ML20236X219
| ML20236X219 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/30/1987 |
| From: | Eggeling W ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#487-4992 OL, NUDOCS 8712090056 | |
| Download: ML20236X219 (1) | |
Text
- _ - _ _ _ _ _ _ _ _
diib ROPES & GRAY 225 FRANKLIN STREET DClhlii r BOSTON, MASSACHUSETTS O2110 IN PROVIDf NCE IN WASHINGTON 30 M E NNEDY PLAZA TELEX NUMBER 940$l9 ROPGRALOR B5 Y S ECON D STR E ET, N W PRoviOE%CE,R L 02903 TELEX NUMBER 951973 ROPE 5 GRAY $$N W ASHI NGTO N, D. C. 2 00 37 (2 o2) 42 9-is o o 400 6;ti-64oo itLEcoPiERS I6171 423 2377
<si7) 423 yi.e, u
)
OCKNING 5 51 HVII,f.C
""'")***~'
T E L E cm'iE R: (soin sat osio INTER N AT10N AL i617) 423-6905 BRANCH November 30, 1987 Peter B. Bloch, Chairman Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Kenneth A.. McCollom Administrative Judge 1107 West Knapp Stillwater, Oklahoma 74075 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 pocket Nos. 50-445-OL & 50-446-OL
Dear 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 October 26, 1987, through November 23,
- 1987, to Notices of Violation and " notices of deviation" rendered by the NRC Staff.
Very t uly your,
William S.
Egge ng WSE/plw Enclosure cc:
Service List 8712090056 871130 PDR ADOCK 05000445 G
])5o3
M
- == 9 Log # TXX-6888
.::=
File # 10130
=
=
IR 84-16 nlELECTRIC
- ' # 1*C'R****I wim
- c. c nw November 2, 1987 r=w, v,a rm.=,w 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 DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION ITEM A (445/8416-V-01)
REF: 1)
TUGC0 Letter TXX-4346 from B. R. Clements to R. L. Bangart dated November 1, 1984.
2)
TUGC0 Letter TXX-4369 from B. R. Clements to R. L. Bangart dated November 28, 1984.
3)
TUGC0 Letter TXX-4393 from B. R. Clements to R. L. Bangart dated January 14 1985.
4)
TV Electric Letter TXX-6440 from W. G. Counsil to U.S.N.R.C. dated May 8, 1987.
5)
TV Electric Letter TXX-6614 from W. G. Counsil to U.S.N.R.C. dated July 31, 1987.
Gentlemen:
Reference (5) stated that the required modifications and rework of Unit 1 Cable Tray Hangers (CTH) were scheduled for completion by November 2,1987.
This effort is being performed in conjunction with our room and area turnover program. As a result of the substantial effort required by these programs, the scheduled completion date for the modification and rework of Unit 1 Cable Tray Hangers is hereby revised to be January 8,1988.
Our completion date for the Unit 2 CTH modification and rework program is still scheduled for October 31, 1988, as stated in reference (5).
Very truly yours, f
W. G. Counsil DAR/gj c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3) 400 Nonh OI,ve Street LB GI Dallu. Tesu 15201
_ VO l 1 & I A I O. O I
a~s g
y na+sw
i g
Los # TXX-6895 File # 10130
~
b J
IR 84-32 E
3 IR 84-11 Ref # 10CFR2.201 ftELECTRIC November 6, 1987 wn.a. c. cws Eawsove Vwe hwsunum U. S. Nuclear Regulatory Comission i
Attn: Document Control Desk Washington, D. C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STMION (CPSES)
DOCKET NOS. 50-445 AND 50-446 REQUEST FOR AD0!TIONAL INFORmTION REGARDING INSPECTION REPORT: 50-445/64-12 AND 50-446/84-11
Reference:
1.
Lettar froe D. 8. Nia6 er (NRC) to M. D. Spence (TUGCo) dated Feb'ruary 15, 1985 2.
TXX-6144 from W. G. Cotinsil (TUEC) to R. D. Martin (NRC),
dated February 2, 1987 Gentlemen:
On July 15, 1987, TU Electric representatives met with your H. F. Warnick and members of his staff to discuss the subject inspection report (Reference 1) and our response to the attached Notice of Violation, Item 1 and 3 (Reference 2). As a result of that meeting, the following additional information relative to our response to these items is provided.
For convenience, the alleged violation from the subject report and our initial response has been provided, followed by the additional information.
