ML20212E639
| 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
Text
i
o
.
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
deficiencies. Please clarify how this action is pertinent to precluding
i
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
C/CPRT r d
S
/87
HSPhillips:gb
IBarnes
gHJohnson
'
a/p/86
i l
rz /30/86
a /30/86
'
- ~. 8 " f
b
8701050388 861230
ADOCK 05000445
O
.
-
-
-
. - -
_~
.-
. _ , - - ,
- - - , .
.-
r
.
Texas Utilities Generating Company
2
s
!
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
~
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
78711-2548
Administrative Judge Peter Bloch
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555
.
.-
,
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)
.
.
bcc distrib. by RIV:
'
'
'
.-
- RPB
- MIS System
~
-
-
- RRI-0PS
-*RSTS Operator
-
,
- RRI-CONST
- R&SPB
-
.
- T. F. Westerman, RSB
DRSP
4
V. Noonan, NRR
R. Martin, RA
. ,
, .
-
,.
L. Chandler, 0GC
- RSB .
-
- RIV File-
-
J. Taylor, IE
- D. We':s, RM/ALF
J. Conklin, IE
- I. Basiias, CPTG
- Project Inspector
,
- w/766
Log # TXX-4727
-
.
.
-
File # 10130
IR 85-07
,
TEXAS UTILITIES GENERATING COMPANY
85-05
9
anywAv vowra . .oo noans ouvz svarer. a m. si . DAW.AN. TEXAS Maos
April 2, 1986
_ _ _ . -
EIIMJAf?JE*A
L,
@ @ f.
1 r-
q{ l .
Mr. Eric H. Johnson, Director
,, g g
Division of Reactor Safety and Projects
U. S. Nuclear Regulatory Commission
i'~..
.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
!
Attachments
,
i
c-
Region IV (Original + 1 copy)
Director, Inspection and Enforcement (15 copies)
l
'
U. S. Nuclear Regulatory Commission
Washington, D.C.
20555
Mr. V. S. Noonan
Mr. D. L. Kelley
r
L
A onnsox or nexAs unLn1ES ELECTRIC CoMPAhT
dom N ff!6!bo W
9g,)
.
.
.
.
.
.
',
APPENDIX A
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
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
10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 QAP,
l
Section 5.0, Revision 2 requires that activities affecting quality shall
l
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.
l
,
i
I
._
. .. =. . - -
-
.
+
.
.
.
'
-
-2-
,
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)
.
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
i
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
had been inspected quarterly since the trucks were placed in service
,
l
in 1977.
(445/8507-04; 446/8505-02)
i
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).
,
This is a Severity Level IV violation (Supplement II.E).
l
.
, _ . . ,
. , . _ , . . . , . . . . . _
- . . . _ . _ _ _ . , - . - _ . . , _ _ _ . .
_ _ _ _ _ . , _ _ . ,
...m
. _ _ _ _ , _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
-
.
.
.
r
,
-3-
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
>
l
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ - . _ - - - - - - - - - - - - _ _ _ - - _ _
]
-
-
~
.
Response to Notice of Violation
.
Item 1 (445/8507-01 and 446/8505-01)
'.
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 result of two unrelated administrative oversights in handling the
The violation is
Part 21 notice.
when a "potentially" reportable deficiency was ca
the subject Part 21 notice.
The second administrative oversight
i
involved omission of tne issue when a program was conducted in mid 19
to assure corrective actions were accomplished for prior Part 21
issues.
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),
measures were established in mid 1984 to positively control corrective
programmatic
actions related to Part 21 issues.
notices as "potentially" reportable deficiencies purs
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 was the result of the same identifier being assigned to two
different items.
This was the subject of a previous violation
(445/8440-01).
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 findings related to the RTE-Delta Part 21 notice were correctedAll of t
'
in August 1985.
'
~
,n,
- - . . - - - . - - - - . - - - , - - - -
Response to Notice of Violation
'
- .
,'
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 of the installation.
p
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.
.-
-
.
-
-
Response to Notice of Violation
.
-
Item 2(b) (445/8507-03)
-
1.
Reason for Violation:
.
,
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.
.
.
-
.
.
__.
-
- . _ .
_
._.
--
_ . _ - . _
i'
Response to Notice of Violation-
m
"o
Item 2(c) (445/8507-04 and 446/8505-02)
-
.
.
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)
J
4
4
1
!
t
f
!
!
l
i
l
[
i
l
1
i
.
<
I
,
!
i
!
i
- - - , , , , . . - . . _ . . _ . _
_
.
.
-
_ . , _ _ . . . _ - . . _ . . , . . . _ _ _ _ _ , _ . . . . , _ . . . - . . . _ _ _ . _ _ _ _ . _ . , _ _ _ _ _ , , _ , _ . . _ . _ _ . , _ , _ . , _ . _ . _ _ _ _ _ , , . - . _ , _ . , . _ _ _ . _ _
-
,
_. .
.
._ _
_ _ _ _ _ _ _ _ _ _ . _ _
_ _ _ _ _ _
_ _ - - - - - _
_ _ _ _
_ _ _ _ _ _ _
,
.. .. o
.~
Response to Notice of Violation
Item 2(d) (445/8507-06 and 446/8505-04)
.
P
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.
,
. _ - .
.
____
_ _ _ _ _ _ _ _ _ _ _ _ _ _ -