ML20235A780
| ML20235A780 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/11/1988 |
| From: | Edgar G NEWMAN & HOLTZINGER, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5308 OL, NUDOCS 8801130015 | |
| Download: ML20235A780 (1) | |
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.NEWMAN & hoi;rZINGER, P.c6NRC
' JACK R NEWM AN 1615 L ST R E ET, N.W. wlLUAM C. SAER, JR JOHN E MOLTZINGER, JR -
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~~I ~ January 11, 1988 Jc'
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DONALD J StLvtRMAN _
g assot Apumte m D C Peter B. Bloch, Esquire Dr. Kenneth A. McCollom Chairman Administrative Judge
-. Atomic Safety and Licensing 1107 West Knapp Board Stillwater, Oklahoma 74075 U.S. Nuclear Res;ulatory Commission Elizabeth B. Johnson Washington, D.C. 20555 Oak Ridge National Laboratory P.O. Box X, Building 3500 Dr. Walter H. Jordan Oak Ridge, Tennessee 37830 c/o Carib Terrace Motel 522 N. Ocean Boulevard Pompano Beach, Florida 33062 Re: Texas Utilities Generating Company, et al.
Docket Nos. 50-445-OL and 50-446-OL-
Dear' Administrative Judges:
Enclosed; herewith please find Applicants' fourth submission in response to the Board's request of August 12, 1987, for copies of Applicant's responses to " Notices of Violation" and Notices of Deviations" issued by the NRC Staf f. The enclosed responses cover the period November 23, 1987 to December 28, 1987. 1 Sincerely, i
< h George . Edgar I i
Enclosures 1 I
cc: Service List 8801130015 880111 ~ !
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T//-6937
_ , Fiia s 10130
= = IR 87-16 I
7t/ELECTR/C Pef
- IOC 2 01 mihom c. rounui November 23, 1987 i.....,, s. m.~.,
U. ( Nuc laar Paoulatory Commission Attn: Document Control Desk
'.!a s h i n : t on . D. C. 20555 t; l)P J E r i : gjM;NCHE PEAK STEAM ELECTPIC STATI0ri (CPSES)
DOLLET N05. 50-445 AND 50-446 PE5PON5E TO NRC INSPECTION REPORT N05.
- sn-JJ;/87-16 AND 50 446/A7-13 Gentlemen:
TH Elec t r ic he reviawed your letter dated 0ctober 23, 1987 concerning the inspection conducted by Mr. I. Barnes and other inspectors in the Comanche Peak Pro _1ect Di.1sion during the period August 5 through September 2, 19-87.
This inspection covered activities authorized by NRC Construction Permits (PPP-126 anel CPPP-127 for CPSES Units 1 and 2. Attached to your letter was a Notite of Violation and Devietion.
On No. ember 23, 1987, per a telephone conversation with Mr. R. F. Warnick, we requested and received an extension as follows: Item A (445/8716-V-02; J46/8713-V-01) and item B (445/8716-V-10; 446/8713-V-09) extended until Decamber 7 1987.
Ele hereb, respond to the Notice of Violation and Deviation in the attachmsnt to this letter.
I Very t ruly yours,
. 1%
W. G. Counsil PDD:grr attachmont
'-Mr P. D. Martin, Pegion IV Pesident inspectors, CPSES (3) d
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i November 23, 1987 Page 1 of 6
.. NOTICE OF VIOLATION ITEM A (445/8716-V-02: 446/8713-V-01)
A.
Criterion XVI of Appendix B to 10 CfR Part 50, as implemented by Section 16.0,-Revision 0, of the TU Electric Quality Assurance (QA) Flan, requirrs, " Measures shall be established to assure that conditions adverse to quality...(be corrected and)... action taken to preclude repetition."
Nuclear Engineering and Operation Procedure NE0 3.06, " Reporting and Control of Deficiencies," implements this criterion by requiring deficiencies ~(principally programmatic, not directly related to hardware problems) be identified, the cause established, and action taken to-prevent repetition.
Contrary to the above, numerous nonconformance reports (NCRs) have been invalidated with no further action required, when action to prevent repetition appears to have been necessary. Examples of these NCRs include 4
- M-21940, M-26470, M-26471, M-20857, M-21861, M-28567, M-21982, and M-26189 (445/8716-V-02; 446/8733-V-01). . )
RESPONSE TO VIOLATION-ITEM A (445/8716-V-02: 446/8713-V-01)
Response will be provided by December 7, 1987.
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, ' Attachment to TXX-6937 November.23, 1987 Page 2 of 6 NOTICE OF VIOLATION ITEM B (445/8716-V-10: 446/8713-V-09)
B.
Criterion VII of Appendix B to 10 CFR Part 50, as implemented by Section 7.0, Revision 3, dated July 31, 1984, of the TV Electric QA Plan, requires that, " Measures shall-be established to ' assure that purchased material,... conform to the procurement documents. These measures shall i' include provisions, as appropriate, for... inspection at the contractor or subcontractor source...." Such measures were established and implemented concerning TU Electric purchase order CPF-13820-S, Supplement 1, for 264 jackshafts (components in 6.9kv circuit breakert) from BBC Brown Boveri, Inc.
A TV Electric trip report, dated June 9, 1987, documents an inspection of these jackshafts at the vendor's plant prior to shipment. The 264 jackshafts shipped.from the vendor's plant had been inspected and accepted by TV Electric as complying with new welding acceptance criteria previously approved by TV Electric engineering. One of these criteria was, "The 3/16" fillet weld can be a minimum of 1/8"..."
! Contrary to the above, during an NRC inspection of five jackshafts, onsite awaiting installation, one jackshaft (item number 273) was found with a fillet weld less than 1/8" over a length of 9/16". Subsequent to this NRC inspection, conducted September 1, 1987, TU Electric initiated inspections t.o identify any other jackshafts out of the 264 shipped that did not comply with the welding acceptance criteria (445/8716-V-10; 446/8713-V-09).
RESPONSE TO VIOLATION ITEM B (445/87!6-V-10: 446/8713-V-09)
Response will be provided by December 7, 1987.
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s l . Attachment to TXX-6937 L November 23, 1987 l Page 3 of 6 NOTICE OF VIOLATION ITEM C (445/8716-V-12)
C.
Criterion XVI of Appendix B to 10CFR Part 50, as implemented by Section l
16.0, Revision 0, of the TV Electric QA Plan, states in part, " Measures l shall be established to assure that conditions adverse to quality, such as i i
failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In
.the case of significant conditions adverse to quality, the measures shall assuretothat taken the cause preclude of the condition is determined and corrective action repetition..."
TV Electric, in response to Corrective Action Report (CAR) 65X, which identified a missing cotter pin as a Construction Deficiency, established the Hardware Validation Program (HVP)' for safety-related pipe supports.
