IR 05000445/1986028
| ML20205T527 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/31/1987 |
| From: | Barnes I, Phillips H, Spessard R, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20205T492 | List: |
| References | |
| 50-445-86-28, 50-446-86-23, NUDOCS 8704070315 | |
| Download: ML20205T527 (10) | |
Text
APPENDIX CONSTRUCTION INSPECTION REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-445/86-28 Permits: CPPR-126 50-446/86-23 CPPR-127 Dockets: 50-445 Category: A2 50-446 Construction Permit Expiration Dates:
Unit 1: August 1, 1988 Unit 2: August 1, 1987 Applicant:
Texas Utilities Electric Company Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 & 2 Inspection At: Glen Rose, Texas Inspection Conducted:
October 1 through November 30, 1986 Inspectors:
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3 /30 /F7 H. S. Phillips, Senior Rssident Reactor Date Inspector, Construction, Region IV CPSES Group (paragraphs 1, 2, 3, 4, 5, 6, 7, and 8)
k.b d 04 vJLu 3/27/67 P. C. Wagner, React)r Inspector, Region IV Date CPSES Group (paragraph 3)
Consultant: EG&G - A. Maughan (paragraph 3)
8704070315 870331 PDR ADOCK 05000445 G
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Reviewed By:
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R. L. Spesspd, Deputy Director, Division of D~a te '
Inspection Programs, Office of Inspection dnd Enforcement Nc eo 3/J//r7
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Approved:
c 1. Barnes, Chief, Region IV CPSES Group Date Inspection Summary Inspection Conducted October 1 through November 30, 1986 (Report 50-445/86-28)
l Areas Ins]ected: Routine, unannounced inspection of applicant actions on previous iRC inspection findings and review of 10 CFR 50.55(e)' reports.
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Results: Within the two areas inspected, no violations or deviations were
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identified.
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Inspection conducted: October 1 through November 30, 1986 (Report 50-446/86-23)
Areas Inspected: Routine unannounced inspection of plant status, general plant inspections, applicant actions on previous NRC inspection findings, 10 CFR 50.55(e) reports, ASME N-5 Data Report program, and installation of safety-related components.
j Results: Within the six areas inspected, no violations or deviations were identified.
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DETAILS 1.
Persons Contacted
- J. Barker, Engineering Assurance Manager, TUGCo D. Bize, Engineering Assurance, TUGCo
- T. Braudt, Comanche Peak Response Team (CPRT), TUGCo
- R. Camp, Project Manager, Unit 1, TUGCo
- W. Counsil, Executive Vice President, Nuclear Engineering and Operations, TUGCo C. Davies, Engineering Assurance, Brown & Root, Inc. (B&R)
- P. Halstead, Manager, Quality Control (QC), TUGCo N. Hammett Engineering Assurance, B&R T. Heatherly, Engineering Assurance, Southern Technical Services
- D. McAfee, Quality Assurance (QA) Manager, TUGCo G. McKibbin, Quality Engineer (QE), Ebasco Services, Inc.
- J. Krechting, Director of Engineering, TUGCo J. Middlemas, QC Inspector, Ebasco Services, Inc.
- L. Nace, Vice President, Engineering and Construction, TUGCo D. Noss, QE Supervisor, Daniels International, Inc.
- D. Reynerson, Project Manager, Unit 2, TUGCo D. Robinson, Engineering Assurance, Shelly and Wheat Technical
- M. Steelman, CPRT, TUGCo
- J. Streeter, Director of QA, TUGCo W. Sealover, Engineering Assurance, B&R J. Waters, Engineering Assurance, Southern Technical Services C. Welch, QC Services Supervisor, TUGCo The NRC inspectors also interviewed other applicant and contractor employees during this inspection period.
- Denotes personnel present at October 1986 exit interview.
- Denotes personnel present at the October and November 1986 exit interviews.
- Denotes personnel present at the November exit interview.
2.
Plant Status, Unit 2 The NRC inspector discussed the status of work with TUGCo and contractor (electrical and mechanical) management personnel. Project status reports were also reviewed. Construction has turned over approximately 60 percent of the subsystems to TUGCo Startup and overall construction is about 83 percent complete.
3.
General Plant Inspections, Unit 2 At various times during the inspection period, the NRC inspector conducted-general inspections of the Unit 2 reactor, safeguards, and diesel generator buildings. Selected rooms in these buildings were inspected to
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observe the status of current work activities with respect to major safety-related equipment, electrical cable / trays, mechanical components,
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piping, welding, coatings, Hilti bolts, and removal of debris from 1-inch
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seismic gap between buildings..The housekeeping and storage conditions inside these buildings and various outside storage areas were also L
inspected. One backshift inspection.was performed during this inspection period. The following are. specific findings which were brought to the-applicant's attention for correction.
