ML20205L966

Const Insp Repts 50-445/86-20 & 50-446/86-17 on 860701-0831.Violations Noted:Failure to Specify Documents/ Revs,Describe Work Operations & Failure of Qa/Qc to Adequately Monitor/Assure Traveler Sys Implementation

ML20205L966
Person / Time
Site:	Comanche Peak
Issue date:	03/24/1987
From:	Barnes I, Phillips H, Spessard R, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20205L898	List: IR 05000445/1986020 ML20205L894 ML20205L926 ML20205L966
References
50-445-86-20, NUDOCS 8704020235
Download: ML20205L966 (23)

See also: IR 05000445/1986020

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APPENDIX B

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CONSTRUCTION INSPECTION REPORT

U.S. NUCLEAR REGULATORY COMMISSION

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NRC Inspection Report:

50-445/86-20

Permits:

CPPR-126

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50-446/86-17-

CPPR-127

Dockets: 50-445

Category: A2

50-446

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Construction Permit.

Expiration Dates:

Unit 1: August 1, 1988

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Unit 2: August 1,:1987; -

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Applicant:

Texas Utilities Electric Company.

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Skyway Tower

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400 North Olive Street

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Lock Box 81

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Dallas, Texas

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Facility Name:

Comanche Peak Steam Electric Station (CPSES),. Units.'1 & 2

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Inspection At:

Glen Rose,-Texas

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Inspection Conducted: July 1 through August 31, 1986.'

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Inspectors:

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H. S. Phillip(, Senior R%sident Reactor

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Inspector, Construction, Region IV

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CPSES Group

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(paragraphs 1,2,3,4,5,6,7,8,

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and 10)

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P. C. Wagner, Reactor Vnspector, Region IV

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CPSES Group

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(paragraph 9)

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Consultants:

EG&G - A. Maughan (paragraph 9)

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Parameter - J. G. Gibson (paragraph 9)

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8704020235 870330

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ADOCK 05000445

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Reviewed By:

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R. L. Spessard7 Deputy Director, Division of

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Inspection Programs, Office of Inspection

and Enforcement

Approved:

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3/27/97

I. Barnes, Chief, Region IV CPSES Group

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Inspection Summary

Inspection Conducted: July 1 through August 31, 1986 (Report 50-445/86-20)

Areas Inspected: Routine, unannouriced inspection of applicant actions on

previous NRC findings.

Results: Within the one area inspected, one violation, with multiple examples,

was identified (failure to specify documents / revisions, describe work

operations, and obtain Westinghouse approval on travelers, paragraphs 5b(2) and

5b(3) and failure of QA/QC to adequately monitor / assure traveler system

implementation, paragraph Sc).

Inspection Conducted: July 1 through August 31, 1986 (Report 50-446/86-17)

Areas Inspected: Routine, unannounced inspection of plant status; general

plant conditions; applicant actions on previous hRC findings; installation of

electrical, mechanical, and support components; safety-related pipe welding;

steam generator installation; control rod position detectors; and electrical

work activities.

Results: Within the eight areas inspected, two violations one with multiple

examples, were identified (a. failure to specify document / revision and obtain

Westinghouse approval on NSSS equipment travelers, paragraph 5b(2); failure to

describe work operations or reference procedures in travelers, paragraph 5b(3);

failure of QA/QC to adequately monitor /e sure traveler system implementation,

paragraph Sc; failure to have work traveler package at worksite, paragraph 6;

b. failure to issue NCR on steam generator name plates and documentation,

paragraph 7).

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DETAILS

1.

Persons Contacted

Applicant Personnel

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• • • J. Audas, Senior Licensing Engineer, Texas Utilities Generating

Company (TUGCo)

• • • J. Barker, Engineering Assurance Manager, TUGCo

• • T. Brandt, TUGCo Quality Engineering (QE) Supervisor, EBASCO

• • R. Camp, Project Manager, Unit 1, TUGCo

• W. Counsil, Executive Vice President, TUGCo

• P. Halstead, Manager, Quality Control (QC), TUGCo

• J. Kuykendall, Vice President, TUGCo

D. McAfee, Quality Assurance (QA) Manager, TUGCo

• • • J. Krechting, Director of Engineering, TUGCo

• • J. Merritt, Director of Construction, TUGCo

• • L. Nace, Vice President, TUGCo

• J. Streeter, Director of QA, TUGCo

• • • T. Tyler, Comanche Peak Response Team (CPRT) Program Director, TUGCo

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• F. Powers, Assistant Unit 1 Project Manager, TUGCo

• • • • C. Welch, QC Services Supervisor, TUGCo

Contractor Personnel

R. Baker, Assistant Manager Regulatory Compliance, Brown & Root

(B&R)

R. Vurpillat, QA Manager, B&R

B. Wright, Welding Engineer, B&R

The NRC inspectors also interviewed other applicant employees during this

inspection period.

• Denotes personnel present at the August 7, 1986, exit interview.

• • Denotes personnel present at August 7 and September 5, 1986, exit

interviews.

• • • Denotes personnel present at September 5, 1986, exit interview.

• • • • Applicant representative at August 13, 1986, meeting to discuss

details of violations identified.

See paragraph 10 of this report.

2.

Plant Status, Unit 2

The NRC inspector discussed the status of work with TUGCo and contractor

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(electrical and mechanical) management personnel.

Project status reports

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were also reviewed.

Construction has turned over approximately 56% of the

subsystems to TUGCo Startup and overall construction is about 83%

complete.

3.

