ML20002A825
| ML20002A825 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/20/1980 |
| From: | Crossman W, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20002A816 | List: |
| References | |
| 50-445-80-20, 50-446-80-20, NUDOCS 8011210631 | |
| Download: ML20002A825 (7) | |
See also: IR 05000445/1980020
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U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEFINT
REGION IV
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Report No. 50-445/80-20; 50-446/80 m
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 conducted: September 1980
Inspector:
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R. V.' faylor[ Resident Reactor Inspector, Projects Section
Approved:
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W. A. Crossman, Chief, Projects Section
Date
Inspection Summary:
Inspection during September 1980 (Report No. 50-445/80-20; 50-446/80-20)
Areas Inspected: Routine, announced inspection by the Resident Reactor
Inspector (RRI), with limited support by two Regional IE inspectors, in-
ciuding general site tours; piping, electrical and instrumentation, installa-
tion activities; protection of installed and uninstalled equipment and
pipe supports and restraints. The inspection involved ninety-two inspector
hours by the RRI and four hours by two Regional IE inspectors.
Results:
No items of noncompliance were identified in five of the areas.
One item of noncompliance and a deviation (infraction - unsuitable weld
surface as required by magnetic particle test procedures
paragraph 6;
deviation - incorrect design of pressuri::er spray system control valve
piping
paragraph 5) were identified in two other areas.
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DETAILS
1.
Persons Contacted
Principal Licensee Employees
- R. B. Clements, TUGCO, Vice-President, Nuclear Operations
- D. N. Chapman, TUGCO, Quality Assurance Manager
- R. G. Tolson, TUGCO, Site Quality Assurance Supervisor
Other Persons
J. V. Hawkins, Brown & Root, Project Quality Assurance Manager
D. C. Frankum, Brown & Root, Construct ion Project Mangager
The RRI also interviewed other lice de and Brown & Root employees
during the inspection period including both craft labor and QA/QC
personnel.
- Denotes those person:. with whom the RRI held on-site management
meetings during the inspection period.
2.
Site Tours
The RRI toured the safety-related plant areas several times weekly
during the inspection period to observe the general progress of
construction and the p ractices involved. Four of the tours were
accomplished during portions of the second shift where the main
activity continues to be installation of electrical cables and the
application of protective coatings.
No items of noncompliance or deviations were identified.
3.
Protection of Major Installed Equipment
The RRI observed that the Reactor Vessel Internals (core support
structure) were partially installed in the Unit I vessel as part
of the final alignment nachining operation. The internals and
the vessel were well covered and protected from any construction
debris.
The Unit 2 Reactor Vessel continued to be protected during
periods when personnel had to enter the vessel for coolant pipe
welding and weld inspection.
The Unit 2 internals remain in their storage enclosures near a
facility warehouse. The RRI observed tba.*. randomly selected
electric prime sovers for. pumps have Ute.c space heaters energized
as have the actors associated with motor operated valves. The
safety-related switchgear and motor control centers either have
their space heaters energized or have large light bulbs installed
to keep them dry.
The control room panels and boards were maintained
in an air-conditioned environment during the period to preclude heat
damage to the electronic components.
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No items of noncompliance or deviations were identified.
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Storage of Uninstalled Components
The RRI toured the warehouses and outdoor laydown areas during
the inspection period. All components observed, including a
substantial number of prefabricated pipe spools and cable reels,
appeared to be well cared for in accordance with normal industry
practice and the recommendations of the various suppliers of
major components, with_one exception. The RRI noted in touring
an outdoor storage area what appeared to be spent fuel storage
racks identified by an attached sign as "NON-Q" (not within the
scope of the licensee's quality assurance program). Also the
lay-down positions of some of the rack modules were such that
water might collect in some areas in the event of rain.
The RRI reviewed the files of the on-site vendor coordination
and found that the racks had been furnished by Westinghouse as
Seismic I components as indicated by the FSAR Section 17.2 and
that there was a Westinghouse quality release document on file.
The RRI initiated a discussion with licensee QA personnel and
was informed that they were aware of the problem and that a
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Nonconformance Report had been initiated but not yet finalized.
This situation will be considered to be an unresolved item pending
completion of the Nonconformance Report and whatever actions are
taken to rectify the matter.
5.
