IR 05000445/1984026
| ML20137M213 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/13/1984 |
| From: | Haughney C NRC |
| To: | Calvo J, Marinos E NRC |
| Shared Package | |
| ML20136F476 | List: |
| References | |
| FOIA-85-59 NUDOCS 8512030637 | |
| Download: ML20137M213 (51) | |
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Aserswel For Cleerence Per Conversetton
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For Cervoetion Propem Repy As Requested i
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U 00 NOT use tNs form as a RECORD of e els, concurrenc, die maois, clearances, and similar actmas l
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Document Neme:
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10/02-01 Recuestor's ID:
LEE
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Author's Nare:
Oberg/,i,i Document Comments:
Comanche Peak 50-445/84-26 Destination Name:
LEADOP Distribution Name:
NRCRIV_0P3_0020 Addressee:
Data Sent:
12/07/84 Time Sent:
11:06 Messace:
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P DEt.IVER TO:
V. NOONAN c/o D. Wessman FR 0:
D. HUNTER, REGION IV CONTACT: Gracie 728-8113
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Texas Utilities Electric Coneany-2-DDAFT In Reply Refer To:
DRAFT Dockat-50-445/84-26 Texas Utilities Electric Company ATTN:
M. D. Spence, President, TUGC0 Skvway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Gentlemen:
This refars to the soecial inspection of the Safeguards and Auxiliary Building durino the period of July 16, 1984, through September 28, 1984, of activities authorized by NRC Construction Permit CPPR-126 for the Comanche Peak Facility, Unit 1, and to the discussion of our findinos with you and other members of your staff at the conclusion of the insDection.
This insDection was the fourth in a series of planned construction completier room / area inspections, and the primary purpose of this inspection was to evaluate actuel at huilt status of the Safecunede and Auxiliary Buildino co cared to the desion and irtnactina oncumantation. This inspection covered ccnstruction characteristics, such as cable separation, workmanship, and as-built configuration, which have been the subject of allegations to the NRC; however, this inspection was not intended to achieve resolution of any specific allegation. Resolutior of specific allegations may involve additional
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inspaction in these areas, and nAy result in additional corrective actions.
Because tha insp*ction revealed a lack of certain OC inspection criteria and subsecuently identified significant numbers of deficiencies in the areas of electrical conduit separation, cable tray hangers, pipino suppnrts, base plate mounting, con'iguratinn, pipe clamps, and instrumentation tubing, additional correctiva actions are required. Tha deficiencies identifed by the NRC inspectors were based on a limited sample and revealed the failure to adequately install and inspect safety-related items. Your encrective actions taken and results achieved should include a program for independent review and inspection es erpropriate of all safety-related systems to ersure conformance with the drawings and specificatines. Nonconforming conditions identified shall be processed in accordance with established 0A program procedures, includino the determination of the generic implications of the deficiencies.
This program should be coordinated with the actions planned and taken as a result of the Technical Review Team.(TRT) finding's.
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Texas Utilities Electric Company-3-DRAFT Portions of four safety-related systems were examined during the inspection.
These included the auxiliary feedwater system (AFWS), containment spray system (CSS), cteponert cooling water system (CCWS), and the chemical volume and control systen (CVCS).
In addition, electrical separation was examined throughout the buildings. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspectors. These_ findings are documented ir the enclosed inspection report.
During this intrection, it was found that certain of your activities were in violation of NRC reouirements. Consecuently, you are required tn respond to these violations, in writina, in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2. Title 10, Code of Federal #egulations. Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely
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Dorwin R. Hunter, Chiaf Reactor Project Branch 2
Enclosure:
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1. Appendix A - Notice of Violation
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2. Appendix B - NRC Inspectinn Report 50 445/84 26
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ec w/ enclosure:
Texas Utilities Electric Company Texas utilities Electric Comoany ATTN:
B. R. Clements, Vice ATTN:
H. C. Schmidt, Manager President, Nuclear Nuclrar Services Skyway Tower Skyway Tower 400 North Olive Street 400 North Olive Street Lock Pox 81 Lock Box 81 Dallas, Texas 75701 Dallas, Texas 75201
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APPENDIX A NOTICE OF VIOLATION l
Texas Utilities Electric Company Docket:
50-445/84-26 Conanche Peak Steam Electric Station Construction Permit: CPPR-126 Based on the results o' an NRC inspection conducted during the perinc' nf July 16 throuch September 28, 1984, and in a
REGION IV==
NR'C Inspaction Report: 50 445/84-26 Construction Pernit: CPPR-l?6 Docket: 50 445 Category: A2 Licensee: Texas Utilities Electric Company i
Skvway Tower l
400 North Oliva Street J
Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Unit 1 Inscection At: CPSES, Unit 1. Glen Rose, Texas Inspection Conducted: July 16 - September 28, 1984 Inspectors:
C. R. ODerg, Reactor Inspector, RIV Task Force Date
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M. E. Skow, Reactor Inspector, RIV Task Force Da te
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Other Accompanyinp Personnel:
W. R. Bennett, Peactor Inspectnr, RIV Approved:
D. M. Hunnicutt Team Leader, RIV Task Force Date Insnection Summarv Insoection Conducted July 16-Septamber 28, 1984 (Report 50-445/84-26)
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Areas Inspected: 5pecial inspectinn of construction inside Unit I Auxiliary and Safeguards Buildings of piping and pipe supports, safety-related eouipment, electrical raceway and supports, as-built program, and instrumentation.
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Expanded insoection of the enntainment buildino included piping and pipe suoports, electrical conduit and supports, and instrumentation. The inspection involved 726 inspector-hours onsite by three NRC inspectors.
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Results: Within the areas inspected, two violations and one resolved item was icentified. One violation was identified in the electrical area pertaining to flexible conduit separation (445/8426-01, paragraph 9) and one violation pertaining to QC inspection of pipa supports and cable tray hangers (445/8426-02, paragraph 11).
An cutline of the report follows:
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-3-DETAILS 1.
Persons Contacted Principal Licensee Employees (TUGCO)
- L. F. Fikar, Executive Vice Presidert Engineering
- J. T. Merritt, Assistant Project General Manager
- B. R. Clements, Vice President Nuclear Operations
- F. L. Powers, Unit 1 Building Manager J. A. Dittmar, Assistant Building Manager
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- A. Vega, Site OA Supervisor L. M. Popplewell, Project Engineering Manager C. G. Creaner, I&C Engineer B. C. Scott, OA Supervisor
- C. H. Welch, Site QA Manager's Staff Brown & Rent (BAR1 S. Wagner, OC Inspector
J. Reynolds, Building Coordinator W. Young, Building Coordinator R. B. Kelley, Irstrument Superintendent J. B. Leutwyler, OC Supervisor J. Christansen, I&C Engineer D. Hanke, QC Irspector
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F. Colemen, QC Inspector
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J. W. Wythe, Lead I&C Engineer R. Siever, OA Group Supervisor
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Other Contractor Contacts R. E. Camp, Startup Mananer (InDell Corporation)
R. J. Vandergri#t, Startup (Westinghouse)
C. D. Bradbury, Plant Operations (Impell Corporation)
D. C. Snyder, Assistant Building Manager, (UE&C)
R. Moehler, Site Representative (Westinghouse)
The NRC inspectors also contacted other plant personnel including members of the construction, technical, quality assurance, and administrative staffs.
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- Denotas those attending the exit interview on September 28, 1984
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2.
Inscaction Qb.iectivas and Scope The objective of this inspection was to evaluate the completion of the Auxiliary and Safeguards Buildincs. This objective was accomplished by examining four safety-related systems contained within those buildinos.
