ML20005E275
| ML20005E275 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/21/1989 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Charemagne Grimes Office of Nuclear Reactor Regulation |
| References | |
| TXX-89851, NUDOCS 9001040196 | |
| Download: ML20005E275 (17) | |
Text
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i Log # TXX 89851 l
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File # 10086 i
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nlELECTRIC I
December 21, 1989 wnu c.cm.n Mr. Christopher. Grimes, Director l
Office of Special Projects Comanche Peak Project Division i
Office of Nuclear Reactor Regulation l
United States Nuclear Regulatory Commission
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Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50 445 AND 60 446 FESPONSE TO CASE DOCUMENTED REQUEST FOR ACTION - THERMO-LAG
Dear Mr. Grimes:
Texas Utilities Electric Company (TV Electric) hereby responds to CASE's l
November 29, 1989 Documented Request for Action concerning THERMO LAG.
For
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the reasons stated below and in the Attachments hereto, the Request for Action r
should be denied.,
TV Electric's investigations of the subject events are documented in Attachments A and B.
Attachment C provides TV Electric's response to twelve questions that CASE posed to TV Electric concerning the subject dispute. TV Electric's specific responses to CASE's Attachment 2. Sequence of Events and Preliminary Findings, are set forth in Attachment D hereto, i
TV Electric's positions concerning CASE's allegations are summarized as follows:
1.
CASE's A11eaations of Harassment and intimidation While the OC Level III inspector did make a statement on November 2 to the effect that "we will not write an NCR on THERMO-LAG." the investigation shows that the OC Level Ill inspector and OC Supervisor were not attempting to harass and intimidate the OC inspectors to prevent them from documenting the fact that the THERMO-LAG conduit sections were undersized.
OC Supervision maintained that the applicable procedures allowed the 3
material to be marked "Unsat" on an Inspection Report and placed on hold pending issuance of a DCA from engineering. However, OC Supervision did
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TXX 89851 Page 2 of 5 t
not effectively explain their interpretation of the applicable procedure to the OC inspectors.1 On the next day, the OC Supervisor was shown the procedure that the OC inspectors believed to be applicable, and af ter 3
review, agreed that an NCR could be appropriate for the conduit THERMO LAG section.
In order to assure that TV Electric's policies are clearly understood, and that OC Supervision's directions about not writing NCR's on THERMO LAG could not be misconstrued and extrapolated by 00 receiving inspectors in the future. TU Electric undertook three additional actions.
A meeting was held between all QC receiving inspectors and OC management to assure that the inspectors had a complete understanding of applicable procedures.
In particular, OC managements a) reinforced the requirements for proper documentation of nonconforming conditions; b) explained the intent of the procedure initially relied upon by OC Supervision during the November 2 i
events; and c) reviewed the other options available to resolve receiving inspection problems. OC management emphasized TU Electric's policy that there should be no improper restraints on OC inspectors in regard to documentation *:f non conforming conditions.
Corporate Security interviewed the OC receiving inspectors in the area or present during the time that OC Supervision made the remarks concerning the NCRs to determine whether they felt intimidated or restrained from writing NCRs by virtue of the November 2 event or otherwise by virtue of CpSES policies and practices.
These interviews showed no evidence of any such intimidation or restraint, rinally. 0A/0C Management took action to prevent recurrence of the ineffective communication manifested by 0C Supervision and the Level 111 inspector in connection with the November 2 event by counseling both of the individuals on the importance and expectation of clear communications.2 1The Level III inspector has been counseled because of the ineffective communication and supervisory skills that he manifested.
However, there is no evidence supporting CASE's allegation that he lacked " professional commitment to the highest quality standards" (Request for Action, page 3).
His interpretation of the applicable procedure was valid; but even if it was mistaken, his direction would still have resulted in documenting the unsatisf actory status of the material and its being placed on hold.
