IR 05000445/1988065

Safety Insp Repts 50-445/88-65 & 50-446/88-61 on 880909- 1004.Violation Noted.Major Areas Inspected:Follow Up on Violations/Deviations,Corrective Action Program for Pipe & Pipe Supports,Hvac & Conduit Supports & Plant Tours

ML20204J487
Person / Time
Site:	Comanche Peak
Issue date:	10/18/1988
From:	Livermore H NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20204J453	List: IR 05000445/1988065 ML20204J448 ML20204J481
References
50-445-88-65, 50-446-88-61, EA-86-009, EA-86-9, NUDOCS 8810250147
Download: ML20204J487 (14)

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APPENDIX B U. S. NUCLEAR REGULATOPY COMMISSION OFFICE OF SPECIAL PROJECTS l

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NRC Inspection Report: 50-445/88-65 Permits: CPPR-126 r 50-446/88-61 CPPR-127 l

Dockers: 50-445 Category: A2 ,

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50-446 Construction Permit Expiration Dates:

Unit 1: Extension request submitte Unit 2: Extension request submitte Applicant: TU Electric Skyway Tower 3 400 North Olive Stroet Lock Box 81 l Dallas, Texas 75201 a t Facility Name: Comancha Peak Steam Electric Station (CPSES),

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Units 1 & 2 i

! Inspection Att Comanche Peak Site, Glen Rose, Texas i Inspection Conducted: September 9 through October 4, 1988 l

! Inspection conducted by NRC consultants:  !

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J. Dalo - EG&G (paragraph 3.a, d, f and 4.b, '

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K. Graham - Paramotor (paragraph 2.a-b, 3.b-c, e and 4.a) I

! P. Stanish - Parameter (paragraph 2.c and 4.c)  ;

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l Revicued by: JP5/thmb & _f4 -J A -PP H. H. Livermore, Lead Senior Inspector Date [

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Inspection Summary:

Inspection Conducted: September 9 throug,h October 4 1908 (Report 50-445/88-65; 50-446/88-61)

Areas Inspected: Unannounced, resident safety inspection of applicant's actions on previous inspection findings; follow-up on violations / deviations: Corrective Action Program (CAP) for pipe and pipe supports, HVAC, and conduit supports; and plant tour Results: Within the areas inspected, no significant strengths or weaknesses were identifie Onc violation (paragraph 4.a) was identified concerning undocumented work activities. One open item (paragraph 4.a) related to improperly installed cotter pins was identifie i

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l DETAILS Persons Contacted

• R. W. Ackley, Jr., Project Manager, Stone & Webster ,

Engineering Corporation (SWEC) '

• P. Baker, Licensing Complianco Manager, TU Electric

• L. Barker, Manager, Engineering Assurance, TU Electric

• J. W. Beck, Vice President, Nuclear Engineering, TU Electric

• L. Bell, Nuclear Licensing, Dallas, TU Electric

• H. D. Brunar, Senior Vice President, TU Electric l *W. J. Cahill, Consultant, TU Electric l *J. T. Conly, APE-Licensing, SWEC l *W. G. Counsil, Executive Vice President, TU Electric l *J. C. Crnich, Project General Manager, Ebasco

• L. Davis, Nuclear Operations, Results Engineer Manager, ,

TU Electric  !

j *G. G. Davis, Nuc1 car Operations Inspection Report Item Coordinator, TU Electric

• E. Deviney, Deputy Director, Quality Assurance (QA), :

TU Electric l * H. Froid, Chief Mechanical / Nuclear Engineer, Bechtel l * P. Garde, Attorney, CASE

• G. Guldemond, Executive Assistant, TU Electric

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

• L. Heatherly, Licensing Compliance Engineer, l TU Electric l " B. Hog, Engineering Manager, Bechtel I *R. T. Jenkins, Manager, Mcchanical Engineering, TU Electric l * J. Kelley, Manager, Plant Operations, TU Electric

• 0. W. Lowe, Director of Engineering, TU Electric

• F. W. Mcdden, Mcchanical Engineering Manager, TU Electric

• M. McAfee, Manager, QA, TU Electric j *J. W. Muffett, Manager of Civil Engineering, TU Electric l * D. Nace, Vice President, Engineering & Construction, TU Electric t

