IR 05000445/1987035

Insp Repts 50-445/87-35 & 50-446/87-26 on 871202-880105. Violations & Deviations Noted.Major Areas Inspected:Actions on Previous Insp Findings,Assessment of Allegations, Followup on Violation/Deviations & Corrective Actions

ML20149J722
Person / Time
Site:	Comanche Peak
Issue date:	02/12/1988
From:	Ellershaw L NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20149J607	List: ML20149J605 ML20149J632 ML20149J659 ML20149J722
References
50-445-87-35, 50-446-87-26, NUDOCS 8802230188
Download: ML20149J722 (23)

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APPENDIX C'  ?

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.U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS

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NRC Inspection Report:

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50-445/87-35 Permits: CPPR-126  !

50-446/87-26 CPPR-127 1 Dockets: 50-445 Category: A2 , ,

50-446 -

Construction Permit Expiration Dates: _

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Unit 1: August 1, 1988  ;

Unit 2: Exten= ion requast

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submitte Applicant: TU Electric ' '

Skyway Tower '

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400 North Olive Street '

, Lock Box 81 Dallas, Texas 75201 .

Facility Name

Comanche Peak Steam Electric Station (CESTS),  ;

Units 1 & 2

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Inspection At: Comanche Peak Site, Glen Rose, Texas

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!' Inspection conducted: December 2, :987 through January 5,~1988 ,

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Inspector: # #/1.hrweA G n L. 2. E21Ershaw, Reactor Inspector jtpgdq#  !

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(paragraphs 2, 3.a o. 4, 5.a-o, 6, and 7)  ;

i l Consultants: EGEG ~ J. tale (paragraph 4)

i i l Parameter - P. Stanish (parac,ach 2, L a, 3.b, :

and 5.b)  !

j K. Graham (paragraphs 3.c, 3.d, 0 o, ann ,

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3900230166 880212 PDA APOCM 05000445 Q DCD

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RevitWed by: . j d d .1,yu d d ___ 2/g/pp '

H. H. .'Jverme.re, Lead Senior Inspector /Date i

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Inspection Suma g: .

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'ns.r,eetive Conducted: December 2, 1987 throuch January 5, 1988 * i j forQhA45 / 87-5Nijko-44 GJ st1~26 ) '

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Unannounced resident safety inspection of j sppf M t actions on previous inspection findings, assessment of- -

a allegations, follov-up on violations / deviations, general plant Areas (tours), Ceacoche Pea)c Response Team (CPRT) issue-specific ,

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acticn pir.n (ISAPc) VII,b.04, Corrective Action Program, and  ;

hilow mp on NRC compliance Bulletin 87-0 i i

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Rosults: Within the seven areas inspected, one violation (improper as-built documentation, paragraph 5.a and fallure to implement  ;

i procedural requirementa for HVAC CAP, paragraph 5.c) and two

deviatio.a (improper as-built documentation, paragraph 5.b; and -

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' failure to implement procedur&1 requirements, paragraph 2) were  !

identifie !

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- 3 DETAILS Persons Contacted

• W. H. Benkert, Staff Assistant Manager, Operations Quality Assurance (QA), TU Electric

• D. Best, Nuclear Operations Inspection Report Item Coordinator, TU Electric

• N. Bize, Engineering Assurance (EA) Regulatory Compliance Supervisor, TU Electric

• R. Blevins, Manager, Technical Support, TU Electric

• D. Gaden, CPRT, IT Corporation

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

• L. Heatherly, EA Regulatory Compliance Engineer, ,

TU Electric -

• W. Lowe, Director of Engineering, TU Electric

• D. Nace, Vice President, Engineering & Construction, TU Electric

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

• M. Reynerson, Director of Construction, TU Electric

• J. Figgs, Plant Evaluation Manager, Operations, TU Electric

• Ei Scott, Vice President, Nuclear Operations, TU Electric

• E. Scott, Manager, Startup, TU Electric

• C, R. Smaney, Unit 1 Assistant Project Manager, TU Electric

• R. Steelman, CPRT, TU Electric ,

• B. Stevens, Manager, Electrical Engineering, TU Electric

• B. B. Taylor, Nuclear Operations, Maintenance Manager, TU Electric

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The NRC inspectors also interviewed other applicant employees during this inspection perio * Denotes personnel present at the January 5, 1988, exit [

intervie ; Applicant Action on Prevkous Inspection Findings (92701)

(closed) Unresolved Item (445/8731-U-04): This item is being closed in this inspection period and elevated to a deviatio ~

This unresolved item involved several apparent inconsistencies in the documentation of dates that calculations were performed and subsequently checked. Two instances were cited, one where

< the checker dated the calculation page the day before the

engineer performing the calculation dated it, and a

, calculation summary sheet that appeared to be prepared before

' some of the calculations summarized on this sheet were

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performe Upon further investigation into the cause of these inconsistencies, Impell stated the case of the checker dating ,

the calculation sheet prior to the calculation being performed ;

appeared to be an error on the part of the checker. For the summary page, Impell stated that it appeared that some of the calculations in this package had been added after the summary i

page had been initially prepared and signed off by the ,

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engineer and checker; however, when the information generated as a result of these additional calculations was added to the summary sheet, the summary sheet was not revised to indicate there had been a chang Also, in this inspection period, on page la of 63, of calculation A-02151 for Room 148B, entitled "Open Items", the checker indicated that his work was completed on January 6, 1987; however, the preparer signed and dated this document on

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January 7, 1987. The abovb examples of improper documentation now constitute a deviation from Appendix A to Project Instruction PI-0210-053-001 (445/8735-D-01).

