IR 05000445/1987031

Insp Repts 50-445/87-31 & 50-446/87-23 on 871104-1201. Violations & Deviations Noted.Major Areas Inspected: Applicant Actions on Previous Insp Findings & Corrective Action Program

ML20238D460
Person / Time
Site:	Comanche Peak
Issue date:	12/18/1987
From:	Ellershaw L, Livermore H NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20238D401	List: IR 05000445/1987031 IR 07100104/2012001 ML20238D398 ML20238D419
References
50-445-87-31, 50-446-87-23, NUDOCS 8801040267
Download: ML20238D460 (15)

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APPENDIX C d S. NUCLEAR REGULATORY COMMISSION

OFFICE OF SPECIAL PROJECTS f

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NT// Inspection Repe.:t 50-445/87-31 Permits: CPPR-126 50 - 4 4 6 / 8 ~1,- 2 3 CPPR-127 Dockets: 50-46 4 Category: A2 50-446

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g i Construction N rmit E.xpiration Dates s .

Ifnit 1: August i, 1988 Unit 2: Extension request submitte Applicar t. : ..TU Slect:'ic i Skyway Tower

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400 North Olive Street

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Lock Box 81 Dallas, Tm:as 75201 l Facility Name: Comanche Peak Steam Electric Station (CPSES), .

Units 1 & 2 ,

Inspection At: Comanche Peak Sif;e'; Glen Rose, Texas

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Inspection Conducted: Nover.'03er 4 through DecedMr 1, 1987

, l Inspectors: s d '

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D. E. El'lershaw, Reactor Inspector Diat9'

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(paragraphs 2, 3, 4, and 5.b) ..>

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Consultants: FG&G - J. Dale (paragraph 2) ,, .

hrameter - K. Graham (paragraphs 3.a and b)

P. Stanish (paragraphs 3.c and d)

1 's Reviewed by: RFliian,rtM & -

/W/r/87 H. H. Livermore, Lead Project Date Inspector

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8801040267 871213 PDR ADOCK 05000445 G PDR s

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Inspection Sumrpay:

Inspection Conducted: November 4 through December 1, 1987 (Report 50-445/87-31; 50-446/87-231 Areas Inspected: Nonroutine, unannounced inspection of applicant actions on previous inspection findings and the corrective action  ;

progra l Results: Within the two areas inspected, two violations l (incorrect walkdown data was recorded, paragraph 3.c; and i uncontrolled rework was performed, paragraph 2.c and 2.d) and one l deviation (several departures from the criteria of the post l construction hardware validation program not identified, paragraph 3.d) were identifie i I

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i DETAILS Persons Contacted

• R. P. Baker, Engineering Assurance (EA) Regulatory Compliance Manager, TU Electric

• R. D. Best, Nuclear Operations Inspection Report Item Coordinator, TU Electric l *D. N. Bize, EA Regulatory Compliance Supervisor, TU Electric

• J. T. Conly, Lead Licensing Engineer, Stone & Webster Engineering Corporation (SWEC)

C. G. Creamer, Instrumentation & Control (I&C) Engineering Manager, TU Electric

• R. D. Delano, Licensing Engineer, TU Electric

• M. D. Gaden, CPRT, IT Corporation

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

• T. L. Heatherly, EA Regulatory Compliance Engineer, TU Electric  !

• D. A. Hodge, CPRT Interface, TU Electric .

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• R. T. Jenkins, Manager, Mechanical 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

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

• D. E. Noss, QA Issue Interface Coordinator, TU~ Electric

• D. M. Reynerson, Director.of Construction, TU Electric

• M. J. Riggs, Plant Evaluation Manager, Operations, 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

• J. F. Streeter, Director, QA, TU Electric _ .

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

• T. G. Tyler, Director of Projects, TU Electric j The NRC inspectors also interviewed other applicant employees during this-inspection perio * Denotes personnel present at the December 1, 1987, exit intervie . Applicant Action on Previous Inspection Findings (92701) (Closed) Open Item (445/8511-0-04): During reinspection of ERC's Verification Package I-M-HVIN-038, it was identified that (a) the exhaust flange gasket did not cover the entire area, (b) the gasket was unevenly compressed, and (c) some lock washers did not have full contact with the flange. Similar conditions were identified for the inlet duct connectio i A subsequent reinspection of this verification package by' I the NRC inspector revealed that the exhaust gasket, while ,

