ML20151J661
| ML20151J661 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/15/1988 |
| From: | Counsil W, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-88575, NUDOCS 8808030030 | |
| Download: ML20151J661 (9) | |
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' File # 10130
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r IR 88-24 IR 88-21 7UELECTRIC Ref. # 10CFR2.201 mgg
-July 15, 1988 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT NOS.
50-445/88-24 AND 50-446/88-21 Gentlemen:
TV Electric has reviewed your letter dated June 23, 1988, concerning the inspection conducted by Mr. C. C. Williams in conjunction with Mr. S. M. Matthews, Director and Chief Inspector, Boiler Division, Texas Department of Labor and Standards (TDLS) during the period March 8,1988 through June 3, 1988.
This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for CPSES, Units 1 and 2.
Attached to your letter were a Notice of Violation and Unresolved Item.
We hereby respond to the Notice of Violation and Unresolved-Item in the attachment to this letter.
Very truly yours, D. b b W. G. Counsil Byf 5f/
J7 E Dr Walker Manager, Nuclear Licensing DAR/grr Attachment c - Mr. R. D. Martin, Region IV P?sident Inspectors, CPSES (3)
Texas Department of Labor and Standards Boiler Division C. O. Thompson State Office Building P. O. Hex 12157, Capitol Station
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Aastic, Texas 78701 4,0 u
Attn Steve Matthews
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/ d) m 8800030030 G90715
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pnn 6CDCK O50 pf K0 Nonh Olbs Street LB 81 Dellas. Texas 301 o
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Attachment to TXX-88575 July 15, 1988 Page 1 of 8 UNRESOLVED ITEM 445/8824-U-03 flRC Inspection Report 445/8824; 446/8821 documents the results of a detailed NRC evaluation of the Unit 1 Reactor Coolant System (RCS) Cold Hydrostatic Test performed on July 30 and 31, 1982.
During the course of the inspection a number of issues were identified which caused the NRC and the Chief Inspector, Texas Department of Labor and Standards Boiler Division (TOLS-DD) to question the acceptability of the Unit 1 RCS Cold Hydrostatic Test.
As stated in Paragraph 3.D(2)(c) of the Inspection Report, "The applicant apparently failed to establish and/or comprehensively follow detailed procedures controlling the examination of the Unit 1 Primary System Cold Hydrostatic Test examination activities and concurrently the apolicant apparently failed to maintain objective records of related activities.
To this extent, the acceptability of the Cold Hydrostatic Test of the Unit 1 Primary System is considered indeterminate... This matter is considered unresolved (50-145/8824-U-03)."
RESPONSE TO UNRESOLVED ITEM 445/8824-V-03 Three specific issues are cited in the inspection report as the bases for questioning the acceptability of the hydrostatic test.
The first issue is that the methodology for converting piping documentation information to hydrostatic test field examination points was not comprehensively proceduralized.
Additionally, forms which were procedurally used to document the status of reviews of piping documentation packages were not required to be maintained as part of the final Hydrostatic Test Documentation Package.
The second issue is the adequacy of the information provided to the QC inspectors who performed the field walkdown inspections during the hydrostatic test.
This issue derives in part from the first issue in that the lack of proceduralized conversion methodclogy may have caused some inspection points not to be identified to the inspectors while others were not definitively characterized as to type (e.g., field weld, shop weld, base metal repair involving welding, high stress point) or exact location.
In addition, ambiguities in written records regarding the existence or non-existence of welded base metal repairs were identified on the drawings supplied to the QC inspectors.
The third issue is one of procedural compliance and relates specifically to vendor supplied components which were pressure tesced during the Unit 1 RCS Cold Hydrostatic Test rather than by the vendor at the time of fabrication.
As established in the NRC inspection report, this is an acceptable practice provided that the ASME Code commitments of the vendor are met during the completed system hydrostatic test.
During the NRC inspection it wv identified that the vendors' AHis did not sign the Pressure Te" % a Sheet fo: the Unit 1 RCS Cold Hyd ' static lest to indicate that they itnessed those portions of the test applicable to their components as required by the governing procedure.
In response to concerns expressed during the NRC inspection, TV Electric, performed an evaluation of the Unit 1 RCS Cold Hydrostatic 7est based or documentary evidence available.
