IR 05000445/1985019

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Cable Tray Support As-Built Program Insp Rept 50-445/85-19 on 851118-1218.Violation Noted:Failure of Walkdown Teams & QC Inspectors to Correctly Determine & Verify as-built Cable Support Attributes
ML20202F221
Person / Time
Site: Comanche Peak Luminant icon.png
Issue date: 03/18/1986
From: Solla E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20202F175 List:
References
FOIA-86-382 50-445-85-19-01, 50-445-85-19-1, NUDOCS 8607150114
Preceding documents:
Download: ML20202F221 (11)
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APPENDIX l

SPECIAL UNIT 1 i CABLE TRAY SUPPORT "AS-BUILT" PROGRAM INSPECTION U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

l 1 NRC Inspection Report: 50-445/85-19 Construction Permit: CPPR-126 Docket: 50-445 Category: A2

. Applicant: Texas Utilities Electric Company (TVEC)

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Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201

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Facility Name: Comanche Peak Steam Electric Station (CPSES), Unit 1 Inspection At: Glen Rose Texas Inspection Conducted: November 18 - December 18, 1985

Inspectors: -

R. E. Lipinski, NRR Date

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J. R. Dale, RIV Consultant Date

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_J -- < 3-/8-86 E. A. S,qlla NRR Consultant Date i

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T. Langowski, NRR Consultant Date 8207150114 860709 PDR FOIA CARDE86-382 PDR

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-2-Reviewed By:

I, Barnes, Group Leader, Region IV CP5ES Group Date Approved:

T. F. Westerman, Chief, Region IV CP5ES Group Date Inspection Summar Inspection Conducted November 18 - December 18, 1985 (Report 50-445/85-19)

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Areas Inspected: Special, unannounced inspection of the Unit I cable tray support as-built inspection program and the related QA audit program for this activity. The inspection involved 224 inspector-hours onsite by six NRC I-personne Results: Within the two areas inspected, three violations (failure of walkdown teams and QC inspectors to correctly determine and verify, respectively, as-built cable tray support attributes, paragraph 3.a-3.h; failure to perform periodic audits of the as-built cable tray support program, paragraph 6; use of weld angles in cable tray supports wh.'ch were below the permissible minimum values, paragraph 5) were identifie ...

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-3-DETAILS Persons Contacted (*)(**)R.A.Muldoon,Ebasco (*)R. B. Bronson, Eoasco (*)R. C. Iotti, Ebasco (*)(**)R. M. Kissinger Texas Utilities Generating Company (TUGCo)

(*)R. Siever, B&R (*)(**)C. R. Hooton, TUGCo (*)(**)R. E. Camp TUGCo (*)(**)W. F. Rockwell, Ebasco ,

C. A. Briggs, TUGCo (**)H. A. Harrison TUGCo (**)P. Halstead. TUGCo '

(**)T. Brandt, TUGCo (**)J. S. Marshall, TUGCo (**)J. Vorderbrueggen. Impell H. A. Levin, TERA The NRC inspectors also interviewed other applicant employees during this inspection perio (*) Denotes those present during November 22, 1985, exit meetin (**) Denotes those present during December 5, 1985, exit meetin . Cable Tray Support As-Built Inspection Program The inspection was performed to verify the adequacy of the Unit 1 as-built inspection program for cable tray supports. The bases used for this inspection were: (a) TUGCo Nuclear Engineering (TNE)

Procedure TNE-AB-CS-1, Revision 1, dated September 30, 198E. "As-Built .

Procedure, Cable Tray Hanger Design Adequacy Verification;* and (b) the '

as-built red lined drawings which were prepared by TUGCo walkdown teams (composed of a walkdown engineer and a QC inspector) in accordance with Procedure THE-AB-CS-1, Revision )

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From a total of 789 cable tray supports that had been through the walk-dow:. program, a total of 66 supports were selected by the NRC inspection team using a random number generator. These supports were then broken

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-4-down by building and type. An engineered sample of 32 supports was selected. This sample included the following cable tray supports:

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Reactor Building Fuel Building CTH-1-42 CTH-1-1695 CTH-1-239 CTH-1-1716 CTH-1-4738 CTH-1-1742 CTH-1-5488 CTH-1-1845 CTH-1-5517 CTH-1-1853 CTH-1-5538 CTH-1-1963 CTH-1-5757 CTH-1-5352 CTH-1-5787 CTH-1-7047 CTH-1-5817 CTH-1-5873 Control Room

