IR 05000445/1986006: Difference between revisions

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{{Adams
{{Adams
| number = ML20212P737
| number = ML20210S473
| issue date = 08/21/1986
| issue date = 02/10/1987
| title = Insp Repts 50-445/86-06 & 50-446/86-04 on 860201-0331. Violations Noted:Failure to Address Spec Criteria for Cable Installation in Procedures,Improper Cable Placement & Failure to Install Cable Support Grips
| title = Ack Receipt of 861009,31 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/86-06 & 50-446/86-04
| author name = Barnes I, Michaud P, Phillips H, Wagner P
| author name = Johnson E
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name =  
| addressee name = Counsil W
| addressee affiliation =  
| addressee affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| docket = 05000445, 05000446
| docket = 05000445, 05000446
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-445-86-06, 50-445-86-6, 50-446-86-04, 50-446-86-4, NUDOCS 8609030256
| document report number = NUDOCS 8702170638
| package number = ML20212P724
| title reference date = 01-22-1987
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 13
| page count = 2
}}
}}


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APPENDIX B, CONSTRUCTION INSPECTION REPORT U.S. NUCLEAR REGULATORY COMMISSION
In Reply Refer To:'  FEB I O INT Dockets: 50-445/86-06 50-446/86-04 Texas Utilities Generating Company ATTN: Mr. W. G. Counsil Executive Vice President 400 North Olive L.B. 81 Dallas, Texas 75201 Gentlemen:
Thank you for your letters of October 9,1986, October 31, 1986, and January 22, 1987, in response to our letters and Notice of Violation dated August 26, 1986, ar.d December 30, 1986. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.


==REGION IV==
Sincerely,
NRC Inspection Report: 50-445/86-06  Permits: CPPR-126 50-446/86-04  CPPR-127 Dockets: 50-445  Category: A2 50-446 Applicant: Texas Utilities Electric Company (TVEC)
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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 Rose, Texas Inspection Conducted: February 1 through March 31, 1986 Inspectors:  zg [.#/
svaal signed By
H. S. Phillips, SenioTr Resident Reactor 7 Mf4 Date Inspector (SRRI), Construction, Region IV CPSES Group (paragraphs 1, 2, 3, 4, 5, 6a, and 9)
      /Tl HHf E. H. Johnson, Director Division of Reactor Safety and Projects cc:
  @ C. 03 % h  B/ie/66 Date P. C. Wagner, Reactor g pector, Region IV CPSES (paragraphGroup 7 )
Texas Utilities Electric Company ATTN: G. S. Keeley, Manager Licensing Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 RIV:CPRTh  CPRT .5F '
8w  Tb/f94 F P. Michaud, Reactor Inspector, Region IV Date (paragraph 8)
PCWagner:gb  IBarnes 2. /1 /87
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      /"DRP EHJohnson 2./$ /87    1/y/87 l$P!888! 8?88;go    / {' D PDR  \
Consultants: EG&G-J.11. McCleskey (paragraphs 2, 4, and 6b)
8609030256 e60826 DR ADOCK0500g5
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= Texas Utilities Generating 2 Company Juanita Ellis President - CASE 1426 South Polk Street Dallas, Texas 75224 Renea Hicks Assistant Attorney General Environmental Protection Division P. O. Box 12548 Austin, Texas 78711-2548 Administrative Judge Peter Bloch U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Elizabeth B. Jahrson Administrative Judge Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Dr. Kenneth A. McCollom 1107 West Knapp  ,
Stillwater, Oklahoma 74075 Dr. Walter H. Jordan 881 Outer Drive Oak Ridge Tennessee 37830 Anthony Roisman, Esq.


Parameter-J.' C. Gibson (paragraph 7)
Executive Director Trial Lawyers for Public Justice 2000 P. Street, N.W. Suite 611 Washington, D.C. 20036 Texas Radiation Control Program Director bec to DMB (IE01)
Approved: bw  P/2-1/F6 1. Barnes, Chief, Region I Date CPSES Group Inspection Summary Inspection Conducted: February 1 through March 31, 1986 (Report 50-445/86-06)
bec distrib. by RIV:
Areas Inspected: Routine, unannounced inspections of Unit I which included a plant tour of the reactor, safeguards, electrical control and auxiliary buildings; applicant actions on previous inspection findings; structural steel and steel support safety-related components; and safety-related pipe supports and restraint Results: Within the four areas inspected, no violation or deviations were identifie Inspection Conducted: February 1 through March 31, 1986 (Report 50-446/86-C4J Areas Inspected:
*RPB  * MIS System
  ~
*RRI-0PS  *RSTS Operator
Routine, announced and unannounced inspections of Unit 2 which included plant tours of the reactor, safeguards, diesel generator, electrical control, and auxiliary buildings; applicant actions on previous inspection findings; structural steel and steel supports; reactor coolant loop pipe welding; safety-related components, and electrical cable installatio Results: Within the seven areas inspected, two violations (failure to address specification criteria for cable installation in procedures and improper placement of cables, paragraph 7; failure to install cable support grips as required, paragraph 7) were identifie l l
*RRI-CONST  *R&SPB
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*T. F. Westerman, RSB DRSP V. Noonan, NRR  R. Martin, RA L. Chandler, OGC *RSB
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*RIV File  J. Taylor, IE
*D. Weiss, RM/ALF J. Conklin, IE
*I. Barnes, CPTG * Project Inspector
*R. Hall  P. Wagner
*w/766


