ML20215J897

Cable Tray Support As-Built Program Insp Rept 50-446/86-02 on 851211-12.Violations Noted:Seven Examples of Errors Identified in Major Attributes Associated W/Cable Tray Support as-built Drawings & QC Acceptance of Drawings

ML20215J897
Person / Time
Site:	Comanche Peak
Issue date:	10/16/1986
From:	Barnes I, Dale J 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, 50-446-86-2, NUDOCS 8610270236
Download: ML20215J897 (8)

See also: IR 05000446/1986002

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APPENDIX D

SPECIAL UNIT 2

CABLE TRAY SUPPORT "AS-BUILT" PROGRAM INSPECTION

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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

Docket: 50-446 Category: A2

Applicant: TexasUtilitiesElectricCompany(TVEC)

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: December 11-12, 1985

Inspector: ), , yo a/gg,

. [ ale,itIV Consultant Date

Participating NRR Personnel: R. Lipinski

Participating NRR Consultants: V. Ferrarini

T. Langowski

C. Richards

( E. Solla

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Approved: 8m s J)6/}/

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I. Barnes, Chief, Region IV CPSES Group Date

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Inspection Summary

Inspection Conducted: December 11-12,1985(Report 50-446/86-02)

Areas Inspected: Special, unannounced inspection of the Unit 2 safety-related

j cable tray support program.

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

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

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8610270236 861017

PDR ADOCK 05000445

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DETAILS

1. Persons Contacted

• J. F. Streeter, TUGCo QA Director

• C. R. Hooton, TUGCo Civil Engineering Supervisor

• 0. B. Jones, TUGCo Unit 2 Project Engineer

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• C. A. Biggs, TUGC0 Quality Engineer

• P. E. Halstead, TUGCo Quality Control Manager

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• H. A. Harrison, TUGCo Project Manager

T. G. Tyler, TUGCo Comanche Peak Response Team Program Director

• J. D. Hicks, TUGCo Quality Control Supervisor

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• J. Duncan, TUGCo Quality Engineer

• W. A. Kattness, TUGCo Quality Engineer

D. Mercier, TUGCo

• E. J. Hee, TUGCo (Quality EngineerR.L. Cloud and Associates)

• Denotes those present at the December 12, 1985, exit interview.

The NRC inspectors also interviewed other employees of the applicant.

2. Safety-Related Cable Tray Support Inspection

This inspection was performed to verify the adequacy of the walkdown

as-built inspection program for Unit 2 safety-related cable tray supports.

The bases used for this inspection were the following:

a. TUGCo Procedure THE-AB-CS-3, Revision 0, dated September 3, 1985,

" Cable Tray Hanger 'As-Designed' and 'As-Built' Drawing Development."

b. TUGCo Instruction QI-QP-11.10-2A, Revision 5, dated September 12,

1985, " Inspection of Cable Tray Supports in Unit II."

c. TUGCo Instruction QI-QP-11.2-1, Revision 20, dated October 24, 1985,

" Installation of Hilti Drilled-In Bolts."

! d. TUGCo Instruction QI-QP-11.21-1, Revision 13, dated November 8, 1985,

l " Requirements For Visual Weld Inspection."

i e. Appropriate drawings depicting cable tray configurations and related

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inspection packages.

j A total of 21 cable tray supports were selected by the NRC inspection team

, using a random number generator. The supports were broken down between

i three buildings. The sample included the following cable tray supports:

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Reactor Building

CTH-2-11929 CTH-2-11592 CTH-2-10101

CTH-2-11516 CTH-2-9774 CTH-2-11529

CTH-2-10059 CTH-2-10119 CTH-2-11570

Safeguards Building

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CTH-2-10264 CTH-2-7137

CTH-2-10420 CTH-2-11391

! CTH-2-11068

Diesel Generator Building

CTH-2-9850 CTH-2-9825 CTH-2-9947

CTH-2-9866 CTH-2-9901

CTH-2-9977 CTH-2-9926

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As a result of this inspection, violations were identified in major

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attributes associated with the cable tray support as-built drawings and QC

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acceptance of these drawings.

