPPR-126 50-446/89-19  CPPR-127 Dockets: 50-445  Category: A2 50-446
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Construction Termit 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)      4 Reviewed by:  Auf.A.udtr2P ,  V- /Y'- 8S H. H. Livermore, Lead Senior Inspector  Date 8904200412 890414 PDR O ADOCK 05000445 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).
 
n  Results: . Within the' areas inspected,.a weakness was identified regarding QC measurement' techniques (paragraph ~2.g). One violatio J .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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JUL ? I 1989 In Reply Refer To:
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Dockets: 50-445/89-19 50-446/89-19 Mr. W. J. Cahill, Jr.
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DETAILS 1.' 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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Executive Vice President TU Electric 400 North Olive' Street, Lock Box 81 Dallas, Texas 75201
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  *J. E. Wren, Assistant Director QA for Administration, l    TU Electric The NRC inspectors also interviewed other applicant employees
==Dear Mr.'Cahill,==
  ~during this inspection perio * Denotes personnel present at the April 4, 1989, exit meetin . Applicant Action on Previous Inspection Findings (92701)~ (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
Thank you for your letter dated May 15, 1989, and supplemental letter dated July 14, 1989,'in response to our letter dated April 14, 1989. As discussed in previous meetings, we considered your first response to the Notice of Violation to lack a necessary evaluation of the adequacy of QC training with respect to the cited examples. Your supplemental response satisfactorily addressed our concern. 'We have no further questions at this time.
    . 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-S 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 installe The new duct piece was as-built, detailed, and inspected (See Inspection Report B-1-756-196-01) by EBASCO and found acceptabl 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 acceptabl No further violations or deviations were found. This open item is close (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-02 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 close (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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Sincerely, bmCINhL SIG'NED BY H. F. V7ARNTCT R. F. Warnick, Assistant Director for Inspection Programs Comanche Peak Projects Division *
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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 close 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 .
PM87-00667, Revision 1, and was dispositioned " rework" I per Specification 2323-MS-10 I l
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The NRC inspector examined the subject bolt in the field and concurred that the nonconforming condition had been corrected. This open item is close 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 cavit 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 FSA This open item is close 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 i 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 i
IP:CPPD:NRR IP:CPPD:N ' AD:IP:CPPD:NRR
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  //v7/t/80 7/t1/89 7/2s/89 i
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inserts. -As a result of further review of FVM-075 calculations, the NRC inspector has concluded that the-  '
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 exist This open item is. close 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 Repor 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 notic This discrepancy was documented on NCR 89-256 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 matte 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 angle 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 inspecto Valve OC Inspector Survey Crew Isometric XSF-131 34 5 SFX-085 9 N/A 1 ICS8382B 30 4 ;
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7  j 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 E  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
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far less accurate than i 5 degree 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 trainin 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 PCHV 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-07 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 activitie 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-01 l
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'pf jg  UNIT ED STATES g' g NUCLEAR REGULATORY COMMISSION g .: p  W ASHING TON,0. C. 20555 e
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  " " * * $~a  JJL ? I 1989 In Reply Refer To:
Dockets: 50-445/89-19 50-446/89-19 Mr. W. J. Cahill, Jr.