Very truly yours, G.G. Su W. G. Counsil By:)
D. R. Woodlan Supervisor, Docket Licensing c-Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) 400 Nonh Ohve Street LB tl Datins Teus 75201
November 6, 1987 Page 1 of 10 A11eoedVioldlion 1.
Failure to Reaularly Review the Status and Adecuacy of the OA Procram Criterion II of Appendix B to 10CFR50, as implemented by the Preliminary Safety Analysis Report (PSAR) and the Final Safety Analysis Report (FSAR),
Section 17.1, " Quality Assurance Program," and ANSI N45.2-1971, requires that the quality assurance program shall provide for the regular review by the management participating in the pregram, of the status an0 adequacy of the part of the quality assurance program for which they have designated responsibility.
Contrary to the above, the applicant did not establish quality assurance procedures to regularly review the status and adequacy of the construction quality assurance program; nor did the applicant appear to have reviewed the status and adequacy of the construction quality assurance program.
(445/8432-02; 446/8411-02)
TUGio kESPONSE TUGC0 acknowledges that procedures were not established for the regular I
review of the status and adequacy of the construction quality assurance (QA) program. Notwithstanding this lack of procedures, it is TUGCO's view that managers and corporate officers by virtue of their day to day involvement were aware of the status and adequacy of the construction QA i
program. That awareness was based on various practices employed by TUGC0 managers and officers during the history of CPSES to evaluate the QA program. Those practices included the use of quality committees, documented hanagement review, and independent evaluations. In addition, i
these managers and officers routinely received a variety of repcrts concerning the adequacy of the construction QA program such as TUGC0 QA internal audit reports and reports produced by independent personnel from outside of the TUGC0 organization.
1.
Corrective Action and Results Achieved TUGC0 recognizes that regularly scheduled QA program assessments and reviews serve to focus management's attention on program adequacy and effectiveness. Accordingly, the Quality Assurance Overview Comeittee was j
formed and has met regularly since September 1985. The original charter
(
for this comeittee was contained in Procedure DQP-CQ-5. The duties and respoestM11ttes of this committee are currently described in the
{
followhg pelicles and procedures-1 NE0 Policy Statement Number 2, " Quality Assurance Program" l
o (Revision 0 dated June 23,1986): Requires the NEO Vice Presidents to meet periodically to assess the status and 1
adequacy of the QA program and at least annually to provide a written assessmer,t of the overall effectiveness of the program to the Executive Vice President, NEO. The Executive Vice President, NE0 will ascure that an annual j
4
Page 2 of 10
-)
independent assessment of the TUGC0 audit program is parformed and the results reflected in the Vice-3 1
Presidents' annual assessment.
NEO Procedure 2.20, " Senior Management QA Overview i
o.
Program" (Revision 2, dated October 13,1986): Defines j
the methodology employed by the NEO Vice Presidents in i
meeting their responsibilities as defined in NE0 Policy
{
Statement No. 2.
This procedure establishes a committee which meets at least quarterly to evaluate the status and adequacy of the TUGC0 QA program.
i NEO Procedure 2.08, " Joint Utility Management Audit o
Program" (Revision 0 dated June 23,1986): Provides o method which the Executive Vice President, NEO may utilize to perform the independent assessment of the TUGC0 audit program as delineated in NE0 Policy Statement No. 2.
1 2.
Corrective Steps to Avoid Recurrence The corrective actions described above are considered sufficient to prevent further violations.
3.
Date When in Full Compliance Full compliance was achieved June 23, 1986.
A00!TIONAL INFORMATION The lack of procedures resulted in a lack of documented reviews of the status and adequacy of the construction quality assurance program. This condition represented a weakness in the construction quality assurance program.
Based on the NRC finding, it was determined that specific fomal controls to address this area were required. This, in part, resulted in the issuance of a memorandum from the President of Texas Utilities which called for development of policies and procedures to ensure that the "Overall effectiveness of the quality assurance program...be regularly reported to Corporate Management...".
Subsequently, Nuclear. Engineering and Operations (NEO) Policy Statement Number 2 was issued, detailing this policy and causing the development of implementies NE0 procedures 2.20, " Senior Management 0A Overviet Program," and 2.08, " Joint utility Management Audit Program".
The lack of e^ tablished procedures to regularly review the status and adequac:.
s of the construction quality assurance program concern was addressed in issue Specific Action Plan (ISAP) VII.a.5.