General Plant Inspections, Unit 2

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At various times during the inspection period, the NRC inspector conducted

general inspections of the Unit 2 reactor, safeguards, and diesel

generator buildings.

Selected rooms in these buildings were inspected to

observe current work activities or major safety related equipment which

was stored in place.

The storage inside these buildings and the storage

area for steel supports located just outside Unit 2 were also inspected.

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One backshift inspection was performed during this inspection period.

No violations or deviations were identified.

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4.

Applicant Actions on Previous NRC Inspection Findings, Units 1 and 2

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a.

(0 pen) Unresolved Item (445/8516-U-04; 446/8513-U-04):

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action on IE Bulletin 79-28.

In early November 1985, the NRC

inspector found that 2 of 14 NAMCO switches inspected had

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identification numbers on the travelers which did not match the

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identification numbers on switches installed on residual heat

removal (RHR) valves 1-HCV-606 and 1-FCV-618. At this time only

travelers EE82-1415-5801 and EE83-1851-5801 were found; however,

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approximately 1 1/2 to 2 months later, TUGCo located and submitted

travelers EE83-0459-5801 and EE83-0373-5801 to the NRC inspector to

show that the identification of installed switches was consistent.

with the documentation.

The NRC inspector found that the number of switches replaced in

Unit 2 was unavailable.

After the NRC inspection period ended, two

generic nonconformance reports (NCRs) E83-01074, R2 and E83-01077,

which required replacement of switches in Unit 2, were located.

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specific item remains unresolved pending the review of the NCRs and

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corrective actions for Unit 2.

b.

(Closed) Unresolved Item (445/8614-U-02; 446/8611-U-04):

Redlining

cable tray welds on new design drawings.

This item pertained to the

practice of redlining new design drawings when craft / engineering

inspected and found undersized welds on cable trays which had been

previously installed, inspected, and accepted to old design

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documents.

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The NRC inspector reviewed the documentation maintained by the TUGCo

QA organization and found that nonconformances will not be generated

because Corrective Action Report (CAR) No. 53, Revisions 0, 1, and 2,

dated November 26, 1985, January 3 and 31, 1986, will cover this item

generically.

The redlined drawings identifying these undersized

welds will be maintained or referenced in the CAR file to show

deficiencies identified and corrected as a part of the generic

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corrective action.

The final step after correcting or modifying

these hangers will be QC inspection for acceptance and, if

unacceptable welds or as-built conditions are identified at this

point, NCRs will be issued.

No violations or deviations were identified.

5.

Installation of Electrical, Mechanical, and Support Components, Units 1

and 2

a.

Review of Procedures, Instructions, and Drawings

The NRC inspector reviewed B&R Procedure CP-CPM-6.3, Revision 1,

dated 1978, through Revision 12, dated July 14, 1986, and found that

the traveler controls the work activities either by the description

of work on the traveler or through references to multiple

construction procedures, drawings, specifications, and other

documents which control work activities.

The traveler is also used

as a QC checklist to assure that work activities are performed and

documents the inspection in those cases where no inspection report is

required.

As a result of this review, two open items were identified

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as follows.

Paragraph 3.1.1 of CP-CPM-6.3 discusses Westinghouse (W) site

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organizational approval of travelers when work involves Nuclear Steam

System Supplier (NSSS) equipment.

Although it is clear that major

equipment travelers must be approved, this paragraph does not clearly

state whether this means only large equipment, small equipment, or

all equipment.

The W role is also unclear as their organization is

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not described in the TUGCo QA program.

This is an open item

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(445/8620-0-01; 446/8617-0-01).

Attachment 3 of B&R Procedure CP-QAP-12. " Mechanical, Component

Installation Verification N-5 Certification," Revision 7, dated

April 4, 1986, shows 18 items that are verified on the operational

traveler for N-5 Certification.

Item No. 18 involves verifying the

code class of items.

Procedure CP-CPM-6.3 for processing travelers

does not address entering the code class.

This is an open item

(445/8620-0-02; 446/8617-0-02).

b.

Inspection of Completed Work and Records

The NRC inspector observed completed work rather than work in

progress because major safety-related components have been in place

for some time.

This activity was accomplished by observing

components in place and reviewing records of work activities.

(1) Receipt Inspection, Material Certification, and Nonconformance

Reports

The NRC inspector reviewed nine receiving inspection reports,

five material receiving reports, eight }{ quality releases, and

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two nonconforming reports for NSSS components listed in

Appendix C, Table 1.

No violations or deviations were identified.

(2) Traveler Preparation, Review, and Approval

The NRC inspector selected 21 travelers that were processed

between 1979 and 1983 which controlled work such as rigging,

setting, and installation of NSSS equipment. These travelers

were reviewed to determine if they were prepared, reviewed, and

approved in accordance with Procedure CP-CPM-6.3.

Procedure CP-CPM-6.3, Revisions 1-12, has consistently required

general information on the traveler such as traveler number;

equipment number; reactor unit number; quantity; activity

description; reference drawings; specification, work procedure

and/or engineering instruction; location of work system; and

review / approval block.

This information is required in blocks

1-10 of the traveler form. This information was generally on the

traveler except for the following information which was of ten

missing in blocks 7 and 8 of the form; i.e., reference drawings

and specifications, work procedure and/or engineering instructions.

Paragraph 2.1.1 of CP-CPM-6.3 requires that operations,

description, methods, and procedures (including instructions) be

provided on the traveler by number and revision.

Paragraph 3.1.2 states that it is the responsibility of the

organization controlling the traveler to ensure that the current

document revision number is referenced on the traveler.