- Moreover, there is nothing improper in utilizing an option, permitted by the procedure, that takes into account the pendency of an engineering decision.
l 2TU Electric does not agree with CASE's apparent view that the circumstances relating to the November 2 event raise the concern that "TU management is not effectively communicating with site management as to the proper method of handling disputes involving the identification of non conforming conditions" (Request for Action, page 3).
Admittedly, the i
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p TXX 89851 t
Page 3 of 5 t
On the basis of the foregoing, TV Electric submits that management has exercised its discretion to take actions that are reasonable and appropriate for the facts and circumstances of the November 2 event.
No further action by either TV Electric or NRC is warranted 3 and CASE's-Request for Action in regard to harassment and intimidation should be denied.
2.
CASE's A11eaation of Retaliatory Layoff and Demotion CASE alleges that as a result of their actions in proposing to document undersized THERHO LAG conduit sections on an NCR, Inspector A was laid off, and Inspector C was demoted from OC receiving inspector to " helper" (with no change in pay status).
The decision to lay off inspector A was made without knowledge of the alleged harassment.
In addition, neither the Level III inspector nor OC Supervisor had any input into the layoff decision.
The layoff decision was made by the 0C manager on the basis of established criteria (i.e., seniority, pay rate, and performance), using a list that identified the individuals involved by social security number, l
seniority, pay rate and performance evaluation, but not by name. There is I
simply no evidence to support a claim that Inspector A's layoff was in any way related to the alleged acts of harassment on November 2.4 TU Electric's investigation indicated that Inspector C was not demoted.
On the basis of the foregoing, TV Electric submits that there was no retaliatory action that affected the employment status of either
(.
Level 111 inspector and OC Supervisor did not handle this particular dispute appropriately; and they have been counseled.
However, there is no information supporting the notion that this isolated event was caused by a lack of l
effective communication between TV Electric management and site management.
3 CASE's Request for Action indicates that TV Electric's preliminary l
November 16, 1989 response included no discussion of CASE's allegation that the Level III Inspector requested that the acceptance specifications for the t
l material be changed. TV Electric's November 16, 1989 response did not discuss l
this allegation since this portion of the investigation was not then complete.
Subsequently, it was determined that there was no evidence to support the allegation.
(See Attachment A, page 2: Attachment C, answers 5, 6, and 9).
1 l-4 Independent of this, the Level III Inspector recently received a l
reprimand for an inappropriate and unprofessional remark made some 2 months l
before the subject events to Inspector A.
I TXX-89851 Page 4 of 5 j
Inspectors A or C.
Accordingly, no further action by either TU Electric or NRCS is warranted and CASE's Request for Action in regard to retaliatory action should be denied.
3.
CASE's A11eaations of a OA/0C Breakdown for Vendor Fabricated THERMO LAG I
Material CASE's allegations concerning an apparent breakdown in OA/0C at CPSES as it relates to November 1989 receipt inspection of vendor fabricated THERMO LAG material are summarized in its cover letter and detailed in to its Documented Request for Action.
Attachment D provides TV Electric's specific responses to pertinent portions of CASE's.
It is TV Electric's position that CASE's allegations are unsupportable in at least three respects.
First, with respect to CASE's 7
insistence that TU Electric should have issued a Stop Work Order (SWO) for vendor fabricated THERMO LAG, it is sufficient to note thatt e) a SWO was not called for under applicable CPSES procedures: and b) in any event,
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since the rejected material was placed on hold in the warehouse, a SWO would not have been necessary for the purpose of preventing the installation of additional non conforming material in the plant.
- Second, CASE's attempt to connect previous problems with site fabrication and installation of THERMO LAG panels to the subject issues involving vendor fabricated material is simply illogical.
The underlying cause of the vendor fabricated receipt inspection non conformances was shipment and handling damage and acceptance criteria that were impractical to use by receipt inspectors which resulted in material being rejected that was adequate to comply the with design.