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not covering the entire flange, did cover the entire mating surface of the flange connections.. The gasket is more compressed just beneath the bolt heads; however, it is acceptable in accordance with Revision 1 of QI-02 The NRC inspector found all lock washers to be fully compressed and in contact with the flang The NRC inspector determined by reinspection that the above items are in conformance with inspection requirements and should not have been identified as potential deviations by the ERC inspector. Therefore, this item is close (Open) Open Item (446/8511-0-09): A potential deviation regarding grout not completely covering the base plate shims for Verification Package I-S-PWRE-51 Note: The NRC discussion pertaining to this open item in NRC Inspection Report 50-445/87-06; 50-446/87-05 is incorrect and is being restated her Subsequent to the identification of this potential deviation, ERC initiated Deviation Report (DR)

I-S-PWRE-518-DR1 on October 11, 1985. The DR was invalidated on November 26, 1985, based on the fact that grout and shims are not attributes to be inspected in the pipe whip restraint population. The DR further stated that "an out-of-scope observation may be written."

Further NRC review of this open item has determined that an out-of-scope (DOS) observation was written (1344);

however, it has.not yet been evaluated, thus an nonconformance report (NCR) has not been initiated. This item will remain open pending evaluation of the OO (Closed) Open Item (446/8511-0-11): This item addressed damaged grout (a crater) which was identified during an ERC inspection of Verification Package I-S-PWRE-51 Note: The NRC discussion pertaining to this open item in NRC Inspection Report 50-445/87-06; 50-446/87-05 is incorrect with respect to the OOS and NCR numbers, and is being restated her ERC initiated OOS 205 on October 23, 1985, which documented the presence of a crater which had been chipped out of the base plate grout. The 005 was evaluated and resulted in the issuance of NCR C 86-200378X on February 14, 1986. The disposition of the NCR required rework by correcting the defective area in accordance with the latest revision of CCP-1 It required the use of an approved commercial nonshrink

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grout with mixing to be performed in accordance with manufacturers instruction. QC was to inspect per the latest revision of QI-QP-11.0-5. This disposition was approved by engineering and-QA on January 8, 1987, and February 9, 1987, respectively. . Subsequently on June 20, 1987, the disposition, verification'and closure block was annotated with the' statement " Transferred to NCR

1. CC-87-8190X."

The NRC inspector reviewed NCR CC-87-8190X dated June 16, 1987, and identified the following:

The disposition had been' changed to use-as-is with the following note, "This disposition includes pages 1 thru 8."

All disposition approval blocks were signed off and dated, including QA/QC verification which was dated August 10, 198 Page 6 of the NCR is a memorandum dated June 12,.1987, and addressed to the NCR group and states ir, part,

"Between the time NCR disposition was issued and then corrected . . . the area in question was repaired on general preparation of room for coatings. Area is repaired but not to the disposition of [the] NCR."

Page 5 of the NCR is a memorandum dated June 16, 1987, addressed to SWEC Civil / Structural group and references the above memo (page 6).- It recognizes the fact that the disposition must be changed because the work had already been performed, but not to the stated disposition. It stated that in order to revise the disposition, a new NCR must be issue Page 4 is a memo dated July 14, 1987,.from SWEC' I civil / Structural to QC in which it is stated that visual inspection shows no damage at the specified location. It .

also requests verification of location and that this i clarification is required for the disposition-(use-as-is)

of NCR CC-87-8190X. The reply from QC on July 16,.1987, states that " Indication of damage can not be ascertained at this date because paint craft patched the damage ,

unaware of the reporting NCR . . . . "

l Criterion XVI of Appendix B to 10 CFR Part 50, as implemented by Section 16.0, Revision 0, of the TU Electric Quality Assurance Plan (QAP), states, in part, " Measures shall be established to assure that conditions adverse to quality . . are promptly identified and corrected . . . and corrective action )

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Nuclear Engineering and Operation Procedure NEO 3.06,

" Reporting and Control of Deficiencies," requires deficiencies (principally programmatic and not directly related to hardware problems) to be identified, the cause established, and action taken to prevent repetitio The changing of the NCR disposition from " rework" to .

"use-as-is" subsequent to engineering becoming aware that i the conditions which created the need for the NCR had been corrected by uncontrolled work; i.e., outside the l scope and control of the NCR, constitutes a violation of Criterion XVI of Appendix B to 10 CFR Part 50 and NEO Procedure 3.06, " Reporting and Control of Deficiencies."

