ML20032E586
| ML20032E586 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak |
| Issue date: | 11/05/1981 |
| From: | Randy Hall, Clay Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20032E578 | List: |
| References | |
| 50-445-81-15, 50-446-81-15, NUDOCS 8111200717 | |
| Download: ML20032E586 (7) | |
See also: IR 05000445/1981015
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APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND Ef:FORCEMENT
REGION IV
Report:
50-445/81-15; 50-446/81-15
Dockets:
50 445; 50-446
Category A2
Licensee:
Texas Utilities Generating Company
2001 Brycn Tower
Dallas, Taxas 75201
Facility Name:
Comancne Peak, Units 1 and 2
Inspecticn at:
Comanche Peak Site, Glen Rose, Texas
Inspection caducted:
October 13-16 and 19-23, 1981
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Inspector:
v/r/> /
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[C.E.' Johnson,ReactorInspector,Engineeringand
Date
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Materials Giction
Other
Accompanying
Personnel:
R. E. Hall, Acting Chief, Engineering and Materials Section
(October 23, 1981)
Approved: /' /f.le
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R. E. HalIN Acting Chief, Engineering and
Date
MaterialY Section
Inspection Summary
Inspection Conducted October 13-16 and 19-23, 1981 (Report No. 50-445/81-15;
50-446/81-16)
Areas Inspected:
Routine, unannounced inspection of construction activities
incluaing a site tour and observation of work and review of records for
safely-related pipe supports, protective coatings, and restraint systems in
Units 1 and 2.
The inspection involved sixty-five inspector-hours by one NRC
inspector.
Results:
In the three areas inspected, no violations or deviations were
identified in two areas.
One violation was identified in the area of
protective coatings (violation - failure to follow procedures for the
inspection of coatings
paragraph 3.b).
8111200717 811106
DR ADOCK 05000
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DETAILS
1.
Persons Contacted
Princir al Licensee Personnel
- D. N. Chapman, Texas Utilities Generating Company (TUGCO), Quality
Assurance Manager
- R. G. Tolson, TUGCO, Site Quality Assurance Supervisor
B. C. Scott, TUGCO, Quality Engineering
Other Personnel
- J. R. Merritt, Texas Utilities Services, Inc., (TUSI), Engineering
and Construction Manager
J. V. Hawkins, Brown & Root (B&R), Project Quali / Assurance Manager
H. Williams, B&R, QC Superintendent, Non-ASME
J. Ragan, B&R, Site QC Manager
The NRC inspector also contacted other licensee and Brown & Root
employees during the inspection period including both craft labor and
QA/QC personnel.
- Denotes presence at the exit interview conoucted October 23, 1981.
2.
Site Tour
The NRC inspector toured the site several times during the inspection to
observe construction activities in progress and to inspect housekeeping.
The areas toured included the Units 1 and 2 Reactor Containment Buildings,
Safeguards Building, Auxiliary Building, paint shop, and paint warehouse.
There were no violations or deviations identified.
3.
Protective Coating
a.
Concrete Coatings Application
The NRC inspector reviewed six records of protective coating
application on concrete in Reactor Containment Building No. 2.
The NRC inspector identified some procedural inconsistencies
including those listed below.
(1) no inspector initials or signature
(2)
incorrect pot life specified or indicated
(3) dates missing
(4)
induction time signed N/A when there should have been a
minimum time listed
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In four of the six records observed, the finish coat had been
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applied; however, checklists documenting the preceding applications
had neither been completed nor finally accepted. The majority of
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the inspection docuiaentation had not hac final acceptance.
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The NRC inspector informed the. licensee representative of the
discrepancies found. The licensee representative then informed the
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NRC inspectcr that they were aware of the problems. After a brief
discussion, the licensee representative showed the NRC irspector an -
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audit report performed during September 14-18, 1981, by TUGC0 QA
pertaining to this matter. The audit report was' titled, " Protective
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Coatings," QA Audit File: TCP-24. This audit identified the same
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deficiencies as did the NRC inspector. The scope of the audit
included receiving, storage and handling, certifications, measuring
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and testing equipment, application, and inspection documentation
regarding protective coatings on concrete. This audit requested a
response to the deficiencies and concern: identffied by November 6,
1981.
