TXX-6394, Responds to Request for Addl Info Re Notice of Violation Item D.1(50-446/8602-V-21) & Item E (50-446/8602-V-17) & Notice of Deficiency Item B (50-445/8603-D-18).Type 01- CSM-2a-II Conduit Supports Will Be Design Verified
| ML20215M468 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/06/1987 |
| From: | Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-6394, NUDOCS 8705130255 | |
| Download: ML20215M468 (7) | |
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1 Log # TXX-6394 File # 10130 IR 86-03
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IR 86-02 Ref # 10CFR2.201 7t# ELECTRIC wunoi c. c-.a May 6, 1987 Etnutiw & ke l>rsident U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT NOS. 50-445/8603 AND 50-446/8602 REQUEST FOR ADDITIONAL INFORMATION REGARDING NOV ITEMS D.1 AND E AND N0D ITEM B.
REF:
- 1) TUGC0 Letter TXX-6089 from W. G. Counsil to E. H. Johnson date January 12, 1987 Gentlemen:
s We hereby submit our response to your request for additional information regarding~NOV item D.1 (50-446/8602-V-21), NOV item E (50-446/8602-V-17) and N0D item B (50-445/8603-D-18).
Per a telephone conversation with Mr. I.
Barnes, an extension was requested and granted to May 8, 1987.
Please note on the attachment that our amended response is indicated by change bars in the right margin. Also, note that as a result of the corrective actions taken, the following dates of compliance have been revised: NOV item D.1, from March 15, 1987, to December 31, 1987; and NOV item E, from May 1987 for Unit 1 and September 1987 for Unit 2 to March 1988 for Unit I and July 1988 for Unit 2.
- 0ur position regarding N00, item B (445/8603-D-18) is being reevaluated.
Per a telecon with Mr. I. Barnes, we expect to reply to your request by June 9, 1987.
Very t uly yours, Md b W. G. Counsil 8705130255 870506
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By: /
G. S. Keeley
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c Manager,NuclearLignsing GLB/gj c - Mr. E. H. Johnson - Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV j
400 Enh Olise Street I..it 81 Dallas. lexas 75201
' Attachment-1 TXX-6394 April 21, 1987 Page 1 of 6 RE0 VEST FOR ADDITIONAL INFORMATION
-NOTICE OF VIOLATION.
ITEM D.1 (446/8602-V-21)
You did not address whether or not a review was, performed with respect to the support analysis (No. 01-CSM-2a-II on conduit No. C23G04066) to assure that the support capacity was considered.
Please provide us with this information.
NOTICE OF VIOLATION ITEM 0.1 (446/8602-V-21)
D.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, of the TUGC0 QAP, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings.
Contrary to the above, the following conditions were identified with respect to Unit 2 conduit supports in which the prescribed' activities were not accomplished:
1.
Section 2.4 in TUGC0 Procedure TNL-AB-CS-2, Revision 0, states, in part, "The Field Engineer shall prepare a field isometric indicating the general routing and location of supports, and...
shall include span lengths and configurations... decision points and locations.... Decision points are considered as places on a typical drawing for which two or more options are acceptable for the same location."
Independent inspection revealed a decision point which had not been included in the isometric drawing by the Field Engineer. One support was observed in which a 3/8" Hilti bolt had been installed. The applicable typical drawing specified a 1/2" Hilti bolt with the option of using-a 3/8" Hilti bolt provided the support capacity was reduced. The absence of this information could possible preclude the required reduction in support capacity by the Design Engineer.
AMENDED RESPONSE TO ITEM D.1 (446/8602-V-21) 1.
Reason for the Vioiation We admit to the alleged violation for the reasons that follow.
Due to an unclear note (No. 4) on drawing 2323-S2-0910, Sh. CSM-2a-II, Rev. 3, engineering walkdown failed to identify the 3/8" Hilti-Kwik Bolt (HKB) on the isometric drawing.
w LAttachment-jTXX-6394
- April-21, 1987
~Page.2 of_6-AMENDED RESPONSE TO ITEM D.1 (446/8602-V-21) CONT'D
- 2! Corrective Action Taken NCR M86-201023 was issued on April-1,1986, to identify the use of 3/8" HKBs in-type CSM-2a-II conduit supports for conduit sizes 2" S thru 5" #
and the need to verify conduit support and clamp capacities in such cases.
fIsometric drawing No.-2323-S2-0910, Sh. 04066, Sk. 01 was revised (Rev. 2)
~to show the 3/8" HKB for support No. 1 on April 16, 1986. The adequacy of the support in question (No. 01-CSM-2a-II on condition No. C23G04066) was
. verified on September 11, 1986; as documented by calculation No. 04066, Rev. O,- Sh. 6 of 11. Substitution of the 3/8" HKB reduced the design capacity of the support from 400 to 100 lbs. which is adequate for the actual load of 65 lbs.