" Periodic Review of 0A Program." The ISAP evaluated the new procedural controls implemented based on the requirements of ANSI N45.2-1971 and 10CFR50 Appendix B, as well as applicabl~
criteria from the Institute for Nuclear Power Operations and the applicable sections of the NRC Standard Review Plan, NUREG-0800. Because of the similarity of the criteria in these documents, the ISAP criteria were developed to closely reflect and expand upon the criteria contained in the Standard Review Plan. The ISAP review reached the following conclusions:
1 1
F ~, >
Novembrr 6, 1987 Page 3 of 10
^
The program now provides for a regular assessment of the status o
and adequacy of the QA Program.
The program defines the management positions responsible for the o
pert. odic review of the QA Program.
The program describes the methodology for performing the program o
assessments and their frequency, The program d? scribes the methodology for reporting, tracking and o
follow-up of the esults of the periodic review of the QA Program.
Regular program review meetings are being held in conformance with -
o the new procedures.
Meetings are focusing effectively on identified problems in the QA o
program.
Refinements are being made to improve the implementation and o
documentation of the procedural controls which govern the review.
Based on the above described actions, we Delieve that the concerns identified in the violation have been thoroughly addressed. These actions will assure that the QA Program remains in compliance with the specified requirements.
Alleged Violaticn 2.
Failure to Establish and Implement a Comprehensive Systew of Planned and Periodic Audits Criterion XVIII of Appendix B to 10CFR50, states, in part, "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to detemine the effectiveness of the program." The requirements are addressed in the PSAR and FSAR, Section 17.1, " Quality Assurance Program,"
which references Regulatory Guide 1.28 (ANSI N45.2) and ANSI N45.2.12 (Draft 3, Revision 4). Those commitments require that a comprehensive system of planned audits be performed on an annual frequency.
Contrary to the above, the following examples were identified which demonst ets the failure to establish and implement a comprehensive system of plaq and periodic audits of safety-related activities as required, as not e gelow:
Ar,nual audits were not adequately addressed by the audit a.
implementation procedures.
TUGC0 Procedure 00P-CS-4, Revision 0, dated August 9, 3
378, only required two audits of vendors f abricating reEtor coolant pressure boundary components, parts and
November 6, 1987 Page 4 of 10 I
equipment; sat audit of vendors fabricating engineered safeguards components, parts, and equipment; and audits of balance of plant (safety-related) as required by the quality assurance manager.
o TUGC0 Procedure DQP-CS 4, Revision 2, dated April 16, 1981, required only that organizations will be audited on a regularly scheduled basis.
o TUGC0 Procedure DQP-CS-4, Revisions 2 and 10, did not specify auditing frequencies for design, procurement, construction, and operations activities.
o TUGC0 Procedure DQP-CS-4, Revision 10, based audit requirements on Regulatory Guida 1.33, Revision 2, February 1978. This comitment did not fully address the requirements of the construction quality assurance program.
The above procedure and subsequent revisions failed to describe and require annual audits in accordance with comitments and requirements. Earlier audit procedures were not available to determine if they met requirements.
b.
Planning and staffing to perform 1983 audits was inadequate to assure that a comprehensive system of audits was established and implemented to verify compliance with 111 aspects of the quality assurance program, in that, of 656 safety-related procedures (which control safety-related activities) the NRC review revealed that the applicant sampled only 165, or 25 percent, during the 1983 audit program. Consequently, significant aspects of the safety-related activities were not adequately audited.
The Westinghouse site organization, established in 1977 to perform c.
Nucletr Steam System Supply (NSSS) engineering services, was not audited by TUGC0 during the years of 1977, 1978, 1979, 1980 and 1981.
d.
Audit of vendors that manufacture or fabricate parts, components, and equipment for reactor coolant pressure boundary and engineered safeguards systems have not been conducted annually dating back to August 9, 1978. (445/8432-03; 446/8411-03)
TUGC0 RESPONSE The number and scope of audits conducted each year by TUGC0 over the history of the CPSES project reflect the evolution of the TUGC0 audit program from an initial overview function to the present role in which TUGC0 has assumed primary audit responsibility. The TUGC0 audit program was initially described in the CPSES QA Plan and beginning in 1978 in Procedure CQP-CS-4.
