IR 05000445/1988015

Insp Repts 50-445/88-15 & 50-446/88-11 on 880203-0301.No Violations or Deviations Identified.Major Areas Inspected: Applicant Actions on Previous Insp Findings & Comanche Peak Rept Review Group Recommendations

ML20148D431
Person / Time
Site:	Comanche Peak
Issue date:	03/18/1988
From:	Livermore H, Runyan M NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20148D405	List: IR 05000445/1988015 ML20148D401
References
50-445-88-15, 50-446-88-11, NUDOCS 8803240042
Download: ML20148D431 (13)

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q U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS NRC Inspection Report: 50-445/88-15 Permits: CPPR-126 50-446/88-11 CPPR-127 Dockets: 50-445 Category: A2 50-446 Construction Permit Expiration Dates:

Unit 1: August 1, 1988 Unit 2: Extension request submitte 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: February 3 through March 1, 1988 Inspector: 1 U Av co 3} p 88 M. Runyana Resident Inspector, Date Civil Structural (paragraphs 3, 4, 5, 6.a)

Consultant: W. Richins, Parameter (paragraphs 2, 6.b, 7.c)

Reviewed by: @E%RFils S// Y H. H. Livermore, Lead Senior Inspector Date 8803240042 880318 PDR ADOCK 05000445 Q DCD

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Inspection Summary:

Inspection Conducted: February 3 through March 1, 1988 (Report 50-445/88-15; 50-445/88-11)

Areas Inspected: Unannounced, resident safety inspection of

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applicant actions on previous inspection findings; comanche Peak' ,

Report Review Group. recommendations; and-applicant-actions on- 1

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Issue-Specific Action Plans (ISAPs)'II.a, II.c, and VI Results: Within the areas' inspected, a weakness was identified concerning the disposition of field-cured concrete test cylinder-discrepancies. An identified strength was the thoroughness'and-precision of the applicant's program to validate seismic double wall gaps in response to ISAP II.c. ' No violations or deviations were identifie .

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DETAILS ' Persons Contacted D. A. Balatincz, Field Coordinator, Bisco C. Beasley, Senior Engineer, Evaluation and Research Corporation (ERC)

G. S. Braun, TENARA (TERA)

N. A. Britton, Civil Engineering,.TU Electric

• W. G. Counsil, Executive Vice President, TU Electric N. D. Hammett, Engineering Assurance,- Brown and Root (B&R)

• T. L. Heatherly, EA Regulatory Compliance Engineer, TU Electric C. R. Hooton, Civil Engineering Manager, TU Electric

• J. J. Kelley, Manager, Plant Operations, TU Electric R. M. Kissinger, Civil Engineering, TU Electric J. J. McNally, Engineer, Stone and Webster Engineering Company (SWEC)

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

• D. Nace, Vice President, Engineering & Construc"ion, TU Electric

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

• M. R. Steelman, Comanche Peak Review Team (CPRT), TU Electric T. Vears, SWEC The NRC inspectors also interviewed other applicant employees during this inspection perio * Denotes personnel present at the March 1, 1988, exit intervie . Applicant Action on Previous Inspection Findings (92701)

(Closed) Open Item (445/8518-0-18): This item addressed a potential deviation regarding incorrect marking for bolt material on the Reactor Sump No.1 in Unit 1. A-193 bolts are required by Drawing 2323-51-0564. The markings on the bolts could not be identified by the CPRT inspector. This condition was identified by CPRT during an NRC witnessed inspection of Verification Package I-S-STEL-117, documented on CPRT Deviation Report (DR) I-S-STEL-ll7-DR1, and incorporated into Nonconformance Report (NCR) M-86-100454SX. NCR M-86-100454SX states that the bolts are acceptable as is. The basis for the disposition is that material traceability exists through documentation. The bolts were vendor supplied and the markings are military standard identification symbols for ASTM A-193, Grade B8, Class 1 bolts. The NRC inspector verified the material traceability and concurs with the disposition of NCR M-86-100454SX. This item is close _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _

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3. (Closed) Comanche Peak Report Review Group (CpRRG)

