ML20238D419
| ML20238D419 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/18/1987 |
| From: | Warnick R NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20238D401 | List: |
| References | |
| 50-445-87-31, 50-446-87-23, NUDOCS 8801040250 | |
| Download: ML20238D419 (3) | |
See also: IR 07100104/2012001
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APPENDIX A
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TU Electric
Dockets:
50-445/87-31
50-446/87-23
Comanche Peak Steam Electric Station
Permits:
CPPR-126
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Units 1 and 2, Glen Rose, Texas
CPPR-127
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During an NRC inspection conducted on November 4 through
December 1,
1987, violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedure
f or NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the
violations are listed below:
A.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by
Section 5.0, Revision 3 of the TU Electric Quality Assurance
Plan (QAP), states, in part,
Activities affecting quality
"
shall be prescribed by documented instructions, procedures, or
drawings, or a type appropriate to the circumstances and shall
be accomplished in accordance with these instructions,
procedures, or drawings.
"
. . .
Section 7.7.1 of Revision 2 to EBASCO's Field Verification
Method (FVM) CPE-EB-FVM-CS-033, states, in'part, "The Walkdown
Engineer will identify each type of support by comparison with
supplement I and/or 2323-S-0910 sketches or drawings, and will
as-built the support on the applicable sketch or
drawing .
Paragraph K of this section of the FVM
"
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further states, "All dimensions and/or attributes shown will
be verified .
If the designed dimensions / attributes are
. . .
incorrect, they shall be lined out and the actual dimension /
attribute recorded."
Further, paragraph N states that the
walkdown engineer will redline ".
. any HKB/HSKB spacing
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violation per Table
2."
Contrary to the above, the following conditions were
identified:
1.
For support C13OO7808-04, which is a 2323-S-0910
Type CA-la support, the anchor bolts identified as
bolts A, E, and F were lined out.
This implied that
anchor bolts did not exist at these locations for'this
unique support.
During a subsequent walkdown by the NRC
inspector, however, an anchor bolt was found to exist at
the location designated for anchor bolt A.
This bolt was
determined to be a 1/4" Hilti Kwik bolt with the letter
designation "D" and a projection of
1".
While the
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- xistence of this additional anchor bolt Mill not have a
detrimental effect on the structural integrity of the
support, the fact that it was not identified during the
EBASCO walkdown is of significance relative to the-
adequacy of the walkdown itself.
2.
On support C14G21398-03 the walkdown engineer failed to
record one of the dimensions required to fully locate the
structural tubing on the base plate.
This information is
required in order to calculate base plate stress and
anchor bolt loads.
This dimension is one of the
dimensions required to be reported for this type of
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support (2323-S-0910 sh. CSM-18 type support).
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3.
On support C14B13125-02, Lie walkdown engineer. failed to
note a spacing violation between the 1/4" Hilti Kwik bolt
designated as Bolt F on the support in question, and a
3/8" HKB on an adjacent conduit support.
The NRC
inspector found these anchor bolts to be 2 1/4" apart;
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while the FVM required a spacing of at least 3 1/8".
This is a Severity Level V violation (Supplement II)
(445/8731-V-01).
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B.
Criterion XVI of Appendix B to 10 CFR Part 50, as implemented
by Section 16.0, Revision 0, of the TU Electric QAP, states,
in part, " Measures shall be established to assure that-
conditions adverse to quality .
. are promptly identified
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and corrected .
and corrective action taken to preclude
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repetition."
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Nuclear Engineering and Operation Procedure NEO 3.06,
" Reporting and Control of Deficiencies," requires deficiencies
(principally programmatic and not directly related to hardware
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problems) to be identified,'the cause established, and action
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taken to prevent repetition.
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Contrary to the above, the " rework" dispositions of NCRs
I-85-101890SX and C-86-200378X were incorrectly revised to
"Use-As-Is" dispositions, subsequent to engineering becoming
aware that the conditions which created the need for the NCRs
had been corrected outside of the scope and control of the
NCRs.
By revising the dispositions and closing out the NCRs,
actions were not taken to determine the cause of the
deficiency (uncontrolled work) or to prevent repetition.
This is a Severity Level IV violation (supplement II)
(445/8731-V-02; 446/8723-V-01).
Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby
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required to submit a written statement or explanation to the U.
S.
Nuclear Regulatory Commission, ATTN: Document Control Desk,
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20555 with a copy to the Assistant Director for
Inspection Programs, Comanche Peak Project Division, Office of
Special Projects, within 30 days of the date of the letter
transmitting this Notice.
This reply should be clearly marked as a
" Reply to a Notice of Violation" and should include for each
violation:
(1) the reason for the violation if admitted, (2) the
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corrective steps that have been taken and the results achieved,
(3) the corrective ateps that will be taken to avoid further
violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in
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this Notice, an order may be issued to show cause why the license
should not be modified, suspended, or revoked er why such other
action as may be proper should not be taken.
Consideration may be
given to extending the response time for good cause shown.
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FOR THE NUCLEAR REGULATORY COMMISSION
$$fh&
Dated at Comanche Peak Site
this 18th day of December 1987
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