IR 05000445/1975005
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U. S. NUCLEAR R EGULATORY COMMISSION l
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OFFICE OF INSPECTION AND ENFORCEMENT REClON IV
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IE Inspection Report Nos. !O-445/75-05 Docket Nos. 50-445
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50-446/75-05 50-446
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Applicant:
Texas Utilities Generating Co.
Category A2
2001 Bryan Tower
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Dalla s, Texas 75201
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Facility:
Comanche Peak Steam Electric Station
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Units 1 & 2 yg Location:
Glen Rose, Texas
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Type of Licensee:
Type of inspection: R ou tin e, Unannounc ed
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Dates of Inspection: February 27-28, 1975
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Dates of Previous Inspection: February 5,1975
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Principal Inspe c tor:
8!4[7[
R. C. Stewart, Reactor Inipector Date
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Accompanying Inspector:
W 3/6/7s W. G. Hubacek, Rea#.or Inspector Date i
Other Accompanying Personnel: None t
3[0[7f Reviewed By:
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W. A. Crossman, Senior Reactor Inspector Date
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890504O'313 890425
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SUMMARY Of FINDINGS
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1.
Enforcement Action J '
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Iterns of Noncompliance
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Violation
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Infra c tion g..,,
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Deficiencies
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OA/OC Procedural Deficiency
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Contrary to 10 CFR 50, Appendix B, Criterion V,
.an inspection procerture was not developed and Dc, M
implemented for activities related to the excavation for the reactor containtnent structures 5i..
of CPSES, Units 1 and 2, in accordance with Brown
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& Root Procedure CP-QCP 12. The procedure,
" Excavation and Soils Backfill, Compaction,
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Inspection and Testing", issued July 1,1974, revised November 1,1974, Section 3.1, states in part, "The Brown & Root, Inc. Proiect Quality
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Assurance Manager is responsible for all test N
activities covered by this procedure. For work W
RI performed by Brown & Root, procedures shall be developed and implemented by Brown & Root which
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cover inspection and testing requirements and
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provide documentation that requirements have been f
me t. " (DETAILS, paragraph 3)
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This deficiency was identified by the inspector.
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B.
Deviations 7,,
None
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Licensee A.. tion on Previously Identified Enforcement Matters
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New Unresolved items
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None r+ !
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IV.
Status of Previously Reoorted Unresolved items
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74-02/VII B Brown & Root (BLR) OA Procram Manual r;(
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Revisions to the BkR QA Program Manual have been completed and the
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document has been approved by TUSI. This matter is resolved.
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V.
Desien Chances V
None
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VI.
Unusual Occurrences
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None f,
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Other Significant Items
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Manacement Interview
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On February 28, at the conclusion of the inspection, a management I
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meeting was held with the following licensee representatives in attendance:
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s Texas Utilitie s Services. In c. (TUSI)
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Mr. H. C. Schtnidt, QA Manager
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Mr. C. H. Gatchell, Resident Manager
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I Brown & Root. Inc. (BL R)
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Mr. H. C. Dodd, Project ManaBer Mr. C. E. Bonin. Assistant Project Manager Mr. P. L. Bussolini, Project QA Manager Mr. D. L. Hansford, QA/QC Engineer Gibbs & Hill (GLH)
Mr. J. V. Hawhins, QA Engineer The inspection findings, as contained in the summary and detail sectionr
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cf this report, were discussed.
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(continued)
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R_EPORT DETAILS
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L Persons Contacted w
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Texas Utilities Eervices. Inc. (TUSI)
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Mr. H. C. Schmidt, QA Manager
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Mr. C. H. Gatchell, Resident Manager 7,
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Gibbs & Hill (GLH).
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Mr. J. V. Hawkins, QA Engineer
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Mr. J. J. Moorehead, Resident Engineer
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b Brown L Root. Inc. (B&R)
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Mr. H. C. Dodds, Project Manager Mr. C. E. Bonin, Assistant Project Manager
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Mr. P. L. Bus solini, Project QA Manager
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Mr. D. L. Hansford QA/QC Engineer
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Mr. J. L. Woodruff, Superintendent, Blasting P
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Mason.Johnston & Associates (MJA)
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Mr. B. V. Dreyer, Chief of Engineering. Geology e
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Mr. W. T. Cromeans Resident Chief Technician
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Mr. A. D. Ca b1r., Assistant Resident Technician Mr. H. C. Crowder, Field Geologist
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Mr. K. G. Christopher, Assistant Geologist E-Reoort of Subjects inspected
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1.
