TXX-6262, Forwards Revised Response to 860502 Notice of Violation,Due to Inability to Achieve Completion Schedules
| ML20212C389 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/27/1987 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EA-86-009, EA-86-9, TXX-6262, NUDOCS 8703030777 | |
| Download: ML20212C389 (21) | |
Text
Log # TXX-6262 L"""" 9 File # 10118 P-
-Z Ref. # 10CFR2.201 1UELECTRIC February 27, 1987 m,,, c, %,
1:m utne i k e f>esulerrt U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 EA N0. 86-09 Gentlemen:
By letters dated August 4, 1986, and August 25, 1986, TU Electric provided responses to two Notices of Violation (N0Vs), designated Appendix A and Appendix B to an NRC letter dated May 2, 1986. Our letters provided information relating to corrective actions to be taken for each item listed in the NOVs, including completion schedules.
We have determined that some of the completion schedules provided in our responses cannot be achieved.
In addition, several of the descriptions are being revised. We are therefore revising our responses to reflect the new schedules and the description changes. A summary of all changes is provided in Attachment 1. provides the revised pages (original pages were transmitted by our letter of August 4,1986) with revision bars denoting the location of changes.
Several of the dates for full compliance are related to the completion of the electrical penetration module replacement effort which is the subject of SDAR-CP-86-10 and is reportable under the provisions of 10CFR50.55(e).
Should any future schedule changes occur which impact that effort, we will update the
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SDAR correspondence but will not update our EA 86-09 responses to reflect such changes unless so requested.
Very truly yours, hNs W. G. Counsil BSD:1w Attachments c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV THE STATE OF TEXAS COUNTY OF DALLAS I hereby swear that the above stated information and the referenced attachments are true and correct to the best of my knowledge and belief.
WV.k Subscribed and sworn to before me, a Notary Public in and f r on this 7/9 day of h, 1987.
c My commission expires 7/E
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_ to TXX-6262 February 27, 1987 Page 1 of.2 SUMARY OF CHANGES PAGE DESCRIPTION OF CHANGE A3
- Editorial "CP-QA-2.1" has been revised to read "CP-QP-2.1".
- Revision - Deleted words which incorrectly indicated that the ASME certification program would be evaluated under ISAP I.d.2. and added explanatory sentence.
A4
- Editorial "QI-QAP-2.1" has been revised to read "QI-QAP-2.1-5".
A12 - Clarification - The name of the Damage Study Group has been changed to the Systems Interaction Group.
A16 - Clarification - Engineering evaluation of the walkdown results will be used to determine which supports have adverse interactions.
- Clarification - The " Corrective Actions to Avoid Recurrence" section has been expanded to be more descriptive.
- Revision - A statement is added that the adequacy of installation of Train C conduit will be assured prior to the fuel load of the respective units.
A20 - Editorial - The words "non-nuclear safety related" are revised to read "non-safety related".
A23 - Editorial - Same as A20.
A28 - Clarification - Provides more detail concerning the reason for the violation.
- Editorial "ISAP V.d" is revised to read "ISAP V,b".
- Revision - The statement " the effectiveness and adequacy of the construction operation traveller program will be evaluated in conjunction with the root cause and generic implication investigations associated with Corrective Action Report (CAR) 052" has been replace by the statement "the cause of this violation and actions to preclude recurrence will be addressed in Corrective Action Report (CAR) 101".
84
- Revision "TNE-FVM-CS-001 Rev. 4 dated March 20, 1986" has been revised to read "TNE-FVM-CS-001 Rev. 5 dated July 16, 1986".
89
- Editorial
" Appendix A" has been revised to read " Appendix B".
Bil
- Editorial - The words "and equipment" were deleted because they were inappropriate in that sentence.
- [larification - The name of the Damage Study Group has been changed to the Systems Interaction Group.
B12 - Revision - The date for full compliance has been changed from December 31, 1986 to May 31, 1987.
. - _ =
Attachment I to TXX-6262 i
February 27, 1987 Page 2 of 2 I
B14 - Revision - The date September 30, 1986 was changed to reflect when the subject FSAR amendment was submitted.
1 l-B18 - Clarification - Added statement that the reinspection to verify quality of important attributes of selected vendor supplied equipment is being done under ISAP VII.a.9.
j
- Revision - The date of implementation for using checklists to conduct source and receipt inspections, has been changed from September 1, 1986 I
to October 17, 1986.