'CTH-1-5942 CTH-1-7199 CTH-1-5976 CTH-1-6041 Safeguards Building CTH-1-6497 CTH-1-207 CTH-1-6517 CTH-1-607 CTH-1-6559 CTH-1-636 CTH-1-6631 CTH-1-707 CTH-1-12075 CTH-1-13026 As a result of this inspection, deficiencies were identified in major attributes associated with the Unit I cable tray supports red-lined as-built drawing . Summary of Deficiencies (TNE-AB-CS-1)

A summary of the findings from this inspection which appear to be in violation of 10 CFR 50, Appendix B Criterion X and THE AB-CS-1, Revision 1, are as follows:

Tray Size (1) Procedute Requirements TNE-AB-CS-1, Revision 1, Section 4.2.2.B.7 requires verification l of the following:

" Cable Trays a. Width b. Depth Location within Support" s

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-5-(2) Findings CTH-1-5817 is recorded as a 4" x 12" tra It was found to be a 4" x 24" tray by NR Tray Span (1) Procedure Requirement TNE-AB-CS-1, Revision 1, Section 4.3.2. requires verification of the following:

" Indicate span from support to. support . . ."

(2) Findings

CTH-1-5817 conduit span was in error by I' 6".

CTH-1-239 spans were in error by 8" and 10". Tray Clamps (1) Procedure Requirement THE-AB-CS-1, Revision 1 Section 4.2.2.B.6 requires verification of the following:

" Clamp Type (Attachment D) Bolted Flat washer or bevel washer Welded Weld size and weld length will be verified in accordance with Reference 1-6."

(2) Findings

CTH-1-12075 cable tray clamp was recorded as a Type B

" Heavy Duty Clamp" i" plate welded to channel. Actual clamp was a Type C bolted clam *

CTH-1-1845 cable tray clamp G-2 was recorded as a bevel washer only, actual clamp contained a bevel and a flat washe _ . ..

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l-6-d. Member Size (1) Procedure Requirement TNE-AB-CS-1, Revision 1. Section 4.2.2.8 recyires verification of the following:

" Hanger Configuration Member shape and nominal size per AISC (see Table 13 Or AISC manual of steel construction 7thedition)."

(2) Findings CTH-1-5787 angle shape under tray was identified as 5/16" in thickness. Actual thickness was 7/16".

e. Weld Qualitative Measurement (1) Procedure Requirement

TNE-AB-CS-1, Revision 1. Section 4.2.2.B. requires

verification of the following

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" MemberConnectionDetails(Connectiontosupport member) Welds shall be verified by the QC inspector in accordance with Reference 1-G."

Reference 1-G, QI-QP-11.10-9 Cable. Tray Hanger As-Built,

(Inspection / Verification), Revision 2, Section 3. requires verification of the following:

"3 ..3 5 Welding Inspection 3.3.5.1 General Welding shall be inspected for quantitative and qualitative attributes as listed below without paint remove ...

Quantitative

. Type of Weld (fillet, flare bevel, groove,etc.) Confi etc.)guration (two sides all around, Weld Length Weld size"

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In Supplementary Safety Evaluation Report (SSER) 12 Section 3.8.3 which addresses FSAR Amendment 55, the applicant has been given approval to use Nuclear Construction Issue Grcup (1CIG) document NCIG-01, Revision 2 " Visual Weld Acceptance Criteria for Structural Welding to Nuclear Power Plants" (VWAC). VWAC specifies the following acceptance criteria for fillet welds:

"3.5.2.2 Acceptance Criteria: a fillet weld shall be permitted to be less than the size specified by 1/16 for i the length of the weld."

