ML20199A599

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Rev 1 to Procedure CP-QAP-14.1, Insp of Storage & Maint of Mechanical Equipment
ML20199A599
Person / Time
Site: Comanche Peak, 05000000
Issue date: 02/02/1983
From: Scott R
BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.)
To:
Shared Package
ML17192A346 List:
References
FOIA-85-313, FOIA-85-59, FOIA-86-A-20 CP-QAP-14.1, NUDOCS 8606120523
Download: ML20199A599 (8)
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APtQ 8ROWN & ROOT, INC.

ISSUE CPSES NLMSG REVISION CATE PAGE J08 35-1195 CP-QAP-14.1 1

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[~b'J3 INSPECTIO;I 0F STORAGE AND MAINTENANCE OF REVIEWED BY:

MECHANICAL EQUIPMENT DATE APPROVED BY:

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3/83 SiteCAMagger DATE

1.0 REFERENCES

1-A CP-MCP-10

" Storage and Storage Maintenance of Mechanical and Electrical Equipment" 1-B G&H Project No. 2323-03049 Equipment List

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6 1-C CP-QAP-16.1, " Control of Nonconformin l

2.0 GENERAL k

, }y '~ 2.1 PURPOSE The purpose of this is to describe methods utilized by Quality

) to ensure that items are ).

stored and requi ance is being performed on I,

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mechanical equi ccordance with Reference 1-A. }

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2.2 SCOPE l

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mechanical equipme..; rw.ared by Reference 1-B, from the i'

time of arrival of the equipment on the job site until the equipment is turned over to the Owner.

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1FORMKE0K 2.3 RESPONSIBILITY.

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The QC Group Supervisor shall be resp oJMe,f ih i on l

of this procedure.

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2.4 DEFINITIONS 1

M 2.4.1 Verify (V) - assuring conformance by physid 1b z;::tir.g an item after performance of an operation, does not require physical observation of the work being performed; or, by reviewing objective evidence attesting to the fact that the operation was performed and sa or ly deted.

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ISSUE CPSES NLMBER REVISION DATE PAGE J08 35-1195 2 fa CP-QAP-14.1 1

FEB 021983 l

l 2.4.2 Witness (W) - assuring confonnance by physically observing the entire operation being performed.

3.0 PROCEDURE 3.1 STORAGE SURVEILLANCE A surveillance of each storage location shall be conducted at least once per month by the QC Group to assure that

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mechanical equipment is being stored in accordance with A

Reference 1-A.

Storage violations shall be reported as nonconfonning in accordance with Reference 1-C.

3.2 EQUIPMENT MAINTENANCE Equipment Maintenance Record (EMR) Cards shall be prepared for all mechanical equipment contained in Reference 1-B which requires maintenance.

l 3.2.1 InsDection of Maintenance of Mechanical Equipment The M111 wright Superintendent shall notify QC when maintenance is to be perfonned.

Except as noted in l

Paragraph 3.2.2. the QC inspector shall witness all required maintenance.. QC shall verify that:

i a.

Equipment nameplate agrees with the EMR;

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The required maintenance and maintenance frequency are listed on the EMR and the EMR has been approved by l

Engineering; I

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Required maintenance has been perfonned and a

i description of the maintenance performed and the date perfonned is entered on the EMR; l

d.

Any calibrated instruments used in maintenance have current calibration sticker and have had M&TE numbers and calibration due date entered on EMR; l

of a through d ab4N) eQCg*hs%tk 1 Upon completion shall initial and date the " Verified b QCf Dat!a d '

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BROWN & ROOT INC.

ISSUE CPSES NLDSER REVISION DATE PAGE 3 fa CP-QAP-14.1 1

FEB 021983 3.2.2 Waiver of Inspections Based on the complexity of required maintenance and/or a degree of confidence established from previous maintenance intervals, the Quality Engineering Supervisor may waive witnessing up to and including 2 consecutive maintenance intervals on a particular item.