3.
Action to Prevent Recurrence Note 4 on drawing 2323-S2-0910, Sh. CSM-2a-II was revised (Rev. 5) on November 6,1986, to state, in part, ".. 3/8" Hilti-Kwik bolt may be used for 2" diameter thru 5" diameter conduit only where specified on the isometric or individual support drawing. All Unit 2 conduit supports indicated on isometric ~ drawings as type CSM-2a-II for conduit sizes 2" J thru 5" # HKBs will be design verified assuming 3/8" HKBs were installed.
for the CSM-2a-II type supports. This applies to all isometric drawings with Rev. O issued prior to November 6,.1986.
For those drawings issued
-after this date, note 4 on drawing 2323-S2-0910, Sh. CSM-2a-II, Rev. 5, applies. Additional evaluation is not required. NCR M86-201023 was converted to NCR-87-3742 on March 18, 1987.
4.
D3_te When Full Comoliance Will Be Achieved Full compliance will be achieved when the design verification effort has been completed and NCR-87-3742 closed. This is expected by December 31, 1987.
1 1 Attachment 4
TXX-6394' April 21, 1987
'Page 3 of 6:
. REQUEST FOR ADDITIONAL INFORMATION NOTICE OF VIOLATION ITEM E (446/8602-V-17)
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It wasDidentified that~ subsequent to our 1etter dated January 12, 1987,
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additional HVAC organization realignment occurred. This action affects your i
response provided in Item E of paragraph 3., " Action to Prevent Recurrence."
Please provide the changes caused by this realignment with respect to the Unit 2 HVAC support field verification program.
ITEM E (446/8602-V-17).
E.
Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section
'10.0, Revision 1, dated July 31, 1984, of the TUGC0 QAP, states,'in part, "A program for inspection of activities affecting quality shall be i
established and executed...to verify conformcnce with the documented instructions, procedures, and drawings for accomplishing the activity."
Contrary to the.above, the.following examples from Unit 2 HVAC duct support inspections were observed where the Bahnson inspection program
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failed to identify nonconformances with the documented instructions, procedures, and drawings:
1.
Section 9.1 in Revision 1 of Bahnson Procedure WP-TUSI-001 states, in part, with respect to intermittent welds, " Weld increments shall begin and terminate within 1/8" of the ends of the joints or length....."Seven HVAC duct supports, however,-inspected by the NRC had intermittent fillet welds which did not begin or terminate within 1/8" of the ends of the joints.
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2.
Section 6.5 in' Revision 5 of Bahnson Procedure QCI-CPSES-011 states, in part, with respect to welding, "The Quality i
Representative shall make certain that. the size, length, and location of all welds conform to the requirements of QCI-CPSES-014 i
and DFP-TUSI-003, and to the detailed drawing...."
Independent inspection identified the following conditions in l
three HVAC duct supports:
a.
A 2" long, 1/4" fillet weld required by the drawing was measured as being 1/8" for the full i
length.
5-b.
Two, 2-1/2" long, 1/8" fillet welds required by the drawing between the two lateral braces and the j.
main support were missing.
l c.
Two, 1-1/2" long, 1/8" fillet welds required by l
the drawing were measured as being 1-1/4" long.
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Attachment TXX-6394 April 21, 1987 Page 4 of 6 ITEM E (446/8602-V-171 3.
Section 6.6 in Revision 5 of Bahnson Procedure QCI-CPSES-Oll states, in part, " Weld profiles shall meet the following requirements:
The faces of fillet welds may be slightly convex, flat, or slightly concave... Welds shall' be visually examined to determine if the following defects are evident:
Undercut shall not exceed 1/32" for materials thicker than 1/4"."
One support was identified in which two welds exhibited 1/16" undercut for 50 percent of the weld lengths on members which were 1/2" thick. The support also had a 1/4" and a 3/8" weld in which grinding of the weld produced excess convexity, resulting in an unacceptable weld profile.
4.
