TXX-4727, Responds to NRC Re Violations Noted in Insp Repts 50-445/85-07 & 50-446/85-05.Corrective Actions:Specific Finding Accomplished for Facility Per Startup Work Permits Z-2912 & Z-2914 in Dec 1984

Responds to NRC Re Violations Noted in Insp Repts 50-445/85-07 & 50-446/85-05.Corrective Actions:Specific Finding Accomplished for Facility Per Startup Work Permits Z-2912 & Z-2914 in Dec 1984

ML20211A093
Person / Time
Site:	Comanche Peak
Issue date:	04/02/1986
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20210U608	List: ML20210U604 TXX-4727, Responds to NRC Re Violations Noted in Insp Repts 50-445/85-07 & 50-446/85-05.Corrective Actions:Specific Finding Accomplished for Facility Per Startup Work Permits Z-2912 & Z-2914 in Dec 1984
References
FOIA-86-192, FOIA-86-A-54 TXX-4727, NUDOCS 8610100774
Download: ML20211A093 (9)

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'fi Log # TXX-4727 File # 10130 IR 85-07

, TEXAS UTILITIES GENERATING COMPANY 85-05 BKYWAY TOWER

• 400 NORTH OLIVE WTREET. L.B. A t e DALLAS. TEXAS 78301 April 2, 1986

.TP4"A*?.f.7.TA Mr. Eric H. Johnson, Director Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NOS.: 50-445/85-07 AND 50-446/85-05

Dear Mr. Johnson:

We have reviewed your letter dated February 3, 1986, concerning the inspec-tion conducted by Messrs. J. E. Cummins, H. S. Phillips, and others during the period April 1, 1985, through June 21, 1985. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2.

We requested and received a two week extension in providing our response during a telephone discussion on March 6, 1986. We requested and received a second two week extension on March 19, 1986.

We have responded to the Notice of Violation in the attachments to this letter. We have attached the Notice of Violation to aid in understanding our response.

Very truly yours, W. G. Counsil JWA/ arm Attachments c- Region IV (Original + 1 copy)

Director, Inspection and Enforcement (15 copies)

U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. V. S. Noonen Mr. D. L. Kelley kjo2co connggil*essoo, -

4-54 PDR A DEVES10N OF TEXAS EITILETTES ELECTRIC COMPANY l A-I l

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APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Docket: 50-445/85-07 Comanche Peak Steam Electric Station 50-446/85-05 Units 1 and 2 Permit: CPPR-126 CPPR-127 During an NRC inspection conducted on April 1 through June 21, 1985, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are listed below:

1. Failure to Promptly Correct an Identified Problem with RTE - Delta Potential Transformer Tiltout Subassemblies 10 CFR 50, Appendix B, Criterion XVI, as implemented by Texas Utilities Generating Company. (TUGCO) Quality Assurance Plan (QAP), Section 16.0, Revision 0, requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficien-cies deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, a potential problem with RTE - Delta potential transformer tiltout subassemblies, which are used in the emergency diesel

generator control panels, was identified to the applicant via a letter, dated June 15, 1983, from Transamerica Delaval Inc. This letter also provided instructions for correcting the potential problem. However, the i applicant did not take the corrective action. The NRC initially reported j this item as unresolved in NRC Inspection Report 50-445/84-40.

This is a Severity Level IV violation. (Supplement II.E) (445/8507-01 446/8505-01).

2. Failure To Follow Procedures 10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 QAP, Section ,5.0, Revision 2 requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accor-dance with these instructions, procedures, or drawings.

a. Drawing 2323-51-0550, Revision 4, Section 6-6 specified the use of Class E" concrete for the Unit I reactor coolant pump and steam generator supports.

Contrary to the above, comercial nonshrink grout was used to grout the Unit i reactor coolant pump and steam generator supports in lieu

.of Class "E" concrete. (445/8507-02)

This is a Severity Level V violation (Supplement II.E).

b. Brown and Root Procedure QI-QAP-7.2-8, " Receiving of Westinghouse Safety Related Equipment," Section 3.1.d.1, requires a QC inspector to verify that the Westinghouse Quality Release (QR) document checklist items be filled out completely and accurately.