3. Summary of Violations

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A sumary of findings from this inspection which are in violation of

Criterion X of Appe.7 dix B to 10 CFR Part 50 and the appropriate TUGCo

,7rocedures or instructions are as follows:

a. Procedure Requirement

Paragraph 3.2.3 in Revision 5 to TUGCo Instruction QI-QP-11.10-2A

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states, in part, "The

is in accordance with QC the work inspector shalldrawing

package verify (s)he completed

. This verification support

shall include the following attributes . . . . Verification of

dimension shown on the work package drawing (s) . . . . All dimensions

' shall have field measurement tolerances as follows . . . Modified

structural shapes, field cut plates, etc; 1/8" . . . . Cable tray

i span and cantilever tolerance is 16" . . . unless specific directions

are given on the work package drawing (s) . . . . The gauge distance .

tolerance measured from the centerline of the bolt / hole to the heel

of the angle is 11/4"; for all other shapes, the tolerance is

1/8" . . . . Tolerance for dimension between welded steel

attachments on embedded plates is il" when the dimension is shown on

i the drawing . . . elevation . . . will be verified by Field

l Engineering (Surveyors)."

i Paragraph 2.4 in Revision 0 to TUGCo Procedure THE-AB-CS-3 states, in

l part, "The walkdown drawing shall correctly depict the in-field

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condition including all the information necessary for QC

i verification. The drawing shall include . . . Support configuration

dimensions and material sizes . . . ."

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b. Findings

(1) The as-built drawing for support CTH-2-9774 did not show the

vertical dimensional location of the 3/8"X4"X5" plate in relation

to the C-6 channel. Further, the dimensional location of the

tray clamp plate in relation to the C-6 channel was missing.

(2) The as-built drawing for support CTH-2-10264 showed the base

plate for this support to be 1-3/4" east of support CTH-2-10263

while the field measurement was actually 1-1/2" West.

(3) The as-built drawing for support CTH-2-10420 showed the location

of the C-6 channel iron in Section B-B as being 4-3/8" from a

welded conduit support; however, the actual field measurement was

5-3/4".

(4) The chart in the as-built drawing for support CTH-2-9850 showed

the "U" dimension for " Clamps Type B" as 1-5/16" while the actual

field measurement was 1-7/8".

(5) The as-built drawing for support CTH-2-11570 showed the elevation

of the channel supporting the cable tray as being 846'-06", while

the elevation as measured in the field was 848'-0-1/2".

(6) The as-built drawing for support CTh-2-10119 showed the gage

dimension for bolt G1 to be 1"; however, the actual field

treasurement was 1-3/16".

(7) The as-built drawing for support CTH-2-9825, showed the "L1" tray

span as being 3'-0"; however, the actual dimension as measured in

the field was 5'-05".

These findings constitute a violation (446/8602-V-14).

4. Sunnary of Unresolved Items

a. Gap Between Base Angle and Concrete

A gap of 1/16" existed between the base angle of support CTH-2-11570

and the concrete wall. Cable tray support procedures did not address

this type of condition, and as a result, may not be reflected in the

final as-built analysis. This condition is an unresolved item

(446/8602-U-15).

b. The drawing for support CTH-2-7137 showed the adjacent cable tray

support identification number as being 288796. Observation of the

support showed the stamped number 288796, which was subsequently

determined to be the material heat number. The isometric drawing

showed the correct support identification number to be CTH-2-7136.

The reason for the use of a material heat number in lieu of a support

number could not be ascertained This item is unresolved

(446/8602-U-16).

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5. Exit Interview

An exit interview was conducted on December 12, 1985, 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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ENGINEERING SERVICES

TRIP REPOP,T NO. 2200

PROJECT 6410T

HVAC HANGER PROGRAM AUDIT

COMANCHE PEAK

FRIDAY, JANUARY 17, 1986

Atttendees: L. Shao - NRC R. Camp - TUGC0

D. Jeng - NRC J. J. Rivard - TES

T. Westerman - NRC S. F. Superson - TES

C. Hoffman - Brookhaven V. Ferrarini - EAS

J. Streeter - TUGC0

The purpose of this audit was to determine the status of the HVAC sup-

ports at Comanche Peak. Mr. John Streeter of TUGC0 gave an overview of the

current status of the Unit I HVAC supports.

