ML20199K977
| 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: |
| 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 ,
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 t
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
Inspectorst / (2 h/
N. 5. Ptiillips, Senicfr Resident Redctor
f/Z/ff6
Date
Inspector (SRRI), Construction,RegionIV
CPSES Group
(paragraphs 1, 2, 3, 4, 5, 6, and 8)
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L 4G% illa - Jh/hd
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D. T. Kelley, 5RRI, pperat/ons, Region IV
CPSES Group
(paragraph 7) <
Consultants: EG&G-J. H. McCleskey
Parameter-T. H. Young s
Reviewed By: 8mM .
I. Barnes, Grot'p Leader, Region IV CP5ES
4M_
.Date
Group
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8604100269 860404
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Approved: ~
T. F. W a terman, Chief, Region IV CPSES Grcup Date :
Inspection Strncary
inspection Conc' acted: November 1-30,1965(Report 50-445L85-161 ,
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. ,
A cettion Conaucteo: Sovemoer 1-30.1985 (Repyt_5f-446/05-13)
AreaLIn_ spec
s _ted: Routine, anacuaced and unannounced inspection of (Jnit 2
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 ,
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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1. Pwsog ontacted
j Texas _ Utilities, Generating Company (TUCCo)
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K. Arcp> Site Design Engineer ,
R. Babb, Engineer and Site Fire Protection Leader, TUGCo Nuclect
i Engiraering (TNE)
H. Cheatheam, Tecnnical Support Engineer
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R. Cisneros, Special Project Group Coordinator ,
9. Halstead, M'anager, Quality Control
i J. Hicks, Licent ing
J. Marshali, ticensing
- J. liarri'tt, Assistant Project General Manager, Unit 2
! 0. Palmer, Industrial Operating Experiente Coordinator
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C. Welch, QC Services Supervisor
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j 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 ,
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
the retrieval of completed packages from the vault when modifications
are required.
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b. (Closed) Deviatica (445/8408-D-03): Deviation from desig,, information
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 q
without a corresponding chance in details for bolted connections.
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On October 24-28, 1985, the NRC inspector followed up on this item to
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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
BISCO fire seal. The applicant initiated corrective action which
included: (1) providing training to construction to reindoctrinate ,
them on CPSES rules and policies s (2) performing a walkdown
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
Part50.55(e " Iteru/
The Events
review Underthat
revealed 10the
CFR Part 21procedures
following and 10 CFR '
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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
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such test requirements or DOW test results.
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:
1 The NRC inspectors evaluated corrective action taken on reportable
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deficiencies by reviewing TUGCo deficiency reports. The inspector found no
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corrective action completion date for CP-84-29, "HVAC Fire Scenarlo." It
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 i
described in deficiency reports and the open items list, also give no '
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,
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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.
The initiation of this effort will follow the task review of the
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10 CFR Part 50.55(e) program which is presently in progress.
This item is unresolved (445/8516-U-02, 446/8513-U-02).
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b. The TUGCo actions on two IEBs (i.e., Nos. 79-14 and 79-28) were
t selected to revicw hardware evaluations or repair / replacements. TUGCo
10ER Log Sheet, page 10, dated April 9, 1984, was reviewed to
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determine the status of the IEBs.
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(1) IEB 79-14 was evaluated by TUGCo in 1983 and was statused as ,
closed. The NRC inspector indicated that the closure of IEB 79-14
was premature since Stone & Webster is currently analyzing Unit 1
i 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
supplemental report will be submitted upon completion of the
j ongoing project engireering work.
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Theaboveitem(IEBNo.79-14)statusisconsideredanopenitem
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(445/8516-0-03,446/8513-0-03).
(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
i and emitted a yellow-brown crystal like resin that can cause these
i switches to fail. The NRC inspector found the TUGCo documentation
to be complete with respect to the specified corrective action of
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replacing these switches with switches manufacturt.d in acceptable .
lots.
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l Field verification of replacement of 14 switches identified,
l however, that the identity of 2 switches could not be traced to
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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
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as EA 180-32302 and EA 170-31302, respectively. The switches
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). l
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5. QA Records Retention !
i The NRC inspectors found that construction deficiency and IEB files were
- not stored in the QA records vaults. Because such records have not been i
i deposited in a central location, difficulties have been encountered in
retrieval. TUGCo is assessing this record file issue.
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This item is open pending the completion of their review (445/8516-0-05,
446/8513-0-05).
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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
i 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
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TB-803-010A-1008A.
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
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,
t 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
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
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,
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,
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
l rescinded because the hose stream test data was destroyed or lost
l 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
l 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
i 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. The
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.
! . TUGCo interoffice memorandum (Creamer to Kennedy) dated October 16,
, 1985, discussed the rework of all seals affected by ANI disapproval
l of S-26.
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. BISCO memorandum to TUGCo (Trent to Anger) dated October 24, 1985,
( 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,
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 IEEE
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;
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EEI-16, Revision 0; EEI-18, Revision 3; EEI-21, Revision 0; EEI-23
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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