ML20151F184
| ML20151F184 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/18/1988 |
| From: | Counsil W, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-88552, NUDOCS 8807260405 | |
| Download: ML20151F184 (3) | |
Text
. _ _ _ _ _ _ _ _ _ _ _ _ _ -.
Log # TXX-88552 File # 10130 IR 88-36
~
IR 88-31 3
C Ref # 10CFR2.201 1UELECTRIC July 18, 1988 Wmism G. Counsil Execwho Vwe President U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION DOCKET 50-445 AND 50-446 RESPONSE TO INSPECTION REPORT N05.
50-445/88-36 AND 50-446/88-31 Gentlemen:
TV Electric has reviewed your letter dated June 17, 1988, concerning the inspection conducted by Mr. M. Runyan and a NRC consultant during the period May 4 through June 7, 1988. This inspection covered activities authorized by HRC Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2.
Attached to your letter was a Notice of Violation.
We hereby respond to the Notice of Violation in the attachment to this letter.
Very truly yours, b). C,. O W. G. Counsil By: (1 D. R. Wocdlan Docket Licensing Manager RDD/mlh Attachment c-Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) 8807260405 880718 PDR ADOCK 05000445 i
G PDC 400 hrth Olne Street Lut! Dall.u. Texas 7H01
i a
Attachment to TXX-88552 July 18, 1988 Page 1 of 2 NOTICE OF VIOLATI0fi (445/8836-V-01)
A.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 0, of the TV Electric Quality Assurance Manual dated February 1, 1988, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, er drawings.
TV Electric Specification 2323-55-30, "Structural Embedments," Revision 3, Appendix A, Section 4.3, dated August 3, 1987, requires that Hilti expansion bolts be of sufficient length to provide length below the attachment equal to the thickness of grout topping in addition to the required embedment.
In addition, a topping thickness of two inches shall be used.
Drawing 2323-5-0910, Sheet G-4a, Revision CP-01, requires a minimum embedment length of two inches for 3/8 inch diameter Hilti expansion bolts.
This drawing further specifies that the minimum embedment lengths are into structural concrete.
Contrary to the above, two 3/8 inch diameter Hilti bolts used for Conduit Support C02012055-07 and installed through grout topping of undetermined thickness on a concrete pedestal, did not have the required embedment lengths.
The bolts extend into the combination of grout topping and structural concrete approximately 2 inches, therefore, the as-built embedments (2 inches minus the thickness of the grout) are much less than the required embedments of 2 inches into structural concrete.
(Similar conditions could exist in other areas, when grout topping on concrete pedestals is not well documented, and may not be limited to conduit supports.)
RESPONSE TO NOTICE OF VIOLATION ITEM A (44578836-V-Gl)
TV Electric agrees with the alleged violation and the requested information follows:
1.
Reason for the Violation The engineer who developed the "As-Built" drawing did not identify tie existence of grout at the Hilti bolt location noted in the violation, during the implementation of conduit support field verifications.
This occurred as a result of inadequate instructions for verifying the embedment depth of the Hilti bolts installed in grouts associated with leveling of equipment.
L.
1 Attachment to TXX-88552 July 18, 1988 Page 2 of 2 RESPONSETONOTICEOFVIOLATIONITEMA(C0HT'01 (4T578BN-RT) 2.
Corrective Steps Taken and Results Achieved NCR 88-09714 has been initiated to resolve the insufficient Hilti bolt embedment identified in this violation.
This NCR has been dispositioned "Use As Is" rince conduit CO2012055 is qualified without conduit support C02012055-07.
A review of Field Verification Method (FVM) procedures which require Engineering examination of Hilti bolts us part of a connodity support verification was conducted.
This review resulted in the conclusion that similar conditions should not exist in verifications of Hilti bolt embedment for commodities other than conduit supports since the instructions for other grout applications were adequate.
To assure appropriate Hilti bolt embedment however, equipment pads in Category I structures will be visually examined to identify commodities attached to concrete pedestals with Hilti bolts.
Seismic Category I and 11 bolts which do not meet the specification requirements for embedment will be documented on NCRs for resolution.
Non-safety related bolts which do not meet the specification requirements for embedment will be documer,ted and resolved per the applicable non-safety procedures.
3.
Corrective Steps Which Will be Taken to Avoid Further Violations FVMs of commodity supports which include Quality Control inspection r
adequately implement the requirements of 2323-SS-30 for Hilti embedment.
Those FVMs where commodity support verifications were conducted by Engineering personnel have been completed, respective to field verification activities, therefore revision of these FVMs is not necessary and no farther action is required.
4.
Date When Full Coupliance Will be Achieved The examinat:on of equipment pads in Unit I and Common Category I structures for adequate Hilti bolt embedment will be completed by December 31, 1988.
Equipment pads in Unit 2, rategory I structures will be examined and necessery action will be cempleted prior to Unit 2 fuel load.
l