ML20003J176
| ML20003J176 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/19/1981 |
| From: | Crossman W, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20003J175 | List: |
| References | |
| 50-445-81-02, 50-445-81-2, 50-446-81-02, 50-446-81-2, NUDOCS 8105080535 | |
| Download: ML20003J176 (6) | |
See also: IR 05000445/1981002
Text
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U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No.
50-445/81-02; 50-446/81-02
Docket No.
50-445; 50-446
Category A2
Licensee:
Texas Utilities Generating Company
2001 Bryan Tower
Dallas, Texas 75201
Facility Name:
Comanche Peak, Units 1 and 2
Inspection at:
Comanche Peak Steam Electric Station
Inspection conducted:
February 1981
.5/6/f/
Inspecto -
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R. G. Taylor, Resident Reactor Inspector
Date
Projects Section No. 3
Approved:
ff,
3f/f/f/
m=
W. A. Crossman, Chief, Projects Section No. 3
Date
Inspection Summary:
Inspection During February 1981 (Report 50-445/81-02; 50-446/81-02)
Areas Inspected:
Routine, anhounced inspection by the Resident Reactor
Inspector (RRI) including general site tours; protection of installed and
uninstalled equipment; installation and welding of safety-related piping;
the design and installation of pipe supports and restraints.
The inspec-
tion involved eighty-five inspector-hours by the RRI.
Results:
Of the four major areas inspected, no violations or deviations were
identified in three areas.
One violation was identified in the area of pipe
installation (violation - failure to follow procedures for piping installation -
paragraph 2).
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DETAILS
1.
Persons Contacted
Principal Licensee Personnel
- D. N. Chapman, TUGCO, Quality Assurance Manager
- R. G. Tolson, TUGCO, Site Quality Assurance Supervidor
- J. R. Merritt, TUSI, Engineering and Construction Manager
Other Persons
J. V. Hawkins, Brown and Root, Project Quality Assurance Manager
The RRI also interviewed other licensee and Brown and Root employees
during the inspection period including both craft labor and QA/QC
personnel.
- Denotes those persons with whom the 'lRI held on-site management meetings
during the inspection period.
2.
Site Tours
The RRI toured the safety-related plant area several times during the
inspection period to observe the gen 3ral progress of construction and
the practices involved.
During a tour on February 20, 1981, which
included the 790 ft. level of the Unit 1 Safeguards Building, the RRI
noted that a run of piping, estimated to have been about 18 feet long,
was unsupported except for being attached to a valve by the connecting
weld.
Further examination revealed that valve was also supported at the
other end by a weld to a continuing run of pipe which passed through
a sleeve in the adjacent concrete wall.
The unsupported length of pipe
was estimated to weigh approximately 1500 lbs while the valve may have
weighed at least that much more, all combining to place a considerable
stress in the valve body.
Such practices are not considered to be good
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industry practice and are specifically prohibited by the Piping Erection
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Specification, MS-100 and site procedures.
An earlier comparable
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situation was the subject of a Notice of Violation issued with Inspection
Report No. 50-445/80-11 to which the licensee has responded with a
commitment to instruct the craft via procedures not to leave unsupported
pipe in place.
The licensee's commitment was implemented by a revision to Brown and
Root Procedure CPM-6.9E which prohibited pipe from being supported by
blocks, jacks or similiar methods if the pipe run were to be unattended.
It appeared to the RRI that this specific instruction had been violated
in that there was a floor jack adjacent to the pipe and there was no
evidence that there had ever been a more positive support in position.
The RRI was also aware that several Nonconformance Reports have been
issued during the past year, two of which are still active, dealing
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with the same problem.
These Nonconformance Reports, along with the
incident related above, indicate that the corrective action taken earlier
was not completely effective.
The RRI informed both the licensee and
Brown and Root QA management of the findings which was in turn followed
up with an official Notice of Violation transmitted by letter, dated
February ?5, 1981.
3.
Protection of Major Installed Equipment
The RRI observed that the reactor vessel internals (core support struc-
ture) continued to be partially installed within the Unit 1 reactor
vessel.
