ML20202F221
| ML20202F221 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/18/1986 |
| From: | Solla E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20202F175 | List: |
| References | |
| FOIA-86-382 50-445-85-19-01, 50-445-85-19-1, NUDOCS 8607150114 | |
| Download: ML20202F221 (11) | |
See also: IR 05000445/1985019
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APPENDIX
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SPECIAL UNIT 1
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CABLE TRAY SUPPORT "AS-BUILT" PROGRAM INSPECTION
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report:
50-445/85-19
Construction Permit: CPPR-126
Docket: 50-445
Category:
A2
Applicant:
Texas Utilities Electric Company (TVEC)
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Skyway Tower
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400 North Olive Street
Lock Box 81
Dallas, Texas 75201
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Facility Name:
Comanche Peak Steam Electric Station (CPSES), Unit 1
Inspection At: Glen Rose Texas
Inspection Conducted: November 18 - December 18, 1985
Inspectors:
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R. E. Lipinski, NRR
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J. R. Dale, RIV Consultant
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E. A. S,qlla NRR Consultant
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T. Langowski, NRR Consultant
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8207150114 860709
CARDE86-382
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Reviewed By:
I, Barnes, Group Leader, Region IV CP5ES Group
Date
Approved:
T. F. Westerman, Chief, Region IV CP5ES Group
Date
Inspection Summary.
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Inspection Conducted November 18 - December 18, 1985 (Report 50-445/85-19)
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Areas Inspected: Special, unannounced inspection of the Unit I cable tray
support as-built inspection program and the related QA audit program for this
activity. The inspection involved 224 inspector-hours onsite by six NRC
-personnel.
Results: Within the two areas inspected, three violations (failure of walkdown
teams and QC inspectors to correctly determine and verify, respectively,
as-built cable tray support attributes, paragraph 3.a-3.h; failure to perform
periodic audits of the as-built cable tray support program, paragraph 6; use
of weld angles in cable tray supports wh.'ch were below the permissible minimum
values, paragraph 5) were identified.
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DETAILS
1.
Persons Contacted
(*)(**)R.A.Muldoon,Ebasco
(*)R. B. Bronson, Eoasco
(*)R. C. Iotti, Ebasco
(*)(**)R. M. Kissinger Texas Utilities Generating Company (TUGCo)
(*)R. Siever, B&R
(*)(**)C. R. Hooton, TUGCo
(*)(**)R. E. Camp TUGCo
(*)(**)W. F. Rockwell, Ebasco
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C. A. Briggs, TUGCo
(**)H. A. Harrison TUGCo
(**)P. Halstead. TUGCo
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(**)T. Brandt, TUGCo
(**)J. S. Marshall, TUGCo
(**)J. Vorderbrueggen. Impell
H. A. Levin, TERA
The NRC inspectors also interviewed other applicant employees during this
inspection period.
(*) Denotes those present during November 22, 1985, exit meeting.
(**) Denotes those present during December 5, 1985, exit meeting.
2.
Cable Tray Support As-Built Inspection Program
The inspection was performed to verify the adequacy of the Unit 1
as-built inspection program for cable tray supports. The bases used for
this inspection were:
(a) TUGCo Nuclear Engineering (TNE)
Procedure TNE-AB-CS-1, Revision 1, dated September 30, 198E. "As-Built
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Procedure, Cable Tray Hanger Design Adequacy Verification;* and (b) the
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as-built red lined drawings which were prepared by TUGCo walkdown teams
(composed of a walkdown engineer and a QC inspector) in accordance with
Procedure THE-AB-CS-1, Revision 1.
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From a total of 789 cable tray supports that had been through the walk-
dow:. program, a total of 66 supports were selected by the NRC inspection
team using a random number generator. These supports were then broken
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down by building and type. An engineered sample of 32 supports was
selected. This sample included the following cable tray supports:
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Reactor Building
Fuel Building
CTH-1-42
CTH-1-1695
CTH-1-239
CTH-1-1716
CTH-1-4738
CTH-1-1742
CTH-1-5488
CTH-1-1845
CTH-1-5517
CTH-1-1853
CTH-1-5538
CTH-1-1963
CTH-1-5757
CTH-1-5352
CTH-1-5787
CTH-1-7047
CTH-1-5817
CTH-1-5873
Control Room
'CTH-1-5942
CTH-1-7199
CTH-1-5976
CTH-1-6041
Safeguards Building
CTH-1-6497
CTH-1-207
CTH-1-6517
CTH-1-607
CTH-1-6559
CTH-1-636
CTH-1-6631
CTH-1-707
CTH-1-12075
CTH-1-13026
As a result of this inspection, deficiencies were identified in major
attributes associated with the Unit I cable tray supports red-lined
as-built drawings.