' Contrary to the above, the voltage recorded on Westinghouse QR.41424 checklist, attachment 1, step 4.1, was outside the specified tolerance, but the QC receipt inspector accepted QR as satisfactory.

(445/8507-03)

This is a Severity Level IV violation.

c. Brown & Root Procedure 35-1195-CCP-10. Revision 5, dated December 4, 1978, requires that central and truck mixer blades be checked quarterly to assure that mixer blade wear does not exceed a loss of 10% of original blade height.

Contrary to the above, on May 31, 1985, the NRC inspector determined that there was no objective evidence (records) that the mixing blades had been inspected quarterly since the trucks were placed in service in 1977. (445/8507-04;446/8505-02)

This is a Severity Level V violation (Supplement II.E)

d. Brown & ~ Root Procedure CP-QAP-15.1, " Field Control of Nonconforming Item. " states that nonconforming conditions shall be documented in a Deficiency and Disposition Report (DDR). Procedure CP-QCP-1.3, " Tool Equipment Calibration and Control," dated July 14, 1975, states that out-of-calibration equipment shall be identified on a DDR.

Contrary to the above, on May 31, 1985, the NRC inspector reviewed the calibration file for scale (MTE 779) used for weighing cement and found that a 24-48 pound deviation from the required accuracy was encountered with the water and cement scales during a 1975 calibration

1. of the backup plant scales, however, no DDR was issued to identify this condition an'd require disposition of the scale and concrete (if any) produced. (445/8507-06; 446/8505-04).

This is a Severity Level IV violation (Supplement II.E).

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Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violations if admitted, the corrective steps which have been taken and the results achieved, the corrective steps which will be taken to avoid further violations, and the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

Dated at Arlington, Texas, this 3rd day of February,1986 h

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Response to Notice of Violation Item 1 (445/8507-01 and 446/8505-01)-

1. Reason for Violation:

The violation relates to a Part 21 notice provided by a CPSES diesel generator subtier supplier (RTE-Delta) in June 1983. The violation is the result of two unrelated administrative oversights in handling the Part 21 notice. ,

The initial oversight involved overlooking necessary corrective' actions when a "potentially" reportable deficiency was cancelled dealing with the subject Part 21 notice. .The second administrative oversight involved omission of the issue when a program was conducted in mid 1984

to assure corrective actions-were accomplished for prior Part 21 issues.

2. . Corrective Steps Taken and Results Achieved:

Action for the specific finding was accomplished for Unit 1 per startup-work permits Z-291E and Z-2914 in December 1984. Unit 2 activities

were identified by master Data Base Item 3003-31 (issued January 1985)

'and completed in August of 1985. These actions were initiated in i response to an NRC open item (445/8440-02).'

3.. Corrective Steps to Avoid Recurrence:

In response to an earlier NRC open item (445/8407-01), programmatic measures were established in mid 1984 to positively control corrective actions related to Part 21 issues. These measures included a review of prior Part 21 issues and required the handling of future Part 21 notices as "potentially" reportable deficiencies pursuant to I 10CFR50.55(e). Programmatic controls for these issues are currently governed by TUGC0 Corporate Procedure NE0-CS-1, " Evaluation of and Reporting of Items / Events under 10CFR21 and 10CFR50.55(e)."

The oversight of the specific (RTE-Delta) Part 21 notice during the mid 1984 review is considered to be isolated. The failure to recognize l this issue was the result of the same identifier being assigned to two 4 different items. This was the subject of a previous violation (445/8440-01). No other instance of a similar nature was identified during our review of the earlier violation.

L 4. Date When in Full Compliance:

Programmatic measures were established in mid 1984 to positively control corrective actions related to Part 21 issues. All of the spe--

cific findings related to the RTE-Delta Part 21 notice were corrected in August 1985.