3. Follow-up on Violations / Deviations (92702)

' (Closed) Deviation (445/8603-D-13):' This deviation dealt with three cases where pipe to pipe clearances did not meet the specified criteria of OI-025, but were not'

id6ntified by Evaluation Research Corporation (ERC)

during reinspection of the Verification Package I-M-LBCO-148. In NRC Inspection Report 50 '445/87-18; 50-446/87-14, the NRC inspector documented that he

reviewed, and concurred, that an appropriate deficiency report (DR) had been issued and further concurred that satisfactory disposition of Nonconformance Report (NCR)

M-25340 would remedy the situation; however, at that time the rework required by the NCR had not been performed, so this item remained open pending completion of this rework. In this inspection period, the NRC inspector was

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able to verify that the rework required in the NCR'

disposition had been completed and the pipe to pipe clearances in question are now in compliance with the specified criteria. Therefore, this deviation is close (Closed) Deviation (445/8607-D-10): This deviation dealt with OI Package 13-I-M-LBCO-148 not identifying unsatisfactory decisions made during the course of the initial ERC reinspectio It dealt with three pipe to pipe clearance deficiencies identified by the NRC inspector in the above mentioned deviation (445/8603-D-13). Corrective action included revision of the OI checklist to reflect actual field conditions and .

issuance of the appropriate DR and NCR. Actions to I prevent recurrence included documented discussion of this l finding with all overview inspectors and a documented !

discussion between the overview inspector and the initial i ERC inspector of recor I i

In NRC Inspection Report 50-445/87-18; 50-446/87-14, the NRC inspector documented his review and finding of acceptability of the DR and the subsequent NCR, that the OI checklist had been corrected to reflect the actual i field conditions, and that the committed discussions had l

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taken place and been documente However, since the committed rework had not been completed, this item '

remained ope In this inspection period, the NRC inspector verified that the committed rework has been '

completed; therefore, this deviation is now closed.

> (Closed) Violation (445/8631-V-01): This violation dealt with the applicant's engineering technical evaluation of NCR M-83-101128, Revision 0, pertaining to reported ;

excessive reinforcement (5 deficiencies) and undercut (2 !

deficiencies) in containment liner welds. Radiographic examination (RT) performed by Chicago Bridge and Iron ,

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(CBI) was part of the technical justification for the '

use-as-is disposition although RT of the weld areas in

question had not been performe ,

In response to the NOV, the nonconforming conditions were reevaluated by engineering, QA/QC and ER The five deficiencies pertaining to excessive reinforc< ment were either not considered valid by the

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applicant or the reinforce.nent was in an area of the seam weld that had not been subj,ected to radiography. This

evaluation and disposition was accepted by engineering, ,

ERC and QA/QC.

The two deficiencies pertaining to undercut were reinspected by a Level III inspector and the ERC

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inspector who initially identified the deficiencie No

~~ endercut condition could be loccted that exceeded 1/32".

Tnis depth is acceptable in accordance with ACI code 359 ' '

, and the applicable specification (2323-SS-14,

"Containment Steel Liner").

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The NRC inspector reviewed NCR M-85-101128, Revision 2,

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and concurs with the reevaluation of the NCR by the :

applican !

On March 4, 1986, Corrective Action Request (CAR) 062 was i

initiated and identified, in part, that a generic

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deficiency existed concerning inadequate technical

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evaluations for closed NCRs. Part of the corrective action to preclude recurrence included training of ,

engineers associated with NCR disposition l

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l In addition, 50.55(e) report, SDAR-CP-86-48, was

! transmitted to NRC on July 16, 198 The SDAR was )

initiated as a direct result of CAR-062 deficiencies and

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will be evaluated by the NRC when closing the SDAR.'

The NRC inspector verified, by review of TU Electric

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Letter TUQ-4662, that additional training had been  ;

provided to project personnel. The NRC inspectors.will

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review the SDAh (which will be tracked by the 50.55(e)

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report number) in a subsequent inspection _ report.-

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' (Closed) Violation (445/8607-V-02): . TU Electric Nuclear .[

Engineering (TNE) provided design information which- l

delineated the inspection acceptance criteria'for base  ;

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material defects on field fabricated tanks to ERC in a  !

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response to'-Technical-Information Request (TIR) TIR-017, 'l dated August 26, 1985. TNE's' method-for verifying the _i

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adequacy of the design information was by the use of j l calculations. Those calculations were incomplete and  !

unapproved on May 13,-198 .

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i inspection acceptance criteria for base material defects, , j i TNE-SY-CA-0000-290,- Revision 1, and determined that no -r

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change to previously issued acceptance criteria was  !

I required. NRC inspectors reviewed the contents of the  :

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calculation and questioned engineering ; personnel  :

j concerning the margins of conservatism '( .3% below the -  !

