ML20151F284

Notice of Violation from Insp on 880608-0706.Violation noted:1/4 Inch Fillet Welds Missing at Each End of Tubing & Condition Not Noted During Final QC Insp

ML20151F284
Person / Time
Site:	Comanche Peak
Issue date:	07/22/1988
From:	Warnick R NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20151F278	List: ML20151F276 ML20151F284 ML20151F292
References
50-445-88-46, 50-446-88-44, NUDOCS 8807270015
Download: ML20151F284 (3)

Text

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APPENDIX A NOTICE OF VIOLATION TU Electric Dockets: 50-445/88-46 50-446/88-44 Comanche Peak Steam Electric Station Permits: CPPR-126 Units 1 and 2, Glen Rose, Texas CPPR-127 During an NRC inspection conducted on June 8 through July 6, 1988, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed below:

A. Critorion V of Appendix B to 10 CFR 50, as implemented by Section 5.0, Revision 0, of the TU Electric Quality Assurance Manual requires that activities affecting quality shall be prescribed by documented instructiocs, procedures, or drawings appropriate to the circumstances in order to provide assurance that those activities have been satisfactorily accomplished.

Contrary to the above, due to an error resulting from Revision 3 of MMI-904, "Steam Generator Manway Removal and Replacement," paragraph 5.3.10 specifies installation torquing requirements which deviate from the NSSS vendors recommendations. MMI-904, Revision 3, requires a three-step torquing sequence (125, 300, 450 ft./lbs), removal of one bolt at a time for lubrication, then reinstallation of the bolt and torquing to 300 ft./lbs. After all the bolts are lubricated amd torqued to 300 ft./lbs., all bolts are to be retorqued to 45? ft./lbs. Westinghouse Technical Bulletin NSID-TB-87-01 reqcire. the same three-step torquing sequence; then removal, reluar. cation, and retorquing of each bolt to 450 ft./lbs.

Common industry practice is to discard and replace a flexatallic gasket after one compression cycle has been Experienced. The error in Revision 3 of MMI-904 resulted in quality control acceptance of the torquing of high pressure firaged connections an Unit 2 steam generators which may result in the connections not performing their intended safety related function.

This is a Severity Level ' /lolation (Supplement II)

(445/8846-V-01; 446/8844-4--01).

8807270015 G80608 PDR ADOCK 05000445 Q PDC

2 B. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3 of the TU Electric Quality Assurance Plan, states, in part, "Activities affecting quality shall be prescribed by docmacnted instructions, procedures, or drawings, or a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings . . . . "

Specification 2323-SS-16B, "Structural Steel / Miscellaneous Steel," Appendix B,Section III, paragraph 4.5.1 states, in part, "Verify the acceptability of the support in accordan,2 with the design document, along with all drawing sections, plans, elevation and views."

Yrocedure NQA 3.09-10.01, "Requirements for Visual Weld Inspection," which governs weld irspections foi conduit supports, paragraph 6.3.3.3.2.1 t,tates, in part, "The length and location of welds shall be r.s specified on the detail drawing . . . . "

t Contrary to the above, on support IN-C04G31220-51, the design l

drawing locates this support 4' - 1" south of the centerline l of column No. 3703. The NRC inspector measured the location to be 3' - 8" south of this column. Also, on this support, the drawing requires two flare bevel groove welds and I two 1/4" fillet welds between a section of 3" x 3" structural l tubing and the existing structural framing at each end of the #

I tube steel. However, the NRC inspector's review revealed that I the 1/4" fillet welds were missing at each end of the tubing and this condition was not noted during the final QC inspection.

This is a Severity Level IV violation (Supplement II)

(445/8846-V-02).

Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby required to submit a written statement or explanation to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC, 20555, with a copy to the Assistant Director for Inspection Programs, Comanche Peak Project Division, Office of Special Projects, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other I

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action as may be proper should not be taken. Where good cause is shown,_ consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY' COMMISSION ffl} AE Dated at Comanche Peak Site this 22nd day of July 1988

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