This subject bears no relationship to the underlying causes of the site fabrication and installation problems, which were addressed in SDAR CP-89 025 (TXX 89737), and will be further discussed in TU Electric's response to the Notice of Violation for NRC Inspection Report 50 445/8971.
Finally, TV Electric does not believe that the quality issues associated with the receipt inspection of vendor fabricated materials can be meaningfully analyzed by merely labeling the situation a OA/0C breakdown, and - as CASE has done rigidly insisting upon a SWO as the only appropriate remedial action.
In fact, TU Electric did put rejected material on hold at the point of receipt, pending determinations as to cause and corrective action: determined the cause and appropriate corrective actions (see Attachment D. Parts II B.1 5. Pages 3 4): and proceeded to implement that corrective action.
Since late November, the incidence of non-conforming THERMO LAG has been negligible.
On the basis of the foregoing TV Electric submits that its corrective STU Electric understands that inspector A has filed a complaint with the Department of Labor (DOL) pursuant to Section 210 of the Energy Reorganization Act.
Under the existing NRC/ DOL Memorandum of Understanding, DOL has exclusive jurisdiction over any remedy relating to the employment status of individuals under Section 210.
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TXX 89851 Page 5 of 5 actions in regard to non conforming vendor fabricated THERMO LAG material were timely and effective. Accordingly, no further action by either TU Electric or NRC is warranted, and CASE's Request for Action in regard to its allegations of 0A/0C breakdown should be denied.
For the reasons stated above and on the basis of the information presented in Attachments A, B, C and D hereto, TV Electric respectfully requests tii.?-
pursuant to Paragraphs B.3 5 of the Joint Stipulation, the Director, Office of Special Projects, Comanche Peak Project Division, should promptly issue a decision denying CASE's Request for Action and resolving the subject dispute.
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Very truly yours,
/ '
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AV7U W. G. Counsil Vice Chairman WGC:1mi Attachment A: " Rejected THERM 0-LAG NCR Issues," December 19, 1989 Attachment B:
" Layoff of OC Receiving Inspector," December 19, 1989 Attachment C:
"TV Electric's Response to Twelve Questions that CASE Posed to i
TV Electric Concerning the Subject Dispute" : "TU Electric's Specific Response to CASE's Attachments, Sequence of Events and Preliminary Findings" c
Juanita Ellis Billie P. Garde. Esq.
Janice Moore Esq.
t Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)
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-Attachment A to TXX89851 Page 1 of 2
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?11UELECTRIC t
OFFICEMEMORANDUM
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nar=nhar 19, 1989 l
No map =se anguir d
'IO:
W. G. Counsil
SUBJECT:
Dejected 'IMERPD-IJG ER Issus Based on reading and condensing the concern 9:-; --H by concernes on November 3,1989, the main issue is, "'Ihe omoernae is concerned that Supervisor Curtis BigJs and a QC Inspector Imvel III, Greg Bennetzen, will not let the QC Inspectors in receiving write an NCR on rejected ' therm-A-lag."
'Ihe assistance of Cugets hirity was requested in investigating this concern. 'Ibe following is based upon irput frun the Manager of corporate hirity - Nuclear.
corporata security's investigation into this ocnoorn included intarviews with a former QC inspector, tan additimal QC Receiving Inspectors, including all who were working in the Construction Warehouse on November 2,1989, a i
Procurenant QA employee, the QC sgervisor, Curtis Biggs and the QC Imvel III, Greg Bennetzen. corporate Security's inquiry also involved a rwview of h=ntation and procedures relative to this issue.
'Iha Cwgets hirity investigation into this concern substantiates that Greg Bennetzen made a statement that "we will not write an NCR m 'Iherm-A-lag."
Curtis Biggs and Greg Bennetzen stated that they believed the p etwe applicable to the situation on Novenhar 2,1989, was NQA 3.05, Section 6.1.1. (b), whid they felt allowed the material to be marked "unsat" on the inspectim wt and placed m " hold" pending the issuance of a DCA frun engineering whid s@ervision knew was forthoaming. Mr. Biggs and Mr.
