IR 05000445/1981005

Insp Repts 50-445/81-05 & 50-446/81-05 During Mar 1981.No Violations or Deviations Noted.Major Areas Inspected:General Site Tours,Protection of Installed & Uninstalled Equipment, Installation of safety-related Piping & Const Deficiencies

ML20237H886
Person / Time
Site:	Comanche Peak
Issue date:	04/15/1981
From:	Crossman W, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20237H794	List: IA-87-411, Final Response to FOIA Request for Plant Insp Repts.Forwards App B Document.App a & B Documents Available in Pdr.App C Documents Totally Withheld (Ref FOIA Exemption 5).Info Re Insp Repts Not Covered in Apps Provided IR 05000445/1981005 ML20237H790 ML20237H845
References
FOIA-87-411 50-445-81-05, 50-445-81-5, 50-446-81-05, 50-446-81-5, NUDOCS 8708170398
Download: ML20237H886 (7)

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U. S. NUCLEAR REGULATORY COMMISSION

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' OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Report No. 50-445/81-05; 50-446/81-05 ( Docket No. 50-445; 50-446 Category A2 l

Licensee: Texas Utilities Generating Company 2001 Bryan Tower l Dallas, Texas 75201 l

Facility Name: Comanche Peak, Units 1 and 2 l Inspection at: Comanche Peak Steam Electric Station

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l Inspection condu 2d: ch 1981

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Inspectors: /A,Il/2ht // f/ 3 R. 'G. 'Tayl or, Resident Reactor Inspector ~/ Date j

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Projects Section No. 3 '

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W. A. Crossman, Chief, Reactor Projects Section No. 3

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Inspection Summa,ry:

Inspection During March 1981 (Report 50-445/81-05; 50-446/8-1-05)

Areas Inspected: Routine, announced inspection by the Resident Reactor Inspector (RRI) including general site tours; protection of installed and uninstalled equipment; installation and welding of safety-related piping; review of licensee actions on previous inspection findings; and review of licensee actions regarding previously identified potentially significant construction deficiencies. The inspection involved 100 inspector-hours by the RR Results: No violations or deviations were identifie B70812 PDR FDIA ,

WILLIAN87-411 PDR

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p DETAILS Persons Cont' acted ,

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Princiral Licensee Personnel j

• R. G. Tolson, TUGCO, Site Quality Assurance Supervisor

• J. R. Merritt, TUSI, Engineering and Construction Manager

• J. B. George, TUSI, Vice President and CPSES Project General Manager Other Persons J. V. Hawkins, Brown & Root, Project Quality Assurance Manager .I J. Ragan, Brown & Root, Site Quality. Control Manager J.' Maxwell, Brown & Root, Discipline NDE Level III Examiner The RRI also interviewed other 1'icensee and Brown & Root employees during .I the inspection period including both craft labor and QA/QC personne ,j

• Denotes those persons with whom the RRI held on-site management meetings during the inspection perio . Licensee Action On Previous Inspection Findings (Closed) Unresolved Item (50-445/79-24;.50-446/79-23) This' unresolved item f involved an absence in the licensee's. procedural system that would provide I a substantial degree of protection to electrical cables installed in ope ~l cable tray where welding was required above;the-tray with the attendent-  ;

falling of hot metal into the' tray-and the possible damage to the cabl . Brown & Root has now published' instructions in regard to.this matter'via CPM-14.1 " Protection of Permanent Installed _ Equipment."- This procedure provides that the tray within a reasonable area of such welding be protec-ted with fire proof blankets. The RRI has observed during plant' tours that such blanketing is being provided and that generally a craft super-visor at the foreman level is in the near vicinity to assure complianc This item is considered close l (0 pen) Violation (50-445/81-02) Failure to Follow Procedures For Piping Installatio The licensee stated in his letter dated March 19, 1981 1 to RIV regarding this matter that two procedures would be revised or issued, l as appropriate, to provide improved instructions to the craft labor force )

in this matter, i.e. , removal of temporary supports to piping resulting in possible damage to-installed equipment. The RRI has verified that; procedure CPfi-6.9E was. revised .to require that only "hard" supports be-ut$lized where'.the pipe fitters are not working on the piping run and that the supports be attached to the pipe so as to make removal by other -!

craft' difficul Brown & Root has also published procedure CPM-14.1-pertaining to protection of installed plant equipment which prohibits