Paragraph 3.1.1 requires the discipline engineers or

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construction personnel to obtain }{ approval of the traveler if

it involves NSSS equipment.

The NRC inspector found that 16 of 21 travelers processed to

control work on NSSS equipment were not prepared and reviewed in

full accordance with paragraphs 2.1.1, 3.1.1, and 3.1.2 of

CP-CPM-6.3 as shown in Appendix C, Table 2; i.e.,

document / revision and W approval.

The NRC inspector selected seven additional travelers to

determine if recently processed travelers were processed in

accordance with CP-CPM-6.3.

These travelers, listed in

Appendix C, Table 3, were processed from 1984 to 1986 and were

used to control electrical, mechanical, and hanger work

activities.

In addition to procedural requirements previously referenced,

paragraph 2.2.1 of later revisions of CP-CPM-6.3 (Revisions 10

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through 12) requires that room location, where work will be

done, be provided.

The NRC inspector found that each of the seven recently

processed travelers were not prepared and reviewed in full

compliance with paragraphs 2.1.1, 2. 2.1, 3.1.1, or 3.1. 2 as

shown in Appendix C, Table 3.

Blocks 7, 8, 9, and 10 did not

contain the information required; i.e., document / revision,

location, and system.

This failure to prepare and adequately review travelers to

assure that the correct documents and revisions are specified

and obtain W approval for work on NSSS equipment is a violation

of Criterion V of Appendix B to 10 CFR Part 50 (445/8620-V-03;

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446/8617-V-03).

(3)

Installation Instructions for NSSS Equipment and Accessories

(a) The NRC inspector evaluated completed work described on

travelers for two large heavy pieces of NSSS equipment,

nitrogen air tank (CP2-SIATRT-01) and accumulator

(TCX-SIATRT-03), a part of the Unit 2 Safety Injection

System.

Paragraph 2.1.1 of CP-CPM-6.3, Revision 9, requires that

the traveler not only provide the general information

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previously discussed, but also requires detailed

information described in the work operations.

Any other

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information as required to successfully complete the

operation in accordance with applicable requirements is

also required.

The following traveler deficiencies in the description of

work operations (steps) were identified:

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1)

Traveler ME83-2702-5700 for installing tank No. 1,

dated March 8, 1983, did not reference MCP-1 General

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Installation of Mechanical Equipment, or incorporate

the necessary procedural steps of this procedure into

the traveler.

As required by paragraph 4.1.2, the

traveler did not specify minimum clearance between

equipment base and foundation.

As required by

paragraph 4.2.3 of Revision 3, rigging traveler

RI83-1051-5700 for tank No. 1 did not specify that QC

will be notified 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to equipment

installation and did not describe t.he loading and

transporting equipment used.

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As required by paragraphs

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MCP-1, Revision 3, trav.ser MC79-260-5700 for tank

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No. 3 did not descri b the leveling and shimming to

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assure proper installation.

It also did not include

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an operation which describes tightening the nuts to

secure the tank to anchor bolts.

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In the operational steps of the traveler for tank

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No. 3, grouting was specified in accordance with

CPP-16; however, no revision was documented on the

traveler.

4)

Operation Nos. 2 and 5 were revised after the traveler

was approved.

Operation No. 2 was a minor change;

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however, No. 5 was a major revision as a step which

had been left out was added.

Such changes were not

approved or noted as revisions.

(b) The NRC inspector reviewed travelers and found that work

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steps or operations for Class 1E switches installed on

valve 1-HCV-606 did not adequately describe all work

operations or reference appropriate project procedures.

The following are examples:

1)

Operation No. 1 on traveler EE82-1415-5801 differed

from that contained in traveler EE83-0459-5801, a

traveler which replaced the same switch, in that

EE82-1415-5801 traveler cautioned that determinating

the conductors should be done gently to prevent damage

while the other traveler did not mention this

instruction.

Both travelers stated that NAMCO

switches should be determinated "per standard

construction practices"; however, this standard

practice was neither described in the traveler nor

referenced in a written instruction such as Procedure

EEI-8, " Class IE and Non-Class IE Cable Termination,"

or other standard instruction manual.

Similarly,

Operation No. 5 of traveler EE82-1415-5801 stated that

retermination should be done "per standard

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construction practices."

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2)

Traveler EE83-0459-5801 stated that back cover screws

should be torqued to 20 in-lbs, per EEI-21 but

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EE82-1415-5801 traveler did not mention EEI-21 in

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block 8 or in subsequent traveler operations.

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traveler stated whether the installation should be in

accordance with paragraphs 3.0, 4.0, or 5.0 (which are

instructions for different locations of switches).

Traveler EE82-1415-5801 did not clearly describe the

torquing of terminal and top cover screws as described

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in EEI-21, Revision 0, dated August 20, 1982.

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This failure to provide or describe work operations is a violation of

Criterion V of Appendix B to 10 CFR Part 50 (445/8620-V-04;

446/8617-V-04).

c.

QA/QC Monitoring of System Implementation

The NRC inspector reviewed QA/QC activities concerning the

development, review, approval, and inspection activities in 28 work

travelers (Appendix C, Tables 2 and 3) which cover work that was

accomplished between 1979 to August 1986.

Paragraph 2.1 of CP-CPM-6.3, Revision 12, states that the B&R Site QA

Manager is responsible for monitoring the implementation of this

system.

The NRC inspector found that the system had not been adequately

monitored to assure implementation.

Twenty-three of 28 travelers,

dating back to 1979, contained one or more deficiencies and were not

adequately reviewed to assure compliance with construction, QA

procedures and the equipment manufacturer's manual.