Bennetzen further stated that they waru of the opinion that an NCR was not the j
appropriata r -et tral vehicle to document the fact that the 'Iberm-A-lag
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conduit sections were undersized. Cuperate hirity's investigation established that Mr. Biggs and Mr. Bennetzen were not trying to intimidata the inspectors to prevent them frun h=nting the fact that the 'Iberu-A-lag conduits were urxlersized.
Interviews with other QC Receiving Inspectors substantiated that they did not feel intimidated or harassed by Mr.
Bennetzen's remark. Both Mr. Biggs arti Mr. Bennetzen denied that any statanents they made to the inspectors during the discussion were meant to imply that the inspectors should not h'mant the fact the 'Iberm-A-lag conduit
Attachment A to TXX-89851
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Page 2 of 2 3
sections did not mest specifications. In fact, the im-+-s were told by Mr. Bemetzen and Mr. Biggs that the material should be marked "unnat" on the inspection report and placed on " hold."
1he investigative evidence further suggests that the lack of effective ocasunicatim by QC supervision, in failing to explain their gW int =riation, led to a significant amount of frustratim and misw-emianding en the part of the Receiving Inspectors. The Receiving LWwrs were of the opinion that the applicable ghiire was NM 3.09-11.03, Section 6.1.3, Whi& they fdt parummitated the imming of an NCR.
1 Curtis Biggs, Who had only been the Receiving supervisor for a few weeks, stated that he was shown N@ 3.09, Section 6.1.3, by the QC.1.ead the next day and agreed that the issue coald be gen to interprutation. Mr. Biggs said that, after zwviewing the r<-
two, he believed that either interpretation could be applied. Mr. Biggs stated that, thus when the NCR was brought to him, he had no problem signing it, because it only related to one line-iten of conduit sections (NCR 89-11452, Rev. 0).
l Corporata Security's inquiry further failed to substantiate the allegatim 4
that QC sqpervision att==*=4 to persuade John Simnans to sange the J
requirunents on the verification plan to 3/8 of an inch. John Sinnens stated that he was aware of the prelans with the Therm-A-lag and was in contact with both QC Receiving and Procatrument Engineering in an attampt to oces to a soluticn that would "get the most out of the material." Mr. Simeans stated that no QC Roosiving personnel had asked him to mange the requirements on the verification plari. Mr. Simums further stated that he did not have the authority to change the acomptance critaria.
In addition, the Manager, Quality control stated that a meeting with all QC Roomiving Inspectors was held Mcmday, Nownbar 27, 1989. During this meeting, the philosci y of NCRs was diamamari along with the intent of HM 3.05, t
Secticn 6.1.1. (b), and other progrannatic gtions (e.g., DChs, Vendor performing rework cn site, returning material to vendor, etc.) available to resolve receiving inspection problems.
QC ma%
- d. has diamaami the situation with Mr. Biggs and Mr. Bennetzen and has taken appropriata corrective action to preclude a recurrence of the ineffective ocamunication.
Robert L. Pfiteger NIO Cbnsultant
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'Attachm:nt B to TXX-89851
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f"11UELECTRIC OFFICEMEMORANDUM Decenbar 19, 1989 No Response Required
'IO:
W. G. Counsil SUB7BLT: Iayoff of QC Receiving Inspector Based on rasvHng and condensing the concern expr====4 by cancemos on November 3,1989, the main issue is, "Cancernae feels his HOF is part of a
' vindictive layoff.' In addition, concernae alleges that Greg Bemetzen told i
the cancemos about two months ago, 'If I ever get in the position to terminate anyme, you will be the first to go.'
'Ihm concernes also alleges that Mr. Bennetaan has also threatened lead Willie Wolf."
'Ihe assistance of corporate Security was requestad in investigating this cancern. 'Ihm following is MmM upon input frtan the Manager of Occ zete
.p Security - Nuclear.
