ML20213A032
| ML20213A032 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/22/1987 |
| From: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8704270351 | |
| Download: ML20213A032 (12) | |
See also: IR 05000445/1985007
Text
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In Reply Refer To:
NR 22 E
Dockets: 50-445/85 07
50-446/85-05
TU Electric
ATTN:
W. G. Counsil
. Executive Vice President
400 N. Olive L.B. 81
Dallas, Texas 75201
/
Gentlemen:
Thank you for your letters of April 2,1986, January 28, 1987
February 20, 1987, and March 27, 1987, in response to our letters dated
February 3,1986, and December 30, 1986. We have reviewed your reply and find
it responsive to the concerns raised in our Notice of Violation. !ic will
review the implementation of your corrective actions during a future inspection
to determine that full compliance has been achieved and will be maintained.
Sincerely,
Original Signed byr
R.E.HALU
E. H. Johnson, Director
Division of Reactor Safety
and Projects
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cc:
TU Electric
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ATTN:
G. S. Keeley, Manager,
Nuclear Licensing
.i
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas
75201
Juanita Ellis
President, CASE
1426-South Polk Street
Dallas, Texas
75224
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RIV/CPTg //EHJohnson
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IBarnes
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8704270351 870422
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ADOCK 05000445
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TU Electric
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Renea Hicks
Assistant Attorney General
Environmental Protection Division
P.O. Box 12548
76711 - 2548
Administrative Judge Peter Bloch
U.S. Nuclear Regulatory Commission
Washington, D. C.
20555
,
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
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RSTS Operator
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R. Martin, RA
RIV File
J. Taylor, IE
J. Konklin, IE
L. Chandler, OGC
D. Weiss,LFMB(AR-2015)
RSB
I. Barnes, CPTG
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Log # TXX-6211
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File # 10130
IR 85-07
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IR 85-05
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January 28, 1987
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U. S. Nuclear Regulatory Commission
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ATTN: Document Control Desk
Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446
INSPECTION REPORT NOS.: 50-445/85-07 AND 50-446/85-05
SUPPLEMENTAL REQUEST FOR INFORMATION TO NRC
NOTICE OF VIOLATION (NOV) ITEMS 1, 2.A AND 2.8
REF:
TUGC0 LETTER TXX-4727 FROM W.G. COUNSIL TO
E. H. JOHNSON DATED APRIL 2, 1986.
,
Gentlemen:
We have reviewed your letter dated December 30, 1986, requesting additional
information to our response referenced above regarding NOV 445/8507-01 and
446/8505-01 (Item 1), 445/8507-02 (Item 2.a) and 445/8507-03 (Item 2.b).
We
hereby respond to the request for supplemental information in the attachment
to this letter.
We requested and received an extension until January 26, 1987, in providing
our response during a telephone conversation with Mr. I. Barnes on January 15,
1987. We requested and received an extension until February 16, 1987, in
providing our response to NOV 445/8507-03 (Item 2.b) during a telephone
conversation with Mr. I. Barnes on January 23, 1987. We requested and
received an extension until January 28, 1987, in providing our response during
a telephone conversation with Mr. I. Barnes on January 26, 1987.
Very truly yours,
&
W. G. Cougsil
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By:-
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G. S. Keeley
Manager, Nuclears vu/
.evsing
RSB:lw
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Attachment
c - Mr. Eric H. Johnson, Region IV
Mr. D. L. Kelley, RI-Regicn IV
Mr. H. S. Phillips, RI-Region IV
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400 North Othe Street
I..B. 81 Dallas Te as 75201
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Attachment to TXX-6211
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January 28, 1987
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Page 1 of 4
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ITEM 1 (445/8507-01 AND 446/8505-01)
SUPPLEMENTAL REQUEST FOR INFORMATION
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.
SUPPLEMENTAL RESPONSE TO ITEM 1
In our previous response we noted the deficiencies involving the Unit 1 RTE-
Delta Potential Transformer Tiltout assemblies were corrected using startup
work permits. We failed to note that inspections and the acceptance of
completed work are inherent in the startup work permit program. We have ~
confirmed these activities were accomplished as documented on the completed
work permits (Z-2912 & Z-2914).
As noted in our review of a previous NRC finding (445/8407-01), the program
for managing 10CFR21 defects was not positively controlled.
In some cases,
and in the case of the RTE-Delta 10CFR21 notice involved in this finding, the
deficiencies were corrected without nonconformance reports.
