ML20198E853

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Insp Repts 50-445/85-18 & 50-446/85-15 During Dec 1985.No Violations or Deviations Noted.Major Areas Inspected:Actions on Const Deficiencies,Ie Notices,Generic Ltrs & Protective Coatings
ML20198E853
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 05/06/1986
From: Barnes I, Clay Johnson, Kelley D, Michaud P, Phillips H, Westerman T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198E698 List:
References
50-445-85-10-1, 50-445-85-18, 50-446-85-15, GL-83-11, GL-83-16, NUDOCS 8605280303
Download: ML20198E853 (10)
v • d • e


See also: IR 05000445/1985018

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                                                                                                               APPENDIX C

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                                                                                                    CONSTRUCTION INSPECTION REPORT

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                                                                                                 U. S. NUCLEAR REGULATORY COMMISSION

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                                                                                                                REGION IV
                                                                    NRC Inspection Report:          50-445/85-18                   Permits: CPPR-126
                                                                                                    50-446/85-15                                     CPPR-127

i Dockets: 50-445 Category: A2 

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                                                                               50-446
                                                                    Applicant: Texas-Utilities Electric Company (TVEC)
                                                                                 Skyway Tower
                                                                                 400 North Olive Street
                                                                                 Lock Box 81
                                                                                 Dallas, Texas           75201
                                                                    Facility Name:     Comanche Peak Steam Electric Station (CPSES), Units 1 & 2

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                                                                    Inspection At: Glen Rose Texas
                                                                    Inspection Conducted: December 1-31, 1985

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l                                                                   Inspectors:                                '#/                                   '//29/M
                                                                                      H. S.'711111ps, Senior Resident Reactor                        Date

. Inspector (SRRI), Construction,RegionIV 

                                                                                          CPSES Group
                                                                                          (paragraphs 1, 2, 3, 4, 5, 6, 8, 9, 12)
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                                                                                               SaA                                                   .r/5/r l,                                         .
                                                                              p C. E. Johnson, SRRI, Construction, Region IV                         Date
                                                                                          South Texas Project (paragraph 7)
                                                                                    GJCu%:cLJ
                                                                                      P. W. Michaud,M eactor Inspector, Region IV
                                                                                                                                                     +n-z.
                                                                                                                                                     Date
                                                                                          (paragraph 10)

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                                                                                            wAA 0                                                        /

. D~. '.' Kelle~y, TRRI?Dperaftons , Region IV 

                                                                                            _                                                        Dater
                                                                                          CPSES Group (paragraph /11)
                                                                    Consultant:       EG&G - J. H. McCleskey
                                                                           e605280303 e60512
                                                                           PDR   ADOCK 05000445
                                                                           G                        PDR
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      Reviewed by:     - [ 8 0_ s -o                                       f/S/4'4
                      1. Barnes, Group Leader, Region IV CPSES             Date
                        Group
      Approved:         Nr
                      T. F.~ Westerman, Chief, Region IV CPSES Group
                                                                            [[#[EC
                                                                           Date
      Inspection Summary
      Inspection Conducted:    December 1-31, 1985 (Report 50-445/85-18)
      Areas Inspected:    Routine, unannounced inspections of Unit 1 which included
      applicant actions on construction deficiencies, applicant actions on previous
      NRC inspection findings, IE Notices, Generic Letters, and followup of NRC
      Technical Review Team (TRT) coating findings.
      Results:   Within the five areas inspected, no violations or deviations were
      identified.
      Inspection Conducted:    December 1-31, 1985 (Report 50-446/85-15)
      Areas Inspected:     Routine, announced and unannounced inspections of Unit 2
      which included plant tours; applicant actions on construction deficiencies;
      applicant actions on previous inspection NRC findings; IE Notices; Generic.
      Letters; protective coatings; heating, ventilation, and air conditioning (HVAC);
      pipe supports; and electrical cable tray / equipment.
      Results:   Within the nine areas inspected, no violations or deviations were
      identified.

