ML20199K963
| ML20199K963 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/04/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20199K948 | List: |
| References | |
| 50-445-85-16, 50-446-85-13, NUDOCS 8604100262 | |
| Download: ML20199K963 (3) | |
Text
_
a APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Dockets: 50-445/85-16 50-445/85-13 Comanche Peak Steam Electric Pennits: CPPR-126 Station, Units 1 and 2 CPPR-127 During an NRC inspection conducted on November 1-30, 1985, four violations of NRC requirements were identified. The violations involved an unacceptable design basis for grouting Richmond inserts, failure of QC inspectors to detect undersize welds, failure to verify conformance to procedure requirements for Hilti bolt installation, and QC inspector acceptance of an HVAC duct system exhibiting damage and an unacceptable gasket gap.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are listed below:
A.
Criterion III of Appendix B to 10 CFR Part 50, as implemented by Section 3.0, Revision 4, dated November 20, 1985, of the TUGC0 Quality Assurance Plan (QAP), states, in part, "... Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design...."
Contrary to the above, the Unit 1 field substitution of a grouted Richmond insert for a 11/4-inch diameter Super-Hilti bolt was authorized by Design Change Authorization (DCA) 13349 without being subject to design control measures commensurate with those applied to the original design. Table I of Appendix 3 to Gibbs and Hill (G&H) Specification 2323-SS-30, Revision 0, provides allowable loads for Richmond inserts which are cast in place in 4000 psi concrete. Allowable loads were not, however, provided by this specification for grouted Richmond inserts.
Calculation SRB-128C, Set 2, Sheets 168 and 169, which was referenced by DCA 13349, also did not address the shear capacity of the concrete-grout interface and thus did not establish the tensile capacity of the grouted Richmond insert.
This is a Severity Level IV violation (Supplement II) (445/8516-V-08).
B.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 QAP states, in part,
" Activities affecting quality shall be prescribed by documented instruc-tions, procedures or drawings... and shall be accomplished in accordance with these instructions, procedures, or drawings." in Revision 7 of Brown & Root, Inc. (B&R) Procedure CEI-20 requires a minimum center-to-center spacing of 11 1/4 inches between 1 1/4-inch and 1-inch Hilti expansion bolts. Attachment 1 also indicates that this minimum spacing applies to Hilti bolts detailed on separate adjacent fixtures and that violation of minimum spacing must be approved by issuance of design change documents by the applicable Comanche Peak Project Engineering groups.
8604100262 860404 PDR ADOCK0500g5
o 2
4 Contrary to the above, a center-to-center spacing of 101/2 inches existed between a 1 1/4-inch Hilti bolt and a 1-inch Hilti bolt on adjacent fixtures of Support No. SI-1-039-044-S42R. This Unit 1 support was previously inspected and accepted on December 21, 1981, without evidence of any design change documents approving this condition.
This is a Severity Level IV violation (Supplement II) (445/8516-V-14).
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 TUGC0 QAP, 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."
Paragraph 5.1.2 in B&R Procedure CP-NDEP-200, Revision dated September 27, 1979, states, in part, "The final surface condition of plate and piping welds shall be visually inspected after completion of the wcid for...
fillet size (as applicable)." Revision 4 of Drawing CC-1-131-010-S43R requires welds on two sides for item 8 to item 9, with a fillet size of 1/4 inch. A weld fillet size of 1/4 inch is also specified for items 9 and 10.
Contrary to the above, inspection of Unit 1 ASME Pipe Support No. CC-1-131-010-S43R, which had been previously inspected and accepted by Quality Control, identified the presence of undersize welds. A total weld length of approximately 20 inches was found to be undersize by a minimum of 1/16 inch with respect to the item 8 to item 9 fillet welds. A consecutive 2-inch segment was also present in these welds which was 1/8 inch undersize.
The vertical welds on the outside of the wide flange joining items 9 and 10 were also found to be undersize by a minimum of 1/16 inch for more than 25%
of the weld length.
This is a Severity Level IV violation (Supplement II) (445/8516-V-13).
D.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 QAP states, in part, "Activ: ties affecting quality shall be prescribed by documented i
instructions, procedures or drawings... and shall be accomplished in accordance with these instructions, procedures, or drawings."
Appendix 7 to G&H Specification 2323-MS-85, Revision 3, states, in part, with respect to field fabricated ductwork, " Install in accordance with an approved Traveler... Field modify as necessary and document modification
...." Table 2.10-1 in the G&H specification states that the minimum acceptance criteria for visual inspection are "No Visible Defects."
o 3-Paragraph 6.2, in Bahnson Quality Field Procedure QFP 10.001 CPI, Revision 2, states, in part, " Inspections of... installation... shall be performed by inspection personnel in accordance with the requirements established by the... Ductwork Installation checklist... and appli-cable QCIs." The Ductwork Installation checklist addresses visual damage.
Paragraph 5.1.3 in Bahnson Procedure QCI-CPSES-003, Revision 6,. states, "The Bahnson QC inspector shall verify that the duct joints are bolted together so that the gasket is compressed to a thickness of 1/8" plus or minus 1/32". Verification may be accomplished either at the time of installation or during final walk-thru."
Contrary to the above, observed damage to Unit 2 Battery Room Ventilation Exhaust Duct System EMD-3, which apparently occurred during installation as a result of force bending Flange Nos.17 and 18 to preclude interference with an adjacent wall, was neither documented as being a field modification nor was it identified as visual damage on the Bahnson final inspection report dated April 1,1983. This report states, "EMD-3 Jts. 1-18 (BRVE) have been inspected and arc acceptabic." Further, the force bcnding created a gasket gap of 1/4 inch in the trough of the bend which is in excess of the maximum allowable gap of 5/32 inch.
This is a Severity Level IV violation (Supplement II) (446/8513-V-10).
Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is hereby required to submit to this office, within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including:
(1) the reasons for the violations if admitted, (2) the corrective steps which which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration may be given to extending your response time.
)
Dated at Arlington, Texas, this 4th day of April,1986 f
I l
-