The vessel head and the lifting rig assembly were found to be
adequately covered with heavy plastic to provide protection from
construction dust and small debris.
The Unit 2 reactor vessel was
observed to be well protected in its installed location with the
internals remaining in their temporary enclosure.
The RRI observed that electric pump drivers and valve actuators continued
to have their space heaters activated in that each unit checked was
warmer than near-by metal surfaces.
The RRI also observed that installed
instrument sensing devices were well covered with wooden boxes wired
in place and that partially installed instrument impulse tubing runs
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were adequately plugged, all in accordance with good practices.
No violations or deviations were identified.
4.
Protection of Uninstalled Equipment
The RRI toured the several piping laydown areas to observe the condition
of the piping spools prior to installation.
All were found to be well
capped and supported off the ground.
The stainless steel spools
evidenced little or no rust which would indicated that the handling
and welding practices in both the on-site and off-site pipe fabrication
shops have been adequate.
In connection with the tours of lay-down
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areas, the RRI also examined several moment restraints which were the
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subject of a Notice of Violation (Inspection Report No. 50-445/80-20)
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and observed that the weld joints were relatively smooth and apoeared
to be of good qua!ity.
No violations or deviations were identified.
5.
Safety-Related Pioing Installation and Welding
The RRI made several observations of the handling practices relative
to piping components during the inspection period, both in the on-site
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fabrication shop and within the main plant buildings.
With the exception
described in paragraph 2, " Site Tours," the practices were consistent
with the requirements outlined in Construction Procedure 35-1195-CPM-6.9,
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Project Specification MS-100, and good industry practice.
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The RRI observed the following welds being made during the inspection
period:
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Weld Number
Isometric _No,
Filler Metal Ht.
Welder (sl Procedure
FW-11
RC-2-520-001
464176
AMS-BRS
99028
FW-9
FW-1-RB-0058-1
87401
BGU
11020
FW-7
FW-1-RB-0058-1
87401
BGU
11020
The first of the above welds connects the Loop 2 Reactor Coolant Crossover
piping to the associated Steam Generator of Unit 2 Reactor.
The latter
welds are located in Line 6-FW-1-099-1303-2 in the Unit 1 Steam Generator
Feedwater system.
The RRI verified that the welders, weld procedures
and filler metal had all been qualified in accordance with applicable
portions of the ASME Code.
The RRI examined the radiographs of the following welds for compliance
to the requirements of ASME Section III for weld quality and Section V
for the quality of the radiographs:
Weld No.
Isometric No.
Line No.
FW-2-2 and FW-1
RC-1-RB-05
12-RC-1-007-2501R1
FW-8 and 8-1A
SI-1-RB-60
10-SI-1-181-2501R1
FW-7
SI-1-RB-053
8-SI-1-091-2501R1
FW-20
SI-1-RB-016
6-SI-1-101-2501R1
W-19, W-18, W-21 & W-20 RC-2-RB-071
3-RC-2-111-2501R1
W-32, W-37, W-33 & W-35 RC-2-RB-071
3-RC-2-146-2501R1
W-36 & W-34
RC-2-RB-071
3-RC-2-146-2501R1
W-31
RC-2-RB-071
6-RC-2-108-2501R1
FW-5-1
CT-1-RB-020
6-CT-1-075-301R2
W-14
SI-2-SB-045
4-SI-2-039-1501R2
FW-10
FW-1-SB-017
18-FW-1-034-2003-2
No violations or deviations were identified.
6.
Design and Installation of Pipe Supports and Restraints
The RRI selected eight pipe supports and restraints associated with
Line 12-SI-1-031-152R2 and which represent all of the supports installed
as of this inspection period and about half the total of those to be
installed on the line by completion of construction.
The objective of
the inspection was to determine whether:
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a.
The supports and restraints had been fabricated utilizing
the specified materials shown on the design drawings and that
the workmanship was commensurate with the requironents of the
applicable Code, ASME Section III.
b.
The QA/QC documentation adequately reflected the quality of
construction.
c.
The design had been adequately reviewed where field changes
had been required.