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.. ' ~ ' Attachment to TXX-88575 July:15, 1988 Page 2 of 8-The fol. lowing objectives were established for this evaluation:
- 1.. Determine the extent to which the Unit l RCS. Cold Hydrostatic Test demonstrated system integrity and satisfied applicable ASME Code technical requirements.
'2.
Determine the extent to which procedures controlling the Unit 1 RCS' Cold Hydrostatic Test provided necessary guidance for-preparation, conduct', and reviews of the test.
3.
Determine the extent to which QC personnel performing acceptance
-inspections were qualified to conduct those inspections.
4.
Identify and-propose resolution of any potentially discrepant conditions.
5.
Identify any areas where program enhancements could-contribute to more definitive and comprehensive test packages.
Objectives 1, and 2 of this self assessment focused on the type of issues documented in Inspection Report 455/8824; 446/8821. Objectives 4 and 5 provided added assurance that the review was comprehensive, that identified problems were resolved, and that lessons learned were properly fed back into the Hydrostatic Test Program.
The following methodology was employed during this assessment:
1.
A matrix was developed correlating ASME Section ill Hydrostatic Test requirements to hydrostatic test procedure requirements.
2.
A review of documentation was conducted to identify required hydrostatic test inspection points and the results were compared to the inspection points utilized in the test.
3.
The procedures governing the preparation for, conduct of, and review of the Unit 1 RCS Cold Hydrostatic Test were evaluated with respect to ASME Code and regulatory requirements for level of detail and technical content.
4.
Qualifications of the inspection personnel involved in the test were compared to applicable requirements.
The results of this review were documented in Engineering Report ER-ME-01, "Reactor Coolant System Cold Hydrostatic Test Report," dated June 16, 1988.
A copy of this report was transmitted to the NRC via TV Electric letter IXX-88529 dated June 17, 1988.
Based on this review, the following conclusions were reached:
1.
The Unit 1 RCS Col 1 Hydrostatic Test demonstrated RCa integrity and satisfied applicab.e ASME Section 111 Code requirements because:
a.
The Code class boundary was pressurized in accordance with Code requirements.
1
Attachment to TXX-88575 July 15, 1988
.c Page 3 of 8 b.
With the exception of four integrally welded attachments, all required inspection points were properly identified on the isometrics, spool sketches, and flow diagrams used for field examination during the hydrostatic test.
Two_ of the four integrally welded attachments were identified in 1982 and retested in 1983.
The remaining two integrally welded attachments were identified during the recent review.
The size and configuration of the welds associated with these attachments are such that had the attachments been made after-the 1982 test, retesting would not be required by ASME.Section 111.
Consequently, failure to explicitly identify these attachments had no impact on the technical acceptability of the hydrostatic test.
VuM ng this portion of the review specific attention was devoted to base metal repairs involving welding which would require inspection during the hydrostatic test.
A total of 37 such repairs were identified. All 37 repairs fell into one of the following three categories.
A repair weld was made to a pipe end prep prior to making the associated butt weld, and the repair weld was subsequently consumed by the butt weld.
A repair weld was adjacent to a butt weld as evidenced by the repair being radiographed with the butt weld.
Repair documentation clearly indicates the location of the repair with respect to the butt weld (i.e., running from the toe of the weld into the base metal).
It is concluded that it would have been impossible to not inspect the repaired areas while inspecting the associated butt welds.
c.
The inspections during the test were conducted by fully qualified inspectors who documented the acceptability of the portion of the test boundary assigt.
to them in accordance with approved procedures using the proper acceptance criteria.
d.
The test was accepted to the requirements of ASME Boiler and Pressure Vessel Code,Section III by the NA Certificate Holder.
e.
Vendor supplied components were inspected and accepted to ASME Section 111 Code requirements as documented by Vendor ANI signatures on the components' Code data reports, f.
The post Hydrostatic Test Review completed by the installer was comprehensive as demonstrated by the identification of a number of discrepancies, some of which required retesting.
2.
The technical procedures governing the test contained the applicable ASME Section til technical requirements.
Based on this information TV Electric concludes that the Unit 1 RCS Cold Hydrostatic Test was satisfactorily completed in accordance with applicable ASME Code and Regulatory Requirements.
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'A ttachment to TXX-88575
- July 15, 1988 Page 4 of 8 The methodology used to convert piping documentation packages into field examination packages was not comprehensively proceduralized, nor was the
- format or level of detail required in the field examination packages explicitly identified.
