ML20212E639

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/85-07 & 50-446/85-05.Addl Info Needed Re Items 1,2.a & 2.b in Notice of Violation.Supplemental Info Requested within 20 Days

ML20212E639
Person / Time
Site:	Comanche Peak
Issue date:	12/30/1986
From:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8701050388
Download: ML20212E639 (3)

See also: IR 05000445/1985007

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In Reply Refer To:

Dockets: 50-445/85-07 DEC 30126

50-446/85-05

Texas Utilities Generating Company

ATTN: Mr. W. G. Counsil

Executive Vice President

400 North Olive, L.B. 81

Dallas, Texas 75201

Gentlemen:

Thank you for your letter of April 2,1986, in response to our letter and the

attached Notice of Violation (NOV) dated February:3, 1986., We apologize for

our oversight in not previously acknowledging your response. As a result of

our follow up on the corrective action described in your letter, we. find that

additional information is needed with respect to Items 1,.2.a. and 2.b in the

NOV. ,

Item 1, NOV: We find that the corrective steps taken and results achieved do

not indicate that the installation of the replacement. RTE-Delta Potential

Transformer tiltout assembly was reinspected and accepted. Also, there is no

indication that these deficiencies were documented on a nonconformance report

for Units 1 and 2.

Item 2.a. NOV: The described corrective steps,taken do not indicate whether

a nonconformance report was written for Units 1 and 2. Follow up by the NRC

inspector identified that the drawing which was used for the activity (i.e.,

Westinghouse Drawing 1457F29) had been reviewed and stamped by Gibbs and Hill,

signifying apparent approval of a drawing which allowed use of grout instead

of Class E concrete. Accordingly, it is requested that the stated reason for

the violation be reevaluated, in that the engineering interface or review may

have contributed to causing this violation. Please also identify the design

change authorization, if any, that permits use of grout rather than Class E

concrete in Unit 2, in that the referenced design change DCA-21,179 would

appear to be applicable to Unit 1 only. In your corrective steps to avoid

recurrence, you stated that operational travelers issued during the same time

frame for similar type installations would be reviewed for similar

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deficiencies. Please clarify how this action is pertinent to precluding

recurrence. Your response also indicated that any corrective actions deemed

nececsary, as a result of this review, would be reported to Region IV by

April 15, 1986. In that no supplementary response has been received by

Region IV, please identify whether or not your review determined corrective

actions were necessary. ,

RIV: SRI

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PDR ADOCK 05000445

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Texas Utilities Generating Company 2

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Item 2.b, NOV: With respect to the corrective stens taken, please describe

what formal actions were taken (e.g., specificaticn revision) to justify the

change in output /oltage from 10 1 2v to 12 2v on the revised Westinghouse

Quality Release. Your response also fails to provide any actions taken to

assure that other equipment received from this vendor, irrespective of time

frame, did not exhibit similar documentation deficiencies.

No response was required by our letter of February 3,1986, w'ith respect to

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Item 2.c of the NOV and we have no further questions with respect to Item 2.d

of the NOV.

Please provide the supplemental information within 20 days of the date of this

letter.

Sincerely,:.{[Of._

od$r. ~;

VG M

E. H. Johnson, Director

Division of Reactor Safety

and Projects

.

cc:

Texas Utilities Electric Company

. ATTN: G. S. Keeley, Manager

Licensing

Skyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas 75201

Juanita Ellis

President - CASE

1426 South Polk Street

,

Dallac, Texas 75224

,

Renea Hicks

Assistant Attorney General

Environmental Protection Division

P. O. Box 12548

Austin, Texas 78711-2548

Administrative Judge Peter Bloch

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555

.

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Texas Utilities Generating Company 3

-Elizabeth B. Johnson

Administrative Judge

Oak Ridge National Laboratory

.P. O. Box X, Building 3500

Oak Ridge, Tennessee 37830

Dr. Kenneth A. McCollom

1107 West Knapp

Stillwater, Oklahoma 74075

Dr. Walter H. Jordan

881 Outer Drive

Oak Ridge, Tennessee 37830

Anthony Roisman, Esq.