Under our current program, the Site Coordinator, whose responsibilities are
specified in Procedure NE0-CS-1, " Evaluation of and Reporting of Items / Events
Under 10CFR21 and 10CFR50.55(e)," is responsible for assuring proper
deficiency documentation, including NCRs, are issued.
Our previous response incorrectly indicated that the Unit 2 10CFR21
deficiencies were corrected in August 1985. The work was actually completed
in September 1985 and QA/QC review of the work packages was completed in April
1986.
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Attachment to TXX-6211
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January 28, 1987
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Page 2 of 4
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ITEM 2.a (445/8507-02)
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SUPPLEMENTAL REQUEST FOR INFORMATION
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
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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 I 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-
recurrence. Your response also indicated that any corrective actions deemed
necessary, 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
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were necessary.
SUPPLEMENTAL RESPONSE TO ITEM 2.a
As a result of discussions with the NRC Resident Inspector, and our review of
the Violation, we have determined that a revision to our response is required.
The revised response below provides the supplemental information requested.
1.
Reason for Violation
We admit to the Violation, ano the required information follows.
This violation was the result of inadequate design review of the
Westinghouse equipment drawing by the primary on-site design group after~
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the drawing had been received on-site. The drawing, which specified the
use of grout, disagreed with the Gibbs and Hill, Inc. civil drawing which
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specified Class "E" concrete. Subsequently, this disparity was overlooked
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when an operational traveler was developed which specified the use of
grout without formal design concurrence on incorporation.
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Attachment to TXX-6211
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January 28, 1987
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Page 3 of 4
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- SUPPLEMENTAL RESPONSE TO ITEM 2.a CONT'D
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2.
Corrective-Action Taken
After reviewing grout card No. 186, which documented the material used in
the actual installation, and the results of.the compressive strength test
for the grout used in this application, a design change (DCA-21,179) was
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used to document acceptance of the installation. These actions were
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initiated after identification of the condition via an NRC Inspection
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Report item.
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After further review of this matter,~.two DRs (C-86-12 and C-86-13) were
issued December 29, 1986, to ensure appropriate drawing changes were made;
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to formally document acceptance of the grout used in these and other
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nearby installations; and to specifically identify the root cause of this
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deficiency.
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3.
Action to Prevent Recurrence
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Operational travelers, grout cards, and drawings used during the same time
frame were reviewed for similar installations.- The operational traveler
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review completed on May 15, 1986, indicated that other drawings used for
similar installations did not contain the same disparity as discussed in
Item 1 above. However, the review revealed that grout was used in seven
other installations in Unit I and eight installations in Unit 2 due to
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differences between drawings 2323-SI-0550, 2323-S2-0550, and 1457F29. The
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grout used in these other fifteen installations was evaluated and found to
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have a compressive strength in excess of Class "E" concrete. DCA-21,179
and DCA-26,101 issued November 8, 1986, and November _26, 1986,
,
respectively, were used to document acceptance of the installations in
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Unit I and Unit 2, respectively. Based on the specific nature of the
discrepancies and the results of our review, this violation is considered
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to be an isolated occurrence.
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A Project Directive was issued on July 17, 1986, reemphasizing, a) the
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requirements for properly documenting design alternatives prior to
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initiating construction activities, and b) the precedence of design versus
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vendor documents.
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The review of vendor drawings (except for Fire Protection and HVAC
drawings) is performed by Stone and Webster Corporation (SWEC) in
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accordance with SWEC Procedure PP-053, " Review of Vendor Drawings." The
review of vendor HVAC drawings is performed by Ebasco in accordance with
TUGC0 Procedure ECE-DC-5, " Vendor Document Review." These vendor drawings
are reviewed against design drawings to resolve any discrepancies.
The
review of vendor Fire Protection drawings is performed by Impell
e Corporation in accordance with Impell Procedure IMP-FP-19, " Vendor
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- will be revised to clarify and specifically require the review of vendor
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drawings to insure compliance with design drawings.
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4.
Date of Comoliance
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CPSES is currently in full compliance.
SWEC Procedure PP-053 will be
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revised and. issued by February 27, 1987.
Impell Procedure IMP-FP-19 will
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be revised and issued by April 30, 1987.
