ML20214V196
| ML20214V196 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/03/1986 |
| From: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8612090567 | |
| Download: ML20214V196 (3) | |
See also: IR 05000445/1986001
Text
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DEC 3 1986
In Reply Refer To:
Dockets: 50-445/86-01
50-446/86-01
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 letters dated October 13, 1986, and November 4, 1986, in
response to our letter dated August 29, 1986. As a result of our review, we
find we are in need of additional information with respect to Item A in the
Notice of Violation (N0V) and Items B and C in the Notice of Deviation (NOD).
NOV Item A: With respect to Item A.1, you did not provide the " Reason for
Violation" regarding your failure to implement the requirements of
Procedure CP-QP-16.3 for Deviation Reports (DRs) which were generated for
non-ASME components; e.g., HVAC equipment. Additionally, in regard to
" Corrective Action Taken," please confirm that the review of DRs was not
limited to just those associated with ASME equipment. With respect to Item A.4,
staff review of Procedure CP-QAP-16.1, Revision 25, finds that the document
literally requires that nonconforming items identified on nonconformance
reports (NCRs) are to be clearly identified with signs, barriers, and/or hold
tags. Accordingly, while we have no questions concerning the subsequent
revision made to this procedure, we do not concur with your stated reason for
disagreement with this finding. Therefore, please provide the information
required by the NOV for this item.
With respect to Item A.6, your response indicates that you have restricted
consideration of the violation to Comanche Peak Response Team (CPRT)
activities only. The fact that you acknowledged in the " Reason for Violation"
for Item A.3, the existence of conditions outside of CPRT activities which
were not documented on NCRs, supports the stated violation. Therefore, please
provide the information required by the NOV for this item.
N0D Item B: With respect to Items B.1, B.2, and B.3, pleate identify what
specific documented actions were taken to prevent recurrence for each of the
three stated examples.
N00 Item C: Please clarify whether surveillances and/or audits have
specifically addressed the work activities of the QA/QC engineer applicable to
this deviation.
RIV:CPRT /M [ DRSP
IBarnes:gb EHJohnson
// /2r/86 el' gv/v/86
8612090567 861203 /[OI l l
PDR ADOCK 05000445
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Texas Utilities Generating Company' 2
We have no further questions regarding Items A.2, A.3, A.5, and B of the NOV -
and Item A of the N00. Your response to Item B in the NOV will be factored
into our inspection of ISAP VII.a.9 implementation, as it applies-to cable
procurement.
Please provide the supplemental information within 20 days of the date of this
letter.
Odginal signed By
E. H. Johnson .'- .
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E. H. Johnson,' Director >
Division of Reactor Safety
and Projects -
...
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cc.
Texas Utilities Electric Company - ,
ATTN: G. S. Keeley, Manager
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
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
Elizabeth B. Johnson
Administrative Judge
Oak Ridge National Laboratory
P. O. Box X, Building 3500
Oak Ridge, Tennessee 37830
(continuednextpage)
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Texas Utilities Generating Company 3
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Dr. Kenneth A. McCollom- s
1107 West.Knapp i
Stillwater, Oklahoma 74075
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Dr. Walter H.-Jordan '
.
881 Outer Drive ,
0ak Ridge, Tennessee 37830 * ' -
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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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- RRI-0PS *RSTS Operator
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- T. F. Westerman, RSB DRSP
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- RIV File J. Taylor, IE
- D. Weiss, LFMB (AR-2015) J. Conklin, IE
- I. Barnes, CPTG
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Log # TXX-6070
f File # 10130
IR 86-01
i TEXAS LTILITIES GENERATING COMPANY IR 86-01
SKYWAY TOWER . 4Ee NORTH OLIVE STREET. I.B. OR . DALLAS, TEXAS 75301
November 4, 1986
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NOV 6 1986
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Mr. Eric H. Johnson, Director
Division of Reactor Safety and Projects
U. S. Nuclear Regulatory Commission
611 Ryan Plaza Drive, Suite 1000
Arlington, Texas 76012
SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446
SUPPLEMENTAL RESPONSE TO NRC NOTICE OF VIOLATION
AND NOTICE OF DEVIATION INSPECTION REPORT
NOS. 50-445/86-01 AND 50-446/86-01
Dear Mr. Johnson:
We responded to Inspection Report Nos. 50-445/86-01 and 50-446/86-01 on
October 13, 1986 (TXX-5048). In the response to Notice of Deviation, Item A
(445/8601-D-04), we stated that CPSES Engineering is still evaluating the
Notice of Deviation and the tests and requirements for the Auxiliary Feedwater
Pumps. In addition, we committed to provide a complete response by November
3, 1986.