Selected samples of instrumentatinn, piping, and components ware examined to ensure that the installation conformed with the FSAR comritments, approved desicn, and inspection documents.
The following systems were selected for review:
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Auxiliary Feedwater System (AFWS)
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Containment Spray System (CSS)
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Component Coolino Water System (CCWS)
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Chemical and Volume Control System (CVCS)
The selection of these systems was based on their importance to se.fety of operations and baing representative of the type of other safety-related systems installed in the Auxiliary and Safeguards Buildings.
Inspection of conduits, conduit supports, and cable trays was included. A selected number of cable tray supports were examined to gain additional information relative to the problem previously identified in the cortainment room inspection (see NRC Inspection Report 50-445/84-16).
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The major components, piping, instrumentation, and electrical portions of the 4 systems were contained in 17 rooms of the 2 buildings, as follows:
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Room Number Description
Containment Spray Pump Room (train A)
Component Cooling Water Drain Tank Room
Valve Isolation Tank Room (train A)
South Valve Ronm (train A)
RHR and CSS Heat Exchanger Room (train A)
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N-S Corridor
E-W Corridor
Motor Driven Aux. FW Pump Room (train A)
Motor Driven Aux. FW Pump Room (train B)
Turbine Driven FW Pump Room
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Valve Room 175 Heat Exchanger Room
179 Corridor 200 Centrifugal Charging Pump Room (train A)
203 Valve Room 205 Component Cooling Water Pump Room (train A)
206 Boric Acid Tank Room
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-5-Detailed inspection data sheets were prepared for each of the systems involved. These data sheets are included as attachments to this report.
While net rstry component ir each system was inspected, the number of items selected and inspected has permitted a broad overview of each system. A mere detailed discussion of the inspection scope is given below.
Auxiliarv Feedwater System The auxiliary feedwater system can supply high pressure feedwater to the
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steam generators following a loss of normal feedwater. The system is used in the event of a main steam line break, feedwater line break, steam generater tube rupture, and as an alternate to the main feedwater system during nnrmal hot shutdown, cooldown, and startup operations. Two motor driven pumps and one turbine driven pumo provide a suoply of feedwater.
Each ouep is located in a separate room in the Safeguards Building. The system is classified as nuclear safety-related and is designed to Seismic Category I requirements.
The condensate storage tank provides the normal source of feedwater. An alternate source is the service water system. Feedwater is supplied to all four steam generators. The auxiliary feedwater pumps start automatically after receipt of a signal indicating a main steam line break, a feedwater line break, or a loss of main feedwater pressure,.
Auxiliary Feedwater Dump Turbine Steam Supply Upstream of the main steam isolation valves, of steam generators No. I and No. 4, a four inch line is provided for supplying steam to the turbine
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drive of the auxiliary feedwater pump. Each line has an air operated,
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fail open valve which will admit steam to the turbine upon demand.
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For inspection purposes, the AFWS can be considered to be composed of several subsystems or areas.
Water sources (Condensate Storage Tank)
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Pump suction piping
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AFW pump 3 (2 electrical, I turbine driven)
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Pump discharge piping
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Instrumentation and instrumentation tubing
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Electrical power sources
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Main steam oiping to turbine driven pump
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Steam turbine exhaust pipino
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Valves and valva-operators
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Air supplies to valve operators
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Piping supports and restraints
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-6-This system was examined in greater detail than the other three systems in response to a commitment made to the CPSES Hearing Board by Region IV management. The inspection began at the water source and ended at the junctier between AFWS and Main Feedwater System (MFWS).
Portions of all the above areas in train B and the turbire driven pump were exemined in order to gain a comprehensive picture of the entire system.
Conteirment Sorav System (CSS)
The CSS has a dual function for removing heat and fission products from containment in a post-accident situation.
It is designed as two independent, redundant trains.
In addition to circulating spray water, the CSS provides, by a subsystem, the addition of sodium hydroxide into the spray water to maintain its effectiveness. A CSS train is principally composed of a motor driven spray pumo, a heat exchanger (cooled by the CCW system) and associated piping and valves. Only that part of train B outside of containment was examined during this inspection.
Comoonent Cooling Water System (CCWS)
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Tha CCWS is an intermediate cooling loop between radioactive or potentially radioactive heat sources and the ultimate heat sink water (station service water system). The CCWS provides cooling water to essential plant auxiliary components including containment spray pump heat exchangers, RHR pump seal coolers, safety-related chilled water seal coolers, and system condensers as well as control room AC unit condensers.
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The portion of train B contained within the safeguards and auxiliary building was examinad during this inspection. This included the CCW surge._
containment spray (CSS)g and valves, CCW pump, CCW heat exchanger, the tanks, associated pipin heat exchanger, and associated instrumentation.
Chemical and Volume Control System (CVCS)
The CVCS is designed to control and raintain reactor coolant inventory and
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to control the bornn concentration in the reactor coolant. Part of the CVCS is a beric acid makeup and injection system. The portion of that system included in this inspectinn included a boric acid tank, a boric acid transfer pump, associated piping and valves, instrumentation and one centrifugal charoing pump. The boric acid makeup and transfer capability is important to the overall CVCS system function.
In planning for this inspection, provisions for expanding the sample sira were made in case identified discrepancies were of sufficient significance or indicated a generic problem. Table (1) lists the inspection sample size.
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Supports /
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System Comconents Pipe (FT)
Restraints FT Tubing AFWS
650
14/406 CSS
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CCWS
300
5/115 CVCS
250
RCS 8/213 Other:
Cable Trays - 34 (I 275')
Cable Tray Suppor*
Conduits - 27 ( (Is - 35 725')
Conduit Supports - 156 3.
Status of Auxiliary and Safeauards Buildinos
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Ooan Items
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The Master Data System (see NRC Inspection Reports 50-445/83-23 and 50-445/84-10) is used tn monitor the status of open itens pertainino to tha Auxiliary and Safeguards Buildinas. From a data report dated Santamber 70, 1984, approximately 850 itens had been identified in the Auxiliary Building for completion. This number includes Unit 2 itens as well, since Units 1 & 2 share portions of the Auxiliary Building. Approximately 750 items had been identified in the Safeguards Ruilding.
Construction work and testing were being dona in these buildings durino the entire. NRC inspection; howaver, little work was being dona on the systens invnived in the inspection.
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-8-The " punch lists" items have been prioritized with five indicetions.
Fenm most urgent to less important:
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"Do It" (Requires Innediate Action)
SU Real (Startup Recuirement)
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OP Need (Needed for Operations)
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Pre-Fuel (Must be done prior to fuel load)
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Post Fuel (Can be delayed until after fuel is inaded)
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Tha vast majority of the itens are indicated as " post-fuel," or after fuel loading.
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Room Area Inspections Thera are 157 rooms / areas (NOTE: The total of 157 includes stairs and corriders) in the safeguards and auxiliary buildings that were subject to this room inspection.
In order to obtain a picture of the overall condition of these two buildings, the inspectors made an effort to enter and inspect as many rooms / areas as was practical.
The inspectors did enter 126 of these rooms / areas, or 80%.
It was observed that construction in all the rooms / areas was generally complete. The more detailed inspection of the selecteo systems (described in paragraph 2) provided a concentrated inspection of 17 roons. A small number of rooms still had work being performed, but it appeared to be local corrective rework.