- Revision - The "Date When in Full Compliance" section has been changed to reflect that full compliance will be achieved upon completion of ISAP VII.a.9.
f j
B181 - Revision - The words " Travelers prepared for replacement EPA modules by engineering", has been replaced by the words "The replacement of EPA modules will be controlled by instructions which".
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Revision - The date for full compliance has been changed from December 31, 1986, to May 31, 1987.
4 B21
- Clarification - The description of the task to walkdown equipment required to be qualified under the environmental, mechanical, and/or seismic qualification programs has been expanded to provide additional l
details.
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- Revision - Changed words which incorrectly implied that the equipment l
{
to be inspected under the EQ verification program included inaccessible i
equipment or equipment which has little overall influence on the verification effort.
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- Revision - The date for full compliance has been changed from l
December 31, 1986, to May 31, 1987.
l t
i 824 - Editorial "NCR M-85-1-1697" has been revised to read "NCR M-85-101967".
l B25 - Clarification - The "Date When in Full Compliance" section has been i
expanded to detail the scope of work to be completed.
i
- Revision - The date for full compliance has been changed from 1
April 25, 1986, to July 1, 1987.
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_ to TXX-6262 February 27, 1987 Page 1 of 17 The execution of ISAP I.d.1 revealed instances where individuals were certified who did not meet ANSI minimum capabilities for the following reasons:
o Accepting prior experience which was not related and not providing
. additional training and testing beyond specified minimums to establish capability, o
Not clearly documenting that additional training and testing given was done to establish capability in lieu of the ANSI minimum experience.
o Not specifically documenting the basis for reduction of training and testing requirements for individuals with related experience beyond the ANSI minimums.
The reasons for and generic implications of the above violations will be addressed in the collective evaluation of ISAPs I.d.1, I.d.2, and VII.c.
(3)
Corrective Steos Taken and Results Achieved:
We have pursued a two-fold effort to address the question of inspector qualification. The first effort is an assessment of personnel already certified and is addressed within the framework of ISAPs I.d.1 and VII.c.
For those personnel whose credentials cannot be established, a reinspection program will determine the adequacy of hardware items they inspected. The second effort entails a reassessment of the program used to certify inspection personnel, including the roles of the personnel who implement and maintain the program.
The approach taken for the certification of ASME inspectors contained sufficient controls and qualification assessment to assure a reasonable basis for personnel certification. The approach taken for non-ASME inspector certifications required revision and enhancement.
Steps taken su3 sequent to the TRT review included the following:
o Revision of CP-QP-2.1, " Training of Inspection Personnel," on August 19, l
1985, to address Regulatory Guide 1.58 (Revision 1) and ANSI N45.2.6-1978 requirements, o
Application of a conservative approach to Position C.6 of the Regulatory Guide and ANSI N45.2.6-1978 Section 3.5.
That is, no reduction of the education and experience minimums is allowed, o
Assignment of a full-time qualified and experienced Quality Training l
Supervisor to assure proper implementation of the certification program.
The adequacy of non-ASME certification programs is being evaluated in ISAP I.d.2.
Since the B&R procadure governing the ASME certification ~ program met or l
exceeded the requirements of ANSI N45.2.6 and Regulatory Guide 1.58, no enhancements of the ASME inspection certification program are needed.
l (4)
Corrective Steos to Avoid Recurrence:
The corrective steps taken to date have resulted in a program which will preclude the certification of non-ASME personnel who do not meet the ANSI l
PAGE A3 l
to TXX-6262 February 27, 1987 Page 2 of 17 minimum capabilities. Moreover, the program is monitored by the Quality Training Supervisor, audit personnel, and site surveillance personnel.
Certification practices of ASME personnel have not invoked the use of the other factors since the TRT inspection; however, the procedure for ASME inspector I
qualifications (QI-QAP-2.1-5) contains wording which permits the use of "other l factors". The ASME procedure will be revised to delete this revision by August 31, 1986.
(5)
Date When in Full Compliance:
The program is now in full compliance. Compliance will be addressed in ISAPs I.d.1, I.d.2, and VII.c.
PAGE A4
, _. _ ta TXX-6262 February 27, 1987 i
Page 3 of 17 i
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. (3)
Corrective Steos Taken and Results Achieved:
The nonseismic control room ceiling is being replaced with a design which can readily be seismically qualified.
Our response to Appendix A Item I.B.5 addresses the steps taken to resolve the non-safety related conduits two inches or less issue.
