ML20005G620
| ML20005G620 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/12/1990 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-90014, NUDOCS 9001220009 | |
| Download: ML20005G620 (7) | |
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MM Log # TXX-90014
""" 9 File # 10130
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IR 89-71 C
C IR 89-71 7tlELECTRIC Ref. # 10CFR2.201 l-January 12, 1990 Docuene %cr P,rsident U.S. Nuclear Regulatory Commission Attn: Document Control Desk G
Wathington, D.C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 NRC INSPECTION REPORT NOS. 50-445/89-71; 50-446/89-71 RESPONSE TO NOTICES OF VIOLATION
' Gentlemen:
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TV Electric has reviewed the NRC's letter dated December 1, 1989, concerning the inspection conducted by Mr. R. Latta and NRC consultants during the period E
October 4 through November 7, 1989. This inspection covered activities l-
' authorized by NRC Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2.
Attached to the NRC's letter were two Notices of Violation.
In a discussion with Mr. R. F. Warnick of the NRC on December 27, 1989, i
-TU Electric requested and was granted an extension until January 12, 1990, for responses to the Notices of Violation.
TU Electric hereby responds to the Notices of Violation in the attachments to this letter.
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. Additionally, the subject inspection report identified an apparent weakness in i
the CPSES procurement program. A response to this issue is also provided in the attachments to this letter, s
Sincerely, William J. Cahill, Jr.
JDS/ DEN /grp Attachments c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) 9001220009 900112
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Attachment I to TXX-90014 January 12, 1990
,.Page 1 of 2 NOTICE OF VIOLATION (445/8971-V-01)
Criterion V of Appendix B to 10 CFR Part 50 as implemented by Section 5.0 of the TU Electric Quality Assurance Manual requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings.
Paragraph 9.3.1 of TV Electric's Specification 2323-MS-38H, Revision 2, requires that "Thermo-lag 330-1 (site arefabricated sections) dry film thickness shall be 1/2 inch to 3/4 inc1."
Contrary to the above, the required dimensional inspections to insure a minimum dry film thickness of 1/2 inch minimum to 3/4 inch maximum were inadequately performed in that deficient site-fabricated thermolag was inspected, accepted, and issued to construction by the applicant's Quality Control (QC) organization.
RESPONSE TO NOTICE OF VIOLATION (445/8971-V-01)
-TV Electric accepts the violation and the requested information follows.
1.
Reason for the Violation in the inspection acceptance process for site fabricated THERM 0-LAG panels, Specification 2323 MS-38H, " Cable Raceway Fire Barrier Materials,"
required QC inspection to verify the material thickness at a minimum of every two square feet.
In July 1989 engineering personnel identified several QC accepted site fabricated THERM 0-LAG panels in warehouse storage which exhibited dry film thickness (DFT) of less than the 1/2 inch minimum required by Specification 2323-MS-38H. These deficiencies involved the edges of the site fabricated panels and localized thin areas near the panel stiffener ribbing. These deficiencies occurred because the QC inspectors did not appropriately select locations for '.nspection points to assure identification of thin areas of the panels as intended by the j
specification.
i Specification 2323-MS-38H was reviewed, and no deficietcies were found in the inspection criteria which could have caused this failure to select sufficient inspection points. Although the reasons for this failure cannot be determined conclusively, there appear to be two likely explanations based on conversations with QC and craft personnel:
(1) QC l
inspectors assumed that thin edges would either be trimmed or built up by craft during installation, and (2) QC inspectors assumed that the locations near the stiffener ribbing would be least susceptible to being out of the allowable thickness range.
Regardless of the specific reason, the fundamental problem was that certain inspectors did not sufficiently implement inspection criteria set forth in the specification.
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Attachment I to TXX-90014 January 12, 1990
' Page 2 of 2 2.
Corrective Steos Taken and Results Achieved i
The inspector error is generic to site fabricated THERM 0-LAG panels.
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Those panels have been removed and scrapped.
TU Electric is reviewing information relating to past performance of the e
QC personnel involved with the selection of those inspection soints to determine the adequacy of inspections by such personnel in otier areas or disci)1ines. Unless such review determines that similar errors were made in ot1er areas or disciplines, no further corrective actions are required.
