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Insp Repts 50-445/87-14 & 50-446/87-11 on 870708-0804.No Violations or Deviations Noted.Major Areas Inspected: Followup on Previous Insp Findings & Applicant Identified Const Deficiencies,General Plant Insps & Penetrations
	ML20237G606
Person / Time
Site:	Comanche Peak
Issue date:	08/26/1987
From:	Phillips H, Warnick R; NRC OFFICE OF SPECIAL PROJECTS
To:	;
Shared Package
ML20237G582	List: ML20237G579; ML20237G606;
References
	50-445-87-14, 50-446-87-11, NUDOCS 8709020328
	Download: ML20237G606 (13)
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U. S. NUCLEAR REGULATORY COMMISSION

OFFICE OF SPECIAL PROJECTS

NRC Inspection Report: 50-445/87-14 Permits: CPPR-126

50-446/87-11 CPPR-127

Dockets: 50-445 Category: A2

50-446

Construction Permit

Expiration Dates:

Unit 1: August 1, 1988

Unit 2: Extension request

submitted

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Applicant: TU Electric

Skyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas 75201

Facility Name: Comanche Peak Steam Electric Station (CPSES)

Units 1 and 2

Inspection At: Comanche Peak Site, Glen Rose, Texas

Inspection Conducted: July 8 through August 4, 1987

Inspector: . / d* d[8'7

l H'. $. Phillips,' Senior Resident Reactor Date

Inspector, Construction

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Reviewed by: R F u)aamIcA F- 2 t.- F7

R. F. Warnick, Assistant Director Date

for Inspection Programs

Comanche Peak Project Division

Office of Special Projects

8709020328 870826

PDR ADOCK 05000445

O PDR

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Inspection Summary

Inspection Conducted: July 8 through August 4, 1987 (Report

Nos. 50-445/87-14; 50-446/87-11)

Areas Inspected: Routine, unannounced safety inspection including

(1) followup on previous inspection findings; (2) followup on

applicant identified construction deficiencies; (3) general plant

inspections; (4) storage / handling of safety-related components;

(5) penetrations; (6) piping and supports; and (7) electrical work

activities.

Results: Within the areas inspected, no violations or deviations

were identified. A meeting was held on July 22, 1987, to resolve

the NRC's concern with the TUE response to NRC Inspection Report

50-445/84-32; 50-446/84-11 (paragraph 2).

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DETAILS

1. Persons Contacted

R. P. Baker, Regulatory Compliance Manager, TU Electric

(TUE)

J. L. Barker, Engineering Assurance Manager, TUE

M. Blevins, Technical Support Manager, TUE

W. G. Counsil, Executive VP, Nuclear Engineering &

Operations, TUE

R. D. Delano, Licensing Engineer, TUE

D. E. Deviney, Operations Quality Assurance (QA) Manager,

TUE

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T. L. Heatherly, Regulatory Compliance Engineer, TUE

J. Hicks, Licensing, TUE

J. J. Kelley, Plant Operations Manager, TUE

0. Lowe, Engineering Director, TUE

L. D. Nace, VP, Engineering and Construction, TUE

D. Noss, QA, TUE

D. M. Reynerson, Director of Construction, TUE

, *A. B. Scott, VP, Nuclear Operations, TUE

C. E. Scott, Startup Manager, TUE

J. C. Smith, Plant Operations Staff, TUE

P. B. Stevens, Electrical Engineering Manager, TUE

J. F. Streeter, Director of QA, TUE

T. G. Tyler, Projects Director, TUE

The NRC inspector also interviewed other applicant employees

during this inspection period.

Denotes personnel present at the August 4, 1987 exit

interview.

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2. Management Meetings (30702)

a. On July 22, 1987, R. F. Warnick, H. S. Phillips, and C.

Hale of the NRC met with TUE staff members J. F.

Streeter, R. Spangler, and D. Noss to discuss the TUE

response to NRC Inspection Report 50-445/84-32;

50-446/84-11. The NRC requested clarification and

additional information. That is, the response reflected a

more positive view of the TUE QA and audit program when

compared to the Comanche Peak Response Team results

reports for Issue-Specific Action Plans (ISAPs) VII.a.4

and VII.a.5. Also the response did not factor in the

generic findings and corrective action discussed in the

ISAPs.

b. Three representatives from the Texas Department of Labor

and Standards were onsite the week of July 13-17, 1987.