'Ihe evidence obtained in corporate Security's investigation fails to substantiate the allegation that the ocruernee was the victim of a
" vindictive lay-off." 'Ihe decision to include the ocnoernee in the RDF was made by the QC Manager MmM on applicable policy which evaluated such factors as seniority, billing rate and performance. 'Ihe QC Manager was not aware of the alleged conflict between the cancernes and Greg Bennetzen and the alleged conflict was not a factor in the decision to include the canoames in the RDF. Furthermore, Mr. Bennetzen did not evaluate the cancemee, and had no input into the factors which detarmined the conoemee's ranking on the ROF list, and had no input into the IOF decision.
Corporate Security's inquiry substantiated that Greg Bennetzen had previously made a statement that should he ever be in the position, the concernee would be the "first to go."
However, neither this statanent nor the fact that the cancemse and Mr. Bennetzen had disagreed over the issuance of an NGt was known by the QC Manager or were factors in the concernee's irclusion on the IDF list.
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Attachment B to TXX-89851
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L In additica, Gr.te security could ru:t substantiate that lead Willie Wolf j
had been prwicusly threatened by W. Bennetzen as alleged by the cxmaarnee.
%+iate action has been taken by QC nanagesnant with regard to the ocument l
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Attachment C to TXX-85851 on Page 1 of 3 TU ELECTRIC'S SPECIFIC RESPONSES TO CASE'S "00ESTIONS REGARDING THERM A-LAG INSPECTIONS" p
Question 1: What is the SAFETEAM procedure when a worker asks that a safety concern be given to the NRC7 Responset From the inception of the SAFETEAM program it has been the SAFETEAM practice to make all concerns available for information and review upon NRC request.
In addition, SAFETEAM has made it a practice to notify the NRC of potentie11y safety significant concerns or concerns that are know's to be of j
particular interest to the NRC.
Because of the isset. raised by this inquiry, SAFETEAM has modifica its process o' handrq those concerns when the concernee requests the NRC be notified. As of Lecember 1, 1989, if a concernee states that his concern should be reported to the NRC or he would like to talk to the NRC, SAFETEAM l
will handle those matters as follows:
1.
If the concernee will agree to talk to the NRC, the SAFETEAM interviewer will call the NRC and request that someone from the NRC I
be sent over to tal% to the concernee.
1 2.
If the concernee will not agree to talk to the NRC, the interviewer will document that on the concern report form and the NRC will be notified that the concernee felt that the NRC should be made aware of the concern. The NRC then reviews the concern as appropriate.
The interviewer will make sure the concernee understands that reporting concerns to SAFETEAM is not the same as reporting them to the NRC. The interviewer will point out to the concernee that information about reporting concerns to the NRC is contained in the exit information package and offer 4
him a copy, even if he is not exiting.
Question 2:
PO 665-71871. Section 3.2 required the vendor to comply with 10 1
CFR 50, App. B, and be subject to verification by TV Electric.
A.
Was a pre-award survey performed?
B.
What were results?
C.
Provide a copy of survey.
Response: The TU Electric Quality Assurance organization performed a Pre-Award Survey (dated July 30-31, 1981) along with two source Audits (0A Audits.
TSI-1, dated August 24 25, 1981: and TSI-2, dated September 15-17, 1981). The survey and audits resulted in approval of TSI as a source supplier, in accordance with C01-CS-4.4, on August 21, 1981 (0XX-806) and TSI was added to the Approved Vendors List in Revision 4, Supplemental Memo #2, dated August 1981 (Reference 0XX-825).
A copy of the survey will be provided to CASE under separate cover.
At' tach:ent C to TXX 85851 Page 2'of 3 i
Question 3: What is the explanation for OC management (Biggs and Bennetzen) directing the lead and inspectors not to write an NCR on THERMO-LAG that did not meet specs?
