ML20140H954

Insp Repts 50-445/86-04 & 50-446/86-03 on 860101-0314. Violation Noted:Distribution of Drawings W/O Evidence of Review & Approval by Authorized Personnel & Failure to Perform Required Detailed Receiving Insps

ML20140H954
Person / Time
Site:	Comanche Peak
Issue date:	03/24/1986
From:	Barnes I, Wagner P, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20140H904	List: IR 05000445/1986004 ML20140H899 ML20140H954
References
50-445-86-04, 50-445-86-4, 50-446-86-03, 50-446-86-3, NUDOCS 8604040234
Download: ML20140H954 (8)

See also: IR 05000445/1986004

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APPENDIX A

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: .50-445/86-04 Construction Permits: CPPR-126

50-446/86-03- CPPR-127

Dockets: 50-445 Category: A2

50-446

Applicant: Texas Utilities Electric Company

400 North Olive, L.B. 81

Dallas, Texas 75201

Facility Name: Comanche Peak Steam Electric Station-(CPSES), Units 1 and 2

Inspection At: Glen Rose, Texas

Inspection Conducted: January 1 through March 14, 1986

Inspector:

P. C. Wagner, Reactos

N7b Inspector, Region IV

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CPSES Group

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Consultants: EG&G - A. Maughan

Parameter - J. Gibson

Reviewed by: hy ,,a 3/2 4t-[#'4

I. Barnes, Group Leader, Region IV CPSES Group Date

Approved: NN s

T. F. Westerman, Chief, Region IV CPSES Group

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Date

Inspection Summary

Inspection Conducted January 1 through March 14, 1986 (Report 50-445/86-04;

50-446/86-03)

Areas Inspected: Nonroutine, unannounced inspection of procurement and

installation / modification practices associated with electrical penetration

assemblies (Ef'is) furnished by Bunker Ramo Corporation. The inspection involved

350 inspector-hours onsite by three NRC inspectors and two consultants.

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8604040234 860327 *

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. Results

Within the two areas inspected, eight violations (distribution of

drawings for use containing handwritten entries without accompanying evidence of

review'and approval by authorized personnel, paragraph 4.a;' failure to identify

EPAs as nonconforming and perform required corrective actions upon receipt of

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required rework instructions, paragraph 4.b; absence of required records to

, support equipment qualification adequacy of vendor splice rework procedure,

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paragraph 4.b; failure to perform required detailed receiving inspections and to

l file a receiving inspection checklist in the records vault, paragraph 4.d;

l failure to -identify absence of required staggering of vendor cable splices,

i~ paragraph 4.d; acceptance of-EPA installation configuration not in accordance

j with drawing requirements, paragraph 5.c; failure to seal junction boxes in

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accordance with drawing requirements, paragraph 5.d; failure to support EPA

module pigtail conductors in accordance with prescribed instructions, ,

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paragraph 5.e) and one deviation (use of cable splices in trays without

submittal of Regulatory Guide 1.75 required analysis in Final Safety Analysis

j Report (FSAR), paragraph 5.a) were identified. *

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DETAILS

1. Persons Coi.tacted

• C. T. Brandt, TUGCo Quality Engineering Supervisor

• R. E. Camp, Assistant Project General Manager, Unit l'(Impell Corp.)

• D. E. Deviney, TUGCo Operations QA Supervisor

• P. E. Halstead, TUGCo Site QC Manager

• J. L. Hansel, ERC QA/QC Review Team Leader

• J. T. Merritt, TUGCo Assistant Project General Manager, Unit 2

• J. C. Smith, TUGCo Operations QA

F. D. Stobaugh, TUGCo Purchasing Supervisor

• J. F. Streeter, TUGCo Assistant to Executive Vice President

W. I. Vogelsang, TUGCo Electrical Coordinator

• J. R. Wells, TUGCo Director QA-

• Denotes those persons who attended the February 5, 1986, exit interview in

regard to NRC Inspection Report 50-445/86-01; 50-446/86-01. The NRC

inspection status with respect to EPAs was discussed during this exit

interview.

2. Background

While witnessing an applicant inspection of field installed butt splice

electrical connections in response to Comanche Peak Response Team Issue -

. Specific Action-Plan No. I.a.2, the NRC inspector noted what appeared to be

insufficient lengths of heat' shrinkable insulation tubing (HSIT) over

adjacent cable splices. Review established that the apparent HSIT length

problem was associated with vendor installed cable splices for EPA IE78.

