ML20215J821
| ML20215J821 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/17/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20215J811 | List: |
| References | |
| 50-445-86-03, 50-445-86-3, 50-446-86-02, 50-446-86-2, NUDOCS 8610270201 | |
| Download: ML20215J821 (7) | |
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s APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Dockets:
50-445/86-03 Comanche Peak Steam Electric Station 50-446/86-02 Units 1 and 2 Permits:
CPPR-126 CPPR-127 During NRC inspections conducted on December 11, 1985, through March 31, 1986, violations of NRC requirements were identified. The violations involved implementation of an electrical Design Change Authorization (DCA) in a manner different to that specified, failure to take corrective action with respect to Inspection Process Control group findings, inadequacies in performance of Unit 2 conduit support inspection program and omissions in engineering documents, inadequacies in performance of Unit 2 HVAC duct support inspection program, inadequate DCA resolution of a nonconforming condition, inadequate drawings and inspection performance with respect to Unit 2 cable tray supports, failure to comply with ACI-359 requirements with respect to radiographic examination of a liner weld, and incomplete site operations trend analysis.
In accordance with the " General Statement of Policy (and Procedure for NRC1985), the v Enforcement Actions," 10 CFR Part 2, Appendix C listed below:
A.
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 Quality Assurance Plan (QAP), requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings.
Paragraph 2.5 of TUGCo Procedure CP-EP-4.6, " Field Design Change Control,"
Revision 10, dated April 16, 1984, states, in part, " Design changes / deviations to specified engineering documents shall be documented by revision initiated by an Engineering Change Request (ECR) a Design ChangeAuthorization(DCA)oraComponentModificationCard(CMC)."
DCA 18,016 required removal of wire strands using a wire stripper to reduce wire size from #16AWG to #18AWG.
Contrary to the above, wire size reductions were implemented for Unit 2 termination cabinets, 2-TC22 and 2-TC23, by construction operation travelers in a manner different than specified on DCA 18,016; no revision to the DCA had been initiated, nor were either an ECR or CMC initiated.
This is a Severity Level V violation (Supplement II) (446/8602-V-08).
B.
Criterion XVI of Appendix B to 10 CFR Part 50, as implemented by Section 16.0, Revision 0, dated July 1,1978, of the TUGCo QAP, states, in part, " Measures shall be established to assure that conditions adverse to quality, such as... deficiencies, deviations... are promptly identified and corrected."
8610270201 861017 PDR ADOCK 05000445 i
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, Contrary to the above, the measures established did not assure that the following described condition adverse to quality was promptly identified or promptly corrected. The NRC inspector reviewed a sample of 70 Sample Recheck Request / Report forms, completed by the Inspection Process Control (IPC) group since July 1985, and identified 80 examples where QC inspectors had entered " SAT" inspection attributes in inspection reports where "NA" (i.e., not applicable) was the correct entry. This condition was identified in the monthly IPC reports beginning with the September report dated October 11, 1985. Subsequent IPC reports (October and November) characterized this condition as both "a generic problem" and a significant deficiency and requested that corrective action be taken as early as December 13, 1985.
However, no apparent action has been taken to establish how long this condition may have existed before September 1985 nor has corrective action, in a generic sense, been taken.
This is a Severity Level IV violation (Supplement II) (446/8602-V-06).
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 TUGCo 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."
Contrary to the above, the following conditions which had been inspected and accepted by the applicant's inspection program, were identified as being nonconforming during independent inspection of Unit 2 conduit supports:
1.
Section 3.3.1 in Revision 7 of TUGCo Instruction QI-QP-11.10.1A states, in part, "The QC inspector shall inspect the support for the following: Member (s) shape... size and dimensions."
Inspection revealed a 1/2" thick shim plate installation on one support and a 5/8" thick shim plate installation on another support for which the applicable drawings required the use of a 5/8" thick and 1" thick shim plate, respectively.
2.
Section 3.5.1 in TUGCo Instruction QI-QP-11.10-1A, Revision 7, states, in part, " Conduit spans shall be as indicated on the isc. metric drawing. Conduit span Tolerance is 3 (inches)...."
Inspection revealed a measured span length of one conduit run as being 3/4" over the allowable tolerance shown on the isometric drawing.
3.
