IR 05000445/1985003

Insp Repts 50-445/85-03 & 50-446/85-02 on 841219-850331.No Violations or Deviations Noted.Major Areas Inspected:Action on Previous findings,applicant-identified Design/Const Deficiencies & Review of Afco Steel Purchase Order

ML20137Q457
Person / Time
Site:	Comanche Peak
Issue date:	06/04/1985
From:	Cummins J, Hunnicutt D, Phillips A, Phillips H, Tapia J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20137Q436	List: IR 05000445/1985003 ML20137Q432
References
50-445-85-03, 50-445-85-3, 50-446-85-02, 50-446-85-2, IEB-84-03, IEB-84-3, NUDOCS 8509200166
Download: ML20137Q457 (15)

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I APPENDIX U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-445/85-03 Permit: CPPR-126 50-446/85-02 CPPR-127 Docket: 50-445; 50-446 Category: A2 Appplicant: Texas Utilities Electric Company (TUEC) .

Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 and 2

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Inspection At: Glen Rose, Texas Inspection Conducted: December 19, 1984 through March 31, 1985 Inspectors:f Mk

1. J. E. Cummins, Senior Resident Reactor M.27/Ff'

Da'te Inspector (paragraphs 2, 3, 4, 5, 7, 10, 11, and 13)

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, 2f- &i H.~S. Phil' lips, Senior Resident Reactor

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s/21/ss Date Inspector (paragraphs 11 and 13)

cs Dw6s p J. I. Tapia, Reactbr Inspector, Project abc Date Section 8 (paragraph 8)

4A h D. M. Hunnicutt, Chief, r/a v/rs Date /

Reactor Project Section B (paragraphs 6, 9, and 12)

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-2-Approved:

reworked and reinspected. Procedure QI-QAP-11.1-28A,

" Installation Inspections of ASME Class 1, 2, and 3 ,

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-5-Snubber", was deleted and the snubber inspections incorporated into Procedure QI-QAP-11.1-28, " Fabrication and Installation Inspection of ASME Component Supports, Class 1, 2, and 3." Revision 24 to QI-QAP-11.1-28 was issued to clarify the requirements for snubber and sway strut installations and appropriate inspection personnel were retrained in the correct configuration for snubber and sway strut installations. The generic implications of this issue require further review. This matter remains ope . Action on Applicant Identified Design / Construction Deficiencies (10 CFR Part 50.55(e) Reports) (Units 1 and 2)

The 10 CFR Part 50.55(e) reports discussed below were reviewed by the NRC inspector and closed. The reports were reviewed for content, compliance with NRC requirements for reporting, appropriate applicant evaluation, and adequacy and implementation of corrective action. Each report is identified and tracked by the unique, applicant assigned numbe CP84-02 Applicant's letter (TXX-4108) dated February 8, 1984, reported to the NRC that' linear indications had been found on the emergency, diesel generator engine push rods. The applicant has replaced the push rods in both of the Unit 1 diesel generators and will replace them in the-Unit 2 diesel generators prior to operation of Unit NRC inspector observations during the teardown, inspection and reassembly of the Unit'l emergency diesel generators was reported in NRC Inspection Reports 50-445/84-17 and 50-445/84-2 CP84-04 The applicant reported by-letter (TXX-4109) dated February 13,'1984, that three of the four Unit i safety-related inverter ferroresonant output transformers had failed. This 10 CFR 50.55(e) report to the NRC was discussed _in NRC~ Inspection Report No. 50-445/84-22; 50-446/84-07. The transformers have been modified by the vendor to correct the defec CP84-33 The 10 CFR Part 50.55(e) report was initiated by the applicant based on a 10 CFR Part 21 report made by Brown Boveri. The 10 CFR Part 21 reported that voltage balance relays (Model ITE-60) were found that operated outside specified operating times. Brown Boveri notified the applicant by letter dated November 13, 1984, that the problem did not exist for the Brown Boveri (ITE)

switch-gear furnished to the applicant. The applicant also perfonned a review and determined that the questionable relays were not used at CPSES. The applicant reported by

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-6-letter (TXX-4376) dated December 10, 1984, that this item was not reportabl . Inspection and Enforcement Bulletin (IEB) Followup (Units 1 and 2)

