ML20196C423

Forwards Revised Response to NRC 870911 Notice of Deviation, Item E as Noted in Insp Rept 50-445/86-07.Corrective Actions:Procedure CP-QAP-16.1 Revised,Including Block on Ncr Form Identifying Evaluations Per 10CFR50.55(e)

ML20196C423
Person / Time
Site:	Comanche Peak
Issue date:	06/22/1988
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-88527, NUDOCS 8807010091
Download: ML20196C423 (4)

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Log # TXX-88527 C. - File # 10130 Z Z Ref. # 10CFR2.201 TUELECTRIC June 22, 1988

. %illiam G. Counsil bemive Vwe Preaten-V. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-4 M AND 50-446 REVISED RESPONSE TO NOTICE OF DEVIATION ITEM E (445/8607-D-01)

REF: 1) TV Electric Letter TXX-6222 from W. G. Counsil to USNRC dated February 18, 1987

2) TV Electric Letter TXX-6526 from W. G. Counsil to USNRC dated July 1, 1987 3)' USNRC Letter dated September 11, 1987 from R. F. Warnick to W. G. Counsil Dockets 50-445/87-07 and 50-446/87-05 Gentlemen:

Reference (1) transmitted our response to Notice of Deviation Item E, 445/8607-D-01. Reference (2) transmitted our interim report concerning SDAR CP-83-08. Reference (3) transmitted your re regarding statements made in References (1) andquest (2). for additional information Reference (1) stated that the welding on the subject brackets had been determined to be acceptable. Reference (1) also stated that our correspondence pertaining to SDAR CP-83-08 (TXX-3657) would be supplemented to document why lack of welding documentation does not constitute a significant condition adverse to quality. These statements were made based on the disposition of Nonconformance Reports (NCR) M-9575 through -9636. These NCRs identified a lack of documented evidence of welding acceptability and bracket material for ASME certification. The welds and brackets were determined to be outside the ASME N-5 bon dary; therefore, documentation to support ASME N-5 certification of the brackets and welds was not required and on that basis the NCRs were dispositioned use-as-is. The Certificate of Conforma'ce which had been provided by the vendor (Fisher Controls Company) was judged to be sufficient to accept the valves and brackets for seismic qualification. It was our belief that the subject brackets and welds were acceptable based on the vendor supplied documentation.

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TXX-88527 June 22, 1988 Page 2 of 2 Reference (2) contained the following statements:

"The clip [ bracket] was procured by Fisher Control in accordance with their QA Program. The welding of the clips [ brackets] to the skirt

[ actuator] was aerformed by qualified welders to qualified welding procedures, witi qualified filler material-and in accordance with the Fisher Control QA Program (for ASME Section IX). The welds were inspected per the Fisher Control QA Program and released under the Vendor Control Program.

Compliance with the requirements of the component design specification, and seismic qualification was certified by Fisher Control."

These statements were made based on the disposition of NCRs M-9575 through

-9636. Subsequently, additional concerns regarding the subject brackets have been identified. These concerns and our planned actions are discussed in an update to SDAR CP-83-08 (TXX-88526 dated June 22,1988).

Reference (1) also included a discussion in our actions regarding the technical adequacy of NCR dispositions as documented in Significant Deficiency Analysis Report (SDAR) CP-86-48. Our actions relative to SDAR CP-86-48 are discussed in separate correspondence. We have made programmatic changes that should prevent recurrence of this Deviation. Improvements have been made in our 10CFR50.55(e) reportability program, nonconformance control program, and commitment tracking methods which provide assurance that commitments to the NRC are tracked and are either met or modified via docketed correspondence.

Our response to Notice of Deviation Item E (445/8607-D-01) is hereby revised to reflect the above considerations. The changed portions of the text are indicated by revision bars in the right margin.

Very truly yours,

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

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Attachment to TXX-88527 June 22, 1988

. Page 1 of 2 NOTICE OF DEVIATION ITEM E (445/8607-0-01)

E. Section 16.0, Revision 0, of the TVGCo Quality Assurance Plan states, in part, "In the case of significant conditions adverse to the quality, which are reportable to NRC under the provisions of 10 CFR Part 50.55(e),

measures are taken to assure that the cause of the condition is determined and corrective action is implemented ...."

21, 1983, submitted to NRC in TVGCo Letter accordance TXX-3657 with dated Ap)ril 10 CFR 50.55(e , identified a significant condition adverse to quality (no objective evidence is available documenting acceptable weld quality on seismic arrestor brackets) and stated that the corrective actions would be to discard and replace the arrestor brackets, and that the corrective action would proceed immediately.

In deviation fron the above, the committed corrective actions had not been implemented as of the end of this inspection perioo (445/8607-0-01).

RESPONSE TO ITEM E (445/8607-0-01)

We admit the deviation and the requested information follows.

1. Reason for Deviation Subsequent to issuance of TV Electric Letter TXX-3657, the NCRs documenting bracket welding documentation deficiencies were revised and dispositioned "use-as-is" because the brackets were judged to be outside the ASME N-5 certified boundary. However, the NCR form then in use per Construction Procedure CP-QAP-16.1, Rev. 17, "Control of Nonconforming items," did not contain provisions to indicate whether or not the "nonconforming condition" had been judged to be reportable per 10CFR50.55(e) or 10CFR21. Consequently, the engineer who specified the "use-as-is" disposition on the revised NCRs was not aware that the "Nonconforming condition" had been re)orted to the NRC and that TV Electric had committed to replacing t1e subject brackets.

2. Corrective Steps Taken and Results Achieved The absence of ASME documentation has been determined to be acceptable.

Other aspects of bracket weld acceptability are documented in TV Electric letter TXX-88526 dated June 27, 1988.

Attachment to TXX-88527

.- June 22, 1988 Page 2 of 2

3. Corrective Steps Which Will Be Taken To Avoid Further Deviation Provisions to prevent recurrence of these conditions were implemented by revision to procedure CP-QAP-16.1 (Rev. 25, dated September 12,1985).

These provisions consisted of includina a block on the NCR form which identified the evaluations conducted pu%uant to 10CFR50.55(e). In providing this identification, dccketed commitments can be considered in subsequent revisions to the NCR (procedure CP-QAP-16.1 has since been

.aplaced by procedure AAP-16.1). Corporate procedures NE0 3.05, "Reporting and Control of Nonconformances" and NE0 9.01, "Evaluation and Reporting of Adverse Conditions Under 10CFR21 and 10CFR50.55(e)" have been issued. These. procedures provide increased assurance that nonconformances are promptly reviewed for reportability and that connitments made to the NRC pertaining to recortable items are tracked and either met or modified via docketed cor espondence. Our commitment tracking mechanisms have also been improved and a sitewide connitment tracking system is being implemented.

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

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