ML20206U336

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Forwards IE Circular 81-05,for Info
ML20206U336
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 03/31/1981
From: Seyfrit K
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Gary R
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML20206Q979 List:
References
FOIA-85-59 NUDOCS 8607100176
Download: ML20206U336 (1)
v • d • e


Text

t g*4g UNITED STATES

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NUCLEAR REGULATORY COMMISS.JN

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REGION IV RECEIVED

    • g 611 RYAN PLAZA DRIVE. Su!TE 1000

,q ARLINGTON, TEXAS 76011 06 m March 31,1981 Docket Nos.

50-445 T.U.S.I. - NUCLEAR DIV.

50-446 LICENslNG r

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Texas Utilities Generating Company ATTN: Mr. R. J. Gary, Executive Vice President and General Manager 2001 Bryan Tower Dallas, Texas 75201 Gentlemen:

The enclosed IE Circular is forwarded for your information. No written response to this circEai~)is required.

. (s(-O@

If you have any questions related to this matter please contact this office.

Sincerely, u,

Karl V. Seyfrit Director

Enclosures:

1.

IE Circular No. 81-05 l

2.

List of Recently Issued IE Circulars Received APR 2 1981 yc: B. /8 R.J. GARY.

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W.G..

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APR 7 1981 i

TUGC0 QA DALLAS 8607100176 860625 PDR FOIA GARDE 85-59 PDR L

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umTED STATES

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survey package for stress problem 1-017 (a portion of the Safety Injection System) was examined and the as-built survey deficiency punchlist ccm: uter printout for problems 1-003, 1-006, 1-007, 1-010A, 1-01CC, 1-0199, 1-021 and

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. r: gram cetails were c,.scussac with

, v-3 were reviewec.

..J S.;) iecnnical the.iexas Utilities :ervices,. c.

.n Services Suoervisor (responsible for engineering asgscts) anc the TUSI CA Scecialis: Su:erviser and As-Built C:crcinater (res:cnsible for field inspec-icns).

As a result.of this "As-Euilt" review, the NRC CAT inscec-

rs,. centi:1ec c:ncerns as t: ne exciusive use of ;unen-lis:s to document discre:ar.cies :e: ween detaii crawings and 9

as-cuilt narcware tversus a cecumentec/controslec me:noc of ice.ntifying, c:rrec-irg anc :reven:1ng recurrence :

ceticiencies.

ine acove procedures co not invcive ne nonconformance precedure or ctherwise involve tne cuali y assurance program in accressing ciscre: ant concitiens :n ;C accec:ec ci:ine anc sa::cr:s/ restraints.

Scecific exam:iss

f this c:ncer5 are ce ailec in ne succor / restraint secticn c :nts reccr:.

ine re'a:ec :r: gram recul-eman 3 are.ciscussec in nis reper: in Secticn IX.3.2 "Correc ive

-ction Systems."

2.

i:e Su::cr:s/ Restraints 2.5ME ri:e su:: r / restraints are f a:rica ec, ins ai:ec, anc CC ins:ec ec : cetailec drawings Ore:arec by ITT Grinrei, Nuclear
wer Services !ncustries (NPSI), or TUSI Fipe Succor: Engineer-ing (?SE) ar.c a::licatie Ccmecnen: Meci#ica-icn Car:s (~5Cs).

Smali acre (isss nan Zi" dia.1 Class 2, 3 3 5 su:::r:s/

restrair.:s may :e snown :n tycicai :rawings r cr. "eng neerec"

e aitec crawings. Sc::cr:s may be na:" :ns:ec:ec severa:

1.es cased on subsecuent changes : criginal cesign; cecause f

-he issuance :f revisec cesign :rawings, anc crimarily :y :ne issuance of CMCs by PSE. (fiele engineering).

When engineering c:nsi:ers that the " final as-cuil ' s;ress analysis has been :er#:rmec anc :nere is a nign ;r acili y :na-furtner cnanges :: ne su::cr: wiii net te recuirec, a Venccr Certified Crawing (VCC) for large bore supccr:s anc a Cesign Review Drawing (CRD) f:r small bore su:ccr:s is issuec.

These frawings inc:r: crate any "information only" :y;e CMCs anc any mccifica:icns necessi a ec by icad cranges. CC :ren ins:ects

ne su::cr:s for :ncse features revisec cy te 7CC/,CP.C anc #:r covicus missing :ar:s.

The felicwing sam le f 21 installed anc QC acce:tec :i:e su :cr:s/ restraints were se,.ec:ec for inspecticn

rovice a variety of types, si
es, systams and locations:

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Succor-/ Restrain Nc. Lcca icn Size Class Tvce

.I' RC-1-015-708-C41R Cent.

2" 1

Strat CC-2-AB-023-002-3 Aux.

2" 3

Strut SI-1-SB-238-006-2 Safeguarcs li" 2

Sox SI-1-068-706-C42R Cent.

2" 2

Sox 1

RH-1-004-007-532R Safecuards 12" 2'

Strut S

CS-1-357-001-S22R Safeguarcs 5"

2 Stru Y' r:

12" 2

Sox S I-2 -031 -425-Y32R a

CS-2-063-413-542R Safeguarcs 8"

2 Strut RC-2-121-401-SS2R Safecuarcs 3"

2 Stru:

CS-2-012 403-C42R Cent.

3" 2

Strut CC-1-136-706-E63R Elec:r.

3" 3

Strat SI-1-037-005-532A Safeguar:

2" 2

Ancher

.4-1-017-702-C52X Cent.

'5" 2

Snubter CC-1-116-037-F43A Fuel 12" 3

Anchor CT-1-002-008-532R Safeguarcs 16" 2

Strut r.

. 1#-00e'-c.":.

. e 's

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u 2 RH-1-003-002-542R Safeguarcs 12" 2

Stru:

C5-1-063-008-5222 Safecuarts 3"

2 Scx 51-1-031-046-Y325 Yard' 12" 2

Scring RM-1-001-C01-C415 Cent.

12" 1

Spring S:-1-092-008-CAIX C:nt.

5" 1

Snubber S-1-001-016-Ca2X Cent.

2" 2

Snubcer C5-1-055-010-5425 Safeguarcs 2"

2 S ring

'C-1-C75-026-C51R C nt.

2" 1

Strat

-:cce cf tnese su:perts nad '/C :s issuec, scce cic nc:. The accvc su:ccr s aera ins:ected agains thei-de ail drawings and CFCs for ::nfiguration, icentifica:icn,1:ca:icn, f astaner/ ancner

cit installa:icn, clearances, ec:er si:e, anc carage/or::ac-
i:n.
n acditien, aparexicately 20C acci-icnai sa::cr:s aere Observed in the field for cbvicus ceficiencies suen as icese or missing fasteners, i :re:er clearances er angularity, camage anc i=:recer ex ansion ancnce scacing.

Acce::ance criteria for tne field inspecticns are : ntaine.d in

ne felicwing cccuments:

Detail suppor / restraint drawings and applicable CMCs syp1:al crawings inciucing smal,t bore e,,enera. Notes crawing, t

CP aA-C01 OI-GAP-11.1-25, Rev.16. "Faoricaticn, :ns:alia-icn Ins;ec-tiens of ASME C:mpenent Su:cor:s, Class 1, 2, anc 3" CI-QAP-11.1-2SA, Rev. O, 'Installa:icn Ins:ecti:n Of 4SME Class 1, 2 and 3 Snue,cers" 01-0?-11.2-3, Rev. 1", "Ter:uing anc Scacing :f Concrete Anchor Soits" 77'_d e

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The follcwing discrepancies were icentified on the supports / restraints inspected:

t U-bolt c:nfiguratien no per drawings:

CS-1-063-028-532R AF-1-059-001-533R H-RC-1-RB-039-015-2 H-CS-1-RB-017-001-2 H-RC-1-RS-038-004-2 Lug to restrain; clearance excessive:

00-2-019-007-F33R (11/32" vs 3/32")

Cimensicn not per drawing:

RC-1-075-025-051R (2' a 3/4" vs 2' 10 1/2")

Richmenc insert anch:r be'- threacs not as recuired:

C5-1-001-016-Ca2X Snu:ber icac cin missing:

FW-1-017-702-C32K

'/cic in concre a nea-c:ncrets ex: ansi:n an:ncr:

e.,n-t-Auc-i.c-(-

R

' cose strut 'ccknuts:

SW-1-C03-CC2 433R SI-1-Cla-C25-532R

.vissing/ broken cetter pins:

la supports Class 3 nanger miscarkec as Class 2:

H-GH-X-AB-0042-003 Numerous other instances of loose locknuts, U-bolts, and missing or broken cotter ains were oservec en Class 5 su :or:s/

res raints that were uncer ne T.'GC3 "A/CC :r:gra.m.

n ri-Outinc :o ne O.r:clems icentifisc si n ~J-cci: installations are cenrusing crawings wnicn sn w 'J.coi:s witn./.o :nen :learance recuired, cut also wi n ecucie nuts :n ne u sice of :ne retaining olate. Clear acceo anca criteria is needec Orier ::

inspections :aing perfor ec.