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• F. Ottney, Representative, CASE

• S. Palmer, Project Manager, TU Electric l

• D. Redding, Executive Assistant, TU Electric I I *D. M. Reynorson, Director of Construction, TU Electric

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

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

• E. Scott, Manager, Start-up, TU Electric j

• C. Smith, Plant Operations Staff, TU Electric  ;

' L. Stamm, Project Engineerinc Manager, SWEC )

• R. Steciman, CPR1, TU Electric i

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

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

• G. Tyler, Director of Projects, TU Electric

• D. Walker, Manager of Nuclear Licensing, TU Electric l

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• K. C. Warapius, Project .nirector, Impell

• R. Waters, Licensing Compliance Engineer, TU Electric The NRC inspectors also interviewed other applicant employees during this inspection perio *Denoter personnel present at the October 4, 1988, exit meetin . Applicant's Action on Previous Inspection Findings (92701) (Closed) Open Item (445/8513-0-22): During CPRT witnessed reinspections, ERC identified the following condicions to the NRC inspector as subject to evaluation as potential deviations:

Verification Package I-M-PBOM-62, Flange No. 3 (Drawing l BRP-CH-1-EC-0048) had two studs without the required one l thread past the outer face of the nut.

l The potential deviation was validated on ERC Deviation l Report (DR) I-M-PBOM-62-DR-1. Nonconformance Report i I (NOR) M-23356N was subsequently issued to document the '

deviation and was dispositioned use-as-is.

l The NRC inspector reviewed ASME Procedure AQP 11.2, Revision 3, which specifies inspection requirements for <

pipe flange bolting material. This procedure has been l

l revised to permit the QC acceptance of thread engagement )

l when the end of the stud is flush with the face of the j nu The NRC inspector concurs with disposition of the l

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identified conditio The NRC inspector also noted that another ERC DR l R-M-PBOM-062-DR-1 was evaluated and dispositioned l use-as-is by NCR M-23356 This DR portains to pipe l l flange bolt torquing reqlirements for connection of the l piping system to a chilled water system pump. The NRC l inspector determined through discussions with engineering l l personnel and review of documentation that the bolting is torqued in accordance with applicable requirement This open item is close (Closed) Open Item (445/8516-0-53): During CPRT reinspection of Field Fabricated Tank (FFTA) sample i FFTA-01, ERC identified the following conditions to the !

NRC inspector as r,ubject to evaluation as potential l deviations: (1) a stitch weld was used where a full length weld is required, (2) weld size was indeterminate on lap joints, (3) a 3/8-inch fillet weld was specified '

on 1/4-inch thick material, (4) Bill of Material item 6 to 11 fillet weld had an insufficient weld throat size, l

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l (5) seismic restraint gussets had insufficient weld throat size, and (6) anchor bolt ring chairs had undersize wold The potential deviations were validated on ERC Deviation Report I-M-FFTA-001-DR-1. Nonconformance Report M-23322N was subsequently issued to document the deviations and was dispositioned use-as-i The NRC inspector reviewed the disposition of NCR M-23322N and interviewed SWEC engineering personnel to determine the adequacy of the technical justification for the NCR disposition. As a result of the NRC l inspection, NCR 88-14546 was issued which clarifies and supersedes the technical justification supporting the use-as-is disposition for NCR M-23322N. The technical justification for the conditions listed above is as follows:

(1) Per CB&I design calculations and the related Impell i Environmental Qualification (EQ) validation package, the as-built weld configuraticn is adequate for design loads and no corrective action is require (2) A review of Impell EQ validation package revealed that the welds were not considered for stress analysis or seismic considerationn. Per CB&I records these wolds passed a vacuum box test (VB)

for leaks. No corrective action is require (3) The size requirements of ASME Section III ,

I paragraph ND 3352.4 are met. No corrective action is require !