3.
Summary of Deficiencies (TNE-AB-CS-1)
A summary of the findings from this inspection which appear to be in
violation of 10 CFR 50, Appendix B Criterion X and THE AB-CS-1,
Revision 1, are as follows:
a.
Tray Size
(1) Procedute Requirements
TNE-AB-CS-1, Revision 1, Section 4.2.2.B.7 requires verification
of the following:
"7.
Cable Trays
a.
Width
b.
Depth
c.
Location within Support"
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(2) Findings
CTH-1-5817 is recorded as a 4" x 12" tray.
It was found to be
a 4" x 24" tray by NRC.
b.
Tray Span
(1) Procedure Requirement
TNE-AB-CS-1, Revision 1, Section 4.3.2. requires verification
of the following:
"6.
Indicate span from support to. support . . ."
(2) Findings
CTH-1-5817 conduit span was in error by I' 6".
CTH-1-239 spans were in error by 8" and 10".
c.
Tray Clamps
(1) Procedure Requirement
THE-AB-CS-1, Revision 1 Section 4.2.2.B.6 requires
verification of the following:
"a.
Clamp Type (Attachment D)
1.
Bolted
a.
Flat washer or bevel washer
2.
Welded
a.
Weld size and weld length will be verified
in accordance with Reference 1-6."
(2) Findings
CTH-1-12075 cable tray clamp was recorded as a Type B
" Heavy Duty Clamp" i" plate welded to channel. Actual
clamp was a Type C bolted clamp.
CTH-1-1845 cable tray clamp G-2 was recorded as a bevel
washer only, actual clamp contained a bevel and a flat
washer.
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d.
Member Size
(1) Procedure Requirement
TNE-AB-CS-1, Revision 1. Section 4.2.2.8 recyires verification
of the following:
"E.
Hanger Configuration
s.
Member shape and nominal size per AISC (see
Table 13 Or AISC manual of steel construction
7thedition)."
(2) Findings
CTH-1-5787 angle shape under tray was identified as 5/16" in
thickness. Actual thickness was 7/16".
e.
Weld Qualitative Measurement
(1) Procedure Requirement
TNE-AB-CS-1, Revision 1. Section 4.2.2.B. requires
verification of the following:
"3.
MemberConnectionDetails(Connectiontosupport
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member)
a.
Welds shall be verified by the QC inspector
in accordance with Reference 1-G."
Reference 1-G, QI-QP-11.10-9 Cable. Tray Hanger As-Built,
(Inspection / Verification), Revision 2, Section 3.3.5
requires verification of the following:
"3 3 5 Welding Inspection
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3.3.5.1 General
Welding shall be inspected for quantitative and
qualitative attributes as listed below without
paint removed.
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Quantitative
a.
Type of Weld (fillet, flare bevel,
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groove,etc.)
b.
etc.)guration (two sides all around,
Confi
c.
Weld Length
d.
Weld size"
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In Supplementary Safety Evaluation Report (SSER) 12
Section 3.8.3 which addresses FSAR Amendment 55, the
applicant has been given approval to use Nuclear
Construction Issue Grcup (1CIG) document NCIG-01,
Revision 2 " Visual Weld Acceptance Criteria for Structural
Welding to Nuclear Power Plants" (VWAC).
VWAC specifies
the following acceptance criteria for fillet welds:
"3.5.2.2 Acceptance Criteria: a fillet weld shall be
permitted to be less than the size specified by 1/16
for i the length of the weld."
(2) Findings
CTH-1-5942 fillet weld #1 was found to be 1/16" undersized
from that recorded for greater than 1/4 of its length.
CTH-1-1845 fillet weld detail B was found to be 1/16"
undersized from the recorded for greater 1/4 of its length.
CTH-1-5517 fillet weld #1 was found to be 1/16" undersized
from that recorded for greater than 1/4 of its length.
CTH-1-5488 fillet weld was found to be undersized 1/16"
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from that recorded for greater than 1/4 of its length.
CTH-1-4738 fillet weld was found to be undersized 1/16"
from that recorded for greater than 1/4 of its length.