The NRC_ inspectors reviewed the applicant's file for the IEB discussed below and performed inspections as necessary to verify that the applicant had conducted ar adequate review to determine if the IEB was applicable to the CPSES facility, and to verify that the applicant had taken the action required by the IE IEB 84-03: Refueling Cavity Water Seals This bulletin identified a potential loss of water from the refueling cavity and spent fuel pool due to the failure of the refueling cavity seal during refueling operations. The bulletin was issued because an incident of this type occurred at the Haddam Neck Nuclear Plant. As directed by the bulletin, the applicant evaluated the potential for and consequences of a refueling cavity water seal failure at the CPSES site. The applicant's response letter (TXX-4373) dated December 4, 1984, reported that the refueling cavity water seal at CPSES is a different design from the seals used at Haddam Neck. The refueling cavity water seal at CPSES is a stainless steel ring that is permanently welded in place and does not require the use of any pneumatic type device. The CPSES refueling cavity water seal design is less likely to experience a gross failure than seal designs utilizing pneumatic seals or gaskets. The applicant determined from the evaluation that level alarms located in the containment building sump and the spent fuel pool would detect leakage from the refueling cavity or spent fuel pool and that makeup water sources would be available in the event that there was a leak. Prior to the first refueling, the applicant will revise applicable procedures to check the refueling cavity for leakage and to explicitly address 'a leak in the refueling cavity seal. The NRC review of the refueling cavity leakage check and refueling cavity seal leak procedures during a subsequent inspection is an unresolved item (445/8503-01; 446/8502-01).

' Review of Afco Steel Purchase Order Package for Fuel Building Liner Plates (Unit 1 and 2)

In response to an allegation, the NRC inspector reviewed the Afco Steel

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package for P0 No. 35-1195-14911 (Job No. and Account 35-1195-1-0-1312-193703-002) from Brown & Root, Inc. (B&R) to Afco Steel, Little Rock, Arkansas, Change Orders, letters of approval, and related

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. correspondence to this P0 to determine whether B&R had improperly cancelled their contract with Afco Stee . .The P0 was let by B&R to Afco Steel on July 6, 1977, for stainless steel i liners (S/SL)'and gates for the two spent fuel pools, the S/SL transfer

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canal, and the S/SL wet cask loading pit. The P0 requirements were i

specified by Gibbs and Hill (G&H) (Specification 2323-SS-18, Revision 2; 2323-SS-7, Revision 1; 2323-SS-20 Revision 4; and drawings M1-0014, Revision E; M1-0015, Revision E; S-0831, Revision 1; S-0832, Revision 1;-

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S-0833, Revision 1: S-0834, Revision 1, and SI-0560, Revision 3). The P0 .

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specified that " Safety Related QA was Required."

During the course of the contract, B&R processed twelve: Change Orders

. between the dates of August 5, 1977, and July 31, 1978. These change orders were required to incorporate changes in scope of work with '

c drawings, tolerance requirements, method of transmittal of documents, '

i material additions required, amendments related to monetary conditions, and reductions in materials require !

A B&R letter (BRF-8550), dated July 13, 1978, stated in part ". . . . please find a Change Order request from Afco Steel on P0 35-1195-14911 in which they supplied the stainless steel liner for the Fuel Building. . . ."

This letter also stated that B&R felt the listed monetary credits were

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reasonable and justifie The NRC inspector's review of the documentation revealed no apparent discrepancies regarding the contract between B&R and Afco Stee No violations or deviations were identifie . Followup of 10 CFR Part 21 Report (Unit 1)

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The NRC inspector reviewed documents related to a potential 10 CFR Part 21 report from RTE Delta. RTE Delta reported via letter dated April 3, 1984, to the Director of NRC Region IV that Texas Utilities Services Incorporated (TUSI) (the responsible organization name was later changed '

to Texas Utilities Generating Company), had possibly violated

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10 CFR Part 21 requirements by actions TUSI had taken in replacing type

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CFD' differential relays in the diesel generator control panels. The NRC inspector reviewed the following documents: RTE Delta letter to the Director, NRC Region IV, dated April 3, 1984.

4 Transamerica Delaval (TDI) letter to TUSI dated April 12, 198 _ Texas Utilities letter to TDI dated August 24, 1983.

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. Comanche Peak Deficiency Review Report-(DRR) No. 046.