Safetv-Related Piping Installation and Welding
The RRI made several general observations of the handling practices
for piping components during the inspection period both in the
on-site fabrication shop and within the sain plant buildings. The
practices were found to be consistent with the construction practices
outlined in Construction Procedure 35-1195-CPM 6.9 which in turn are
consistent with the Project Specification MS-100 and good industry
prac ice.
The RRI observed, during a portion of one of the tours, that the
installation and welding of a portion of the pressurizer spray
piping had evolved to a point where the final layout configuration
of this subsystem of the reactor coolant system was evident. The
RRI obtained the pertinent isometric drawings. for the subsystem
and verified that the piping was installed essentially as shown.
The design layout, however, was found not to match the commitments
of Section 5.1 of the FSAR in that Note 2 of Figure 5.1-1 had not
been achieved. This note requires that pressurizer spray control
valves be located a sinimum of ten feet below the top of the pressur-
1:er while the isometric drawings indicate that the two valves are
actually located two feet eleven inches and one foot four inches,
respectively above -he top of the pressurizer.
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This-is considered to be a deviation to the FSAR commitments.
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The RRI observed the following welds being made during the inspection
period:
Weld No.
Isometric
Filler Ht.
Welder (s)
Procedure
Process
FW-4
AF-2-SB-003 87401
BPK
11321
V-7-12
SW-1-SB-003 762550
BWP
88025
FW-5
RC-2-520-001 434788
ARN-BRS-AFP
99028
GTAW (Machine)
FW-1
RH-1-RB-001 746100
AEN
88021
The RRI verified that the weld filler setals being utilized in the
above welds were certified by the suppliers via certified Material
Test Reports as meeting the applicable requirements of ASME Section II.
The welders and weld procedures noted were verified to have been properly
qualified in accordance with ASME Section IX.
The RRI also examined the radiographs of the following velds for
compliance to the requirements of ASME section III for veld quality
and Section V for the quality of the radiographs themselves.
Weld No.
Isometric
Line No.
W-16
RC-2-RB-073
4-RC-2-091-2501R1
FW-16A
CS-1-RB-028
2-CS-1-112-1501R1
W-4
CS-2-RB-042
3-CS-2-235-2501R1
FW-14
SI-1-RB-017
6-SI-1-046-2501R1
FW-7A
CS-1-RB-028-
' 2-CS-1-112-2501R1 ~
FW-7
SI-1-RB-037
10-SI-1-179-2501R1
W-13
SI-2-RB-042
2-SI-2-036-2501R1
FW-11A
RC-1-RB-006
6-RC-1-070-2501R1
W-19
FW-2-SB-029
6-FW-2-097-1303
Except as noted abeve, no items of noncompliance or deviations were
identified.
6.
Piping System Supports and Restraints
The RRI initiated an inspection of a group of some one hundred
piping system soment restraints that had been fabricated by Chicago
Bridge & Iron Co. under Brown & Root (acting as a purchasing agent
for the licensee) subcontract 35-1195-0585 and shipped to the site
complete, except for sandblasting and painting.
The inspection was initiated as a result of an investigation of
allegations received by Region IV as documented in Inspection
Report 50-445/80-22; 50-446/80-20. The allegation essentially
stated that some of the weld surfaces of the fabrications were such
that a meaningful magnetic particle inspection within the requirements
of ASME Section III, subsection NF could not have been done as
certified to by the subcontractor.
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A secondary considerati c csatained within the allegation, although
not specifically stated, was that the Authorized Nuclear Inspector
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assigned to the facility was derelict -in that the fabrica tion had
been stamped and certified as having met the Code requirements.
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The RRI, with the assistance of two NRC inspectors specialized in
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weld inspections and nondestructive examination techniques, performed
a magnetic parti:le and visual examination of selected portions of
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the welds of four of the fabrications using the Chicago Bridge &
Iron procedures. Several of the selected areas examined revealed
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indications that could only be resolved by surface removal of the
. welds, thus. substantiating the specific allegation. Tt.e secondary
allegation referred to above was effectively refuted when the RRI
found that the magnetic particle inspection was required by the
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Architect / Engineer as a supplemental addition beyond the require-
ments of the ASME Code. Subsection NA of the Code specifically
' excludes the Authorized Nuclear Inspector from taking responsibility
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for requirements imposed by a designer that are in excess of the Code
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requirements. The Code requirement was for a visual examination
only oflthese components s'nd each of the welds examined by the NRC
personnel appeared to satisfy the Code stated accept 2nce criteria.