A systems interaction review of all plant architectural features (nonseismic partitions, other architectural ceilings, doors, etc.) and lighting fixtures 4
will be performed in the Systems Interaction Program. A design verification of I
the Systems Interaction Program to address the generic implications of the two i
specific technical issues will be performed under ISAP II.d. The verification effort will include an assessment of the control room lighting and all other j
architectural features.
(4)
Corrective Steos to Avoid Recurrence:
l The Systems Interaction Program is ongoing and will continue to review / evaluate l future modifications to the plant.
f (5)
Date When in Full Como11ance:
The systems interaction review is complete for existing items and any l
unacceptable interactions identified are being dispositioned. The scheduled completion date of the control room ceiling installation is November 1,1986.
ISAP II.d will assess the adequacy of the Systems Interaction Program and any i
needed corrective actions.
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PAGE A12 i
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to TXX-6262 February 27, 1987 Page 4 of 17 installation instructions caused the craft to install a portion of the two inch diameter and smaller population in groups of more than one conduit, which is inconsistent with the engineering assumption.
(3)
Corrective Steos Taken and Results Achieved:
ISAP I.c_ was prepared to address compliance with FSAR commitments for support of non-safety related conduits less than or equal to two inches diameter. The ISAP includes the walkdown within Category I structures for installed supports on non-safety related conduits two inches diameter and smaller to determine adverse interactions.
For those supports determined by engineering evaluation of the walkdown results to have adverse interactions, they will be changed to ensure that they are seismically adequate.
(4)
Corrective Steos to Avoid Recurrence:
Two actions have been taken:
a.
A new construction procedure (ECP-198) was issued which gives generic support types and provides acceptable methods for installing Train C conduit (2-inch diameter and less) such that the conduit will maintain structural integrity during an SSE event. The procedure also provides instructions to obtain engineering assistance whenever custom support types are needed.
b.
A program was established to review new installations of safety-related plant features for potential targets for Train C conduit which may fail during as SSE event. The program also provides for reviews of the removal or modification of existing structural features because these structural features may have been used as a barrier to protect safety-related features from Train C conduit which may fail during an SSE event. This program is being implemented by Impell Corporation for TV Electric and is described in Impell Project Instruction No. PI-0210-53-01. When the program implementation is assured by Comanche Peak Engineering, the program document will be converted to a Comanche Peak Engineering document.
3 The above two items will be performed by engineering personnel under approved procedures with quality assurance surveillance and auditing of the implementation.
i (5)
Date When in Full Como11ance:
Compliance will be addressed in ISAP I.c.
The adequacy of the installations of Train C conduit will be assured prior to fuel load of the respective units.
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PAGE A16 to TXX-6262 February 27, 1987 Page 5 of 17 ALLEGED VIOLATION - APPENDIX A. ITEM I.B.8 10 CFR Part 50, Appendix B, Criterion III requires in part that measures must be established to assure that applicable regulatory requirements and design bases, as defined in 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies, are correctly translated into specifications, drawings, procedures and instructions. These measures must include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. The design control measures must provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
In addition, design changes, including field changes, must be subject to design control measures commensurate with those applied to the original design.
CPSES FSAR, Section 1A(B) commits to the guidance provided in Regulatory Guide 1.64,
" Quality Assurance Requirements for the Design of Nuclear Power Plants," which endorses ANSI N45.2.11 (Draft 2, Revision 2-5/73).
ANSI N45.2.11 in paragraph 3.1 requires that design inputs, such as design bases, be identified, documented, and their selection reviewed and approved.
Changes from specified design inputs, including the reasons for the changes, shall be identified, approved, documented and controlled.
Contrary to the above, at the time of the TRT inspection, the applicant failed to adequately identify design bases and inputs including specific Design Basis Accident (DBA) test reports, and failed to properly perform and document review and analysis of design and design inputs, especially design changes.
For example, allowable coating thicknesses applied to the inside of the Containment Liner were repeatedly changed without engineering evaluation and review to demonstrate,that the coatings of different thickness would survive testing under DBA conditions.
TVEC RESPONSE (1)
Admission or Denial of Alleaed Violation:
We admit the alleged violation.
(2)
Reason for Violation:
We did not adequately identify specific documentation related to DBA test data for coatings systems and provide adequate engineering justification to support l
approval of design changes.
(3)
Corrective Action and Results Achieved:
NUREG-0797, Supplement No. 9, approved the declassification of protective coatings applied inside containment to non-safety related.
Corrective action for coatings previously applied at CPSES was not required because the failure of coatings would not result in or contribute to causing or increasing the l
consequences of any design basis accident.
