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{{Adams
{{Adams
| number = ML19344F523
| number = ML19343A499
| issue date = 07/22/1980
| issue date = 06/23/1980
| title = IE Insp Repts 50-445/80-15 & 50-446/80-15 During June 1980. Noncompliance Noted:Failure to Establish QA Program for Class 5 Pipe Support Sys & Failure to Follow Const Procedures Required by Drawings
| title = Discusses IE Insp Repts 50-445/80-15 & 50-446/80-15 on 800606 & 09 & Forwards Notice of Violation
| author name = Crossman W, Taylor R
| author name = Seidle W
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name =  
| addressee name = Gary R
| 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 = 50-445-80-15, 50-446-80-15, NUDOCS 8009150367
| document report number = NUDOCS 8009180095
| package number = ML19344F498
| package number = ML19343A500
| 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 = 6
| page count = 2
}}
}}


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U. S.-NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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==REGION IV==
Report No.
50-445/80-15; 50-446/80-15 Docket No.
50-445; 50-446 Category A2 Licensee: Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 Facility Name:
Comanche Peak, Units 1 and 2 Inspection at:
Comanche Peak Steam Electric Station, Glen Rose, Texas Inspection.Conductedt. June 1980 ~
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77-7//S
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Inspector:
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M. G. Taylor, Reside /ReactorInspector
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UNITED STATES


Projects Section Approved:
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7/3
NUCLEAR REGULATORY COMMISSION PDR t,'
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. A. Crossman, Chief (/ Projects Section
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611 RYAN PLAZA DRIVE, SUITE 1000 TIC OC ARLINGTON, TEXAS 76012
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Inspection Summary:
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Inspection During June 1980 (Report 50-445/80-15; 50-446/80-15)
Areas Inspected: Routine, announced inspection by the Resident Reactor Inspector (RRI) including general site tours; safety-related piping instaastion and welding; electrical cable installation; protection of major components; and safety-related pipe supports. The inspection involved ninety-nine inspector-hours by one NRC inspector.
 
Results: Of the five areas inspected, no items of noncompliance were identified in four areas.
 
Two items of noncompliance (infraction - failure to establish quality assurance program for Class 5 pipe support systems paragraph 6; and deficiency - failure to follow construction procedures required by drawings -
paragraph 6) were identified in one area.
 
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CENTRAL FILES
*****
June 23, 1980
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In Reply Refer To:
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RIV Docket No. 50-445/80-15 50-446/80-15 f
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Texas Utilities Generating Company
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ATTN:
i DETAILS
Mr. R. J. Gary, Executive Vice
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Persons Contacted
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Principal Licensee Eiployees
President and Geneal Manager 2001 Bryan Tower Dallas, Texas 75201
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*J. T. Merritt, TUSI, Construction and Engineering Manager j
'_*D. N. Chapman, TUGCO, Quality Assurance Manager
*R. G. Tolson, TUGCO, Site Quality Assurance Supervisor
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Other Persons
*D. C. Frankum,.B'rown & Root, Project Manager
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*W. E. Baker, Brown & Root, Project Welding Engineer The RRI also interviewed other licensee and Brown & Root employees during the inspection period including both craf t labor and QA/QC personnel.


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Gentlemen:
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This refers to the inspection activities performed by our Resident Inspector, Mr. R. G. Taylor, of activities authorized by NRC Construction Permits No.
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* Denotes those persons with whom the RRI held on-site management meetings during the inspection period.


2.
CPPR-126 and 127 for the Comanche Peak Steam Electric Station, Units No. 1 and 2, and to the discussion of the findings by the inspector with members of your staff on June 17, 1980.


Site Tours The RRI toured the safety-related plant areas several times weekly during j
j During the inspection, it was found that certain activities under your license appear to be in noncompliance vita Part 50, Title 10, of the Code of Federal Regulations. The item of noncompliance and references to the pertinent j
the inspection period to observe the general progress of construction and s
requirements are identified in the enclosed Notice of Violation. Details of i
the practices involved. Four of the tours were accomplished during portions
i this item will be included in an inspection report to be issued in the near
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future and identified as Inspection Report No. 50-445/80-15; 50-446/80-15.
of the second shift with primary emphasis on electrical cable installation


-efforts.
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This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.