Seven travelers

(EE86-41073-2-4901, EE84-40170-2-5501, EC85-JB-2C-4870

EE86-4069-2-5701, HS86-4450-1-3100, HS86-4293-1-4900, and

MP85-4901-5100) are recent examples which indicate this condition

currently exists.

Specific examples are as follows:

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(1) Paragraph 3.6 of CP-CPM-6.3, Revisions 5 and 9 in effect in

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1979 and 1982, requires that revisions, regardless of their

significance, shall be documented by revision numbers and a

description of the change after the last step of the traveler.

Travelers RI83-1051-5700 (1-19-83), Operation 5 for rigging and

hoisting a tank added a step; dimensions were changed on

ME83-2702-5700 (3-8-83), Attachment No. 1; and ME79-260-5700

(3-27-79), Attachment No. 1, without documenting revision number

or describing the change.

(2) Paragraph 2.2.1 of CP-CPM-6.3, Revision 11, dated August 8,

1984, and Revision 12, dated July 14, 1986, requires the QC

inspector to annotate the applicable inspection / revision numbers

on the traveler operation at the time of the inspection.

Paragraph 3.1.2 of CP-CPM-6.3, Revisions 11 and 12, which were

in effect in 1985 and 1986 requires the CC inspector to record

the design document revision level used at the time of final

inspection.

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Columns 3 and 4 of Table 3 of Appendix C shows that QC inspectors

did not annotate inspection and/or revision numbers on four of

seven travelers and did not record the design document revision

level on three of seven travelers used at the time of final

inspection.

In addition, paragraph 3.0 of QI-QP-11.1-47

Revision 10, dated June 21, 1984, " Electrical Inspection of

Class IE Limit Swifches," states, in part, "The QC inspector

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shall inspect the installation of Class IE limit switches to the

latest revision of all referenced documents."

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Specifically, traveler EE84-40170-2-5501, part No. 1 did not

reference EEI-21 and EEI-8 and the QC inspector did not annotate

the applicable inspection procedure revision number on the

traveler at the time of inspection as required by CP-CPM-6.3,

Revision 11.

Therefore, there is no indication on the traveler

that the inspection was accomplished to the proper revision;

and likewise for traveler EE86-41073-2-4901.

Similarly,

EE83-0459-5801 did not state, as required, current procedures

and revisions which were used.

(3) Paragraph 3.2 of B&R Procedure QI-QAP-11.1-39, Revision 0 (2-2-83),

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states, in part, "QCI shall verify . . . b. The top of the concrete

foundations are free of oil, grease, and foreign materials."

No such operation or inspection was described on traveler

ME83-2702-5700 (3-8-83) for setting the nitrogen air tank.

(4) Paragraph 3.4.1 of QI-QAP-11.1-39, Revision 0 (2-2-83) states,

in part, "QCI shall verify that equipment is positioned, oriented,

and set to elevation as shown on Level / Location / Elevation / Record

(Attachment 1)" and paragraph 5.0 states, in part, "QCI shall

sign and date . . . Record (Attachment 1)."

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Attachment 1 of ME83-2702-5700 (3-8-83) was not signed and

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dated by the QC inspector to show that the nitrogen air tank was

installed as required.

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(5) Paragraph 3.4.2.2 of QI-QAP-11.1-39, Revision 0 (2-2-83) states,

in part, "b. All equipment excluding rotating equipment and heat

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exchangers may be set using a carpenter's level placed on the

base of machined surface, as appropriate.

The equipment shall

be shimmed so that the bubble is contained between the two

closest lines on the level.

NOTE: for a. and b. above, (quipment

setting requiring grout, a minimum grout space of one inch shall

be provided at the point of minimum clearance between the

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equipment bases and concrete foundation."

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Neither a minimum clearance was specified on traveler

ME83-2702-5700 (3-8-83) nor was the applicable construction

Procedure MCP-1, Revision 3, referenced.

No evidence of

inspection was shown on the traveler.

(6) Paragraph 3.4.3 of QI-QAP-11.1-39, Revision 0 (2-2-83) states, in

part, "QCI shall verify that anchor bolt threads are not damaged

prior to and during the setting of equipment."

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Traveler HE83-2702-5700 (3-8-83) neither specified the inspection

of anchor bolt threads in the operational steps nor addressed

the tightening of the bolts.

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This failure to adequately monitor traveler implementation to assure

completeness and compliance with QA/QC and construction procedures is a

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violation of Criterion V of Appendix B to 10 CFR Part 50 (445/8620-V-05;

446/8617-V-05).

6.

Safety-Related Pipe Welding, Unit 2

The NRC inspector observed mainsteam spool piece MS2-RB-29-1 which was on

the 905' elevation of the reactor building.

The ends were being prepared

for welding field weld (FW) No. I which will join the spool piece to the

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steam outlet of the steam generator No. 3.

The various welding activities

are recorded on weld data card No. 650239.

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On July 2, 1986, in the same general location, the NRC inspector observed

the post weld heat treatment of FW-27 on a 6-inch feedwater line

FW-2-RB-024R-2 which is shown on Drawing FW-2-RB-024R-2.

During a

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discussion with the attendant who was monitoring the heat treatment

controls, the NRC inspector learned that he was in training.

Copies of

the work traveler and checklist were requested; however, they were not at

the work site but were located a considerable distance away at the weld

rod room outside containment.

Paragraph 3.2 of CP-CPM-6.3, Revision 12, dated July 14, 1986, requires

that the work traveler package remain in the work area until the work has

been completed and accepted by QA/QC or until the end of the shift, which

ever is first.

