ML20205H226
| ML20205H226 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/25/1987 |
| From: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8704010001 | |
| Download: ML20205H226 (3) | |
See also: IR 05000445/1986003
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WR 2 51987
In Reply Refer To:
Dockets: 50-445/86-03
50-446/86-02
TV Electric
ATTN: Mr. W. G. Counsil
Executive Vice President
400 North Olive, L.B. 81
Dallas, Texas
75201
Gentlemen:
Thank you for your letters of January 12, 1987 and March 12, 1987, in response
to our letter dated October 17, 1986. As a result of our review, we find that
additional information, with respect to Items D. I and E in the Notice of
Violation (N0V) and Item B in the Notice of Deviation (N00) is needed.
Specifically, for NOV, Item D.1, you did not address whether or not a review
was performed with respect to the support analysis (No. 01-CSM-2a-II on
conduit No. C23G04066) to assure that the reduced support capacity was
considered.
Please piv/ide us with this information.
For NOV, Item E, it was identified that subsequent to your letter dated
January 12, 1987, additional HVAC organization realignment occurred.
This
action affects your response provided in Item e, of paragraph 3., " Action to
Prevent Recurrence." Please provide the changes caused by this realignment with
respect to the Unit 2 HVAC support field verification program.
For N0D, item 0, base material defect inspection was not identified as an
attribute to be excluded as is required by ERC CPP-007.
Your response that
accurate reinspection cannot be performed following application of coatings is
not consistent with your position regarding inspection for weld defects
through paint.
Inspection of welds in the coated condition and after removal
of the coating was successfully demonstrated by ERC using QI-062. The
observed condition became acceptable in accordance with Ql-QAP-11.1-28 only
after the issuance of DCA-41710 which clarified acceptance criteria.
Therefore, please respond to the deviation as originally requested.
Your response to N00, Items C and D indicates disagreement with the stated
deviations. We have reviewed the additional information you have provided and
have inspected further the as-built condition of Verification Package
1-S-HVDS-075. Based on this review and further inspection, we agree that the
stated deviations did not occur and are withdrawing them.
We have no further questions regarding NOV. Items A, B, C, D.2, F, G, I, and
N00, items A and E, and will review your corrective actions during a future
inspection.
A
RIV/CPTG
CPTG 56
DRSP
(EEllersHw:gb
IUarnes
EHJohnson
3d2/87
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$/gtl/87
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0704010001 070325
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ADOCK 05000445
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TU Electric
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With respect to NOV, Item H, the response time was extended until April 10
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1987.
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Please provide the supplemental information within 20 days of the
date of this letter.
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Sincerely.
,
orlatna! $tened 8y
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E. H. Johnson
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E. H. Johnson, Director
Division of Reactor Safety
and Projects
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CC:
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TU Electric
ATTN:
G. S. Keeley Manager
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Nuclear Licensing
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Skyway Tower
400 North Olive Street
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Lock Box 81
Dallas. Texas
75201
)
Juanita Ellis
President - CASE
1426 South Folk Street
Dallas. Texas
75224
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Renea Hicks
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Assistant Attorney General
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Environmental Protection Division
P. O. Box 12548
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78711-2548
Administrative Judge Peter Bloch
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U.S. Nuclear Pequiatory Comission
Washington, D.C.
20555
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Elizabeth B. Johnson
Administrative Judge
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Oak Ridge National Laboratory
P. O. Box X. Building 3500
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Oak Ridge. Tennessee
37830
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Dr. Kenneth A. McCollom
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1107 West Kna)p
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Stillwater. 0(lahoma
74075
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TU Electric
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Dr. Walter H. Jordan
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E81 Outer Drive
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Cak Ridge, Tennessee
37830
Anthony Roisman, Esq.
Executive Director
Trial Lawyers for Public Justice
2000 P. Street, N.W. Suite 611
Washington, D.C.
20036
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Texas Radiation Control Program Director
bectoDMB(IE01)
bec distrib, by RIV:
- RPB
- MIS System
[
- RRI-OPS
- RSTS Operator
- RRI-CONST
- R&SPB
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- T. F. Westerman, RSB
DRSP
V. Nocnan, NRR
R. Martin, RA
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L. Chandler, OGC
- RSB
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- RIV File
J. Taylor, IE
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- D. Weiss, RM/ALF
J. Conklin, IE
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- I. Barnes, CPTG
- Project Inspector
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- R. Hall
- w/766
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Log # TXX-6089
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File # 10130
IR 86-03
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TEXAS UTILITIES GENERATING COMPANY
86-02
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SKYWAY TOWER . 400 NORTH OLIVE ErTREET, l.B. 88 . DALLAS, TEXA5 78208
January 12, 1987
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Mr. Eric H. Johnson
Division of Reactor Safety and Projects
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U. S. Nuclear Regulatory Commission
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611 Ryan Plaza Drive, Suite 1000
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Arlington, Texas 76011
SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446
RESPONSE TO NRC NOTICE OF VIOLATIO1 AND
NOTICE OF DEVIATION INSPECTION REPORT NOS. 50-445/86-03
AND 50-446/86-02
Dear Mr. Johnson:
We have reviewed your letter dated October 17, 1986, concerning the inspection
conducted by Mr. I. Barnes and other members of the Region IV Comanche Peak
Group during the period December 11, 1985, through March 31, 1986.
This
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inspection covered activities authorized by NRC Construction Permits CPPR-126
and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2.
Attached
to your letter were Notices of Violation and Notices of Deviation.
On November 14, 1986, per a telecon with your Mr. T. Westerman, we requested
and received a three week extension.
On December 5, 1986, we requested and
received a two week extension and on December 19, 1986, we requested and
received a three week extension. On January 9, 1987, per a telecon with your
Mr. D. Hunnicutt, we requested and received a three day extension.
We hereby respond to the Notices of Violation and Notices of Deviation in the
attachments to this letter.
Very truly yours,
h
unJ5f
W. G. Counsil
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By:
G. S. Keeley
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Manager,NuclearLiceYsing
GLB/gj
Attachments
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IF
January 9, 1987
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Page 2 of 2
c - Region IV (Original + 1 copy)
Director, Inspection and Enforcement (15 copies)
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U. S. Nuclear Regulatory Comission
Washington, D. C.
20555
Mr. V. S. Noonan
Mr. D. L. Kelley
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Attachment 1
ITEM A (446/8602-V-08)
A.
Criterion V of Appendix B to 10 CFR Part 50, as implemented
by Section 5.0, Revision 3, dated July 31, 1984, of the TUGCo Quality
Assurance Plan (QAP), requires that activities affecting quality shall be
prescribed by and accomplished in accordance with documented instructions,
procedures, or drawings.
Paragraph 2.5 of TUGCo Procedure CP-EP-4.6, " Field Design Change Control,"
Revision 10, dated April 16, 1984, states, in part, " Design
changes / deviations to specified engineering documents shall be documented
by revision initiated by an Engineering Change Request (ECR), a Design
Change Authorization (DCA) or a Component Modification Card (CMC)." DCA
18,016 required removal of wire strands using a wire stripper to reduce
wire size from #16AWG to #18AWG.
Contrary to the above, wire size reductions were implemented for Unit 2
termination cabinets, 2-TC22 and 2-TC23, by construction operation
travelers in a manner different than specified on DCA 18,016; no revision
to the DCA had been initiated, nor were either an ECR or CMC initiated.
RESPONSE TO ITEM A (446/8602-V-08)
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1.
Reason for the Violation:
We admit to the alleged violation for the reasons that follow.
A DCA is not intended or required to show the specific process for
implementing the change. Consequently when the traveler was. prepared, no
review of the DCA was considered resulting in an alternate method being
utilized.
2.
Corrective Actions Taken:
The DCA (No. 18,016) was revised to delete the specifics regarding wire
size reduction. Also, to ensure the method used was acceptable, an
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engineering evaluation was performed on the cable in question with no
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adverse effects regarding resistance, etc. being found.
3.
Action to Prevent Recurrence:
The procedure CP-CPM 6.3 defines the traveler program and will be revised
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to require that a review of the DCA be conducted prior to the traveler
being issued to ensure that if the DCA data contain specifics they are
incorporated into the traveler.
4.
Date of como11ance:
The revision to the procedure will be issued by January 9, 1987.
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Attachment 1
Page 2 of 22.
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ITEM B (446/8602-V-06)
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B.
Criterion XVI of Appendix B to 10 CFR Part 50, as implemented by Section
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16.0, Revision 0, dated July 1,1978, of the TUGC0 QAP, states, in part,
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" Measures shall be established to assure that conditions adverse to
quality, such as . . . deficiencies, deviations . . . are promptly
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identified and corrected."
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Contrary to the above, the measures established did not assure that the
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following described condition adverse to quality was promptly identified
or promptly corrected. The NRC inspector reviewed a sample of 70 Sample
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Recheck Request / Report forms, completed by the Inspection Process Control
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(IPC) group since July 1985, and identified 80 examples where QC
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inspectors had entered " SAT" inspection attributes in inspection reports
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where "NA" (i.e., not applicable) was the correct entry.
This condition
was identified in the monthly IPC reports beginning with the September
report dated October 11, 1985. Subsequent IPC reports (October and
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November) characterized this condition as both "a generic problem" and a
significant deficiency and requested that corrective action be taken as
early as December 13, 1985. However, no apparent action has been taken to
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establish how long this condition may have existed before September 1985
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nor has corrective action, in a generic sense, been taken.
