ML20236H388
| ML20236H388 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/30/1987 |
| From: | Gad R ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#487-4751 OL, NUDOCS 8711040097 | |
| Download: ML20236H388 (24) | |
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1 ROPES & GRAY COLKtTED l 225 FRANKLIN STREET BOSTON, MASSACHUSETTS O2110 j 17 W -2 P4 :43
,,,,gy g (617) 423-610 0 , N . A. N , N o ,0 N 30 KE NN EDY PLAZ A TELEX NUMBER 940519 ROPGRALOR BSN 1001 TW E NTY-S ECO N D STR E ET, N W PROVIDE N C E, R. t 02903 TELEX NUMBER 95t973 ROPE 5 GRAY eMFICE M e,'t Jpiig y WASHINGTON, CLC 20037 (4 01) 521-6400 TELECOPIERS (6171 423-2377 (617)4a@9Q$EilNG A 5[irylc[ :202 4291600 .
T E LECOPIE R I401) 521-0910 INT E R N ATIO N AL (617) 423-6905 TE ECOPIER (202) 429-1629 October 30, 1987 Peter B. Bloch, Chairman l Atomic Safety & Licensing Board i U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1
Dr. Kenneth A.. McCollom !
l Administrative Judge l 1107 West Knapp l Stillwater, Oklahoma 74075 1
Dr. Walter H. Jordan Administrative Judge 881 W. Outer Drive Oak Ridge, Tennessee 37830 Re: Texas Utilities Electric Company, et al.
Comanche Peak Steam Electric Station Docket Nos. 50-445-OL & 50-446-OL Deat Administrative Judge:
In accordance with TU Electric's response dated August 24, 1987 to Judge Bloch's request therefor, we transmit herewith copies of the responses submitted by TU Electric during the period of September 25, 1987 through October 26, 1987, to Notices of Violation and " notices of deviation" rendered by the NRC Staff.
9ery ul yours,
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R. K. Gad \
RKG/plw Enclosure cc: Service List R 97 B71030
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nones l EE log. #;..TXX-6753
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File.f.10130 8 i
r IR 86-26 .
l lllELECTRIC IR 86*22 i Ref # 10CFR2.201 J mui m c. couma euna,,, va emem October 23, 1987 U. S. Nuclear Regulatory Commission Attn: Document Control Desk l Washington, D. C. 20555 l i
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STAfl0N(CPSES)
DOCKET N05. 50-445 AND 50-446 REQUEST FOR ADDITIONAL INFORMATION REGARDING INSPECTION REPORT: 50-445/86-26 AND 50-446/86-22 !
Ref: !
- 1) NRC letter from E. H. Johnson to W. G. Counsil dated, April 2, 1987 l
- 2) TV JuneElectric 5, 1987Letter TxX-6472 from W. G. Counsil to NRC dated Gentlemen:
Your letter dated September 3,1987, requested additional information on the subject inspection report with respect to Notice of Deviation (N0D) Item B (445/8626-0-03; 446/8622-D-01) and Item C (445/8626-D-04; 446/8622-0-02).
On September 23, 1987, per a telephone conversation with your Mr. R. F.
Warnick, we requested and received an extension until October 7, 1987. On October 7,1987, per a telecon with your Mr. Ian Barnes, we requested and received an extension until October 23, 1987.
In pursuing the request for additional information, we have determined that a revision to our original response was required to clarify our position.
Accordingly, information, is a revised enclosed. response, including the requested additional revision bars have been provided.Since the entire response has been revised, no We hereby respond to the above items in the attachment to this letter.
Very truly yours, b.b
, W. G. ounsil By:
D. R. Weedlan i
l Supervisor, Docket Licensing 400 North OI,ve Street LB 81 Dallas. Tens 73201
9 C
M rtin, Region IV Resident Inspectors, CPSES (3) .
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' Attachment to'TXX-6753 October 23, 1987
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REQUEST FOR ADDIT 10NAL INFORMATION MTTRE OF DIVIATION -
ITEMB(435/8626-0-03;446/8622-D-0Q l NOD tTEM B:
l Your response to item B of the N0D indicates disagreement with the stated deviation. Your response, however, fails tc' recognize that the ISAP 1.d.3 i l
requirements were being implemented prior to the SR1 approval or issuance of the Results Report. Accordingly, we roquest that you provide the information '
originally requested for this deviation.
l NOTICE OF CEVIATION '
ITEM 9 ('M 7FJ26 D 03: 446/8622-0-01)
B.
