TXX-6440, Submits Revised Response to Violations Noted in Insp Rept 50-445/84-16.Corrective Actions:Stated Nonconformance Repts, Including M84-01836,issued to Document Specific Examples of Nonconformances Identified
| ML20215L532 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/08/1987 |
| From: | Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-6440, NUDOCS 8705120275 | |
| Download: ML20215L532 (4) | |
Text
._____- -_
d s
~
Log # TXX-6440 File # 10130
=M IR 84-16 5
Ref # 10CFR2.201
=
=
1UELECTRIC May 8, 1987 w n. c. nwi Lmuttw 6 h e l'traknt U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NO. 50-445 INSPECTION REPORT NO. 50-445/84-16 REVISED RESPONSE AND DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION ITEM A (445/8416-V-01)
REF:
- 1) TUGC0 letter TXX-4346 from B.R. Clements to R.L. Bangart dated November 1, 1984.
- 2) TUGC0 letter TXX-4369 from B.R. Clements to R.L. Bangart dated November 28, 1984.
- 3) TUGC0 letter TXX-4393 from B.R. Clements to R.L. Bangart dated January 14, 1985.
Gentlemen:
In pursuing the corrective actions as delineated in our referenced responses to NOV 445/8416-V-01, we have determined that a revision to our responses is required. We hereby submit our revised response in the attachment to this letter. The original Notice of Violation has also been included to aid in understanding our revised response.
Our stated corrective action has been expanded substantially and has taken longer than originally anticipated.
It was previously expected that all inspections of CTHs and final analysis results would be completed and available by February, 1985. Currently, the Date of Full Compliance for implementation of the required modifications and rework to the Unit 1 CTHs is scheduled to be completed by August 1,1987 and completion of the Unit 2 CTH program by December 27, 1987. Accordingly, the attached amended response is submitted.
Very t uly yours, Y
8705120275 870508 W. G. Co il PDR ADOCK 05000445
/
G PDR By* d.
,m Man ger 1
g Attachment c - Mr. E. H. Johnson - Region IV
- f Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV
- M) Nor1h Olne Mrect t It M1 Dallas. Iem 75201
Attachment to TXX-6440 May 8, 1987 Page 1 of 3 NOTICE OF VIOLATION ITEM A (445/8416-V-01)
A.
Failure to Prooerly_ inspect Cable Trav Hanaers (CTHs) 10 CFR Part 50, Appendix B, Criterion X requires that the inspection program of activities affecting quality shall be established and conducted in a manner to verify conformance with the documented instructions, procedures, and drawings.
Procedure QI-QP-11.10-2, Rev. 27, " Cable Tray Hanger Inspection",
specifies the inspection attributes for inspecting assembly, configuration, base plate grouting, welding, etc., for conformance with design drawings and documents.
Contrary to the above:
1.
The NRC inspectors identified two cases where three supports shared common clip angle attachments to the concrete wall.
CTHs 6503, 6504, and 6505 shared a common clip angle that was not called for on Drawing 2323-S-903, Detail D for Case SP4 or on Component Modification Card (CMC) 11097. CTHs 6576, 6577, and 6578 shared common clip angles that were not called for on Drawing 2323-S-903, Detail D for SP4.
2.
The NRC inspectors identified two hangers where the dimensions did not agree with the drawings.
CTHs 6632 and 6638 both have installed dimensions that are more than the 1/4 inch allowed tolerance from those specified in the appropriate design documents. The dimensional errors are specifically documented on Nonconformance Report M84-01834.
The dimensional errors of the members varied from 7/8 of an inch to 1-1/8 of an inch shorter than those shown on the FSE-00159 drawing.
3.
The NRC inspectors identified two cable tray hangers that did not have the weld configuration specified on the design drawings.
CTH 6642 and CTH 6645 both had horizontal welds at the clip angle to support connection and the design drawings specified vertical welds.
4.
The NRC inspectors identified five cable tray hangers that had wall / floor connections that did not conform to those specified by the design drawings.
CTH 6657 had a beveled washer that was improperly installed so that it actually decreased the bearing surface between the nut and the clip angle.
CTH 5519 did not have 1 inch of grout under base plate as specified on Drawing 2323-S-913, Detail 6.
CTHs 5491, 5498 and 5499 had clip angles that utilized a combination of welding to embed plates and Hilti bolts for the wall or beam attachment for which there was no detail.
Attachment to TXX-6440 May 8, 1987 Page 2 of 3 The above are examples identified by the NRC inspectors where cable tray hangers were installed by the craft to condition other than those specified by the identified design documents and the QC inspectors failed to identify and document these conditions.