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-8- Construction Operation Travelers Z-2485 and Z-248 Qualification Report NES 26291-1TR, IEEE Qualification Report for Generator Control Pane TUGC0 P0 CPF-11509-5 TUGC0ReceiptInspectionReport(RIR)24286 The NRC inspector determined from review of these documents and discussions with appropriate applicant personnel that the CFD relays were replaced by the applicant with prequalified General Electric type IJD52-A relays. The applicant also revised Qualification Report NES 262991-1TR, IEEE Qualification Report for Generator Control Panel-(G&H Specification 2323-MS-34, Revision 1) to reflect the change in these relays. General Electric documentation that verified the relay qualification was attached to the qualification report for the diesel generator control panel TUSI provided TDI with specifics of the replacement relay type IJD 52-A by letter dated August 24, 1983. When notified by letter dated April 12, 1984, from TDI of the possible 10 CFR Part 21 violation reported by RTE

" elta, the applicant initiated a review (documented on DRR No. 046) to

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evaluate the situation. The conclusion of the TUSI evaluation was that TUSI was responsible for onsite revisions or modifications and that the activities related to the relay change had been adequately documente No violations or deviations were identifie . Concrete Placement (Unit 2)

The NRC inspector reviewed quality related procedures relative to the proposed placement of the Unit 2 containment building construction opening structural concrete. The review was conducted to ascertain whether these procedures reflected proposed work accomplishment' consistent with NRC requirements and Safety Analysis Report commitments. The following procedures for the proposed concrete placement in the Unit 2 containment wall were reviewed:

B&R Procedures

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No. 35-1195-CCP-12, Rev. 4, " Concrete Patching, Finishing and Preparation of Construction Joints" No. 35-1195-CEI-24, Rev. O, "Rebar Prepour Inspection for Containment #2 Exterior Only"

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-9-No. 35-1195-CCP-14, Rev. 4, " Concrete Prepour Inspection and Pour Card Sign Off" No. 35-1195-CCP-10, Rev. 5 " Concrete Batch Plant Operations" No. 35-1195-CCP-11, Rev. 0, " Concrete Placement"

,. No. 35-1195-CCP-13 Rev. 3, " Concrete Curing" TUGC0 Procedures No. CP-QP-11.0, Rev. 4, " Civil Inspection ~ Activities"

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No. QI-QP-11.0-3, Rev. 5, " Concrete or. Mortar Placement Inspection" No. QI-QP-11.0-2, Rev. 4, " Reinforcing Steel, Miscellaneous Steel and Embedded Item. Placement Inspection" No. QI-QP-11.0-1, Rev. 5 "Cadweld Inspection' Activities" No. QI-QP-11.0-8, Rev. 2, " Concrete Production Inspection"

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No. QI-QP-11.0-4, Rev. 4, " Summer Concrete or Mortar Curing Inspection" l The procedures were found to comply with NRC requirements and Safety Analysis Report commitments. Specifically, the applicable portions of the following documents were found to have been incorporated in the review procedures:

American Concrete Institute Documents No. 318-71, " Building Requirements for Reinforced Concrete" No. 301-72,'" Specification for Structural Concrete for Buildings" No. 614-59, " Recommended Practice for Measuring, Mixing, Transporting, and Placing Concrete" No. 308-71, " Recommended Practice for Curing Concrete" Although a specific concrete placement plan had not been developed for the

construction opening, discussions were held with the engineers responsible for its generation. Since the actual-plan was not expected for another

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six weeks.:a similar placement plan previously used in the auxiliary building was presented to show those attributes to be considered. The'

proposed placement plan contents were also found to consider those admonitions from the American Concrete Institute which, when employed, will yield satisfactory concrete placement t No violations or deviations were identified. . ._,_ .- . . - _

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-10-l 9. Reinforcing Steel Splices (Unit 2) Records Review of Crew Qualifications The NRC inspector reviewed the qualifications records of 16 cadweld personnel. Applicable experience and education for each person was included in the qualification records. The records indicated that each person had prepared two qualification splices for each of the threecadweldsplicepositions(horizontal, vertical,anddiagonal).

The cadweld splices were made using No. 18 reinforcing bars (rebar).

Each cadweld splice met the requirements specified in Regulatory Guide 1.10. " Mechanical (cadweld) Splices in Reinforcing Bars of Category I Concrete Structures" and G&H Specification No. 2323-SS-11, Revision Each cadweld crew member had been instructed by a representative of the manufacturer in the preparation of cadweld splices for each of the three splice position Each cadwelder had been assigned a unique identification number (symbol) consisting of two letters, Observations of Cadwelding of Rebar The NRC inspector observed five preparations for cadwelding rebar splices on five different days and observed the following:

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(1) the ends of the rebar were cut reasonably square, were clean and free from slag or adhered weld splatter or rust scale, and a reference line had been marked on each rebar; (2) the rebar ends and the cadweld splice sleeve were checked for location (centering);

