ML20205D026

Notice of Violation from Insp on 860701-0831

ML20205D026
Person / Time
Site:	Comanche Peak
Issue date:	03/18/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20205C998	List: ML20205C993 ML20205D026 ML20205D102 ML20205D213
References
50-445-86-22, 50-446-86-20, NUDOCS 8703300315
Download: ML20205D026 (3)

Text

APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Dockets: 50-445/86-22 50-446/86-20 Comanche Peak Steam Electric Station Permits: CPPR-126 Units 1 and 2 CPPR-127 During an NRC inspection conducted on July 1 through August 31, 1986, four violations of NRC requirements were identified. The violations involved stainless steel and carbon steel piping stored in outside areas with improper protective end coverings; records of heat treatment were not available for disc inserts and spares for main steam safety valves, nor was it apparent that proper source and receipt inspections were performed; nonconformance reports (NCRs) dealing with installed valve bonnets were incorrectly dispositioned; and a correct assessment was not made regarding adequacy of design with respect to square groove welds in HVAC duct supports. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below:

A. Criterion VII of Appendix B to 10 CFR Part 50, as implemented by Section 7.0, Revision 4, dated July 31, 1984, of the TUGCo Quality Assurance Plan (QAP), requires that objective evidence of quality be furnished by the contractor or subcontractor, and that inspection be made at the source or upon delivery. Documented evidence that material and equipment conform to the procurement requirements is required to be available at the nuclear plant site. The documentation is also required to be sufficient to identify the specific requirements of codes or standards met by the purchased material.

Section III of the ASME Boiler and Pressure Vessel Code, as imposed by Purchase Order (P0) CP-0077 for main steam safety valves, specifies in paragraph NA-4932 of Subsection NA that records of all heat treatments be maintained by the owner as permanent records.

Contrary to the above, records of heat treatments were not available for disc insert N91124-55-0322, which is part of main steam safety valve CP-2MS-021, and spra disc inserts N91124-40-0141 and N91124-40-0139. All main steam safet) valve; and associated documentation were source inspected and released under Quality Assurance Release (QAR) 2725. The total shipment, including the spare disc inserts, was received and documented in Receipt Inspection Report (PIR) 13686 which referenced QAR 2725; however, it was not apparent that the spare parts were inspected in either the QAR or RIR.

This is a Severity Level IV violation (Supplement II) (445/8622-V-02; 446/8620-V-03).

B. Criterion XV of Appendix B to 10 CFR Part 50, as implemented by Section 15.0, Revision 5, dated October 17, 1985, of the QAP, requires that measures be established to prevent the inadvertent use of nonconforming items, and that these measures include procedures for 0703300315 870318 PDH ADOCK 05000445 G PDR

i identification, documentation, segregation, disposition, and notification to affected organizations. It further requires that nonconforming items be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures.

Paragraph 2.3.2 in TUGCo Nuclear Engineering Instruction TNE-AD-5-2, Revision 7, states, in part, with respect to the dispositioning of NCRs, "The disposition shall clearly state what actions are necessary to resolve the nonconforming condition identified . . . ."

Contrary to the above, NCRs M-23175N, Revision 1, and M-23178N, dealing with installed bonnets on diaphragm valves, were incorrectly dispositioned and closed relative to necessary actions to resolve the identified nonconforming condition. The NCRs identified that the bonnets were not traceable to a Manufacturer's Data Report Form NPV-1 and that documentation was not available to show that the required ASME Code hydrostatic test had been performed. Part of the disposition on both NCRs, relative to justifying the acceptability of the bonnets, was the statement, "An acceptable bonnet hydro test was performed during the System /Sub-system Hydro Test." The disposition statement is incorrect in that the bonnets were isolated by the diaphragm from hydrostatic pressures during system / subsystem tests.

This is a Severity Level IV violation (Supplement II) (445/8622-V-04).

C. Criterion III of Appendix B to 10 CFR Part 50, as implemented by Section 3.0, Revision 4, dated November 20, 1985, of the TUGCo QAP, states, in part, " Measures shall be established to assure that applicable regulatory requirements and the design basis . . . are correctly translated into specifications, drawings, procedures, and instructions . . . The design control measures shall provide for verifying or checking the adequacy of design, such as by the . . .

performance of suitable testing program . . . ."

Memorandum No BSC-2156, which references Section 6.2 of Revision 8 to Bahnson Service Company (BSC) Procedure DFP-TUSI-003, states, "The following shall be considered a part of the subject procedure: All groove welds on the seismic duct hanger detail drawings shall be shown as square groove welds. Unless otherwise stated the weld shall be considered partial penetration. No size will be shown. Per the attached test

' results a penetration of not less than 1/8" (0.125") is achieved. These tests results with coupons are retained in DCC.

Contrary to the above, the following conditions were identified:

l

1. The original test program documentation did not assure that testing was performed in such a manner so as to provide for a correct assessment of the depth of partial penetration. Further, the test coupons were not retained in the Document Control Center (OCC) and could not be located.

L _ ._

1

2. Macroetch testing, witnessed by the NRC inspector, was performed on five additional weld samples which were welded with a 3/32" electrode in the vertical position using BSC Welding Procedure Specification BSC-20. The results of this testing revealed a maximum partial penetration of 0.047", which is .0.078" less than the claimed penetration used for analysis.

This is a Severity Level IV violation (Supplement II)

(446/8620-V-02).

O. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGCo QAP, requires that activities affecting quality shall be prescribed by and accomplished in accordance with the documented instructions, procedures, or drawings of a type appropriate to the circumstances.

Paragraphs 3.1.7 and 3.1.8 of Procedure MCP 10, Revision 9 " Storage and Storage Maintenance of Mechanical and Electrical Equipment," states, in part " Items in storage (outside) shall have all covers, caps, plugs, or other closures intact . . . Carbon steel piping material or structural tubing shall not be capped."

Contrary to the above, during an NRC inspection on July 10, 1986, of outside pipe storage on the north side of Warehouse C, four pieces of stainless steel pipe (Heat Nos. 670757, 05826, 713577, and F11744) were found with pipe end covers or caps not intact and several pieces of carbon steel pipe were found that were capped. The pipe fabrication shop also hadstainlesssteelpipingandtubin9storedintheWarehouseCarea,as well as in an area behind the Welder s Qualification Training Center, that had damaged, loose, and deteriorated tape for end coverings.

ThisisaSeverityLevelIVviolation(SupplementII)(445/8622-V-16; 446/8620-V-07).

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 for each violation: (1) the reason for the violations if admitted, the corrective steps which have been taken and the results achieved, the corrective steps which will be taken to avoid further violations, and the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

Dated at Arlington, Texas this 18th day of March 1987