U. S. NUCLEAR REGULATORY COMMISSIONOFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Report No. 50-445/79-25; 50-446/79-24

Docket No. 50-445; 50-446 Category A2

Licensee: Texas Utilities Generating Company2001 Bryan TowerDallas, Texas 75201

Facility Name: Comanche Peak, Units 1 and 2

Inspection at: Comanche Peak Site, Glen Rose, Texas

Inspection conducted: October 3-4, 9-11 and 16-19, 1979

Inspectors: _// 2s/7fL. D. Gilbert, Reactor Inspector, Engineering Datd

Support Section (Paragraphs 1, 3, 5 and 6)(October 9-10 and 16-19, 1979, only)

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L.E'. Martin /ReactorInspector, Engineering /Da t'eSupport Section (Paragraphs 2, 4 and 6)(October 3-4 and 9-11, 1979, only)

Other AccompanyingPersonnel: D. G. Mcdonald, Reactor Inspector, Engineering

Support Section (October 9-11, 1979, only)

h.MI-I ?+ k ///P/ 7Reviewed:R. G. Taylor, Resident Reactor Inspector DateProjects Section

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Approved: ///2/!79W. A. Crossman, Chief, Projects Section Date

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R. E.' Hall, Ch'ief, Eng,if:eering Support Section / Da'te '

Inspection Summary:

Inspection on October 3-4, 9-11 and 16-19, 1979 (Report No. 50-445/79-25;50-446/79-24)Areas Inspected: Routine, unannounced inspection of construction activitiesincluding site tour; observation of work and review of records for safety-related piping; observation of work for Reactor Coolant Pressure BoundaryPiping; and review of QA implementing procedures for electrical cable and afollow-up review of a previously identified item of noncompliance. The inspectioninvolved ninety inspector-hours by two NRC inspectors.Results: No items of noncompliance or deviations were identified.

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DETAILS SECTION

1. Persons Contacted

Principal Licensee Personnel

**R. G. Tolson, TUGCO, Site QA Supervisor**J. B. George, TUSI, Project General Manager**J. Merritt, TUSI, Engineer and Construction Manager*L. M. Popplewell, TUSI, Project Electrical Engineer

Other Personnel

C. Wallace, Piping and Welding QC Supervisor, Brown and Root (B&R)W. Sims, Lead QC Inspector, B&RS. Ali, Mechanical QA Engineer, B&RR. Statham, Pipe Foreman, B&RW. Baker, Project Welding Engineer, B&R

*B. E. Fuston, General Superintendent Electrical Instrumentation, B&R*U. D. Douglas, Construction Program Manager, B&R

* Denotes those attending exit interview on October 11, 1979.

** Denotes those attending exit interview on October 19, 1979.

2. Licensee Action on Previous Inspection Findings

(0 pen) Unresolved Item (50-445/79-06; 50-446/79-06, paragraph S.b.(2)):Quality Control Requirements for Cable Tray Supports. The licensechas an ongoing inspection on non Class IE hangers with a finalinspection on non Class IE hangers to be done by area prior to Hot FunctionalTesting. The non Class IE hangers installed before March 1979 are beingreinspected as seismic Category 1 including welding.

This item will remain open pending completion of this reinspection.

(Open) Infraction (50-445/79-19; 50-446/79-19): Failure to Follow Noncon-formance Procedures for Electrical Cable. NCR E-1570 has been revised toinclude proper identification of all the improperly color coded cable inthe reel yard and installed. The disposition now properly addresses allaspects of the nonconformance description. All of the improperly colorcoded cable reels have been returned to the manufacturer and the fourcables that were installed have been repulled with proper color coded cable.QI-QP-11.3-15 " Electrical Cable Installation Inspection Procedure" has beenrevised (Revision 2) to include cable type and color verification. Theprocedure covering handling of nonconformance reports has been revised toinclude a review by the Quality Engineering Group to insure that the noncon-formance is properly described, the disposition is proper and complete andthat all nonconforming materials are properly identified and controlled.

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This item will remain open pending implementation of the revised trainingprogram as committed in the licensee's response letter to IE InspectionReport 79-19.

(Closed) Unresolved Item (50-445/79-19; 50-446/79-19, paragraph 6.a.):Cable Identificatica Deterioration. The licensee has contacted the cablemanufacturers and determined that the observed deterioration was due toexposure to weather in the cable reel yard. The licensee has chosentwo methods to correct the fading and peeling of the color coding inaccordance with the manufacturers' recommendations: (1) reapply colorcoding using recommended coating onsite; and (2) return selected reels tothe manufacturer for recoating. All cable reels that are susceptibleto deterioration have been covered to prevent further deteriorationdue to exposure.

This item is closed..

3. Site Tour

The IE inspectors toured the Unit 1 and 2 Reactor Buildings and AuxiliaryBuilding to observe construction activities in progress and to inspecthousekeeping.

No items of noncompliance or deviations were identified.