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b NRC CAT members varied from a detailed inspec~.t

'f many

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attributes to a verificaticn that in fact a snu0bc. is installec

. Walkdcwn prece.dures wnen a snu:ber is indicated as recuired.

aisc de not :rev ce sur:1cient spec 1:1c ins:ect; n attributes anc checklis:/markuo controis for icentifica icn anc correction cf the large number of icose anc missing cotter pins and fasteners.

a A review of the dccumen:t:icn cackages for the 24 suoperts/

restraints listec previcusly was perfcrmed. The packages are cifficult to follcw due to the large number of changes involved with an average of :ver five CMCs :er su:ccr: and as many as 16 On one succcr. Previcus ins:ecticns are ne: voiced.

!! was observed that frem a o:11 cf 55 ins:ection rescris, c vering accroximately 410 total attributes, nere was cnly one indica-tien of an unsatisf actory IR and only cne NCR was written. For non-ASME su: ports, GC rejects 20 percent of :ne succor:s sub-mitted for final ins:ecticn in acdition o recuiring immediate c:rrection of minor hardware items (locse belts, etc.).

The near perfect recorc in the ASME oregram incicates tnat orcolems are :eing turned cack :: constructicn f:r resolu-ica (tarcusn immeciate correction or issuance of CMCs)..This practfce wnen

ncuctec for aii-tyees tf' deficiencies cia #:umvents tne-Gerre:-

tive Action.:r: gram.:o -identify anc preven recurrence Of

' significan deficiencias.

Review of la cf these :ackaces incicated the f llcwinc discre:-

ancies/ a: reinfcrce this 5:ncern. Aitncugn :ne Muliiple Weld Ca a Carc (MWDC) has a CMC log bicck, in numer:us ins ances ne ic; incicates CMC revisiens anc entry ca:es ru n ia:er tnan :ne GC ins;ection signcff ca es (s:me entries ever One year after inspecticn). As ne 00vershee: Inspecticn ie:cr: ::es.c: iis CMC revisiens, it is not possible in most cases icentify wnicn CMC (cesign document) was usec :: perform the ins:ecticn.

Furtner, the "0C Checklis for Snu:ber Ins: zila-icn" cnes no-s:ecify :ne drawing er CMC revision.

In 10 cf :ne 14 packages, CMC revisions were issuec after tne ca:e tna: c:nstruction signed off en the MWOC tha :ne instalia:icn was complete, and en er snortly befcre tne date of tne CC ins;ecticn. Mest of these CMC revisiens were not "information eniy" or clarifica-tien, but cer:ained to imcortant design features such as dicen-sions, material enanges, baseclate configuration, etc.

In one instance, three CMC revisicns were issuec be: ween ::nstructicn

maletion anc OC ins:ection.
n one case, the IR was signec l

cff indicating ins:ecticn ::::letec ne cay :efore ne MWCC wi:n

-he detailec enecxlist items aas signec.

In One instance, :ne center-to-center cimension en a snuccer was enangec en a CMC revision to " meet as-cuil: c:ncitions", but had been QC inspec-ted satisfac:crily :wice bef:re.

The fellowing statements summari:e the assessment of c'i:e succor:/ res: rain: activities:

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Numerous cases of OC accepted installed hareware not 4

conforming to drawings and CMCs were identified by the NRC CAT inspectors, ANI, and S&R OC during '/CD inspections, and by TUSI "as 'cuilt" perscnnel.

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These concitions incicate peor ins:ec-ion worx, unclear /

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erroneous drafting, anc/or unauthori:ec, unccq:rollec alteratien of ccmcieted work.

w Numercus instances exis wnere nonconforming conci icns have not been properly icentifiedsto :revice ne in;ut to

ne OA Corrective Action Program for determining rect

,4 causes anc preventing recurrence.

4-

.r:m ciscussiens witn site personnel an-

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-av :us:y c.

.large number of CMCs.ri;;ac: ears criginal cesign drawings +

gyerg;used,enly.as guices..:: ::ns,:ructign, anc :ne ac ual design / analysis was perfermed a-ter constructicn anc ins;ecticn. This may have resultec # rom the many cnanges recuirec cue :: reiccatec ci:ing, inter #erences, anc he CMC pr: gram itself.

e.

The acce:: ability of the installec har: ware : meet cesign t

recuirements basec :n a series Of ;artial ins:ecti:ns (versus a final ccm:lete ins:ectier. after acrx is

meletec) is uesti:na :e :asec :n :ne f:U : wing cints:

Numcers Of "cesi;n" changes (;MCs)

Scmewhat uns:ecifi: ins;ecti:n Or:cecu-es Accun: of enceing c nstructi:n ac;iv -ies anc :ne a:Caren: lacx cf :isci:line -egarcir.g ::nstrue:icn perscnnel tam:ering with CC ac:ee:ec nar: ware.

Orafting and cesign ciscrecancies nc ec in initial crawings, CMCs and 'lC s.

.ne numcer of discre:ancies notec cn sucperts :revi-ously ac:epteo by GC.

Inscection dccumen ation not incicating the ":esign" i

cocument (:rawing anc/or CMC) -evisicn that was usec for :ne ins:ection.

In c:nclusion, althougn ex ensive ma;cr :ecnnical :r:ciems were not icentified in :ne : ice su::cr / restrain: nar: ware, pr:m:

action is recuirec :o accress ne a:ove Or: gram c:ncerns.

Scecifically, atten-icn mus: :e #: cussed in :ne areas :' :ne ncnconformance/ corrective acticn er: gram, ::m:renensive 'inal ins:ections and inscection accumenta:ien in orcer

revice conficence in the acceotacility of insta11ec ;i:e su::cr:s/

restraints, i

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16 TUGC0 CP-QP-11.13, Revisions 5 and 6, "As-Built Verification" QI-QP-11.13-1, Revision 8, dated January 4, 1983,* "As-Built Piping Verification Instructions" QI-QP-11.13-2, Revision 1, dated December 16, 1981, "Installa-tion Reinspection of Pipe Supports" QI-QP-11.16-1, Revision 14 and 21, " Installation Inspections of NNS Seismic Category II Supports For Class V Piping" CP-QP-15.0, Revision 3, dated July 19, 1983, " Tagging System" CP-QP-15.4, Revision 5, dated June 22, 1983, " Design Change Verification" CP-QP-16.0, Revision 10, dated June 10, 1983, "Nonconformances" CP-QP-17.0, Revision 1, dated June 10, 1983, " Corrective Action" CP-QP-18.0, Revision 12, dated July 19, 1983, " Inspection Report" The program represented by the above procedures should result in as-built drawings that reflect the actual installed equipment, piping, and supports, including design review and appropriate inspec-tion documentation.

The licensee is also doing a complete review of CMC's to ensure that they have been incorporated into the installa-tion and documented by inspection reports.

These programs essentially result in a re-inspection of all ASME Class 1, 2, and 3 and many non-ASME Class 5 supports.