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RESPONSE TO ITEM B (446/8602-V-06)
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Reason for the Violation
We admit to the alleged violation for the reascns that follow.
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The practice of entering " Sat" on Inspection Report (IR) attributes when
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the attribute has more appropriately "N/A" was implemented due to
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instructions given to QC Inspectors by a field QC Supervisor. The
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supervisor instructed his subordinate inspectors to status all IR
attributes as " Sat" whenever the attribute was not unsatisfactory. The
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practice was considered acceptable by the supervisor since it could not
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lead to describing an unsatisfactory attribute as satisfactory. This
action was taken to avoid the incorrect use of "N/A" when " Sat" or "Unsat"
was more appropriate. Since the practice was not implemented by all
supervisors, inconsistent documentation resulted.
For example, when only
one hilti bolt was located in a room or area, the minimum spacing to other
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hilti's was considered " Sat" by some QC Inspectors and "N/A" by other
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inspectors.
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The IPC program identified examples where IPC personnel considered the
" Sat" status of these IR attributes to be unacceptable, even though
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unsatisfactory installations were not identified. These items were
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reported as unsatisfactory on Surveillance Recheck / Request Report (SRRR).
QE reviewed SRRRs on an ongoing basis as surveillances were completed and
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the reports received. As stated in the details of the NRC IR, QE
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concluded that the entry of " Sat" when N/A was applicable, did not render
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the quality of the item unacce> table and, therefore, did not warrant NCR
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issuance. This practice was,
iowever, considered undesirable from a
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consistent documentation standpoint. This view was shared by QC
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Nanagements however, since nonconforming conditions were not involved,
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actions to resolve the inconsistency in documentation practices was not
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promptly initiated.
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Attachment 1
Page 3 of 22
ITEM B (446/8602-V-06) CONT'D
RESPONSE TO ITEM B (446/8602-V-06) CONT'D
2.
Corrective Action Taken
Actions taken to resolve inconsistent IR completion involved informal
training of QC Inspectors at the request of the Site QC Supervisor (letter
TUQ-3511 dated 12/10/85). This request emphasized the need to assure
consistent entry of " Sat /Unsat" vs. "N/A" or irs based on the October 1985
IPC Report. As this instruction was not totally effective in resolving
the inconsistencies, formal classroom training was initiated in February
1986 and completed in May 1986.
It was not and is not considered
necessary to determine the extent or duration this inconsistency existed
since the issue involves inconsistent IR completion only, and does not
alter the status of QC accepted items.
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3.
Action to Prevent Recurrence
The training described above should prevent recurrence of this violation.
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Ongoing Quality surveillances and trending would identify further
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inconsistencies of this nature. The Surveillance Inspection program in
effect since January 1986, has not identified further inconsistencies of
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this type.
4.
Date of Comoliance
CPSES is currently in full compliance.
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Attachment-1
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Page 4 of 22
ITEM C (446/8602-V-20)
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Criterion X of Appendix B to 10 CFR Part 50, as implemented
C.
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by Section 10.0, Revision 1, dated July 31, 1984, of the TUGC0 QAP,
states, in part, "A program for inspection of activities affecting quality
shall be established and executed . . . to verify conformance with the
documented instructions, procedures, and drawings for accomplishing the
activity."
Contrary to the above, the following conditions which had been inspected
and accepted by the applicant's inspection program, were identified as
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being nonconforming during independent inspection of Unit 2 conduit
supports:
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1.
Section 3.3.1 in Revision 7 of TUGC0 Instruction QI-QP-11.10.1A
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states, in part, "The QC inspector shall inspect the support for
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the following: Member (s) shape . . . size and dimensions."
Inspection revealed a 1/2" thick shim plate installation on one
support and a 5/8" thick shim plate installation on another
support for which the applicable drawings required the use of a
5/8" thick and 1" thick shim plate, respectively.
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2.
Section 3.5.1 in TUGC0 Instruction QI-QP-11.10-1A, Revision 7,
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states, in part, " Conduit spans shall be as indicated on the
isometric draw
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Conduit span Tolerance is +/-3
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(inches).
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Inspection revealed a measured span length of one conduit run as
being 3/4" over the allowable tolerance shown on the isometric
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drawing.
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3.
Section 3.4 in Revision 20 of TUGC0 Instruction QI-QP-11.2-1
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specifies that where embedded plates are occupied by attachments
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within 12" of a Hilti, the minimum clearance between a 3/8" and
1/2" Hilti bolt and a Nelson stud will be 5-7/8" and 6-1/2",
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respectively.
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Ins)ection revealed two supports in which the Hilti bolts were
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wit 11n 12" of an attachment but the minimum clearances between a
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3/8" and 1/2" Hilti bolt and the Nelson studs were 5 3/8" and 4-
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3/8",respectively,
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4.
Section 3.2.3 in Revision 7 of TUGC0 Instruction QI-QP-11.10-1A
states, in part, "Each support inspected on a raceway system shall
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be assigned a number shown on the engineering isometric drawing
included in the conduit system work packages. . . ."
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Inspection revealed one support in which its identification number
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did not match the applicable isometric drawing support
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identification number.
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Attachment 1
Page 5 of 22
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ITEM C (446/8602-V-20) CONT'D
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5.
Section 3.9 in Revision 7 of TUGC0 Instruction QI-QP-11.10-1A
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states, in part, "The QC Inspector shall verify the conduit
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supports have been installed in accordance with the requirements
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of the isometric drawing . . . ." It further requires the use of
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an inspection report to document inspection results. Step (V) 1.b
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in the inspection report states, " Verify conduit configuration."
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Inspection revealed a conduit span bend opposite to that which was
shown on the applicable isometric drawing, and step (V)1.b had
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been signed off as being acceptable.
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RESPONSE TO ITEM C (8602-V-20)
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1.
Reason for the Violation:
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We admit to this alleged violation for the reasons that follow.
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This violation is a result of isolated QC Inspector errors.
Inaccurate
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dimensional measurements were made along with the misidentification of a
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conduit support during the inspection verification process. The
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deficiencies involved seven separate attributes identified in 234 conduit
supports.
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2.
Corrective Action Taken:
NCRs were initiated for each of the nonconforming conditions identified in
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this violation.
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3.
Action to Prevent Recurrence:
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Each of the QC Inspectors involved with acceptance of the discrepant
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installations identified have been made aware of their errors. To
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determine the need for further corrective action, the performance of these
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inspectors was evaluated through review of Quality Surveillance
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reinspection results. Based on this review it has been determined that
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the involved inspectors have demonstrated a high degree of accuracy in the
performance of inspections and that no further corrective action is
needed.
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4.
Date of Comoliance:
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The compliance will be achieved when the NCRs are closed.
It is
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anticipated that these NCRs will be closed by February 23, 1987.
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Attachment 1
Page 6 of 22
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ITEM D (446/8602-V-21)
D.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section
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5.0, Revision 3, of the Tugco QAP, requires that activities affecting
quality shall be prescribed by and accomplished in accordance with
documented instructions, procedures, or drawings.
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Contrary to the above, the following conditions were identified with
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respect to Unit 2 conduit supports in which the prescribed activities were
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not accomplished:
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1.
Section 2.4 in Tugco Procedure TNL-AB-CS-2, Revision 0, states, in
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part, "The Field Engineer shall prepare a field isometric
indicating the general routing and location of supports, and . . .
shall include span lengths and configurations . . . decision
,
points and locations . . . . Decision points are considered as
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places on a typical drawing for which two or more options are
acceptable for the same location."
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Independent inspection revealed a decision point which had not
been included in the isometric drawing by the Field Engineer. One
support was observed in which a 3/8" Hilti bolt had been
installed. The applicable typical drawing specified a 1/2" Hilti
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bolt with the option of using a 3/8" Hilti bolt, provided the
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support capacity was reduced. The absence of this information
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could possibly preclude the required reduction in support capacity
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by the Design Engineer.
RESPONSE TO ITEM D.1 (446/8602-V-21)
1.
Reason for the Violation
We admit to the alleged violation for the reasons that follow.
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Due to an unclear note (No. 4) on drawing 2323-S2-0910, Sh. CSM-2a-II,
Rev. 3, engineering walkdown failed to identify the 3/8" Hilti-Kwik Bolt
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(HKB) on the isometric drawing.
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2.
Corrective Action Taken
The isometric drawing no. 2323-S2-0910, Sh. 04066, Sk.01 has been revised
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to show the 3/8" HKB.
3.
Action to Prevent Recurrence
Note 4 on drawing 2323-S2-0910, Sh. CSM-2a-II has been rewritten to state,
in part, ".. 3/8" Hilti-Kwik bolt may be used for 2" diameter thru 5"
diameter conduit only where specified on the isometric or individual
support drawing," (change will be incorporated on Rev. 5) per disposition
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of NCR #M-86-201023, Rev. 1.
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Attachment I
Page 7 of 22
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ITEM D (446/8602-V-21) CONT'D
RESPONSE TO ITEM D.1 (446/8602-V-21) CONT'D
3.
Action to Prevent Recurrence (Cont'd)
NCR #M-86-201023 will specify listing of all CSM-2a-II supports used on 2"
thru 5" diameter conduit and reinspection to verify that:
a.
1/2" HKB are used, or
b.
3/8" HKB are used and are shown on the isometric or individual
support drawing.
No further action is necessary to prevent recurrence.
4.
