TXX-4429, Responds to NRC Re Violations Noted in Insp Rept 50-445/84-26.Corrective Actions:Rev 1 to DCA 20,721 Issued Against Drawing E1-1702-02 & Generic Nonconformance Repts for Items Identified by NRC Issued & Dispositioned
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February 28,.1985 TXX-4429 4
Corwin R. Hunter, Chief Reactor Project Branch 2 U.S. Nuclear Regulatory Commission Office of Ins:ection & Enforcement 511 Ryan Pla:a Drive. Sui:e 10C0 Docket Nos..
50-aa5 Arlington, TX 76011 50-aa6 CD!ANCHE PEAK STEAM ELECTRIC STATION RESPONSE TO NRC NOTICES OF VIOLATION INSPECTION REPORT 84-26 FILE NO.:
10130
Dear Mr. Hunter:
We nave reviewed your letter dated January 13, 1985 on the special inspection of the Safeguards and Auxiliary Building conducted by C.R. Oberg, M.E. Skow, and W.R. Bennett of activities authorized by NRC Construction Permit CPPR-125 for C:manche Peax Unit 1.
n a ccnversation between David Chapman and Doyle Hunnicutt, an extension of the 1
res:onse time was granted to March 1, 1985.
We are ;:roviding a partial response to the findings listed in Appendix A of that letter.
To aid in the understanding of cur response,.we have repeated the Notices of Viol dion followed by a summary of our corrective actions.
The specific corrective action for eacn item identified is available at CPSES fcr i
your Inscector's review.
The generi.c implications of these items are being-evaluated oy the team established to develop our Technical Review Team (TRT)
Action Plan.
If you nave any cuestions, please advise.
Very truly yours,
/
Silly R. Clerents 3RC:tig
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PDR A Lo19'l 80 4 s c r TEX A n t *rt E,t Tit.'s V2.ECrRtr t't).%C YA N T
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v APPEMOIX A 1
MOTICE OF VIOLATION Texas Utilities Electric Company Docket: 50-445/54-26 Comanche Peak Steam Electric Station Construction Permit: CPPR-126 E sed on the results of an NRC inspection conducted during the period of July 16 through September 28, 1984, and in a:cordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 49 FR 8583, dated March S, 1984, tne 4
following violations were identified:
3 A.
Failure to Protide CC Ins:ection Criteria and Minimum'Seoaratien
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10 CTR 72rt 50. A:vencia 5, Cri:erien y st:tes, in :2rt.
- n :r..;tian.. :rcetaares, er cra ongs sna;; incluce a::r::rtate cuantitative or qualitative acceptance criteria for cetermining tnat imacetant activities nave been satisfactorily acccmplisned."
IEEE-324 provides separation criteria of Class IE equicment and circuits.
The Comanene Peak Steam Electric Station Electrical Erection 5:ecification 2323-E5-100 crovides for the implemantation of the criteria of IEEE-384
.(1974).
Section 4.4.6 of 2323-ES-100 states in part, "In no case shall any part of the conduit or the conduit support system come in direct contact with uninsulated equipment in the piping system or with pipe restraints or j
anchors."
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01-QP-11'.3-29.1, Revision 16, paragraph 3.1.~7, states in part, "In no case shall any part'of the raceway or raceway support system come in i
direct contact with uninsulated equipment in the piping system or with pipe restraints or anchors unless otherwise approved oy the owner."
Q1-00-11.1-23, P.evision 2S, paragraph 3.3.4.2, states in part, "There shall be in air gap (i.e., no contact) between electrical concuit/ conduit supports 9 d piping comp ~enent supports."
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.4. :.2.: ef 22:2-EE-:c? :::ct<ie :e:2rati:n to:..v.3e tn:utt of cifferent : rains nich, for 'ne ex'amples listec, is a :nt.m cf :ne t
incn.
QI-OP-11.3-23, Section 3.9, specifies conduit separation per drawing 2323EI-1702-02, including several detailed sketches.
