ML19325D261

Final Deficiency Rept CP-89-025 Re Site Fabricated thermo- Lag Panels.Initially Reported on 890915.Design Change Issued to Revise Design & Installation Spec to Eliminate Fabrication of thermo-lag Panels Onsite

ML19325D261
Person / Time
Site:	Comanche Peak
Issue date:	10/12/1989
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CP-89-025, CP-89-25, TXX-89737, NUDOCS 8910200045
Download: ML19325D261 (3)

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Lo f TXX-89737 Fi e # 10110 -

1 C 909.5 i C C Ref. # 10CFR50.55(e) c

( 1UELECTRIC L October ^12, 1989 ,

O<$S$$ln't U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 SITE FABRICATED THERM 0-LAG PANELS  :

SDAR: CP-89-025 (FINAL REPORT) ,

Gentlemen:

l-On September 15, 1989, TU Electric verbally notified the NR'C of a deficiency that.it had identified involving' inadequacies in site fabricated one hour fire -

barrier thermo-lag panels.' After further evaluation, we have concluded this i deficiency is reportable pursuant to 10CFR50.55(e). . The required information -

follows.

Description Site fabricated thermo-lag panels have localized dry film thickness (DFT) of less than the 1/2" requirement of the design specification. This deficiency ,

impacts approximately 2,000 square feet of thermo-lag installed in the plant and 11,000 square feet in the warehouse.

Additionally, during the removal of site fabricated panels from the plant, '

panels were observed which violated the requirements of the. installation ,

specification. ' Thermo-lag panels were less than 1/2" thick in areas of seams, .

joints, edges and bolting. Also,.some panels removed were found to have been modified to accommodate protrusions without compensating for the reduced material thickness. This problem impacts approximately 12,000 square feet of installed thermo-lag.

The causes of these deficiencies are attributed to an inadequate onsite fabrication process for the site fabricated thermo-lag, failure to identify deficiencies in the site fabricated panels, failure to comply with installation specifications in certain applications, and failure to detect the nonconforming finish conditions. The failure to detect nonconforming-conditions was attributed to inadequate change / revision to the specification and the corresponding inspection criteria.

8910200045 891012 PDR S

ADOCK 0500044D PDC

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.,i SW North Olive Street LB 81 Dallas, Texas 73201 -

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I TXX-89737 October 12, 1989 Page 2 of 3 l

l The generic implications of the deficiency extend to the adequacy of one hour l o barrier thermo-lag fabricated and/or installed _ in 'accordance with the CPSES j specification.  !

Safety Sianificance l

I The design and installation specification and procedures were found to be .j inadequate to assure the required one hour fire-barrier. Had these i deficiencies remained uncorrected, the potential existed that a fire could l have breached the barrier and adversely affected the ability to safely I shutdown the plant; therefore, the deficiencies are reportable pursuant to 10CFR50.55(e). ,

I Corrective Action l A corrective action request has been initiated to track this deficiency and ensure that it is corrected and that the thermo-lac is installed in accordance l with the appropriate specifications. Corrective and preventive ~ action has i been outlined as' described below.

A nonconformance report (NCR).was initiated to require inspection of the site  ;

fabricated thermo-lag panels in the warehouse. Many of.these panels were '

found to be sub-standard or sus)ect. To prevent the use of these site l fabricated thermo-lag panels, tiis NCR has been dispositioned to' scrap the ,

site fabricated panels stored in the warehouse.  ;

A design change authorization has been issued to revise the design and installation specification to eliminate the fabrication of thermo-lag panels on-site, to recognize only vendor fabricated panels, and to clarify inspection requirements.

Site fabricated thermo-lag panels installed in the plant prior to l September 6, 1989, are being identified by engineering inspection. Thermo-lag determined by these inspections to be site fabricated will be removed and scrapped. Panels which cannot be identified as vendor fabricated (acceptable) ,

or site fabricated (unacceptable) are being treated as site fabricated panels I and will be removed and scrapped, j In addition to the removal and scrapping of site fabricated thermo-lag, installed vendor supplied panels will be inspected to assure that there are no improper modifications to accommodate surface protrusions and to assure that-the 1/2" criteria was not violated in the areas of seams, joints, edges and 1 bolting. Deficient installations will be repaired or removed and. scrapped. '

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l TXX-89737 \

October 12, 1989 l Page 3 of 3 l Formal re-training sessions have been provided to craft by qualified vendor 1.

1 personnel to prevent recurrence.

l Completion schedule of rework for Unit I will be prior to Unit I fuel load.

l Thermo-lag has not been installed in Unit 2, hence rework for Unit 2 is not ,

t required. '

Sincerely,

$_ e4 William J. C ill, Jr..

JTB/vid-c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)

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