ML19344F301

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IE Insp Repts 50-445/78-11 & 50-446/78-11 on 780620-23. Noncompliance Noted:Failure to Follow Piping Installation Procedures
ML19344F301
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/29/1978
From: Crossman W, Renee Taylor
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19344F268 List:
References
50-445-78-11, 50-466-78-11, NUDOCS 8009150105
Download: ML19344F301 (6)


See also: IR 05000445/1978011

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U. S. ilUCLEAR REGULATORY COMMISSIO!!

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0FFICE OF IfiSPECT10ft Afl0 EtiFORCEMEtiT

REGI0ti IV

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Report 11o. 50-445/78-11; 50-446/78-11

Docket lio. 50-445; 50-446

Category A2

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Licensee: Texas Utilities Generating Company

2001 Bryan Tower

Dallas, Texas

75201

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Facility flame:

Comanche Peak, Units 1 & 2

Inspection at:

Comanche . Peak Steam Electric Station, Glen Rose, Texas

Inspection conducted: June 20-23, 1978

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Inspector:

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R. G. Taylor Reactor inspector, Projects Section

Date/

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Approved:

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W. A.' Crossman, Chief, Projects Section

Date

Inspection Summa.y:

Inspection on June 20-23, 1978 (Report tio. 50-445/78-11: 50-446/78-11)

Areas Inspected:

Routine, unannounced inspection related to review of licensee

actions on previously identified inspection findings and potential construction

deficiency reports. The inspection involved twenty-nine inspector-hours by one

t1RC inspector.

Results: Ora item of noncompliaace was identified (infraction - failure to

follow piping installation, procedures - paragraph 3).

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DETAILS

1.

Persons Contacted

Principal Licensee Emoloyees

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  • J. B. George, TUSI, Preject General Manager

R. G. Tolson, TUGC, Site QA Supervisor

  • R. V. Fleck, TUGC0/G&H, Civil QC Inspection Supervisor

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  • D. E. Deviney, TUGCO, QA Technician

J. V. Hawkins, TUGC0/G&H, QA Product Assurance Supervisor

Other Personnel

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  • U. D. Douglas, B&R, Project Manager

J. P. Clark, B&R, QC Site Supervisor

P. Van Teslear, Westinghouse, Site Representative

The IE inspector interviewed other contractor employees during the

course of the inspection.

  • denotes those attending the exit interview.

2.

Licensee Action on Previous Insoection Findings

ceca

pummuur

a.

(Closed) Unresolved Item (50-445/78-04; 50-446/78-04):

Procedures

for Storage and Maintenance of Equipment. - The IE inspector re-

viewed the below listed procedures and found that the confusing

and conflicting requirerents had been resolved so as to provide a

clear, cohesive set of instructions.

1)

35-1195-ACP-3, " Material Receiving, Storage and Handling,"

Revision 6, dated May 6,1978.

(2) ~35-1195-MCP-10, " Storage and Storage Maintenance of Mechani' cal

and Electrical Equipment," as revised by Interim Change Notice

4, dated April 12, 1978.

(3)

35-1195-CP-CPM 10.4, " Cleanliness Control," dated April 18',

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1978, which supersedes 35-1195-SCP-2 of the samt ti tl e.

(4)

35-1195-PCI-001, " Pipe Department Cleanliness Control Guide-

lines," dated April 25,1978. (See paragraph 3 of this report

for further information relative to this procedure)

b.

(Closed) Unresolved Item (50-445/78-05):

Potential Construction

Deficiency Regarding Possible DamaSe to the Unit 1 Pressurizer.

The licensee determined that the pressurizer had not been damaged

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by the derailment of the transporting railroad car as reported

in earlier inspection report (50-445/78-05).

This determination

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was based upon extensive visual examination of the vessel as it

was received.

The shipping skid and pressurizer were reported

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by the licensee personnel as showing no evidence of movement or

distress during the incident.

Subsequent visual examination of

the vessel after o#f-loading and electrical tests of the heater

elements also indicated no significant damage had occurred. The

IE inspector visually examined the vessel and reviewed the report

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of the electrical tests and had no further questions.

(Closed) Unresolved Item (50-445/78-07; 50-446/78-07):

Storage

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of Electrical Components.

Procedure 35-1195-MEI-10-511, " Storage

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and Maintenance Requirements of Diesel Engine," has been modified

by revision 2, dated April 20, 1978, to include requirements for

plugging and/or capping all openings.

The IE inspector examined

one of the two~ diesels presently on site and found all openings

plugged or capped as appropriate.

The IE inspector also reviewed

procedure 35-1195-MEI-10-514, revision 1.