Further, by revising the disposition and closing out the NCR, actions were not taken to determine the cause of the deficiency (uncontrolled work) or to prevent repetition (445/8731-V-02A; 446/8723-V-01A). (Closed) Open Item (445/8514-0-16): This item addressed two sending Units 1-LS-6712 and 1-LS-6717 which were identified by the ERC inspector to the NRC inspector, as being reversed during a reinspection of Verification Package I-E-ININ-069. As a result of this observation, ERC DR I-E-ININ-069-DR1 was initiated which resulted in the issuance of NCR I-85-101890 SX. The disposition of the NCR required rework by TUGCo I&C calibration l

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personnel which consisted of returning the switch housings to their originally installed positions and for QC to verify location and serial number in accordance with the current revision of QI-QP-11.8-5. This disposition was approved by engineering on June 6, 1986, and QA on June 9, 1986. The comments block was annotated with the statement "Rev. 2 For Disposition." The disposition of Revision 2 to NCR I-85-101890 SX shows the Use-As-Is box checked off and contains the statement,

"This is no longer a non-conforming conditio Instruments are located per location drawing 2323-M1-2610 and serial number. See attached instrument installation j checklist and material received record." A check was 1 made with permanent plant maintenance (PPM) to determine if the sending units had been corrected during routine ] ,

maintenance. PPM was unable to locate any work requests for the sending units in questio The changing of the NCR disposition from " rework" to

"use-as-is" as a result of uncontrolled work being

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performed, is another example of the violation contained in paragraph 2.c above (445/8731-V-02B; 446/8723-V-01B).

3. Corrective Action Program (CAP)

NRC inspections were performed to verify the applicant's activities associated with the Post Construction Hardware Validation Program (PCHVP). The PCHVP was established to reconcile the design to the design bases appropriate to satisfy licensing commitments, and to reconcile the hardware  ;

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to the design: 1.e., the constructed / installed systems meet the intent of the design. The following CAPS were inspected during this report perio HVAC (50100)

The NRC inspector has reviewed the following procedures associated with implementation of the HVAC CAP and will continue to evaluate the implementation of these procedures during subsequent NRC inspections:

CPE-EB-FVM-CS-029 - Revision 5, " Field Verification Method Procedure for Seismic HVAC Duct and Duct Hanger As-Built Verification in Unit 1 and Common Areas" CPE-EB-FVM-CS-066 - Revision 1, " Field Verification 1 Method Procedure for As-Built Verification of Seismic HVAC Air Handling Units, Plenums, and Equipment Supports in Unit 1 and Common Areas" CHV-101 - Revision 1, "HVAC - Detailing, Fabrication, Installation, Rework, and Repair" CHV-106 - Revision 1, " Qualitative Walkdown of HVAC Supports and Ducts (Unit 1 and Common Areas)"

The NRC inspector reviewed the construction operation travelers (COT) listed below to determine if the applicants safety class, system pressure, and duct construction type designation are in accordance with Comanche Peak Engineering Specification 2323-MS-85,

"HVAC - Ducts, Louvers, and Accessories," Revision 5, dated September 15, 198 B-1-801-751-091, Revision 0 B-1-801-751-093, Revision 0 B-1-801-751-094, Revision 0 B-1-801-751-150, Revision 0 B-1-801-751-151, Revision 0 B-1-3201-752-158, Revision 0 B-1-3201-752-163, Revision 0 B-1-3201-752-164, Revision 0

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B-1-3201-757-037, Revision 0 )

B-1-3201-757-042, Revision 0 B-1-3601-653-091, Revision 0 B-1-3602-655-027, Revision 0 B-1-3603-654-044, Revision 0 B-1-3603-654-050, Revision 0 B-1-3901-658-014, Revision 0 B-1-3901-658-022, Revision 0 B-1-3901-658-023, Revision 0 B-1-3901-658-025, Revision 0 The NRC inspector reviewed the COTS listed below in order to evaluate the adequacy and completeness of engineering instructions for performance of craft work activitie B-1-701-756-249, Revision 0 B-1-701-756-272, Revision 0 B-1-701-758-059, Revision 0 B-1-701-758-139, Revision 0 B-1-701-758-144, Revision 0 B-1-701-758-145, Revision 0 B-1-701-758-148, Revision 0 B-1-702-758-081, Revision 0 B-1-702-758-082, Revision 0 B-1-702-758-083, Revision 0 B-1-2401-760-055, Revision 0 The NRC inspector determined that, for the listed COTS, the applicant has correctly designated the classifications in accordance with Specification 2323-MS-85, Revision 5, and that the engineering instructions are adequate and complet No violations or deviations were identifie b. Large Bore Piping and Pipe Supports (50090)

