ML20195F910

Insp Repts 50-445/88-71 & 50-446/88-67 on 881005-1101. Violations Noted.Major Areas Inspected:Applicant Actions on Previous Insp Findings,Followup on Violations/Deviations & General Plant Area Tours

ML20195F910
Person / Time
Site:	Comanche Peak
Issue date:	11/18/1988
From:	Livermore H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20195F904	List: ML20195F900 ML20195F905 ML20195F910
References
50-445-88-71, 50-446-88-67, NUDOCS 8811220409
Download: ML20195F910 (18)

See also: IR 05000445/1988071

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7PPENDIX E

U. S. NUCLEAR REGULATORY COMMISSION

OFFICE OF SPECIAL PROJECTS

NRC Inspection Report: 50-445/88-71 Permits: CPPR- 126

50-446/88-67 CPPR-127

Dockets: 50-445 Category: A2

50-446

Construction Permit

Expiration Dates:

Unit 1: Extension request

submitted.

Unit 2: Extension request

submitted.

Applicant: TU Electric

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EXyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas 75201

Facility Name: Comanche Peak Steam Electric Station (CPSES),

Units 1 & 2

Inspection At: Comancho Peak Sito, Glen Rose, Texas

Inspection conducted: October 5 through November 1, 1988

Inspection conducted by NRC cor.sultants:

J. Dalo - EG&G (paragraphs 2.a and 3.a)

K. Graham - Paramotor (paragraph 5.c)

P. Stanish - Paramotor (paragraph 2.b - 2.d, 3.b,

4.a - 4.0, 5.a, and 5.b)

Reviewed by: R F ld M L fw N-a-M

H. H. Livormore, Lead Senior Inspector Dato

8311220409 881118

PDH ADOCK 05000445

O PDC

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Inspection Summary:

Inspection Conducted: October 5 through November 1, 1988 (Repgrt

50-445/88-71; 50-446/88-67)

Areas Inspected: Unanncanced, resident safety inspection of

applicant actions on previous inspection findings, follow-up on

violations / deviations, action on 10 CFR 50.55(c) deficiencies,

Corrective Action Program for Conduit Supports Trains A & B and

Train C > 2", piping and pipe supports, and general plant areas

(tours).

Results: Within the areas inspected, the NRC inspector identified

a strength in the manner in which modification to conduit supports

for Train A & D and Train C > 2" are being installed and inspected.

This is based on the number of modifications inspected by the NRC

inspector versus the small number of inspection errors detected

(paragraph 5.a). In the PCHVP, weaknesses were identified in the

area of applying appropriate controls for the evaluation of

inaccessible / unverifiable final acceptance attributes, processing

of nonconformance reports (NCRs) related to the implementation of

the PCHVP, and corrective actions for previous NRC inspection

findings (paragraph 5.c). Additional significant weaknesses were

identified in the Corrective Action Program for piping and pipe

supports in the areas of corrective action to audit findings and

NRC issues related to errors in design calculations, performance

and review of design calculations as well as procedural and

training weaknesses (paragraph 5.i). Three violations (paragraphs

5.b and 5.c) were identified documenting: (1) failure to provide

documented instructions for performing technical dispositions for

inaccessible inspection attributes exempted from inspection by

DCA 58252, (2) failure to properly inspect thread engagement in a

spring hanger, and (3) failure to properly review a design for

suitability of application. One unresolved item (paragraph 5.b)

related to SWEC design calculations for piping and pipe supports

was identified.

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DETAILS

1. Persons Contacted

• R. W. Ackley, Jr., Director, CECO

• R. P. Baker, Licensing Compliance Manager, TU Electric

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

• D. P. Barry, Manager, ESG, Stone and Wcbster Engineering

Corporation (SWEC)

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

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

• H. D. Bruner, Senior Vice President, TU Electric

• W. J. Cahill, Consultant, TU Electric

• J. T. Conly, APE-Licensing, SWEC

• G. G. Davis, Nuclear Operations Inspection Report Item

Coordinator, TU Electric

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

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

TU Electric

• G. L. Edgar, Attorney, Newman and Holtzinger

• G. E. Grabruck, QA, Impell . .