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!      Leg # TXX-6213 File # 10130 IR 86-06
*  TEXAS UTILITIES GENERATING COMPANY    IR 86-04 SKYWAY TOWER . 489 NORTH OLIVE STREET. LB. 88 . DALLAS, TEXAS 7M01 January 22, 1987    ~~~- '
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%?&^*.L #.U E      ; # ? 6198'l Mr. Eric H. Johnson, Director    I. , _
Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission    L-611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT NOS.: 50-445/86-06 AND 50-445/86-04 SUPPLEMENTAL RESPONSE FOR INFORMATION TO NRC NOTICE OF VIOLATION (N0V) ITEM A(2)
REF: 1. TUGC0 Letter TXX-5037 from W. G. Counsil to E. dated October 9, 1986.


DETAILS Persons Contacted Applicant Personnel
2. TUGC0 Letter TXX-6071 from W. G. Counsil to E. dated October 31, 1986.
***J. Barker, Executive Assistant to Executive Vice President, Texas Utilities Generating Co. (TUGCo)
***J. Beck, Vice President, TUGCo
***T. Brandt, Quality Engineering (QE) Supervisor, EBASCO ,
***R. Camp, Assistant Project General Manager, Unit 1, Impell~ .
***W. Counsil, Executive Vice President, TUGCo  .
J. Crim, Civil Structural Engineer, TUGCo B. Dacko, Licensing Engineer, TUGCo
*P. Halstead, Manager, Quality Control (QC)
C. McClaskey, QE, EBASCO  - - .
* Merritt, Director of Construction, TUGCo  -
* Streeter, Director of Quality Assurance (QA), TUGCo  -
** Redding, Executive Assistant, TUGCo
** Tyler, CPRT Program Director, TUGCo J. Walker, Quality Engineer, TUGCo Contractor Personnel B. Baker, Welding Engineer, Brown & Root Inc. (B&R)
8. Bhujang, Principal Engineer Civil / Structural, Gibbs & Hill Inc. (G&H)
H. Porter, Welding Engineer, B&R G. Purdy, QA Manager, B&R D. Wheland, QA Records Review, B&R C. Woodard, Paper Flow Group Review, B&R B. Wright, Welding Engineer, B&R The NRC inspectors also interviewed other applicant and contractor personnel during this inspection perio * Denotes personnel present at the February exi ** Denotes personnel present at the March exi *** Denotes personnel present at both exit . Applicant Actions on Previous Inspection Findings (Closed) Unresolved Item (445/8514-U-02; 446/8511-U-01): SDAR files do not contain sufficient information. The NRC inspector reviewed the following reportable /nonreportable construction deficiency file Nos. CP-82-12, CP-84-17, CP-83-20 and CP-84-16, CP-82-13, CP-84-14, CP-84-19, and CP-84-20, respectively, and found that the files now contain complete auditable documentation, l
 
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4 (0 pen) Unresolved Items (445/8516-U-01; 446/8513-U-01): TUGCo Task Force (TTF) to review SDAR system. The NRC inspector reviewed the status of the TTF effort and found it to be incomplete. The TTF review covers only construction deficiencies which have not been inspected and documented in NRC inspection reports. The following files were reviewed and were complete: (1) reportable items CP-82-12, CP-84-17,andCP-83-20,and(2)nonreportableitemsCP-82-13, CP-84-14 and CP-83-16, CP-84-19, and CP-84-20. From a preliminary list of completed items, only two hardware issues were ready for inspection; 1.e., the " George Washington Bridge" weld failures and a Chiller System room flooding evaluation;- The Chiller System was selected and the NRC field inspection verified corrective actio At the end of March 1986 the status of the review was 87 still in review process, and 36 completed and ready for NRC inspection., ,
      - (0 pen) Unresolved Item (445/8516-U-02;~446/8513-U-02): TTF to review IE Bulletins. NRC inspectors have previously' inspected TUGCo's system for receiving, distributing, and reporting on IE' Bulletin These inspections were documented in NRC Inspection .
Reports 445/84-07, 446/84-06; 445/84-22, 446/84-07; 445/84-29,
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446/84-10; and_445/85-16, 446/85-1 These previous NRC inspections consisted of a review of'IE Bulletin files for the period 1975-1984 for Units 1 and 2 and concentrated on evaluating the TUGCo system for handling IE Bulletins. During this
 
inspection, the NRC inspector determined that IE Bulletins 75-05, 75-06, 76-06, 77-04, 77-05, 77-06, 77-08, 79-01, 79-28, 80-18, 81-02, 81-03, 83-05 and 84-03 required either repair, rework, replacement, or engineering evaluation. These IE Bulletins are considered open pending an NRC field inspection of selected hardware or engineering evaluations required by the IE Bulletin.