Included in this program is a required verification that locking devices are present and correctly installed. >
- - Contrary to the above, the sway strut rear bracket load pin on safety- '
related 21, 1987, pipe support CC-1-295-006-C53R, Revision 4, was observed on August to have two missing cotter pins although this support had been reworked by craft and accepted by QC in accordance with the HVP (445/8716-V-12).
RESPONSE TO VIOLATION ITEM C (445/8716-V-12)
TV Electric agrees with the alleged violation and the requested information follows:
- 1. Reason for Violation The subject pipe support was inspected and accepted in accordance with the Hardware Validation Program (HVP) in May of 1987. Although our findings cannot be confirmed, TV Electric believes that the subject cotter pins may have been removed during painting activities which are known to have occurred subsequent to the HVP inspection and prior to the NRC inspectors observation of missing cotter pins.
- 2. Corrective Steos Taken t,nd Results Achieved On August 26, 1987, Non-Conformance Report (NCR) 81-A01243 was written documenting the missing cotter pins. To determine the extent of the problem, a reinspection was initiated of 10% of the approximately 3000 pipe supports which had been inspected per the HVP. On September 4, 1987, after reinspecting 45 pipe supports, a loose jam nut was found on pipe support CC-X-079-004-A43R. NCR 87-A01446 was written and the reinspection effort was terminated. Based on the identification of an additional discrepancy relating to configuration control, further sampling was not considered necessary and Corrective Action Request (CAR)87-075 was initiated.
Attachment to TXX 6937 November 23, 1987 Page 4 of 6
' RESPONSE TO VIOLATION ITEM C (445/8716-V-12) (Cont'd) 3.
Corrective Steos Which Wil.l.be Taken to Avoid Further Violationt On September 9, 1987, the Director of Construction directed that the missing / loose , pipe support hardware be investigated and personnel retrained as required.
On September 14,.1987, a Stop Work Order was issued for painting, insulating, and cleaning of safety related systems and temponents pending retraining of appropriate Co1struction Department personnel.
On September 15,'1987, Corrective Action Request (CAR)87-075 was issued to document the generic concerns raised by the discovery of the loose / missing hardware.
On September 18, 1987, following completion of the required training, the
, Stop Work Order of September 14, 1987, was lifted. .
On October 27, 1987, a training memo was issued for sign-off by all Comanche Peak. Engineering personnel. This memo included instructions on the protection of permanent plant equipment, and was transmitted to all engineering contractors for training of their personnel.
- 4. Date When Full Comoliance Will be Achieved Additional corrective actions for CAR 87-075 are currently being considered. An update to this Response to a Notice of Violation will be submitted providing all additional corrective actions planned and our dates for completion of those actions. The updated response will be submitted no later than January 15, 1988.
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I Attachment to TXX-6937 i November 23, 1987 I Page 5 of 6 {
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NOTICE OF DEVIATION (445/8716-D-01) l Appendix 1A(B) of the FSAR commits the applicant to Regulatory Guide 1.68, Revision 2, August 1978. Regulatory Position C.2 of Regulatory Guide (RG) 1.68 (Revision 2 of August 1978), requires, in part, the establishment of administrative controls to ensure adequate retesting of systems or design features maintained or modified during or following preoperational testing. '
RG 1.68 requires that u,oon licensing, all safety related systems ano design features must meet the preoperational test acceptance criteria as described in the FSAR rith any and all exceptions identified to the NRC and appropriately justified.
In deviation from the above, Operations Administrative Procedure STA-623,
" Post Work Testing," Revision 1 of June 26, 1987, does not contain *
- administrative controls to ensure adequate retesting of systems or design .
- fntures which have been maintcined or modified following preoperational testing (445/8716-D-01).
RESPONSE TO DEVIATION (445/8716-D-01)
TU Electric agrees with the alleged deviation and the requested information follows:
- 1. Reason for Deviation: 1 At the completion of Preoperational Test activities in the Fall of 1984, it was erroneously assumed that plant licensing was imminent and the only applicable test requirements from Regulatory Guide 1.68 would be those of testing for operability and tests deferred until after fuel load. When plant licensing was delayed, Nuclear Operations personnel failed to reevaluate Regulatory Guide 1.68 for requirements to maintain preoperational test requirements.
- 2. Corrective Steos Taken and Results Achieved In the Spring of 1987, Project personnel realized the need to revalidate preoperational test criteria and initiated development of the Pre-Start Test Program. As part of the Pre-Start Test Program, work activities performed on systems after completion of preoperational testing are being reviewed. The objective of this review is to identify testing <needed to ensure that systems and design features still meet preoperational test acceptance criteria.
Testing needed to revalidate conformance to preoperational test acceptance criteria will be completed before fuel load or deferred if absolutely necessary to initial heatup. Station work control procedures are being revised to provide administrative controls for identifying and completing post-work testing, needed to validate preoperational test acceptance criteria, as required by Regulatory Guide 1.68.
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Attachment to TXX-6937 November 23, 1987 Page 6 of 6 RESPONSE TO VIOLATION i (445/8716-D-01) (Cont'd) '
3.
Corrective Stens Which Will be Taken to Avoid Further Deviation 1
Translation of Pre-Start, Test Program requirements into project procedures-and revision to existing station work control procedures will provide the administrative controls for preventive action.
- 4. Date When Full Comoliance Will be Achieved
-i Procedures delineating the Pre-Start Test Program will be issued by December 31, 1987.
i Revisions on changes to existing work control procedures will be complete
'by December 31, 1987.
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= c Log # Tu-6939 File # 10120
= = IR 87-18 ,
TilELECTRIC pgg ,39cfhg 9, l
wmim c. counui December 7, 1987
- 1. .or,,, s ,.nen.se,,, j l
U. S. Nuclear Regulatory Commission Attn: Document Control Desk .
f Washington, D. C. 20555 SUBJECT. COMANCHE PEAL STEAM ELECTRIC STATION (CPSES) !
DOCKET N05, 50-445 AND 50-446
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PESPONSE TO NRC INSPECTION REPORT N05.
50-445/87-18 AND 50-446/87-14 5
Gentlemen:
TV Electric has reviewed your letter dated November 5,1987, concerning the !
inspection renducted by Mr. 1. Barnes and other inspectors and consultants 1 c'urihg the period September 3 through October 6,1987. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPP-127 for CP5ES Units 1 and 2. Attached to your letter was a Notice of Violation and Deviation.
We hereby respond to the Notice of Violation and Deviation in the attachment to this letter.
Very truly yours, f.' ). G C.
W. G. Counsil j i
l By: .
JL W. Beck Vice President Nuclear Engineering PDD:grr Attachment i
c - Mr. R. D. Martin, Region IV Resident lospectors, CPSES (3)
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Attachment to TXX-6939 December 7, 1987 Page 1 of 12 t10TICE OF VIOLATION ITEM A (445/8718-v-04; 446/8714-V-03)
A.