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                                          DETAILS
     1. Persons Contacted
        Texas Utilities Generating Company (TUGCo)
        L. Hart, Quality Assurance (QA), TUGCo Nuclear Engineering (TNE)
        P. Halstead, Manager, Quality Control (QC)
        F. Madeen, TNE Mechanical Engineer
        J. Merritt, Assistant Project General Manager
        D. Palter, Industry Operating Experience Coordinator
        P. Stevens, TNE Electrical Engineer
        C. Welch, QC Services Supervisor
        The NRC inspectors also interviewed other applicant employees during this
        inspection period.
     2. Applicant Action on Previous NRC Inspection Findings, Units 1 and 2
        a.    (0 pen) Unresolved Items (445/8514-U-02 and 03; 446/8511-U-01 and 02;
              and 445/8516-U-01; 446/8513-01): Procedures did not address
              construction deficiency file content, incomplete QA record files,
              deficiency report corrective action, and TUGCo commitment to review
              this matter. The NRC inspector continued the previous inspection by
              following up on each of these items during this inspection period.
              TUGCo was still working on these items and anticipated completing the
              review and taking necessary action to improve the current system by
              March 1, 1985.
        b.    (0 pen) Unresolved Items (445/8516-U-02 and 03; 446/8513-U-02 and 03):
              IE Bulletin files for 79-14 and 79-28. The NRC inspectors continued
              the previous inspection by following up on each of these items.
              TUGCo was working on improving the IE Bulletin system and has named a
              new coordinator. They will consolidate the files and place QA          ,
              records in the vault. The corrective action on all applicable IE       l
              Bulletins requiring hardware evaluation, repair, replacement and       I
              verification will be reviewed and reassessed to assure that the
              cognizant construction organization tracks or has tracked present or   l
              past actions to completion. The files will be organized to contain
              sufficient information to identify the evaluator, summarize the
              evaluation, and identify the documents which describe final actions.   l
              No violations or deviations were identified.
     3. Applicant Action on 10 CFR 50.55(e) Deficiencies
                                                                                     i
         (Closed) Construction Deficiency D-1-0181 (CP-85-30): Switch gear cabinet
        terminations by the vendor. The NRC inspector reviewed this item to

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                     determine why the terminations were replaced when TUGCo letter TXX-4598
                     dated October 16, 1985, stated that the deficiency was not reportable.
                     The inspector reviewed the TUGCo evaluation and found that this item was
                     not reportable because of the conclusion that the deficiency would not
                     adversely affect the safe operation of the plant.                                                 The terminations were
                     replaced because they did not meet TUGCo's workmanship standards;                                                                         i.e.,
                     Attachment 9 of QI-QP-11.3-28.
                  4. Applicant Actions on Office of Inspection and Enforcement Information
                     Notices (IENs)
                     IENs are sent to the nuclear industry for information purposes and require
                     no action by the licensees and applicants with respect to reporting to the
                     NRC. They are encouraged, however, to take action on applicable technical
                     issues to prevent similar technical problems. The following IEN files
                     were reviewed to determine how TUGCo determined applicability, made
                     distribution, and took action:                                                 IEN 85-04, 85-22, 85-33, 85-34, 85-35,
                     85-36, and 85-56. This review of TUGCo files showed that their
                     established system was working satisfactorily.
                     No violations or deviations were identified.
                  5. Applicant Actions on Generic Letters
                     NRC Generic Letters are also sent to the nuclear industry for information
                     purposes and require no response to the NRC.                                                 The NRC is interested,
                     however, in how the utility distributes, evaluates, and, if applicable,
                     takes corrective action. The NRC inspector reviewed 15 files and selected
                     Generic Letters 83-11 and 83-16 for a more detailed review. TUGCo
                     Licensing receives and distributes these letters to the operations support
                     group for their review and action.                                                  Review of the files revealed that the
                     TUGCo system does adequately consider Generic Letters and appropriate
                     actions were ascertained to have been taken.
                     No violations or deviations were identified.
                  6. General Plant Inspections of Unit 2
                     At various times during the inspection period, NRC inspectors conducted
                      inspections of the reactor, safeguards, and the electrical / control
                     building. The NRC inspector observed ongoing construction work and
                     discussed various subjects with personnel engaged in work activities.
                     No violations or deviations were identified.
                  7. Protective Coatings, Units 1 and 2
                     a.    The NRC inspector reviewed the coating specifications and procedures
                           for clarity, consistency, technical criteria, and instructions for
                           applying coatings.                                                The procedures were found to contain more
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        comprehensive instructions criteria than the old procedures which
        were reviewed by the TRT in 1984. Personnel training / qualification,
        concrete / steel reinspection and inspection, testing, documentation,
        and repair are well covered in Specification 2323-AS-31 and in
        Procedures CP-EP-14.2, -14.3, -14.7, -14.8, -14.1, -14.4, -14.9,
        -14. 0, -14. 5, -14. 6, -6. 2; CCP-30 and -40.
     b. The NRC inspector observed in progress and completed work in
        pressurizer room 31, steam generator rooms 26 and 29, elevator shaft
        room 30, room 21, and the fabrication shop. The paint storage
        building was also inspected for compliance with storage requirements.
        Most of the work observed was surface preparation; however, a final
        application of the coating of the steel liner was observed in
        room 21. The surface preparation and application of coating were
        accomplished in accordance with good commercial practices and the
        crafts and field engineers were knowledgeable. Field inspectors were
        present and were notified by the craft when hold points were imposed.
        Paint storage areas were temperature controlled and material shelf
        life was closely monitored and controlled.
     c. Records Review: The purpose of the protective coatings paper flow
        group (PFG) is to establish a method of initiating, preparing,
        issuing, tracking, logging, and controlling protective coatings
        travelers and associated supporting documentation for the
        verification of coatings activities.
        The NRC inspector reviewed protective coatings travelers to determine
        if the records were adequate, complete, legible, easily retrievable
        and documented in accordance with site procedures. In addition, the
        NRC inspector compared the completed and in process travelers to the
        PFG tracking system to determine if the tracking system was accurate.
        A computer printout is used for the tracking system, listing the
        traveler number, package number, unit, area code / room, number, any
        outstanding coating deficiency reports and the traveler status.
        Records reviewed were legible, easily retrievable and complete in
        accordance with site coatings procedures. Review of the Unit 2
        coating records tracking system by the NRC inspector indicated that
        the site system is both reliable and accurate. The tracking system
        is updated on a daily basis.
        The NRC inspector also reviewed in process travelers in the field.
        One minor isolated discrepancy was noted on traveler 2-21-0; however,
        the signature (which was in the wrong block) was promptly corrected
        when it was brought to the foreman's attention. All other travelers
        reviewed were correct.