The revision changed

the reference basis from attachment 205K to 205L of the Westing-

house Nuclear Service Division (WNS0), Vol 1 storage recommendations.

Attachment 205L requires essentially the same storage and maintenance

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requirements as 205K but does not require measurement and recording

of stator winding and ambient air temperatures.

The IE inspector

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interviewed the Westinghouse site representative who indicated the

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somewhat more severe storage requirements were f or plants where

significant (up to several years) of construction delay had

occurred rather than a normal storage period such as at CPSES. The

IE inspector also interviewed the craft personnel charged with doing

the storage maintenance work and was assured that he always checks

space heater power input and verifies by hand feel that the motor

is above ambient temperature.

The IE inspector had no further

questions on this matter.

d.

(Closed) Unresolved 'cea (50-445/78-05, 50-446/78-09):

Potential

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Reactivity of Concr: te Fine Aggregate

Information relative to

this item is contained in. paragraph 4 of this report.

3.

Site Tour

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The IE inspector walked through various areas of the site to observe

construction activities in progress and to inspect housekeeping and

equipment storage.

Of particular interest was the lay-down area for the upper two contain-

ment dome sections where piping and supports for the containment spray

system were being installed on the prefabricated dome sections.

The

'E inspector observed that the two spray ring headers were completely

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installed except for a final closure " pup".about twelve inches long

in each header.

The open ends of the installed pipe spools at the

" pups" were noted to be capped and taped with silver colored tape

in two cases while the other two were only capped.

During a subsequent review of procedure 35-1195-CP-CPM 10.4, "Clecc-

liness Control," the IE inspector noted a general requirement regard-

ing cleanliness control relative to installed piping and inquired as

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to the existence of a procedure containing the specific requirerents.

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The Brown and Root QC Supervisor produced a procedure, 35-1195-?CI-001,

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" Pipe Department Cleanliness Control Guidelines," dated April 25, 1978.

This procedure requires that the unwelded, open end of pipe spools

installed and welded in at the other end be examined by a pipe fitter

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foreman af ter completion of welding.

If satisfactory, the open end is

to be capped and taped with red tape and tagged per the parent pro-

cedure.

The IE inspector verified his original observation relative to the

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containment spray header installation and inquired as to why the.

procedure was not being followed.

The B&R QC Supervisor ascertained

that neither the pipe fitters nor the QC inspectors who work on the

spray piping were aware of the existence of procedure 35-1195-PCI-001.

This situation is considered to be in noncompliance with Appendix B

and is further considered to have generic implications relative to

the Brown & Root QA program. Specifically, the Brown & Root con-

"

struction procedures allow for the generation of detailed procedures

to fulfill the more generalized requirements of higher level pro-

cedures.

The detailed procedures reference the higher level pro-

cedures but not vise versa, nor is there any commonality in the

numbering system. As an example 35-1195-PCI-001 references 35-1195-

CP-CPM 10.4 and WES-22 and provides detailed instructions required

by general statements of the latter documents. A given craft labor

employee or QC inspector has no mechanism of determining what or how

many detailed procedures may be in existence to govern his activities.

4.

Potentially Reactive Fine Aggregate

The licensee has continued the investigation of problems with recently

detected fine aggregate containing potentially reactive arounts of

silica.31 The licensee utilized the services of Erlin, Hime Associates

__i/ Inspection Report 50-445/ 78-09;5C-446/ 78-09

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of fiorthbrook, Illinois- to investigate the matter. Erlin, Hime

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~ Associates' report,' dated June 6,1978, contains , in summary, the

following conclusions:

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a.'

The fine ~ aggregate used on the project has always contained

moderately deleterious amounts of silica.

b.

The entire series of ASTM C289, " Potential Reactivity 'of

Aggregates," tests performed by R. W. Hunt Company, both off-

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sits and on-site, 'and recent tests by Southwestern Laboratories

Hunt testsp/roneous results. With the exception of recent R. W.- , all te

provided e

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-it undoubtedly was.not. The report indicates that the test is

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very technique sensitive without any' recognized. standardization

method being available.

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- The' fine aggregate is acceptable for use, provided a cement

c.

with a . nominal .5% alkali content is used and recommends that .

a low alkali cement in accordance with ASTM C150 be used. ASTM

' C150 specifies a maximum of .6% alkali content when low alkali

cement is specified.

While the project specification has not until recently specified a

low alkali . cement, it appears that the ceT.ent supplier, Gifford-Hill

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Portland Cement Company, has consistently supplied such cement as

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part of its normal manufacturing process.

Test data made available

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to the_ IE inspector indicated the following: '

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a.

1976 Average alkali .44% maximum .50%

b.

1977 Average alkali .44% maximum .53%

c.