Section 4.1.E of ISAP I.d.3, Revision 0, requires, in part, that ERC perform an evaluation of the craft training procedures including training
- and retraining, and that the following items will be considered during this evaluation
"How- craf t personnel become aware of chan \
requirements and how retraining occurs." ges in design and construction "How craft personnel are informed and become knowledgeable of QA/0C requirements / criteria and changes to those requirements / criteria."
Section 4.1.3 of the ISAP also states, in part, " Based on this review (of procedures), conclusions will be drawn by the OA/0C Review Team Leader as to the adequacy of both past and current practices used for craft selection and training. If current procedures are determined to be inadequate, reconrnendations for impecaement will be provided to TUGC0 prior to the closure of this action plan."
In deviation from the above, ISAP 1.d.3 Results Report does not provide a recommendation that TUGC0 revise the Bahnson Service Company's craft training Procedure QCI-CPSES-013, " Indoctrination and Training of Personnel," whicn does not assure that: (1) 'craf t personnel become aware of changes in design and construction requirements"; and (2) " craft requirements / criteria and changes to those requirements / criteria" (445/8626-D-03; 446/8622-0-01).
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Attachment to TXX-6753 October 23, 1987
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REVISED RESPONSE ITEM B (445/8626-D-03, 446/8622-D-01) -
TU Electric agrees with the alleged deviation and the requested information follows: -l
- 1. Reason for Deviation l This deviation occurred because the ISAP I.d.3 Results Report did not recommend that TV Electric revise the Bahnson craft trainin QCI-CPSES-013, " Indoctrination and Training of Personnel". g procedure The reasons for not making the recommendation are:
1)
Revision 0 of ISAP I.d.3 dated January 24, 1986, instructs the QA/QC Review Team Leader to ..."If current procedures are determined to be l inadequate, recommendations for improvement will be provided to TUGC0 prior to the closure of this action plan." The Action Plan Change Request for Revision 0 of the ISAP dated August 27, 1986, removed ]
this requirement. The Results' Report was written according to the j precepts of Revision 1 of the ISAP. .
At the time the NRC identified the alleged deviation, Revision 1 was not formally approved by the !
SRT, but was being used by the Issue Coordinator.
(TV Electric recognizes that this situation is not in accordance with ;
Revision 3 of the CPRT Program Plan which was in effect at that i
time). This is discussed further in our response to N00 Item C j' (445/8626-0-04; 446/8622-0-02).
2)
Revision 1 of ISAP I.d.3 was designed to broaden the scope of adequacy assessment and to address use of results from other ISAPs.
Section 4.1.2 states, in part, ... The assessment of craft personnel l training programs was accomplished by reviewing craft training procedures, interviewing craft personnel, and observing training activities." Section 4.1.3 states, in part, ..."The QA/QC Review Team used results of their activities to draw conclusions about the adequacy of past and current craft personnel training practices.
These craft conclusions personnel are may be modified if shortcomings in the training of determined..."
Based on the above, the net result of the analysis performed in I.d.3 !
indicated that adequate re-training did in fact occur for Bahnson !
personnel re-trainingeven through of craft QCl-CPSES-013 lacked specificity regarding personnel. Therefore, ISAP I.d.3 did not '
ru ommend a revision to the Bahnson procedure. However, upon further consideration of this matter, TV Electric agrees that the Bahnson procedure should occur. should have been revised to state clearly how re-training j This would provide assurance that training and re-training would continue to occur in a timely and prudent fashion.
However, is no longer since Bahnson is no longer onsite, revising their procedure a concern.
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- t Attachment to TXX-675).
October 23, 1987 ( (
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Page 3 of 5
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- 2. Corrective Steps Taken and Results Achieved
. J No corrective steps have been identified with regard to revising Bahnson Training Procedure QCl-CPSES-013 since Bahnson is no longer performing work at CPSES. j HVAC construction work activity is currently controlled by l TU Electric procedure ECC-1.16-1, " Orientation, Indoctrination and I Training of Fluor Daniel Project Personnel." This procedure includes specific requirements for Project employee training and re-training. I
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Corrective steps taken for !$AP !.d.3 changes that were implemented prior to SRT approval is addressed in our response to N00 Item C (445/8626-0-04; 446/8622-D-02).
- 3. Corrective Steps Which Will be Taken to Avoid Further Deviations Since Bahnson is no longer onsite and HVAC activities are controlled by TV Electric, no further action is required.
The corrective steps required to prevent recurrence of the situation where changes in ISAP implementation are made prior to SRT approval are addressed in the response to N00 Item C (445/8626-D-04; 446/8622-0-02).
- 4. Date When Full Compliance Will Be Achieved The CPRT is now in full compliance.