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During a tour of the Unit 2 reactor building, the NRC inspector noted that the cover was removed from junction box JB2C 269G, located on the 832'
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level. Since the inspector had observed this removed cover during
previous tours of that area, he brought the condition to the attention of the applicant's QE department. The cover had been reinstalled when the NRC inspector toured the same area on the next day.
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The NRC inspector also noted that-the hydrogen sensor calibration mechanism, mounted on a column at 170 degrees on the 832' level of the
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reactor building, was not protected from other construction activities and l
informed the applicant's QE department.
Subsequent' inspection showed that a fire-retardant plywood cover had been built and installed over the i
assembly.
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No violations or deviations were identified.
4.
Applicant Actions on Previous NRC Inspection Findings, Units 1 and 2
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a.
(0 pen) Violation (445/8507-V-01; 446/8505-V-01):
Failure to promptly correct problems with RTE-Delta Potential Transformer Tiltout
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i Subassemblies.
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The NRC inspector reviewed TUGCo response (TXX-4727) to verify that corrective action was taken on this. item during the previous j
inspection period (September 1986); however, this item was kept open i
pending a review of the documented inspection referenced in TUGCo's response and TUGCo's response to an NRC letter requesting additional
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information. During this inspection period, the NRC inspector found that these inspections were documented on travelers Z-2914 and 2912 for trains A and B, Unit I diesel generators. This item remains open pending the review of TUGCo's response and determination as to whether a nonconformance should have been written.
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b.
(Closed) Violation (445/8507-V-04; 446/8505-V-02): Failure to document inspections of concrete mixer blades.
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The NRC inspector reviewed TUGCo file TJ-171 and determined that
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TUGCo memo CPP-18560 required civil engineering to evaluate the blade condition of ready-mix trucks against "as-built" drawings.
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Procedure CCP-10 was revised to document blade inspection on a l
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checklist. This item is closed.
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c.
(Closed) Unresolved Item (445/8507-U-08): Wall stickers in Unit 1 reserved wall space for hangers when work was complete.
The NRC inspector reviewed this item during the previous inspection period, but the item was not closed because information concerning the control of stickers was unavailable.
In this period, the NRC inspector received information which showed that no procedures,-
instructions, or logs were used to control the application or removal of stickers; however, TUGCo engineering and QA personnel stated that the use of stickers has no effect on plant design or construction activities. This is the case because plant specifications, drawings, and design change authorizations would override any potential conflict between the stickers and design documents. This item is closed.
d.
(0 pen) Violation (446/8509-V-02):
Procedures did not address material / personnel control to prevent contamination with materials such as mercury.
The NRC inspector reviewed TUGCo response dated April 2, 1986, and file T1-217 which contained memoranda and Surveillance Report C-86-174, a surveillance which had been performed to assure that deleterious materials and access to vital equipment areas were controlled in Unit 2.
The surveillance was also performed to assure that Procedure CP-CPM-9.2, " Chemical Substances Used in Safety Related Buildings," which was revised to improve such control, was implemented. This item remains open until issues dealing with Unit I are inspected and closed.
e.
(Closed) Violation (446/8509-V-03):
Failure to protect equipment from adjacent work activities.
The NRC inspector reviewed the TUGCo response which indicated that TUGCo took corrective action immediately after being informed that an unauthorized platform was placed on a small pressurizer pipe and larger piping had not been protected from overhead welding.
File T1-218 documented meetings with construction superintendents, engineering, and QC supervisors to stress the importance of protecting installed equipment. With respect to equipment protection, a list of surveillances in this file summarized 9 surveillances which showed that 27 deficiencies (some similar to this open item) were-identified in Surveillance Report C-86-089 (February 5,1986) but conditions appeared to improve as no
deficiencies were identified in Report C-86-162 (March 27,1986).
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Monthly surveillances are performed to assure continued compliance.
The NRC inspector verified that a wooden two by four, which was previously found at the bottom of the pressurizer in Room 16 r f the e
reactor building, was no longer laid across a 3/4-inch pipe. The NRC inspector has observed house keeping during monthly inspections since the violation occurred but has not identified additional violations.
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f.
(Closed) Violation (446/8511-V-01):
Failure to document minimum wall
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violation on a nonconformance report (NCR).
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The NRC inspector reviewed TUGCo response TXX-4666 and other documentation in file TI-181; that is, memos, NCRs, and procedures which
support the corrective action; i.e., that the. weld repair was
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adequate and personnel were retrained as stated in the response.
Based on the TUGCo actions noted-in this file, it is apparent that j
this violation was isolated and resulted from an oversight. The inspector closed this item based on the objective evidence in the file.
No violations or deviations were identified.
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5.
Review of=10 CFR 50.55(e) Reports, Unit I and 2
a.
