ML20151Y864

Responds to NRC Re Violations Noted in Insp Repts 50-445/88-46 & 50-446/88-44.Corrective Actions:Ncr 88-11586 Issued & Dispositioned.Response to Item a Will Be Provided by 880906

ML20151Y864
Person / Time
Site:	Comanche Peak
Issue date:	08/22/1988
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-88623, NUDOCS 8808290067
Download: ML20151Y864 (4)

Text

. .

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. . Log # TXX-88623

-,_, .-- Fi1e # 10130

_- _ IR 88-46 l TUELECTRIC 9,g,,lchg ng llyy,j C Q August 22, 1988 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

SUBJECT:

COMANCHEPEAKSTEAMELECTRICSTATION(CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT N05.

50-445/88-46 AND 50-446/88-44 l

Gentlemen:

TV Electric has reviewed your letter dated July 22, 1988, concerning the

, inspection conducted by Mr. P. Stanish and other NRC consultants during the l period June 8 through July 6, 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 was a Notice of Violation.

On August 16, 1988, per a telephone conversation with Mr. R. F. Warnick, we requested and received an extension for NOV Item A (445/8846-V-01; '

446/8844-V-01) until September 6, 1988.

l l We hereby respond to Item B (445/8846-V-02) to the Notice of Violation in the attachment to this letter.

Very truly yours.

/$ 6

. G. Counsil RDD/grr c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)

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Attachment to TXX-88623 August 22, 1988 Page 1 of 3 NOTICE OF VIOLATION ITEM A (4457BT46-V 0ll 44678844-V-01) ,

A. Criterion V of Appendix B to 10 CFR 50, as implemented by Section 5.0, .

Revision 0, of the TV Electric Quality Assurance Manual requires that activities af fecting quality shall be prescribed by documented instructions, procedures, or drawings appropriate to the circumstances in i order to provide assurance that those activities have been satisfactorily l accomplished. -

Centrary to the above, due to an error resulting from Revision 3 of /

MMI-904, "Steam Generator Manway Removal and Replacement," paragraph 5.3.10 specifies installation torquing requirements which deviate from the NSSS vendors recommendations. MMI-904, Revision 3, requires a three-step . __.

torquing sequence (125, 300, 450 ft./lbs), removal af one bolt at a time ""

for lubrication, then reinstallation of the bolt and torquing to 300 ft./lbs. After all the bolts are lubricated and torqued to 300 ftT71bs.. ~

all bolts are to be retorqued to 450 ft./lbs. Westinghouse Technical Bulletin NSID-TB-87-01 requires thF same three-step torquing sequence; then removal, relubrication, and retorquing of each bolt to 450 ft./lbs.

Common industry practice is to discard and replace a flexatalTic gasket after one compression cycle has been experienced. The error in Revision 3 of W41-904 resulted in quality control acceptance of the torquing of high pressure flanged connections on Unit 2 steam generators which may result in the connections not performing their intended safety related function (445/8846-V-01; 446/8844-V-01).

Resp 0NSE TO NOTICE OF VIOLATION 1IEFAl4'457B846V-01;44678844T01).

Response to be provided by September 6, 1988, f

4

Attachment to TXX-88623 August 22, 1988

, Page 2 of 3 NOTICE OF VIOLATION 1fUT(445788457-T2)

B. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3 of the TV Electric Quality Ast,urance Plan, states, in part, "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, or a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings . . .

Specificatior. 2323-55-168, "Structural Steel / Miscellaneous Steel,"

Appendix B, Section 111, paragraph 4.5.1 states, in part, "Verify the acceptability of the support in accordance with the design document, along with all drawing sections, plans, elevation and views "

Procedure il0A 3.09-10.01, "Requirements for Visual Weld Inspection," which goverr,s weld inspections for conduit supports, paragraph 6.3.3.3.2.i states, in part, "The length and 1ccation of welds shall be as specified on the detail drawing . . ."

l Contrary to the above, on support IN-C04G31220-51, the design drawing locates this support 4' - 1" south of the centerline of column No. 3703.

The NRC inspector measured the location to be 3' - 8" south of this I column. Also, on this support, the drawing requires two flare bevel groove welds and two 1/4" fillet welds between a section of 3" x 3" structural tubino and the existing structural framing at each er.d of the tube steel. Honever, the NRC inspector's review revealed that the 1/4" l fillet welds were missing at each end of the tubing and this condition was not noted during the final QC inspection. (445/8845-V-02)

RESPONSE TO NOTICE OF VIOLATION ITEM B (445788~46-V-02)

TV Electric agrees with the alleged violation and the reauested information follows:

1. Reason for Violation The violation resulted from an oversight by the QC inspector during final inspection of the conduit support configuration.

2. Co_rrective Steps Taken and Results Achieved NCR 88-11586 was issued and dispositioned to use the support "as-is." As stated in DCA 60745, Rev. I and the associated calculation IN-C04G31220-51, Rev. 01, the as-built weld is acceptable and the dimensional changes will have no impact on the structural adequacy of the support.

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- Attachment to TXX-88623 August 22, 1988 Page 3 of 3 RESPONSE TO NOTICE OF VIOLATION (CONT'D)

ITEM 8 (445/8846-V-02)

2. Corrective Steps Taken and Results Achieved (cont'd)

Information obtained from the QA Inspection Surveillance Vait indicates that surveillance overview has been performed on the QC inspector of record since March, 1986. An evaluation of the surveillance results reveals that out of a total of 3,080 checklist attributes verified to date by surveillance, only 20 (0.6%) were found to be unsatisfactory.

Therefore, we consider this error by the inspector to be an isolated -

occurrence.

3. Corrective Steps Which Will be Taken to Avoid Further Violations The QC inspector has been made aware of his error.

4. Date When Full Compliance Will be Achieved Full compliance has been achieved.

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