; In addition to the previously referenced IE Bulletins, IE Bulletins 85-01, 85-02, and 85-03 will be inspected after the TTF completes their review of their present system for handling IE Bulletin Neither the IE Bulletin files nor the actions taken were ready for inspection. The records were still not in the QA vaul No violations or deviations were identifie . General Plant Inspections, Units 1 and 2 At various times during the inspection period, the NRC inspector conducted inspections of the Unit 1 and 2 reactor, safeguards, electrical / control, auxiliary buildings, and the Unit 2 diesel generator building. Almost all of the rooms in these buildings were inspected to observe current work
==Dear Mr. Johnson:==
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We have reviewed your letter dated December 30, 1986, requesting additional information to our responses referenced above regarding NOV 445/8604-V-02 (Item A(2)). We hereby respond to the request for supplemental information in the attachment to this letter.


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Very truly yours, h  th b W. G. ouns 1 By: [, . /
G. S. Keeley W/y Manager, Nuclear ticensing RSB/amb:lw Attachment c - NRC Region IV (0 + 1 copy)
Director, Inspection and Enforcement (15 copies)
U. S. Nuclear Regulatory Commission Washington, D. C. 20555


activities or major safety-related equipment which was stored in plac The storage inside these buildings and the area for steel supports located just outside Unit 2 were also inspecte A special inspection was performed in Unit 1 during TUGCo's self imposed stop work which resulted from the expiration of the Unit 1 construction permit CPPR-126. The NRC inspector observed no unauthorized work activit NRC licensing letter dated February 10, 1986, extended the subject permit to August 1, 198 During this inspection period, two backshift inspections were performed on the second shift (4-12pm). Work activities in the Unit 2 reactor, safeguards, and diesel generator buildings were observed. The NRC inspector also observed the cleaning of the Unit 2 condensate storage tank. Two minor unsatisfactory in place storage conditions were identified; i.e., in Rooms 73 and 74 in the Unit 2 safeguards building, the splined shafts of the feedwater pumps h61 been decoupled from the motors without the machined surfaces being covered and protected. Workers in this area immediately covered these surfaces and the NRC inspector !
Mr. V. S. Noonan Mr. D. L. Kelley
considered this matter close The NRC inspector observed the following Unit 2 work activities:
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ACTIVITY  BUILDING DESCRIPTION  ROOM RESULTS Welding of  SGB  Per drawing E2 1703 electrical  Room 83 and 1703-0 ground cabinet T22-KEB-J-1 In place storage SGB  Access to these breaker control Room 83 components was controlled cabinets for: safety  and in place storage was injection pump #21,  satisfactory. Components RHR pump #23,   were protected from auxiljary feedwater  overhead weldin pump #21, component cooling water pump
a vunsuov er nus cruurua mcmc corunn   b '
#21, and incoming breaker BOS 2A In place storage, SGB Room 80 This material was two cable reels,  properly identified and orange color codestore W-706-6 and W-706- Ir place storage SGB  In place storage letdown heat  Room 80 satisfactor exchange .
pv ms    -Ywe% +'


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        . Welding of station  SGB Drawing BRP-SW-2-SB-03 service water lin Room 53 Welds 1A and 7A, cleanliness and fitup, were acceptabl Welding of diesel  SGB Room 85 In process weld per generator ski Drawing MSB-2605-D 601 by welder BJI using WPS10046, Weld Data Card 84-7146-2-3003, and
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Procedure CCP-22. Weld current being used was as required. Thirteen portable weld ovens in this area were checked
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and were acceptabl Welding of structural SGB Observed 3 piece parts steel suppor Room 77 (C23G-2-8835-1-01) that were fillet welde These welds were measured to be greater than the required 1/4 inch. The weld was made by welder (symbol COT). Electrical  SGB Witnessed part of terminatio Room 103 termination operation of conductor NK028373, points 1-12, in junction box JB 2S-922 and appeared to be acceptabl Completed welding on RCB The 1-inch plate main steam line  none (6041-2-5) shown on restrain , drawing MS2-003-414C72K had a rounded indication which initially appeared unacceptabl A review of the visual acceptance i'          criteria in ASME Section III, Division 1, subsection NF, showed it to be acceptabl No violations or deviations were identifie I l
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. Attachment to TXX-6213'
January 22,--1986 Page 1 of 2
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NOTICE OF VIOLATION ITEM A(2) 446/8604-V-02 SUPPLEMENTAL REQUEST FOR INFORMATION In your response to Item A(2), you mention that problems related to the overflowing of electrical cable from the cable trays that were identified by the NRC inspector had been previously identified by applicant personnel and were in the process of being reworked. Accordingly, you did not agree that the NRC identified condition was a violation and, therefore, did not provide the information required by the NOV.