(The procedure identification was changed to DQP-CS-4 in 1982.) The TUGC0 QA Department audit responsibilities described in tre
D,
.NoTeinbTe6,398E ~
Page 5 of 10 SAR were ormalized in Revision 0 (dated Au procedure which estabitshed an audit plan. gust 29,1978) of this Consistent with TUGCO's initial overview role-as outlined in PSAR Table 17.1-1, a minimum number of audits were planned and conducted for those organizations whose QA programs wem described in the SAR. As TUGC0 assumed direct responsibility for site construction and engineering activities, the aucit -
responsibilities of the QA Department expanded commensurately.
I Accordingly, procedure CQP-CS-4 was revised to address these
. responsibilities by providing for regularly scheduled audits of these activities and organizations and for the generation of an annual audit plan.
TUGC0 believes that the audit planning and scheduling practices employed by TUGC0 and its principal contractors over the history of-the project collectively provided adequate audit coverage of.the construction QA program. The conclusions of the CPRT independent review regarding audit planning and scheduling, at described in the Results Report for ISAP-VII.a.4, was that " Audit planning and scheduling, though in the past not in compliance regarding frequency and not formally systemized until recently, did appear to be well thought out in the context of the TUGC0 concept of the audit program requirements at any particular time".
Our response to each of the exarples is set forth below.
ig[TIMAL INFORMATION To address the concerns of this violation, Issue Specific Action Plan (ISAP)
VII.a.4 was developed. This plan had the specific task of evaluating and considering.the implications of these concerns on construction quality, determining the root cause of the findings and any generic implications, addressing the collective significance of the deficiencies, and proposing an action plan which would ensure that such problems do not recur. Input to the ISAP included the NRC Notice of Violation, 10CFR50 Appendix B, SSER 11, the applicable portions of NUREG 0800,'and various regulatory guides and standards.
The ISAP VII.a.4 Results Report states: "The overall effectiveness of the audit program has been less than fully adequate. Specific examples are:
it has failed to identify and cause corrective action of inadequacies in such areas as QC inspector training, qualification, and certification; and control of non-confh et items and corrective action.
It is concluded, from the evidence that the failure to identify and cause corrective action in these two uges was due primarily to the practice of auditing to existing procedures istle not performing verification of the adequacy of existing procedures to implement program requirements.
It is further concluded that the cause of the deviations and weaknesses in the QA audit program which have been identified in this report are the result of inadequate procedures."
The JSAP Results Report also states: "Although audit program deviations and weaknesses related to construction activities were identified, it has been deternined that no action is required t>eyond that specified in ISAP VII.c,
i November 6, 1987 I
Page 6 of 10 l
which addresses all areas of safety-related hardware and is intendad to provide confidence that any currently unidentified concerns related to the quality of construction of the CPSES hardware will have been identified, evaluated and resolved."
TUGC0 RESPONSE TO EXAMPLE 2.a TUGC0 has committed to meet the provisions of ANSI N45.2.12. " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants,"
Draft 3, Revision 0 (vice Revision 4 as stated in the Notice of Violation), dated May 2,1973. We acknowledge that the TUGC0 audit implementation procedures did not explicitly establish an annual audit frequency for all organizations or activities. However, the preplanned audits conducted each year by TUGC0 and its principal contractors provided audit coverage of the involved organizations and the activities of design, construction, procurement and others, as applicable, j
1 1.
Corrective Action and Results Achieved Procedure DQP-CS-4, " Procedure to Establish and Apoly a' System of Preaward Evaluations, Audit and Surveillance", was revised in November 1984 to specifically require that applicable elements of the construction QA program be audited by TUGC0 annually or at least once within the life of an activity, whichever is shorter. Procedure DQP-CS-4 has subsequently been re-identified as DQP-QA-15.
2.
Corrective Stens to Avoid Recurrence The corrective actions described above are considered sufficient to avoid further violations.
3.
Date When in Full Comoliance Full compliance was achieved in November 1984.
' ADDITIONAL INFORMATION ITEM 2.a ISAP VII.a.4 evaluated the audit program performance based on records of the audits performed. The evaluation concluded that the failure to perform vendor audits on as annual frequency resulted in no adverse affect on the audit program of the additional activities implemented by the QA organizat supplement the audits which did occur. These additional activiti uded joint inspection / audits during which auditors would accompany rs on release inspection trips to investigate specific problems, and requests for corrective action sent to vendors for specific, identified problems that did not warrant an audit investigation or did not appear to indicate an adverse trend.