The NRC inspector reviewed 53 initial or interim reports which were due and received during this inspection period. The contents of these reports have improved with respect to the description of the analysis, corrective action taken, applicability to Units 1 and 2, corrective action dates, and the next report.due date. The reports received during the inspection period appeared to be timely; i.e.,
submitted as stated in previous reports. The NRC inspector selected five reportable deficiencies to evaluate the applicant's task. force work which started in November 1985. One of two files, which was considered complete and was selected for field verification of
corrective action, could not be verified.
b.
(0 pen) Construction Deficiency (D1-0052): Welded connections of Unit 1 main control board did not meet design requirements.
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The NRC inspector reviewed.TUGCo final report TXX-3110 and QA File
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CP-80-03 which describe the deficiency, analysis of safety
implications and corrective action.
Supporting documentation was
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reviewed such as Reliance' Electric letter dated August 15, 1980, and attached seismic calculations; rework.and reinspection travelers i
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CE 80-032-0200 through CE 80-042-0200, and CE 80-072-0200 through I
CE 80-082-0200; design change authorizations (DCAs) 3150 and 7394 Revisions 4 and 9 respectively, and welder retraining records on Procedure CP-CPM-6.9.
File CP-80-03 and the_ deficiency report did not address the Unit 2 main control board panel; i.e.,-it did not address whether the same deficiency existed or state how the
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deficiency would be prevented from recurring in Unit 2..The file for this deficiency had no information on Unit 2.
In response to this
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question by the NRC inspector, TUGCo provided information concerning Unit 2 panels and is considering wl.cther a supplemental-response is
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needed.
l The NRC inspector requested that the TUGCo inspector accompanying him show that the panels were in accordance with present "as-built" drawings and/or DCAs and work had been inspected to_the appropriate i
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design and QC document revision level. The TUGCo. inspector was unable to show this because of the following.
The NRC inspector randomly selected three of eleven Unit 1 panels CP1-ECPRCB-01A, 05A and 09A for field inspection. The TUGCo inspector was unable to locate DCA 7394, Revision 6, in the_QA records vault. He was able to determine from an office memorandum of July 31, 1980, that Revision 6 reduced the size of fillet welds from 1/4" to 1/8"; however, none of the later revisions (7-13) showed this reduced weld size.
In addition, the QC inspector determined that Revision 6 of DCA 3150 voided all previous revisions and states, "See DCA 7394 for information on mounting of Unit I control room bench boards"; however, the TUGCo inspector found that DCA 7394 does not have complete details for the welding of bench' boards; i.e., inside welds. The NRC inspector was unable to initiate and complete the hardware inspection until the design. documentation is located.
The NRC inspector reviewed the various revisions of DCA 7394 and work traveler CE-80-032-0200 to learn more about corrective action for panel CP1-ECPRCB-01. The traveler contained six work steps for completing the corrective action; i.e., shimming and welding. This traveler exhibited many.of the problems documented in NRC Report 50-445/86-20, 50-446/86-17; i.e., failure to comply with project Procedure CP-CPM-6.3, Revision 6.
Specifically, the reference drawing revision was not given, and revisions to the traveler were not described below the last traveler operation as required by paragraph 3.6.1 of the procedure. As a result of not complying with the procedure, multiple entries were made between the traveler work operations, which not only made it very difficult to read but also made the description of the change so cryptic that it was unclear as to what was done and in what order. Since this-practice appears to be another example of a previously-identified violation in the NRC report referenced above, this item was referred to the applicant for corrective action under the above referenced Notice of Violation and is considered an open item instead of writing repetitive violations (445/8628-0-01; 446/8623-0-01).
The NRC inspector also asked for other clarifications as follows:
DCA 7394, Revisions 6-13 were generically worded in the
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" Details" to include all 11 panels; however, discussions with the TUGCo inspector and review of DCAs revealed that all revisions did not necessarily apply to all panels. This needs to be clarified; i.e., which panels.are specifically affected by
each revision?
There was no indication that a seismic analysis occurred after
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Revision 6.
This needs to be clarified; i.e., did Revisions 7-13 affect the previous seismic analysis?
This item remains open until these issues are resolved.
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(Closed) Construction Deficiency (D-0112): GE transformer failure due to core vibration.
The NRC inspector reviewed final report TXX-4109 and QA File CP-84-04 which give-deficiency description, safety analysis and corrective action.. Supporting documentation such as NCR C-84-00218, Revision 1, inspectionreport(IR-1-0047319), material receiving report 12691,
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receiving report 12691, Unitx 1worktravelers(Z-2562throughZ-2565)
and Unit 2 reinstallation travelers (EE-85-11794 through 11797-2-02c)
provide objective evidence that the deficient transformers were removed, shipped for vendor repair,' returned, and reinstalled.. This item is closed.