• W. G. Guldemond, Executive Assistant, TU Electric

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

• T. L. Heatherly, Licensing Compliance Engineer,

TU Electric

• C. B. Hogg, Engineering Manager, Bechtel

• R. T. Jenkins, Manager, Mechanical Engineering, TU Electric

• J. J. Ke.11ey, Manager, Plant Operations, TU Electric

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

• F. W. Madden, Mechanical Engineering Manager, TU Electric

• G. M. McGrath, TS/SP Manager, Startup, TU Electric

• J. C. Miller, Site Mana_Jr, TENERA

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

• L. D. Nace, Vice President, Engineering & Construction,

TU Electric

• E. F. Ottney, Representative, CASE

• S. S. Palmer, Project Manager, TU Electric

• J. D. Redding, Executive Assistant, TU Electric

"D. M. Reynorson, Director of Construction, TU Electric

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

TU Electric

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

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

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

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

• T. G. Tyler, Director of Projects, TU Electric

• J. R. Waters, Licensing Compliance Engineer, TU Electric

The NRC inspector also interviewed other applicant employees

during this inspection period.

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• Denotes personnel present at the November 1, 1988, exit

meeting.

2. Applicant Action on Previous Inspection Findings (92701)

a. (Closed) Open Items (445/8513-0-10): During a Comanche

Peak Response Team (CPRT) reinspection, the Evaluation

Research Corporation (ERC) inspector identified the

following to the NRC inspector as subject to evaluation

as potential deviations: (1) pipe clamp parallelism,

(2) spherical bearing gap, and (3) no locking devices on

pipe clamps.

The NRC inspector verified that all of the potential

deviations were documented on ERC deviation reports (DRs)

and subsequently by TU Electric on NCR M-86-23228N. The

NCR was dispositioned "Repair / Rework" for the spherical

bearing gap and no locking devices on pipe clamps and

"other" for pipe clamp parallclism. A safety

significance evaluation and calculation were provided for

the pipe clamp parallelism; these two documents conclude

that pipe clamp parallelism is acceptable as-is for this

installation.

The NRC inspector has reviewed the closed NCR and

supporting documentation and concurs that TU Electric has

properly dispositioned the NCR in accordance with

applicable requirements. This item is closed.

b. (closed) Unresolved Item (445/8607-U-27): CPRT

identified a potential for switching non-ASME and ASME

Code class valve bonnets and concluded that there was "no

implication that switching of non-ASME and ASME valve

bonnets could be safety significant." The NRC reised

questions as to how the results report considered the

differences between non-ASME and ASME Codo requirements

with respect to material identification and traceability,

welding and weld repairs, nondestructive examinations,

and personnel qualifications.

As stated in NRC Inspcction Report 50-445/88-32;

50-446/88-28, documentation provided by the vendor dated

April 8, 1988, does not support the conclusions presented

in the results report. In this inspection period, CPRT

provided errata to the ISAP VII.b.2 Results Report which

definos diffcrences between the valve bonnets and

manufacturing process and modified the Results Report

conclusion to "tharo is not a significantly greater

likelihood that a safety significant defect would remain

undetected . . . " and ". . . it is very unlikely that

interchanging a non-ASME bonr.ct with an ASME bonnot on an

ITT-Grinnell diaphragm valve would be safety-significant."

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The NRC inspector agrees that this conclusion is more in

line with the documentation. This item is closed.

c. (Closed) Unresolved Item (445/6656-U-03; 446/8852-U-02):

This item dealt with an inspection method for hand tight

bolts that could not ensure that bolts that were

overtightened would be detected. During this inspection

' period, the NRC inspector and SWEC civil / structural

personnel witnessed an inspection of two monorails which

had a requirement for the bolts on one end of each

monorail, where it attaches to the building structure, to

be handtight. The results of these inspections revealed  ;

that several of these bolts were overtightened, which i

substantiated the concern. Subsequent to these  ;

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inspections, review of the records for the PCHVP

inspection effort performed-in accordance with FVM-090,

determined that this condition had been identified by the

inspector and documented on NCR-88-09973 and

NCR-88-10306. Therefore, the results of the PCHVP

. inspections confirm that these inspections are adequate

to resclve this ccncern. This item is closed.

d. (Open) Unresolved Item (445/8856-U-05; 446/8852-U-03):

This item documented three examples of deviations from

the requirements of the applicable wold procedure

specification (WPS). Two examples had unconsumed filler

material, and one had an excessively large fit-up gap. ,

The applicant has initiated an evaluation of the extent '

of this condition and its safety significance under

Corrective Action Request (CAR)88-028. In this

inspection period, SWEC presented its proposed sampling

plan to be utilized as part of the correctivo action for  ;

this CAR. '

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I The SWEC plan calls for a random sample of welded joints l

to be inspected. The weld joints will be inspected for  ;

unconsumed filler material and compliance with fit-up

. requirements of the WPS. Deficiencies will ha documented

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and evaluated in accordance with NEO 3.05.