This failure to maintain the traveler package in the work

area is a violation of Criterion V of Appendix to of 10 CFR Part 50

(446/8617-V-06).

7.

_ Inspection for Steam Generator No. 4 Installation

The NRC inspector. reviewed Final Safety Analysis Report (FSAR),

Section 5.0, Volume 1, Figure 1-2-18, Amendment 10 dated 1980;

Figure 5.1-1, " Flow Diagram Reactor Coolant System," Amendment 54 dated

January 1985; and Gibbs & Hill, Inc. Drawings 2323-A2-502, Revision

(Rev.) 5, 2323-A2-0503, Revision 4, and 2323-0504, Revision 4, to select

and inspect components.

Steam generator loop No. 4 was identified in the

FSAR and Gibbs & Hill drawings as Spin No. TCX-RCPCSG-04 and this

component was selected in order to continue a previous inspection; i.e.,

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the pressurizer (which is a part of loop No. 4) had been previously

inspected.

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In July 1986, the NRC inspector reviewed installation records (which were

in the QA records vault) for steam generator loop No. 4 spin

No. TCX-RCPCSG-04, to complete the planned inspection; however, an

inspection performed during the August 1986 inspection period revealed

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that records previously reviewed were actually for the steam generator

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located in loop No. 1, compartment No. 1.

This matter was pursued by

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discussing the deficiency with W personnel.

The NRC inspector found that

no NCR had been written; however, several letters (written in 1980)

discussed the fact that the spin numbers were incorrect.

Texas Utilities

,

Service, Inc. letter (CPPA-6244) dated August 25, 1980, and

telecommunications (TWX #12,309) dated June 27, 1980, requested W to

correct the deficiency by changing the name plates and documentation.

The

name plates and documentation were not changed.

As a result, the

'

hardware, the FSAR, drawings, and QA documentation is incorrectly

identified.

The same is true for loops 2 and 3.

Subsequent to NRC

identification of this condition, NCRs M-2875, M-2876, M-2877, and M-2878

were written.

i

This failure to write an NCR and correct FSAR and Gibbs & Hill drawings is

a violation of Criterion XVI of Appendix B to 10 CFR Part 50

(446/8617-V-07).

8.

Installation of Control Rod Position Detectors. Unit 2

a.

Storage / Handling

The NRC inspector observed the storage and handling of three control

,

rod drive (CRO) position detectors (equipment No. TCX-RCPCRV-01)

which were removed from the warehouse "C" to the staging area at

Unit 2 equipment hatch.

The handling of these components was

controlled by traveler HW86-7528-2-5501 which authorized movement to

the 905' elevation of the reactor building.

The rigging was

accomplished in accordance with B&R Procedure CP-24, Revision 4,

dated June 26, 1980.

b.

Detector Installation

The NRC inspector witnessed the cleaning (with demineralized water)

of the CR0 rod travel housing which the detector fits over.

Detector

M2-SN34SH00194 was placed in accordance with the traveler and

W Drawing 1533E84, Revision 3.

The NRC inspector observed detector

Nos. 04, and L3 which had previously been placed,

c.

Installation Record

The NRC inspector reviewed the subject traveler, drawing, and the

sign off sheet attached to the traveler.

No violations or deviations were identified.

'

9.

Inspection of Electrical Work Activities. Unit 2

The NRC inspector observed the following, in process, electrical work

activities:

l

\\

l

!

.

- -

-

-

-

-

-

-

-

- -

-

- -

-

t

l

.

.

l

l

13

!

I

a.

Installation of Class IE Cable

l

(1) Cable Reel Storage

The NRC inspector toured the electrical cable storage yard to

evaluate the adequacy of the storage activities.

The NRC

'

l

inspector noted that all cable reels were uniquely identificd by

number and that those reels which had not, as yet, been QC

accepted were segregated from the others.

The NRC inspector

noted that plastic sheeting was used to cover the Class 1E

l

cables and verified that the cable ends, for approximately ten

Class 1E cables, were sealed with either heat shrink tubing caps

or electrical tape,

.

i

No violations or deviations were identified.

(2)

In-Process Storage

The NRC inspector made the following observations of in process

cable stor N ':

(a) Cables removed from cable tray T240SF0, located in the

Unit 2 safeguards building, were coiled, hung from piping,

and covered with plastic for protection while modifications

were performed on the cable tray.

In addition, the

immediate area was roped-off and tagged "No work in area

without QC notification."

(b) Cables to be installed in cable tray T240RDD, located near

electrical penetration assembly 2E65 on the inside of the

Unit 2 reactor building, were coiled, hung from

scaffolding, and covered with flame retardant material in

preparation for being connected to the penetration

assembly.

.

(c) Cables in cable trays T23GRCL and T22GRBM, located in the

lower level of the Unit 2 reactor building, were protected

from painting activities in the area by wrapping the trays

with plastic sheeting.

As part of daily plant tours, the NRC inspector verified that

electrical cables were protected from cutting, grinding, and

welding activities in their vicinity by covering with fire

retardant blankets or boards during these activities.

The NRC

inspector also observed: (1) that cable, cable tray and conduit

identification, both color coding and numerical designations,

were being properly applied and maintained; and (2) that damaged

'

components were identified by red "QC lloid" tags, indicating

that NCRs were written for the disposition of the problem.

I

l

No violations or deviations were identified.

I

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i

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.

. - .

.-

.

-

- - _ -

.

-.

-

_-

_-

<

l

.

.