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allowable stress) for the. boric acid tank wall stress f j level In response to the NRC-inspectors concern over i j lack of conservatism, Engineering personnel-provided l

copies of the new calculations generated by the Impell .t Corporation as a part of the Equipment Qualification y Corrective Action Program. Calculation (

. IMT-CA-EQ-0116-ME-67, Revisi'on 0, "Resolution'of Boric  !

Acid Tank Discrepancies", and IMT-CA-EQ-0146-MS-67,  ;

1 Revision 0, "Resolution of-Recycle Hold-up Tank i Discrepancies", were reviewed by the NRC inspector. Tha.t_ ___Ji J review concluded that a greater margin of conservatism i

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for tank wall stress levels exists than those documented I j by ths THE calculatio Ht NRC inspector - found the new l

calculations to be correc i

i The applicant's corrective action for the violation-

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included a review of all other TIRs which had been issued '

1 and supplemental training of engineering personnel. The i NRC inspector has reviewed the corrective action and

, cor.siders it to be adequately responsive to-the ,

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(Open; Violation (445/8607-V-04)

Field design changes,  !

J pertaining to the installation of stainless steel shims  !

I between the reactor coolant system crossover leg piping  !

] and saddle blocks, were not submitted to the organization i i that performed the original design for review and l 4 approva In addition, the traveler which was used to l j implement the design change did not document all of the  !

t changes that occurre I l  !

l The applicant issued DR C-87-866 to address the NRC l j inspection findin This DR required a review of shim  !

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installation travelers and the issuance of NCRs for any deficiencies identified. The NCRs issued as a result of the DR do not document the conditions noted in the Notice of Violation. No evidence has been provided to~ determine if a generic problem exists. The failure to document the NRC identified conditions precludes the evaluation of corrective action requirements for other NSSS travelers where shimming was required. This violation remains open pending further Applicant actio ; Allecation Follow-up (99014)

(Closed) Allegation (OSP-87-A-0038): Concerns number one and two of this allegation were addressed and closed in NRC Inspection Report' 50-445/87-24, 50-446/87-18. This report ,

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addresses the third concern regarding Hilti Kwik bolt installatio The alleger claimed that (a) QC inspectors were verifying Hilti bolts after tensioning instead of prior to tensioning as required by QC prgcedure, (b) that many Hilti Kwik bolt installations exceeded 6 from' perpendicular, (c) that the craftsman had been terminated as a result,of -

having followed instructions, and (d) that the practice of straightening Hilti bolts was commo .

Review '

i The NRC inspector reviewed the last 10 revisions of .

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QI-QC-ll.2, "Inspection of Hilti Bolts"; Project Specification 2323-SS-30, Revisions 1 through 3, "Structural Embedment

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Inspections"; and the CPRT Results Report for ISAP VII. .The NRC inspector interviewed various craft and QC inspection i personnel, and performed over two hundred inspections of Hilti Kwik bolt installations at the Comanche Peak Power Plant with the following results: '

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QI-QC-ll.2 and 2323-SS-30 did not and does not currently address inspecting Hilti Kwik bolts prior to tensionin Inspections are performed after tensionin .

Due to lack of specificity on the part of the alleger, the NRC inspector was unable to locate the subject bolts or to verify that two Hilti Kwik bolts had or had not been straightened or that the craftsman had been terminated for straightening bolts. However, during the NRC inspections of the small bore supports, large bore supports, HVAC equipment supporta, HVAC duct supports, instrumentation supports and conduit supports, the i inspector was unable tog locate any Hilti Kwik bolts with an angle greater than 6 from vertica Further, from a review of the ISAP VII.b.04 and VII.c Results Reports, J the inspector determined that out of approximately 3000 inspection points for angularity, only 3 resulted in ;

deviations. All craft and QC personnel interviewed were :

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fully aware of the correct requirements for Hilti Kwik

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bolt installation. The NRC inspector was unable to

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substantiate this concern. Although chis allegation is considered closed, the NRC does plan additional  ;

inspections of Hilti bolt installatio '

5. Corrective Action Program (C_AP)

NRC inspections were performed to verify the applicant's activities associated with che Post Construction Hardwarc Validation Program (PCHVP). The PCHVP was established to ,

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reconcile the design to the design bases appropriate to

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satisfy licensing commitments, and to reconcile the hardware to the designs i.e., the constructed / installed systems meet the intent of the design. The following CAPS were inspected ,

during this report perio Conduit Supports A & B Train and Train C > 2" (48053)

i During this inspection period, the NRC inspector selected a sample of fifteen conduit walkdown packages to verify the accuracy and ccrrectness of the Ebasco field collected data. The following is a list of the NRC inspected packages:

Conduit Size Room * Area ** Supports C13005319 1" 56 SG1 6 i C13G04860 2" 66 SG1 6

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C13G15122 1" 74 SG1 10 -

C14G20243 2" 163/155A RB1 , 3 C14R13875 2" 154 RB1 6 C14G32427 1 1/2" 154 RB1 12 C14030157 1" 154 RB1 3 C14G21444 3/4" 174 AUX 4 C12G07286 1" 179/201 AUX 7 j C13G05991 3/4" 179 AUX 1 C14G11447 3/4" 175 AUX 15 C14B14844 3" 133 ECB 6 C12G19612 3"/2" 133/113 ECB 9 C12G07907 2" 133 ECB 8 C13006609 2" 133 ECB 5 i

• SG1 - Unit 1 Safeguards Buildi *RB1 - Unit 1 Reactor Building

• AUX - Auxiliary Building 1

• ECB - Electrical / Control Building l

• • Number of supports includes conduit, junction box and l pull box support l

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! The NRC inspector's walkdowns were performed while !

adhering to.the criteria of field verification method l

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(1) on conduit Support C13G04860-02, the walkdown engineer failed to note that there were no washers j installed under the hex nuts on the Hilti Kwik i bolt Because of this, there was no nonconformance  ;

report written as required by the FVM. These  :

washers, provided with the Hilti Kwik bolts, provide  !