NOTICE OF DEVIATION
ITEM A (445/8601-0-04)
A. FSAR Section 10.4.9.1 states that the Auxiliary Feedwater (AFW) System is
capable of supplying the minimum required flow to at least two steam
generators against a back pressure equivalent to the accumulation pressure
of the lowest set main steam safety valve plus the system frictional and
static losses.
FSAR Table 14.2-2, Sheet 51, Test Method No. 3 commits the applicant to
verify through preoperational testing that the hydraulic performance of
each AFW pump meets design requirements and is within limits assumed in
the appropriate accident analysis.
In deviation from the above, preoperational tests ICP-PT-37-01, " Auxiliary
Feedwater System (Motor Driven Pumps)," and ICP-PT-37-03, " Auxiliary
Feedwater System (Turbine Driven Pumps)," failed to test the AFW pumps
against a back pressure determined using main steam safety valve
accumulation pressure, but instead incorrectly used the safety valve iqi
pressure. This amounts to a less conservative 36 psi reduction in the
back pressure during this test. Consequently, the pump capacity data
recorded in the above completed test packages are incorrect for the
maximum back pressure test.
1
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'.- 'TXX-6070
t November 4, 1986
Page 2 of 2
'a
RESPONSE TO ITEM A
1. Reason for Deviation
'
The acceptance criteria in the test procedures deviated from the design
limits described in FSAR Section 10.4.9.1 due to incomplete documentation
of the accident analysis assumptions. The acceptance criteria for the
test procedures were based on the acceptance criteria in FSAR Table 14.2-2
and Secticn 15.2 neither of which documented the 3% accumulation.
2. Corrective Action Taken
To ensure the adequacy of the Auxiliary Feedwater System, the test
procedures and data are being reviewed and evaluated.
The evaluation includes a review of the test objectives, acceptance
criteria, test methodology, and data. The results of this evaluation will
be attached to the Unit I test procedures and test data packages. The
Unit 2 test procedures will be revised to incorporate the evaluation
findings prior to the Unit 2 tests.
FSAR Table 14.2-2 and Chapter 15 will be revised to document the
appropriate acceptance criteria.
3. Action to Prevent Recurrence
The desigr; limits assumed in each accident analysis will be reviewed
against the FSAR Chapter 15 documentation and the FSAR corrected as
required. Any resulting FSAR changes will be reviewed against the
affected test procedures / test data packages and corrective action
documented as discussed above for the Auxiliary Feedwater System.
4. Qate of Full Como11ance
TUGC0 will be in full compliance prior to fuel load or we will submit a
specific request to load fuel with this deficiency outstanding.
Very truly yours,
bW
W. G. Counsil
RSB/amb
j c - Region IV (Original + 1 copy)
Director, Inspection and Enforcement (15 copies)
U. S. Nuclear Regulatory Commission
i Washington, D. C. 20555
Mr. V. S. Noonan
4
Mr. D. L. Kelley
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Log # TXX-5048
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Filef 10130
TEXAS UTILITIES GENERATING COMPANY IR 86-01
es,w ve ma . a. ==,= ouve me a n . .*ua. rsma == 86-01
October 13, 1986
." E.".*d%2fL b@M MMT
Mr. Eric H. Johnson Director EIdE
Division of Reactor Safety and Projects J IL lg
U. S. Nuclear Regulatory Commission '
611 Ryan Plaza Drive, suite 1000
Arlington, Texas 76012
SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET N0S. 50-445 AND 50-446
RESPONSE TO NRC NOTICE OF VIOLATION AND NOTICE OF DEVIATION
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INSPECTION REPORT N05 : 50-445/86-01 AND 50-446/86-01
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Dear Mr. Johnson:
We have reviewed your letter dated August 29, 1986, concerning the inspection
conducted by Mr. T.F. Westerman and other members of the Region IV Comanche
Peak Group during the period November 1, 1985, through January 31, 1986. This
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 was a Notice of Violation and Notice of Deviation.
We requested and received a two week extension in providing our response
during a telephone conversation on September 29, 1986.
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We hereby respond to the Notice of Violation and Notice of Deviation in the
atttchment to this letter.