Many of the same attributes of inspection discussed in other parts of this report were inspected here. The inspectors checked seismic pipe
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and electrical supports for general workmanship and completion;
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instrument tubing was checked for loose fittings and conformance to installation criteria; other items that appeared out of the ordinery were noted. The specific items noted are listed in Attachment H.
I Many items noted as deficiencies in other parts of this report resulted from detailed inspection to drawings. This inspection ses a walkdown without drawings and was not intended to identify protlens that would be found using drawings.
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Auxiliary Feadwater System (AFWS)
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General Insoection of the AFWS included a ma,ior portion of the associated water, main steam, instrumentation, and electrical subsystems. -
Inspection attributas are contained in the appropriate inspection data sheets. Items inspected and the results obtained are given ir tha following paragraphs.
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Conconent Inspection Inspection of the following AFWS components was conducted:
(1) Auxiliary Feedwater Pumos - Two Electric and one steam turbine driven pump are used in the AFWS. All three pumps were inspected. The installation, alignment records, procurement records, modifications, and applicable NCRs were examined. The major components in the auxiliary feedwater system were identified by physically compari.ng each of the major components to drawings, specifications and procurement documents. Train A is located in Room 72, train B is located in Room 73. The steam turbine and its integral pump are located in Room 74 Each rnom is separated by concrete walls, and each is secured from entry by a locked door.
Pump alignments, coupling alignments and modifications were documented on " travelers". All NCRs were satisfactorily closed.
The NRC inspector found that the AFW pumps, motors, and steam turbine were procured, installed, aligned, tested and made operable within the requirements and manufacturer's recommendations.
No deviations or violations were identified during this portion of the inspection. Specific items and documents reviewed are identified in Attachment A.
(2) Main Steam Valves - Selected valve installations were examined
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by the NRC inspectors. The AFWS turbine is supplied steam from two of the four steam generators. The valves listed below are
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on these two lines.
1-MS-101 Manual, gear operated gate valve 1-HV-245?-1 Air operated steam supply valve, loop 4 1-MS-144 Marual, gear operated gate valve 1-MS-128 Manual, gear operated gate valve 1-MS-137 Manual, gear operated gate valve The inspection included observation of the installed valves for general workmanships, conformance to vendor manual and drawings, and documents in the valve data package, such as installation travelers (see data sheets).
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The valves wara found to be installed in accordance with
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travelers and manufacturer's installation instructions.
Some minor problems were identified during the inspection.
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These were discussed with the licensee. The discrepancies and the licensen's action is indicated in Table 2.
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AFWS Pipine and PiDe SuoDorts Eighteen Brown & Root Hanger Location (BRHL) drawings were selected for an expanded reviaw of the AFWS. The BRHLs had 265 supports identified; 78 were inspected to the vendor certified drawings (VCDs)
and other QC inspection records in the documentation package. The findings of the inspection are documented on the inspection data sneets. Problems identified during the inspection were discussed with the licensee. The nature of those problems and the action takan by the licensee is indicated in Table 3.
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Instrumentation The following 14 AFWS instrumentation runs were selected for inspection.
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Instrument No.
2206-04-1-58(2 sheets)
1-PS-2470A 2206-06-1-70A 1-PS-2470B 2206-06-1-70B 1-PI-2469 2206-06-1-69 1-PI-2488 2206-07-1-88 1-PT-2455 2206-03-1-55 1-PI-2468 2206-06-1-68 1-PT-2477 2206-06-1-77 1-PI-2390 2202-05-1-90
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1-PT-2476 2206-06-1-76
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2206-01-1-57 (2 sheets)
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1-PT-2392 2202-05-1-92 1-PS-2454A
??O6-03-1-54A (2 sheets)
1-PS-2454B 2206-03-1-54B (2 sheets)
Specific problems identified in these runs are listed in Table 4 Action taken by the licensee on these items is noted.
As a result n# the artensive use made of instrumentation drawines.
_tne NRC inena-+ne identified a ennearn inunivino tha isnmatric er CCT Jnstrument drawino These drawings are generated by a draftsman and I&C Engineer from an examination of the as-installed instrument runs.
The instrument tubing runs are " field runs" fabricated and installed
.hv B&R I&C craftmen using installation criteria cenerated*by G&H.
These documents include:
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-11-2323-I-001 Seismic Tubing Support Package 2323-I-002 Criteria for Seismic Tubing Support Placement FSI-00069 Seismic Tubing Support. Span Lengths Drawing Series 2323-M1-2103, 2507, 2104 and others for instrument tabulations and instrument details.
The above items are controlled, design documents, issued through tha DCC. However, the FSIs are not controlled design documents and no QA program procedural requirements have been generated for them.
The TUGC0 I&C Engineer indicated that the FSIs were being produced as
"Information Only" drawings for operation.
(However, all drawings
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have been marked " Issued for As-Built") QC inspectors do not use the FSI for any purpose. All other materials, inspections, and design efforts come under the 10 CFR, Appendix B QA progran.
This item was discussed with the licensee. In response, the licensee has stated that the FSI drawings will have the "As-Puilt" notation deleted. A rote will be added explaining the information nature of the drawings.
This is considered an unresolved item pending completion of the actions by the licensee and review during a subsequent inspection.
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(445/8426-031
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The major AFWS components inspected were found to be installed / aligned correctly. There were minor itens found on two MS valves. The installed seismic Instrument Rack CPI-EIPRLI-31 had some welding and other ninor problems. Thirteen pipe supports were found to have one or more discrepancies. Six NCRs were issued by the licensee on pipe supports. Discrepancies were found on thirteen of the instrument runs reviewed by the NRC inspectors. The discrepancies included hardware and paperwork problems. Of specific concern was the uncontrolled issue of instrumentation FSIs.
5.
Centainnent Soray System (CSS)
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General Inspection of the containment spray system included a portion of one train involving a heat exchanger, a cump, piping and valve isolation tank, and motor operated valves. Sixteen piping supports were inspected.
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CSS Cnmorrent Inspection The following components were inspected in regards to completenass, workmanship and documentation.
CPI-CTATVT-01 Containment Spray Valve Isolation Tank CP1-CTAPCS-04 Containment Spray Pump CP1-CTAHCS-02 Containment Spray Heat Exchanget In general, the components were found to be installed in accordance with applicable drawings and vendors manuals. Specific problems found are shown in Table 5.
Of particular note was the power and instrumentation leads entering the spray valve isolation tanks. No permanent provision had been made for securing the leads away from the sharp edge of the electrical penetration pipe inside the tank. This item was identified to the licensee representative and was placed on the Master Data Base for action, c.
CSS Pioinc and Pioe Succorts
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Six Brown & Root Hanger Location (BRHL) drawings were selected for an expanded view of the containment spray system. The BRHLs had 62 supports identified; 16 were inspected to the vendor certified drawinos and other QC inspection records in the documentation package. The findings of the inspection are documented on the
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inspection data sheets of Attachment B.
Problems identified during tha inspection were discussed with the licensea. The nature of those problems and the action taken by the licensee is indicated in Table 6.
An item of importance is the missing welds on pipe suponrt CT-1-014-015-542K.
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Summarv One important item was not identified during the licensee's OC inspection - missing welds on pipe support CT-1-014-015-542K.
Another. notable problem was the hanging leads inside the valve isolation tanks.
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-13-6.
ComponentCoolineWaterSystem(CCWSJ
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Genei31 A portion of the CCWS was operational during inspection of components and piping. The part of the CCWS chosen for the inspectiori included a pump, three valves, piping, and a heat exchanger. Additions 1 inspection was conducted for CCWS pipe suppc-ts inside evntainment building, b.