Response
See Attachment A, Question 4: Why did QC management (Biggs) ask that acceptance criteria be reduced to allow buy off of the material?
Response
The acceptance criteria denoted in the verification plan was not changed at the request of-0C supervision, (See Attachment A for additional discussion.)
?
' Question 5:
By what procedure or practice does QC management have the authority to suggest or propose a Design Change to avoid writing an NCR7 (Historically this technique has been used to avoid writing NCRs).
Response
Any individual, including OC supervision, has the freedom to suggest a design change.
However, QC supervision riid not request a DCA relating to THERMO-LAG material, and a DCA was not used to circumvent and undermine the deficiency reporting process as implied by CASE.
Question 6: Why was John Simmons, in procurement, asked to make a change to the specified ar.1 approved P0 requirements, thereby failing to identify deficient material and defective vendor QA program?
Response
See our response to Question No. 4 above. The question also implies that-the vendor had a manufacturing problem which was not properly documented during the receiving inspection, which began November 2, 1989.
To the contrary, the IR (within Verification Plan 89 2092) was documented as "unsat" and NCR 89-11452 was issued on November 3, 1989. These two actions-occurred while the receiving inspection was still "in process." The final paper work was completed November 8, 1989, and is contained in RIR No. 02934.
Question 7:
Since this was a priority one order and material was needed badly, why was no source inspection imposed?
Response
After May 18, 1989, source inspections for TSI were not required in procurement documents based on the following:
1.
The acceptable evaluation of the vendors program as determined by the Pre-Award Survey, periodic Audits, and history of teceipt of acceptable material 2.
On-site review of material conformance testing (burn test) 3.
Relative lack of meterial complexity 4.
Critical inspection attributes could be verified through normal site receipt inspection.
l The decision to discontinue the requirement for source inspections was made by Procurement GA due to the satisfactory performance of the vendor.
Hence.
shipments received against P0 665-71871, Supplements 7 and 10 which were l
being inspected on November 2, 1989, did not require a source inspection.
Y
'At'tachment C to TXX-85851
=Page 3 of 3 Question 8: Did TV Electric OA management know about THERMO LAG rejected by QC inspectors and the direction to not write an NCR7 Response:. 0A/0C management above Mr. Biggs were not aware of the incident until the SAFETEAM concern and the CASE allegation was received.
Question 9: Was OA management aware of OC supervisor and Level III proposals to. John Simmons to reduce acceptance criteria?
Response
No proposal was ever made by QC Supervision or the Level III inspector to Mr. Simmons to reduce the acceptance criteria for inspections occurring on November 2, 1989, for THERMO-LAG.
Question 10: What is the sequence of events pertaining to recent THERMO-LAG problems in Documents SDAR 89-25 and CAR 89-097
Response
See Attachment D, Part I.A.
Question 11:
How was concernee chosen for a layoff the same day he argued to write NCRs?
Response: See Attachment B, third paragraph.
Question 12: Did QA management issue a Stop Work?
If not, why not?
Response: A Stop Work Order was not issued by Quality Assurance management.
0A management determined that the criteria of procedure NEO 3.25 "Stop Work," Rev. O, had not been met.
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W Attachment D to TXX-85851 Page 1 of 5 TU ELECTRIC *S SPECIFIC RESPONSES TO CASES *S ATTACHMENT 2.
" SEQUENCE OF EVENTS AND PRELIMINARY FINDINGS" I.
SITE FABRICATED THERMO-LAG A.
SEQUENCE OF EVENTS For the reasons indicated in Paragraph 3 of the cover letter, the site fabricated THERMO-LAG issue is logically independent of the vendor fabricated THERMO-LAG issue. The site fabricated THERMO-LAG issue was addressed in SDAR CP-89-025 and will be discussed in response to the Notice of Violation for Inspection Report 445/8971: 446/8971.
B.
