TXX-6222, Responds to NRC Re Violations & Deviations Noted in Insp Repts 50-445/86-07 & 50-446/86-05.Requests for Extensions for Listed Violations & Deviations Granted,Per 870120,0206 & 13 Telcons.Corrective Actions Encl
| ML20211H881 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/18/1987 |
| From: | Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-6222, NUDOCS 8702260315 | |
| Download: ML20211H881 (33) | |
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= Log # TXX-6222 P9 File # 10130
-.- C IR 86-07
- C 86-05 M1 ELECTRIC Ref. : 10CFR2.201 UIu"lOdN,a.,,, February 18, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION / DEVIATION INSPECTION REPORT NOS. 50-445/86-07 AND 50-446/86-05 Gentlemen:
We have reviewed your letter dated December 22, 1986, concerning the inspection conducted by Mr. I. Barnes and other members of the Region IV Comanche Peak Task Group during the period April 1 through May 31, 1986. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2. Attached to your letter were Notices of Violations and Deviations.
On January 20, 1987, per a telecon with your Mr. I. Barnes, we requested and received an extension to February 6, 1987, with the following exceptions:
445/8607-V-02, V-04, V-20, and V-21 were extended until February 27, 1987.
On February 6, 1987, per a telecon with your Mr. I. Barnes, we requested and received an extension to February 13, 1987, with the following exceptions:
445/8607-V-02, 04, 20, 21, 22, and D-13 were extended until March 6, 1987.
On February 13, 1987, per a telecon with your Mr. I. Barnes, we requested and received an extension to February 20, 1987.
We hereby respond to the Notices of Violations and Deviations in the attachment to this letter.
Very truly yours, thb W. G. Counsil 1
8702260315 870218 PDR ADOCK 05000445 By: - ,
G PDR /-
G. S. Keeley e Manager, Nuclear \l'icensing JCH/mlh c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI -Region IV
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. Attachment to TXX-6222
. . February 18, 1987 Page 1 of 31 NOTICE OF VIOLATION ITEM A (445/8607-V-24)
A. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGCo Quality Assurance Plan (QAP),
requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Paragraph 3.2.3 of TUGCo Procedure CP-QP-17.0, Revision 6, states, in part,
" Corrective Action Reports shall remain open until all of the required corrective action has been completed."
Contrary to the above, CAR-049 was closed before corrective action was completed and more importantly, before the corrective action was clearly defined. CAR-049 was closed on January 16, 1986, on the basis of a memo (CPPA-47,715) dated November 26, 1985, which stated that Unit 2 limit switch terminations would be identified upon issuance of DCA-23,473; however, this Design Change Authorization (DCA), issued on December 4, 1985, had no requirement to identify or correct previously installed limit switch terminations on Unit 2 (445/8607-V-24).
RESPONSE TO ITEM A (445/8607-V-24)
We admit the violation and the requested information follows:
- 1. Reason for Violation During review for closure of CAR-049, the Quality Engineer failed to recognize that installations made~ prior to issuance of the DCA would be affected.
Therefore, the Quality Engineer did not request any additional information addressing those installations.
- 2. Corrective Steos Taken and Results Achieved CAR-049 was reopened as CAR-049, Rev. I to include, in the disposition, limit switches installed in Unit 2 prior to issuance of DCA 23,473.
From the total of forty-eight CARS that had been closed as of May 8, 1986, Quality Engineering randomly selected a sample of ten and performed a review to determine if the root cause identification and the corrective action taken to correct the identified deficiency were adequate to justify closure. This review was completed July 2,1986 and indicated that the justifications for closure were adequate.
- 3. Corrective Steos Which Will Be Taken To Avoid Further Violation Quality Engineering personnel responsible for reviewing CAR dispositions received additional training in the requirements of CP-QP-17.0 " Corrective Action", on June 30, 1986. The current program, effective 12/22/86, requires review by the Manager, QC; Manager, QA; or Manager, Operations, QA, as appropriate prior to CAR closure.
Attachment to TXX-6222 February 18, 1987 Page 2 of 31 -
NOTICE OF VIOLATION RESPONSE TO ITEM A (445/8607-V-24) CONT'D
- 4. Date When Full Comoliance Will Be Achieved CPSES is currently in compliance.
Attachm:nt to TXX-6222 February 18, 1987 Page 3 of 31 NOTICE OF VIOLATION ITEM B (445/8607-V-02)
B. Criterion III of Appendix B to 10 CFR Part 50, as implemented by Section 3.0, Revision 4, dated November 20, 1985, of the TUGCo QAP, states, in part,
" Measures shall be established to assure that applicable regulatory requirements and the design basis . . . are correctly translated into i specifications, drawings, procedures, and instructions. . . . The design control measures shall provide for verifying or checking the adequacy of design, such as . . . by the use of alternate or simplified calculational methods . . . . The design control measures shall be applied to items such as
. . . delineation of acceptance criteria."
Contrary to the above, on September 25, 1985, TUGCo Nuclear Engineering (TNE), ,
in response to Evaluation Research Corporation's Technical Information Request I (TIR) No. TIR-017 dated August 26, 1985, provided design information which delineated the acceptance criteria for base material defects on field fabricated tanks. TNE's method for verifying the adequacy of the design information was by the use of calculations. However, as of May 15, 1996, those calculations were incomplete and unapproved (445/8607-V-02).
RESPONSE TO ITEM B (445/8607-V-02)
This alleged violation is under evaluation. We expect to send a report by March 6, 1987.
Attachment to TXX-6222 February 18, 1987 Page 4 of 31 NOTICE OF VIOLATION ITEM C (445/8607-V-21)
C. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGCo QAP, dated July 31, 1984, requires that activities affecting quality shall be prescribed by and
. accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Paragraph 4.0 of Revision 6 to CPSES Startup Administrative Procedure CP-SAP-13, " Temporary System Modifications," dated December 9, 1985, states, in part,
" Temporary modification tags shall be filled out and placed on all modifications required to be logged and tagged. . . , a Log Sheet shall be filled out . . . , and lifted leads shall be suitably insulated."
Paragraph 4.2.4 of CPSES Station Administrative Manual Procedure STA-602,
" Temporary Modifications," Revision 1, dated March 5, 1986, states, in part, "Each temporary modification will be clearly identified with a Temporary Modification Tag. . . , The tag normally will be hung on the lifted lead . . .
or placed as close to the modification as possible."
Contrary to the above:
- 1. The white conductor of cable EG123389 was found lifted in Unit 1 Termination Cabinet 4 without being tagged, logged, or insulated.
- 2. The black conductor of cable EG106004 was found lifted in Unit 1 Control Room Relay Rack No. 2 without being tagged or logged. This conductor was subsequently reconnected without documentation of the nonconforming condition (445/8607-V-21).
RESPONSE T0 ITEN C (445/8607-V-21)
This alleged violation is under evaluation. We expect to send a report by March 6, 1987.