4. Electrical Systems And Components

a. Review of Electrical Instructions and Procedures

The IE inspector reviewed the following procedures to determinecompliance with 10 CFR 50, Appendix B; Chapters 3, 8, and 17 ofthe FSAR; and related IEEE and IPCEA standards:

QI-QP-11.3-4, Revision 10, " Exposed Conduit, Condulet, ElectricalBox and Support Inspection"

QI-QP-11.3-5, Revision 8, " Cable Tray Inspection"

QI-QP-11.3-6, Revision 2, " Lighting Fixture Inspection"

QI-QP-11.3-7, Revision 2, " Lighting Wire Installation"

QI-QP-11.3-9, Revision 2, " Lighting Conduit and Box Installation"

QI-QP-11.3-15, Revision 2, " Electrical Cable Installation Inspec-tion"

QI-QP-11.3-16, Revision 2, " Class IE Cable Terminations"

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. _ _ _ . _ ._ _ . . . _ _ _ _ .

35-1195-ECP-19, " Exposed Class IE Conduit and Conduit HangerFabrication"

35-1195-EEI-7, Revision 1, " Electrical Cable Installation"

35-1195-EEI-8, Revision 1, " Class IE and Non Class IE CableTe rminations"

35-1195-CEI-20, Revision 4, " Installation of 'Hilti' Drilled Bolts"

b. Observation of Work

The IE inspector observed coupleted installation of cable tray,conduit, raceway support, and cables in the auxiliary buildingand control complex to determine physical compliance with FSAR,Craft and QC Procedures, and applicable IEEE and IPCEA Standardsand Practices.

The IE inspector witnessed the installation of cable E0104300.This installation was accomplished in accordance with QI-QP-11.3-15.

During this inspection, there were no items of noncompliance ordeviations identified; however, the IE inspector had three areasof concern which were discussed at length with licensee represent-atives both preceding and during the exit interview.

(1) The IE inspector found several areas where the EEIs (CraftWork Instructions) did not agree with QIs (Quality ControlInstructions). All of the QIs that were reviewed duringthis inspection had b.mn revised during the last six monthsand many of them were in the process of being revised again.The licensee advised the IE inspector that the EEIs werebeing updated as rapidly as possible.

At the present time the areas that conflict are not appli-cable to the work being accomplished. The licensee hascommitted to a complete review and update of these con-flicting areas in a timely manner, prior to their fielduse for safety-related work activites.

(2) During discussions with QA, QC and Craft personnel, the IEinspecter received different answers to the same questionsconcerning the use of cable lubricants in a conduit, therequirements for flexibility loops at transition points ina raceway, and what were transition point and bend radius

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requirements. This appeared to indicate a lack of communi-cation between QA, QC ani Craft personnel.

(3) The IE inspector became aware through discussions with thelicensee that the Craft personnel were not receiving thesame level of training and guidance as the QC personneland that the two organizations did not appear to be operatingby the same guidelines for quality.

The licensee and the IE inspector discussed these items of concernand the licensee committed to an immediate and complete reviewof commitments to preclude the possibility of problems as theelectrical work accelerates. These three aspects of the electricalcable installation program will be considered an unresolved itempending completion of the licensee's review and subsequent IEinspection.

5. Safety Related Piping - Units 1 and 2

The IE inspector observed the fitup and root welding of field weldFW-14 on line 2-CC-1-SB-035A-1 of the Unit 1 Component Cooling Systemfor compliance with Welding Procedure Specification No. 11021 Revi-sion 3 and the welding of field weld FW-2 on line 3-CT-1-117-301R-2of the Unit 1 Containment Spray System for compliance with WeldingProcedure Specification No. 88021 Revision 5/ICN 4.

The fitup cleanliness was inspected on field weld FW-7 for line3-CS-2-217-ISIR-2 of the Unit 2 Chemical and Volume Control System.The welding of field weld FW-6 on line 16-CT-2-014-301R-2 of the Unit 2Containment Spray System was monitored for compliance with WeldingProcedure Specification No. 88023 Revision 7/ICN 1.

The IE inspector observed piping activities involving handling andinstallation of pipe spool RH-1-RB-01-2 for the Residual Heat RemovalSystem of Unit I and storage and protection of pipe spool SI-1-RB-5A-2for the Safety Injection System of Unit 1.

A review of the weld records was performed for field weld FW-1 online 1 -SI-1-026-2501R-1 to verify that the liquid penetrant exam-ination had been accepted by qualified QC personnel. The weldwas inspected to verify that the surface condition was suitablefor liquid penetrant and radiographic examinations.

In the areas inspected, no discrepancies from the requirements ofthe welding procedure specifications; the piping fabricationconstruction procedure No. CP-CPM-6.9; storage procedure MCP-10:or the ASME B&PV Code were noted.

No items of noncompliance or deviations were identified.

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6. Unresolved Items

Unresolved items are matters about which more information is requiredin order to ascertain whether they are acceptable items, items ofnoncompliance, or deviations. An unresolved item disclosed duringthe inspection is discussed in paragraph 4.

7. Exit Interview

The IE inspectors met vith licensee representatives (denoted in para-graph 1) and R. G. Taylor (NRC Resident Inspector) on October 11 and 19,1979, and summarized the purpose, scope and findings of the inspection.The licensee representatives acknowledged the statements and items ofconcern including those detailed in paragraph 4.

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