ML20246Q173
| ML20246Q173 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/12/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89257, NUDOCS 8905220401 | |
| Download: ML20246Q173 (5) | |
Text
..
- I
.==
=__
=__ '
. Log # TXX-89257 2
File # 10130
~ 7UELECTRIC Ref. # 10CFR2.201 May 12,:1989 w.s.c.hm
' Executive Vice President.
L U. S. Nuclear Regulatory Commission
' Attn: Document Control Desk Washington,.D. C.
20555 f
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 o
FOLLOW-UP RESPONSE TO NOTICES OF VIOLATION (NOV) 445/8871-V-03, 445/8906-V-02 AND 445/8912-V-03 l
REF:
~1.
TXX-89209 dated' April.24, 1989, W. J. Cahill to NRC 2.
TXX-89112 dated February 28, 1989, W. J. Cahill to NRC Gentlemen:
Reference 1 provided our initial response to Notice of Violation 445/8906-V-02 a
- and Notice'of Violation 445/8912-V-03.
In that response, we stated that a follow-up response would be submitted by May 12, 1989, which would provide actions planned to resolve the conditions identified during an engineering walkdown of pipe supports. Additionally, in Reference 2 we stated that a i
follow-up response would be submitted which provides our assessment of the generic implications and any additional corrective action taken to resolve the i
pipe support angular misalignment issue identified in Notice of Violation 445/8871-V-03. The generic implication assessment was included as part of the i
engineering evaluation of potential deviations described in Reference 1.
Corrective actions have been established and are described herein.
1 We hereby provide the follow-up response to these Notices of Violation in the attachment to this letter.
l Sincerely, h
William J. Cahill, Jr.
BSD/grp
' Attachment 1
c - Mr. R. D. Martin, Region IV Resident Inspectors CPSES (3) l l
0 400 North Olive Street LB 81 Dallas, Texas 75201
\\
~1
Attachment to TXX-89257 May 12, 1989 Page 1 of 4 Discussion In response to Notice of Violation 445/8912-V-03 and concerns expressed by the NRC in the March 7,1989 exit meeting regarding pipe supports, TV Electric Senior Management directed the performance of a walkdown of reasonably accessible pipe supports by Engineering to identify potential problems.
The results of the walkdown have been evaluated and compiled.
As described in detail below, it is the general conclusion of this evaluation that the CPSES pipe support installation program is effective in assuring that design requirements are properly implemented.
The relatively small number of findings in comparison to the large population of reviewed attributes demonstrates the effectiveness of the pipe support Post Construction Hardware Validation Program (PCHVP).
Plant completion programs, including IEB 79-14 walkdowns, system and area turnovers and commodity clearance walkdowns, when completed, provide additional assurance of quality installations.
RESPONSE TO NOTICES OF VIOLATION (445/8906-V-02 AND 445/8912-V-03) 1.
Reason for the Violation The engineering evaluation of walkdown observations described in our initial response to the above Notices of Violation (NOVs) have been completed.
The evaluation of the walkdown observations shows that the pipe support PCHVP has been effective. The engineering walkdown included approximately 23,000 pipe supports (safety related and non-safety related). The 1,972 observations affecting safety related pipe supports identified during the walkdown are summarized as follows:
1131 observations were determined to be either in compliance with current acceptance criteria, work items in-process, or conditions that had been previously identified with resolution in progress.
841 observations (589 supports) were evaluated and initially determined to be potentially valid discrepant conditions.
These observations have been forwarded for field verification and action, as appropriate, per procedure ECC-9.ll, " Room / Area Completion Wal kdown". While we anticipate that the Construction Engineering actions will find that some of these conditions actually meet applicable requirements, the conditions were assumed to be as described in the observation for purposes of the Engineering evaluation.
The Engineering evaluation identified 27 categories of observations.
The 23 examples of deficiencies identified in NOV 445/8912-V-03, the pipe support deficiencies described in NOV 445/8906-V-02 (i.e., U-bolt pipe clearance and loose jam nut), and the pipe support angular misalignment (swing angle) issue identified in NOV 445/8871-V-03 are included in these categories.