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?.'o date,19 wold joints have been inspected by QC, SWEC,

and the NRC inspector. In this sample, there were no

further examples of the use of unconsumed filler metal to

l compensate for poor fit-up; however, there were two

additional examples of deviations from the fit-up

requirements of the WPS. These deviations were

documented on NCRs 88-16728 and 88-16729. This item will

remain open pending completion of the SWEC review and

closure of the CAR.

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

a. (Closed) Deviation (445/8601-D-13): QI-058 requires the

ERC inspector to verify that the lockwire on snubbers is t

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not damaged. The NRC inspector identified that although

the lockwire was broken, the inspection checklist item -

for this attribute was accepted.

The NRC inspector verified that this deviation was

documented on out-of-scope observation number 289 which

was' subsequently transferred to NCR M-86-23447H and

dispositioned to replace the broken lockwire. Further,

the requirements of QI-037 and QI-058 have been revised

to include a more comprehensive inspection' checklist and  :

instructions for the inspection and signoff of lockwires.

A further supplementary reinspection was performed on the  !

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pS 7N and PS 42 populations (47 supports) to verify that

other lockwires had not been damaged. The NRC inspector

has reviewed the closed NCR, tha revisions to QI-037 and

QI-058, and the reinspected supports and concludes that

the NCR was dispositioned correctly and that the

revisions to the procedures provide a clearer

understanding of the inspection requirements. This item

is closed.

b. (Closed) Violation (EA 86-09 Appendix A Item I.B.5): The

Technical Review Team (TRT) found that the design

analysis for non-Category I equipment offects on seismic

Category I structures, equipment, or components was

incomplete. The support installation for

nonsafety-related conduits less than or equal to 2 inches ,

was inconsistent with seismic requirements and no  !

evidence could be found that substantiated the adequacy <

of the installation for nonsafety-related conduit of any i

size.

The applicant denied this violation as written, because l

they stated that there is documented evidence that  !

nonsafety conduits larger than two inches in diameter had

been properly analyzed and adequately supported and

restrained where necessary. For conduit less than or

equal to two inches in diameter, they admitted the ,

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violation.

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During this report period, the NRC inspector reviewed i

Calculations SCS-1740, Set 1, Revision 4; and SCS-226C, l

Set 1, Revision 2, performed by Gibbs & Hill (G&H).

These calculations providu documentation for Train C ,

conduit supports and allowable spans between supports for

2-1/2 inches diameter and larger conduit. Thorofore, the i

NRC inspector concurs that there is evidence that these

conduits had been analyzed and scismically supported. t

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However, since these conduits have been included as part

of the corrective action program and are being

reinspected and reverified, adequacy of these G&H

calculations was not reviewed.

In response to this issue, as it applies to Train C

conduit less than or equal to 2 inches in diameter, CPRT

performed an independent, third-party review of the

adequacy of the installation of these conduits to assure

compliance to regulatory requirements'and FSAR

commitments. Because the initial reviews performed as a

part of the response to this issue exhibited an

unacceptably high failure rate, the applicant elected to

resolve the concern by performing a 100% seismic

qualification program as part of the Corrective Action

Program (CAP). The NRC staff has performed multiple

inspections of both the methodology and the

implementation of this phase of the CAP and concur that

this program brings the installed Train C conduit less

than or equal to 2-inches in diameter into compliance

with the FSAR commitments and regulatory requirements.

To ensure that future installations meet the applicable

requirements, the applicant issued Construction

Procedure ECP-19B to provide the criteria and

documentation requirements for the fabrication and

installation of supports in Category 1 buildings for

Train C two inch and under conduit systems. Thc NRC

inspector reviewed this procedure and concurs that this

procedure provides adequate instruction to ensure that

all applicable requirements are satisfied.

Further, the CAP program for Train C conduit less than or

equal to 2 inches in diameter consists of a multilevel

screening program based on the existence of

safety-related targets and other structures that may have

been assumed to protect safety-related targets from

adverse interactions with Train C conduits. Therefore,

the program provides for reviews of now installations of

safety-related plant features as potential targets for

Train C conduit which may fail during an SSE event. It

also provides for reviews of the removal or modification

of existing structural features that may have been used

as a barrier to protect safety-related features from a

potential Train C conduit failure. These reviews will be

continued as needed after construction completion by

Comanche Peak Engineering (CPE). The method for

performing these reviews is documented in Impell Project

Instruction (PI)-0210-053-013, Revision 1. The NRC

inspector reviewed this procedure and finds that it

adequately addresses all the regulatory requirements and

FSAR commitments. This violation is closed.