There was concern on the part of the CAT Team relating to missing hardware, documentation problems (NCR, IR, Punchlist), partial inspections instead of final inspections, design change verification, and drawing revision numbers.

All of these concerns were originally addressed in the program, however, they were sometimes all encompass-ing type statements.

The procedures are now more specific and

$2 7 j7 punchlists are now adequately addressed and trended.< NCR's and IR's j have always been trended.

~

The scope of these procedures has greatly broadened since their actual implementation began due to identified problems in previous inspections.

A program that is able to detect previous short comings in inspections, ensure closed loop on design change implementation and verification, and provide final inspection documentation is a good program.

31 k.

VCD walkdowns do not ensure that components have been installed to requirements.

This item is addressed in the Mechanical Construction area of this report.

None of the supports reviewed by CAT had received final inspection at the time of the CAT inspection'.

These items are considered closed.

2.

CAT Potential Finding

" Contrary to 10 CFR 50, Appendix B, Criteria II and XV, and FSAR Sections 17.1.2 and 17.1.15, nonconforming conditions identified relative to some safety-related hardware installations are not being properly documented, evaluated, and dispositioned through the corrective action program (Sections III.B.2 and IX.B.2) 20/ (see Attachment)

This item has been addressed to some degree in almost every other section of this report.

RFIC's are no longer used to document separation problems, even though the Region IV inspector could not identify any gross misuse of RFIC's. /NCR's and IR's have always

' received evaluation and been utilized for trend analysis and generic, corrective action.

Punchlists are now trended. /

This item is considered closed.

3.

Summary of Region IV Followuo to CAT Inspection This report plus the Region IV letter of May 31, 1983, and the attached Notice of Violation document the Region IV followup to the CAT inspection and their potential findings as documented NRC Inspection Report 50-445/83-18 dnd 50-446/83-12.

The Region IV inspector did not expand the sample size of the CAT.

The potential findings and specific concerns provided a sufficient sample size.

The Region IV inspector reviewed the specific concerns and then.

made an indepth look at these concerns.

Four violations were identified by the SRIC and will be followed by the SRIC.

One new unresolved item is identified in this report.

4.

Unresolved Item U'nresolved items are matters which require more information to ascertain whether they are acceptable items, violations, or deviations.

One unresolved item is identified in the Electrical and Instrumentation Area of this report pertaining to the installation of NIS conduits in close proximity to fluorescent light fixtures.

(8328-01)

s

  • /.

df~

In Reply Refer To:

Dockets: 50-445 @

JUL 271!E3 Texas Utilities Generating Company ATTN:

R. J. Gary, Executive Vice

[$

President & General Manager l VI 2001 Bryan Tower Dallas, Texas 75201 Gentlemen:

This refers to the special inspection conducted of the Fuel Building completion during the period May 23 throuch June 10. 1983, of activities autnorized by NRC Construction Permit CPPR-126 for the Comanche Peak facility, Unit 1, and to the discussion of our findings onsite with Mr. J. T. Merritt and other members of your staff at the conclusion of the inspection on June 3, 1983, and to discussionf of our findings in your corporate offices with you, Mr. Fikar, and other members of your staff on June 10, 1983.

Areas examined during the inspection included the turnover / access control process as relates to the final construction completion of conduits / cable trays and supports, piping and supports, electrical separations, and cable routing, termination and seismic mounting; maintenance of installed equipment; punchlist controls; and QA audits.

Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the irapectors.

These findings are documented in the enclosed inspection report.

As you are aware, this represents the first inspection of the turnover / access control process.

The turnover / access process was selected since it presents the first time that areas or rooms are essentially complete with exception of the preidentified incomplete items. We consider this inspection to be our initial effort with regard to construction completion and that the results of this inspection should provide you with insight into areas where actions appear necessary to improve the turnover / access control process.

We have drawn no final conclusions from this inspection.

It is the plans of this office to conduct future inspections of selected completed areas or rooms.

During this inspection, it was found that certain of your activities were in violation of NRC requirements.

Consequently, you are required to respond to these violations, in writing, in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.

Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter.

RPS-Ap/2, RPS-g RPS1 ES g RPB2 JGag'htai!GV UREP&EP/

TWesterman

' 'C ro s sman GMadlen DHunnicutt WSeidle do 7/;t4/83

/S./83 7/rp83 6

7/A /83 7/- }/83

,7V/8N s

O*A mq'f/ %' 4/Ch h

f J

Gv~.v s

7 TC

Texas Utilities Generating JUL 2 7 583 Company A specific reply to each example in Item 1 of the attached Notice of Violation is, not requested; however, you are requested to provide this office within 30 days of the date of this letter, the conclusions of your review of these items regarding the adequacy of safety function and the overall actions you

~

are taking to improve your QA/QC program.

Review of the actions you have taken with regard to each specific example will occur during a subsequent inspection.

In accordance with 10 CFR 2.790(a), a cop'y of'this letter and the enclosures will be placed in the NRC Public Document Room unless you notify this office, by telephone, within 10 days of the date of this letter, and submit written application to withhold information contained therein within 30 days of the date of this letter.

Such application must be consistent with the requirements of 2.790(b)(1).

The response directed by this letter and the accompanying Notice is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Should you have 'any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

  • Ortsinal 54"d #

ag g, MAOSEN*

G. L. Madsen, Chief Reactor Project Branch 1

Enclosures:

1.

Appendix A - Notice of Violation 2.

Appendix B - NRC Inspection Report 50-445/83-23 cc w/ enclosures:

l Texas Utilities Generating Company l'

2001 Bryan Tower ATTN:

H. C. Schmidt, Project Manager Dallas, Texas 75201 i

Texas Utilities Generating Company ATTN:

B. R. Clements, Vice President, Nuclear 2001 Bryan Tower, Suite 1735 Dallas, Texas 75201

.e

JIAL 27 23 Texas Utilities Generating

  • Company bec to DMB (IE01) bec dist. rib. by RIV:

RPB1 D. Kelley, SRI-Ops RPB2 R. Taylor, SRI-Cons TPB Section Chief (RPS-A)

J. Collins, RA D. Hunnicutt, ES C. Wisner, PA0 L. Martin M. Rothschild, ELD C. Oberg MIS SYSTEM C. Johnson RIV File K. Whittlesey L. Gilbert J. Tapia W. Crossman J. Bess Enforcement Assistant TEXAS STATE DEPT. OF HEALTH Juanita Ellis David Preister t

~

APPENDIX A NOTICE OF VIOLATION Texas Utilities Generating Company Docket:

50-445/83-23 Comanche Peak Steam Electric Station, Unit 1 Permit:

CPPR-126

~~~

Based on the results of an NRC inspection conducted during the period of May 23 through June 10, 1983, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 47 FR 9987, dated March 9, 1982, the following violations were identified:

1.

Insoection Program 10 CFR 50, Appendix B, Criterion X states that, "a program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity."

The Final Safety Analysis Report, Section 17.1.10 states that, "the organization having the responsibility for provision of such items also has the primary responsibility to assure that adequate inspection is done by the supplier.

Contrary to the above, the following examples were identified in which your inspection program did not detect failures to meet final construction requirements:

a.

Cable Tray Sucoorts Cable tray support material for Cable Tray Hangers 1848 and 1979 deviated from final design documents, b.

Conduit Hilti Bolts Hilti bolt spacing of one bolt at Support 8 for Conduit Run CO2012850 deviated from minimum spacing allowed to adjacent abandoned hilti bolt.

c.

Large Bore ASME Pipe Supports (1)

Five pipe supports deviated from final design documents as follows:

one weld for Support SF-X-002-026-F53R was undersized; dimensions for Supports SF-X-024-010-F43R and SF-X-002-025-F53R deviate from vender certified drawings; and materials for Supports SF-X-005-015-F435 and SF-X-033-006-F43R deviate from vendor certified drawing.

y n e r - r,1/o n Q.N J ' WJ l [ LX

Texas Utilities Generating 2-Company (2) A oroken cotter pin was found on Support SF-X-004-006-43R which j

had been inspected per QI-QP-11.1-28, Revision 20, for integrity.

1 d.

Small Bore ASME Pipe Supports Three pipe supports deviated fr.om final design documents as follows:

dimension for Support H-CH-X-FB-003-001-3 deviated from final review drawing; shimes for Support H-CH-X-FB-003-010-3 were misoriented during the documentation of as built conditions; and the material in Support H-CH-X-FB-004-003-3 deviates from the final review drawing.

This is a Severity Level IV Violation.

(Supplement II.e)

(445/8323-01) 2.

' Instructions 10 CFR 50, Appendix B, Criterion V states that, " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

The Final Safety Analysis Report, Section 17.1.5 states that,

" appropriate requirements have been established in the TUGCO/TUSI Quality Assurance Program to assure thac quality-related activities for CPSES are prescribed by documented instructions, procedures, or drawings:

accomplished in accordance with such documents; and that approved acceptance criteria are met."

Contrary to the above, procedures for the installation and inspection of the "NPSI" seismic sway strut jam nuts do not appear acequate to insure snugness as required by QI-QP-11.1-28, Revision 20, and as evidenced by the finding of five loose jam nuts on the following large bore ASME pipe supports:

l SF-X-011-019-F43K CC-X-040-004-F43K i

i i

e e

_c

Texas Utilities Generating Company SF-X-024-010-F43R SF-X-002-018-F43R SF-X-006-027-F53R This is a Severity Level IV Violation.

(Supplement II.e)

(445/8323-02)

Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Generating Company is hereby required to submit to this office, within 30 days of the date of this Notice, a written statement or explanation in reply to violation 2 above, including:

(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken.to avoid further violations; and (3) the date when full compliance will be achieved.

Consideration may be given to extending your response time for good cause shown.

JUL 271983 Dated:

S 6

APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report:

50-445/83-23 Docket:

50-445 License Permit: CPPR-126 Licensee:

Texas Utilities Generating Company (TUGCO) 2001 Bryar. Tower Dallas, Texas 75201 Facility Name:

Cominche Peak, Unit 1 Inspection At:

Comanche Peak, Unit 1, Glen Rose, Texas Inspection Conducted:

M;y 23-June 10, 1983 Inspectors:

fe

/d )

~7-2 5 23 T. F. Westerman, Chief Date Reactor Project Section A (pars. 7, 12, 13, & 14)

I 7'X f3 C. R. Oberg, Reacaor Inspector Date -

Reactor Project Section B (pars. 3, 4, & 5) 0f&

7A).a"/f !

4. E. Bess, Reactor Inspector Date Engineering Section (pars. 8, 9, 10, & 11) 7/:x 4 /93 L. D. Gilbert, Rea: tor Inspector Dhte Engineering Section (par. 6)

C0aA,L h0 7/2c/ss C. E. Johnson,' Reactor Inspector Date Engineering Section (pars. 2a, 2b, & 2c(1)-(3))

cM e --

mj, hg7(k?Jf { U

2

\\.[_)

NM3 -

7 / 3-5 / F; J. I.' ]ap14, Reactoj (Inspector Date i

Engipy ring Section par. 2c(4))

h Y2 $/8E K. A. Whittlesey, Reactor Inspector JOate/

Engineering Section (par. 6)

Approved:

  • /. [ /M 7/A f3 T. F. Westerman, Chief Date Reactor Project Section A l/M /PI C --

.AI. A. Crossman, Chie_r/

Date Reactor Project SectTon B bh 7/.24/83 D. M. Hunnicutt, Chief Date '

Engineering Section Insoection St. wary Insoection Conducted May 23-June 10, 1983 (Recort 50-445/83-23)

Areas Inscected:

Special inspection of turnover / access control process as relates to conduits / cable trays and supports, piping and supports, electrical separations and cable routing, terminations and electrical equipment seismic mountings; maintenance of installed equipment; punchlist controls; and QA audits.

The inspection involved 366 inspector-hours onsite by seven NRC inspectors.

Results:

Within the 13 areas inspected, two violations were identified.

One violation with several examples related to the inspection process (Details, paragraphs 2, 3.d, 6) and one violation related to adequacy of inspection /

installation procedures (Details, paragraph 2).

3 Details 1.

Persons Contacted Principal Licensee Employees "R. Tolson, Site QA Supervisor "D. Deviney, Ops. QA Supervisor "C. Brandt, Non-ASME QA/QC Supervisor

  • W. Nixon, Reactor Engineer "L. Dunn, Engineer Results
  • J. Merritt, Manager Startup and Manager Engineering & Construction R. Gary, QA Supervisor Document Review M. Young, QC Inspector B. Cromeans. 0A Supervisor Permanent Records

'M. Welch, QA Supervisor for Room Completions D. Davis, Maintenance Services Engineering D. Schoen, Completion Supervisor J. Finneran, Project Pipe Support Engineer R. Whitehouse, Area Manager Fuel and Auxiliary Building D. Davis, Maintenance Services Engineer Brown & Root (B&R)

"R. Balon, Staff Engineer

  • D. Frankum, Project Manager
  • G. Purdy, Site QA Manager In the course of the inspection, crafts, inspectors, engineers, and supervisory personnel were interviewed who are not specifically listed.

"Presentatexitmeetingonjune3,1983 2.

Safety-Related Pioe Supports a.

Review of procedures The NRC inspector reviewed several procedures during the course of the inspection.

These procedures appear to conform to the facility's QA program.

These procedures specify inspection criteria and hold poin:s that must be accomplished by the OC inspectors in order to perform a satisfactory inspection.

Installation criteria for U-bolts have been added to Crocedure QI-QAP-11.1-28, " Fabrication, Installa-tion Inspections of ASME Component Supports 1, 2, and 3."

This was one of the findings addressed by the Construction Appraisal Team (CAT) Team.

Procedures reviewed are listed below:

l QI-QP-11.16-1, Revision 19, Installation Inspections of NNS Seismic Category II Supports for Class V Piping

4 QI-QP-11.1-28, Revision 20, " Fabrication, Installation Inspections of ASME Component Supports, Class 1, 2 and 3" CP-QAP-16.1, Revision 14, " Control of Nonconforming Item" QI-QAP-11.1-28A, Revision 2, " Installation Inspection of ASME Class 1, 2, and 3 Snubbers" b.

Review of Records The NRC inspector reviewed lice'nsee/ contractor records for 50 large bore, 36 small bore, and 8 Class V supports.

The records were reviewed primarily for final as-built configuration and the NRC inspectors review indicated the following:

1 Type and classification of pipe support comply with appropriate drawings Location, tolerances, and critical clearances meet licensee's specifications and have been verified by QA/QC 1

j Welding material used corresponds to the material specified in l

the 1.icensee's procedures and the weld filler material log j

(WFML)

The NRC inspector reviewed the licensee / contractor system for report-ing and dispositioning nonconforming items, component modification j

cards (CMC), parts and components associated with safety-related pipe supports.

Review of these items indicated the following:

The records adequately document current status of nonconformances and deviations The records are legible, complete, and indicate that reports are promptly reviewed by qualified personnel for evaluation and disposition The records are routinely being processed through established channels for resolution of the immediate problem The records are being properly identified, stored, and can be retrieved in a reasonable time for large and small bore.

