ML20247G753
| ML20247G753 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/15/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89255, NUDOCS 8905310061 | |
| Download: ML20247G753 (4) | |
Text
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. Log # TXX-89255-
. File # 10130
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IR 89-19 Ref 10CFR2.201 MIELECTR/C WHHam J. Cahm, Jr.
Executive Vice President U. S. Nuclear Regulatory Commission Attn: ' Document Control Desk Washington, D; C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT N05. 50-445/89-19 and 50-446/89-19 Gentlemen:
TV Electric has reviewed your letter dated-April 14, 1989, concerning the inspection conducted by Mr. M. Runyan and NRC consultants during the. period March 8 through April 4, 1989.
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 i'n the attachment to this
.,l e t te r.
Sincerely,_
William J. Cahill, Jr.
BSD/bsd Attachment j
1 c - Mr. R. D. Martin, Region IV
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Resident Inspectors CPSES (3)
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i 8905310061 890515 PDR ADOCK 05000445 l
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400 North Olive Street LBBI Dallas, Texas 75201
' LAttachment to TXX-89255
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" May 15,1989 Page 1 of 3.
f NOTICE OF VIOLATION ITEM 445/8919-V-01; 446/8919-V-01 Criterion II of Appendix B to 10 CFR Part 50, as implemented by Section 2.0, Revision 0, of the TV Electric Quality Assurance Manual. requires that the quality assurance program "take into account the need for special controls, processes, test equipment, tools, and skills to attain the required quality, and the need for verification of. quality by inspection and test.
The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained."
Contrary to the above, Quality Control inspectors were not equipped nor trained to measure the following inspection attributes to the tolerance required by the Post-Construction Hardware Validation Program:
- 1. Valve stem orientation is required by Procedure AQP-11.5, "ASME Component Installation Verification," (referenced by CPE-SWEC-EE/ME/IC/CS-090) to be 3
measured within + 5 degrees.
This requirement is based on the principle that the precision of measurement must at least be equal to the tolerance defined by the acceptance criteria. QC valve stem orientation measurement methods demonstrated to the NRC were not correct.
For example, in three specific cases valve stem orientation measurements taken by QC were out-of-tolerance while those taken by an engineering survey crew were acceptable (i.e., one example: QC 340; survey crew 51.30; and drawing 510).
- 2. The linear. distance either side of the low elev cion coupling of the incore instrument tubing to the first developed arc is required by Procedure AQP-11.5 to be measured to within + 2 inches.
The use of a straightedge and 0.01-inch feeler gauge as was Demonstrated by QC to the NRC introduced a minimum tangential error of 1.7 inches with respect to the 12-foot (nominal) radius arc.
The tangential error is increased by a flattening of the arc near the tangent point.
Seven measurements taken by the NRC inspector differed from those recorded by the QC inspector by more than the allowed + 2 inches. As indicated by these errors, the failure by QC to measure the tangential point of the tubing arc correctly has introduced an
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automatic error into measurement accuracy.
RESPONSE TO NOTICE OF VIOLATION ITEM 445/8919-V-01; 446/8919-V-01 We agree with the violation and the requested information follows.
- 1. Reason for the Violation The examples of incorrect Quality Control Inspector (QCI) measurement methods identified by the NRC inspector resulted from the failure by
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' Attachment to TXX-89255 May 15, 1989 Page 2 of 3
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the QCI's to apply their knowledge and training properly, which we believe
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to be isolated instances for the reasons noted below.
As noted by the NRC inspector in section 2.g of inspection report 50-445/89-19, the 79-14 as-built verification program includes measurement of safety-related valve angles by engineering (survey.
Deficiencies identified as a result of this as-built verification i.e., measured dimensions which exceed design tolerances), are documented on nonconformance reports (NCR's). A review of the NCR's initiated as a result of the 79-14 verification revealed that of the approximately 3600 valves thus far remeasured in the 79-14 verification program, greater than 97 percent did not exceed the,+ 5 degree tolerance for valve angle.
A significant portion of the less than three percent that did exhibit valve angle discrepancies are apparently attributable to causes other than QCI measurement or measurement methods (e.g., misinterpretation of design drawings).
None of the NCRs pertaining to valve angle discrepancies attributable to QCI measurement or measurement method identified by 79-14 verification required rework.
While we agree that the method of valve angle measurement demonstrated by the QCI as described in example 1 would not produce accurate results, measurement methods predominantly utilized by 0CIs in the performance of valve angle measurements for PCHVP inspections have been accurate.
The verification of dimensions to the tangent of a radius is required at CPSES only with respect to the incore instrument tubing. These dimensions were measured during PCHVP inspection by one QCI.
The QCl failed to recognize that the unusual design requirements for that installation rendered inapplicable the usual techniques for measuring pipe bend radius.
- 2. Corrective Steps Taken and Results Achieved Valve angles which may have been changed by rework to apply seal welds subsequent to 79-14 as-built verification have been reinspected by Quality Engineers using the triangulation method to verify valve angle.
No additional out of tolerance valve angles were identified.
Valve ICC-692 was documented on NCR 89-2564 as described in the details related to unresolved item 445/8911-U-01. NCR 89-2564 has been dispositioned "use-as-is".
I Regarding the incore instrument tubing measurement error, NCR 89-1095 has been revised to include in the description of nonconformance that the QCl measurement method introduced an error of 1.7 inches. While a final disposition has not been determined for this NCR, a preliminary review indicates that this measurement error does not affect the ability of the instrument tubing to perform its intended functions.
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' Atta'chment'to TXX-89255 l
May 15, 1989 Page 3 of 3 Lr
- 3. Corrective Steps Taken to Avoid Further Violations QCI's responsible for valve angle measurements have been directed to measure valve angle using the method referred to as triangulation.
This method has been shown to produce results within the required degree of accuracy. QCI's have received training to re-emphasize the correct method of performing valve angle measurements using the triangulation method.
In addition, QCI's including the individuals who performed the inspections described in items 1 and 2 of this violation, have been briefed on the issues that resulted in this violation.
- 4. Date of Full Compliance Full compliance will be achieved upon disposition of NCR 89-1095 which will be completed by May 26, 1989.
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