Date of Comoliance
Compliance will be achieved when NCR #M-86-201023 is closed.
It is
anticipated that the NCR will be closed by March 15, 1987.
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Attachment 1
Page 8 of 22
ITEM D (446/8602-V-21) CONT'D
D.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section
5.0, Revision 3, of the Tugco QAP, requires that activities affecting
quality shall be prescribed by and accomplished in accordance with
documented instructions, procedures, or drawings.
Contrary to the above, the following conditions were identified with
respect to Unit 2 conduit supports in which the prescribed activities were
not accomplished:
2.
Section 3.3.1.1 in Revision 14 of Tugco Instruction QI-QP-11.21-1
requires that the welding symbol for an intermittent fillet weld
be in accordance with standard welding symbols of AWS 2.4-79.
Inspection revealed the existence of intermittent fillet welds on
11 conduit supports in which the applicable, typical support
drawing did not depict an intermittent fillet weld symbol.
RESPONSE TO ITEM 0.2 (446/8602-V-21)
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1.
Reason for the Violation
We admit to the alleged violation for the reasons that follow.
The typical support drawing detail CSM-6C-I depicts an intermittent fillet
weld utilizing the dimensional / hatching method in lieu of providing the
applicable information within the welding symbol. This method of
detailing welding requirements is recognized by AWS 2.4-79, paragraph
4.4.1.
Although TUGC0 Instruction QI-QP-11.21-1, Revision 14 states that
the standard welding symbols will be in accordance with AWS 2.4-79, the
procedure does not explicitly address the acceptable practice of utilizing
the dimensional / hatching method. Only examples of commonly used standard
welding symbols from AWS 2.4-79 are referenced. Additionally, weld
lengths and locations are as depicted on CSM-6C-I.
2.
Corrective Action Taken
It has been the intent of the procedure to include some of the most
commonly used weld symbols to facilitate the inspection process, not to
include all possible weld symbols from AWS criteria which may be used.
TUGC0 Instruction QI-QP-11.21-1 will be clarified to state that standard
welding symbols as referenced in the procedure are only " typical" as
allowed by AWS 2.4-79.
Additionally, a subsequent revision of drawing
2323-S2-0910 sheet CSM-6C-I, more clearly depicts the weld location using
the dimensional / hatching method described above.
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Attachment 1
Page 9 of 22
ITEM D (446/8602-V-21) CONT'D
RESPONSE TO ITEM D.2 (446/8602-V-21) CONT'D
2.
Corrective Action Taken Cont'd
Concurrently, an engineering evaluation was conducted with the following
results:
Due to the generic nature of drawing 2323-S2-0910, Sh. CSM-6C-I, Rev. 3,
the plate size (at the welds in question) can vary up to l'-6" max.
In
order to accurately communicate the welding requirements for this joint
design, the engineer utilized the weld symbol to specify the weld size and
minimum length. The typical centerline for acceptable weld spacing for
this generic application was identified separately on the sheet. This is
an acceptable industry practice which meets the intent of AWS 2.4-79.
To assure that the engineering requirements were met during installation,
as-built sketches were made of the eleven (11) supports identified in the
NRC report. An engineering evaluation of these as-builts has verified
that all eleven are in compliance with the welding requirements specified
by this typical drawing.
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3.
Action to Prevent Recurrence
The revision of QI-QP-11.21-1 as addressed in the Corrective Action taken
will prevent recurrence of this condition.
4.
Date of Comoliance
QI-QP-11.21-1, Revision 17 will be revised by January 30, 1987.
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Attachment 1
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Page 10 of 22
ITEM E (446/8602-V-17)
E.
Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section
10.0, Revision 1, dated July 31, 1984, of the TUGC0 QAP, states, in part,
"A program for inspection of activities affecting quality shall be
established and executed . . . to verify conformance with the documented
instructions, procedures, and drawings for accomplishing the activity."
Contrary to the above, the following examples from Unit 2 HVAC duct
support inspections were observed where the Bahnson inspection program
failed to identify nonconformances with the documented instructions,
procedures, and drawings:
1.
Section 9.1 in Revision 1 of Bahnson Procedure WP-TUSI-001 states,
in part, with respect to intermittent welds, " Weld increments-
shall begin and terminate within 1/8" of the ends of the joints or
length . . . ." Seven HVAC duct supports, however, inspected by
the NRC had intermittent fillet welds which did not begin or
terminate within 1/8" of the ends of the joints.
2.
Section 6.5 in Revision 5 of Bahnson Procedure QCI-CPSES-011
states, in part, with respect to welding, "The Quality
Representative shall make certain that the size, length, and
.
location of all welds conform to the requirements of QCI-CPSES-014
and DFP-TUSI-003, and to the detailed drawing . . . ."
Independent inspection identified the following conditions in
three HVAC duct supports:
a.
A 2" long, 1/4" fillet weld required by the drawing was
measured as being 1/8" for the full length,
b.
Two, 2-1/2" long,1/8" fillet welds required by the
drawing between the two lateral braces and the main
support were missing.
c.
Two,1-1/2" long,1/8" fillet welds required by the
drawing were measured as being 1-1/4" long.
3.
Section 6.6 in Revision 5 of Bahnson Procedure QCI-CPSES-011
states, in part, " Weld profiles shall meet the following
requirements:
The faces of fillet welds may be slightly convex, flat, or
slightly concave . . . Welds shall be visually examined to
determine if the following defects are evident:
...
Undercut shall not exceed 1/32" for materials thicker than
1/4"."
One support was identified in which two welds exhibited 1/16"
undercut for 50 percent of the weld lengths on members which were
1/2" thick. The support also had a 1/4" and a 3/8" weld in which
grinding of the weld produced excess convexity, resulting in an
unacceptable weld profile.
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.
=
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.-
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_
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Attachment 1
Page 11 of 22
4
ITEM E (446/8602-V-17) CONT'D
l
4.
Note 2 in Attachment 4 of Revision 10 to Bahnson DFP-TUSI-004
states, in part, "Where the embedded steel plates are occupied by
,
attachments within the minimum distance shown above (12"), the
i
minimum clearance from 1" Hilti anchors to . . . the edge of the
!
embedded plate and only 3/8" from the edge.
RESPONSE TO ITEM E (446/8602-V-17)
i
1.
Reason for the Violation
j
We admit to the alleged violation for the reasons that follow.
Our review indicates the violation occurred as a result of inadequate
implementation of procedures on the part of the HVAC contractor charged
with the responsibility for design, fabrication, and QC activitie:;.
2.
Corrective Action Taken
!
For each specific discrepancy noted in the Violation, a nonconformance
!
report (NCR) or Deficiency and Disposition Report (DDR) has been issued
,
for evaluation and disposition.
Note, as indicated in paragraph 3, the engineering responsibility for this
area has been reassigned. DDR's are the technical nonconformance
i
documents used by the current responsible architect / engineering
!
contractor.
i
j
3.
Action to Prevent Recurrence
!
In order to correct the conditions noted in this violation the following
corrective measures are being implemented:
j
a.
The project organization and responsibilities for Unit I and
i
Common HVAC activities have been realigned.
Engineering and QC
!
activities previously performed by Bahnson have been assumed by
l
Ebasco and TUGCO, respectively.
!
b.
Field verification efforts include all Unit I and Common Seismic
j
Category I duct supports.
,
!
c.
Engineering evaluations will be performed to ensure compliance
l
with FSAR commitments.
!
d.
Construction rework will be performed, as deemed necessary, by the
engineering evaluations of field verified information to assure
compliance with FSAR criteria for the affected supports.
.
I
l
e.
To assure Unit 2 installations comply with prescribed
requirements, Unit 2 HVAC supports will be field verified. The
'
as-built effort will be conducted by Bahnson, with QC verification
by TUGCO.
Ebasco has been given responsibility for the adequacy
of the as-built verification effort and design.
All discrepancies will be documented by Nonconformance Reports.
_
_ _ _ _ _ _ _ - - .
.
.
. . .
.
i
,
,
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Attachment 1
Page 12 of 22
ITEM E (446/8602-V-17) CONT'D
RESPONSE TO ITEM E (446/8602-V-17) CONT'D
-
4.
Date of Comoliance
The procedure revisions and retraining were completed December 31, 1986.
The balance of preventative actions will be completed by May 1987 for Unit
I and September 1987 for Unit 2.
,
o
!
!
,
4
1
l
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0
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,
.
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Attachment 1
Page 13 of 22
ITEM F (445/8603-V-04)
F.
Criterion III of Appendix B to 10 CFR Part 50, as implemented by Section
3.0, Revision 4, dated November 20, 1985, of the Tugco QAP, states, in
part, " Measures shall be established to . . . include provisions to assure
that appropriate quality standards are specified and included in design
documents and that deviations from such standards are controlled . . . The
design control measures shall provide for verifying or checking the
adequacy of design . . . Design changes, including field changes, shall be
subject to design control measures commensurate with those applied to the
original design . . . ."
Contrary to the above, verification or checking of a design change,
initiated to resolve a deviation from design documents, did not assure the
adequacy of either the design change' or the disposition of the
nonconformance report (NCR) which documented the deviation. NCR M-80-
00161, initiated on November 6, 1980, addressed the drilling through of a
" probable" template bar, a rebar, and notching another rebar. The
disposition was "Use-As-Is" and referenced DCA No. 9091. The solution in
the DCA stated that, "The condition as described is acceptable." However,
the described condition addressed just one cut bar.