Very truly yours,
e
W. G. Counsil
R$8/gj
Attachments
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c-Region IV (Original + 1 Copy)
Director, Inspection & Enforcement (15 copies)
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Mr. V.S. Noonan
Mr. D.L. Kelley
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Attachment to TXX-5048 Page 1
October 13, 1986
HDIlGI QE VIOLATION ;
ITEMS 81 THROUGH 81 (111/A101-y-11 AND 146/gigi-y-91)
A. Criterion XV of Appendix 8 to.10 CFR Part 50 requires that measures be
established to prevent the inadvertent use of nonconforming items, and !
g that these measures include procedures for identification, documentation,
segregation, disposition, and notification to affected organizations. It
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further requires that nonconforming items be reviewed and accepted,
rejected, repaired, or reworked in accordance with documented procedures.
E
i Section 15.0 of Revision 5 to ths TUGCo Quality Assurance Plan (QAP)
- states, in part, "The identificati.'n, documentation, segregation, and
i disposition of nonconforming materials, parts, or components is outlined
in written procedures...." A nonconformance report is used to document
deficiencies unless another method is prescribed by a specific
procedure / instruction. Nonconformance reports . . . are made available to
TUGCo for evaluation ....(and) TUGCo QA assures that periodic evaluations
i of these reports are forwarded to TUGCo management identifying trends
adverse to quality."
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Section 3.9 of Revision 3 to the TUGCo Operations Administrative Control
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and Quality Assurance Plan states, in part, " Material, parts and
- components which are determined to be nonconforming, shall be identified i
- and re>orted. Nonconformance reports shall be prepared which identify and ;
l descri>e the nonconformance, the disposition of the nonconformance, and '
j the . . . acceptability of the item after the disposition has been
completed . . . ." j
l Contrary to the above, established procedures for handling of I
nonconforming materials, parts, or components were not effectively
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- - implemented as evidenced by the following observed conditions: j
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h Deviation Reports (DRs) enerated by ERC to document nonconforming
conditions did not, in a 1 cases, result in the initiation of l
l nonconformancereports(NCRs)bytheTUGCoQA/QCCoordinatoras ,
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required by Revision I to Procedure CP-QP-16.3 dated August 28, 1985.
h2 The TUGC0
Revision I to QA/QC Coordinator
Procedure CP-QP-16.3 failed
datedtoAugust
initiate28,
NCRs
1985,asforrequired numerousby
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ERC identified out-of-scope observations which were subsequently
- repaired or reworked.
h Nonconforming items identified by the TUGCo QC Ins ection Process
Control Group, and subsequently reworked and repal ed, were not
c documented on NCRs as required by Revision 9 of Procedure STA-405
i dated November 11, 1985, but rather on three-part office memos.
4. A large number of nonconforming items have not been physically
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identified with signs, barriers, or hold tags as required by Revision
i 25 of Procedure CP-QAP-16.1 dated August 17, 1985.
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Attachment to TXX-5048 Page 2
October 13, 1986 .,/
y fept
fiQJEI Of VIOLATION
M A.1 THROUGH A.i (115/85.Q1-1-11 AliD 316/81M-1-91)-CQtiI'D
hDeficiencyNotifications(DNs),asrequiredbyRevision4ofProcedure
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N61-1 dated December 10, iv65, are to be used only for documenting
deficient conditions identified during repair or replacement of
mechanical components previously accepted by TUGCo. However, numerous
- instances have been identified where DNs have also been used to
imprope*1y document nonconformances and effect the issuance of work
i requests and work orders.
,
6. Failure to initiate required NCRs impacts on the validity of the
monthly trend analysis report required by Revision 1 of Procedure
. QI-QP-17.0-1. The report is required to contain potentially adverse
trands, which are based on the number of NCRs issued during the report
period,
ftESPONSE IQ M 81 IliBNiti A.1
1
1. Reason for Violation
Item 1 - The requirements of CP-QP-16.3 were not implemented for DRs .
[ generated when the component identified fell under the scope of ASNE
Section XI program.
Item 2 - CP-QP-16.3 R1 required an evaluation to be done on out-of-scope
observations to determine whether they warrant the issuance of an NCR.
, There have been instances where the evaluation did not require the
y ,
issuance of an NCR when in fact an NCR should have been issued.