(2) Findings

CTH-1-5942 fillet weld #1 was found to be 1/16" undersized from that recorded for greater than 1/4 of its lengt CTH-1-1845 fillet weld detail B was found to be 1/16" undersized from the recorded for greater 1/4 of its lengt *

CTH-1-5517 fillet weld #1 was found to be 1/16" undersized from that recorded for greater than 1/4 of its lengt *

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CTH-1-5488 fillet weld was found to be undersized 1/16" from that recorded for greater than 1/4 of its lengt *

CTH-1-4738 fillet weld was found to be undersized 1/16" from that recorded for greater than 1/4 of its lengt *

CTH-1-12075 measurement of the top and bottom of member weld lengths was recorded in reverse * i CTH-1-1853 measurement of the top and bottom of member weld lengths was recorded in reverse ;

f. Dimensional Measurements (1) Procedure Requirements

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TNE-AB-CS-1, Revision 1 Section 4.2.2. requires verification of the following:

"A.2 Elevation (of lowest horizontal member)

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B.2. Hanger Configuration b Dimension, including addition of required dimension ___

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-8- Expansion anchor bolt projection and/or embedment (Table 12).

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B.4 Support Anchorage

. Bolt distance from heel of angle or channel, et (Gage 'G' dimension)"

(2) Findings

CTH-1-5942 dimension to edge of column was in error 1".

CTH-1-1845 dimension between attachments was in crror l' 3/4".

CJH-1-1963elevationwasinerrorby3"(ElevationA-A).

CTH-1-42 gage dimension was in error 1".

CTH-1-239 gage measurement was in error 5/16".

CTH-1-1845 bolt projection measurement was in error 3/4"

CTH-1-7047 bolt projection for bolts #1, #2, and #3 was in error greater than 1".

CTH-1-5976 bolt projection measurement was in error 1/2" g. Bolt Size (1) Procedure Requirement

TNE-AB-CS-1, Revision 1, Section 4.2.2.B requires verification of the following:

"3.b Bolts 1-Size" (2) Findings CTH-1-6631 hex nut was standard when a heavy hex nut was specifie h. Member Orientation (1) Procedure Requirements

TNE-AB-CS-1, Revision 1, Section 4.2.2.B requires verification of the following:

" Hanger Configuration"

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-9-(2) Findings

CTH-1-1845 angle to wall was rotated 90 degrees from drawing detail.

i Other Findings Related to TNE-AB-CS-1 Measurements Criteria were not provided with respect to the required acuracy of measurements in obtaining THE-AB-CS-1 red-line data. Variations in

bolt projection and gage measurements were identified which appear

to be attributable, in part, to the many different methods used to make the measurements. The applicant has indicatcJ that TNE-AB-CS-1 will be revised to provide clear guidance with respect to measurements. This in considered an open item-(445/8519-0-01).

The NRC inspectors compared NRC measured dimensions and the red-line recorded dimensions to the tolerances given in tables attached to TNE-AB-CS-1. Measurements which violated these tolerances are identified in paragraph 3 abov Inaccessibility The NRC inspectors identified that there were attributes which appeared accessible, although they had been identified as inaccessible.

The applicant stated that the training provided to the walkdown personnel instructed that measurements be taken only if they were fully accessible at the support. Further, the training provided gave instruction that all attributes of a particular component be fully accessible before it is inspecte The applicant has indicated that the term inaccessible will be clarified by revision to TNE-AB-CS- This considered an open item (445/8519-0-02).

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> Weld Bevel In addition, the NRC inspectors noted weld bevels which appeared to be in violation of the American Welding (AWS) D1.1 Society Code. The quantita-tive weld attributes, such as bevel, were inspected by the applicant only for the first 100 supports in accordance with TNE-AB-CS-1.. It was there-fore not a requirement of the Unit 1 as-built cable tray program to verify weld bevel beyond the first 100 supports inspecte .

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-10-The FSAR, Table 17A-1 states that cable tray hangers will be constructed in accordance with American Institute of Steel Construction (AISC) Cod The AISC Code, Seventh Edition, Page 4-131, states that "The AISC Specification and the American Welding Society exempt from tests a qualification most of the common welding joints applicable to steel structures. When the joints . . . as designated as prequalified . . ."

Gibbs and Hill, Inc., Specification 2323-SS-16B, Section 6.4, dated May 7, 1975, states, " Welding construction shall conform to AISC Specifi-cation for Design, Fabrication and Erection of Structural Steel for Buildings and AWS D1.1."

The AWS D1.1-75 Code, Section 2.9.2.4 states with' respect to weld groove angle, "The groove angle is minimum. It may be detailed to exceed the dimension shown by no more then 10 degrees."

