ML20148Q597
| ML20148Q597 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/06/1978 |
| From: | Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20148Q584 | List: |
| References | |
| NUDOCS 7811300109 | |
| Download: ML20148Q597 (4) | |
Text
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01 TEX AS 1 TII.lTIES GENERATING CO311%NY l
2( 911 lii t i \\ N 'I t su l i t. t 141 l. \\ m l'l \\ \\- 7n t il November 6, 1978 TXX-2901 su a w y
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Mr. W. C. Seidle Reactor Construction and l
Engineering Support Branch U. S. Nuclear Regulatory Commission Office of Inspection & Enforcement 611 Ryan Plaza Dr., Suite 1000 Docket Nos. 50-445 Arlington, Texas 76011 50-446 COMANCHE PEAK STCAM EL.ECTRIC STATION
- 1981-83 2300 MW INSTALLATION RESPONSE TO NRC INSPECTION REPORT DATED AUGUST 30, 1978 l
REF:
TXX-2881 l
DOCKET NOS. 50-445 & f>0-446 l
FILE NO. 10130 l
Dear Mr Seidle:
This letter provides additional information as requested by your letter of October 10, 1978 to our response (our letter no. TXX-2881)
I to the report dated August 30, 1978, relative to the inspection con-ducted by your resident inspector, Mr. R. G. Taylor, and other members of your staff during the period ending August 25, 1978 of the activities authorized by NRC Construction Permit Nos. CPPR-126 and 127 for the Comanche Peak facility.
In the interest of continuity, we have repeated the requirement and your findings followed by our original response and the requested supplementary information. The additional information is noted by a vertical bar in the right hand margin of the page.
If you have any further questions, please advise.
Very truly yours, M/
R./J. Gary /
RJG:dla Attachment 781130 D/df f
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i Additional Response to NRC Inspection Raport dated August 30, 1978 TXX-2901 Page 2
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Failure to Follow Weld Monitoring Prccedures
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Criterion V of Appendix B requires that established instructions, procedures, or drawings be fallowed for ~all activities affecting quality.
Brown and Root documents 35-1195-WCP-3 Revision 8, dated November 7, 1977, titied " Administration and Organization of Field Welding Techni-cal Center," requires in paragraph 4.3 that each welder be monitored, as a minimum, every ten working days and the results recorded on
" parameter logs. "
Contrary to the above:
The inspector observed during a review of the parameter logs that three welders identified as welding on the reactor coolant system had been monitored last on June 20, 1976; June 26, 1978, and December 6, 1977, respectively.
This matter has been discussed with licensee representatives who have confirmed that the facts outlined are essentially correct.
This item of noncompliance is an infraction.
Corrective Steps Which Have Been Taken and Results Achieved:
Additional record research revealed that welder monitoring reports were available for the three welders in question and were located in the Completions Department having been routed in error to that department in lieu of the QA Vault.
A total audit was made by Welding Engineering of the welder monitoring progran and a small number of discrepancies from procedure requirements '
was noted.
The majority of these non-comp?iances were on welders who welded l
very few safety related welds and had completed the welds before action could be taken.
Corrective Steps Which Have Been or Will Be Taken to Avoid Further Noncompliances:
Improvements in the welder tracking system have been nade and will aid in maintaining procedural compliances.
Also the format of the Welder Performance Qualification Log has been adopted and modified by the Field Weld Technical Center to maintain closer tracking of welders working on safety related systems.
Improvements in the welder tracking system have included steps to maintain the status of the welder monitoring activities on a daily basis by appropriate notations on the Welder Performance Qualification Log.
A system of color codes and markings has been established to
Additional Response to NRC Inspection Report dated August 30, 1978' TXX-2901 i
Page 3 l
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indicate the welder observed, shif t worked, and parameters which may have been out of tolerance.
These improvements will insure that welders are monitored as a minimum every ten working days as required by the subject procedure.
The Site QA Surveillance group has revised their surveillance schedule to provide monthly surveillance of welder monitoring activi-ties until an adequate level of confidence has been established.
Date of Full Compliance:
The revised welder tracking system was implemented on October 1,1978.
The monthly QA surveillance efforts will begin during the month of November, 1978.
3.
Failure to Adequately Control and Tag Nonconforming Items 10 CFR Part 50, Appendix B, Criterion XV, requires that measures be established to prevent inadvertent use or installation of noncon-forming items which include identification and segregation.
Brown and Root Procedure QAP-lb.1, Section 5.1.1 requires that nonconforming items be tagged, segregated and/or marked.
Contrary to the above:
Although measures have been established for identification and segre-gation of items which are nonconforming, the IE inspector found, at 9:30 a.m. on August 25, 1978, that nonconforming cable tray supports were not adequately tagged and segregated.
The inspector specifically found:
1) the barrier separating nonconforming cable tray supports from acceptable supports was broken and fallen to the ground; 2) the nonconformance tag, No. E-1105, was attached to the barrier tape which had fallen to the ground and was obscured by dust; 3) the individual nonconforming items were not marked as to their status; and 4) the Nonconformance Report, NCR E-1105, did not identify by item number or count the nonconforming cable tray supports.
This item of noncompliance is an infraction.
Additional. Response to flRC Inspection-Report dated. August 30, 1978 TXX-2901 Page 4 Corrective Steps Which Have Been Taken and Results Achieved:
flonconformance Report flo. E-1105 was revised to specifically identify those cable tray hangers which were nonconforming.
A total of fourteen (14) hangers were identified and red " Hold" tags were applied to each hanger.
Corrective Steps Which Have Been or Will Be Teken to Avoid Further
.fbncompliance:
Brown and Root. QA has initiated steps to insure that field super-visory personnel and QC field inspectors are made aware of the requirements of CP-qAP-15.1 (flon-Conformance Reporting).
Additionally, Brown and Root is now implementing a rystem whereby every employee attending the B&R Construction Supervisors Training Class is given a detailed explanation of the procedure usea in con-trolling nonconforming items at CPSES.
All QC Field Inspectors have been reinstructed in the procedural requirements of CP-QAP-15.1. All Superintendents, General Foremen, Foremen and Department Heads have been advised by interoffice memo-randum of the procedural requirements that were violated.
Procedural requirements were clearly explained therein and all personnel were reminded of their responsibilities relative to control of nonconform -
ing items.
l The Site QA Surveillance group performed a surveillance on September 26, 1978 in the area of Inspection and Test Status (Hold Tags) which was found satisfactory (QA Surveillance Report - G-009). Additional surveillances will be scheduled monthly as a means of assuring ad-herence to procedural requirements.
After further review, it has been determined that the Construction Supervisors Training Class is not an effective corrective action to the identified infraction in that attendance is voluntary.
He here-with withdraw this action and will rely on the measures described,
above to control future activities.
]
Date of Full Compliance:
Corrective action for the specific hangers involved was completed and verified on September 18, 1978.
Preventive actions were fully implemented by October 11, 1978.
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