No items of noncompliance or deviations were' identified.
Section 2.201 requires you to submit to this office, within M days of your receipt of this notice, a written statement or explanation in reply including:
(1) corrective steps which have been taken by you, and the results achieved;
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(2) corrective steps which will be taken to avoid further noncompliance; and (3)-the date when full compliance will be achieved.


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Electrical Installation-Activities
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The RRI made a number of observations of electrical cable installations during the-inspection period.
 
The primary inspection effort was directed toward verification that the' cable installation crews are knowledgeable of the' site -procedures for such work and are following them.-
The RRI also.


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observed the' activities'of.the QA/QC personnel assigned to monitor the
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cable installation in order to ascertain their apparent level of capability and their diligence in monitoring the craft labor activities.
The RRI noted, during observations of three different labor crews and four different
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QA/QC inspectors, that each crew and each inspector was following the respec-
~tive~ procedures.
The RRI inspected a random selection of cable trays for
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. proper installation and for it?rpos from burrs and other sharp edges. The inspector also-initiated an inspection of the structural steel support
; system.for the. cable trays in the Unit No. 2 spread-room.
This latter
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effort is not complete due to the size'and complexity of the installation.
8 0 09180Df5
 
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The RRI observed, on two different-occasions, the activities of electrical l cable terminators' working in'the Unit No. I cable spread room termination
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cabinets.
 
The RRI observed that the stripped ends of the individual wires Twere' free of nicked strands and subsequently observed that each wire was J
 
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terminated with the correct size lug and connected to the terminal desig-nated on the engineer's termination schedule.
The lug compression tools in use by the terminators were noted to be within their calibration period and were in good mechanical condition and correctly used during the observa-tion time.
No items of noncompliance or deviations were identified.
4.
Safety-Related Piping System Installation The RRI made limited observations of piping component handling practices during the inspection period and determined such activities to be consistent with project procedures and good practice. During the period, the RRI observed welder APL working on pass number six of weld FW-6 as identified on Isometric SI-1-090 for line number 10-SI-1-105-2501R2.
The welder was observed to be following Welding Procedure No. 88025 on this pass and using weld rod identified by. Heat No. 762550.
The RRI has verified, during
. several previous inspection periods, that the weld procedure and the welder have been certified in accordance with ASME Section IX.
The RRI obtained and revi'ewed the Certified Material Test Report - for Heat No. 762550 and verified that the material met the requirements of ASME'Section II and that the weld material was appropriate for the base metal involved.
The RRI also examined the following radiographs for completed safety Class 1 and 2 welds as denoted by the last number in the line designation.
The radiographs indicated that the welds conformed to the requirements of ASME Section III for the applicable class. The radiographs themselves met the quality requirements of ASME Section V.
Weld Isometric Line
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W-11, 12 & 13
.CS-1-RB-031B 1.5-CS-1-249-2501R1 W-36, 43 & 45 SI-1-RB-015 2-SI-1-086-2501R1 W-42 SI-1-RB-015 2-SI-1-086-2501R1 W-14, 20 & 21 SI-1-RB-015 2-SI-1-059-2501R1 W-13 & 22 SI-1-RB-015 2-SI-1-059-2501R1 FW-2 & FW-3 RC-1-RB-018 4-RC-1-087-2501R1
FW-1 & FW-21 RC-1-RB-08 3-RC-1-052-2501R1 W-27 CS-1-RB-027 2-CS-1-112-2501R1 FW-2 RC-1-RB-020 4-RC-1-075-2501R1 W-4 CS-1-SB-050 1-CS-1-667-2501R1
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Weld Isometric Line W-13-
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CS-1-RB-29 2-CS-i-112-2501R1
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FW-19
- SI-1-RB-016 6-SI-1-029-2501R1
' FW-4 SI-1-RB-059 10-SI-1-037-2501R1 W-8'
- CS-2-RB-042 3-CS-2-235-2501R1
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W-6 CS-2-RB-013 2-CS-2-107-2501R1 h
FW-2 -
SI-1-RB-054 6-SI-1-327-2501R1 FW-6 CS-2-SB-02 8-CS-2-063-151R2 FW-10 FW-1-SB-20 18-FW-1-37-2003-2
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No items of noncompliance or deviations were identified.
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5.
Protection of Major Installed Equipment The RRI observed, during the general plant tours, that the Reactor Pressure
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Vessels-in both Units No. 1 and 2 are covered and prot _cted.as provided for by the supplier or as recommended by him. The Unit No. 1 Reactor Pressure Vessel internals remain in their enclosures within the Reactor Containment Building while.the Unit No. 2 internals are provided with outdoor pro-
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tection from the arcosphere. The RRI observed that pump motors and valve
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motors'were connected to power for space heating purposes while the various switchgear, motor control centers and control panels were space s
heated by light bulbs in accordance with standard industry practices.
t No items of noncompliance or deviations were identified.
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6.