4 As stated in the response to a recent NRC request for additional information regarding this ISAP (Reference TXX-6656, dated August 14, 1987), "when the ISAP VII.a.4 Results Report was prepared...there were no 'known problems with
Page 7 of 10 vendor supplied material' which were attributed to the failure to perform vendor audits on an annual basis. In other words, no procurred hardware problems werer known that could have been identified and corrected through audits or other vendor compliance activities. Subsequent to issuance of the ISAP VII.a.4. Results Report, the scope and methodology of ISAP VII.a.9 has been revised to include hardware inspections which may identify problems which might have beenl identified in an audit program. Information pertinent to the adequacy of the audit program that is gathered during implementation of ISAP VII.a.9 and other ISAPs will be evaluated during the collective evaluation process and described in the Collective Evaluation Report."
TUGC0 RESPONSE TO EXAMPLE 2.b TUGC0 denies'the allegation of a violation for the reasons that follow.
With respect to staffing levels, a designated audit group staff was established in 1979 which increased in strength each year through 1983; however, the number of qualified personnel who actually perfomed audits during those years also included members of the QA organization _ other than those assigned to the audit group. It is.TUGC0's view that the total number of QA personnel who performed audits during 1983 represented an adequate staffing level. The CPRT independent review resulted in the same conclusion as documented in the Results Report for ISAP VII.a.4.
With respect to audit planning,-TUGC0 has reviewed the 1983 audit plan against those safety-related procedures for activities which were being more than minimally performed during 1983. Those procedures were grouped t,y activity groups which were then compared to the scopes of the audits conducted during.1983. All but three of the sixty activity groups identified were subject to audit during 1983. Of the three activity groups not subjected to a specifically secped audit during 1983, two received ancillary coverage as a result of the 1983 auditing activities and one (Protective Coatings QC Inspection) was excluded from the 1983 audit program due to the extensive review by the NRC of that area which was ongoing during 1983.
TUGC0 believes that.the 1983 audit' program coverage of the design and construction phase of CPSES was adequate. This conclusion was also reached by the CPRT independent review as described in the Results Report for ISAP VII.a.4. However, TUGC0 concluded that some of its administrative practices in scheduling audits should 'a femalized in a processer er instruction.
Accordin Phase Audit Program", gly, Instructi a DQI-AG-1.7, "CPSEl Cons was issued June 27, 1985.
(This inst has since been re-identified as Procedure DQP-AG 4.) A simil p ecedure for the scheduling of operations phase audits has been issued aar W-AS ?., 'CPSES Operation Phase Audit Program."
ADDITIONAL INFORMATION ITEM 2.b No additional information was requested.
November 6,7987 Page 8 of 10-
.IpGC0 RESPONSE TO EXAMPLE 2.c TUGC0 denies the allegation of a violation for the rtasons that follow.
TUGC0 did not perform audits of the Westinghouse 1113 organization because this organintion is not and has never been responsible for the perfomance of safety-related activities. This was verified by TUGC0 during Westinghouse audits TWH-23 and TWH-24 conducted in 1982. However, subsequent to the NRC inspection TUGC0 performed an audit in November 1984 (audit number TWH-30) of the Westinghouse site activities which confirmed that the Westinghouse site organization was not responsible for the perfomance of safety-related work activities. Therefore, there is and was no requirement to audit this organization. The CPRT independent review resulted in the same conclusion as documented in the Results Report for ISAP VII.a.4.
To assure that we remain cognizant of the scope of work for the i
Westinghouse site organization, the Westinghouse Division responsible for the Westinghouse site organization has been identified on the vendor audit schedule and the TUGC0 Approved Vendors List (AVL). This assures that an annual evtluation of that Division's activities will be perfomed.
ADDITIONAL INFORMATION ITEM 2.c The CPRT review of this issue examinr' the scope of activities for which Westinghouse was responsible during t;.e period in question. This review detemined that between 1977 and 1981, the Westinghouse site organization provided support to the Westinghouse home office through involvement in the transmittal of Field Change Notices (FCNs) and engineering dispositions of i
Field Deficiency Reports-(FDR) to TU Electric. Based on this, it was determined that the Westinghouse site organization did perfom activities subject to 10CFR50 Appendix 8 Criterion VI, " Document Control."
This activity was perfomed by Westinghouse personnel in accordance with procedures OPR 210-2 for FDRs and OPR 305-4.for FCNs. These procedures are in j
turn implemented in accordance with the requirements of the Westinghouse Nuclear Service Division Quality Assurance Program Plan WCAP 9245. As a result of this, the site organization was subject to audit by Westinghouse per WCAP 9245, uns audited six times in the period from January 1978 to October 1 For this
, the requirements of ANSI 45.2.12 were met by TU Electric's audits of inghouse parent organization for compliance with 10CFR50 Appendix B Crfterion XVIII.