PRELIMINARY FINDINGS For the reasons indicated in Paragraph 3 of the cover letter, the site fabricated THERMO-LAG issue is logically independent of the vendor fabricated THERMO-LAG issue. The site fabricated THERMO-LAG issue was addressed in SDAR CP-89-025 and will be discussed in response to the Notice of Violation for Inspection Report 445/8971: 446/8971.
II.
VENDOR FABRICATED THERMO-LAG A.
SEQUENCE OF EVENTS Page No.
Line(s) or of CASE Paragraph No. of CASE Attachment 2 TU Electric Response / Comment l
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06-15-89 PO #665-71871 was issued for the purchase of pre-shaped conduit l
sections with a one-hour design rating.
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11-02-89 We do not know the source of CASE's numbers. The data on rejections that we have retained indicates the following:
The acceptance criteria for 5" diameter (ID) THERMO-LAG conduit sections were 1/2" minimum - 3/4" maximum as specified by DCA 77269 R/10. A total of 191 linear ft. of this shipment was inspected and 49.5 linear ft. was rejected (reject rate - 261). This condition was-documented on NCR-89-11452 on 11/3/89.
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Attachm:nt D to TXX-89851 3
Page 2 of 5 Page No.
Line(s) or of CASE Paragraph No. of CASE Attachment 2 TU Electric Response / Comment The acceptance criteria for 3/4" diameter (ID) THERMO-LAG conduit sections was the same as for 5" THERMO-LAG conduit.
sections. A total of 501 linear ft. was inspected and.30 linear ft. was rejected (reject rate -- 61). This is an overall reject rate which includes data for before and after the acceptance criteria changed on 11/4/89. We do not have separate reject rate data for before and after the change.
This condition was documented on NCR-89-11537 on 11/8/89 when the inspection was completed.
4 11-03-89 See Attachments A and C.
4 11-03-89 See Attachments A and C.
4 11-03-89 The Level III attended a meeting with the NRC to discuss site fabricated THERMO-LAG. Although the Level III presented information related to proposed NRC violations relating to site fabricated THERMO-LAG. he did not argue about the' proposed violations. TU Electric did not attend the meeting for the purpose of discussing vendor fabricated THERMO-LAG.
It is TU Electric's position that the site-fabricated and vendor fabricated THERMO-LAG issues are logically independent matters.
4 11-04-89 See Attachments A and C and cover letter. ites 2.
The. inspector was not denoted. He was assigned to a two-man inspection team with the responsibilities of a QC receipt inspector. The other member of the team was designated as lead, but the subject inspector was not designated as a " helper."
5 11-07-89 The deficiencies noted against the vendor supplied THERMO-LAG conduit sections were not relevant to the violations noted for the site fabricated panels.
lu
x Attache nt D'to TXX-89851 Page 3 of 5 Page No.
Line(s) or c.a of CASE Paragraph No. of CASE Attachment 2 TU Electric Response / Comment 5
11-08-89
-The Level III did not raise an issue pertaining to Certificates of Conformance.
5 11-10-89 See cover letter.
B.
CASE *S PRELIMINARY FINDINGS 1.
TU Electric does not believe that a OA breakdown occurred in the receipt inspection process for vendor fabricated THERMO-LAG. The receipt inspection procedures were properly executed and' adequately reflected the specification requirements. All quality related requirements were met.
The high rejection rate was attributed to shipment and handling damage and acceptance criteria that were impractical for use by receipt inspectors which resulted in material being rejected that in most cases was adequate to comply with design conditions.
l 2.
TU Electric does not share CASE's opinion. CASE's conr.ection of the subject issues to the Service Water System issues stretches the bounds of reason. TU Electric's position.in regard to the Service Water System piping issues is a matter of record on which TU Electric will stand.
In particular TU Electric's specific responses to the positions expressed by CASE's consultant, j
i Mr. Phillips, and by CASE's counsel are set forth in TU Electric's December 11 and 12,1989 l
1etters TXX-89847 and TXX-89848, respectively.
3.
