ML20140H954
| 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: |
| 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:
N7b
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P. C. Wagner, Reactos Inspector, Region IV
Da~te
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CPSES Group
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
3dp/pg
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T. F. Westerman, Chief, Region IV CPSES Group
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
ADOCM 05000445
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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
required rework instructions, paragraph 4.b; absence of required records to
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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
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file a receiving inspection checklist in the records vault, paragraph 4.d;
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failure to -identify absence of required staggering of vendor cable splices,
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paragraph 4.d; acceptance of-EPA installation configuration not in accordance
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with drawing requirements, paragraph 5.c; failure to seal junction boxes in
accordance with drawing requirements, paragraph 5.d; failure to support EPA
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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
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submittal of Regulatory Guide 1.75 required analysis in Final Safety Analysis
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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
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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-
ments of the HSIT manufacturer.
An additional handwritten note was
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entered above the lined-out note which indicated that the comments on
HSIT length were withdrawn on the basis of field rework in accordance
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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
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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
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the epoxy. module interface.
From review of BRC furnished equipment
qualif.ication data, it appeared that the tested design did not utilize
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
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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
as of the end of this report period.
This matter is considered an
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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,
which was applicable to these EPAs, indicated,.however, that the cable
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support fixture was attached to the EPA nozzle and not the EPA header
plate. Visual inspection showed no inboard cable support installation
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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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