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Executive Vice President TU Electric
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, 400 North Olive Street, Lock Box 81 Dallas, Texas 75201
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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 embedments used for 3088 supports-(Category I, II and nonsafety'related). All spacing' violations were identified and evaluated in 53 calculations using current    j 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-01 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 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 applican (
==Dear Mr. Cahill,==
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Thank you for your letter dated May 15, 1989, and supplemental letter d.ated July 14, 1989, in response to our letter dated
The NRC inspector previously performed field inspections of completed as-built drawings for one beam, two columns,     4 and two wall surface packages. The NRC inspector also    i reviewed the calculations for each package which    )
. April 14, 1989. As discussed in previous meetings, we considered your first response to the Notice of Violation to lack a necessary evaluation of the adequacy of QC training with respect to the cited examples. Your supplemental response satisfactorily addressed our concern. We have no further questions at this time.
identified and evaluated concrete attachment spacing    ]
violations. These inspections are documented in the    l following NRC inspection reports:
50-445/88-82, 50-446/88-78 50-445/89-05, 50-446/89-05    1
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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    )
of IBM Personal Computer Program CES." The computer    j
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Sincerely, RFIDaA R. F. Warnick, Assistant Director for Inspection Programs Comanche Peak Projects Division Office of Nuclear Reactor Regulation j
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~      l program CES computes the ' pacing between concrete l 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 !
contains a description of the' program,-user instructions, i limitations, explanation of the program output, an k p  qualification of the program. The.NRC inspector reviewed )
the calculation package and performed supplemental j calculations to verify the results obtained by the program CES. 'The NRC inspector concluded that the progrta CES correctly identifies potential concrete attachment spacing violation 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 close . Follow-up on Violations / Deviations (92702) (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 dept 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 nonconformanc 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" disposition 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
  .SDAR CP-86-4 ]
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Since (1).the applicant;has taken' appropriate corrective- f action:for'the identified violation, (2) the program for  1
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  -nonconformance control has.been revised to preclude-
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<x  recurrence, and.(3) a: program for thefreview'of previous-NCR~ dispositions has been established, this. item is  3 close )
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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 I
Package CS-090-SG1-834-94-S2/I 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
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weld was determined by.the NRC inspector to.be undersized 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 exis This violation is close ,
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4. Action on 10 CFR.Part 50.55(e) Deficien6ies Identified by the 1 Applicant (92700)    l
  -    I (Closed) Construction Deficiency (SDAR-CP-86-54):  !
  " Original Design of Control Room Ceiling.". By letter j '
TKX-6007 dated October 3, 1986, the applicant informed the NRC that a deficiency involving the design and installation of the control room ceiling was.a reportable ite 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 performe 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-requirement 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 close (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-5 Specification 2323-MS-101 and associated site procedures were upgraded and training was conducted for all responsible QA and QC personne 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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cc:
Roger D. Walker  TU Electric Manager, Nuclear Licensing c/o Bethesda Licensing TU Electric  3 Metro Center, Suite 610 Skyway Tower  Bethesda, Maryland 20814 400 North Olive Street, L.B. 81 Dallas, TX 75201  E. F. Ottney P. O. Pox 1777 Juanita Ellis  Glen Rose, Texas 76043 President - CASE 1426 South Polk Street Joseph F. Fulbright l Dallas, TX 75224  Fulbright & Jaworski 1301 McKinney Street Susan M. Theisen  Houston, Texas 77010 Assistant Attorney General Environmental Protection Division George A. Parker, Chairman P.O. Box 12548, Capitol Station Public Utility Committee Austin, TX 78711-1548  Senior Citizens Alliance of Tarrant County, Inc.


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GDS Associates, Inc. 6048 Wonder Drive 1850 Parkway Place, Suite 720 Fort Worth, Texas 76133 Marietta, GA 30067-8237 Jack R. Newman, Esq.


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Lanny A. Sinkin Newman & Holtzinger, P.C.
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4, S ' t e 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 close . Post-Construction-Hardware Validation Program (PCEVP) (46053, 46055, 46071, 48051, 48053, 48055, 50073) 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 y 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 support 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-31 This discrepancy was documented on NCR 88-07883 and
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the handwheel was replace 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 packag (2) BRP-AF-1-SB-009, Safeguards building, Auxiliary Feeddater. This PCHVP inspection entailed approximately 40 feet of 6-inch piping depicted on I isometric drawing BRP-AF-1-SB-009. The QC inspector ;
documented that all applicable attributes were satisfactor The NRC inspector walked dcwn all piping relevant to l the isometric drawing and verified that all j applicable attributes were satisfactory. The NRC inspector concurred with the results of this PCHVP
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Christic Institute  Suite 1000 1324 N. Capitol Street 1615 L. Street N.W.
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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 o changed from 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 syste 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 satisfactor (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 inche This condition was. documented on NCR PM-87-00790 and  !
  :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 packag c. Incore Instrument Tubing (CPE-SWEC-FVM-EE/ME/IC/ CS-090)
Washington, DC 20002  Washington, D.C. 20036 Ms. Billie Pirner Garde, Esq.
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-1 _ _ _ _ _ - _ - _ - - _ -


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Garde Law Office 104 East Wisconsin Avenue Appleton, WI 54911 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 William A. Burchette, Esq. l j
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Counsel for Tex-La Electric    '
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Cooperative of Texas Heron, Burchette, Ruckert & Rothwell 1025 Thomas Jefferson St., NW Washington, DC 20007 l
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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 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 r'ecorded by the QC inspector by more than two inches for the seven examples listed belo Tube N Dimension Checked JZ2 .NRC 34 C 5''4 3/4" 4' 11 3/4" 24 C 5' 3" 5' 0" 32 C 7' 5 1/16' 7' 2" 3 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' techniqu 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 recor The QC inspector applied a portion of a straightedge  l flush to the linear portion of the tube and then wedged a 0.01-inch feeler gauge to the point where it stoppe This point was then marked and used as a measurement poin 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 inche 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 I i
 
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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 12 l Duct Segment 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 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  l following discrepancies: unpainted surfaces, bent access i door handles, oversized washers on bolts, distorted hem flanges due to overtorque, loose register bolts, lack of fusion on welding, and welding over galvanizin 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 i 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 uni The NRC inspector concurred with this explanatio 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 discrepancies is left to the discretion of the applican No other deficiencies were identified among the items referenced above.
 