All containment building coating procedures were completely rewritten to reflect the change to a non-safety related program, and to assure compliance PAGE A20 l
l to TXX-6262 February 27, 1987 Page 6 of 17 was sufficient technical justification to modify the application tolerances of coating materials which were previously qualified by Oak Ridge National Laboratories.
(3)
Corrective Steos Taken and Results Achieved:
The dry film thickness tolerances for containment coating materials were evaluated and modified to assure compliance with ANSI N101.2 and ANSI N512.
Specification 2323-AS-31 was revised in December 1984 to delete the requirement that containment coating systems be DBA tested at Oak Ridge National Laboratories and by the coating manufacturer. The specification now references only compliance with ANSI N101.2 and ANSI N512.
Procedures have been revised and are being applied in strict accordance with the manufacturers' written instructions.
(4)
Corrective Steos to Avoid Recurrence:
Protective coatings inside containment are now non-safety related. The l
specification requires implementing procedures be approved by the Coatings Engineer.
(5)
Date When in Full Como11ance:
December 19, 1984 l
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l ALLEGED VIOLATION - APPENDIX A. ITEM I.C.3 10 CFR Part 50, Appendix B, Criterion X requires, in part, that a program for inspection of activities affecting quality be established and executed by or for the organization performing the activity to verify conformance with the documented i
instructions, procedures, and drawings for accomplishing the activity.
I TUEC procedure QI-QP-ll.14-1, " Inspection of Site Fabrication and Installation of i
Structural and Miscellaneous Steel," delineates inspection criteria for support 4
i bolts. Work package MRB-0550-013-RB authorized the cutting of 1-1/2 inches off the j
9-inch length of 144 bolts. The bolts were purchased to hold the steam generator 1ateral supports to the wall plates but were ordered 1-1/2 inches too long.
Contrary to the above, required quality control inspections for the installation of the steam generator upper lateral restraint anchor bolts were not performed.
i TUEC RESPONSE i
i (1)
Admission or Denial of A11eaed Violation:
We admit the alleged violation.
(2)
Reason for Violation:
i -
We believe the applicable SSER page reference to be N-149 rather than N-57 as cited by the NRC.
The reason for the violation was the failure of Engineering to provide sufficient information regarding the cutting and inspection of the bolts, and the failure of Engineering and/or Construction to generate documents such as construction operation travelers to control the cutting and inspection of the i
i bolts.
(3)
Corrective Steos Taken and Results Achieved:
i We conducted an extensive search for the inspection records associated with the cited restraint. When ths inspection records could not be located, a program was implemented to determine and document the length of the installed bolts, i
and to initiate hardware replacement if thread engagement was less than the i
minimum specified by MRB-0550-013-RB. Because unauthorized bolt cutting has i-been identified, analysis and bolt replacement is currently in progress.
(4)
Corrective Steos to Avoid Recurrence:
l This matter is being addressed in ISAP V,b and DSAP Vlil.
These action plans have implemented a verification of Unit 2 Steam Generator lateral restraints l
bolt engagement, a sample inspection of bolt engagement on other structural I
bolted connections, and an evaluation of the adequacy and implementation of I
past and current QA program requirements relative to this issue. The cause of this violation and actions to preclude recurrence will be addressed in j
Corrective Action Report (CAR) 101.
l (5)
Date When in Full Comoliance:
Compliance will be addressed in ISAP V.b, DSAP VIII, and CAR 101.
l PAGE A28 l
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to TXX-6262 February 27, 1987 Page 8 of 17 Soon after the program suspension, TUGC0 personnel received information that walkdown engineers were (1) being directed by their Walkdown Manager to not take the independent measurements called for in their procedure, and (2) being threatened by their Walkdown Manager with the loss of certain privileges if the walkdown engineers did not meet production quotas. TUGC0 management promptly called for an independent investigation by corporate security personnel from Texas Utilities Services, Inc. (TUSI). The investigation was quickly commenced and completed and confirmed the information and led to the Walkdown Manager and his immediate subordinate being removed from the site.
The TUSI investigation efforts were later reviewed at CPSES by the NRC's Office of Investigation (01) on February 18, 1986. The OI representative commented that TUGC0 management acted quickly in calling in TUSI to conduct the investigation and that TUGC0 dealt quickly with the personnel problems revealed by the investigation.
The 01 representative also commented that the TUSI investigation was thorough and timely.
In March 1986 TUSI corporate security personnel received a telephone call on the " Hotline" from an individual involved in the revised Unit 1 CTH as-built program. The caller alleged that past management practices regarding production pressure, production quotas, and intimidation were continuing.