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Attachment to TXX-6211
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January 28, 1987
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Page 4 of 4
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ITEM 2.b (445/8507-03)
SUPPLEMENTAL REQUEST FOR INFORMATION
With respect to the corrective steps taken, please describe what formal
actions were taken (e.g., specification revision) to justify the change in
output voltage from 10 +/- 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.
SUPPLEMENTAL RESPONSE TO ITEM 2.b
TU Electric Quality Assurance is in the process of obtaining related
information from the vendor and reviewing site documentation. We anticipate
submitting our response no later than February 16, 1987.
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Log # TXX-6284
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File # 10130
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IR 85-07
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IR 85-05
7tlELECTRIC
Ref # 10CFR2.201
DwI ,Yjr,,a,,,,
February 20, 1987
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U. S. Nuclear Regulatory Commission
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ATTN: Document Control Desk
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Washington, DC 20555
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SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
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DOCKET NOS, 50-445 AND 50-446
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INSPECTION REPORT NOS.: 50-445/85-07 and 50-446/85-0a
SUPPLEMENTAL REQUEST FOR INFORMATION TO NRC
NOTICE OF VIOLATION (N0V) ITEMS 1, 2.a and 2.b
REF:
1) TV Electric Letter TXX-4727 from W. G. Counsil to
E. H. Johnson dated April 2, 1986
2) NRC letter from E. H. Johnson to W. G. Counsil
dated December 30, 1986
3) TV Electric Letter TXX-6211 from W. G. Counsil to NRC
dated January 28, 1987
Gentlemen:
We reviewed your letter (Reference 2) requesting additional information on the
subject inspection report, and responded to the NOVs in our letter TXX-6211
(Reference 3).
In our response to NOV 445/8507-03 (Item 2.b), we stated that
TV Electric Quality Assurance was in the process of obtaining related
information from the vendor and reviewing site documentation, and we
anticipated submitting our response no later than February 16, 1987.
We
requested and received an extension in providing our response to NOV 445/8507-
03 (Item 2.b) until February 20, 1987, during a telephone conversation with
Mr. I. Barnes on February 17, 1987. We hereby respond to Item 2.b in the
attachment to this letter.
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Very truly yours,
@
W. G. Counsil
RSB:lw
Attachment
c - Mr. E.'H. Johnson, Region.IV~
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Mr. D. L. Kelley, RI - Region IV
Mr. H. S. Phillips, RI - Region IV
Omd1 Tl (fh(fY& 00'-
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400 North Olise Street
I..li 81 I)aila3, Texas 75201
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Attachment to TXX-6284
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February 20, 1987
Page 1 of 2
ITEM 2.b (445/8507-03)
SUPPLEMENTAL REQUEST FOR INFORMATION
With respect to the corrective steps taken, please describe what formal
actions were taken (e.g., specification revision) to justify the change in
output voltage from 10 +/- 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.
SUPPLEMENTAL RESPONSE TO ITEM 2.b
Further evaluation of the apparent violation revealed a need to revise our
original response. Accordingly, the following revised response is submitted.
1.
Reason for the Violation
The root cause of the out-of-tolerance condition was a relocation of the
Westinghouse subtier supplier's test facility in 1978. A change in the
local power level from 240v nominal at the old test facility to 277v
nominal at the new location was not initially detected. This change
affected the test result output. The supplier representative failed to
detect the apparent out-of-tolerance condition noted on the test report
prior to release of the equipment from the subtier suppliers shop (Halmar
Electronic Corporation) and subsequent shipment to CPSES.
The out-of-tolerance conditions noted on the test report was not detected
by CPSES QC receiving inspection personnel because Westinghouse supplied
non-ASME equipment is receipt accepted based on the Westinghouse Quality
Release (QR) being complete and general conformance verification to
purchase order requirements.
2.
Corrective Steos Taken and Results Achieved
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Westinghouse Engineering performed a review of test data for all Electric
Hydrogen Recombiner (EHR) Silicon Controlled Rectifier (SCR) panels tested
during the period May 13, 1975 to March 8, 1981, bracketing the period
during which the 240 to 277 volt plant power transition effect on test
results may not have been recognized.
The result of the documentation
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review for the 209 SCRs revealed an additional out-of-tolerance condition
of the same nature, which has been documented on a Westinghouse Deviation
Notice (DN).
The Westinghouse Engineering review has established that
there was no adverse effect on the performance or function of the
equipment as a result of the deviation.