Scooe of Insoection
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p The inspection was limited to the review of the site QA/QC program
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implementation as it applies to work activities regarding safety i
related structures during the initial construction phase. The inspectior. included the review of CA/QC records, procedures, and
. observation of the work in the areas of reactor building containment excavation, blasting, fill placement, preparations for concrete placement, and work activities relating to the safe shutdown-l
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impoundment dam (SSI Dam).
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Plant Progress The overall plant construction progress is reported as 1. 07. complete.
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Significant progress was observed in the construction of the main i
dam (Squaw Creek Dam), intake tunnels, and reactor building
containment excavations.
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The Squaw Creek Dam core trench is essentially complete to
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bed rock and impervious and filter materials are being installed.
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Work is continuing on the main concrete batch plant and construction
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field office building.
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the core trench excavation has not commenced.
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3.
Contamment Buildine Excavations - Units 1 and 2 f
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i The inspector visited the site of the excavations for the containment N
k buildings, Units 1 and 2.
Evidence of rock "overbreak" around the FA
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perimeters due to blasting was cbserved in both of the excavations E
l but was more pronounced for Unit 1. This problem was reported by
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the licensee on February 4 in accordance with the requirements of e;
10 CFR 50. 55(e).
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M Discussions with TUS1, BLR and MJA personnel of actions proposed
to determine the extent of damage and corrective measures to be O
taken indicated that a program to resolve the difficulty has been d
developed and is being implemented. MJA will provide Feologic Iss data for use in engineering evaluations in determining the need for,
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extent of, and preferred type of remedial operations.
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i The inspector's examination of documentation relative to the E
excavations indicated an apparent lack of required quality control
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I procedures applicable to excavating operations that have been com-p' e t e d.
BLR procedure CB-QCP-12 " Excavation and Soils Backfill, b.
Compaction, inspection and Testing" under Scope states: "This r
i procedure covers all excavations to foundation rock and the selection, placement and compaction of structural fill soils and embankment
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materials required for permanent construction"; Section 3.1 states:
"The Brown & Root, Inc. Project Quality Assurance Manager is
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responsible for allinspection and test activities covered by this p'
procedure. For work performed by SkR, procedures shall be developed and implemented by BLR which cover all inspection and
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testing requirements and provide documentation to assure that A
requirements have been met. "
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Gibbs & Hill Specifiestion No. 2323-55-6 " Excavation for Plant Strnetures" which ir applicable to the excavation of all materials
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encountered for construction of major structures on the plant y
f site lists in Section 1.1 " Major Structures" the containment p,
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structure under the heading of CateFory I Structures". This j['
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listing appears to include excavation work for Cagetory I Structures
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and that excavating operations be subject to the same level of quality
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control.
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Criterion V of 10 CFR 50 states in part: " Activities affecting quality
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shall be prescribed in documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be
accomplished in accordance with these instructions, procedures and d rawing s ".
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Contrary to the above requirements, B&R inspection procedures
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containments of CPSES, Units 1 and 2 did not exist. Based on the E
inspector's finding s, this matter ha s been identified as a deficiency
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in OC procedural development and implementation for a quality
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related activity.
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4.
Review of OA/OC Procram for Initial Construction a
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Implementation of OA Procram g/;
p The QA Manuals for TUSI. Brown & Root and Gibbs & Hill L
were reviewed and observed to contain descriptions of.QA/QC
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personnel duties and responsibilities. The descriptions and r
organization charts provide for freedom of CA/QC personne2 I
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from persons having cost and scheduling responsibilities.
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Functional relationships were appropriately described.
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The inspector observed that the TUSI, BLR and GLH QA Manuals I
and procedures establish. requirements for audits of OC activities
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by QA personnel and that documentation of audit activities is r equi r e d.
Reports of audits are submitted to appropriate manag ement.
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OC System Review
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Review of TUS1, BLR and G&H QA Manuals established that P
chey tontain the necessary requirements relative to procurement,
material certifi;ation, and shipping, receipt and storage.
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5.
SSI Dam Activities l
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The SSI Dam site has been cleared in preparation for start of (
con s t ruc tion. During the inspector's review of the QA/QC e,
activiti,s associated with the SSI Dam the inspector was informed I
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that preliminary soundness tests of the rock fill rnaterial, taken
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from the previously selected borrow areas, did not meet the f
design specification. In discussing the problem with the MJA (
l geotechnical staff, the inspector was informed that the SSI Dam t
rock fill design was established utilizing the same material in
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the initial test sections built to prove out the design. The inclusion y
of the ASTM C. 88, " Test for soundness of aggregates by use of B
sodium sulfate or magnesium sulfate" in the specification occurred
after the design had been established.