L._____________________-. _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _
Attachment to TXX-67 October 23, 1987 (
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Page 4 of 5 REQUEST FOR ADDITIONAL INFORMATION - i NOTICE OF DEVIATION ITEM C (445/8626-D-04; 446/8622-D-02)
NOD ITEM C:
Your response to item C of the N0D does not address how the SRT was aware of ISAP changes which were made in the Results Reports. In addition, you state corrective action was taken with the SRT on May 20, 1987. Either this date is in error or your corrective actions were not timely. Therefore, we request that you revise your response to this deviation to address the above two 1 concerns. !
1 NOTICE OF DEVIATION ITEM C (445/8626-D-04; 446/8622-D-02) l i
C.
The W. G. Counsil letter (CPRT 207) to the NRC, dated January 27, 1986, regarding CPSES submittal of Revision 3 of the Comanche Peak Response Team '
(CPRT) Program Plan and ISAPs, committed that, "...further substantive ;
i modifications to these documents (CPRT Program Plan ISAPs) will require '
the approval of the Senior Review Team prior to implementation."
Change Notice 001 to Comanche Peak Project Procedure CPP-024, " Issue {
i Specific Action Plan Revision," dated April 4, 1986, requires that "...the SRT approves substantive changes prior to implementation."
l In deviation from the above, substantive changes to ISAP 1.d.3 were '
implemented prior to approval by the Senior Review Team (SRT). For example, in April 1986 the Special Evaluation Team's effort was transferred to Quality Assurance / Quality Control (QA/QC) Review Team personnel and the issue coordinator was changed; however, the SRT did not approve these and other changes until August 1986 (446/8626-D-04; 446/8622-0-02).
1 REVISED RESPONSE i
1 ITEM C (445/8626-D-04: 44F/8622-0-02) l TV Electric agrees with the alleged deviation and the requested information follows:
- 1. Reason for Deviation l
All substantive changes to CPRT Action Plans are approved by the SRT.
However, on occasion, Action Plan changes have been implemented prior to receiving formal SRT approval, which is inconsistent with the guidance delineated in CPRT-207, PAG-01 and CPP-024.
Therefore, on occasion, the SRT has deviated from program requirements by not formally approvin substantive changes to Action Plans prior to their implementation. g These deviations have occurred due to an oversight by the SRT.
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October 23, 1987 (
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Page 5 of 5
- 2. Corrective Steps Taken and Results Achieved The SRT has now formally approved the substantive changes to ISAPs as delineated in PAG-01, Revision 4.
have been implemented and later included within the action plan resultI report have also been documented on Action Plan Change Requests.
The SRT is made aware of proposed changes to' action plans through Action Plan Change Requests per PAG-01.
identify proposed changes to action plans, provide justification for theT changes and document approval by the SRT.
TV Electric was first informed of this deviating condition. by the NRC during the NRC exit meeting held:on October.9, 1986. Further information i
was obtained from the NRC to clarify the deviating condition _ during October and November 1986. . An SRT meeting was held on January 27 1987,.
to clarify the intent of PAG-01 regarding " substantive changes." , Based on ;
the results of the SRT meeting PAG-01 was revised (Revision 2, 2/3/87) to further define substantive changes. TV Electric officially received. NRC l l
Inspection Report 445/8626 and 446/8622 identifying this deviation on April discuss2,.1987, and a meeting the response was held with the SRT on May 20, 1987, to to'this N00.
The SRT agreed that, in accordance with procedural requirements any future substantive changes to ISAPs that have l not yet been completed will be formally approved by the SRT prior to implementation of the changes.
1 3.
Corrective Steps Which Will Be Taken to Avoid Further Deviations i Presently, the investigative activities of all action plans have been completed or nearly completed. I The completed action plans have had their respective results reports approved by SRT and issued. Any future substantive changes to ISAPs will be formally approved by the SRT prior to l
implementation in accordance with procedural requirements.
- 4. Date When Full Compliance Will Be Achieved The SRT is now in full compliance.
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M Log # TXX-6775 EE File # 10130 - -
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IR-85-13 IR-85-09 7UELECTRIC Ref #10CFR2.201 -
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., September 30, 1987 William G. Counsil Encunve Vwe Presusent U. S. Nuclear Regulatory Commission Attn: Document Control Desk i Washington, D. C. 20555 j
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 REVISED RESPONSE REGARDING INSPECTION REPORT: ;
50-445/85-13 AND 50-446/85-09 .
