ML20236Q350
| ML20236Q350 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/10/1987 |
| From: | Terao D NRC OFFICE OF SPECIAL PROJECTS |
| To: | NRC OFFICE OF SPECIAL PROJECTS |
| References | |
| NUDOCS 8711190333 | |
| Download: ML20236Q350 (8) | |
Text
1 p
.[ ;[bg UNITED STATES
\\
8 NUCLEAR REGULATORY COMMISSION
' ' y, I
wAsHIN3 TEN, D. C. 20006 j
o November 10, 1987 j
j.
Docket Nos. 50-445 and 50-446 APPLICANT:
Texas Utilities Electric Company (TU Electric)
FACILITY:
Comanche' Peak. Steam Electric Station (CPSES), Units 1 and 2 1
SUBJECT:
SUMMARY
OF AUDIT ON SEPTEMBER 8-11, 1987 - HVAC-AS-BUILT--
VERIFICATION PROGRAM j
l-On September 8-11, 1987, the NRC staff and its consultants continued its audit of the as-built field verification program for seismic Category I heating, ventilation and air conditioning (HVAC) duct segments, air handling units, plenums, and related equipment supports in the' Comanche Peak Steam Electric Station Unit I and common ~ areas. The HVAC.as-built verification i
program is being conducted by Ebasco Services, Incorporated (Ebasco) as 1
part of the TV Electric Corrective Action Program for design validation.
The purposes of the audit were (1) to verify comprehensiveness and com-plateness of the walkdown procedures in their ability to record the HVAC structure as-built condition for design verification, (2) to verify the adequacy of the Ebasco walkdowns and transfer of data into preliminary l
as-built drawings for complian'ce with the written procedure, and (3). to conduct a followup audit of the TU Electric QC as-built inspection program
~
defined in QI-QP-11.14-14 as it relates to the field verification of HVAC ducts. As specified in Ebasco procedure CP-EB-FVM-CS-029 (referred to later as "CS-029"), many of the HVAC duct attributes,' including qualitative attributes.
-l are inspected and verified by the TU Electric QC group.
The scope'of the audit included (1) a. review of the'Ebasco procedure CPE-EB-FVM -
l CS-066 (referred to late'r 'as "CS-066") for' performing the field verification.
l handling units, plenums, and HVAC equipment supports, and (packages f (2) a review of a sample of the Ebasco walkdown (as-built)
- 3) a walkdown of several HVAC items such as an air handling unit, a plenum, a heater support, and a fan support. As part of the followup audit of the HVAC duct as-built program, this audit also included a review of a sample of the TU Electric QC inspection (as-built) reports for duct segments and a walkdown of 2 duct segments for QC attributes. A list of persons involved with the audit.is provided in to this sumary.
As-Built Verification Procedure The audit team reviewed the Ebasco field (as-built) verification procedure CPE-FVM-CS-066, Revision 0.
In addition, the team interviewed the Ebasco:
walkdown group supervisor on the details of the CS-066 procedure and the TU Electric QC.walkdown supervisor on the QC responsibilities pertaining to both the CS-029 and CS-066 procedures. The Ebasco walkdown of the air handling units, plenums, and equipment supports is in the early stages of implementation with only those HVAC components in the diesel generator building. approaching 8711190333 871110' PDR ADOCK 05000445 p
O a
o Summary of Audit on 9/8-11/87 completion. The audit team found the procedures for the HVAC as-built verifi-cation effort' to be sufficiently comprehensive and complete to identify the major deficiencies and attributes that could affect the design qualification of the HVAC equipment.
In addition, the team found the procedures were adequate to provide the necessary data to develop the as-built drawings and perform a detailed structural analysis of the HVAC duct supports. The procedures incor-porate the appropriate steps to ensure accurate recording of the attributes.
As reported in the audit summary of the August 12-14, 1987 audit on the HVAC hangers and duct segments, the audit team planned to conduct a followup audit to address the TU Electric QC responsibilities with respect to the walkdown pro-cedures.
Consequently, this site audit included a review of the implementation of the TV Electric QC inspection procedures.
Both the CS-029 and C5-066 pro-
)
cedures specify that TU Electric QC will perform their inspections and veri-fications of attributes in accordance with the QC procedure QI-QP-11.14.14.
l This procedure provides for the QC verification of all the walkdown attributes documented in the Ebasco walkdown efforts.
In addition, TU Electric QC performs an inspection of the qualitative attributes such as weld quality, structural member damage, sheet metal damage, flange gasket and bolting. The audit team determined that this aspect of the HVAC verification procedure is being performed and the QC inspection procedures appear to be reasonably complete and comprehensive.
Review of Walkdown Verification Documentation The audit team reviewed the documentation for several HVAC packages for air handling units, plenums, and equipment supports to determine whether the field verification (as-builting) procedures controlling the flow of design data were being correctly implemented (see Enclosure 2).
The packages reviewed contained the required documentation including the red-line drawings, the required modi-fication forms, signed off checklists, and inputs from field engineering.