1 Attachment to TXX-6222 February 18, 1987 Page 5 of 31 1
NOTICE OF VIOLATION ITEM D (445/8607-V-20)
D. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, i Revision 3, of the TUGCo QAP dated July 31, 1984, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Drawing 2462-1005, sheet 1, Revision CP-1, requires that identification be provided adjacent to " components."
Contrary to the above, except for TB-53, -54, -55, the terminal blocks in Unit 1 Control Room Panel CP1-ECPRCR-01 were not identified (445/8607-V-20). ,
i RESPONSE TO ITEM D (445/8607-V-20)
This alleged violation is under evaluation. We expect to send a report by March 6, 1987.
Attachment to TXX-6222 February 18, 1987 Page 6 of 31 NOTICE OF VIOLATION ITEM E (445/8607-V-22)
E. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3 of the TUGCo QAP dated July 31, 1984, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the a
circumstances.
Paragraph 2.1.3 of THE Procedure TNE-DC-7, Revision 16, dated February 14, i 1986, " Preparation and Review of Design Drawings," requires that completed drawings shall be checked for accuracy and compliance. Paragraph 2.1.4 also requires an engineering review for technical accuracy upon completion of the drafting / design check.
Contrary to the above, drawings were not appropriately reviewed / checked for accuracy. The following drafting errors were involved with unsatisfactory items identified during inspections related to ISAP I.a.4:
l 1. Drawing 2323-El-0172, sheet 17, identified cable EG120248 as EG20248,
- 2. The white conductors of cables EG109964, EG109975, EG109963, and EG109764 were not shown on Drawing 2323-El-0156, Revision CP-1.
- 3. Drawing 2323-El-0156, Revision CP-7, shows the green conductor of cable EG118347 landed at terminal TCA-5; the conductor actually installed is white with a black stripe. This drawing also showed the orange conductor of cable EG130012 landed at terminal TCA-7; the conductor physically installed was black from cable EG118347A. There was no " cloud" on the drawing to indicate that this was a design change.
- 4. Drawing 2323-El-0172, sheet 17, Revision CP-4, did not identify the color of the conductor to be landed at TB2-31 (445/8607-V-22).
. RESPONSE TO ITEM E (445/8607-V-22)
This alleged violation is under evaluation. We expect to send a report by March l 6, 1987, i
l l
l-
Attachment to TXX-6222 February 18, 1987 Page 7 of 31 NOTICE OF VIOLATION ITEM F (445/8607-V-04)
I. Criterion III of Appendix B to 10 CFR Part 50, as implemented by Section 3.0, Revision 4, dated November 20, 1985, of the TUGCo QAP, states, in part, ". . .
Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and approved by the organization that performed the original design. . . . "
Contrary to the above, field design changes, pertaining to the installation of stainless steel shims between the reactor coolant system crossover leg piping and saddle blocks, were not submitted to the organization that performed the original design for review and approval. In addition, the traveler which was used to implement the design change did not document all of the changes that occurred (445/8607-V-04).
RESPONSE TO ITEM F (445/8607-V-04)
This alleged violation is under evaluation. We expect to send a report by March 6, 1987.
Attachment to TXX-6222
! . February 18, 1987 Page 8 of 31 NOTICE OF DEVIATION ITEM A (445/8607-D-07)
A. Paragraph 2.0 of Procedure ERC-QA-01, " Preparation, Maintenance and Control of E&ESD Quality Assurance Manual," Revision 0, states, "This procedure applies to the preparation, distribution, maintenance, and control of the E&ESD Quality Assurance Manual." Further, paragraph 5.1 states that, "The E&ESD Quality Assurance Department shall prepare, maintain, and control the Quality Assurance Manual."
In deviation from the above, the ERC E&ESD Quality Assurance Manuals have not been maintained and controlled. The following omissions from controlled copies of this manual were identified: Revision 1 of ERC-QA-007, " Corrective Action Request"; and all revisions of ERC-QA-028, " Performance of Overview f
Inspections" (445/8607-D-07),
RESPONSE TO ITEM A (445/8607-D-07)
, We admit the deviation and the requested information follows:
- accomplished by two entities
- 1) The ERC Corporate QA Program and Procedures Manual was issued by an offsite ERC QA activity and distribution was limited to four (4) CPRT Review Team Personnel. proper updating of these manuals had not been performed due to oversight by ERC.
- 2) Even though there was a problem with the ERC E&ESD Quality Assurance Manual, the QA/QC Review Team Management Plan and Procedures Manual which includes the requirements of the ERC Corporate QA Program was issued by the QA/QC Review Team Records Office (onsite) to a total of forty-four (44) personnel. Appropriate i groups required to make use of the applicable procedures did in fact have them
) available.
I 2. Corrective Steos Taken And Results Achieved The four ERC Corporate QA Program and Procedures Manuals have been recalled. A review of the distribution of the QA/QC Review Team Management Plan and Procedures Manual resulted in the recall of controlled copies and the reissuance of eleven 1 (11) controlled copies.
l Even though ERC-QA-007, Revision 1, was not in some controlled copies of the ERC E&ESD Quality Assurance Manual, it was present in the manual of the on-site QA
, Group. This procedure prescribes the issuance, control, review, followup, maintenance, and status reporting of CARS, which is the direct responsibility of the on-site QA Group.
f 4
Attachment to TXX-6222 February 18, 1987 Page 9 of 31 NOTICE OF DEVIATION RESPONSE TO ITEM A (445/8607-D-07) CONT'D Additionally, ERC-QA-28 is used to direct the selection, preparation, and review of Overview Inspection (01) Packages and assign packages to inspectors. ERC-QA-28 provides a format to document 01 results, identify, obtain, and close out required I corrective actions, and generally administer the 01 activity. This procedure has been revised four (4) times since the initial issue (1/17/86). Each revision was discussed in detail with the Overview Inspectors in a formal documented training session after each procedure revision. Therefore, improper work would not have resulted from this procedure.
- 3. Corrective Steps Which Will Be Taken To Avoid Further Deviation All controlled copies of the QA/QC Review Team Management Plan and Procedures Manual, currently distributed, have been verified to the August 28, 1986, Table of Contents t,y the ERC on-site QA Group.
Future changes to the QA/QC Review Team Management Plan and Procedures Manual will be distributed by the on-site QA/QC Records Administrator.
- 4. IhLti When Full Comoliance Will Be Achieved TV Electric achieved compliance on August 28, 1986.
Attachment to TXX-6222 February 18, 1987 Page 10 of 31 NOTICE OF DEVIATION ITEM B f445/8607-D-05)
- 8.Section III, paragraph K of the CPRT Program Plan states, in part, "The CPRT SRT is committed to assuring the quality of CPRT Program activities and results. The SRT's commitment to quality is manifested 'in the CPRT Program principals and the CPRT Third-Party Quality Assurance Program described in Appendix G."
