ML20151N898
| ML20151N898 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/23/1985 |
| From: | Barnes I, Kelley D, Norman D, Phillips H, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20151N849 | List: |
| References | |
| 50-445-85-13, 50-446-85-09, 50-446-85-9, NUDOCS 8601030186 | |
| Download: ML20151N898 (8) | |
See also: IR 05000445/1985013
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APPENDIX D_
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CdNSTRUCTIONINSPECTIONREPORT
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U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Reports:
50-445/85-13
Permit: CPPR-126
50-446/85-09
CPPR-127
Dockets:
50-445
Category:
A2
50-446
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Applicant: . 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), Unit 1 and 2
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Inspection At:
Glen Rose, Texas
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' Inspection Conducted: August 23 through September 30, 1985
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Inspectors:
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R.. S. Phil' lips, Sehior Residenc Reactor
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Inspsctor (SRRI), Construction, Region IV
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CPSES Group (paragraphs 1,2,3,4,5,6,
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.and 9)
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D. L. Kelley, SRRT', Op'e}atio
, Region IV
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CPSES Group (paragrapns 1,
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D. E. Norman, Reactor Inspector
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Region IV CPSES Group
(paragraphs 1, 2, 4, 5, 6, 7, and 9)
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8601030186 B51224
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Consultant:
Parameter-T. H. Young
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Rev.iewed'by:
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I. Barnes, Group Leader, Region IV CPSES Group
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Approved:
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.T. F. Westerman, Chief, Region IV CPSES Group
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Inspection Summary
Inspection Conducted:
August 23 through September 30, ~1985
(Report 50-445/85-13)
Areas. Inspected:
Routine, unannounced inspections of Unit 1 which included a
review of plant status and applicant actions on previous NRC inspection
findings.
The inspection involved 24 inspector-hours onsite by 2 NRC
inspectors and one consultant.
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Results:
Within the two areas inspected, no violations or deviations were
identified.
Inspection Conducted:
August 23 through September 30, 1985
(Report 50-446/85-09)
Areas Inspected:
Routine, announced and unannounced inspections of Unit 2
which included review of plant status; plant tours; installation / storage of
reactor pressurizer and piping; structural welding on CRD support platform;
review of. welding procedures; inspection of welding of safety injection piping;
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review of electrical /QC procedures and' applicant actions on previous NRC
inspection findings.
The inspection involved 100 inspector-hours onsite by
3 NRC inspectors.
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Results: Within the eight areas' inspected, two violations (failure to
establish procedures which describe control of. deleterious materials'around
stainless steel piping and NSSS equipment, paragraph 4.a; failure to provide
protection of equipment stored in place, paragraph 4.b) were identified.
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DETAILS
1.
Persons Contacted
J. Merritt, Assistant Project General Manager, TUGC0
C. Welch, QA Supervisor, TUGC0
L. Smith, Engineer, Brown & Root (B&R)
W. Baker, Engineer, B&R
B. Wright, Engineer, B&R
- The NRC inspectors also interviewed other applicant employees during this
inspection period.
2.
Construction Status
The percentage completion for Unit 1 and 2 is 99% and 77%, respectively.
Current work on Unit 1 relates to Comanche Peak Response Team (CPRT)
activities.
Unit 2 work on large and small bore piping is about 95%
complete.
Electrical cable trays are 100% complete while seismic conduit
dnd supports are about 97% and 89% complete, respectively.
Cable pulling
is about 78% complete.
The heating and cooling ductwork and supports are
about 93% and 60% complete, respectively.
3.
Applicant Actions on Previous NRC Inspection Findings
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a.
(0 pen) Unresolved Item (445/8226-06):
Excessive deflections in
supports.
The NRC inspector reviewed a study entitled " Piping Seismic Analysis
- Parametric Study of Support Stiffness" dated March 31, 1983, which
addressed stiffness and deflection questions and justified the
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equipment as designed.
This item will remain open pending completion
of NRC staff review of CPRT/ Stone & Webster (S&W) design activities.
b.
(0 pen) Unresolved Item (445/8226-07):
Stress analysis of pipe
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support No. CC-1-107-008-E23R.
The NRC inspector reviewed the background of this item on page 41 of
NRC Inspection Report 50-445/82-26, 50-446/82-14, which showed the
stiffness of the support to be 1/8th of the generic stiffness used in
the original calculations.
However, an NRC consultant (Dr. Chen)
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stated (during testimony before the ASLB in May 1983 Questions and
Answers 19 and 20) that the value was 1/360th of the generic value.
In addition, he stated that the mounting plate was increased to a
thickness which increased the stiffness to an acceptable level.
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Subsequently, TUGC0 requested and made further modifications to mount
the pipe support off of square tube steel instead of the stairway
platform I beam.
The NRC inspector requested the documentation for
this modification but it was not immediately available.
This item
remains open pending a review of this documentation and completion of
NRC staff review of CPRT/S&W design activities.
c.
(0 pen) Unresolved Item (445/8226-05): Moment restraints and local
pipe stress due to welded stanchions on pipes.