Another independent investigation by TUSI corporate security personnel was promptly conducted between March 13 and April 2,1986.
The investigation revealed that all of the allegations were unfounded.
Our reviews and investigation in response to the Unit 1 TH as-built program resulted in a multitude of corrective actions by engineering and QC regarding the conduct of the program and associated inspection activities.
Some of the significant actions were:
1.
The engineering portion of the program was reorganized to place increased emphasis on the assurance by engineering of a quality product and a new Walkdown Manager was appointed who has proved abilities.
2.
The engineering and inspection procedures governing the process of walking down the CTHs, as-building all relevant attributes, creating the red-line drawings, and QC inspection / verification activities were completely rewritten.
TNE-FVM-CS-001 Rev. 3 dated January 28, 1986, governed the restart of walkdown activities and QI-QP-ll.10-9 Rev 4 dated April 25, 10986 governed the restart of inspection / verification activities.
(TNE-stillcoverstheQCl FVM-CS-001 Rev. 5 dated July 16, 1986, presently covers the engineering efforts and QI-QP-11.10-9 Rev. 4 dated April 25, 1986, inspection / verification activities.)
The rewrite of the engineering procedure was accomplished with the personal oversight of the responsible Ebasco Vice President who also approved the procedure. The principal changes related to providing unequivocal separation between the engineering walkdown and QC functions and providing precise instructions as to what the walkdown engineers are expected to do.
PAGE B4 to TXX-6262 February 27, 1987 Page 9 of 17 ALLEGED VIOLATION - APPENDIX B. ITEM I.B.I.a 10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 Quality Assurance Plan (QAP), Section 5, Revision 1, dated April 16, 1979, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and be accomplished in accordance with these instructions, procedures, or drawings.
Paragraph 3.1.2 of Brown & Root (B&R) Procedure CPM-6.3 Revision 8, dated April 2, 1981, states, "The traveler package shall contain, or may reference if normally available, the drawings, procedures, instructions, manufacturer's manuals / guidelines, etc., necessary to accomplish the activity."
Contrary to the above, at the time of this inspection, January 1 - March 14, 1986, construction operation travelers for installation of electrical penetration assemblies (EPAs) 1E76, IE77, IE78, and IE79 referenced a type of inboard cable support assembly that was attached to the EPA header plate instead of the EPA nozzle as required by the applicable Bunker Ramo Corporation (BRC) Drawing 50022078, Revision F.
TUEC RESPONSE (1)
Admission or Denial of A11eaed Violation:
We admit the alleged violation.
(2)
Reason for Violation:
The caution note in the traveler for the valve isolation tank electrical penetration assemblies (EPAs) is a modification of the caution note on a standard EPA traveler, which reads:
"The outboard cable support fixture is attached to the header plate and must be fully su) ported at all times."
(emphasis added) There are differences between t1e standard penetrations and the tank penetrations. The first main difference is that the penetrations are reversed in orientation for the tank application.
The second main difference is that there is no cable support fixture on the tank penetrations similar to the one on the standard penetrations. The inboard cable support is affixed after the penetration is installed and it is attached to the nozzle and not the header plate.
The engineer who prepared the valve isolation tank EPA traveler changed the word " outboard" to the word " inboard" in the caution note to reflect the change in orientation; however, the engineer failed to recognize the caution note should not have been present since there is no cable su] port fixture similar to the one on the standard penetrations. The inboard caale support should have been installed later in accordance with the drawing under traveler Step 4m; however, Step 4m does not specifically require the support be consistent with the applicable drawing.
(See response (2) to Appendix B ltem I.B.4.a for a related discussion.)
l (3)
[orrective Steos Taken and Results Achieved:
This issue will be corrected with the replacement of all Bunker Ramo EPA modules.
PAGE B9
_ _________ ______ to TXX-6262 February 27, 1987 Page 10 of 17 ALLEGED VIOLATION - APPENDIX B. ITEM I.B.1.b 10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 Quality Assurance Plan (QAP), Section 5, Revision 1, dated April 16, 1979, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and be accomplished in accordance with these instructions, procedures, or drawings.
Drawing 2323-EI-0514, Revision 7, dated April 13, 1984, requires that conductor entry conduit, through which cables from certain EPAs were routed into junction boxes, must be sealed as specified.
Contrary to the above, during this inspection, the junction boxes to which cables were routed from EPAs IE44, IE45, IE46, and IE47 were observed to have unsealed conductor entry conduit.
