ML20133K835
| ML20133K835 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/30/1985 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20133K799 | List: |
| References | |
| TXX4513, NUDOCS 8510220312 | |
| Download: ML20133K835 (11) | |
Text
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TEXAS UTILITIES GENERATING COMPANY M KYWAY lt 9 WEN
- too NONTil OLIVE MT HEET, L.H. MI
- DALLAM.TEXAM 7320B TS Off30AS July 30,1985
. 01 @ f TXX-4513
- ~
i) g 311985 l
Mr. D.R. Hunter, Chief
_ _ _ _.. _. J Reactor Project Branch 2 U.S. Nuclear Regulatory Commission Office of Inspection & Enforcement 611 Ryan Plaza Drive, Suite 1000 Docket Nos.:
50-445 i
. Arlington, TX 76011 50-446 COMANCHE PEAK STEAM ELECTRIC STATION l
RESPONSE TO NRC NOTICES OF VIOLATION l
INSPECTION REPORT 84-26 FILE N0.:
10130
Dear Mr. Hunter:
In a response dated February 28, 1985 we responded to your letter of January 18, 1985 on the inspections of the Safeguards and Auxiliary Buildings. conducted by C. R. Oberg, M. E. Skow and W. R. Bennett of activities authorized by NRC l
Construction Permit CPPR-126 for Comanche Peak Unit 1.
In accordance with your discussions with Phillip Halstead on May 7, 1985 and June 10, 1985, we are now supplementing our February 28, 1985 response to provide additional information on actions taken.
This supplemental response should be considered in-lieu of the February 28, 1985 response since this response is basically a duplication of our previous submittal with greater detail of actions taken included.
If you have any questions, please advise.
Very truly yours, m
f l
W.G. Counsil WGC:tig l
Attachment cc:
NRC Region IV (0 + 1 copy)
Director, Inspection & Enforcement (15 copies)
U.S. Nuclear Regulatory Commission Washington, DC 20555 8510220312 851016 Mr. V.S. Noonan PDR ADOCK 05000445 G
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> mv M n-o r r.ar as c, c con anr
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I APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Docket: 50-445/84-26 Comanche Peak Steam Electric Station Construction Permit: CPPR-126 Based on the results of an NRC inspection conducted during the period of July 16 through September' 28, 1984, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 49FR8583, dated March 8,1984, the following violations were identified:
A.
Failure to Provide QC Inspection Criteria and Minimum Separation 10 CFR Part 50, Appendix B, Criterion V states, in part, "... Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
IEEE-384 provides separation criteria of Class IE equipment and circuits.
The Comanche Peak Steam Electric Station Electrical Erection Specification 2323-ES-100 provides for the implementation of the criteria of IEEE-384 (1974).
Section 4.4.6 of 2323-ES-100 states in part, "In no case shall any part of the conduit or the conduit support system come in direct contact with uninsulated equipment in the piping system or with pipe restraints or anchors."
Ql-QP-II.3-29-1, Revision 16, paragraph 3.1.7, states in part, "In no case shall any part of the raceway or raceway support system come in direct contact with uninsulated equipment in the piping system or with pipe restraints or anchors unless otherwise approved by the owner."
Ql-Q P-I I.1-28, Revision 25, paragraph 3.3.4.2, states in part, "There shall be an air gap (i.e., no contact) between electrical conduit / conduit supports and piping component support."
Section 4.11.32 of 2323-ES-100 specifies separation between conduits of different trains which, for the examples listed, is a minimum of one inch.
Ql-QP-i l.3-23, Section 3.9, specifies conduit separation between conduits of different trains which, for the examples listed, is a minimum of one inch.
Ql-Q P-1 1.3-23, Section 3.9, specifies conduit separation per drawing 2323-El-1702-02, including several detailed sketches.
f Contrary to the above, 1.
Specifications and QC inspection procedures do not contain specific acceptance criteria for separation of redundant trains of flexible conduits.
2.
The separation requirements between conduits as contained in the erection specifications ES-100 and implementing procedures had not been met.