4. Structural Steel and Steel Supports, Units 1 and 2 The NRC inspector inspected structural steel and supports inside and outside containment. Since the work had been completed in most instances, the completed work and records were inspected and reviewed instead of observing in process work activitie Reactor Building Containment Liner Welding, Unit 2: The NRC inspector reviewed the Final Safety Analysis Report (FSAR),
Based on our review of the information provided in your response and additional information provided by members of your staff, we cannot agree that the cited condition had been, or necessarily would have been, identified as a result of the rework that had been undertaken. While we agree that many of the same cables were involved in both the NRC identified condition of overflowing cable tray siderails and the rework being conducted, we disagree ;
paragraphs 3.1.5 and 3.8, to identify the design and structural requirements. G&H Specification 2323-SS-14 implements FSAR commitments and describes how the containment liner steel is designed to meet -the pressures and temperatures from a spectrum of loss of coolant accidents and secondary system ruptures. A review of this specification indicated to the NRC inspector that it meets the proposed American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section III, Division 2, Subgroup on Concrete Components, and American Concrete Institute (ACI) 359. Chicago Bridge & Iron (CB&I) Contract 74-2428 and associated file folders (Nos. 3.0, 4.1.2, 4.1.5, 5.1, 5.2, 5.5, 6.1, 7.2.1, 7.3, 7.4, 7.6.3, 7.1.1, 7.7.2, 7.7.3, 7.9, 7.10, 8.1, 8.4, 8.5, 8.6.1, 8.6.2, 8.7, 8.9, 8.10, 8.11, 8.12, 8.16.2, 8.19 and radiographic film) were reviewed to determine whether the steel liner was assembled and installed as required. Four specific welds in the containment liner were chosen for detailed review. For each of the welds, the file folders identified the following: weld unique identification, location, weld procedure used, weld procedure qualification, weld material, weld material certification (chemical and physical), welder identification, welder qualifications, nondestructive examination (NDE) records, NDE procedures, NDE procedure qualifications, NDE inspection records, NDE performed at specified hold points by qualified inspectors using appropriate test equipment which was
that the NRC identified problem would necessarily have been resolved by pulling the cables back to remove interlacing and then reinstalling these cables in the same size cable tray. In addition, the NRC inspector did not identify any QC hold tags (indicating an identified problem) during the NRC inspection.
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calibrated at documented intervals.


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SUPPLEMENTAL RESPG : TO ITEM A(2)
Nonconformance reports (NCRs) were included in folders 3.0 and These reports showed a description of the problem, review and recommended corrective action, review and signoff for the completed NCR. File folder 8.6.P. was an NCR control list which showed the various steps for each NCR, with a signoff and date for acceptanc Onsite receiving reports showed inspection of the required document The containment steel liner welding records were found to be in order and are stored onsite in the permanent plant records vault (PPRV), Unit 1 and Unit Safety Injection Vertical Restraint Welding, Unit 2: The NRC inspector reviewed paragraphs 3.2 and 6.3 in the FSAR to identify the design and structural requirements. G&H Specification 2323-SS-16B
As a result of discussions with the NRC Resident Inspector and our review of this violation, we have determined that a revision to our response is required. The revised response below will provide the supplemental information requested.
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1. Reason for Violation f We admit the violation, and the requested information follows.
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implements the FSAR commitments and describes how the Safety Injection System (SIS) is designed to meet the reactor coolant cooling requirements of a design bases acciden The SIS pipe whip vertical restraint work was divided into eight packages, an upper and lower package for each of the four reactor coolant loops in the reactor containment building. The assemblies are located in each of the reactor coolant pump rooms in the reactor containment building. The supports were constructed using ASME SA540, B23 and B24, class 2 steel. Westinghouse Inc. contract CP-0001 and two of the eight associated B&R document packages (travelers CD84-318-02-8902 and CD84-316-02-8902) were reviewed by the NRC inspector to determine that the installation of this portion of the SIS was accomplished as required. Other documents included in the review were Westinghouse Drawing 22415, Sheet 5, and Quality Release 53333; Teledyne P0 No. 217359; and material certification for Heat No. D744 During the onsite assembly and partial fabrication of the SIS pipe whip vertical restraint, field travelers were used to control the work. Esch traveler identified steps in the work to be performed, hold points for QC inspection, and review and approval of the completed traveler package. The package contained weld history records fer each weld which included or identified the weld location,
The deficiences noted in this violation involving unacceptable cable installation'were the result of corrective actions in progress per NCR E-85-101983 and inadequacies in the cited TUGC0 Inspection Instruction QI-QP-11.3-26 and B&R Construction Procedure EEI-7. Specifically, criteria governing the installation and inspection of electrical cable were found insufficient to prevent the improper cable installation identified in the NOV.
! fit up inspection, weld procedures, welder ID, and the weld filler material log. This log identified the issued weld material, the welder withdrawing the material, amount withdrawn, amount returned, and dates. Also included or identified in the package were NDE records, NDE procedures, weld repair records, weld procedures, visual inspection reports, magnetic particle inspection reports, engineering as-built drawings, design change authorizations (DCAs), and a structural assembly verification card (SAVC). The SAVC is a written checklist which verifies that the materials used in the assembly are traceable to material certification documents. One NCR was written against package CD84-316. This NCR described the problem which was reviewed and identified and the corrective action which was reviewed and approved. .0nsite documentation providing support to the packages were NDE proceduro qualification, NDE inspector qualification, weld procedure qualification, and welder qualification records. Other supporting packages from Westinghouse contained the chemical,
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physical, and Charpy V-notch test result c. Diesel Generator Skid Support Steel, Unit 2: The NRC inspector reviewed FSAR paragraphs 3.2, 3.8, 8.3, 9.5.5, and 9.5.8 to identify the design and structural requirements. G8H Specification 2323-MS-034
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implements FSAR commitments and descrihes how the diesel generators are designed to meet the requirements of a design basis acciden Delaval Turbine Inc., Engine and Compressor Division Order No. 76001/04, receiving inspection reports (RIRs), and Drawings MSB-2606-DG36-WZ, MSB-2605-DG37-WY, and MSB-2605-DG37-XA were reviewed by the NRC inspector to determine whether installation of
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2. Corrective Steos Taken A request for engineering clarification (RFIC E-11180) was initiated on March 4,1986 requesting engineering to evaluate cable tray nodes T240SF001, 02, 03, 04, and 05 for siderails and to document installation l
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problems encountered during cable rework associated with NCR E-85-101983.