REF:
- 1) NRC December letter 24,from 1985E. H. Johnson to W. G. Counsil dated i
- 2) TUdated Electric April 3,letter 1986 TXX-4740 from W. G. Counsil to NRC
- 3) TUdated Electric May 5,letter 1987 TXX-6342 from W. G. Counsil to NRC
- 4) TV dated Electric letter4,TXX-6697 September 1987 from W. G. Counsil to NRC Gentlemen:
C (445/8513-D-03) of Inspection ReportReference (2) provided our o 50-445/85-13 and 50-446/85 09. In reference to clarify our (4) TV Electric committed to revise our original response in order position.
Accordingly, a revised response is enclosed. Since the entire response had been revised, no revision bars have been provided.
Very truly yours, l
d v W. G. C unsip / -
RDD:tgj By: .
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c- Mr. R. D. Martin, Region IV G. S. Keeley r l Resident Inspectors, CPSES (3) Manager Nuclearensing Lfg/--
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400 Nonh Olhe Street LB 81 Dallas. Texas 73201
Attiachment to TXX-6775
,, September 30, 1987 Page 1 of 2 NOTICE OF DEVIATION .
ITEM C (445/8513-0-03)
Paragraph 5.0 of ERC Project Procedure No. QI-027, Revision 0, identifies the applicable inspection notes to be used, and requires that the reinspection checklist is to be used by the inspector to document the inspection results.
Note 30, an identified inspection note states, "In the course of inspection i the inspector shall note any item not covered by reinspection / verification i which appears out of the ordinary as related to the construction of the inspected item or surrounding area. Note such in the remarks column of inspection checklist."
Contrary to the above, the ERC inspectors failed to identify and note an out-of-the-ordinary condition in the remarks column of the inspection checklist for ASME pipe support MK No. CT-1-053-436-C52A; i.e., the existence of four 9/16" diameter holes in item 2 of the pipe support that were not shown on the applicable drawing.
REVISED RESPONSE j ITEM C (445/8513-D-03)
TV Electric agrees with the alleged deviation and the requested information follows:
- 1. Reason For Deviation l .
Due to inspector error, a notation was not entered in the remarks column of the checklist identifying the out-of-the-ordinary condition observed by the inspector during the inspection on 9/11/85.
The original intent of Note 30 to 01-027 Rev. O, was to provide a method of informing the responsible ERC Discipline Engineer of any apparent !
deviations, associated with the sample item being inspected, that were out-of-the-scope of the Quality Instruction. Q1-027 included this note because it had been issued prior to the development and :.pproval of ERC Project Procedure CPP-020, "Out-of-Scope Observations". Five other Quality Instructions also contained a note similar to Note 30 in QI-027.
With the later approval of ERC Procedure CPP-020, in which all inspectors are trained, the requirements of Note 30 in QI-027 (and similar notes) became redundant and therefore were not included in other Quality Instructions that were subsequently issued.
This inconsistency for the inspector'sbetween error. Quality Instructions was a contributing cause -
2.
Corrective Steos Taken and Results Achieved An out-of-Scope Observation (OS0) #126 was written by the inspector on 9/19/85 to document the identified condition. Furthermore, since CPP-020 requires that all OS0s be distributed to the responsible ERC Discipline Engineer, Note 30 to Q1-027 was no longer required and therefore deleted.
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. September 30, 1987 Page 2 of 2 l
The similar notes referenced above have also been deleted from QI-019, QI .
029, QI-045, QI-051 and QI-055.
3.
Corrective Steos Which Will Be Taken To Avoid Further Deviations The corrective steps described above adequately address the deviation and will prevent recurrence.
- 4. Date When Full Comoliance Will Be: Achieved TV Electric is now in full compliance.
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M Log # TXX-6777 l
MM File # 10130 f
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IR 87-11 IR-87-09 MlELECTRIC Ref # 10CFR2.201 wim- c. couma '
smo,,,va m, U. S. Nuclear Regulatory Commission Attn: Document Control Desk l Washington, D. C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT l
NOS. 50-445/87-11 AND 50-446/87-09 l
Gentlemen:
We have reviewed your letter dated September 2, 1987, concerning the inspection conducted by Mr. I. Barnes and other members of the Comanche Peak Project Division during the period from June 5 through July 7, 1987. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 to your letter was for Comanche a Notice Peak Steam Electric Station Units of Violation. 1 and 2.
Attached l I
We hereby respond to the Notice of Violation in the attachment to this letter.
Very truly yours, -
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W. G. Counsil ROD:tgj Attachment c- Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) 400 Nonh Ohve Street LB 81 Dallas. Tesss 73201
attacnment to iAA-o///
October 2, 1987
,, Page 1 of 2 NOTICE OF VIOLATION ITEM A (445/8711-V-02: 446/8709-V-02)
CriterioniofAppendixBto10CFRPart50,asimplementedbySection 5.0, Revision 3, dated July
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31, 1984, of the TU Electric Quality Assurance Plan, 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.