The following conditions were identified:
1.
Flexible conduits in the Safeguards and Auxiliary Buildings do not maintain the required one inch minimum separation between trains. For example, flexible conduit Cl3G20208 contacts Cl30lll32, and the 1" altspace is not maintained between Cl3007415 and Cl3G07413.
2.
Flexible conduits in the Safeguards and Auxiliary Buildings come in direct contact with uninsulated equipment in the piping system or with pipe restraints or anchors. Examples include:
Flexible Conduit Number item Description Cl3G07743 Flex rests on pipe bracket next to valve,1-flV-5365.
Cl3G07744 Flex rests on pipe next to valve 1-IIV-5365 Cl4021161 Flex rests on pipe support for 1-MS-030 and 1-MS-268 Cl3G12499 Flex rests on support for JBIS 455G Cl3G08781 Flex touches corner of support for valve 1-liv-4179 C12005387 Flex touches pipe at elbow passing near valve 1-11V-8106 Cl3015915 Flex resting on top of actuator for-valve 1-liv-2188 Cl3G21323 Flex touching flange of support next to valve 1-FV-2196 Cl3G06734 Flex rests against unistrut below valve 1-FV-4537
F C12G04690 Flex conduit rest on fire pipe Cl3G06834 Flex wraps around adjacent support o
Cl4G20503 Flex rests on valve bocy o
C12002856 Flex contacts 1-HV-2480 Corrective Action Summary The installation drawings did not contain a method for maintaining the required separation distance for flexible conduits to prevent inadvertent movement of these conduits. As a result separation violations af ter inspection occurred. To resolve this problem, DCA 20,721, Revision I was issued on September 18, 1984 against drawing El-1702-02. This DCA contains an approved method for maintaining minimum separation distance between flexible conduits of different trains / channels.
To identify any other conduit separation problems in Unit 1, generic NCR's were issued. One NCR was issued for each of the buildings / areas where safety related flexible conduits are installed. Walkdowns of these buildings / areas by QC to identify separation deficiencies in violation of the criteria of QI-QP-11.3-29 are being conducted. Engineering will evaluate and disposition all findings, and craft will correct violations by use of mechanical separators as specified in DCA 20,721, Revision 1 as appropriate.
For the flexible conduit installations in Unit 2 which have yet to be installed the referenced DCA and changes identified in Ql-QP-II.3-28, Revision 24 should preclude recurrence and provide detection by inspection. For previously installed flexible conduits in Unit 2 post construction ' inspection in accordance with Ql-QP-11,3-40 would identify. Training of personnel to the latest revision of procedures is ongoing and is considered adequate for resolution of this problem.
It should be noted that flexible conduit to cable separation is being addressed by the Comanche Peak Response Team Action Plan Item VII.C.
B.
Failure to Properly inspect 10 CFR Part 50, Appendix B, Criterion X requires that the inspection program of activities affecting quality shall be established and conducted in a manner to verify conformance with the documented instructions, procedures, and drawings.
Procedure Ql-QP-il.10-2, Revision 28, " Cable Tray Hanger Inspection", specified the inspection attributes for inspection assembly, configuration, location, welding, etc., for conformance with design drawings and documents.
F 1
Procedure QI-QAP-il.1-28, Revision 25, " Fabrication and Installation Inspection of Safety Class Component Supports," specifies the inspection attributes for inspecting fabrication, installation, material, dimensional control, welding, etc., for conformance with design drawings and documents.
Contrary to the above:
1.
The NRC inspector identified one cable tray hanger, CTil 639, that was missing the diagonal brace called for on drawings 2323-El-0601-01-S and 2323-S-901.
2.
The NRC inspector identified one cable tray hanger, CTil 12416, that had the horizontal legs aligned north-south versus east-west as specified on drawing 2323-El-0601-0lS and FSE 00159 sheet 12416.
3.
The NRC inspector identified one pipe support that was missing two welds as specified on drawing CT-1-014-015-S42K.
