TXX-3655, Responds to NRC Re Violations Noted in IE Insp Repts 50-445/83-07 & 50-446/83-04.Corrective Actions:Const Personnel Will Be Reinstructed in Necessity for Rigid Compliance W/Design & Procedural Requirements
| ML20076D100 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/15/1983 |
| From: | Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20076D081 | List: |
| References | |
| TXX-3655, NUDOCS 8305200674 | |
| Download: ML20076D100 (3) | |
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April 15, 1983 TXX-3655
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Mr. G. L. Madsen, Chief M i 81983 Reactor Project Branch 1 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement j
611 Ryan Plaza Drive, Suite 1000 Docket Nos.:
50-445 Arlington, Texas 76012 50-446 COMANCHE PEAK STEAM ELECTRIC STATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NO. 83-07/04 FILE NO.:
10130
Dear Mr. Madsen:
This will serve to document our telephone conversation with T. F. Westerman on April 12, 1983, wherein we requested an extension of the due date for responding to the Notice of Violation contained in NRC Inspection Report No. 83-07/04.
An extension of three working days, until April 18, 1983, was granted.
We have reviewed your letter dated March 14, 1983 on the inspection conducted by Messrs. L. D. Gilbert and C. E. Johnson of activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak, Units 1 and 2.
We have responded to the finding listed in Appendix A of that letter.
To aid in the understanding of our response, we have repeated the requirement l
and your finding followed by our corrective action.
We feel the enclosed infor-mation to be responsive to the Inspector's finding.
If you have any questions, please advise.
Very truly yours, I
RJG:aq Enclosures cc:
NRC Region IV - (0 + 1 copy)
Director, Inspection & Enforcement (15 copies) s l
U. S. Nuclear Regulatory Commission Washington, DC 20555 8305200674 83051s PDR ADOCK 05000445 O
APPENDIX A NOTICE OF VIOLATION Texas Utilities Generating Company.
Docket:
50-445/83-07 Comanche Peak Unit 1 Permit:
CPPR-126 Based on the results of an NRC inspection conducted during the period January 27-28 and February 1-2, 1983, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 47 FR 9987, dated March 9,1982, the following violation was identified.
Failure to Follov Procedure Criterion V of Appendix B to 10 CFR Part 50 requires that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances, and shall be accomplished in accordance with the procedures.
Brown & Root, Inc., Construction Procedure CP-CPM 9.10, Revision 8, paragraph 3.2.4, specifies that the fit-up gap for "T" fillet joints should l
not exceed 1/16"; however, if the gap is in excess of 1/16", but not exceed-i ing 5/32", this condition will be considered acceptable provided the leg of the fillet weld is increased by the amount of separation in excess of 1/16".
Contrary to the above, on January 28, 1983, the NRC inspector determined that l
Pipe Support Mark No. SW-1-10.2-106-Y33K had been welded with a fit-up gap of l
1/4" at one end of the "T" fillet joint which attached piece 7 to piece 4.
The 1/4" fit-up gap exceeds the 5/32" maximum allowable fit-up gap require-ment of Procedure CP-CMP 9.10.
This is a Severity Level V Violation.
(Supplement 11.E) (445/8307-01)
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Corrective actions have. included the following:
1)
Identification of the procedural violation as a nonconforming condition (NCR-51235);
2)
Removal of the affected portions of the pipe support (for investi-gative reasons) and replacement with new materials; 3)
Engineering evaluation of the total weld for purposes of evaluating safety consequences, if any.
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Notice of Violation TXX-3655 As noted above, the pipe support was reworked to comply with design and procedural requirements.
Engineering evaluation of the original as-built conditions revealed the following:
- 1) The excessive gap occurred at the toe of the skewed angle, and for a distance of six inches toward the heel on one side and seven inches on the other. No design cregit is taken for the weld at the o
toe of the angle, as it exceeds 135 (157 ).
Additionally, to account for the corner effect caused by the radius of the tube steel, 2.56 inches cf the weld on each side at both the toe and heel is excluded from design consideration.
This results in a total weld length (for which design credit is taken) of 10.24 inches on each sida.
- 2) Taking no credit for the weld where gap is in excess of 5/32, and excluding 2.56 inches at both the toe and heel, the remaining weld which is within acceptance criteria is 6.8 inches on one side and 5.8 inches on the other.
3)
Design calculations based on as-built piping loads indicate a total of 1.6 inches of fillet weld is required on both sides to meet structural design requirements.
In summary, had the gap condition not been detected, there would be no adverse results.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Affected construction personnel will be reinstructed in the necessity for rigid compliance with design and procedural requi'rements.
l DATE OF FULL COMPLIANCE Corrective actions are complete.
Preventive measures are scheduled to be completed by April 22, 1983.
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