Section 3.7.6.1.1.b of TU Electric Specification 2323-MS-808, Revision 0, dated May 17, 1976, states, in part, with respect to safety-related water chillers, forbidden." "... Splicing of wiring connections or use of common wire nuts is l,
l Section 3.7.6.2.a of the above specification states, in part, "... All control I and instrumentation wiring shall be brought to terminal blocks mounted within NEMA 12 boxes in accordance with NEMA standards..." i Contrary to the above, the NRC inspector identified the following:
1.
Cap type, inline splice connectors were used to splice wires'inside '
junction / outlet boxes and to terminate instruments and limit switches on all four of the safety-related water chiller units, CPI-CHCICE-05 and -06 and CP2-CHCICE-05 and -06.
2.
A cap type, inline splice was installed on wire #110 between a relay and terminal strip inside the control panel mounted on chiller unit CP1-CHCICE-06.
This splice was located inside a wiring trough.
3.
One of the auxiliary oil pump motor leads was found terminated using a twist-on wire nut on chiller unit CP2-CHCICE-06, (445/8711-V-02; 446/8709-V-02).
RESPONSE TO NOTICE OF VIOLATION ITEM.A (445/8711-V-02: 446/8709-V-02)
TV Electric agrees with the alleged violation tnd the requested information follows:
- 1. Reason For Violation The violation was caused by a failure on the part of the equipment supplier (York-Borg Warner) to comply with specification requirements involving splices and wire nuts. As noted in the chiller procurement specification 2323-MS-808, " Centrifugal Water Chillers," splices and the application of wire nuts are prohibited.
2.
Corrective Steos Taken And Results Achieved NCR's 21, 1987CE-87-9610 and CE-87-10026 were issued on August 11, 1987 and August l respectively, documenting the nonconforming conditions. These NCR's have been dispositioned nuts with approved connections. to replace the unauthorized splices and wire i
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s .. Attachment to TXX-6777 October 2, 1987 Page 2 of 2 s
3.
Corrective Steos Which Will Be Taken To Avoid Further Violations The Approved Vendor List has been revised to restrict further purchases from Tork-Borg Warner pending receipt and approval of a revised QA program.
Further purchases will be limited to spare parts. We have l confirmed no Borg Warner.
other safety-related equipment has been procured from York- '
Issue Specific Action Plan ISAP) VII.a.9 has beer implemented to address concerns regarding vendor co(mpliance with procurement / design i A report detailing the results of the.ISAP VII.a.9 findings is scheduled for issue by December 15, 1987. By January 30, 1988, we will provide a ,
i description of additional corrective actions (if any) planned as a result of the ISAP VII.a.9 Results Report.
- 4. Date When Full Comoliance Achieved Removal of unauthorized splices and wire nuts per NCRs CE-87-9610 and CE-87-10026 will be completed by November 30, 1987. i I
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_ LogM..TXX'-6798
.- - File # 10130 -
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! ., September 30, 1987 l William G. Counsil Eucuant Vre Persskat U. S. 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 REVISED DATE OF FULL COMPLIANCE FOR NOTICE OF DEVIATION ITEM A (445/8702-D-03; 446/8702-D-03) f Gentlemen:
The TV Electric response to Notice of Deviation (N0D) Item A (445/8702-0-03; 446/8702-0-03) stated that full compliance would be achieved by September 30, 1987.
Please be advised that this date has been revised to November 30, 1987.
Very truly yours, b'N',, L, &7 W. G. unsil By: / . #
G. S.'Keele .
Manager Nuc ear c nsing RDDtd c- Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) 400 Nonh Olne Street LB 81 Dallas. Texas 7320I l
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Log # TXX-6803
. File # 10130
= = IR-86-07 WELECTR/C Ref #$C 2 01 l
mm.m c. counsa Esecutose %ce , ares,dem October 1* 1987 1
h V. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 e i
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET N05. 50-445 AND 50-446 l
REQUEST FOR ADDITIONAL INFORMATI0K REGARDING INSPECTION REPORT: 50-445/86-07 AND 50-446/86-05 Gentlemen:
Your letter dated September 11, 1987, requested additional information on the subject inspection report with resr,ect to Notice of Violation (NOV) Item A (445/8607-V-24), Notice of DeviatSn (N00) Item E (445/8607-0-01) and Notice ,
1 1 of Deviation (N00) Item I.3 (445/8607-0-11). i We hereby respond to the above items in the attachment to this letter.