A further expression of this commitment is found in the Counsil to Noonan letter dated February 28, 1986, that states, in part, "To support the Senior Review Team in fulfilling its responsibilities, the Overview Quality Team (0QT) has been established In deviation from the above, the following weaknesses have been identified that collectively indicate lapses by the Senior Review Team (SRT) in assuring the quality of the CPRT Program activities.
- 1. Appendix G to the CPRT Program Plan states that a series of Policies and Guidelines had been developed; however, these Policies and Guidelines (six in all) exist only in draft, are dated February 28, 1985, have no apparent control, but appear to be issued for use by CPRT personnel.
- 2. Attachment 1 of Appendix G to the CPRT Program Plan describes how and where QA elements applicable to the Issue Specific Action Plans are addressed.
For the QA element of " Instructions, Procedures, and Drawings," the appropriate guidance is stated as being in Section 5.3 of " General Policy for Conduct of Action Plans," one of the six draft CPRT Policies and Guidelines; however, Section 5.3 only addresses inspections, examinations, and tests and the QA element for instructions, procedures, and drawings is not addressed in the identified policy guide.
- 3. The charter and objectives of the 00T is documented in the " Overview Quality Team Program for Comanche Peak Response Team Activities," dated February 20, 1986. This document is intended to support the SRT in fulfilling its responsibilities; however, there is no evidence of SRT review and approval of the current version or the preceding version (January 1926) of the 0QT program. Further, the currently documented 00T program is not as comprehensive as the one described in the Counsil to Noonan letter dated August 16, 1985. See also Notice of Deviation, Item C, pertaining to the 0QT (445/8607-D 05).
RESPONSE TO ITEM B (445/8607-D-05)
We admit the deviation and the requested information follows:
ITEM B.1
- 1. Reason for Deviation Prior to May 30, 1986, Policies and Guidelines (PAGs) were formally approved by the SRT; but they were not formally issued in a controlled fashion. The determination of not formally issuing PAGs was made by the SRT in the formative stages of the CPRT effort.
, Attachment to TXX-6222 February 18, 1987 Page 11 of 31 NOTICE OF DEVIATION !
RESPONSE TO ITEM B (445/8607-D-05) CONT'D ITEM B.1 (Cont'd)
- 2. Corrective Steos Taken And Results Achieved When the NRC made CPRT aware of this concern, Policy and Guideline, PAG-10,
" Policy for Issue and Control of Policy and Guideline Documents" was prepared and subsequently approved by SRT on May 22, 1986. The PAGs were subsequently formally reviewed and approved by SRT and issued under controlled distribution on May 30, 1986.
1
- 3. Corrective Steos Which Will Be Taken To Avoid Further Deviation As stated in item 2 above, all PAGs have been formally reviewed and distributed in a controlled manner.
I This deviation had no adverse impact on work completed by CPRT and SRT in particular during the period before May 30, 1986. The reason for this is the fact that activities associated with ISAPs require a files reverification per Attachment 4 of Appendix G which audits compliance with the Program Plan, PAGs, ;
and the ISAP. This reverification is performed prior to the ISAP Results Report I
being submitted to the SRT for review and approval. Furthermore, the SRT reviews l and approves ISAP Results Reports. During this review the SRT assures themselves through questioning of the Review Team Leader and/or Issue Coordinator that the i frogram Plan, ISAP, and PAG requirements have been satisfied.
- 4. Date When Full Como11ance Will Be Achieved i
TV Electric achieved compliance on May 30, 1986.
i ,
i ITEM B.2 i
- 1. Reason For Deviation l
, An error occurred in the correlation of the eighteen Appendix B critoria to PAGs
- or CPRT Program requirements when Appendix G was prepared. The guidance for QA l clement " Instructions, Procedures, and Drawings" in Appendix G should have been:
! "CPRT Program Plan, CPRT Policies and Guidelines, and each ISAP".
i 2. Corrective Steos Taken And Results Achieved l
l Appendix G was revised to resolve these concerns. This revision has been approved L l
by the SRT. ,
, i 1 3. Corrective Steos Which Will Be Taken To Avoid Further Deviation None required.
, Attachment to TXX-6222 February 18, 1987 Page 12 of 31 NOTICE OF DEVIATION
,. RESPONSE TO ITEM B (445/8607-D-051 CONT'D l
ITEM B.2 (Cont'd)
- 4. Date When Full Compliance Will Be Achieved
! The revised Appendix G is scheduled to be issued by July 31, 1987.
ITEM B.3
- l. Reason for Deviation The intent of the Executive Vice President when he established the Overview Quality Team (00T) was for the 00T to provide assurance that the quality assurance programs governing the CPRT Quality of Construction and Design Adequacy efforts
! were being properly implemented. However, the August 16, 1985, letter from the
- Executive Vice President to the NRC and the original 0QT program document developed subsequent to that letter described a more comprehensive 0QT program than originally intended.
I Although not documented, the Chairman of the SRT was involved in the development
. of the 0QT program document dated February 20, 1986, and had approved it at the 1
time of the NRC inspection.
- 2. Corrective Stoos Taken And Results Achieved Action was initiated in October 1985 at the direction of the Executive Vice 4
President to bring the OQT program document in line with his original intent for the 00T. Followup letters to the NRC were submitted by the Executive Vice President on February 28 and July 23, 1986, clarifying the role of the 00T. The
, revised 0QT program document submitted with the July 23, 1986 letter is consistent with the original intent for the OQT and was approved prior to submittal by the CPRT SRT.
- 3. Corrective Steos Which Will De Taken To Avoid Further Deviation
! Prior to implementation of any future revisions of the 0QT program document dated
! July 23, 1986, they will be approved by the SRT and will only be implemented without prior NRC notification if they do not conflict with SSER 13 and the February 28 and July 23, 1986 letters to the NRC.
- 4. Date When Full Comoliance Will Be Achieved l
l TV Electric achieved compliance on July 23, 1986.
Attachment to TXX-6222 February 18, 1987 Pag] 13 of 31 NOTICE OF DEVIATION ITEM C (445/8607-D-06)
C. Appendix G of the CPRT Program Plan states, in part, "The measures contained herein are based upon the relevant criteria and principals contained in 10 CFR Part 50, Appendix 8."
Criterion XVIII of 10 CFR Part 50, Appendix B, states, in part, "A comprehensive system of planned and periodic audits shall be carried cut to verify compliance with all aspects of the quality assurance program. . .
audits shall be performed in accordance with the written procedures or check lists . . . Follow-up action, including reaudit of deficient areas, shall be taken . . " The 0QT appears to be the principal group established to implement this criterion in whole or part relative to the overall CPRT effort.
In deviation from the above, the currently documented 0QT program: (1) lacks a system of planned activities related to 0QT audits and reviews and has no clear review and audit responsibility portaining to all aspects of CPRT activities; (2) has no definitive procedure (s) describing the responsibilities and authority of the 00T; and (3) has no procedural controls for the 0QT or SRT that require the timely followup and resolution of identified deficiencies (445/8607-D 06).