14

(3) Electrical Cable Installation

l

The NRC inspector witnessed the termination of cable E0245751 in

Unit 2 cable spreading room termination cabinet CP2-ECPRCR32.

The instrument cable contained two conductors and a shield wire,

which were terminated on a Weidmuller terminal block.

The NRC

inspector verified that: (a) the connections were made in

accordance with the applicable drawing, (b) cable identification

was preserved, (c) cable bend radius was maintained, and (d)

wire stripping was performed in accordance with the applicable

procedures.

The termination of cables EG224092Z, EG224182Z, EG224182X, and

EG224092V, Y, and W in junction box J82C-484C and the

retermination of cable EG239372, involving twisted shield wires,

was also observed.

Project QC inspectors witnessed the

termination and continuity testing of the latter cable which

were performed in accordance with the applicable drawings and

procedures.

Tape was observed to be covering the outer jacket of a cable

l

that was routed through conduit C13018589 located in the Unit 2

I

safeguards building. A review of appropriate records showed

that the above conduit contained electrical cables A0 009333 and

A0 104419 and that a cable jacket repair had been satisfactorily

performed.

The NRC inspectors also performed more detailed inspections of

the Class 1E and associated cables, conductors, and terminations

at the Unit 2 hot shutdown panel, CP2-ECPRLV-01, and the

.

shutdown transfer panel, CP2-ECPRLV-15.

These inspections were

of approximately 321 cables comprising 1,925 terminations and

related jumpers.

The NRC inspections consisted of observations to determine if:

(a) cable, wire, and termination materials were as specified.

(b) cable identification was preserved and' located where

.

i

specified; (c) bending radius was.as specified; (d) required-

'

separation and independence was maintained; (e) segregation was

maintained; (f) any evidence of damage existed;'(g) the

terminations were properly located and made and of the correct

type; (h) cable supports were provided and were adequate; (i)

cables and conductors were protected from sharp edges, hostile

environments and adjacent construction activities; (j) the

panels were maintained free of debris; and (k) specified fire

barriors, compartment boundary seals and fire retardant

materials were installed or applied where required.

In

addition, as-built verification was performed by obtaining the

latest revision of the installation drawings and unincorporated

design changes to the applicable drawings, and then comparing

i

these documents with the actual installation.

.

.

15

!

During the inspection of the above items, the NRC inspectors

identified the following conditions:

(a) Unit 2 Hot Shutdown Panel (CP2-ECPRLV-01)

1)

Drawing 2323-E2-0173-01, Rev. 2, 9-20-84

Drawing shows cable EG224092 connected to TB11.

.

Cable was physically identified in panel as

"E2-224092."

Drawing shows jumpers from TB14, terminals 80 and

.

81, to TB7, terminals 145 and 146 on Drawing

E2-0193.

These jumpers were not physically

installed.

Drawing shows a jumper from TB14, terminal 78 to

.

terminal 81.

The jumper was not tight under the

terminal 81 screw.

2)

Drawing 2323-E2-0192, Rev. 3, 8-21-84

Drawing shows cable EG204523 with two conductors

.

identified as "SP(BW)" and "SP(BLB)." These

conductors were not physically identified as

nSp,n

The flex communication cable sheath was not

.

connected at the box mounted on the vertical

divider.

Also, the plug.was not fully engaged at

the floor mounted box.

3)

Drawina 2323-E2-0193, Rev. CP-1, 7-7-86

At 105, terminal 51, a vendor installed terminal

.

lug was bent apparently in excess of 90 degrees.

'

Drawing shows cable E0204734 had an unlanded

.

spare conductor identified as "SP(WB)."

Physically, conductor "WB" was landed at TB5,

terminal 85.

A jumper was physically installed at TBG, between

.

terminals 1 and 7, the drawing does not show this

jumper.

The jumpers shown on the drawing at TB7,

.

termdnals 145 and 146, were not installed.

\\

.

.

16

(b) Unit 2 Shutdown Transfer Panel (CP2-ECPRLV-15)

1)

Drawing 2323-E2-0173, Rev. CP-1, Sheet 15, 5-15-86

General Coment - It would appear that certain

.

revisions made by CP-1 are physically

accomplished, while others are not. This

revision incorporates alread

changeauthorizations(DCAs)yissueddesign

and a package

processing form (PPF).

Drawing shows cable E0206065 with conductors

.

landed on TBl.

The cable was physically

identified as E0206965.

Cable E0211195, conductor GLB was physically

.

landed at TB3, terminal 47. The drawing does not

show this connection.

!

'

Drawing shows cable E0211195, conductor OB landed

.

at TB3, terminal 50. The conductor physically

installedwasBL(blue).

l

l

Drawing shows a jumper at TB3 between terminals

.

96 and 101.

This jumper was not installed.

l

Drawing shows cable E0211195, conductors BLB and

.

BW, landed at TB3, terminals 116 and 117.

(

respectively. These conductors were not

I

physically installed at these terminals.

Drawing shows cable E0209831 has spare conductors

.

SP(B,0). These conductors were physically landed

at TB4, black (B) at terminal 1, and orange (0)

at terminal 11.

Drawing shows cable E0211317 has spare conductor

.

SP(B); however, the black (B) conductor was

landed at TB4, terminal 41.

Drawing shows cable E0209801 has unlanded spare

.

l

conductorSP(W).

This conductor was physically

landed at TB4, terminal 33.

Drawing shows cable E0209836 has unlanded spare

.

conductorsSP(B,0). These conductors were

physically installed at TB4, terminals 63 and 73,

respectively.