CTH-1-12075 measurement of the top and bottom of member
weld lengths was recorded in reversed.
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CTH-1-1853 measurement of the top and bottom of member
weld lengths was recorded in reversed.
f.
Dimensional Measurements
(1) Procedure Requirements
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TNE-AB-CS-1, Revision 1 Section 4.2.2. requires
verification of the following:
"A.2 Elevation (of lowest horizontal member)
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B.2. Hanger Configuration
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Dimension, including addition of required
dimensions.
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f.
Expansion anchor bolt projection and/or
embedment (Table 12).
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B.4 Support Anchorage
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e.
Bolt distance from heel of angle or
channel, etc.
(Gage
'G' dimension)"
(2) Findings
CTH-1-5942 dimension to edge of column was in error 1".
CTH-1-1845 dimension between attachments was in crror
l' 3/4".
CJH-1-1963elevationwasinerrorby3"(ElevationA-A).
CTH-1-42 gage dimension was in error 1".
CTH-1-239 gage measurement was in error 5/16".
CTH-1-1845 bolt projection measurement was in error 3/4"
CTH-1-7047 bolt projection for bolts #1, #2, and #3 was
in error greater than 1".
CTH-1-5976 bolt projection measurement was in error 1/2"
g.
Bolt Size
(1) Procedure Requirement
TNE-AB-CS-1, Revision 1, Section 4.2.2.B requires
verification of the following:
"3.b Bolts
1-Size"
(2) Findings
CTH-1-6631 hex nut was standard when a heavy hex nut was
specified.
h.
Member Orientation
(1) Procedure Requirements
TNE-AB-CS-1, Revision 1, Section 4.2.2.B requires
verification of the following:
"2.
Hanger Configuration"
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(2) Findings
CTH-1-1845 angle to wall was rotated 90 degrees from
drawing detail.
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4.
Other Findings Related to TNE-AB-CS-1
a.
Measurements
Criteria were not provided with respect to the required acuracy of
measurements in obtaining THE-AB-CS-1 red-line data. Variations in
bolt projection and gage measurements were identified which appear
to be attributable, in part, to the many different methods used to
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make the measurements. The applicant has indicatcJ that TNE-AB-CS-1
will be revised to provide clear guidance with respect to
measurements. This in considered an open item-(445/8519-0-01).
The NRC inspectors compared NRC measured dimensions and the red-line
recorded dimensions to the tolerances given in tables attached to
TNE-AB-CS-1. Measurements which violated these tolerances are
identified in paragraph 3 above.
b.
Inaccessibility
The NRC inspectors identified that there were attributes which
appeared accessible, although they had been identified as
inaccessible.
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The applicant stated that the training provided to the walkdown
personnel instructed that measurements be taken only if they were
fully accessible at the support.
Further, the training provided
gave instruction that all attributes of a particular component be
fully accessible before it is inspected.
The applicant has indicated that the term inaccessible will be
clarified by revision to TNE-AB-CS-1.
This considered an open item (445/8519-0-02).
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5.
Weld Bevel
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In addition, the NRC inspectors noted weld bevels which appeared to be in
violation of the American Welding (AWS) D1.1 Society Code. The quantita-
tive weld attributes, such as bevel, were inspected by the applicant only
for the first 100 supports in accordance with TNE-AB-CS-1.. It was there-
fore not a requirement of the Unit 1 as-built cable tray program to verify
weld bevel beyond the first 100 supports inspected.
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The FSAR, Table 17A-1 states that cable tray hangers will be constructed
in accordance with American Institute of Steel Construction (AISC) Code.
The AISC Code, Seventh Edition, Page 4-131, states that "The AISC
Specification and the American Welding Society exempt from tests ar.d
qualification most of the common welding joints applicable to steel
structures. When the joints . . . as designated as prequalified . . ."
Gibbs and Hill, Inc., Specification 2323-SS-16B, Section 6.4, dated
May 7, 1975, states, " Welding construction shall conform to AISC Specifi-
cation for Design, Fabrication and Erection of Structural Steel for
Buildings and AWS D1.1."
The AWS D1.1-75 Code, Section 2.9.2.4 states with' respect to weld groove
angle, "The groove angle is minimum.
It may be detailed to exceed the
dimension shown by no more then 10 degrees."
The weld bevel for hanger drawing CTH-1-5538, full penetration weld #2,
was found to be 30* by the NRC inspector.