G
Item 3 - TUGC0 QC Inspection Process Control Group, used IPC-3 which did
C"> not require that an NCR be issued when the inspectors noted a deficiency
that was out-of-scope from the inspector's checklist. Instead 3-part
, memos were used to notify personnel of deficiencies in order to effect
corrections _- x
Item 4 do not agree with the alleged' iolation because QP-QAP-16.1
R25 did not' require the~ application of f 1d tag in all cases. The items
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were being controlled since whether or not hold tags were placed on the )
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\ items, further processing of the items was controlled through work package
holds. However, a revision to CP-QAP-16.1 has been made which now
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requires the placing of hold tags on nonconforming items where practicable
regardless of the stage of component processing. If a hold tag is not
placed, the initiator must provide a brief justification on the NCR.
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Item 5 - This violation resulted from deviating from the requirements
contained within N61-1 dated 12/10/85. In several instances, DRs were
received from ERC (that were associated with the N61-1 program) and TUGCo
incorrectly used DNs to process these DRs.
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Attachment to TXX-5048 Page 3
October 13, 1986
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RESPONSE IQ IIIt!181 THROUGH 81 IQtiI'Q
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Item 6 - We disagree with this violation. Quality Instruction
QI-QP-17.0-1 " Preparation and Distribution of Trend Reports" contains
criteria for the identification of Potential Adverse Trends (PAT) during
the monthly NCR trend results evaluation. Since the objective of the
Trend Program is the timely identification of activities which may require l
corrective action, NCRs initiated per CP-QP-16.3 " Processing CPRT i
Deviation Reports /0ut of Scope observations" are excluded from the Trend
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Program due to the inability to clearly identify current program
weaknesses based on analysis of deficiencies not related to present
conditions or requirements. In order to clearly exclude these NCRs from
trending, these NCR numbers are suffixed with an "X" and do not have a
specific Trend Code applied. Trend Reports provided for management review 1
therefore contain evaluation results pertinent to ongoing construction and
inspection / testing activities.
The CPRT Program Plan describes methods used by CPRT to develop, approve
and document corrective action for deviations or deficiencies identified
by CPRT. Methods used include identification of adverse trends through
the evaluation of related observations and/or deviations. For these
items, CPRT provides reports of adverse trends or areas requiring TUGCo- ,
management review and action as appropriate. '
2. Corrective Action Igkg8
Item 1 - A review of DRs received was conducted and NCRs were issued for
all DRs not previously documented on NCRs.
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Item 2 - CP-QP-16.3 R2 now requires that all out-of-scope observations be
documented on NCRs regardless of the described condition. All out-of-
scope observations have been reviewed to determine if NCRs were issued for
them. NCR0 have now been issued for all out-of-scope observations.
Item 3 - NCR E-86-200637 R3 was generated to disposition all items listed
on the 3-part menos.
Item 5 - Per CP-QP-16.3 R2, DNs may no longer be used to process DRs.
NCRs are used to document deficiencies regardless of the stage of
component processing. All previous DRs have been addressed as noted in
Item 1 above.
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Attachment to TXX-5048 Page 4
October 13, 1986
RESPONSE IQ IIIH1 A.1 THROUGH 8 1 fallI'Q
3. Action in Prevent Recurrence
Item 1 - CP-QP-16.3 Rev. 3 was revised to delete the reference to N61.1.
This revision unequivocally requires that all DRs received be documented
in accordance with CP-QP-16.0 "Nonconformances" or CP-QAP-16.1 " Control of
Nonconforming Items".
Items 2 - Same as corrective action noted above.
Item 3 - The Inspection Process Control Program was replaced by the
Inspection Surveillance Program, which requires NCRs to be generated en
all deficiencies noted.
Item 5 - Same as corrective action noted above.
4. Qalg gf Egil comoliance:
Item 1 - CPSES is currently in full compliance.
Items 2 - CPSES is currently in compliance with CP-QP-16.3.
Item 3 - CPSES is currently in compliance with the Inspection Surveillance
Program.
Item 5 - CPSES is currently in compliance with the CP-QP-16.3.
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Attachment to TXX-5048 Page 5
October 13, 1986
NOTICE DE VIOLAIl0N
M A (115/Aln-Y-11 als 115/A691-Y-Ai)
B. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section
5.0, Revision 3, dated July 31, 1984, of the TUGC0 QAP, requires that
activities affecting quality shall be prescribed by and accomplished in
accordance with documented instructions, procedures, or drawings of a type '
appropriate to the circumstances.
Paragraph 6.15.1(t) of Gibbs and Hill Electrical Erection Specification
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2323-ES-100, Revision 2, dated October 15, 1980, requires: (1) that
field tests shall be performed by the Contractor on all cable reels in
accordance with the manufacturer's recommendations, and (2) that the owner
will witness these tests.
