ML20198E853
| ML20198E853 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| 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) | |
See also: IR 05000445/1985018
Text
{{#Wiki_filter:* .. ' APPENDIX C . CONSTRUCTION INSPECTION REPORT i U. S. NUCLEAR REGULATORY COMMISSION REGION IV , NRC Inspection Report: 50-445/85-18 Permits: CPPR-126 50-446/85-15 CPPR-127
Dockets: 50-445 Category: A2 i i 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 Inspection At: Glen Rose Texas ' ] Inspection Conducted: December 1-31, 1985 i 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) SaA .r/5/r l, ' . p C. E. Johnson, SRRI, Construction, Region IV Date South Texas Project (paragraph 7) GJCu%:cLJ +n-z. P. W. Michaud,M eactor Inspector, Region IV Date (paragraph 10) J 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 ! . . . - - . .
I . . -g- Reviewed by: - [ 8 0_ s -o f/S/4'4 1. Barnes, Group Leader, Region IV CPSES Date Group Approved: Nr [[#[EC T. F.~ Westerman, Chief, Region IV CPSES Group 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. i
I ' . -3- 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 Bulletins requiring hardware evaluation, repair, replacement and verification will be reviewed and reassessed to assure that the cognizant construction organization tracks or has tracked present or 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. 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 - - - -
. ' . -4- 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 c - - - - - - . - . - - -
! o . l -5- 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.
I , , -6- 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. ) .
' i -7- (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
- , t -8- 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 - - - - - - - - - - - a
- - . _ - _ ' . 1 -9- 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. a. Work Observed: Penetrations MIII-18, MIII-19, MV-2, MV-14, and MV-1 4 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 ' documentation. - , No violations or deviations were identified.
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. ' , 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; . 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. < The NRC inspector reviewed seven safety-related pipe support documentation i packages including records of materials, welding, QC inspection, NCRs, ! i '! l . . - - - - - - - - - - - - - - - - - - -
I . . -10- 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. - - - A }}