ML20202F221

Cable Tray Support As-Built Program Insp Rept 50-445/85-19 on 851118-1218.Violation Noted:Failure of Walkdown Teams & QC Inspectors to Correctly Determine & Verify as-built Cable Support Attributes

ML20202F221
Person / Time
Site:	Comanche Peak
Issue date:	03/18/1986
From:	Solla E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20202F175	List: IA-86-382, Final Response to FOIA Request.Forwards App B Documents.App a & B Documents Also Available in PDR ML20202F171 ML20202F221
References
FOIA-86-382 50-445-85-19-01, 50-445-85-19-1, NUDOCS 8607150114
Download: ML20202F221 (11)

See also: IR 05000445/1985019

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APPENDIX

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SPECIAL UNIT 1

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CABLE TRAY SUPPORT "AS-BUILT" PROGRAM INSPECTION

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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NRC Inspection Report:

50-445/85-19

Construction Permit: CPPR-126

Docket: 50-445

Category:

A2

Applicant:

Texas Utilities Electric Company (TVEC)

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Skyway Tower

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400 North Olive Street

Lock Box 81

Dallas, Texas 75201

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Facility Name:

Comanche Peak Steam Electric Station (CPSES), Unit 1

Inspection At: Glen Rose Texas

Inspection Conducted: November 18 - December 18, 1985

Inspectors:

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R. E. Lipinski, NRR

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J. R. Dale, RIV Consultant

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E. A. S,qlla NRR Consultant

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T. Langowski, NRR Consultant

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8207150114 860709

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FOIA

CARDE86-382

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Reviewed By:

I, Barnes, Group Leader, Region IV CP5ES Group

Date

Approved:

T. F. Westerman, Chief, Region IV CP5ES Group

Date

Inspection Summary.

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Inspection Conducted November 18 - December 18, 1985 (Report 50-445/85-19)

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Areas Inspected: Special, unannounced inspection of the Unit I cable tray

support as-built inspection program and the related QA audit program for this

activity. The inspection involved 224 inspector-hours onsite by six NRC

-personnel.

Results: Within the two areas inspected, three violations (failure of walkdown

teams and QC inspectors to correctly determine and verify, respectively,

as-built cable tray support attributes, paragraph 3.a-3.h; failure to perform

periodic audits of the as-built cable tray support program, paragraph 6; use

of weld angles in cable tray supports wh.'ch were below the permissible minimum

values, paragraph 5) were identified.

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DETAILS

1.

Persons Contacted

(*)(**)R.A.Muldoon,Ebasco

(*)R. B. Bronson, Eoasco

(*)R. C. Iotti, Ebasco

(*)(**)R. M. Kissinger Texas Utilities Generating Company (TUGCo)

(*)R. Siever, B&R

(*)(**)C. R. Hooton, TUGCo

(*)(**)R. E. Camp TUGCo

(*)(**)W. F. Rockwell, Ebasco

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C. A. Briggs, TUGCo

(**)H. A. Harrison TUGCo

(**)P. Halstead. TUGCo

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(**)T. Brandt, TUGCo

(**)J. S. Marshall, TUGCo

(**)J. Vorderbrueggen. Impell

H. A. Levin, TERA

The NRC inspectors also interviewed other applicant employees during this

inspection period.

(*) Denotes those present during November 22, 1985, exit meeting.

(**) Denotes those present during December 5, 1985, exit meeting.

2.

Cable Tray Support As-Built Inspection Program

The inspection was performed to verify the adequacy of the Unit 1

as-built inspection program for cable tray supports. The bases used for

this inspection were:

(a) TUGCo Nuclear Engineering (TNE)

Procedure TNE-AB-CS-1, Revision 1, dated September 30, 198E. "As-Built

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Procedure, Cable Tray Hanger Design Adequacy Verification;* and (b) the

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as-built red lined drawings which were prepared by TUGCo walkdown teams

(composed of a walkdown engineer and a QC inspector) in accordance with

Procedure THE-AB-CS-1, Revision 1.