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s Response to Notice of Violation Item 2(a) (445/8507-02) 9

1. Reason for Violation:

The violation is the result of a failure on the part of personnel pre-paring work control documents to properly recognize the hierarchy of design documents. Specifically, when design and vendor installation documents differ, the design document establishes precedent.

Although consistent with the requirements of the vendor drawing (W Drawing 1457F29), the use of non-shrink commercial grout was contrary to the requirements of the design drawing (2323-S1-0550). The design drawing specified the use of class "E" concrete. The use of grout as an acceptable design alternative should have been properly documented by design change prior to the placement.

2. Corrective Steps Taken and Results Achieved:

Based upon a review of the grout card (No. 186 issued November 1981) and the results of the compressive strength test for the grout used in this application, a design change (DCA-21, 179) was issued November 8, 1984, to document acceptance of the installation.

3. Corrective Steps to Avoid Recurrence:

Operational travelers (work control documents) for similar type installations issued during the same time frame as the installation identified in the violation will be reviewed for similar deficiencies.

Results of the review will be completed by April 4, 1986.

Although we believe the specific finding is an isolated case, a project directive will be issued re-emphasizing:

0 the requirements of properly documenting design alternatives prior to initiating construction activities, O the precedence of design vs. vendor documents.

4. Date When in Full Compliance:

Any corrective actions deemed necessary based on the results of the (Item 3) review will be reported by April 15, 1986, to Region IV. The project directive will be issued by April 15, 1986.

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Response to Notice of Violation Item 2(b) (445/8507-03)

1. Reason for Violation:

The out-of-tolerance condition was not detected by receiving inspection when reviewing the data package.

2. Corrective Steps Taken and Results Achieved:

Receiving inspection reports issued in same time frame as the receipt of the equipment in question, were reviewed for similar oversight. No deficiencies were noted. Westinghouse QRN-41424 Rev. I was added to receiving inspection report package to identify the change in output values.

3. Corrective Steps to Avoid Recurrence:

Construction receiving inspection personnel were retrained in reviewing receiving inspection documentation packages.

4. Date When in Full Compliance:

February 27, 1986.

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. Response to Notice of Violation Item 2(c) (445/8507-04 and 446/8505-02)

A reply to this notice of violation .is riot required as noted in the NRC Region IV letter of February 3, 1986 (E.H. Johnson to W.G. Counsil) k g l

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. Response to Notice of Violation Item 2(d) (445/8507-06 and 446/8505-04)

1. Reason for Violation:

1 A review of the historical procedures files has indicated that the majority of project procedures controlling safety related work, and programmatic requirements were not issued until or after 7/14/75.

Although project practice at this early stage of construction was to defer safety related work until the appropriate implementing and sup--

port procedures were issued and distributed, the established control was inadequate in this instance.

2. Corrective Steps Taken and Results Achieved:

Concrete pour records were reviewed to determine which category I place-ments were made during the subject calibration interval.

Nonconformance reports (NCR-C-85-101882 R. 1 issued 11/26/85 NCR-C-85-201617 R.1 issued 11/27/85) were initiated to document the two placements made. Engineering dispositioned these NCR's basing the decision on the design cylinder compressive results. These NCR's were closed in December 1985.

3. Corrective Steps to Avoid Recurrence:

The site procedures controlling these activities and the associated programmatic requirements, were issued onsite after the discrepancy identified by the inspector had occurred and prior to the next sche-duled calibration. These procedures provided the necessary controls for handling nonconforming items, implemented a detailed calibration program and required auditing the effectiveness of the established 10CFR50 Appendix B Quality Program requirements; continuing periodic audits by TUGCO, Brown & Root, and third parties have insured accep-table implementation of the controlled measuring and testing equipment calibration program. This appears to be an isolated instance since review of pour cards during this time period did not identify any safety related placements other than those addressed above. Safety related mechanical and electrical activities had not yet commenced.

4. Date When in Full Compliance:

CPSES is currently in full compliance wl h 10CFR50 Appendix B Criterion XII.

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