RESPONSE TO ITEM C (445/8607-D-06)
We admit the deviation and the requested information follows:
- 1. Reason for Deviation The 00T program document dated February 20, 1986, that existed at the time of the inspection was not as definitive as it could have been in describing such things as 0QT overview activities, schedules, and followup actions to resolve open items.
- 2. Corrective Steos Taken And Results Achieved The 0QT program document was revised July 23, 1986 to make it more definitive. As described in Item 3 of the July 23, 1986, letter transmitting the 00T program document to the NRC, we believe controls exist to assure timely followup and resolution of matters identified by the 0QT. Item 2 of that letter describes actions taken to develop and maintain a master schedule of 00T overview activities.
- 3. Corrective Steos Which Will Be Taken To Avoid Further Deviation Prior to implementation of any future revisions of the 00T program document dated July 23, 1986, they will be approved by the SRT and will only be implemented without prior NRC notification if they do not conflict with SSER 13 and the February 28 and July 23, 1986 letters to the NRC.
- 4. Date When Full Comoliance Will Be Achieved TV Electric achieved compliance on July 23, 1986.
- Attachment to TXX-6222 February 18, 1987 Paga 14 of 31 NOTICE OF DEVIATION ITEM D (445/8607-08)
D. Section 5.5.1 of Procedure ERC-QA-18, Revision 0, " Administration of Quality Assurance Auditing," states, "The QA Audit administrator logs and tracks findings of deviation resulting from audits. Follow-up actions include:
5.5.1.1 Maintenance of an Audit Status Log to reflect the current status of each audit. See Attachment 6.5.
5.5.1.2 Maintenance of an Audit Action Request (AAR) status log showing the current status of each AAR that has been issued.
In deviation from the above, the Audit Status Log did not contain the audit closure date for audit ERC 85 03 even though the findings and audit were closed on March 21, 1986, as documented in a letter from the audit team leader to the QA/QC Review Team Leader. Further, neither the current status nor the audit findings for audit reports ERC 86-01 and 86-02 have been maintained in the AAR Log (445/8607-0 08).
RESPONSE TO ITEM D (445/8607-08)
We admit the deviation and the requested information follows:
- 1. Reason for Deviation At the time of the NRC inspection, the Audit Status Log and the AAR log had just been shipped and received at CPSES and had not been updated. These logs had been kept at the ERC Oak Ridge, TN office. However, this office was closed and the aforementioned logs were shipped for interim storage to the ERC office in Washington, D.C. Therefore, due to the transfeir of these logs from one office to another the appropriate updating did not occur.
- 2. Corrective Steos Taken And Resnits Ach*qysd An ERC individual has been assignad the responsibility to maintain these subject logs and the logs have been updated accordingly.
- 3. Corrective Steos Which Will Be Taken To Avoid Further Deviation An individual has been assigned the full time audit responsibilities for ERC and the logs are the individual's responsibility.
- 4. Date When Full Comoliance Will Be Achieved TV Electric achieved compliance on May 30, 1986.
Attachment to TXX-6222 February 18, 1987 Page 15 of 31 NOTICE OF DEVIATION ITEM E (445/8607-D-01)
E. Section 16.0, Revision 0, of the TUGCo's Quality Assurance Plan states, in part, "In the case of significant conditions adverse to the quality, which are reportable to NRC under the provisions of 10 CFR Part 50.55(e), measures are taken to assure that the cause of the condition is determined and corrective action is implemented. . . ."
TUGCo letter TXX-3657 dated April 21, 1983, submitted to NRC in accordance with 10 CFR 50.55(e), identified a significant condition adverse to quality (no objective evidence is available documenting acceptable weld quality on seismic arrestor brackets) and stated that the corrective actions would be to discard and replace the arrestor brackets, and that the corrective action would proceed immediately.
In deviation from the above, the committed correction actions had not been implemented as of the end of this inspection period (445/8607-D-01).
RESPONSE TO ITEM E (445/8607-0-01)
We admit the deviation and the requested information follows:
- 1. Reason for Deviation Subsequent to issuance of TV Electric letter TXX-3657, the NCRs documenting bracket welding deficiencies were revised and dispositioned "use as is." Since the brackets were judged to be outside the ASME N 5 certifled boundary, the revised NCR disposition is technically correct. However, tne NCR form then in use per Construction Procedure CP-QAP-16.1, Rev.17, " Control of Ncnconforming Items",
did not contain provisions to indicate whether or not the "non-conforming condition" had been judged to be reportable per 10CFR50.55(e) or 10CFR21.
Consequently, the engineer who specified the "use as is" disposition on the revised NCRs was not aware that the "non-conforming condition" had been reported to the NRC and that TU Electric had committed to replacing the subject brackets.
- 2. Corrective Steos Taken And Results Achieved Since the welding on the subject brackets has been determined to be acceptable, no corrective action on the existing installations is required. TU Electric has initiated action to supplement letter TXX-3657 to document why the lack of welding documentation does not constitute a significant condition adverse to quality.
Significant Deficiency Analysis Report (SDAR) CP 86 48 was issued, pursuant to 10CFR50.55(c), addressing the conditions described in the Notice of Deviation and other similar discrepancies. In order to address generic concerns, a sample 1 consisting of 300 previously dispositioned NCRs was reviewed to verify the adequacy of the dispositions. The results of this review, which currently include all NCRs dispositioned " void", " repair", or "use-as-is", and further corrective actions are documented in SDAR CP 86 48. t
, Attachment to TXX-6222 February 18, 1987 Page 16 of 31 NOTICE OF DEVIATION RESPONSE TO ITEM E (445/8607-D-01) CONT'D
- 3. Corrective Steos Which Will Be Taken To Avoid Further Deviation Provisions to prevent recurrence of these conditions were implemented by revision to procedure CP-QAP-16.1 (Rev. 25 dated September 12,1985). These provisions consisted of including a block on the NCR form which identified the evaluations conducted pursuant to 10CFR50.55(e). In providing this identification docketed commitments can be considered in subsequent revisions to the NCR.
A. Date When Full Compliance Will Be Achieved The supplement to TU Electric letter TXX-3657 will be issued no later than March 6, 1987.
i l
~
. Attachment to TXX-6222 Febr'sary 18, 1987 Page 17 ef 31 NOTICE OF DEVIATION ITEM F (445/8607-0-03)
F. Section 4 of CPRT Project Procedure CPP-009, Revision 3, states, in part,
" Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instruction . . . ."
Section 5.1.2 of ERC Procedure QI-013, Revision 5, dated February 4, 1986, states, in part, " Verify by review of the ins)ector certification files that each person who signed as a QC inspector on tie Instrument Tubing Manufacturing Record Sheet is certified to QI-QP-11.8-1 or -5, whichever was in effect at the time the record sheet was signed."