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d.
(0 pen) Construction Deficiency (D-1-0134): Ventilation exhaust damper deficiencies.
The NRC inspector reviewed final report TXX-4409 and QA File CP-84-27 for safety analysis and corrective action taken. Supporting documentation consisted of numerous memoranda which discussed evaluations of 88 deficient dampers and resultant work modifications.
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The corrective action completion date_for Unit I was stated to be July 1985 for modifications and September 1985 for equipment
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qualification report, final safety analysis. report and specification
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updates.
The NRC inspector reviewed documents to determine if the modification work was completed and found that work was not completed.
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addition, a special HVAC test to ensure removal of hydrogen gas was i
to be performed but no date was given in the report. No specific date of completion was given for Unit 2.
TUGCo is considering the need to update the final 10 CFR 50.55(e) reports to describe work and new corrective action dates.
This item remains open pending completion of work.
e.
(0 pen) Construction Deficiency (D-1-0135): Rosemount Model 1153 leakage in thread seal between sensor module and electronic housing.
The NRC inspector reviewed final report TXX-4364 and QA File CP-84-28
for the safety analysis and corrective action. No specific corrective action date was provided in the report; however, NCR-I-84-100466-S and I-84-200169 for Units 1 and 2 were referenced and they will track the corrective action to completion. TUGCo is i
considering the need to provide corrective action dates in the
report.
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TUGCo was in the process of reviewing this item for work and documentation completion. This item remains open pending the completion of their review and subsequent NRC review.
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f.
(0 pen) Construction Deficiency (D-1-0136):
Unreviewed fire scenario could affect control room habitability and alternate shutdown capability.
The NRC inspector reviewed final report TXX-4350 and QA File CP-84-29 for safety analysis and corrective action. No corrective action date was given in this November 1984 report and work order (PFF-165) was incomplete.
TUGCo had not completed the assembly of supporting documentation and the final review. This item remains open pending the completion of these actions and subsequent NRC review.
g.
(0 pen) Construction Deficiency (D-1-0138):
Nonseismic wall in control room.
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The NRC inspector reviewed final report TXX-4349 and QA File CP-84-31 for the safety analysis and corrective action taken. This report stated that work would be completed by December 15, 1984; however, the work was not completed. This item was identified by the NRC Technical Review Team in 1984.
This item remains open pending the completion of the TUGCo review.
No violations or deviations were identified.
6.
Inspection of ASME N-5 Data Report Program, Unit 2 The NRC inspector found that B&R Procedure CP-QAP-12.1, Revision 17
" Mechanical, Component Installation Verification, N-5 Certification,"
provides instructions for final verification of installation for American Society of Mechanical Engineers (ASME), Division 1,Section III and the preparation of applicable Code Data Reports.
The NRC inspector selected the safety injection system to review a package completed in accordance with the procedure; however, the QA records vault supervisor stated that a N-5 certification package had not been completed for this system.
In discussions with QA personnel, the NRC inspector learned that this program is yet to start. Only four subsystems, 2LL-8, 2009, 2DD-4, and 2VA-1, have been completed to date and these were subsystems in the Fuel Handling Building which had been completed in conjunction with completing the Unit 1 program.
The NRC inspector learned that Stone & Webster Engineering Corporation (SWEC) activity has impacted this program and the procedure will be revised to incorporate necessary changes recomended by SWEC personnel. Subsystem 2-DD-3 will be considered a test case by the contractor to determine how well the new procedure works.
No violations or deviations were identified.
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7.
Installation of Safety-Related Components, Unit 2 The NRC inspector selected containment spray pump CP-2-CTAPCS-03 to review various work activities.
Four drawings, one component modification card, three material receiving reports, one N-1 Data Report, two pemanent equipment transfer fonns, seven NCRs, one instrument installation checklist, four inspection reports, and ten installation work travelers were reviewed.
A number of discrepancies were identified with travelers (e.g., inspection procedure revision level or QA concurrence not shown for ME85-1038-4800, WE84-026-4800, ME82-1138-4802, and ME84-1019-4802). The work procedure was not specified for RI79-236-4800 and ME85-1038-4800. Similar failures to follow project Procedure CP-CPM-6.3 were documented in the previously referenced NRC Inspection Report 50-445/86-20; 50-446/86-17. As a result, these travelers are considered further examples of the failure to follow procedures and as a result will be tracked as open items instead of
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writing a repetitive violation (446/6623-0-02).
No violations or deviations were identified.
8.
Exit Interview Exit interviews were conducted on November 12 and December 9,1986, with the applicant's representatives identified in paragraph 1 of this appendix. During these interviews, the NRC inspectors sumarized the scope and findings of the inspection. The applicant acknowledged the findings.
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