selected skid steel and piping components of the Train B diesel generator were accomplished as require DCAs were issued against the skid support steel and associated cooling water lines. The required DCA work was performed onsite. The skid offsite and onsite construction records were found by the NRC inspector to be in order and stored in the PPRV and the Interim Records Vault (IRV).
i A design change (DCA #24,289) was issued on April 4, 1986, to replace the
 
The diesel generator skid and parts were receipt inspected, stored, installed, and inspected by qualified inspectors using appropriate test equipment. The specifications of the materials and componer.ts used in the assembly of the skid were verified. The required manufacturing and construction records included chemical and physical test certifications, drawings, and installation records which were apprcpriately verified by QC personne The NRC inspector determined that the PPRV and IRV documents were legible, retrievable, and showed that required inspection activities were complete Documentation for QC and NDE personnel used both offsite and onsite for this project show that they were qualified at the time inspections and tests were performed. The weld and NDE procedures that were used had documented qualification records. The welders used for the modification were documented as being qualified to the procedures used for the welding. The QC and NDE personnel used appropriate testing equipment which was calibrated at the time of the testing and was scheduled for calibration at regular interval During the modification of the diesel generator steel skid supports and coolant lines, weld history records were maintained for each of the 20 welds reviewed. These records included or referenced NDE records, NDE procedures, weld procedures, weld material records, welder identification, and weld repair record The weld material documented the date, size, class of the weld, welder identification, heat number of material and amount issued / amount returned, and the weld procedure. The modification records contained NCRs which described the problem, corrective action, and contained signoffs for review and approva d. Reactor Makeup Water Storage Tank, Unit 2: The NRC inspector reviewed FSAR paragraphs 3.2, 3.8.4, and 9.2.3 to identify the design and structural requirements. G&H Specifications 2323-55-17 and 2323-MS-67B implement FSAR commitments and describe how the reactor make-up water storage tank (RMWST) is designed to meet the initial containment cooling requirements of a design bases accident. The RMWST is constructed from reinforced concrete with a stainless steel liner, which is partitioned by a rubber membrane barrier to separate the water from the air inside the tank. The welded liner is constructed of 3/16 inch ASTM A240, 304L steel. A review of this specification, with respect to the RMWST, indicates that the tank meets the requirements of ASTM A24 CB&I Contract 83426 and associated file folders (Nos. 3.0, 4.1.3, 4.1.4, 4.1.5, 5.1, 5.2,
 
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r 5.3, 5.5., 5.6, 5.7. 6.1, 6.4, 7.2.1, 7.2.2, 7.3, 7.9, 8.4, 8.5,
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8.6.1, 8.6.2,=8.9, 8.10, 8.11, 8.12, 8.16.1, 8.16.2, 8.17, and 8.19)
were reviewed to determine that the steel liner installation for the RMWST was accomplished as require A review of site records showed that the tank steel liner was dimensionally inspected during onsite. receiving, nondestructively tested, stored, and inspected for fitup prior to welding. The i  specifications of.the materials and components used in the assembl of the RMWST were. verified and included chemical and-physical test    ,
certifications. . Documents also showed that the construction of the RMWST met the G8H specification and that the installed vessel measurements and location were-within design tolerances, and that the
,  completed vessel _ testing requirements had been met.
 
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;. The PPRV documents were legible, retrievable and showed that required
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inspection activities were completed. Documentation for QC and NDE personnel used both offsite and onsite for this project show that
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they were qualified at the time inspections and tests were performe The inspection personnel used appropriate testing equipment which was calibrated at the tine of the testing, and was scheduled for
12" tray nodes with 18" width trays to correct the stated cable overfill and irregular routing problems. Construction Deficiency Report CDR-87-801 was issued on January 19, 1987 to identify the need for reinspection of existing cable installations for cable overfill conditions. If the disposition of the CDR indicates that corrective action is required, a CAR
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calibration at regular interval ,
During the construction of the steel tank liner, weld history records were maintained for each weld which included: NDE records, NDE procedures, NDE procedure qualification, NDE inspector. qualification l  records, weld repair records, weld procedures, weld procedure j  qualification, welder identification, and welder qualification i  records. The control list for the nonconformances describes the problem, resolution, action, inspection and acceptance signoff.
 
5 Structural Steel Design Changes, Unit 1: The NRC inspector selected two design changes for review. DCAs 18728 and 19894 are part of a modification package to change a steel structure in the reactor
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j containment from nonseismic to Category II. These changes were properly controlled.
 