-
RESPONSE TO ITEM F (445/8603-V-04)
1.
Reason for the Violation
We admit the alleged violation for the reasons that follow.
The disposition of NCR M-80-00161 addressed authorization to cut a single
layer of concrete reinforcing steel. The disposition inadvertently failed
to address the remaining conditions due to the nature of the deviations
described as follows:
The bar cut at 2-1/2" depth is authorized by DCA 9091. The bar cut at 5-
1/2" depth is a template bar requiring no authorization for its cutting.
It has no structural significance and is used only for facilitating
installation. The template bar is a construction aide which does not (and
is not required to) appear on design drawings. Therefore, the cutting of
this bar is not a nonconforming condition. The bar notched at 7" depth is
the end of the tail of a bent bar. The cutting of such bars is
generically approved by DCA 243; no additional authorization is required
and hence this is not addressed in DCA 9091.
2.
Corrective Action Taken
NCR M-80-00161 was revised in April 1986 in order to reference the
information noted above.
>
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.
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Attachment 1
Page 14 of 22
ITEM F (445/8603-V-04) CONT'D
RESPONSE TO ITEM F (445/8603-V-04) CONT'D
3.
Action to Prevent Recurrence
The adequacy of nonconformance dispositions has been the issue of a site
initiated Corrective Action Request (CAR-062 dated March 4, 1986) and a
deficiency considered to be potentially reportable under the provisions of
10CFR50.55(e) (SDAR CP-86-48 dated June 16,1986).
The evaluation of these issues include,1) an assessment of the adequacy
of NCR dispositions, and 2) programmatic problems with revising NCRs.
A review of a random sample of NCRs has been conducted to determine the
safety significance of actions resulting from completed dispositions.
This review has provided a high degree of assurance of the adequacy of the
dispositions of NCRs at CPSES. To further ensure that safety concerns do
not exist, a review program encompassing technical review of all
previously closed NCRs with " void," " repair" or "use-as-is" dispositions
is planned.
,
In order to maintain a high degree of confidence that NCR dispositions
-
will not result in safety concerns, an interdiscipline review effort has
)
resulted in new corporate procedures for controlling nonconformances and
deficiencies.
4.
Date of Comoliance
The implementing procedures and the training of personnel on the new
procedures were completed December 22, 1986.
The NCR review program will
be completed by June 30, 1987.
l
.
'
.'
Attachment 1
Page 15 of 22
ITEM G (446/8602-V-14)
G.
Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section
10.0, Revision 1, dated July 31, 1984, of the Tugco QAP, states, in part,
"A Program for inspection of activities affecting quality shall be
established and executed . . . to verify conformance with the documented
instructions, procedures, and drawings for accomplishing the activity."
Paragraph 2.0 in Revision 0 to Tugco Procedure TNE-AB-CS-3 requires
walkdown drawings to reflect history and methodology to produce as-built
drawings.
It further requires the walkdown drawings to depict all the
necessary information required for subsequent QC verifications; i.e.,
support configuration dimensions and material sizes.
Paragraph 3.2.3 in Revision 5 to Tugco Instruction QI-QP-11.10-2A requires
the QC inspector to verify that the completed support is in accordance
with the as-built drawing.
Contrary to the above, the following conditions were identified with
respect to seven Unit 2 cable tray support drawings:
1.
Walkdown drawings neither depicted all required information nor
included correct dimensional information necessary for subsequent
~
QC verification.
RESPONSE TO ITEM G.1 (446/8602-V-14)
1.
Reason For the Violation
We admit to the alleged violation for the reasons that follow.
Review of the specific cable tray support installations noted in the
finding has indicated this condition is the result of errors in field
measurements obtained during the preparation of as-built drawings.
In one
instance (CTH-2-9774), the finding resulted from a weakness in the
inspection procedure.
2.
Corrective Action Taken
The following nonconformance reports were issued as a result of the
conditions noted in this violation:
1
!
,
. . , , . _.,
.
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-
-
n
._
_ _ . _ _ .
_ _ _ _ .
_
_
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.____ _
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Attachment 1
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'
Page 16 of 22
I
ITEM G (446/8602-V-14) CONT'D
J
RESPONSE TO ITEM G.1 (446/8602-V-14) CONT'D
Sunoort
NCR No.
Disposition
Closure
CTH-2-9774
M-85-201794 (12/17/85)
Revise procedure
08-01-86
QI-QP-11.10-2A,
Rev. 5
CTH-2-10264
M-85-201804 (12/17/85)
Revise drawing,
03-04-86
l
reinspect
l
CTH-2-10420
M-85-201805 (12/17/85)
Revise drawing,
03-24-86
reinspect
'
i
!
CTH-2-9850
M-85-201820 (12/18/85)
Revise drawing,
02-07-86
!
reinspect
CTH-2-11570
M-85-201802 (12/17/85) Revise drawing,
05-08-86
CTH-2-10119
M-85-201795 (12/17/85) Revise drawing,
03-08-86
l.
CTH-2-9825
M-85-201819 (12/10/85)
Revise drawing,
Superce-
i
i
reinspect
ded by
,
j
Rev. 1.
CTH-2-9825
M-85-201819 (02/14/86)
Revised drawing,
02-28-86
j
Rev. I
reinspect
i
!
Each specific finding (cable tray installation) has been documented by
l
nonconformance report (NCR).
Except for CTH-2-9774, disposition of the
NCRs resulted in revision to the drawing and re-inspection of the support.
For CTH-2-9774 (the support affected by the procedural weakness),
i
disposition of the nonconformance resulted in revision of the procedure
and re-inspection.
Additionally, since the preparation of the drawings noted in the findings,
classroom instruction and the application of proper measurement techniques
i
has been established as a prerequisite for engineering personnel involved
in the preparation of CTH drawings.
!
3.
Action to Prevent Recurrence
!
The only item of a recurring nature was as listed on NCR #M-85-201794
!
(CTH-2-9774).
Revision 06 of Procedure QI-QP-11.10-2A was issued on
j
2/24/86 and QC personnel were trained to this procedure revision.
!
4.
Date of Comoliance
Compliance has been achieved, as described above.
, . - __ - - - .. - _ _ _ -
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-
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Attachment 1
Page 17 of 22
ITEM G (446/8602-V-14) CONT'D
i
G.
Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section
10.0, Revision 1, dated July 31, 1984, of the TUGC0 QAP, states, in part,
" A Program for inspection of activities affecting quality shall be
4
,
l
established and executed . . . to verify conformance with the documented
'
i
instructions, procedures, and drawings for accomplishing the activity."
l
'
Paragraph 2.0 in Revision 0 to TUGC0 Procedure TNE-AB-CS-3 requires
i
walkdown drawings to reflect history and methodology to produce as-built
i
drawings.
It further. requires for subsequent QC verifications; i.e.,
i
support configuration dimensions and material sizes.
Paragraph 3.2.3 in Revision 5 to TUGC0 Instruction QI-QP-11.10-2A requires
!
the QC inspector to verify that the completed support is in accordance
with the as-built drawing.
Contrary to the above, the following conditions were identified with
,
respect to seven Unit 2 cable tray support drawings:
,
.
2.
QC inspectors accepted support dimensions which were different
1
i
from those specified on the walkdown drawings.
i
RESPONSE TO ITEM G.2 (446/8602-V-14)
!.
!
1.
Reason for Violation
We admit to the alleged violation for the reasons that follow.
i
With the exception of those discrepancies which pertain to supports CTH-2-
i
9774 and CTH-2-10420, the dimension verification discrepancies described
]
in this violation are the result of isolated QC Inspector errors. The
reason for the violations associated with supports CTH-2-9774 and CTH-2-
j
10420 are as follows:
1
For CTH-2-9774, the QC inspector was required by Quality Instructions to
!
verify that dimensions shown on "As-built" drawings were within the
j
tolerances specified in QI-QP-11.10-2a. QC inspection has not been
required to assure that all dimensions are included on the drawing. Since
,
i
the dimensional information referenced in the finding was not on the "As-
i
built" drawing, those dimensional verifications were not performed by the
l
QC inspector.
,
For CTH-2-10420, the inspection method used by the inspector to measure
[
the distance between the welded attachments involved measuring the
i
distance from the ing of the weld on the C-6 channel to the ing of the
weld attaching the conduit support to the embedded plate. This inspection
method was considered acceptable practice from approximately June 1985 to
l
April 1986 due to the perceived conservatism achieved (i.e., greater
separation).
However, this measuring method resulted in the plus side of
I
the 1" tolerance allowed by QI-QP-11.10-2a being exceeded on CTH-2-1042-
'
when measured from the f_ ara of the attached member to the f_tra of the
other welded attachment.
.
_ - . . _ _ __ _ ,_._ . - _ . _ _ _ . _ ._ _ _ _ _ _ .... _ -
.-
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.
.____ _ __
_ _ _ _
.
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Attachment 1
Page 18 of 22
-
!
!
ITEM G (446/8602-V-14) CONT'D
RESPONSE TO ITEM G.2 (446/8602-V-14) CONT'D
!,
2.
Corrective Action Taken
!
Nonconformance Reports were initiated to address the dimensional
discrepancies.
The dispositions required the drawings to be revised to
'
,
show the "As-built" conditions with the exception of the following NCRs:
l
0
NCR M-86-201794 addressing CTH-2-9774 was dispositioned "Use-as-
is."