The audit team found that the process and flow of design data was being implemented properly in accordance with the procedural requirements of CS-066.
The TV Electric QC inspection reports for several HVAC duct segments were reviewed by the audit team for completeness of implementation as required by CS-029.
The packages reviewed indicate that the QC as-built inspection of the duct segments was thorough and well documented.
Deficiencies noted by the audit team in its walkdown of the selected HVAC duct segments were also found to have been appropriately identified by QC and recorded in the QC inspection reports.
The audit team will review the data transfer process and use of QC inspection report I
data by the Ebasco design verification group in a subsequent audit of the latter effort.
Walkdown of HVAC Hancers and Duct Segments The audit team randomly selected a sample of HVAC air handling units, plenums, and equipment supports for a walkdown audit. The purpose of this walkdown was to provide an assessment on the completeness and accuracy of the Ebasco field verification activities.
The team walkdown covered an inlet plenum, a heater support, a fan support, and an air handling unit.
This walkdown audit identified an open item as discussed below.
l l
l
's Summary of Audit on 9/8-11/87 While conducting the walkdown of the Diesel Generator Building Intake Plenum "A,"
the audit team observed that the air filter assemblies attached to the plenum were missing two support bolts. These missing bolts were located in the supports between the stacked air filter assemblies. The audit team found that the air filter assembly - considered HVAC equipment - is qualified under the equipment qualification scope of the Corrective Action Program (being conducted by Impell) and is not part of the Ebasco HVAC as-builting program. The concern, however, is the potential impact of the missing support bolts on the design verification of the intake plenum. Considering the configuration of the intake plenum and air filter assembly, a de-coupling of the two areas of responsibilities may cause the deficiency to be overlooked. A review of the governing procedures used to address this interface will be required. The audit team will follow up this item in its review of the HVAC design criteria and methodology. The team's findings will be reported in a future audit summary or safety evaluation upon completion.
Audit Team Findings Based on its review of the Ebasco procedures, a sample of the as-built documentation and drawings, and walkdowns of selected equipment, the audit I
team concluded that the walkdown procedures for HVAC ducts, air handling units, plenums, and equipment supports are adequate, that the procedures are being implemented correctly by the field verification teams, and the recorded as-built l
I data are complete and properly documented.
The open item identified during the diesel generator building walkdown does raise l
a concern about interface responsibilities related to coupled HVAC/ equipment i
I assemblies. The audit team requires additional information as noted above to resolve this issue.
The audit team is continuing its review in this area and will discuss its findings in a future audit summary.
The TV Electric QC as-built inspection procedures related to HVAC ducts were determined to be comprehensive and well documented. The team will review the proper transfer and use of this inspection data by the Ebasco design verifica-l tion group in its audit of the HVAC design verification activities.
A total of 48 hrs. was involved in this site audit.
David Terao, Mechanical Engineer Comanche Peak Project Division Office of Special Projects
Enclosures:
1.
List o' Audit Personnel and Personnel Interviewed 2.
List of Documents Reviewed cc: See next page l
l 4
7-
']
,: t Comanche'. Peak l Steam Electric Station W. G.~Counsil.
Texas Utilities Electric Company.
Units;1 Land 2.
j-cc:
- Asst. Director for Inspec. ProgramsL.
"j Thomas G.'Dignan, Jr.
- Comanche Peak Project Division?.
Ropes & Gray 225 Franklin-Street LU.S.' Nuclear Regulatory Commission Boston, Massachusetts 02110 P.J0. Box 1029.
-Granbury, Texas? 76048' p
1 Robert A;.Wooldridge, Esq.
Regional' Administrator, Region IV.
Worsham, Forsythe, Sampels'&
-. U.S. Nuclear Regulatory Commission ~
Wooldridge
.611 Ryan Plaza'.' Drive,, Suite.1000 2001 Bryan Tower, Suite 2500 Arlington, Texas.'76011-1 l
Dallas,. Texas 75201 Lanny'A..Sinkin.
Mr. Homer C..Schmidt.
' Christic Institute Director of Nuclear Services 1324 North Capito1' Street Texas Utilities Electric Company Washington,:D.C. 20002 l
Skyway Tower.
400 North Olive Street,-L.B. 81 Ms. Billie Pirner' Garde, Esq.
Dallas, Texas 75201-
~ Government Accountability Project i
Midwest Office.
Mr. Robert E. Ballard,.Jr.
104' East Wisconsin Avenue i
Director of Projects Appleton, Wisconsin 54911 j
11 Penn Plaza-j Gibbs and Hill, Inc.
New York, New York 10001 David R.'Pigott, Esq.
j Orrick,-Herrington &'Sutcliffe i
600 Montgomery Street Mr. R. S. Howard San Francisco,, California ~ 94111 Westinghouse Electric Corporation P. O. Box 355 Anthony Z. Roisman.Esq.
Pittsburgh, Pennsylvania 15230-Suite.600 (4'l 1401 New Yo'rk Avenue, NW'
~
Renea Hicks Esq.
