IR 05000445/1982003
| ML20054M553 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/21/1982 |
| From: | Murray B, Renee Taylor, Westerman T, Wilborn L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20054M546 | List: |
| References | |
| 50-445-82-03, 50-445-82-3, 50-446-82-02, 50-446-82-2, NUDOCS 8207130579 | |
| Download: ML20054M553 (12) | |
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APPENDIX B
'U.
S. NUCLEAR REGULATORY COMMISION
REGION IV
Report: 50-445/82-03; 50-446/82-02
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Dockets: 50-445; 50-446 Category: No. A2 Licensee: Texas Utilities Generating Company 2001 Bryan Tower Dallas, TX 75201 Facility Name:
Comanche Peak, Units 1 and 2 Inspection At:
Comanche Peak Steam Electric Station Inspection Conducted:
February and March 1982 Inspectors:
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[/G'[ N R. G. Taylor, Senior Resident Inspector-Constr. Date Reactor Projecc Section A m
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L. WilbgrA, Radiation Specialist Date Facilib'6s Radiation Protection Section (Details Section, pars. 2 and 4)'
n Reviewed by: D <dL1 J. M U At DL/
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B. Murray, Chief
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Facilities Radiatiod-Protection Section Approved:
7[ - [6 gat /v v T. F. Westerman, Chief Datt Reactor Project Section A
Inspection Summary Inspection Conducted During February an_d March 1982 (50-445/82-03; 50-446/82-02 Areas Inspected:
Routine, announced inspection by the Se'nior Resident Inspector-Construction (SRIC) including general site tours; follow up on previous inspection findings and licensee reported deficiencies; inspection of piping installation activities; procurerr.ent cycle. activities; concreting
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activities; and instrumentation and electrical installation activities.
There was also a special, unannounced followup inspection by a Region IV-based inspec-tor of the licensee's corrective actions relative to excessive groundwater withdrawal that was identified during inspection 50-445/80-09.
The inspection involved 132 inspector-hours by the SRIC and 5 inspector-hours by the Region IV-based inspector.
Results:
No violations or deviations were identified in four of the five major activity areas inspected.
One violation (paragraph 7) was identified in the area of procurement control.
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Details 1.
Persons Contacted
- R. Lancaster, TUGCO, Radiation Protection Engineer
- C. Curry, TUGCO, Chemistry and Environmental Technician
- R. Tolson, TUGCO, Site Quality Assurance Supervisor
- L. Popplewell, TUSI, Project Electrical Engineer
- J. Merritt, TUSI, Engineering and Construction Manager
- J. Kuykendall, TUGCO, Manager of Nuclear Operations
- D. Chapman, TUGCO, Quality Assurance Manager
- B. Clements, TUGCO, Vice-President, Nuclear
- A. Vega, TUGCO, Supervisor, Quality Assurance Services The SRIC also interviewed other licensee and Brown & Root employees during the inspection period.
- Denotes those persons who attended management meetings with either the SRIC or the region-based inspector.
2.
Licensee Action on Previous Inspection Findings a.
(Closed) Violation (50-445/80-09; 50-446/80-09) Excessive Groundwater Withdrawal.
The Region IV-based NRC inspector verified that licensee actions committed to in response to the Notice of Violation referenced have been implemented.
For further details, see paragraph 4 of this report.
b.
(Closed) Unresolved Iten (50-445/81-19; 50-446/81-19) Correct Revision of Appendix 8 to Project Specification MS-46A.
This matter concerned a finding that CPSES project engineering was using the above appendix at a revision 4 level, whereas the revision of record
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in the site document control center was revision 1 During the l
above inspection, it was ascertained that the licensee's architect-engineer (A/E) had forwarded revision 4 (and the intermediate
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l revisions) to site engineering via a letter of transmittal that did not reference the parent specification.
The document control center had the letters of transmittal and revision 4 of the appendix, but because the letter did not reference the parent specification, the document was not readily available to the NRC inspectors when they attempted to obtain or ascertain the pisper revision.
Revision 5 of the appendix has now been issued by the A/E, received at the site, and has been incorporated into MS-46A via Design Change Authorization 12445.