Criterion V of Appendix B to '10 CFR Part 50, as implemented by Section 5.0, Revision 3. dated July 31, 1984, of the TV Electric Oaality Assurance Plan (OAP), requires that activities affecting quality thall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings. .
Section 5.0 01 Brown and Root Procedure CP-CPM-7.1, Revision 3, " Package Flow Control" requires that the contents of documentation packages be verified as being complete and current by distribution satellite personnel prior to initial issuance of the package, and upon return or completion of work, the distribution satellite personnel are to assure the documents issued are returned. The package inventcry card is used by dist-ibution satellite personnel to account for the documents contained in one documentation packages.
Contrary to the above, on September 16 and 17,1987, the NRC inspector identified 10 electrical penetration assembly documentation packages, which had been verified by distribution sitellite personnel as egreeing with the package inventory card, whose contents did not agree with the package inventory card. The following documentation packages contained megger data sheets not listed on the package inventory card: 2E-16, IE-59 module E, IE-43 module A, IE-43 module 8, IE-43 module C. IE-52 module
<A. IE-52 module B, IE-52 module C, 1E-52 module D, and IE-55 module F (445/8718-V-04; 446/8714-V-03).
RESPONSE TO VIOLATION ITEM A (T45787i8-V-04; 44678714-V-03)
TV Electric agrees with the alleged violation and the requested information follows:
- 1. Reason for Violation The megger data sheets referenced in the notice of violation were provided as an attachment to procedure EEI-22, " Installation of Conax Feedthrough/ Adapter Module Assemblies into Amphenol Sams Penetrations".
Megger data is recorded on these sheets in the field and the sheets are retained in the applicable Electrical Penetration Assembly (EPA) documentation packages. The documentation packages were not found to be missing any megger data sheets, however, the data sheets were not always entered on the Package Inventory Cards (PIC). The failure of Package Flow r,roup (PFG) personnel to consistently enter the megger data sheets ,
j on the Plc resulted trom uncertainty as to how to make the entry. Unlike i most entries on the PICS, the megger data sheets had no descriptive title, and were not part of a OC Inspection Report that would have provided a unique identifier.
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Attachment to TXX-6939 l December:7 1987 Page 2 of 12 NOTICE OF VIOLATION ITEM A (445/8T T-W O4: 446787F4~V-03) (CONT'D)~
" Although. PFG personnel f ailed to consistently enter the megger data sheets on the PIC, TV Electric believes that the PICS would have been corrected during the package review proce'ss. After all work associated with a package is complete and prior to transmittal to the records vault, the package is reviewed in accordance with procedure CP-CPM-7.ll, "Non-ASME O Documentation Package Review." This procedure requires verification that the PIC includes all required documents.
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In this manner, assurance is'provided that the PICS are' complete prior to vaulting of the package.
- 2. Corrective Stegs Taken'and Results Achieved l
~The PFG has instituted a standard method for designating procedure '
attachments on the PICS. All EPA documentation packages have been reviewed and the PICS have been corrected to indicate the megger data sheets contained in the packages. Since all documentation packages are.
reviewed per CP-CPM-7.ll prior to vaultinf, no further package review is considered necessary.
- 3. Corrective Steps Which Will be Taken to Avoid Further Violations
.The PFG Group Leaders have instructed their group personnel on the standard methods to be used for designating procedure attachments on the PICS.
- 4. Date When Full Compliance Will be Achieved The instruction of PFG personnel on the standard method for designating procedure attachments on PICS was completed by October 9, 1987.
The review'of EPA packages and' correction of PICS was completed by October 16, 1987.
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l-Attachment to: TXX-6939
-December 7, 1937 Page 3 of 12 NOTICE OF VIOLATION ITEM B~T4G7871BT-119) i J
B. Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section 10.0, Revision 1, dated July 31,.1984,.of.the TU Electric QAP states, in
~part, "A program for inspection of activities affecting quality shall be established and executed by or for the organization.performi.ng the .'
-activity to verify conformance with the documented instructions, procedures, and drawings f.or accomplishing.the activity... Examinations, measurements, or tests of material or products processed shall be perf ormed for each work operation where necessary to assure quality."
. Engineering and Construction Engineering Procedure ECE 9.04-04, which is part of the post construction hardware validation program, addresses the reinspection /walkdown of accessible attributes. It also requires the identification of. inaccessible attributes so that an' engineering evaluation will be performed.
Contrary to the above, the following condition was identified:
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The adjacent weld distance attribute for pipe support WP-X-AB-050-003-3 was documented as being satisf actory on the associated Adjacent' Weld Checklist. However, this attribute is inaccessible due to the presence of Bisco, seal material in the penetration that the pipe runs'through.
The acceptance of this inaccessible attribute by QC precluded the required engineering evaluation from being performed (445/8718-V-09).
RESPONSE TO VIOLATION ITEM 8 (445/8718-V-09)
TV Electric agrees with the alleged violation and the requested information folicws:
1.- Reason for Violation The cause cf the deficiency was a lack of adequate direction in inspection Procedure CP-QAP-12.1 for the disposition of Hardware Validation Program (HVP) supplemental attributes which are determined to be inaccessible.
- 2. C_orrective Steps Taken and Results Achieved To address the specific concern identified in the Notice of Violation, Nonconformance Report (NCR) M-87-A01921 was issued on September 29, 1987.
This NCR will resolve the issue as it relates to this specific Adjacent Weld Checklist attribute.
Due to the nature of the deficiency identified on NCR M-87-A01921, Deficiency Report C-87-3884 was issued to address programmatic concerns.
The disposition of the DR identified the cause described above, and Procedure CP-QAP-12.1 has been modified to specifically address the initiation of a NCR for HVP supplemental inspection checklist attributes which Are inaccessible.
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Attachment to TrX-6939 December 7,.1987 Page 4 of-12 NOTICE OF VIOLATION ITEM B T44578718-V-09nCONT'D)
During a recent routine inspection surveillance of ASME pipe support.
packages, .it was noted that QC verification of some attributes had been inappropriately documented and/or performed. The results of these examinations, the issuance of DR C-87-3884 and the similar issues raised in NRC Notice Corrective ofRequest Action Violation(CAR) 445/8718-V-08 87-78. resulted in issuance of-This CAR was issued to address the programmatic deficiencies and assure that additional HVP activities were conducted in accordance with project requirements. All HVP pipe support packages placed.in the Interim Records Vault prior to, November 15, 1987, will be reviewed by ASME OC personnel to identify and resolve any package deficiencies in accordance with the process defined in the response to CAR 87-78.,
- 3. Corrective Steps Which Will be Taken to Avoid Further Violations To prevent further violations CP-QAP-12.1, " Mechanical Component
' installation Verification," was revised on November 15, 1987, to specifically address the in.itiation of NC.h for HVP supplemental inspection checklist attributes which are inaccessible.
