ML20149J632

Notice of Violation from Insp on 871202-880105.Violation Noted:Failure to Note Absence of Washers Under Hex Nuts on Hilti Kwik Bolts,Incorrect Measurement of Support Baseplate, & Correction Made to Procedure CHV-106 W/O Formal Rev

ML20149J632
Person / Time
Site:	Comanche Peak
Issue date:	02/12/1988
From:	Warnick R NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20149J607	List: ML20149J605 ML20149J632 ML20149J659 ML20149J722
References
50-445-87-35, 50-446-87-26, NUDOCS 8802230151
Download: ML20149J632 (3)

Text

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. i L APPENDIX'A l

NOTICE OF VIOLATION ,

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! TU Electric Dockets: S0-44S/87-35 4

50-446/87-26 7 i

Comanche Peak Steam Electric Station Permits: CPPR-126 '

Units 1 and 2,. Glen Rose, Texa,s CPPR-127 i ,, .

l During an NRC inspection conducted on December 2,-1?,37, through l l January 5, 1988, violations of NRC requirements were identified.

, In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the  !

l violation is listed below: 4  :

N Criterion V of Appendix B to 10 CFR Part 50, as implemented.by '

Section 5.0, Revision 3, of the TU Electric Quality Assurance Plan (QAP), requires that activities affecting quality shall be  !

prescribed by and accomplished in accordance with documented  !

instructions, procedures, or drawings. j

! Section 7.7.1 of Revision 2 of Ebasco's'Fiel'd Verification Method 1 tFVM) CPE-EB-FVM-CS-033, states, in part, "The Walkdown Engineer

will identify each type of support by comparison with Supplement I and/or 2323-S-0910 sketches or drawings, and will as-built the support on the applicable sketch or, drawing . . . . " Paragraph K of this section of the FVM further states, "All dimensions and/or  ;

, attributes shown will be verified . . . . If the designed dimensions / attributes are incorrect they shall be lined out and the actual dimension / attribute recorded." Also, Section 13.1, of this -W FVM further states, "Deficiencies identified in conjunction with i j

t~ne implementation of this procedure shall be_ documented on a '

Nonconformance Report (NCR) . . . . Examples of deficiencies are:

. . . D. Missing washers on Hilti Bolts . . . . "

Comanche PeAX Engineering Procedure CPE-EB-FVM-CS-029, "Procedure 1

For Seismic HVAC Duct and Duct Hanger As-Built Verification in Unit 1 and Common Areas," Revision 5 dated September 21, 1987,

)l requires that welding shall be identified for type of weld (fillet, j flare bevel, groove, etc.), weld length, and weld size.

2 i Comanche Peak Engineering Specification 2323-MS-85, Revision'5 dated September 15, 1987, Appendix r., paragraph 4.6, requires that  ;

j a galvanized coating shall be applied to. areas where galvanizing i has been removed due to welding or other fabrication / installation  !

i operations.  !

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a Engineering and Construction Procedure ECC 1.04, "Preparation, Issuance,.and control of Construction Department Procedures and

' Instructions," Revision 0 dated August 27, 1967, requires that any l change to controlled construction procedures be made by formally j revising the existing procedure, r

contrary to the above, the following conditions were identified:  !

1. On Conduit Support C13G04860-02, the walkdown engineer failed I .

to note that there were no washers installed under the hex l l nuts on the Hilti Kwik bolts. Because of this, there was no I i- NCR written to correct the situation as required by the TVM. , I l

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2. For Conduit Support C14G20243-01, the walkdown_ engineer l reported the length of the support baseplate to be 9-7/8". '

The NRC inspector measured this dimension'to be 9 1/2".

3. Conduit Support C14G11447-03, a No. 2323-S-0910 Type 1A support utilizing P5000 Unistrut members with one main member and three outriggers, supports two 3/4" conduits. For'tWe westernmost end of the main Unistrut member to the centerline of the west conduit, the walkdown engineer reported this dimension to be 5 1/8" and the NRC inspector measured this  ;

dimension to be 5 7/8". For the center outrigger, the l l

walkdown engineer reported 7 1/8" and the NRC inspector i l measured this dimension to be 8 5/8". For the easternmost i outrigger, the walkdown engineer reported it to be located- '

15/16" from the end of the main Unistrut member and the NRC inspector measured this dimension to be 1 1/4".

4. For Conduit Support C14G11447-04, the dimension locating the center outrigger was reported by the walkdown engineer to be 6 5/8" from the westernmost end of the main Unistrut member.

The NRC inspector measured this distance to be 7 1/2".

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5. On Conduit Support C14G11447-14, the walkdown engineer reported a total of eight Hilti. Kwik bolts (HKBs) - two 1/4" i HKBs in each of the three outriggers and two 3/8" HKBs in the  ;

main Unistrut member. The NRC inspector noted that there were l actually nine HKBs (there were three 3/8" HKBs in the main '

Unistrut member and not two as reported).

6. A fillet weld 3/16" x 5/8" long, which exists at the location identified by note 3 on seismic duct hanger Drawing DH-1-844-1K-4F, Revision 1, was incorrectly identified by engineering personnel during the Post Construction Sardware Validation Program as a tack weld.

7. Five finished welds located on seismic Duct Hanger DH-1-844-1K-WP13 and portions of three welds located ons i --. .-

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-.. s selwmic duct hanger Drawing DH-1-844-IK-lE did not hava the required galvanized coating.

8. Admintstrative and technical informacien corrections were @cdm to figure 7.6 of Constraction Proceduro CRV-106, RevAsion 1, a form used to document the results of an angineering qualitative walkdown of Duct segment 3-1~658-016 withon.t performing a farmal revision to the prouadure.

This is a. severity Loval IV violation (Supplament II?

(445/8735-V-02).

I Pursuant to the' provisions of 10 CFR 2.201,.TU'E}cetric is herehr .

required to submit a writteh statement or explanatic'c to the C. 8.

Nuclear Regulatcry Commission, ATTN: Document Control Cook,. . .

Washington, DC 20555 with a copy to'the Assistant Dir@ctor for Inspection Programs, Comanche Desk Project Division, Offico of Special Projects, within 30 days of the date of the ltitter transmitting this Notice. This reply should be clearly marked et a "Reply to a Notice of Violation" and should include for cach violation: (1) the reason for the violation if admitted, 12s th0 corrective steps that have heen taken and the results achieved, (3) ~the corrective steps that will be taken to avoid furtneR violations, and (4) the date when full compliance will.bc achieved.

If an adequate reply is not received within the time specified in this Notice, an order may be issued no show cause why the license should not be modified, suspbnded, or revoked or why such other action as may be proper should not be taken. Considaratien nay be given to extending the response time for good cause shoun.

FOR TE3 enEEAR' REGULATORY COMMIILSTCN i

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Dated at Comanche Peak Site l this 12th day of February 1988

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