This EPA, which was manufactured by Bunker Ramo Corporation (BRC), formed

the pressure boundary seal for the entrance of electrical conductors into a

Unit 1 containment spray valve isolation tank. This subject will also be-

identified as an unresolved item in NRC Inspection Report 50-445/85-18;

50-446/85-15.

3. Followup Inspection

During followup inspection, the NRC inspector examined other.EPAs installed

in the reactor containment buildings for Units 1 and 2. A review was also

performed of procurement history and other pertinent records, including IE

Bulletin 82-04 responses and documentation pertaining to installation and

modification of EPAs. The scope and results of these inspections are

i documented in the paragraphs below.

4. Procurement History

The facility drawings. for EPA 1E78 were reviewed on initial evaluation of

the adequacy of the HSIT length. These drawings did not, however, indicate

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the existence of the cable splices in question. The NRC inspector was

informed that the splices were considered to be an integral part of the EPA,

as a result of installation by the EPA manufacturer and, accordingly, were

not required to be specifically identified in the facility drawings. The

adequacy of this practice was not reviewed during this report period and is

considered an open item (445/8604-0-01; 446/8603-0-01).

a. Vendor Orawings: As a result of the absence of information regarding

vendor installed cable splices on facility drawings, a review was

performed of BRC EPA drawings of record maintained at the CPSES site.

Examination of Drawing 5002823, Sheet 2, showed a lined-out handwritten

note which questioned the acceptability of the identified 2-inch HSIT

length with respect to satisfying the equipment qualification require-

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ments of the HSIT manufacturer. An additional handwritten note was

entered above the lined-out note which indicated that the comments on

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HSIT length were withdrawn on the basis of field rework in accordance

with BRC Procedure 123-2286. Neither handwritten note was signed or

dated. Ten BRC drawing sheets out of a total of approximately 80 sheets

examined were observed to contain handwritten notes which appeared to

be_ questions, instructions, or concerns for vendor action. Examples

of subject material of handwritten notes were: (1) questioning of the

adequacy of the seismic support with respect to Drawing 50031814,

Junction Box; and (2) questioning of the adequacy of the stress cone

connections with respect to Drawing 50019900, " Cable Assembly," and

Drawing 50019918, " Module Pigtail Assembly, Medium Voltage."

Limited review of Gibbs and Hill (G&H) correspondence with BRC

established that some of the comments observed on the drawings had

been transmitted to the manu'acturer.

The reasons for current file BRC drawings of record containing.

questions pertaining to engineering adequacy were not established as

of the end of this report period. Copies of these drawings were

maintained in both the Document Control Center (microfilm) and TUGCo

Nuclear Engineering (TNE).

The distribution for use of these drawings is an apparent violation of

Criterion VI of Appendix B to 10 CFR Part 50 (445/8604-V-02;

446/8603-V-02).

b. BRC Procedure 123-2286 for Field Rework: Record review established

that BRC Procedure 123-2286, " Procedure to Rework L.V. Module Pigtail

Assemblies," dated February 26, 1982, was transmitted to the applicant

by G&H letter of August 10, 1982. The required rework consisted of

application on each splice of Okonite 35 tape with a 50% spiral

overlap, extending to 1 inches beyond each end of the HSIT. Field

inspection found no evidence that this required rework had been

accomplished.

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The failure to identify affected EPAs as nonconforming and implement

required corrective action is an apparent violation of Criterion XV

and Criterion.XVI of Appendix B to 10 CFR Part 50 (445/8604-V-03;

446/8603-V-03).

The NRC inspector requested applicant personnel to furnish the

information which provided the basis for establishing the equipment

qualification adequacy of the stipulated field rework of the cable

splices. ' Applicant personnel subsequently informed the NRC inspector

that such information could not be located. The absence of required

records to support the equipment qualification adequacy of this

procedure is an apparent violation of Criterion III and Criterion XVII

of Appendix C to 10 CFR Part 50 (445/8604-V-04; 446/8603-V-04).

