ML20199K977

Const Insp Repts 50-445/85-16 & 50-446/85-13 on 851101-30.No Violation or Deviation Noted.Major Areas Inspected:Const Deficiencies,Ie Bulletins,Qa Records,Electrical Penetrations & Electrical Insp & Installation Test Procedures

ML20199K977
Person / Time
Site:	Comanche Peak
Issue date:	04/04/1986
From:	Barnes I, Kelley D, Phillips H, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20199K948	List: ML20199K943 ML20199K963 ML20199K972 ML20199K977 ML20199L020
References
50-445-85-16, 50-446-85-13, IEB-79-14, IEB-79-28, NUDOCS 8604100269
Download: ML20199K977 (10)

See also: IR 05000445/1985016

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APPENDIX C_

CONSTRUCTION INSPECTION REPORT

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report:

50-445/85-16

Permits: CPPR-126

50-446/85-13

.CPFR-127

Dockets: 50-445

Category; A2

50-446

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Applicant: Texas Utilities Electric Company (TVEC)

Skyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas

75201

Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 & 2

Inspection At: Glen Pose, Texas

Inspection Conducted: November 1-30, 1985

(2 h/

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Inspectorst

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N. 5. Ptiillips, Senicfr Resident Redctor

Date

Inspector (SRRI), Construction,RegionIV

CPSES Group

(paragraphs 1, 2, 3, 4, 5, 6, and 8)

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D. T. Kelley, 5RRI, pperat/ons, Region IV

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CPSES Group

(paragraph 7)

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Consultants:

EG&G-J. H. McCleskey

Parameter-T. H. Young

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Reviewed By:

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I. Barnes, Grot'p Leader, Region IV CP5ES

Group

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8604100269 860404

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Approved:

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T. F. W a terman, Chief, Region IV CPSES Grcup

Date

Inspection Strncary

inspection Conc' acted: November 1-30,1965(Report 50-445L85-161

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Areas Inspected:

Routine, uncanounced in3pection of Unit I which ine'uoed

applicant actions on construction deficiencies, applicart oc'tions en previcus

Ni<C " inspection findings, IE Bulletins, QA records, and electrical cGr.etrations.

The inspection involved 143 inspector-hours onsite t'y one NRC inspector ard twa

censultants.

Results: Within the seven areas inspecteed, no violations or deviations were

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Ide?itl fied.

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A cettion Conaucteo: Sovemoer 1-30.1985 (Repyt_5f-446/05-13)

AreaLIn_ spec _ted:

Routine, anacuaced and unannounced inspection of (Jnit 2

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wnich included plent tours, applicant actioni, en corntractiori deficiencies,

applicant actions or previous NRC inspaction findings, IE Sulletins, OA

record 3, electr ical penetrations, and review of electrictsl inspection and

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installation test procedures.

The inspection itivolved 226 inspector-boors

onsite by two NRC inspectors and two consultants.

Results- Wjthin the six areas inspected, no violatfor.s or deviations were

identified.

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Pwsog ontacted

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Texas _ Utilities, Generating Company (TUCCo)

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K. Arcp> Site Design Engineer

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R. Babb, Engineer and Site Fire Protection Leader, TUGCo Nuclect

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Engiraering (TNE)

H. Cheatheam, Tecnnical Support Engineer

R. Cisneros, Special Project Group Coordinator

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9. Halstead, M'anager, Quality Control

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J. Hicks, Licent ing

J. Marshali, ticensing

J. liarri'tt, Assistant Project General Manager, Unit 2

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0. Palmer, Industrial Operating Experiente Coordinator

C. Welch, QC Services Supervisor

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Contractor Personnel

W. Baker, Engineer, Brown & Root (8&R)

D. 6alenthez, Site QC Supervisor, Brand Industrial Services Inc.

(81500)

G. Fedor, Development Engineer, BISCC, Park Ridge, Illinois

B. Kennedy, Site Project Manager, BISCO

t. Smith, Engineer, B&R

8. Wright, Engineer, B&R

The NRC inspectors also interviewed other applicant employees during this

inspectibn period.

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2.

Applicant Action on Previous NRC Insoection Findings

a.

(Cbsed) Unresolved Item (445/8119 'J-02):

Control of QA records for

pipe supports.

Procedures, had not addressed or given instructions

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for retrieval of records for items that had been completed and then

needed to be modified.