Training of the ASME QC parsonnel responsible for implementation or this procedure has been conduc.ed. *
- 4. Date When Full Compliance Will be Achieved The review of pipe support packages placed in the Interim Records Vault' prior to November 15, 1987, is anticipated to be completed by December 31, 1987. CAR 87-78, NCR M-87-A01921 and DR C-87-3884 will be closed by January 31, 1988.
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Attachment to IXx-6939 l December 7. 1987 Page 5 of 12 NOTICE OF VIOLATION ITEM C (445/8718-V-08)
C. Criterion XV of Appendix 8 to 10 CFR Part 50, as implemented by Section 15.0, Revision 5, dated July 31, 1984, of the TV Electric OAP, states,
" Meas" tires shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, documen htion, segregation, disposition, and notification to affected organizatius. Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures."
Procedures CP-QAP-12.1, paragraph 6.1.2, Revision 20, dated July 10, 1987, states, in part, "For defective or flawed material or components, i an NCR must be generated...."
Contrary to the above, a nonconformance report (NCf! <as not issued for a high strength capscrew (item 15 of pipe support CC- 58-001-001-3) which broke during installation before the spec #ied design torque value was achieved. This precluded an investigation and engineering evaluation of the nonconforming item (445/8718-V-08).
RESPONSE TO VIOLATION ITEM C (41578718-V-68) 10 Electric agrees with the alleged violation and the requested information follows:
- 1. Reason for Violation The reason for this violation was an inadequate procrdure which did not adequately address the issuance of an NCR for defective or flawed material.
- 2. Corrective Steps Taken and Results Achieved Following identification of this issue by the NRC, a Nonconformance Report (M-87-A10852) was issued to address the specific installation identified. This NCR has been dispositioned to have the applicable hanger reworked to the original design.
To address the programmatic concerns, a Deficiency Report (C-87-3885) was initiated. This DR initiated a review of the controlling procedure and determined that it did not adequately define the terms " flawed" or
" failed" material. This procedure, CP-QAP-12.1, " Mechanical Component Installation Verification," has been revised to expand the definition of "flaned material."
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Attachmentst o'Txx-6939 December 7, 1987 Page 6 of IP l
NOTICE OF. VIOLATION -
ITEM C~TR57B718-V-08)l0NT'D)
During a recent routine surveillance of ASME. pipe support packages it was noted that QC verification of some attributes hsd been inappropriately documented and/or performed. The results of these examinations, the issuance of DR C-87-3885, and similar. issues raised in NRC Notice of Violation 445/8718-V-09 resulted in issua,ce of Corrective Action' Request (CAR) 87-78. This CAR was issued to address the programmatic
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deficiencies and assure that additional Hardware Validation Program (HVP).
activities were conducted in accordance with project requirements. All HVP pipe support packages placed in the Interim Records Vault prior to November 15, 1987, will be_ reviewed by ASME QA personnel. . This. review will resolve any package deficiencies in accordance with the process defined in the response to CAR 87-78.
- 3. Corrective Steps Which Will be-Taken to Avoid Further Violations
- Procedure CP-QAP-12.1 was revised on November 15, 1987, to expand the definition of " flawed material." The AS U OC personnel responsible for applying this revised definition have been retrained in its application.
- 4. Dato When Full Compliance Will be Achieved
' The review of pipe support packagts placed.in the Interim Records Vault prior to November 15, 1987, is anticipated to be completed by necember 31, 1987. CAR 87-78, NCR M-87-A10852 and DR C-87-3885 will be closed by January 31, 1988.
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Attachment to IXX-6939 December 7, 1987 Page 7 of 12 NOTICE OF VIOLATION ITEMD(445/8718-V-02;44fil8714-V-0_1_1 0.
Criterion XVI of Appendix 8 to 10 CFR Part 50, as implemented by Section 16.0, Revision 0, dated July 1, 1978, of the TV Electric OAP, states, in part, " Measures shall be established to assure that conditions adverse to quality, such as... deficiencies, deviations and nonconformances...are promptly identified and corrected." i l
Section 17.1.15 of the CPSES FSAR, states, in part, "A nonconformance report (NCR) is a document used for documenting, controlling, and correcting a condition..."
The disposition of such a document, NCR M-2320, Revision 3, required that for the 3" steam generator hold-down bolts:
(1) Bolts with gaps greater than .010 inch shall be shimmed.
l (2) The tabs on stainless steel shims shall be held up against the bolt head with 3/4" wide carbon steel band Mg. The banding shall be tight enough to prevent removal by hand.
(3) A copy of the material documentation for the shims shall be attached to the NCR.
Disposition of NCR M-2320 was completed and verified complete by QC inspection on November 25, 1981. "
Contrary to the above, the NRC inspector found the following not accomplished during a field inspection on September 11, 1987: (1) shims required to be installed under two of the Unit 2 steam generator hold-down bolts were found to be missing; (2) banding required to be installed to hold the shim material in place for the Unit 2 steam generator hold-down bolts was found to be missing from two bolts and was improperly placed for an additional six bolts; and (3) documentation of the shim material identity was not included in the NCR H-2320 (445/8718-V-02; 446/8714-V-01).
RESPONSE TO VIOLATION ITEM D (445/8718-V-02; 446/8714-V-Ol i 10 Electric agrees with the alleged violation and the requested information follows:
l Peason for Violation Based on review of documentation and discussions with personnel involved, the subject shims and bands were installed as required by NCR M-2320 Rev.
- 3. Subsequent to installation, some of the shims and bands were apparently dislodged by personnel working in or transiting the area. The area of the steam generator lower support ring where the shims and bands were located is known to be an area where personnel walk and the shims and bands could have been easily stepped on and/or kicked loose.
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- At tachmen't to :TXX-6939 December:7. 1987- i Page 8'of 12 q
. NOTICE OF VI01.AT10N '!
ITEM D (445/8718-V-02; 446/8714-V-01)-(CONT'0)
(
The OC ir,spection~ report which is included in the NCR M-P320 Rev. 3 is package contains a sign-off that the QC inspector verified the material identification. Also, the completed OlCR and supporting documentation was i,
reviewed and approved by a QC Supervisor, an Authorized Nuclear inspector
(
and a Quality Engineer. fu Electric, therefore,. believes that the material documentation for the shims was lost subsequent to close out of the f4CR.
- 2. Corrective Steps Taken and Results Achievej NCRs 87-00041 through -00047 have been written to document the missing and improperly placed shims and bands, and the micsihg material documentation.for both Unit 1 and Unit 2 steam generators. iMeasures will '
be taken'to' ensure that-the shims and bands are not damaged or dislodged I after the deficient conditions are corrected.
- 3. Correctiv'e Steps Which Wil'l. be Taken to A. tid. further Violations .
On October 27, 1987, the Director of Engineering issed a memo directing that personnel be trained on protection of plant equipment.