c. Sacrificial Sleeves: During review of NRC Inspection

Report 50-445/84-12; 50-446/84-06 relative to Region IV followup

inspection of applicant actions in response to IE Bulletin 82-04,

~" Deficiencies In Primary Containment Electrical Penetration Assemblies,"

a reference was noted to use of an additional sleeve over some of the

conductors at the' module epoxy interface. Review of NRC Inspection

Report 99900116/82-01 indicated that.BRC had incorporated the sleeve

in October 1978, for the purpose of eliminating previously encountered

cracking at the epoxy-conductor interface. Examination of BRC

Orawing 50028182, Revision H, showed that the sleeve was required to

be inserted 0.28 inches' minimum into the epoxy and was to be located

0.15 to 0.18 inches from the internal conductor splice. Field

inspection identified instances where the " sacrificial" sleeve was

observed to be circumferential1y cracked. The potential for the

observed cracking to extend along the' length of the sleeve and the

close proximity of the sleeve to the internal conductor splice raise

, concerns relative to the development of an electrical leakage path

between conductors during accident conditions. This matter is

considered an unresolved item (445/8604-U-05; 446/8603-U-05).

Field inspection also identified that installed EPA modules were of

both designs; i.e., with and without sleeves over the conductors at

i~ the epoxy. module interface. From review of BRC furnished equipment

qualif.ication data, it appeared that the tested design did not utilize

sleeves. It was also not apparent from examination of G&H and TNE

equipment qualification review data for the BRC EPAs that vendor

drawings were included in the review scope. Other anomalies' were also

noted with respect to adequacy of BRC design data; e.g., prototype

helium and nitrogen leak rates were both reported as 1 X 10 scc /sec

relative to required respective maximum values of 1 X 10-6 scc /sec and

1 X 10-2 scc /sec. As a result of the above, the adequacy of the

equipment qualification review is considered an unresolved item

(445/8604-U-06; 445/8603-U-06).

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d. Receiving Inspection: A review was performed by the NRC inspector of

available receiving inspection records for EPAs IE76, 1E77, 1E78, 1E79,

2E76,.2E77, 2E78, and 2E79. When Receiving Inspection Report (RIR) 11777

was reviewed in regard to receipt inspection of EPAs 1E76, 1E77 and

1E78, it'was discovered that the attached completed inspection check-

list was applicable to cable tray parts and not the received EPAs. The

correct checklist was not located as of the end of this report period.

The failure to comply with Brown and Root (B&R) Procedure CP-QAP-7.2,

. Revision 3, requirements for filing of receiving inspection checklists

with the RIR in the records vault is an apparent violation of

Criterion VII of Appendix B to 10 CFR Part 50 (445/8604-V-07).

Review of RIR 12562 (applicable to EPAs IE79, 2E76, and 2E77) and

RIR 14284 (applicable to EPAs 2E78 and 2E79) disclosed that numerous

, checklist attributes had been marked by the receipt inspector as not

verified. Final TUGCo QA inspection at the vendor facility was waived

for these EPAs. B&R Procedure CP-QAP-7.2, Revision 3, requires for

this circumstance that the B&R QC engineer / inspector perform a detailed

receiving inspection using the checklist prepared for the applicable

item. The failure to perform detailed receiving inspections is an

apparent violation of Criterion VII of Appendix B to 10 CFR Part 50

(445/8604-V-07; 446/8603-V-07).

Review of BRC drawings relative to BRC installation of cable splices

indicated that the splices were required to be staggered. Specifically,

BRC Drawings 50028232, Revision C, dated November 22, 1978, and 50020346,

Revision F, dated April 25, 1978, contained the following note with

respect to the pigtail assemblies, " Splices shall be staggered in

location so that a ring of 2.40 inch ID can be slid over the finished

bundle up to the module." The NRC inspector noted extremely limited

staggering of the vendor splices for the seven EPAs installed in the

valve isolation tanks; i.e., IE76, IE77, 1E78, IE79, 2E76, 2E78, and

2E79. EPA 2E77 in Unit 2 was not installed because of applicant

identified nonconformances. Although specific measurements could not

be made, visual examination indicated that a ring of at least 4-inches

inside diameter would have been required to slip over the spliced

cable bundle. The failure of receipt inspection to identify the

nonconforming conditions with respect to required staggering of cable

splices in an apparent violation of Criterion VII of Appendix B to

10 CFR Part 50 (445/8604-V-08; 446/8603-V-08).

e. Source Inspection and Release for Shipment: As a result of the

identification of handwritten notes on the BRC file drawings at the

CPSES site, the NRC inspector requested to see the TUGCo QA program

procedures that were in place at the time of this procurement.