The NRC inspector reviewed pages 38-40 of NRC Inspection
Report 50-445/82-26 and 50-446/82-14 concerning this technical issue.
In an affidavit dated October 14, 1983, page 1, Questions and
Answers, NRC consultant (Dr. Chen) considered the applicant's work in
this area acceptable.
This item will remain open pending completion
of NRC staff review of CPRT/S&W design activities.
4.
Routine Plant Tours (Unit 2)
a.
At various times during the inspection period, the NRC inspectors
conducted general tours of the reactor building, safeguards building,
and electrical 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 activities.
The NRC inspector observed that the cleanliness controls in the
reactor building does not appear to be well defined.
For example,
during the previous inspection period (June 22 through August 22,
1985), the NRC inspectors found evidence of chewing tobacco and
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cigarette butts on.the 905 feet elevation of the reactor containment
building (RCB).
This was pointed out to the applicant management at
the previous exit interview.
During this inspection period,
cigarette butts were again found in the area around the pressurizer
head on this 905 feet elevation, on the top of the control rod drive
seismic support platform, and scattered throughout the RCB.
The
applicant is not committed, however, to the housekeeping practices
defined in ANSI N45.2.3.
Gibbs and Hill Specifications 2323-MS-100 and 2323-MS-101 dated
July 5, 1984, address the subject'of contamination through use of
temperature crayons, machinery lubricants / coolants, instruments
containing mercury, temporary plugging with rags, taping and the
prohibition of halogens, copper, low melting point metals (lead,
zinc, cadmium, tin, antimony, bismuth, sulfur and mischmetals).
The NRC inspector contacted the B&R welding organization to inquire
where the control of such materials was discussed (QA or working
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procedures).
After a brief review they found that one paragraph
discussing the subject of mercury had been unintentionally deleted
from General Piping Procedure CP-CPM-69, Appendix E.3.2.
Personnel
in the applicant's site QC department were also contacted to identify
procedures which address protection and preservation.
B&R Procedure
MCP-10, Revision 9, dated July 2, 1985, was identified as the
procedure with such controls.
These procedures do not adequately
addr c.is material / personnel control to prevent contamination and also
do not reference use of only materials which have been procured in
accordance with Gibbs & Hill sper.ification requirements.
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This failure to establish such proceduies is a violation of
Criterion XIII of 10 CFR Part 50, Appendix B (446/8509-V-02).
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b.
In reactor building room 16 near the bottom of the pressurizer, the
NRC found a wooden two by four which had been laid across 3/4-inch
line RC-2-095-2501-R-2 to serve as a step.
The wooden step was about
one.and one half feet from where this line enters the tank.
The use
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of such personnel supports is prohibited without engineering
approval, and is a violation of Criterion V of 10 CFR Part 50,
Appendix B, and B&R procedure MCP-10 (446/8509-V-03).
c.
Cleanliness in the area of the pressurizer from the 905 to 854 feet
elevation was inspected. As discussed previously,, tobacco was
observed and a sign was also noted in the reactor building elevator
which prohibited tobacco or food at the 905 feet elevation.
At the
bottom of the pressurizer a used grinding wheel and wire brush were
found, yet no visible work had recently occurred.
Since such
uncontrolled or unaccounted for tools could potentially be used
interchangeably on stainless and carbon steel, this subject was
brought to the applicant's attention.
Region IV will continue to
monitor the applicant's cleanliness controls.
5.
Reactor Pressurizer and Piping, Housekeeping and Welding
The NRC inspector reviewed FSAR Volume VI, Section 5.0, " Reactor Coolant
System & Connected Systems", Subsection 5.4.10, which describes the
pressurizer system design bases, design analysis and performance
characteristics, test, and inspection.
" Flow Diagram Reactor Coolant System Sheet 2 of 2" shown on Drawing
No. 2323-M2-0251, Revision CP-1, was used to physically trace all piping
entering into the pressurizer dome. -Both pressurizer spray lines were
traced to the 860 foot elevation and one was traced to the cold leg of
Loop 4 of Steam Generator No. 4.
All piping was traccd up to the inlets
of the three safety relief valves (2-8010A, B and C) and two power
operated relief valves (2 PCV-455 and 456).
Approximately 100 welds
within this system were visually inspected for surface condition.
No
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unacceptable surface conditions were found in this system except as
follows:
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The NRC-inspector determined that welding performed on a ,b,:nger base plate
located above ' completed weld No. 42 in 6-inch line RC-2-09b-2501R-1 had
caused deposition of carbon steel weld spatter on the surface of the
stainless steel piping line.
This failure to adequately protect equipment
from construction damage is a violation of Criterion V of 10 CFR Part 50,
Appendix B, and B&R Procedure MCP-10, Revision 9, dated July 2, 1985,
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(446/8509-V-03).
6.
Structural Steel Welding on Control Rod Drive Seismic Support
Platform
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The NRC inspector observed structural welding on the platform.