CCWS Comonnents Installation The inspection of the components included the installation, electrical connections, workmanship and documentation. The components inspected include the following:
CP1-CCAPCC-02
. Component Cooling Water Pump CP1-CCAHHX-02 Component Cooling Water Heat Exchangers ICC-048/ICC-055 24" Wafer Trunion Valves 1HV-4575 Motor Operated Valve 1FE-4537A Orifice Plates (Inspected documentation package only)
Generally, these components were installed in accordance with the
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manufacturer's technical manual and applicable drawings. Some
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deficiencies were noted end are listed in Table 7.
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CCW Pipino and Pipe Supports
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Twelve Brown & Root Hanger Location (BRHL) drawings were selected for an expanded view of the component cooling water system, The BPHLs e
had 166 supports identified; 37 were inspected to the vendor h
certified drawings and other OC inspection records in the
-
documentation package. The findings are documented on the inspection
!
deta sheets of Attachment C.
Problems identified during the
r inspection were discussed with the licensee. The nature of those problems and the action taken by the licensee is indicated in
.
Table 8.
I f
d.
CCWS Instrumentation Y
.
Five CCWS instrumentation tube runs were selected for inspection.
One of t5e runs was in the containment building as an expansion to the inspection scope to determine if problems similar to those in the auxiliary and safeguards building existed elsewhere. The following runs were examined:
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-14-Instrument No.
FSI Number 1-FIS 3537A (LP & HP)
2229-04-1-37A-1 (2 sheets)
2229-04-1-37A-2 (2 sheets)
1-PI 4523 2229-03-1-23 1-PT-4521 2229-03-1-21 1-FT 4680 (LP & HP)
2231-01-1-80 No hardware problems were identified. Howevar similar problems with the FSI were identified. These are listed in Table 9.
This item is part of the open item regarding instrumentation FSIs.
e..
Surnarv The portion of the CCWS inspected was considered acceptable with the exception of those deficiencies listed.
7.
Chemical and Volume Control System (CVCS)
a.
General A portion of the CVCS was selected for inspection that included a bnric acid tank, a horic acid transfer pump, pipin'g and supports, and a centrifugal charging pump, b.
CVCS Comoonents Insta11atinn The following components were inspected:
--
TBX-C5ATBA-01 Boric Acid Tank
._
TBX-CSAPBA-01 Boric Acid Transfer Pump TBX-CSAPCH-01 Centrifugal Chargino Pump
_
Minor problems were identified on the charging pump and transfer
.oump.
Specific items are given in Table 10. The findings of the inspection are documented in the inspection data sheets.
Attachment D.
c.
CVCS Pioino and Pioa Supports Twenty Browr & Root Hancer Location (BRHL) drawings were selected for an expanded view of the chemical and volume control system. The BRHLs had 176 suoports identified; 47 were inspected to the vendnr certified drawings and other QC inspection records in the documentatinn package. The findings of the inspection are documented on the inspection data sheets of Attachment D.
Problems identified during the insn*ction were discussed with the licensee. The nature o' those prnblems and the action taken by the licensee is indicated in Table 11.
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d.
Summary Minor problems were identified while inspecting the CVCS components.
Nonconforming items were identified for two CVCS supports. Twn NCRs were issued by the licensee.
E.
Electrical Racewavs and Succorts This section of the report contains information regarding the inspection of cable trays, conduit runs, and their associated supports. Specific problems identified are contained in Table IP.
,
a.
Attributes Attributes for inspection are identified on the specific inspection data sheet. The following paragraphs give a detailed description of
'
these attributes:
_
Color Coding - Safety-related trains are indicated by the color as indicated below:
.
I
"A" train - orange - 0
!
Associated "A" train - orange with white stripes
"B" train - green - G Associated 'B" train - grean with white stripes
__
._
"C" trein - black - K - non-Q Instrument Channel I - Red-R Instrument Channel II - White-W Instrument Channel III - Blue-B Instrument Chennel IV - Yellow-Y Cable trays and conduits are marked with unioue identification numbers which include a train or color code designation. The use of color code assisted in the determination of acceptable
,
saparatinn achievement.
Documentation - review of installation and inspection records to
-
- nsure that these records document the as-installed raceway and supports, and aar*e with the current approved design information.
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Type and Size - This certains to the type and size of conduit or cable tray including fittings, splices, pull boxes, covers, offsets, and fasteners.
-
Trav covers - Installed as required or identified as an opar iten.
-
Grounding - Installed as required on all receways. This grounding is primarily for personnel protection.
-
Craftsnanship - All fasterers proper 1v installed, raceways free of sharp edges and burrs, Galvinox protection, raceways free of damage, overall integrity of raceways, and proper bending of conduit. In addition, note was made of correctness of craft functions such as appropriate and adequate use of cable ties, crimping of connections, correct and clear identification of the cables, bend radius of cables, and surface condition of cable.
-
Identification - Raceway identification and train or channel identification at each 'end and at the proper intervals in between as specified in IEEE 384
_
Supports - Proper type and spacing of raceway supports, material size and dimensions, welding, structural attachments, raceway attachments, location, bolt size, and spacing.
b.
Electrical Raceway and Raceway Supports
_
The NRC inspectors selected sections of cable tray for inspection.
.-
The specific raceway sections inspected are identified on the raceway inspection data sheets of Attachment E of this report.
.
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The NRC inspectors exanined 35 cable tray sections, 34 cable tray supports, and approximately 225 feet of cable tray.
Two cable tray hangers (CTH) were found to deviate from their associated drawings. CTH 639 was missing a diaconal brace.
In response, the licensee issued non-conformance report (NCp) number M84-100470. CTH 12416 was shown on its FSE-00159 sheet, FSE-00176 and on drawing 2323-El-0601-01-5 as the horizontal leos being aligned east-west.
It was installed with a north-south alignment.
In response, the licensee issued NCR M84-100476.
c..
Electrical Conduit and Conduit Suponets
.
The ND.C inspectnrs physically walked down and inspected 29 conduit runs and approximately 156 conduit sucports, totaling approximately 725 linear feet of conduit. The NRC inspectors utilized the current approved derign information and the latest OC inspection report to determine the adequacy of installation and accuracy of documentation.
,
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-17-The clamp attaching the conduit to support C14B13160-5 was loose.
NCR MS4-100469 was issued to document this finding. One of the Hilti bolts on C14010056-2 was not flush with its associated nut. NCR M84-100471 was issued. Conduit support C14015121-3 was deleted and this was not properly documented. Other Component Modification Cards disagreed about the conduits size and indicated that some support types (CSM18c) should be installed. There were none used. NCR M84-100472 was issued to resnive these documentation deficiencies.
9.
Electrical Seoaration The NRC inspector conducted an inspection in the Auxiliary and Sa'equards
Building of Class IE circuit separation. Separation criteria for Class IE circuits for CPSES is contained in IEEE-384-1974 (draft). Typical separation details for cables and raceways is contained in G&H drawing
2323-El-1702-02. This drawing was based on the Electrical Erection Specification 2323-ES-100. Section 4.11 " Separation Criteria". Additional criteria for separation is contained in Section 4.4 of this specification.
The criteria contained in the above document was used as basis for exanining train separation.
Within the buildings, several rooms were selected for close inspection.
The rooms selected and the specific details of the inspection are included in Attachment H.
The discrepancies identified in the data sheets are not a complete list, but rather examples of the different types of discrepancies found.