Class V pipe supports records have not been combined into finalized packages.

This is considered an open item.

(OI 8233-07)

I Nonconformance reports include the status of corrective action or resolution Resolution of nonconformances appears te be reasonably appropriate

--._,.-_r

__,._r.-_

m.

5 j

c.

Observation of Work By direct observation, the NRC inspector visually inspected completed work to determine whether activities relative to large bore, small bore, and Class V pipe supports systems are being accomplished in accordance with NRC requirements, SAR commitments, and licensee procedures.

The NRC inspector examined the support for general configuration, weld appearance and size, hardware, dimensional check, clearances, tolerances, and support spacing between small bore.

(1)

Laroe Bore ASME Pipe Suoports The NRC inspector visually inspected 50 large bore pipe supports in accordance with the completed as-built vendor certified drawing (VCD) and current CMC's.

Six supports out of 50 contained discrepancies; which are considered to relate to adequate QC inspectidt.

Five supports were identified to have loose jam nuts on the seismic sway struts.

These discrepancies are considered to be generic in nature and appear to relate to NpSI supports utilizing single jam nuts.

Supports that contained discrepancies are noted below under a specific category.

Satisfactory supports are not listed.

The support identification is same as the drawing.

1 Undersized Weld 4

Drawing SF-X-002-026-F53R, R2 (VCD) indicated a 1/2" fillet weld.

Field conditions measured 7/16" for one fillet weld.

Dimensions Not As per VCD Drawing SF-X 024-010-F43R, R2 indicated for Tube Steel (TS) 4" x 4"~x 3/8", a dimension of 2' 3" from the center line.

The As-Built condition was 2' 5".

Drawing SF-X-002-025-F53R, R6 indicates a dimension between two wall plates of 2' 4-3/8".

The As-built condition was 3' 2-1/2" Materials Not As Per VCD Drawing SF-X-005-015-F435, R3 Indicated Item 3 as 4" x 6" x 1/2" TS.

As-built conditions for Item 3 was 4" x 6" 1/4" TS.

Drawing SF-X-033-006-F43R, R2 (Bill of Materials) lists Item 8 to be 9" long.

The NRC inspector found that Item 8 (a bolt) was longer that 9".

D

6 Broken Cotter Pin QI-QP-11.1-28, Revision 20, requires inspection of cotter pins and snap rings to insure int'egrity, a cotter pin was found broken on Drawing SF-X-004-006-F43R, R3.

The above' discrepancies are considered to be in violation of 10 CFR 50, Appendix B, Criterion A, and the FSAR, Section 17.1.10.

Loose Jam Nuts

~

Procedure QI-QP-11.1-28, Revision 20, requires that nuts be snug tight.

Loose Jame nuts were found on the following:

Drawing SF-X-001-019-F43K, R3 Drawing CC-X-040-004-F43K, R5 Drawing SF-X-024-010-FA3R, R2 Drawing SF-X-002-018-F43R, R6' Drawing SF-X-006-027-F53R, R3 This discrepancy is considered to be in violation of 10 CFR 50, Appendix B, Criterion V and the FSAR, Section 17.1.5.

(2)

Small Bore ASME Pioe Suoports i

The NRC inspector visually inspected 35 small bore pipe supports in accordance to current as-built VCD's and CMC's.

Three

~

supports were observed to have discrepancies.

They are listed below by category.

Dimensions Not AS Per Final Review Drawine (FRD)

Drawing H-CH-X-FB-003-001-3, R0 indicated Item I was to be l' 6.5" between the 11/16" diameter holes.

As-built conditions was l' 6".

Shim Not as Per FRD The shims shown on Drawing H-CH-X-FB-003-010-3, R1 were misoriented during QC documentation of as-built conditions.

Bill of Materials Not as Per FRD Drawing H-CH-X-FB-004-003-3, R1 indicated Item 4 to be 1" thick clate.

As-built conditions has Item a was found to be 7/8" thick.

The 1" wall plate for Support H-CH-X-FB-004-003-3 was determined to be from 7/8" stock material by heat number.

This was originally thought to be 1" material not meeting j

ASTM mill tolerances.

The licensee is now tracing down this 7/8" material to determine if any more of this 7/8" material was used as 1" material.

Subsequent pnene call.

s 7

from licensee indicates this to be an isc. lated occurrence.

There will be a follow up inspection on the tracability of this material use as I" material by the NRC inspector.

This is an open item.

(OI 8223-08)

The above discrepancies are considered to be in violation of 10 CFR 50, Appendix B, Criterion X and the FSAR, Section 17.1.10.

(3) Class V Pipe Supports The NRC inspector also ins'pected eight Class V supports.

Traveller packages did not contain all current drawings, inspec-tion reports, and CMC's.

The licensee informed the NRC inspector that not all final documents have been combined by document control.

This is an open ite=.

(OI 8223-07)

The licensee was able to retrieve the current design and inspection documents for the NRC inspector and the eight Class V supports inspected reflected, as-built configuration, current VCD's, and current CMC's.

(4)

Pipe Succort Stability NRC Region IV staff reviewed the pipe supports in paragraphs 2.C(1),

(2), and (3) for stability.

No cases of instability were identified.

In summary of paragraphs 2.C(1), (2), and (3), the NRC inspector gave the licensee a list of pipe supports discrepancies noted.

The discrepancies noted by the NRC inspector mostly consisted of dimen-sional tolerances, loose jam nuts, material not specified by the bill of materials, and one undersized weld.

The discrepancies noted are of no major safety significance but do reflect on QA/QC effectiveness.

Procedures used by QC require inspection of items above.

3.

Inspection of Conduit Raceways a.

General This portion of this inspection examined 14 Class IE conduit raceways in the fuel handling building.

This included. 22 junction boxes, 111 4

supports, and 2 terminal boxes.

In general, the conduit raceway installations was found to be in accordance with the applicable i

design criteria established in the FSAR, Gibbs & Hill Specifica-tion 2323-MS-100, " Conduit Raceways" and applicable implementing blueprints.

While no major discrepancies were identified, some items had minor problems.

These are catagorized and detailed in the paragraphs below.

e

S-8 b.

Conduit Raceways Inspected The following conduit raceways were inspected.

Conduit Raceway Supports No. JB C03012851 11 2

C03G17933 3

1 C13G12992 4

1 C13G12568

. 13 2

C13G12569 5

2 CO2012850 14 2

C03G11515 5

2 C03G11747 14 2

C03G11746 3

2 C13G14996 4

1 C03014070 3

1 C13G11514 4

2 CO2G09618 6

1 C23G04971 22 1

111 22 c.

Accarent Missino Conduit Suotort After review of the applicable record package and making a visual inspection of conduit C13G 12992, the NRC inspector concluded that one of the four supports was mis' sing.

The licensee representative was made aware of the finding and subsequently identified an IRN (inspected item removal notice) documenting the removal of the "-2" l

support.

The IRN, 151546, had been incorrectly keypunched and did not appear on the list for IRN's awaiting corrective QC inspection.

The IRN was subsequently entered into the records for close out.

The

~

remaining supports did meet the minimum spacing requirements (6'7" between supports).

d.

Installation of Hilti Bolts t

l One-half inch bolt on Support 8, of conduit run CO2012850 was found installed less than 1" (approximately 3/4") from a cut off embedded anchor bolt.

The minimum distance of '1" is specified in Table 1 of QI-QP-11.2-3, " Torquing and Spacing of Concrete Anchor Bolts." This was the only example identified during the inspection of 111 supports l

and is considered to be an isolated example.

No other problems is l

installation of Hilti bolts were identified.

This is considered to be a viclatica of 10 CFR 50, Appendix B, Criterion X and the FSAR, Section 17.1.10.

l l

J

9 e.

Junction Box Suocorts An inconsistancy in installation of junction boxes was noted.

The general notes of Drawing 2323-5-0910, Note III.3, gives the option of installing shims to prevent excessive bending of junction box mounting lugs.

While no excessive bending was noted, there were several instances of bending of support lugs on the unistrut channel supports.

Specific examples were noted on JB1F01G, JB1F02G, and JB1F03G.

These three large junction boxes were installed on the same unistrut support.

Other junction boxes did have a,dequate support by the use of shims or more exact fitting of the unistrut supports to the junction box lugs.

This was not a specific QC inspection requirement.

This item was brought to the licensee's attention, the NRC Region IV plans no further action.

I f.

Conduit Couclinos ES-100, " Conduit Specification," paragraph 4.4.6 requires couplings to be installed such that flat surfaces (walls) shall not prevent the proper installation or removal of the coupling.

