ML20148C473

Insp Repts 50-445/78-13 & 50-446/78-13 on 780801-31. Noncompliance Noted:Failure to Follow Weld Monitoring Procedures & Failure to Follow Concrete Testing Procedures

ML20148C473
Person / Time
Site:	Comanche Peak
Issue date:	09/19/1978
From:	Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20148C440	List: ML20148C436 ML20148C458 ML20148C473
References
50-445-78-13, 50-446-78-13, NUDOCS 7811020055
Download: ML20148C473 (9)

See also: IR 05000445/1978013

Text

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U. S. NUCLEAR REGULATORY COMMISSION

0FFICE OF IllSPECTION AtlD EllFORCEMEllT

REGION IV

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Report No. 50-445/78-13; 50-446/78-13

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Docket flo. 50-445; 50-446 Category A2

Licensee: Texas Utilities Generating Company

2001 Bryan Tower

Dallas, Texas 75201

Facility flame: Comanche Peak, Units 1 & 2

Inspection at: Comanche Peak Steam Electric Station, Glen Rose, Texas

Inspection con. ducted: August 1-31, 1978

Inspector d m N bM- 7//R/M

AR. G. Taylor, Resident Reactor Inspector, Projects Date

/ $6Etion' ,

Approved: 2./ -v - - 9//8/78

W. A. Crossman, Chief, Projects Section Date .

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Inspection Summary:

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, Inspection August 1-31,1978 (Report No. 50-445/78-13; 50-446/78-13)

Areas inspected: Routine inspection by Resident Inspector of safety related

construction activities including follow up on licensee actions on previous

findings, equipment storage and maintenance, construction fire protection,

welding of reactor coolant boundary and safety related piping, storage and ',

protection of the reactor vessel and its internals, and concrete batching

and testing activities. The inspection involved one-hundred twenty-six

hours of inspection by one fiRC inspector. '

Results: Of thirteen major activities inspected, two items of noncompliance -

were identified in two areas (infraction - failure to follow weld monitoring . . .

procedures - paragraph 7 and infraction - failure to follow concrete testing

procedures - paragraph 11). ,

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DETAILS

1. Persons Contacted

Principal Licensee Employees

• • R. G. Tolson, TUGC0 Site QA Supervisor

• • J. V. Hawkins, TUGC0/G&H Product Assurance

G. C. Clancy, TUGC0 QA Specialist

W. Varnell, TUSI Mechanical Engineer

A. Nease, TURC0 Test Laboratory Supervisor

R. V. Fleck, TUGC0/G&H Civil Inspection Supervisor

• A. Vega, TUGC0 Quality Assurance

• D. N. Chapman, TUGC0 Quality Assurance Manager

• J. T. Merrit, TUSI Resident Manager

• J. B. George, TUSI Project _ General Manager

• D. E. Diviney, TUGC0 QA Technician

Other Personnel

P. S. Van Teslaar, Westinghouse Site Manager

B. C. Scott, Brown & Root QC Manager

A. Ganzmann, Brown & Root QC Inspector

J. P. Clarke, Brown & Root QC Manager

L. M. Willians, Brown & Root Fire Chief

S. T. Hoggard, Brown & Root Safety Supervisor

L. Allen, Brown & Root General Foreman - Batch Plant

The IE inspector also interviewed other contract employees during the

course of the inspection.

• denotes those attending the interview on August 25, 1978.

• • denotes those attending the interviews on August 21 and 30,1978.

2. Licensee Action on Previous Inspection Findings

(Closed) Infraction (50-445/78-05): Failure to Follow Pipe Fabrication

Procedures. The licensee stated, in his letter dated May 12,1978, that

all pipe counterboring tools have been modified to provide the 30 tran-

sition angle between bored and original inside diameters. The IE in-

spector verified that the tools have been modified. The licensee has

also issued procedure QI-MCP-7-1 dated April 19, 1978, which requires a

B&R quality control inspector to record the serial number of each tool

used to counterbore any given pipe spool piece and to verify the continued

correctness of the ground angit of each tool used during each work shift.

The IE inspector verified that the procedure is being complied with by

review of the required record and examination of several tools. This item

is considered closed.

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(Closed) Infraction (50-445/78-11; 50-446/78-11): Failure to Follow

Piping Installation Procedures. The licensee stated, in his letter

of July 28, 1978, that compliance with procedure 35-1195-PCI-001 was

essentially attained by July 25, 1978, and is being maintained as

verified through periodic audits. The IE -inspector, through a series

of tours of the various plant areas where pipe erection was in progress,

observed that all pipe ends were capped, taped and tagged as required

by the procedure. The licensee has revised the procedure to delete the

requirement to use only red tape and now allows the use of other colors.