The NRC inspector performed a review of Brown and Root (B&R) Instruction QI-QAP 11.1-28, Revision 38, l

"Fa'orication and Installation Inspection of Safety Class Component Supports." Revision 38 provides relaxed quality control inspection criteria for the determination of acceptable versus unacceptable welding arc strikes on pipe supports. The basis for this change in pipe support inspection requirements _was Design Change Authorization (DCA) 18322, Revision 3, to mechanical specification 2323-MS-100, " Field Fabrication and Erection of Piping and Pipe Supports, which resulted in the subsequent revision of the B&R instruction. NRC inspectors reviewed the following references supporting the technical justification for approval of the DCA:

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i Van Malssen, S. H., "The Effects of Arc Strikes on Steels !

Used in Nuclear Construction" - Welding Journal, July 1984 Kasen, M. B., Hicho, G. E., and Placious, R. C.,

" Inherent Through-Wall Depth I. imitations on Blunt Discontinuities in Welds" - Welding Journal, June 1984 Kasen, M. B., " Significance of Blunt Flaws in Pipeline Girth Welds" - Welding Journal, May 1983 l From this review, the NRC inspectors concur with the DCA and the resulting revision to QI-QAP 11.1-2 No violations or deviations were identifie c. Conduit Supports A & B Train and C Train > 2" (48053)

During this inspection period the NRC inspector selected a sample of six conduit walkdown packages to verify the accuracy and correctness of the EBASCO collected dat The following is a list of the NRC inspected packages:

Conduit Size Room * Area ** Supports ,

FC14B13125 3" 155A RB1 6 i C13OO7808 3" 108 SG1 8

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C13OO7294 1 1/2" 154 RB1 3  ;

C13008625 1 1/2" 161A RB1 6 l C14G21398 1" 66/70 SG1 7 CO2011930 3" 135/148 ECB 3 C12K15004 3" 133 ECB 10

• SG1 - Unit 1 Safeguards Building

• RB1 - Unit 1 Reactor Building

• ECB - Electrical / Control Building

• • Number of supports includes conduit, junction box and pull box support The NRC inspector's walkdowns were performed while l adhering to the criteria of field verification method (FVM) CPE-EB-FVM-CS033, Revision 3, and resulted in the l

identification of the following discrepancies:

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i (1) on Conduit Support C13007808-04, the walkdown engineer lined out the anchor bolts in locations A, E, and F. This implies that these bolts do not exist for this suppor During a subsequent walkdown by the NRC inspector, it was noted that an additional anchor bolt did exist in the position designated on the support sketch as location I

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,' 10 This anchor bolt was determined to be a 1/4" Hilti Kwik bolt with the letter designation "D" and a projection of 1". While the existence of this additional anchor bolt will not have a detrimental effect on the structural integrity of the support, the fact that it was not identified during the EBASCO walkdown is of significance relative to the adequacy of the walkdown itsel (2) For Support C14G21398-03, a 2323-S-0910 sh. CSM-18 type support, the walkdown engineer failed to report one of the dimensions required to fully locate the structural tubing on the baseplate. This information is required to calculate the baseplate stress and anchor bolt loads. The dimension not provided locates the bottom of the structural tubing relative to the bottom of the baseplate as installed and is a dimension that is required to be reported for this type of suppor (3) on support C14B13125-02, the walkdown engineer failed to note a spacing violatic? between the 1/4" Hilti Kwik bolt designated as Bolt F on the support in question, and a 3/8" HKB on an adjacent conduit support. The NRC inspector found these anchor bolts to be 2 1/4" apart; while the FVM required a spacing of at least 3 1/8".

Criterion V of Appendix B to 10 CFR Part 50, as implemented by section 5.0, Revision 3 of the TU Electric QAP, states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedure, or drawings, or a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. . . . "

Section 7.7.1 of Revision 2 to EBASCO's FVM CPE-EB-FVM-CS-033, states, in part, "The Walkdown Engineer will identify each type of support by comparison with j Supplement I and/or 2323-S-0910 sketches or drawings, and

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will as built the support on the applicable sketch or drawing . . . . " Paragraph K of this section of the FVM further states, "All dimensions and/or attributes shown will be verified . . . . If the designed dimensions / attributes are incorrect, they shall be lined out and the actual dimension / attribute recorded."