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Attachment to TXX-6284
February 20, 1987
Page 2 of 2
ITEM 2.b (445/8507-03)
SUPPLEMENTAL RESPONSE TO ITEM 2.b - CONT'D
2.
Corrective Steos Taken and Results Achieved - Cont'd
The output voltage specification was changed and documented in Halmar test
procedure TP-001 and approved by Westinghouse Engineering per Westinghouse
DN No. 26961 to compensate for the change in the test power supply.
3.
Corrective Steos Which Will Be Taken to Avoid Further Violations
Westinghouse's revaluation revealed only two panels out of 209
manufactured in the given time period to exhibit this out-of-tolerance
condition.
Therefore, this is considered a limited incident of personnel
error by Westinghouse's subvendor (Halmar) specific to these panels.
These errors were not identified in the Westinghouse surveillance review
of the test data due to the sampling nature of this review.
Since the
time period of this issue, but not as a result of this apparent violation,
Westinghouse subtier supplier generated documentation has been subjected
to increased frequency and depth of review by Westinghouse prior to
authorization for shipment.
4.
Date When Full Comoliance Will Be Achieved
CPSES is presently in compliance.
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Log # TXX-6349
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File # 10130
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Ref # 10CFR2.201
K' ELECTRIC
March 27, 1987
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U.S. Nuclear Regulatory Commission
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ATTN: Document Control Desk
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Washington, D.C.
20555
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SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
~
DOCKET NOS. 50-445 AND 50-446
INSPECTION REPORT NOS. 50-445/85-07 AND 50-446/85-05
CLARIFICATION OF SUPPLEMENTAL RESPONSE TO NOV 445/8507-01
AND 446/8505-01
REF: 1) TUGC0 letter TXX-4727 from W. G. Counsil to E. H. Johnson dated
April 2, 1986
2) TU Electric letter TXX-6211 from W. G. Counsil to the NRC dated
January 28, 1987
Gentlemen:
In further review of our supplemental letter identified in Reference 2, we
have determined that a clarification to the subject response is required. The
supplemental request for information for Notice of Violation 445/8507-01 and
446/8505-01 (Reference 2) has been restated to aid in understanding our
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revised response.
ITEM 1 (445/8507-01 AND 446/8505-01)
SUPPLEMENTAL REQUEST FOR INFORMATION
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.
REVISED SUPPLEMENTAL RESPONSE TO ITEM 1
In our response, we noted the deficiencies involving the Unit 1 RTE-Delta
Potential Transformer Tiltout assemblies were corrected using startup work
permits. We fail rd to note that inspections and the acceptance of completed
l
work are inherent in the startup work permit program. We ha/e confirmed these
'
activities were accomplished as documented on the completed work permits
(Z-2912 & Z-2914).
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[ x) North Olne Street
1. H M t Da!!a. lexa 75201
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MARCH 27, 1987
PAGE 2 of 2
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REVISED SUPPLEMENTAL RESPONSE TO ITEM 1 - CONT'D
As noted in our review of a previous NRC finding (445/8407-01), the program
for managing 10CFR21 defects was not positively controlled.
In some cases,
and the case of the RTE-Delta 10CFR21 notice involved in this finding,-the
deficiencies were corrected without nonconformance reports. Our current
programs for reportability evaluation and nonconformance control are specified
in procedures NE0 CS-1, " Evaluation of and Reporting of Items / Events under
10CFR21 and 10CFR50.55(e)," and NEO 3.05, " Reporting and Control of
Nonconformances." Procedure NEO CS-1 requires personnel to notify the Site
Coordinator upon receipt of 10CFR21 information.
The Site Coordinator is
required to transmit the documented information concerning a potentially
significant item to the appropriate manager in the Nuclear Engineering and
Operations group. Procedure NEO 3.05 states that Engineering and Operations
are responsible for initiating or requesting Nonconformance Reports (NCRs),
where required, for identified nonconformances. These programs should ensure
that 10CFR21 notifications are evaluated and any required NCRs are initiated.
Our previous response incorrectly indicated that the Unit 2 10CFR21
deficiencies were corrected in August 1985. The work was actually completed
in September 1985 and QA/QC review of the work packages was completed in April
1986.
Very truly yours, 1
f&lka/
W. G. Counsil
RSB/ef
c- Mr. E. H. Johnson,: Region IV
t
Mr. D. L. Kelley, RI - Region IV
Mr. H. S. Phillips, RI - Region IV
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