ML20245C746

Summary of 870812-14 Audit W/Nrc Consultants at Plant of as-built Field Verification Program for Seismic Category 1 HVAC Duct Hangers.List of Personnel Involved & List of Documents & Drawings Reviewed Encl

ML20245C746
Person / Time
Site:	Comanche Peak
Issue date:	10/29/1987
From:	Terao D NRC OFFICE OF SPECIAL PROJECTS
To:	NRC OFFICE OF SPECIAL PROJECTS
References
NUDOCS 8711030498
Download: ML20245C746 (8)

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[$n tso UNITED STATES o

.- 8 NUCLEAR REGULATORY COMMISSION

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nAsHINGTON. D. C. 20656 i

October 29, 1987 Docket-Nos.

50-445 and S0-446 l-APPLICANT:

Texas Utilities Electric Company (TV Electric)

FACILITY:

Comanche Peak Steam Electric Station (CPSES),

Units 1 and 2

SUMMARY

OF AUDIT ON AUGUST 12-14 '1987 -

HVAC AS-8UILT VERIFICATION PROGRAM On August 12-14, 1987, the NRC staff and its consultants performed an audit of the as-built fia,1d verification program for seismic Category I heating, ventilation, and ai

• conditioning. (HVAC) duct and duct hangers at the Comanche j

Peak Steam Electric Station. The HVAC as-built program is being conducted i

by Ebasco Services, Incorporated (Ebasco) as part of the TU Electric Corrective Action Program for design validation. The purposes'of the NRC audit were (1) to verify the comprehensiveness and completeness of the walkdown procedures in their ability to record the as-built' condition of the HVAC components for design verification and (2) to verify the adequacy of the Ebasco walkdowns and transfer of data into preliminary as-built drawings for

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compliance with the written procedure. A list of persons involved with the

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j audit is provided in Enclosure 1.

i The scope of'the audit included (1) a review of the Ebasco procedure CPE-EB-FVM-CS-029 for performing the field verification, (2) a review of a j

j sample of the Ebasco walkdown (as-built) packages for.both duct segments and j

duct hangers, and (3) a walkdown of 19 HVAC hangers and 16 duct segments.

As-Built Verification Procedure The audit team reviewed the Ebasco field (as-built) verification procedure CPE-EB-FVM-CS-029 Revision 2 (referred to later as "FVM-CS-029"), and interviewed the Ebasco walkdown group supervisor on the details of the The Ebasco walkdown effort of the HVAC ducts and hangers is procedure.

essentially complete with the exception of responding to questions and The

-inquiries from the Ebasco design verification group (DVG) in New York.

audit team found the procedure for the HVAC hanger as-built verification to be sufficiently comprehensive and complete to identify the major deficiencies l

and attributes that could affect the design qualification of the HVAC hangers.

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The procedure was also found by the audit team to provide the necessary data to develop the as-built drawings and to perform a detailed structural evaluation.

The procedure incorporates the appropriate steps to ensure accurate recording of the attributes.

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Audit Summary of 8/12-14/87 ~ The HVAC duct segment walkdown procedure outlined in Section 3.6.2 of FVM-CS-029 addresses only gross dimensional attributes such as changes in direction and size of ducts, duct cross section linear dimensions. HVAC in-line items, and distance between hangers and companion flanges.. The FVM-CS-029 procedure specifies that certain local dimensional attributes, such as duct thickness, flange sizes, and flange bolt spacing, as well as-qualitative attributes, are to be verified and inspected by TU Electric QC.

in accordance with the QC procedure QI-QP-11.14-14. This aspect and procedure in the HVAC verification procedure was not addressed in'this site audit but 8-11, 1987.

was the subject of a subsequent audit performed during September The audit team identified a concern-in the FVM-CS-029 procedure (Sections 3.1.2.8.13 and 3.6.2.B) related to clearances. A minimum clearance of 1" is required t,etween the duct or duct hanger and adjacent piping components and For all other items, only a visible air gap is required.

1 pipe insulation.

For the latter, "go or no gn" criteria is used, i.e., the duct or. hanger could essentially be in imminent contact with another component but as long as No justification j

positive contact does not exist, no violation would be noted.

TU Electric did indicate or rationale for this clearance criteria was given.

that Stone and Webster Engineering Corporation has initiated a commodity There are definitive l

clearance program which is described in CPE-FVM-CS-068.

clearances in the latter procedure for HVAC ducts and hangers. However, this

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issue is considered to be unresolved and the staff will perform a followup audit of this issue during review of the HVAC design verification activities.

j The results will be reported in a future audit summary or safety evaluation upon completion of review.

