ML19325E122

Responds to NRC 890926 Ltr Re Violations Noted in Insp Repts 50-445/89-64 & 50-446/89-64.Corrective Actions:Craft Electrician,Welder & Foreman Responsible for Bypassed Hold Point Counseled Re Performance in Instance

ML19325E122
Person / Time
Site:	Comanche Peak
Issue date:	10/26/1989
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-89743, NUDOCS 8911020020
Download: ML19325E122 (5)

Text

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""l: Log # TXX 89743 [

.~ File # 10130 r = IR 50 445/89 64 IR ******I*"

nlELECTRIC Ref. # 10CFR2.201 i w J.c.hm October 26, 1989  !

Lnn unvr s kt l'resulent t

U. S. Nuclear Regulatory Commission I Attn: Document Control Desk I Washington, D. C. 20555

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SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) i DOCKET NOS. 502445 AND 50 446 NRC INSPECTION REPORT NOS. 50-445/89 64; 50 446/89 64 i RESPONSE TO NOTICE OF VIOLATION & NOTICE OF DEVIATION  !

Gentlemen  !

i TV Electric has reviewed the NRC's letter dated September 26, 1989, concerning j the inspection conducted by Mr. R. Latta and other NRC consultants during the j period August 2 through September 5. 1989. This inspection covered activities  ;

authorized by NRC Construction Permits CPPR 126 and CPPR-127 for CPSES Units 1  !

and 2. Attached to the NRC's letter were a Notice of Violation and a Notice i of Deviation. l TV Electric hereby responds to the Notice of Violation in Attachment A and to

. the Notice of Deviation in Attachment B to this letter, i i

Sincerely,  ;

William J. ahill, Jr. i DAR/WJH/yxs i Attachments l

c - Mr. R. D. Martin, R1gion IV '

1 Resident Inspectors, CPSES (3) f i

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} .i 8911020020 891026 l t PDR ADOCK 05000445 j ,

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400 North Ohve Street LB 81 Dallas Texas 73201 l

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Attachment A TXX 89743 Page 1 of 2  ;

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1 i NOTICE OF VIOLATION i (445/8964 V 01)

Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, (

Revision 1, of the TU Electric Quality Assulance Manual, requires that i activities affecting quality shall be prescribed by and accomplished in  !

accordance with documented instructions, procedures, or drawings.

Contrary to the above, on August 21. 1909. the NRC inspector observed that a ,

QC hold point had been bypassed prior to welding of the replacement tray I fittings as specified in the applicable work package T140 EDA 42 01.  ;

l RESPONSE TO NOTICE OF VIOLATION l;

(445/8964 V 01) i  :

TU Electric ac:epts the alleged violation and the requested information  !

follows:

1. D,1 son.for Violation

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The bypassed hold point identified by the NRC inspector resulted from f l errors by the craft persons involved. Based upon discussion with the ,

craft electrician responsible for lifting and protecting the cables, the l

l craft foreman believed that OC inspection of lifted cables had been performed. The foreman then assigned the work package to the craft welder  :

l and this individual did not verify that the inspection had been performed '

prior to welding. }

To determine the extent of errors involving bypassed hold points, Monthly  !

Integrated Performance Analysis reports containing the evaluation of  !

deficiency data trended from March to August 1989 were reviewed. These i reports are developed in accordance with the TU Electric OA procedure, j

" Quality Assurance Trend System." The review found'that in May 1989, TU l Electric identified a need for action to resolve a repetitive condition involving bypassed hold points. In response to this repetitive condition.  !

l TU Electric initiated corrective measures including supervisory and craft  !

retraining, improvements in the work process (i.e. multi discipline  !

j involvement), and improved documentation techniques for specifying hold

• points. Trend reports compiled and issued subsequent to these actions l indicated that the corrective measures taken have been effective, and that few instances similar to that identified by the NRC inspector have [

l occurred.  ;

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Attachment A to TXX 89743 ,

Page 2 of 2  ;

2. Corrective Steps Taken and Results Achieved A Nonconformance keport (NCR) was written on August 23, 1989, to document i the bypassed hold point. The hold point was established to obtain OC i inspection of cable lifting and protection prior to welding of replacement tray fittings on cable tray T140 EDA 42. This NCR has been dispositioned ,

"use as is" based on verification that no cable damage resulted from the  !

welding operations.