The weld bevel for hanger drawing CTH-1-5538, full penetration weld #2, was found to be 30* by the NRC inspector. In addition, the weld bevel for hanger CTH-1-5517, 1" plate full penetration weld, was measured to be 36*-38 . The prequalified weld bevel specified by the hanger drawings (CTH-1-5538 and CTH-1-5517) was 45*.

The failure to control weld bevel angles appears to be in violation of the AWS D1.1 Code and 10 CFR 50, Appendix B, Criterion I . Audit of As-Built Cable Tray Support Inspection Program The NRC inspectors could find no objective evidence that the cable tray support as-built inspection program had been audited or scheduled to be audite The failure to establish planned periodic audits of the cable tray support as-built inspection program is considered to be in violation of 10 CFR 50, Appendix B, Criterion XVII . Applicant Corrective Actions The applicant promptly initiated the following corrective actions:

TUGCo Engineering was requested to document and evaluate each finding to determine corrective action on November 22, 198 *

Stop Work was issued to field activities associated with Unit 1 as-built / inspection program on November 26, 198 *

A Corrective Action Request was issued on November 26, 1985.

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A TUGCo investigation was initiated to determine the cause. Personnel actions have resulted from the investigation underwa *

Inspection of the as-built program Unit 2 was initiated to determine if similar problems existed in Unit *

The evaluation of actions necessary to resume the as-built program is in progres . Exit Meeting Exit meetings were held on November 22, 1985, and December 5, 1985, respectively, to discuss the initial and final findings from this inspectio A subsequent exit meeting was held with TUGCo corporate management on December 18, 1985, to review the findings from this inspection, at which time, potential escalated enforcement action was discussed.

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Those present included:

TUGCo W. G. Council J. W. Beck NRC R. D. Martin V. S. Noonan

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, In Reply Refer To:

Docket: 50-445/85-19 Texas Utilities Generating Company ATTN: Mr. W. G. Counsil Executive Vice President 400 North Olive, L.B. 81 Dallas, Texas 75201 Gentlemen:

This refers to the special inspection conducted by Mr. T. F. Westerman, members of the Region IV Comanche Peak Group, and NRR personnel during the period of November 18 through December 18, 1985, of activities authorized by NRC Construction Permit CPPR-126 for the Comanche Peak Steam Electric Station, Unit 1, and to discussions with Mr. R. E. Camp and other members of your staff on November 22, 1985, and December 5, 198 The purpose of the special inspection was to evaluate the Comanche Peak Steam Electric Station, Unit I as-built cable tray inspection program. The inspection identified multiple instances involving the failure to properly inspect and document as-built cable tray attributes. In addition, violations were identified relative to both the failure of the QA programs to establish QA overview and audits of the Unit 1 as-built cable tray inspection program and the use of incorrect weld bevel angles. The violations and related NRC concerns were discussed with you in the subsequent exit meeting held on December 18, 198 No response to this letter is requeste Enforcement actions relative to this inspection will be forwarded under separate correspondenc ...

RIV: CPG C: CPG AD:DRS&P ES NRR IBarnes;ap TWesterman EJohnson DPowers VNoonan

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i Texas Utilities Generating Company -2-Should you have any questions concerning this letter, we will be glad to discuss them with yo

Sincerely, E. H. Johnson, Director Division of Reactor Safety and Projects Enclosure:

Appendix - NRC Inspection Report -

50-445/85-19 ,

cc w/ enc 1:

Texas Utilities Electric Company ATTN: J. W. Beck, Vice President Licensing Quality Assurance and Nuclear Fuels Skyway Tower 400 North Olive Street bec to DMB (IE01)

Lock Box 81 Dallas, Texas 75201 bec distrib. by RIV:

  • RPB * MIS System Juanita Ellis *RRI-0PS *RSTS Operator President - CASE *RRI-CONST *R&SPB 1426 South Polk Street *TFWesterman, CPTG DRSP Dallas, Texas 75114 V. Noonan, NRR R. Martin, RA S. Treby, ELD *RSB Renea Hicks *RIV File J. Taylor, IE Assistant Attorney General *D. Weiss, LFMB (AR-2015)

Environmental Protection Division R. Heishman, IE *D. Powers, EC P. O. Box 12549 Austin, Texas 76711

  • w/766 Texas Radiation Control Program Director 1
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