Cable E0211318 had conductor WR landed at TB4,

.

.

l

terminal 64, and conductor 0, landed at TB4,

l

l

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.,

.

.

.

,

,

.

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i

17

i

'

I

-

,

-

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terminal 72.

The draw %g ooes not show these

[

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connections.

'

,

Cable E0209802 hadconductar/RlandedatTbN

i

.

terminal 65.

The drawirg' dens not show this';

.

connection.

, , .

Drawing shows catie E0209839 has two unlanded

'

-

,

.

, ,

l

spare conducto,rs, SP(B, 0).

Thesc-conductors

-

...

were physically installed at TB4 terminals 94 ,

,

,

and 104, respectively.

-

,

,

Drawing shows cable E0209806 has aniunlanded

.

spare conductor SP(W).

This conductor was

7

,

,

physically installed et id4, terminal 95. ,J

'

Drawing shows cable LO211319 has unlanded spare

.

conductors SP(5', 0, OL, WB).

The B ard 0

-

conductors were phys!cally installed at 10g,

terminals 96 and 103, respectively.

2)

Drawing 23;'3-E2-0173. Revision' CP-2. Shekt 36, 4-23-P6

w

,

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l

Drawing shows six conductors landid at NB10,,

'

.

terminals 119 through 124, which are fp m cafd

. ame assu.:bly /,, Connector J-8.

Theu

'

'

conductors were not physically installee!,

.

,

.

~

'

Drawing shows six con @Jctors landed at TB11,

.

terminnis 119 through 124, wnich ara from card

frame casembly A, conr.,tetor J-7.

These

'

conductors weri not physically installed.

.

Drawing shows cable E0211101 with conductors

N

.

landed at T812.

This cable was not installed.

l

Drawing shows cable Eu,?06212 has an unlanded

'

.

'

spare conductor SP(0).

This cunductor was

physically installed at T012, terminal 98.

,

At TB12, terminal 98, there were additional

.

, , .

orange and red conductors installed.

The

drawings does not show these ronductors.

.

Cable E0211102 bad conductors'RB vnd AB Qttelled

.

l

at YB12, terminals 110 and 118. Wspet.tinly.

-

,

'

The drawing does not show these connectfuns.

j

P

Drawing shows cable E020G212 hrs snianded spare

.

l

coniluctor SP(B).

This conductor van' physically

-

installed at TB12, terminki 117,

iure was also

-

,

,

,

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what appeared to be a jumper installed at TB12,

,

i

terminal 117, that is not shown on the drawing.

I

The above identified observations were discussed with

appropriate applicant personnel to ascertain the source of the

!

apparent discrepancies.

These items remain unresolved pending

l

fesults of the applicant's review and response to the apparent

discrepancies (446/8617-U-08).

'

L

-

No violations or deviations were identified.

b.

Installation of Instrunentation

The NRC inspector checked the routing, slope, fittings, supports, and

identification markings of the instrumentation tubing for the Unit 2

-

Containment Spray Pump instruments, 2PT-4775-1, and 2PI-4771-1

-

and -2.

The NRC inspector noted that instrument rack 2LI-21, upon which two

Containment Spray flow transmitter instruments (2FT-4773-1 and -2)

were mounted, had two junction boxes attached to the left side with

_

flexible conduit connected to the instruments.

Neither the junction

box, nor the short piece of conduit connecting the boxes, was

2,

identified by an alphanumeric designation as would normally be

required by CPSES electrical specifications.

All three components-

were, however, identified by green color coding as being safety

related, as Train B components and the incoming conduit were

appropriately designated with both the green color coding and number

C24G08204.

The condition concerning missing designations was

1

,

l

discussed with applicant QE personnel who provided copies of drawings

,

j

to explain the installation.

1

A review of Drawing 2323-E2-2803-01, " Conduit Layout, Seismic

,

'

Instrument Rack," Revision 3, dated September 24, 1984, showed that-

the typical configuration consists of one junction box with rigid

,

'

conduit and conduit fittings routed to the instruments.

However, as

allowed by Note 4 of this drawing, the use of.an equivalent junction

box and flexible conduit can be' substituted for the rigid conduit

!

and/or conduit fittings.

These components are then considered part

'

'

,

of the instrument rack.

The interpretation that the junction boxes

)

and conduits are a part of the instrument rack was further confirmed

)

'

by review of the cable and raceway schedule which indicates the

'

instrument rack as the cable destination.

'

a

1, ,

No violations or deviations were identified.

' <: .

Instrument Tubing Replacement

i

The NRC inspector witnessed the replacement of tubing for loop 4

steam generator level transmitter 2LT-547.

The craft personnel

Estalled the tubing and fitting as required by the drawings and

.

!

i

i

$

'r.

--

, . , .

-

,

- -

,

. . . - - ,

- . - - - - .

,

, . , ,

.

-

. .

-

-

.-.

.

.

!

19

procedures.

No QC was present during the installation.

This

l

installation was to be inspected by QC at a later date.

l

No violations or deviations were identified.

l

10.

Exit Interview

l

Exit interviews were. conducted on August 7 and September 5, 1986, with the

!.

applicant's representatives identified in paragraph 1 of this report.

l

During these interviews, the NRC inspectors summarized the scope and

findings of the inspection.

The TUGCo Director of QA responded during the

l

August 7, 1986, exit interview to the findings concerning work travelers

by stating that they too were reviewing travelers.

He requested a meeting

to determine if they had independently identified the deficiencies

regarding travelers prior to the NRC inspector's identification of a-

violation in this area.