As explained in Paragraph 3 of the cover letter, the site fabricated THERMO-LAG issue is logically independent of the vendor fabricated THERMO-LAG issue. This issue was addressed in-SDAR CP-89-025 and will be discussed in response to the Notice of Violation for Inspection Report 445/8971: 446/8971.
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Attach;ent D to TXX-89851 Page 4 of 5 4.
The decision to not require source inspections was based upon the vendor's (TSI*s) prior.
performance, not project schedule. Thermal Science, Inc. (TSI), has a 10CFR50, Appendix B, OA program that governs the manufacture of THERMO-LAG products used at CPSES.
This program has been audited by TU Electric, as well as many other nuclear facilities, and found to.be adequate with appropriate 0A procedures in place to control the quality of finished products.
Approximately 2000 sq. ft. of the 14,000 sq. ft. (CASE's number) of THERMO-LAG installed in the-plant was site-fabricated, or indeterminate, prior to final removal. The remaining 12,000 sq.
ft., plus some quantity in the warehouse, consisted of vendor-fabricated materials which had passed site QC receipt inspections, with no deficiencies identified. Subsequent shipments were also received without deficiencies. TU Electric did initiate source inspections on November 8, 1989, as a result of two NCRs (89-10699 and 89-11142) in October and two in early November (89-11452 and 89-11471). These NCRs identified deficiencies with received products and were aggressively investigated by OC, Engineering, and the vendor. This evidence is hardly indicative of inadequate QA management overview or poor judgement in regard to source inspections.
5.
Due to accelerated production schedules, some materials were received which, although technically dry and stable, were structurally soft in places. Some of the panels had compression indentations due to shipping and handling.
NCRs 89-11142, 89-11452, and 89-11471 discussed in Item 4 above identified these as deviations from Specification 2323-MS-38H.
Discussions with TSI*s technical staff revealed that compression of the material did not impair its fire protective properties. The material is relatively spongy and is less subject to compression indentation as it ages and continues to-lose moisture. Specification 2323-MS-38H was revised by DCA 77269 R/11 on 11-4-89 to allow minor deviations below minimum thickness, as approved by TSI, such as minor compression and surface blemishes which do not impair the fire l
protective properties of the materials. No changes were made to any THERMO-LAG formulas, l
6.
TSI brought one of its calibrated frame mounted dial indicators on site.
Initially the gauge l
was used to take reference measurements. OC Supervision recognized upon receipt of the tool i
that it was not site calibrated. The direction given to the inspectors during a tool l
demonstration was that the tool could be used if checked prior to use with a set of gauges which were calibrated and located in the OC office. This was to assure that the dial indicator (which l
is adjustable) was reading properly. The process was demonstrated to those involved and is not considered an inappropriate use of measuring equipment.
After the need for the tool was established, the Calibration Lab was contacted, and the tool received site calibration. The tool was entered into the TU Electric calibration program. The inspectors were aware of the calibration status of the tool. The method used to assure tool accuracy prior to site calibration is not considered inappropriate.
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7.
.This measuring device,' loaned'to TU Electric by TSI, is made of: light weight aluminum tubing andi..-
is flexible-enough that the reading is affected by how:one holds it.
The' sensitivity ifaits of'.
'the device.and how to use;it were demonstrated by TSI prior to receipt by TU Electric.
' ' t-8.
The PO provision for the-vendor.to make nonconformance reports applied to nonconformances identified by the vendor. Once the material was~onsite, the CPSES administrative controls.were applicable to nonconformances identified with vendor' material, and the vendor.was under no obligation to-issue nonconformance reports for' conditions' identified.onsite. See Attachments A'-
6 and C,. and cover letter (Paragraph 1) for additional ~information.
9.
a.
See Attachment A, and cover letter (Paragraph 1).
b.
See Attachment C.
c.
See Attachment D.Section II.A. 11-03-89, third response ites.
d.
See Attachment B, and cover letter (Paragraph 2).
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