Cn October 29 and November 4, 19&S, the NRC

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inspector reviewed the applicable procedures that were implemented

from 1982 until the present.

These procedures adequately addressed

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the retrieval of completed packages from the vault when modifications

are required.

b.

(Closed) Deviatica (445/8408-D-03):

Deviation from desig,, information

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for the installation of Seismic Category I/ Seismic Category II

structural steel for the bolted connections between the part designated

W16x40 and the wall on platform OP-11 in the pressurizer compartment.

This deviation concerned a platform that was upgraded to Category I

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without a corresponding chance in details for bolted connections.

On October 24-28, 1985, the NRC inspector followed up on this item to

determine if corrective action was complete.

TUGCo's response dated

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August 23, 1984, Indicated that design change authorization

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(DCA) 19469, Revision 1, was issued to require a locking mechanism on

platform OP-11 bolts and that the DCA addressed locking devices.

The

response also indicated that a complete review of the " hand-tight"

instruction would be complete by October 1,1984. .The last DCA was

issued in July 1985 to cover this issue.

The NRC inspector took a

sample of 17 DCAs and one drawing that had been generated or revised

to address the " hand-tight" issue.

These all showed that locking

devices were required where potential movement and backing off of nuts

must be addressed.

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c.

(Closed) Violation (445/8422-V-03):

Unit I unauthorized removal of

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BISCO fire seal.

The applicant initiated corrective action which

included:

(1) providing training to construction to reindoctrinate

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(2) performing a walkdown

them on CPSES rules and policies s

inspection of Unit 1, and (3) initiating programmatic controls for

construction.

The NRC inspector reviewed the following documentation

of the corrective actions:

T-141, TUGC0 CAR-038, IM No. 27535 dated

August 3, 1984, and also the practice of using discrete constructioa

packages containing the necessary instruction and forms to complete

the specified work.

d.

(Closed) Unresolved Item (445/8426-U-03):

As-built notation on field

sketch instrument number (FSI) drawings.

There was a question on one

"as-built" notation on FSI drawings.

During November 6 and 7, 1985,

the NRC inspector followed up on this item to determine if the

applicant had completed the actions they agreed to complete.

Sample

copies of six of the drawings in question were requested at the

central document control center (OCC).

All had been stamped "for

reference purposes only." Also, the drawings at the central DCC and

four other distribution points are stamped "for office and

engineering use only" when issued.

None of the drawings had

"as-built" on them.

This action satisfies the NRC concerns.

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e.

(Closed) Unresolved Item (445/8432-U-01, 446/8432-U-01): TUGCo

organization.

On November 1, 1985, the NRC inspector reviewed this

unresolved item.

The essistant project general manager of TUGCo

still reports to two different vice presidents; however, a third vice

president is responsible for licensing, nuclear fuel, and quality'

assurance (QA),

The Of rector of QA reports directly to the TUGCo

Vice President, Licensing, Nuclear Fuel and QA.

This separation is

acceptable from a cost and scheduling standpoint and the reporting

level is sufficiently high to provide organizational freedom for

organizations performing QA functions.

This concern is reflected in

the CPSES QA Plan, Section 1.1, Quality Assurance Division, which was

revised October 18, 1985.

f.

(0 pen) Unresolved Item (445/8514-U-02, 446/8511-U-01):

Procedures do

not address 10 CFR Part 50,55(e) file content or provide a method for

completion /signoff for corrected construction deficiencies.

The NRC

inspector reviewed TUGCo Procedure NEO CS-1 entitled, " Evaluation of

and Reporting).of Iteru/ Events Under 10 CFR Part 21 and 10 CFR

Part50.55(e

The review revealed that the following procedures

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were inconsistent with Procedure NE0 CS-1:

CP-QP-16.1, Revision 6,

dated January 16, 1985; TNE-AD-5, Revision 3, dated June 21, 1984;

DQP-QA-12, Revision 2, dated September 9, 1985; and CP-QP-15.6,

Revision 3, dated January 16, 1985.

The inconsistencies included

conflicting responsibilities, method of evaluation, repo*tability

criteria, notification policy, and reporting instructions.

TUGCo has committed to the resolution of file tracking problems and

procedural inconsistencies by March 1, 1986.

g.

(0 pen) Unresolved Item (445/8514-U-03, 446/8511-U-02):

Incomplete

significant deficiency analysis report files.

TUGCo has indicated

that actions are being taken to identify all records necessary to

close out open files.