In total, these discrepancies represent a generic separation problem with
--
flexible conduits. The flexible conduits could have met separation
,_
recuirements.at the time they were inspected by QC. However, because of their flexibility, the conduit can be moved to violate separation requirements. The details listed show examples where conduit had moved or; could easily be moved to positions violating separation requirements. As an example of how this movement could occur, the NRC inspector observed an individual cleanino in the area of safety-related flexible conduit and noted him moving them as ha cleaned. When questioned, the person said he
-
had nnt received any direction or training relating to precautions for noving flexible conduits.
Sectinn 4.4.6 of Specification 2323-ES-100 states:
,
.
"In no case shall any part of the conduit or the conduit support system cnme in direct contact with uninsulated equipment in the piping system or with pipe restraints or anchors." In addition, Section 4.11.3.2 of.
2323-ES-100 specifies separation between ennduits of different trains is one inch minimum for the examples listed.
.
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.
-18-01-OP-19.5-1, Section 3.5, implements the electrical and mechanical separation requirements.
01-0P-11.3-23, Section 3.9 specifies conduit separation per drawing 2323-El-1702-02, which includes several deteiled sketches. This erection specification and QC inspection procedures describe conduit separation recuirements, but do not recognize the possible loss of separation if the conduit is moved within it arc of flexibility.
.
01-0P-11.3-29.1, Revision 16, paragraph 3.1.7, states in part:
"In no case shall any part of the raceway or raceway support system come
,
in diract contact with uninsulated ecuipment in the piping system or with pipe restraints or anchors unless otherwise approved by the owner."
01-0P-11.1-28, Revision 25, paragraph 3.3.4.2, states in part:
"There shall be an air gap (i.e., no contact) between electrical conduit / conduit supports and piping component supports."
Specific examples of violations of these requirements are listed in Table 13.
,
In addition, scope 7.nd generic aspects o' this problem were not reccanized by the licensee until identified by the NRC inspector.
The failure to provide adequata OC inspection criteria and failure to meet minimum separation as rcquired is a violation of Criterion V of Appendix B
__
to 10 CFR 50 (445/8426-01).
._
NOTE: Generic NCRs for the electrical to electrical separation problem
.
identified above have been issued and corrective action has started.
-
Unit 1 Structura NCR Number
.
Safeguards Buildino E-84-1003095
,
Deactor Containment E-84-1003105 Service Watar Initial E-84-100311S Control Building E-84-1003125 Auxiliary Building E-84-1003135 Fual Ruilding E-84-1003145
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Disposition of these NCRs is as follows:
Part 1: A team consisting of Engineering, QC and craft shall perform a walk-down of the buildings to identify any specific cases where flexible crnduits could inadvertantly be moved and causa e separation violation.
As these cases are encountered during the walk-down, OC shall documant the problem on an electrical separation deficiency report (figure 2 of 01-0D-11.3-291 and Engineering will provide a disposition for each.
The na.iority of the problems can be resolved by installing a mechanical separator as shown in DCA-20,721. In these cases, after Engineering disposition of the deficiency report, craft shall install the separator and OC shall inspect the installation. Any remaining items will be handled en a case-by-case basis with an NCR hold tag attached to the affected raceway (s).
Upon completion of the walk-down, a part 2 disposition will be issued to document all violations found. This will be accomplished by attaching the deficiency reports to the NCR and sorted by room number.
DCA 20,721, Revision 1, dated September 18, 1984, approved a method for r.aintaining minimum separation distance between flex conduits of different trains / channels.
10. Reactor Coolant Instrumentation (Containment Building)
--
The inspection plan for instrumentation was expanded into the containment buildino to determine if problems similar to those identified in the
..
Safeguards Building existed in other areas. The following instrument runs were examined:
_
_
Instrument No.
2250-04-1-34 1-FT-434 (HP)
2250-04-1-34 1-FT-436 (LP)
2250-04-1-36 1-FT-436 (HP)
2250-04-1-36 1-FT-424 (LP)
2250-04-1-24 1-FT-424 (HP)
2250-04-1-24 1-FT-426 (LP)
2250-04-1-26 1-FT-426 (HP)
2250-04-1-26 These included approximately 213 feet of tubinc and 94 supports.
-
No hardware problems were identified. However, similar FSI problems to those specified in paragraph 4.d. were identified. These are listed in Tabla 14 This item is part of the unresolved item regarding instrumentation FSIs (see paragraph 4.d.).
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-20-11. OC Insoection Criterion X of Appendix B to 10 CFR 50 requires that the inspection program of activities affecting quality shall be established and conducted in a manner to verify conformance with the documented instructions, orncedures and drawings.
Several examples have been identified in other sections of this report that show failure of QC inspectors to identify nonconformances. Those nonconformances are detailed below along with the specific procedure that was violated.
a.
Cable Tray Hanger, CTH 639, was missing the diagonal brace called for on drawings 2323-El-0601-015 and 2323-5-901. 01-0P-11.10-2, Revisinn 28, paragraph 3.1.4.2, Configuration, states:
"The OC Inspector shall verify the completed support is in accordance with the design drawing and applicable design change documents. This verification shall include the following attributes:
a.
Support type b.
Support Member (s) shape (i.e., angle, channel, etc) and size c.
Location of members in accordance with design drawing dimensions including " work points" when shown"
__
.-
b.
Cable Tray Hanger, CTH 12416, had the horizontal legs aligned north-south vice east-west as called out on drawing 2323-El-0601-015 _
and FSE-00159 sheet 12416. 01-Qp-11.10-2, Revision 28, paragraph
-
3.1.4.1, Cable Tray Drawings, states:
"The OC Inspector shall use the FSE-00159 oniv for location of cable tray hanger, verify hanger unique number, and hanger elevation unless directed by the engineer and a Design Change Document regardless of the referenced document."
c.
The pipe suoport of drawing CT-1-014-015-542K was missing two welds.
Other weld deficiencies were noted on AF-1-026-005-533R, MS-1-026-010-575K, and instrument rack CP1-EIPRLI-31.
01-QAP-11.1-28, Revision 25, paragraph 3.5.5.1, Weld Inspection, states:
,
"The fillet weld size shall be as specified on thc drawing
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Base plate Hilti location dimension discrepancies were noted for Drawings AF-1-035-037-Y33R, AF-1-035-034-Y33R, and MS-1-028-047-543K.
01-QAP-11.1-28, Revision 25, paragraph 3.3.1.1, Installation Tolerances, subparagraph 2 states:
Hole location
- 1/4" or as shown on the design drawing e.
Dimensional discrepancies were noted for Orawings AF-1-026-003-533R, CC-1-011-034-A63K CC-1-043-013-A43K, MS-1-026-010-575K.
CC-1-236-700-C53R, CC-1-234-700-C53R, MS-1-025-003-R7EX.
CS-1-AB-208a-001, CC-1-238-004-C53R, CS-1-554-706-A33R.
i 01-0AP-11.1-28, Revision 25, paragraph 3.3, Material Dimensional Control, states:
,
"The completed hanger shall be inspected to ensure compliance with the dimensional sketch on the hanger drywing."
f.
The pipe clamp of drawing AF-1-103-036-553K was resting on the adjacent floor penetration pipe. This could have caused the penetration pipe to suoport the system pipe. This violated 01-0AP-11.1-28 Revision 25, pargraph 3.3.1, which states in pPrt:
" Fabrication and installetion shall be performed in accordance with the drawing detail...."
,
g.
Conduit support C140-10056-2 had a Hilti Bolt with insufficient thread engagement. 01-0P-11.2-1, pef.16, paragraph 3.3.5 states in
__
,
part:
.-
"The engagement of the nut shall be such, that after torquing,
_
the erd of the bolt is not lower than flush with the top of the -
nut."
h.
