ML20002A130
| ML20002A130 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/18/1980 |
| From: | Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19351D256 | List: |
| References | |
| NUDOCS 8010090341 | |
| Download: ML20002A130 (5) | |
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TEXAS UTILITIES GENERATING COMPANY 2003 BMYAN 'M)WER
- DA1J AJL TEXAS 76201
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August 18, 1980 TXX-3177 Mr. W. C. Seidle, Chief Reactor Construction and Engineering Support Branch U. S. Nuclear Regulatory Comission Office of Inspection & Enforcement 611 Ryan Plaza Dr., Suite 1000 Docket Nos. 50-445/80-15 Arlington, Texas 76012 50-446/80-15 COMANCHE PEAK STEAM ELECTRIC STATION 1981-83 2300 MW INSTALLATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT N0. 80-15 DOCKET N05. 50-445 & 50-446 FILE NO:
10130
Dear Mr. Seidle:
I We have reviewed the reports dated June 23, and July 23, 1980 on the inspection conducted by Mr. R. G. Taylor, of activities authorized by NRC Construction Pemits No. CPPR-126 and 127 for the Comanche Peak 4
facili ty.
We have responded to the findings listed in Appendix A of those reports.
To aid in the understanding of our response, we have repeated the re-quirement and your findings followed by our corrective action.
We believe the attached information to be responsive to the Inspector's findings.
If you have any questions, please advise.
Very truly yours, df R. J. Gary Attachment RJG:dk f.! W
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8010 0oo MI I
Inspection Report No. 80-15 TXX-3177 Page 2 Appendix A NOTICE OF VIOLATION (Dated June 23,1980)
Based on results of the NRC inspection conducted on June 6 and 9, 1980, it appears that certain of your activities were not conducted in full compliance with the conditions of your NRC Constructioi Permits No. CPPR-126 and 127 as indicated below:
Failure to Establish Quality Assurance Program for Class 5 Pipe Succort Systems Appendix B, Criterion II states in part, "The applicant shall establish at the earliest-practicable time, consistent with the schedule for' accomplishing the activities, a quality assurance program which comolies with the requirements of this, appendix.
This program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions.
The applicant shall identify the structures, systems, and I
components to be covered by the quality assurance program...."
FSAR, paragraph 3.2.2.3 defines Class 5 piping systems as those in the non-nuclear safety category whose failure in a seismic event could result in a loss of capability of a safety-related function.
FSAR, Table 17A-1 (page 24) identifies the Chilled Water System as having supports in the
-Class 5 category and by reference to Note 27, appearing on page 40 of the same table, indicates that certain portions of Appendix B apply.
Contrary to the above:
On or about June 9,1980, the RRI identified several pipe supports for Chilled Water piping in the Auxiliary Building (common to both Units 1 and 2) that appeared to be essantially complete.
Referente to applicable drawings established that these 3upports had been classified as Class 5 supports. Various inquiries by the RRI, coupled with a search of site quality assurance procedures and tne applicable specification 2323-MS-46B, "Non-Nuclear Pipe Hangers and Supports," :stablished that a quality assurance program has not been establidrza for these hangers as required by Appendix B and commitments of *the FSAR.
The licensee stated to the RRI that approximately 2500 other Class 5 hangers already ' installed are involved.
This is an' infraction.
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Inspection Report No. 80-15 TXX-3177 page 3 4
e Corrective Steps Which Have Been Taken and Results Achieved The applicable fabrication and installation specifications have been re-viewed and now include specific provisions for Quality Assurance criteria to be applied to the design, fabrication and installation of Class 5 Hangers. Construction and Quality Control procedures to incorporate these provisions have been prepared and are currently being implemented.
Corrective Steps Which Will Be Taken to Avoid Further Noncompliance The stated corrective action will preclude recurrence of the noncompliance.
Date of Full Compliance Implementing procedures were established by July 25, 1980 and are current',y being applied to ongoing fabrication and installation activities.
Inspection 1
of hangers previously installed will be accomplished as soon as practical,
' consistent with the project schedule for turnover to startup personnel.
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i Inspection Report No. 80-15 TXX-3177 Page 4 Appendix A NOTICE OF VIOLATION (Dated July 23,1980)
Based on the results of an NRC inspection conducted during June 1930, it appears that certain of your activities were not conducted in full compliance with conditions of your NRC Construction Permits No. CPPR-126 and 127 as indicated below:
Failure to Follow Construction Procedures Required by Drawir.gs Appendix B, Criterion V states in part, " Activities affecting quality shal' be prescribed by documented instructions, procedures, or drawings, of i type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
The Comanche Peak Steam Electric Station Quality Assurance Plan implements this requirement by Section 540 which states in part, "The quality assurance actions described throughout this manual shall be delineated in documented instructions, procedures, drawings, ;cecifications, check-lists or manuals, as appropriate."
Contrary to the above:
j The NRC Resident Reactor Inspector identified several drawings during his inspection that state:
4 (1)
"All tolerances in accordance with QCP #2A001 U.N.0."
j (2)
" Fab. Procedure is GH-101."
The RRI established that the above referenced documents were not available on the Comanche Peak site at the time of the fabrication of the components and, therefore, could not have been followed. One such drawing described an installed component support identified as SI-1-031-007-A42R and modified by Component Modification Card 12042R3.
This is a deficiency.
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Inspection Report No. 80-15 TXX-3177 Page 5 Corrective Steps Which Have Been Taken and Results Achieved CPSES Engineering has determined that the notes referenced on the drawings apply only to shop fabrication by ITT Grinnell at their Warren, Ohio facility and are not applicable to fabrication at other facilities or at the CPSES Site.
Fabrication or installation activities other than at Warren are controlled in accordance with approved fabrication or installa-tion procedures and to the. dimensional data of the drawings and accept /
reject criteria established by the fabrication and installation specifica-tions.
To provide positive record of this situation, a change to the site drawings is being prepared which will then be submitted to document holders of record per established CPSES procedures for Document Control.
Corrective Steps Which Will Be Taken to Avoid Further Noncomoliance The st '.ed corrective action will preclude further noncompliance.
Date of Full Comoliants The clarifying change to the component support drawings is scheduled for implementation by September 1,1980.
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