(3) the fiberglass rope was properly inserted into the spaces between the splice sleeve and the rebar; (4) the cadweld carbon receptacle which acts as a receiver for the cadweld powder and a carbon funnel to channel the ' molten metal into the sleeve volume to form a splice between the two rebar ends and the splice sleeve was properly and securely attached prior to loading the cadweld powder; (5) after each cadweld splice had been completed and permitted to cool, the weld surface area was cleaned and inspected; (6) the acceptance standards for visually inspected cadweld splices were in accordance with American Weld Society (AWS) D1.1-72,

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. Section 8.15, Regulatory Guide 1.1 and G&H Specification No. 2323-5S-11, Revision 2; and '

(7) rejected (unacceptable) cadweld splices were removed in accordance with AWS D1.1-72. Section Nonconformance Report (NCR) on Rebar Due to Longitudinal Seams A No. 18 rebar was tagged with an NCR (C-85-200-210) due to longitudinal seams identified during visual inspection. A representative from the rebar fabricating company inspected this rebar and other rebar with visually observed seams. The representative evaluated the seams and submitted a letter discussing rebar seams. The letter, dated March 14, 1985, and supporting test results indicated that longitudinal tensile tests on rebar with seams in excess of 3/4" have been performed. The test results indicated that no propagations or failures in full section (the cross sectional area is 4 square inches) testing occurred in tests performed in accordance with Specification ASTM A-615 which is designed for tensile testing in the longitudinal directio Rebar Certifications Material Specifications The NRC inspector reviewed the certifications for No.18 reba Those certifications indicated that the rebar conformed to the requirements of ASTM A-615-72, Grade 60. The certified minimum yield strength is 60,000 psi. The minimum certified ultimate strength is 90,000 psi. The minimum certified elongation is 7 percent in 8 inche No violations or deviations were identifie . NRC Region IV Followup on Special Review Team (SRT) Identified Deficiencies (Unit 1)

During the period from April 3, 1984, to April 13, 1984, the NRC SRT conducted a review at the CPSES site, of activities related to construction, inspection and testing. Details of the SRT review were documented in a report that was transmitted to the applicant via letter dated July 13, 1984. In Section E.b.(8), page 36, of the report the NRC SRT inspectors noted 14 deficiencies in pipe supports that were identified during a field walkdown in the Unit 1 containment building. Two of these deficiencies (Supports CC-1-295-005-C53R and MS-1-151-025-C52K) were considered to be a potential enforcement item and the details of the Region IV followup action for these two supports were reported in NRC Inspection Report No. 50-445/84-34; 50-446/84-13. The NRC inspector

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-12-verified that the applicant had taken adequate action to correct nine of the remaining deficiencies by reviewing the applicant's documentation, discussions with cognizant applicant personnel, and field inspections as necessary. The nine SRT deficiencies inspected during-this report period are listed below. The applicant's NCR that documented the corrective action is also listed. To preclude repetition Quality Instruction QI-QAP-11.1-28A was deleted and revision 24 was issued to address more

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clearly sway strut and snubber installatio Support N Status NCR CC-1-218-012-C53K Snubber connection cotter keys missing M-13377 CT-1-038-436-C62K Snubber connection cotter keys missing M-13380 No washers in rear bracket CT-1-117-405-C62K Snubber connection cotter key missing M-13383 CT-1-117-415-C62K Snubber safety wire broken M-13382 CT-1-053-444-C62K The south snubber was installed M-13376 improperly DD-1-046-020-C65R Snubber cotter keys missing M-84-01113 FW-1-096-705-C62K Snubber safety wire broken M-13381 FW-1-102-002-C62K Snubber cotter key missing; needs M-13379 relative adjustment on snubber FW-1-102-003-C62R Snubber cotter keys not bent M-13378 No violations or deviations were identifie . Special Plant Tours (Unit 1)

On January 10, 1985, the NRC inspector conducted a tour of selected areas of Unit 1 and Unit 2. The group consisted of two NRC inspectors, a Technical Review Team (TRT) representative, two NRC consultants, and two allegers (who were brought to the site to specifically locate hardware which had previously been alleged to be deficient). With the allegers'

consent a tape recorder was used to note locations and describe any alleged deficiencies. The TRT recorded this information and will decide what action should be take During this plant tour a portable welding rod oven was observed to be empty and was without paperwork. The NRC inspector discussed this with a