If this is done, the Quality Engineering Supervisor shall note on the EMR that witnessing of the particular maintenance interval has been waived, and sign and date this note.

Additionally, the QC Inspector shall verify that required maintenance has t

been performed, and enter a "V" in the " Verified by QC" block on the EMR and initial and date adjacent to the "V".

3.3 EQUIPMENT MAINTENANCE LOG The applicable QC Lead shall maintain an Equipment l

Maintenance Log (EML) (Attachment 2) for all mechanical equipment which have EMR's.

The EML shall contain as a l

minimum:

Equipment description including tag number and serial a.

l number, if applicable; b.

Arrival date on job site; i

c.

Storage location (obtained from the Equipment Record Card or from Material Control personnel).

In the event that the storage location changes, the location noted on Attachment 2 shall be changed by drawing a single line through the old location and the new location entered.

The change shall be initialed and i

dated by the person making the change; and 4

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Pennanent installation location including building and elevation.

i NOTE:

In the event that equipment is to be " Stored in Place" immediately after arrival on siter the storage location on the EML s

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" Stored in Place".

( i be completed concu reh Yh The EML shall provide for a means of verifyin ng performed as required.

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ISSUE CPSES NIMIER REVISION DATE PAGE CP-QAP-14.1 1

FEB 021983 4 of a The date of maintenance and the inspector's initials shall appear in the appropriate month block.

Additionally, the inspector shall indicate whether maintenance.was witnessed or verified.

EXAMPLE 1:

pgg This example indicates that maintenance was perfomed on the fifth through the eighth of the month and was witnessed I

by QC.

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EXAMPLE 2:

I'l - V 24-W si-v pr This example indicates that weekly maintenance was performed on the sixth, seventeenth, twenty-fourth, and thirty-first of the month, and was witnessed by QC on the sixth and twenty-fourth, and that QC verified that maintenance was perfomed on the seventeenth and thirty-first by reviewing the EMR.

If the entry was logged on the EML by an inspector who initialed the EMR, then that inspector's initials shall be added to the EML and the entry initialed and dated by the inspector logging the entry.

EXAMPLE:

{b -V JS 8 z3-V JS 40-An X shall be entered in the month the equipment is turned over to the Owner.

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The applicable QC Leed shall reviewl t$'k's'iire that,all.!l each day, week or month, as requirdd,'to 3is maintenance is being performed, withesst( y.eEd7MNsrltied))

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as required.

A new EML shall be established prior to da,'r%gr 3.>

i nuary of each year l

and shall encompass all equipment within the gepp4'.hf this {g instruction, with the exception of eq'uipment for N c Owner has accepted maintenance responstuiiities.

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l 8ROWN & ROOT, INC.

ISSUE CPSES NLMBER REVISION DATE PAGE 2 3 M 195 CP-QAP-14.1 1

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Completed EML's shall be maintained by QC.

l 3.4 LACK OF REQUIRED MAINTENANCE t

i The following conditions shall be reported by the QC Inspector as nonconforming in accordance with Reference 1-C.

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a.

Maintenance is not perfomed as required by the EMR; i

b.

Scheduled daily or weekly maintenance is not perfonned I

on schedule.

Weekly maintenance may be perfonned within 3 days of the scheduled date; c.

Scheduled monthly maintenance is not perfonned within

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seven days of the scheduled date; or d.

Damage to equipment.

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3R0tdM & ROOT INC.

ISSUE CPSE3 NtmBER REVISION DATE PAGE 4

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B M & ROOT, INC.

ISSUE CPSE3 M ER REVISION DATE PAGE J08 35-1195 cp-o e-14.1 1

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ISSUE CPSES IRDWER REVISION QATE PAGE FEB 021983 e ce e W 14.1 1

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N m V 'M O m a :.u:3 In Reply Refer To:

Dockets:

50-445/83-18 50-446/83-12 Texas Utilities Generating Company ATTN:

R. J. Gary, Executive Vice President & General Manager 2001 Bryan Tower Dallas, Texas 75201 Gentlemen:

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This refers to the construction appraisal inspection conducted by the Office

'of Irispection and Enforcement (IE) on January 24 - February 4,1983, and February 14 - March 3,1983, at the Comanche Peak Steam Electric Station and your Dallas corporate office, and inspection ccnducted by our Senior Resident Inspector, Mr. R. G. Taylor, during May 1983.