Recommendation 48: Concrete Quality Concerns Associated with Potential Mixing Blade Deficiencies, During inspections conducted from April 1, 1985, through June 21, 1985, and documented in NRC Inspection Report 50-445/85-07; 50-446/85-05, NRC inspectors identified a lack of records indicating that mixing blades in concrete mixers had been periodically inspecte This was documented as Violation 445/8507-V-04; 443/8505-V-02. The applicant is committed to American Concrete Institute (ACI) Standard ACI-304-7 Section 4.2 of this standard states that "mixers should be properly maintained to prevent mortar or dry material leakage and inner mixer surfaces should be kept clean and worn blades replaced." Section 3.9.4 of B&R Procedure 35-1195-CCP-10 states that mixing blades should be checked quarterly and replaced whenever they lose ten percent of their heigh The quarterly checks were not formally required to be documented, and it was the lack of such documentation which raised the concern that the inspections had not been performed. Violation 445/8507-V-04; 446/8505-V-02 was closed in Inspection Report 50-445/86-28; 50-446/86-23, based on a procedure revision to require documented inspection of the blade However, the concern that concrete quality may have been affected by deficient mixing blades remained open and was identified as ID Recommendation 48 in Enclosure 1 to Stello's memorandum, "Implementation of Recommendations of Comanche Peak Report Review Group," April 14, 1987. The CPRRG

ecommended an extensive review of concrete compression tests to determine if concrete quality had been adversely affected by the potentially defective mixing blade During this inspection the applicant informed the inspector that mixing blades had never been replaced and that the same trucks had been used throughout plant constructio This, combined with the fact that documented quarterly inspections of the mixing blades beginning June 6, 1985, have been satisfactory, appears to remove any suspicion that deficient mixing blades have been used. The NRC inspector visually inspected the mixing blades in truck RT-41 and verified the applicant's position that blade wear was precluded by the presence of fins at the ends of the blade Only one small defect was identified: a one square inch hole at a blade-fin junction which appeared to be more of a fabrication defect than an erosion feature. Therefore, it appears discrepant mixing blades have not been used at the sit In order to assess the possible effect of the mixing blades in the concrete, the NRC inspector reviewed approximately 2,000 concrete pour test records from 1977 to the present for deficiencies due to compressive strength, air content, and

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slum This review revealed 99 instances where field-cured cylinders failed to meet specifications, but failed to show a gradual quality degradation which would be indicative of mixing blade wea Due to the large number of field curing test failures, the NRC inspector requested information concerning the disposition of five safety-related pours, where in one case (Pour 101-E808-006) the field-cured cylinder failed at less than the design strength of 4000 psi, and in four cases (Pours 201-4885-009, 205-8873-001, 205-4852-001, and 205-4852-001) the field-cured cylinders broke at greater than 4000 psi, but less than 85 percent of the break pressure of the corresponding laboratory-cured cylinders. The 85 percent criteria is derived from ACI 318-71 and is used to demonstrate that curing methods in the field have been adequate to ensure the quality of installed concrete. Pour 101-E808-006, was documented on NCR C-2178, resulting in a retest of a core bore sample of the placement. The core sample failed at 4340 psi and the placement was determined to be acceptable. For the other four cases, however, no action was taken. The applicant's policy throughout construction was that the failure of field-cured test cylinders to attain 85 percent of the strength of lab-cured samples represented a process-control limitation rather than a quality-of-concrete problem. This position is not in violation of ACI 318-71 which states that the 85 percent criteria has been set merely as a rational basis for judging the adequacy of field curing and.that instructions to be followed when these strength tests fail are not dogmatic, but are subject to judgement of the true significance of the test results. Multiple failures of field-cured samples to meet comparison specifications should have been identified as an adverse trend and resulted in an effort to improve field-curing tecnniqu Instead, each case was considered individually and dispositioned with no action take The NRC inspector considers the failure to identify the adverse trend and take corrective action to be a weaknes Most safety-related placement of concrete is now complete, but for what remains, the applicant should reconsider its disposition of field-cured test failure . Reinforcing Steel in the Reactor Cavity (ISAP II.a) (48055)

ISAP II.a involved an incident where the intention to add additional rebar failed when a revised drawing did not reach the field in time. The ISAP also addressed the generic implications of this incident. The following activities for ISAP II.a were reviewed by the NRC inspector during this report perio Previous inspections regarding ISAP II.a were documented in NRC Inspection Reports 50-445/86-01, 50-446/86-01; 50-445/85-13, 50-446/85-09; and 50-445/85-11, 50-446/85-0 . _ . _ _ .