. a hardened surface between'the hex nut and the mild i steel clamp.- This assures that the torque being applied to the assembly results in tension in th "'~~

anchor bolt and is not dissipated by deformation in the mild steel clamp which could result in less than the required preload being applied to the anchor . l bol l (2)' For Support C14G20243-01, the walkdown engineer 1 raported,the length of the support bsseplate to be  ;

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9 7/8".' During'a subsequent walkdown by the NRC  !

inspector, this dimension was found to be 9 1/2". l An error such as this could result in the calculation of incorrect baseplate stresses and

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anchor bolt load .

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(3) on Conduit Support C14G11447-03, the walkdown j engineer reported several dimensions that could not 1 be verified by the NRC inspector during his i 1 inspection of this' suppor The support in question

is a 2323-S-0910 Type CA-la support which utilizes f P5000 Unistrut members with one main member and three outriggers. This support is being used to ,

support'two 3/4" conduits - conduit numbers  !

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C14G11447 and C14G11446. The first discrepancy is t the dimension from the westernmost end of the main Unistrut member to the centerline of the west  !

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condui The walkdown engineer reported this l

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dimension to be'5 1/8"; the NRC inspector found 'this dimension to be 5 7/8". The second discrepancy was

the dimension reported for the location of the  ;

center outrigger. The walkdown engineer reported i

7 1/8", and the NRC inspector found this dimension ,

j to be 8 5/8" The third dimensional discrepancy  ;

found on this support was the location of the i

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easternmost outrigger. The walkdown engineer  !

reported it to be located 15/16" from the end of the <

main Unistrut member, and the NRC inspector ~

determined this dimension to be 1 1/4". Errors of  :

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this nature could result in the calculation of  !

incorrect anchor bolt loads and incorrect Unistrut '

i member stresse i

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(4) on; support C14Gil447-04, which is the same type'of support as discussed in item (3) above, the dimension locating the center outrigger was. reported by the walkdown engineer to be 6 5/8" from the westernmost and of the main Unistrut membe HowcVer the NRC inspector found'this dimension to be 7 1/2". Again, an error of thi's nature could~have-an adverse affect'on the calculated anchor bolt-loads and Unistrut-member stresse (5) For Conduit Support'C14Gil447-14, 2323-5-0910 Type CA-la support,-the walkdown engineer reported a

' total of eight HKBs - two 1/4" HKBs in each of the three outriggers and-two 3/8" HKBs in.the main Unistrut membe During the NRC inspector's ,

walkdown, it was noted that there were,:in fact, nine HKBs the difference being that there were three 3/8" HKBs in the main Unistrut member not two as-reporte The additional HKB is located at the centerline of the center. outrigger and has.the

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letter designation "H" and projects 3/4" from the surface of the concret These are five examples of incorrectly documenting existing conditions, a violation (445/8735-V-02) of'

criterion V of Appendix B of 10 CFR 50 and FVM CPE-EB-TVM-CD-033. Three more examples are in paragraph 5.c ot' this repcT On the remaining conduit runs, the results of the NRC walkdown revealed certain data that did not match that recorded by Ebascos however, it was deemed to be acceptable since the difference in the recorded dimensions was still within the tolerances specified in the applicable TVM. These minor differences are not

' considered to be of any significanc The five examples discussed above were detected in the walkdown of fifteen conduit walkdown packages. In these packages, there are in excess of three thousand inspectable attribute In light of this data, the Ebasco walkdown personnel are performing in a reasonably good manne Conduit Supports C Train Less than or Ecual to 2" (48053) _

For this inspection period, the NRC inspector performed a review /walkdown of the total scepe of work Impell performed for Room 76 of the Unit 1 safeguards building and Room 148B of the electrical / control building.

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Room 76 Safeouards Buildino

The-following calculation /walkdown packages were included

in the inspector's review of Room 76: l Calculation N Title l: .

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I RCO-1-SG-76 . Room Closeout-Calculation

[ L2-5-1-SG-76 Level 2 - Conduit Support  :

1 Evaluation  :

l A-00379 Level 5 support Evaluation ,

A-00383

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Level 5 support Evaluation i A 00535 Level 5 support Evaluation  ;

A-00628 Level 5 support Evaluation-

L6-1-sG-76 Train C Conduit Interaction ,. !

Evaluation

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While performing the review /walkdow'n for Room 76, thefNRC  !

inspector identified the following discrepancies with

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respect to the walkdown a For RFI-E5-1-0118, Appendix A to Calculation A-00628,  !

i page 4 of 4 of this appendix is the as-built drawing  !