Review of Walkdown Verification Documentation The audit team reviewed the documentation for several HVAC hanger and duct a

l segment paclages (see Enclosure 2) to determine whether the field verification (as-builting) procedures relative to flow of documents were correctly implemented-The packages reviewed contained the required documentation as j

listed in S;ction 3.4 of FVM-CS-029. The required documentation included the j

red-line drawings, the red-line drawing cover sheet with signatures, the required modification forms, signed off checklists, inputs from field engineering and the site design verification group, and the field checked computer aided drafting detail drawing.

The audit team found that the field j

verification process and documentation requirements have been implemented 4

properly in accordance with the applicable procedures.

Walkdown of HVAC Hangers and Duct Segments The audit team randomly selected a sample of HVAC hangers and duct segments The purpose of this walkdown was to provide an for a walkdown review.

independent assessment on the. completeness and accuracy of the Ebasco field The audit walkdown covered 19 HVAC hangers and 16 verification team work.

duct segments.

This walkdown audit identified two findings:

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4 Audit Summary of 8/12-14/87 1.

'A segment hanger DH-1-854-2N-C36 on the control building air conditioning system had been.mistagged as hanger DH-1-2N-1EC.

As a result of this' mistagging, the portion of the hanger was mislabeled on duct segment drawings 8-1-758-203 and B-1-758-205 as well as on the HVAC layout drawing SI-0758C.

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Required modifications for missing bolts were not indicated in Detail' 3 of Hanger Drawing DH-1-854-2N-C36, Sheet 7 of 8.

In the case of the first finding, TV Electric committed to correcting the hanger tag identification and the affected drawings. The mistagging was deemed to be an isolated error.

In:the case of the second finding, a further examination of the walkdown docu-mentation revealed that the Ebasco field walkdown team had actually identified the deficiency in the red-line drawings but the correct information was not transferred to Revision 0 of the hanger detail drawing.

It should also be noted that the Ebasco design validation group in New York had discovered the deficiency subsequent to the release of the preliminary as-built drawing.

Thus, the audit i

team found the deviation to be an isolated error in data transfer rather than an overlooked attribute.

Audit Team Findings Based on a review of the Ebasco procedures and a sample of the as-built documen-tation and drawings and the walkdown, the audit team concluded that contingent upon resolution of the above deficiency related to clearances and a review of i

the QC portion of the field' verification program, the Ebasco as-built verifica-i tion program and procedures appear to be adequate (1) to record and document the as-built configuration in sufficient detail to perform a design verification analysis and (2) to identify any major design and fabrication deficiencies which The could impact the structural integrity of the HVAC duct and duct supports.

audit team also concluded that the "as-builting" process as defined in the Ebasco procedure was implemented correctly.

The review of the work packages for a sample of components indicated the as-built data appeared to be well The walkdown, with the exception of the two documented and properly recorded.

findings above, found no significant deviations from the recorded as-built data.

As noted above, the staff has determined the findings to be isolated errors.

This site audit of the field verification program for HVAC hangers and ducts involved 48 staff hours.

David erao,t%chan cal Engineer manc e Peak Pr t Division Of of Special Projects l

Enclosures:

1.

List of Personnel Involved with Audut 2.

List of Documents and Orawings Reviewed cc:

See next page

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,(J r.cmanche Peak Steam Electric Station-Wi GE Counsfi:

. Te'xas, Utilities Electric Company Units 1 and 2.

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'.y' S Thonin,G. 'Dignan, 'Jr.

' Asst. Director.for Inspec. Programs Comanche Peak Project Division Ropes >& Gray 225 Frank 11r/ Street U.S. Nuclear Regulatory. Commission M,a Bost'on, massachusetts 02110 P. O. Box 1029' 1

Granbury, Texas 76048-e

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Gobert A. Wooldridge, Esq.

. Regional Administrator, Region IV

'Worsham, Forsythe,' Sampels 8 U.S. Nuclear Regulatory Commission 611 Ryan Plazd'Orive Suite 1000 Woo?dridge.

1 2001 Bryan Tower, Suite 2500 Arlington, Texp 76011 d

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Sgl.las, Texas' 75201-l-

gc Lanny A. Sinkin

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o ChrfMic Institute 1

Mr. ' Honwr / C. ' Schmi dt1 Director of Nucie n 5& vices 1324 North Capitol Street c.

Texas 1 Utilities Electijic' Company Washington, D.C.

20002 6

~ Skyway Towern n

q 400~ North Olive Street, L.B. 81 Ms. Billie Pirner Garde, Esq.

Government Accountability _ Project -

Dallas,. Texas 75201:

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-Midwest Office Mr. Robert Ei Ballard, Jr.