Instances were found (Conduits C02012850 and C23G04971) where conduit couplings were in tight contact with the wall.

Release of the adjacent supports would

^

permit turning of the coupling. While this item is not of safety significance, it does not meet the intent of the specification.

It was not a specific QC inspection item.

This item was brought to the licensee's attention, the NRC Region IV plans no further action.

g.

Conduit Identification l

One instance of inconsistant conduit numoering was ide.ntified.

Conduit C13G-11514 goes between a wall in the Fuel Handling Building

(

(Room 249B) into JB1F-111G.

Continuation of.the conduit goes to l

JB1F03G with the same conduit number.

This is not consistant with l

the boundries of a conduit run being a junction box or panel termina-l tion.

JB1F111G was characterized as an " unscheduled pull box."

The NRC inspector noted many examples of junction boxes being used as pull boxes, some installed next to conduit elbows.

Specification ES-100 permits the field installation of pull boxes which should be identified as "PB."

The short conduit run identified above appears to be an isolated occurrence and dees not have any safety significance.

This was brought to the licensee's attention, the NRC Region IV plans no further action.

h.

General Workmanship The overall installation of the conduits met the expected standards of craft workmanship.

There were some minor items noted during the inspection which if eliminated would improve the quality of the installation.

Washers were missing under screws on 1/4" conduit elbow

10 One screw was missing on a junction box cover Two types of screws were used on an LBD One screw was not tight on a junction box creating a gap in the gasket seal A junction box cover securing chain was missing One terminal box contained'two open bags of terminal nuts Some dust and dirt was found in junction boxes This item was brought to the licensee's attention, the NRC Region IV plans no further action.

1.

Conclusions With the exception of the items noted above, the conduits inspected met the requirements as specified in the applicable design and installation documents.

The Hilti bolt spacing is considered to be a violation of 10 CFR 50, Appendix B, Criterion X, and the FSAR, Section 17.1.10.

4 Insoection of Cable Trays Thirteen cable trays in the Fuel Handling Building were inspected.

No instances of improper installation was noted.

QC inspection records were examined for the following cable trays:

T140FDA-83 through 90 T130FCZ-22, -24 through C-27 and -30 Inspection of cable tray supports and the attachment of the cable trays to the supports are documented in paragraph 6 of this report.

5.

Conduit Raceway and Cable Tray Records The records for the conduits and cable trays were examined in conjunction with a physical inspection.

TUGC0 Procedure CP-0-21.0 (Revision 1, May 12, 1983) " Inspection Verification for Room Turnover," paragraph 3.3 requires that a records review be performed upon receipt of the room inventory package.

This was done by record vault personnel who reviewed a record log check sheet for the conduits and cable trays identified in the inventory package.

However, a random check of cable tray records revealed minor discrepancies in entering the data into the handwritten check This was discussed with supervisor personnel.

sheets.

l l

l l

l l

i o

11 CP-QP-15.2 (Revision 3, April 16, 1981), "Startup/ Turnover QA Activities,"

paragraph 3.2, requires that details of record verification, as outlined I

in QP-15.2, to be perscribed in documented quality instruction.

In opposition to this, the record vault personnel appeared to be using an untitled, unapproved check list for reviewing the completeness of conduit i

and raceway files.

Precise definition of what was to be expected in the files had not been determined.

The extent of this problem was not determined, therefore, this item is considered unresolved.

(8323-03) 6.

Cable Tray Sueoorts The NRC inspector performed an as-built inspection of 13 Class IE cable tray supports to determine conformance of the as-built configuration to the approved final design:

4 CTH 1694 CTH 1948 CTH 1696 CTH 1951 CTH 1701 CTH 1979 CTH 1704 CTH 3966 CTH 1712 CTH 3988 CTH 1845 CTH 6670 CTH 1848 Gibbs & Hill (G&H) Drawing 2323-El-800-5, Revision 2, and corresponding FSE Map 200 were used to locate and identify the supports.

Design details for individual hangers are dictated by G&H Drawing 2323-El-800-5 unless superseded by a component modification card (CMC).

Support location, welding, configuration, and materials were considered within the scope of the inspection.

Within the areas inspected, support location 1as as specified by drawing l

and the welds were consistent with drawing requirements for weld type, size, and location.

However, deviations from final design were identified for CTH 1848 and CTH 1979.

The final design of CTH 1848 is dictated by CMC 8230, Revision 3, and final QC inspection indicated the installed condition conformed to the requirements of the CMC.

The actual installed condition deviated from the controlling CMC in that the installed steel angle wall connection was l

L5" x 5" x 3/4" rather than the L6" x 6" x 3/4" specified by the controll-ing CMC.

Note that the original hanger design allowed the use of either L5" x 5" x 3/4" or L6" x 6" x 3/4" at the wall connection.

CMC 8230, Revision 3, reflects a modified configuration resulting from rebar congestion and physical interference.

Inspection of CTH 1979 also indicated an installed condition deviation from design.

The horizontal support member installed is 6" channel with a 6" channel stiffener rather than the 4" channel witnout stiffener called for by detail "L" on G&H Drawing 23.23-El-800-5, Revision 2.

No documenta-

,_..._m.

12 tion of this nonconforming condition could be located although the support had been final QC inspected.

The deviation of CTH 1848 and 1979 from design documents is considered to be in violation of 10 CFR 50, Appendix B, Criterion X and the FSAR, Section'17.1.10.

s During the course of the inspection, the NRC inspector identified one concrete anchor bolt (Hilti) associated with CTH 3988 which appeared to be more than the allowed 6 off normalc This is considered an isolated case and has been referred to the licensee.

The NRC inspector also observed examples of poor bolting practice in the connection of cable tray to CTH 3988.

A cursory inspection of bolted connections between cable tray and supports revealed several similar situations and the conditions were referred to the licensee.

Bolted connections between individual cable tray sections were found to be complete and secure with no exposed bolt ends on the interior of trays.

The Hilti anchor bolt issue and the example of poor bolting practice discussed above are considered to be unresolved items.

(UI 8323-04) 7.

Maintenance of Installed Comoonents The NRC inspector reviewed the licensee's program to assure preventative maintenance is performed on major components install in the spent fuel pool and clean up system until full custody is assumed by TUGCO.

The NRC inspector found that in accordance with Startup Administrative Procedure CP-SAP-3 Custody Transfer of Station Components, Revision 11, test releases are forwarded to the TUGC0 maintenance superintendent.

The TUGC0 maintenance superintendent establishes a preventative maintenance program in accord-ance with Procedure MDA-301, Revision 2.

Tracking of the performance of preventative maintenance 'and schedule is computerized.

The established preventative maintenance program continues for the life of the component.

The NRC inspector verified from review of records that a preventative l

maintenance program had been established for the spent fuel pools cooling

]

pumps and includes:

Lubrication - Yearly Drain and Flush Lubricating Oil - 6 months Meggering and High Pot Test - Yearly Rotate Motor - Monthly Verify Motor Heaters Energized - Monthly The NRC inspector verified monthly motor rotation and heater energization for Pump 2.

No violations or deviations were identified.

O

13 8.

Verification of Electrical Terminations During this inspection, the NRC inspectors verified the terminations of Class 1E control cables at the spent fuel control panel (CPX-E1PRLV-06).

The NRC inspectors verified that the use of specified material and installa-tion procedures reflect the "as-built" condition of the panel and conformed to NRC requirements.

The cables inspected are as follows:

Terminal Board TB-1 Termination Point Ca'ble No Wire Color 1

EG105989 Bk (Black)

EG106084 Sk (Black) 2 EG105989 Wh (White)

EG205989 Wh (White) 3 EG205989 Bk (Black)