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4. Action on 10 CFR Part 50.55(e) Deficiencies Identified by the

Applicant (92700)

a. (Closed) Construction Deficiency SDAR-CP-86-80: This

item dealt with the fact that the manufacturers

recommended torque values for certain tubing supports had

not been incorporated into the applicable installation

procedures. This item was initially determined to be

nonreportable, because the applicant felt that the

manufacturer's recommended torque values were met and in

most cases exceeded. However, stress in the clamp due to

overtorquing was not addressed. During requalification

efforts in 1987, this deficiency was evaluated and

determined to be reportable and the NRC was notified in

the applicant's letter TXX-88140 dated January 29, 1988,

and further actions will be reported under SDAR-CP-88-21.

SDAR-CP-86-80 is considered closed. Actions will be

tracked under SDAR-CP-88-21 which is open.

b. (ClcJed) Construction Deficiency SDAR-CP-85-36: The NRC

TRT axamined the installation of nonsafety-related

conduit supports in selected Category I areas of the

plant. According to Regulatory Guide 1.29 and the CPSES

FSAR Section 3.78.2.8, seismic Category II and nonscismic

items should be designed in such a way that their failure

would not adversely affect the function of safoty-related

components or cause injury to plant personnel. No

evidence could be found that substantiated the adequacy

of the installation for nonsafety-related conduit.

On September 6, 1985, the NRC was notified that

TU Electric had determined that there was an

indotorminacy of their compliance with the Regulatory

Guide with respect to the installation of

nonsafety-related conduit, 2-inch diameter and smaller

and would be evaluated under CPRT Program Plan Item I.c.

On November 5, 1987, TU Electric determined that this

item was reportable under the provisions of

10 CFR 50.55(o). As corrective action, the applicant

instituted the Train C Correctivo Action Program (CAP)

for Unit 1 and Common Arcas. In previous inspection

reports, the NRC inspection staff, as well as

Headquarters personnel, have documented review of the

CPRT Issue Specific Action Plan I.c, reviewed the

procedures for physically validating the conduit under

the PCHVP, and performed extensive independent

inspections of the overall CAP for this commodity. Based

on the above, the NRC inspector concurs that the initial

concern has boon adequately addressed.

To prevent recurrence of this deficiency, Cesign Basis

Document (DBD) DBD-CS-093 titled "Seismic Adequacy of

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Train.'C' Conduits (Two Inch Diameter and Less)" was

issued to provido an adequate design basis. Also,

Construction Procedure ECP-19B was issued to provide

guidance'for future inctallation of Train 'C' conduit

supports. -The NRC inspector has. reviewed these documents

and concurs that they provide adequate guidelines to

prevent a recurrence of the stated problem. Further,

PI-0210-053-013 has been written to document the method

to maintain compliance from initial walkdown onward; the

NRC inspector concurs that this procedure is

comprehensive and will aid in assuring compliance to the

i Regulatory Guide and FSAR commitments.

This deficiency is closed.

c. (Open) Construction Deficiency SDAR-CP-85-51: This item

concerned the application of low sulphur content A-588

I steel in pipe whip restraints. NCR.M85-20ll25 was

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written to document that matorial was installed that did

not comply with design requirements. Specifically, note

No. 4 on drawing 2323-S2-0581-01 states, in part, "The

material shall be A588 Gr. A or Gr. B and the sulfur

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content shall be limited to 0.010% . . . . This

condition precipitated Stop Work Order (SWO) 85-03 which

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documented a material control problem. Actions taken in

response to the SWO dealt with the specific material

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referenced and did not address any review of

documentation to determine if thoro are any generic

implications associated with this, or any other loss of

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material segregation. Therefore, this item will remain

open pending response to this concern,

i d. (closed) Construction Deficiency SDAR-CP-85-15: This

item involved the equipment hatch on the inside of the

! Unit 1 Reactor building. The concern was that the

I-beams that act as guidos for the equipment hatch and

the guides that rest on the I-beams could transmit forces

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from the hatch to the internal building structure during

a scismic event. G&H performed an analysis, which was

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reviewed by the NRC inspector, which shows that tho

l forces that could be generated are very low and as such

do not constituto a safety concern. This SDAR is closed.

c. (Closed) Construction Deficiency SDAR-CP-87-87:

Westinghouse's ovaluation of the location of relief

valves and piping configuration disclosed a possible

problem where the design pressure of a chemical and

! volumo control system lino could be exceeded because of

the location cf a relief valvo. This section of pipino

has boon analyzed for offsito radiological doso effects

under the High Enorgy Line Break (HELB) - outside

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containment analysis program. The results of the HELB

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analysis indicate the release.of radioactivity would be'

well within the design basis. However, the valve in

question is scheduled to be relocated to comply with ASME

B&PV Code requirements. This SDAR is closed.