Messenger
, wire posts were installed on top of the platform and NDE personnel were
liquid penetrant testing the welds which connected these posts to the top
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aof the platform-in accordance with Drawing 2323-52-0599-19, Revision 0.
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The drawing symbol showed a 1/4-inch fillet weld all around the post base
which connected it to the platform.
The liquid penetrant test was
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accomplished in accordance with B&R Procedure QI-QAP-10.2-1, Revision 3,
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February 18, 1983. Welding Data Card Serial No. 004167, Traveler
MW 85-7330-6802, and Design Control Authorization 23203 R.0. controlled
these work activities.
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The applicant's inspectors had inspected weld No. 2 for cleanup, fitup,
preheat, final ultrasonic testing (IOM 25944), and liquid penetrant
testing was in process.
Welding was accomplished in accordance with Weld
Process Specification 11032.
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No violations or deviations were identified.
7.
Safety-Related Piping
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Procedures and Instructions
.This inspection was conducted to verify the adequacy of documents
used by the site contractor for field welding of safety-related
piping.
The NRC inspector reviewed QA and other welding related
documents to determine whether QA plans, instructions, and procedures
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had been established and whether procedures had been established for
preparing, qualifying, distributing and revising welding procedure
specifications (WPSs).
Two WPSs and supporting procedure
qualification records (PQRs) were reviewed to determine whether
stated welding variables and mechanical tests complied with
requirements of the applicable editions of Sections III and IX of the
ASME Code. .The following documents were reviewed during the
~ inspection:
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B&R QA Manual, Section 10, October 31, 1984, " Control of Special
Processes"; CP-CPM-6.9, Revision 2. November 7, 1980, " General Piping
Procedure"; QI-QAP-11.1-26, Revision 17, August 17, 1985, "ASME Pipe
Fabrication and Installation Inspections"; WES-030, Revision 2,
July 19, 1984, " Specification for Control, Testing and Documentation
of Weld Procedures Qualifications";
Index of CPSES Welding
Procedures, April 15, 1985; WPS 88012, Revision 7, October 10, 1984
and PQR 0803AB203, Revision 6, March 14, 1980, " Gas Tungsten Arc and
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Shielded Metal Arc Process"; and WPS 88032, Revision 9, October 22,
1984, and PQR 0808BB112, Revision 4, February 12, 1981, " Shielded
Metal Arc Process."
b.
Observation of Work
The NRC inspector inspected a 24-inch line at the 815 feet
elevation.
At this location, the pipe exits the refueling water
storage tank and goes down into the pipe tunnel as shown on Drawing
2323-A2-0500. Work had been stopped on SI-2-YD-02.2 because of a
mixup on paperwork for welding one 1-inch plate identified as
S1-2-0029-412-Y42R.
Subsequent fuitowup of this item revealed that
Nonconformance Report (NCR) 18651 had been written to correct the
paperwork problem.
No violations or deviations were identified.
8.
Review of QA Manual - Electrical
The NRC inspector began a review of the applicant's QA/QC program and
procedures relating to the installation of electrical components and
cables.
The areas covered in the review are organizational structure and
personnel; audits; quality requirements; work and quality inspection
procedures; control of material; control of processes; corrective action;
document control; test control and control of test equipment; quality
records; and onsite design control.
This portion of the inspection was conducted to identify the QA/QC program
specifics and procedures which pertain to the installation of electrical
components and cables.
The program and procedures were then compared to
the commitments contained in Sections 7, 8, and 17 of the FSAR and
10 CFR 50, Appendix B, to determine if the program and procedures
adequately addressed the required criteria.
To date, the following have been_ reviewed; Sections 7, 8, and 17 of the
applicant's FSAR; TUGC0/TUSI(now TNE) CPSES QA' Plan; B&R Quality Assurance-
Manual; B&R Quality Assurance Procedures Manual; and implementing
Procedures CP-QP-2.0, Revision (R)-1; CP-QP-2.1, R-18; QI-QP-2.1-23, R-0;
CP-QP-2.2; R-E, CP-QP-3.0, R-15; CP-QP-6.0, R-8; CP-QP-7.1, R-12;
CP-QP-11.3, I-4; QI-QP-11.3-24, R-14; QI-QP-11.3-25, R-23; and
QI-QP-11.3-26, R-23,-(in part).
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Ond'other, aspect that will be included in the present and subsequent
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reviews and. inspections will be to determine if the " lessons learned" on
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Unit.No. 1 have been incorporated.into the Unit No. 2 QA/QC inspection
programs and procedures
Thus far, review has begun in the following
areas:~ organization and structure (personnel is ongoing); quality
requirements; work.and quality' inspection procedures; corrective actions;
document control; and quality records.
The remaining areas are yet to be
. started. ~To date, no problem areas have been encountered.
No' violations or deviations were identified. ~
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~ Exit Interview
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An' exit interview was conducted October 4, 1985, with the applicant
.-representatives identified in paragraph 1 of Appendix E of this report.
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During this interview, the NRC inspectors summarized the scope and
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findings of the inspection.
The applicant acknowledged the findings.
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