ML20196H408

Notice of Violation from Insp on 980713-31 & 0921-25. Violation Noted:As of 980712,AFW Pipe Supports Were Not Constructed IAW Details Shown on Design Drawings as Listed

ML20196H408
Person / Time
Site:	North Anna
Issue date:	11/05/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20196H401	List: ML20196H395 ML20196H408 ML20196H413
References
50-338-98-05, 50-338-98-5, 50-339-98-05, 50-339-98-5, NUDOCS 9812090063
Download: ML20196H408 (3)

Text

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NOTICE OF VIOLATION Virginia Electric and Power Company Docket Nos. 50-338,50-339 North Anna Nuclear Plant License Nos. NPF-4, NPF-7 During an NRC inspection conducted at your North Anna facility, on July 13 through 31,1998, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, i procedures, or drawings. The requirements for construction of safety related pipe supports were specified in the applicable Stone and Webster drawings, which showed required weld sizes and support configuration.

Contrary to the above, as of July 12,1998, AFW pipe supports were not constructed in accordance with details shown on the design drawings as specified below:

1. Drawing (Sketch) number MFSK-4289A-3 required 1/4" fillet welds on connections between steel members (angles or angles and wide flanges) for the upper box frames and Detail T box frame for pipe support SHP-R-187. The as-built weld sizes were measured as 1/8" or 3/16" at numerous locations on these l members.  ;

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2. Drawing (Sketch) number 7054 required 1/4" fillet welds on connections between I steel angle members for the three box members for the 3 inch diameter pipes on pipe support numbers SHP-R-188 and 189. The as-built welds were determined to be 1/8" at several locations at the top of the box frames.

3. Drawing (sketch) number 2-4233 required 1/4" fillet welds on connections between bill of materials (BOM) items 4 and 5 on pipe support 2SHP-R-34. The vertical weld at top, left connection measured 3/16". I

4. Drawing number 12050 ZFSK-2536A-2 required 5/16" fillet welds at connections of 4x4 tube steel posts to surface mounted plates attached to the tunnel ceiling on support 2SHP-R-15. The welds on the right side of left post and front and left i sides of the right post measured 1/4". j

5. Drawing number 11715-PSSK-102FA.3 required 1/4"" fillet welds at the l connection of BOM item 1 (6" wide flange) to base plate on pipe support 1-WAPD-R-198. The weld on the top web at right connection measured 3/16". I i

l Enclosure 1 9812090063 981105 PDR ADOCK 0500033G PM G

NOV 2

6. Drawing number 11715-PSSK-102FD.1 required 1/4" fillet welds at the connection of BOM items 2 (6" wide flanges) to the baseplate on pipe support 1-WAPD-R-22. The welds on the bottom and sides of the top wide flange measured 3/16". The drawing also specified no gap (a zero inch gap) at the bottom of the 6" inch diameter pipe. A gap existed.

7. Drawing number 11715-PSSK-102FD.4 required 1/4" fillet welds between BOM item 5 (stiffener plates) and the baseplate on pipe support 1-WAPD-A-18. The welds measured 3/16".

8. Drawing number 11715-PSSK-102FD.3 required 1/4" fillet welds for connection of BOM items 8 (steel angles) to BOM item 1 (wide flanges) per Section 1-1 and for connection of BOM item 9 (stiffener plate) to BOM item 6 (baseplate) on pipe support 1-WAPD-R-24. The welds measured 3/16" at right side of BOM item 9 i and on right and left sides of BOM item 8. 1 This is a Severity Level IV violation (Supplement 1)

B. 10 CFR 50, Appendix B, Criterion XVI, requires that measures shall be established to assure that conditions adverse to quality shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

l Virginia Power procedure VPAP-1601, Corrective Action, implements the requirements of 10 CFR 50, Appendix B, Criterion XVI, at the North Anna Power Station. Paragraph 6.3.3.a and 6.3.3.b of VPAP-1601 requires that corrective action be implemented in  :

accordance with approved procedures, and verification of timely and proper corrective action measures.

Contrary to the above, corrective actions to resolve the AFW pipe support corrosion problems identified on September 29,1996, and documented in Deviation Report N 96- l 2135, were not effective. As of July 19,1998, the licensee failed to perform verification of timely and proper corrective actions performed to close DR N 96-2135. As a result, additional corrosion of the Unit 2 AFW tunnel pipe supports had occurred, resulting in potential operability concerns.

This is a Severity Level IV violation (Supplement I) applicable to Unit 2 only.

C. 10 CFR 50.55a(g) requires performance of inservice inspection of Class 1,2, and 3 pipe supports in accordance with ASME Section XI.

Contrary to the above, as of July 15,1998,10 Unit 1 and 39 Unit 2 Class 3 AFW system pipe supports were not included in the ASME Section XI inservice inspection program.

This is a Severity Level IV violation (Supplement 1).

Enclosure 1 l

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4 NOV 3 Regarding Violation A, pursuant to the provisions of 10 CFR 2.201, Virginal Electric and Power Company is hereby required to submit a written statement or explanation to the U.S. Nuclear l Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Admini-strator, Region 11, and a copy to the NRC Resident inspector at North Anna, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This j

reply should be clearly marked as a " Reply to a Notice of Violation" and should include for j Violation A: (1) the reason for the violation, or, if contested, the basis for disputing the violation  ;

or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the  !

j corrective steps that will be taken to avoid further violations, and (4) the date when full

! compliance will be achieved. Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response. Where 4

good cause is shown, consideration will be given to extending the response time.  ;

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If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, j D.C. 20555-0001.

4 Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an adequate response, please provide the level of protection described in 10 CFR 73.21.

I Regarding Violations B and C, the NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence and the date when full compliance will be achieved will be adequately addressed on the docket in Inspection Report No. 50-338/98-05. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, follow the instructions for Violation A.

l Dated at Atlanta, Georgia this 5* day of November,1998 Enclosure 1 l 1

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