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The purpose of their visit was to inspect applicant

compliance with the ASME Boiler and Pressure Vessel Code

as required by Texas law. A representative from the NRC

onsite staff attended their entrance and exit meetings.

In addition, P. F. McKee, R. F. Warnick, and H. S.

Phillips (J. G. Keppler and C. I. Grimes were in

attendance part of the time) met with Steven M. Matthews,

Director and Chief Inspector, Boiler Division; George

Bynog, Assistant Director, Boiler Division; and Ricky

Bryan, Lead Inspector for Comanche Peak, Boiler Division

on July 14, 1987, to discuss their responsibilities and

authority, under Texas law, and items of mutual interest

relating to the applicant's compliance with the ASME

Code.

3. Followup On Previous Inspection Findings (92701, 92702)

a. (Closed) Open Item (445/8214-01): Region IV (RIV)

planned to do additional inspection of vendor shop

performed welding (including NPSI) during a subsequent ,

inspection.

This item was opened during a RIV followup inspection in

response to a visit by an alleger at RIV. The original

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concerns dealt with American Welding Society (AWS)

Structural Welding Code, D.1.1, welds that were not in

accordance with this code. The RIV inspector inspected

five girder welds and a box structure on main

steam /feedwater pipe whip restraints, addressing the

alleger's concerns in NRC Inspection Report 50-445/82-14.

Although the concerns were addressed, the NRC inspector

chose to perform additional inspection of similar vendor

l welds including Nuclear Power Services, Inc. (NPSI)

l during a future inspection and left the item open.

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The currently assigned NRC inspector found that

additional inspections were performed and documented in i

50-445/82-22; 50-445/84-29, 50-446/84-10; 50-445/83-24, !

50-446/83-15; 50-445/82-25, 50-446/82-13; 50-445/80-22, l

50-446/80-22; and the special NRC Technical Review Team

inspection documented in NUREG 0797 Supplement 10 1

(AQW-22, AW-39, AW-57, AQW-75, and AQW-76).

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b. (Closed) Violation (445/8507-V-06; 446/8505-V-04):

Failure to document on a Deficiency and Disposition

Report (DDR) a 24-48 pound deviation on cement scale MTE

779 frcm required accuracy.

The NRC inspector reviewed the corrective action file and

found that the violation was caused by a lack of

procedures. Nonconformance reports (NCR)-C-85-101882,

Revision 1, and NCR-C-85-201617, Revision 1, were issued

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to require an evaluation of two concrete placements while

the scales were in this condition and it was found that

specified design strengths were attained. This resolves

this issue.

c. (Closed) violation (445/8507-V-02): Failure to use Class

"E" concrete as specified.

The NRC inspector reviewed a TUE file on this item.

The original response (TXX-4727) from TUE was inadequate;

however, the supplemental response (TXX-6211) provided

the necessary information and action. As a result of the

NRC inquiry, two deficiency reports were issued to ensure

appropriate drawing changes, document the design change,

and identify causes. The applicant also found that this

grout substitution for Class E cencrete occurred in seven

Unit 1 and eight Unit 2 installations not previously

identified in response TXX-4727.

The NRC inspector found that the use of commercial

non-shrink grout with an average compressive strength of I

8450 psi is an acceptable substitute even though it's use j

was unauthorized at the time. This strength exceeds the l

Class "E" concrete minimum strength of 4000 psi. The

inspector observed a typical baseplate (TBX-RCPCG-01)

that was grouted. )

The applicant's file showed that a project directive

(CPPA-56,467) was issued to emphasize the precedence of

design documents over vendor documents. Stone & Webster

Procedure PP-053, TUE Procedure ECE-DC-5 (used by

Ebasco), and Impell Procedure IMP-FP-19 have either been

revised or emphasized to assure that conflicts between

vendor drawings and design drawings are resolved and that

design takes precedence.

d. (Closed) Unresolved Item (446/8511-U-03): The issuance

of drawing packages from satellites to the field and the

logging of the status of design change authorizations

(DCAs) and component modification cards (CMCs) into the

computer were not in controlled procedure DCP-3 but were

covered in uncontrolled guidelines.