The procedures which viere in place at the time did, however, direct those responsible for field examination package preparation to the sources of information necessary to ensure that all required inspection points were identified and captured on drawings suitable for use by inspection personnel in conducting field examinations.
The acceptability of the processes employed was confirmed by the review effort described above.
Consequently, these issues have been demonstrated to have had no impact on the validity of the final product.
The vendors' Anis did not sign the pressure test data sheets as required by procedure to document their acceptance of the pressure test of supplied components; however, they did document their acceptance on the code data reports.
The Document Status Forms required by procedure CP-QAP-12.1 were not required to be retained as quality records. Other documentation exists which demonstrates that this action was completed including installation, fabrication, and construction documentation, the Pressure Test Data Sheet, and the final test package which demonstrates satisfactory system performance.
Af ter careful evaluation TV Electric concludes that none of the issues had any impact on the technical acceptability of the Unit 1 RCS Cold Hydrostatic Test.
However, TV Electric has taken action or is in the process of taking actions to enhance the controls for Code pressure testing in response to the issues expressed by the NRC.
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Attachment ~to TXX-88575 July-15, 1988 Page 5 of 8 NOTICE OF VIOLATION ITEM A (445/8824; 446/8821-V-01)
A.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 0, of the TV Electric Quality Assurance Manual dated February 1, 1988, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures or drawings.
TV Electric' Final Safety Analysis Report _ Table 5.2.1 establishes commitments to appropriate ASME Boiler and Pressure Vessel Codes.
The ASME Boller and Pressure Vessel Code Section Ill Division 1-1974 Edition, Subsection NA, Article NA 4112, states in part that "... the applicant shall establish a... Quality Assurance Program for the control of the quality of specific items... or of the other work which he proposes to perform."
Further, Article NA 4420 states, "The Certificate of Authorization holder shall maintain a written description of the procedures used by his organization for control of quality and examinations, showing in detail the implementation of the quality assurance requirements of this section."
The applicants' procedure number CP-QAP-12.2 dated May 11, 1982, paragraph 2.4 states that "Vendor components that have not been pressure tested by the vendpr shall be tested as part of the system pressure test.
ensure that the component manufacturer and component manufacturer's AN!
have witnessed and shown concurrence on the Pressure Test Data Sheet."
Contrary to the above:
1.
No comprehensive and detailed procedures could be identified that could objectively demonstrate control of the conversion of the documentation content of piping (component) data packages to "marked-up" isometric drawings that were used by the inspectors during their examination to assure that all vendor welds, shop welds, field welds and high stressed areas were appropriately examined during hydrostatic testing and examination of the CPSES Unit-1 primary coolant system.
2.
The cold hydrostatic test procedures (CP-QAP-12.2, CP-QAP-18.2 and CP-QAP-6.91), either individually or collectively, do not adequately demonstrate requisite control of the piping system examination activities during the Unit-1 primary system cold hydrostatic test.
Moreover, in the instance of the Unit-1 reactor coolant system hydrostatic test (No. ICP-PT-55-1) the completed "Pressure Test Data Sheet" dated July 31, 1982 has no provisions for the vendor's AN!s to concur by signature and vendor concurrences are not apparent on this document nor were they indicated by reference to other documents.
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' Attachment to TXX-88575 July 15, 1988 Page 6 of 8 2
RESPONSE TO NOTICE OF VIOLATION ITEM A (445/8824-V-01;-446/8821-V-01)
Part 1 and First Portion of Part 2 1.
Reason for Violation TV Electric acknowledges that the procedures in place at the time of the Unit 1 RCS Cold Hydrostatic Test did not specify the exact methodology to be employed in the conversion of piping (component) data packages into field examination packages, and did not specify a format for field examination packages which uniquely identified each inspection point as to type (vendor, shop, and field welds and high stress points).
2.
Corrective Steps Taken and Results Achieved TV Electric has performed a detailed review of various aspects of the Unit 1 RCS Cold Hydrostatic Test as documented in Engineering Report ER-ME-01, "Reactor Coolant System Cold Hydrostatic Test Report." A copy of this report was transmitted to the NRC by TV Electric letter TXX-88529 dated June 17, 1988.