No violations or deviations were identifie . Unit 2 Reactor Coolant (Rx) Loop Pipe Welding The NRC inspector reviewed the TUGCo FSAR and Quality Assurance Plan to
. determine the requirements for controlling special processes such as Rx
!  loop welding. These documents stated that special processes are controlled
;  by approved or qualified procedures, which include design criteria, codes, standards, specifications, and other special requirements; personnel qualifications; and examinations, tests, and inspections.
 
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FSAR Section 17.1.9, " Control of Special Processes," states that audits are to verify the adequacy of selected site and vendor shop activities and the effectiveness of the special process control procedures being-implemente The NRC inspector found that Unit 2 Rx loop welding was accomplished between July 1980 and September 1981. The 1980 and 1981 audit files were reviewed to determine if audits had verified the adequacy of welding to determine.if this special process was effectively controlled. The files in the QA vault did not contain the checklists for all audits performed in 1980 and 1981. This matter was discussed with TUGCo and B&R management, who stated that this information may be in the files at the B&R office in Houston, Texa This item is unresolved pending the receipt and review of all 1980-1986 audit files (445/8606-U-01; 446/8604-U-01).
 
No violations or deviations were identifie . Safety-Related Components, Units 1 and 2 During the general inspections documented in paragraph 3 above, the NRC inspector ~ observed safety-related equipment in both units to determine whether the subject equipment was protected while stored in place (except where access was blocked by construction in Unit 2 and some locked areas in Unit 1). Two specific safety-related components were examined more closely as follows: Component Cooling Water (CCW) Pumps, Units 1 and 2: The NRC inspector reviewed Table 17A-1 of FSAR Volume XIV, Section 17.0 and determined that the CCW pumps are ASME Section III, Class 3 and Seismic Category I. The CCW system provides an intermediate barrier
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between radioactive heat sources and the Service Water System (SWS).


It removes heat from various plant components and must operate during all phases of plant operatio Each system has two 100 percent capacity CCW pumps to provide redundanc The NRC inspector performed an inspection of two Unit 2 Bingham-Willamette pumps after learning from craftsmen that these pumps were in the process of tear down. Startup personnel were contacted to review this work and it was determined that linear indications were found on the cast impellers made from ASTM A216, Grade WCB. According to the documents reviewed, these cracks appeared to be casting shrinkage cracks. B&R had issued NCR M-20,613 and 20,614 dated January 24, 1986. Bingham-Willamette Company letter dated January 9, 1985, documented some discrepancies in the original design concerning running clearances for stationary and rotating wear ring diametrical clearances. This item was also under evaluation per 10 CFR 50.55(e). Resolution of this matter will be tracked as an open item (446/8604-0-04).
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. Attachment to TXX-6213 January 22, 1986 Page 2 of 2
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3. Action to Prevent Recurrence Inspection Instruction QI-QP-11.3-26 and Construction Procedure EEI-7 have been revised to address the specific requirements of the electrical erection specification in the areas identified in the NOV. An additional inspection attribute has been incorporated into the inspection instruction prohibiting cables from extending above the top of cable tray siderails except where entering and exiting the cable tray.


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4. Date of Como11ance Implementation of design change DCA-24,289 and associated cable rework is scheduled to be completed by July 1,1987. A change notice (DCN #5) was issued against the Installation Procedure EEI-7 on October 31, 1986.
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e ., ,
12 Containment Spray Pump and Motor Stands, Unit 2: The NRC inspector reviewed FSAR paragraphs 3.2, 3.8, and 6.5.2 to identify the design and structural requirements. G&H Specification 2323-MS-012 implements FSAR requirements and describes how the stands (Serial-Nos. 15210090 and 15210092) are designed to. meet the requirements of a design bases accident. Bingham-Willamette Company, No.'76002/04 and associated files (RIR's 11780/ 12534/13507 and G&H letters 25324, 27896, 29064, 30557, and 30700) were reviewed to determine that the base of the containment _ spray pump and motor-support steel installation (for component numbers CP2-CTAPCS-02 and CP2-CTAPCS-04) was accomplished as required. The skid construction
  . records were found by the NRC inspector to be in order. .These records are stored onsite in the PPRV and DC The containment spray pump and motor stands'were' receipt inspected,
' stored, installed, and inspected by qualified inspectors. -The specifications of the materials and components used in the assembly of the skid were verified.' The required manufacturing and construction records included chemical and physical test certifications, drawings and construction records which were appropriately verified by quality control personnel. Also-included were checklists used during the-construction which documented the weld metal verification, weld inspections, and procedures, weld
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procedure approval, and weld procedure qualificatio No violations or deviations were identifie . Electrical Cable Installation During March 1986, the NRC inspector performed an inspection of completed electrical cable installations in the Unit 2 Safeguards Building, elevations 810 feet 6 inches and 832 feet. The inspection consisted of observation of installed cables in cable trays and review of applicable specification, drawing, procedure, and instruction requirement This inspection identified that cables were spilling over the siderails of cable trays T240SF005, 006, 007, 008, and T240SDA91 above area 82 at elevation 810 feet 6 inches, and out of trays T240SF003 and 004 near area 94 at elevation 832 feet. Also at elevation 832 feet. it was identified that cables installed in tray sections 1240SF003 and T240SF004 were not supported (trained to conform to the tray configuration) at the transition from the horizontal to the 45 degree riser sections, and for various distances either side thereo Paragraph 4.2.2.3.a of G&H Electrical Erection Specification 2323-ES-100 requires that all cables be installed in a workman-like manner and that they shall be neatly trained without interlacing. Paragraph 4.2. requires that cables be laid in the trays whenever possible, and to a uniform depth. B&R Procedure EEI-7, Revision 6, dated March 26, 1986,
" Cable Pulling," addresses the installation of cables in an orderly manner and stipulates that they are to be laid in the trays whenever possible;
 