The following is a compilation of additional deficiencies by general category and the drawing or component where it was found.
Category Component or Drawing Number of items Welding MS-1-026-010-S75 1
AF-1-026-005-S33R 1
Inst. Rack CP-1-EIPRLI-31 2
Dimensions AF-1-026-003-S33R 1
M S-1-026-010-S75 K 1
MS-1-025-009-R75K 1
CC-1-234-700-C53 R I
CC-1-238-004-C53R I
CC-1-236-700-C53R I
CS A B-208 A-001 2
C S-1-564-706-A 33 R 1
AF-1-035-037-Y33R I
AF-1-035-034-Y33R I
M S-1-028-047-S43 K 1
CC-1-Oll-034-A63K 1
e General A F-1-103-036-S53 K 1
Workmanship Inst. Rack CP-1-EIPRLI-31 1
A-FT-2458 1
C l 4010056-2 1
TOTAL ITEMS 22 l
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The above are examples identified by the NRC inspectors where items were installed by the craft to conditions other than those specified by the identified design documents, QC inspections had been completed, and the QC inspectors failed to identify these conditions. The inspection report details these findings.
This is a Severity Level IV Violation. (Supplement II.D)(445/8526-02)
Corrective Action Summary item B.1 The condition, as described for CTH-639, was identified on and corrected per disposition of nonconformance report M-84-100470 (closed 10/1/84).
To assure the acceptability of cable tray hangers in Unit I and Unit 2, an as-built (design analysis and field verification) program for hangers has been initiated. This issue has been identified in the Comanche Peak Reponse Team Action Plan as item Vill, item B.2 The condition, as described for CTH-12416, was identified on and corrected per disposition of nonconformance report M-84-100476 (closed 10/2/84).
Refer to item B.1 for corrective steps to preclude repetition.
Item B.3 The condition, as described for pipe support CT-1-014-015-S42K was identified on and corrected per disposition of nonconformance report M-14722. The subject welds, a continuation of a side weld 2" around the top and bottom corners on the base plate, were required for analysis since the hiltis installed on the side opposite the weld could not be used to qualify the support. The weld is designed to take 100% of the shear. Since the hiltis were properly installed, however, the support would not have failed during normal system operation.
The following is a compilation of additional deficiencies by general category, the drawing or component where it was found and the responses to these deficiencies.
Category:
WELDING Component or Drawing:
MS-1-026-010-S75K - Additional weld on item 3 and 11, were not shown on the drawing.
a
F
Response
There was no requirement to show additional welds not required by design on the drawing. These welds were annotated on the VCD inspection conducted on 6/23/83, and are part of the as-constructed history package. To preclude further question, however, Ql-QAP-II.1-28 has been revised to reflect that Engineering will show all as-installed welds for Unit 2, regardless of their significance to the design analysis.
Component or Drawing:
AF-1-206-005-S33R beam weld gap is incorrect
Response
Fit-up gap is within permissive tolerance, and weld size was increased to provide the required reinforcement when fit-up exceeded 1/16" gap.
Component or Drawing:
Inst. Rack CPI-EIPRLI Undersize welds
. Response The condition, as described for instrument rack CPI-EIPRLI-31, was identified on and corrected per disposition of nonconformance report 1-84-100493 (closed 1/25/85).
The disposition of this nonconformance report called for reinspection of all Unit 1 instrument racks, this was concluded and deficiencies corrected prior to closure of the nonconformance report.
In Unit 2, Engineering is currently evaluating all instrument racks for acceptance, deletion, and/or repair (reference nonconformance reports 1-84-200384 and 1-84-200385). Upon completion of this review, and subsequent repair, QC will verify acceptability.
Cateogry:
DIMENSIONS Component or Drawing:
A F-1-026-003-S33R - Grout too thick Resonse:
QC has reinspected this support and finds the grout to be slightly greater than 1" but less than 1-1/8" thick. Sufficient embedment has been obtained and the VCD has been revised to reflect grout thickness.