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         The following work packages which contained more than one traveler -
        -were reviewed: 2-21-F , 2-21-0, 2-21-I , 2-21-N , 21-H , 2-21-B , 2-21-E ,
         2-21- AJ , 2-21-G , and 2-21-L.
         The NRC inspector reviewed eight coating training records for field
         engineers who were trained and qualified in accordance with site
         Procedure CP-EP-14.1, Revision 0.    American National Standards
         Institute (ANSI) 45.2.6 is no longer applicable since the approved
         declassification of protective coatings; however, the majority of the
         coating field engineers' qualification records that were reviewed by
         the NRC inspector indicated that they had been qualified or certified
         to ANSI 45.2.6 before the declassification of protective coatings
         occurred. Regardless, a beginning coating field engineer must still
         meet the following qualification requirements:
         .     Shall have a minimum of 1 1/2 years experience in the inspection
               and documentation of protective coatings work at a nuclear
               facility,
         .     shall be physically capable of performing the assigned tasks,
               and
         .     shall have natural or corrected near distance visual acuity such
               that they are capable of reading J-1 letters on a standard
               Jaeger Chart.
         These inspectors are given classroom instruction on all coatings
         procedures, and a proficiency test for all instrumentation used to
         perform the inspections. The coatings field supervisor evaluates the
         proficiency of the inspector's use of these instruments.
     d.  Calibration:    The NRC inspector reviewed two procedures, IEI-15,
         " Calibration of DFT Gauges," Revision 5, dated March 11, 1982, and
         IEI-35, " Calibration of Adhesion Testers," Revision 3, dated
         February 27, 1984. The gauges and adhesion testers were calibrated
         to an accuracy of +/- 10 percent. The coating procedure for minimum
         adhesion readings for the Elcometer adhesion tester'was more
         conservative than required.
         The NRC inspector reviewed calibration records of two Elcometer
         adhesion testers (M&E #3741 and M&E #2904) and four DFT gauges (M&E
         #4332, M&E #4333, M&E #2809, and M&E #2923). Records indicated that
         the instruments were calibrated at the proper intervals.
     e.  Action required of TUEC by NUREG-0797, Supplement No. 9:       On page 9,
         the NRC inspector reviewed the status of actions required of TUEC          ,
         related to the TRT findings.                                               )
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          (1) Backfit test program - The NRC inspector compared the data
               collected for the Elcometer calibration correction to the data
               for adhesion tests covering miscellaneous steel items in Units 1
               and 2.   The data was complete but has not been formally reported
               and submitted to NRC for review.
          (2) Traceability - This category deals with nonconformance reports
               (NCRs) which provide "use as is" dispositions for discrepant
               coating materials with inadequate technical justification for
               the disposition. The action required for this category has been   ,
               completed by the applicant and was submitted for review to the
               Director of Nuclear Reactor Regulation in TUGCo
               letter (TXX-4613) dated November 18, 1985.
          (3) Coatings procedures - The TRT found deficiencies in procedures
               and instructions for coatings work and related inspection
               activities, during the construction phase, which rendered them
               inappropriate or inadequate for determining satisfactory
               accomplishment of important work activities. The TRT also found
               that the system for review and approval of procedures was
                inadequate to detect and correct these deficiencies. The NRC
                inspector's review of the current procedures showed that TUGCo
               had revised their coating procedures for the Unit 2 construction
               phase and the reinspection activities for Unit 1 to include
                inspection attributes for determining satisfactory
               accomplishment of irnportant work activities. CP-EP-6.2 was
               established to assure that procedures and instructions are
               reviewed and approved by technically qualified individuals to
               assure consistency and clarity.
               TUGCo letter TXX-4613 outlined the coatings surveillance program
                for operations.
          (4) Coating exempt log - The TRT requested an updated estimate of
                the number of additional items to be entered on the exempt log.
               Unit 2 exempt log is current and up-to-date. However, Unit 2
               will have few entries into the exempt log because any deficient
               coating areas will be reworked or repaired. When the Unit 1
               backfit test program data is complete, an estimate will be
               entered into the exempt log.
          No violations or deviations were identified.
   8. HVAC Systems, Unit 2
      a.  Review of FSAR, Specification, and Drawings: The NRC inspector
          reviewed the CPSES FSAR to identify the HVAC's design and quality
          assurance requirements. FSAR Volume IV, Section 3.2, " Classification
          of Structures, Components and Systems," states that part of the
          containment ventilation system is seismic Category 1. FSAR Volume XIV
          Section 17.0, Appendix 17A, " List of Quality Assured Items," states