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a. . Review Circumstances Leading to Proyision for and Deletion of Subject Rebar (NRC Reference 02.a.02.00)

The NRC inspector reviewed the Results Report, Revision 1, in which the following facts were presente The structural job engineer, based on his professional experience, concluded that minor cracking of concrete in Reactor Building 1, at the corners of slots provided for neutron detectors could occur in the event of a loss of coolant accident (LOCA). As a result, he estimated tbn additional quantity of rebar needed to prevent the cracking, which resulted in Revision 3 to struc': ural .

Drawing 2323-51-0592. Since this change was merely an enhancement, backup calculations were not performe The revised drawing arrived in the field after the concrete pour was completed and was documented on NCR C-66 After TU Electric concluded that the rebar modification was discretionary, Revision 4 to the subje.t drawing was issued to delete the added rebar. Since the structural calculation of record did not include the rebar placement of Revision 3, it was not changed with the issuance of R,"ision An analysis of the as-built condition of the Unit 1 reactor cavity by Gibbs & Hill (G&H) was previously reviewed by the NRC inspector (NRC Report 50-445/85-11; 50-446/85-06). G&H concluded that the omitted reinforcing steel was not required to maintain the structural integrity of the reactor cavity. The NRC inspector concurred with this result. The review of the circumstances of the subject case appeared to be adequate and the NRC inspectcr agreed with the CPRT conclusion that the additional rebar was not require No violations or deviations were identifie b. Review Rebar Omissions Documented in Project NCRs (NRC Reference 02.a.03.00)

A total of 21 NCR documented cases of rebar omission in Units 1 and 2 safety-related Category 1 building structures were identified by the CPRT, excluding the previous subject case. The NRC inspector reviewed the subject NCRs and subsequent conclusions presented in the Results Repor All of the 21 NCRs, in contrast to the preulous subject case, were due to errors in placement of rebs- > xi w e r-2 not caused by failure of the eng.r 3 ring /rNi'd change interface to convey impending C' v. chan<,m. ,

'hirteen cases pertained to mirJing 3 .t r esaed to missing vertical er horizontal 4 - " *

' :tained to missing shear ties. Based on

. s , ' nults Report conclusion that no other 2 ni ,

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'A to the subject case had been documented on .i au Justified. The 21 rebar placement

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errors were either corrected in the field or analyzed

"use as is."

No violations or deviations were identifie c. Review Sample of Pour Cards for Use of Current Design Documents and Review Engineering Field Interface of Najor

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Embedments (NRC. References 02.a.04.00,and 02.a.05.00)

The applicant randomly selected a total of 66 concrete pour cards, including the subject case, each of which involved the embedment of reinforcing steel. For each *

pour card, the rererenced design drawing was compared to the current design drawing with respect to reinforcement requirements for the particular structure involved in the pour. The NRC incpector reviewed the selected pour cards and resulting analysis. There were no additional instances identified where reinforcement requirements were changed subsequent to the pou In addition, the CPRT reviewed 100 percent of the pour cards for major embedments in Reactor Building 1. Out of 124 embedments reviewed by CPRT, there were no additional cases of post-construction changes in the design of embedment structures. The CPRT review of pour cards provided convincing evidence that the subject case was an isolated inciden No violations or deviations were identifie d. Design Change Procedures and Their Effect Regarding Implementation (NRC Reference 02.a.06.00)

The CPRT reviewed document control, installation and inspection, and construction hold procedures for both the time of the previous subject case (May 1977) and the time of the review (October 1985).