Pipe Hangers and Supports
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The RRI inspected the licensee's program for design, fabrication, installa-
a Texas Utilities Generating Company-2-June 23, 1980 Should you have ar.y questions concerning this inspection, we will be pleased to discuss them with you.


- tion and quality control of pipe hangers, supports and restraints (component supports; of safety-related piping systems and for nonsafety systems which have been classified as-requiring seismically capable supports due to the secondary consequences of pipe failure in a seismic event.
Sincerely,
-l I6_.


' The RRI randomly selected a total of seventeen installed devices represent-ing a cross section of hangers,Lsupports and movement restraints with five being in ' Class 2 piping systems, six in' Class 3 and six in the Class 5 area
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- (the site designation'for nonsafety piping subject to seismic support as required.by NRC Regulatory Guide-1.20 and the FSAR).
W. C. Seidle, Chief Reactor Construction and Engineering Support Branch Enclosure:
 
Appendix A, Notice of Violation ec: w/ enclosure Texas Utilities Generating Company ATTN:
The.RRI determined
Mr. H. C. Schmidt, Project Manager 2001 Bryan Tower Dallas, Texas 75201
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that there was no. quality assurance effort being made by the licensee in
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. regard to the. Class.5' hangers / supports except that an on going surveillance-of concrete insert bolts-(Hilti) was as applicable to the Class 5 hangers as-to_any.other application of such bolts. Research.of the FSAR f.ndicated
 
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that many of the plant piping systems had been categorized as Class 5 and that the licensee had commited to applicable portions of Appendix B as required by RG 1.29 and the FSAR. Additional research, particularily of Project Specification MS-46A for safety-related hanger / supports and MS-46B for nonsafety hangers / supports, indicated that the Class 5 devices had been placed into the nonsafety specification and that no quality assurance requirements had been imposed on either the vendors or the field work. The RRI's research indicated that a substantially complete program for design, material selection, fabrication and installation is required through the governing code, B31.1 Power Piping Code, and the various references including the specifications of the American Institute For Steel Construction (AISC).
t
 
The RRI considered this to be an item of noncompliance which was provided to the licensee by a Region IV letter dated June 23, 1980.
 
The RRI also inspected the Class 2 and 3 hangers / supports for conformance to the design drawings, reviewed available documentation, and further evaluated the-designs versus the governing ASME Code requirement, Section III, Subsection NF.
 
Seven of eleven drawings contained the following notes:
(1) All tolerances in accordance with QCP #2A001 U.N.O.
 
(2) Fab. Procedure is FH-101 (3) All products designed in N-4 accordance with EPL File No. 1, Rev. 12.
 
Since all of drawings carry the Brown & Root log and were issued "for construction," it appeared that the above notes were applicable to the field fabrication and installation efforts.
 
The RRI was unaware of these procedures and attempted to obtain them from the site document control center.and the QA library of site procedures only to find that such pro-cedures were apparently not on site. Discussions with cognizant licensee personnel indicated that the drawings involved were actually ITT-Grinnell drawings converted to Brown & Root procedures. The licensee stated that the Brown & Root General Piping Procedure CPM 6.9 contained both tolerance and fabrication information that was applicable to the Brown & Root work effort.
 
The RRI indicated that an apparent item of noncompliance with Criterion V of Appendix B had occurred since it was evident that.the field wack had not been accomplished in accordance with procedures referenced in applicable drawings. The procedures could not have been followed since they were not on site. For the record, the RRI would note that his inspections of hangers and supports have not shown any apparent technical problem with the hangers on supports as a result of this noncompliance.
 
The RRI noted, during the inspection of installed components and the subse-quent drawing review, that a few of the observed attachment welds of various members to their base plates did not appear to conform to the
 
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detail requirements of Subsection NF of ASME Section III.
 
