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Insp Repts 50-445/89-35 & 50-446/89-35 on 890503-0606. Violations Noted.Major Areas Inspected:Applicant Actions on Previous Insp Findings,Followup on Violations,Applicant Action on NRC Bulletins & Fuel Storage Racks
	ML20245D994
Person / Time
Site:	Comanche Peak
Issue date:	06/19/1989
From:	Livermore H, Phillips H; Office of Nuclear Reactor Regulation
To:	;
Shared Package
ML20245D952	List: ML20245D950; ML20245D980; ML20245D994;
References
	50-445-89-35, 50-446-89-35, NUDOCS 8906270294
	Download: ML20245D994 (12)
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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

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NRC Inspection Report: 50-445/89-35 Permits: CPPR-126.

50-446/89-35 CPPR-127

Dockets: 50-445 Category: A2

50-446

Construction Permit

Expiration Dates:

Unit 1: August 1, 1991

Unit 2: August 1, 1992

Applicant: TU Electric

Skyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas 75201

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

Units 1 & 2

Inspection At: Comanche Peak Site, Glen Rose, Texas

Inspection Conducted: May 3 through June 6, 1989

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Inspector: ~ #" U

H. / M,;llips

S. Phi

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Senior Resident Inspector Date

Construction

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Reviewed bye. 4fM/&hE -

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H. B. Livermore, Lead Senior Inspector Date

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iL LInspection Summary:

l Inspection Conducted: May 3 through June 6, 1989 (Report

50-445/89-35; 50-446/89-35)

Areas Inspectedi Unannounced, resident' safety inspection of

(1) . applicant's actions on previous: inspection findings,

(2) follow-up on violations, (3) applicant action on NRC Bulletins,

(4) allegation follow-up,.(5) review of commercial procurement for

AFW components, (6) fuel storage racks, and.(7) general' plant areas

.(tours).

Results: . Within the areas inspected, one violation: ' failure to

control design changes, paragraph 2.a. Three. unresolved items were

identified.(two in paragraph 6.b and one in paragraph 6.c)

concerning the procurement of commercial items. That is, the NRC

. inspector questioned the decisions that these items (a part of a

safety-related component) can not affect the component's ability to

function and assure safe shutdown. The procurement area continues

to exhibit symptoms that may indicate a continuation of weaknesses

identified during the procurement of services for coating removal

From Unit'1' service water piping.

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DETAILS .

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1. Persons ContactedL

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M. Axelrad, Newman and Holtzinger

P' *D. P. Barry,1 Senior., Manager, Engineering,.SWEC

D. Bize, License' Support, TU Electric

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

W. .J. Cahill, Executive Vice President, Nuclear, TU. Electric

H. M. Carmichael, Senior QA Program Manager, CECO

'*J. T. Conly, APE-Licensing, SWEC a

W. G. . Counsil, Vice Chairman, Nuclear, TU Electric

S. Ellis, Performance and Testing, UT Electric

P. E. Halstead, QC Manager, TU Electric-

C'. B.-Hogg, Engineering Manager, TU Electric

R.:T.tJenkins, Manager,' Mechanical Engineering, TU Electric

J. J. Kelley, Manager, Plant Operations, TU Electric

J. J.:LaMarca, Electrical Engineering Manager, TU Electric

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

S. G. McBee, NRC Interface, TU Electric

B. Packo, Licensing Engineer, TU ilectric

*S.-S. Palmer, Project Manager, TU Blectric

P. Raysircar,-Deputy Director, Unit 2, CECO

D. Real, Dallas Morning News

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

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

R. L. Spence, TU/QA Senior Advisor, TU Electric

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

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

The.NRC inspectors also interviewed other applicant employees

during this inspection period.

Denotes personnel present at the June 6, 1989, exit

meeting.

2. Applicant's Action on Previous Inspection Findings (92701)

g a. (Closed) Unresolved Item (445/8908-U-02): Silicone bronze

h, bolts in auxiliary feedwater (AFW) motors changed without

proper engineering authorization. The NRC inspector

identified this deficiency and several other concerns

relative to a material change that was made when the AFW

motors were worked.on to correct the reversed ;

unidirectional fans in Unit 1 motors. During this 1

maintenance activity, a Westinghouse (W) representative

(consultant) stated that the silicon bronze bolts should

be replaced with carbon steel bolts because the former had

cracked and failed because of fatigue. W letter WPT-10729

stated they were unaware of any problems and had tried to

contact the consultant who worked for them, but were

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unable to locato him. W maintained that this was not a

problem. This unresolved item is closed.