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        that the containment ventilation system (which contains eight
        subsystems / components) is seismic Category II and non-nuclear-safety
        with the exception of the containment purge exhaust ductwork, support,
        debris screen, and isolation valves, which are seismic Category I.
        Only the isolation valves, which are safety and code class 2, are.
        safety-related and seismic Category I.
        The Gibbs & Hill Inc. specification for HVAC systems is 2323-MS-85,
        Revision 3. Selected portions of this specification were reviewed to
        select the the hardware to be inspected. Isolation dampers or valves
        and hydrogen purge systems were selected for inspection,
     b. Work observed: The NRC inspector used Drawings 2323-M-2-0301,
        Revision CP-4, and 2323-M2-0502, Revision 1, to verify the equipment
        as-installed; i.e., identification, location, and configuration of the
        hydrogen supply / exhaust, and containment supply / purge / relief systems.
        The following were inspected:
        CONTAINMENT                           SERIAL   RECEIVING INSPECTION
        PENETRATION           VALVE           NUMBER   REPORT (RIR)
        M III 18            2HV 5543         14759-1B    12191
                            2HV 5563         14759-1B    12191
                            2HV 5542         14759-1F    12191
                            2VA 001          AF 074      9579
        M III 19            2HV 5541         14759-1A     12191
                            2HV 5562         14759-1B     12191
                            2HV 5540         14759-1C     12191
                            2VA 002          AF 003      9579
        MV2                 2HV 5539         14759-3C     12191
                            2HV 5538         14759-3D     12191
        M V 14              2HV 5549         14759-2A     12191
                            2HV 5548         14759-2B     12191
                            2VA 005          AD 213      08565
        MV1                 2HV 5537         14759-3A     12191
                            2HV 5536         14759-3B     12191
                            2VA 003          AD 219      08509
     c. Records Review: The NRC inspector reviewed RIR packages: 12191, 13110,
        13186, and 13187.     These packages contained a receiving checklist,
        drawings, QA checklist, and a documentation package which included:
        drawings, order specification sheet, material traceability list, body
        mill test report (MTR), disc MTR, stem MTR, disc pin MTR, gasket
        retainerMTR,gasketretainerboltscertification(Cert),fillermetal
        test report (TR), manufacturer's material TR, certificate of compliance,
        liquid penetrant TR, weld repair report, body radiography TR, wall
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                                                                                                                  thickness measurement report, final TR, cleaning Cert, cycle TR, ASME                                         ,
                                                                                                                 Data Report, and assembly shop traveler.                                                                       -
                                                                                                                 No violations or deviations were identified.
                                                          9.                          Mechanical Penetrations, Unit 2
                                                                                      In conjunction with the HVAC inspection, the NRC inspector observed
completed mechanical penetration work and reviewed selected records.