Further, paragraph N states that the walkdown engineer will redline ". . . any HKB/HSKB spacing violation per Table 2."

The three above examples of incorrectly documenting existing conditions constitutes a violation of

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Criterion V of Appendix B to:10 CFR Part 50 and FVM CPE-EB-FVM-CS-033-(445/8731-V-01).

On the remaining conduit runs, the results of the NRC

. walkdown revealed certain data that did not match that recorded by EBASCO; however, it was deemed to be acceptable.since the. difference in the recorde dimensions was still within.the tolerances specified in the applicable FVM. This is not considered to.be a proble Conduit Supports C Train Less Than or Equal to'2" (48053)

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For this inspection period, the NRC inspector performed a

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review /walkdown of the total scope of work Impell performed.for_ Room 155 of the Unit 1 Containment building and Room 101 of the Unit 1' Safeguards buildin Room 155 Containment Building l

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The following calculation /walkdown packages were-included in the NRC inspector's review of Room 15 ,

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RC01-CT155 Room Closecut' Calculation / Documentation L2-S1-CT155 Level 2 - Conduit Support Evaluation A02454 Level 5 Support Evaluation A02603 Level 5 Support' Evaluation L6-1-CT155 Level 6 - Train C Conduit' Interaction Evaluation l

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Section 4.1, "Walkdown Guidelines" of Revision 2 to Impell Project Instruction (PI) 0210-052-004~ states, in part, "The Walkdown information will be documented using i the checklists provided in Attachment B . . . . Table 1- l l

provides the acceptable tolerances to be'used in the walkdown proces ;

"Guildelines for performing the conduit support and conduit routing walkdowns are provided below:

" Item Support configuration

- Draw an as-built sketch

- Identify all structural /Unistrut membe sizes, lengths . . .

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" Item Hilti Kwik Anchor bolt Information

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of all anchor bolts on supports . . .. .

" Conduit Routing Checklist

" Item 1 Conduit' Isometrics )

- Draw an as-built sketch s'> wing conduit routing . . .

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- Determine span lengths"

-4 l Section 4.1.4, " Seismic Evaluation of Train C, Conduit Supports," of Revision 3 to Impell PI: 02310-052-003, states, in part, " . . . SSE support loads.are' generally calculated by multiplying'the conduit tributary: mass times the equivalent static. acceleration . . . . "

Paragrapk 4.3.4 further states, ". . .. for interaction of . . . loads, the following interaction . .. . equation shall be used . . . . "

While performing the review /walkdown for. Room.155, the .

NRC inspector identified the following discrepancies with respect to the walkdow (1) While performing the load calculation for the northeast / southwest direction'for support'A02605 (a-Type 5 support) in Calculation / Problem A02454, the engineer neglected to include.a 14"-length of conduit between the support being evaluated and an adjacent support. This omission would'cause.the load on this support to be understate (2) On the Type 5 support evaluation for the support-identified as analysis tag No. A02605/NQ16507, the calculated embedment length for the Hilti Kwik bolt was found to be incorrect. The Impell evaluation sheet reports the embedment to be 2 3/4";.however, based on the data. recorded by the NRC inspector, the embedment was' determined to be 1 3/4". Furthermore, on this evaluation, the interaction check for the-

" finger" clamp. indicates a'value of'l.05 versus an allowable of 1.0. There is a note appended to the calculation stating'"this is acceptable due to the conservatism in the evaluation"; however, this support is the same support mentioned in (1)'above for which the load. calculation is incorrect'

(unconservative).. Therefore, the. actual interaction will be higher than the-l.05 calculated.and Impell l

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, 13 should review this in light of the change in applied load to insure adequacy of the suppor (3) On the Type 7 support identified as analysis tag 1 number A02456/NQ16508, the NRC inspector identified I several discrepancies. The baseplate mounted on the j wall was reported to be 3/8"x8"x8"; however, it is !

actually 3/8"x9"x8". This change in the length of the baseplate would have a detrimental effect on the calculated loads on the anchor bolt Impell reported that the anchor bolts en this support were 1/2" Hilti Kwik bolts and the NRC inspector determined that .ey are 1/2" Hilti Super j Kwik bolt While this is an error which is j

