ML20238D419

Notice of Violation from Insp on 871104-1201.Violation Noted:Walkdown Engineer Failed to Record One Dimension Required to Fully Locate Structural Tubing on Base Plate

ML20238D419
Person / Time
Site:	Comanche Peak
Issue date:	12/18/1987
From:	Warnick R NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20238D401	List: IR 05000445/1987031 IR 07100104/2012001 ML20238D398 ML20238D419
References
50-445-87-31, 50-446-87-23, NUDOCS 8801040250
Download: ML20238D419 (3)

Text

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APPENDIX A NOTICE OF VIOLATION I

TU Electric Dockets: 50-445/87-31 50-446/87-23 Comanche Peak Steam Electric Station Permits: CPPR-126 I Units 1 and 2, Glen Rose, Texas CPPR-127 I

I During an NRC inspection conducted on November 4 through December 1, 1987, violations of NRC requirements were identified.

In accordance with the " General Statement of Policy and Procedure f or NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violations are listed below:

A. 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), states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, or a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. . . . "

Section 7.7.1 of Revision 2 to EBASCO's Field Verification Method (FVM) 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." Further, paragraph N states that the walkdown engineer will redline ". . . any HKB/HSKB spacing violation per Table 2."

Contrary to the above, the following conditions were identified:

1. For support C13OO7808-04, which is a 2323-S-0910 Type CA-la support, the anchor bolts identified as bolts A, E, and F were lined out. This implied that anchor bolts did not exist at these locations for'this unique support. During a subsequent walkdown by the NRC inspector, however, an anchor bolt was found to exist at the location designated for anchor bolt A. This bolt was determined to be a 1/4" Hilti Kwik bolt with the letter designation "D" and a projection of 1". While the 8801040250 871218

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xistence of this additional anchor bolt Mill not have a detrimental effect on the structural integrity of the support, the fact that it was not identified during the EBASCO walkdown is of significance relative to the-adequacy of the walkdown itself.

2. On support C14G21398-03 the walkdown engineer failed to record one of the dimensions required to fully locate the structural tubing on the base plate. This information is required in order to calculate base plate stress and anchor bolt loads. This dimension is one of the dimensions required to be reported for this type of l support (2323-S-0910 sh. CSM-18 type support).

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3. On support C14B13125-02, Lie walkdown engineer. failed to note a spacing violation between the 1/4" Hilti Kwik bolt designated as Bolt F on the support in question, and a 3/8" HKB on an adjacent conduit support. The NRC inspector found these anchor bolts to be 2 1/4" apart; j while the FVM required a spacing of at least 3 1/8".

This is a Severity Level V violation (Supplement II)

(445/8731-V-01). -

B. Criterion XVI of Appendix B to 10 CFR Part 50, as implemented by Section 16.0, Revision 0, of the TU Electric QAP, states, in part, " Measures shall be established to assure that-conditions adverse to quality . . . are promptly identified and corrected . . . and corrective action taken to preclude repetition." .!

l Nuclear Engineering and Operation Procedure NEO 3.06,

" Reporting and Control of Deficiencies," requires deficiencies (principally programmatic and not directly related to hardware i problems) to be identified,'the cause established, and action  !

, taken to prevent repetition. I' 1

Contrary to the above, the " rework" dispositions of NCRs I-85-101890SX and C-86-200378X were incorrectly revised to "Use-As-Is" dispositions, subsequent to engineering becoming aware that the conditions which created the need for the NCRs had been corrected outside of the scope and control of the NCRs. By revising the dispositions and closing out the NCRs, actions were not taken to determine the cause of the deficiency (uncontrolled work) or to prevent repetition.

This is a Severity Level IV violation (supplement II)

(445/8731-V-02; 446/8723-V-01).

Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby '

required to submit a written statement or explanation to the U. S.

Nuclear Regulatory Commission, ATTN: Document Control Desk,

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Washington, DC 20555 with a copy to the Assistant Director for Inspection Programs, Comanche Peak Project Division, Office of Special Projects, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a

" Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation if admitted, (2) the <

corrective steps that have been taken and the results achieved, (3) the corrective ateps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

If an adequate reply is not received within the time specified in ,

this Notice, an order may be issued to show cause why the license l should not be modified, suspended, or revoked er why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown.

J FOR THE NUCLEAR REGULATORY COMMISSION l

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Dated at Comanche Peak Site this 18th day of December 1987 l

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