The disposition does not require the location of the
3/8"x4"x5" plate with respect to the C-6 channel to be on the
drawing, only that the weld requirement of the plate to channel is
per design drawing. This weld dimensional requirement was
,
verified by QC at the time of the original QC inspection.
O
Also, per the NCR disposition, DCA 24400 was issued April 2, 1986,
to provide verification criteria when the dimensional location of
,
the tray clamp in relation to the C-6 channel is not shown on the
l
drawing. QI-QP-11.10-2A has been revised to include this
criteria.
l-
0
NCR M-86-202657 was initiated to address the previous use of the
toe-to-toe method to measure the separation distance between
]
welded attachments to embedded plates. CTH-2-10420 is addressed
in the NCR since it was inspected using this method.
Further
!
action will be taken as required by the NCR disposition.
Subsequent clarification was received by Engineering whereby the
,
j
separation measurements were to be verified using face-to-face,
)
unless otherwise detailed on the design drawing. The clarified
method for measuring has been applied since April 1986.
i
1
3.
Action to Prevent Recurrence
i
!
Each of the QC Inspectors involved with acceptance of the discrepant
installations identified have been made aware of their errors. To
i
determine the need for further corrective action, the performance of these
j
inspectors was evaluated through review of Quality Surveillance
reinspection results.
Based on this review it has been determined that
i
the involved inspectors have demonstrated a high degree of accuracy in the
!
performance of inspections and no further corrective action is needed.
l
Per the disposition of NCR N-86-201794, no further action is required for
!
the dimensional 3/8"x4"x5" plate-to-channel finding. However, the
revision of QI-QP-11.10-2a should prevent recurrence of the erroneous
j
dimensional location of the tray clamp plate-to-the channel finding.
The clarification of attachment separation inspection methods used should
l
prevent recurrence of this finding.
4.
Date of Comoliance
!
CPSES is presently in compliance, with the exception of NCR M-86-202657
l
which will be dispositioned by February 27, 1987.
I
i
_ _ _ _ _ _ _ _ _ _ , . _ . . . _ _ . _ . . _ _ _ _ _ _ .
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.
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.
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Attachment 1
Page 19 of 22
ITEM H (446/8602-V-10)
H.
Criterion IX of Appendix B to 10 CFR Part 50 states, in part, " Measures
shall be established to assure that special processes, including
welding . . . and nondestructive testing, are controlled and accomplished
by qualified personnel using qualified procedures in accordance with
applicable codes, standards, specifications, criteria, and other special
requirements."
Section CC-5521.1.1 of Code ACI-359, states, in part, "If the 12-in.
Radiograph in the 50-ft-long increment of weld does not meet the
acceptance standards, two 12-in. Films shall be taken at other locations
within the 50-ft-long increment . . . . If either of the second
2
radiographs does not meet the acceptance standards . . . the remaining
portion of the 50-foot increment of this weld shall be radiographed."
Contrary to the above, the required radiography of the remaining portion
of a 50' increment of weld was not performed even though one of the two
second 12" radiographs (No. 146T2) at seam P84 in the Unit 2 containment
liner did not meet the acceptance standards.
RESPONSE TO ITEM H (446/8602-V-10)
-
This alleged violation is under evaluation. We expect to send a report by
February 20, 1987.
1
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Attachment 1
Page 20 of 22
ITEM I (445/8603-V-02)
1
I.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGCo's
Final Safety Analysis Report (FSAR) Section 17.2, " Quality Assurance
'
During the Operations Phase," dated July 19, 1985, requires that
activities affecting quality be prescribed by and accomplished in
accordance with documented instructions, procedures, or drawings of a type
appropriate to the circumstances.
Operations Administrative Control and Quality Assurance Plan Section 3.9
states that, " Deficiency Reports (DRs) and nonconformance reports (NCRs)
4
!
shall be reviewed periodically for adverse trends . . . Results of trend
l
analysis shall be reported to the Manager, Nuclear Operations, Manager,
Plant Operations, and Manager, Quality Assurance."
,
1
Contrary to the above, site operations trend analyses were performed on
3
DRs only for 1984 and 1985. Consequently, trend analyses for problems
identified on NCRs were not performed and thus not reported to the
required levels of management.
Further, site procedures do not clearly
describe the conditions under which a DR or an NCR is to be written, nor
i
i
were DRs reviewed for potential conditions requiring an NCR prior to a
'
June 1985 revision to the deficiency reporting procedure STA-404.
~
RESPONSE TO ITEM I (445/8603-V-02)
'
We admit to the alleged violation for the reasons that follow.
i
Hgte:
This violation consists of three discrete parts that are addressed
i
separately in this response.
1
Part 1
.
1
". . . site operations trend analyses were performed on DRs only for 1984
and 1985. Consequently, trend analyses for problems identified on NCRs
were not performed and thus not reported to the required levels of
t
l
management."
1
a
1.
Reason for the Violation
!'
NCR dispositions (except use-as-is) are accomplished through the work
l
control program and become part of equipment maintenance history. The
i
violation was caused by a misunderstanding of the requirement to trend
NCRs directly and not as part of the Equipment Maintenance history
)
trending program.
l
2.
LQInctive Action Taken
<
1
l
As corrective action, all TUGC0 Operations NCRs have been reviewed and no
significant adverse trends were identified. Trend analysis performed on
1985 NCRs was reported to the appropriate levels of management by the 1985
Quality Assurance Annual Report.
__
,
.
. .
. _ _ , _ . . _ _ . _
__
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.
.
.
Attachment 1
Page 21 of 22
ITEM I (445/8603-V-02) CONT'D
RESPONSE TO ITEM I (445/8603-V-02) CONT'D
Part 1 cont'd
3.
Action to Prevent Recurrence
NCR trend analysis is now being conducted on a quarterly basis to prevent
further violations of this nature.
4.
Date of Comoliance
Full compliance has been achieved.
Part 2
" ... site procedures do not clearly describe the conditions under which a
DR or an NCR is to be writ'$n ..."
1.
Reason for the Violation
.
At the time of inspection, procedures failed to clearly describe the
conditions for initiating a DR or NCR.
2.
Corrective Action Taken
Recently issued Nuclear Engineering and Operations (NE0) procedures
clearly define the site guidelines for deficiency and nonconformance
reporting.
Implementing procedures will be revised to include
requirements of the appropriate NE0 procedures.
3.
Action to Prevent Recurrence
The corrective action should prevent recurrence of this part of the
Violation.
4.
Date of Compliance
The procedures will be revised by January 15, 1987.
Part 3
" ... nor were DRs reviewed for potential conditions requiring an NCR prior
to a June 1985 revision to the deficiency reporting procedure STA-404."
1.
Reason for the Violation
All prior revisions of STA-404, " Control of Deficiencies", have required
Quality Assurance to determine if the deficiency "may cause or has caused
a nonconformance." This part of the violation occurred because STA-404
did not require clear documentation of the review for noncoriforming
conditions.
_
_ ___
_.
.
_
_ _
__ _
_ __.__.
.
.
Attachment 1
Page 22 of 22
ITEM I (445/8603-V-02) CONT'D
RESPONSE TO ITEM I (445/8603-V-02) CONT'D
Part 3 cont'd
2.
Corrective Action Taken
STA-404 was revised in June 1985 to document the review for nonconforming
conditions by providing a "Yes/No NCR required" block on the DR form.
3.
Action to Prevent Recurrence
To provide further assurance that a nonconforming condition did not go
undetected, all Deficiency Reports issued prior to June 1985 will be
reviewed.
4.
Date of Comoliance
The review will be complete by January 15, 1987.
.
4
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_
,..-my
,
, _
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Attachment 2
Page 1 of 13
i
NOTICE OF DEVIATION
j
ITEM A (445/8603-D-14)
A.
Paragraph 5.3.5(A) of Evaluation Research Corporation (ERC) QI-019,
i
j
Revision 3, states, in part, " Verify that the clearance meets the
following criteria:
. Where design shows 0-inch on one side and 1/16-
. .
j
inch on the other side, the sum of both gaps may_not exceed 1/8-inch or be
less than 1/32".*
1
- Where design shows 0" on bottom (in the gravity direction) then it shall
,
l
be such with no allowable variation."
!
Section II of ERC Description Memorandum QA/QC-RT-1436 addresses changes,
i
reasons, and effects incorporated in Revision 3 of ERC QI-019 and states,
i
in part, regarding paragraph 5.3.5(A), "Added clarifying information on
j
allowable clearances for dead weight and 0" clearance supports . . . ."
i
1
Attachment A to the above ERC Description Memorandum lists previously
]
issued reinspection packages and states that package I-S-SBPS-051 is not
l
j
affected by changes incorporated in Revision 3 of ERC QI-019.
-
a
j
In deviation from the above, independent inspection identified that
i
clearances which had been correctly accepted by ERC for Verification
j
Package No. I-S-SBPS-051, when inspected to Revision 1 of QI-019, were no
-
longer acceptable to the requirements _ of Revision 3 of QI-019. Drawing
CP-AA-040, Revision 0, shows clearance in the gravity direction of zero.
Independent inspection measured a gap of 1/16" in the gravity direction,
,
1
and thus determined that the changes in Revision 3 did, in fact, affect
i
the previous inspection of Verification Package No. I-S-SBPS-051.
1
i
RESPONSE TO ITEM A (445/8603-D-14)
1.
Reason For Deviation
!
{
We admit to the alleged deviation for the reasons that follow,
i
!