! which forms the basis of this calculatio On thi l J drawing, the engineer who performed-the walkdown reported  :

that the Unistrut bolts being used to secure the junction l

• box to the Unistrut member were 3/8" in diameters  !

however, the NRC inspector found these bolts to be,'in '

i fact, 1/2" in diamete Also, on this same as-built  !

l drawing, the walkdown engineer reported that the NKB on i the north side of the junction box was located 1 1/2" j away from the junction box. The NRC inspector determined l'

i i-the distance to be 1 1/8". I l Room 1488 Electrical / Control Build (ag  !

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4 The following calculations /walkdown packages were l j included in the NRC inspector's review of Room 1488: i i  !

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% l, Calculation No'. Tikle ,

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RCO-1-EC-148B Room Closeout Calculation /

Documentation l L2-S-1-EC-1488 -Level 2 Conduit Support-Evaluation l i

L4-S-1-EC-1488 Level 4 2 Conduit Support Evaluation  !

L4-JB1-ECB-148B Lovel 4 - Junction Box /CI Box / Light ~'

l Fixture Evaluation' '

A-01357 Level 5 - Junction Box /CI Box / Light i i Fixture Evaluation  !

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A-01385 Level 5 -' Junction Box /CI Box / Light '

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Fixture Evaluation -

! A-01387 Level 5 - Junction Box /CI Box / Light  !

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Fixture Evaluation

A-01388 Level 5 - Junction Box /CI Box / Light ,

Fixture evaluation ,

j A-01389 Level'-5 . Junction Box /CI Box / Light }

Fixture Evaluation A-02151 Level 5 - Support Evaluation _

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j , L6-1-EC-148B Level 6 -. Train C Conduit Interaction

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Evaluation .

I While performing the review /walkdown'for Room 1488, the I NRC inspector identified the following discrepancies with- .:

respect to the Impell walkdow l j .

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(1) on the isometric drawn to depict the conduit runs -!

i . being evaluated as part of the calculation' entitle'd i i A-0215I7'and shown on page 24 of 43 of this  !

calculation, there'are several errors and omission l First, the dimensional data and orientation for l

{ conduits C-1PA-CR2 and C-1FD-A180, south of the  !

l Type 6 support tagged NQ-19688/A-02156, have been L

reversed; therefore, the isometries for both conduit  !

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runs are incorrectly depicted. Also, on_the same

! page of the calculation in question, the dimension e

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{ northsof the Type 6 support tagged NQ-06005/A-02157

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i to the change in elevation is not shown on the ~

j isometric fr ' conduit run C-1PA-A265. These-two items, when reviewed with Impelt personnel, appear i i to be drafting errors because the data for the first  !

! discrepancy appears to be correct on the engineer's i

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hand sketch generated in the field, and the data was [

redrawn incorrectly and this error was not detected  ;

by the checker. For the second discrepancy, even j though the dimension was missing from the final j

, isometric, it appeared in the engineer's draft copy  ;

so it was included in the evaluation of the  ;

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supports; again this appears to-be an undetected  !

drafting error.

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(2) The second discrepancy found in the NRC inspector's [

i walkdown is the east-west dimension from the Type 6  !

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support tagged NQ-06004/A-02168 to the-rise in elevation of the' conduit to the bolted junction box-tagged NQ-08650. This dimension was reported by the walkdown engineer to be 22" and the NRC inspector measured this dimenaicn at 13".

(3) On the Type 7 support tagged NQ-06002/A-02160, shown on page 26 of 43 for calculation A-02151, the walkdown engineer reported an overall length of the ,

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P1001 Unistrut member to b5 10";' this length was determined to be 8" by the NRC inspecto The discrepancies above detected in Rooms 76 and 148B ,

constitute a deviation (445/8735-D-03) from the

' 1 commitments of the pI-0210-053-00 . .

The results of the review /walkdown of the remainder of ,

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the' data presented for the above rooms revealed certain-

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data which did not match that recorded by Impell; '

however, it was deemed to be acceptable'since the difference in the recorded dimeraions was still within

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the tolerances specified in the applicable project l

'* instruction (PI) and are not considered to be of any l significanc l The discrepancies listed above represent a very small '

percentage of the total inspection / review points for the two rooms inspected. Therefore, the results of the .

Impell walkdown engineers is considered to be adequat 'c . Heating, Ventilation, and Air-Conditioning (HVAC) (50100)

NRC inspectors performed field inspections and documentation reviews of the following documentation packages generated as a result of construction, engineering, and inspection activities related to HVAC .

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CAP implementation: i Seismic Duct Hangers Unit Room

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DH-1-884-1K-WP13 1 99A  !

DH-1-844-1K-4F 1 99B  !

DH-1-844-1K-1R 1 99B DH-1-844-1K-WP-12 1 99A Seismic Duct Segment Unit Room B-1-658-016 1 99B i NRC inspection of Seismic Duct Hanger DH-1-844-1K-4F, Revision 1, identified that a fillet weld. 3/16" x 5/8"

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long, which exists at the location shown by note 3 on the j design drawing had been incorrectly recorded by  ;

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engineering personnel as a tack weld. This weld is too large to.be classified as.a tackLwel FVM' .