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Rock currently being quarried contain clay stone fissures that can not withstand the magnesium sulfate test (ASTM C. 88). resulting in weighted percentage losses exceeding the specification (35%-95%
l versus 20% 1imit) using particles passing 2-1/2 inch sieve and retained on a 1-1/2 inch sieve.
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V The cognizant MJA Geologist indicated that the particular ASTM B
standard may be unreasonably restrictive for the intended application;
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however, he expressed confidence in finding available sources of rock on site that will maet the specification. Surveys of other
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borrow areas are now l aing investigated. The licensee represen-
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tatives stated that the current delay in starting construction of
the SSI Dam will not affect the overall completion ~ schedule of the
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plant.
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U. MATOMIC ENERGY COMMISSIN4
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DIRECTORATE OF REGULATORY OPERATIONS
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REGION IV
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RO Inspection Report Nos. 50-445/75-01 Docket Nos. 50-44 5
50-446/75-01 50-446 Applicant:
Texas Utilities Generating Company License No. None 1506 Commerce Street l
Dallas, Texas 75201 Category A2 Facility: Comanche Peak Steam Electric Station - Units 1 & 2
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Location: Glen Rose, Texas j
Type of Licensee:
CASE EXHIBIT s
Type of Inspection: Routine, Announced Dates of inspection: January 8-9, 1975 Dates of Previous Inspection: December 6,1974 Principal Inspe cto r:
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R. C. Ste' wart, Reactor Inspector Date
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Accompanying inspector: None Other Accompanying Personnel: None
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s7 Reviewed By:
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W. A. Crossman, Senior Reactor
' Date Inspe ctor j
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SUMMARY OF TINDINGS
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I.
Enforcement Action m
A.
Violation
,e None I
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Infraction None
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C.
Deficien cie s
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None
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II.
_ Licensee Action on Previous 1v Identified En.forcement Matters
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None outstanding III.
New Unresolved Items None
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IV.
Status of Previous 1v Reported Unre' solved Items
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74-02/VII B Brown & Root (BLR) OA Program Manual I
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The BLR " Quality Assurance / Control Manual for Nuclear Projeets, Construction Phase, Volume II", contains the BLR QA Program Policy and Commitments. The manual does not contain references to other BkR Ouality Assurance /
Control Manuals in use, nor, is it clear as to the manuals
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fr.nettonal application to the Comanche Peak Project. These
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~2-matters remain unresolved. (DETAILS, paragraph 2)
V.
Design Changes None
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VI.
Unusual Occurrences
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None
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(continued)
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'VII. 'Other Significant Items
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Proicet Status
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Site clearing / preparation and excavation is reported as 507. complete.
. Excavation of the core trench for the main lake dam has commenced.
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The start of construction of the Safe Shutdown Impoundment Dam (SSI) has been delayed until February 1.
This delay will not affect the overall plant schedule. There are no safety related work activities currently in progress.
The reported on-site work force is 355 personnel.
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VIII. Manacement Interview
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On January 9, at the conclusion cf the inspection, a management meeting
was held to discuss the results of the inspection. The following licensee
representatives were in attendance:
TUSI Mr. R. G. Tolson, QA Engineer Mr. P. M. Milam, QA Engineer
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Mr. C. H. Gatchell, Resident Manager l
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BLR
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Mr. L. A. Ashley, Construction Manager
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Mr. H. C. Dodd, Project Manager i
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Mr. C. E. Bonin, Assistant Project Manager l
Mr. C. L. Whitford, QA Manager
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Mr. P. L. Bussolini, Project QA Manager
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Mr. D. L. Hansford, QA/QC Engineer M r. C. H. Ivey, Project Engineer
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The inspection findings, as contained in the Summary and Report Details l
Sections of this report, were discussed.
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REPORT DETAILS
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. G. i List' of Persons Contacted
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Texas Utilities Services. Inc. (TUS1)
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Mr. -R. W. Caudie, Project Manager - Nuclear Plants
.,j Mr. R. H. Hickman, CPSES Project Engineer Mr. H. C. Schmidt, QA Manager-
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a Mr. R. G. Tolson, QA Engineer
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Mr. P. M. Milam,- QA Engineer
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Mr. ' C. H. Gatchell, Resident Manager Brown & Root, In c.
(BLR)
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Mr. L. A. Ashley, Construction Manager
Mr. H. C. Dodd, Project Manager Mr. C. L. Whitford, QA Manager Mr. C. E. Bonin, Assistant Project Manager
- Mr. P. L. Bussolini, Project QA Manager Mr. C. H. Ivey, Project Engineer -
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Mr. D. L. Hansford, QA/QC Engineer Freese & Nichols (FLN)
Mr. J. M. Dodson, Resident QA Manager
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Mr. W. L. McGrath, QA Engineer
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Mason-Johnston L Associates, Inc. (M-J)
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Mr. W. T. Cromeans, Resident Chief Technician Mr. A. D. Cabla, Assistant Resident Chief Technician Mr. H. C. Crowder, Geologist
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Report of Subjects Insoected
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1.