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                                                                                      a.                         Work Observed:                                    Penetrations MIII-18, MIII-19, MV-2, MV-14, and MV-1
                                                                                                                 were located using Drawing 2323-M2-0502, Revision 1, and were found to
                                                                                                                 be properly identified and configured. These penetrations were
;                                                                                                                properly protected and showed no damage,
                                                                                      b.                          Records Reviewed:                                  The NRC inspector reviewed the RIR package for
                                                                                                                 penetration MIII-18 and found that the package contained the proper                                            '

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                                                                                      No violations or deviations were identified.
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j 10. Safety-Related Pipe Supports and Restraint Systems i

a. Procedures
The NRC inspector reviewed Brown & Root Inc., (B&R) QA
                                                                                                                 Manual, Section 16, Revision 16; Section 19, Revision 8 (in part); and
                                                                                                                 Appendix 1.0, Revision 3 (in part). ASME QA Procedures CP-QAP-2.1,
                                                                                                                  Revision 12; -11.1, Revision 8; -11.1-28, Revision 34; and -19.1,
                                                                                                                  Revision 2 (in part) were also reviewed.
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                                                                                      b.                         Observation of Work Activity: The NRC inspector interviewed three                                              (
                                                                                                                 craftsmen who were installing an anchor support for containment spray
                                                                                                                 piping in the Safeguards building. The welding of the support and

, torquing of baseplate anchor bolts were witnessed. Work was ! accomplished in accordance with the requirements of the work packages. 

                                                                                      The NRC inspector inspected a total of 24 pipe supports on the safety
                                                                                       injectionsystempiping. Of these, two were large bore spring hangers, one                                                                 ,
                                                                                     was a small bore snubber, one was a large bore snubber, two were equipment                                                                 i
                                                                                      snubbers, eleven were small bore restraints, and seven were large bore
                                                                                      restraints. Several discrepancies were noted on the following supports:
                                                                                      H-SI-2-SB-020-1-2, -3-2, 5-2, 6-2, 8-2, 10-2, 11-2, and 12-2;
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                                                                                      H-SI-2-58-019-1-2, 3-2, 4-2, and 5-2; SI-2-039-401-S22R, SI-2-039-404-S22R;
l'                                                                                    SI-2--309-406-522R; SI-2-044-401-522R; SI-2-070-404-522R; SI-2-070-405-522K;
                                                                                      and SI-2-070-406-S22R. However, B&R inspection had not been performed on
                                                                                      the supports. Since installation and inspection were not complete, there

i are no NRC findings at this time. The discrepancies found were generally

insufficient clearance or a departure from the design drawing.
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                                                                                      The NRC inspector reviewed seven safety-related pipe support documentation

i packages including records of materials, welding, QC inspection, NCRs, 

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         rework, and reinspection as follows:      RH-2-5B-024-001-2, CT-2-038-402-C52R,
         CS-2-RB-072-702-1, CC-2-041-713-A63R, MS-2-150-448-C52K, H-CS-2-RB-021-7120-1,
         and H-SI-2-RB-0580-701-2.
         The items of nonconformance identified by B&R inspectors were generally for
         dimensions that were slightly out of tolerance; i.e., Hilti bolt minimum
         spacing. All NCRs appeared to be dispositioned properly.
         No violations or deviations were identified.
     11. Observation of Electrical Work Activities
          During this report period, the NRC inspector observed two safety-related
         cable termination activities. The first termination activity observed was
         a Train A (orange cable) termination in a junction box in containment; the
          second was two Train B (green cable) terminations in a motor control
         center (MCC) in the green switchgear room.
          In-process work observation was performed to verify that: (a) the latest
         drawings and termination cards were being used; (b) the cables were
         protected from damage from nearby construction activities; (c) that proper
          separation was maintained; (d) segregation of power, control, and instrument
         cableswasmaintained;(e)cableidentificationwaspreserved;(f) bending
          radius was maintained; (g) cable entry point was acceptable; (h) tools
          requiring calibration were in good repair and properly calibrated;
          (i) connection tightness was correct; (j) terminations were of the correct
          type and properly located; (k) junction boxes, MCCs and switchgear were
          free of debris; (1) QC activities were performed at the times specified;
          (m) nonconformances were identified and resolved in accordance with
          procedures; and (n) installation and inspection activities were being
          documented during the in-process work activity. Terminations of two types
         were observed. One termination type required terminal lugs while the other
          type did not. The attributes specific to the termination type, in addition
          to those attributes common to both, were inspected. Cable numbers and
          termination points were: Cable No. E02199710, termination point junction
          box 2C245 in containment; and Cable Nos. EG213168, AG213254 termination
          point CP2-EPMCEB-06 in the green switchgear room. The NRC inspector
          verified that all pertinent requirements had been met.
          No violations or deviations were identified.
     12. Exit Interview
          An exit interview was conducted January 7, 1986, with the applicant
          representatives identified in paragraph 1 of Appendix D of this report.
          During this interview, the NRC inspectors summarized the scope and findings
          of the inspection. The applicant acknowledged the findings.

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