Very truly yours, Q.G. Y W. G. Counsil 1
By: (.J . >>
Jorn W. Beck Vice President, Nuclear Engineering RDD:tgj C- Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) l l
l l 400 Nonh O! ve Street LB 81 Dallas. Texas 75201
Attachment to TXX 6803 October 1, 1987
'Page _1 of 2 RE0 VEST FOR ADDITIONAL INFORMATION NOTICE OF VIOLATION ITEM A (445/8607_-V-24)
...(W)ith respect to NOV Item A, the corrective steps taken appear inadequate in light of the reason given for not performing a technical evaluation of all 48 closed Corrective Action Reports (CARS) to assure that they have been properly dispositioned.
Additionally, please inform us of actions taken to ascertain whether this problem exists in CAR systems used by other groups, such as Brown and Root."
RESPONSE TO ITEM A (445/8607-V-24)
In our original response to this Notice of Violation, we indicated that a review of 10 of the previously. closed CARS had. identified no. additional inadequate justifications for closure. We believe that this result is indicative of the quality of actions taken to address previously closed CARS, and properly addresses the concerns raised in the violation.
To further demonstrate this, the 38 remaining CARS closed prior to the action taken to prevent further violations will also be examined. The review has-been initiated, and will verify the adequacy of each CAR's disposition.
A similar review of the adequacy of the disposition of closed CARS which were i
issued by other organizations, such as Brown and Root, will also be performed.
The reviews are scheduled to be completed by October 30, 1987..
RE0 VEST FOR ADDITIONAL INFORMATION ITEM E NOTICE OF DEVIATION (445/8607-D-01)
With respect to N00 Item E, please provide the basis for the statement in your February 18, 1987, response (TXX-6222) indicating that.the welding on the- '
seismic arrestor brackets has been determined to be acceptable. ' Additionally, your response identified that your letter-TXX-3657 would-be supplemented to document why lack of welding documentation does not constitute a significant -
condition adverse to quality. .TXX-3657 was supplemented by.TXX-6526. Please clarify the statements in supplement, TXX-6526, relative to control of bracket materials and welding by the valve manufacturer.
n o n..cn6 6v ina-cova !
, October 1, 1987 j
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RESPONSE T0 l
ITEM E (445/8607.D.01) )
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Information concerning the acceptability of reismic arrestor bracket welds, I acceptance criteria, and clarification of statements regarding the manufacturer's control of bracket materials and welding will be provided in l I
our next update to SDAR CP-83-08. As stated in TXX-6526, we will review Fisher Control's Certificates of Confortr.nce and will inspect the bracket attachment welds in accordance with the visual weld acceptance criteria (VWAC), and the weld sizes as depicted on the vendor's design drawings.
Although our next report is scheduled for issue by January 14, 1988, in view of your concern regarding this issue we will submit an updated response to the SDAR 1987.
which will include the additional information no later than November 30, Ef_@EST FOR ADDITIONAL INFORMATION !
NOTICE OF DEVIATION ITEM I.3 (445/8607-D-ll)
Please identify the actions taken in regard to N0D Item I.3 to avoid recurrence of further errors by the identified ERC inspector, i
RESPONSE TO ITEM I.3 (445/8607-D-11)
No actions were taken in regard to N00 Item I.3 to avoid recurrence of further errors by the identified ERC inspector.
documented the "out" side caliper reading, had been terminated due to aThe ER reduction in force (May 21,1986) prior to this error being identified to TV Electric.
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Log # TXX-6815 y9 File # 10130
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IR 86-06 -
r = 1R 86-04 7UELECTRIC Ref # 10 CFR 2.201 October 1, 1987 William G. Counsil Esecuene Vet Prvsutent U. S. 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 N0. 50-445/86-06 AND 50-446/86-04 REVISED DATE OF FULL COMPLIANCE TO NOTICE OF VIOLATION (NOV) ITEM A(2)
REFERENCE:
- 1) TUGCo Letter TXX-5037 from W. G. Counsil to E. H. Johnson dated October 9, 1986 ,
- 2) TUGCo Letter TXX-6071 from W. G. Counsil to E. H. Johnson dated October 31, 1986
- 3) TUGCo Letter TXX-6213 from W. G. Counsil to E. H. Johnson dated January 22, 1987
- 5) TV Electric Letter TXX-6481 from W. G. Counsil to NRC dated June 30, 1987
- 6) TV Electric Letter TXX-6774 from W. G. Counsil to NRC dated September 14, 1987 Gentlemen:
Reference would (6) statedbythat be completed the cable October 1,1987.rework associated with NCR CE-87-7481 We have encountered additional delays in performing this rework. Accordingly, our date for completion of cable rework specified in NCR CE-87-7481 is hereby revised to be no later than November 1, 1987.