Attachment'to TXX-89257 May 12, 1989 Page 2 of 4 l
l Four groups of causes have been established for the 27 categories as follows:
Group 1 Conditions which, based on the limited number of observations or diversity of likely causes, are considered to have been caused by isolated circumstances.
Examples include warpage, U-bolt pipe clearance and base plate grouting.
Group 1 includes 300 observations in 14 categories.
Group 2 Conditions caused by damage during ongoing construction and maintenance.
Examples are dislodged spherical bearings, loose jam nuts and missing / damaged cotter pins. Group 2 includes 439 observations ir. 5 categories.
Group 3 Conditions caused by insufficient installation and/or inspection 4
criteria.
Examples are pipe clamp parallelism (angular misalignment) and end clearance.
Group 3 includes 102 observations in 6 categories.
Group 4 Observations which were determined to be invalid or not within the scope of the engineering walkdown (i.e., commodity clearance observations).
Group 4 includes 2 categories of observations.
Specific details relating to the number of observations, category description, and root causes are contained in Project Technical Report (PTR)-06 " Engineering Evaluation of Pipe Support Inspection Issues",
included as an attachment to Corrective Action Request (CAR)89-004.
CAR 89-004 is available for your review at the CPSES site.
2.
Corrective Steps Taken and Results Achieved The conditions contained within the four groups will be resolved as follows:
Groups 1 and 2 These conditions will be reworked as required by the disposition of the specific deficiency.
Group 3 These conditions will be reworked as required by the disposition of the specific deficiency. Additionally, Specification 2323-MS-100 will be revised to include criteria for the installation and inspection of the following attributes:
Maximum and minimum distance between the clamp ears.
t V Attachment to TXX-89257
- May 12,'1989
" Page' 3. of 4
' Minimum clearance between the clamp ears and adjacent parts.(welds, 4'
snubber / strut body, etc.), including applicable max./ min. field trim requirements.
Minimum clearance between paddle and. clamp ear / spacer.
Minimum clearance between paddle and rear bracket.
Minimum clearance between bolt (including bolt for transition kit) and clamp.
Implementation of the revised specification criteria will require Quality Control reinspection of installed pipe supports affected by this revision, to verify compliance with these criteria.
Group 4 Valid observations in this group are being addressed by the Field Verification Commodity Clearance Program, CPE-SWEC-FVM-CS-068. Copies of commodity clearance observations have been forwarded to the commodity clearance group for resolution.
3.
Corrective-Steos Taken to Avoid Further Violations Although the results of the Engineering walkdown and evaluation of observations show that the pipe support PCHVP has been effective, the following program enhancements have been or will be implemented to further assure the adequacy of pipe supports.
TO Electric' has established a surveillance program to monitor completed commodities to assure maintenance of completion.
TU Electric has implemented an increased awareness program which includes:
Instructing the appropriate Construction Department personnel to emphasize the general policy memorandum which cautions against damage to installed hardware.
Posting of clearly visible signs highlighting the general policy memorandum in various rooms / areas of the plant.
The QA Department will develop a procedure to provide for QA involvement in the Room / Area turnover programs and in monitoring of 1
commodities to assure they are maintained in an acceptable condition.
ASME QA procedures AQP 11.5, "ASME Component Installation Verification," will be revised to include verification of the completeness of pipe supports within the NIS-2/N-5 boundary prior to finalizing the NIS-2/N-5 ASME Code Certification.
I
' *. Attachment to TXX-89257 May 12, 1989 Page 4 of 4 4.
Date of Full Comoliance The resolution and rework as required for the specific discrepancies identified in NOVs 445/8871-V-03, 445/8906-V-03 and 445/8912-V-03 will be completed by June 16, 1989.
Preinstruction of appropriate Construction Department personnel will be completed by June 1, 1989.
The revision of Specification 2323-MS-100 addressed in item 2 above, will be complete by June 1,1989.
The development and/or revision of QA procedures described in item 3 above will be complete by June 1,1989.
The reinspection and rework (as required) of pipe supports affected l
by the revision to Specification 2323-MS-100 and the resolution of the remaining observations will be completed consistent with the ASME Code Certification (NIS-2/N-5) completion schedule.
i
__ _