Washington, D.C.-20005 Assistant Attorney General l
Environmental Protection' Division Robert Jablon i
P. O. Box 12548, Capitol Station
' Bonnie S. Blair.
Austin, Texas 78711 Spiegel & McDiarmid:
j 1350 New York Avenue, NW Mrs. Juanita Ellis, President Washington, D.C. 20005-4798 l
Citizens Association for Sound Energy 1426 South Polk-George A. Parker, Chairman Dallas, Texas 75224 Public Utility Committee-l Senior. Citizens Alliance Of-Ms. Nancy H. Williams
. Tarrant County,-Inc.
CYGNA Energy Services 6048 Wonder Drive 2121 N. California Blvd., Suite 390 Fort Worth, Texas 76133 j-Walnut Creek, CA 94596
.j q
j
+
'W. G. Counsil
- 2'-
Comanche Peak' Electric Station _
Texas Utilities Electric Company Units 1 and 2'
~
.j cc::
j Joseph F. Fulbright i
Fulbright & Jaworski 1301 McKinney Street Houstort, Texas 77010 Roger D. Walker Manager, Nuclear Licensing.
l Texas Utilities Electric Company Skyway Tower i
'400 North 011ve Street, L.B. 81 l
Dallas, Texas -75201 Mr.~ Jack Redding c/o Bethesda Licensing Texas Utilities Electric Company 1
3 Metro Center, Suite 610 Bethesda, Maryland 20814 William A. Burchette, Esq.
Counsel.for Tex-La Electric Cooperative of Texas Heron, Burchette, Ruckert & Rothwell.
Suite 700 i
1025 Thomas Jefferson Street, NW.
Washington, D.C.
20007 e
James M. McGaughy GDS Associates, Inc.
Suite 450 2525 Cumberland Parkway Atlanta, Georgia 30339 Administrative Judge Peter Bloch U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory P. O. Box X. Building 3500 Oak Ridge, Tennessee 37830 l
Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, Oklahoma 74075 1
Dr. Walter H. Jordan Administrative Judge 881 West Guter Drive Oak Ridge, Tennessee 37830 4
- h.
List of Audit Personnel and Personnel interviewed September 8-ll, 1967 NRC Staff-and Consultants D. Terao*
.NRC R. Wray.
Teledyne Engineering Services R. Rose Teledyne Engineering Services Personnel Interviewed M. Faggioli Ebasco M. Strehiow Ebasco K. Fitzgerald Ebasco-J. Aaen Ebasco M. Quin TU Electric /QC
- Part time
4 e
Q-.
Documents Reviewed
'I 1).
Ebasco Procedure CPE-EB-FVM-CS-029, Rev. 2 Procedure for Seismic HVAC Duct and Duct Hanger As-Built Verification in Unit l'and Common Areas 1
2)
Ebasco Procedure CPE-EB-FVM-CS-066, Rev. 0
.1 Procedure for Seismic HVAC Air Handling Units, Plenums,.
and Equipment Supports As-Built Verification'in Unit 1 and Comon Areas
'l 4
3)
TUE Procedure QI-QP-11.14.14, Rev. 2-Verification / Inspection of Seismic HVAC Systems 4)
QC Inspection Report 1-0125385 Duct Segment B-1-756-031 5)
QC Inspection Report 1-0125913 Duct Segment B-1-756-032 6)
QC Inspection Report 1-0118148 Duct Segment B-1-751-159-7)
Ebasco Drawing No. HS l-VAEHUH-23, Rev. 0 Diesel Generator Building Heater Support 8)
Ebasco Drawing No. P-1-844-IK-INT-A, Rev. O Diesel Generator-Building Intake Plenum "A" 9)
Ebasco Orawing No. AHU-1-VAFNAV-09, Rev. 00 APES
- 10) Ebasco Drawing No. FS-VAFNAV-37 Rev.-00 j
APES l
'l I
- 11) Ebasco Drawing No, ME-X-VAACTC-02, Rev. 00 APES
- 12) Ebasco Walkdown Package Heater Support HS-1-VAEHUH-23
- 13) Ebasco Walkdown Package Equipment Support ME-X-VAACTC-02
- 14) Ebasco Walkdown Package Air Handling Unit AHU-1-VAFNAV-09
Summary of Audit on 9/8-11/87
- 4'-
Distribution:,
eMik NRC PDR:
LPDR<
CPPD Reading.
OSP Reading
-J. Keppler/J. Axelrad C. Grimes P. McKee J. Lyons.
R. Warnick M. hkiloy D. Terao A. Vietti-Cook CPPD-LA OGC-Bethesda F. Miraglia E. Jordan.
'ACRS'(10)
.R. Wray, Teledyne R. Rose, Teledyne 1
0FC
- 05P:CPPD ggy-
- 0SP PPD
- D
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- A/D:05 CPPD :
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- M al oy-
- JLyo NAME :DTerao:cb
. ____:..__..... ______:_.............:.............:........__....:....... _____.:_______.......l DATE :10/30' 87
- 11/6 /87
- 11/Jb/87
- 1143 /87
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