In deviation from the above, the ERC inspector failed to identify, during the review for Verification Package R-E-ININ-079, that the QC inspector was not certified to the appropriate procedure when he signed the tubing record sheet for pressure transmitter 1-PT-4520 (445/8607-D 03).
RESPONSE TO ITEM F (445/8607-0-03)
We deny the alleged deviation for the reason that follows:
The QC inspector in question, as identified to ERC by the NRC, was James Williams.
Mr. Williams' certification was contalried in the Permanent Plant Records Vault (PPRV) and he was certified on September 7, 1979, to QI-QP-11.8-lRI.
, Attachment to TXX-6222 February 18, 1987 Page 18 of 31 NOTICE OF DEVIATION ITEM G (445/8607-0-15)
G. Section 4.1.2 of CPRT Issue Specific Action Plan (ISAP) I.a.2, " Inspection Reports on Butt-Splices," states, in part, " Review all drawings and design change documents involving butt-splices of safety related cables in the control room and cable spreading room of Unit 1 to assure that the splices are documented in the design document."
In deviation from the above, CPRT Reviewers failed to review all design change documents as evidenced by the fact that cables A0102707, E0106963, E0ll1093, E0106993 and E0llll79 were found to contain splices which were not shown on the drawings. These splices had been authorized by Design Change Authorization (DCA)-17,762, Revision 2, and inspection reports documented that these splicos were installed. None of these splices were, however, identified by the CPRT reviewers during the review of drawings and design change documents (445/8607 D-15).
RESPONSE TO ITEM G (445/8607 D-15)
We deny the alleged deviation for the reasons that follow:
Cable A0102707 1-CR-13 was deleted by Revision 3 of DCA 17,762.
Cable E0106963 1 CR-13 was deleted by Revision 3 of DCA 17,762.
Cable E0111093 1-CR-13 was deleted by Revision 3 of DCA 17,762.
Cable E0106993 1-CR 13) was deleted by Revision 3 of DCA 17,762.
Cable E0111179 l-CR-13) was deleted by Revision 3 of DCA 17,762.
These fivo (5) cables were authorized to be spliced by DCA 17,762, Revision 1, dated June 17, 1983. However, these 5 cables were all deleted by DCA 17,762, Revision 3, dated June 29, 1983.
Since those cables were not listed to be spliced on the current revision of DCA 17,762 (Revision 5, dated August 11,1983) at the time of the review, there would be no reason for CPRT reviewers to identify them.
Splicos have indeed been found in each of the 5 cables listed ahnvn. The CPRT insacction reports for each of these splices were marked "Unsat" for Activity 5 wit 1 the annotation " Splice not shown on drawing." This is the correct procedure por Quality Instruction (Q1)-002, Revision 4. Further, TU Electric had been apprised of the CPRT findings and issued NCRs E 85 100124S and E-86 105110X to require correction of the drawings, accordingly.
Based on the above discussion, all activities have been acrformed properly by CPRT. Thorofore, a deviation does not exist and no furtier action is necessary.
Note: The Electrical Review Team is evaluating those CPRT findings of splices which were never authorized by design documents and will present its conclusions and any recommended corrective action (s) in the Results Report for ISAP !.a.2.
Attachment to TXX-6222 February 18, 1987 Page 19 of 31 (LOTICE OF DEVIATION ITEM H (445/8607-D-19)
H. Section 4.1.1, " Inspection Program," of CPRT ISAP I.a.4, " Agreement Between Drawings and Field Terminations," Revision 4, dated January 24, 1986, states, in part, "An inspection program employing random sampling will be initiated which will enable a determination to be made with reasonable assurance of whether the essential Class IE conductors in the control room and cable spreading room which interface with the Alternate Shutdown Panel are terminated in accordance with the applicable drawings." Section 4.1.1.2,
" Random Sampling," of this procedure states, in part, " Based on the preliminary determination of a population size of 3812, the minimum sample size according to Appendix D is 300 with a re,jection number of zero (i.e., the critical region is one or more deficiencies found in the sample). If one (1) deficiency is found, a root cause evaluation of the deficiency will be performed, and a sample expansion in accordance with Appendix D will be undertaken."
In deviation from the above, the random sample (approximately 338) inspected in this program included approximately 50 spare conductors which were not terminated nor shown to be terminated on the applicable drawings and, accordingly, could not be considered to be essential Class lE conductors which interface with the Alternate Shutdown Panel (445/8607-D-19).
RESPONSE TO ITEM H (445/8607-t 19)
We deny the alleged deviation for the reasons that follow:
As discussed in the response to the NRC Staff request for additional information (Ref. TXX-4786, dated May 2, 1986), the basis for including spare conductors in the population was as follows:
o Spare conductors could potentially be involved with functional deficiencies (e.g., a spare conductor reversed with a functional conductor, a spare conductor connected to an active circuit, etc.), thus information concerning spares should not be bypassed, o Conductors that were once functional were often converted to spares by design change, and it was considered to be important to check these conductors for adequacy of the design change implementation process, 1
I o The NRC/TRT checked and addressed spares. One of their findings involved saare conductors that had once been functional and (after being spared by design c1ange) were not lifted from their respective terminal points.
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Attachment to TXX-6222 February 18, 1987 Page 20 of 31 NOTICE OF DEVIATION RESPONSE TO ITEM H (445/8607-D-19) CONT'D The concern which gave rise to the SRT decision to perform some additional sampling was a question as to whether " unlanded spares" should have been included as valid members of the population to be sampled (see TXX-4921 dated July 23, 1986). The SRT was and is of the opinion that unlanded spares appropriately belong in a population to be sampled for termination accuracy. Other observers with the staff were of the view that since unlanded spares were not physically terminated (or should not have been) they should not be considered part of the population to be sampled. Rather than carry forward what the SRT viewed as a minor difference of opinion, the SRT directed that the then existing sample be sufficiently expanded to meet the desired statistical size excluding the presence of unlanded spares. An additional 34 functioning (i.e., non-spared) conductors were inspected and the conclusions of the results report were not affected by the additional inspection results. These additional inspections eliminated any question regarding the ISAP requirements (i.e., at least 300 " safe shutdown" conductors).
The Electrical Review Team has reread the ISAP requirements for the remaining eight (8) ISAPs under its cognizance (I.a.1 through I.a.3, I.a.5, and I,b.1 through I,b.4) and assured itself regarding any question that all requirements regarding random sampling have been fully complied with.
Additionally, as part of the CPRT Working File Verification, all ISAP requirements and sampling activities are carefully checked in accordance with PAG-02, Revision
- 2. All future Results Reports will have been screened to this procedure prior to issuance.