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  -however, this procedure did'not address the installation of cables to a uniform depth. TUGCo' Instruction'QI-QP-11.3-26, Revision 24, dated October 11, 1985, " Electrical ^ Cable Installation Inspection," did not address any of the above specification requirements. . The failure to (a)fullyaddressspecification-requirementsinimplementingdocumentsand (b) to comply with-installation instruction is an apparent violation o Criterion V of Appendix B to 10 CFR-Part 50 (446/8604-V-02).
Revision 31 of Inspection Instruction QI-QP-11.3-26 is scheduled to be issued by January 31, 1987, upon completion of requisite training. If required, appropriate corrective action to disposition CDR-87-801 will be completed by July 1,1987.


At elevation 832 feet, it was identified that cable support grips were not
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  , installed at the top of the vertical . risers' containing tray sections T23GECX91 and T24GEDG98. The risers were observed.to be greater than 25 feet high and the installed cables were multi-conductor, No.18 AWG through 12 AWG. Paragraph 4.2.1.5.b(2) of G&H specification 2323-ES-100 states, "One. cable support shall be provided at the top of the vertical raceway or as close to the top as is practical." The specification further
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  . defines, however, that for the aforementioned cable sizes, no support grips would be required if the total height of the vertical riser was less than 25 feet. The NRC inspector reviewed B&R procedure EEI-23, Revision 1, dated July 21, 1983, " Cable Support Grip Installation," and TUGCo Instruction QI-QP-11.3-26, Revision 24, dated October 11, 1985, " Electrical Cable Installation Inspection." Both of these documents reflected the !_
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specification requirements. The failure to install cable support grips on cables at the top of cable tray risers containing tray sections T23GECX91 and T24GEDG98 is an apparent violation of Criterion V of Appendix.B t CFR Part 50-(446/8604-V-03).  , Safety-Related Pipe Supports and Restraints, Unit 1: The NRC' inspector verified the dimensions and locations of eight large bore pipe anchors located on two main steam, three safety injection, and three component ,
cooling water lines. The physical ~ dimensions and locations were compared with the as-built drawings to determine their accurac ~
Three of the as-built drawings were in agreement with the actual .
configuration of the following lines: SI-1-037-005-532A, SI-1-339-001-C41A, and CC-1-198-002-C53A. Two anchors were in agreement with the'as-built drawings for lines MS-1-027-051-553A and MS-1-028-049-C553 Three additional anchors (CC-1-008-029-533A, CC-1-155-013-543A, and !
SI-1-300-003-522A) were examined which had QC Hold tags that had been recently applied. The NRC inspector selected and observed'other dimensions that were not affected by the Hold tag and verified that these dimensions were acceptabl No violations or deviations were identifie . Exit Interview Exit interviews were conducted March 4 and April 4, 1986, with the applicant's representatives identified in paragraph 1 of this repor During these' interviews, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the findings.
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Revision as of 00:28, 3 December 2021

Ack Receipt of 861009,31 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/86-06 & 50-446/86-04
ML20210S473
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/10/1987
From: Johnson E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Counsil W
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8702170638
Download: ML20210S473 (2)


Text

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In Reply Refer To:' FEB I O INT Dockets: 50-445/86-06 50-446/86-04 Texas Utilities Generating Company ATTN: Mr. W. G. Counsil Executive Vice President 400 North Olive L.B. 81 Dallas, Texas 75201 Gentlemen:

Thank you for your letters of October 9,1986, October 31, 1986, and January 22, 1987, in response to our letters and Notice of Violation dated August 26, 1986, ar.d December 30, 1986. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely,

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svaal signed By

/Tl HHf E. H. Johnson, Director Division of Reactor Safety and Projects cc:

Texas Utilities Electric Company ATTN: G. S. Keeley, Manager Licensing Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 RIV:CPRTh CPRT .5F '

PCWagner:gb IBarnes 2. /1 /87

/"DRP EHJohnson 2./$ /87 1/y/87 l$P!888! 8?88;go / {' D PDR \

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= Texas Utilities Generating 2 Company Juanita Ellis President - CASE 1426 South Polk Street Dallas, Texas 75224 Renea Hicks Assistant Attorney General Environmental Protection Division P. O. Box 12548 Austin, Texas 78711-2548 Administrative Judge Peter Bloch U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Elizabeth B. Jahrson Administrative Judge Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Dr. Kenneth A. McCollom 1107 West Knapp ,

Stillwater, Oklahoma 74075 Dr. Walter H. Jordan 881 Outer Drive Oak Ridge Tennessee 37830 Anthony Roisman, Esq.