TU Electric will submit a supplemental response to this Notice of Violation if any additional corrective action is necessary.
3.
Corrective Steos Taken to Avoid Further Violations QC personnel involved in inspection activities will be instructed regarding the inadequate inspections by January 19, 1990. QC inspection personnel involved in the site fabrication inspection were made aware of the deficiencies in their site fabrication inspection prior to submittal of TXX-89737.
4.
Date of Como11anct Based on the extensive reviews of other inspection activities by the CPRT l
and TU Electric surveillance efforts, as well as the uniqueness of the THERM 0-LAG site fabrication process, TV Electric is confident that the inadequate QC inspections are limited to the site fabricated THERMO-LAG area, and that CPSES is currently in full compliance.
The confirmatory l
review discussed in Section 2 above will be completed and any adverse l
.results and corrective actions provided to the NRC by January 26, 1990.
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to TXX-90014 January 12, 1990 o
,.Page 1 of 2 NOTICE OF VIOLATION (445/8971-V-02)
Criterion XVI of Appendix B to 10 CFR Part 50 as implemented by Section 16 of the TV Electric Quality Assurance Manual requires that in the case of significant conditions adverse to quality, the identification and corrective measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, the applicant's response to the reportable deficiency documented as SDAR-89-025, involving defective site-fabricated thermolag, was determined to be inadequate. Specifically, the generic implications-associated with a QC program which failed to detect a significant deficiency were not edequately addressed and the response did not provide adequate assurance that the cause of this condition was properly determined and corrected.
The response did not address the broadness issues: in what other areas or disciplines had QC issued potential defective material?
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RESPONSE TO NOTICE OF VIOLATION (445/8971-V-02)
TU Electric accepts the violation and the required information follows.
1.
Reason for the Violation i
TV Electric's Significant Deficiency Analysis Report (SDAR)89-025, as i
documented in TXX-89737, dealt, in part, with deficiencies in the site fabrication and QC inspection of THERM 0-LAG panels, l'
TXX-89737 stated that the generic implications of the overall THERM 0-LAG l
deficiencies extended to all THERM 0-LAG previously fabricated and/or installed at CPSES.
It indicated that all site fabricated THERM 0-LAG was being removed and scrapped. After TXX-89737 was submitted, TV Electric decided to remove and scrap all THERM 0-LAG installed prior to September 7, 1989.
(Installation deficiencies are being discussed in more detail in the close-out of Corrective Action Report (CAR)89-009).
- Thus, with respect to the deficiencies in site fabricated THERMO-LAG panels, the generic implications were considered, and appropriate corrective actions were taken.
However, NOV 445/8971-V-02 notes as a violation that the responses to the reportable deficiency documented in SDAR 89-025 did not adequately address -
the generic implications of the QC inspection program's failure to detect the defective site fabricated THERM 0 LAG; namely, whether potentially L
defective material may have been issued in other areas or disciplines.
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E to TXX-90014
. January 12, 1990
, ' Page 2 of 2 q
At the time TXX-89737 was submitted TV Electric believed that the inadequacies in the QC inspections were limited to site fabricated THERMO-LAG panels by virtue of some specific deficiencies in the j
fabrication process which created the potential for inadequate dry film thickness in specific localized areas on the panels. The generic implications of this problem were addressed by revising Specification 2
2323-MS-38H to preclude the use of site fabricated THERM 0-LAG.
- However, the bases for TU Electric's conclusions were not explicitly discussed in TXX-89737. -TU Electric has since concluded during the processing of CAR 29-009 and in responding to this Notice of Violation that the failure of i
QC inspectors to select appropriate locations for inspection points was a significant contributing factor in the failure to identify inadequate dry film thickness. However, TV Electric remains confident that this matter is confined to the site fabricated THERMO LAG area based on the uniqueness of the fabrication process and on the extensive reviews of other inspection activities by the CPRT and the surveillance efforts.
2.