CPE-EB-FVM-CS-029, Revision'5 provides the. definition of a tack weld. The failure tb das-built"Lwelding-in- '

accordance with HVAC CAP. commitments.is a violation of Criterion V ( 445/8735-V-02) ( 6th exar.iple) .

NRC' inspection of seismic' duct hanger packages, DH-1-844-1K-WP13, Revision-1,.and DH-1-844-1K-1R, Revision.1, revealed-that construction had removed *

galvanized coatings from welds to: allow for.a visual inspection by QC inspectors and.had failed toLreapply the required galvanized coating in accordance with HVAC: CAP commitments. The NRC inspector identified that five welds located on Seismic Duct Hanger.DH-1-844-1K-1R did- ,

not have the galvanized. coating as required by' Comanche Peak Engineering.(CPE) Specification 2323-MS-8 Engineering personnel confirmed that all planned HVAC ' CAP I inspections of these items were complet The CPE. -

specification requires that a galvanized. coating shall be applied to areas where galvanizing has been removed due-to welding or other fabrication / installation operation Engineering personnal were unable to provide a basis for

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exemption of the, coating requirements from the identified weld This is a violation of Criterion V (445/8735-V-02) (7th example).

The NRC inspector reviewed the contents of Duct Segment Package B-1-658-016. A comparison.of forms used in.the

.____ duct segment package with those contained in controlled Procedure CHV-106, Revision 1, determined;that engineers performing a qualitative walkdown of duct segments were documenting results of their activities on a controlled form, Figure 7.6, on which minor corrections had been.

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made without a. formal revision of the procedure being performe This informal revision of a procedural form was discussed wit > angiaeering and QC personne Subsequent to that discussion, DR C-87-05093 was issued by the applicant. Additionally, TU Electric Letter MC-1461 provides a discussion of the NRC inspection findin Project personnel-did not comply with the requirements of Procedures ECC 1.03 and ECC 1.04 for

procedure revision and revision control. The failure to

follow these requirements is-a violation of Criterion V

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(445/8735-V-02) (8th example).

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NRC inspection of DucC Segment B-1-658-016 revealed several areas on the hem flange between B-1-658-016 and

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B-1-658-015 where the gasket material, Tremco 440,'had

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been squeezed out from between the flange and was no longer serving its intended function. It was determined that this particular section of gasket material had been installed with a row on each side of the bolted

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connection and that in the process of being squeezed out, the hard rubber core was also expelled. The same problem, was identified on 12 different duct segments in the same building. This condition was identified by Ebasco on CAR 87-079, and is considered an open item pending further clarification ~and NRC review (445/8735-0-04).

Assessment Implementation of the NVAC CAP requires that welding be as-built to reflect actual field conditions. Although welding was incorrectly as-built, the error is conservative in natur *

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The HVAC CAP was established to assure that field installed components meet design requirements. The-design. specification for HVAC clearly states that a ,

protective coating shall be applied to completediweldin The failure to apply protective coatings occurred due to

, a misunderstanding between QC and engineering as to who was responsible for field verificatio The NEC inspector considers the structural safety significance of

this finding to be lo Project personnel bypassed the requirements of project l

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. procedures when revising a form used t'o document engineering walkdown results. The changes that were made <

to the form were improvements and clarified how to '

document result .. CPRT ISAPs: Hilti Anchor Bolt Installation (ISAP VII.b.4) l (480638) ' Review Specifications / Procedures and Identify Safety-Significant Attributes (NRC Reference 07.b.04.01) l L

The following specifications / procedures were reviewed by l the CPRT: l Specification / Procedure Revision Title j Gibbs & Hill Specifica- 1 Structural tion 2323-SS-30 Embedments Brown & Root Procedure 9 Installation of j CEI-20 Hilti Drilled-In l Bolts  !

TU Electric Instruction 18 Installation of l QI-QP-11.2-1 Hilti Drilled-In l Bolts l l .. - \

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The CPRT review revealed that the following attributes were addressed: (1) bolt size, type and quantity, (2) embedmont depth, (3) spacing, (4) angularity, (5) concrete damage, and (6) nut engagement and nut bearing. However, CPRT also identified that the procedures'did not address the requirement for maintaining a 1:20 bearing for nuts and washer In addition, the installation procedures did not provide specificity with respect to spacing criteria associated with penetration sleeves or chamfered concrete corner Due to the fact that the reinspections of ISAP VII. were to be conducted as part of the reinspection of ISAP VI populations, it was necessary to incorporate'

all of the safety-significant attributes into the quality ,

instructions (QI) associated with each of the ISAP VI . population _

The NRC inspectors reviewed the above list'ed specificationw/ procedures to assure that those safet .

significant attributes contained in the specifications / *

procedures had been identified by CPRT in ISAP VII. The NRC inspectcrs also reviewed all QIs associated with the ISAP VII.c. populations bei~ng used for the Hilti bolt reinspections. This review assured that all safety-significant attributes (including those identified as not being addressed in the procedures / specifications) were included in the QI . Inspection of this reference item is now complet No

, violations or deviations were identifie , Review Action Plan ISAP VII.c to Assure Inclusion of Safety-Significant Attributes (NRC Reference 07.b.04.02) 1 i

