ML20148C516
| ML20148C516 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/15/1988 |
| From: | Counsil W, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-88221, NUDOCS 8803220418 | |
| Download: ML20148C516 (4) | |
Text
-==
r --
Log # IXX-88221 Fi1e # 10130
___r
=
IR 87-16 IR 87-13 7tlELECTRIC Ref. # 10CFR2.201 March 15, 1988 w mim c. counsa 1;necwin ske Presdent U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NO. 50-445 AND 50-446 INSPECTION REPORT NOS. 50-445/87-16 AND 50-446/87-13 UPDATEDRESPONSETONOTICEOFVIOLATION(NOV)
ITEM C (445/8716-V-12)
REFERENCE:
- 2) TV Electric letter TXX-88092 from W. G. Counsil to NRC dated January 13, 1988 Gentlemen:
Reference (1) provided our response to Notice of Violation Item C (445/8716-V-12).
In that response we stated that an update would be provided no later than January 15, 1988.
Reference (2) extended that date to February 16, 1988.
On February 16, 1988, per a telephone conversation with Mr. R. F. Warnick, we requested and received an extension as follows:
Item C (445/8716-V-12) extended until March 15, 1988.
Attached is our updated response.
Those portions of the response which have been revised are. denoted by a revision bar in the right margin.
Ve y truly yours, a).G. W W. G. Counsil 8803220418 890315 s
DR ADOCK 05000445 By:
562 PDR D. R. Woodlan Docket Licensing Manager RDD/ck Attachment c-Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3) 60/
l a soras ative sarece iaai voitas. rex., ?noi
Attachment to TXX-88221 March 15, 1988 Page 1 of 3 NOTICE OF VIOLATION ITEM C (445/8716-V-12)
C.
Criterion XVI of Appendix B to 10CFR Part 50, as implemented by Section 16.0, Revision 0, of the TV Electric QA Plan, states in part, "Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition..."
TV Electric, in response to Corrective Action Report (CAR) 65X, which identified a missing cotter pin as a Construction Deficiency, established the Hardware Validation Program (HVP) for safety-related pipe supports.
Included in this program is a required verification that locking devices are present and correctly installed.
Contrary to the above, the sway strut rear bracket load pin on safety-related pipe support CC-1-295-006-C53R, Revision 4, was observed on August 21, 1987, to have two missing cotter pins although this support had been reworked by craft and accepted by QC in accordance with the HVP (445/8716-V-12).
UPDATED RESPONSE TO VIOLATION ITEM C (445/8716-V-12)
TV Electric agrees with the alleged violation and the requested information follows:
1.
Reason for Violation The subject pipe support was inspected and accepted in accordance with the Hardware Validation Program (HVP) in May of 1987. Although our findings cannot be confirmed, TV Electric believes that the subject cotter pins may have been removed during painting activities which are known to have occurred subsequent to the HVP inspection and prior to the NRC inspectors observation of missing cotter pins.
2.
Corrective Steps Taken and Results Achieved On August 26, 1987, Non-Conformance Report (NCR) 87-A01243 was written documenting the missing cotter pins.
To determine the extent of the problem, a reinspection was initiated of 10% of the approximately 3000 pipe supports which had been inspected per the HVP. On September 4,1987, af ter reinspecting 45 pipe supports, a loose jam nut was found on pipe support CC-X-079-004-A43R.
NCR 87-A01446 was written and the reinspection ef fort was tenninated.
Based on the identification of an additional discrepancy relating to configuration control, further sampling was not considered necessary and Corrective Action Request (CAR)87-075 was initiated.
Attachment to TXX-88221 March 15, 1988 Page 2 of 3 UPDATED RESP 0llSE TO VIOLATI0il ITEM C (445/8716-V-12) (Cont'd) 3.
Corrective Steps Which Will be Taken to Avoid Further Violations On September 9, 1987, the Director of Construction directed that the missing / loose pipe support hardware be investigated and personnel retrained as required.
On September 14, 1987, the Director of Construction ordered that painting, insulating, and cleaning of safety related systems and components be stopped pending retraining of appropriate Construction Department personnel.
On September 15, 1987, Corrective Action Request (CAR)87-075 was issued to document the generic concerns raised by the discovery of the loose / missing hardware.
On September 18, 1987, following completion of the required training, the Work hold of September 14, 1987, was lifted.
l On October 27, 1987, a training memo was issued for sign-off by all Comanche Peak Engineering personnel.
This memo included instructions on the protection of permanent plant equipment, and was transmitted to all engineering contractors for training of their personnel.
On February 1,1988, operations procedure STA-606, "Work Requests and Work Orders," was revised to require specific instructions for the removal and restoration of interferences.
On February 1, 1988, startup administrative procedures CP-SAP-13, "Temporary Modifications," and CP-SAP-6, "Control of Work on Station Components After Release from Construction to Startup," were revised to contain a cautionary statement indicating that only the work contained in the work documents is permitted.
On February 4, 1988, the Construction Department issued ECC Policy Statement No.2, "Maintaining Component Integrity," which emphasized the responsibility of individuals concerning component integrity.
A Nuclear Engineering and Operations (NED) policy statement will be issued to site personnel with badges permitting them to enter the plant.
This policy statement will reiterate that alteration must only be accomplished in accordance with approved procedures and documents.
Documented reading of this policy statement will become a formal part of the badging process.
A program will be established whereby a team will observe ongoing work activities in the field and inspect work documents to assess whether activities are strictly within the scope of work documents provided.
Attachment to TXX-88221 March 15, 1988 Page 3 of 3 The team will also assess whether damage is occurring to equipment in the area of work activities. Appropriate actions will be taken based on the results of the team's observations. An update to this response will be submitted providing additional details of the teams composition and methodology.
Construction Procedure CP-CPM-7.1 "Package Flow Control" will be revised to require that work instructions contain specific direction to only perform those activities within the scope of the authorized documentation.
The requirements of procedure CP-CPM-6.10, "Inspected item Removal form,"
are being revised and incorporated into new procedure ECC 2.13-5, "Construction Travelers," and ECC 2.13-5A " Construction Traveler Generation" which will include appropriate guidance for working on or around accepted hardware.
The twelve CPE procedures that require personnel to enter Category I buildings will be revised to include cautionary statements regarding the alteration of installed and accepted equipment.
Painting Specifications 2323-AS-30 & 31 are being revised to include guidance for working on or around installed and accepted safety related equipment.
To determine the extent of missing or loose pipe support hardware, we have reinitiated sampling of pipe supports which have been inspected per the HVP.
Additional actions will be taken as required, based on the results of this sample. We will provide an update to this response describing the results of the sample and any additional actions planned.
4.
Date When Full Compliance Will be Achieved Except as noted below the actions described above will be completed no later than May 15, 1988.
Procedures ECC 2.13-5 and 2.13-5A will be issued by May 1, 1988.
}
The revisions to Specification 2323-AS-30 and 2323-AS-31 will be completed by June 16, 1988.
An update to this response describing the work observation teams and the sample results including any additional actions planned will be provided l
by July 1, 1988.