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craft other than the pipefitters from removing temporary supports from pipe runs without prior coordination with the responsible pipefitter The RRI has observed that this action plan is in progress throughout the j facility and should be completed by the committed final date of l

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April 13, 1981. The RRI was assured that verbal training in this matter was given to all craft personnel during meetings on or about March 23, a 198 The RRI has also reviewed a preliminary engineering calculation I which indicated that neither the valve nor attached piping that were found unsupported by the .RRI on February 20, 1981, (the subject of the Notice of Violation) were damaged by the identified condition. This item will remain open until the licensee has finalized both the engineering c&ulations and plant walk-down and the RRI has had an opportunity to i verify as necessar l Site Tours The RRI toured the safety-related areas of the facility several times during the inspection period to observe the general progress of construc-tion and the practices involved in on going work and the condition of installed equipment. The practices observed were consistent with accepted industry practices and the condition of the equipment was such that there was no evidence of deterioratio No violations or deviations were identifie . Protection of Major Installed Equipment The RRI observed that the reactor vessel internals (core support structure)

continue to be partially installed in the Unit 1 reactor vessel. The j vessel head, also partially installed, is adequately protected from con- '

struction debris by a reinforced plastic cover. The Unit 2 reactor vessel was observed to be well protected in the installation position by a steel I cover and that Unit 2 internals remain in their temporary enclosur The RRI observed that electric pump drivers and valve actuators have their

space heaters energized and each was slightly warmer than surrounding materials. The RRI also observed that instruments are adequately protected from damage by substantial covers and that incomplete instrument tubing runs were consistently plugged to prevent the ingress of construction debris.

l No violations or deviations were identified.

I i Protection of Uninstalled Equipment >

l The RRI toured the several outdoor storage areas during the inspeci. ion period to observe how the stored equipment was being preserved and any substantial evidence of deterioration. The RRI found that piping spools in the laydown areas were consistently plugged with caps or tape to pre-vent the ingress of water and dirt and that the spools were raised off i

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i the ground on dunnage as required by site procedures. Electric cable in the storage area was adequately protected by having the ends taped or booted so as to prevent water from entering. The only evidence of any deterioration found was a little light rusting of a few bolts and/or pins among the several thousand yard stored pipe support devices. Such rusting as was evident was minor and would have no safety significanc No violations or deviations were identifie ! Safety-Related Piping Installation and Welding The RRI made several random observations of the handling practices relative to piping components during the inspection period. As noted in paragraph 2, substantial progress has been made to provide improved temporary pipe supports for partially installed piping runs where the permanent supports have not been installed. The RRI observed no instances where the support was not considered adequate to prevent excessive strain on the component Other handling practices were found to be commensurate with good industry ,

practic .l The RRI was able to observe only one pipe weld being made during the pc.'iod due to the present stage of construction in the safety-related area The RRI found welder BGU working on weld FW-21 as identified on isometric FW-1-RB-0088. The welder appeared to be working within the parameters of Weld Procedure 11020 and was using the weld filler metal identified on the Weld data Card in his possession. The RRI subsequently verified that ,

the filler metal heat had been certified by the vendor as meeting the requirements of ASME Section II. The welder was found to have been quali-l fied in accordance with Section IX of the ASME Code, as was the procedur The RRI also examined a number of radiographs of Class I pipe welds. All of the radiographs met the radiographic quality requirements of ASME

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Section V and all met the weld quality requirements of ASME Section II !

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The RRI noted however that about 25 percent of the radiographs displayed j radiographic techniques that were not representative of good industry J l practice although meeting the less than specific requirements of the Code.

l In one instance the radiographic penetrometer (penny) was located over an inch from the indicated toe of the weld and the radiation source was yet further away as indicated by. the curvature of both the weld and the penny imag Another film set had the penny sufficiently close to the weld but the source was clearly located well off set from the weld centerline. Two other film sets showed the penny across the weld rather than adjacent to it, which is allowed under very limited geometric configurations but the i film did not indicate such a configuration was present nor did the technique notation on the film interpretation recor j The RRI interviewed the Brown & Root Level II interpreter who had previously-accepted the radiographs and found that he was aware of the less than satis-factory techniques but felt powerless to reject film in the face of the i

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I lack of specific requirements in the Cod The RRI suggested that the Brown & Root Level III examiner and the Brown & Root QC Manager review the film and determine if they felt that good techniques had been utilize This was done and both agreed that the techniques were less than catis-factory and stated that the radiographs would be shot agai The RRI then selected eighteen film sets from the plant permanent records vault which were for recently shot Class 2 welds and found that approxi-mately 30 percent also displayed the same undesirable shooting techniques evidenced in the Class 1 films set. As a result of this concern, the Brown