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The RRI watained the current drawing for each selected item and inspected
the items for conformance to the drawings with particular emphasis being
placed on the size of the concrete anchor bolts used to attach the
items to the building structure and to the quality of the welds involved.
Several of the items were found to have been painted which would
effectively mask any cracks in the welds that might be present but the
size and general appearance of the seld could be effectively verified.
The remaining items were not painted and could be fully examined.
It
was found that each support and restraint had been fabricated from
the materials specified and that the anchor bolts were of the diameter
and length required with full embedment.
The welding was of the
correct size and the surface appearance indicated sound workmanship
with no evidence of cracking.
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The RRI obtained and reviewed the QA/QC documentation for each item.
The documentation was found to adequately reflect the quality of construc-
tion including the identification of materials and the welder.
All were
qualified for the process and procedure used.
One of the selected items
was a mechanical type snubber wherein the snubbers were noted during
the physical inspection as not having been installed.
This fact was
appropriately noted on the QA/QC documentation.
The documentation also
reflected that the anchor bolt tightening (preload) values had been
verified as required by site procedures.
The RRI noted that four of the eight drawings had been modified by site
engineering via Component Modification Cards.
The site engineering
procedures and instructions require that such modifications be reviewed
after the fact by an independent design review group to assure that the
modified item will safely carry loads.to be imoosed on the item during
normal and emergency conditions.
None of the items in the inspection
sample had actually been through the review process although each
was identified to be scheduled for review in the future.
One of the
review group engineers did, however, take the RRI through the cal-
culational series using the procedural documentation to show how the
review is conducted.
The RRI noted in the process that the engineer
used a calculated embedment depth for the concrete anchor bolts rather
than the minimum embedment depth specified by site Construction Procedure
CEI-20 which details the installation process for the anchor bolts and
is particularly applicable when embedment depth is not specified by the
drawing as was the case with all of the samples selected.
The engineer
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explained that his calculated embedment was that which would have to be
obtained to preload /'orque) the bolts, considering the specified bolt
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length.
The RRI con.urred in the logic but asked how he verified
that no shimming / grouting had taken place between the hanger baseplate
and the ceiling to which it was being secured.
The engineer replied
that such shimming / grouting was not reflected on the as-built QA/QC
records (in the possession of the RRI during the interview) which was
also true.
The RRI subsequently reviewed other drawings in the sample
and concluded that the original designers had also assumed that no
shimming and grouting would be necessary in securing other comparable
supports and restraints.
Considering that the RRI had verified during
this inspection (and the previous one, Inspection Report No. 50-445/81-01)
that only specified anchor bolts had been used and that shimming / grouting
had not been encountered, it appeared that the designer and/or design
reviewers assumptions were valid.
The RRI was concerned, however, because
the site Construction Procedure CPM-9.10 for hanger installation allows
such shimming and grouting where necessary and without engineering
concurrence.
The companion QA/QC inspection procedure does not require
documentation of the shimming and grouting on the as-built QA/QC record
although a document is generated to assure that the grouting is accomplished
by another element of the construction force.
The RRI discussed the
above concern with both the licensee's QA management and engineering
management who committed to identifying any supports that may have been
shimmed and grouted in the past; to refining the procedures to eliminate
the possibility that embedment of anchor bolts less than that predicated
by the design would occur without appropriate documentation; and to
reanalyzing any subsequently identified cases where this may have
occurred.
Since only a potential for noncompliance was identified in
the course of this inspection rather than an actual noncompliance, this
matter will be considered to be an unresolved item which will hereafter
be identified as " Engineered Depth of Concrete Anchor Bolt Embedment."
No violations or deviations were identified.
7.
Unresolved Items
Unresolved items are matters about which more information is required
in order to ascertain whether they are acceptable items, violations
or deviations.
An unresolved item disclosed during the inspection is
discussed in paragraph 6.
8.
Management Meetings
The RRI met with one or more of the persons identified in paragraph 1
on February 3, 4, 6, 13, 17, 19, 20, 23, and 25, 1981, to discuss
inspection findings and the licensee's actions and positions.
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