The IE inspector also verified that the periodic audits of the process

are being accomplished as committed. This item is considered closed.

3. General Construction Area Tours

The IE inspector toured one or more plant areas several times weekly

during the reporting period to observe the progress of safety related

installation work and the general construction practices involved

including housekeeping. Two tours were conducted during a portion of

the licensee's second shift to observe the type of work involved and

the level of effort. The second shift appears to be about one third

of the day shift and to largely involve civil type construction. No

safety related welding effort was detected on either second shift tour.

During the course of the tours, the IE inspector paid particular atten-

tion as to how various safety related components were being handled and

protected during the transporting and erection processes. Included with-

in the components observed was one reactor coolant pump casing, several

service water pipe spools, and several stainless steel pipe spools.

Also observed was the handling and transport of component cooling system

pumps and electric drive motors.

No items of noncompliance or deviations were identified.

4. Electrical and Mechanical Safety Related Equipment Warehousing

The IE inspector extensively inspected the three primary storage ware-

houses, the adjacent outdoor temporary shelters and open laydown areas

on August 29, 1978, with the following results:

a. All stainless and carbon steel pipe spool pieces stored in the

open-to-the-weather laydown areas were on wood dunnage with ends

and branch nozzles sealed adequately to prevent the ingress of

water or debris. All spools were marked with appropriate coding

to allow complete identification. The acceptance status of the

spools was clearly identified with " Released for Construction" or

"QC Hold" tags securely affixed to each spool observed in the areas.

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b. Outdoor-stored vessels, such as the safety injection accumulators,

were protected by pressurization with six to thirteen psig of

nitrogen or were tightly sealed to prevent the ingress of water

or debris as in the case of the volume control tank. The several

vessels inspected were supplied by the NSSS vendor and the storage

was found to be in accordance with his documented recommendations.

c. Valves and pumps not yet installed were found to be in indoor ware-

houses on wooden pallets or dunnage. Openings were sealed, generally

with wood covers, primarily for protection of weld joint preparations.

The space heaters of all observed valve electric motor operators were

connected to a power source and operative as evidenced by their hand

warm condition.

d. Electrical equipment such as motors for the reactor coolant pumps

and safety injection pumps had their space heaters energized. The

6.9 KV switchgear had large electric lights in the lower areas

providing moderate warmth to the cabinet interiors. Such equipment

was stored in permanent warehousing on substantial dunnage to allow

good air circulation.

No items of noncompliance or deviations were identified.

5. Electrical and Mechanical Safety Related Equipment In-Place Storage

The IE inspector observed the status of the in-place stored equipment,

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such as the auxiliary feedwater pumps, component cooling water heat

exchangers, and valves with motor operators. All were found to be

covered, protected or energized in accordance with good nuclear con-

struction practices and the licensee's procedures, primarily 35-1195-

MCP-10, " Storage and Storage Maintenance of Mechanical and Electrical

Equipment."

No items of noncompliance or deviations were identified.

6. Construction Fire Protection

The IE inspector gave particular attention to the availability of fire

protection equipment in the various areas where work was in progress

which might provide an ignition source such as welding or grinding. The

IE inspector observed that generally, but not in every case, welders had

a portable fire extinguisher at hand or near by. The IE inspector

examined approximately ten (10) portable extinguishers in work areas and

i found all but one to be properly charged for use. The single fire hose

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standpipe and hose reel found in the auxiliary building appeared to be

usable without difficulty. The IE inspector noted that no significant

accumulations of burnable materials such as wood or rags were evident

nor were any paints or other potential highly combustible solvents or

oils found where they weren't in immediate use.

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Discussions with appropriate site personnel indicated that, while no

formal procedure is currently available covering fire prevention or

protection, there is an organized fire brigade headed by experienced

personnel and that the combined site safety, medical and fire brigade

units of approximately twenty-six people have been trained in fire

fighting methods. The safety organization, with the assistance of the

craft labor force, routinely check portable fire extinguishers for their

charge condition. ,

An interview with a foreman of electricians on August 28, 1978, indicated

that he was aware of where the portable fire extinguishers in his area

were located. The IE inspector verified that the extinguishers were where

the foreman indicated and were fully charged.

The IE inspector had no further questions regarding this matter.

7. Reactor Coolant Pressure Boundary Pipe Welding

The IE inspector observed the licenseo's contractor personnel performing

welding on two joints in the primary loop piping.

On August 18, 1978, the IE inspector observed two welders working on

opposite sides of joint FW-15 which connects the cold leg pipe to the

reactor coolant pump discharge nozzle in loop 2.

On August 21, 1978, the IE inspector observed a single welder working

on joint FW-9 connecting the loop 2 hot leg pipe to the reactor vessel

nozzle.