The primary reasons for the deviation are imprecise guidance in QI-019 and
j
inspector misinterpretation of that guidance.
Prior to Revision 3, QI-019
did not specifically address allowable clearances in the gravity direction
.
!
for dead weight, box frame supports. Although these clearance
requirements were covered in ERC Inspector training, some confusion
!
existed over eleven inspection packages in which the box frame support
i
drawings showed the pipe in contact with the support but specified no
!
allowable clearance value.
ERC decided to revise QI-019 to reflect
I
clearance requirements as taught in inspector training, and to reinspect
!
those eleven packages. As a result, ERC Description Memorandum QA/QC-RT-
1436 (dated 2/10/86) was issued to describe the Revision 3 changes to
section 5.3.5(A) of QI-019.
(The memo erroneously stated that no
previously issued packages were affected by the changes, when in fact
Attachment A to the memo listed the eleven (11) packages requiring
!
l
reinspection. Recognizing the error in the memo, ERC issued Revision 1 to
,
!
QA/QC-RT-1436 the same day, stating that the change to QI-019 did affect
the eleven (11) previously issued packages.)
-
. _ - ,
- - - - -
.
- - . .
..-
--_ - .
. ..- ---. - --- - .-.
_
._
_ - _ _ - _ _ _
.
Attachment 2
Page 2 of 13
NOTICE OF DEVIATION
ITEM A (445/8603-D-14) CONT'D
1.
Reason for Deviation (cont'd)
Subsequent to the issuance of QA/QC-RT-1436, listing the eleven (11)
packages to be reinspected, ERC became aware of past inspector confusion
over allowable clearances even when zero inches (0") clearance in the
gravity direction was specified on the drawing.
ERC then issued
Supplemental Inspection Instructions requiring reinspection of all box
frame, dead weight supports in the small bore population.
In total, 32
packages were reinspected resulting in 9 Deviation Reports regarding zero
l
clearance in the gravity direction.
Package No. I-S-SBPS-051 was among
those reinspected, and a clearance violation in the gravity direction was
noted on Deviation Report No. I-S-SBPS-051-DR3 and subsequently on NCR M-
23400N R-1. Attachment A to memo QA/QC-RT-1436 was not revised to reflect
i
these reinspections.
2.
Corrective Action Taken
Corrective Action has been completed with the issuance of Rev. 3 to QI-019
and with the reinspection of all affected packages as of May 30, 1986.
~
Revision 2 to QA/QC-RT-1436 was issued on November 11, 1986, and contains
a note referring to the reissuance of all affected packages.
3.
Action to Prevent Recurrence
No action to prevent recurrence is contemplated for the Small Bore
population as reinspection efforts are complete and Rev. 3 to QI-019 has
been issued. As a result of CAR-16, ERC QI procedures were reviewed in
meetings between engineers and inspectors to ensure clarity and
consistency of the procedures. The need to clarify box frame support
clearance criteria in QI-019 was identified in a January 11, 1986, CAR-16
meeting.
4.
Date of Comoliance
Compliance has been achieved, as described above.
I
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.
Attachment 2
Page 3 of 13
-
NOTICE OF DEVIATION
,
i
ITEM B (445/8603-D-18)
i
B.
Paragraph 5.1 of ERC Procedure CPP-007, Revision 2 states, in part,
" Responsible QA/QC discipline engineers review the latest . . . Brown &
Root . . . documents relating to the population.
Subsequently, the
engineer develops a list of safety significant attributes that are common
<
j
to the population and which can be reinspected . . . .
Paragraph 3.4.4.3 in Brown & Root, Inc. Instruction QI-QAP-11.1-28,
'
Revision 31, identifies requirements for base material inspection and
states, in part, "The depression depth produced by grinding shall not
i
exceed . .
1/32" for material less than 3/8" thick (structural shapes)."
In deviation from the above, the responsible QA/QC discipline engineer
i
failed to identify and incorporate into ERC QI-029 this base material
i
inspection attribute. As a result, ERC inspection of Verification Package
1
i
No. I-S-LBSN-065 failed to identify that grinding on base material in
excess of 1/32" existed on item 3 of pipe support MK No. CT-1-008-001-
)i
S22S.
RESPONSE TO ITEM B (445/8603-D-18)
We deny the alleged deviation for the-reasons that follow.
_
,
Section 5.1 of CPP-007 states in part, " Responsible QA/QC Discipline
,
i
Engineers review the latest Gibbs and Hill, Brown and Root, and
i
subcontractor design documents relating to the population. As applicable,
'
the latest installation procedures, construction drawings (including as-
i
builts), and manufacturer's prints and manuals are also reviewed."
Section 5.2 of CPP-007 states in part, " Subsequently, the engineer
4
develops a list of safety-significant attributes that are common to the
'
population and which can be reinspected..."
l
The ERC QA/QC Discipline Engineer did in fact review QI-QAP-11.1-28
Revision 3) for applicability in developing the QI-029 inspection
checklist.
Inspection for excessive grinding due to welding defects on
i
base materials was not included on the checklist for the following
i
reasons. While excessive grinding may be readily detected after initial
i
installation is complete, it cannot be accuratelv reinspected following
i
application of coatings.
In most cases, the grinding performed to remove
1
weld defects would not be detectable through paint at all.
Further, while
!
the ASME Code Subsection NF stipulates that grinding to remove weld
defects may not encroach on minimum base metal thickness, there is no code
'
requirement to inspect for other types of defects in base metal as a
!
result of the welding process. Once coatings have been applied, it is
l
difficult to distinguish between markings due to grinding versus other
i
potential causes.
Paint removal to inspect for potential excess grinding
i
is impractical.
In addition, paint removal methods also remove some base
metal in the process, making an accurate determination of the depression
j
depth impossible.
For these reasons, the ERC QA/QC discipline
I
.
.
>
- - . - -
- -
. - - - -
. - . - - . - -
. . -
-
.-
.
_
.
__
_.
.
.
Attachment 2
Page 4 of 13
.
NOTICE OF DEVIATION
ITEM B (445/8603-D-18) CONT'D
RESPONSE TO ITEM B (445/8603-D-18) CONT'D
engineer concluded that inspection for excessive grinding of base metal
through paint is not a recreatable characteristic of the welding
attribute.
In accordance with ISAP VII.c, attributes or subattributes
which are deemed not recreatable are not included on inspection
checklists.
However, due to NRC inspector concerns, the ERC inspector wrote an Out-of-
Scope observation for Verification Package No. I-S-LBSN-065 noting
potential excess grinding on the pipe support base metal. A
Nonconformance Report was subsequently issued and is currently being
evaluated to disposition the Out-of-Scope observation.
It should also be noted that the nominal flange thickness for this pipe
support (a W4 x 13 structural shape) is 3/8 inch.
In accordance with QI-
QAP-11.1-28, a depression depth of 1/16 inch (the observed condition) is
.
thus acceptable.
.
i
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i
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.,.
- . . - , _ - , _ - - - - -
_ _-
.-
. _-. . _ - _ ,
__
__
.
.
.
Attachment 2
Page 5 of 13
NOTICE OF DEVIATION
ITEM C (445/8603-D-17)
C.
Section 5.2 of ERC Procedure CPP-022, Revision 0, states, in part, " Paint
shall be removed from the weld connections which have been inspected
through paint . . . . Results of these visual inspections shall be
documented and include, as a minimum, criteria utilized, (and) any
discrepancies." Section 5.2.D of ERC QI-062, Revision 0, states, " Verify
surface of welds are sufficiently free of overlap, abrupt ridges and
ripples so proper interpretation of radiographic and/or other required NDE
could be accomplished."
In deviation from the above, ERC quality inspection documented in
Verification Package No. I-S-NPBW-014 that the surface of welding which
attached item 1 to support steel identified on Drawing FW-1-019-901A-C57W
was acceptable.
Independent inspection identified, however, that after
removal of coatings the weld surface was unacceptable.
Subsequent to the
NRC inspection, ERC personnel issued a deficiency report documenting the
rejectable weld condition.
RESPONSE TO ITEM C (445/8603-D-17)
We deny the alleged deviation for the reasons that follow.
> -
The surface of the subject weld (with paint on) was inspected per packages
I-S-PWRE-006 and I-S-NPBW-014. Weld surface irregularities were noted by
the inspectors and the attribute rejected in each package. The rejection
was documented on DR No. I-S-PWRE-006 DR2.
(No DR was written for the
NPBW package, as the second part of the inspection called for weld surface
examination with the paint removed.)
Following paint removal, the weld surface could be more easily examined.
The weld surface attribute was accepted in I-S-NPBW-014 and later in
Overview Inspection Report No.24-008 (I-S-PWRE-006). Due to NRC concerns
about the weld surface, however, an independent Level III inspector was
brought to CPSES to examine the weld. The report by this Level III
inspector stated, "This writer found this weld to be acceptable except in
some cases where abrupt ridges and valleys were pronounced due in part to
limited grinding of the surface.
It should be noted that this is a
judgement interpretation that would vary from weld to weld and in some
cases the final magnetic particle test may require additional surface
preparation influenced by the specific MT method used." The independent
Level III inspector concluded: "It is evident that the magnetic particle
examination would be the last determining factor as to the adequacy of the
weld."
A review of the original magnetic particle examination of the weld
performed by Chicago Bridge and Iron indicated the acceptability of the
weld and weld surface. Based on the judgement of the ERC inspectors, the
independent Level III inspector report, and the acceptance of the weld in
the original NDE report, ERC concluded the weld surface was acceptable.
