ML20215J832

Notice of Deviation from Insp on 860201-0331

ML20215J832
Person / Time
Site:	Comanche Peak
Issue date:	10/17/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215J811	List: IR 05000446/1986002 ML20215J809 ML20215J821 ML20215J832 ML20215J864 ML20215J897 ML20215J921
References
50-445-86-03, 50-445-86-3, 50-446-86-02, 50-446-86-2, NUDOCS 8610270205
Download: ML20215J832 (4)

Text

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APPENDIX B NOTICE OF DEVIATION 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 Based on the results of an NRC inspection conducted on February 1-March 31, 1986, deviations from comitments to the NRC were identified. The deviations consisted of incorrect review of a revision to a Quality Instruction (QI) with respect to impact on inspection performed to a prior revision, omission of a required inspection attribute from a QI, failure to identify an unacceptable weld surface condition after coating removal, inadequate engineering review for applicability of an inspection attribute, and failure to comply with approved instructions in performance of reinspections. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the deviations are listed below:

A. Paragraph 5.3.5(A) of Evaluation Research Corporation (ERC) QI-019, Revision 3, states, in part, " Verify that the clearance meets the following criteria: . . . Where design shows 0 inch on one side and 1/16 inch on the other side, the sum of both gaps may not exceed 1/8 inch or be less than 1/32".*

• Where design shows 0" on bottom (in the gravity direction) then it shall be such with no allowable variation." ,

Section II of ERC Description Memorandum QA/QC-RT-1436 addresses changes, reasons, and effects incorporated in Revision 3 of ERC QI-019 and states, in part, regarding paragraph 5.3.5(A), "Added clarifying information on allowable clearances for dead weight and 0" clearance supports . . . ."

Attachment A to the above ERC Description Memorandum lists previously issued reinspection packages and states that package I-S-SBPS-051 is not affected by changes incorporated in Revision 3 of ERC QI-019.

In deviation from the above, independent inspection identified that clearances which had been correctly accepted by ERC for Verification Package No. I-S-SBPS-051, when inspected to Revision 1 of QI-019, were no longer acceptable to the requirements of Revision 3 of QI-019. Drawing CP-AA-040, Revision 0, shows clearance in the gravity direction of zero.

Independent inspection measured a gap of 1/16" in the gravity direction, and thus determined that the changes in Revision 3 did, in fact, affect the previous inspection of Verification Package No. I-S-SBPS-051 (445/8603-D-14).

B. Paragraph 5.1 of ERC Procedure CPP-007, Revision 2 states, in part,

" Responsible QA/QC discipline engineers review the latest . . . Brown &

Root . . . documents relating to the population. Subsequently, the engineer develops a list of safety significant attributes that are comon to the population and which can be reinspected . . . . "

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Paragraph 3.4.4.3 in Brown & Root, Inc. Instruction QI-QAP-11.1-28, Revision 31, identifies requirements for base material inspection and states, in part, "The depression depth produced by grinding shall not exceed . . 1/32" for material less than 3/8" thick (structural shapes)."

In deviation from the above, the responsible QA/QC discipline engineer failed to identify and incorporate into ERC QI-029 this base material inspection attribute. As a result, ERC inspection of Verification Package No. I-S-LBSN-065 failed to identify that grinding on base material in excess of 1/32" existed on item 3 of pipe support MK No. CT-1-008-001-S22S (445/8603-D-18).

C. Section 5.2 of ERC Procedure CPP-022, Revision 0, states, in part, " Paint shall be removed from the weld connections which have been inspected through paint . . . . Results of these visual inspections shall be documented and include, as a minimum, criteria utilized, (and) any discrepancies." Section 5.2.D of ERC QI-062, Revision 0, states, " Verify surface of welds are sufficiently free of overlap, abrupt ridges and ripples so proper interpretation of radiographic and/or other required NDE could be accomplished."

In deviation from the above, ERC quality inspection personnel documented in Verification Package No. I-S-NPBW-014 that the surface of welding which attached item 1 to support steel identified on Drawing FW-1-019-901A-C57W was acceptable. Independent inspection identified, however, that after removal of coatings the weld surface was unacceptable. Subsequent to the NRC inspection, ERC personnel issued a deficiency report documenting tha rejectable weld condition (445/8603-D-17).

D. Section 5.1.1 of Revision 2 to ERC Procedure CPP-008 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, an independent inspection of Verification Package No. I-S-HVDS-075, support DG-844-2K-1J, revealed that Sections 2F.1, 2F.2, and 2F.3 in'the checklist for QI-035, dealing with embed plates and spacing violations, had been "N/A'd" by the engineer.

Further, the noted justification for this entry was "No Embedded PLs."

However, independent inspection identified the existence of an embed plate with dimensions of approximately 20' X 8" (446/8602-D-13).

E. Section 4 of Revision 3 to ERC Procedure CPP-009 states, in part,

" Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions . . . ."

In deviation from the above, the following examples were noted where field reinspections of hardware items were not performed in accordance with approved instructions:

1. Attribute 2D. in Section 5.0 of Revision 0 to QI-035 states, " Verify member lengths and all other dimensions that describe the lengths and positions of members on the support frame (i 1/2")." For Verification Package No. I-S-HVDS-075, Support D6-844-2K-1J, the ERC inspector signed the checklist that this attribute (2D.) was acceptable. An independent inspection revealed, however, that there were several members for which no dimensional information was provided.in the drawing thus making it impossible to verify required member lengths and all other dimensions that describe the lengths and positionsofthosemembers(446/8602-D-12).

2. Attribute 3B. in Section 5.0 of Revision 0 to QI-035 states, " Verify that weld sizes meet the requirements of the duct support detail drawings." For Verification Package No. I-S-HVDS-037, the ERC inspector signed attribute 3B. as being acceptable and noted that all welds had been measured with a Fiber Metal Fillet Gauge. During an independent inspection, it was noted that there were two skewed fillet welds on this support in which one leg of the fillet on each weld could not be measured with a Fiber Metal Fillet Gauge or any otherconventionalmethod(446/8602-D-11).

3. Attribute 1.f in Section 5.2.6.2 of QI-025, Revision 2, states, in part, " Ensure that a minimuu of 2 inches clearance is maintained, including pipe insulation, with respect to other piping when one or both lines have an operating temperature of 200 F or greater . . . ." For Verification Package No. I-M-LBC0-148, the ERC inspector signed off this attribute as acceptable, even though there were three cases where the minimum separation criteria were not met and no documentation existed justifying this condition. The three instances were as follows:

a. Line 2-CC-1-060-152-3 was in contact with the inspected line at a location 6' 6" north of wall 7-S and 10' west of wall D-S.

The two lines were parallel and were in contact for about 4'.

b. Line 2-CC-1-061-152-3 was in contact with the inspected line at a location 12' 6" north of wall 7-S and about 8' west of l wall D-S.

} c. Line 1-CC-1-062-152-3 was clcser to the inspected line than the allowable 2" at a location 6' 6" north of wall 7-S and 7' 6" westofwallD-S(445/8603-D-13).

Texas Utilities Electric Company is hereby requested to submit to this office, within 30 days of the date of this letter transmitting this Notice, a written

. statement or explanation in reply, including for each deviation: (1) the i reason for the deviation if admitted, (2) the corrective steps which have been j

taken and the results achieved, (3) the corrective steps which will be taken to l

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avoid further deviations, 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 /~/M dayofd&$44.>1986 l

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