EG014539 Bk (Black) 4 EG014539 81 (Blue) 5 EG014539 Or (Orange) 6 EG014539 Gr (Green) 7 EG014539 Rd (Red)

EG106084 Rd (Red)

B EG014539 Wh (White) 9 EG015766 Rd (Red) 10 EG015766 Wh (White) 11 EG015766 Bk (Black)

Terminal Board TB-2 Terminal Point Cable No.

Wire Color i

1 EG106084 Wh (White) l EG014539 Wh/B1 (White / Black) l l

l

14 Terminal Board TB-3 1

E0105988 Bk (Black)

E0106083 Bk (Black)

2 E0205988N Wh (White)

E0105988 Wh (White) 3 E0014536 Bk (Black)

E0.105988N Bk (Black) 4 E0014536 B1 (Blue) 5 E0014536 Or (Orange) 6 E0014536 Gr (Green) 7 E0106083 Rd (Red)

E0014536 Rd (Red) 8 E0014536 Wh (White)-

9 E0015791 Rd (Red) 10 E0015791 Wh (White) 11 E0015791 Bk (Black)

Terminal Board TB-4 Terminal Point Cable No.

Wire Color 1

E0014536 Wh (White)

E0106083 Wh/B1 (White / Black)

The NRC inspectors verified the terminations of Class IE power cables at the motors for the two spent fuel pumps (CPX-SFAPSF-01 and CPX-SFAPSF-02).

The NRC inspectors verified that the use of specified material and installa-tion procedures reflected the "as-built" conditions of the pumps and conformed to NRC requirements.

The cables inspected are as follows:

4 CPX-SFApSF-01 Train A (0rance)

T-1 E0000450 (A)

T-2 E0000450 (B) 4'.

T-3 E0000450 (C) e

15 CpX-SFADSF-02 Train B (Green)

T-1 EG000590 (A)

T-2 EG000590 (B)

T-3 EG000590 (C)

The NRC inspectors verified that the above terminations for the referenced panel and motors agreed with the issued cable pull card, meggering cards, continuity cards and cable sign-off cards.

Thy scope of this verification included:

cable identification, number of cabia conductors, cable descrip-tion, conductor colors, lugs, heat shrink tubing, and termination points.

No violations or deviations were identified.

9.

Cable Tray Installation

.During this inspect 9on, the NRC inspectors verified the completed installa-tion of cable trays carrying Class IE cables.

A total of 13 node points were inspected.

The NRC inspectors verified that the use of installation procedures and issued drawings reflected the "as-built" condition and conformed to NRC requirements.

The cable tray node points inspected are as follows:

T120FBU01 TB0FCZ22 T120FBUO3 T130FCZ25 T120FBUO4 T130FCZ30 T12FBUO6 T130FCZ31 T120FBUO9 T130FCZ32 T120FBU10 T130FCZ34 T120FBU11 The NRC inspectors verified that the above cable tray node points agreed with the issued cable tray routing cards.

The scope this verification i

included:

cable tray routing, node point sequencing, node point identifica-tion, and legibility.

No violations or deviations were identified.

10.

Cable and Cable Tray Separation The NRC inspectors inspected cable tray installation to ascertain whether tray separation met applicable separation criteria.

The NRC inspectors observed that all Train A (orange) safety-related cables were installed in cable trays.

The safety-related cables pertaining to Train B (green) systems were installed in conduit.

This method of installation appeared to have met applicable separation criteria, The NRC inspectors verified that the separation of the two instruments i

l listed below had met applicable separation criteria:

I

,.. -. ~,

~.

16 X-HS-4829 Train A (orange)

X-HS-4832 Train B (green)

The instruments exceeded the minimum distance (6") required between Train A and Train 8 terminations.

The NRC inspectors verified that power cable spacing within trays met applicable separation criteria.

The cables inspected are as follows:

E0000450 (A)

E0000450 (B)

E0000450 (B)

The spacing between the power cables within trays exceeded the minimum requirements of distance between cables (1/4" the diameter of the largest cable).

No violations or deviations were identified.

11.

Verification of Seismic Installation and Documentation

~

The NRC inspector inspected the spent fuel pool panel (CPX-E1PRLV-06) to ascertain whether the installation reflected "as-built" conditi,on.

The NRC inspector also examined documentation to determine whether established procedures had been followed during the construction and installation of panel.

The documentation review is as follows:

Gibbs/ Hill - Quality Assurance Release QAR-2651 dated December 4, 1979 Material Receiving Records - MRR 6634 dated December 10, 1979 Quality Assurance Receiving Inspection Report 12878 dated January 3, 1980 Inspection Reports E60896 (

Reference:

NCR-E-83-011685) " Post Construction Verifica-tion" - Q1-QP-11.3-40, Revision 4 E57869 (

Reference:

NCR-E-83-011685)

Traveler R180-382-4700 " Transport and Installation of Spent Fuel Pool Panel" Traveler CE-80-061-0200 " Mounting Spent Fuel Pool Panel" Traveler E-80-137-2303 "Rewo.k Mounting of Spent Fuel Pool Panel" Grout Placement Cards 051 dated August 27, 1980; 025 dated November 1,-

1979

17 NCR M-83-01178,' Revision 1, dated April 25, 1983 DCA 5526, Revision 6 No violations or deviations were identified.

12.

Review of Large Bore Pipe Configuration A sample of large bore piping runs associated with the spent fuel pool cooling and cleanup system were selected for review.

These runs include the following:

BRHL-SF-X-FB-022, Revision 1 BRP-SF-X-FB-017B, Revision 6 BRHL-SF-X-FB-017A, Revision 2 BRHL-SF-X-FB-0178, Revi sion 2 BRP-SF-X-FB-0?7A, Revi sion 8 The above runs were inspected in the field for proper configuration, identification of valves, surface condition, valve orientation, bolted flange connections, interferences, and support / restraint location ~, and function.

No violations or deviations were identified.

13.

Punchlist The NRC inspector reviewed the licensee's program for punchlisting incomplete items.

The NRC inspector reviewed the following three punch-lists:

the construction punchlist, the completions punchlist, and the master punchlist.

The construction punchlist consists of outstanding construction items normally generated on a room or outside area basis.

Work in these areas is performed in accordance with normal construction procedures with QA/QC coverage as requried for safety-related work by the QA/QC program.

The completions punchlist in accordance with CP-SAP-3, " Custody Transfer of Station Components," Revision 11, requires the assigned startup test engineer at approximately 6 to 8 weeks prior to a target turnover date (or when assigned) to conduit periodic walkdowns and compile punchlists of uncompleted work, missing components and or damaged equipment.

A test release (TR) is subsequently issued at time of system is turned over to TUGCO.

The completions punchlist of incomplete items is attached.

This punt ist is system oriented.

Work on a system after TR requires a stariup work authorization (SWA).

The tracking of component / system problems after turnover to startup testing is termed the " Master System Punchlist" by Startup Administrative Procedure CP-SAP-18 " Control of System / Component Problems."

e g

18 In order to facilitate closecut construction on a room or area basis, controls have been established in CPM-15.2 " Work Activiites on Rooms Which Have Been Turned Over," Revision 2, te limit access to rooms or areas considered turned over to TUGC0 startup.

Work in these rooms or areas maybe performed only on room work notifications (RWN) which require QC review and inspection, and a control access log of allowed activities is established.

Work in the room maybe also accomplished with a SWA.

The construction punchlist and completions punchlist was used to establish the control access list for the Fuel Building.

Room inventory of all non-ASME code items occurs at this time in ac.cordance with QP-21.0, Revision 1, to verify that necessary inspection documents are satisfactory for all installed items.

Based on the inspector's review of the punchlist system, the NRC inspector found that basic controls do exist; however, there are problems areas identified for which further actions appear necessary as follows:

There is no procedural control of the construction punchlist.

There is no procedural control for punchlist input.

There is no procedural control for removal of punch 1fst' items.

There is no historical record of items on the punchlist.

It is not clear when the construction punchlist and master system punchlist is to be combined.

There is no QA/QC review of the punchlist from the standpoint of the need for corrective action.

sap-18 is incumbent on the startup and operations organizations, but not the construction organization.

QI-QP-15.2-1, Revision 4, has been outdated with regard to record verification as record deficiencies are now input to the construction punchlist vice to the completion punchlist.

Pending followup on the above items, this matter is considered unresolved.

(UI 8323-05) 14 QA Audits The NRC inspector found that a general inspection by audit personnel had occurred in the Fuel Building, but it was not documented as a formal audit.