The instrument tube from 1-FT-2488 (HP) touched a pipe support at a 90' berd about 4' 2-3/4" from valve IAF-0039. QI-0P-11.8-5, Revision 14, paragraph 3.4.1.1 states in part:
"The QC Inspector shall verify proper air gap. The minimum air gap spacing shall always be 1/8 inch to allcw each instrument sensing line to expand independently at all bends without striking adjacent sensing lines, other equipment, concrete or st**1 building members."
.
The tables included in the precading sections of this report provide
,
details of the specific conditions noted, the tables also note the specific initial actions taken by the 1.icensee in response to these conditions, such as listing the NCR number that was generated.
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The failure to properly inspect quality attributes to the requirements is a v olation nf Criterien X of Appendix B to 10 CFR 50 (445/8426-02).
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17. Unresolved Items
,
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Unresolved items are matters about which more infomation is required in
crder to escertain whether the items are acceptable or not. One unresolved item identifieo in paragraph 4.d. of this report (445/8426-03).
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13. Exit Interview
!
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l On September 28, 1984, the NRC inspectors and other members of the Recion
!
IV staff including the Resident Inspectors met with the licensee personnel
denoted in paragraph 1 of this report. The NRC inspectors discussed the findings of this report. The licensee acknowledged the unresolved item
and the items o' noncorpliance.
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Tahic 2 SYSTFM: AFWS Components
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ITEM DESCRIPTION LICENSFE ACTION l-MS-137
Packing gland appears to be resting on the bonnet with no Has been listed on Master
room for more tightening of the packing. The packing gland Data System item #01975, retainer is not tight on the packing gland. The packing and fixed.
gland retainer nuts are painted over.
Saismic Instrument rack CPI-FIPRLI-31 1.
Mark Box "0" holts / nuts not fully engaged on the rack side.
1. Issued NCR E84-1005165 These bolts hnid the terminal strips inside the box, not the box to tha rack.
2.
Label missing at the top of the rack for 1-PI-2488.
7. Label replaced 3.
U-bolt missing at the upper valve for 1-PS-2470A.
3. Will he reinspected per IR #1-1-0054422 j
4.
Section "C-C" upper right - The stitch weld 3/16" 3"-7]"
4. NCR I-84-1004935 issued is only 2" to 2)" long.
5.
Section "C-C" center right - The stitch weld 3/16" 2" - 6" 5. NCR I-84-1004935 issued is only about li to ll" Inng.
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Table 3 SYSTEM: AFWS Pipe Supports ITEM DESCRIP110N LICFNSEE ACTION AF-1-035-037-Y33R: Base plate Hilti dimensions not correct.
NCR-M 14,680N issued to Rev. VCD AF-1-035-034-Y33R: Base plate locations for Hilti anchors NCR-M 14,679N issuad to are not IAW VCD (rev 4) (21/8" vs 1 1/16" on VCD).
Rev. VCD AF-1-026-015-533R: Sway strut hinding.
Fixed AF-1-026-003-533R: VCD calls for max 1" grout.
I 1/P" arout exits.
VCD to be corrected -
-
AF-1-103-036-553K: Pipe clamp is resting tight on floor penetration pipe.
Snubber is not level.
NCR-M 14,756N issued AF-1-102-013-533R: Sway strut not level, outboard bearing NCR-M 14,757N issued
,
dislodged.
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SYSTEM: AFWS Pipe Supports
'
ITEM DESCRIPTION LICENSEE ACTION
.
&
AF-1-102-028-S33R: 2 broken cotter kevs.
Keys have been replaced.
MS-1-026-010-575K: (Class 5) Oversized holes found in items 4 & 5, NCR M-15150 issued
'
tube steel (4x4), holas should be 1 5/8", approx 1"+
'
oversire.
t MS-1-028-047-543K: Hilti bolt placement dimensions not in NCR M-14,84?N issued
!
accordance with drawing; upper right bolt of base plate t
(item 4) 3/8" more than stated. (tolerance i 1").
!
MS-1-025-009-R75K: Upper right Richmond insert indicated NCR M-15151 to Rev. VCD
,
l as 1 1/16" hale; a 11" Richmond insert exists.
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Table 4 SYSTEM: AFWS Instrumentation ITEM DESCRIPTION LICFNSFE ACTION 1-FT-2458 (HP): Line touches pipe support at 90* bend Fixed
,
approx 4' 2-3/4" from 1AF-0039 (EL805'4").
':
1-PI-7469: Loose bolt on T092D1 suppart, first from 1AF-0147 Fixed FL 796' 9".
,
,
1-PT-2455: (a) Test tee below instrument was not shown on DWG.
(a) Fixed (b) A loose nut & bolt was found on T03P2025 support 2' 1/8" (b) Fixed below valve HAG-25-6.
1-PI-2468: (a) The span between the first two supports off root (a) Fixed valve AF-145 has been stepped on and bent.
(b, c, and d) FSI Resolution
'
(b) Unions between last two supports before instrument will delete "as-built" nota-rack not shown on FSI.
tion on FSI drawings and add (c) The forth 3D support form Root Valve has a loose nut, disclaimer note.
(d) As-build and specified tube span lengths do not agree.
.
DIM. from as shown root v1v en FSI as built 2nd 7 3/4" 10" 4th 7 3/8" 3"
Sth l' 6 1/8" l' 7 1/2" 1-PT-2477: Elbow fitting innediately above root valve IAF-0035 FSI Resolution
'
is not shown on FSI.
1-PI-2390: (a) The first support back towards the root valve (a) Fixed IMS-0164 from the tee is loose.
(b) The second span from root valve IMS-0164 has less than 1/8" clearance (b) Fixed
,
from ae adjacent support and can easily touch it.
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Table 4-2-SYSTEM: AFWS Instronentation ITEM DESCRIPTION LICENSFE ACTION 1-PT-2476: The 3' 1-13/16" span between the first two supports fixed from rnot valve AF-026 has been stepped on and bent.
1-FT-2457 (HP): (a) 45" offset not shown on FSI af ter 3rd (a and b) FSI Resolution support from root valve AF-053.
(b) Union not shown on FSI, 2nd support from instr. rack.
1-FT-2457 (LP):
<5* off sets not shown on last span from root FSI Pesolution valve to p, int "B".
1-PT-2392: Last support from root valve 1-MS-0288 before Fixed
,
i the tee was loose.
,
j 1-PS-2454 A A B: (a) There are two check valves on the "A" FSI (a) Correct per DWG TNE-MI-2120-01
'
whict are labeled 1-AF-221 and 1-AF-222. As built, they
have 10 tags showing 1-AF219, and 220 respectively.
>
The "B" FSI does not identify its two similar check valves, but the valves have ID tags installed which were supposed to be on the CH "A" valves.
(b) CH "A", there is a 6)" length shown entering an air (b, c, d, and e) FSI operated valve assembly on sheet I that is 4 3/4" as built.
Resolution
.
(c) CH "B",, at the valve in the tube upstream of the two
!
check valves on sheet 2, the upstream length is shewn on i
the FSI as l'1",
it is 5" as built.
(d) The length downstream from the same valve above, is shown as 2 9/16", it is Si as built.
(e) The tubing'from the tee adjacent to Pt "A" leading to tha fisher controls on valve 1-PV-24548. Starting where
-
the tube starts to run horizontal f, rom the wall along what the FSI shows as 10 5/8", the tubino devitates from the FSI in routing and lengths of run. There is no resemblance upon which
~
details can be compared.
