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HVAC Duct Support As-Built Program Insp Rept 50-446/86-02 on 860225-0307.Violation Noted:Four Examples of Errors Identified Re Major Attributes Associated W/Hvac Duct Support Final QC Accepted as as-built Drawings
	ML20215J921
Person / Time
Site:	Comanche Peak
Issue date:	10/16/1986
From:	Barnes I, Dale J, Jew D; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20215J811	List: IR 05000446/1986002; ML20215J809; ML20215J821; ML20215J832; ML20215J864; ML20215J897; ML20215J921;
References
	50-446-86-02-01, 50-446-86-2-1, NUDOCS 8610270247
	Download: ML20215J921 (7)
	v • d • e

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APPENDIX E

SPECIAL UNIT 2

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HVAC DUCT SUPPORT "AS-BUILT" PROGRAM INSPECTION

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-446/86-02 Construction Permit: CPPR-127

Docket: 50-446 Category: A2

Applicant: Texas Utilities Electric Company (TUEC)

Skyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas 75201

Facility Name: Comanche Peak Steam Electric Station (CPSES), Unit 2

Inspection At: Glen Rose, Texas

Inspection Conducted: February 25 through March 7, 1986

Inspectors: /o!&!A(,

A. Dale,JIV Consultant Date

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D.~ L. Jew, R M Conibltant

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Participating NRR Consultants: G. Degrassi

J. J. Rivard

Approved: 8e /o/)6/#4

1. Barnes, Chief, Region IV CPSES Group Date ,

Inspection Sunnary

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Inspection Conducted: February 25 through March 7, 1986 (Report 50-446/8602)

Areas Inspected: Special, unannounced inspection of the Unit 2 HVAC duct

supports as-built inspection program.

Results: Within the one area inspected, one violation (four examples of errors

in the as-built inspection program, paragraph 3) was identified.

8610270247 861017

PDR ADOCK 05000445

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DETAILS

1. Persons. Contacted

B. Farrawood, Project Manager, Corporate Consulting Limited (CCL)

T. Chambers, Project Manager, Bahnson Service Company (BSC)

J. Canup, QA Corporate Manager, BSC

G. Benfer, Project QA Manager, BSC

W. Walker, QA Engineer, BSC

C. Nelson, Vice President, BSC

C, G. Hughes, Vice President Operations, CCL

J. Gore, Subcontractor Supervisor, TUGCo

J. Herritt, Director of Construction, TUGCo

, *T. Brandt, Quality Engineering Supervisor, TUGCo

g *J. Kralik, Unit 2 Project Manager, TUGCo

V. English, Subcontracts, Brown & Root

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J. Walsh, Quality Engineer, TUGCo

. * Denotes those person'. who attended the exit interview.-

The NRC inspectors also contacted other applicant employees during this

inspection.

2. HVAC Duct Support As-Built Inspection Program

a. Unit 1: On January 17, 1986, NRR performed a site audit to determine ,

the status of the HVAC duct supports at Comanche Peak. An overview

of the current Unit 1 status was presented by TUGCo.

,

Subsequent to the site audit, additional information was developed

with respect to the as-built support analysis program which began in

January 1985. Preliminary results indicated that deviating

conditions exist which may impact the existing analysis. Due to the

identification of the deviating conditions, the status of CPSES

Seismic Qualification Report of Seismic Category I Duct Work and

Hangers was changed by TUGCo from " Approved" to "Not Approved" on

January 21, 1986.

A copy of the NRR trip report, which addresses the status, is

contained ir. this Appendix as Attachment 1.

b. Unit 2: This inspection was performed to verify the adequacy of the

Unit 2 as-built inspection program for HVAC duct supports. The bases

used for this inspection were the following:

(1) BSC Procedure QCI-CPSES-012, Revision 4, dated September 6,

1984, " Surveillance and Inspection of Concrete Anchor Bolt

Installation Procedure."

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(2) BSC Procedure QCI-CPSES-016, Revision 1, dated September 6,

1984, " Verification of Weld Size for Skewed Weld Joints

Procedure."

(3) BSC Procedure QCI-CPSES-Oll, Revision 5, dated September 24,

1985, " Visual Inspection of Welds Procedure."