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a e 16 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 ,
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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 r  not verify the location of'the unsatisfactory condition 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,  i
 
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 specifie .
l The above. concerns will be addressed as part of.the continuing review of unresolved item 445/8905-U-02, which identified similar problem . 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
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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 observe . Exit Meeting (30703)
An exit meeting was conducted April 4, 1989, with the applicant's representatives identified in paragraph 1 of this repor No written material was provided to the applicant by
 
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P4    During this meeting,ithe NRC inspectors summarized the scope Land findings'of the inspection.'
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Latest revision as of 17:19, 16 March 2021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/89-19 & 50-446/89-19
ML20247E594
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/21/1989
From: Warnick R
Office of Nuclear Reactor Regulation
To: William Cahill
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8907260227
Download: ML20247E594 (3)
v • d • e


Text

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JUL ? I 1989 In Reply Refer To:

Dockets: 50-445/89-19 50-446/89-19 Mr. W. J. Cahill, Jr.

Executive Vice President TU Electric 400 North Olive' Street, Lock Box 81 Dallas, Texas 75201

Dear Mr.'Cahill,

Thank you for your letter dated May 15, 1989, and supplemental letter dated July 14, 1989,'in response to our letter dated April 14, 1989. As discussed in previous meetings, we considered your first response to the Notice of Violation to lack a necessary evaluation of the adequacy of QC training with respect to the cited examples. Your supplemental response satisfactorily addressed our concern. 'We have no further questions at this time.

Sincerely, bmCINhL SIG'NED BY H. F. V7ARNTCT R. F. Warnick, Assistant Director for Inspection Programs Comanche Peak Projects Division *

Office of Nuclear Reactor Regulation l

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" " * * $~a JJL ? I 1989 In Reply Refer To:

Dockets: 50-445/89-19 50-446/89-19 Mr. W. J. Cahill, Jr.

Executive Vice President TU Electric

, 400 North Olive Street, Lock Box 81 Dallas, Texas 75201

Dear Mr. Cahill,

Thank you for your letter dated May 15, 1989, and supplemental letter d.ated July 14, 1989, in response to our letter dated

. April 14, 1989. As discussed in previous meetings, we considered your first response to the Notice of Violation to lack a necessary evaluation of the adequacy of QC training with respect to the cited examples. Your supplemental response satisfactorily addressed our concern. We have no further questions at this time.

Sincerely, RFIDaA R. F. Warnick, Assistant Director for Inspection Programs Comanche Peak Projects Division Office of Nuclear Reactor Regulation j

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W. J. Cahill, Jr.

cc:

Roger D. Walker TU Electric Manager, Nuclear Licensing c/o Bethesda Licensing TU Electric 3 Metro Center, Suite 610 Skyway Tower Bethesda, Maryland 20814 400 North Olive Street, L.B. 81 Dallas, TX 75201 E. F. Ottney P. O. Pox 1777 Juanita Ellis Glen Rose, Texas 76043 President - CASE 1426 South Polk Street Joseph F. Fulbright l Dallas, TX 75224 Fulbright & Jaworski 1301 McKinney Street Susan M. Theisen Houston, Texas 77010 Assistant Attorney General Environmental Protection Division George A. Parker, Chairman P.O. Box 12548, Capitol Station Public Utility Committee Austin, TX 78711-1548 Senior Citizens Alliance of Tarrant County, Inc.

GDS Associates, Inc. 6048 Wonder Drive 1850 Parkway Place, Suite 720 Fort Worth, Texas 76133 Marietta, GA 30067-8237 Jack R. Newman, Esq.

Lanny A. Sinkin Newman & Holtzinger, P.C.

Christic Institute Suite 1000 1324 N. Capitol Street 1615 L. Street N.W.

Washington, DC 20002 Washington, D.C. 20036 Ms. Billie Pirner Garde, Esq.

Garde Law Office 104 East Wisconsin Avenue Appleton, WI 54911 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 William A. Burchette, Esq. l j

Counsel for Tex-La Electric '

Cooperative of Texas Heron, Burchette, Ruckert & Rothwell 1025 Thomas Jefferson St., NW Washington, DC 20007 l

i l

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