TXX-4037, Responds to NRC Re Violations Noted in IE Insp Rept 50-445/83-23.Corrective Actions:Engineering Evaluation Concluded That Plant Safety Would Not Have Been Affected. Mods Made to Insp Procedures

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Responds to NRC Re Violations Noted in IE Insp Rept 50-445/83-23.Corrective Actions:Engineering Evaluation Concluded That Plant Safety Would Not Have Been Affected. Mods Made to Insp Procedures
ML20080S767
Person / Time
Site: Comanche Peak Luminant icon.png
Issue date: 08/31/1983
From: Gary R
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To: Madsen G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20080S751 List:
References
TXX-4037, NUDOCS 8310180488
Download: ML20080S767 (3)


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NJG 3 I1983 /

Mr. G. L. Madsen, Chief .

l D Reactor Project Branch 1 U. S. Nuclear Regulatory Connission Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Docket No.: 50-445 Arlington, TX 76012 50-446 COMANCHE PEAK STEAM ELECTRIC STATION RESPONSE T0 fRC NOTICE OF VIOLATION INSPECTION P.EPORT N0. 83-23, FINDING N0.1 FILE N0. : 10130

Dear Mr. Madsen:

We have reviewed your letter dated July 27, 1983 on the Special Fuel Building inspection of activities authorized by NRC Construction Permit CPPR-126 for Comanche Peak, Unit 1. Our report logged TXX-4031 dated August 24, 1983 provided the response to Finding No. 2 contained in Appendix A of that letter.

In addition, an extension until September 1,1983 was granted for responding to Finding No. 1. To aid in the understanding of our response, we have repeated the requirement and Finding No.1 followed by the conclusions of our review of these items regarding the adequacy of the safety function and the overap actions taken to improve our QA/QC program. We feel the enclosed information to be responsive to the Inspector's finding. If you have any questions, please advise.

Very truly yours,

$$bw w RJG:1n Enclosures ,

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cc: tRC Region IV - (0 + 1 copy)

Director, Inspection & Enforcement (15 copies)

U. S. Nuclear Regulatory Commission Washington, DC 20555 h0h[0 G

, ,TXX-4037 APPENDIX A NOTICE ;0F, VIOLATION Texas Utilities Generating Company Docket: 50-445/83-23 Comanche Peak Steam Electric Station, Unit 1 Permit: CPPR-126 Based on the results of an NRC inspection conducted during the period of May 23 through June 10, 1983, and in accordance with the NRC Enforcement Policy 30 CFR Part 2, Appendix C), 47 FR 9987, dated March 9,1982, the following violations were identified:

1. Inspection Program 10 CFR 50, Appendix B, Crit?rion X states that, "a program for inspection of activities af fecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity." The Final Safety Analysis Report, Section 17.1.10 states that, "the organization having the responsibility for provision of such items also has the primary responsibility to assure that adequate inspection is done by the supplier."

Contrary to the above, the following examples were identified in which your inspection program did not detect failures to meet final construction requirements:

a. Cable Tray Supports Cable tray support material for Cable Tray Hangers 1848 and 1979 deviated from final design documents.
b. Conduit Hilti Bolts Hilti bolt spacing of one bolt at Support 8 for Conduit Run C02012850 deviated from minimum spacing allowed to adjacent abandoned hilti bolt.
c. Large Bore A_SX S Pipe Supports (1) Five pipe supports deviated from final design documents as follows: one weld for Support SF-X-002-026-F53R was undersized; dimensions for Supports SF-X-024 010-F43R and SF-X-002-025-F53R deviate from vendor certified drawings; and materials for Supports SF-X-005-015-F43S and SF-X-033-006-F43R deviated from vendor certified drawings.

(2) A broken cotter pin was found on Support SF-X-004-006-43R which had been inspected per QI-QP-11.1-28, Revisior, 20 for integrity.

TXX-4037 Page 2

d. Small Bore ASME Pipe Supports Three pipe supports deviated from final design documents as follows:

dimension for Suport H-CH-X-FB-003-001-3 deviated from final review drawing; shims for Support H-CH-X-FB-003-010-3 were misoriented during the documentation of as built conditions; and the material in Support H-CH-X-FB-004-003-3 deviates from the final review drawing.

This is a Severity Level IV Violation. (Supplanent II.e) (445/8323-01)

Conclusions Our engineering evaluation has concluded that had the aforementioned deviations gone undetected there would be no affect on plant safety. .

t Improvements of QA/QC Program Consistent with our engineerinag evaluation of these items, we have also concluded that no sign'ficant QA/QC program improvements are required.

Although the basic QA/QC program will remain the same, we have made minor adjustments to inspection proceduras and checklists. These adjustments merely provide more detail to existing program requirements.

Documentation regarding our Conclusions and Improvements will be available for your Inspectors review at the CPSES site.

2. As stated in the cover letter, a response to this item was provided in TXX-4031, dated August 24, 1983.

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