Specific procedures requested were those which addressed the

procurement interface with G&H and those which provided the criteria

used to determine source inspection requirements and release for

shipment. This information has not been received from the applicant

e as of the end of this report period. This matter is considered an

unresolved item (445/8604-U-09; 446/8603-U-09).

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5. Installation / Modification

a. Field Splices: Examination of field installed splices connecting EPA

pigtails to field cabling showed also limited staggering of splices.

The NRC inspector questioned the basis for splices being present in

cable trays, as a result of the applicant's FSAR commitment to

Regulatory Guide 1.75, Revision 1. Regulatory Guide 1.75, Revision 1,

discourages the use of cable splices in raceways because they have

been the source of a number of fires; however, limited use of splices

is permitted if an analysis has been made and the results submitted to

the NRC as part of the FSAR. The results of such an analysis had not

been included in the FSAR. This failure to comply with Regulatory

- Guide -requirements is an apparent . deviation (445/8604-D-10;

446/8603-D-10).

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b. Installed Splice Conditions: An inspection was performed of selected

EPAs to assess the visual adequacy of vendor installed splices.

During this effort, the'NRC inspector identified one conductor in

EPA 1E10 which showed exposed copper wire beyond the HSIT. This

conductor was subsequently established to not be in service. While

verifying the NRC inspector's observation, applicant personnel

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identified an additional conductor in 1E10 which showed the same-

condition and.was in service. Numerous instances were also observed

by the NRC inspector where the HSIT over the vendor installed splice

was not properly adhering to the cable jacket. The acceptability of

the vendor installed splices is considered an unresolved item

(445/8604-U-11; 446/8603-U-11).

c. Cable Support Assemblies: Review of construction operation travelers

for installation of EPAs IE76, IE77, 1E78, and IE79 showed that a

-verification was performed of the attachment of the inboard cable

support fixture to the EPA header. BRC Drawing 50022078, Revision F,

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which was applicable to these EPAs, indicated,.however, that the cable

support fixture was attached to the EPA nozzle and not the EPA header

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plate. Visual inspection showed no inboard cable support installation

was present, other than a Kellen grip external to the EPA. Acceptance

by QC of the installed configuration is an apparent violation of

Criterion V of Appendix B to 10 CFR Part 50 (445/8604-V-12).

d. Sealing of Junction Boxes: The NRC inspector noted that junction

boxes to which cables were routed from EPAs 1E44, 1E45, 1E46, and IE47

did not have the conductor entry conduit sealed as specified on

Drawing 2323-El-0514, Revision 7, dated April 13, 1984. The failure

to perform required sealing operations is an apparent violation of

Criterion V of Appendix B to 10 CFR Part 50 (445/8604-V-13).

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e. Use of Conax Modules in BRC EPAs: Visual inspection of EPA IE14

showed that the outboard cable support plate was~not attached to the

EPA header and was lying in an adjacent cable tray. The NRC inspector

verified that the removal of the cable support plate had been author-

ized on June 28,'1985, by construction traveler EE-85-40, 452-9301 in

order to facilitate cleaning. The NRC inspector additionally noted

that two Conax modules had been installed in EPA 1E14. The conductors

for these two Conax modules were observed to not currently pass through

the appropriate holes in the cable support plate. Temporary support

of the EPA cable bundle had not been provided as part of the traveler

operations for removal of the cable support plate. In that the

function of the cable support plate is to minimize applied loads at

the epoxy module interface, the absence of a temporary support is

considered an unresolved item (445/8504-U-14).

Visual inspection of 1E14 also showed that the Conax module pigtail

conductors were supported on the inboard side (reactor containment

building) at distances of 43 inches to 60 inches from the header plate.

~ Review of pertinent' instructions for Conax module installation (i.e.,

Conax Manual IPS-890, Revision E; B&R Engineering Instruction EEI-22,

Revision 0; and TUGCo Instruction QI-QP-11.3-49) revealed that each

required that module pigtail cnnductors be supported at a maximum of

36 inches from the penetrating header plate or conductor support. The

failure to accomplish installation in accordance with prescribed

instructions is an apparent violation of Criterion V of Appendix B to

10 CFR Part 50 (445/8604-V-15).

6. . Unresolved Items

Unresolved items are matters for which more information is required in

order to ascertain whether they are acceptable items, violations, or

deviations. Five unresolved items disclosed during the inspection are

discussed in paragraphs 4.c, 4.e, 5.b, and 5.e.

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