The procedure review focused on the following items:

. Claar identification that the drawing is released for constructio . Controlled transmittal of the drawing from Engineering to site document contro . Controlled distribution to the fiel . Construction hold notice . Pre-placement inspection of rebar and embedded items.

l The NRC inspector reviewed poJtions of the procedures used to justify the general CPRT conclusion that all procedures past and present were adequate to ensure qualicy. The only significant procedural weakness identified by CPRT, vhich may have contributed to the

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previous subject case, was a lack of formal procedures

.related to the generation of Construction Hold Notices (CHN). Current procedures for CHNs are more formalized and are adequat The CPRT procedure review was a comprehensive effort which encompassed all aspects of the subject cas No violations or deviations were identifie Review of Results for Generic Applications (NRC Reference 02.a.07.00)

In order to verify the adequacy of the action plan to consider generic applications, the applicant assessed the placement of rebar that had been exposed in association with ISAP II,b, "Concrete Compressive Strength." A total of 87 rebar placements were exposed for analysis in regard to ISAP II b. The Project made as-built sketches of the exposed areas and a third party compared the sketches to the design requirements. Eight minor discrepancies were identified each of which was evaluated to be acc eptable without corrective actio This analysis further supported CPRT's claim that the subject case was isolated and that the ISAP action plan did not need to be expande No violations or deviations were identifie The conclusion of the ISAP II.a Results Report, Revision 1, signed October 23, 1987, that the administrative controls and resulting placement of rebar is adequate to meet or exceed design requirements was well supported. This completes the NRC review of ISAP I . Maintenance of_ Air Gap between Concrete structures (ISAP II.c)

(46053) (46055)

The following activities for ISAP II.c were revicWad by the NRC inspector during this report period. Previous inspections regarding ISAP II.c were documented in NRC Inspection Reports .

50-445/87-11, 50-446/87-09; 50-445/87-09, 50-446/87-07; 50-445/87-06, 50-446/87-05; 50-445/86-26, 50-446/86-22; 50-445/86-22, 50-446/86-20; 50-445/86-15, 50-446/8612; 50-445/86-07, 50-446/86-05; 50-445/86-03, 50-446/86-02; and '

50-445/86-01, 50-446/860-0 Analyze Final As-Built Condition and Documentation of Einal As-Built Condition (NRC References 02.c.03.00 and 02.c.04.00)

The NRC inspector witnessed Bisco inspections of seismic double wall gaps subsequent to debris remova Bisco

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inspections were performed in accordance with procedure NQA-3.09-1.08, "Building Separation Gap and Conditi7n Inspections," Revision 0. These inspections were documented on the following construction operation travelers:

Traveler CE87-1914-01-8904 Inspection of the doub.'.e walled building separation gap between the Auxiliary building and Safeguards building, Unit 1. Minimum gap width as specified on Design Change Authorization (DCA) 21829, Revision 8, varies between 1" and 3/4" for unscaled areas, and is 1 1/2" for sealed areas. The minimum gap width observed was 1 1/2" except for several pieces of rotofoam, duct tape, bolts, nails, and wire Loose items will be removed, as well as, fixed items (such as nails) which violate dimensional tolerance Traveler CE87-1855-01-8904A Inspection of the double walled building separation gap between the Reactor building and Auxiliary building, Unit 1. Minimum gap width, as specified on DCA 21829, Revision 8, varies between 2" and 1/2", depending on elevation. The greatest discrepancy found was a 15 square foot area with a separation width of 1.906" encompassing an area where the required separation width is 1.914" or 1.970". Other discrepancies adentified were areas where form ties and concrete ridges caused local

, dimensional violation Bisco officials stated that all identified discrepancies would be documented on NCRs and corrected prior to the final closecut inspection to be performed by the

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applicant's QC inspector The NRC inspector verified that the two referenced double wall gap inspections were performed in accordance with Procedure NQA-3.09-1.08. Bisco employees used calibratec probes to test dimensions and used cameras to visually inspect surface conditions. The CPRT and Bisco considered all loose debris to be unacceptable whereas fixed deformities (such as embedded form ties) were considered acceptable as long as dimension tolerances were not violate The NRC inspector identified the above activity as 4 strength in that the efforts of Bisco engineers and interfacing applicant representatives to clean and validate the double wall gaps were clearly professional and reflected an excellent attitude toward qualit c -