& Root QA Manager stated that a review would be made of the film in the vault back in time far enough to eliminate any such poor shots. .The QA Manager further stated that the Brown & Root radiographic procedure would be revised to clearly indicate where the penny and the radiation source should be located in relation to the weld and thus assure that only good techniques are utilize This matter will be considered to be an unresolved item pending revision of the procedure and completion of the re-examination of the already l accepted film in the vault (the latter expected to take from two to three

months).

l l Piping System Supports On January 20, 1981, the licensee informed the RRI that a potentially significant construction deficiency had been identified wherein an epoxy based grouting material, utilized to fill voids between pipe support baseplates and the mounting surface of the buildings, had been found to lose compressive strength at high ambient temperatures such as might occur in a hot Texas summer. Useage of the material had been restricted ;

to supports attached to walls and ceilings and only then to a suall number of support On February 18, 1981, the licensee notified RIV by letter that further investigation had lead to a conclusion that the matter was not reportable and that information to support this contention was on file and available for review. The RRI obtained the referenced file and found that the investigative analysis was based upon calculations which indicated that i the highest compressive strength required for the grouting material was ')

actually on the order 500 psi whereas the procurement specification required a compressive strength of no less than 6000 psi, and further that even at the elevated temperatures, the material still had a com-pressive strength of 5000 psi or about ten times higher than actually require The licensee's conclusion appeared to well founded. The'RRI, while examining the data, however, found yet more information that might well have a bearing on the use of the material in question. Data pro-vided by the vendor and partially substantiated by preliminary tests performed on the site indicated that the material was far more compressible than the usual sand / cement grout If the material behaves as elastically as the data indicates at this time, it appears questionable that the epoxy grout will serve the intended purpos _ _ - _ _ _ _ - _ _ -_ _ -

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I The licensee's Engineering Manager proposed to run controlled tests of the L

material which would reveal both the compressive failure point and the

! compression' achieved prior to compressive failure. This data would then l be factored into the design analysis for baseplate flexibility.

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l The licensee had placed a stop work order on the use of the grouting.

L material when the preliminary notification had been given to the RRI in

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February and this stop work order has remained in effect and will remain in effect entil' the tests described above aro concluded and the material

! has b'een shown conclusively to be acceptable. This matter will be con-i sidered to be an unresolved item until that time.

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8. Emergency Diesel Generators L

On September 26, 1980, the licensee informed the RRI that a potential significant construction deficiency had been identified relative to the emergency diesel generators. The deficiencv involved a lack of certifi-cation for compliance with ASME Section III, Subsection NF by the manu-facturer of the engine auxiliary skid and certain pipe supports mounted .

on the skid and the engine. FSAR Section 9.5 states that all components {

of the diesel fuel system and air start systems, not mounted on the engine itself, would be in ecordance with ASME,Section III, which of course.

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includes compliance to Subsection NF. The skid and the component mountings

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attached to the skid are within this area of concern. DeLaval Company, the vendor of the diesel engine and skid assembly' had not interpreted the licensee's procurement specification to require compliance to Subsection NF even though he did recognize his responsibility to design, fabricate and certify all the system pressure boundry parts /and components ~

to the Code, i.e., Subsection ND. Information from DeLaval Company to  !

the licensee stated that fabrication welders had been qualified to ASME,Section IX, that the materials used were ASTM equivalents to ASME, SA' i materials, but were not certified as suc The information also included design basis data that was more conservative than required by Subsection N ]

l The licensee plans to amend the FSAR to indicate.that the pressure boundary I components were-designed and inspected in accordance with ASME,Section III, Class 3 with supports designed and fabricated in accordance with the AISC Cod Pending such an a.nendment and its acceptance by NRR and completion of the on-site related work, this matter will be considered to be an unresolved issu . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or deviations. Unresolved items disclosed during the inspection period are: 1 i

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i Paragraph 6; Quality of Radiographs of Pipe Welds Paragraph 7; Pipe Support Grouting Material I Paragraph 8; Emergency Diesel Generator Auxiliary Skid Fabrication i

10. Management Meetings  !

The RRI met with one or more of the persons identified in paragraph 1 on March 4, 5, 13, 17, 25, and 27, 1981 to discuss inspection findings and the licensee's actions and position ll l

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