Component or Drawing:
.MS-1-026-010-S75K - Upper bolt holes teamed on items 4 and 5 Corrective Steps:
Support was originally inspected as MS-1-026-010-S72K, and reclassified to "S75K".
The upper botr holes are teamed and NCR M-15150 has been initiated for Engineering disposition.
(
Component or Drawing:
hts-1-026-009-R75K - The VCD calls for a 1 1/16" base plate hole for the upper right hitti; a 1 1/2" hitti is installed.
Corrective Steps This was an obvious drafting error as all four locations had existing 1 1/2" Richmond Inserts, as reflected in item 8 of BOh!. NCR hi-15151 has been initiated for Engineering disposition against VCD hiS-1-026-009-S75K.
Component or Drawing:
CC-1-043-013-A 43 K - VCD calls for 7'3" from rear bracket plate to wall; actual is 7'5".
t Corrective Steps The above support was neceptable as the subject dimension has a tolerance of i 2" based on pipe location (re., Ql-QAP-il.1-28, paragraph 3.3.7).
NCR hi-14744 was issued in response to the NRC concern however, and the VCD was revised to reflect the as-constructed dimension.
Component or Drawing:
CC-1-234-700-C53K - Sheet 2 Section C-C lower attachment bolt spacing discrepancy (conflicting dimensions).
Corrective Steps:
Distance from attachment centerline to bolt hole centerline, as shown on the VCD, is an obvious drawing error, as the cumulative dimensions are not possible on the 8" x 12" plate, assuming the minimum 2" edge distance is maintained. NCR hi-15147 was initiated for TUGCO Results Engineering disposition against VCD CC-1-234-700-C53R; this NCR has Men closed based on the issuance of TUGCO Operations NCR 84-0267 which has also been closed following revision of the drawing to reflect as-built conditions.
Component or Drawing:
CC-1-238-004-C53R - Structural separation dimensional discrepancy.
Corrective Steps:
The location of the strut end brackets, upper and lower, determines the structural loading, and have working point tolerances of t 1 ". Accordingly, NCR M-15148 was initiated for TUGCO Results Engineering disposition against support CC-1-238-004-C53R; this NCR has been closed based on the issuance of TUGCO Operations NCR 84-0268 which has also been closed following revision of the drawing to reflect as-built conditions.
Component or Drawing:
CC-1-236-700-C53R - The vertical distance from the pipe centerline is dimensioned to the bottom of an associated support and not to its own support (i.e.,
required 5" overlap is not reflected).
Corrective Steps:
The dimensioning on the attached VCD is an obvious drafting error, as the 5" overlap is specified in view A-A, and exists in the as-constructed condition. Accordingly, NCR M-15149 was initiated for TUGCO Results Engineering disposition against VCD CC-1-236-700-C53R; this NCR has been closed based on the issuance of TUGCO Operations NCR 84-0269 which has also been closed following revision of the drawing to reflect as-built conditions.
Component or Drawing:
CS A B-208 A-001 - (a) 3 1/2" dimension from edge of Item I to the bracket centerline is actually 1 5/8";
(b) 12" reference dimension is actually 9 7/8".
Response
(a)
A constructed, the support was acceptable as the above dimension has a tolerance of 2 2" since it is by definition a reference dimension to a ghosted support (re: Ql-QA P-il.1-28, paragraph 3.3.6).
(b)
The above dimension has a tolerance of 2 2"; using a tape measure between the hypothetical centerline of an end bracket and the hypothetical centerline of the support pin, both of which are on different planes, the reference dimension is acceptable within standard metrological accuracy. NCR M-14713 was issued in response to the NRC concern however, and the VCD was revised to reflect the as-constructed dimension.
Component or Drawing:
CS-1-564-706-A33R - The 2'8" dimension between the wall and centerline of item #2 is actually 2'9-5/8" (i.e.,
5/8" greater than permitted tolerance).
Corrective Steps:
NCR M-14712 was initiated; Enginering evaluated the as-constructed condition and revised the VCD to show the 2'9-5/8" dimension.