(445/8416-V-01)
REVISED RESPONSE TO ITEM A (445/8416-V-01)
We admit to the Violation and the requested information follows.
1.
Reason for Violation The design drawings used for the installation and QC inspection of the Unit I cable tray hangers did not provide sufficient detail which resulted in improper field installation and inadequate inspection.
2.
Corrective Steos Taken and Results Achieved NCRs M84-01834, M84-01835, and M84-01836 were issued to document the specific examples of nonconformances identified in the Notice of Violation (NOV).
Of the fifteen cable tray hangers (CTHs) identified, twelve were dispositioned "use-as-is" and three required " rework".
To address the generic implications of the issues raised in the NOV, an evaluation of the Unit 1 CTHs was initiated in early November 1984. The evaluation consisted of reinspection and design verification of a sample of 451 Unit 1 CTHs utilizing single as-designed composite drawings for each CTH.
By early June 1985 the results indicated the need to expand the program. The expanded program was subsequently incorporated into the CPRT program (Action Plan VIII).
By July 1985 the sampling approach was abandoned in favor of a reinspection program for both units.
In November 1985 a site Corrective Action Request (CAR-053) was issued to document programmatic concerns identified by the NRC (Ref:
IE Report 50/445-8519).
A Significant Deficiency Analysis Report (SDAR: CP-85-52) was subsequently issued on the CTH reverification program referencing CAR-053 as the appropriate corrective action mechanism.
Disposition of CAR-053 required another complete reinspection of the Unit 1 CTHs with revised engineering and QC inspection procedures, but did not affect the Unit 2 program. The procedures were revised to separate the engineering activities from QC activities providing assurance that information obtained for as-built conditions were independently reviewed.
After CAR-053 was issued, Unit 1 CTHs field verification was performed by Engineering personnel in accordance with procedure TNE-FVM-CS-001, " Unit 1 Cable Tray Hanger As-Builting and Design Adequacy Verification Program".
Reinspection by Quality Control was performed in accordance with procedure QI-QP-ll.10-9, " Modification, Rework, and As-Built Inspection / Verification Cable Tray Hangers in Unit 1".
The walkdown, as-builting, and reinspection of all Unit 1 CTHs has been completed.
Final design verification of the Unit 1 CTHs has been completed for about 75 percent of the hangers.
Attachment to TXX-6440 May 8, 1987 Page 3 of 3 REVISED RESPONSE TO ITEM A (445/8416-V-01) CONT'D Preliminary analyses indicate that approximately 550 hangers will require modification to bring them into compliance with design requirements.
In addition to these modifications caused by inadequacies in design of the existing hangers, approximately 85 percent of the hangers have been determined to require some amount of rework to bring them in compliance with specification requirements.
For Unit 2 CTHs field verification was con (;::ted by Engineering in accordance with TNE-FVM-CS-003, " Unit 2 Cab a Tray Hanger As-Builting and Design Adequacy Verification Program" and the earlier revision, TNE-AB-CS-003 " Cable Tray Hanger As-Designed and As-Built Drawing Development".
Reinspection by Quality Control is being conducted in accordance with QI-QP-11.10-2A, " Inspection of Unit II Cable Tray Supports". The walkdown and as-builting of all of the installed Unit 2 CTHs has been completed.
Final design verification for the Unit 2 CTHs precedes QC inspection, so any required modification is implemented prior to QC inspection and acceptance. Approximately 70 percent of the Unit 2 CTHs have been QC inspected and accepted.
3.
Corrective Steos Which Will be Taken to Avoid Further Violations New CTH design criteria were developed by Ebasco/Impell to supersede those criteria used by G&H in the original design of the cable tray hangers.
These criteria were formalized and issued in design procedures SAG-CP-4,
" Seismic Design Criteria for Cable Tray Hangers (Unit No. 1)", SAG-CP-3,
" Seismic Design Criteria for Cable Tray Hangers (Unit No. 2)", and Impell Report No. 01-0210-1462, " Design Criteria and Methodology for CPSES 1 -
Cable Trays and Supports".
General instructions for the implementation of these design criteria were issued by Ebasco under cover letter SAG-TUG-23456 and by Impell under numerous specific project instructions.
B&R Construction Installation Procedures ECP-10 and ECP-10A were revised to reflect the new CTH design requirements. Quality Inspection Procedures QI-QP-ll.10-9 and QI-QP-II.10-2A were similarly revised. Appropriate personnel were trained and/or certified.
4.
Date of Full ComDlianqq Implementation of the required modifications and rework to the Unit 1 CTHs is scheduled to be completed by August 1, 1987. Completion of the Unit 2 CTH program has been scheduled for December 27, 1987.
_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.