ML20212P761
| ML20212P761 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/29/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20212P745 | List: |
| References | |
| 50-445-86-01, 50-445-86-1, 50-446-86-01, 50-446-86-1, NUDOCS 8609030263 | |
| Download: ML20212P761 (3) | |
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f APPENDIX B NOTICE OF DEVIATION Texas Utilities Electric Company Dockets: 50-445/86-01 50-446/86-01 Comanche Peak Electric Station, Permits: CPPR-126 Units 1 and 2 CPPR-127 Based on the results of an NRC inspection conducted from November 1,1985, to January 31, 1986, of operations and Comanche Peak Response Team (CPRT) activities, three deviations from commitments to the NRC were identified. The deviations involved failure to preoperationally test the auxiliary feedwater pumps in accordance with Final Safety Analysis Report (FSAR) commitments, i
failure to comply with approved instructions in performance of reinspections, and inadequate engineering review during preparation of an inspection checklist.
In accordance with the " General Statement of Policy and Procedure i
for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the deviations are listed below:
A.
FSAR Section 10.4.9.1 states that the Auxiliary Feedwater (AFW) System is capable of supplying the minimum required flow to at least two steam 1
generators against a back pressure equivalent to the accumulation pressure of the lowest set main steam safety valve plus the system frictional and static losses.
FSAR Table 14.2-2, Sheet 51, Test Method No. 3 commits the applicant to verify through preoperational testing that the hydraulic performance of each AFW pump meets design requirements and is within limits assumed in the appropriate accident analysis.
In deviation from the above, preoperational tests 1CP-PT-37-01, " Auxiliary Feedwater System (Motor Driven Pumps)," and 1CP-PT-37-03, " Auxiliary Feedwater System (Turbine Driven Pump)," failed to test the AFW pumps against a back pressure determined using main steam safety valve accumulation pressure, but instead incorrectly used the safety valve set pressure. This amounts to a less conservative 36 psi reduction in the i
back pressure during this test. Consequently, the pump capacity data maximum back pressure test (445/8601-D-04)ges are incorrect for the recorded in the above completed test packa B.
Section 4 of Revision 3 to CPRT Procedure CPP-009 states, in part,
" Qualified QA/QC Review Team personnel perform field inspections of -
specific hardware items and reviews of appropriate documents in accordance i
with approved instructions...."
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G In deviation from the above, the following examples were noted where field reinspections were not performed in accordance with approved instructions:
1.
Attribute 1.f in Section 5.2.6.2 of Quality Instruction (QI) QI-025 Revision 1, which states, in part, "All lines with operating temperatures belov 200*F may be installed with a minimum of one inch clearance, including insulation, with respect to other piping," was signed off as acceptable by the ERC inspector for Verification Package No. I-M-LBC0-038. However, independent inspection showed an existing clearance of 0.75 inch between spool piece 2Q2 of Drawing BRP-CS-1-SB-060 and the inspected line at a point 12 inches above sleeve 3 (445/8601-D-17).
2.
Attribute 1.f in Section 5.2.6.3 of QI-025, Revision 1, which requires that all lines with operating temperatures less than 200*F be installed such that an air gap exists between the pipe, or pipe insulation, and other objects, was signed off as acceptable by the ERC inspector for Verification Package No. I-M-LBC0-144. However, independent inspection identified a portion of a pipe support in contact with the insulation of the inspected line at approximately 14 feet south of the 76* bend in the package (445/8601-D-20).
3.
Attribute 1.d in Section 5.2.4 of QI-025, Revision 1, which states, in part, " Ensure that the actual piping dimensions are in agreement with those shown on the piping isometric...," was signed off as acceptable by the ERC inspector on December 9, 1985, for Verification Package No. I-M-LBC0-144. However, field survey measurements taken by Brown and Root on December 6, 1985, in response to an ERC request, showed the distance from the end of the containment penetration at field weld 18-A to the working point of the 76* bend as 10 feet 5 7/16 inches with respect to a distance (with a tolerance of i 2 inches) indicated by the applicable Isometric Drawing BRP-CC-1-RB-046 of 10 feet 81/8 inches (445/8601-D-19).
4.
Paragraph 6 on page 34 of Attachment 6.17 of QI-058 requires (for vendor safety wiring of attachment bolts between the forward bracket assembly and the snubber assembly) that the inspector shall verify that the lockwire is not damaged.
Independent inspection showed for Verification Package No. I-S-PS42-021 that the inspection checklist was accepted by the ERC inspector despite the presence of a broken lockwire on the snubber adaptor plate (445/8601-D-13).
C.
Section 4.0 of CPRT Project Procedure CPP-008, Revision 1, requires that verification packages provide the information necessary to conduct reinspections and document the results. Section 5.1.1 of this procedure states, in part, "... Should an attribute appear on the generic checklist and not be applicable to the specific item, the engineer indicates 'N/A' and provides reasonable justification for the entry."
In deviation from the above, the engineer incorrectly indicated "N/A" for attribute 1.e on the checklist for Verification Package No. I-M-LBC0-038.
i i
i As a result, this attribute, dealing with assuring branch connections were in accordance with the piping isorr.etric drawing, was not reinspected by ERC.
Independent inspection identified that_the attribute was applicable for Verification Package No I-M-LBCO-038 as evidenced by the observation of the presence of a branch connection (445/8601-D-18).
Texas Utilities Electric Company is hereby requested to submit to this office, within 30 days of the date of this Notice of Deviation a written statement or explanation in reply, including for each deviation:
(1) the reasons for the deviations if admitted, (2) the corrective steps which have been taken and the results achieved, (3) corrective steps which will be taken to avoid further deviation from commitments made to the Commission, and (4) the date when full compliance will be achieved. Where goud cause is shown, consideration will be given to extending the response time.
Dated at Arlington, Texas, this 29th day of August 1986 l
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