TV Electric has implemented a " package" concept for control of both ASME and Non-ASME documentation. Documentation for individual components is kept in a single package and the contents are inventoried when the package is returned to Paper Flow Group. These measures facilitate prompt identification of lost documentation'and implementation of appropriate corrective actions. The control of packages is governed by procedure CP-CPM-7.1, " Package Flow Control" and its appendixes.
Procedure CP-CPM-7.1 was made effective for Unit 1 and Unit 2 on December 15, 1986, and February 7,1984, respectively.
- 4. Date When Full Compliance Will be Achieved Correction of the shim and banding deficiencies, and implementation of measures to prevent damage or dislodging of shims and bands will be completed no later than Plant Heatup for Unit 1 and Hot functional Iesting for Unit 2.
The training of appropriate Engineering and Construction field personnel on protection of equipment will be completed no later than December 18, 1987.
_ Attachment to TXX-6939 )
December 7, 1987 Page 9 ci 12 NOTICE _OF DEV1AT10N (445/8718-0-10)
Section 4.1, "Walkdown Guidelines," of Revision 1 to Impell Project Instruction (PI) 0210-052-004, states, in part, "The walkdown information will be dpcumented using the checklists provided in attachment B.... Table I provides the acceptable tolerances to be used in the walkdown process.
" Guidelines for performing the conduit support and conduit routing walkdowns l are provided below....
"ltem 5. Support Configuration l
- Draw an as-built sketch l
- Identify all structural /Unistrut member sizes, lengths... !
" Item 6. Support Deficiencies l
- Identify any gross deficiencies in the support... I
"' Item 7. Hilti Kwik Anchorbolt Information *
- Identify letter stamp and Projection Length of all anchor bolts on I supports...."
]i The following examples, identified by the NRC during inspection and review of 1 the post construction hardware validation program (PCHVP) module, Train C i Conduit less Than or Equal to 2", are in deviation from the above criteria:
{
(1) For analysis tag A-03173 in Room 206, Impell (ncorrectly recorded the length designatt>r on the end of a 1/4" diameter Hilti Kwik bolt as being an "E" stamp (3 1/2" long).
The NRC inspector observed the length designator to be a "0" stamp (3" long).
(2) For analysis tag A-03173 in Room 206, it was determined during the NRC inspector's inspection that an 1/8" gap exists between the 3/4" diameter conduit and the conduit support shim plate, thus invalidating its three-way restraint design function. This invalidates all portions of the Impell analysis where this three-way support was considered.
(3) .For analysis tag A-03177 in Room 206, Impell had recorded that the projected length of the 1/4" diameter Hilti Kwik bolt was 3/4". The subsequent NRC inspection determined this length to be 1 1/8". The specified allowable tolerance was 1/4".
(4) for Calculation No. A-03451 in Room 54, Impell had recorded on RFl No.
RF1-E5-1-1043. . that Hilti Kwik bolt No. I was located 4 1/2" from the top edga of Ihe Unistrut channel. The NRC inspector < however, determined the bolt to be located 3" from the edge. The specified allowable tolerance was 1/4".
[ '
. Attachment to TXx-6939-December 7,.1987
'Page 10 of 12 (5) For Calculation No. A-03138 in Room 54, Impell had recorded that'the j projected length of the 1/2" diameter Hilti Kwik bolt for support A-03145/NQ-08290 was 1". The subsequent NRC. inspection detennined this length to be 1 1/2". The specified allowable tolerance was 1/4" !
(445/8718-0-10). :{
In addition to the-deviation specified above, the NRC inspectors.have identified other discrepancies of a similar nature. These discrepancies have been presented as Open Items in NRC inspection Report 50-445/87-25: 50-446/87-
- 19. The Open items are restated below:
"While performing the walkdown for Calculation L2-S-1-EC-130, the NRC.
inspector identified a discrepancy in the Impell work. It involved the span length between supports 2-23955 and 2-23956. Impell had recorded this span length as 40" while the NRC inspector determined it to be 47 1/2." Subsequently, Impell' stated that the Level 6 interaction 4 evaluation determined that there were no safety-related equipment, '
systems, or components in the room. Accordingly, no interactions (either
- acceptable or unacceptable) will occur in this room and the conclusions initially arrived at would not be affecteJ. The NRC inspector concurred with this explanation; however, a determination must still be made as to whether this error was an' isolated case and what impact, if any, it would have on other walkdowns that the identified individuals were involved with. This subject is an open item pending the making of triis determination (445/8725-0-02)."
"While performing the field walkdown on the Request for Field I_nformation (RFI) data for the level 5 calculation A-00631, the NRC inspector identified a discrepancy. It involved the span distance between supports A-00632 (N/0-07192) and A-00633 (N/0-07191). Impell had recorded this dimension as 11 1/2" while the NRC inspector determined it to be 35 1/2".
Upon notification of this discrepancy, Impell informed the NRC inspector that this error had occurred on Revision 0 of the calculation which had
_1' been superseded by Revision I which states, " Supports in this calculation have been qualified by level 6." The Level 6 evaluation showed that no s.3fety-related equipment existed in the vicinity of these supports. The NRC inspector verified that the supports were qualified by the level 6 l
)
support interaction evaluation.; however, a determination must still be l' made as to whether this error was an isolated case and what impact, if any, it would have on other walkdowns that the identified individuals were involved with. This subject is an open item pending this
~
determination (445/8725-0-03) ." 4 j
1
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... Attachment to Txx-6939 December-.7, 1987' Page.ll of 12-RESPONSE TO DEVIATION (445/8718-0-10)
TV Electric agrees ~with the alleged deviation and the requested information follows:
~
- 1. Reason for Deviation , ;
The.five discrepancies identified in the Notice of Deviation and the two discrepancies identified in the Open ltems all resulted from inaccurate recording and checking of walkdown data on the part of personnel.
2 Corrective Steps Taken and Results' Achieved The discrepant conditions described in. items 1 through 4 of the Notice of Deviation were examined in the field by Impell personnel. The results of the examination confirmed the NRC inspectors observation in each case.
The applicable walkdown forms and calculations have been revised accordingly, in each case _, the qualification status of the conduit support did not change.
- The discrepant condition described in item 5 of the Notice of Deviation '
was examined in the field by Impell personnel. The results of the examination showed that the projection length of the 1/2 inch Hilti bolt !
was 1 3/8. inches instead of 1 inch as recorded on the RFl. The applicable walkdown forms and calculations have been' revised accordingly.
The qualification status of the support did not change.
The t 7ccepant conditions described in Open items 445/8725-0-02 and -03 were e.amined in the field by Impell personnel. The results of the examination confirmed the NRC inspectors observation. However, Impell had subsequently determined that for both cases, there was no safety related equipment in the vicinity per the Level 6 support interaction ,
evaluation. Hence, the discrepant calculations were rendered unnecessary. i
- 3. Corrective Steps Which Will be Taken to Avoid Further Deviations Those. engineers that are still on site who were involved in the walkdowns that resulted in items 1 through 3 of the Notice of Deviation, as well as all other personnel involved in the structural integrity group have been j 3
retrained on the importance of documenting walkdown data accurately.