5. Corrective Action Program (CAP)

a. Conduit Supports Train A and B and Train C Greater Than_2

Inches FVM-033 (48053)

During this inspection period, the NRC inspector selected

a sample of six conduit support modifications to verify

the accuracy and correctness of the final QC inspection

data. The following is a list of the NRC inspected

supports and the corresponding DCA.

Support DCA

C12012285-06 39137 Revision 2

'C13G12831-02 41012 Revision 1

CO2018343-07 33063 Revision 2

CO2018213-20 41775 Revision 1

C13C10414-03 25919 Revision 2

C13G16456-07 25798 Revision 2

The NRC inspection of those supports was performed in

accordance with the requirements of the applicable

section of Specification 2323-SS-16B and the DCA. The

results of this inspection revealed that the recorded

data were within the tolerances of the specification.

No violations or deviations were identified.

Based on the NRC inspector's review of this activity, it

is apparent that both craft and QC personnel are

cognizant of the requirements of the applicable

proceduros and specifications and are performing their

work in a manner which is producing a quality product,

b. Piping and Pipe Supports (50090)

During this inspection period, the NRC inspector reviewed

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SWEC Calculation GENX-315, Revision 0, and Calculation

Chango Notice No. 1 to this revision of this calculation.

This calculation was initiated in response to the

excessive water corrosion found in areas of the Station

Sorvice Water System caused by failure of the internal

! plasite coating. The corrosion caused localized pipe

l wall thinning in various areas of this system. The

purpose of this calculation was to dotermino the minimum

pipe wall thickr. css required to satisfy the ASME Code

dasign requirements and the system functional capability

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requirements outlined in CPPP-7, Revision-4. Later, this

calculation method was utilized to justify that damage

caused tcr the piping during the coating removal process r

need not be repaired prior to operation.

Review of this calculation found that the method of

analysis was lcgically arrived at and meets code'

requirements. However, there were many inconsistencies

found in the results of the analysis. These i

inconsistencies, most of which resulted from the preparer

not adt.ering to the procedure outlined in the method of

analysis, resulted in the tabulation of minimum required

pipe wall thickness having many nonconservative results.

Calculation Change No. 1 was-prepared to perform a

similar analysis for the 10-inch portion of the Station i

Service Water due to the damage caused in the coating

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removal process. NRC review of this change'to GENX-315

revealed that for this esiculation effort, the preparer

failed to follow the established procedure in overy

i. instance reviewed, resulting in nonconservative results.

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Calculation GENX-315 and the change notice were prepared

by the same person; however, the reviews were performed

by three different individuals all of whom failed to

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detect the errors. Further examples of this type of

design. review concern were cited in NRC Inspection Report

50-445/88-11; 50-446/88-09. The NRC inspector reviewed

five design calculations which all contained errors that

had not been detected in the review process; this

indicates that there is a potentially significant flaw in

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SWEC's design review process.

l Further, the NRC inspector reviewed audits performed by

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the applicant's Technical Audit Program tTAP) on the

design efforts at various SWEC locations including the

site. The audits reviewed were ATP-87-03 performed at i

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the New York office, ATP-87-09 performed at the Cherry

Hill offico, ATP-87-14 performed at CPSES, and ATP-87-56 -

performed at the Houston offico. In all of those audits,

similar errors were detected. Recommendations made by  ;

the auditors in several instances stato that there is a  :

need for improvement of the review process.  :

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niso, reviewed were soveral of the action items from the ,

! EFE audits. Many of the concerns documented in the '

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action items identify the checkor (reviewer) or the

review process as the focal point of the concern. The

typical SWEC response to this type of audit finding was

that the preparer was advised of the error that had been '

i mado, additional calculatio;.s performed by the preparer

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wore reviewed (in some instancos the reviewer's work was r

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also reviewed - but this appears to be the exception

rather than the rule) and no safety significance was

found. Also, that the concern in question would be

addressed in the final reconciliation phase of the piping

and pipe support effort. The TAP group accepted this

type of response stating that they would confirm the

effectiveness of the proposed action during the

reconciliation effort. However, the EFE group accepted

this type of responso and closed out the items. This

represents a weakness in the EFE audit program.

