TXX-6260, Interim Deficiency Rept CP-86-04 Re Placement of Inserts in Proximity of Loaded Embedded Plates & Design/Const Requirements for Min Separation of Welded Attachments to Embedded Strip Plates.Next Rept Expected by 870429
| ML20211C893 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/13/1987 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CP-86-04, CP-86-4, TXX-6260, NUDOCS 8702200254 | |
| Download: ML20211C893 (3) | |
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Log # TXX-6260
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File # 10110 903.8 7UELECTRIC Ref # 10CFR50.55(e)
Milliam G. ( mmsil 1:m sane i k e l*remient February 13, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 PR0XIMITY PLACEMENT - RICHMOND INSERTS TO EMBEDDED PLATES AND WELDED ATTACHMENTS TO EMBEDDED PLATES SDAR: CP-86-04 (INTERIM REPORT) i Gentlemen:
On January 13, 1986, we verbally notified your Mr. T. F. Westerman of a deficiency regarding the placement of Richmond inserts in the proximity of loaded embedded plates which could compromise the structural integrity of adjacent shear cones. Our last interim report was logged TXX-6031, dated October 20, 1986.
On June 5, 1986, we verbally notified your Mr. I. Barnes of a deficiency involving the design / construction requirements for minimum separation of welded attachments to embedded strip plates which were not 3roperly reflected in inspection procedures.
Previous responses to this item lave been reported under SDAR CP-86-44, " WELDED ATTACHMENTS TO EMBEDDED STRIP PLATES" under the provisions of 10CFR50.55(e). Our last interim report for SDAR CP-86-44 was logged TXX-6035, dated October 20, 1986.
The scope of SDAR CP-86-04 has been expanded to include evaluation of SDAR CP-86-44. All subsequent reports on these issues (SDAR CP-86-04 and SDAR CP-86-44) concerning reportability under the provisions of 10CFR50.55(o) will be reported via SDAR CP-86-04.
We have concluded that the deficiencies identified above are reportable under the provision of 10CFR50.55(e), and the required information follows:
DESCRIPTION OF PROBLEM A review of the issues has identified four deficiencies:
1.
Quality Instruction QI-QP-ll.23 2, " Inspection of Completed Installations for Separation / Spacing", and other discipline procedures, (i.e., QI-QP-11.10-1, " Inspection of Seismic Electrical Support and Restraint Systems",
QI-QP-ll.10-2, " Cable Tray Hanger Inspection", and QI-QP ll.8-5,
" Inspection of Instrument Tubing Fabrication, Installation and Instrument Installation"), do not require inspection to or in accordance with CCP-45/SS-30, " Permanent and Temporary Attachments to Embedded Wold Plates / Structural Embedments", for minimum separation requirements for welded attachments to embedded steel plates.
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TXX-6260 February 13, 1987 Page 2 of 3 2.
Prior to March 3,1986, design and installation documents did not identify minimum spacing criteria between loaded Richmond inserts and loaded embedded plates. The use of a Richmond insert in proximity to a loaded embedded plate could compromise the structural integrity of adjacent shear Cones.
3.
Existing design and installation documents do not adequately identify minimum spacing criteria between Hilti bolt installations and loaded embedded plates. The placement of a Hilti bolt in proximity to a loaded embedded plate could compromise the structural integrity of adjacent shear Cones.
4.
Existing quality instructions do not delineate the separation criteria between welded attachments to embedded plates and existing Hilti bolts.
Deficiencies 1 and 4 resulted because the Quality Control procedures governing the inspection of embedded plates were not developed in accordance with the requirements of CP-QP-6.0, " Preparation of Quality Procedures and Instructions".
Procedure CP-QP-6.0 states that the requirements of QC instructions and procedures be derived from engineering / construction requirements in design documents.
Deficiencies 2 and 3 were the result of inadequate engineering review of the design specification (2323-SS-30) and related construction / quality control procedures pertaining to embedded plates (i.e., CEI-20, " Field Installation of Hilti Bolts", CCP-45, QI-QP-11.10-1, QI-QP-11.10-2, QI-QP-11.8.5 and QI-QP-11.23-2).
SAFETY IMPLICATION The lack of proper acceptance criteria in the quality instructions and procedures could have resulted in unacceptable embedded plate, Richmond insert and/or Hilti bolt installations which may have adversely affected the safety of the plant during accident conditions.
Also the appropriate design criteria for spacing between loaded embedded plates and loaded Richmond inserts or Hilti bolts were not adequately specified in the applicable design documents.
These deficiencies represent a significant breakdown in the QA Program required by 10CFR50 Appendix B (Criteria 3 and 5).
CORRECTIVE ACTION To prevent recurrence of deficiencies I and 4, all personnel rasponsible for the development of quality control procedures for embedded plates will be reinstructed in the requirements of CP-QP-6.0.
To prevent recurrence of deficiencies 2 and 3, Engineering Assurance will be instructed to review and revise, if necessary, the appropriate engineering procedures to ensure proper engineering review of all revisions to existing and future design specifications and inter-disciplinary review of construction and quality control procedures.
TXX-6260 February 13, 1987 Page 3 of 3 As previously reported, the design specification and related construction / quality control procedures pertaining to embedded plates are being revised. The procedure revisions, scheduled for completion by late February, will ensure the proper control of attachments to embedded plates.
Quality Control Procedure QI-QP-11.14-13, " Separation Verification of Attachments to Loaded Embedded Plates", has been developed to address the inspection of attachments to embedded plates and spacing requirements for welded attachments, Hilti bolts, and loaded Richmond inserts. Unit 1 field verification efforts are scheduled to start in early March.
Non-conforming conditions identified by the field verification effort will be evaluated by engineering.
The schedule for the Unit 2 corrective and preventative actions will be provided in our next report.
We will submit our next report no later than April 29, 1987.
1 Very truly yours, 4%'
W. G. Counsil BSD:lw c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV l
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