The most notable situation was where "I" beams had been tee welded to the base plate and there was generally no weld on the inside edge of the flange.
 
The Code bas one of two applicable requirements, depending on whether the joint is considered by the designer as a " plate and shell" or as a " linear type" joint.
 
In the case of the plate and shell type, the Code requires a full fillet joint. As observed, the flange faces were welded to the base plate and in order to have a full fillet configuration, the inside of the flange as well must also be welded to the plate.
 
In the case of the linear type support, the NF referenced paragraph XVII-2452.1 requires that side and end welds be returned around the corner at the end or side.
 
In the case of the "I" beam design, the weld on the flange faces would have to turn the end of the flange and go down the inside of the flange two times the specified weld size, or typically about
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one-half inch.
 
The RRI also noted other installations and drawings utilizing square structural tubing wherein the weld in several instances was only along two sides of the tube.
 
The Code appears to require an all around weld if the support is in the plate and shell category and the weld go around the corner of the box on to the currently unwelded faces at least twice in length of the specified weld size, again typically a half-inch.
 
The RRI noted during a records review of several of the component supports, that while in some instances the QA/QC inspection of the welds had been documented, none of the supports involved in the inspection were finally inspected.
 
Most of the items selected did not indicate that any weld inspection had yet taken place.
 
Since the QA/QC status of the selected supports was relatively incomplete, the RRI does not know what the final acceptance decision by QA/QC is and therefore this will be considered to be an unresolved item.
 
7.
 
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations. One such item disclosed during the inspection is discussed in paragraph 6 and will hereafter be refered to as " Weld Configuration of Component Supports."
 
8.
 
Management Interviews The RRI met with one or more of the persons identified in paragraph 1 on June 4, 10, 17, 18.and 25, 1980, to discuss inspection findings and the licensee actions and positions.
 
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Revision as of 16:09, 24 December 2024

Discusses IE Insp Repts 50-445/80-15 & 50-446/80-15 on 800606 & 09 & Forwards Notice of Violation
ML19343A499
Person / Time
Site: Comanche Peak  
Issue date: 06/23/1980
From: Seidle W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Gary R
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML19343A500 List:
References
NUDOCS 8009180095
Preceding documents:
Download: ML19343A499 (2)
v • d • e


Text

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[4 m c,

UNITED STATES

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NUCLEAR REGULATORY COMMISSION PDR t,'

4 {[

.

REGloN lv LPDR E9 o

611 RYAN PLAZA DRIVE, SUITE 1000 TIC OC ARLINGTON, TEXAS 76012

" j-

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.

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NSIC

%, %"

CENTRAL FILES

June 23, 1980

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In Reply Refer To:

RIV Docket No. 50-445/80-15 50-446/80-15 f

Texas Utilities Generating Company

,

ATTN:

Mr. R. J. Gary, Executive Vice

'

President and Geneal Manager 2001 Bryan Tower Dallas, Texas 75201

Gentlemen:

This refers to the inspection activities performed by our Resident Inspector, Mr. R. G. Taylor, of activities authorized by NRC Construction Permits No.

CPPR-126 and 127 for the Comanche Peak Steam Electric Station, Units No. 1 and 2, and to the discussion of the findings by the inspector with members of your staff on June 17, 1980.

j During the inspection, it was found that certain activities under your license appear to be in noncompliance vita Part 50, Title 10, of the Code of Federal Regulations. The item of noncompliance and references to the pertinent j

requirements are identified in the enclosed Notice of Violation. Details of i

i this item will be included in an inspection report to be issued in the near

}

future and identified as Inspection Report No. 50-445/80-15; 50-446/80-15.

!

This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.

Section 2.201 requires you to submit to this office, within M days of your receipt of this notice, a written statement or explanation in reply including:

(1) corrective steps which have been taken by you, and the results achieved;

,

(2) corrective steps which will be taken to avoid further noncompliance; and (3)-the date when full compliance will be achieved.

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>

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,

8 0 09180Df5

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a Texas Utilities Generating Company-2-June 23, 1980 Should you have ar.y questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

-l I6_.

,-

W. C. Seidle, Chief Reactor Construction and Engineering Support Branch Enclosure:

Appendix A, Notice of Violation ec: w/ enclosure Texas Utilities Generating Company ATTN:

Mr. H. C. Schmidt, Project Manager 2001 Bryan Tower Dallas, Texas 75201

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