Subsequent to the issuance of the Notice of Deviation and Open items l discussed above, NRC inspectors have informed TV Electric of what appears to be additional Train C walkdown discrepancies. Deficiency Report C87-4800 has been initiated and TV Electric is investigating these {
discrepancies implications. and formulating appropriate actions to address any generic '
l' An update to this response will be submitted describing our additionai corrective actions.
[_.._______.____.-___ - -- - - ~---- - -- ~ '- - - ~~
l .-tsatnment to iAA-oy39
. December 7, 1987 Page 12 of 12 NOTICE OF DEVIATION
, (445/8718-0-10) (CONT'0) l l
- 4. Date When Full Compliance Will be Achieved An opdate to this response will be submitted describing our, additional correttive actions no later than January 29, 1988.
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== Loo # TXX-6997
_ 3 File # 10130
= = IR 86-02 7UELECTRIC IR 86 03 Ref. # 10CFR2.201 William G. Coumil emo,,,, u ,ere,sem itovember 20, 1987 i
U. S. Nuclear Regulatory Commission Attn: Document Control Desk liashington, D. C. 20555
SUBJECT:
C0f4NCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 REVISED DATE OF FULL C0fiPLIANCE FOR NOTICE OF DEVIATI0ft ITEfi B (445/8603-D-18) i Gentlemen:
The TV Electric response to flotice of Deviation (fl00) Item B (445/8603-0-18) stated that full compliance would be achieved by flovember 30, 1987. Please be advised ' hat completion of the review of attributes for each construction work .
6 category (CUf) has been revised to December 31, 1987.
Very truly yours, W C -c .
W. G. Counsil By: / J J @ W. Beck Vice President, fluclear Engineering GLB/grr C - fir. R. D. fiartin, Region IV Fesident inspectors, CPSES (3) j l
4 , y <f __ 400 Norm Oltse Street LB 89 D. Hn. Teus 73.'01 Y
-- Log # TXX-7013 h j File # 10130
= = IR 86-07 n8 ELECTRIC peg, y chg ng William G. Courts
%n., vic, ema.
November 30, 1987.
V. 5. Nuclear Regulatory Commission Attn: Document Control Desk Washington,: D. C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET N05. 50-445 AND 50-446 INSPECTION REPORT.N05. 50-445/86-07 and 50-446/86-05 REVISED DATE-0F FULL COMPLIANCE FOR NOTICE OF VIOLATION, ITEM E (445/8607-V-22)
REF:
(1) TV Electric Letter Txx-6729 from W. G. Counsil to hRC dated September 9, 1987 Gentlemen:
The referenced. letter stated that DCA 31,277 Rev. I required extensive rework in the field and as a result, our date for incorporation of this DCA into drawing 2323-El-0156 would be delayed until November 30, 1987. The field work associated with this DCA has been impacted by our Conduit Support Program.
The scheduled close out date of Design Modification 85-077 and subsequently DCA 31,277 (which is currently in Rev. 2) is February 24, 1988. Incorporation of DCA 31,277 Rev. 2 into drawing 2323-El-0156 will be completed by this date.
Very truly yours,
'It' '
W. G. Counsil RDD/gtr. .
c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) l soo sons ohve Street LB 81 Dallas. Tesas 7520)
] ?ffff _ _.
= Log # TXX-7014
.i File # 10130
= = IR 86-26 1UELECTRIC 9,g, , chg 9$
William G. Coumil i.mwn, ur u.am November 30, 1987 U. 5. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT NOS. 50-445/86-26 AND 50-446/86-22 REVISED DATE OF FULL COMPLIANCE FOR NOTICE OF. VIOLATION (NOV), ITEM C.2 (446/8622-V-07)-
REF: TV Electric Letter TXX-6742 from W. G. Counsil
.to NRC dated September 11, 1987 Gentlemen:
The. referenced letter provided our response to Notice of Violation (NOV) Item C.2 (446/8622-V-07). In that response, we stated that the evaluation and conversion of discrepancy forms generated per Procedure PP-051, " Equipment Qualification Walkdown," would be completed no later than November 30, 1987.
The evaluation of some of these discrepancies is being perfonned in conjunction with our Environmental Qualification Design Validation Program.
Based on our scheduled completion date for this program, we now anticipate that the evaluation and conversion of discrepancy forms generated per PP-051 will be completed no later than December 30, 1987.
Very truly yours, N.
W. G. Counsil RDD/grr
. - Mr. P. O,fN tin, Region IV Pes i<len t inspectors, CPSES (3) 4t si %rtn t ila c stra t iH %I l bih t i n,i, ?,4'01
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E m mi== Log # Txx-7021 L
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d File # 10130
= IR 86-07 NELECTRIC '
p,g, p 19cfg ny Wihm G. Cou,uil Eaeare.e Osce Premient-December 1., 1987 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET N05. 50-445 AND 50-446 INSPECTION REPORT N05. 50-445/86-07 AND 50-446/86-05 REVISED DATE FOR SUBMITTAL 0F UPDATED RESPONSE TO SDAR CP-83-08 REF:
TV Electric Letter TXX-6803 from W. G. Counsil to NRC dated October 1, 1987 Gentlemen:
The above referenced letter provided TV Electric's response to your request for additional information on Notice of Deviation (N00) Item E (445/8607-0-01). In that response we stated that an updated response to 50AR CP-83-08 would be issued no later than November 30, 1987. We are currently reviewing additional information provided by the subject valve vendor (Fisher). Accordingly, our date for submittal of an updated response to SDAR CP-83-08 is hereby revised to be no later than January 14, 1988. ;
Very truly yours, G-W. G. Coun 'l 1
By:_ % __ >
D. R. Woodlan Supervisor, Docket Licensing POD /grr c - fir. R. D. Martin, Region IV Resident inspectors, CPSES (3)
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== Log
- TxX-7015 j File # 10130
= = IR 87-11 1UELECTRIC peg, a c n; William G. OpumIl n,. .,m , m on,*,i, flovember 30, 1987 U. S. riuclear Reaulatory Commission Attn: Document Control Desk Uashington. D. C. 20555
SUBJECT:
COMAllCHE PEAL STEAM ELECTRIC STATION (CPSES)
DOCKET fl05. 50-445 AND 50-446 lilSPECT10fl REPORT fiOS. 50-445/87-11 Af10 50-446/87-09 REVISED DATE OF FULL COMPLIANCE FOR fl0TICE OF VIOLATION (NOV), ITEM A (445/8711-V-02; 446/8709-V-02) i REF: TV Electric Letter TXX-6777 from W. G. Counsil to NRC dated October 2, 1987 Gentlemen:
The referenced letter provided our response to Notice of Violatien (NOV) Item A (445/8711-V-02: 446/8709-V-02). In that response we stated that the removal of unauthorized splices and wire nuts per NCRs CE-87-9610 and CE-87-10026 would be completed by November 30, 1987. Completion of this work has taken longer than expected. Accordingly, our date for completion of this work is hereby revised to be no later than January 29, 1988.