Scone of Inseeetion j
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The inspection was limited to the review of the site QA program imple-mentation as it applies to safety related work activities in the initial Construction Phase. In addition, a review and examination was con-ducted of the activities associated with the construction d the SSI Dam.
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2.
BLR QA Program Manual Review
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U During the previous inspection 1_/ the BkR QA Manual, " Quality Assurance /
Control Manual for Nuclear Projects, Construction Phase, Volume II" was
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still in final review and had not been issued for use.
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(continue d)
1/ RO Inspection Report Nos. 50-445/74-05 & 50-446/74-05, dated 12/16/74,Section IV, item 74-02/VIIB.
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t During this inspection, it was established that the manual was approved
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and issued to TUSI December 30. However, TUSI representatives have indicated that a final review and acceptance by TUSI has not been
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completed at this time.
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Daring the inspector's review of the Construction Phase II Manual.
the following matters were identified and discussed with the BLR repre-
sentatives as items that appear to require further clarification:
The Manual, Section 1. 0 "QA Program", references individual a.
project PSAR's for specific details regarding QA program requirements. The functional application of the manual and
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commitments applicable to the Comanche Peak Project are not clear.
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b.
The manual does not appear to contain references to other BLR Corporate QA Manuals which appear to be in use at the site, specifically: the QA/ Control Manual, Engineering, Volume 1;
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the QA/ Control Manual, Procurement, Volume III; and the manual entitled, " Administrative Procedures".
In view of items a and b above, ~ the BLR "QA Program" for c.
Comanche Peak, Units 1 and 2, require clarification.
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The pages in the manual are not numbered.
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f The manual contains sections entitled Electrical, Civil, non-n
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conformance, etc. There appears to be no reference to these
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sections, nor is it clear as to their application to the Comarche
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Peak Project.
l In discussing the above items with the BLR QA Manager, the QA
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._3 Manager stated that he would review the items and corrective measures
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would be initiated. The inspector stated that the items would remain
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unresolved pending a subsequent RO review during the next inspection.
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The inspector had no further questions relative to his review of the remaining portions of the manual, Section 1, " Quality Assurance Prog ram".
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3.
BLR QA Site Activities (C. P. Authorization)
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The SLR QA Project Manager and one staff member are presently
assigned full time to the site. During discussions held with the BLR QA staff, the inspector reviewed the BLR QA/QC activities relative to
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' site preparation applicable to the commencement of construction of j
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l safety related structures. The QA/QC staff members appear to be knowled eable of the QA functions to be implemented during the
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l initial phases of construction. The inspector verified that approved QC procedures are maintained on-site relative to the construction
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l activities associated with excavattori,; fill placement, blasting and ground water control. ' BLR QA/QC personnelindependence and l
I personnel duties and responsibilities 6 appear to be in accord with the
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licensees QA program requirements.
The TUS10A/QC site office has been established on-site; however, full time resident inspection activities have not been established. The
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TUS! QA staff members currently conduct weekly surveillance / audits i
of the contractors site activities. The areas of review and the timeliness of their activities appear to be consistent with the work
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in progress.
The start of blasting and excavation for the reactor containment
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structure is currently scheduled for late February.
e 4.
Construction Activities - SSI Dam The start of excavation and construction of the SSI Dam has been The BLR representatives indicated that construction of the
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delayed.
SSI Dam is now scheduled to start the first week in February :md that
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the delay would not affect the overall schedule.
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a.
FLN Activities s
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A follow-up review of the FLN QA/QC program implementation for the SSI Dam construction was conducted by the inspector.
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Discussions were held with the site personnel and a review of the FLN Procedures, Appendix J,. " Inspection and Testing",
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was conducted..The FLN QA/QC staff demonstrated an under-
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P, standing of the FLN QA Program and Procedural Requirements.
There were no matters that remain outstanding.
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b.
M-J Discussions were held with the M-J staff members relative to
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the status of their procedural development and final preparation
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for site testing activities. The M-J representatives stated that
.. s all QC Program Procedureg have been developed, however,
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approximately 26 procedures are stillin various forms of final review, approval, and issuance. The procedures required for (continued)
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the anticipated site testing activity in February are in final w i
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.. 7-1 M-J has 12 personnel on-site. The site testing laboratory
facility appears to be operational and in phase with the current
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