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B&R supervisor to determine how long the welding rod had been outside the heated oven. The welding supervisor did not know who had checked out the oven and welding rod; did not know what procedure controlled welding rods; did not-know the general content of the procedure which controls welding rod material; and could not find the procedure in his work area. The NRC inspector further determined that 13 welders worked for this supervisor and that the welding oven in question-belonged to this supervisor. He was asked how he knew his men were following procedures, if he did not know the requirements of the procedure. He replied that he relied on his men and the training they had received.s Although the paperwork was not at the portable oven, the welder (who was assigned this oven) had the paper-work with .the subject welding rod. The welding rod material had not exceeded the time that it was allowed to be out of the ove The NRC inspector' discussed this matter with TUGC0 Assistant Project General Manager and as a result 73 welding supervisors were retrained and tested on CPM 6.93 "Wald Filler Material Control." One of 73 failed the test after receiving trainin In addition, training was administered to welding supervisors concerning other welding procedures depending on their scope of responsibility. The following are the results:

Procedures No. Persons Test Failures WES 29 (Welding Structural Steel) 43 3 CP-CPM 9.10 (Welding ASME Hangers) 36 0 CP-CPM 6.9D (Welding Piping and 37 6 Components)

A B&R Memo (28140) dated January 15, 1985, indicated that after additional training was given all passed the test. -This memo indicated that the reason for the failure was the fact that the individuals only occasionally used or needed to refer to a specific type item. One failure was attributed to a supervisor having no welding related responsibilitie ' The NRC inspector considers this item unresolved pending further review (446/8502-01).

On February 5,1985, the NRC inspector conducted a plant tour with the NRC Contention Panel 5 members. The purpose of the tour was to observe the quality of construction in Unit 1 and to observe some of the deficiencies

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-14-identified by the NRC to TUEC management in a series of meetings between the NRC TRT members and TUEC management, staff, and consultant On February 25, 1985, the NRC inspector conducted a tour for a number of NRC licensing personnel and NRC consultants to observe mechanical hangers, restraints, and snubbers throughout Unit On March 7,1985, the NRC inspector and a TRT member from NRR conducted an inspection of selected areas in Unit 1. The purpose of this inspection was to allow an alleger to physically identify areas that were alleged to be deficient. . Several NRC consultant personnel, who were members of the TRT and who had followed up on specific allegations, went=along to .

evaluate specific deficiencies that were to be pointed out. With the consent of.the alleger, a tape recorder was used to' note locations'and describe the alleger's concerns. This inspection centered on visually inspecting the stainless steel liner plate in Units 1 and 2 reactor refueling cavities and the copper-nickel tubes in the condenser. The TRT recorded this information and will decide what action should be take No violations or deviations were identifie . Alleged Improper Construction Practices Involving CPSES Main Condensers (Unit 1)

A potential safety concern from an alleger was forwarded to TUEC by an NRC letter dated June 19, 1984. The allegation had been expressed during an interview conducted on August 24, 1983, by members of the NRC Office of Inv_estigation (01) Field Office. The allegation concerns were assessed by the TRT and were documented in NUREG-0797, Supplement No. 8, pages K-111 through K-11 The NRC inspector reviewed the applicant's July 9,1984, response to the NRC June 19, 1984, letter. NRC inspectors _ performed inspection activities during the scheduled Mini-Hot Functional Testing (Mini-HFT) Program ~during late 1984. NRC inspection observations and a review of NCR 84-0229 determined that the condenser was of acceptable cleanliness immediately prior to and during the Mini-HFT test period.- NCR 84-0229 and Revision 1 to NCR 84-0229 indicated that following HFT during the period between

' January 1983 and May 1983 debris collected in the condensers as a result of various work activities performed between mid-1983 and mid-1984; however, the debris was removed prior to the start of the Mini-HFT. The Unit I condenser is clean and closed at the present time. Surveillance of the condenser. cleanliness will be determined by the applicant through water sampling and analyses. The water analyses will determine water purity (quality)-as required by Procedure STA-610 " Secondary Water Chem _istry Control Program," Revision 2. The water will be analyzed for chlorides, dissolved oxygen, silicone, and other chemical compounds to

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determine the purity of the water and assure that deleterious chemicals do not remain in the water for _the secondary side of the steam generator No . violations or deviations were identifie . Routine Plant Tours (Units 1 and 2)

At various times during the inspection period, the NRC inspector conducted general tours of the reactor building, fuel building, safeguards building, electrical and control building, and the turbine building. During the tours the NRC inspector observed housekeeping practices, preventive maintenance on installed equipment, ongoing construction work, and discussed various subjects with personnel engaged in work activitie No violations or deviations were identifie . Exit Interviews The NRC inspectors met with members of the TUEC staff (denoted in paragraph 1) at various times during the course of the inspectio The scope and findings of the inspection were discussed. The applicant acknowledged .the finding +

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