Note 2 in Attach 4 of Revision 10 to Bahnson DFP-TUSI-004 states, in part, "Where the embedded steel plates are occupied by attachments within the minimum distance shown above (12"), the minimum clearance from 1" Hilti anchors to...the edge of the embedded plate and only 3/8" from the edge.
AMENDED RESPONSE TO ITEM E (446/8602-V-17) 1.
Reason For The Violation We admit to the alleged violation for the reasons that follow.
Our review indicates the violation occurred as a result of inadequate implementation of procedures on the part of the HVAC contractor charged with the responsibility for design, fabrication, and QC activities.
2.
Corrective Action Taken For each specific discrepancy noted in the Violation, a nonconformance report (NCR) or Deficiency and Disposition Report (DDR) has been issued for evaluation and disposition.
Note, as indicated in paragraph 3, the engineering responsibility for this area has been reassigned. DDRs are the technical nonconformance documents used by the current responsible architect / engineering contractor.
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Attachment"
- .. TXX-6394 April 21,- 1987
- Page 5 of 6
' AMENDED RESPONSE TO ITEM E (446/8602-V-17) CONT'D 3.
Action To Prevent Recurrence In order to correct the conditions noted in this violation the following corrective measures are being implemented:
a.
The project organization and. responsibilities for all HVAC activities have been realigned.
Bahnson has been relieved of all responsibility for engineering, construction, and quality control activities at CPSES.
Ebasco has assumed responsibility for all HVAC systems engineering ^and design activities. 'Daniels Construction Company and TU Electric have assumed responsibility for construction and quality control activities respectively.
b.
Field verification efforts include all Unit I and Common Seismic Category I duct supports.
c.
Engineering evaluations will be performed to ensure compliance with FSAR commitments.
d.
Construction rework will be performed, as deemed necessary, by the engineering evaluations of field verified information to assure compliance with FSAR criteria for the affected supports.
e.
To assure Unit 2 installations comply with prescribed requirements. Unit 2 HVAC-supports will be field verified. The as-built effort will be conducted by Ebasco, with QC verification by TU Electric. Ebasco has been given responsibility for the 1-adequacy of the as-built verification effort and design.
All discrepancies will be documented by Nonconformance Reports.
4.
Date When Full Como11ance Will Be Achieved The procedure revisions and retraining were completed December 31, 1986, except for those affected by the recent assignment of Daniels.
These changes in program responsibilities will delay completion of the corrective action program for Unit I and Common HVAC until March 1988 and until July 1988 for Unit 2.
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,*.iAttachment-TXX-6394 April 21,=1987-Page 6 of 6 REQUEST'FOR ADDITIONAL INFORMATION NOTICE OF DEVIATION ITEM B (445/8603-D-18 For_ N00, Item 8, base material defect-inspection was not identified as an attribute to be excluded as is required by ERC CPP-007. Your response that accurate reinspection cannot be performed following application of coatings is not consistent with your position regarding inspection for weld defects through paint.
Inspection of welds in the coated condition and after removal of the coating was successfully~ demonstrated by ERC using QI-062. The observed condition became acceptable in accordance with QI-QAP-11.1-28 only after the issuance of DCA-41710 which clarified acceptance criteria..Therefore, please respond to the deviation as originally requested.
s NOTICE OF DEVIATION ITEM B (445/8603-D-18) 8.
Paragraph 5.1 of ERC Procedure CPP-007, Revision 2 states, in part,
" Responsible QA/QC discipline engineers review the latest... Brown &
Root... documents relating to the population. Subsequently, the engineer develops a list of safety significant attributes that are common to the population and which can be reinspected...."
Paragraph 3.4.4.3 in Brown & Root, Inc. Instruction QI-QAP-11.1-28, Revision 31, identifies requirements for base material inspection and states, in part, "The depression depth produced by grinding shall not exceed... 'l/32" for material less than 3/8" thick (structural shapes)."
In deviation from the above, the responsible QA/QC discipline engineer failed to identify and incorporate into ERC QI-029 this base material inspection attribute. As a result, ERC inspection of Verification Package No. I-S-LBSN-065 failed to identify that grinding on base material in excess of 1/32"' existed on item 3 of pipe support MK No. CT-1-008-001-S22S.
AMENDED RESPONSE TO ITEM B (4445/8603-D-18)
.1.
Reason for the Deviation This issue is being reevaluated. We expect to transmit our reply to your request by June 9, 1987.