TUGC0 RESPONSE TO EXAMPLE 2.d TUGC0 assumed responsibility for the vendor audit program from Gibbs &
Hill beginning in January 1978. To assure the most effective utilization of audit resources, TUGC0 QA management scheduled vendor audits based on the following:
iiiMatii,19si~ ~
~*
Paga 9 of 10
~
Vendor Activity; o
Evaluation ratings determined from reviews of source o
release inspection trip reports; Receipt, installation or test problems connunicated to the 0
audit group from the site; o
The last audit date.
This practice assured the application of audit resources to a vendor during active fabrication or when source or receipt inspections or other information indicated potential quality problems.
J There were occasions when vendors were not audited annually due to satisfactory vendor ratings or lack of activity at the vendor facility.
However, it is our view that our practices resulted in an adequate vendor audit program and were equivalent to the practices endorsed by the NRC in Regulatory Guide 1.144, Revision 1.
The CPRT independent review of this violation concluded'in the Results Report for ISAP VII.a.4 that the failure to perfom audits of all TUGC0 vendors on an annual freques, did not result in any adverse effects on the audit program because of t e additional activities implemented by the QA organization to supplement the audit activity.
1.
Corrective Action and Results Achieved Following the NRC Special Review Team inspection conducted in early 1984, TUGC0 detemined that the FSAR description of its external audit program neaded clarification. Consequently, in August 1984 TUGC0 revised FSAR Table IA(8) to adopt a committaent to paragraph C.3(b), " External Audits",
of Regulatory Guide 1.144. Revision 1.
This commiitment requires the performance of annual evaluations and triennial audits of active vendors.
TUGC0 Procedure DQP-CS-4, " Procedure to Establish and Apply a System of Pre-award Evaluations, Audits and Surveillance," was revised in November 1984 to incorporate this cosmiitment. (This procedure has since been re-identified as DQP-QA-15, 'TUGC0 QA Audit Progras.') Evaluations for all active vendors on the AVL which were last audited during or before 1983 were completed in the first quarter of 1985. As of January 1, 1986 all active venders en the AVL were within their annual evaluation and tri endit frequency.
2.
CG.. -
1*^-~ ta Avoid Recurrence w
The corrective actions der.cribed above are considered sufficient to prevent recurrence of this violation.
~
' November 6,1987-
.Page 10 of 10 3.
Date When in Full Compliance Full compillance was achieved as of January 1,1986.
ADDIT 10NAL INFORMATION ITEM 2.d A CPRT review was perfomed based on the audit index for the period, which determined that the audits were not performed in accordance with the applicable requirements for timeliness or frequency. The review determined that a number of mitigating activities were performed during this period.
These included:
A vendor rating program was used to adjust the scheduling of o
. inspections and audits. Some of the audits which were reviewed by the CPRT were noted to have been performed in response to unsatisfactory inspection results.
o' In mid-1979, a joint inspection / audit program was instituted whereby auditors would accompany inspectors.on release inspection trips to investigate specific program areas based on problems identified during previous source inspections.
TV Electric QA used " Request (s) for Corrective Action" which were o
correspondence with the vendors requesting corrective action for specific, identified problems when it was concluded that the problems did not warrant an audit investigation or did not appear to indicate an adverse trend.
Internal documents known as " Yellow Flag Sheets" were also o
utilized by the TU Electric QA Staff to ensure that applicable QA persennel were aware of status and/or problems with particular vendors (e.g., a hold placed on shipments from a vendor until after an audit was performed).
While source inspections and limited scope audits were not intended to serve l
as substitutes for a regularly scheduled program of audits, they did provide data which was used by TU Electric to evaluate the effectiveness of vendor QA programs.
)
I As discussed in the response to NRC's request for additional information i
related
!$AP(TXX-6656datedAugust 14,1987),"Subsequenttothe 4
issue of ISAP VII.a.4 Results Report, the scope and methodology of ISAp VII.a.9 revised to include hardware inspections which may identify
- problems, eight have been identified in an audit program.
Information pertinent to the adequacy of the audit program...will be evaluated during the collective evaluation process and described in the Collective Evaluation Report."
l
J 4
M Log # TXX-6917 t
- === m File # 10130 IR 87-13
=
=
IR 87-10 Ref # 10CFR2.201 ft#ELECTR/C November 6, 1987 wmw c. coon.u eaaa,.e va en,aa U. S. Nuclear Regulatory Commission Attn:
Document Control Desk j
Washington, D. C. 20555 l
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO INSPECTION REPORT NOS.