Section 3.4 in Revision 20 of TUGCo Instruction QI-QP-11.2-1 specifies that where embedded plates are occupied by attachments within 12" of a Hilti, the minimum clearance between a 3/8" and 1/2" Hilti bolt and a Nelson stud will be 5-7/8" and 6-1/2", respectively.
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. Inspection revealed two supports in which the Hilti bolts were within 12" of an attachment but the minimum clearances between a 3/8" and 1/2" Hilti bolt and the Nelson studs were 5-3/8" and 4-3/8",
respectively.
4 Section 3.2.3 in Revision 7 of TUGCo Instruction QI-QP-11.10-1A states, 'in part, "Each support inspected on a raceway system shall be assigned a number shown on the engineering isometric drawing included in the conduit system work packages..
Inspection revealed one support in which its identification number did not match the applicable isometric drawing support identification number.
5.
Section 3.9 in Revision 7 of TUGCo Instruction QI-QP-11.10-1A states, in part, "The QC Inspector shall verify the conduit supports have been installed in accordance with the requirements of the...
isometric drawing...."
It further requires the use of an inspection report to document inspection results. Step (V)1. bin the inspection report states, " Verify conduit configuration."
Inspection revealed a conduit span bend opposite to that which was shown on the applicable isometric drawing, and step (V)1.b had been signed off as being acceptable.
This is a Severity Level IV violation (Supplement II) (446/8602-V-20).
D.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, of the TUGCo QAP, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings.
Contrary to the above, the following conditions were identified with
-respect to Unit 2 conduit supports in which the prescribed activities were not accomplished:
1.
Section 2.4 in TUGCo Procedure THE-AB-CS-2, Revision 0, states, in part, "The Field Engineer shall prepare a field isometric indicating the general routing and location of supports, and... shall include span lengths and configurations... decision points and locations.... Decision points are considered as places on a typical drawing for which two or more options are acceptable for the same location."
Independent inspection revealed a decision point which had not been included in the isometric drawing by the Field Engineer. One support was observed in which a 3/8" Hilti bolt had been installed. The applicable typical drawing specified a 1/2" Hilti bolt with the option of using a 3/8" Hilti bolt, provided the support capacity was reduced. The absence of this information could possibly preclude the required reduction in support capacity by the Design Engineer.
. 2.
Section 3.3.1.1 in Revision 14 of TUGCo Instruction QI-AP-11.21-1 requires that the welding symbol for an intermittent fillet weld be in accordance with standard welding symbols of AWS 2.4-79.
Inspection revealed the existence of intermittent fillet welds on 11 conduit supports in which the applicable, typical support drawing did not depict an intermittent fillet weld symbol.
This is a Severity Level IV violation (Supplement II) (446/8602-V-21).
E.
Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section 10.0, Revision 1, dated July 31, 1984, of the TUGCo 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."
Contrary to the above, the following examples from Unit 2 HVAC duct support inspections were observed where the Bahnson inspection program failed to identify nonconformances with the documented instructions, procedures, and drawings:
1.
Section 9.1 in Revision 1 of Bahnson Procedure WP-TUSI-001 states, in part, with respect to intermittent welds, " Weld increments shall begin and terminate within 1/8" of the er.ds of the joints or dimensioned length...." Seven HVAC duct supports, however, inspected by the NRC had intermittent fillet welds which did not begin or terminate within 1/8" of the ends of the joints.
2.
Section 6.5 in Revision 5 of Bahnson Procedure QCI-CPSES-011 states, in part, with respect to welding, "The Quality Representative shall make certain that the size, length, and location of all welds conform to the requirements of QCI-CPSES-014 and DFP-TUSI-003, and to the detailed drawing...."
Independent inspection identified the following conditions in three HVAC duct supports:
a.
A 2" long, 1/4" fillet weld required by the drawing was measured as being 1/8" for the full length, b.
Two, 2-1/2" long, 1/8" fillet welds required by the drawing between the two lateral braces and the main support were
- missing, c.
Two,1-1/2" long,1/8" fillet welds required by the drawing were measured as being 1-1/4" long.
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. 3.
Section 6.6 in Revision 5 of Bahnson Procedure QCI-CPSES-011 states, in part, " Weld profiles shall meet the following requirements:
The faces of fillet welds may be slightly convex, flat, or slightly concave... Welds shall be visually examined to
-determine if the following defects are evident:.... Undercut shall not exceed 1/32" for materials thicker than.1/4"."