TUEC RESPONSE (1)
Admission or Denial of A11eaed Violation:
We admit the alleged violation.
(2)
Reason for Violation:
The requirements to provide seals per Detail B on Drawing 2323-El-514, Revision 7 was issued by Design Change Authorization (DCA) 10,628 Revision 0 in July 1981. This DCA was incorporated in the drawing in April 1983, and the seals which were intended to be equipment seals were entitled fire stops.
Controls for the installation of the seals were not developed and implemented because l
fire stops were not within the scope of the Design Change Verification Group and the System Interaction Group was not aware of the requirement for the l
equipment seals. Consequently, the seals were not installed and there was no program to verify the installation of such equipment seals.
(3)
Corrective Steos Taken and Results Achieved:
The lack of these seals was identified on NCR E-86-101009. A review of the design indicates that these seals provide no safety function and are not required. Therefore, we are giving consideration to reclassifying these seals as non-safety related and/or eliminating them from our design.
(4)
Corrective Steos to Avoid Recurrence:
Procedural controls related to this area have been enhanced for other reasons since this event and appear to be adequate to prevent recurrence of this event.
The Paper Flow Group now reviews all DCAs and revised drawings for work items, and assures that any work items are entered on the Master Data Base and that work packages include DCA requirements. Also, during final record review the Paper Flow Group reviews all packages for completeness and implementation of DCAs prior to issuance of the records to the records vault.
(5)
Date When in Full Comoliance:
The disposition of NCR E 86101009 will assure full compliance prior to fuel load of the respective units.
PAGE Bil to TXX-6262 February 27, 1987 Page 11 of 17 ALLEGED VIOLATION - APPENDIX B. ITEM I.B.1.c 10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 Quality Assurance Plan (QAP), Section 5, Revision 1, dated April 16, 1979, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and be accomplished in accordance with these instruction, procedures, or drawings.
Paragraph 6.5 of B&R Engineering Instruction EEI-22, Revision 0, dated October 4, 1982, and paragraph 3.1.3 of TUGC0 Instruction QI-QP-ll.3-49, Revision 0, dated October 1,1982, states, " Pigtail conductors must be supported a maximum of 36 inches from the penetration header plate or conductor support."
Contrary to the above, during this inspection, the pigtail conductors for the Conax modules in EPA lE14 were observed to be supported on the inboard side (inside the reactor containment building) at distances of 43 inches to 60 inches from the penetration header plate.
TUEC RESPONSE (1)
Admission or Denial of A11eaed Violation:
We admit the alleged violation.
(2)
Reason for Violation:
The construction and inspection procedures properly stated that the maximum supported cable length should be 36".
The procedures were not followed by craft and inspection personnel.
(3)
Corrective Steos Taken and Results Achieved:
The cables in question and other similar cables subject to construction Procedure EEI-22 will be supported as required by reworking them.
(4)
Corrective Steos to Avoid Recurrence:
Before the replacement EPA modules are installed both craft and inspectors will be trained to the proper installation procedures.
(5)
Date When in Full Como11ance:
The cables will be reinspected and corrections made by May 31, 1987.
PAGE B12 to TXX-6262 February 27, 1987 Page 12 of 17 (5)
Date When in Full Como11ance:
An FSAR amendment addressing this matter will be submitted to the NRC by November 30, 1986. Any rework that may be necessary to comply with that FSAR l amendment will be completed prior to fuel load.
PAGE B14
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February 27, 1987 Page 13 of 17
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(3)
Corrective Steos Taken and Results Achieved:
A review of the thirty-one Receiving Inspection Riports (RIR) for all Bunker Ramo EPAs were reviewed. Specification checklists were utilized in twenty-three of the thirty-one packages. Of the remain %g eight RIR packages, two RIRs were required to have complete specification checklists, but no documentation could be located. This included the checklist for EPAs 1E76, 1E77, and IE78. The remaining six RIR packages did not riquire checklists to be completed.
Since all Bunker Ramo EPAs will be replaced with EPAs f,omkaother vendor and s.
these replacement EPAs will be subjected to consistent inyections using checklists prepared by engineering, no further action with respect to the Bunker Ramo EPAs is planned. '
A reinspection of the quality of selected vendor-supplied equipment will oe" performed to verify the quality of important attributes. This effort will identity any conditions which were not identified as a result of a lack of detailed receipt inspections. Thit effort is being conducted under ISAP VII.a,9.
