ML20236C872
| ML20236C872 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/15/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89129, NUDOCS 8903220358 | |
| Download: ML20236C872 (5) | |
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Log # TXX-89129 File # 10130
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TUELECTRIC
- w. s. c.hini March 15, 1989 E:arcunve Vke l' resident 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 REVISED RESPONSE TO UNRESOLVED ITEM 445/8824-U-03 REF:
TV Electric letter TXX-88575 from W. G. Counsil to V. S. Nuclear Regulatory Commission dated July 15, 1988.
Gentlemen:
The referenced letter provided TU Electric's response to Unresolved Item 445/8824-U-03.
Through additional research it has been determined that a portion of that response concerning Quality Control Inspection activities requires clarification.
The attached revised response has been updated to provide the required clarification and to reflect the latest revisions and transmittals of the associated engineering report (ER-ME-01, " Reactor Coolant System Cold Hydrostatic Test Report").
The changed portion of the text is indicated by revision bars in the right margin.
The original Unresolved Item has been included to aid in understanding the updated response.
Sincerely, A
William J. Cahill, Jr.
DAR/ddm Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)
Texas Department of Labor and Standards Boiler Division i
E. 0. Thompson State Office Building P. O. Box 12157, Capitol Station Austin, Texas 78701 Attn:
Steve Matthews 8903220358 890315
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DR 400 North Olive Street LB 81 Dallas, Texas 73201
' Attachment to TXX-89129 I
March 15,1989'
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Page 1 of 4 i
UNRESOLVED ITEM
'445/8824-U-03 NRC Inspection Report 445/8821 documents the results of a detailed NRC evaluation of the Unit 1 Reactor Coolant System (RCS) Cold Hydrostatic Test performed on July 30 and 31, 1982.
During the course of the inspection a number of issues were identified which caused the NRC and the Chief Inspector, Texas Department of Labor and Standards Boiler Division (TDLS-DD) to question the acceptability of the Unit 1 RCS Cold Hydrostatic Test.
As stated in 1
Paragraph 3.D(2)(c) of the Inspection Report.."The applicant apparently
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failed to establish and/or comprehensively follow detailed procedures controlling the examination of the Unit 1 Primary System Cold Hydrostatic Test examination activities and concurrently the applicant'apparently failed to maintain objective records of related activities.
To this_ extent,.the acceptability of the Cold Hydrostatic Test of the Unit 1 Primary System.is considered indeterminate...
This matter is considered. unresolved (50-445/8824-U-03).
.)
1 RESPONSE TO UNRESOLVED ITEM j
445/8824-U-03 l
1 Three specific issues are cited in the inspection report as the bases for questioning the acceptability of the hydrostatic test.
The first issue is that the methodology for converting piping documentation information to hydrostatic test field. examination points was not comprehensively proceduralized. Additionally, forms which were procedurally used to document the status of reviews of aiping documentation' packages were not required to be maintained as part of tle final Hydrostatic Test Documentation Package.
The second issue is the adequacy of the information provided to the QC inspectors who performed the field walkdown inspections during the hydrostatic test.
This issue derives in part from the first issue in that the lack of
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proceduralized conversion methodology may have caused some inspection points not to be identified to the inspectors while others were not definitively I
characterized as to type (e.g., field weld, shop weld, base metal repair involving welding, high stress point) or exact location..In addition, ambiguities in written records regarding the existence or'non-existence of I
welded base metal repairs were identified on the drawings supplied to the QC inspectors.
The third issue is one of procedural compliance and relates specifically to vendor supplied components which were pressure tested during the Unit 1 RCS Cold Hydrostatic Test rather than by the vendor at the time of fabrication.
t As established in the NRC inspection report, this is an acceptable practice provided that the ASME Ccde commitments of the vendor are met during the completed system hydrostatic test.
During the NRC inspection it was identified that the vendors' ANIS did not sign the Pressure Test Data Sheet
- 7. -
Attachment'to TXX-89129 March 15, 1989 Page'2.of 4 for the Unit 1 RCS Cold Hydrostatic Test to indicate'that they had witnessed those portions of the test applicable to -their components. as required.by the l
governing procedure, l
In response to concerns expressed during the NRC inspection,- TV Electric, performed an evaluation..of the Unit 1 RCS Cold Hydrostatic Test based on
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documentary evidence available.
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The following objectives were established for this evaluation:
1.
Determine the extent to which the Unit 1 RCS Cold Hydrostatic Test
-J demonstrated system integrity and satisfied applicable ASME. Code technical requirements.
2.
Determine the extent to which procedures controlling the Unit 1 RCS Cold Hydrostatic Test provided necessary' guidance for preparation, conduct, and reviews of the test.
3.
Determine.the extent to which QC personnel performing' acceptance l.
inspections were qualified to conduct those inspections.
4.
Identify and propose resolution of any potentially discrepant conditions.
5.
Identify any areas where program enhancements could contribute -to more I
definitive and comprehensive test packages.
Objectives 1, and 2 of this self assessment focused on the type of. issues documented in Inspection Repoi ' 455/8824; 446/8821. Objectives 4 and 5 provided added assurance that the review was comprehensive, that' identified problems were resolved, and that lessons learned were properly fed back into l
I the Hydrostatic Test Program, i
l The following methodology was employed during this assessment:
1-l' 1.