(4) BSC Procedure QCI-CPSES-014, Revision 4, dated September 13,

1985, " Seismic Duct Support Installation Inspection Procedure."

(5) BSC Procedure DFP-TUSI-003, Revision 10, dated May 6, 1985,

" Duct Support Design Fabrication and Installation Procedure."

(6) BSC Procedure DFP-TUSI-004, Revision 10, dated April 17, 1984,

" Drilled-In Expansion Bolts Installation Procedure."

(7) BSC Procedure DFP-TUSI-010, Revision 3, dated April 11, 1984,

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" Permanent Attachments to Embedded Weld Plates Procedure."

(8) BSC Procedure DFP-TUSI-016, Revision 0, dated /spril 11, 1985,

"As-Built Procedure."

(9) BSC Procedure WP-TUSI-001, Revision 1, dated July 1,1985,

" Welding Procedure."

(10)'AppropriateDuctSupportDesignChangeRequests(DSDCRs)and

Duct Design Change Requests (DDCRs) to further clarify the

procedures.

.(11) Appropriate Deficiency and Disposition Reports that describe and

provide disposition of discrepant condi.tions.

(12)BSCHVACductsupportdrawingswhichhadreceivedfinalQC

acceptance.

From a total of approximately 650 HVAC duct support drawings that had

received final QC acceptance, the NRC selected the following 32 supports

for inspection:

,

Safeguards Building Reactor Building

SG-773-2H-WP2 RB-808-VR-21C

SG-773-2H-4D RB-808-2A-WP2

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SG-790-2H-1Q RB-808-2E-7A

SG-790-2H-1B RB-808-2D-C2

3' -SG-790-2H-1AC~ RB-808-2D-1B

SG-790-2J-1P RB-832-2E-1G

r SG-790-2H-RIE RB-832-VR-17D

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SG-790-2J-1B RB-860-VR-12A

SG-790-2H-R1P RB-860-2D-1Q

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SG-831-2J-1G RB-860-VR-7H

SG-852-2H-WP16 RB-860-2E-4H

SG-852-2J-1AW RB-905-2D-1H

RB-905-2D-4AH

Diesel Generator Building RB-905-VR-8B

RB-905-RB2-PS-16

DG-844-2K-9A

DG-844-2K-1J

DG-844-2K-1AA

DG-844-2K-1AF

2K-PS5 (Drawing No. 2323-M2-0659-01)

As a result of this inspection, one violation of Criterion X of Appendix B

to 10 CFR Part 50 and two unresolved items were identified with respect to

major attributes associated with the Unit 2 HVAC duct support final QC

accepted as-built drawings, and applicable BSC QC procedures and

specifications.

3. Summary of Violations to~ Criterion X of Appendix B to 10 CFR Part 50

(446/8602-V-17)

a. Intermittent Fillet Welds

(1) Procedure Requirements

Section 9.1 in WP-TUSI-001, Revision 1, states, in part, with

respect to intermittent welds, " Weld increments shall begin and

terminate within 1/8 inch of the ends of the joints or

dimensioned length . . . ."

(2) Findings

The following list of supports had intermittent fillet welds

between the duct and the duct support, whic' did not begin or

terminate within 1/8" from the joint ends:

SG-790-2H-1Q RB-832-VR-17D

SG-790-2H-1AC RB-860-VR-7H

SG-790-2J-1P DG-844-2K-1J

SG-831-2J-1G

b. Qualitative Measurement

(1) Procedure Requirements

Section 6.5 in BSC Procedure QCI-CPSES-011, Revision 5, states,

"The quality representative shall make certain that the size,

length, and location of all welds conform to the requirements of

QCI-CPSES-014 and DfT-TUSI-003, and to the detailed drawing,

that no specific welds are omitted, and that no specific welds

have been added without engineering approval."

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Section6.3inBSCProcedureQCI-CPSES-014,

" Verify that all welding, (amount, placement,Revision

and type 4}isstates,

in

accordance with drawing."

(2) Findings

HVAC duct support drawing No. 2K-PS5 (ref. drawing

No. 2323-M2-0659-01) requires a 2" long, 1/4" fillet weld

between the main support structure and the vertical

direction brace. Inspection revealed this weld to be

undersized by 50 percent; i.e., 1/8".

