ML20151U921
| ML20151U921 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/22/1988 |
| From: | Warnick R NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20151U907 | List: |
| References | |
| 50-445-88-20, 50-446-88-17, NUDOCS 8805020200 | |
| Download: ML20151U921 (3) | |
Text
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3 APPENDIX A NOTICE OF VIOLATION TU Electric Dockets:
50-445/88-20 50-446/88-17 Comanche Peak Steam Electric Station Permits:
CPPR-126 Units-1 and 2, Glen Rose, Texas CPPR-127 During an NRC inspection conducted on~ March.2 through April 5,
'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 (1987), the
' violations are listed below:
A.-
Criterion IX of Appendix B to 10 CFR Part 50, as implemented by Section 9.0, Revision 0, of the TU Electric Quality Assurance Manual, dated-February 1, 1988, requires the establishment of measures to assure that nondestructive testing is accomplished using qualified procedures in accordance with applicable codes,-standards, specifications, criteria, and other special requirements.
Contrary to the above, ultrasonic digital thickness measurements of site fabricated pipe bends to verify acceptable post-bend wall thickness, a Corrective Action Program commitment, were performed through protective' coatings (primer and paint) without consideration of the impact of c
protective coatings on accuracy of measurements.
This is a Severity Level IV violation (Supplement II) j (445/8820-V-01; 446/8817-V-01).
t-l B.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 0, of the TU Electric Quality Assurance Manual dated February 1, 1988, requires that activities affecting qurlity shall be prescribed by and accomplished in I
L accordance with documented instructions, procedures, or drawings.
1 Brown and Root ASME Quality Procedure AQP-10.7, l
f "Nondestructive Examination Marking Requirements," Revision 0, l
dated July 10, 1987, paragraph 6.3, approves the use of Nissen l
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ink markers and Marsh stencil ink markers for temporary marking of stainless steel surfaces.
No other ink markers are approved by this procedure.
Contrary to the above, while witnessing an ultrasonic digital thickness measurement inspection of a pipe bend on Spool 1Q3 of Piping Isometric BRP-WP-X-AB-041, the NRC inspector observed the QC inspector marking the stainless steel pipe surface with ballpoint pen ink, which is not an approved ink marker.
This is a Severity Level IV violation (Supplement II)
(445/8820-V-02; 446/8817-V-02).
C.
Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section 10.0, Revision 1, dated July 31, 1984, of the TU Electric Quality Assurance Plan, states, in part, "A program for inspection of activities affecting quality shall be established and executed.
to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity."
contrary to the above, the following conditions which had been inspected and accepted by the applicant's inspection programs were identified as being nonconforming during independent inspection of Unit 1 cable tray supports.
Section 3.2.2.B.2.a.1.d of TU Electric Field Verification Method TNE-FVM-CS-001, Revision 5 dated July 1, 1986, states, in part, "Welding shall be verified for quantitative attributes as listed below without paint removed.
weld size (to be measured)."
Section 3.2.2.B.2.2.b, states, in part, "A fillet weld shall be permitted to be less than the size specified by 1/16" for 1/4 (25%) the length of the weld."
l Section 1.5, "Visual Weld Acceptance Criteria for Structural Welding at Nuclear Power Plants," Revision 2 dated May 7, 1985 states:
"The workmanship provisions of AWS D1.1 are not modified by the acceptance criteria presented in this Section 3.3.1 of AWS D1.1 dated 1975 document if states, in part, concerning gaps between members, the separation is 1/16 inch or greater, the leg of the fillet weld shall be increased by the amount of the separation or the contractor shall demonstrate that the effective throat has been obtained."
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Section 4.1.2.2, "Visual Weld Acceptance Criteria for i
Structural Welding at Nuclear Power Plants," NCIG-01, Revision 2 dated May 7, 1985, states, in part, "A fillet weld
3 shall be permitted to be less than the size specified by 1/16" for 1/4 the length of the weld."
Contrary to the above, independent inspection identified the following conditions in two supports:
a.
An 8" long, 5/16" fillet weld required by the drawing for a cable' tray support was measured as being 1/4" for the full length, b.
Two 6" long,' 1/4" fillet welds required by the drawing, for a cable tray support were measured as being 1/8" (due to an 1/8" gap between members) for the full length of both welds.
This is a Severity Level IV violation (Supplement II)
(445/8820-V-04).
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 action as maysbe proper should not be taken.
Where good cause is shown, consideration will be given to extending the response time.
FOR THE NUCLEAR REGULATORY COMMISSION 2 f&Jandeh l
Dated at Comanche Peak Site this 22nd day of
- April, 1988 l
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