Very truly yours, At)- G .
W. G. Counsil By: _kd.b John W. Beck Vice President, Nuclear Engineering c- Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) l l
400 Nonh Ohve Street LB 81 Dallas. Texas 73201 l
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M Log # TXX 6832
' File # 10130
-- J IR 85-16 i
= = IR 85-13
# I* OI
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filELECTRIC wa.m c, coun.u October 9, 1987 Executive Vxv Presadent U. S. 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 REVISED RESPONSE REGARDING INSPECTION REPORT 50 445/85-16 AND 50-446/85-13 1
l Ref: 1) NRC letter from E. H. Johnson to W. G.'Counsil dated April 4, 1986
- 2) TV Electric letter TXX-4826 from W. G. Counsil dated June 16, 1986 ,
1987 Gentlemen:
Reference (2) provided our original response to Notice of Violation (NOV) Item C (445/8516-V-13) of Inspection Report 50-445/85-16 and 50-446/85-13. In reference (3) TV Electric committed to revise our original response'in order to clarify our position. Accordingly, a revised response is enclosed. Since the entire response has been revised, no revision bars have been provided.
Very truly yours, ,
97ty W. G. Counsil RDO:tgj c- Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) 400 North Olive Street LB 81 Dallas. Texas 73201
Attachment to TXX-6832 October 9, 1987 l Page 1 of 2 NOTICE OF VIOLATION i ITEM C (445/8516-V-13) '
C. Criterion X of Appendix B to 10 CFR 50, as implemented by Section 10.0, Revision 1, dated July 31, 1984, of the TUGC0 QAP, states, in part, " A program for inspection of activities affecting quality shall be established and executed ... to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity." i Paragraph 5.1.2 in B&R Procedure CP-NDEP-200, Revision dated September 27, !
1979, states, in part, "The final surface condition of plate and piping '
welds shall be visually inspected after completion of the weld for ...
fillet size (as applicable)." Revision 4 of Drawing CC-1-131-010-S43R requires welds on two sides for item 8 to item 9, with a fillet size of 1/4 inch. A weld fillet size of 1/4 is also specified for items 9 and 10. 4 Contrary to the above, inspection of Unit 1 ASME Pipe Support No. CC l 131-010-543R, which had been previously inspected and accepted by Quality 4 Control, identified the presence of undersize welds. A total weld length of approximately 20 inches was found to be undersize by a minimum of 1/16 inch with respect to the item 8 to item 9 fillet welds. A consecutive 2- 3 i
inch segment was also present in these welds which was 1/8 inch undersize. 3 The vertical welds on the outside of the wide flange joining items 9 and 1 10 were also found to be undersize by a minimum of 1/16 inch for more than 25% of the weld length (445/8516-V-13).
REVISED RESPONSE I ITEM C (445/8516-V-13)
)
TV Electric agrees with the alleged violation and the requested information follows:
- 1. Reason for Violation The reason for the violation was inadequate QC inspection of the as-built weld i size to the weld size required by the associated design documents.
- 2. Corrective Steos Taken and Results Achieved To address the specific deficiencies identified in the violation, j Nonconformance Report (NCR) XI-708 was issued on November 14, 1985. This NCR '
was subsequently transferred to NCR M 25650 on March 11, 1986. NCR M-25650 was dispositioned " accept as is" based on an evaluation of the as-built I conditions.
3.
Corrective Steos Which Will be Taken to Avoid Further Violations The Issue Specific Action Plan VII.c weld size reinspection 1
Attachment to TXX-6832 October 9, 1987 Page 2 of 2 conducted on Unit 1 by the third party did not indicate the quality of pipe support welds to be a problem area. The reinspection results indicated a very low incidence of undersized welds, and none were identified that were considered safety significant. TV Electric believes that these results demonstrate the isolated nature of this violation and adequately address the undersize weld issue for Unit I weld inspection activities. We also believe that these results are indicative of the quality of work performed in Unit 2 since it was constructed and inspected using similar criteria and the same personnel.
Since initial inspection of the subject welds in 1979 and the final weld inspection in 1982, a number of revisions to the component support weld inspection program have been made. These revisions were aimed at improving the quality of weld inspections and their documentation. For example:
With the issuance of QI-QAP-11.1-28 Revision 16 on December 15, 1982, a Weld Inspection Checklist (WICL) was required to be completed by the QC Inspector (QCI) for each pipe support at the time of fabrication completion. Prior to this time, less stringent documentation requirements were applied. Completion of the WICL required the QCI to measure the actual weld size and record it on the WICL, initial and date the WICL, and sign and date the hanger design drawing and/or CMC. Since the hanger design drawing and/or CMC contained the design weld sizes, these provisions provided additional assurance that the inspectors were comparing the deposited weld size to the design weld size.