Contrary to the above, 1.
Specifications and QC inspection procedures do not contain specific 1
' acceptance criteria for separation of. redundant trains of flexible conduits.
2.
The separation requirements between conduits as contained in the erection specifications ES-100 and implementing procedures had not been met.
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The f:'iewing c:nciticns..ere identified:
1.
Fle.<ible conduits in the Safeguards and Auxiliary Euildings do not maintain the required one inch minimum separation between trains.
For examole, flexible conduit Cl3G20208 contacts Cl3011132, and the 1" airscace is not maintained between C13007415 and Cl3G07413.
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2.
Flexible condJits in the Safeguards and Auxiliary Suildings come in 1
direct contact with uninsulated equipment in the piping system or
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with pipe restraints or anchors. Examples include:
5 Flexible Conduit i
Numoer Item Description i
^
Cl3G07743 Flex rests on pipe bracket next to valve j
l-HV-5365.
i C13G0772 Flex rests en pipe next to valve 1-HV-
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5365.
C14021161 Flex rests on pipe succort for 1-MS-030 and 1-MS-268.
C13G12499 Flex rests on support for J515 455G.
C13G03731 Flex touches corner of support for valve 1-HV-4179.
C12005387 Flex touches pipe at elbow passing near valve 1-HV-8106.
C13015915 Flex resting en too of actuator for i
valve 1-HV-2138.
Cl3G21323 Flex touching flange of succort next to i
valve 1-FV-2196.
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Flex rests against unistrut below valve i
1-FV-4537.
3'3334693
' Flex'. conduit res s on fire pice.
Cl3GC6334 Flex wraps around adjacent support.
C14G20503
' Flex
- rests on valve bcdy.
C12002856 Flex contacts 1-HV-2480.
This is a Severity Level IV Violation (Supplement II.0) (445/S426-01)
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Cc-rective Action Summary OCA 20,721, Revision 1, dated Sectemcer 13, 1984 has been issueo against crawir; El-1702-02. This DCA contains an accroved method for maintaining minimum secarati:n i
distance between flex conduits of different trains / channels. This action was i
completed prior-to the walkdowns described below.
Generic NCR's for the items identified by the NRC have been issued and dispositioned.
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One NCR was issued for each of the following buildings: Safeguards, Reactor Containment, Service Water Intake, Control, Auxiliary and Fuel. The disposition included a walkdown by Engineering, QC and craft personnel to identify any specific cases where flexible conduits could inadvertantly be moved and cause the minimum separation criteria to be less than. allowable. QC will document these instances
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i on an electrical Separation Deficiency Report in accordance with QI-QP-ll.3-29.
Engineering will provide a disposition for eacn deficiency report. Upon completion.
of the walkdown, the dispnsitioned Separation Deficiency Reports for each building will be attached to the appropriate ovilding NCR.
I 3.
Failure to Properly Insoect 10 CFR Part 50. Accenoix B, Criterion X recuires that the inscection j
program of activities affecting quality shall be estaolished and conoucted in a manner to verify conformance with the documented instructions, crocedures, and drawings.
Procedure 01-07-11.10-2, Revision 28, " Cable Tray Hanger Inspection,"
specifies the inscection attributes for inspection assemoly, configu-ration, location, welding, etc., for conformance with design drawings and documents.
Procedure QI-CAP-l'.1-28. Revision 25, " Fabrication anc Installaticn-i Inspection of Safety Class Ccmponent Supports," specifies the inscection attributes for inspecting fabrication, installation, material, dimensional control, welding, etc., for conformance with design drawings and documents.
Contra't to the acove:
1.
The NRC inspector identified one cable tray hanger, CTH 539, that was missing the diagr-h1 b/)ce called for on drawings 2323-El-0601-1 01-S and 2323-5-901.
2.
The NRC inspector identified one cable tray hanger, CTH 12416, that
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had the horizontal legs aligned nortn-south vice east-west as specified on drawing 2323-El-0601-01S_and FSE-00159 sheet 12415.
t 3.