~
'(4)
Corrective Steos to Avoid Recurrence:
, y A program is being established for engineering to develop on an as needed basis checklists to be used during source and receipt inspections. These new checklists will ensure that, inspections of the necessary depth are consistently pt.rformed. Verification of all applicable attributes will be required for each shipment, either at the source or upon receipt. These new checklists will be based on drawings as well as specifications. The first effort in this program which is underway is to develop the checklist for the replacunent EPAs.
Source and receipt inspections after October 17, 1986 will be conducted using the checklists developed in accordance with this program. As an interim measure, the Quality Engineering group will review and approve checklists. The supervisors of source and reed pt inspectors will assure that inspectors are consistently verifying applicable checklist attributes and that source and recolpt inspectors perform and document some verifications utilizing vendor drawings.
Source and receipt inspectors will be briefed on the Bunker Ramo issues Ard the corrective actions by August 15, 1986.
(5)
Ditr When in Full Cngg]iAqqg:
Compliance of selected vendor-supplied equipment with applicab'le engineering specifications is being addressed in ISAP VII.a.9.
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,n to TXX-6262 February 27, 1987 Page 14 of 17 ALLEGED VIOLATION - APPENDIX B. ITEM I.B.4.a 10 CFR Part 50, Appendix B, Criterion X as implemented by the TUGC0 QAP, Section 10.0, Revision 1, Dated July 31, 1984, requires that a program for inspection of activities affecting quality be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.
An inboard cable support assembly was not present for EPAs 1E76, IE77,1E78, and 1E79 even though Quality Control inspections had verified these installations.
TVEC RESPONSE (1)
Admission or Denial of A11eaed Violation:
We admit the alleged violation.
(2)
Reason for Violation:
The lack of specificity in the traveler regarding installation of the inboard support assembly in Step 4m and the failure of the inspector to verify that the support was consistent with the drawing were the reasons for the violation.
(3)
Corrective Steos Taken and Results Achieved:
This deviation will be corrected with the replacement of all Bunker Ramo EPA modules.
(4)
Corrective Steos Taken and Results Achieved:
The replacement of EPA modules will be controlled by instructions which will l
clearly convey installation and inspection requirements to minimize the possibility of error.
Present procedures regarding the preparation of construction travelers will be reviewed to determine if there is a need to revise them in light of this violation and any necessary revisions will be 1
completed by August 31, 1986.
(5)
Date When in Full Comoliance:
(
May 31, 1987 f
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? to TXX-6262 Feb.uary 27, 1987 Pat # 15'of 17 (3)
Corrective Steos Taken and Results Achieved:
Due to the lack of explicit information that demonstrates the EPAs are environ =cntally qualified with or without the rework, and due to other considerations, TUGC0 has decided to replace all Bunker Ramo EPA modules with qualified modules from another vendor. Therefore, TUGC0 does not plan to accomplish the rework. The replacement activity has been entered into the Master Data Base for work control purposes.
A task has been initiated as part of the CPSES EQ verification program to walk down equipment required to be qualified under the environmental, mechanical,
+
and/or seismic qualification programs. This EQ verification program will include comparison of the qualification attributes of the observed equipment to the qualification reports on file at CPSES and will include comparison of the l
equipment and its installation to vendor-supplied documents which define the same. This equipment is to include Class IE equipment, non-1E equipment required to have seismic qualification, and non-1E equipment requiring environmental qualification in accordance with Regulatory Guide 1.97.
The EQ verification program will include all equipment identified in the above categorfes with the exception of items that are inaccessible or have little oiserall ginfluence in this verification effort. This effort will identify, 3s document; and resolve discrepancies such as the failure to accomplish the Bunker-Ramo taping rework when such discrepancies are determined to affect the t-qualification of equipment. The extent of this effort will provide assurance that installed equipment at CPSES has been qualified in accordance with the specified qualification requirements.
(4)
Corrective Steos to Avoid Recurrence:
Procedube THE-PR-2, Rev. 2, which is now in effect requires in Section 2.1.2 that prior to engineering authorizing the release of equipment for shipment the F
vendor must have met all specification requirements. This would require verification that the equipment has been environmentally qualified.
Procedure s
TNE-DC-5, Rev. 3, which is also in effect requires that drawings be revised to incorporate comments similar to the taping comments prior to the granting of an engineering release. Therefore, we believe present controls would not allow a similar event to occur today.
l (5)
Date When in Full Compliance:
i May 31, 1987
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to TXX-6262 February 27, 1987 Page 16 of 17 ALLEGED VIOLATION - APPENDIX B. ITEM II 10 CFR Part 50, Appendix B, Criterion IX requires, in part, that measures be established to assure that special processes, including welding, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes and standards.