50-445/87-13 AND 50-446/87-10 Gentlemen:
TU Electric has reviewed your letter dated October 7,1987, concerning the inspection conducted by Mr. I. Barnes and other inspectors and consultants during the period July 8 through August 4, 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.
We hereby respond to the Notice of Violation in the attachment to this letter.
Very truly yours, 0.0-W. G. Counsil By:
D. R. Woodlan Supervisor, Docket Licensing RDD/tgj i
Attachment c-Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) i OM Gikt NM
[8 Tl OAW5. NAM UTl yy-u
,,nv,-,
E Nove:ber 6, 1987
'Page 1 of 2 4
(445/8713-V 01)
Criterion V of Appendix-B to 10CFR Part 50, as implemented.by Section 5.0, Revision 3,' dated July 31, 1984, of the TU Electric Quality Assurance Plan
-(QAP), reautres that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions ' procedures, or
' drawings'ef_a type. appropriate to the circumstances.
i.
Section 4.2.4 of CPSES Startup Administrative Procedure CP-SAP-6, Revision 9,
" Control of Work on Station Components After Release From Construction to TUGCO," dated March 10, 1983, requires with respect to processing of a Startup i
Work Permit (SWP), that TUGC0 Startup "... provide a step-by-step (operation sequence) description of work to be performed including any reference to
)
required procedures, design documents or instruction manuals..."
Contrary to the above, Startup Work Permit (Construction Operation Traveler)
Z-2214, issued to perform a hydrostatic test on ths discharge vent cover and the suction drain cover on Positive Displacement Charging Pump TBX-CSAPPD-01,
~ failed to provide a description of the applicable torque requirements 1
specified by the vendor instruction manual for reinstallation of these pressure boundary covers (445/8713-V-01).
RESPONSE TO (445/8713-V-01)
TV Electric agrees with the alleged violation and the requested information follows:
1.
Reason for Violation N purpose of the Startup Work Permit (SWP Z-2214) was to remove the p.ip's vent and drain piping to perform a hydrostatic test of that piping.
The bolting of flanged connections in other piping systems _has no specified torque requireaants.
Since the cover plates were welded to the piping system and bolted to the pump casing, it was not apparent that the cover plates (flanges) should have been considered as part of the pump equipment. Consequently, the pump vendor manual was not referred to during the preparation of the SWP and the designation of these cover plates as pressure boundary components with torque requirements was overlooked.
2.
Corrective Stens Taken and Results Achieved:
1 Upon notification of the problem and review of the vendor manual, the Westinghouse site organization was contacted to determine the applicability of the bolt torquing procedure, relative to Section 2.2 of the procedure which states; "This procedure is limited to lubricated i
external threads and dry collar."
It was confirmed that the cover plates l
_ _ = _ _
Page 2 of 2 C
should have been torqued as stated. With that' confirmation
.t non-
'8' conformable reports were initiated identifying the flanges a,s not having
.been tor (ued following reinstallation under the SWP in January 1984, altho the pump was subsequently operated in preoperational testing in June 1
, without evidence of leakage.
These NCRs have not.yet been dispositioned.
To' determine' the scope of the violation, a review of. surveillance reports on Startup activities since'1982 was conducted. This review determined that 10 surveillance were conducted on the activity of work control, with eight of..the 10 specifically addressing the use of SWPs. A total 0f. 307.
SWPs were reviewed during the surveillance and various problems were found with 65 of the 307.SWPs. All 65 SWPs were evaluated with respect to this. violation; that is, specification of vendor manual requirements
-l contained in-the work instructions.
This evaluation completed.on October
'21, 1987, determined that within the sample of 65 SWPs where vendor manual requirements applied to the work being performed, requirements were either specified on the SWP or directions provided which referred the individual to the manual (for example, disassemble in accordance with technical manual xyz).
Based upon this evaluation, the scope of the violation is determined to represent an isolated case.
3.
Corrective Stans Which Will be Taken to Avoid Further Violations:
Revision 13 of CP-SAP-6, " Control of Work on Station Components After Release from Construction to Startup," Section 4.2.4 will contain a requirement to obtain a review of each new SWP for adequacy of instruction by the individuals group leader.