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3. Corrective SteDs Taken to Avoid Further Violations  !

The craf t electrician, the craft welder, and the craf t foreman responsible ;

for this bypassed hold point have been counseled regarding their performance in this instance. Copies of the employee " Conference Reports" .

are contained in the employees' personnel files. In addition, the  !

Electrical Craft Manager has issued a memorandum to all electrical craf t ,

employees (including electrical craft welders) reemphasizing the need to observe hold points established on work documents. To assure common ';

understanding of this memorandum, additional training of electrical craft personnel has been conducted.  ;

It should be noted that the few hold points bypassed following the I corrective measures taken in June, 1989, have been "in process" type hold points similar to the item identified by the NRC inspector. Upon work completion, construction and quality procedures require that the work ,

documents be reviewed to verify satisf actt:y completion, including the i results of required inspections. Deficiencies identified through this  !

review are documented in accordance with procedure requirements and ,

resolved prior to final acceptance of the work package. The review of i completed work documents is described in the TV Electric construction  ;

procedure. " Construction Documentation Preparation, Control and Review,"

and the TV Electric quality procedure, " Review of Work Process Control  !

Documents."

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4. Date of Full Como11ance E i

Based upon the additional training of Electrical Department personnel and the ongoing work document reviews described above, full compliance has l been achieved.

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Attachment B TXX 89743 Page 1 of 2 NOTICE OF DEVIATION (445/8964 0 02)

As stated in TV Electric's letter TXX 88294. dated March 25, 1988, the applicant committed to the replacement of the nonqualified Class IE. Unit 1 diesel generator wattneters with qualified components prior to Unit I hot functional testing.

Contrary to the above, the subject wattneters were installed after Unit I hot functional testing. This failure to adequately implement the corrective actions specified in the reference letter is identified as a deviation.

RESPONSE TO NOTICE OF DEVIATION (445/8964 D 02)

TU Electric accepts the alleged deviation and the requested information f ollows :

1. Reason for Deviation In TXX-88294. dated March 25. 1988 TV Electric committed to replace the Unit I diesel generator wattesters with Class 1E certified wattneters prior to Unit 1 Hot Functional Testing. This commitment was entered into the Licensing Commitment Resolution (LCR) database with a due date of December 28. 1988 which, at that time, was the scheduled start of Hot Functional Testing.

In the fall of 1988, when the new consolidated Commitment Tracking System (CTS) was developed to expand TU Electric's ability to track and monitor project commitments, the data in the LCR database was manually transcribed and entered into the new CTS database by the Nuclear Licensing Department.

The commitment regarding the wattneter installation was incorrectly entered with a completion milestone of " Fuel Load" rather than " Hot Functional Testing."

Neither the organization responsible for this commitment nor the Nuclear

/ l.icensing Department detected this error. As a result. TV Electric failed to recognize that the wattneter replacement was required prior to Hot Functional Testing and the work was not completed.

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l Attachment B to TXX 89743 Page' 2 of 2 i  !

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2. Corrective Steps Taken and Results Achieved (

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. The wattmeters were installed shortly after Hot Functional Testing. Upon  :

discovering that a commitment had not been completed on schedule, an  !

evaluation was made as to safety significance. A letter (TXX 89509 dated  ;

July 21,1989) was then issued to inform the NRC of the missed due date  :

and of the fact that the late installation of the wattneters was not

, safety significant. l t

3. Corrective Steos Taken to Avoid Further occurrences j

The organization responsible for the wattmeter installation has assigned i adequate resources to track and close open commitments, j In addition, independent of this event, in April 1989. TV Electric l initiated a series of steps to enhance the management and use of the CTS

• and to upgrade the quality of the CTS database. This corrective action is still in progress. ,

Corrective steps include: ,

o Executive Management has iss'Jed a letter to user organizations reinforcing the importance of the CTS as a management tool to

" increase the confidence in the completion of, and compliance with 6 regulatory commitments."  ;

o Corporate and departmental procedures regarding the use of the CTS have been enhanced to improve the effectiveness of the system. '

o Training has been conducted for management and user organizations regarding objectives and use of the CTS.

j o A review of the CTS database is in progress. This review is designed l to locate and correct inaccuracies.

! i I 4. Date for ComDietion of Corrective Action (

l For those actions not identified as complete above, the corrective action described in this response will be completed prior to fuel load.

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