Corrective Steos Taken and Results Achieved Should the confirmatory efforts described in Section 2 of the response to NOV 445/8971-V-01 reveal that the problem with QC inspections is not limited to the site fabricated THERM 0 LAG areas, supplemental responses to this violation and SDAR CP-89 025 will be submitted to explicitly discuss that conclusion and associated corrective actions.
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Corrective Steos Taken to Avoid Further Violations TV Electric site personnel responsible for the preparation of SDAR res)onses to the NRC have been reminded of the importance of assuring that suct responses include an appropriate description of each identified problem, that a determination as to the corrective actions needed to resolve each identified problem be fully supported, with appropriate consideration of the generic implications, and that such determination be clearly discusced in the response.
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In addition, a management review committee was established in November i
1989 to provide additional assurance that TV Electric evaluations of and corrective actions for reportable deficiencies are thorough and comprehensive. The review committee is comprised of representatives from Quality Assurance, Engineering and Licensing.
The purpose of the committee is to confirm the correctness of the root cause(s) and the adequacy of the corrective action (s) for 10CFR50.55(e) reportable conditions by review of substantiating information.
These actions are sufficient to avoid further violations.
4.
Date of Compliance Full compliance has been achieved.
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i to TXX-90014
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January 12, 1990 Page 1 of 2 WEAKNESS IN PROCUREMENT PROGRAM The NRC inspection report states that. "The Applicant's failure to provide adequate receipt inspection criteria for the vendor procured thermolag t-material, which could have detected this deficient condition and averted the potential for significant rework, is identified as a weakness within the procurement program." The report attributes this weakness to a decision to delete receiving inspection requirements for verification of the thickness attribute.s from Verification Plan 89-2092. The report also states that the decision to delete that requirement was apparently made in the absence of j
historical information relative to THERMO-LAG discrepancies.
Prior to September 29, 1989, the critical characteristics prescribed in the Verification Plan included thickness of vendor supplied THERM 0 LAG panels.
This attribute was verified on a sample basis (i.e., one panel inspected per pallet, which was approximately 10%). The Verification Plan was changed as a consequence of Change Order 6C-33604 dated September 29, 1989, to eliminate thickness measurements based on the following factors:
(a) Thermal Science, Inc. (TSI) was on the Approved Vendor's List with no restrictions since 1981, (b) TSI's QA program was favorably audited six (6) times between 1981 and 1989, and (c) no discrepancies were found in previous receiving inspections for thickness of TSI panels, j
TU Electric is not aware of any " historical information relative to thermolag discre)ancies" with vendor supplied THERM 0-LAG items that existed at the time that C1ange Order 6C-33604 was issued. To the contrary, as noted above, as of September 29, 1989, material received from TSI had successfully passed TV Electric QC receiving inspection.
Previous problems relating to QC inspection of site fabricated THERMO-LAG did not relate to the vendor fabricated materials since the vendor's fabrication process did not include
-l the deficiencies involved in the site fabrication process.
l On October 23, 1989, during routine inspection activities, out-of-scope discrepancies associated with vendor supplied panels of THERM 0-LAG were identified and were documented on NCR 89-11142.
Based on this NCR, which called into question the performance of the vendor, the thickness criteria were promptly reinstated into the Verification Plan.
A reinspection of a representative sample of the vendor supplied material at CPSES was performed by the vendor.
It demonstrated that the conditions identified in the NCR were 1solated and were caused by compression of the panels in localized areas due to handling and shipping.
It was also determined that the conditions were not detrimental to the fire resistance response of the panels and, therefore, the j
thicknesses were found acceptable as is.
(The thickness criteria have since been replaced with density criteria, which are more appropriate.)
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! to TXX-90014 January 12, 1990 Page 2 of 2
.In summary, TU Electric believes that the decision to eliminate the thickness
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attribute from receipt inspection of TSI fabricated THERMO-LAG was justified by available information. The deletion of the thickness criteria did not cause any rework since the NCR was dispositioned use-as-is.
Historical information related to the vendor was available and was considered in the decision to delete the criteria for thickness measurements.
Therefore, it is concluded that this matter does not represent a weakness in the procurement program.
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