1978 Average alkali .49% maximum .54%

The IE inspector noted that the Erlin, Hime Associates' recommendations

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and.the materials furnished by Gifford-Hill are consistent with para-

graph 5.3 of ASTM C33,'" Concrete Aggregates," which requires that a

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cement with a maximum of. 6% alkalies be used when the fine aggregate

.contains dele.teriously reactive substances.

The licensee's engineer has revised project specification SS-9, " Concrete,"

effective on June 1,1978, to require that all future cement delivered

for project use have an alkali content of .6% or less.

The IE inspector had no. further questions regarding this matter.

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Z/ Inspection- Report 50-445/78-09;.50-446/78-09

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Exit Interview'-

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The:IExinspector met with: licensee ~ representatives (denoted in para-

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graph 1)-lat: the conclusion of the inspection on June.:23,1978.

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zIEjinspector. summarized the scope and findings of the inspection.

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The licensee representatives. indicated understanding both the specific

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item cf noncompliance and its generic implications.

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UNI TED S TATES

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NUCLE AR REGULATORY COMMISSION

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R E GION IV

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611 RYAN PLAZA DRIVE.SUtTE 1000

ARLINGTON, TEXAS 76011

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February 27, 1979

In Reply Refer To:

RIV

Docket flo. %N/Rpt. 79-04

50-446/Rpt. 79-04

.

Texas Utilities Generating Company

ATTil:

Mr. R. J. Gary, Executive Vice

President and General Manager

2001 Bryan Tower

Dallas, Texas

7S201

Gentlemen:

members of our staff during the period FebruaryThis refers

ties authorized by flRC Construction Permit flos. CPPR-126 and 127 for

5-8, 1979, of activi-

our findings with Mr. R. G. Tolson and other members

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the conclusion of the inspection.

,

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Areas examined during the inspection and our findings are discussed in

the enclosed inspection report.

sisted of selective examination of procedures and representative

interviews with personnel, and observations by the inspectors

,

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During the inspection, it was found that certain activities under your

license appear to be in noncompliance with Appendix B to 10 CFR 50 of

the ilRC Regula'tions, " Quality Assurance Criteria for fluclear Power

Pl an ts . "

requirements are identified in the enclosed flotice of Violation

7

This notice is sent to you pursuant to the provisions of Section 2 201

of the llRC's " Rules of Practice," Part 2, Title 10, cme of Federal

.

Regulations.

Section 2.201 requires you to submit to this office, with-

in 30 days of your receipt of this notice, a written statement or expla-

nation in reply including:

you, and the results achieved; (2) corrective steps which will be

to avoid further noncompliance; and (3) the date when full compliance

will be achieved.

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jexas" Utilities Generating

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February 27, 1979

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, During _ the inspection, 'it was found that certain of your activities

= appeared to deviate from commitments in the FSAR.

This item and ref-

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crences to the specific comitments are identified in'the enclosed

Notice of Deviation.

In your reply, please include your comments

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concerning' this item, a description of any steps that have been or will

.

be taken to correct it, a description of any steps that have been or

will be taken'to prevent recurrence, and the date all corrective

.

actions or preventive measures were or will be completed.

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One new unresolved item is identified in paragraph 6 of the enclosed

report..

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part

2, Title 10, Code of Federal Regulations, a copy of this letter and the

enclosed inspection repor_t will be placed in the NRC's Public Document

Room.

If the report contains any information that you believe to be

proprietary, it is necessary that you submit a written application to

this office, within 20 days of the date of this letter, requesting that

such information~be withheld.from public disclosure.

The application

must include a full statement of the reasons why it is claimed that the

information is proprietary.

The application should be prepared so that

any proprietary information identified is cqntained in an enclosure to

,

the application, since the application without the enclosure will also

be placed in the Public Document Room.

If we do not hear from you in

this regard within the specified period, the report will be placed in

the Public Document Room.

Should you have any questions concerning this inspection, we will be

. pleased to discuss them with you.

.

Sincerely,

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W.C.Seid)e, Chief

Reactor (phstruction and

Engineering Support Branch

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Enclosures:

1.

Appendix A, Notice of Violation

2.

Appendix B, Notice of Deviation

3.

IE Inspection Report No. 50-445/79-04

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50-446/79-04

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_ / enclosures

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cc:

. Texas Utilities Generating Company

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i ATTN: Mr. H. C. Schmidt, Project Manager

-2001 -Bryan Tower

Dallas,' Texas

-75201-

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Appendix A

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NOTICE OF VIOLATION,

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Based on the results of 'the NRC inspection conducted on February 5-8,

1979,-it appears that certain of your activities were not conducted in

full- compliance with the conditions of your NRC Construction Permit No.