The audits reviewed by the NRC inspector were performed

in early to mid-1987 and additional concerns by the NRC

were documented in a February inspection report and the

latest example was taken from a calculation performed in

August 1988. The fact that the same types of errors keep

recurring indicates that SWEC's corrective actions are

not offectivo, and do little to indicate that their

efforts in the final reconciliation will be any better.

Also, reviewed by the NRC inspector in this inspection

period was SWEC'a Engineering Assurance

Procedure EAP 5.3, Revision 3, entitled "Preparation and

Control of Manual and Computerized Calculations (Nuclear

Projects)." This procedure establishes the requirements

for the preparation, review, and control of all manual

and computerized engineering and design calculations.

The requirements of this procedure for reviewing

calculation results list several options, one of which

allows the reviewer to "cyoball" the results to determine

if they are "appropriate to the objective . . . ." This

type of requirement, when viewed in light of the number

of errors found in the sample reviewed, is obviously not

producing a quality product. Further, this procedure

does not require the reviewer to indicate the type of

review performed; therefore, there is no auditable trail

to the method of review utilized. A proceduro such as

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this, which endorses cursory design reviews, sends a

message that the review process is a relatively ,

unimportant task, and dees little to emphasize the need

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for quality.

Many of the errors that have gono undetected stem from

che preparors failure to follow the applicable

procedures, which for the most part appear to be complete

- though they may not be presented in the most usable

format. This indicates a potential flaw in the training

program and procedures.

On October 28, 1988, a meeting was held between

representativos of the NRC, TU Electric, and SWEC to

discuss the above concerns. After the concerns were

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detailed by the NRC, SWEC presented an overview of their

design and design review process. It was their opinion

that while they strive for perfection as an ideal, that

they recognize that it is not readily achievable;

however, they feel that, even though errors and omissions

are made and are not detected in the review process, the

final product they are delivering is a quality product.

Their position is based on the fact that when errors in

their calculations have been found, they have been able

to perform the corrected, or alternate, calculations and

not exceed the allowable capacity of the support assembly

in question. However, in many cases the percentage of

allownble stress increases and this could present a

future concern to the applicant. If this condition were

to go undetected and future piping analyses caused design

loads to increase, the applicant may not be able to

assume that the stress levels presented in SWEC

calculations are accurate and would be required to

reverify the entire calculation for each affected

support.

The NRC concerns discussed above were also discussed at

the inspection exit meeting on November 1, 1988.

Pending receipt of additional information from the

applicant and the results of further NRC reviews, this

will be an unresolved item (445/8871-U-01).

During a plant tour, the NRC inspector observed that a

spring hanger SI-1-336-001-522S, located in room 66, did

not have a sight hole in the load coupling; therefore,

thread engagement could not be verified. The NRC

inspector reviewed the documentation package for this

support and found that the inspector who inspected this

support during the PCHVP walkdown indicated that the

thread engagement was satisfactory even though the

inspection report form identifies the need for a sight

hole to verify this attribute. When brought to the

attention of the applicant's personnel, NCR-88-16375 was

written to document this condition along with several

other discrepant items. This failure to properly inspect

th.is support is a violation of Critorion X

(445/8871-V-02).

Also observed by the NRC inspector during a plant tour

was a sway strut on support SW-1-132-039-A43R that had

very little clearance in the clamp / forward paddle

connection. This clearance is provided to accommodate

angular rotation in this connection caused by

piping / equipment movement in the unrestrained directions.

( The sway strut in question was manufactured by NPSI and

is identified as an SRF-08 strut with an SPC-08-100 pipe

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clamp. The NRC inspector measured the distance bnLW4en

,

the ears of the clamp, at the location of the inner

spacer and at the load pin, to be approximately 5/8-inch

and the thickness of the forward paddle to be 1/2-inch.

Based on the obserygd dimensions, this sway strut would

ongy accommodate +3 of angular rotation rather than the

+5 that is assumed by design engineers. Forthgs

support, DCA 47818, Revision 4, states that 3.78 11 s

needed in the direction in question. This means that

because of this condition (internal interference between

component support parts) there will be forces and moments

imposed on the piping and the remainder of the support

assembly that were not evaluated in the original design

calculations. Further, the condition cited meets the

applicable inspection criteria of Brown & Root ASME

Quality Proceduro AQP-ll.3, Revision 4, DCN 2; therefore,

appropriate quantitative acceptance criteria have not

been provided to QC inspectors for this attribute.