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The licensee was informed .of the NRC findings informally on September
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19, 1980, and formally by a Region IV letter dated September 24, 1980.
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The licensee placed a QC hold on all of the components and has
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initiated a' reinspection program involving an identified one hundred
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'ive units received under the order.
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The RRI also became aware of another substantial group of:large
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fabrications used as pipe whip restraints that were fabricated by
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Chicago Bridge 86 Iron under ancther subcontract and has initiated
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an inspection of these that is not complete.
7.
Electrical' Installation Activites
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The RRI made a number of observations of electrical cable pulling
operations during the period. The RRI observed the activities of
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'esch of the six cable pulling crews one or more times during the.
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period in order to ascertain whether they were working within the
parameters of the site installation procedures and good practices,
The RRI alo observed the activities of the QA/QC personnel assigned
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to monitor the pulling crews. The RRI found both groups (craft and
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QA/QC) to work consistently within their respective procedures,
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EEI-7,and QE-QP-11.3-26. The RRI also inspected randomly selected
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cable tray segments in Unit 1 Safeguards area for freedom from cable
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damaging burrs and excessive debris. The selected segments were
found to be in a satisfactory condition for cable pulling.
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The RRI examined the wiring within the 118 VAC Distribution Panels
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.shown~on FSAR Figure 3.3-15 and identified as IPCI thru IPC4.
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was found that from two to four nonsafety cables entered each panel-
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along with several safety-related cables. Within the panel, the
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safety and nonsafety cables .were tightly tied together which appears
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to be contrary to commitments of the FSAR to maintain a six inch space
between safety and nonsafety cables within panels.
Reference to the
above FSAR Figure revealed that safety and nonsafety cables were
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shown and that the nonsafety cable was to be landed on circuit breakers
assembled among the safety-related breakers which would make the six
inch spacing nearly impossible regardless of cable routing techniques.
The same Figure also shows the nonsafety cabling being powered off a
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safety bus with no other means than a circuit breaker of an over-current
type to serve as isolation. This situation appears to violate the
recommendations of Regulatory Guide 1.75.
It appears that the nonsafety
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cables should be designated as associated safety-related cables and
given segregated routing through the cable raceway system.
Since the issue is clearly shown on the referenced FSAR Figure and
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since the electrical / instrument wiring scheme is still under active
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review by NRR, this matter will be considered to be an unresolved
ites rather than a deviation subject to either a FSAR revision or
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specific approval by NRR of the as-built design.
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8.
Instrument Installation Activities
The RRI observed during the inspection period that various instruments
are being placed on their supports throughout the Unit 1 and Common
Plant areas. The instruments observed were noted to be covered with
wooden boxes wired in place for the purposes aof physical-protection.
Where the-instrument' impulse tubing has not been connected ^to'the
instrument, the ports have been capped to protect from the entrance
of debris, all considered to be good industry practices.
The RRI continued to examine the engineer's drawing in the electrical
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and instrument areas to establish whether all safety-related devices
and circuits have been identified and to also develop the IE inspection
plan. The RRI noted the Engineer's Instsament Tabulation List does
not appear to address those safety-related devices associated with
the heating and ventilation controls as being within the QA/QC scope
even though they are connected with safety-related cabling to safety-
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related control circuits. - The RRI discussed this matter with cognizant
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engineering personnel and was informed that the instrument list was
under active review and would be corrected in a timely manner.
No items of noncompliance or deviations were identified;
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9.
Unresolved Items
Unresolved items are satters about which more Laformation is required
in order to ascertain whether they 'are acceptable items, items of
noncompliance, or deviations.
Unresolved items disclosed during the
inspection are discussed in paragraphs 4 and 7 and will, in future
inspection reports, be referred to as:
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50-445/80-20; 50-446/80-20 Spent Feel Storage Racks
b .~ 50-445/80-20; 50-446/80-20 Design of the AC Instr'unent
Distribution Panels
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10.
Manasement Interviews-
The RRI set with one or more of the. persons identified in paragraph I
on September 2, 3, 5, 12, 15, 19, and 24, 1980, to discuss inspection
findings and the licensee's actions and positions.
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