The Construction Appraisal Team (CAT) was composed of members of IE and a number of consultants.

The inspections concerned construction activities authorized by NRC Construction Permits CPPR-126/127.

Based on our initial review of the potential enforcement items' identified in Appendix B of the IE Ictter of April 11, 1983; discussions between this office and IE; and the enforcement meeting held in this office on May 9, '1983, with members of your staff, it was found that certain of your activities were in violation of NRC requirements.

Consequently, you are required to respond to these violations, in writing, in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.

Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter.

The remaining potential enforcement items identified in Appendix B of the IE letter of April 11, 1983, are under evaluation by this office.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Room unless you notify this office, by telephone, within 10 days of the date of this letter, and submit written application to withhold information contained therein within 30 days of the date of this letter.

Such application must be consistent with the requirements of 2.790(b)(1).

RPS-A RPB1 ORRP&E '

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[V O/ORP TWeste4 man': dsm GLMadsen JEGagl rdo JT llins JTaylor 4 83 5/ /83 5/y/8/3 5/y1/83 5/./83 5/

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I Texas Utilities Generating Company The response directed by this letter and the accompanying Notice is not subject to the clearance procedures of the Office of Management and Budget as l

required by the Paperwork Reduction Act of 1980, PL 96-511.

Should you have any questions concerning this inspection, we will be pleased to discuss them with you..

I Sincerely, j

gnet stan j

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G.L?,Madsen, Chief Reactor Project Branch 1

Enclosure:

Appendix A - Notice of Violation cc w/ enclosures:

Texas Utilities Generating Company ATTN:

H. C. Schmidt, Project Manager 2001 Bryan Tower Dallas, Texas 75201 bec to DM8 (IE01) bec distrib. by RIV:

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0. Kelley, SRI-Ops RP82 R. Taylor, SRI-Cons TPB Section Chief (RPS-A)

J. Collins, RA C. Wisner, PA0 l

M. Rothschild, ELD MIS SYSTEM RIV File TEXAS STATE DEPT. OF HEALTH Juanita Ellis i.1EWED FOR PROPRI

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lilFORMATION PER 10 CFIV l

SECTION 2.790 /

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l APPENDIX A NOTICE OF VIOLATION Texas Utilities Generating Company Dockets:

50-445/83-18 l

Comanche Peak Steam Electric Station 50-446/83-12 l

Permits:

CPPR-126 CPPR-127 l

Based on the results of an NRC inspection conducted during the period of February 14-March 3,1983, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 47 FR 9987, dated March 9, 1982, the following I

violations were identified:

1.

Failure to Provide Adequate Procedures, Instructions, or Drawing for Installation of Major Items of Equipment Criterion V of Appendix _B_ to 10 CFR 50 requires that activities affecting i

quality shall be prgscribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances.

Project Specification 2323-MS-101 requires in paragraph 4.7.2 that the manufacturers recommendations and instructions for the installati.on of equipment be complied with by the installer, and in paragraph 4.12.3 requires that all bolting attaching rotating or vibrating equipment to the building structure be provided with locking or with wuble nuts.

Contrary to the above, the Senior Resident Inspector (SRI) Construction determined by review of the " Construction Operations Traveler" for the installation of Heat Exchanger TCX-CSAHLD-01 that the recommendations by Westinghouse, the supplier, that the nuts attaching the component to the building be left loose to allow for thermal expansion were neither referenced nor included in the instructions and further verified that the nuts were fully tightened as installed.