(4) Per CB&I calculations and the related Impell EQ validation package nc decign credit has been taken for the undersize portion of the wold. Therefore, ;

l the small decrease in weld size is acceptable.

l (5) CB&I letter dated November 25, 1986, Sisk to Elmer, documents reevaluation of weld size requirements and i acceptability of the as-built wold size. No corrective action is require !

l (6) These welds were reinspected by TU Electric QC l personnel using a contour weld gauge to determine I weld throat thickness and were found to be l acceptable. The contour gauge methodology provided i

a more accurate determination of weld size. These I wolds meet minimum throat thickness requirement No corrective action is required.

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The NRC inspector has reviewed the NCR and documentation supporting the use-as-is disposition. The NRC inspector concludes that the nonconforming conditions have been dispositioned in accordance with applicable requirement This item is close (open) Unresolved Item (445/8820-U-07): This item deals with the effects of seismic self-weight accolorations (side loads) on the rated capacity of sway struts. In response to the concern raised by the NRC inspector, the applicant directed SWEC to perform an evaluation of the sway struts being used on sit In this inspection period, the applicant provided the NRC inspector with the results of SWEC's evaluation. The evaluation consisted of two distinct parts. First, a walkdown was performed to identify worst-caso exampic These examples were then analy cd to insure chat allowable stresses were not exceeded. The analysis I performed, GENX+312, Revision 0, entitled "Side Loading on Sway Struts," was reviewed by the NRC inspector. The

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result of this review showed that for the examples identified, the stress levels are acceptable. Howeve:',

this calculation also shows that at maximum leingth and I maximum load the stress levels are approximately equal to code allowables. This implies that additional moments caused by side loads due to seismic acceleratiors in the unrestrained directions would cause the struts to be overstressed. When this was brought to the attention of the applicant, it was decided that further action was

require Th.3 item will remain unresolved pending NRC 1 review of additional actio . Follow-up on Violations / Deviations (92702) (Closed) Deviation (445/8706-D-03)

With respect to the action ?n prevent recurrence for Violation 445/8516-V-13,

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TV Electric letter TXX-4826 dated June 16, 1986, stated, I

in part, "The nupport addressed was inspected in 7/83 in i the earliest versions of the As-Built inspection progra Due to problems related to undersite welds, B&R Procedure QI-QAP-11.1-28, Revision 24, issued April 24, 1984, was revised to require the QC inspecter to asnign a l weld number to each weld shown on the design drawing and to document both the required size of the weld per design drawing, and the actual deposited weld size . "

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Contrary to the ebove, the NRC inspector found that the Revision 24 of Brown and Root (B&R) Procedure QI-QAP-11.1-28 had not been revised as state It was found that these requirements had existed since at least l

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l Revision 16 dated December 15, 1982, which was before the j violation was writte TU Electric responded to this deviation with the following information:

"The response to Violation 445/8516-V-13 was incorrect 'i due to inadequate research, preparation and review of the response by QA Departmonc personnel prior to its submittal."

TU Electric reviewed tho other responses provided by the QA Department and identified one other item for which a <

revised response was required (see TU Electric I letter TXX-6473 dated May 29, 1987). Concurrently, in April 1987, TU Electric instituted measures within the QA .

Department to assure that responses from the QA i organization to the NRC are clear and accurate. These l measures included additional staffing of the Issue Interface coordinator (IIC) position. The IIC is i independently responsible fo" verifying the content of TU Electric responses which originate in the QA department. Additionally, a QA Department Procedure NQA-4.01, "NRC Issue Interface," has been prepared which '

will formalize controls applicable to the IIC and the review of preparation and responses made by QA personne The NRC inspector han reviewed Procedure NQA-4.01 and the charter of the IIC and feels that these changes will help alleviate the identified prob? an. This deviation is closed, i (closed) Deviation (445/8805-D-01): NCR-87-A00491, which identified a base material reduction on Pipe Support DO-1-067-708-S53R, and a QC hold point which was bypassed i when reworking the base material reduction, was not trended as required by the FSAR to identify any trend !

adverse to quality. TU Electric letter TXX-88300 dated -

March 31, 1988, provides a response to the deviatio The cause of this deviation was failure to maintain i controls to address trending of NCRs internal to B&R during the period from July 11 to october 5, 198 Corrective action consisted of identifying all B&R NCRs which were not trended and assigning a trend code where appliceble. The trend codes were totaled and then added to the appropriate trend reports. The NRC inspector reviewed the applicant's corrective action and concurs that no adverse trends were identified. Therefore, no additional corrective action is required. To avoid