To avoid future like occurrences, the licensee has directed the A/E to forward all such changes to the site utilizing a Design
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Engineering / Change-Deviation document ather than a simple letter.
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3.
Action on Licensee Identified Design / Construction Deficiencies (Closed) Underspecified Auxiliary Feedwater System Valves.
This item was initially reported to the SRIC on December 7,1981, with an interim letter confirming the verbal report following on December 31, 1981.
The licensee informed Region IV by letter dated March 2, 1982, that an
analysis of the situation had been completed and that it had been deter-mined that the matter was not formally reportable under 10 CFR 50.55(e).
Data reviewed by the SRIC indicated that the eight valves in question had i
been replaced in order to fully comply with the requirements of the ASME Code, but nonetheless still did not constitute an actual unsafe condition during future operations of the auxiliary feedwater system.
During system hydrostatic test, however, the test pressure would be slightly in excess (75 psi) of the valve design hydrostatic pressure and only minimum possibility for damage existed.
The SRIC verified that the engineer's analysis was correct by review of the ASME Code and Chapter 10.4 of the FSAR and had no further questions.
4.
Inspection of Groundwater Withdrawal Controls The NRC inspector verified that the licensee had conducted a review of flow measuring instrumentation, water demand, and recording procedures.
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The licensee concluded that a need existed to better communicate groundwater withdrawal values as the maximum allowable value was approached and that a need existed for incorporating flow measurement devices in a calibration program.
To avoid future violations, the licensee instructed recording personnel by letter CPPA-4890, dated April 23, 1980, to notify the CPSES resident manager if the maximum allowable rate was approached.
The flow measurement devices were incorporated into TUGC0 operations calibration program.
The NRC inspector reviewed TUGC0's corrective action as submitted to NRC Region IV in a letter (TXX-3132)
dated May 5, 1980, in response to a Notice of Violation issued with Inspection Report 50-445/80-09; 50-446/80-09.
A licensee representative
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interviewed during the inspection stated that the construction contractor had been recording the integrator readings from the groundwater wells on a daily basis until about March 1980.
The licensee began experiencing
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difficulties in obtaining the readings from the contractor and decided l
that TUGC0 personnel would start recording the readings.
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approximately the same time, the licensee put into operation a surface water treatment plant which decreased their reliance on groundwater i
usage.
With the surface water treatment plant in operation and those
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construction activities which require the most water (i.e., processing, i
placement, and curing concrete completed, or nearly so) the licensee began recording integrator readings on a monthly basis.
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The NRC inspector reviewed records of groundwater withdrawal rates for the period March 1980 through February 1982 and noted the average monthly rates were well below the allowable rate of 250 gpm through December 1980 at which time the withdrawal of groundwater was reduced to an annual average of 30 gpm.
The rates noted were typically 150 gpm through December 1980 and approximately 15 gpm during 1981.
The NRC inspector noted that TUGC0 operations personnel had included the l
flow measuring devices in their calibration program.
They had determined that the flow measuring devices were nonsafety items and, therefore, had been given a calibration frequency of at least once every 2 years.
The inspector reviewed records of calibration for the flow measuring devices.
The inspector noted that the devices were calibrated as follows:
Instrument Identification Date Integrator Batch (West) X-FI-4144 February 23, 1981 Integrator Meteor (East) X-FI-4150 February 23, 1981 Flow Recorder Batch (West) X-FR-4144A May 30, 1980 Flow Recorder Meteor (East) X-FR-4150A May 30,-1980 Flow Transmitter Batch (West) X-FT-4144 December 19, 1980 Flow Transmitter Meteor (East) X-FT-4150 December 19, 1980 Flow Recorder Strip Chart X-FR-4144/50 December 29, 1980 No violations or deviations were identified.
5.
Concrete Placement Activities The SRIC ooserved substantially ali of the concrete placed during the lowest lift of the concrete for the construction opening in the Unit 1 Containment Building.
The SRIC also observed a portion of the place-ment work for the second lift.
In each instance, there was strong evidence of good prior placement planning in that the form work had been
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modified to provide inspection windows that would allow for visual i
verification that the fresh concrete had been adequately consolidated,
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particularly during the initial placement in an area highly congested i
with reinforcing steel.