Executive Director Trial Lawyers for Public Justice 2000 P. Street, N.W. Suite 611 Washington, D.C. 20036 Texas Radiation Control Program Director bec to DMB (IE01)

bec distrib. by RIV:

  • RPB * MIS System
  • RRI-0PS *RSTS Operator
  • RRI-CONST *R&SPB
  • T. F. Westerman, RSB DRSP V. Noonan, NRR R. Martin, RA L. Chandler, OGC *RSB
  • RIV File J. Taylor, IE
  • D. Weiss, RM/ALF J. Conklin, IE
  • I. Barnes, CPTG * Project Inspector
  • R. Hall P. Wagner
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! Leg # TXX-6213 File # 10130 IR 86-06

  • TEXAS UTILITIES GENERATING COMPANY IR 86-04 SKYWAY TOWER . 489 NORTH OLIVE STREET. LB. 88 . DALLAS, TEXAS 7M01 January 22, 1987 ~~~- '
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%?&^*.L #.U E  ; # ? 6198'l Mr. Eric H. Johnson, Director I. , _

Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission L-611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT NOS.: 50-445/86-06 AND 50-445/86-04 SUPPLEMENTAL RESPONSE FOR INFORMATION TO NRC NOTICE OF VIOLATION (N0V) ITEM A(2)

REF: 1. TUGC0 Letter TXX-5037 from W. G. Counsil to E. dated October 9, 1986.

2. TUGC0 Letter TXX-6071 from W. G. Counsil to E. dated October 31, 1986.

Dear Mr. Johnson:

We have reviewed your letter dated December 30, 1986, requesting additional information to our responses referenced above regarding NOV 445/8604-V-02 (Item A(2)). We hereby respond to the request for supplemental information in the attachment to this letter.

Very truly yours, h th b W. G. ouns 1 By: [, . /

G. S. Keeley W/y Manager, Nuclear ticensing RSB/amb:lw Attachment c - NRC Region IV (0 + 1 copy)

Director, Inspection and Enforcement (15 copies)

U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Mr. V. S. Noonan Mr. D. L. Kelley

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. Attachment to TXX-6213'

January 22,--1986 Page 1 of 2

NOTICE OF VIOLATION ITEM A(2) 446/8604-V-02 SUPPLEMENTAL REQUEST FOR INFORMATION In your response to Item A(2), you mention that problems related to the overflowing of electrical cable from the cable trays that were identified by the NRC inspector had been previously identified by applicant personnel and were in the process of being reworked. Accordingly, you did not agree that the NRC identified condition was a violation and, therefore, did not provide the information required by the NOV.

Based on our review of the information provided in your response and additional information provided by members of your staff, we cannot agree that the cited condition had been, or necessarily would have been, identified as a result of the rework that had been undertaken. While we agree that many of the same cables were involved in both the NRC identified condition of overflowing cable tray siderails and the rework being conducted, we disagree ;

that the NRC identified problem would necessarily have been resolved by pulling the cables back to remove interlacing and then reinstalling these cables in the same size cable tray. In addition, the NRC inspector did not identify any QC hold tags (indicating an identified problem) during the NRC inspection.

SUPPLEMENTAL RESPG : TO ITEM A(2)

As a result of discussions with the NRC Resident Inspector and our review of this violation, we have determined that a revision to our response is required. The revised response below will provide the supplemental information requested.

1. Reason for Violation f We admit the violation, and the requested information follows.

The deficiences noted in this violation involving unacceptable cable installation'were the result of corrective actions in progress per NCR E-85-101983 and inadequacies in the cited TUGC0 Inspection Instruction QI-QP-11.3-26 and B&R Construction Procedure EEI-7. Specifically, criteria governing the installation and inspection of electrical cable were found insufficient to prevent the improper cable installation identified in the NOV.

2. Corrective Steos Taken A request for engineering clarification (RFIC E-11180) was initiated on March 4,1986 requesting engineering to evaluate cable tray nodes T240SF001, 02, 03, 04, and 05 for siderails and to document installation l

problems encountered during cable rework associated with NCR E-85-101983.

i A design change (DCA #24,289) was issued on April 4, 1986, to replace the

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12" tray nodes with 18" width trays to correct the stated cable overfill and irregular routing problems. Construction Deficiency Report CDR-87-801 was issued on January 19, 1987 to identify the need for reinspection of existing cable installations for cable overfill conditions. If the disposition of the CDR indicates that corrective action is required, a CAR

will be generated, k _ - .
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. Attachment to TXX-6213 January 22, 1986 Page 2 of 2

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3. Action to Prevent Recurrence Inspection Instruction QI-QP-11.3-26 and Construction Procedure EEI-7 have been revised to address the specific requirements of the electrical erection specification in the areas identified in the NOV. An additional inspection attribute has been incorporated into the inspection instruction prohibiting cables from extending above the top of cable tray siderails except where entering and exiting the cable tray.

4. Date of Como11ance Implementation of design change DCA-24,289 and associated cable rework is scheduled to be completed by July 1,1987. A change notice (DCN #5) was issued against the Installation Procedure EEI-7 on October 31, 1986.

Revision 31 of Inspection Instruction QI-QP-11.3-26 is scheduled to be issued by January 31, 1987, upon completion of requisite training. If required, appropriate corrective action to disposition CDR-87-801 will be completed by July 1,1987.

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