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No violations or deviations were identifie Revision of Enaineering Calculations to Reflect Final As-Built Condition (NRC Reference 02.c.05.00)

The NRC inspector reviewed SWEC calculation 16345-CS(B)-044, "Assessment of Seismic Air Gaps Between Structures, Unit 1," dated October 22, 1987. The objective of this calculation was to show that inter-building relative displacements during the safe Shutdown Earthquake (SSE) are less than the minimum required gaps as proposed in Design Basis Document (DBD)

-CS-019, Revision 1. The actual building gaps will be verified by the applicant's QC inspectors to he greater than the DBD required gaps. The SWEC calculation considered the worst-case condition of maximura seismic and thermal deflections. The results of the SWEC calculation are preliminary in most cases and require confirmations of various assumptions and boundary conditions. The gap requirements of DPD-CS-019 were found by SWEC to be acceptable with the exception of gap dimensions specified between the containment internal structure and containment shell. An attachment to the calculation provided revised gap dimensions to bc incorporated in the next revision of DBD-CS-01 SWEC's reprocentatives expect other gap requirements to remain unchanged even after all confirmations are cleare The NRC inspector reviewed the calculation for assumptions, methodology, numerical accuracy, and conclusions. All questions were satisfactorily answered oy SWEC official No violations or deviations were ide'tifie This completes the NRC inspection of ISAP II.c. Inspection of the final approved calculations and final quality control (QC)

inspections of the double walls will be addressed under the Corrective Action Program (CAP) in association with Issue A2 . Quality of Construction (ISAP VII.c)

Issue-Specific Action Plan VII.c was initiated by Ud Electric to provide assurance that unidentified concerns related to the quality of construction of the hardware would be identified, evaluated, and resolve This ISAP was a self-initiated

, program developed independent of issues' raised by external source Populations of homogeneous QC-accepted safety-related construction work products were randomly sample Reinspections and/or documentation reviews were performed for the sampled hardware. The results were collectively evaluated with conclusions and recommendations

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presented for each population in the appendices to the Results Report for-ISAP VI The following activities for ISAP VII.c were reviewed by the NRC inspector during this report period: Concrete Placement (NRC Reference Item 07.c.27.00)

(47056)

The NRC inspector reviewed the Results Report for ISAP VII.c, Appendix 18, "Concrete Placement." Questions resulting from this review were satisfe:terily answered by the responaible CPRT engineer and b5 reference to Safety Significance Evaluations (SSE) contained in the main document file. Field inspections were performed and documented in previous NRC inspection reports (50-445/87-02, 50-446/87-02; 50-445/86-26, 50-446/86-22; 50-445/86-01, 50-446/86-01; 59-445/85-18, 50-446/85-15; 50-445/85-16, 50-446/85-13; 50-445/85-14, 50-446/85-11; 50-445/85-13, 50-446/85-09). The NRC inspector reviewed documentation in the CPRT working files that supports CPRT activities and corclusions for this population including: (1) population description, homogeneity justification, and sampling methods; (2) matrices used for determining adverse trends and tabulating deviations versus attributes; (3) documentation used as reference for the identification of inspection attributes and the compilation of CPRT inspection procedures; and (4) justification for the root causes, generic implications, recommendations, and conclusions detailed l in the Results Report. NRC inspections of SSEs were performed and documented in NRC Inspection Report j 50-445/87-04; 50-446/87-04. The Results Report conclusion that there is reasonable assurance that concrete is adequately installed to perform its i safety-related function appeared justified by the details l of the report and supporting working files noted above.

l The implementation of corrective actions documented in i Section 4.0 of the Results Report will be inspected under

! the Civil / Structural CA This completes the NRC review of ISAP VII.c, Appendix 1 *

l No violations or deviations were identified.

l l Cement Grout (NRC Reference Item 07.c.32.00) (470561 The NRC inspector reviewed the Results Report and supporting CPRT working files for ISAP VII.c, Appendix 21, "Coment Grout." Questions resulting from this review were satisfactorily answered in discussions with the responsible CPRT engineer and/or reference to specific SSEs. Documentation reviews were perfermed and

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reported by the .'1RC inspector in NRC Inspection Report  !