This action is scheduled to be completed by

March 1, 1986.

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h.

(0 pen) Unresolved Item (445/8422-U-04):

Material certification for

electrical penetration seals.

The NRC inspector quet,tioned the

certification of the chemical and physical testing.

In response,

TUGCo provided BISCO certificate of compliance (C0C) Nos. 3057, 3081,

2893, and the BISCO site receiving inspection checklist for Purchase

Order (PO) Nos. 2730 and 2773. There was a statement that the

articles complied with all P0 specification requirements (2323-MS-38F);

however, no reference was made to the DOW Corning, Inc., chemical and

physical testing of the subject material.

This item remains open

pending the receipt of a C0C which certifies that this material meets

such test requirements or DOW test results.

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During this inspection, the NRC inspector found other documentation

and hardware issues which are discussed in paragraph 6 of this report.

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3.

Applicant Action on 10 CFR Part 50.55(e) Deficiencies:

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The NRC inspectors evaluated corrective action taken on reportable

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deficiencies by reviewing TUGCo deficiency reports. The inspector found no

corrective action completion date for CP-84-29, "HVAC Fire Scenarlo."

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was noted that corrective action for deficiency CP-84-27. " Ventilation

Exhaust Dampers," was to be completed for Unit I by September 1985 and for

Unit 2 before startup testing. However, as of November 30, 1985, Unit 1

deficiencies were not corrected and it was not clear how corrective action

for Unit 2 will be tracked. Deficiencies CP-85-13 and CP-85-05, which are

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described in deficiency reports and the open items list, also give no

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corrective action dates.

Several final 10 CFR Part 50.55(e) reports contained corrective action

completion dates; however, work was neither completed by the reported date

nor was a supplemental report made to the NRC to report on significant

corrective action date changes.

Deficiency report for CP-84-31 " Control

Room Separation Wall," stated that corrective action was scheduled for

completion by December 15, 1984; however, it was not completed as of

November 30, 1985.

Similarly, deficiency reports for CP-85-11. " Instrument

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Fitting Locations," and CP-85-12 " Auxiliary Feedwater Pressure Control "

stated that corrective action was scheduled to be completed for Unit 1 by

May 1985. The open items list indicated that they were not completed on

November 30, 1985.

TUGCo management has assembled a task force consisting of four to five

engineers or specialists to evaluate and take action on the matters

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described above. This item is unresolved (445/8516-U-01, 446/8513-U-01).

No violations or deviations were identified.

4.

Applicant Action on IE Bulletins (IEBs)

a.

In response to discussions regarding the TUGCo program concerning IEBs,

Circulars, and Infomation Notices, Region IV was informed that TUGCo

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will perform a review of related procedures and records to determine

the adequacy of procedures and the completeness of associated records.

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The initiation of this effort will follow the task review of the

10 CFR Part 50.55(e) program which is presently in progress.

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This item is unresolved (445/8516-U-02, 446/8513-U-02).

b.

The TUGCo actions on two IEBs (i.e., Nos. 79-14 and 79-28) were

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selected to revicw hardware evaluations or repair / replacements. TUGCo

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10ER Log Sheet, page 10, dated April 9, 1984, was reviewed to

determine the status of the IEBs.

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(1)

IEB 79-14 was evaluated by TUGCo in 1983 and was statused as

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closed. The NRC inspector indicated that the closure of IEB 79-14

was premature since Stone & Webster is currently analyzing Unit 1

seismic analysis versus as-built drewings, which directly relates

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to this IEB. Unit 2 as-built work has also not been completed.

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TUGCo stated that the IEB 79-14 file will be reopened and a

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supplemental report will be submitted upon completion of the

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ongoing project engireering work.

Theaboveitem(IEBNo.79-14)statusisconsideredanopenitem

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(445/8516-0-03,446/8513-0-03).

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(2)

IEB 79-28 identified deficiencies with certain manufactured lots

of NAMCO EA 180 limit switches. The gasket material of the

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faulty lots, when exposed to temperatures above 175"F, vaporized

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and emitted a yellow-brown crystal like resin that can cause these

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switches to fail. The NRC inspector found the TUGCo documentation

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to be complete with respect to the specified corrective action of

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replacing these switches with switches manufacturt.d in acceptable

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Field verification of replacement of 14 switches identified,

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however, that the identity of 2 switches could not be traced to

existing travelers. Specifically, the replacement NAMCO limit

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switches on residual heat removal valves 1-HCV-606 and 1-FCV-618

were identified on travelers EE 82-1415-5801 and EE 83-0373-5801

as EA 180-32302 and EA 170-31302, respectively.