HVAC duct support drawing No. RB-905-RB2-PS-16 requires a

2-1/2" long,1/8" fillet weld between the raain support

structure and each of the two lateral braces. Inspection

revealed these two fillet welds to be non-existent.

HVAC duct support drawing No. SG-790-2H-RIE requires a

1-1/2" long, 1/8" fillet weld on both sides of the 6" long

2X2X1/4 angle steel directly above the duct. Inspection

revealed both welds to be 1-1/4" long.

c. Weld Quality

(1) Procedure Requirements

Section 6.6 in BSC Procedure QCI-CPSES-Oll, Revision 5, states

in part, " Weld profiles shall meet the following requirements:

The faces of fillet welds may be slightly convex, flat, or

slig'ntly concave . . . Rejectable defects - welds shall be

visually examined to determine if the following defects are

evident: . . . Undercut shall not exceed 1/32" for material

thicker than 1/4"."

(2) Findings

HVAC duct support SG-852-2J-1AW, consisting of 1/2"

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members, contained 2-4" long fillet welds in which 1/16"

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undercut was observed in over 50 percent of each weld

length,

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HVAC duct support SG-852-2J-1AW contained a 1/4" and 3/8"

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fillet weld, in which grinding of the weld produced

excessive convexity, resulting in an unacceptable profile.

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d. Anchor Bolt Spacing

(1) Procedure Requirements

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Note 2 in Attachment 4 to BSC Procedure DFP-TUSI-004,

Revision 10, states, "Where the embedded steel plates are

, occupied by attachments within the minimum distance shown above

(12 inches), the minimum clearance to Hilti anchors shall be as

follows:

Hilti Anchor Nelson Stud Edce of Plate

Size To Hilti Anchor To Filti Anchor

1" 9" 7 1/2"

(2) Findings

HVAC duct support DG-844-2K-1J had a 1" diameter Hilti 11" away

from an attachment on an embedded steel plate. However, the

Hilti was positioned 3/8" from the edge of the embedded plate

rather than the required 7-1/2" minimum.

4. Summary of Unresolved Items

a. Gap Between Concrete and Support Steel

While performing the inspections, it was observed on three supports

that the support steel which is bolted to a concrete wall with Hilti

Bolts was not completely flush with the concrete wall. Details of

gap conditions are listed below:

Support Gap Description

RB-832-VR-17D Gap existed for approximately 30 percent

of the length of the 6X6X5/8 angle steel

steel and measures up to .25". The gap

encompassed the total area around one

Hilti.

DG-844-2K-1J Gap existed for approximately 70 percent

of the length of the 6X6X5/8 angle steel

and varies up to .375". The gap

encompassed the total area around one

Hilti.

SG-852-2H-WP16 Intermittent gaps existed between

concrete and C 6X8.2 channel steel on

the East side. Total gap region

encompassed 25 percent of the length and

was prevalent at one Hilti.

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From discussion with the applicant, BSC and CCL personnel, it was not

apparent that inspection of gap conditions had been considered as a

necessary element for factoring into the CCL reanalysis of HVAC duct

supports. This matter is an unresolved item pending clarification by

the applicant (446/8602-U-18).

b. Analysis of Square Groove Welds

During the inspection, it was noted that certain BSC drawings, in

which square groove welds were specified for seismic HVAC duct

supports, did not specify applicable groove depths or the required

effective throat dimensions. The applicable supports were

RB-832-VR-17D, RB-860-VR-7H, RB-905-2D-4AH, RB-905-VR-88,

RB-905-RB2-PS16, SG-790-2H-1Q, and SG-790-2H-1B. It was additionally

noted that these attributes could not be verified by the current

inspection program. This matter is considered an unresolved item

pending additional NRC review (446/8602-U-19).

5. Exit Interview

An exit interview was conducted on March 6, 1986, with the applicant

representatives denoted in paragraph 1 of this appendix. During this

interview, the NRC inspectors summarized the scope and findings of the

inspection. The applicant acknowledged the findings.

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ML20215J921

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