Further, since this condition exists to a lesser extent

at nominal dimensions, it also appears that there is

little basis for the tolerances established by the vendor

for the dimensional attributes critical to this design

feature. This condition has potential generic

implications to an approved design widely used on this

project. This failure to properly translate design bases

into procedures and instructiens is a violation of

Criterion III (445/8871-V-03).

Based on the abovo vic1ations and the concerns stated in

the unresolved item, there appears to be significant

programmatic weaknesses in the pipo support engineering

and inspection program.

c. piping Systems and Supports - FVM-081; FVM-090 (50090)

The PCHVP by either physical validations or through an

engineering evaluation methodology, assures that each of

the final acceptance attributos defined in the attribute

matrix is validated. During this report period, NRC

inspection focused on procedures which provido the

guidelinos for performing and documenting tho engineering

ovaluations of piping system final acceptanco attributes

identified by the attribute matrix. Future NRC

inspections of the PCHVP will provide additional

evaluations of these activities.

The NRC inspector interviewed supervisory personnel from

Quality control, Quality Assurance, SWEC, and

TU Electric's licensing personnel to determine

managements involvement in assuring quality. These

personnel wore cognizant of the appl' abic procedures for

controlling specific activitics in their area of

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responsibility. However, as discussed below, NRC

inspection of management's involvement in assuring

quality with respect to engineering evaluations required

by ECE 9.04-05, PCHVP engineering evaluations, determined

that policies were poorly stated and understood in that

procedures do not describe all methods currently being

used to disposition inaccessible attributes. Therefore,

compliance with ECE 9.04-05 is indeterminate.

The purpose of the PCHVP is to domenstrata that existing

systems, structures, and components are in compliance

with the revised installation and design requirements,

which provide a methodology for the resolution of

technical issues from a safety standpoint. PCHVP

commitments are implemented by Field Verification Methods

(FVMs). Procedure ECE 9.04-01 defines an FVM as:

"A procedure prepared to control the activities of field

verification activities to substantiate the design

criteria used for design calculations, design drawings

and specifications and provides the data necessary to

demonstrate compliance with the approved design."

The NRC inspector reviewed FVM-081 and FVM-090 which are

two of the FVMs applicable to piping and pipe support

installations. These FVMs are implemented by specific

engineering and quality centrol procedures which are

identified in the reference section of the FVM.

NRC review of FVM-090 noted that paragraph 7.7,

Revision 5, states, in part:

"If, during the execution of reinspections required by

this FVM, any components are identified by QC as

unverifiable or uninspectable (e.g., due to item not

being installed, subject to in-process work, hidden or

inaccessible) an NCR shall be initiated."

NRC review of Quality Control Procedure AQP 11.5 and

CP-QAP 12.1, which are implementing procedures for

FVM-081 and FVM-090 noted that certain attributes which

were inaccessible or unverifiable by QC were exempt from

inspection requirements although the attribute motrix

identifies "Reinspection required" for the attrib 2tes.

The NRC inspector requested project personnel to provide

the basis for this departure from program commitments and

,

was informed that DCA-58252, which altered the

i installation inspection requirements of 2323-MS-100,

l Revision 9, provided the basis for changes to the QC

i procedures. SWEC engineering personnel stated that

Procedurc ECE 9.04-05 provided a method for evaluating

the attributes exempted from inspection requirements, but

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were unable to provide the NRC inspector evidence of

appropriate procedural control of the described technical

evaluation. Changes to the PCHVP which deleted the

requirement to document inaccessible attributes with an

NCR (i.e. DCA 58252) were approved by SWEC Mechanical

Engineering, SWEC Material Engineering, SWEC Pipe Support

Engineering, SWEC Quality-Assurance, TU Electric Quality

Assurance, TU Electric Quality Control, and other

discipline supervisors. Subsequent to NRC inspection

activities, a SWEC interoffice memorandum dated

October 13, 1988, requested a review to verify the scope

of the exempted attributes and initiation of the required

technical disposition.