.
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Table 5 SYSTEM: CS Components ITEM DESCRIPTION LICENSEE ACTION CPI-CTATVT-01, containment spray valve isolation tank:
electrical leads hanging by a plastic strap. The strap Put on Master Data Base could easily drop from its catch point and leave the wires draped over a sharp edge.
- CPI-CTAPCS-04, containment spray pump S/N 15210088; conduit C14K30963, attached to pump, brace missing.
Has been put on Master Data Base
.
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Table 6
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SYSTEM: CS Pipe Supports ITEM DESCRIPTION LICENSEE ACTION CT-1-014-015-542K is missing two welds. They are both 5/16" NCR M-14,722N issued fillet welds 2" long. They shoulit be located at the top and bottori of the base plat.e (shown in section A-A of the support drawing) at the imbedded plate.
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Table 7
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SYSTEM: CCHS Components LICENSEE ACTION ITEM DESCRIPTION
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_
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CPI-CCAPCC-07, component cooling water pumpS/N 14210677 a.
Ground wire from motor to feeder conduit has approx.
a. Non-9, fixed 40% of Strands out of clamp.
(C11G08174)
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b.
1" Flex conduit (Cl3G08451) has ymall hole in sheath b. NCR E84-100,4925 issued cover about 2" above 45* fitting..-
-
.
,
/' :
' ~,, J:.-
FI'ex conduit (C11608174) has a small tear above 45'
c. NCR E84-100,4915 issueU
/
/
'
-
-blend aboyt 5".
'
-
1-CC-048:
a.
Rust Present (not excessive)
a. Non-Q, Fixed b.
difficult to get to, no ladder provided b. Non-0, will be looked at during STA 802 walkdown
,
1-HV-4575, Motor Operated Valve a.
Position indicator badly bent a. Not critical - valve is either
"
'
open all the way, or shut b.
Screws on electrical cover not snug and lock washers b. On MDS Item 7795
,
appear to be missing c.
Conduit separation violations (C13G04311 & Cl2G04691)
c.
NCR-E84-100,490S fixed a broken conduit laying on handwheel, touching motor / gear housing fitting on conduit C13G04311, during this repair the separation problems were fixed.
d.
Ground cable loose at ground lug on motor / gear box housing d. Nnn-0, Fixed j i e.
Unit needs cleaning / painting e. Non-Q, fixed
.
.
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+
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-
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.
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Table 8
.
SYSTEM: CCW Supports *
ITEM DESCRIPTION LICENSEE ACTION
'CC-1-234-700-C53R, sheet 2, section C-C: The lower attachment bolts NCR 15147 issued to rev.
are 3.15/16" apart vice the 51" shown. The upper bolts are VCD 3 7/8" apart. It should be noted that this problem is the result of conflicting dimeesions. The plate is 8" wide.
The bolt of CL: are to be 2" minimum from the edges of the plate.
The remaining bolt separation then may only be 4" maximum.
(in Containment)
CC-1-238-004-C53R: The 6" dimension from pipe CL to the S.E.
NCR 15148 ussued to rev.
strut is 7 7/8" as built. The strut separation at the oppesite VCD end from the pipe is 8" vice 9" shown.
(in Containment)
CC-1-236-700-C53R: This support attaches to an existing support NCR 15149 issued to rev.
with a 5" overlap of vertical members, per plan. However, the VCD vertical distance shown from pipe CL to the bottom of the existing i
support of 21 5/8" is the measurement from pipe CL to the top
!
of the 5" overlap as installed.
(Drafting Error)
(in Containment)
CC-1-Oll-034-A63K, The 2' 7" distance from the wall to the snubber connecting pin CL is 2' 5 1/8" as installed.
NCR M-li,745N issued CC-1-043-013-A43K: The dimension from the wall that is NCR M-14,744N issued shown as 7'3" is 7'5".
,
.
.
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-
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.
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.
.
Table 9 SYSTEM: CCW Instrumentation
.
ITEM DESCRIPTION LICENSEE ACTION FSI-2229-04-1-37A-1: The distance from component IFIS-4537A FSI Resolution
'
to valve assembly FAQ 27-6 is shown on sheet 1 (LP) as 10 3/8" and on sheet 2 (HP) as l'0".
Both lines run side by side and are the same length, 10 3/8" as built.
FSI-2229-04-1-37A-2: The last span entering valve 1-CC-0051 is FSI Resolution j
routed differently than shown on the FSI.
4
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Table 10 SYSTEM: CVCS Components ITEM DESCRIPTION LICENSEE ACTION Boric Acid Transfer Pump, TBX-CSAPRA-01: Room 79 a.
Boric acid solution is seeping out of drain valve (1C5-075)
a. on Master Data Base, has and through instrumentation connections.
heen fixed b.
Rear holt is not tight, the lock washer not compressed, b. Traveler issued to inspect
'
and tighten as reouired c.
Drain valve 1C5-075 (and others) not over drain.
c. Non-0, SWA 23317 will fix
,
d.
Equipment drain has lip (about 1") preventing water d. Non-Q, SWA 73317 will fix from draining.
,
i '
t i
Centrifugal Charging Pump, TBX-CSAPCH-01: Room 200 a.
Lo to Temp Probe - Cl3K13847 conduit loose.
a. Non Q-Fixed
,
i i
b.
L. O. pressure gage line out of support.
b. Fixed c.
Cl4K30590 resting on probe protection bracket. iiole c. Non 0
,
could result.
d.
Ground cable hanging in air.
d. Non Q-Fixed
,
l e.
C14K30591 conduit loose in coupling.
e. Non Q-Fixed
!
f.
C12K05018 LBD loose, f. Non Q-Fixed g.
Valve ISW-408 flange - Strainer Drain; 1 nut bolt 9. on MOR subsystem 0402 item
,
-
not flush with nut top.
POSS
,,
,
f
',,
h.
Coupling cover bolt on 1 leg not installed, h. Non 0-Fixed
.
.
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.
-
-
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-
..
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. -.. -.
.
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.
.
.
Table 11 SYSTEM: CVCS Supports ITEM DESCRIPTION LICENSEE ACTION CS-1-AR.20RA.001:
Thel'0"fREF)dimensionforthedistancefroman NCR M-14,713N issued to a.
adjacent bracket is only 9 7/8" as installed.
change VCD b.
The 3)" dimension form the same adjacent bracket to the NCR M-14,713N issued to
-
near end of pc 1 is ll" as installed. This appears to change VCD have been created by NCR #AM-01001.
CS-1-564-706-A33R: The distance from the wall to the CL of NCR M-14,71?N issued to the joint of the perpendicular member and diagonal brace change VCD is 2'10" vice 2'8" as installed.
.
.
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Table 12 SYSTEM: Electric Cable Trays (supplemental)
Room 65 - Safeguards ITEM DESCRIPTION LICENSEE ACTION CTH 639: The diagonal brace shown is not installed.
NCR M84-100470 issued CTH 12416:
The structure is rotated 90* to a North-South NCR M84-100476 issued alignment.
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Table 12
.
SYSTEM: Conduit (supplemental)
-7-ITEM DESCRIPTION LICENSFE ACTION C14910056-2: One of the Hilti bolts not flush with its NCR M84-100471 issued associated nut.
C14915121-3: Conduit not attached to suponrt.
NCR MP4-10047? issued
.