The NRC inspector reviewed a TUE package which showed

that the uncontrolled guidelines were incorporated into

controlled procedures. Paragraph 3.1.2.3 of DCP-3,

Revision 19, dated March 31, 1986, described the issuance

of drawings to the field. Paragraph 2.1.5 of ECE-DC-7,

Revision 19, dated October 31, 1986, described the

tracking of DCAs and CMCs. This resolves this issue.

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e. (Closed) Open Item (445/8601-0-01; 446/8601-0-01):

Ultrasonic testing procedures were not onsite.

The NRC inspector reviewed copies of the CB&I procedures

UTP-18B and UTP-25B that are now in the records vault.

TUE reviewed CB&I records that were removed and returned i

to site and found that they have essential records. This

resolves this issue. I

No violations or deviations were identified.

4. Followup On Applicant Identified Construction Deficiencies

(92700)

The NRC inspector reviewed construction deficiency reports j

CP-87-13 through CP-87-54 which had been identified as l

potentially reportable construction deficiencies in accordance j

with 10 CFR Part 50.55(e). Each report was reviewed to assure '

that the deficiency was fully identified, described,

evaluated, and that the NRC was notified in accordance with

TUE Procedure NEO-CS-1, Revision 1 and 10 CFR 50.55(e).

The following potentially reportable items were inspected in

the field to observe the deficient conditions and any

corrective actions in process.

Location Number Deficient Condition

1

RCB 1&2, CP-86-61 Polar Crane not installed i

el 905' properly I

RCB 1&2 CP-85-26 Steam generator lateral

el 905' support restraint bolts

shortened

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AB 2 CP-86-76 Gould battery racks

el 792' improperly spaced

EC 1 CP-85-07 Butt splice CPI-ECPRC-13

el 830' improperly made

EC 1&2 CP-86-54 Seismic supports for CR

el 840' ceiling improperly

installed

AB 1&2 CP-86-11 CCW pump impellers cracked

el 810'

AB 1&2 CP-87-18 CCW heat exchangers have

el 790' deficient seismic

qualifications

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Location Number Deficient Condition

SGB 1 CP-87-15 Air accumulators improperly

el 790' stored

SGB 1 CP-87-20 6.9kV transformer porcelain

el 810' bus cracked

DGB 2 CP-84-02 DG piston skirt had linear

el 810' indication

SGB 2 CP-86-10 Bunker-Ramo penetration

el 852' assemblies removed

No violations or deviations were identified.

5. General Plant Inspections

At various times during the inspection period, the NRC

inspector conducted general inspections of the Unit 1 and 2

reactor containment (RCB), safeguards (SGB), auxiliary (AB),

electrical control (ECB), and diesel generator (DGB)

buildings. All accessible rooms in these buildings were

inspected to observe current work activities with respect to

major safety-related equipment, electrical cable / trays,

mechanical components, piping, welding, coatings, Hilti bolts,

and removal of debris from the seismic gap between the

buildings. The housekeeping, storage and handling conditions

inside these buildings and various outside storage areas were

l also inspected (paragraph 6). Four backshift and two weekend )

inspections were performed during this inspection period.

Work activities that were selected for more detailed l

inspections are described in paragraphe 7, 8 and 9. l

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No violations or deviations were identified. '

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6. Identification and Storage of Site Materials, Parts, and

Components (50073, 50090, 50095, 51053, 51063, 53053)

a. Identification

The NRC inspector verified that equipment, components,

parts, and materials used in civil, electrical, and

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mechanical activities were positively identified during

receiving, storage, and installation.-

l b. Warehouses /Laydown Yards

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The NRC inspector observed all materials, parts, and

components stored in all warehouses (A, B, C, D, and

Electrical) and all laydown yards to determine if storage

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met the equivalent measures of Regulatory Guide 1.38 and

American National Standards Institute (ANSI)

N45.2.2-1972. These measures were implemented to prevent

damage, deterioration, or contamination.

