ML20247B070

Notice of Violation from Insp on 890208-0307.Violations Noted:Snubbers Installed W/Low Strength Bolting That Could Have Been Overstressed If Subjected to Max Allowable Design Load & Inadequate Review of Design Calculations Identified

ML20247B070
Person / Time
Site:	Comanche Peak
Issue date:	03/24/1989
From:	Warnick R Office of Nuclear Reactor Regulation
To:
Shared Package
ML20247B065	List: IR 05000445/1989012 ML20247B059 ML20247B070
References
50-445-89-12, 50-446-89-12, NUDOCS 8903290277
Download: ML20247B070 (5)

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APPENDIX A NOTICE OF VIOLATION TU Electric Dockets: 50-445/89-12 50-446/69-12 I

Comanche Peak Steam Electric Station Permits: CPPR-126 Units 1 and 2, Glen Rose, Texas CPPR-127 During an NRC' inspection conducted on February 8 through March 7, 1989, violations of NRC requi'tements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed below:

A. Criterion III of Appendix B to 10 CFR Part 50, as implemented by.Section 3.0, Revision 0 of the TU Electric Quality Assurance Manual, states, in part, " Measures shall also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components . . . .

Paragraph 6.3.c of ECE-5.19, Revision 2, states, in part, "The RE [ Responsible Engineer] assigned to perform the review of the vendor document shall ensure that the following items are considered as appropriate or applicable: the material, equipment, document, Service, or "process is in compliance with CPSES design requirements . . . .

Contrary to the above, snubbers were installed with low strength bolting that could have been overstressed if subjected to the maximum allowable design load.

This is a Severity Level IV violation (445/8912-V-01).

B. Criterion III of 10 CFR 50, Appendix B, as implemented by Section 3 of the TU Electric Quality Assurance Manual (QAM), 4 states, in part, ". . . design control measures shall provide I for verifying or checking the adequacy of design, such as by {

the performance of design reviews, by the use of alternate or simplified calculaticaal methods, or "

by the performance of a suitable testing program . . . . l Contrary to the above, the NRC inspector identified the l

following examples of inadequate review of design calcu'. n 4 cns b90324 h[j [O$bk 3500ggg5 Q

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1. Piping calculation GENX-315, Revision 0, and Calculation Change Notice (CCN) No. 1 to this revision of the calculation were found by the NRC to contain numerous examples (such as not utilizing proper stress

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intensification factors for piping thickness less than 3/16 inch and not performing a functionality check using the proper wall thickness) of the reviewer's failure to identify that the preparer did not follow the analysis procedure outlined'in the body of the calculation.

2. The following pipe ~ support calculations were also found by the NRC to contain errors that were not identified by the reviewer:

a. CT-1-137-714-S22R - Forces and moments transposed incorrectly.

b. H-SW-1-SB-019-017 Three different instances of incorrect moments.

c. H-CC-1-SB-046B-011 Computer model incorrect.

d. CC-1-068-028-A33R - One weld calculation incorrect.

Wrong weld configure

• ton used in another weld calculation. '

e. CS-1-SB-053A-001 Out-of-plane forces not evaluated. Local effects not evaluated.

f. SI-1-093-011-S42R - Local stress evaluation incorrect. Web crippling not evaluated. Computer model nonconservative,

g. SI-1-SB-024-007 Computer model incorrect.

h. CC-1-146-013-S43R - Construction tolerance not considered in the worst case. "Z" load incorrect.

Slenderness ratio incorrect.

i. CS-1-906-032-542K - Moment calculation incorrect. ]

j. CT-1-011-005-S22K - Baseplate model incorrect.

k. SI-1-039-026-S32R - Weld configuration analyzed does not agree with as-built.

1. SI-1-039-042-S42K - Weld analysis incorrect.

Baseplate model incorrect.

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m. VD-1-049-017-S45R - Weld analysis incomplete.

n. SI-1-095-003-S42R - Baseplate model incorrect.

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o. MS-1-025-008-S75K - Construction tolerance not-factored into analysis.

p. CT-1-008-004-S22R - Loads due to offsets not considered. Baseplate model incorrect.

q. CS-X-AB-014-001 Weld analysis incorrect.

Baseplate model incorrect,

r. CC-X-079-005-A43K - Local stress evaluation incorrect.

s. SW-1-AB-014-018 Construction tolerance not factored into analysis. Computer model incorrect.

This is a Severity Level IV violation-(445/8912-V-02).

C. Criterion V of Appendix B to 10'CFR 50, as implemented by Section 5.0, Revision 0 of the TU Electric Quality Assurance Manual (QAM), 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. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

The requirements for inspections of component supports, which include pipe supports: are contained in Brown & Root ASME .

Quality Procedure AQP-11.3.  ;

contrary to the above, the NRC inspector identified the i

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following examples of inadequate inspection of pipe supports: .)

l l (1) MS-1-003-001-C725 - The beam attachment had one ear that i was bent.

(2) FW-1-018-718-C72K - The snubber clamp on this support does not provide the necessary clearance to allow for the i

full range of angular motion.

(3) CT-1-038-418-C62S - The spring load column is cocked beyond the tolerance of ASTM-A-125.

(4) CS-1-002-700-C52S - No sight hole in one of the spring load couplings.

(5) CC-1-258-003-C53R - che spherical bearing in the sway  !

strut paddle end is partially dislodged. i

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(6) RC-1-135-004-C51K - The clamp for this snubber will not allow the' full range of angular movement.

(7) CC-1-207-020-C53R - The space between the ears'of the I clamp exceeds maximum tolerance.

(8) FW-1-096-002-C62K - Inadequate clearance between the clamp and snubber body to allow the full range of angular movement.

(9) FW-1-096-002-C62R - Space between the ears of'the clamp exceeds the maximum tolerance.

l (10) MS-1-340-001-C52s - The eye nut is bound against the top of the pipe clamp.

(11) CC-1-269-700-C53A - One of the welds has a fit-up gap that exceeds the criteria of the weld procedure specification.

(12) MS-1-344-700-C52K - The spherical bearing on the paddle end of-the snubber is completely dislodged.

(13) RC-1-018-038-C51K - The space between the ears of the clamp exceeds the maximum tolerance.

(14) FW-1-098-701-C62K - The jam nuts on both sway strut bodies are loose.

(15) MS-1-RB019-005-2.- The clamp ears are bent to less than the minimum allowable dimension.

(16) CT-1-014-001-322S - The threaded rod on this support interferes with the supporting steel.

(17) SI-1-070-006-S22R - The ears on the cotter pin are not spread.

(18) BR-X-106-064-S43R - Baseplate not grouted properly.

(19) CS-1-908-702-S42R - Jam nut for the sway strut body not tightened properly.

(20) SI-1-060-006-S42R - Clamp ears not parallel and load pin not parallel to clamp bolt.

(21) CS-1-106-717-C42R - Cotter pin missing.

(22) CS-1-106-723-C42R - Cotter pin missing.

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l (23) CC-1-016-700-A43R - Cotter pin ears not spread (previous inspection finding 445/8865-0-01).

This is a Severity Level IV violation (445/8912-V-03).

1 pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby required to submit a written statement or explanation to the U. S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, i Washington, DC, 20555, with a copy to the Assistant Director for l Inspection Programs, Comanche Peak Project Division, Office of Nuclear F.. actor Regulation, 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 corrective steps that have been taken and the results achieved, (3) the corrective steps 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 this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION RFb)J Dated at Comanche Peak Site this 24th day of March 1989