The unauthorized material substitution is a violation of

Criterion III Design Control which requires that design

changes, including field design changes, shall be subject

to design control measures commensurate with those applied

to the original design and be approved by the organization

that performed the original design. Two NCRs

(89-02548/02547) required the carbon steel bolts to be

replaced with the silicon bolts that were originally

authorized (445/8935-V-01).

b. (Closed) Open Item (445/8908-O-05): During a previous

inspection,'the NRC inspector found that instrumentation

tubing for flow transmitters in the Unit 1 reactor coolant

loop had been bent. This item was referred to

TU Electric. They stated that they were aware of bent

tubing and the damage would be documented on a NCR. The

item was left open pending the roccipt of NCRs.

TU Electric submitted files to the NRC with nine NCRs that

documented more damage than the NRC inspector had found.

It appears that the proper controls are in place for

identifying and correcting such deficiencies. This item

is closed.

c. (Closed) Open Item (445/8909-0-01): FSAR flow diagram

error. During a walkdown of the Unit 1 safety injection

system, the NRC inspector determined that

drawing 2323-M1-0261, Amendment 67 showed two isolation

valves that were labeled with the same valve No. 1-S1-048

in 12-inch piping run (12-1-031-151R). The NRC inspector

reviewed TU Electric files that were submitted to confirm

that needed changes were made. The NRC confirmed that

appropriate action to change the FSAR drawing and

identify the valves correctly was taken. This item is

closed.

3. Follow-up on Violations (927021

e. (Closed) Violation (445/8727-V-01a): TU Electric found

that Unit 2 AFN fans in the motors were backwards, but

failed to check and ccrrect Unit i fans. The NRC

challenged the assumption that the AFW fans were correct *

in Unit 1 because they passed preoperational testing. In

response, the fans were checked and were found to be

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backwards. These cond3tions were docu:uented on

nonconformance reports (NCRs) and were correctly installed

in accordance with work orders C87-0003441/0003442. This ,

item is closed. :

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b. (Closed) Violation (445/8727-V-01c; 446/8720-V-01A): The

interface between the AFW pump and motor was not

established in the applicable specification. As a result

of this confusion about the direction of motor and pump

shaft rotation / coupling, the unidirectional fans were

installed backwards.

TU Electric issued design changes to Specification

2323-ES-lD and 2323-MS-7 to clearly indicate the direction

of rotation. All other safety-related motors were checked

for similar deficiencies. In addition, all project

specifications were reviewed. This item is closed.

4 .- Applicant Action on NRC Bulletins (92703)

a. (Closed) IEB 78-08, " Radiation Levels from Fuel Element

Transfer-Tubes": This bulletin was issued as a result of

personnel. exposures during the first refueling outage at

another nuclear plant. The exposure occurred inside the

reactor building because labyrinth-type shielding access

was not controlled. The bulletin required licensees to:

(1) review shielding design, (2) assure access control,

(3) assure that radiation hazard signs are posted,

(4) identify radiation streaming when design was reviewed,

and (5) provide a response to the NRC. TU Electric

received this bulletin when the construction phase was in

progress and no response was required. Regardless, these

design issues and administrative controls were addressed

in Final Safety Analysis Report, questions 531.10, 331.21,

and the answers; health physics Procedure HP1-600 and

Station Administrative Procedure (STA)-660. This item is

closed.

b. (closed) IEB 79-13 and Revisions 1 and 2, " Cracking in

Feedwater System Piping": This IEB followed the discovery

of pipe cracks at another nuclear plant after that plant

was shutdown'to investigate leakage inside containment.

The cracking occurred at the feedwater nozzle to piping

welds on the steam generators at different plants. Thir ,

IEB required radiographic and ultrasonic examination of i

steam generators fabricated by Westinghouse or combustion

Engineering. Gupports/snubters that were not

volumetrically examined since 1979, and others were to be i

visually examined during the next fuel outage. Revision 1 !

of the IEB revealed failure by fatigue, assisted by !