A matrix was developed correlating ASME Section III Hydrostatic Test requirements to hydrostatic test procedure requirements.
2.
A review of documentation was conducted to identify required hydrostatic test inspection points and the results were compared to the inspection points utilized in the test.
3.
The procedures governing the preparation for, conduct of, and review of the Unit 1 RCS Cold Hydrostatic Test were evaluated with respect to ASME Code and regulatory requirements for level of detail and technical content.
4.
Qualifications of the inspection perscunel involved in the test were compared to applicable requirements.
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Attachment to TXX-89129 March 15,'1989
. Page 3 of 4
- The results for this review were documented in Engineering Report ER-ME-01,
" Reactor Coolant System Cold Hydrostatic Test Report," dated June 16, 1988.
copy of this report was transmitted to the NRC via TV Electric letter _
A TXX-88529, dated June 17, 1988.
Revisions-1 and 2 to this report were transmitted via TV Electric letters TXX-88636, dated August 23, 1988, and TXX-88130, dated March 14, 1989 respectively.
Based on this review, the following conclusions were reached:
q 1.
The Unit 1 RCS Cold Hydrostatic Test demonstrated RCS integrity and
_j satisfied applicable ASME Section III Code requirements because:
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- a. The Code class boundary was pressurized in accordance with Code i
requirements.
- b. With the exception of four integrally welded attachments, all required inspection points were properly identified.on the isometrics, spool sketches, and flow diagrams used for. field examination during the hydrostatic test.
Two of the four integrally welded attachments were identified in 1982'and retested in 1983..The remaining two integrally welded attachments were identified during the-recent review.
The size and configuration of the welds associated with these attachments are such that had the attachments been made after the 1982 test, retesting would not be required by ASME Section III.
Consequently, failure to explicitly identify these attachments had no impact.on the technical l
acceptability of the hydrostatic test.
During this portion of the review specific attention was devoted to base metal repairs involving welding which would require inspection during the hydrostatic test. A total of 37 such repairs were identified.
All 37 repairs fell into one'of the following three J
i categories.
A repair weld was made to a pipe end prep prior to making the associated butt weld, and the repair weld was subsequently consumed by the butt weld.
- A repair weld was adjacent to a butt weld as evidenced by the repair I
being radiographer with the butt weld.
l l
Repair documentation clearly indicates the location of the repair l
with respect to the butt weld (i.e., running from the toe of the j
weld into the base metal).
It is concluded that it would have been impossible to.not inspect the repaired areas while inspecting the associated butt welds.
- c. The inspections performed during the test were conducted by fully I
qualified inspectors who were certified in accordance with approved procedures. Our review also determined that the inspectors used the l
._-_____._-______-_-____.m___m__.m.
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...m Attachment to TXX-89129 March 15, 1989 Page 4 of 4 proper acceptance criteria.
The acceptability of the inspection results for the test boundary assigned to each inspection team is documented by the signature of fully qualified inspectors on behalf of the team.
These signatures were recorded on the Pressure Test. Data attachments.
- d. The test was accepted to the requirements of ASME Boi.ler and Pressure Vessel Code,Section III by the NA Certificate Holder,
- e. Vendor supplied components.were inspected and accepted to ASME-Section III Code! requirements as documented by Vendor ANI signatures.on the 1
components' Code data reports.
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- f. The post Hydrostatic Test Review completed by the-installer was comprehensive as demonstrated by the identification of a number of discrepancies, some of which required retesting.
I 2.
The technical procedures governing the test contained'the applicable ASME l
Section III technical requirements.
Based on this information TV Electric concludes that the Unit 1 RCS Cold.
l Hydrostatic Test. was satisfactorily completed in accordance with applicable ASME. Code and Regulatory Requirements.
The methodology used to convert' piping documentation packages into field examination packages was' not comprehensively proceduralized, nor was the format or level of detail required in the field examination packages explicitly identified.
The procedures which were in place at the time did, i
however, direct those responsible for field examination package preparation to.
i the sources of information necessary to ensure that all required inspection points were identified and captured on drawings suitable.for use by inspection personnel in conducting field examinations.
The acceptability of the processes employed was confirmed by the review effort described above.
Consequently, these issues have been demonstrated to have had no impact on the validity of the final product.
The vendors' ANIS did not sign the pressure test data sheets as required by l
procedure to document their acceptance of the pressure test of supplied components; however, they did document their acceptance on the code data reports.
The Document Status Forms required by Procedure CP-QAP-12.1 were not required to be retained as quality records.
Other documentation exists which demonstrates that this action was completed including installation, fabrication, and construction documentation, the Pressure Test Data Sheet, and the final test package which demonstrates satisfactory system performance.
After careful evaluation TV Electric concludes that none of the issues had any impact on the technical acceptability of the Unit 1 RCS Cold Hydrostatic Test.
However, TV Electric has taken action or is in the process of taking actions to enhance the controls for Code pressure testing.in response to the issues expressed by the NRC.
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