This review determined that; although the conversion of piping and component data into field examination packages and the formatting of field examination packages regarding specific inspection points were not proceduralized in detail, the methodologies used to accomplish these activities were acceptable in that the Unit 1 RCS Cold Hydrostatic Test demonstrated RCS integrity and satisfied applicable ASME Section 111 Code requirements. We consider that no further corrective action is required for this test.
3.
Corrective Steps Which will be Taken to Avoid Further Violations The procedures involved have been changed such that conversion of data packages is no longer required. Our current procedures require the as-issued BRP drawings to identify base metal repairs involving welding, untested vendor welds, and permanent attachment welds.
It is no longer necessary to mark up BRP drawings for use during hydrostatic testing.
Also, the procedures now require that QC inspector and ANI sign off on the applicable BRP drawing to docament their examination of the inspection points noted on the subject drawing.
4.
Date When Full Compliance will be Achieved Full compliance has been achieved.
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Attachment to-TXX-88575 July 15, 1988 Page 7 of 8 RESPONSE TO NOTICE OF VIOLATION ITEM A (445/8824-V-01; 446/8821-V-01)
.Second Portion of Part 2
-1.
Reason for Violation The procedures used to conduct the Unit 1 RCS Cold Hydrostatic Test did not contain provisions for. documenting the procedurally. required component manufacturer and component manufacturer's ANI accepta'nce of the pressure test of supplie.1 components.
2.
Corrective Steps Taken and Results Achieved Although the manufacturer and the manufacturer's ANI did not sign the-Pressure Test Data sheet, they had documented their acceptance by signing the Component Code Data Reports at the time of the hydrostatic test.
Accordingly, ASME Section 111 requirements'and the intent-of CP-QAP-12.2 were satisfied and no further corrective steps are considered necessary with respect to test ICP-PT-55-1.
3.
Corrective Steps Which will be Taken to Avoid Further Violations The requirement to ensure that the component manufacturer and the component manufacturer's ANI have witnessed and shown concurrence on the l
Pressure Test Data Sheet has been deleted from procedure CP-QAP-12.2 (now designated as AQP-12.1).
The procedure requires that the manufacturer and the manufacturer's-ANI sign the Code Data Reports.
4.
Date When Full Compliance will be Achieved full compliance has been achieved.
A.
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h Attachment to'TXX-88575 July 15, 1988 Page 8 of 8 NOTICE OF VIOLATION ITEM B (445/8824-V-02)
B.. 10 CFR 50, Appendix B, Criterion XVII states in part that "Sufficient records shall be maintained to furnish evidence of activities affecting quality.
The records shall include at least the following :
... The results of reviews,... Records shall be identifiable and retrievable..."
-Section 17.0, Revision 0, of the TV Electric Quality Assurance Manual dated February 1,1988 implements these requirements.
TV Electric procedure No. CP-QAP-12.1, "Inspection Criteria and F
Documentation Requirements Prior To Release For Pressure Testing,"
paragraph 3.4 states in part that "... The Quality Engineering Review Group shall verify that all documentation within the subject test boundary is complete... All documentation pertaining to the subject boundary shall be statused on a Documentation Status Form (Attachment 1)."
Contrary to the above, the subject record (Doct.nentation Status Form) was not available for any of the Unit-1 primary system piping data packages examined by the NRC and the TLDS.
TV Electric's representatives indicated that only a few of these records have been identified by their review of the Records of the Unit-1 Primary System Hydrostatic Test dated July 31, 1982.
The documents, according to TV Electric personnel, were lost.
RESPONSE TO NOTICE OF VIOLATION ITEM B (445/8824-V-02) 1.
Reason for Violation The retention of the Document Status Forms were not procedurally required since the forms were only considered an administrative 7echanism for statusing reviews.
2.
Corrective Steps Taken and Results Achieved TV Electric has conducted a review of various aspects of the Unit-1 RCS Cold Hydrostatic Test as documented in Engineering Report ER-ME-01, "Reactor Coolant System Cold Hydrostratic lest Report." A copy of this report was transmitted to the NRC by TV Electric letter TXX-88529 dated June 17, 1988.
This review has determined through alternate documentation that the applicable systems and components were in an acceptable condition to support the hydrostatic test.
3.
Corrective Steps Which will be Taken to Avoid further Violations The procedures involved have been changed such that the Document Status Form is no longer required.
4.
Date When full Compliance will be Achieved full compliance has been achieved.
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