Very truly yours, l ?77,x W. G. Counsil PDD/arr
- Mr. p. r;. Martin. Region IV Pesident inipectors, CP5ES (3) i l
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' E E IR 87-16 i 1RIELECTRIC IR 87 13 pg,, p 19c7pg,go; ,
6 l
%ilham G. Counsa t r w.c ur nr.-
December 7, 1987 H. 5, Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) 00CKET N05. 50-445 AND 50-446-RESPONSE TO NRC INSPECTION REPORT N05.
50-445/87-16 AND 50-446/87-13 Gentlemen:
TV Electric has reviewed your letter dated October 23, 1987, concerning the inspection conducted by Mr. I. Barnes and other inspectors in the Comanche Peak Project Division during the period August 5 through September 2, 1987.
This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2. Attached to your letter was a Notice of Violation and Deviation.
Notice of Violation item C (445/8716-V-12) and Notice of Deviation (445/8716-0-01) were addressed in TV Electric letter TXX-6937 dated November 23, 1987.
On November 23, 1987, per a telephone conversation with Mr. R. F. Warnick, we requested and received an extension as follows: NOV Item A (445/8716-V-02; 446/8713-V-01) and NOV Item B (445/8716-V-10; 446/8713-V-09) extended until Derember 7. 1987.
We hereby respond to the above items in the attachment to this letter.
Very truly yours, W. G. Counsil ROD /grr Attachment c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3) 400.Nonh olne screet LB 8I Dallas. Texas U201 a _, , , e 2!2f?U_s2 __
AttachmenttoT$k-7037
.- December 7, 1987 Page 1 of 4 NOTICE OF VIOLATION ITEM A -(4357BTIFV-02: 4478713-V-01)
A.
Criterion XVI of Appendix B to 10 CFR Part 50, as implemented by Section 16.0, Revision 0, of the TV Electric Quality Assurance .(QA) Plan, requires, "Mesures shall be established to assure that conditions ~ adverse to quality...(be corrected and)... action taken to preclude repetition."
Nuclear Engineering and Operation Procedure NE0 3.06, " Reporting and Control of Deficiencies," implements this criterion by requiring deficiencies (principally programmatic, not directly related to hardware problems) Le identified, the cause established, and action taken to prevert repetition.
Contrary to be above, numerous nonconformance reports (NCRs) have been invalidated with no further action required, when action to prevent repetition appears to have been necessary. Examples of these N(,Rs include M-21940. M-26470, M-26471, M-20857, M-21861, M-28567, M-21982, and M-26189 (445/8716-V-02; 446/8713-V-01).
RESPONSE TO VIOLATION ITEM A (3T5/8716-V-02; 446/8713-V-01)
TV Electric agrees with the alleged violation and the requested information follows:
- 1. Reason for Violation Two procedural requirements provide the controls to identify and prevent repetition of deficient conditions initially identified by NCRs. First is the requirement for review of NCRs for potential need to issue Corrective Action Requests. Second is the requirement to evaluate NCRs for adverse trends.
The NCRs identified in the Notice of Violation were resolved as
" invalid" which precluded application of both of the procedural controls used to prevent repetition of deficiencies. The reason for this violation was personnel error by the individuals who approved the resolution of the NCRs as " invalid" based on inappropriate or incomplete justification.
With the exception of NCR M-28567., the " invalid" resolution of the NCR's identified in the violation was the correct resolution, although the resolution was poorly justified on the NCRs. NCR M-28567 was revised on November 25, 1986 to address the inappropriate initial " invalid" r'esolution which was due to misidentification of the affected equipment.
I _ _ __ _ _ _ -__ - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - --- - ~~ ~
Attachment'to-Txx.7037 December 7, 1987 '
Page 2 of 4 RESPONSE TO VIOLATION ITEM A (445/8716-V-02; 446/8717-T-01) (CONT'D)
)
- 2. C,orrective Steps Taken and Results Achieved l All of the NCRs identified in the Notice of Violation were issued in f accordance with the Brown and Root ASME Quality Assurance Program as it existed prior to issuance of NEO 3.06, " Deficiency Reporting." A review of NCRs issued between August 1986 and August 1987 in accordance with the Brown and Poot ASME QA Program and which had been resolved as " invalid" was conducted to evaluate generic implications. The review identified 37 NCRs which did not appear to pr' ovide adequate justification for resolution as " invalid." These finding were documented on a Brown and Root ASME Corrective Action Request (Number 70). Only one required further documentation to justify its resolution as " invalid" and it was addressed by issuance of DR C-87-04574. No hardware nonconformance was left uncorrected by these NCRs.
A review is also being conducted of non-ASME NCRs which have been resolved as " invalid". This review will provide assurance that similar deficient justifications do not ed st in the TU Electric Construction non-ASME NCR process.
The results need to expand of theseactions.
the corrective reviews will be evaluated to determine the
- 3. Corrective Steps Which Will be Taken to Avoid Further Violations The procedural allowance for the B&R Site 0A Manager to delegate the authority for approval of " invalid" resolutions has been removed which will limit the application of the " invalid" resolution to those specifically approved by the Site QA Manager.
To further improve the quality of Brown and Root ASME NCR resolution, the controlling administrative procedure (AAP-16.1) was revised on November 16, 1987, to require peri + c m pling of each type of NCR classified by disposition.
This review wi n verify the adequacy of the nonconformance descriptions and dispositions.
Based on the results of the review of ASME NCRs described above, the corrective actions described in CAR 70 are deemed adequate to address this issue.
The review of NCRs described in SDAR 86-48 (TV Electric letter TXX-6560 dated July 15,1987) will assure that concerns which could affect engineering requirements, and are not the subject of other reverification efforts, are addressed.
) 4. Date When Full Compliance Will be Achieved i
All identified actions required to address the programmatic deficiencies identified have been completed. The review of TV Electric Construction non-ASME NCR's resolved as " invalid" and the corrective actions for Brown and Root ASME CAR 70 are anticipated to be complete by March 1, 1988.
Additionally, the review of NCRs for impact on engineering requirements ,
will be conducted as scheduled in our reports related to SDAR 86-48.
_ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ = _ _ _ _ _ _ _
Attachment to 10-7037 1
. December 7. 1987 Page 3 of 4 l NOTICE OF VIOLATION ITEM B (445/8716-V-fDi T4678713-V-09) i B.
Criterion VII of Appendix B to 10 CFR Part 50, as implemented by Section 7.0, Revision 3, dated July 31, 1984, of the TV Electric QA Plan, requires that, " Measures shall be established to assure that purchased material.... conform to the procurement documents. These measures shall include provisions, as appropriate, for... inspection at the contractor or subcontractor source...." Such measures were established and implemented concerning TV Electric purchase order CPF-13820-S, Supplement 1, for 264 jackshaf ts (components in 6.9kv circuits breakers) from BBC Brown Boveri, Inc.