NRC review of enforcement history identified a similar

violation (445/8718-V-09) in which the PCHVP program

failed to adequately address the identification of

inaccessible attributes so that an engineering evaluation

would be performed. A QC inspector failed to identify an

inaccessible attribute with an NCR which precluded the

required engineering evaluation. Corrective steps taken

to avoid further violations consisted of procedure

revision to specifically address the initiation of NCRs

for inspection checklist attributes which are

inaccessible. NRC assessment of the applicant's

performance in this area indicates that corrective action

was not completely effective, dealt only with the

identified problem, and was not effective in preventing

recurrence of a similar problem. NRC review of QC PCHVP

inspection results revealed that in many cases an NCR had

been issued by QC to document specific cases where

attributes could not be verified because the piping was

buried or in close proximity of other components which

prevented physical validation of the associated

attributes. NCR 87-02743, nevision 0, is an example of

QC documenting buried piping with an NCR. This NCR was

dispositioned "use-as-is" with the following technical

justification.

"This is no longer a nonconforming condition. DCA 58252

does not require the reported condition (s) to be

reinspected."

The NRC inspector asked SWEC engineering personnel to

provide an explanation of the technical justification

supporting the NCR disposition. Appendix A of the

TU Electric Quality Assurance Manual defines "use-as-is"

as:

"A disposition which may be assigned for a nonconformance

when it can be established that the discrepancy shall

result in no conditions adverse to safety and that the

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item under consideration will continue to meet all

engineering functional requirements. This disposition

requires technical justification by Engineering of the

item's acceptability for use."

SWEC personnel were unable to provide technical

justification for the NCR disposition. Engineering

evaluation of the inaccessible attributes for the buried

piping, per ECE 9.04-04, has not been performed. The

described conditions had been determined not to be safety

significant without a technical basis and the disposition

was reviewed by the Quality Assurance organization and

closed.

NRC review of enforcement history concerning the

dispositioning of NCRs identified a similar violation.

NOV 445/8832-V-01 identified that during the evaluation

of pCHVP nonconformances, engineering personnel failed to

establish that the discrepancies would result in no

conditions adverse to safety and that the item would

continue to meet all engineering functional requirements.

The applicant's root cause analysis appears to have dealt

only with the evident problem area in that corrective

action did not identify similar nonconforming conditions

which had been dispositioned, approved, and closed.

The NRC inspector noted during review of the applicant's

corrective steps taken to avoid further violations in

response to Notice of Violation (NOV) 445/8832-V-01, with

respect to training effectiveness and qualification, that

adequate training may not have boon parformed.

TU Electric's letter TXX-88522 dated July 1, 1988,

states, in part: -

"The personnel involved in this occurrence have been

reminded of the need to fully document engineering

justifications when dispositioning NCRs 'use-as-is', no

longer a nonconforming condition."

A formalized training session in the specific

requirements for dccumenting the technical basis for

"use-as-is" dispositions would have boon more

appropriate.

NRC inspectors and applicant personnel met on October 28,

1988, to discuss the NRC inspection findings. Deficiency

Report (DR) C-88-05182 has been issued to address

inadequacies in the PCHVP evaluation of inaccessible

attributes.

In summary, NRC inspection concludes that documented

instructions appropriate for performing technical

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dispositions of inaccessible attributes exempted from

PCHVP reinspection did not exist in all cases.

Furthermore,.the conditions identified on NCR 87-02743

and other similar NCRs do not have an adequate technical

justification por NCR proceduro requirements.

.The NCR har been reviewed by QA and closed although

engineering personnel have not established that the

indeterminate conditions are in compliance with

applicable requirements. These NRC inspection findings

are a violation of Criterion V (445/8871-V-04).

These departures from PCHVP commitments are indicative of

programmatic weaknesses in that the actual construction

process can not be reexamined for inaccessible

attributes. Therefore, with respect to quality

assurance / quality control for these unverifiable final

acceptance inspection attributes, it is mandatory for the

applicant to establish reasonable assurance that hese

attributes are in compliance with all applicable Jesign

specifications.

6. Plant Tours (50090, 48053, 48063, and 52051)

The NRC inspectors made frequent tours of Unit 1, Unit 2, and

common areas of the facility to observe items such as

housokooping, equipment protection, and in-process werk

activitics. No violations or deviations were identified and

no items of significance were observed.

7. Unresolved Items

Unrosolved items are matters about which more information is

required in order to ascertain whether they are acceptable

items, violations, or deviations. One unrosolved item

disclosed during the inspection is discussed in paragraph 5.b.

8. Exit Mooting (30701)

An exit mooting was conducted November 1, 1988, with the

applicant's representatives identified in paragraph 1 of this

repert. No written material was provided to the applicant by

the inspectors during this reporting porlod. The applicant

did not identify as propriotary any of the materials provided

to or reviewed by the inspectors during this inspection.

During this mooting, the NRC inspectors summarized the scopo

and findings of the inspection.