The switches

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actually installed in the field were identified as EA 180-31302

and EA 180-31302, respectively.

TUGCo is evaluating this

inconsistency to determine if there is other documentation to

account for this.

This item is unresolved (445/8516-U-04, 446/8513-U-04).

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5.

QA Records Retention

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The NRC inspectors found that construction deficiency and IEB files were

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not stored in the QA records vaults.

Because such records have not been

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deposited in a central location, difficulties have been encountered in

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retrieval.

TUGCo is assessing this record file issue.

This item is open pending the completion of their review (445/8516-0-05,

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6.

Electrical Penetrations

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In NRC Inspection Report 50-445/84-22 dated October 11, 1984, the

certification of BISCO electrical penetration seals (fire barriers) was

questioned with respect to the testing of the seals.

During the followup

of this item, which is discussed in paragraph 2.h above, the NRC inspector

identified related but different findings.

The NRC inspector reviewed the records to determine if the documentation

for eight 815C0 seals support the certification statement. The eight

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penetrations inspected were; AB-790-174-1022A, EC-854-150A-1018A and-1018B,

EC-854-151A-2003A and-2004A, EC-854-1518-2025A and-2026A, and

TB-803-010A-1008A.

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The following documents contained apparent conflicting information that the

NRC inspector has identified for further followup:

BISCO letter to TUGCo dated November 13, 1984, answered the NRC

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certification inquiry and stated that the subject fire barrier seal

(Test No. PCA-76, ANI No. S-26, 24"x42", floor / wall, material 6548,

9 inches depth, LAD or SLD tray, all cables, 40% loaded) met all test

requirements of TUGCo Contract No. CP-0707, Gibbs & Hill

Specification 2323-MS-38F, ASTM E-119, and IEEE 634.

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American Nuclear Insurers (ANI) letter to BISCO dated August 20, 1985,

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withdrew its acceptance of BISCO SF-20 (1977) Silicone or Dow Corning

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3-6548 RTV Silicone foam for 2- and 3-hour rating without a damming

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board left in place.

The NRC inspectors ascertained that this

withdrawal was based on BISCO not having complete documentation of

the test results and the recent failure of a BISCO sample tested at

an independent laboratory employed by the ANI.

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ANI letter dated August 20, 1985, to TUGCo informed them of the

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rescinded acceptance and the test failure that occurred 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and

35 minutes into the independent test performed in accordance with

ASTM E-119.

Further, it stated that this fire barrier may not be

adequate where there is a strict requirement for a barrier with a

3-hour rating.

Comanche Peak Final Safety Analysis Report (FSAR), page 9.5-223,

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requires that penetration seals be tested in accordance with

ASTM E-119 and IEEE 634.

FSAR Section 9.5, paragraph D.1.c. requires:

(1) each cable spreading room should be separated from other areas of

the plant by barriers with a minimum fire resistance of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, and

(2) cabling for redundant safety divisions should be separated by

walls having a 3-hour rating as a fire barrier.

Section 9.5,

paragraph D.3.c. requires a 3-hour rating for barriers for cable trays

that contain cold shutdown cabling.

TUGCo Design Deficiency Report (T00R) No. FP-85-063 dated August 29,

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1985, documented the deficiency.

On the same report, the deficiency

was marked not reportable in the 10 CFR Part 21 and Part 50.55(e)

reportable block.

The corrective action was for BISCO to prove

satisfactory testing of the failed seal and all other ANI accepted

seals.

Note:

The evaluation of reportability is being reevaluated by TUGCo.

BISCO letter dated September 16, 1985, stated that approval had been

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rescinded because the hose stream test data was destroyed or lost

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during either a 1976 fire or a subsequent move to another facility.

It also stated that the ANI testing standards are much more stringent

and stated that BISCO seals meet and surpass the test standards of

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ASTM E-119.

The letter turther stated that the ANI representative

witnessed a test on 9-inch silicone foam using the same design

configuration that failed in the ANI test.

However, the letter also

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stated that the success of this BISCO test was based on applying a

3/8-inch proprietary coating on the face of the silicone foam.

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letter stated that this retrofit corrective measure can be employed

by those who wish to upgrade this particular seal design.