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From a total of 789 cable tray supports that had been through the walk-

dow:. program, a total of 66 supports were selected by the NRC inspection

team using a random number generator. These supports were then broken

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down by building and type. An engineered sample of 32 supports was

selected. This sample included the following cable tray supports:

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Reactor Building

Fuel Building

CTH-1-42

CTH-1-1695

CTH-1-239

CTH-1-1716

CTH-1-4738

CTH-1-1742

CTH-1-5488

CTH-1-1845

CTH-1-5517

CTH-1-1853

CTH-1-5538

CTH-1-1963

CTH-1-5757

CTH-1-5352

CTH-1-5787

CTH-1-7047

CTH-1-5817

CTH-1-5873

Control Room

'CTH-1-5942

CTH-1-7199

CTH-1-5976

CTH-1-6041

Safeguards Building

CTH-1-6497

CTH-1-207

CTH-1-6517

CTH-1-607

CTH-1-6559

CTH-1-636

CTH-1-6631

CTH-1-707

CTH-1-12075

CTH-1-13026

As a result of this inspection, deficiencies were identified in major

attributes associated with the Unit I cable tray supports red-lined

as-built drawings.

3.

Summary of Deficiencies (TNE-AB-CS-1)

A summary of the findings from this inspection which appear to be in

violation of 10 CFR 50, Appendix B Criterion X and THE AB-CS-1,

Revision 1, are as follows:

a.

Tray Size

(1) Procedute Requirements

TNE-AB-CS-1, Revision 1, Section 4.2.2.B.7 requires verification

of the following:

"7.

Cable Trays

a.

Width

b.

Depth

c.

Location within Support"

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(2) Findings

CTH-1-5817 is recorded as a 4" x 12" tray.

It was found to be

a 4" x 24" tray by NRC.

b.

Tray Span

(1) Procedure Requirement

TNE-AB-CS-1, Revision 1, Section 4.3.2. requires verification

of the following:

"6.

Indicate span from support to. support . . ."

(2) Findings

CTH-1-5817 conduit span was in error by I' 6".

CTH-1-239 spans were in error by 8" and 10".

c.

Tray Clamps

(1) Procedure Requirement

THE-AB-CS-1, Revision 1 Section 4.2.2.B.6 requires

verification of the following:

"a.

Clamp Type (Attachment D)

1.

Bolted

a.

Flat washer or bevel washer

2.

Welded

a.

Weld size and weld length will be verified

in accordance with Reference 1-6."

(2) Findings

CTH-1-12075 cable tray clamp was recorded as a Type B

" Heavy Duty Clamp" i" plate welded to channel. Actual

clamp was a Type C bolted clamp.

CTH-1-1845 cable tray clamp G-2 was recorded as a bevel

washer only, actual clamp contained a bevel and a flat

washer.

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d.

Member Size

(1) Procedure Requirement

TNE-AB-CS-1, Revision 1. Section 4.2.2.8 recyires verification

of the following:

"E.

Hanger Configuration

s.

Member shape and nominal size per AISC (see

Table 13 Or AISC manual of steel construction

7thedition)."

(2) Findings

CTH-1-5787 angle shape under tray was identified as 5/16" in

thickness. Actual thickness was 7/16".

e.

Weld Qualitative Measurement

(1) Procedure Requirement

TNE-AB-CS-1, Revision 1. Section 4.2.2.B. requires

verification of the following:

"3.

MemberConnectionDetails(Connectiontosupport

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member)

a.

Welds shall be verified by the QC inspector

in accordance with Reference 1-G."

Reference 1-G, QI-QP-11.10-9 Cable. Tray Hanger As-Built,

(Inspection / Verification), Revision 2, Section 3.3.5

requires verification of the following:

"3 3 5 Welding Inspection

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3.3.5.1 General

Welding shall be inspected for quantitative and

qualitative attributes as listed below without

paint removed.

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Quantitative

a.

Type of Weld (fillet, flare bevel,

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groove,etc.)

b.

etc.)guration (two sides all around,

Confi

c.

Weld Length

d.

Weld size"

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In Supplementary Safety Evaluation Report (SSER) 12

Section 3.8.3 which addresses FSAR Amendment 55, the

applicant has been given approval to use Nuclear

Construction Issue Grcup (1CIG) document NCIG-01,

Revision 2 " Visual Weld Acceptance Criteria for Structural

Welding to Nuclear Power Plants" (VWAC).

VWAC specifies

the following acceptance criteria for fillet welds:

"3.5.2.2 Acceptance Criteria: a fillet weld shall be

permitted to be less than the size specified by 1/16

for i the length of the weld."

(2) Findings

CTH-1-5942 fillet weld #1 was found to be 1/16" undersized

from that recorded for greater than 1/4 of its length.

CTH-1-1845 fillet weld detail B was found to be 1/16"

undersized from the recorded for greater 1/4 of its length.

CTH-1-5517 fillet weld #1 was found to be 1/16" undersized

from that recorded for greater than 1/4 of its length.