CPSES FSAR, Section 17.1.9 states, in part, with respect to control of special processes, "TUGC0 requires of its prime contractors that written procedures and controls be prepared to assure that special processes including welding...are accomplished by qualified personnel using qualified procedures, in accordance with applicable codes, standards,..."
The CPSES FSAR, Table 17A-1 and Gibbs and Hill (G&H) Specification 2323-SS-16B dated May 7, 1975, require use of the American Institute of Steel Construction (AISC) Code for cable tray hanger supports. The AISC Code and the G&H specification require that welding be performed in accordance with the American Welding Society (AWS) D1.1.
Code. AWS D1.1-75, Section 2.9.2.4 states with respect to prequalified weld groove angles, "The groove angle is a minimum.
It may be detailed to exceed the dimension shown by no more than 10 degrees."
Contrary to the above, at the time of the NRC inspection the weld groove angles for hanger CTH-1-5538 (full penetration weld #2) and hanger CTH-1-5517 (1/2-inch plate full penetration weld) were found to be below the prequalified weld minimum groove angle indicated on the hanger drawings by 15 degrees and 7-9 degrees, respectively.
TUEC RESPONSE (1)
Admission or Denial of Alleaed Violation:
We admit the alleged violation.
(2)
Reason for Violation:
Welders failed to follow weld fit-up criteria for prequalified weld groove angle, and inspection procedures did not required fit-up inspection by QC of all cable tray hanger (CTH) full or partial penetration welds in Unit I areas at the time these welds were made.
(3)
Corrective Steos Taken and Results Achieved:
NCR M-85-101967 was initiated on December 4,1985 to resolve the specific bevel angle deficiencies identified by the NRC involving CTH-1-5517 and CTH-1-5538.
A walkdown of Unit 1 CTHs was conducted by a Level III Welding Quality Engineer and no bevel groove angles were identified which were less than 30 degrees
(+or-2 degrees). The walkdown consisted of a general review of installed CTHs and was not based upon a formal sampling plan. A similar walkdown of Unit 2 CTHs did not identify any bevel groove angle deficiencies.
Based on these findings, a bevel groove weld with an angle of 30 degrees (+10 degrees, -5 degrees) was qualified (Procedure Qualification Record CP-AWBB153) on December 27, 1985, in accordance with AWS D1.1-75 requirements.
QC Procedure QI-QP-11.10-9, " Cable Tray Hanger As-Built Inspection / Verification", was revised to include bevel groove angle verification criteria of 45 degrees (+10 degrees,
-20 degrees) which is inclusive of the above site qualified groove angle criteria and the PAGE B24 to TXX-6262 February 27, 1987 Page 17 of 17 AWS prequalified groove angle criteria.
(CP-AWBB153 is used only as a basis for resolution of bevel groove angle nonconformances identified during reinspection activities.) Ongoing construction activities are governed by the criteria of 45 degrees (+10 degrees, -5 degrees).
A review of other areas involving AWS weld criteria was conducted by Quality Surveillance personnel to determine if there were generic implications of this violation. A general walkdown of Unit I and 2 items erected in accordance with AWS prequalified weld procedures was conducted to observe bevel groove angles.
This walkdown effort was not governed by a formal sampling plan.
Items reviewed included HVAC supports, pipe whip restraints and structural steel connections. Due to connection configurations and the presence of paint or protective coatings only a limited number of bevel groove angles could be verified; however, no violation of AWS prequalified criteria was identified in any of the bevel angles measured. The configuration of HVAC support reviewed-did not require bevel groove penetration as all welds installed were fillet type.
In addition to this hardware review, site QC procedures applicable to the above installation activities were reviewed to assure that weld fit-up inspection was required.
Each of these activities were governed by procedures which included fit-up inspection.
(4)
Corrective Steos to Avoid Recurrencq:
Since no instances of bevel groove angle deficiencies were identified in Unit 2 and since Unit 2 activities have been and continue to be inspccted against the criteria of 45 degrees (+10 degrees, -5 degrees), this violation is considered limited to Unit 1 CTHs. The Unit 1 CTHs will be subjected to 100% reinspection using the qualified criteria 45 degrees (+10 degrees, -20 degrees).
(5)
Date When in Full Comoliance:
The reinspection of Unit 1 CTHs for bevel groove weld angle deficiencies will be completed by July 1,1987.
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