Note:

It appears that the original seals that were tested had no

. coating.

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TUGCo interoffice memorandum (Creamer to Kennedy) dated October 16,

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1985, discussed the rework of all seals affected by ANI disapproval

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of S-26.

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BISCO memorandum to TUGCo (Trent to Anger) dated October 24, 1985,

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identified eight penetrations to be reworked.

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The letters discussed above appeared to contain conflicting statements.

The BISCO letters dated November 13, 1984, and September 16, 1985, differed

in that the first one certified to meeting ASTM E-119 and IEEE 634 test

requirements, while the latter only mentioned ASTM E-119. The September 16,

1985, letter also stated that BISCO recently retested the original design

configuration and it passed; however, in the same paragraph on page 2 they

stated that they added a 3/8-inch proprietary coating, which according to

TUGCo is not on their barriers that are installed.

In the same paragraph,

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BISCO discussed this coating as if it were a retrofit and/or a design

change. Thus, BISCO's claim that their retest was successful appears to be

based on testing an upgraded test sample. The ANI letter to TUGCo, dated

August 20, 1985, stated that their test was in accordance with ASTM E-119;

however, BISCO claimed that the ANI test exceeded ASTM E-119 requirements

and thus is an inconsistency.

It is also unclear as to how many test

failures have occurred.

Indications are that there were two recent

failures, an ANI test and a BISCO test failure.

The following items are unresolved pending clarification or resolution:

a.

Reevaluation of available 1976 test documentation and recent test

failures for 10 CFR Part 21 and 10 CFR Part 50.55(e) reportability

(445/8516-U-06,446/8513-U-06).

b.

Inconsistent test methods and/or test results documented by BISCO and

the ANI test laboratories for the specific design configuration

PCA-76 (ANI No. S-26) for which the ANI rescinded acceptance and also

the completion of TDDR No. FP-85-063 required corrective actions

(445/8516-U-07,446/8513-U-07).

7.

Review of Electrical Inspection and Installation / Test Procedures

The NRC inspector completed the review of the applicant's QA/QC program

and procedures relating to the installation of electrical components'and

cables.

In addition, a review of the electrical installation / test proce-

dures was conducted. The areas covered in the review were: organizational

structure and personnel, audits, quality requirements, work and quality-

inspection procedures, control of material, control of processes, correc-

tive action, document control, test control, control of test equipment,

quality records, and onsite design control.

In order to identify specific criteria-in the above areas, a review was

conducted of Sections 7, 8, and 17 of the applicant's FSAR to identify the

commitments pertaining to the installation of electrical components and

cables. The tabulation consisted of the pertinent regulatory' guides

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standards, and specific alternative programs. The specific commitments,

coupled with the requirements of of Appendix B to 10 CFR Part 50, form _ the

criteria by which the QA/QC program is judged.

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A second examination was conducted to identify the QA/QC program specifics

and procedures which pertained to the installation of electrical components

and cables. The program and procedures were then compared to the FSAR

commitments and 10 CFR Part 50, Appendix B criteria to determine if the

program and procedures adequately addressed the required criteria.

The following procedures were reviewed: (a) Inspection Procedures QP-11.3-27,

Revision 11; QP-ll.3-28, Revision 28; QP-11.3-29, Revision 17; QP-11.2-29.1,

Revision 18; QP-11.3-31, Revision 8; QP-11.3-38, Revision 7; QP-11.3-40,

Revision 2; QP-11.3-41 Revision 5; QP-11.3-43, Revision 19; OP-11.3-44,

Revision 16; (b) Installation / Test Procedures EEI-5, Revision 3; EEI-6,

Revision 6; eel-7, Revision 5; EEI-8, Revision 5; EEI-13, Revision 4;

EEI-16, Revision 0; EEI-18, Revision 3; EEI-21, Revision 0; EEI-23

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Rev.ision 1; EEI-26, Revision 0; ECP-20, Revision 0; and (c) Administrative

Procedure CPM-6.3, Revision 11.

No violations or deviations were identified.

8.

Exit Interview

An exit interview was conducted December 4,1985, with the applicant

representatives identified in paragraph 1 of Appendix D of this report.

During this interview, the NRC inspectors summarized the scope and findings

of the inspection. The applicant acknowledged the findings. Subsequent to

this interview, the NRC inspector notified the applicant with respect to

the failure to report the 10 CFR Part 50.55(e) deficiency described in

paragraph 6 above.

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