ML20196E488
| ML20196E488 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/05/1988 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-88782, NUDOCS 8812120013 | |
| Download: ML20196E488 (3) | |
Text
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MFE Log # TXX-88782 File # 10130
=
r IR 88-64 chg 1UELECTRIC g,g, y og
- mgg, O w.mber 5, 1988 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT N05.
50-445/88-64 AND 50-446/88-60 Gentlemen:
TV Electric has reviewed your letter dated October 17, 1988, concerning the inspection conducted by Mr. M. Runyan and a NRC consultant during the period September 9 through October 4,1988.
This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2.
Attached to your letter was a Notice of Violation.
On November 15, 1988, per a telephone conversation with Mr. Steve Burris, TO Electric requested and received an extension for NOV (445/8864-V-02) until December 9, 1988.
We hereby respond to the Notice of Violation in the attachment to this letter.
Very truly yoursg NdM W. G. Counsil 3
RDD/mlh Attachment A
c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)
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3912120013 631205 too North ouw serrer LBal Deltas Texai!).'01 PDR ADOCK 05000445 O
PTQC
Attachment to TXX-88782 December 5, 1980 Page 1 of 2 4-NOTICE OF VIOLATION (445/8864-V-02)
Criterion V of A)pendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, of tie TV Electric Quality Assurance Plan, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings.
Contrary to the above, welds were not installed in accordance with applicable drawings in the following two examples:
1.
Two undersized welds on the support structure for pipe whip restraints MS-1-002-911-C67W, MS-1-002-912-C67W, MS-1-002-913-C67W, and MS-1-002-914-C67W were identified.
Drawing 2323-S1-0576, Figure 7, Revisions 3, specifies 5/16-inch fillet welds along the edges of 1/2-inch plates.
The two welds are at least 1/16-inch undersized for the full length of the weld.
2.
On the same pipe whip restraint support structure as example 1 a single square groove weld was installed in areas where two 1/4-inch fillet welds are specified by DCA 13425, Revision 4.
This welding discrepancy was not identified durir.g an inspection conducted to PCHVP Procedure NQI-3.09-H-004, Revision 5, Field Verification of Pipe Whip Restraints" (445/8864-V-02).
RESPONSE TO NOTICE OF VI'vLATION (445/8864-V-02)
TV Electric adm ts the violation in part and the requested information follows:
1.
Reason for Violation We agree that the welds described in the hotice of Violation are discrepant.
The weld discrepancies apparently resulted from failure of welders and QC inspectors to properly implement applicable project procedures when these welds were made and accepted in 1983.
The welding identified in example 2 joins two plates to a shim plate i
(approximately 5/8" thick) that is between them and somewhat recessed.
The rasulting configuration is grooved or "U" shaped.
The design specified that the shim plate was to be joined at its edge to both of the plates using 1/4" intermittent fillet welds. As noted by the ",9C inspector, the "U" or groove is filled with weld metal, creating the appearance of a single square groove weld.
4
.. Attachment to TXX-88782 December 5, 1988 Page 2 of 2 Reason for Violation (cont'd)
NQI-3.09-M-004, as noted by the NRC inspector, requires only that the QC inspector visually verify that welds exist at the locations shown on the design documents in order to accept the inspection attribute. Weld type and size are not within the scope of this particular inspection.
Since 1
each of the plates is attached by weld to the shim plate at the location indicated in the design document, the PCHVP QC inspector correctly l
accepted the attribute for weld presence. While we agree that the weld described in example 2 is discrepant, such discrepancies are not within i
the scope of the inspection required by PCHVP QC inspection procedure NQI-3.09-M-004. Revision 5, "Field Verification of Pipe Whip Restraints".
l 2.
Corrective Steps Taken and Results Achieved Nonconformance Reports (NCRs) have been initiated for the welds identified in both examples 1 and 2.
The disposition of these NCRs indicates that these welds will perform as required and are suitable for "use-as-is".
3.
Corrective Steps Which Will be Taken to Avoid Further Violations The generic implications of the discrepant welds have been adequately i
addressed in the ISAP VII.c Results Report (Appendix 29 - Pipe Whip i
Restraints).
Therefore, additional corrective action is not required, j
Since the time when these welds were installed and accepted, TV Electric has implemented numerous corrective actions to assure that construction personnel and QC inspectors rigidly adhere to the requirements of project procedures and design drawings.
These corrective actions are described in t
various correspondence between TU Electric and NRC such as TV Electric's letter TXX-88495, dated June 9,1988, on the subject of Programmatic Enhancements.
j 4.
Date When Full Compliance Will be Achieved i
CPSES is currently in full compliance, f