Executive Director

Trial Lawyers .for Public Justice _.

2000 P. Street, N.W. Suite 611

-Washington, D.C. 20036

Texas Radiation Control Program Director

bec to DMB (IE01) .

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- Log # TXX-4727

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File # 10130

IR 85-07

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TEXAS UTILITIES GENERATING COMPANY 85-05

9 anywAv vowra . .oo noans ouvz svarer. a m. si . DAW.AN. TEXAS Maos

April 2, 1986

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Mr. Eric H. Johnson, Director

Division of Reactor Safety and Projects q{ l . ,, g g

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U. S. Nuclear Regulatory Commission i'~.. J.  !

611 Ryan Plaza Drive, Suite 1000 OL - g

Arlington, Texas 76012 _. -

SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446

RESPONSE TO NRC NOTICE OF VIOLATION

INSPECTION REPORT NOS.: 50-445/85-07 AND 50-446/85-05

Dear Mr. Johnson:

We have reviewed your letter dated February 3, 1986, concerning the inspec-

tion conducted by Messrs. J. E. Cummins, H. S. Phillips, and others during

the period April 1, 1985, through June 21, 1985. This inspection covered

activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for

Comanche Peak Steam Electric Station Units 1 and 2.

We requested and received a two week extension in providing our response

during a telephone discussion on March 6, 1986. We requested and received

a second two week extension on March 19, 1986.

We have responded to the Notice of Viclation in the attachments to this

letter. We have attached the Notice of Violation to aid in understanding

l our response.

Very truly yours,

V llV/l^

W. G. Counsil

l JWA/ arm

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! Attachments i

c- Region IV (Original + 1 copy)

l

Director, Inspection and Enforcement (15 copies) '

U. S. Nuclear Regulatory Commission

Washington, D.C. 20555

Mr. V. S. Noonan

Mr. D. L. Kelley

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A onnsox or nexAs unLn1ES ELECTRIC CoMPAhT

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APPENDIX A

NOTICE OF VIOLATION

Texas Utilities Electric Company Docket: 50-445/85-07

Comanche Peak Steam Electric Station 50-446/85-05

Units 1 and 2 Permit: CPPR-126

CPPR-127

During an NRC inspection conducted on April 1 through June 21, 1985, violations

of NRC requirements were identified. In accordance with the " General Statement

of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2,

Appendix C (1985), the violations are listed below:

1. Failure to Promptly Correct an Identified Problem with RTE - Delta

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Potential Transformer Tiltout Subassemblies

10 CFR 50, Appendix B, Criterion XVI, as implemented by Texas Utilities

Generating Company (TUGCO) Quality Assurance Plan (QAP), Section 16.0,

Revision 0, requires that measures shall be established to assure that

conditions adverse to quality, such as failures, malfunctions, deficien-

cies deviations, defective material and equipment, and nonconformahces are

promptly identified and corrected.

Contrary to the above, a potential problem with RTE - Delta potential

transformer tiltout subassemblies, which are used in the emergency diesel

generator control panels, was identified to the applicant via a letter,

dated June 15, 1983, from Transamerica Delaval Inc. This letter also

provided instructions for correcting the potential problem. However, the

applicant did not take the corrective action. The NRC initially reported

this item as unresolved in NRC Inspection Report 50-445/84-40.

This is a Severity Level IV violation. (Supplement II.E) (445/8507-01

446/8505-01).

2. Failure To Follow Procedures

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10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 QAP,

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Section 5.0, Revision 2 requires that activities affecting quality shall

be prescribed by documented instructions, procedures, or drawings, of a

type appropriate to the circumstances and shall be accomplished in accor-

dance with these instructions, procedures, or drawings.

I a. Drawing 2323-51-0550, Revision 4, Section 6-6 specified the use of

l Class E" concrete for the Unit I reactor coolant pump and steam

i generator supports.