Placement consolidators and quality control personnel had worked their way down between the inner and outer screens of steel to have better access to the surface of the fresh concrete and adequate lighting had been placed to give them good visibility.
The SRIC i
l observed the early, most difficult, portions of the consolidation efforts through the inspection windows and did not observe "honeycombing" within
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l the wall volume.
The SRIC also observed the testing of the fresh
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concrete prior to placement and found that the requirements of ASME Section III, Division 2, were satisfied.
The SRIC inspected operations of the concrete batch plant and found that concrete constituents required by the design mix were being batch into transit mixers which then made the correct number of mixing revolutions prior to departing for the placement (
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site.
The SRIC observed the batch plant scales were within their calibration period as evidenced by stickers on each scale and that the digital readouts on the control board for the plant correlated with the actual scale readings.
During the period preceding the actual placement of the concrete, the SRIC observed the installation of the reinforcing steel in the construction openings at various times.
The SRIC also observed the preparation and firing of several "Cadwelds" in the primary reinforcing steel and observed portions of the subsequent inspection of the
"Cadwelds" by a QC inspector.
The SRIC inspected several of the
"Cadwelds" following the QC inspection and found that all requirements had been satisfied.
The reinforcing steel in the primary structure was noted to be a continuation of steel work in the area of the wall surrounding the construction opening that had been determined previously to be in compliance with the design drawings and no special effort was directed toward reverification.
The SRIC did verify that the correct steel was used in those areas examined; i.e., six 185 of a grade 60 strength.
The
"Cadwelds" were examined relative to the criteria established in the construction procedures which in turn reflect the recommendations of the above mentioned code and those of the manufacturer, Erico Products.
No violations or deviations were noted in this activity area.
6.
Pipe Welding and Installation Activities During the inspection period, the SRIC made several observations of storage, handling, and installations practices of piping components, including pipe spool and valves with particular emphasis on those l
composed of stainless steel materials.
The practices observed were t
consistent with good nuclear industry practices as delineated in Project Specification MS-100 and site procedures.
The SRIC observed that the piping systems supported without the benefit of the permanent support l
systems were well supported and held in good alignment by well designed i
temporary supports that also contribute in many cases to continued l
installation activities.
The SRIC also examined 44 sets of radiographs of piping system welds during the inspection period.
Forty of the sets were of welds in Unit 1, with balance of welds in Unit 2.
All welds were those defined as being within the reactor coolant pressure boundry and Class 1 within the ASME Section III Code.
The SRIC found that all of the welds were acceptable within the requirements of ASME Section III for weld quality, while the radiographic quality satisfied the requirements of ASME Section V for nondestructive examination methods.
The SRIC observed welder AWJ making the second pass on FW-6 connecting valve 2-8949A to a prefabricated spool identified as RC-2-RB-019-2 in the Unit 2 reactor coolant pressure boundry.
The welder was utilizing Weld
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Procedure 88021 and weld filler metal heat number 746100 in making the weld.
The welder was observed to be following the parameters of the weld procedure.
The SRIC subseguntly verified that the filler metal was appropriate (type 316) for the weld and had been properly certified by the manufacturer, Sandvik Steel.
The SRIC noted that an adjacent weld to FW-6 was substantially different in appearance than those usually encountered at CPSES.
The primary difference was that the weld was considerably wider across the crown than is typical and was composed of several beads about 3/8-inch wide with definite valleys between each bead, whereas the typical finished weld is generally ground smooth or nearly smooth to facilitate both the construction volumetric examination (radiography) and the inservice examination (ultrasonic).
Further examination revealed that the spool was fabricated offsite by Southwest Fabricators and had been given a nameplate stamped with the ASME Code symbol.
For further information about this spool, please refer to the next paragraph (7) of this report.
The SRIC also observed welder AMA making a repair weld identified as weld 10-1 on isometric CS-2-AB-080A.
The welder was utilizing Weld Procedure 88023 and the same weld filler metal noted above.
This welder was welding within the parameters of the weld procedure.
The SRIC verified that each of the above welders had been qualified for the weld procedures observed being utilized in accordance with the requirements of ASME Section IX.