The NRC Construction Assessment Team (CAT) noted in NRC Inspection Report 50-445/83-18; 50-446/83-12 that various items of like equipment such as tanks sometimes had only one nut on the attachment bolts, sometimes similiar tanks had double nuts, and some had a combination of single and double nuts on the same component.

i This is a Severity Level V Violation.

(Supplement II.0)

(50-445/8324-01; (50-446/S315-01) 2.

Failure to Provide Adequate Maintenance of Materials and Equipment in Outdoor Warehouse Areas Qriterion XIII of Appendix B to 10 CFR 50 requires that measures shall be estab11sned to prevent damage or deterioration of stored equipment.

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i Texas Utilities Generating 3

4 Company Brown & Root (B&R) Procedure MCP-10, " Storage and Storage Maintenance of Mechanical and Electrical Equipment," in paragraph 3.18 requires that materials to be stored outdoors shall be prepared for storage by the application of caps, preservatives or other means.

Paragraph 3.11 requires that permanent carbon steel bolts supplied on equipment be i

protected with a suitable preservative.

Contrary to the above, the CAT identified various piping support components with dry and dirty bearings and with rusting bolts and pins.

The SRI during a tour 'of the storage areas for pipe support components noted many instances where bolts and pins were rusted'and a few instances where the support components were rusted through the paint and/or where the paint had chipped off.

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This is a Severity Level V Violation.

(Supplement II.0)

(50-445/8324-02;

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50-446/8315-02) 3.

Failure to Remove Obsolete Drawings From Construction Work Areas

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Criterion VI of Appendix B to 10 CFR 50 requires that only curre'n't drawings be used to accomplish work.

4 FSAR Section 17, paragraph 17.1.6 states that changed documents will be distributed to and used at all work locations.

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B&R Procedure DCP-3, "CPSES Document Control Program provides that all i

revised drawings will be distributed to users on a controlled basis and that each user is accountable for the currentness of his files.

I Contrary to the above, a CAT inspector identifie.d a group of drawings in 3

the construction work area that contained approximately 23 percent l

drawings which were not of the proper revision.

Further, the CAT l

inspector noted that some drawings were sufficiently. illegible in the title and revision block areas of the drawing to prevent identification of e

the drawing and/or the revision level.

I This is a Severity Level IV Violation.

(Supplement II.0)

(50-445/8324-03; 50-446/8315-03) 2 4.

Failure to Provide Adequate Control of Ventilation System Fabrication i

Criterion VII of Appendix B to 10 CFR 50, requires that measures be j

established to assure that materials, equipment, and services purchased through or from a contractor or subcontractor conform to the procurement 1

documents.

These measures must include as appropriate, source evaluations j

and inspections, generation of objective evidence of quality by the 4

contractor or subcontractor, and assessment of the contractor or subcon-tractor's con' trol of quality by the applicant.

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Texas Utilities Generating 3

Company Bahnson Service Company Contract, 35-1195-0526, which incorporate Gibbs &

Hill, Inc. Specification 2323-MS-85, Section 2.1.4.d requires that all fabrication processes conducted by Bahnson Service Company shall be performed in accordance with dimensioned detail drawings.

Contrary to the above, it has been established by NRC inspections that subcontractor Bahnson Service Company, supplied:

a.

A substantial number of welds, approximately 40 percent, on supports for ventilation ducting that are smaller than specified by the design drawings.

b.

There were instances in which the bolting at duct joints was loose or missing and that gaskets in duct joints was missing or improperly j

installed.

c.

Five of the nine supports inspected had dimensional deficiences.

d.

The Bahnson Service Company quality control records failed to reflect either of the above conditions.

e.

The licensee's audits and assessments of the subcontractors control of quality failed to identify the above conditions.

This is a Severity Level IV Violation.

(SupdlementII.0)

(50-445/8324-04; 50-446/8315-04)

Pursuant to the provisions of 10 CFR '2.201, Texas Utilities Generating Company is hereby required to submit to this office, within 30 days of the date of this Notice, a written statement or explanation in reply, including:

(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.

Consideration may be given to extending your response time.for good cause shown.

Dated:

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