One support was identified in which two welds exhibited 1/16" undercut for 50 percent of the weld lengths on members which were 1/2" thick. The support also had a 1/4" and a 3/8" weld in which grinding of the weld produced excess convexity, resulting in an unacceptable weld profile.
4.
Note 2 in Attachment 4 uf Revision 10 to Bahnson DFP-TUSI-004 states, in part, "Where the embedded steel plates are occupied by attachments within the minimum distance shown above (12"), the minimum clearance from 1" 9 Hilti anchors to... the edge of the embedded plate is 7-1/2" "
One HVAC duct support was identified which had a 1" diameter Hilti bolt located 11" from an attachment on an embedded plate and only
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3/8" from the edge.
This is a Severity Level IV violation (Supplement II) (446/8602-V-17).
F.
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... include provisioas to assure that appropriate quality star.dards are specified and included in design documents and that deviations from such standards are controlled... The design control measures shall provide for verifying or checking the adequacy of design... Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design...."
Contrary to the above, verification or checking of a design change, initiated to resolve a deviation from design documents, did not assure the adequacy of either the design change or the disposition of the nonconformance report (NCR) which documented the deviation. NCR M-80-00161, initiated on November 6, 1980, addressed the drilling through of a " probable" template bar, a rebar, and notching another rebar. The disposition was "Use-As-Is" and referenced DCA No. 9091. The solution in the DCA stated that, "The condition as described is acceptable." However, the described condition addressed just one cut bar.
This is a Severity Level I) violation (Supplement II) (445/8603-04).
G.
Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section 10.0, Revision 1, dated July 31, 1984, of the TUGCo QAP, states, j
in part, "A program for inspection of activities affecting quality shall i
I
- be established and executed... to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity."
Paragraph 2.0 in Revision 0 to TUGCo Procedure THE-AB-CS-3 requires walkdown drawings to reflect history and methodology to produce as-built drawings.
It further requires the walkdown drawings to depict all the necessary information required for subsequent QC verifications; i.e.,
support configuration dimensions and material sizes.
Paragraph 3.2.3 in Revision 5 to TUGCo Instruction QI-QP-11.10-2A requires the QC inspector to verify that the completed support is in accordance with the as-built drawing.
Contrary to the above, the following conditions were identified with respect to seven Unit 2 cable tray support drawings:
1.
Walkdown drawings neither depicted all required information nor included correct dimensional information necessary for subsequent QC verification.
2.
QC inspectors accepted support dimensions which were different from those specified on the walkdown drawings.
This is a Severity Level IV Violation (Supplement II) (446/8602-V-14).
H.
Criterion IX of Appendix B to 10 CFR Part 50 states, in part, " Measures shall be established to assure that special processes, including welding... and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Section CC-5521.1.1 of Code ACI-359, states, in part, "If the 12-in, radiograph in the 50-ft-long increment of weld does not meet the acceptance standards, two 12-in. films shall be taken at other locations within the 50-ft-long increment.... If either of the second radiographs does not meet the acceptance standards... the remaining portion of the 50-foot increment of this weld shall be radiographed."
Contrary to the above, the required radiography of the remaining portion cf a 50' increment of weld was not performed even though one of the two second 12" radiographs (No. 146T2) at seam P84 in the Unit 2 containment liner did not meet the acceptance standards.
This is a Severity Level-IV violation (Supplement II) (446/8602-V-10).
I.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGCo's Final Safety Analysis Report (FSAR) Section 17.2, " Quality Assurance During the Operations Phase," dated July 19, 1985, requires that l
i J activities affecting quality'be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Operations Administrative Control and Quality Assurance Plan Section 3.9 states that, " Deficiency Reports.(DRs) and nonconformance reports (NCRs) shall be reviewed periodically for adverse trends... Results of trend analysis shall be reported to the Manager, Nuclear Operations, Manager, Plant Operations, and Manager, Quality Assurance."
Contrary to the above, site operations trend analyses were performed on DRs only for 1984 and 1985. Consequently, trend analyses for problems identified on NCRs were not performed and thus not reported to the required levels of management. Further, site procedures do not clearly describe the conditions under which a DR or an NCR is to be written, nor were DRs reviewed for potential conditions requiring an NCR prior to a June 1985 revision to the deficiency reporting procedure STA-404 This is a Severity Level IV violation (Supplement II) (445/8603-V-02).
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, (2) the corrective steps 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 will be given to extending the response time.
Dated at Arlington, Texas this j7#4> day-of gg 1986 I
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