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CPPR-126 as indicated below:

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Failure. to Follow Equipment Maintenance Instructions

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10 CFR Part 50, Appendix B, T -iterion V requires that activities

.affecting quality shall be accomplished in accordance with the

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prescribed . instructions, procedures or drawings.

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Brown & Root Storage and Maintenance Requirement No. 35-1195-MEI-

10-783 requires that the shaft on Fan CPX-VAFNAV-37 be rotated

. sufficiently to Llubricate the bearings every thirty days.

. Brown & Root Storage and Maintenance Requirement No. 35-1195-MEI-

10-473 establishes requirements for the storage and r..aintenance

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of the Positive-Displacement = Charging Pump TCX-CSAPPD-01. This

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procedure specifically requires that " unpainted carbon steel

surfaces shall be maintained with preservative for duration of

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storage.">

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Contrary to the above:

1.

On February 7,1979, the maintenance records for Ventilation

Fan CPX-VAFNAV-37 indicated that the shaft had only been

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rotated twice (on September 1.2, 1978, and November 13,1978)

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during the five month period 'from September 12, 1978, through

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February 7,1979.

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On February 8,1979, the underside of the Positive Displacement

Charging Pump TCX-CSAPPD-01 was observed to be oxidized due to

lack of preservative.

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_This is an infraction.

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Appendix B

NOTICE OF DEVIATION'.

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Based on the results of the NRC inspection conducted on February

1979, it. appears that certain of your activities deviate from commit-

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ments made in'your Final -Safety Analysis Report (FSAR) as indicated

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below:

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Failure to Achieve Adequate! Separation-Between Redundant S

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Related Wiring-

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FSAR, Section 8.3.1.4.10 states, " Separation of redundant devices

and components is-accomplished by mounting them on phys

arated control boards.

Where this mounting is not feasible from a

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plant' operational point of view,- ..., separation is achieved

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.six inch minimum airspace or by 'a fire retardant barrier " This

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2323-MS-605, Revision 1, paragraph 3.6.7.2

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Boards.

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Contrary to the above:

Boards where Jhe__.sep_aratipn between redund

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less than sitinches. (two-inches 'in,some cases) iring is significantly

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This finding-bas been reviewed with and confirmed by the li

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without barriers.

representatives.

This is a deviation.

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0FFICE OF IllSPECT10tl At:0

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3M

REGION IV

Report flo.

2

50-445/79-04; 50-446/79-04

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Docket flo. 50-445; 50-446

Category A2

'

Licensee:

Texas Utilities Generating Company

2001 Br

'.

Dallas,yan Tower

>

Texas

75201

Facility flame:

,

,

\\

Cominche Peak, Units 1 & 2

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Inspection at:

Comanche Peak Site, Glen Rose, Texas

Inspection conducted:

February 5-8, 1979

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Inspectors:

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L. D. Gi bert', Reactor Inspector, EngineeriMS7[27

Support Section (Paragraph 3)

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J. 1.

, pia, Reacto

t Section ( aragraphs 5 & 6) inspector, Engine

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L. E. Martins Reactor inspector, kngineerin2/27/7'9

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S,upport S$ction (Paragraphs 1, 2

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, 4, 7 & 8)

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Other

Accompanying

Personnel:

R. E. Hall, Chief, Engineering Support Se ti

(February 5 & 7, 1979, only)

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Reviewed:

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p)R.G. Taylor,ResidentInspector,ProjectsSec_ tion

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Date

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Approved:

@,.ffhIMN-

[1 W. A. Crossman, Chief, Projects Se

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pupLICATE DOCUMENT

R. E. Hall, Chief,

.

Entire docum nt previously

entered into system under:

ANO

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No. of pages:

9

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- Inspection Summary:

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. Inspection on February 5-8,1979 (_ Report flo. 50-445/79-04; 50-446/79-04)

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Areas-Inspected:

Routine, unanntiinced inspection of- construction activi-

ties-including site tour; ~ review of procedures and records; and observation

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of workein progress' for Reactor- C)olant Pressure Boundary Piping, Unit 1,

electrical ~ components and systems , and structural concrete. ' The~ inspection

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involved 'eighty-seven inspector-hours by three f1RC inspectors.

Results:

3

0f.the'seven areas insp!cted, one' apparent item of noncompliance

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was identified in one ' area (infraction - failure to follow approved proce-

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dures-for raaintenance of equipmert in' storage - paragraph 5); one apparent

deviation in another. area (FSAR -- failure to. achieve adequate wiring sep-

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aration - paragraph 2); and one unresolved item-(concrete mix-design

requirements

. paragraph 6).

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