However, due to continuing NRC concerns regarding the interpretation of
the independent Level III inspector's report, Deviation Report No. I-S-
NPBW-014 DR1 was generated.
.
_
_ - _ .
_.
_
_
_ __.
-
_ _ _ _ _
.
Page 6 of 13
C 445/8603-0 7
RESPONSE TO ITEM C (445/8603-D-17) CONT'D
To resolve the issues, a Brown and Root Level III inspector performed a
Magnetic Partical Test on the weld. On the basis of the test report
(MT/PT Report #29023) the weld and weld surface were acceptable.
Therefore, no deviation exists. DRs No. I-S-NPBW-014 DRI and No. I-S-
'
PWRE-006 DR2 will be invalidated.
- i
j
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I
i
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-
, . _ _ _ . ,
_ _ _ _
-_ . _ _ _ _ . , _ _ . _ - _ . . _ _ _
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-_
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.
Attachment 2
Page 7 of 13
NOTICE OF DEVIATION
ITEM D (446/8602-D-13)
D.
Section 5.1.1 of Revision 2 to ERC Procedure CPP-008 states, in part,
. . . should an attribute appear on the generic checklist and not be
"
applicable to the specific item, the engineer indicates 'N/A' and provides
reasonable justification for the entry."
In deviation from the above, an independent inspection of Verification
Package No. I-S-HVDS-075, support DG-844-2K-1J, revealed that Sections
2F.1, ?F.2, and 2F.3 in the checklist for QI-035, dealing with embed
plates and spacing violations, had been "N/A'd" by the engineer.
Further, the noted justification for this entry was "No Embedded PLs."
However, independent inspection identified the existence of an embed plate
with dimensions of approximately 20' X 8".
RESPONSE TO ITEM D (446/8602-D-13)
We deny the alleged deviation for the reasons that follow.
Sections 2F.1, 2F.2, and 2F.3 for Verification Package No. I-S-HVDS-075
had been "N/A'd" by the ERC engineer. The justification for this entry
was "No Embedded PLs". A subsequent review of this package by ERC has
,~
!
revealed that a deviation does not exist. The ERC Engineer correctly
N/A'd these attributes.
Quality Instruction (QI) 035, " Reinspection of HVAC Duct Supports"
delineates the inspection requirements to be performed for this population
(HVDS).
Section 5.2.2F of this QI addresses Welded Attachments to
Embedded Plates.
For the 2F. attributes to be inspected, the duct support
has to be attached (welded) to the embedded plates. Verification Package
No. I-S-HVDS-075 contains support DG-844-2K-lJ for inspection.
Support
DG-844-2K-1J is not welded to an embed plate, therefore these attributes
(2F.1, 2F.2, and 2F.3) cannot be reinspected. Therefore, the ERC engineer
correctly N/A'd these inspection attributes.
During the course of this review and subsequent discussions with the NRC
it was brought to the attention of ERC that NRC had a concern with
Attribute 4C.3, "Hilti to Embedded Plate Edges". The ERC inspector had
originally accepted this attribute. QI-035, Section 4C.3 requires the ERC
inspector to " verify that the minimum distance of each Hilti anchor to any
adjacent embedded plate (or Nelson stud, if available) meets the
requirements of Attachment 6.17..."
The required minimum for a 1-inch
Hilti to the edge of an embedded plate is 7-1/2 inches.
Subsequent
inspection of attribute 4C.3 revealed a 1 inch Hilti installation 7/8-inch
from an embedded plate.
Verification Package No. I-S-HVDS-075, was reissued and a deviation report
I-S-HVDS-075-DR4 issued by the ERC inspector on July 31, 1986, identifying
,
the discrepant condition.
In addition, Nonconformance Report No. M-86-
202172X was issued on September 2, 1986 and has not yet been
dispositioned.
l
_
_.
-
-
_
_
_ . . - -
_
..._ _
_ __
_ . _ _
_____ _ _ _
_ _ _ . _
_
.
1
Attachment 2
'
Page 8 of 13
,
NOTICE OF DEVIATION
ITEM E.1 (446/8602-D-12)
l
E.
Section 4 of Revision 3 to ERC Procedure CPP-009 states, in part,
" Qualified QA/QC Review Team personnel perform field reinspections of
4
specific hardware items and reviews of appropriate documents in accordance
!
with approved instructions . . . ."
l
l
In deviation from the above, the following examples were noted where field
j
reinspections of hardware items were not performed in accordance with
approved instructions:
1
E.1.
Attribute 2D. in Section 5.0 of Revision 0 to QI-035 states,
" Verify member lengths and all other dimensions that describe the
,
!
lengths and positions of members on the support frame (+/- 1/2")."
!
For Verification Package No. I-S-HVDS-075, Support D6-844-2K-lJ,
the ERC inspector signed the checklist that this attribute (20.)
l
was acceptable. An independent inspection revealed, however, that
I
there were several members for which no dimensional information
was provided in the drawing thus making it impossible to verify
required member lengths and all other dimensions that describe the
j
lengths and positions of those members.
.
RESPONSE TO ITEM E.1 (446/8602-D-12)
'
l.
Reason for Deviation
!
!
We admit to the alleged deviation for the reasons that follow.
-
I
The ERC inspector accepted attribute 2D for Verification Package No. I-S-
HVDS-075. Therefore, a deviation does exist. During the course of this
inspection, discussions were held between the ERC inspector and the HVDS
j
j
population engineer as to the acceptability of the dimensions for this
i
duct support (DG-844-2K-IJ). The ERC inspector was instructed by the
4
!
population engineer to verify only those dimensions and lengths available
'
!
on the drawing. The member whose lengths were not shown, spanned two
l
members. These members were verified, under the configuration attribute,
to ensure that they spanned the two members. However, a tolerance was not
j
applied to the member length, because it was not considered safety
significant.
Therefore, attribute 2D. was accepted for the aforementioned members. The
acceptance was based on engineering judgement that the member length
attribute was not safety significant in those cases.
1
4
l
2.
Corrective Action Taken
i
l
The ERC population engineer has written a letter to the Design Adequacy
!
Program (DAP) outlining that duct support detail drawings, in general,
i
lack sufficient information concerning member lengths.
Based on the
j
finding, the ERC engineer is reviewing the HVDS Verification Packages to
determine the validity of previous deviation reports written against
,
__.
-
-
-
- .
- _ _ .
.
.
.-- --
'
.
i
Attachment 2
Page 9 of 13
-
NOTICE OF DEVIATION
ITEM E.1 (446/8602-D-12) CONT'D
RESPONSE TO ITEM E.1 (446/8602-D-12) CONT'D
!
2.
Corrective Action Taken Cont'd
I
attribute 20. Additionally, TUGC0 has undertaken a complete HVAC support
reverification program for Unit I and common.
3.
Action to Prevent Recurrence
The DAP employs a systematic process for identifying and evaluating trends
and generic implications. This systematic process implements the CPRT
,
commitment to investigate the generic implications of deficiencies in the
j
area of design. The process is intended to:
i
'
Identify and evaluate any trends in observations, or in deviations
-
from design criteria, or commitments that indicate a possibility of
i
adverse impacts on the design of safety related systems, structures
l
and components.
4
Determine whether identified deficiencies in design have generic
-
l,
implications and effects and, if so, the extent of these effects.
Ensure that adverse impacts on hardware that result from generic
-
i
j
effects are evaluated and resolved.
-
1
'
Identify corrective action necessary to preclude recurrence of each
2
-
i
deficiency,
i
i
4.
Date of Comoliance
!
The DAP analysis is currently in process and is expected to be completed
!
!
by June 1987. The TUGC0 HVAC support reverification program is expected
to be completed by May 1987.
,
!
!
!
I
i
!
.
i
i
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- - - - . - - - - _.-
_ - -
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. .
__
.
.
.
{-
Attachment 2
Page 10 of 13
NOTICE OF DEVIATION
ITEM E.2 (446/8602-D-11)
i
j
E.
Section 4 of Revision 3 to ERC Proce' dure CPP-009 states,.in part,
j
" Qualified QA/QC Review Team personnel perform field reinspections of
specific hardware items and reviews of appropriate documents in accordance
.
with approved instructions . . . ."
'
!
In deviation from the above, the following examples were noted where field
i
reinspections of hardware items were not performed in accordance with
l
approved instructions:
!
E.2.
Attribute 3B. in Section 5.0 of Revision 0 to QI-035 states,
j
" Verify that weld sizes meet the requirements of the duct support
i
detail drawings." For Verification Package No. I-S-HVDS-037, .the
{
ERC inspector signed attribute 38. as being acceptable-and noted
i
that all welds had been measured with a Fiber Metal Fillet Gauge.
j
During an independent inspection, it has noted that there were two
skewed fillet welds on this support in which one-leg of the fillet
on each weld could not be measured with a Fiber Metal Fillet Gauge
or any other conventional method.
~
.+
.
RESPONSLTO ITEM E.2 (446/8602-D-11)
,
'
,
1.
Reason for Deviation
-
,
We admit to the alleged deviation for the reasons that follow.
i
'
Appendix B of the NRC Inspection Report 445/86-03and446/86-d'2'
incorrectly identifies this deviation against Verification Package No. I-
'
,
S-HVDS-037. Hcwever, in Appendix C of the NRC Inspection Report,
1
Verification Package No. I-S-HVDS-075 is correctly identified forwhich
J
the aforementioned deviation exists. Therefore, this response addresses
j
the deviation as identified by the NRC in In:pection Report 445/86-03 and
j
446/86-02 for Verification Package No. I-S-HVDS-075.