In addition, the weld bevel
for hanger CTH-1-5517, 1" plate full penetration weld, was measured
to be 36*-38 . The prequalified weld bevel specified by the hanger
drawings (CTH-1-5538 and CTH-1-5517) was 45*.
The failure to control weld bevel angles appears to be in violation of the
AWS D1.1 Code and 10 CFR 50, Appendix B, Criterion IX.
6.
Audit of As-Built Cable Tray Support Inspection Program
The NRC inspectors could find no objective evidence that the cable tray
support as-built inspection program had been audited or scheduled to be
audited.
The failure to establish planned periodic audits of the cable tray
support as-built inspection program is considered to be in violation of
10 CFR 50, Appendix B, Criterion XVIII.
7.
Applicant Corrective Actions
The applicant promptly initiated the following corrective actions:
TUGCo Engineering was requested to document and evaluate each
finding to determine corrective action on November 22, 1985.
Stop Work was issued to field activities associated with Unit 1
as-built / inspection program on November 26, 1985.
A Corrective Action Request was issued on November 26, 1985.
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A TUGCo investigation was initiated to determine the cause.
Personnel
actions have resulted from the investigation underway.
Inspection of the as-built program Unit 2 was initiated to determine
if similar problems existed in Unit 2.
The evaluation of actions necessary to resume the as-built program
is in progress.
8.
Exit Meeting
Exit meetings were held on November 22, 1985, and December 5, 1985,
respectively, to discuss the initial and final findings from this
inspection.
A subsequent exit meeting was held with TUGCo corporate management on
December 18, 1985, to review the findings from this inspection, at which
time, potential escalated enforcement action was discussed.
Those present included:
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TUGCo
W. G. Council
J. W. Beck
NRC
R. D. Martin
V. S. Noonan
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In Reply Refer To:
Docket:
50-445/85-19
Texas Utilities Generating Company
ATTN:
Mr. W. G. Counsil
Executive Vice President
400 North Olive, L.B. 81
Dallas, Texas 75201
Gentlemen:
This refers to the special inspection conducted by Mr. T. F. Westerman,
members of the Region IV Comanche Peak Group, and NRR personnel during the
period of November 18 through December 18, 1985, of activities authorized by
NRC Construction Permit CPPR-126 for the Comanche Peak Steam Electric Station,
Unit 1, and to discussions with Mr. R. E. Camp and other members of your staff
on November 22, 1985, and December 5, 1985.
The purpose of the special inspection was to evaluate the Comanche Peak Steam
Electric Station, Unit I as-built cable tray inspection program. The
inspection identified multiple instances involving the failure to properly
inspect and document as-built cable tray attributes.
In addition, violations
were identified relative to both the failure of the QA programs to establish
QA overview and audits of the Unit 1 as-built cable tray inspection program
and the use of incorrect weld bevel angles. The violations and related NRC
concerns were discussed with you in the subsequent exit meeting held on
December 18, 1985.
No response to this letter is requested.
Enforcement actions relative to this
inspection will be forwarded under separate correspondence.
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RIV: CPG
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AD:DRS&P
IBarnes;ap
TWesterman
EJohnson
DPowers
VNoonan
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Should you have any questions concerning this letter, we will be glad to
discuss them with you.
Sincerely,
E. H. Johnson, Director
Division of Reactor Safety
and Projects
Enclosure:
Appendix - NRC Inspection Report
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50-445/85-19
,
cc w/ enc 1:
Texas Utilities Electric Company
ATTN:
J. W. Beck, Vice President Licensing
Quality Assurance and Nuclear Fuels
Skyway Tower
400 North Olive Street
bec to DMB (IE01)
Lock Box 81
Dallas, Texas 75201
bec distrib. by RIV:
- RPB
- MIS System
Juanita Ellis
- RRI-0PS
- RSTS Operator
President - CASE
- RRI-CONST
- R&SPB
1426 South Polk Street
- TFWesterman, CPTG
DRSP
Dallas, Texas 75114
V. Noonan, NRR
R. Martin, RA
S. Treby, ELD
- RSB
Renea Hicks
- RIV File
J. Taylor, IE
Assistant Attorney General
- D. Weiss, LFMB (AR-2015)
Environmental Protection Division
R. Heishman, IE
- D. Powers, EC
P. O. Box 12549
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Texas Radiation Control Program Director