CTH-1-5488 fillet weld was found to be undersized 1/16"

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from that recorded for greater than 1/4 of its length.

CTH-1-4738 fillet weld was found to be undersized 1/16"

from that recorded for greater than 1/4 of its length.

CTH-1-12075 measurement of the top and bottom of member

weld lengths was recorded in reversed.

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CTH-1-1853 measurement of the top and bottom of member

weld lengths was recorded in reversed.

f.

Dimensional Measurements

(1) Procedure Requirements

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TNE-AB-CS-1, Revision 1 Section 4.2.2. requires

verification of the following:

"A.2 Elevation (of lowest horizontal member)

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B.2. Hanger Configuration

b

Dimension, including addition of required

dimensions.

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f.

Expansion anchor bolt projection and/or

embedment (Table 12).

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B.4 Support Anchorage

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Bolt distance from heel of angle or

channel, etc.

(Gage

'G' dimension)"

(2) Findings

CTH-1-5942 dimension to edge of column was in error 1".

CTH-1-1845 dimension between attachments was in crror

l' 3/4".

CJH-1-1963elevationwasinerrorby3"(ElevationA-A).

CTH-1-42 gage dimension was in error 1".

CTH-1-239 gage measurement was in error 5/16".

CTH-1-1845 bolt projection measurement was in error 3/4"

CTH-1-7047 bolt projection for bolts #1, #2, and #3 was

in error greater than 1".

CTH-1-5976 bolt projection measurement was in error 1/2"

g.

Bolt Size

(1) Procedure Requirement

TNE-AB-CS-1, Revision 1, Section 4.2.2.B requires

verification of the following:

"3.b Bolts

1-Size"

(2) Findings

CTH-1-6631 hex nut was standard when a heavy hex nut was

specified.

h.

Member Orientation

(1) Procedure Requirements

TNE-AB-CS-1, Revision 1, Section 4.2.2.B requires

verification of the following:

"2.

Hanger Configuration"

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(2) Findings

CTH-1-1845 angle to wall was rotated 90 degrees from

drawing detail.

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4.

Other Findings Related to TNE-AB-CS-1

a.

Measurements

Criteria were not provided with respect to the required acuracy of

measurements in obtaining THE-AB-CS-1 red-line data. Variations in

bolt projection and gage measurements were identified which appear

to be attributable, in part, to the many different methods used to

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make the measurements. The applicant has indicatcJ that TNE-AB-CS-1

will be revised to provide clear guidance with respect to

measurements. This in considered an open item-(445/8519-0-01).

The NRC inspectors compared NRC measured dimensions and the red-line

recorded dimensions to the tolerances given in tables attached to

TNE-AB-CS-1. Measurements which violated these tolerances are

identified in paragraph 3 above.

b.

Inaccessibility

The NRC inspectors identified that there were attributes which

appeared accessible, although they had been identified as

inaccessible.

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The applicant stated that the training provided to the walkdown

personnel instructed that measurements be taken only if they were

fully accessible at the support.

Further, the training provided

gave instruction that all attributes of a particular component be

fully accessible before it is inspected.

The applicant has indicated that the term inaccessible will be

clarified by revision to TNE-AB-CS-1.

This considered an open item (445/8519-0-02).

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5.

Weld Bevel

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In addition, the NRC inspectors noted weld bevels which appeared to be in

violation of the American Welding (AWS) D1.1 Society Code. The quantita-

tive weld attributes, such as bevel, were inspected by the applicant only

for the first 100 supports in accordance with TNE-AB-CS-1.. It was there-

fore not a requirement of the Unit 1 as-built cable tray program to verify

weld bevel beyond the first 100 supports inspected.

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The FSAR, Table 17A-1 states that cable tray hangers will be constructed

in accordance with American Institute of Steel Construction (AISC) Code.

The AISC Code, Seventh Edition, Page 4-131, states that "The AISC

Specification and the American Welding Society exempt from tests ar.d

qualification most of the common welding joints applicable to steel

structures. When the joints . . . as designated as prequalified . . ."

Gibbs and Hill, Inc., Specification 2323-SS-16B, Section 6.4, dated

May 7, 1975, states, " Welding construction shall conform to AISC Specifi-

cation for Design, Fabrication and Erection of Structural Steel for

Buildings and AWS D1.1."

The AWS D1.1-75 Code, Section 2.9.2.4 states with' respect to weld groove

angle, "The groove angle is minimum.

It may be detailed to exceed the

dimension shown by no more then 10 degrees."