The following is a brief history of events in this area.

The NRC Construction Assessment Team (CAT) performed field inspections

of the Comanche Peak HVAC supports during January, February and March of

1983. During this inspection, welds were inspected on fourteen supports,

and nine additional supports were inspected for proper location, configura-

tion, conformance to drawing, dhsign and procedural requirements. At this

time deviations were noted in 45 percent of the welds inspected, while five

of the nine supports reviewed for dimensions had deviations.

Due to the findings of the CAT audit of the HVAC supporn , TUGC0

issued a stop-work notice for all Bahnsan Service Company's (Bahnsan

installed the HVAC supports) structural welding on March 3,1983. TUGC0

also began what resulted in a four-phase review of the HVAC supports.

Phase I (3/83) consisted of a walkdown by Bahnsan of 10a random

supports. Welds and member dimensions were looked at. Bahnsan reported a

number of deviations with both welds and dimensions. This as-built infor-

mation was transmitted to Corporate Consulting Limited (CCL). (CCL

analyzed the HVAC ducts and supports.) CCL found that all the deviations

were not safety significant. CCL did coment that all the supports

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Trip Report "RTri prt(NE

No. 2200 -2- ENGINEERING SERVICES

reviewed had relatively low weld and member stresses and suggested that the

review be expanded to include supports with larger stresses. This resulted

in Phase II.

Phase II (3/83) consisted of a review (no field walkdown) of all

supports with weld stresses greater than one-half the SSE allowable-

(14,000 psi). A total of 240 duct su'pports were identified. It was

assumed that the welds of these supports were one-half the size and three-

quarters the length of that shown on the' design drawings. These reduced

weld sizes were based on weld deviations found in Phase I. An analysis

based on the assumed welds indicated that three of the supports had

stresses above the appropriate allowables. However, an analysis of the as-

built condition of these three supports indicated stresses below the

allowables. Due to the results of Phase I and II, the stop-work order was

lifted at the end of April 1983 and work continued.

Phase III was conducted in June 1983. This phase consisted of a com-

plete field review of 285 supports. Included in this group were the 180

accessible supports in Phase II and 100 additional supports with weld

stresses between 9,000 psi and 14,000 psi. This review consisted of

Bahnsan performing the as-builts of the supports and sending this as-built

information to CCL for an as-built analysis. All supports were found to be

acceptable by CCL.

Phase IV performed in July 1983 consisted of a detailed review by CCL

of the analysis of the Phase II supports noted as being inaccessible.

Since these supports were inaccessible, CCL used a statistical approach for

their evaluation and found these supports to be acceptable.

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In addition to the four-phase review by TUGC0 (Bahnsan and CCL),

Evaluation Research Corportion (ERC) is inspecting HVAC supports as part of

the Construction Adequacy Plan. ERC has reviewed 68 supports on Unit I

noting 202 deviations. The deviations include welding, support configura-

tion, and duct-to-support attachment. There were no details of these

attribute deviations.

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in order to complete the Seismic Qualification Report for the HVAC

cucT.:. and supports, Bahnsan is required to send CCL an as-built of the HVAC

supports to be analyzed by CCL. Preliminary results of the as-built anal-

ysis for approximately 500 supports include the following deviations.

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Based on analysis, between 50 and 60 of the supports reviewed

should have the HVAC duct attached to the support. However, the

design arawing contains no detail for the attachment.

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Of the 50 to 60 supports requiring duct-to-support attachments,

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10 have no attachments. The remaining 40 plus do have an attach-

ment in the field.

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There is no design detail for the attachment of the duct to sup-

port which is required by analysis.

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There is no analysis for four supports in the Reactor Building.

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Five supports have member-dimension deviations.

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CCL did not receive all of the Bahnsan design changes.

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This as-built support analysis began in January 1985, and the project

has not yet determined the full impact of these deviations. However, due

to these findings, the status of CPSES Seismic Qualification Report of

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Seismic Category I Duct Work and Hangers was previously changed from

" Approved" to "Not Approved" on January 21, 1986.

Ank$

[ James d. Rivard

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1 - Trip Report File

l 1 - D. F. Landers (TES)

1 - S. F. Superson (TES)

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