The NRC inspectors reviewed the following QIs applicable to the identified ISAP VII.c population in which reinspections and documentation reviews were performed for Hiiti anchor bolt installations:

ISAp VII.c Population QI Small Bore Pipe Supports QI-019, -020 Large Bore Pipe Supports - Rigid QI-027, -025 i Large Bore Pipe Supports - Nonrigid QI-029, -030 l Equipment Supports QI-066, -067 )

Instrumentation Supports QI-055, -056

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Conduit supports QI-053, -054 Pipe Whip Restraints QI-051, -052 HVAC Duct Supports QI-035, -036 l Structural Steel QI-045, -046 l Mechanical Equipment QI-059, -060 l s

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I This review by CPRT determined that all safety- l significant attributes associated with Hilti bolt l

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installation had been addressed in the QI NRC inspection of this reference item is complet No violations or deviations were identifie c. Review - Specifications, Procedures, OC Inspections, and Training Procedures and Records to Determine Commonality (NRC Reference 07.b.04.03) l The NRC inspectors reviewed the specifications and ,

procedures associated with inspections, training, and )

record requirements in regard to QC inspector qualification ,

Training of QC inspectors and the generation of records associated with the training, is governed by_ site Procedures CP-QP-2.1, "Training of Inspection Personnel,"

and CP-QP-2.3, "Documentation Within QA/QC Qualification Files." These procedures require that the QC inspectors be trained in accordance with the applicable procedures '

developed for a given inspection act1vit ,

The commonality aspect was determined by the NRC l inspectors to be of no concern, in that regardless of the population involved, there were just two QC procedures dealing with Hilti bolts: 1.e., QI-QC-ll.2, "Hilti Bolts," and QI-QC-ll.2-1, "Installation of Hilti Bolts."

Both of these procedures established the criteria by which QC inspectors performed inspections of Hilti bolts and Hilti bolt. installatio It should be noted that CPRT identified questionable ,

qualifications regarding some QC inspectors involved with !

Hilti bolt inspection Evaluations have been performed i and addressed within the framework of ISAP I.d.1, which l deals with QC inspector qualifications, l

NRC inspection of this reference item is comp 3et No <

violations or deviations were identifie l d. Obtain Results From Action Plan VII.c Inspections (NRC Reference 07.b.04.04)

The CPRT reinspection of ISAP VII.c populations is complete and included 517 items containing approximately 3000 Hilti bolts. These reinspections resulted in the identification of 174 deviations. CPRT evaluation'of these deviations determined that none were safety-significan Fifty-nine deviations were identified as a ;

recult of documentation review; all dealing with either '

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missing or indeterminate documentation for Hilti bolt torque inspections.-

The results of the ISAP VII.c reinspection effort are documented in' population reports. These reports are not entirely complete and data is still being evaluated. At this time, however, no new issues regarding Hilti bolts have been' identified by the CPRT. If new issues are identified, they will be addressed within the context of the particular ISAP.VII.c populatio P The NRC inspector's witnessed a minimum of five percent of CPRT reinspection of the ISAP VII.c populations, and-also performed inspections of a minimum of five percent of the ISAP.VII.c population Therefore, with respect to ,

ISAP VII.b.4, no further NRC inspection of this activity will be performed. ;No violations or deviations were identifie .

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i Assure That Sample Size Chosen J From Action Plan VII.c is Adequate (NRC Reference 07.b.04.05)

The NRC inspectors have verified that the Hilti bolt  ;

sample wasrrandomly selected from each of the IFAP VI population's containing Hilti bolts. The actual number -

selected from each population was proportional to the :

number.of items containing Hilti bolts within that population. The'actu'la ISAP VII.c populations sample selections were verified by.the NRC inspectors as being in conformance with Appendix D of the CPRT Action Plan during this inspection; perio I I

NRC inspection of this! reference item is complet No violations or deviations were identifie Perform Reinspections in Accordance with Action Plan VII.c (NRC Reference 07.b.04.06) .

The CPRT inspection of the various ISAP VII.c populations is complete. The inspection attributes for ISAP VII. can also.be found in.and are compatible with the following populations of VI '

Small Dore Pipe Supports Large Bore Pipe Supports I Rigid Large Bore Pipe Supports - Nonrigid Equipment Supports Instrumentation Supports Conduit Supports Pipe Whip Restraints HVAC Duct Supports Structural Steel Mechanical Equipment

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The results of the ISAP VII.c inspections are being evaluated and documented in population reports by CPR At this point in time, however, no new issues have been identified in VII.c concerning Hilti Kwik bolts. If new issues are identified, they will be documented ~in the respective VII.c population The NRC inspectors have verified by witnessing and by performing inspections that the CPRT inspection' effort of ISAP VII.b.4 was conducted in accordance with the requirements of ISAP VI ~

NRC inspection of NRC reference Item 07.b.04.06 is 3 complet No violations or deviations were identified,

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7. Follow-up on NRC Compliance Bulletin 87-02 (25026)