50-445/86-26, 50-446/86-22. NRC inspections of SSEs were performed and documented in NRC Inspection Report 50-445/87-04; 50-446/87-0 The Results Report concludes that there is reasonable assurance that the grout placements have been adequately performed in conformance with the design based on:

(1).the results of the activities performed and documented in the working files and, (2) the satisfactory closure of PDR-60 (a-QA/QC Program Deviation Report).

PDR-60 addresses Inspection Procedure QI-QP-11.0-6, Revision 0, which contained no requirement to verify surface temperature prior to grout placement. Earlier ,

and subsequent procedures included this requiremen Corrective Action Request CAR-080X, Revision 3 was issued

to address PDR-60. Stone and Webster responded to CAR-080X in letter SWTU-4473. SWEC identified 160 grout placements found in the inspection log for the time period that CPI-CPP-11.0-6, Revision 0 was in effec In all cases, the surface temperature was determined by SWEC to be within allowable limits based on a review of ambient temperature records, additional inspection  :

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records, and/or the location of the placements in an enclosed environment.

I The NRC inspector reviewed PDR-60, CAR-080X, and

. SWTU-4473 to ensure that this situation was adequately addresse No corrective action recommendations were listed in the Results Repor The NRC inspector reviewed documentation in the CPRT

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working files that supports CPRT activities and

conclusions for this population including:

(1) population description, homogeneity justification, ans' sampling methods; (2) matrices used for determining

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adverse trends and tabGlating deviations versus

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attributes; (3) documentation used as reference for the identification of inspection attributes and the compilation of CPRT inspection procedures; and (4) justification for the root causes, generic implications, recommendations, and conclusions detailed in the Results Report.

i The conclusions stated in the Results Report appeared to

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be justified by the details of the report and supporting working files noted above. No violations or deviations were identified. This activity is complete and no further NRC inspection is planned for this reference item.

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i Epoxy Grout (NRC Reference Item 07.c.33.00) (47056)

The NRC inspector reviewed the Results Report and supporting CPRT working files for ISAP VII.c, Appendix 22, "Epoxy Grout." Questions resulting from this review were satisfactorily annwered in discussions with the responsible CPRT engineer and/or reference to specific SSEs. Documentation reviews were performed and reported by the NRC inspector in NRC Inspection Report 50-445/86-26, 50-446/86-22. NRC inspections of SSEs were performed and documented in NRC Inspection Report 50-445/87-04; 50-446/87-0 The results report concludes that there is reasonable assurance that the grout placements have been adequately performed in conformance with the design based on the results of the activities performed and documented in the working files. No corrective action recommendations were listed in the Results Report The NRC inspector reviewed documentation in the CPRT working files that supports CPRT activities and conclusions for this population including:

(1) population description, homogeneity justification, and sampling methods; (2) matrices used for determining adverse trends and tabulating deviations versus attributes; (3) documentation used as reference for the identification of inspection attributes and the compilation of CPRT inspection procedures; and (4) justification for the root causes, generic implications, recommendations, and conclusions detailed in the Results Repor The conclusions stated in the Results Report appeared to be justified by the details of the report and supporting working files noted above. No violations or deviations were identified. This activity is complete and no further NRC inspection is planned for this reference j

ite . Exit Meetina (30733)

On February 29, 1988, R. F. Warnick, H. H. Livermore, and J. S. Wiebe met with L. D. Nace and A. B. Scott to discuss

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February inspection findings and other matters of interes An exit meeting was conducted March 1, 1988, with the

applicant's representatives identified in paragraph 1 of this

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repor No written material was providea to the applicant by l the inspectors during this reporting perio The applicant i did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio During this meeting, the NRC inspectors summarized the stope and findings of the inspection.