Contrary to the above, the specified field tests of cable reels were -
neither prescribed by implementing procedures nor performed.
RESPONSE IQ M 3
It is our opinion that the conditions described in this Notice of
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Violation item are not a violation. None cf the manufacturers that have
supplied cable reels to CPSES have recossended that any field tests be run
on cable reels.
CPSES procurement documents invoke and reference all applicable
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specifications and/or testing which is required of our manufacturers. The
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required certification / documentation is transferred to CPSES with the
shipment of cable and is reviewed for acceptability by receiving
inspection and quality control. Site procedures invoke additional 1
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acceptance testing of the individual conductors and cables after '
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installation. These tests are more stringent than testing in the bulk j
reel form.
The requirements in paragraph 6.15.1(t) of electrical erection
specification 2323-ES-100 are meaningless because no cable reel field
tests have been recommended and are redundant because all necessary
testing is already being accomplished by the manufacturer.
In order to eliminate this redundancy in the specification, the paragraph
in question was removed from the specification by design change DCA-24088
! issued January 24, 1986.
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Attachment to TXX-5048 Page 6
October 13, 1986
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ff0I1G1 RE DEVIATION
1I15 A (lil/fdQ1-2-01)
A. FSAR Section 10.4.9.1 states that the Auxiliary Feedwater (AFW) System is
capable of supplying the minimum required flow to at least two steam
generators against a back pressure equivalent to the accumulation pressure
of the lowest set main steam safety valve plus the system frictional and
static losses.
FSAR Table 14.2-2, Sheet $1, Test Method No. 3 commits the applicant to
verify through preoperational testing that the hydraulic performance of
each AFW pump meets design requirements and is within limits assumed in
the appropriate accident analysis.
In deviation from the above, preoperational tests ICP-PT-37-01, " Auxiliary
Feedwater System (Motor Driven Pumps)," and ICP-PT-37-03, " Auxiliary
Feedwater System (Turbine Driven Pumps)," failed to test the AFW pumps
against a back pressure determined using main steam safety valve i
accumulation pressure, but instead incorrectly used the safety valve it.t '
pressure. This amounts to a less conservative 36 psi reduction in the
back pressure during this test. Consequently, the pump capacity data
recorded in the above completed test packages are incorrect for the
maximum back pressure test.
RESPONSE IQ IIEl$ &
CPSES Engineering is still evaluating the Notice of Deviation, the tests
and requirements for the Auxiliary Feedwater Pumps. We intend to provide
,
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a complete response by November 3, 1986.
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Attachment to TXX-5048 Page 7
October 13, 1986
HQI1G1 QE DEVIATION
IIEH B.1 (115/1191-D-11) i
B. Section 4 of Revision 3 t'o CPRT Procedure CPP-009 states, in part, ,
" Qualified QA/QC Review Team personnel perform field inspections of j
)/ 3
specific hardware items and reviews of appropriate documents in accordance
with approved instructions ..."
In deviation from the above, the following example was noted where field l
reinspections were not performed in accordance with approved instructions: ;
1. Attribute 1.f in Section 5.2.6.2 of Quality Instruction (QI) QI-025, ,
Revision 1, which states, in part, "All lines with operating temperatures '
below 2000F may be installed with a minimum of one inch clearance, I
includir.g insulation, with respect to other piping," was signed off as ,
acceptable by the ERC inspector for Verification Package No. I-M-LBCO-038.
However, independent inspection showed an existing clearance of 0.75 inch
between spool piece 2Q2 of drawing BRP-CS-1-SB-060 and the inspected line
at a point 12 inches above sleeve 3.
! RES2DNIE IQ IIEB 1 1
1. Reason f.g.t Deviation
'
ERC investigation confirmed the stated condition. A 0.75-inch clearance
existed between spool piece No. 2Q2 on Drawing BRP-CS-SB-060 at a point 12
inches above sleeve No. 3 on the inspected line. The ERC inspector
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accepted this attribute when in fact a minimum 1-inch clearance was
,
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required.
2. Corrective AGliGB Taken
i Deviation Report (DR) number I-M-LBC0-038-DR-1 was prepared on March 18,
1986, to document the existence of the pipe to pipe insulation clearance
of 0.75-inch. Nonconformance Report (NCR) number M-25226N was generated
as a result of the DR to disposition the above condition.