In a subsequent meeting on August 13, 1986, with the TUGCo Director of QA

and his representative, they stated that they had found that the failure

to follow traveler Procedure CP-CPM-6.3 had caused or contributed to two

hardware problems; i.e., engineering failed to generate a control-document

to accomplish rework of Bunker' Ramo electrical penetration splices and the

failure to process operational travelers for shortening upper lateral

restraint anchor bolts of;the steam generator may have caused this

deficiency. These causes were described in TUGCo response (TXX-4946) to

NRC Notice of Violation dated May 2, 1986.

- -

The TUGCo Director of-QA stated that their review had not revealed the

deficiencies in the traveler system as described in detail by the NRC

inspector.

The applicant acknowledged the, findings.

-

.

l

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=

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. APPENDIX C

M

c'<

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'

'

'

'

Table 1

-

-

-

c

l

_

.

,.

Item

Identification

• RIR

• MRR

• • W QR/ [' ' '

e

NCR

i

l

Accumulator

TCX-SI-ATAT-02

04705

1206

35666

Tanks

TCX-SI-ATAT-03

04705

1206

35667

l

Accumulator

2-8806C

11801

5908

30238

'

10" motor

operator valve

2-36" Nitrogen

CP-2-SI-ATRT-01

19742'

10849

2383

Accumulator

CP-2-SI-ATRT-02

19742

10849

.2383

Tanks, rings and

hardware

s

i

Pressurizer (PZ) TCX-RCPCPR-01

10317

26135/

M-3291;

M-11395

j

,

PZ - 3" Pilot

PCV-2-455A

4750

35199

operated relief

PCV-2-4568

valve

,

(

PZ - 6" Safety

SN-56964-00-0068

03881

36111

i

Relief Valve

l

NDE Records for

TCX-RCPCSG-01/

'15775

02/03/04; and

TCX-CRPC-PR-01

l

• Denotes: RIR - Receiving Inspection Report

l

MRR - Material Receiving Report

l

W QR/NCR - Quality Report /Nonconformance Report

.

-~

. _ - -

.

'

,

..

.

APPENDIX C

Ta.ble 2

Equipment /'

• I.D.

No.

Doc./Rev. S)ecified W

,

Traveler No.

Dwg. Spec.

) roc.

Kpp.

r

Nitrogen

CP2-SIATRT-01

Accumulator Tank

' No.1

RI83-1051-5700

N

N

N

NA

ME83-2702-5700

C

C

N

NA

Accumulator Tank TCX-SIATAT-03

No. 3

'

ME79-260-5700

N

N

N

N-

RI79-182-2-5700

C

N

N

C

CR0 Position

TCX-RCPCV-01

i

i

Detectors

t

MW867528-2-5501

C

N

N

C'

-

Reactor Vessel

TCX- RCPCRV-01

'

,

ME79-248-5500

N

N

N

-C'

'

-

,

'

4

Pressurizer

TCX-RCPCPR-01

-

.

ME85-4896-5500

C

NA

NA

C. .

,

,

- - >

ME85-4872-5500

N

NA

NA

'

.N

-

C.

'

-

'

.

-

'

MW86-7510-2-5500

C

C

C

,g

-

.

~

'

Steam Generator

TCX-RCPCSG-04

/'

'

'

"

ME-83-2747-5500

N

N

NA

'C

.

s

,

RI80-369-5500

N

N

C-

C

-

,

CE79-017-5500

C

C

NA

N.

'>

'

ME84-2993-5500

N

N

N

C

i

ME82-2231-5500

C

NA

NA-

C

ME81-2139-5500

C

N

NA

C-

1

ME83-2758-5500

NA

NA

NA

C

ME83-2959-5500

N

N

NA

N

,

,

ME83-2880-5500

C

NA

NA

'C

'

-

.

ME85-4868-5500

C

NA

NA

C

-

• • RHR Valve

1-HCV-606

Class 1E

Electrical

Switches

EE83-0459-5801

N

N

N

0***

,

EE82-1415-5801

N

N

N

0***

,

- .

,

. . . .

. - . . .

,

_ _ . _ . ,

. . _ _ . ,

_

-

1

.-

.

2

Denotes: C - Compliance

N - Noncompliance'

J

NA - Not Applicable

'

• Denotes: 1.D. No. - Identification Number

• • Denotes: Unit 1 equipment

)

• • • Denotes: Open Item

i

l

1

- -

%

4

t

m

i

o

k

. - .

-

.. .

-

-

..

Y

- .

..

i

APPENDIX C

Table 3

Equipment /

Doc.

W

Insp.

' Design Room

Traveler No.

7Rev.

Kpp.

Rev.

Rev.

Location / System

Spec.

Spec.

Unit

EE86-41073-2/4901

N

NA

C

NA

N

C

EE84-40170-2/5501

N

C

C.

'NA

C

C

EC85-JB2C-4870

N

NA

N

C

C

C

EE86-40692/5701

N

NA

C

N

N

N

HS86-4450-1-3100

N

NA

N

N

N

C

HS86-4293-1-4900

N

NA

N

N

N

C

MP85-4910-5500

N

NA

N

NA

N

C

Denotes: Doc./Rev. - Document / Revision

W App. - Westinghouse Approval

Insp. Rev. Spec. - Inspection Procedure Revision Specified

Design Rev. Spec. - Design Document Revision Specified

EE 86 - Traveler issued by electrical department in 1986

.

,

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.

l$

,

J.

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- -

, , , - - -

.

.

,

. , - - - . -

,

-

,

, - - . ,

. . _ , - , .

.,

-

.

,

-