, Attachment to TXX-6222 February 18, 1987 Page 21 of 31 NOTICE OF DEVIATION ITEM I.1 (445/8607-D-14)
I. Section 4 in Revision 4 to CPRT Project Procedure CPP-009 states, in part,
" Qualified QA/QC Review Team personnel perform field reinspe:tions of specific hardware items and reviews of appropriate documents in accordance with approved instructions . . . ."
Section 4 in Revision 2 to ERC Quality Assurance Procedure ERC-QA-28, "Performcnce of Overview Inspectio:a," states, in part, " Qualified QA/QC Review Team personnel assigned to the on-site QA Representative perform Overview Inspections of work performed in accordance with Reference 3.1 (CPP-009) . . . ." Section 5.4.2 of ERC-QA-28 states, in part, " Based upon each accept / reject criterion specified in the referenced QI/ effective Change Notice (s), the 0! (Overview Inspector) denotes whether the item is (un) acceptable . . . ." Section 5.4.3 of ERC-QA-28 states, in part, "The O!
compares the results of the Overview Inspection with the results of the initial reinspection / documentation review to identify any apparent inconsistencies . . . ."
In deviation from the above, the following error was identified concerning the results of overview inspections:
- 1. 1. The initial ERC reinspection and the ERC overview inspection of structural steel Verification Package I-S-STEL-146 were not performed in accordance with Revisions 1 and 2 of QI-045, the approved instruction. Attribute B3, Section 5.1.B.3 of QI-045 states, " Verify visually, that the connection is orientated, relative to the member, as specified on the design drawing." This attribute is identical in both Revisions 1 and 2 of QI-045. The initial ERC reinspection was performed using Revision 1 of QI-045 and Attribute 83 was accepted.
Revision 2 of QI-045 was used for the ERC overview inspection and Attribute 83 was again accepted. In addition, ERC Overview Inspection Report 35-006 for this verification package states that " Overview Inspection confirms that the initial reinspection / documentation review is: acceptable . . . ." NRC inspection, however, showed that connecting plate C10-17 was incorrectly oriented with respect to member C9-4; i.e., installed at the base of member C9-4 instead of at the top (445/8607-D-14).
RESPONSE TO ITEM I.1 (445/8607-D-14)
We admit the deviation and the requested information follows:
- 1. Reason for Deviation ERC investigation concluded that the gusset plate is welded to the sample beam at the bottom as indicated in the NRC deviation stated above. The errors made by reinspection and overview inspection were due to the use and interpretation of the term "similar" on drawing 2323-S-0799.
. Attachment to TXX-6222 February 18, 1987 Page 22 of 31 NOTICE OF DEVIATION RESPONSE TO ITEM I.1 (445/8607-D-14) CONT'D
- 2. Corrective Steos Taken And Results Achieved ERC initiated a Technical Information Request (TIR) No. 302 on May 22,1986, requesting a definition of the term "similar" as used on drawing 2323-S-0799.
Gibbs & Hill provided a response on Jene 9, 1986, and again on October 2, 1986, responding to the TIR. As a result of the G&H respor se, ERC initiated a Deviation Report, I-S-STEL-146-DR4, on October 3,1986, to address the identified deviation.
An Out-of-Scope Observation (00S) No. 988 was also prepared to identify that the gusset plate and brace on the opposite side of tha structure have also been located incorrectly. Additionally, TUGC0 has prepared Nonconformance Reports (NCR) M-86-100841SXR1 and M-86-104586X to address this deviation.
- 3. Corrective Steos Which Will Be Taken To Avoid Further Deviation No action to prevent recurrence was initiated since this deviation was determined from a review of the STEL population to be an isolated case. No further discrepancies of this type were found.
- 4. Date When Full Como11ance Will Be Achieved CPRT compliance was achieved on October 3, 1986.
TV Electric compliance will be achieved commensurate with the final disposition of the nonconformance reports which is scheduled for March 2, 1987.
. Attachment to TXX-6222 February 18, 1987 Page 23 of 31 NOTICE OF DEVIATION ITEM I.2 (445/8607-D-10)
I. Section 4 in Revision 4 to CPRT Project Procedure CPP-009 states, in part,
" Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions . . . ."
Section 4 in Revision 2 to ERC Quality Assurance Procedure ERC-QA-28,
" Performance of Overview Inspections," states, in part, " Qualified QA/QC Review Team personnel assigned to the on-site QA Representative perform Overview Inspections of work performed in accordance with Reference 3.1 (CPP-099) . . . ." Section 5.4.2 of ERC-QA-28 states, in part, " Based upon each accept / reject criterion specified in the referenced QI/ effective Change Notice (s), the 01 (0verview Inspector) denotes whether the item is (un) J acceptable . . . ." Section 5.4.3 of ERC-QA-28 states, in part, "The 01 compares the results of the Overview Inspection with the results of the initial reinspection / documentation review to identify any apparent inconsistencies . . . ."
In deviation from the above, the following error was identified concerning the results of overview inspections:
l I. 2. Overview Inspection Package 13-I M-LBC0-148 failed to identify an !
unsatisfactory decision made by the initial ERC inspector. NRC l inspection identified three pipe to pipe clearances which were in violation of Section 5.2.6.2 of QI-025, Revision 3. The initial ERC reinspection as well as the overview inspection failed to identify these deviating conditions (445/8607-D-10).
RESPONSE TO ITEM I.2 (445/8607-D-10) l We admit the deviation and the requested information follows:
- 1. Reason for Deviation Investigation by ERC confirmed the three NRC identified clearance violations and one additional clearance violation. The cause of the deviation is due to inspector error which resulted in the failure to identify the clearance violations. Therefore, a deviation does exist for Overview Verification Package No. 13-I-M-LBC0-148.
- 2. Corrective Steps Taken And Results Achieved Overview Verification Package No. 13-I-M-LBC0-148 was revised on July 10, 1986, to identify the four (4) clearance violations. Deviation Report No. I-M-LBC0-148-DR3 I was initiated on August 22, 1986, to address these clearance violations. In l addition, TU Electric has initiated Nonconformance Report No. M-25340N.
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Attachment to TXX-6222 February 18, 1987 Page 24 of 31 NOTICE OF DEVIATION RESPONSE TO ITEM I.2 (445/8607-D-10) CONT'D
- 3. Corrective Steos Which Will Be Taken To Avoid Further Deviation This finding was discussed and documented with all overview inspectors on June 10, 1986. Additionally, the finding was discussed and documented with the ERC reinspection inspectors on July 10, 1986. The overview inspectors were also instructed to review, in detail, all NCRs in each overview inspection package in the future.
- 4. Date When Full Comoliance Will Be Achieved CPRT compliance was achieved on August 22, 1986.
TV Electric compliance will be achieved commensurate with the final disposition of the nonconformance reports which is scheduled for March 2,1987.
. Attachment to TXX-6222 FCbruary 18, 1987 Pago 25 of 31 NOTICE OF DEVIATION ITEM I.3 (445/8607-D-ll)
- 1. Section 4 in Revision 4 to CPRT Project Procedure CPP-0C1 states, in part,
" Qualified QA/QC Review Team personnel perform field reitspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions . . . ."