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corrosion.

Certain applicants for a license were required to perform ,

nondestruct3ve examination (NDE) of the subject I

nozzle-pipe welds and visual inspection after hot i

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functional testing and were to perform inspections after

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required inspections and required the applicant to perform l

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inspections after hot functional testing, but before fuel

loading. (This IEB should have applied to Comanche Peak

Unit 1 since hot functional testing had been completed.)

During a previous inspection of this IEB, the NRC

inspector considered this IEB open pending the receipt of

answers to questions about which of the following were

applicable: (1) were all nozzle-pipe welds radiographer

for both units, (2) was ultrasonic-testing done, (3) what

were the technical conclusions, and.(4) should TU Electric

make a report on an IEB such as this when action is

required.

TU Electric provided a file (TSL-890-68 dated March 30,

1989) that comprehensively addressed the issues in this

IEB. This IEB is closed.

c. (Closed) IEB 79-17 and Revision 1, " Pipe Cracks in

Stagnant Borated Water Systems at PWR Plants": This IEB

was issued after cracks were found in stainless steel

piping which contained oxygenated, stagnant or essentially

stagnant borated water at another plant. The NRC

inspector reviewed a file which showed these issues were

properly considered during ASME Section XI examinations.

Water chemistry control Procedures CEM-506, 509, 511, and

517, also help control chemicals that may be detrimental

to the stainless steel piping. This item is closed.

d. (Closed) IEB.79-24, " Frozen Lines": This IEB was issued

after frozen lines were discovered in safety-related

systems at an operating plant. Specifically, there was no

flow through the recirculation line from the pump

discharge to the borated water storage tank because a line

was exposed to outside weather and froze. Even though

redundant heat tracing was on the line, the freezing

occurred because of prolonged subfreezing temperatures and

a defect in the insulation.

The NRC reviewed this IEB on previous occasions. The last

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review identified three questions about the protection of

H lines: (1) is distribution of heat in tunnels uniform and

effectiva, (2) did the design change authorization (DCA)

require a FSAR change, and (3) should a 50.55e evaluation

be me.de?

TU Electric provided information that answered the

questions .and satisfied the NRC inFpector'S Concerns.

Most importantly it was learned that EBASCO evaluated the

Environment of the lines and concluded

(Calculation 1-EB-3020-1) that the tunnels were heated

effectively. This item is closed.

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5. A11egtion Follow-up - (99014) ]

(Closed) Allegation (OSP-84-A-0010 and RIV-84-A-0146): NCRs

were signed off before work was completed. When the Technical

Review Team (TRT) was on site in 1984 they were to look into

this item.

During this inspection period, the NRC inspector was asked to

reinspect a portion of this allegation. Specifically, die

alleger stated that he or she was asked to sign off on an NCR I

written on a gouge in a flange on a 12-inch diameter spool )

piece before the defect was corrected. The NRC inspector found

insufficient information concerning this matter. That is, the

description of the concern was so vague'that the piping and the

NCR could not be identified. The TRT personnel may have had

the same problem. In that the deficiency was documented and

several individuals were involved, there is no reason to

conclude that appropriate action was not taken. This item is

closed.

6. Review of Commercial Grade Items Used to Repair Safety-Related

Components (35065, 38073)

a. Background

The NRC reviewed NRC Information Notices (88-97, 89-18,

89-22, and 89-39) which described substandard valve parts,

steel parts / materials, and certification of fasteners and

NRC Generic Letter 89-02 which addressed three effective

characteristics for controlling the procurement of

commercial grade products. It also discussed the

dedication of commercial items after receipt to allow them

to be used in safety-related components. The NRC staff

conditionally endorsed the guidelines in EPRI NP-5652,

" Guideline for the Utilization of Commercial-Grade Items

in Nuclear Safety-Related Applications (NCIG-07)." l

b. Review of Procurement Activities

The NPC inspector reviewad TU Electric

Procedure ECE 6.02-02, " Engineering Review of Procurement

Documents," Revision 4, and changes EDCN-01 through 03,

dated January through April 1989. It described '

procurement Codes A, C, N and V. Code A and V require !