The NRC inspector indicated that the subject of audit of the room / area turnover process was considered as an unresolved item pending subsequent planned inspections of the room / turnover process by NRC Region IV.

The licensee has indicated that planned audits will be conducted in the future.

(UI-8223-06)

19 15.

Unresolved Items Unresolved items are matters about which more information is required in

~

order to ascertain whether the items are acceptable, violations, or deviations.

The following unresolved items are discussed in this report.

Paragraph Item No.

Subject 5

8223-03 Conduit Raceway and Cable Tray Records G

8223-04 Cable Tray Support Bolting 13 8223-05 Punchlist u

16.

Exit Interview An exit interview was concucted on June 3, 1983, with those person denoted in paragraph 1 of this report.

At the interview, the NRC inspectors discussed the findings indicated in the previous paragraphs.

The licensee acknowledged these findings.

The resident inspector also attended the exit interview.

In addition, and exit meeting was held in TUGCO's corporate offices on June 10, 1983, with the following personnel present.

TUGC0 R. Gary, Executive Vice President and Gene.41 Manager B. Clements, Vice President Nuclear D. Chapman, Quality Assurance Manager TUSI C. Fikar, Executive Vice President and General J. George, Vice President and Project General Manager NRC P. Check, Deputy Regional Administrator J. Gagliardo, Director, Division of Resident, Reactor Project &

Engineering Programs G. Madsen, Chief, Reactor Project Branch 1 T. Westerman, Chief, Reactor Project Section A l

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4 44-wn August 24, 1983

'9 Page 2 APPENDIX A NOTICE OF VIOLATION Texas Utilities Generating Company Docket-No. 50-445/83-23 Comanche Peak Steam Electric Station, Unit 1 License No. CPPR-126 Based on the results of an NRC inspection conducted during 'the period of May 23 through June 10, 1983 and in accordance with the NRC Enforcement Policy (10CFR2, Appendix C) published in the Federal Register Notice (47CFR9987) dated March 9, 1982, the following violations were identified.

1.

'As stated in the cover letter, a response to this item will be provided no later than September 1,1983.

2.

Instructions 10CFR50, Appendix B, Criterion V states that, " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, ;:rocedures, or drawings." The Final Safety Analysis Report, Section 17.1.5 states that, " appropriate requirements have been established in the TUGCO/

TUSI Quality Assurance Program to assure that quality-related activities for CPSES are accomplished in accordance with such documents; and that approved acceptance criteria are met."

Contrary to the above, procedures for the installation and inspection of the "NPSI" seismic sway strut jam nuts do not appear adequate to insure snugness as required by QI-QP-11.1-28, Revision 20 and as evidenced by the finding of five loose jam nuts on the following large bore ASME pipe supports:

SF-X-011-019-F43K CC-X-040-004-F43K SF-X-024-010-F43R SF-X-002-018-F43R SF-X-006-027-F53R This is a Severity Level IV Violation.

(SupplementII.e)(445/8323-02).

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The five loose jam nuts on the large bore ASME pipe supports identified were reworked and verified by QC to be " snug tight" per QI-QAP-11.1-28, paragraph 6.3.1.1.(c).

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN TO AVOID FURTHER NONCOMPLIANCE Inspection checklists as implemented by procedure CP-QAP-12.1 have been revised to add specific inspection criteria relative to " snug tight" conditions of sway-strut jam nuts.

These checklists are utilized by QC to verify the correctness and integrity of installation of systems prior to N-5 Certification.

THE DATE WHEN FULL COMPLIANCE WILL BE ACHIVED The checklists were revised immediately after identification of the nonconforming condition.

Procedure CP-QAP-12.1 was formally approved August 3, 1983.

TEXAS L'TILITIES GENERATING COMP.OT 2001 MHTAN 70% ER D4LJ.W.TE.%Aps 7W0).30343 Q.J. GARY

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AE 3 I1983 i

Mr. G. L. Mad:en, Chief

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Reactor Project Branch 1

'U. S. Nuclear Regulatory Comission u

Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Docket No.: 50-445 Arlington, TX 76012 50-446 COMANCHE PEAK STEAM ELECTRIC STATION RESPONSE T0 PRC NOTICE OF VIOLATION INSPECTION REPORT NO. 83-23, FINDING NO.1 FILE NO. :

10130

Dear Mr. Madsen:

We have reviewed your letter dated July 27, 1983 on the Special Fuel Building inspection of activities authorized by NRC Construction Pennit CPPR-126 for Comanche Peak, Unit 1.

Our report logged TXX-4031 dated August 24, 1983 provided the response to Finding No. 2 contained in Appendix A of that letter.

In addition, an extension until September 1,1983 was granted for responding to Finding No. 1.

To aid in the understanding of our response, we have repeated the requirement and Findin' No.1 followed by the conclusions of our review of these items regarding the adequacy of the safety function and the overall actions taken to improve our QA/QC program.

We feel the enclosed information to be responsive to the Inspector's finding.

If you have any questions, please advise.

Very truly yours,

$$bw RJG:In

.4 Enclosures cc:

PRC Region IV - (0 + 1 copy)

Director, Inspection & Enforcement (15 copies)

U. S. Nuclear Regulatory Commission Washington, DC 20555 9 y s e i e r n d ci u/s v-swiw v

TXX-4037 APPENDIX A_

NOTICE E VIOLATION Texas Utilities Generating Company Docket:

50-445/83-23 Comanche Peak Steam Electric Station, Unit 1 Pemit:

CPPR-126 Based on the results of an NRC inspection conducted during the period of May 23 through June 10, 1983, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 47 FR 9987, dated March 9,1982, the following violations were identified:

o t'-

1.

Inspection Program 10 CFR 50, Appendix B, Criterion X states that, "a program for inspection of activities affecting quality shall be established and executed by or for the organization perfomjng the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity." The Final Safety Analysis Report, Section 17.1.10 states that, "the organization having the responsibility for provision of such items also has the primary responsibility to assure that adequate inspection is done by the supplier."

Contrary to the above, the following examples were identified 'in which your inspection program did not detect failures to meet final construction requirements:

a.

Cable Tray Supports TroTe tray support material for Cable Tray Hangers 1848 and 1979 o

deviated from final design documents.

b.

Conduit Hilti Bolts Hilti bolt spacing of one bolt at Support 8 for Conduit Run CO2012850 deviated from minimum spacing allowed to adjacent abandoned hilti bolt.

c.

Large Bore ASME Pipe Supports (1)

Five pipe supports deviated from final design documents as follows:

one weld for Support SF-X-002-026-F53R was undersized; dimensions for Supports SF-X-024-010-F43R and SF-X-002-025-F53R deviate from vendor certified drawings; and materials for Supports SF-X-005-015-F435 and SF-X-033-006-F43R deviated from vendor certified drawings.

(2)

A broken cotter pin was found on Support SF-X-004-006-43R which had been inspected per QI-QP-11.1-28, Revision 20 for integrity.

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TXX-4037 Page 2 d.

Small Bore ASME Pipe Supports Three pipe supports deviated from final design documents as follows:

dimension for Suport H-CH-X-FB-003-001-3 deviated from final review drawing;' shims for Support H-CH-X-FB-003-010-3 were misoriented during the documentation of as built conditions; and the material in Support H-CH-X-FB-004-003-3 deviates from the final review drawing.

This is. a Severity Level IV Violation.

(Supplement II.e) (445/8323.01)

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Our engineering evaluation has concluded that had the aforementioned deviations gone undetected there would be no affect on plant safety.

Impro'vements of 0A/0C Program Consistent with our engineerinag evaluation of these items, we have also concluded that no significant QA/QC. program improvements are required.

Although the basfc QA/QC program will remain the same, we have made minor adjustments to inspection procedures and checklists.

These adjustments merely provide more detail to existing program requirements.

Documentation regarding our Conclusions and Improvements will b'e available for your Inspectors review at the CPSES site.

2.

As stated in the cover letter, a response to this item was provided in TXX-4031, dated August 24, 1983.

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