NRC Compliance Bulletin 87-02 pertains to the testing of fasteners to determine conformance with the applicable material specifications, As a result of concerns expressed by l the Industrial Fastener Institute over the potential use of inferior fasteners, the NRC instituted'a limited program which included the collection and testing of a small sample of fastener The results of NRC testing of fasteners obtained ,

from several nuclear power plants revealed approximately 34%

of the fasteners (11 out of 32) failed to meet material specification requirements for mechanical and/or chemical propertie In a separate effort, Baltimore Gas & Electric tested fasteners following their discovery that commercial grade fasteners had been used in safety-related application Their results indicated that approximately 26% of the tested fasteners (399 out of 1539) failed to meet specification requirements for mechanical and/or chemical propertie This data resulted in the initiation and issuance of NRC Compliance Bulletin 87-02 which requires licensees to provide a description of their program with respect to receipt inspection and internal control procedures for fastener Further, it requires that a minimum sample of 10 safety-related fasteners (studs, bolts, and/or cap screws),

10 nonsafety-related fasteners (studs, bolts, and/or cap screws), and a like number of nuts which would be used for each of the sampled fasteners, be selected for independent testin The examples are to be selected from warehouse stoc The testing is to be performed in accordance with the requirements of the applicable fastener's specification, grade, and class. The results of all tests, including supporting information and any safety significance evaluations which would be required for any fastener found out of specification, are to be reported to the NR TU Electric conducted an inventory review and determined which fasteners and nuts existed in stock by material, type, grade,

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i and quantities. TU Electric further determined the' i proportions of installed fasteners and nuts so that the sample

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I to be selected would be as nearly representative as possibl The'NRC inspector participated in the selection process as t directed by the bulletin which resulted in a' sample consisting '

of 20. safety-related fasteners, 12 safety ^related nuts,.

10 nonsafety-related fasteners, and 10 nonsafety-related nuts. . t The sample is made up of the following-i Safety-Related-Fasteners [

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' Material Type / Grade Quantity l

A-193 B7 3 ,

j A-193 B8 2 .

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SAE-J4$9 'l A-307 3  !

A-325 2 A-325 Type 1 1 l

A-325 Type 2 1 A-325 Type 3 2  ;

A-354 Grade BD 1 -

A-490 3

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A-320 1 l

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Safety-Related Nuts  ;

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Material Type / Grade Quantity .!

t A-194 Grade 2H 3  !

A-194 Grade 7 1 A-563 Grade C 3 i A-563 Grade D 1  :

A-563 1 l A-307 1 l

A-540 1 l A-325 1

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l Nensafety-Related Fastaners i

Material Type / Grade Quantity  :

A-490 2 l A-453 Grade 660 2 A-193 B7 6 l

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Nonsafety-Related Nuts Material Type / Grade . Quantity A-194 Grade 2H 8 ,

A-563 Grade C 1 A-307 ,

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The samples were tagged-(identified) and package .

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TU Electric placed Earchase Orders CPF-35104.(nonsafety i related) and CPF-14524-S (safety related) with Southwest Laboratories to perform independent mechanical testing and chemical analysis as required by the material specification and, where applicable, the additional ~ requirements of Section III of the ASME Code. The nonsafety-related items -

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were sent to Southwest Laboratories on December 16, 1987, '

while the safety-related Items were sent on December 18, 198 I The NRC review of the bulletin response will be addressed in a subsequent NRC inspection repor .

8 '. Plant Tours  ;

The NRC inspectors made frequent tours of the facility and observed such items as in-process work activities, housekeeping, and equipment' protectio Protegtion of equipment was observed to be considerably improve No violations or deviations-were identifie ; Open Items Open items are matters which have been discussed with the i licensee, which will be reviewed further by the-inspector, and

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which involve some action on the part of the.NRC or_ Licensee or both. Open items disclosed during the inspection are discussed in paragraph _ x.

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1 Exit Interview (30703)

on January 5, 1988, prior to the exit, R. F. Warnick and H. H. Livermore met with L. D. Nace and A. B. Scott to discuss the following matters from December: NRC inspection reports for November were issued in under

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20 days, Following the enforcement conference on December 8, 1987, a Notice of Violation (three violations) was issued on December 31, 198 l i

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I 22 The NRC letter of December 4, 1987, to TU_ Electric informed the utility that the SALP evaluation process will be resumed for Comanche Pea Four additional NRC inspectors.will be transferred to the site in Januar ' OSP has a new Assistant Director for Licensing, James Wilso . . 'Two nonresident inspections were conducted in December -

U-l preservice and U-1/2 safeguards. Both inspections resulted in favorable findings, Additional examples of Ebasco and Impell walkdown' errors ' ,

were identified by the NRC in December.>> i An exit interview was conducted January 5, 1988, with the applicants representatives identified in paragraph 1 of this repor During this interview, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the finding e

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W 50-445/$f-f$; 50-446/S?-oWo DISTRIBUTION:

NRC PER Local PDR i OSP Reading CPPD-LA l CPPD Reading (HQ) *

• Site Reading File AD for Projects

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• Sr. Lead Insp. - CONS *Sr. Lead Insp. - OPS

• Concurrence '

• MIS System, RIV

• RSTS Operator, RIV DRP, RIV

'RIV Docket File

• DWeiss, RM/ALF -

l JTaylor l SEbneter/JAxelrad CGrimes *

PMcKee JLyons JWilson JMoore, OGC JGl.i.liland, RIV FMiraglia EJordan -

JPartlow BHayes

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