All three welders were using the gas tungsten arc welding (GTAW) process

in accordance with Brown & Root Welding Procedure No. 88025, Revision 5.

The Weld Data Card for FW-15 indicated that the welders were in the

process of making weld pass number 8. The Weld Data Card for FW-9 indi-

cated that pass 13 was in process at the time of the observation. Weld

Material Requisitions A008481 and A008482 were issued to the two welders

for work on joint FW-15 and Weld Material Requisition A011053 was issued

for joint FW-9. All reflected issuances of weld rod material Heat No.

462317. It was noted from the Weld Data Cards that Heat No. 462317 has

been utilized to make all weld passes in both joints.

The IE inspector subsequently reviewed the Certified Material Test

Report furnished by Sandvik, Inc. for Heat No. 462317 and established

that all requirements of ASME Section III, paragraph NB2400 and Section

II, part SFA 5.9 had been satisfied.

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The IE inspector also verified that Weld Pro:edure No. 88025, Revision

0, had been qualified as documented by Procedure Qualification Record

0808AAll4 and that each of the welders observed had been performance

tested; all in accordance with the requirements of the ASME B&PV Code,

Section III.

The IE inspector was unable to establish whether the pipe materials

involved in the weld joints satisfied the commitments of the FSAR or

the requirements of the Code since the licensee was unable to locate

the Certified Material Test Reports furnished by the supplier of the

pipe.

This will be considered an unresolved item until such time as the

reports are made available for review.

The IE inspector observed that while the weld procedure provided data

necessary to control weld heat input which is an FSAR commitment when

welding stainless steel, none of the machines in use had metering

which would indicate the machine output. Discussions with licensee

personnel revealed that frequent monitoring of welding performance was

accomplished by construction personnel in accordance with Procedure

No. 35-1195-WCP-3. QC personnel also monitor performance, but much

less frequently, typically at 90 day intervals. Review of WCP-3 re-

vealed that each welder is to be monitored at least once every ten

working days to assure the welder's conformance to welding parameters.

t Review of the records of this monitoring activity, however revealed

that (at least in regard to the welders observed as outlined above)

the monitoriag had not been done for intervals of from two to eight

months.

The licensee researched the extent of the breakdown in the monitoring

program and informed the IE inspector that, in fact, the required

monitoring in some instances had not taken place, as dist.inguished

from misplaced documentation.

The IE inspector stated that the lack of monitoring of weld performance

is in compliance with 10 CFR 50, Appendix B, Criterion V.

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8. Welding cf Safety Related Pipe _

During this inspection period, the IE inspector observed the inprocess

welding of one stainless steel pipe joint and one carbon steel joint.

On August 11,1978,.the IE inspector observed a welder working on weld

FW-12 as shown on isometric drawing SW-1-YD-13-1 and identified as part

of line 30-SW-1-012-150-3 as shown on figure 9.2-1 of the FSAR. The

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welder had in his possession a " Weld Data Card" authorizing him to

perform welding on the joint and a weld technique document providing

him with necessary welding instructions. In addition, the welder had

a " Weld Material Requisition" for eighty type E-7018 weld electrodes,

all of which were observed to be contained in a portable rod oven.

The IE inspector observed that the welder was accomplishing his assigned

work in accordance with his weld technique document which was referenced

as part of Weld Procedure No.11010, Revision 0.

On August 15, 1978, the IE inspector observed inprocess welding of joint

5A in the pipe fabrication shop. The joint is identified on drawing

CS-1-AB-64-1 and is ,,drt of line 3-CS-1-032-30lR as shown on figure

9.3-10, sheet 2 of the FSAR. It was observed that the welder was per-

forming his work in accordance with his weld technique document refer-

enced as part of Weld Procedure No. 88023, Revision 3. The welder also

had in his possession the proper Weld Data Card and Weld Material Requi-

sition.

The IE inspector subsequently verified that Weld Procedure No.11010 and

No. 88023 had been qualified by Procedure Qualifications 0101ABil9 and

0808AA204, respectively. The IE inspector also verified that the welders

observed had been performance tested and qualified by their employer,

Brown & Root. The weld procedures (WPS), the procedure qualifications

(PQR) and the performance qualifications were conpared to the require-

ments of the ASME Section III and Section IX and found to be consistent.

No items of noncompliance or deviations were identified.

9. Protection of Stored Reactor Vessel Internals

The IE inspector examined the stored upper and lower sections of the

reactor vessel internals in relation to NSSS vendor recommendations,

Brown & Root Procedures MCP-10, " Storage and Maintenance Requirements,"

cnd MEI-10-431, " Supplemental Requirements for Reactor Vessel Internals

Package."

