ML19305B919

Responds to NRC 800123 Ltr Re Violations Noted in IE Insp Repts 50-445/80-01 & 50-446/80-01.Corrective Actions: Analysis of as-built Configuration Indicates Battery Charger Foundations Acceptable as Installed

ML19305B919
Person / Time
Site:	Comanche Peak
Issue date:	02/19/1980
From:	Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19305B918	List: ML19305B919
References
TXX-3099, NUDOCS 8003200619
Download: ML19305B919 (4)

Text

p TEXAS UTILITIES GENERATING COMPANY 2001 BRYAN MWER

• DALLAS. TEX.AS 75201 4

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. . . . , . . .... February 19, 1980

. TXX-3099 Mr. W. C. Seidle, Chief Reactor Construction and Engineering Support Branch U. S. Nuclear Regulatory Commission Office of Inspection & Enforcement 611 Ryan Plaza Dr., Suite 1000 Docket Nos. 50-445/80-01 -

Arlington, Texas 76012 50-446/80-01 COMANCHE PEAK STEAM ELECTRIC STATION 1981-83 2300 MW INSTALLATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT N0. 80-01 DOCKET NOS. 50-445 & 50-446 FILE NO. 10130

Dear Mr. Seidle:

We have reviewed the report dated January 23, 1980 on the inspection by your resident inspector, Mr. R. G. Taylor, of the activities authorized by NRC Construction Permits No. CPPR-126 and 127 for the Comanche Peak facility. We have responded to the findings listed in Appendix A of that report.

To aid in the understanding of our response, we have repeated the require-ment and your findings followed by our corrective action.

We believe the attached infcrmation to be responsive to the Inspector's findings. If you have any questions, please advise.

Very truly yours, R. . Gary' Attachment RJG:df C'

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Inspection Report No. 80-01 l TXX-3099 Page 2 APPENDIX A NOTICE OF VIOLATION Ba::ed on the results of the NRC inspection conducted on January 18, 1980, it arpears that certain of your activities were not conducted in full '

compiiance with the conditions of your NRC Construction Permits No. CPPR-126 and 127 as indicated below:

Failure to Provide Instructions and Procedures Appropriate to the Circumstance 10 CFR 50, Appendix B, Criterion V states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circum-stances and shall be accomplished in accordance with these in-structions, procedures, or drawings."

Contrary to the above:

Instructions and procedures provided for securing the Class IE Battery Chargers to the building structure are inappropriate to the circumstance in that eight three-eights inch fillet welds were required: It is impossible to achieve the required fillet weld size for four of these weld locations because the material thickness is less than .200 inches.

The documents containing instructions inappropriate to the circum-stance were Design Change Authorization 3380; Power Conversion Products, Inc. Drawing D-55-1539; and " Analysis of Anchoring Method of 3SD-130-300 Battery Charger." These documents were verified by the RRI during a review on January 18, 1980.

The Resident Reactor Inspector verified by direct examination of two of .the four Unit No.1 Battery Chargers that the materials shown in the Power Conversion Products drawing referenced above was what was actually furnished and that the four welds do not conform to the required thickness for a three-eights inch fillet weld.

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Inspection Report No. 80-01 TXX-3099 Page 3 The Resident Reactor Inspector also established that the welding was accepted by site Quality Control on January 10, 1980, as documented in Inspection Report IR-E-5724 even though the welds could not be made in the manner required.

This is an infraction.

Corrective Steps Which Have Been Taken and Results Achieved An analysis of the actual as-built configuration was performed in late January 1980 using the same rationale employed in the analysis supporting Design Change Authorization 3380. Results of these calculations indicate that the battery charger foundations, as installed, substantially exceed structural requirements and are acceptable as installed. Upon incorpora-tion of the revised details into the formal analysis for the equipment, the entire matter will be independently reviewed by the Architect / Engineer to further assure the integrity of the equipment and validity of the qualification report.

Corrective Steps Which Have Been or Will Be Taken to Avoid Further Noncompliance Preventive measures have or will include the following actions:

1. Revision 2 to Comanche Peak Engineering Procedure CP-EP-4.6 included a requirement for A/E as well as Vendor review of site originated changes / deviations to items such as equipment foundation details prior to approval for fabrication or con-struction.

2. Senior Quality Assurance personnel will independently review selected installations to assure that electrical equipment mounting details satisfy basic structural requirements and that the results of the equipment qualification reports are consistent with the as-built configuration.

Quality Control actions associated with this matter were reviewed by the Site Quality Engineering group and appeared to be consistent with normal practice (i.e., fillet weld thickness is obviously limited by material thickness). Preventive action in this area will therefore stress the importance of the accuracy of equipment installation records, at both QC supervisory levels and in formal QC training sessions.

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f Inspection Report No. 80-01 TXX-3099 Page 4 Date of Full Compliance Corrective actions were initiated on January 22, 1980 and are scheduled for completion by May 1, 1980. Preventive measures were initiated on January 31, 1980 through formal revision to the referenced Engineering Procedure. The planned QA reviews and QC actions are ongoing activities and as such have no finite starting or completion date.

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