A TV Electric trip report, dated June 9,1987, documents an inspection of these jackshafts at the vendor's plant prior to shipment. The 264 ,
jackshaf ts shipped from the vendor's plant had been inspected and accepted I by TV Electric as complying with new welding acceptance criteria l previously approved by TV Electric engineering. One c,f these criteria was, "The 3/16" fillet weld can be a minimum of 1/8"..." ,
k
)
Contrary to the bove, during an NRC inspection of five jackshafts, onsite awaiting installation, one jackshaft (item number 273) was found with a l fillet weld less than 1/8" over a length of 9/16". Subsequent to this NRC )
inspeciton, conducted September 1,1987, TV Electric initiated inspections to identify any other jackshafts out of the 264 shipped thatcdid not comply with the welding accptance criteria (445/8716-V-10; 446/8713-V-09). I RESPONSE TO VIOLATION ITEM B (44578716-v-10; 44378713-V-09)
TV Electric agrees with the alleged violation and the requested information follows:
- 1. Reason for Violation This violation was an isolated occurrence of failure of the source inspector to identify a condition not in compliance with the specified acceptance criteria.
- 2. Corrective Steps Taken and Results Achieved In addition to stating "(t)he 3/16" fillet weld can be a minimum of 1/8"
... , the weld acceptance criteria also allow a "... gap in the circumferential weld that does not exceed 5/8 inch in length...."
Therefore any undersized weld segment which does not exceed 5/8 inch in length is acceptable.
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' Attachment to Txx-7037-December 7, 1987 t i Page 4 of 4 RE_5PONSE TO VIOLATION ITEMB(445/8716-V-10;446/8713-y-09)(CONT'Dj The source inspection was performed using standard weld inspection methodology. The 210 jackshafts which had not been installed were subjected to a more detailed re-inspection at CPSES for size only, and the results were documented on NCR PE-87-0608 Rev.1. Only one weld was identified which did not meet the above described acceptance criteria using standard weld inspection methodology. This weld (item number 273) was 1 1/4determined inch. to be undersize by approximately 1/32 inch over a length of '
The re-inspection results formed the basis for the determination that this was an isolated occurrence of source inspector oversight. The remaining 54 jackshafts which were previously installed are being removed and will also-be re-inspected. These 54 jackshafts are identified on NCR PE-87-00619.
- 3. Corrective Steps Which Will be Taken to Avoid Further Violations The inspector involved in this event was intonned of the results of this investigation. No additional actions are deemed necessary.
- 4. Date When Full Compliance Will be Achieved Inspection activities related to the 54.jackshaf ts which were previously installed will be complete by February 26, 1988. All other required actions are complete.
Docxcrce UNITED STATES OF AMERICA U$NiiC NUCLEAR REGULATORY COMMISSION 88 JMi ll P2:45 before the OFFICE OT SEu t;4n .
,, ATOMIC SAFETY AND LICENSING BOARD 00CXETtNG r wract BRANCH
)
In the Matter of ) Docket Nos. 50-445-OL
) 50-446-OL TEXAS UTILITIES GENERATING )
COMPANY et al. )
) (Application for an (Comanche Peak Steam Electric ) Operating License) )
Station, Units 1 and 2) )
)
CERTIFICATE OF SERVICE I, Thomas A. Schmutz, hereby certify that the foregoing Notices of Viol'ations and Notices of Deviations were served this llth day of January 1988, by mailing copies thereof (unless otherwise indicated), first class mail, postage prepaid to:
I
- Peter B. Bloch, Esquire *B. Paul Cotter, Jr., Esq. l Chairman Chairman Atomic Saf ety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission ;
Washington, D.C. 20555 Washington, D.C. 20555
- Alan S. Rosenthal, Esq. Assistant Director for i Chairman Inspection Programs i Atomic Safety and Licensing Comanche Peak Project Division j Appeal Panel U.S. Nuclear Regulatory J U.S. Nuclear Regulatory Commission !
Commission P.O. Box 1029 Washington, D.C. 20555 Granbury, TX 76048
- Asterisk indicates service by hand or overnight courier.
1
, .: e
- Juanita Ellis Robert D. Martin l
President, Case Regional Administrator, 1426 South Polk Street Region IV Dallas, TX 75224 U.S. Nuclear Regulatory /
Commission William R. Durchette, Esquire 611 Ryan Plaza Drive Heron, Burchette, Ruckert, Suite 1000
& Rothwell Arlington, Texas 76011 1 Suite 700 1025 Thomas Jefferson St., N.W. *Dr. Kenneth A. McCollom Washington, D.C. 20007 Administrative Judge 1107 West Knapp
- William L. Clements Stillwater, Oklahoma 74075 Docketing & Service Branch U.S. Nuclear Regulatory Joseph Gallo, Esquire Commission Isham, Lincoln & Beale Washington, D.C. 20555 1150 Connecticut Ave., N.W.
Suite 1100
- Billie Pirner Garde Washington, D.C. 20036 Government Accountability Project *Janice E. Moore, Esquire Midwest Office Office of the General Counsel 104 E. Wisconsin Avenue - B U.S. Nuclear Regulatory Appleton, WI 54911-4897 Commission Washington, D.C. 20555 Renea Hicks, Esquire Assistant Attorney General
- Anthony Roisnian, Esquire l Environmental Protection 1401 New York Avenue, N.W.
Division Suite 600 Capito) Station Washington, D.C. 20005 P.O. Box 12548 Austin, Texas 78701 Lanny A. Sinkin Christic Institute Robert A. Jablon, Esquire 1324 North Capitol Street Spiegel & McDiarmid Washington, D.C. 20002 1350 New York Avenue, N.W.
Washington, D.C. 20005-4798 Nancy Williams CYGNA Energy Services, Inc.
- Elizabeth B. Johnson 2123 N. California Blvd.
Oak Ridge National Laboratory Suite 390 P.O. Box X Building 3500 Walnut Creek, CA 94596 Oak Ridge, Tennessee 37830 David R. Pigott
- Dr. Walter H. Jordan Orrick, Herrington & Sutcliffe c/o Carib Terrace Motel 600 Montgomery Street 522 N. Ocean Boulevard San Francisco, CA 94111 Pompano Beach, Florida 33062
., e O 3-
- Robert A.-Wooldridge, Esquire Worsham, Forsythe, Sampels
& Wooldridge 2001 Bryan Tower, Suite 3200 Dallas, Te xa,s 75201
- W. G. Counsil Executive Vice President Texas Utilities Electric -
General Division 400 N. Olive, L.B. 81 Dallas, Texas 75201 b/ / /
Jbw -
IWo6as A. Schmutz ne Dated: January 11, 1988 l
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