! further deviations, QA will perform periodic reconciliation of trend data with the source of the data

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g (e.g., NCRs roccived for trending versus the NCR log of issued NCR numborr) to identify potential trend input data problems. This item is close (closed) Violation (445/8434-V-01): During an NRC special review team (SRT) inspection conducted between April 3, 1984, and April 13, 1984, the NRC inspector determined that sway strut CC-1-295-005-C53R and mechanical snubber MS-1-151-025-C52K exceeded the five degrees maximum offset angle tolerance specified la Procedures QI-QAP-11.1-28 and QI-QAP-11.1-28 These two '

supports had previously been inspected by QC inspectors, but these nonconformances had not been identifie The applicant performed the following corrective actions and actions to preclude recurrence. Nonconformance Reports (NCR) M-13,439 and M-13,384 were generated to document these deficiencies. The supports were reworked per the approved disposition and the latest design document, and QC inspected and accepted the rewor Quality Instruction QI-QAP-11.1-28A was deleted, and Revision 24 of QI-QAP-11.1-28 was issued on April 24, 1984, to address more clearly sway strut and snubber installation. B&R QA personnel received training on QI-QAP-11.1-28, Revision 24, paragraph 3.3.1.1.c. All of the above actions were completed by April 30, 1984.

l NRC letter to Texas Utilities dated October 16, 1985, i stated, in part, "The generic aspects of the findings were not adequately addressed in your response to our Notice of Violation as required by 10 CPR 2.201; however,

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we understand that the generic aspects of sway strut and I

snubber installation will be addressed by the comanche Peak Response Team (CPRT) Program Plan . . . .

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The NRC inspector has reviewed the applicant's response l to the NOV, the dispositioned NCRs, revision of Quality  !

Instructions, and QC training records and concurs that l those actions are adequate to resolve the specific cases  !

identifie !

CPRT performed reinspections of statistically sampled pipe support installations to determine compliance with design and QC inspection requirements. CPRT evaluation of reinspection results determined that a walkdown of l Vendor supplied components should be performed to verify that angularity meets design requirements. NRC inspection of the Post-Construction Hardware Validation i Program (PCHVP) determined that PCHVP procedures require l

I a 100% reinspection of safety-related pipe supports to determine compliance with angularity requirements. This item is close I '

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. , (closed) Violation (445/8731-V-02; 446/8723-V-01): Two NCRs (I-85-101890SX and C-86-200378X) were identified that were dispositioned use-as-is after engineering became aware that the conditions causing the NCRs had been corrected without the benefit of an NCR dispositio Work had been performed withcut benefit of paper. This action precluded actions being taken which would determine cause and prevent repetition of sav DRs C-88-00041 and P-88-00054 were initiated by the applicant to document the items identified as being outside the scope and control of the two identified NCR Additionally, DR C-88-00040 was initiated to address the l personnel responsible for disposi*ioning the NCRs l use-as-is contrary to the requirements of project Procedure NEO-3.06. Engineering and quality engineering personnel responsible for NCR dispositions have been reinstructed in the requirements of NEO-3.06.

l The NRC inspector has reviewed the DRs (C-88-00041, P-88-00054, and C-88-00040) and the training records that are part of the latter DR and concludes that the requirements of NEO-3.06 will be more readily understood and that this is an isolated instance. This violation is close (closed) Violation (EA 86-09, Item I.C.2): Cable tray supports were found by NRC inspectors to contain undocumented plug welds. It was not possible to determine if the plug weld repairs were acceptabic because quality control inspections were not performed to ensure that the welds were performed in accordance with j the applicable codes and procedure TU Electric admitted the violation and provided the following response. The examples identified by the NRC are instances of failure to properly document the

! requirements of the governing procedures for the l

performance of repairs of misdrilled holes on the part of construction personnel, and the resulting lack of documentation of inspection of such repairs on the part of QC, Construction used a construction operation traveler to document repair activities. The issue of repair of misdrilled noles (commonly referred to as "plug i welds") was not speciticslly addressed as a unique ite )

QC would document "plug wcld" inspection using a "QC '