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This matter will be listed as an unresolved item until a satisftctory
reply to the QA Audit, TCP-24 has been documented in a timely manner
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and reviewed by an NRC inspector on a subsequent inspection.
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b.
Steel Coatings Application
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The NRC inspector also reviewed records on protective coating appli-
cation on steel. During the review of these records, the NRC
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inspector noticed that the most current records for miscellaneous
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steel and supports dated from late September 1979 and back. The
NRC inspector reviewed one package which contained several records
of miscellaneous embedments and door frames in Reactor Building No. 2.
This cackage contained documents that were not properly filled out
or Mere incomplete. For example, dry film thickness (OFT) of primer
after application was not recorded and initialed by Quality Control
inspectors on the checklist prior to application of the seal coat as
required. The NRC inspector also noticed incorrect pot life require-
ments on the protective coating material identification and mixing
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checklist. The licensee representative was informed of the defi-
ciencies noted by the NRC inspector.
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The NRC inspector inquired about records of inspection conducted
since September 1979. The licensee representative informed the
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NRC inspector that from late September 1979, there had been no
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checklists maintained as required by the procedures for miscella-
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neous steel, cable tray supports, and pipe supports noted in
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paragraph 3.f below. The licensee representative presented a
log book that Quality Control was maintaining on cable tray
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supports. The licensee representative also informed the NRC
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inspector that they have maintained a log book on miscellaneous
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steel, pipe hangers, and supports. After reviewing the log book,
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the NRC inspector determined that this did not appear to satisfy
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the records requirements'of the procedures. The NRC inspector also
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reviewed protective coatings records of Unit 2 Reactor Building steel
iiner plate, from September 1980 to October'1980.
In reviewing these
records, the NRC inspector noticed that documentation on the " Steel
Substrate Primer Application Checklist" had not been completely filled
out prior to seal coat applications as required by procedure.
This appears tol be in violation of procedural requirements and
10 CFR 50, Appendix B, Criterion V.
c.
Paint Shop
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The NRC inspector toured the paint shop and reviewed coating records
in process by a Quality Control inspector. All records reviewed at
the paint shop appear to conform to Procedures QI-QP-ll.4-1,
QI-QP-ll.4-2, and QI-QP-ll.4-3 as listed in paragraph 3.f.
The NRC
inspector discussed procedural requirements with the Quality Control
inspector in char ge of the paint shop. The Quality Control inspectcr
demonstrated an apparent level of knowledge sufficient to inspect
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protective coating on steel.
The NRC inspector also discussed procedural requirements and qualifi-
cations for applicators with a paint foreman. The paint foreman also
appeared to have the level of knowledge required for protective
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coating applications.
During the tour, the NRC inspector observed some sandblasting taking
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place; however, there was no coating application going on at the time
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on safety-related items.
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There were no violations or deviations identified.
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d.
Paint Warehouse Storage
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The NRC inspector toured the "Q" paint warehouse and randomly inspected
for opened containers and expired dates for shelf life of containers.
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There are two warehouses, one a non "Q" and the other a "Q'" warehouse.
The NRC inspector verified the readings of the temperature recorder
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which varied between 70 degrees and 75 degrees. The temperature was
well within the specification. The temperature recorder calibration
date was current. The NRC inspector reviewed records of the temper-
ature charts and the surveillance checklist for storage and control
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of coatings. The temperature charts covered from January 1,1981, to
August 31, 1981, and the temperature was maintained within the speci-
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fied range. The checklists were filled out and signed. The only
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discrepancy noted on the checklist was in the block " shelf life
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expired", which had been checked in the "yes" blocks. After inquiring
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into this matter, it was found to be in error since the shelf life had
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not been exceeded. This was an isolated case which was immediately
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corrected.
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There were no violations or deviations identified.
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e.
Qualification Records (Coatings)
The NRC inspector reviewed qualificati^n records for six Quality
Control inspectors and ten painters.