'IU Electric or the vendor to apply a QA program in

accordance with 10 CFR 50, Appendix B, while Code C and H ;

do not. For a commercial purchase, QA Code C, form 7.1 of

this procedure contains three blanks which must be checked i

to answer whether an item is a basic component that is i

necessary to assure (1) the integrity of the reactor I

coolant pressure boundary (RCPB), (2) the capability to !

shutdown the reactor and maintain it in a safe shutdown

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condition, cn: (3) the capability to prevent or mitigate

the consequences of an accident (10 CFR 100.11). If the

answer is no to each (1-3), then no quality assurance

requirements (10 CFR Appendix B) need be imposed in the

purchase order and an item that is a part of a

safety-related component can be purchased commercially.

The NRC inspector reviewed 42 purchase orders for

components under the control of TU Electric operations to

select a sample of Code C procurement for January -

February 1988. Purchase Orders 661-76900; 74968; 74960;

74953; 74954, 74946, 74955, 74993, 74994, and'74985 were

items purchased under QA - Code C. That is, the vendor

was not required to provide these items under a 10 CFR 50,

Appendix B, QA program and 10 CFR 20 defects reporting

requirements. The NRC inspector questioned the

correctness of the determination of whether the item (a

part of a component) were required for or could affect

safe shutdown function. If the items were required for or

could affect safe shutdown, quality assurance should have

been required. The following are examples where the NRC

questioned the TU Electric justification for deciding no i

Appendix B QA program or Part 21 defect reporting

requirements were needed.

(1) Purchase Order 661-74955 was issued November 16,

1987, for items to be installed in six auxiliary

feedwater (AFW) pumps in Unit 1 and 2. During

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preoperational testing a test deficiency report

(ME-84-010) was issued because the outboard bearings

exceeded acceptable temperatures. Design

modification 87-1-026 was issued for upgrading

bearing cooling lines, but was revised because

engineering decided that Ingersoll Rand

Bulletin 60-87 would correct the problem. This was

reported to the NRC as a significant construction

deficiency in SDAR CP-87-50. The SDAR stated that i

this condition could cause a loss cf all AFW pumps.

Thrust bearing disc springs, shims, "O" rings, and

end covers were procured through a purchase order

that was classified as a commercial purchase without

any requirement to dedicate or upgrade the item to

safety-related. In this case, the engineer decided

that the function of the item would not be needed to

assure RCPB integrity, safe shutdown, or fer accident

prevention / mitigation. The NRC inspector questioned

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and challenged this conclusion because (1) the item

can affect the quality of an ASME Code component and

(2) the item will affect the capability to safely

shutdown or maintain safe shutdown. This matter was

identified and discussed with TU Electric at the end

of the inspection and will be unresolved until

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TU Electric resolves the apparent conflict between

safety implications described in TXX-6954 versus the

" Basic Component" justification in the " Procurement

Document Review Summary" (445/8935-U-02).

(2) Purchase Order 661-76900S was issued May 18, 1989,

for bonnet seals in ASME Code Valve 1AF-0038 which is

a Borg-Warner check valyc in the AFW system. The

decisions on this item were similar to those

discussed above. However, the NRC inspector

questions if a formal written ovaluation was

performed to support the decision that failure of

this seal will not affect safe shutdown. No such

engineering evaluation was provided to the NRC (only

references were made to the Specification MS-20.1,

Revision 2, and the vendor manual). This item is

unrosolved until TU Electric produces an engineering

justification that failure of the seal material will

not affect the function.of the valve (445/8935-U-03).

(3) Purchase Order 661-74954 was issued for electronic or

electrical printed circuit boards used in a

safety-related application. The original requisition

was for a commercial procurement. This error was

caught and a nonconformance was written. The point

here to be considered is that other'such errors in

judgement may have allowed components to be purchased

commercially because they were thought to not affect

the functioning of components. There is no

indication that TU Electric has addressed this issue <

and has audited a large number of such procurement.

This item is considered a part of the unresolved item

discussed in paragraph 6.c below.

c. Review of TU Electric Audit

During this inspection period, the NRC inspector reviewed

TU Electric Audit TSU-89-01 involving a commercial

procurement. The original audit scope was to perform a

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surveillance of Hot Functional Testing of Unit 1.