Accept" sticker rather than an IR. Upon completion of '

the system and final QC inspection, the stickers were i removed so too components could be painted. As a result, l no documentation specifically traceable to repair of I misdrilled holes remained. Acceptence of all welding on l

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a given suppcrt was indicated by a singic QC signature on the travele In order to provide corrective action, procedures which control the construction operation traveler were revised in November 1980 to specifically identify "plug welds" as a QC hold point, thereby providing documentation traceability to the repair of misdrilled hole Deficiencies identified during NRC inspections resulted in NCRs which were resolved by performing acid etches of the areas in question (under QC witness) to find the extent, if any, of wold material, and'by QC performing a j visual inspection for acceptance. To address potential !

generic implications and inspection procedure adequacy, >

repair of misdrilled holes and program adequacy is '

add *cssed by ISAP e The inspections performed under IdAP V.d determined that '

the repair of misdrilled holes was authorized for cable tray supports. Based on the results of the inspections, :

procedure reviews, and bounding evaluations performed !

under this action plan, CPRT concluded that there is reasonable assur.nce that undocumented plug welds not '

reinspected under this action plan will not compromise e the structural integrity of the component ,

The NRC inspector has reviewed the ISAP V.d Results Report and concludes that the current procedures and I practices for the repair of misdrilled holes, including i their inspection and documentation are adequate and l should preclude the recurrence of undocumented plug wc3d This violation is close (Closed) Violation (EA-80-09, Appendix B, Item II): The ;

NRC inspector determined that the Welders had failed to i follow any fit-up criteria for prequalified weld groove j angles on several identified cable tray hanger (CTH) i cigps. The angle identified by the NRC inspector was !

30g ; the gngl 5equired by the weld procedure was .

45 , + 10 , - 5 .

j In response to the violation, NCR M-85-101967 was initiated by the applicant on December 4, 1985, to !

resolve the specific bevel angle deficiencies identified by the NRC involving CTH-1-5517 and CTH-1-553 i MCR M-85-101967 directs the welding engineero to perform i procedure qualification testing using the 30 beve l This testing was accomplished and accepted on l December 27, 1985, and the results are included with !

Welding Procedare Qualification Record CP-AWBB15 i

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on December 27, 1985, and in accordance with AWS Dl.1, QC l procedure QI-QP-11.10-9, "Cable Tray Hangers As-Built Inspection / Verification," was revised to incluge a begel groove angic verification criteria of 45o + 10 , 2 0 ,

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l which encompasses the criteria set forth in the new I qualified welding procedur The NRC inspector has reviewed CP-AWBB153 (the weld

! procedure qualification record) and QI-Qp-11.10-9 I

and concludes that they more accurately reflect the conditions identified in the fial This violation is close . Corrective Action Program (CAP)

( Piping and Pire Supports (50090)

The NRC inspector performed a field tour of Room 198 and Room 204 to evaluate installation, protection, and preventative maintenance after installation of safety-related pipe supports, piping, and pumps to determine that work is being performed in accordance with applicable procedures, codes, and appli: ant's commitment ,

During evaluation of components located in Room 198, the NRC inspector noted that the base plate for pipe support CC-1-045-005-A43R fits around the piping and includes a groove wold in the middle of the plate (i.e.,

the plate was cut in half and groove welded back together). The flate is distorted due to welding and does not have acceptable bearing against the concreto surface as required by installation procedures. NRC review of inspection requirements determined that no quantitativo criteria for evaluation of welding distortion is provided by the applicable QC procedur However, this support was tagged for grouting of the base plate which will resolve the NRC inspectors observation

, and concern about welding distortion and pisto bearing I

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requirement In addition to the fic3d inspection, a detailed review of the pipe support installation documentation was performed. This review resulted in

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several questions :oncerning adequacy of the l documentation, all of which were resolved by applicant personnel in a timely and knowledgeable manne The NRC inspector did not identify any other conditions potentially adverse to quality in Room 19 ,

During evaluation of components in Room 204, the NRC inspector identified that the ears of a cotter pin which prevent the dislocation of a load pin on pipe support l CC-1-016-700-A43R were not spread as required by '

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installation and incocction procedures. Dislocation of the load pin would prevent the pipe support from performing its required design function. This support had been kardware validated under the PCHVP program. NRC inspection and TU Electric surveillance inspection data confirm that effective control over the removal reinstallation and replacement of cotter nins on pipe supports which have been final accepted ut. der the hardware validation program has not been achieved and could inpact safe operatio. of the plant. The NRC inspector discussed - finding with applicant personnel and was informed som/ area walkdown inspections will provide assu'cancs ; otter pins are correctly installed. The pros aure for room / area walkdoun inspections has not been issued. This is an open item pendir.g issuance and implementation of the proceduro (445/8865-0-01).