Equipment such as instrumentation, tubing, Conax

electrical penetrations, cable, Barton/Rosemount pressure i

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transmitters, ASCO Solenoids, pressure indicator

switches, thermowells/ thermocouple, Magnetrol level

indicators, Namco switches, bulk hardware, and shelf life '

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material were stored to Level A and B requirements in

Warehouse "B". The humidity was being recorded on a

circular chart which measured temperature / humidity and

which was calibrated February 23, 1987 and due for

calibration again August 24, 1987. Materials such as i'

"0" ring seals, spacers, piston kits, gaskets, and

diaphragms for valves were monitored by date of

expiration of shelf life. Other equipment such as pumps,

valves, thermal insulation, abrasives, adhesives,

grouting, and chemical materials were stored to Level "C"

requirements in Warehouses A, C, and D. Bulk electrical

hardware was stored in the Electrical Warehouse.

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l The NRC inspector inspected nine outside storage areas.

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Electrical cable, trays, and miscellaneous hardware were

stored in the cable reel yard and an adjacent yard for

l hardware. Piping supports, reinforcing / structural steel,

fuel racks, and other miscellaneous material were stored

to Level "D" storage requirements; i.e., up on wood

dunnage and covered where necessary.

l c. In Place Storage

The NRC inspector observed all accessible equipment in

i Unit 1 and 2 to determine that equipment moved into

buildings and temporarily or permanently stored in place

continues to be appropriately stored and is afforded

special protection where necessary to protect it from

ongoing construction activities.

d. Quality Control

The NRC jnspector found that quality controls (QC) for

receiving and storage were implemented. In Warehouse "B"

a QC inspector was stationed to perform receipt

inspections and there was evidence that a number of items

had been inspected, rejected, tagged, and segregated to

preclude inadvertent use.

No violations or deviations were identified.

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7. RCB Penetrations and Fire Barriers (53053)

The NRC inspector observed in process or completed work

relative to Unit 1 and 2 electrical and mechanical

penetrations. All mechanical penetrations have been

installed.

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In SGB 1, el 832', room 88, the NRC inspector observed the

physical appearance of the following previously installed

mechanical penetrations as:

MI-09, 10, 11 & 12 Steam generator blowdown

piping

MIII-20 Demineralized H 2O to RCB

MV-3 & 4 CCW from letdown heat exchanger

(Hx) and reactor containment

drain tank Ex

MV-5 Service air to RCB

MV-6 CCW drain tank pump discharge line

The NRC inspector observed the quality of fire barrier seals

installed in SGB 1, el 832', Room 89. One volume control tank

(TBX-LSATVC-01) and the associated piping which penetrates two

walls is located in this room. Completed fire barriers ,

6026183101 2003 6 89, 6026183100 2002 6 89, and 60260831 2001 !

6 89 were installed around the piping. !

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The NRC inspector observed AB 1 and 2 penetrations MV-14 and )

MIII-18, RCB pressure relief and hydrogen purge supply exhaust I

system located on the 832' el.

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Electrical penetrations in SGB 1 and 2 were observed to be in i

various stages of construction; however, no in process work

was observed.

The installation of Bisco seal material Release No.

SG-2-790-RM64-5001 was observed while work was in progress for

Machine 9876-1 System 95.

No violations or deviations were identified.

8. Piping and Piping Supports (50090, 55053)

The NRC inspector previously identified planned work

modifications in SGB 1, room 88, that resulted from DCA 24676,

I Revision 0. During this inspection period the inspector

observed that the modifications were in progress to relocate

valves IMS-149, 151, 153, and 155. Unit 2 valves were to be

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transferred to Unit 1 and be renumbered. The reason for the

change was the existing steam generator blowdown valves did

not meet operability requirements. The applicant considered

this to be a significant deficiency (CP-86-035). The piping

was described on drawings BRP MS-1-SB-003 through 006. The

NRC inspector found that the valve being removed from the

piping going into penetration MI-12 was partially resting on

another pipe. This was pointed out to the applicant who

immediately corrected the problem.