3. Action 12 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. Actions taken to address the error and preclude
recurrence typically included one or more of the following, as necessary:
0 Documented retraining of the inspector (s) to the pertinent Quality
Instruction (s),
O Clarification or revision of the Quality Instruction.
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.
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Attachment to TXX-5048 Page 8
October 13, 1986
RESPONSE IQ IIH R.1 f&fil'D
An Overview Inspection Program was implemented to reinspect a sample of
each Inspector's work. Action is ongoing to analyze the results of the
Overview Inspection Program, which includes pertinent inspector error data
fromothersources(i.e.,NRCinspections,etc.).
4. DalsgfEgilComo11ance
Corrective action will be completed commensurate with the final
disposition of nonconformance report M-25226N. Results of the Overview
Inspection Program are scheduled to be completed by October
31, 1986.
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Attachment to TXX-5048 Page 9
October 13, 1986
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HQIlCE Of DEVIATION
IIEB 31 (115/A621-0-12)
B. Section 4 of Revision 3 to CPRT Procedure CPP-009 states, in part,
" Qualified QA/QC Review Team personnel perform field inspections of
specific hardware items and reviews of appropriate documents in accordance
with approved instructions
3 In deviation from the above, the following example was noted where field
reinspections were not performed in accordance with approved instructions:
2. Attribute 1.f in Section 5.2.6.3 of QI-025 Revision 1, which requires
that all lines with operating temperatures less than 2000F be installed
such that an air gap exists between the pipe, or pipe insulation, and
'
other objects, was signed off as acceptable by the ERC inspector for
Verification Package No. I-M-LBC0-144. However, independent inspection
identified a portion of a pipe support in contact with the insulation of l
.
the inspected line at approximately 14 feet south of the 760 bend in the
package.
RESPONSE IQ IIIM R.1
1. Reason Enr Deviation !
ERC investigation confirmed the trapeze hanger is touching the insulation
on the inspected line. The ERC Inspector did not note this condition at
the time of his original inspection.
, 2.
,
Corrective Action Taken )
Deviation Report (DR) number I-M-LBC0-144-DR-3 was prepared on March 14, l
1986, to document the clearance deviation. Based in part on this DR, I
i Nonconformance Report (NCR) number M-23475N R-1 was generated to
,_
disposition this condition.
3. Action in Prevent Recurrence
In cases where inspector error was evident, the inspector and the lead
inspector or population engineer discussed specifics to deteraine why the
error ocurred. Actions taken to address the error and preclude recurrence
! typically included one or more of the following, as necessary:
0 Documented retraining of the inspector (s) to the pertinent Quality
Instruction (s),
o Clarification or revision of the Quality Instruction.
At the discretion of the lead inspector, formal and informal group
meetings were held to discuss inspectors error on a generic basis. These
discussions allowed appropriate information to be disseminated to various
cognizant ERC inspectors.
An Overview Inspection Program was implemented to reinspect a sample of
each Inspector's work. Action is ongoing to analyze the results of the
overview Inspection Program which includes partinent inspector error data
from other sources (i.e., NRC inspections, etc.).
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Attachment to TXX-5048 Page 10
October 13, 1986
RESPONSE IQ IIEB R.1 - CQlil'Q
4. DalgafEullComoliance
Corrective action will be completed coincident with final disposition of
NCR M-23475N R-1. Results of the overview Inspection Program are ,
scheduled to be completed by October 31, 1986.
.
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Attachment to TXX-5048 Page 11
October 13, 1986
lfD11.([ DE DEVIATION
IIB 3,1 (ill/ASAl-D-11)
B. Section 4 of Revision 3 to CPRT Procedure CPP-009 states, in part, !
" Qualified QA/QC Review Team personnel perform field inspections of
specific hardware items and reviews of appropriate documents in accordance
with approved instructions ...."
In deviation from the above, the following example was noted where field
reinspections were not performed in accordance with approved instructions:
3. Attribute 1.d in Section 5.2.4 of QI-025, Revision 1, which states, in
par', " Ensure that the actual piping dimensions are in agreement with
those shown on the piping isometric ....," was signed off as acceptable by
the ERC inspector on December 9,1985, for Verification Package No. I-M- l
LBCO-144. However, field survey acasurements taken by Brown & Root on
December 6, 1985, in response to an ERC request, showed the distance from
the end of the containment penetration at field weld 18-A to the working
point of the 760 bend as 10 feet 5 7/16 inches with respect to a :
distance (with a tolerance of +2 inches) indicated by the applicable l
Isometric Drawing BRP-CC-1-RB-046 of 10 feet 8 1/8 inches. '
RESPONSE IQ IIM H.1
1. Egnga f.gr Deviation
'
An ERC investigation confirmed the stated condition. The difference
between the Brown and Root field survey results and the dimension shown on
- . the isometric drawing exceeds the +2 in. Tolerance. The ERC Inspector did
not note this condition at the time of his original inspection.