No violations or deviations were identified in this activity area.
7.
Procurement Controls The SRIC became aware during this inspection period that Southwest Fabricators was being utilized by the licensee to furnish prefabricated pipe spools.
In the past, such spools were either fabricated in the onsite shop if 6 inches and under, and by ITT-Grinnel if larger than 6 inches.
The SRIC reviewed the administrative controls specified in Purchase Order CP-0701 for piping orders and to establish the technical requirements
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The SRIC found that the purchase order referenced l
Project Specification MS-43A, which is specifically stated to be for pipe l
fabrication of 8 inches and larger, yet the spool observed in the field had been only 6 inches in diameter.
The text of the purchase order allowed the vendor to grind welds no more than was sufficient, not to mask radiographic defects, whereas the specification stated that all l
welds requiring inservice inspection would either be ground smooth or l
given a flat-topped finish to allow ultrasonic examination.
The specifica-tion also required that each such weld be marked adjacent to the weld with a special means to allow accurate location of the root of the weld during later examination.
These requirements are essential to
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fulfill the requirements of ASME Section XI for inservice inspection as
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adopted by the NRC regulations.
The SRIC established during examination l
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of the welds outlined above, not only that the welds had not been 9.ound, but also that the weld center indicator was not present.
The SRIC also noted during review of the purchase order, that it contained no mechanism for identification of pipe spools for fabrication and, therefore, was not in compliance with site procedures for procurement control.
This matter was discussed with quality assurance management.
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The SRIC then inspected the records documenting the receipt of the spool onsite. He noted that inspection at source had been waived prior to shipment and that the inspection on receipt had failed to identify any anomalies with the spool.
This indicated to the SRIC that vendor control inspection had been less than effective in that the specification
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requirements had not been satisfied and that the anomalies had not been detected by QC.
The licensee developed information that indicated that the order was being administered by the site project engineering group rather than by the procurement control group, and that letters were being used to direct the vendors efforts rather than purchase order amendments, contrary to
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the requirements of CP-EP-5.0 " Procedure For Field Procurement." Thus, the licensee had violated Appendix B of 10 CFR 50 relative to both Criterion IV which requires that procurement documents specify directly, or by reference, requirements necessary to define acceptable quality; and Criterion VII which requires inspections to assure that vendors furnish required quality.
Since this matter was detected early in the inspection period, the licensee had time to initiate corrective measures.
These measures have included cancellation of CP-0701, with the subsequent issuance of CP-0701A to the same vendor with full definition of all quality requirements and a further stipulation that only purchase order amendments will be utilized as the means of specific fabrication I
direction.
Qualified radiographic interpreters have reviewed the l
radiographs of all welds in spools received to date and found all to be l
acceptable.
Each spool that requires inservice inspection has been identified and examined, and those requiring correction have been
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identified for rework.
The licensee's procurement department has performed an audit of all outstanding pruchase orders for evidence of noncompliance with the administrative aspects of Procedure CP-EP-5.0.
The SRIC has verified that the above corrective and preventative t
j steps have been implemented and has no further questions at this time.
8.
General Site Tours The SRIC toured the principal active areas of both Units 1 and 2 several times during the inspection period to ascertain the status of construction and the practices involved.
During the tours, the SRIC
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verified that the storage and maintenance of major components, including the reactor vessels and the vessel internals, continued to be adequate.
The SRIC also oberved limited cable pulling activities and those of personnel installing instrument system tubing runs.
The practices observed during these limited inspections were in accordance with good practice and site specific procedures. -The SRIC noted that the
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safety-related piping systems in Unit 1 are substantially complete from an erection standpoint with only a relatively few hangers yet to be installed.
Electrical cable installation also appears to be nearing completion in Unit 1 with-the bulk of the cabling yet to be installed involving the coaxial and triaxial cable utilized in the nuclear instrumentation system.
Unit 2 activities largely involve piping erec-tion and installation of electrical raceways.
No violations or deviations were identified.
9.
Management Interviews The SRIC met with one or more of the persons identified in paragraph 1 on
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February 1, 2, 3, 11, and March 9, 10, 12, 15, 17, 19, and 31 to discuss inspection findings, and the licensee's actions and positions.
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