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Contrary to the above, commercial nonshrink grout was used to grout

' the Unit I reactor coolant pump and steam generator supports in lieu

of Class "E" concrete. (445/8507-02)

This is a Severity Level V violation (Supplement II.E).

b. Brown and Root Procedure QI-QAP-7.2-8, " Receiving of Westinghouse

Safety Related Equipment," Section 3.1.d.1, requires a QC inspector

to verify that the Westinghouse Quality Release (QR) document -

checklist items be filled out completely and accurately.

Contrary to the above, the voltage recorded on Westinghouse QR 41424

checklist, attachment 1, step 4.1, was outside the specified

'; tolerance, but the QC receipt inspector accepted QR as satisfactory.

(445/8507-03)

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This is a Severity' Level IV violation,

c. Brown & Root Procedure 35-1195-CCP-10. Revision 5, dated December 4,

1978, requires that central and truck mixer blades be checked

quarterly to assure that mixer blade wear does not exceed a loss of

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10% of original blade height.

Contrary to the above, on May 31, 1985, the NRC inspector determined

that there was no objective evidence (records) that the mixing blades

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had been inspected quarterly since the trucks were placed in service

l in 1977. (445/8507-04; 446/8505-02)

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This is a Severity Level V violation (Supplement II.E)

d. Brown & Root Procedure CP-QAP-15.1, " Field Control of Nonconforming

Item, " states that nonconforming conditions shall be documented in a

Deficiency and Disposition Report (DDR). Procedure CP-QCP-1.3, " Tool

l Equipment Calibration and Control," dated July 14, 1975, states that

out-of-calibration equipment shall be identified on a DDR.

Contrary to the above, on May 31, 1985, the NRC inspector reviewed

the calibration file for scale (MTE 779) used for weighing cement and

found that a 24-48 pound deviation from the required accuracy was

encountered with the water and cement scales during a 1975 calibration

of the backup plant scales, however, no DDR was issued to identify

this condition and require disposition of the scale and concrete (if

any) produced. (445/8507-06;446/8505-04).

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This is a Severity Level IV violation (Supplement II.E).

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Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is

hereby required to submit to this office within 30 days of the date of the

letter transmitting this Notice, a written statement or explanation in reply,

including for each violation: (1) the reason for the violations if admitted,

2) the corrective steps which have been taken and the results achieved,

3) the corrective steps which will be taken to avoid further violations, and

4) the date when full compliance will be achieved. Where good cause is shown,

consideration will be given to extending the response time.

Dated at Arlington, Texas,

this 3rd day of February,1986

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Response to Notice of Violation

Item 1 (445/8507-01 and 446/8505-01)

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1.

Reason for Violation:

The violation relates to a Part 21 notice provided by a CPSES diesel

generator subtier supplier (RTE-Delta) in June 1983.

The violation is

the 21

Part result of two unrelated administrative oversights

notice. in handling the

when

the subjectaPart "potentially"

21 notice. reportable deficiency was ca i

The second administrative oversight

involved omission of tne issue when a program was conducted in mid 19

to assure

issues. corrective actions were accomplished for prior Part 21

2.

Corrective Steps Taken and Results Achieved:

work permits Z-2912 and'Z-2914 in December 1984. Action

were identified by master Data Base Item Unit 2 activities

and completed in August of 1985. 3003-31 (issued January 1985)

response to an NRC open item (445/8440-02).These actions were initiated in

3.

Corrective Steps to Avoid Recurrence:

In response to an earlier NRC open item (445/8407-01), programmatic

measures were established

actions related to Part 21 issues.

in mid 1984 to positively control corrective

notices as "potentially" reportable deficiencies purs

10CFR50.55(e).

governed by TUGC0 Corporate Procedure NEO-CS-1, " E

Reporting of Items / Events under 10CFR21 and 10CFR50.55(e)."

The oversight of the specific (RTE-Delta) Part 21 notice during the mid

1984 review is considered to be isolated. The failure to recognize

this issue

different was the result of the same identifier being assigned to two

items.

(445/8440-01). This was the subject of a previous violation

during our review of the earlier violation.No other instance of a similar na

4. Date When in Full Compliance:

Programmatic measures were established in mid 1984 to

control corrective actions related to Part 21 issues. positively '

cific

in Augustfindings

1985. related to the RTE-Delta Part 21 notice were correctedAll of t

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• . Response to Notice of Violation

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Item 2(a) (445/8507-02)

k 1. Reason for Violation:

The violation is the result of a failure on the part of personnel pre-

paring work control documents to properly recognize the hierarchy of

design documents. Specifically, when design and vendor installation

documents differ, the design document establishes precedent.