Further evaluation of components in Room 204 revealed additional examples cf less than adequate control of work being performed on safety-related items for which final QC inspection was complete. The pip'ag system in Room 204 is under the control of Operaticns/ Start-u NRC inspection identified tbst undocumented work had been performed on a safety-related ASCO solenoid operated valve (SOV) which controls airflow to the air operated diaphragr of component cooling water (CCW) valve 1-FV-4536. This condition was evidu cod by air supply tubing wall fretting damage resulting from the undocumented removal of mounting screws for the SOV. The SOV had been inspected per pCHVP requirements on August 1, 1988, and accepte Further, the handwheel on vscae 1-FV-4536 was not properly installed and a capscrew

<?, missing from the cover of electrical junction cox JBlAll770 which supplies power to the SO Site personnel could not provide documentation for these conditions. The failure to ensure that work activities affecting quality are controlled in accordance with applicabic procedures is a violation of Criterion V (445/8865-V-02).

Luring this report period the applicant evaluated an allege. tion that an acute partial penetration weld that joins Item 2 to Item 9 on pipe support H-MS-1-SB-05?-002-2 may have had foreign material introduced into the fit-up gap that was not consumed by the welding process. NCR 88-13972 3acuments the evaluation process. The applicable portion of the pipe support was removed and sectioned for evaluation. The NRC inspector inspected the sectioned pieces and concurs that the weld joint was not sl..gged. However, an excessive fit up gap was identified. The fit-up gap l

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violates parameters of the welding procedure specification (WPS). During a previous NRC inspection, two pipe support welds which did contain unconsumed filler material (slugged welds) were identified to the-NRC by the applican All three_ examples of deviation from WPS requirements are documented on CAR 88-028 and'

are being tracked as previous unresolved item 445/8856-U-05; 446/8852-U-03).

b. Heating, Ventilation, and Air-Conditioning-(HVAC) (50100)

The 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 CAP implemeatation:

Seismic Duct Hengers Unit Room DH-1-844-1K-1W 1 99A DH-1-844-1K-1M 1 99A DH-1-844-1K-1T 1 99A DH-1-844-1K-1AF 1 99A No violations or deviations were identifie c. Conduit Supports Train A and B and Train C > 2" (48053)

During this inspection period, the NRC inspector selected a sample of seven conduit suppert modifications to verify the accuracy and correctness oL the final QC inspection dat The following is a list.of the NdC inspected supports and the corresponding DC l

" Support DCA l C13008620-08

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39135, Revision 2 C12006169-05 47241, Revision 2 .

C12G00314-04 41772, Revision 2 l C12006169-03 39164, Revision 1 l C12006169-04 47240, Revision 1 C13G11066-10 41717, Revision 1 C16B09465-03 41720, Revision 1 The NRC inspector's review of these supports was

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performed in accordance with the requirements of the 4 applicable section of Specification 2323-SS-16B and the DC The results of this inspection revealed the recorded dat a was within the tolerances of the l specificativa.

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No violations or deviations were identified, j

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14 Plant Tours (92700)

The NRC inspectors made frequent tours of Unit 1, Unit 2, and common areas of the facility to observe items such as housekeeping, equipment protection, and in-process work activities. No violations or deviations were identified and no items of significance were observe . Open Items Open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or applicant or both. One open item disclosed during the inspection is discussed in paragraph . Exit Meeting (30703)

An exit meeting was conducted October 4, 1988, with the applicant's representatives identified in paragraph 1 of this repor No written material was provided to the applicant by the inspectors during this reporting period. The applicant 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 scope and findings of the inspectio l l

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