Revision 24 to QI-QAP-11.1-28 issued April 18, 1984 significantly expanded the scope of the Hanger Inspection Report completed for each hanger. This revision required the WICL to be completed for all Unit 2 supports regardless of the fabrication or installation status. Additionally, this revision was intended to assure objective evidence of QCI verification of each quantitative attribute considered relevant to the analysis by engineering.
Another significant change was implemented via Revision 11 of CP-QAP-12.1, which was issued on June 28, 1984. That revision required Brown and Root N-5 package reviewers to assure that individual weld inspections were performed and documented correctly by verifying the inclusion of a completed WICL in the completed work package. That revision also required reinspection of any component support welds which were submitted for package review in accordance with this procedure and not previously documented on a WICL per QI-QAP-11.1-28.
These revisions have resulted in an improved program which enhanced the assurance that weld inspections are properly performed. The majority of the Unit 2 component support weld inspections have been performed with these controls. Throughout implementation of these improvements, the individuals responsible for implementing the changes have been trained in their application.
4.
Date When Full Comoliance Will be Achieved 1
NCR M-25650 was dispositioned on October 6, 1986, and will be closed prior to i Unit 1 fuel load. Revision 11 to CP-QAP-12.1 was approved on June 28, 1984.
M MM Log # TXX-6856 L :
File # 10130 E E IR 86-15 tilELECTRIC I O *
October 15, 1987 WWiam G. Counsa fuewne Vre hesusen, 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 NOS. 50-445/86-15 AND 50-446/86-12 REVISED DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION (N0V) ITEM C (446/8612-V-03)
REF:
- 1) NRC letter December 22,from 1986.E. H. Johnson to W. G. Counsil dated 2)TVElectricLetterTXX-6250frhmW.G.CounsiltoNRCdated February 2, 1987
- 3) May TV Electric 22, 1987 Letter TXX-Cf66 from W. G. Counsil to NRC dated Gentlemen:
Reference (3) provided our revised response to Notice of Violation (N0V)
Item C (446/8612-V-03) of Inspection Report 50-445/86-15 and 50-446/86-12. In that response TV Electric stated that issuance of instructions, examination of enclosures, October 15, 1987.and resolution of NCRs on NEMA enclosures would be completed by For Unit 1 and Common Systems, these activities have been incorporated in the Post Construction Hardware Validation Program. For Unit 2 systems, fuel load. these activities will be accomplished as required to support Unit 2 Accordingly, our date of full compliance is revised as follows.
The issuance of instructions, examination of enclosures, and resolution of March 1,1989, for Unit 2 Systems.NCRs will be completed by March 1, 198 Very truly yours, u> , c . M W. G. Counsil By: . ;
)6 fin W. Beck Vice President, ROD:tgj Nuclear Engineering c-Mr. R. D. Martin, Region IV t Resident Inspectors, CPSES (3) 400 North Olne Street LB BI Dallas. Texas 73201
File # 10130 '
= = IR 86-06 filELECTRIC cfg p,7 , 9; w ann c, coon.n Eucwne %ce Presu:6 tat October 12, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 I,
1
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) !
DOCKET N05. 50-445 AND 50-446 '
INSPECTION REPORT N0: 50-445/86-06 AND 50-446/86-04 REVISED DATE OF FULL COMPLIANCE TO NOTICE OF I
VIOLATION (NOV) ITEM B (446/8604-V-03) 1
Reference:
1)
TUGC0 9, October Letter 1986 TXX-5037 from W. G. Counsil to E. H. Johnson dated 2)
TV Electric May 8, 1987 Letter TXX-6387 from W. G. Counsil to NRC dated 3)
TV Electric June 30, 1987 Letter TXX-6481 from W. G. Counsil to NRC dated Gentlemen: i 1
Reference (3) provided our response to NOV Item B (446/8604-V-03). In that response we stated that by October 15, 1987, Fi' eld Verification Method (FVM) {
procedures would be issued to determine where cable grips are required. The !
FVM for Unit 1 and common systems was issued July 29, 1987. The FVM for Unit 2 systems will be issued as required to support completion of walkdowns, }
generation of DCA's and installation of cable grips by December 31, 1988, ]
i I
Very truly yours, !
l W. G. Counsil RSB:tgj {
C- Mr. R. D. Martin, Region IV !
Resident Inspectors, CPSES (3) !
i i
400 Nonh Ohve Street LB BI Dallas. Texas 73201 i
L______________________._______________._______ _ _ _ ]