Component or Drawing:
AS-1-035-037-Y33R -
1" baseplate material specified on the drawing is actually 1 1/4"
Corrective Steps:
NCR M-14680 wrc; initiated to identify the + 1/4" variance. It should be noted that until early 1981, the Engineering Specification and project procedures permitted the installation of heavier members by craft. This lattitude was generically removed due to the " stiffness" conservatism in the Class I stress problems; however, heavier members in Class 2 and 3 stress problems do not invalidate analysis assumptions.
The VCD has been revised to show the heavier member.
Component or Drawing:
AF-1-035-034-Y33R - Baseplate north side dimensions are not as specified on the drawing, for baseplate holes with respect to the attachment centerline.
Corrective Steps:
NCR M-14678 was issued against the only dimension out of tolerance, the lo:ation of the NW anchor bolt hole, which was moved for proper anchor bolt installation but not reflected on the drawing. The 13/16" variance from the permissive tolerance, was in the conservative direction for edge distance, evaluated b-j Engineering and the VCD was revised accordingly.
Component or Drawing:
M S-1-028-047-S43 K Upper right hitti placement dimension was out of tolerance.
Corrective S ys; NCR M-14842 was initiated to identify the deficiency. The NCR was dispositioned by Engir.ccring to revise the VCD to reflect the as-constructed dimension..
Component or Drawing:
CC-1-O l l-034-A6 3 K VCD calls for 2'7" from wall to snubber, actual is 2'5-1/2".
Response
The above support was acceptable, as the subject dimension has a tolerance of 2 2" based on pipe loation (re: Ql-QAP-II.1-28, paragraph 3.3.7).
NCR M-14745 was issued in response to the NRC concern however, and the VCD was revised to reflect the as-constructed dimension.
Component or Drawing:
Cl40100056 Nut and Hitti Bolt not flush.
Response
The condition, as described for conduit support C14010056-2, was identified on and corrected per disposition of nonconformance report M-84-100471 (closed 10/4/84).
CMC 100703, Revision ) was issued to allow the specific nut in question to be a maximum of 0.05 inches above flush.
I It is considered that this condition was erroneously over looked by the original inspector.
Preventive steps are being taken through the normal training and surveillance program.
Category:
GENERAL WORKM ANSillP Component or Drawing:
AF-1-103-036-S53K - Snubber not level and pipe clamp resting on floor penetration.
Corrective Steps:
The subject support is a strut and the correct n'iniber stould be AF-1-103-026-S53R.
It is believed that the pipe clamp locatlan was inadvertently moved during construction activities in the area after f;aal acceptance by QC on the Hanger luspection Report; this caused the snubber installation angle to be incorrect. The clamp was returned to its design installation angle, in accordance with NCR M-14756 correcting tnis problem.
As a result of the above action, the clamp no longer rests on the floor penetration.
Component or Drawingi 1-FT-2488 - Minimum Air Gap Violated.
Corrective Steps:
The condition was described for instrument tube from 1-FT-248dtilP), actually should be identified as tube from 1-FT-2458.
The condition was corrected during normal inspection processes, and was docuinented on Inspection Report 1-1-00545-4 (closed 9/27/84). No fuither action is considered necessary in that it could not be determined if the minimum air pap was present at the time of the original inspection or it had been caused by subsequent wori in the area.
CONCLUSION The NRC inspection of 178 supports represented the inspection of 1651 welds and 5144 configuration attributes. Based on the items identified deficient in relation to the total population, irnprovement in this area can still be 11ade. Therefore, the procedure for fabrication and installation inspection of safety class comicpent supports was revised to require a more detailed recording of information obratned during the inspection. This action.ind the actions ideritified above shon!d preclude recurrence of the type deficiencies noted. For (Jnit 2, the supports are being ;nspected to these more detailed requirements. Completien of this reinspection effort is scheduled to complete prior to compation of ASME Certifi;ation of Unit 2 Systerns.
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