2. Corrective Action Taken
,
,
'
Deviation Report (DR) I-M LBCO-144 DR2 was prepared on March 14, 1986, to
document the tolereance deviation. Based in part on this DR,
Nonconformance Report (NCR) M-23475N R-1 L s generated to disposition this
condition.
3. Action in Prevent Recurrence
In cases where inspector error was evident, the inspector and the lead
inspector or population engineer discussed specifics to determine why the
arror ocurred. Actions taken to address the error and preclude recurrence
i typically included one or more of the following, as necessary:
l
l
0 Documented retraining of the inspector (s) to the pertinent Quality
'
Instruction (s),
l 0 Clarification or revision of the Quality Instruction.
At the discretion of the lead inspector, formal and informal group
meetings were held to discuss inspector error on a generic basis. These
discussions allowed appropriate information to be disseminated to various
engn bant ERC insoectors. j
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Attachment to TXX-5048 Page 12
October 13, 1986
!
RESPONSE IQ 112 R.1 CQlfI'Q
An Overview Inspection Program was implemented to reinspect a sample of
each Inspector's work. Action is ongoing to analyze the results of the
Overview Inspection Program which includes pertinent inspector error data
from other sources (i.e., NRC inspections, etc.).
4. Q31ggfEgilComo11ance
Corrective action will ba completed coincident with final disposition of
NCR M-23475N R-1. Results of the Overview Inspection Program are
scheduled to be completed by October 31, 1986.
.
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Attachment to TXX-5048 Page 13
October 13, 1986
NOTICE QE DEVIATION
HEH B.i (fil/81Q1-D-D)
B. Section 4 of Revision 3 to CPRT Procedure CPP-009 states, in part,
" Qualified QA/QC Review Team personnel perform field inspections of
specific hardware items and reviews of appropriate documents in accordance
) with approved instructions..."
In deviation from the above, the following example was noted where field
reinspections were not performed in accordance with approved instructions:
4. Paragraph 6 on page 34 of Attachment 6.17 of QI-058 requires (for vendor
safety wiring of attachment bolts between the forward bracket assembly and
the snubber assembly) that the inspector shall verify that the lockwire is
not damaged. Independent inspection showed for Verification Package No.
I-5-PS42-021 that the inspection checklist was accepted.by the ERC
inspector despite the presence of a broken lockwire on the snubber adaptor
plate.
RESPONSE IQ U E5 B.i
1. Reason f.g.t Deviation
l
Inspection for damaged lockwire was not included as an attribute on the
QI-058 inspection checklist. However, Attachment 6.17 required that the
inspector verify that the lockwire is not damaged. Therefore, the ERC
inspector noted the broken lockwire as an out-of-scope observation in lieu
of an in-scope deviation.
'
2. Corrective Action Iaken
An out-of-scope observation (005) number 289 was generated on November 11,
,
1985. Subsecuently, Nonconformance Report (NCR) M-234474 was prepared and
I dispositionec to replace the broken lockwire on the snubber adapter bolts.
l
This action is addressed via TUGC0 work request No. 7288.
In order to clarify inspection requirements, QI-037 and QI-05S are
currently being revised to include the inspection of lockwire on snubber
adaptor plate bolts. In addition, 36 Verification Packages from the PS7N
population and 11 Verification Packages from the PS42 population have been
reinspected, via a supplemental inspection instruction, to verify that
-lockwires are installed and not damaged. This supplemental instruction
will be included in QI-037 and QI-058.
Further, a Hardware Validation Program (HVP) has been initiated based on
Corrective Action Requests (CAR) 65x through 69x. These CARS will be
dispositioned by TUGC0 by performing a 100% reinspection of pipe supports.
Many attributes will be examined including lockwire.
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Attachment to TXX-5048 Page 14
.
October 13, 1986
RESPONSE IQ IIS R.i LQE'Q
3. Ard19A In finxant Recurrence
In addition to the lockwire reinspections required by supplemental
instructions to QI-037 and 058, inspection for lockwire on snubber adapter
plate bolts is required by the ISAP VII.c Quality Instructions QI-019 and
l
QI-029 under a separate attribute for safety wire.
