ML20247C269
| ML20247C269 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/16/1989 |
| From: | Warnick R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20247C266 | List: |
| References | |
| 50-445-89-26, 50-446-89-26, NUDOCS 8905240385 | |
| Download: ML20247C269 (4) | |
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p APPENDIX A NOTICE OF VIOLATION TU Electric Dockets:
50-445/89-26 50-446/89-26 Comanche Peak Steam Electric Station Permits:
CPPR-126 l
Units 1 and 2, Glen Rose, Texas CPPR-127 During an NRC inspection conducted on April 5 through May 2, 1989, I
three violations of NRC requirements 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.
Criteria XVI of Appendix B to 10 CFR Part 50, as implemented by Section 16.0, Revision 0, of the TU Electric Quality Assurance Manual requires that " Measures shall be established to assure that conditions adverse to quality, are promptly identified and corrected."
Contrary to the above, nonconformance reports (NCRs) 88-19673 and 88-18905 were closed out without all identified discrepancies being corrected.
During the NRC inspector's verification of the corrective action on NCRs 88-19673 and 88-18905, which required that a galvanized coating be applied to those areas of duct segments B-1-658-028, 041, 043, 045, 047, and B-1-658-032 bereft of a galvanized coating, the following was observed:
Welds on the north face of the referenced duct segments still lacked the NCR required galvanizing.
Raw exposed edges of structural components located on the internal portion of one duct segment were still uncoated.
This is a Severity Level V violation (Supplement II)
(445/8926-V-01).
B.
Criterion X of Appendix B to 10 CFR 50, as implemented by Section 10, Revision 0, of the TU Electric Quality Assurance Manual states, in part, "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance I
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2 with.the documented instructions, procedures, and drawings for accomplishing the activity."
Centrary to the above, the following conditions were not identified during PCHVP inspection of structural steel Class I and II platforms:
Platform AB-0241-01 A 6" x 3 1/2" angle s Am in Section F-F, page 14 of DCA 62581 is specified to be 3 feet 9 inches in length.
The actual length is 3 feet 10 inches.
Platform SGl-77N-01 The NRC inspector requested QC to verify dimensions on Section 1-1 of drawing 2323-S1-0637.
The QC inspector determined that an error had been made in one dimension and issued an NCR to address the condition.
Platform AB-113-01 l
(1)
Page 5 of DCA 1508, Revision 7, shows a typical brace I
connection with 1 1/2-inch (i 1/4-inch) spacing between the center line of a 3/4-inch A-325 bolt and the end of a 4" x 4" x 1/4" angle.
On the east face of the southwest column, the spacing is 2 1/16 inches.
1 (2)
Page 7 of DCA 1508, Revision 7, shows a minimum edge distance of 1 1/4 inch for a 3/4-inch Hilti bolt on the southeast baseplate.
The actual distance is 1 1/16 inch.
Platform FB-271B-01 A 3" x 3" x 1/4" angle, MK C-12 on drawing MFB-0803-DCA, sheet 2, Revision 1, is shown to be 36 5/16 inches in length.
The installed length is 42 3/4 inches.
Platform AB-206-01 (1)
DCA 5465, Revision 9, page 5, Section 5-E nalls for single bevel groove welds.
Near side and imr side fillet l
welds were installed.
i l
(2)
DCA 5465, Revision 9, page 7, Section AA, calls for single bevel groove welds.
Fillet welds were installed.
s 3
l (3)
Drawing figure 706-001, Revision 1, shows 3 1/2" x 3 1/2" x 1/2" angles, members 6-Y1, to be 7 feet 4 3/16 inches in length.
The installed length is 8 feet 7 1/4 inches.
Also, the angles are shown welded using 3/8-inch single bevel groove welds.
These welds are undersized.
This is a Severity Level IV violation (Supplement II)
(445/8926-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 requires that " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with those instructions, procedures, or drawings."
Contrary to the above, Procedure AQP 11.2, " Fabrication and Installation Inspection of Pipe and Equipment," and Construction Traveler CC-1-RB-003, governing the application of a seal weld to spool piece 803 on isometric drawing i
BRP-CC-1-RB-003, did not provide a necessary requirement for craft and quality control (QC) to verify that the finished configuration remained in specification with the isometric drawing.
This construction activity resulted in the rotation of the stem of valve ICC-692 from the original 'l degree (from vertical) angle depicted on isometric drawing BRP-CC-1-RB-003 to a final configuration of 22 degrees.
This 9 degree difference exceeds the maximum tolerance of 15 degrees permitted by Specification 2323-MS-100, Revision 9.
As a result of the procedural deficiency, neither the installing craft nor the inspecting QC identified the existence of this out-of-specification condition.
This is a Severity Level IV violation (Supplement II) 445/8926-V-03).
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, Washington, DC, 20555, with a copy to the Assistant Director for Inspection Programs, Comanche Peak Project Division, Office of Nuclear Reactor 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,
4 (3)'the corrective steps that will be taken to avoid further violations, and.(4) che 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 FF F /d ar d Dated at Comanche Peak Site this 16th day of May 1989
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