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The upper internals were found to be fully wrapped in plastic which in

turn was fully covered by a heavy weight prefabricated tarpaulin with

l no openings. The package was stored in a specifically constructed

field building, well scaled to the elements. The lower section was

protected in the same manner as the upper section except that access to

the interior is available through a locked small door. The IE inspector

examined the interior which was found to be clean and free of any

collected moisture or debris.

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The IE' inspector reviewed records of measurements of the interior

dimensions of the lower section made by B&R under the observation

of the NSSS representative to detect any distortion of the structure

due to its horizontally stored position. While the diinensions show

variations of up to .005 inches, the NSSS representative stated that

these variations were well within the vendor's requirements.

No items of noncompliance or deviations were identified in this area

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of the inspection.

10. Installed Reactor pressure Vessel protection

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The IE inspector observed, on August 2, 1978, that the reactor pressure

vessel top opening was completely covered with a prefabricated assembly

containing trap doors for access to the vessel interior. The IE

inspector observed that each trap door was securely padlocked at the

time of the visit. It was ascertained that the padlock keys were in

the possession of a craft labor foreman. Discussions with licensee

personnel established that procedures have not yet been developed for

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vessel cleanliness control or for access control. The licensee contends

that the cover prevents damage from heavy debris falling into the vessel

and that the padlocks are there only to prevent the curious from opening

the trap door and falling into the vessel. The licensee indicated that

cleanliness and access control procedures will be developed and imple-

mented when required, such as when internals installation is initiated.

The IE inspector discussed this program with the USSS representative who

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indicated concurrence with the licensee's approach.

No items of noncompliance or deviations were identified.

11. Concrete Laboratory and Batch plant Activities

During a plant tour on August 30, 1978, the IE inspector observed that

a relatively large concrete placement was being made in the containment

interior. The placement was determined to be number 101-4860-008, a

wall around the steam generators of about 450 cubic yards, using Concrete

Design Mix No.133.

The IE inspector visited the batch plant to observe operations. It was

verified that the water, cement and aggregate primary scales were within

their calibration period running from May 30 to August 30, 1978, and that

the digital readout devices on the automatic control panel correlated to

the primary scale readings. The batch tickets in turn correlated to the

digital readout of the control panel.

The IE inspector then visited the truck to pumper discharge area to

observe the acceptance testing of the fresh concrete. The observation

indicated that three laboratory technicians were assigned to the place-

ment and were performing all required tests in accordance with licensee

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procedures QI-QP-ll .1-ll, " Slump of Portland Cement Concrete," QI-QP-ll .

1-12. " Air Content of Freshly Mixed Concrete by the Pressure Methods,"

and QI-QP-11.1-15, " Temperature of Fresh Concrete." It was noted, how-

ever, that while the test sample was being taken from the batch identi-

fied by ticket number 45623, the test technician took only one discharge

sample. Licensee procedure QI-QP-il.1-10, " Sampling Fresh Concrete,"

which is comparable to ASTM C-172 of the same title, requires that two

or more samples be taken from the middle portion of the load. The IE

inspector interviewed the technician relative to how he was to take the

sample and was told that when taking samples only involving slump, air

content and temperature, as distinguished from those also involving

strength cylinders, "they" have always taken only one sample. The IE

inspector asked the technician if the procedural exception was documented;

the technician indicated he wasn't sure. The IE inspector then inter-

viewed the test laboratory supervisor to determine if he, the supervisor,

was aware of the procedural requirement and what his technician was

actually doing. The supervisor was fully aware of the requirements, but

not of the actual practice. The supervisor established,by discussions

with others of his staff,that the observed practice was standard among

the technicians.

The IE inspector informed the licensee that failure to follow the con-

crete testing procedures was in noncompliance with 10 CFR 50, Appendix

B, Criterion V.

13. Unresolved Items

Unresolved items are matters about which more information is required

in order to ascertain whether they are acceptable items, items of non-

compliance, or deviations. An unresolved item disclosed during this

inspection period is discussed in paragraph 7 and will hereafter be

referred to as " Documentation of Reactor Coolant Pipe Quality."

14. Management Interviews

The IE inspector met with licensee representatives (denoted in para-

graph 1) on August 21 and August 30, 1978, to discuss the items of

noncompliance disclosed on those days of inspection. In addition,

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the

tivesIE(denoted

inspectorinparticipated

paragraph 1) inat

a the

meeting with licensee

conclusion representg/

of the inspection _

on August 25, 1978, by other NRC IE personnel. In each meeting, the

licensee acknowledge understanding the discussed items but made no

commitments.

l/See inspection Report 50-445/78-12; 50-446/78-12

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