TUGC0 Operations has issued procedures governing housekeeping and
inspection of plant systems, structures, components and equipment turned
over to Operations. These procedures are QAI-001, " Plant Housekeeping and
Equipment Inspection Plan", and STA-607, " Housekeeping Control". Part of
this monthly inspection requires the visual inspection for loose, damaged,
broken or missing parts / components on equipment.
4. DAtaaffullCompliance
Corrective action will be completed commensurate with the final
disposition of CARS 65x through 69x. ERC reinspection concerning the
aforementioned populations are complete. Revisions to QI-037 and QI-058
are scheduled to >e completed by October 31, 1986.
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
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Attachment to TXX-5048 Page 15
October 13, 1986
NOTICE QE DEVIATION
II.Ett G (illi/AftQ1-D-18)
C. Section 4.0 of CPRT Project Procedure CPP-008, Revision 1, requires that
verification packages provide the information necessary to conduct
/ reinspections and document the results. Section 5.1.1 of this procedure
/( states, in part, "...Should an attribute appear on the generic checklist
J 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, the engineer incorrectly indicated "N/A" for
attribute 1.e on the checklist for Verification Package No. I-M-LBCO-038.
As a result, this attribute, dealing with assuring branch connections were
in accordance with the piping isometric drawing, was not reinspected by
ERC. Independent inspection identified that the attribute was applicable
for Verification Package No. 1-M-LBC0-038 as evidenced by the observation
of the presence of a branch connection
l
RESPONSE IQ 111l[ L
1. Reason for Deviat. ion
l
ERC investigation confirmed that attribute 1.a in the ERC inspection
checklist had N/A incorrectly inserted by the QA/QC engineer, and thus was
not inspected. This attribute addresses assuring that brr ch connections
are in accordance with the piping isometric drawing. The existence of a
branch connection was confirmed on the piping isometric drawing bill of l
material,
'
,
5. Corrective Action Iaken
No corrective action has been planned for this deviation. The lack of
reinspection of one branch connection will not affect the final
conclusions drawn concerning branch connection installation. A
l statistically sufficient quantity of branch connections (approximately
! 115) have been inspected to permit the adequacy of branch connection
installation to be determined.
3. Action in Prevent Recurrence
The QA/QC engineer was instructed to take added precautions when
completing inspection checklists. Additionally, ERC inspectors have been
instructed to correct a checklist when an error '7 found or return the
list to the QA/QC engineer for correction. A mc.arandum dated May 28,
1986, confirmed the above instruction,
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Attachment to TXX-5048 Page 16
October 13, 1986
RESPONSE IQ IIEB G [QNI'Q
In addition to the specific a'ctions identified above, the following
activities are ongoing on a generic basis to identify and correct
inspection, engineering or program deficiencies to insure compliance with !
,
the Quality Assurance guidelines for the CPRT Program
1) Surveillances are scheduled and performed routinely of CPRT activities
per ERC-QA-15, " Performance of Project Surveillance". Specific
elements of the surveillance practice are:
'
0 Monitoring ongoing work to determine what activities have been
slanned, what activities are in process, and what activities have '
>een completed and accepted.
<
0 Verify the work is being accomplished in accordance with
requirements.
'
0 Determining when independent inspections should be made and
re. commending conduct of those inspections.
O Determining when direct observation of the work performance or
overview of inspections and tests should be.made and arranging for
the conduct of those observations.
O
Performing and documenting observations or witnessing of
inspections or tests performed by others.
- .
O Determining when special audits of quality assurance activities
should be performed.
O Initiating recommendations for corrective action based upon
observations.
These surveillances are performed through selected activities such as
monitoring of direct observation of work activities, quality trends,
etc. Surveillance activities and their results are recorded. If any
deviations are identified, the appropriate organization within ERC is
notified to correct the deviation and submit a report describing
corrective action taken or proposed. All deviations are logged and
tracked until closed.
2) Audits are performed per ERC-QA-18, " Administration of Quality
Assurance Auditing". These audits verify the adequacy of the ERC
'
Quality Assurance Program. Audit reports are prepared and if
deviations from the Program Plan or Procedures are identified, the
, audited organization is notified to correct the deviation, review
areas where similar deviations can occur and to initiate corrective
action. All deviations are tracked until closed.
4. Q31.g af Egil Comoliance
l Quality Assurance surveillances and audits consist of an ongoing program.
'
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