Although consistent with the requirements of the vendor drawing (W

Drawing 1457F29), the use of non-shring commercial grout was contrary

to the requirements of the design drawing (2323-51-0550). The design

drawing specified the use of class "E" concrete. The use of grout as

an acceptable design alternative should have been properly documented

by design change prior to the placement.

2. Corrective Steps Taken and Results Achieved:

Based upon a review of the grout card (No. 186 issued November 1981)

and the results of the compressive strength test for the grout used in

this application, a design change (DCA-21, 179) was issued November 8,

1984, to document acce~tance

p of the installation.

3. Corrective Steps to Avoid Recurrence:

Operational travelers (work control documents) for similar type

installations issued during the same time frame as the installation

identified in the violation will be reviewed for similar deficiencies.

Results of the review will be completed by April 4, 1386.

Although we believe the specific finding is an isolated case, a project

directive will be issued re-emphasizing:

0 the requirements of properly documenting design

alternatives prior to initiating construction activities,

O the precedence of design vs. vendor documents.

4. Date When in Full Compliance:

Any corrective actions deemed necessary based on the results of the

(Item 3) review will be reported by April 15, 1986, to Region IV. The

project directive will be issued by April 15, 1986.

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Item 2(b) (445/8507-03)

. 1. Reason for Violation:

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The out-of-tolerance condition was not detected by receiving inspection

when reviewing the data package.

2. Corrective Steps Taken and Results Achieved:

Receiving inspection reports issued in same time frame as the receipt

of the equipment in question, were reviewed for similar oversight. No

deficiencies were noted. Westinghouse QRN-41424 Rev. I was added to

receiving inspection report package to identify the change in output

values.

3. Corrective Steps to Avoid Recurrence:

Construction receiving inspection personnel were retrained in reviewing

receiving inspection documentation packages.

4. Date When in Full Compliance:

February 27, 1986.

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Item 2(c) (445/8507-04 and 446/8505-02)

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i A reply to this notice of violation is not required as noted in the NRC

Region IV letter of February 3, 1986 (E.H. Johnson to W.G. Counsil)

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.~ Response to Notice of Violation

Item 2(d) (445/8507-06 and 446/8505-04)

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1. Reason for Violation:

A review of the historical procedures files has indicated that the

majority of project procedures controlling safety related work, and

programmatic requirements were not issued until or after 7/14/75.

Although project practice at this early stage of construction was to

defer safety related work until the appropriate implementing and sup-

port procedures were issued and distributed, the established control

was inadequate in this instance.

2. Corrective Steps Taken and Results Achieved:

Concrete pour records were reviewed to determine which category I place-

ments were made during the subject calibration interval.

Nonconformance reports (NCR-C-85-101882 R. 1 issued 11/26/85

NCR-C-85-201617 R.1 issued 11/27/85) were initiated to document the two

placements made. Engineering dispositioned these NCR's basing the

decision on the design _ cylinder compressive results. These NCR's were

closed in December 1985.

3. Corrective Steps to Avoid Recurrence:

The site procedures controlling these activities and the associated

programmatic requirements, were issued onsite after the discrepancy

identified by the inspector had occurred and prior to the next sche-

duled calibration. These procedures provided the necessary controls

for handling nonconforming items, implemented a detailed calibration

program and required auditing the effectiveness of the established

10CFR50 Appendix B Quality Program requirements; continuing periodic

audits by TUGCO, Brown & Root, and third parties have insured accep-

table implementation of the controlled measuring and testing equipment

calibration program. This appears to be an isolated instance since

review of pour cards during this time period did not identify any

safety related placements other than those addressed above. Safety

related mechanical and electrical activities had not yet commenced.

4. Date When in Full Compliance:

CPSES is currently in full compliance with 10CFR50 Appendix 8 Criterion

XII.

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