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conservative in nature, it could bring into question '

the adequacy of the information being provided as a result of Impell's walkdow ,

Also, on the same support, Impell reported that the Nelson studs being used to secure the clamp to the '

support were 1/4" diameter, while the NRC inspector determined these bolts to be 3/8" diamete (4) On the support identified as detail "B", a Type 7 support, Impell reported that the anchor bolts were 1/2" Hilti Kwik bolts, but the NRC inspector !

observed that they were actually 1/2" Hilti Super Kwik bolt (5) On the isometric provided on page 4 of 8 in Appendix A, Calculation / Problem No. A02603, Impell reported a length of conduit between the Type 5 support identified as A02628 and an adjacent Type 5 i support as 21". The NRC inspector determined this length to be 12 1/2".

The five items above constitute a deviation to the commitments made in "Walkdown Guidelines" and " Seismic Evaluation of Train C Supports" (445/8731-D-03).

(6) During the review of the calculation package provided for the Level 5 support evaluation A02454, ,

there were several apparent inconsistencies note I First, on pages 15 and 16 of 39, the person checking the calculations dated them prior to the day the calculations were performed. Second, the support load calculations in this package were performed during several days in March 1987, the last of the calculations being performed on the 20th of March and checked on the 23rd of March. However, page 19 of 39 entitled " Summary of Loads," appears to have

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Item 6 above constitutes an Unresolved Item pending further review by the NRC inspector (445/8731-U-04).

Room 101 Safeguards Building The following calculation /walkdown packages were included in the NRC inspector's review of Room 101:

Calculation Title N RCO1-SG101 Room Closecut Calculation / Documentation L2-S1-SG101 Level 2 - Conduit Support Evaluation A00389 Level 5 - Support Evaluation L6-1-SG101 Level 6 - Train C Conduit Interaction Evaluation The results of the review /walkdown revealed certain data which did not match that recorded by Impell; however, it was deemed to be acceptable since the difference in the recorded dimensions was still within the tolerances specified in the applicable Project Instruction (PI).

No violations or deviations were identified during the !

NRC inspector's review /walkdown of Room 10 J 4. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. One unresolved item disclosed during the inspection is discussed in paragraph . Exit Meetings (30703)

Meetings held during this report period are as follows: On November 25, 1987, R. F. Warnick met with A. B. Scott and L. D. Nace to discuss items of mutual interest and the significance of inspection findings for Novembe The following topics were discussed:

(1) All five October inspection reports for NRC site staff were issued in less than 20 days (13.2 days average).

(2) The NRC staff met at the site on November 4 and 5 for the purpose of finalizing OSP's schedule for

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, 15 Comanche Peak and to reach a position regarding the adequacy of the applicant's corrective action program. See J. G. Keppler's memorandum to Victor '

Stello, dated November 6, 1987, which is in the docket file and the public document room. A public meeting to discuss the CAP will be held on December 9, 198 (3) A program has been laid out by the NRC staff for the resolution of open NRC concerns regarding ASME ,

issue See Inspection Report 50-445/87-20, J 50-446/87-1 (4) Four additional NRC inspectors have been hired to I fill onsite staff vacancies - Preoperational I Testing, Civil / Structural, Resident Inspector - I Operations, and Project Inspector. One vacancy remains to be filled (Ellershaw will be transferring to RIV).

(5) The NRC plans to resume the SALP assessments for Comanche Peak. The appraisal period being proposed by the NRC site staff to Headquarters is September 1, 1987 through August 31, 198 (6) The electrical area has several issues of concern to the staff - separation, cable pulling, lubricant, preinsulated environmental seal splices, DCAs with clarifications to the code, and DCAs liberalizing TUE commitment These issues have been documented in inspection reports, 50.55(e) reports, and FSAR amendment (7) The findings that will be documented in the November j

inspection reports appear to be caused by human t error Utility management must be sensitive to j identifying and preventing human error ,

b. An exit interview was conducted December 1, 1987, with j the applicants representatives identified in paragraph 1 I of this report. During this interview, the NRC l inspectors summarized the scope and findings of the l inspectio The applicant acknowledged the finding j l

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u . n-DocketdrilesR(504445/446)?

NRC PDR Local PDR  ;

OSP Reading I CPPD-LA-CPPD Reading (HQ).

• Site Reading

• CPRT Group '

• SRI-OPS

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