The group leader is certified by CP-SAP-
-19, " Indoctrination / Training / Qualification Requirements for Startup Personnel," to Level IV, the highest qualification level for Startup Personnel.
4.
Date When Full Cameliance Will be Achieved:
Full compliance will be achieved with the issuance of CP-SAP-6, Revision 13, which will be November 30, 1987.
l l
)
l I
I i
]
Log # Txx-6938 h
j File # 10130
=
=
IR-86-22
,kckg filELECTRIC p,q nt wim,.c.cona November 13, 1987 Esa urne he Pre.sakm V. 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 DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION ITEM B (445/8622-V-04)
Reference:
- 1) NRC letter from E. H. Johnson to W. G. Counsil dated March 18, 1987
- 2) TV Electric letter TXX-6396 from W. G. Counsil to NRC dated April 27, 1987 Gentlemen:
Reference (2) provided our response to NOV 445/8622-V-04.
In that response we stated that the subject valve bonnet would be replaced per NCR M-23178N no later than November 30, 1987.
We anticipate delivery of the replacement valve bonnet by the end of February,1988.
Accordingly, our date for replacement of the subject valve bonnet is hereby revised to be no later than March 31, 1988.
l Very truly yours,.
h W. G. Counsil RDD:tgj C - Mr. R. D. Martin, Region IV i-Resident inspectors, CPSES (3) l'.
l I
nep p l l qg 4(JO North Olive Street LB 8I Dallas. Tesas 73201 0 (.1
,1 lC
,.c
~<
M
, - s..
Lo.gf..J 'TXX-6964.)
L,,,,,
j File # 10130
,=
=
IR-85-03 l
M# ELECTRIC 86-02 Ref # 10CFR50.201 wmlam G.' Counsil 1,o,,,, vo e,.
November 20, 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 50-445/86-03 AND 50-446/86-02 SUPPLEMENTAL INFORMATION CONCERNING BASE MATERIAL DEFECTS Gentlemen:
Your letter to W. G. Counsil of October 14, 1987, asked what actions will be taken to assure that the base material defect attribute is not a concern relative to the Quality of Construction for pipe supports. CPSES is currently preparing a verification plan that will be used to reverify (for base materia'l defects due to grinding) the welds from a representative sample of 60 pipe.
supports.
The reverification is expected to be completed by December 31, 1987.
Further actions.will be defined as necessary based on'the results of this verification.
Very truly yours, V'6". lea, W. G. Counsil-g,.
N.. >. s. /.. a y.
J. S. Marshall Supervisor, Generic Licensing 850/mgt c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3)
~~~ O rs I \\ %MW
' %(
$ons Otuse Street LB 81 Dallas Tem WOI
_ o q p.J. M v~.)
I
N' V
J~Mle#10130 eg # TXX-6993 P9
.}
=.
=
=
IR 86-22 1tIELECTRIC IR 86' 0 wimm c. counsa November 20, 1987-E, auto.e \\ ne P rsawne U. S. Nuclear Regulatory Commission Attn: Doannent control Desk t
Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION-(CPSES)
DOCKET N05. 50-445 AND 50-446 INSPECTION REPORT 50-445/86-22 AND 50-446/86-20 REVISED DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION ITEM A (445/8622-V-02; 446/8620-V-03)
REF:
(1) TV Electric Letter TXX-6757 from W. G. Counsil to NRC dated September 18, 1987 g
Gentlemen:
Reference (1) providad a revised date of full compliance to NOV item A (445/8622-v-02; 446/8620-V-03).
In that letter we stated that nonconformance documents would be dispositioned by December 18, 1987.
The additional information needed from the valve supplier (Crosby) has not been received, but is expected to be received to allow the nonconformance documents to be disposit ioned by February 15, 1988.
Additionally, Reference (1) stated that a response delineating any required additional corrective action that may result from ISAP Vll.a.9 would be provided by November 20, 1987.
This was cased upon an expected completion of ISAP VII.a.9 by mid-October.
Currently, completion of ISAP VII.a.9 is not expected before mid-January 1988. Consequently, our response delineating any additional corrective action will be provided by February 15, 1988.
Very truly yours.
b). $. Cou.s S d W. G. Counsil By:
J. 5. Marshall Supervisor, Generic Licensing ROD /grr
)
i c - Mr. R. D. Martin, Region IV Residant inspectors, CPSES (3)
I 1
400 North Olne Street LB 88 Dallas. Teus 73:0I OD1 1 9 d M&I Im o tss a r s~>
+('
a