The weld bevel for hanger drawing CTH-1-5538, full penetration weld #2,

was found to be 30* by the NRC inspector.

In addition, the weld bevel

for hanger CTH-1-5517, 1" plate full penetration weld, was measured

to be 36*-38 . The prequalified weld bevel specified by the hanger

drawings (CTH-1-5538 and CTH-1-5517) was 45*.

The failure to control weld bevel angles appears to be in violation of the

AWS D1.1 Code and 10 CFR 50, Appendix B, Criterion IX.

6.

Audit of As-Built Cable Tray Support Inspection Program

The NRC inspectors could find no objective evidence that the cable tray

support as-built inspection program had been audited or scheduled to be

audited.

The failure to establish planned periodic audits of the cable tray

support as-built inspection program is considered to be in violation of

10 CFR 50, Appendix B, Criterion XVIII.

7.

Applicant Corrective Actions

The applicant promptly initiated the following corrective actions:

TUGCo Engineering was requested to document and evaluate each

finding to determine corrective action on November 22, 1985.

Stop Work was issued to field activities associated with Unit 1

as-built / inspection program on November 26, 1985.

A Corrective Action Request was issued on November 26, 1985.

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A TUGCo investigation was initiated to determine the cause.

Personnel

actions have resulted from the investigation underway.

Inspection of the as-built program Unit 2 was initiated to determine

if similar problems existed in Unit 2.

The evaluation of actions necessary to resume the as-built program

is in progress.

8.

Exit Meeting

Exit meetings were held on November 22, 1985, and December 5, 1985,

respectively, to discuss the initial and final findings from this

inspection.

A subsequent exit meeting was held with TUGCo corporate management on

December 18, 1985, to review the findings from this inspection, at which

time, potential escalated enforcement action was discussed.

Those present included:

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TUGCo

W. G. Council

J. W. Beck

NRC

R. D. Martin

V. S. Noonan

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In Reply Refer To:

Docket:

50-445/85-19

Texas Utilities Generating Company

ATTN:

Mr. W. G. Counsil

Executive Vice President

400 North Olive, L.B. 81

Dallas, Texas 75201

Gentlemen:

This refers to the special inspection conducted by Mr. T. F. Westerman,

members of the Region IV Comanche Peak Group, and NRR personnel during the

period of November 18 through December 18, 1985, of activities authorized by

NRC Construction Permit CPPR-126 for the Comanche Peak Steam Electric Station,

Unit 1, and to discussions with Mr. R. E. Camp and other members of your staff

on November 22, 1985, and December 5, 1985.

The purpose of the special inspection was to evaluate the Comanche Peak Steam

Electric Station, Unit I as-built cable tray inspection program. The

inspection identified multiple instances involving the failure to properly

inspect and document as-built cable tray attributes.

In addition, violations

were identified relative to both the failure of the QA programs to establish

QA overview and audits of the Unit 1 as-built cable tray inspection program

and the use of incorrect weld bevel angles. The violations and related NRC

concerns were discussed with you in the subsequent exit meeting held on

December 18, 1985.

No response to this letter is requested.

Enforcement actions relative to this

inspection will be forwarded under separate correspondence.

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RIV: CPG

C: CPG

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NRR

IBarnes;ap

TWesterman

EJohnson

DPowers

VNoonan

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Texas Utilities Generating Company

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Should you have any questions concerning this letter, we will be glad to

discuss them with you.

Sincerely,

E. H. Johnson, Director

Division of Reactor Safety

and Projects

Enclosure:

Appendix - NRC Inspection Report

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50-445/85-19

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cc w/ enc 1:

Texas Utilities Electric Company

ATTN:

J. W. Beck, Vice President Licensing

Quality Assurance and Nuclear Fuels

Skyway Tower

400 North Olive Street

bec to DMB (IE01)

Lock Box 81

Dallas, Texas 75201

bec distrib. by RIV:

• RPB

• MIS System

Juanita Ellis

• RRI-0PS

• RSTS Operator

President - CASE

• RRI-CONST

• R&SPB

1426 South Polk Street

• TFWesterman, CPTG

DRSP

Dallas, Texas 75114

V. Noonan, NRR

R. Martin, RA

S. Treby, ELD

• RSB

Renea Hicks

• RIV File

J. Taylor, IE

Assistant Attorney General

• D. Weiss, LFMB (AR-2015)

Environmental Protection Division

R. Heishman, IE

• D. Powers, EC

P. O. Box 12549

Austin, Texas 76711

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Texas Radiation Control Program Director