The NRC inspector observed welding activities that were in

progress in the Brown & Root Fabrication Shop. The

documentation for support CC1 066 077 S33K, Revision 0,

appeared to conflict with the safety class stamped on the name

plate. The paperwork indicated it was American Society of

Mechanical Engineers (ASME) Class 3 while snubber 15090 was

marked ASME Class 2. The inspector found that there was no

conflict because Section III of the ASME Code allows the

downgrading of components to a lower class. The material for

transition kit 16524-1720 was traceable using receiving

inspection report 20536 and material report 418991. The work

was being accomplished to drawing Revision CP-2.

The NRC inspector observed work in progress in RCB 2 at the

885' el. Feedwater (FW) support FW2-018-444-C72K was being

checked for concrete attachment (embeds) separation

violations. Discussions with the responsible personnel

revealed that multiple separation violations had been

identified when compared to the new specification (SS-30)

criteria. More violations were expected in Unit 2 than Unit 1

because 15,000 embeds were built into Unit 2 versus 3,000 in

Unit 1. The NRC inspector found that corrective action report

(CAR) 86 plus 50.55(e) reports CP 86-04 and 86-59 had

identified these deficiencies to the NRC.

The NRC inspector observed work in progress in RCB 1 at

el 905'. Containment spray piping support CT-2-044-015-C92R

was being reworked, that is, washers were inserted and the

angle of the snubber was checked. The construction foreman

had signed off the completed work.

The NRC inspector observed a CCW pipe support in room 205 of

the AB 1. The installation of support CC-1-043-010-A43K had

been completed but had not been painted.

The NRC inspector observed that several restraints / supports in

the hallway of the AB 2 (elevation 810') had paint removed to

determine the number vibroetched onto this component. They

were located near valve LCV-0112E at centerline GA 8'-0" 0/S

N.6-A. TUE answered an inquiry as to whether this was an

identification (10 CFR Appendix B, Criterion VIII) deficiency

that violated the ASME Section III, Division 1, Code. At a

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meeting the TUE representative stated that there was no code

violation and presented an ASME procedure which controls such

activities and allows the observed practice.

No violations or deviations were identified.

9. Electrical Work Activities (51053, 51063)

The NRC inspector preselected electrical work activities to i

observe. (The storage and handling of electrical materials is j

described in paragraph 6 and includes all that is presently

stored on site.)

The NRC inspector observed a cable tray walkdown in progress ,

in Unit 2 cable spread room. The walkdown was a quality j

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control training exercise. In ECB 1 cable spread room, the

NRC inspector observed in-process work activities at different

times during the inspection period. The activities included a

TUE audit that was in process, conduit walkdowns, and an

electrical modification which resulted from DCA 31278R1 (which

was nonsafety related).

In AB 1, a power distribution panel CPX-EPDPNB-26 and

electronic control panel XAT-10B were inspected. A bolt was

found to be missing from a bolt hole in the base support that

secures these cabinets to the floor. These cabinets were

later identified as nonsafety related.

The NRC inspector observed in SGB 1, room 83, the replacement

of 6.9 kv transformer porcelain buses that had been

overtorqued and cracked.

The NRC inspector observed various work activities in and

around cable trays. Two adverse conditions were referred to

the applicant. First, workers expressed a concern about the

installation of fire protection / detector conduit because

procedure ECP-19A only allowed workers to go one size larger

on conduit elbows. It was stated that this sharp bend radii

will cause problems later when wirdng is run. This

nonsafety-related activity was referred to the applicant for

resolution. Secondly, the NRC inspector observed cable tray

T13GSN83 in AB 1, room 88, which had cable spilling over the

tray. The applicant determined that cable SP1197679 was a

spare which was coiled in the tray and the coil went over the

edge of the tray.

No violations or deviations were identified.

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10. Exit Interview (30703)

An exit interview was conducted on August 4, 1987, with the

applicant's representatives identified in paragraph 1 of this

report. During this exit interview, the scope and findings of

the inspection were summarized.

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DISTRIBUTION:

4 Docket 1 Files:z(50-445/446)([NRCiPDRik

.

Local PDR

CPPD Reading (HQ)

Site Reading

CPRT Group

SRI-OPS

SRI-CONST

MIS System

RSTS Operator

RPB

RIV File

DWeiss, RM/ALF

JKeppler/JAxelrad

CIGrimes

PFMcKee

HSchierling

JLyons

LChandler, OGC

CPPD-LA, OSP

w/766

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ML20237G606

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