104 East Wisconsin Avenue Director.of Projects Appleton, Wisconsin 54911

?Gibbs>and Hi... Inc.

y iljirm P1aza -

New t ork, New York l10001-David R. Pfgott, Esq.

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Orrick, Herrington & Sutcliffe y

J 600'Hontgomery Street.

San Francisco, California '94111 Mr. R..S, Howard-.

Westinghouse Electric Corporation P. 0 1 ox 355?

Anthony Z. Roisman, Esq.

B PittsburghiPennsylvania 15230 Suite 600 ~

I 1401 New.. York Avenue, NW p

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Renea'liicks, Esq.

Washington, D,C. 20005 Assistant Attorney General

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Environmental Protection Division RopertJablon P. O. Box 12548,: Capitol Station

' Bonnie S. Blair i

AustingTexas 78711 Spiegel & ficDiarmid

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1350 New Yttk Avenue, NW, 1

Mrs. Ju pita Ellis, President Washington,-0.C'~20005-4798 Citizens Association'for Sound Energy 1426 South, Polk

' George A. Parker, Chairman L

Dallas, Texas 75224 Public Utility Committee Seifior Citizens Alliance Of a

Ms. Nancy $ Williams Tarrant County, Inc.

CYGNA Energy Services 6048 Wonder Drive 2121 N. California Blvd., Suite 390 Fort Worth, Texas 76133 i

Walnut Creek, CA 94596 V

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.. Comanche Peak Electric Station

r TexasUtf/itiesElectricCompany Units 1 and 2.

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cc-Joseph F. Fulbright.

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Fulbright & Jaworski

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1301 McKinne~y Street -

Houston, Tedas 77010 gf, )

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'!f Roger #..WalL'e'r Manager, Nuclear U censing-j 1

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. Texas Utilities Electric Company Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 c

Mr.~ Jack Redding c/o Bethesda L1 censing Texas Utilities Electric Company 3 Metro Center, Suite 610 Bethesda, Maryland 20814 William A. Burchette, Esq.

- ounsel for Tex-La Electric Cooperative

. of-Texas eron, Burchette, Ruckert & Rothwell Aite 700

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1025 Thomas. Jefferson Street, HW Al' Washington, D.C.

20007 James M. McGaughy GDS Associates Inc.

Suite 450 2525 Cumberland Parkway

, Atlanta, Georgia -30339 Administrative Judg5 Peter Bloch U.S. Nuclear Regulatory Commission Washington, D.C.

EOS5b' Elizadath B. Johnshn < r s i, Administrative Judge i.

Oak Ridge Nat: anal. Laboratory y

P. O. Box X. Bu.! ding 3500 Oak Rit.ge,, Tennessee 57830 l/

i Dr. Kenneth A. McC?ll d t/

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1107 West Knapp 1

4 Stillwater, Oklahoma 74075 Or. Walter H. Jordan Administrative Judge 881 West Outer Drive Oak Ridge Tennessee 37830 L

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~ 399:4 ENCLOSURE 1 i

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LIST OF PERSONNEL INVOLVED WITH HVAC AUDIT

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AUGUST 12-14, 1987_

NRC Staff and Consultants t

D. Terao*

NRC

-l R. Wray-Teledyne Engineering Services

.R.

Rose.

Teledyne' Engineering Services i

Personnel Interviewed M. Faggioli'

.Ebasco M. Strehlow Ebasco J. Aaen Ebasco d-

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ENCLOSURE 2 ListofDocumentsandDrawingsReviewg A.

. Procedures 1.

Ebasco Procedure CPE-EB-FVM-CS-029, Revision 2, Procedure for Seismic HVAC Duct and Duct Hanger As-Built Verification in l

Unit 1 and Comon Areas.

B.

Duct Segment Drawings i

B-1-758-203 B-1-756-030 B-1-758-205 B-1-751-089 B-1-756-031 B-1-751-090

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B-1-756-032 B-1-751-091 B-1-706-131 B-1-751-160 B-1-756-132 B-1-751-158 8-1-756-014 B-1-751-159 B-1-756-299 B-1-758-032 C.

Duct Hanger Drawings DH-1-854-1N-C7 DH-1-830-1N-1AW DH-1-854-1N-1AK l

DH-1-854-2N-C36 DH-1-830-IN-C18 DH-1-830-1N-1AT DH-1-792-1N-1A DH-1-830-1N-1AU DH-1-792-IN-1B DH-1-830-1N-1AY DH-1-792-IN-1C DH-1-830-IN-1AY DH-1-792-1N-4A DH-1-830-1N-1AZ DH-1-792-1N-WP9 l

DH-1-830-1N-1AS DH-1-792-1N-1H l

DH-1-830-1N-C2 DH-1-792-1f1-1G 1

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