The NRC inspector identified one pipe suoport that.vas missing two
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welds as specified on drawing CT-1-014-015-542K.
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The following is a ccc:i'i-':n -" 1::iti: nil deficiencies by general category and the drawing bc :07.crent e.nere it was fcuno.
Category C ::enant er 3rawice Muccer of Items Welding MS-1-026-010-575K 1
l AF-1-026-005-533R 1
Inst. Rack cpl-EIPRLI-31 2
Dimensions AF-1-026-003-533R 1
MS-1-026-010-575K 1
l MS-1-025-009-R75K 1
CC-1-043-013-A43K 1
CC-1-234-700-C53R I
CC-1-238-004-C53R 1
CC-1-226-700-C53R 1
CS-1-43-20SA-001
-2 CS-1-564-706-433R 1
AF-1-035-037-Y33R 1
1 AF-1-035-034-Y33R' 1
MS-1-023-047-543K 1
y CC-1-Oll-034-A63K 1
General AF-1-103-036-553K 1
Worxmansnip Inst. Rack cpl-EIPRLI-31 1
1-FT-2458 1~
C1401C056-2
,.1 TOTAL ITEMS
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i The above are examcies icentified by the MRC inspectors wnere items i
were installed oy the craft to conditions other than those specified by the identified design documents, QC inscections had been ccmoleted, anc tne QC inscecters f ailed to identify these conditions. The inscec-icn report det. ails these findings, s
i This is a Severity Level !? Violation.
(Supplement II.0) (445/3426-l 02) i Corrective Actic_n, Sy=1ary In summary, the corrective actions that'have been taken are listed below.
(Note: Each item celow refers to the corresponding item as nemoered in 1
the Notice of Violation).
1.
MCR M8?-lC0470.was issued and suosecuently closed on Octocer 1, 1934. Disposition included the addition of the diagonal brace.
i 2.
NCR M84-lC0476 was issued and subsecuently closed en October 2, 1984 Disposition included the issuance of CMC 48850, Revision 2 which shows correct orientation.
3.
NCR M-14722 was issued and subsecuently closed on August 22, 1984. Disposition included installation of the two welds.
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9 The remaining twenty-two items have oeen addressed by revision to drawinos or Vencor Certifiec Drawings (VCD's), issuance ado disposition of noncenformance reports (NCR), correction tnrougn normal insoection process performance of an engineering evaluations or performance of an additional review that indicated no corrective action was required. Specifically the resolution of each itse is as follows:
Comconent or Drawing Resolution MS-1-026-010-575K Review indicates no corrective action recuired AF-1-026-005-533R-Review indicates 'no corrective action required b
Inst. Rack CP1-EIPRLI-31 NCR issued
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AF-1-026-003-533R Engineering evaluation indicates no corrective action required i
MS-1-026-010-575K NCR issued MS-1-025-009-R75K Drafting error, NCR issued CC-1-043-013-A43K Review indicates support was acceotable, however NCR issued and VCD revised CC-1-238-004-C53R NCR issueo CC-1-236-700-C53R 3 rafting error, NCR issueo CC-1-234-700-C53R Jrafting error, NCR issued CS-1-AB-208A-001 Review indicates support was acceptable, however MCR issued and VCD revised CS-1-564-706-A33R NCR issued ar.c VCD revised AF-1-035-037-Y33R NCR issued and VCD revised AF-1-035-034-Y33R NCR issued and VCD revised MS-1-028-047-543K NCR issued and VCD revised CC-1-011-034-A63K Review indicates support was acceptable, however NCR issued and VCD revised AF-1-103-035-553K Succort identification should be AF-1-103-025-553K, NCR issued Inst. Rack CPI-EIPRLI-31 NCR issued 1-FT-2458 Corrected during normal inspection process, see IR I-1-0054504 C14010045-2 NCR issued i
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