However, because charging valve FCV-321 demonstrated

arratic behavior and could not control the charging rate

to the pressurizer the auditors followod the actions taken

to correct this problem.. Test Deficiency Report 7298 was

issued and the deficiency was traced to resolution. After

the auditor followed-up, the following are the preliminary

audit findings:

. Maintenance discovered that the controller tubing was

tubed into the wrong ports of the valvo. No

nonconformance was written. They just fixed the

problem.

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W . Startup discovered a new design for the plug and' trim

cage of.the. valve and' decided to use the new design

to avoid retesting'. They found that Union Electric

could provide.the parts Unmediately.

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. A QA - Code "A" requisition was issued. -QA Code A

requires the vendor to be.on TU Electric's approved

vendor list.

. TU. Electric's procurement QA personnel' rejected the

requisition because QA' requirements were not included

and the subject vendor (Union Electric) was not on

the approved list.

. The requisition was changed to QA - Code N

(nonsafety-related) and was designated as

'undesignated spares (parts). As Code N purchases

could not be used in a safety-related system it was

necessary to change to Code C (nonquality

components / parts which have some quality

requirements).- Note: The NRC inspector believes

this definition is confusing TU Electric personnel

and should be clarified.

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.- Accordingly, a series of moves were made to change

the QA Code N to Code C to allow the valve to be i

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changed to the new design. . One move included

., removing.the ASME tag (NPT) from the Copes Vulcan

valve. Design Change Authorization 85385 was issued

to make all of this happen, but according to the

auditor this violated ASME Section XI,

subsection lWA-7220 which requires components to be

evaluated before replacement / installation.

. In addition to the above, the TU Electric auditor

noted that 10 CFR,-Part 21, requirements were not

invoked, appropriate documentation was not required,

and the QC inspector was unaware of the change from a

temporary modification to permanent plant design.

Also, the missing tag was not noted.

The preliminary information discussed above is a real time

example of how the procurement process can be bypassed.

Prior to this inspecticn, the NRC inspector discussed such

potential abuses of the QA Code classification in a

presentation on procurement (that was made by TU Electric

to close previous NRC concerns). At the time, the NRC

inspector was told that commercial procurement. vere

controlled by the quality organization's audit of a small

percentage of the commercial procurement.

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The NRC inspector subsequently reviewed the final audit

(TSU-89-01) report-and interviewed the TU Electric QA

manager with respect to the audit of commercial

procurement. The NRC inspector considers this item to be

unresolved and has requested a meeting with TU Electric to

discuss TSU-89-01, the apparent problems, and audits of

commercial procurement to assure that safety-related

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components and items installed in components are procured

to appropriate regulatory requirements (445/8935-U-04).

7. Fuel Storage Racks (50095)

Two NRC inspectors had previously reviewed Unit 1

specification,. procedures, work instructions, and drawings for ,

Unit 1 racks. The completed work was also inspected for '

configuration and the appearance and size of welds. Records

including travelers, design changes, and inspection reports

were reviewed.

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During this inspection period, the NRC inspector, visually

inspected the racks to assure that they had not been damaged or

substantially changed. The inspector has no further questions

about the storage racks. !

8. General Plant Inspections (55050, 50073)

At various times during the inspection period, the NRC i

inspector conducted independent and planned inspections I

(regular and backshift) of the Unit 1 reactor containment,

safeguards, auxiliary, electrical control, and diesel generator

buildings. All accessible rooms in these buildings were

inspected to observe current work activities with respect to

major safety-related equipment, electrical cable / trays,

mechanical components, piping, welding, and removal of debris

from seismic gap between buildings. The housekeeping, storage,

and handling conditions inside these buildings and various

outside storage areas were also inspected. Fire

prevention / protection measures were observed during the subject

inspections. No violations or deviations were identified.

9. Unresolved Items

Unresolved items are matters about which more information is :

required in order to ascertain whether they are acceptable !

items, violations, or deviations. Three unresolved items

disclosed during the inspection are discussed in paragraphs 6.b

(two) and 6.c (one).

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10. Exit Meeting (30703)

An exit meeting was conducted June 6, 1989, with the

applicant's representatives identified in paragraph 1 of this

report. 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 inspection. During this

meeting,.the NRC inspectors summarized the scope and findings

of-the inspection.

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ML20245D994

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