C14915121: CMC 64790 specifies 1" conduit and 2 supports NCR M84-100472 issued
.;
j built to S-910 drawing CMC 18c specification. Cl4015121 is I
in fact 1)" conduit and no CSM18c supports are in the
.'
conduit run. Two separate inspection reports, however, did reference CMC 64790 014B13160-5: Clamp attaching conduit to support was loose.
NCR MR4-100469 issued i
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._. _
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.
,
.
.
.
Table 14 SYSTEM: Reactor Coolant Instrumentation (Centainment)
ITEM DESCRIPTION LICENSEE ACTION FSI-2250-04-1-34: Elbow fittings on both lines at the instrunent FSI Rosolution are not shown on the FSt.
FSI-2250-04-1-36: Elbow fittings on both lines at the instrument FSI Resolution are not shown on the FSI.
Union between the first two supports from valve 1-RC-6061C j
are not shown on the FSt.
'
FSI-7250-04-1-24: Sheet one shows the lines leaving the FSI Resolution instrument on the horizontal for 41" then turn down.
The elbow is not shown on the FSI. Sheet 2 shows both lines leaving the instrument going down. They are not
.
consistent.
'
-
!
Valve FAQ27-23 is shown on sheet I as FAQ27-33
FSI-2750-04-1-26: Elbow fittings on both lines at the instrument FSI Resolution
'
are not shown nn the FSI.
Union below first support below valve HAG 22-21 not shown.
Union below first support below valve HAG 23-22 not shown.
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I l
TABLE OF CONTENTS i
DETAILS
.
1.
Persons Contacted
.
2.
Inspectinn Ob.iective and Scope
]
3.
Status of Auxiliary and Safeguards Building I
l a.
Open Item
<
j
,b.
Roons Inspected f
i
Auxiliary Feedwater System (AFWS)
a.
General
.
b.
AFWS Component Installation
}
c.
AFWS Piping and Pipe Supports
<
d.
AFWS Instrumentation j
,'
e.-
Sumary
,
5.
Containment Spray System (CSS)
J a.
General
_
<
..
b.
CSS Component Installation
<
-
!
c.
CSS Piping and Pipe Supports
-
i j
d.
Sumary l
6.
Component Cooling Water System (CCWS)
a.
General b.
CCWS Comoonent Installation c.
CCWS Piping and Pipe Support
j d.
CCWS Instrumentation
-
e.
Sumary i
,
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,
.
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-2-7.
Chemical and Volume Control System (CVCS)
a.
Ger.eral b.
CVCS Component Installation I
c.
CVCS Piping and Pipe Supports d.
Summary 8.
Electrical Raceways and Supports 9.
Electrical Separation 10. Reacter Coolant Instrumentation (Containment Building)
11. OC Inspection 12. Unresolved Item 13. Exit Interview Attachments A
Auxiliary Feedwater System (AFWS)
B Containment Spary System (CSS)
C Component Cooling Water System (CCWS)
--
._
D Chemical & Volume Contrni System (CVCS)
E Electrical Raceways and Supports F
Electrical Separation G
Reactor Coolant Instrumentation H
Miscellaneous
.
.
.
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.
Table 13 SYSTEM Electrical Separation FLEXIBLE CONDillT ITEM DESCRIPTION
>
NUMRER Cl3G07743 Flex rests on pipe bracket t'o valve 1-HV-5365.
Cl3G07744 Flex rests on pipe bracket next to valve 1-HV-5365.
C14P21161 Flex rests on pipe support for 1-MS-030 and 1-MS-268.
C13G12499 Flex rests on support for JRIS 455G.
Cl3G08781 Flex touches corner of support for valve 1-HV-4179.
C12P05387 Flex touches pipe at elbow passing near valve 1-HV-8106.
Cl3P15915 Flex resting on top of actuator for valve 1-HV-2188.
Cl3G21323 Flex touching flange of support next to valve 1-FV-2196.
Cl3G06734 Flex rests against unistrut below valve 1-FV-4537.
,
C12G04690 Flex conduit rests on fire pipe.
Cl3G06834 Flex wraps around adiacent support.
Cl4G20503 Flex rests on valve body.
- ,
,;
Cl2902856 Flex contacts 1-HV-2480.
!j Cl3907415 Flex touches the mounting bracket for the limit switch
from Cl3G07413.
1" airspace between the two trains of
,i flexible conduit not maintained.
!
Cl3G20208 Flex contacts C13911132 flex.
,
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.
In Reply Refer To:
Docket: 50-445/84-26
.
Texas Utilities Electric Company ATTN:
M. D. Spence, President. TUGC0 Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Gentlemen:
This refers to the special inspection of the Safeguards and Auulliary Rullding
,
during the period of July 16, 1984, through September 28, 1984, of activities
,
authorized by NRC Construction Permit CPPR-126 for the Comanche Peak Facility, Unit 1, and to the discussion of our findings with you and other members of your staff at the conclusion of the inspection.
.
i
'
This inspection was the fourth in a series of planned construction completion
!
room / area inspections, and the primary purpose of this inspection was to
evaluate actual as-built status of the Safeguards and Auxiliary Building
- i compared to the design and inspection documentation. This inspection covered i
construction characteristics, such as cable separation, workmanship, and as-huilt configuration, which have been the sub.iect of allegations to the NRC; however, this inspection was not intended to achieve resolution of any specific allegation. Resolution of specific allegations may involve additional inspection in these areas, and may result in additional corrective actions.
,
Because the inspection revealed a lack of certain OC inspection criteria and subsequently identified significant numbers of deficiencies in the areas of
'
electrical conduit separation, cable tray hangers, piping supports, base plate
,
mounting, configuration, pipe clamps, and instrumentation tubing, additional corrective actions are required. The deficiencies identifed by the NRC inspectors were" based on a limited sample and revealed the failure to adequately install and inspect safety-related items. Your corrective actions taken and results achieved should incluqg a program for independent review and
-
,.
inspection as appropriate of all safety-relathd systems to ensure conformanca
with the drawings and specifications. Nenconforming conditions identified
,
shall be processed in accordance with established 0A program procedures,
including the determination of the generic implications of the deficiencies.
This program should be coordinated with the actions planned and taken as a
-
_
-
-
>
_
_ _ _ _ _
.o a;
,
Texas Utilities Elect.-ic Company-7-Portions of four safety-related systems were examined during the inspection.
Thesa iccluded the auxiliary feedwater system (AFWS), containment spray system (CSS), cnmponent cooling water system (CCWS), and the chemical volume and control system (CVCS). In addition, electrical separation was examined threughout the buildings. Within these areas.- the inspection consisted of selective examination of procedures and representative records, interviews with personr.* 1, and observations by the inspectors. These findings are documented in the ancic. sed inspection report.
During this inspection, it was found that certain of your activities were in violation of NRC requirements. Consequently, you are required to respond to
these violations, in writing, in accnrdance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part ?, Title 10, $ ode of Federal Regulations. Your response should be based on the specifics contained le the Notice of Violation enclosed with this latter.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
,
Sincerely, Dorwin R. Hunter, Chief Reacter Project Branch 2 Enclosure:
1. Appendix A - Notice of Violation 2. Appendix B - NRC Inspection Report
,
50-445/84-26
,
.
cc w/ enclosure:
Texas Utilities' Electric Company Texas litilities Electric Company ATTN:
B. R. Clements, Vice ATTN:
H. C. Schmidt, Manager President, Auclear Nuclear Services
-
-
Skyway Tnwer 3kyw(y Tower
'
400 North Olive Street 400 North Olive Street
'
Lock Pox 81 Lock Box 81
-
-