The Quality Control inspectors
and painters selected for review were indicated on the records of
six safety related items which had been painted and inspected.
The
NRC inspector traced the qualifications of each Qualitiy Control
inspector and painter on the records during that time period to verify
each individual's qualifications.
All Quality Control inspectors and
painters were qualified during the period of applications.
There were no violations or deviations identified.
f.
Review of Coating Procedures
The NRC inspector reviewed the coating procedures listed below.
All procedures reviewed appeared to include sufficient instructions
and appropriate quantitative and qualitative acceptance criteria for
determining that important activities would have been satisfactorily
accomplished.
Procedures reviewed:
Steel
CP-QP-ll.4, Revision 4, " Inspection of Protective Coatings"
QI-QP-ll.4-1, Revision 3, " Inspection of Steel Substrate Surface
Preparation"
QI-QP-ll.4-2, Revision 4, " Inspection of Steel Substrate Protec-
tive Coating Mixing Operations"
QI-QP-ll.4-3, Revision 5, " Inspection of Steel Substrate Prime
Coat Applications"
QI-QP-ll.4-5, Revision 4, " Inspection of Steel Substrate
Finish Coat Application"
QI-QP-11.4-17, Revision 1, " Storage and Handling of Protective
Concrete
QI-QP-ll.4-10. Revision 1, " Inspection of Concrete Substrate
Surface Preparation"
QI-QP-ll.4-12, Revision 1, " Inspection of Concrete Substrate
Surface Application"
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QI-QP-11.4-14, Revision 1, " Inspection of Concrete Substrate
Finish Coat Application"
There were no violations or deviations identified.
4.
Safety-Related Pipe Support and Restraints
a.
Moment Limiting Components
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spector toured Unit 1 Reactor Containment Building and
randomly selected three monient restraints listed below for inspection:
(1) S-1-0538-06 - Safety Injection System (incomplete)
(2) 5-1-0538-02 - Safety Injection System (complete)
(3) S-1-0538-08 - Chemical and Volume Control System (complete)
The NRC inspector visually inspected the completed moment restraints
in accordance with referenced design drawings. Welds, attachments,
and location all appeared to be in compliance with design drawings.
The NRC inspector reviewed the traveler package contents on work
being performed in Unit 1 Reactor Containment Building, on the
Safety Injection vertical line restraints in each of the four steam
generator compartments.
All documentation appeared to be in the
traveler package as required.
All changes and modifications had
been approved.
The moment restraints reviewed were all fabricated by an off-site
vendor.
The constructor erected, aligned, and welded as required
by the design drawings.
The records of the two completed restraints indicated that verifi-
cation of elevation, location, plumb, and levelness had been verified
by Quality Control.
All welds were in accordance with design drawings
and verified by Quality Control.
Completion of all operations were
verified, signed, and initialed by Quality Control.
The NRC inspector
verified welder qualifications from the completed travelers and also
for work in process in the field.
All welders were found to be
qualified by procedure for the work being performed.
b.
Pipe Supports
The NRC inspector reviewed the records of five pipe supports.
The
records indicated the type and classification of the supports.
The
records confirmed that the specifications and installation procedures
had been met.
The required scope of QA/QC inspections was met. Weld
identification and location corresponded to respective weld card,
drawirig, and work order.
Welders were qualified for the welding
procedures used.
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Records reviewed were for the pipe supports listed below:
CT-1-029:118-C82S - (Contrinment Spray System)
CT-1-014-421-C62R - (Containment Spray System)
CT-1-031-307-C92R - (Containment Spray System)
CS-1-074-047-542R - (Chemical and Volume Control System)
CS-1-074-041-542R - (Chemical and Volume Control Syste.1)
There were no violations or deviations identified.
S.
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 this inspection is dis-
cussed in paragraph 3.a.
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6.
Exit Interview
The NRC inspector met with tSe licensee representatives (denoted in
paragraph 1) and R. G. Taylor, NRC Resident Reactor Inspector, on
October 23, 1981, and summarized the purpose, scope, and findings of
the inspection.
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