The ERC inspector accepted attrib tm 38., Weld Size, for Verification
'
Package No. I-S-HVOS 075/ and roted on Attachment 6.2 that the welds had
I
been measured using i'ibre M6tal Gages, a flashlight, and visual
.
)
j
inspection.
This inspection was performeo November 7,1985. ' On July 31,
'
1
1986, Verification Package No. I-S-hTDS-075 was reissued with a
"
1
supplemental instruction to reverify attribute 38. The ERC-ingactor
1
again accepted attribute 3B and poted on Attachment 6.2'tm the'
supplemental instruction that the welds had been measured with a
.
flashlight, Fibre Metal Fillet Gages, visual ins;oction, and skewed gages.
'
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.
,
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.
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.
'
Attachment 2
-
Page 11 of 13
NOTICE OF DEVIATIM
ITEM E.2 (446/8602-D-11) CONT'D
RESPONSE TO ITEM E.2 (446/8602-D-11) CONT'D
1.
Reason for Deviation (cont'd)
Subsequent discussions with the ERC inspector revealed that a six inch
rule had also been used to verify the skewed weld leg size. The six inch
rule was used to measure the leg that had the member "end prepped." The
inspector apparently accepted the attribute on that basis. Based on
further discussions with the ERC inspector, NRC inspector, and TUGC0 QA/QC
personnel it was determined that the ERC Level III should verify attribute
38. The Level III inspector successfully measured one leg of the skewed
fillet weld using a skewed weld gage. The Level III inspector determined
that the second leg of the weld could not be measured in the manner
demonstrated by the ERC inspector. The measured leg size was 3/8-inch.
Measurement of the second leg was found to be indeterminate. Therefore, a
deviation does exist for Verification Package No. I-S-HVDS-075 attribute
38.
2.
Corrective Action Taken
i ~
ERC Deviation Report (DR) number I-S-HVDS-075-DR5 was prepared to document
the undersized weld.
.
3.
Action to Prevent Recurrence
<
t
For Verification Package No. I-S-HVDS-075, where inspector error was
'
evident, the inspector and the lead inspector and population (ERC)
engineer discussed specifics to determine why the error occurred.
,
Documented evidence of these discussions is available in the file for NRC
review.
At the discretion of the lead inspector, formal and informal group
meetings were held to discuss inspector error on a generic basis. These
Miscussions allowed appropriate information to be disseminated to various
cognizant ERC inspectors.
An Overview Inspection Program was implemented to reinspect a sample of
,
each inspectors work.
Results of the Overview Inspection Program are
j
complete and are available for NRC review. The inspector for Verification
Package No. I-S-HUDS-075 had an overall error rate of 0.18% or 0.0018.
This number is significantly less than one percent and is based on 3279
,
l
decision points reviewed by Overview Inspection with 6 in disagreement.
l
Based on these Overview results, we believe that no further action to
prevent recurrence is required.
4.
DAtg of Comoliance
t
l
Compliance will be achieved with the resolution of DR I-S-HVDS-075-DR5 by
l
February 20, 1987.
-
C
- - . - - - . . _ . . , - - - - . .
,
,
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.,
. , , , ,
- -- . , , -
.
.
_
_-
.
Attachment 2
Page 12 of 13
NOTICE OF DEVIATION
ITEM E.3 (445/8603-D-13)
E.
Section 4 of Revision 3 to ERC Procedure CPP-009 states, in part,
" Qualified QA/QC Review Team personnel perform field reinspections of
specific hardware items and reviews of appropriate documents in accordance
with' approved instructions . . . ."
In deviation from the above, the following examples were noted where field
reinspections of hardware items were not performed in accordance with
approved instructions:
E.3.
Attribute 1.f in Section 5.2.6.2 of QI-025, Revision 2, states, in
part, " Ensure that a minimum of 2 inches clearance is maintained,
including pipe insulation, with respect to other piping when one
or both lines have an operating temperature of 2000 F or
greater . . . ."
For Verification Package No. I-M-LBC0-148, the
ERC inspector signed off this attribute as acceptable, even though
there were three cases where the minimum separation criteria were
not met and no documentation existed justifying this condition.
The three instances were as follows:
a.
Line 2-CC-1-060-152-3 was in contact with the inspected
_
line at a location 6' 6" north of wall 7-S and 10' west of
wall D-S.
The two lines were parallel and were in contact
for about 4'.
b.
Line 2-CC-1-061-152-3 was in contact with the inspected
line at a location 12'6" north of wall 7-S and about 8'
west of wall D-S.
c
Line 1-CC-1-062-152-3 was closer to the inspected line
than the allowable 2" at a location 6' 6" north of wall 7-
S and 7' 6" west of wall D-S.
l
RESPONSE TO ITEM E.3 (445/8603-D-13)
1.
Reason for Deviation
We admit to the alleged deviation for the reasons that follow.
Investigation by ERC confirmed the above findings identified by the NRC.
Therefore, a deviation does exist for Verification Package No. I-M-LBC0-
148, attribute 1.f, which was incorrectly accepted by the ERC inspector.
2.
Corrective Action Taken
Deviation Report (DR) number I-M-LBCO-148-DR-3 was prepared on August 28,
1986, to document the existence where the minimum separation criteria was
not met. Nonconformance Report (NCR) number M-25340N was generated as a
result of the DR to disposition the above conditions.
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Attachment 2
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Page 13 of 13
NOTICE OF DEVIATION
ITEM E.3 (445/8603-D-13) CONT'D
RESPONSE TO ITEM E.3 (445/8603-D-13) CONT'D
3.
Action to Prevent Recurrence
In cases where inspector error was evident, the inspector and the lead
!
inspector or population engineer discussed specifics to determine why the
error occurred.
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Documented evidence of these discussions is available in the file for NRC
review.
3
At the discretion of the lead inspector, formal and informal group
meetings were held to discuss inspector errors on a generic basis. These
,
discussions allowed appropriate information to be disseminated to various
cognizant ERC inspectors. Additionally, this finding was discussed and
documented with all overview inspectors on June 10, 1986. The overview
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inspectors were instructed to review in detail all NCRs in each overview
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inspection package.
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An Overview Inspection Program was implemented to reinspect a sample of
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each inspectors work. Results of the Overview Inspection Program are
complete and are available for NRC review. The. inspector for Verification
Package No. I-M-LBC0-148 had an overall error rate of 1.12% or 0.0112.
This number of errors is slightly more than one percent and is based on
2675 decision points reviewed by Overview Inspection with 30
disagreements. Based on the Overview Inspection, we believe that no
further action to prevent recurrence is required.
4.
Date of Comoliance
Corrective action will be completed commensurate with the final
disposition of nonconformance report M-25340N which is expected by May 1,
1987.
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Outgoing Correspondence bec (2):
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M. D. Spence
L. D. Nace
W. G. Counsil
V. S. Noonan
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J. W. Beck
D. F. Landers
R. W. Ackley
L. E. Powell
R. E. Ballard
PIMS
,
J. L. Barker
R. L. Ramsey
W. R. Burchette
J. D. Redding
J. H. Butts
D. M. Reynerson
R. D. Calder
N. S. Reynolds
Frank Camp
K. L. Scheppele
R. E. Camp
H. C. Schmidt
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D. E. Deviney
A. B. Scott
T. G. Dignan
C. E. Scott
J. Ellis
J. F. Streeter
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B. Finkelstein
B. Tartt
J. B. George
A. Vietti-Cook
R. S. Howard
E. L. Wagoner
R. T. Jenkins
H. M. Warren (2)
R. A. Jones
N. H. Williams
S. D. Karpyak
D. R. Woodlan
G. S. Keeley/
R. A. Wooldridge
J. S. Marshall
J. E. Krechting
October 20, 1986
J. C. Kuykendall
D. F. Landers
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R. P. Lessey
0. W. Lowe
D. M. McAfee/
P. E. Halstead
R. E. McCaskill
J. P. McGaughy
D. D. Mosley
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Log # TXX-6337
P9
File # 10130
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1UELECTRIC
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w a.. c.co ma
March 12, 1987
Em urow ike />ruJrm
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U. S. Nuclear Regulatory Commission
IIk
MAR I 91987
ATTN: Document Control Desk
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Washington, DC 20555
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SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446
RESPONSE TO NRC NOTICE OF DEVIATION
INSPECTION REPORT NOS.: 50-445/86-03 AND 50-446/86-02
Gentlemen:
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In a conversation with your Mr. I. Barnes on March 12, 1987, we advised
Region IV that the date for completion of the corrective action regarding
Notice of Deviation Response to Item E.2 446/8602-D-11 was being revised.
Specifically, the date of full compliance stated in the response was
February 20, 1987. DR I-S-HVDS-075-DR5 was not resolved until March 11,
1987. The date of full compliance, therefore, was achieved on March 11,
1987.
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Very truly yours,
h.
W. G. Counsil
By:
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G. S. Keeley n/_
Manager, Nuclear L yensing
RDD:lw
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c - Mr. E. H. Johnson, Region IV
Mr. D. L. Kelley, RI - Region IV
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Mr. H. S. Phillips, RI - Region IV
79 hShhb h
400 North Olne Street 1.11 81 Dallas, Tesas 75201
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