Section 4 in Revision 2 to ERC Quality Assurance Procedure ERC-QA-28,
" Performance of Overview Inspections," states, in part, " Qualified QA/QC Review Team personnel assigned to the on-site QA Representative perform Overview Inspections of work performed in accordance with Reference 3.1 (CPP-009) . . . ." Section 5.4.2 of ERC-QA-28 states, in part, " Based upon each accept / reject criterion specified in the referenced QI/ effective Change Notice (s), the 01 (0verview Inspector) denotes whether the item is (un) acceptable . . . ." Section 5.4.3 of ERC-QA-28 states, in part, "The 01 compares the results of the Overview Inspection with the results of the initial reinspection / documentation review to identify any apparent inconsistencies . . . ."
In deviation from the above, the following error was identified concerning the results of overview inspections:
I. 3. Paragraph 5.2.1 in Section 5.0 of QI-037, Revision 0, states, in part,
" Verify that pipe clamp halves are parallel . . . ." In addition, Attachment 6.1 states, in part, ". . . dimensions on the same side of the clamp at points 1, 2, and 3 shall be within 1/16" of each other to be acceptable. Also the clamp shall be not more than 1/16" out of parallel from side to side at points 1, 2, and 3 to be acceptable."
For Verification Package I-S-PS7N-011, Attribute 2 (pipe clamp halves parallel) on the CPRT checklist was rejected by the initial ERC inspector, with measurement differences in excess of 3/16".
The 01 rejected the same attribute, but noted that the measurement differences were in excess of 1/16". The 01, during comparison of his inspection results with those of the initial ERC inspector, failed to identify the inconsistency with respect to the measurement differences.
In addition, NRC inspection revealed that Attribute 2 should not have been rejected, in that an acceptable condition existed, with measurements being within 1/16" of each other (445/8607-D-11).
. Attachment to TXX-6222 F]bruary 18, 1987 -
Page 26 of 31 NOTICE OF DEVIATION RESPONSE TO ITEM I.3 (445/8607-D-lli We admit the deviation and the requested information follows:
- 1. Reason for Deviation ERC performed an independent inspection on May 30, 1986, for Verification Package No. I-S-PS7N-011 and confirmed that a difference of 1/4" existed between the ERC inspector and the Overview Inspectors Sl(l) and S2(1) measurements. It was determined that the ERC inspector had made an error by documenting the "out" side caliper reading for these measurements. However, the overview inspector inadvertently failed to identify that there was an inconsistency between the results of his Overview Inspection and the ERC reinspection.
Attribute 2, Pipe Clamp Halves Parallel, was correctly rejected by the ERC inspector and the OI in that the measurements concluded that this attribute was 1/32" out of the acceptable limit.
- 2. Corrective Steos Taken And Results Achieved An Overview Inspection Report No. 2-010(A) was transmitted to ERC QA/QC Engineering on June 24, 1986, instructing that ERC inspector's values for S1(1) and S2(1) be checked and the necessary corrections made to Verification Package No. I-S-PS7N-Oll.
- 3. Corrective Steps Which Will Be Taken To Avoid Further Deviation Discussion of the aforementioned deviation was held with all Overview Inspectors on June 10, 1986. Emphasis was placed on the comparison of measurements and to question differences when acceptable limits were exceeded for field measurements.
This discussion was documented.
Additionally, ERC performed an independent review of all completed overview and associated reinspection packages to ensure that any inconsistencies identified between the verification packages were appropriately addressed.
- 4. Date When Full Compliance Will Be Achieved TV Electric achieved compliance on August 30, 1986.
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. Attachment to TXX-6222 February 18, 1987 Page 27 of 31 NOTICE OF DEVIATION ITEM I.4 (445/8607-D-12)
I. Section 4 in Revision 4 to CPRT Project Procedure CPP-009 states, in part,
" Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions . . . ."
Section 4 in Revision 2 to ERC Quality Assurance Procedure ERC-QA-28,
" Performance of Overview Inspections," states, in part, " Qualified QA/QC Review Team personnel assigned to the on-site QA Representative perform Overview Inspections of work performed in accordance with Reference 3.1 (CPP-009) . . . ." Section 5.4.2 of ERC-QA-28 states, in part, " Based upon each
, accept / reject criterion specified in the referenced QI/ effective Change Notice (s), the OI (0verview Inspector) denotes whether the item is (un) acceptable . . . ." Section 5.4.3 of ERC-QA-28 states, in part, "The 01 comoares the results of the Overview Inspection with the results of the initial reinspection / documentation review to identify any apparent inconsistencies . . . ."
In deviation from the above, the following error was identified concerning the results of overview inspections:
I. 4. Paragraph 5.5.2 in Section 5.0 of QI-037, Revision 0, states, in part,
" Verify that the cotter pins are the maximum size the hole will accommodate . . . ." An NRC inspection of Verification Package I-S-PS7N-056 showed that the cotter pins on the clamp side were undersized.
No ERC Deviation Reports were issued by the initial ERC inspector for undersized cotter pins. Attribute 5.1 on the decision point summary for Overview Inspection Package 38-I-S-PS87N-056, lists " Cotter Pins and Lock Washers in Place" as four correct decisions. The inspection checklist identified no undersized cotter pins (445/8607-D-12).
RESPONSE TO ITEM I.4 (445/8607-D-12)
We admit to the deviation and the requested information follows:
- 1. Reason for Deviation We admit the deviation and the requested information follows:
Overview performed an additional inspection on June 10, 1986, and confirmed the above stated deviation. This deviation was determined to be inspector error. The major contributing factor for this error was Attribute 5.5.2, " pin and bolt locking devices", contained in QI-037, Revision 0, which is more restrictive than in the VII.c Quality Instructions for the same attribute.
- 2. Corrective Steos Taken And Results Achieved Overview Verification Package No. 13-I-S-PS7N-056 was revised on June 10, 1986 to identify the above deviation. Deviation Report No. I-S-PS7N-DR3 was initiated on August 25, 1986, to address the two undersized cotter pins. In addition, TV Electric has initiated CAR-65 to perform a reinspection of all ASME pipe support cotter pin installations.
. Attachment to TXX-6222 February 18, 1987 Page 28 of 31 NOTICE OF DEVIATION RESPONSE TO ITEM I.4 (445/8607-D-12) CONT'D Quality Instruction QI-035 Section 5.5.2 was revised on October 10, 1986, (Revision 2) to state that the cotter pins "...should be the maximum size the hole will accommodate."
- 3. Corrective Steps Which Will Be Taken To Avoid Further Deviation A discussion was held with all overview inspectors responsible for performing inspections for this population on June 10, 1986. This discussion was documented.
