TXX-4370, Suppls 840907 Response to Violations Noted in Insp Rept 50-445/84-08.Corrective Actions:Reinsp of Baseplate Shims & Bolt Tightening Committed to in Completed.Answers to Questions Raised in NRC Encl

Suppls 840907 Response to Violations Noted in Insp Rept 50-445/84-08.Corrective Actions:Reinsp of Baseplate Shims & Bolt Tightening Committed to in Completed.Answers to Questions Raised in NRC Encl

ML20135H681
Person / Time
Site:	Comanche Peak
Issue date:	11/28/1984
From:	Clements B TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20135H680	List: ML20135H679 TXX-4370, Suppls 840907 Response to Violations Noted in Insp Rept 50-445/84-08.Corrective Actions:Reinsp of Baseplate Shims & Bolt Tightening Committed to in Completed.Answers to Questions Raised in NRC Encl
References
TXX-4370, NUDOCS 8509240127
Download: ML20135H681 (4)

Text

-

3 [L ' R (R0 W %

NOV 2 91984 TEXAS UTILITIES GENERATING COMPANY

.xvwAr rowsu soo xonru ouve -ruxxv. i..n. ai nu.u .rsus um - #

November 28, 1984 TXX-4370 v.o?.'.?1hE".'."lb.

Mr. D.R. Hunter, Chief Reactor Project Branch 2 U.S. Nuclear Regulatory Commission, Region IV Office of Inspection and Enforcement Parkway Central Plaza Building

-611 Ryan Plaza Drive, Suite 1000 Docket No: 50-445 Arlington, TX 76011 COMANCHE PEAK STEAM ELECTRIC STATION RESPONSE TO NRC LETTER OF NOVEMBER 2, 1984 INSPECTION REPORT NO. 50-445/84-08 FILE N0: 10130

Dear Mr. Hun.ter:

This letter and the enclosure respond to your letter of November 2,1984 relative to the Severity Level IV Violation (445/8408/02), Failure to Perform Inspections of Installation Activities Related to Unit 1, Main Coolant System Crossover Leg Restraints.

Upon further review of this matter, we have determined that the information contained in our letter No. TXX-4294, dated September 7,1984 was incorrect.

We therefore withdraw that portion of our September 7,1984 letter dealing with the crossover leg restraints. The attached information is responsive to your November 2 letter and provides the current status of corrective actions relative to the Notice of Violation. -

In conclusion, I wish the staff to know that I am concerned that our Seritember 7,1984 supplemental response was not totally accurate. To my knowledge, this is the first time that this has occurred. I am taking measures to assure that confusion such as contained in that supplemental response will not recur.

If you have any further questions, please advise.

Very truly yours, Y

8509240127 850917 PDR ADOCK 05000445 G PDR BRC/brd cc: NRC Region IV (0 + 1 copy)

Director, Inspection & Enforcement (15 copies)

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Vincent S. Noonan A DEV1mION OF TEXAN UTELITIEm KLECTNIC COME'ANY

. . knclosure

' TXX-4370 Page 1 Comanche Peak Steam Electric Station Response to NRC Questions Concerning Notice of Violation 445/8408-02 Failure to Perform Inspections of Installation Activities of Unit 1, Main Coolant System Crossover Leg Restraints In our initial response to this Notice of Violation (B.R. Clements to R.L. Bangart, August 23, 1984, TXX-4271) we stated that some QC documentation for the crossover leg restraint installations had been identified .but that it had not been completed to establish the acceptability of the installation under the quality program. At that time we comitted to reinspect the instal-lations and to complete any necessary work.

On September 7, 1984, in TXX-4294, we submitted a supplemental response on this Notice of Violation which indicated that we had determined why the QC ~

inspections for the crossover leg restraints had not been completed. In that response ~we stated that certain construction work had not been completed and therefore that the necessary inspections could not be performed.

In a memorandum dated November 2,1984 from Mr. D.R. Hunter, Chief Reactor Project Branch 2, Nuclear Regulatory Comission, to M.D. Spence, President, Texas Utilities Generating Company, additional questions cealing with our response to this Notice of Violation were raised. Upon further review of the facts underlying the Notice of Violation, our previous responses and your additional questions, we have determined that our September 7, 1984 supplemental response was incorrect. The following information is provided to clarify this issue and to respond to your specific questions.

The Notice of Violation relates to inspection of shiming of the cross-over leg restraints baseplates and torquing (of at their foundations. Forbolts ease securing these of reference restraints we refer to thattowork as " baseplate work.") In our September 7,1984 supplemental response, we confused this baseplate work with other shiming that is to be performed between these restraints and the piping which they are designed to restrain.

(For ease of reference we refer to this work as " piping work.") In that response, we discussed in the same paragraph both the baseplate work and the piping work. For example, the Test Instruction / Procedure Deviation Report No.

12 on the Reactor Coolant System discussed in our response related to- the piping work. We also discussed NCR-M84-100281, which documented the need to conduct inspections of the baseplate work. The discussion of the piping work was not appropriate because the Notice of Violation does not relate to the piping work. We therefore'wish to withdraw our September 7, 1984 response dealing with the crossover leg restraints including our assertion that the Notice of Violation was incorrect.

With regard to the baseplate work, the reinspection of the baseplate shims and bolt tightening comitted to in our August 23, 1984 response have been completed. This closes NCR-M84-100281. With regard to the Staff's - j additional questions, we provide the following responses: .

l 1

L

Ehclosure

' TXX-4370 Page 2 Question 1 What document (i.e., operational traveler, etc.) implemented Procedure CP-QCP-3.1 for inspection of the crossover leg restraint?

Response

The inspection checklists which were attached to NCR-M84-100281 were the documents that implemented CP-QCP-3.1.

Question 2 How was the intentional postponement of the required inspection documented?

Response

The activity discussed in our September 7 response that was intentionally postponed was the shimming on the top of-the crossover leg restraint, related to piping work. Accordingly, as noted above, we withdraw that discussion as not relevant to the Notice of Violation.

Question 3 Was the individual that signed the QC inspection checklist for the crossover leg restraints (attached to NRC M84-100281) certified to make these in-spections at the time the inspections were made?

Response

No. The individual who signed the inspection checklists in question was certified Level 11 for visual examination on January 28,-1978 in accordance with Brown & Root Incorporated Personnel Training Manual. He was not, however, certified to perform the full scope of the inspections covered by the checklists until September,- 1978. Considering the individual's inspection background, there should be no question relative to his qualifications for performing all of the inspections.

Question 4 Why were the required inspections. related to positioning, leveling and bolt torquing of the floor mounted crossover leg restraint postponed, since the gap measurements to determine shim requirements taken during hot functional testing would be based on the permanent location of this restraint?

~: . -

. E' ' Enclosure-

' ' iTXX 4370-Page 3-

~ Response As noted above, the statement in our September 7 1984 supplemental response confused _ piping-related shims on top of the crossover leg restraints with a shiming attribute on a - checklist used to install the Crossover -Leg Restraints. The shiming attribute on the checklist was provided in case baseplate . leveling shims were used. There would be no reason to await hot functional testing before perfonning the baseplate work.

.,v w