Emphasis was placed on following all instructions of the QI and not to confuse instructions from other QIs with the one being used. Additionally, TU Electric has initiated CAR-65 to perform a reinspection of all ASME pipe support cotter pin installations.
- 4. Date When Full Comoliance Will Be Achieved TU Electric achieved compliance on October 10, 1986.
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. Attachment to TXX-6222 February 18, 1987 Page 29 of 31 NOTICE OF DEVIATION ITEM I.5 (445/8607-D-13)
I. Section 4 in Revision 4 to CPRT Project Procedure CPP-009 states, in part,
" Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions . . . ."
Section 4 in Revision 2 to ERC Quality Assurance Procedure ERC-QA-28,
" Performance of Overview Inspections," states, in part, " Qualified QA/QC Review Team personnel assigned to the on-site QA Representative perform Overview Inspections of work performed in accordance with Reference 3.1 (CFP-009) . . . ." Section 5.4.2 of ERC-QA-28 states, in part, " Based upon each accept / reject criterion specified in the referenced QI/ effective Change Notice (s), the OI (Overview Inspector) denotes whether the item is (un) acceptable . . . ." Section 5.4.3 of ERC-QA-28 states, in part, "The OI
. compares the results of the Overview Inspection with the results of the initial reinspection / documentation review to identify any apparent inconsistencies . . . ."
In deviation from the above, the following error was identified concerning the results of overview inspections:
I. 5. The initial ERC inspector and the OI signed off as acceptable Attribute 3 regarding spherical bearing gap for Verification Package I-S-PS7N-146. Independent inspection of this package revealed that the spherical bearing had been painted, precluding an accurate measurement of either the gap or the spacer (445/8607-D-13).
RESPONSE TO ITEM I.5 (445/8607-D-13)
This alleged deviation is under evaluation. We expect to send a report by March 6, 1987.
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, Attachment to TXX-6222 February 18, 1987 Page 30 of 31
.N0TICE OF DEVIATION ITEM J (445/8607-D-26)
J. Section 4.1.2 of CPRT ISAP VII.b.2, Revision 1, states, in part, " Review applicable procedures, for both construction and QC, to determine if they provided adequate controls of materials during valve disassembly and reassembly . . . ."
In deviation from the above, the review did not identify that adequate controls were not provided, in that procedures for disassembly and reassembly did not exist between January and June 1983 (445/8607-D-26).
RESPONSE TO ITEM J (445/8607-D-26)
We admit the deviation and the requested information follows:
I. Reason for Deviation ERC investigation confirmed that a procedural discrepancy in the valve disassembly / reassembly process existed between January and June 1983. The procedure review conducted under ISAP VII.b.2 had not identified the discrepancy.
The original review had been conducted as follows:
The content of the original procedure (CP-CPM-6.9 including Appendix E) was reviewed for adequacy of controls for the valve disassembly / reassembly process.
These controls were deleted from this procedure by issuing DCN 3 to CPM-6.9E which referenced a new procedure, CP-CPM-9.18. The reviewer incorrectly assumed that the DCN and the new procedure were issued concurrently. The new procedure was then reviewed for adequacy of controls on the valve disassembly / reassembly process.
- 2. Corrective Steps Taken And Results Achieved The impact of the procedural discrepancies on the valve disassembly / reassembly process and the conclusion stated in the ISAP VII.b.2 Results Report were assessed. The procedural discrepancy was found to have no impact for the following reasons:
Prior to January 28, 1983, valve disassembly was accomplished under CD-CPM-6.9 including Appendix E (CPM-6.9E). (Note, a CPM is a construction procedure used by craft to perform their work.) Up to this date, CPM-6.9 and 6.9E (all revisions) contained instructions governing valve disassembly and required valve disassembly to be controlled and documented using operation travelers which contain the instructions to the craft for the disassembly process.
, Attachment to TXX-6222 February 180 1987 Page 31 of 31 NOTICE OF DEVIATION RESPONSE TO ITEM J (445/8607-0-26) CONT'D The issuance of DCN3 to CPM-6.9E (Revision 6) on January 28, 1983, deleted the instructions for valve disassembly, deleted the reference to the operations traveler CPM and referenced CPM-9.18. CPM-9.18 was not issued for use until June 8, 1983. The delay in the issuance of CPM-9.18 was due to the time delay in preparing the generic valve type checklists included as attachments to CPM-9.18.
The text section of CPM-9.18 though not issued was available and understood by craft on January 28, 1983. During the four month period in question, valve disassembly continued to be accomplished using operation travelers. A review of a sample of the travelers written between January 28, 1983 and June 8, 1983, showed them to be similar in context and format to those used prior to the issuance of DCN3. Thus, the valve disassembly process continued unchanged despite the procedural discrepancy. The issuance of CP-CPM-9.18 (Revision 0) on June 8, 1983, covered all requirements which had been in CPM-6.9E prior to DCN3, including methods of documentation.
Additionally, the pertinent portion of the applicable quality assurance procedure (QI-QAP-11.1.26 Revisions 9 through 12) including the requirement for a traveler to govern the valve disassembly process remained unchanged during the four month period. The use of a traveler and the QI-QAP provided adequate process control during this time frame.
- 3. Corrective Steos Which Will Be Taken To Avoid Further Deviation No further action is required for this item. The ISAP VII.b.2 Results Report had already been issued at the time this deviation was identified. However, subsequent evaluation did not warrant any further action for this ISAP.
- 4. Date When Full Comoliance Will Be Achieved The above investigation and conclusions were completed on May 23, 1986.
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Outgoing Corresp:ndence bec (1):
M. D. Spence R. A. Jones C. E. Scott A W. G. Counsil S. D. Karpyak
- L. K. Sterchi J. W. Beck G. S. Keeley/ P. C. Stevens R. W. Ackley J. S. Marshall J. F. Streeter
- R. E. Ballard J. E. Krechting
- 8. Tartt J. L. Barker J. C. Kuykendall
- E. L. Wagoner
- W. R. Burchette
- D. F. Landers H. M. Warren (2)
- J. H. Butts
- R. P. Lessey
- N. H. Williams R. D. Calder 0. W. Lowe D. R. Woodlan F. Camp D. M. McAfee/ R. A. Wooldridge R. E. Camp P. E. Halstead
- R. L. Cloud
- R. E. McCaskill D(,E.Deviney
- J. P. McGaughy
- ' L. Dietrich D. D. Mosley
- T. G. Dignan
- A. Muzzin
- J. Ellis L. D. Nace W. D. Fenoglio PIMS
- B. Finkelstein L. E. Powell J. C. Finneran R. L. llamsey
- J. Garibaldi - Ebasco J. D. Redding J. B. George D. M. Peynerson R. L. Grubb - Impell
- N. S. Rieynolds H. A. Harrison
- K. L. Schepple l
- R. S. Howard H. C. Schmidt R. T. Jenkins . A. B. Scott
, February 5, 1987
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