TXX-6314, Responds to Nonconformance Noted in Insp 99900509/86-01 on 860825-29,per S&W .Corrective Action:Project Memo PM-126 Issued to Provide Interim Program Control for Application of Stress Analysis & Pipe Support Mod Memos
| ML20207S398 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/16/1987 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| REF-QA-99900509 TXX-6314, NUDOCS 8703190391 | |
| Download: ML20207S398 (7) | |
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Log # TXX-6314
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File # 10131 3
3 1UELECTRIC March 16, 1987
%illiam G. Coumil Executiw he />esulera 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 RESPONSE TO THE NOTICE OF NONCONFORMANCE ON STONE & WEBSTER ENGINEERING CORPORATION (SWEC)
NEW YORK OFFICE DOCKET NO. 99900509/86-01 REF:
SWEC letter from R. Kelly to E. Mirschoff dated February 2, 1987 Gentlemen:
The referenced letter from Stone & Webster Engineering Corporation (SWEC) informed you that TV Electric, the licensee for CPSES, will respond to the subject report of findings for the August 25-29, 1986, inspection of Comanche Peak Steam Electric Station activities conducted at SWEC's New York office.
The purpose of the inspection was to feview the program implementation of Stone & Webster's Quality Assurance (QA) activities relating to the Design Requalification of piping and pipe supports for CPSES Units 1 and 2.
In accordance with your request we are responding in the attachment to this letter for the nonconformances identified in Appendix A, Notice of Nonconformance. Stone and Webster admits to the nonconformances and provides the following information within the attached written statements:
1.
A description of steps that have been or will be taken to correct these items.
2.
A description of steps that will be taken to prevent recurrence.
3.
The date(s) the corrective actions and preventive measures were and will be completed.
A 5
N 4 p0 '. V#
400 Noeth 0;ne Street I it 81 Datta3. Icsas 753)I
- March 16, 1987
. Page 2 TU Electric requested and received an extension in providing a response to the referenced letter during the March 2,1987, telephone conversation with Mr. J. Stone.
With respect to the Unresolved Items and NRC Statements, we are available to address these items at your request.
Very truly yours, W. G. Counsil DAR:lw c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV Stone & Wester Engineering Corporation, Boston, MA e
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Attachment'to TXX-6314 March 16, 1987 Page 1 of 3 NOTICE OF NONCONFORMANCE ITEM A (99900509/86-01-01)
Criterion V of Appendix B to 10 CFR 50 requires in part that, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures and drawings.
Instructions, procedures, or drawings, shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Stone & Webster (SWEC) Standard Nuclear Quality Assurance (QA) Program Manual, Section 5, paragraph 2.1.1 requires in part, that project engineering shall indicate quality activities (including special controls) in specifications and procedures, as appropriate. Criteria for the acceptance of specific tasks shall be included in the related document.
Contrary to the above, SWEC failed to meet this commitment as demonstrated by the following examples:
A.
SWEC specifications and procedures had not been written and implemented which prescribe the transfer of design information, (from the SWEC New York office to the Comanche Peak site and between SWEC offices), utilized in the final resolution of safety related pipe support design packages.
(86-01-01)
RESPONSE TO ITEM A (99900509/86-01-01)
We admit to the Nonconformance and the requested information follows:
1.
Reason for Nonconformance l
Specific procedures issued by SWEC for the Comanche Peak Project (CPPPs) did not contain specific details regarding the processing of Stress Analysis (SA), Pipe Support Certification (PSC), or Pipe l
Support Modification (PSM) memoranda from the SWEC New York office to the Comanche Peak site or between SWEC offices. The need for i
instructions governing the processing of these specific docuaents appears to have been overlooked during preparation of these CPPPs.
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Attachment to TXX-6314 March 16, 1987 Page 2 of 3 The SA, PSC, and PSM memoranda are used to identify to the Comanche Peak site engineering organization specific instances which require pipe support modifications or evaluation in order to resolve outstanding analyses issuas involving support design / certification.
These transmittals are originated by the SWEC office responsible for the affected stress / support analysis and forwarded to the SWEC New York office for submittal to SWEC site personnel.
This information is transmitted in this manner to expedite site activities by readily identifying required actions. These actions, once identified, are implemented by initiating design change program documents (DCAs) at l
the site.
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Please note that documentation of the final design consists of engineering design documents compiled as a result of the design control program. These documents include applicable drawings, design i
changes, calculations, and analyses. The transmittals noted in this finding are not used to document the final or as-built design.
2.
Corrective Steos Taken and Results Achieved Project Memorandum PM-126 was issued October 20, 1986 to provide interim program control requirements for the application of SA, PSM, and PSC memoranda.
Although noted to the contrary in PM-126, these requirements will be j
incorporated into the applicable CPPPs.
In addition, SWEC will conduct a review of all SA, PSM and PSC memoranda issued prior to PM-126 to assure proper transmittal, receipt, and accountability.
l Training of applicable personnel will be conducted in at.cordance with i
the SWEC training and indoctrination program.
3.
Corrective Steos Which Will Be Taken To Avoid Further Nonconformances A review of all other forms used to transmit design related information will be conducted by SWEC to assure the implementation of proper controls. All forms identified will have corresponding procedures governing their use and application.
l 4.
Date When Full Como11ance Will Be Achieved l
The procedural revisions, program review, and training will be completed no later than April 10, 1987. All other corrective measures have been completed.
Attachme;t to TXX-6314 March 16, 1987 Page 3 of 3 l
B.
SWEC specifications and procedures had not been written and implemented which prescribe how proposed design modifications are documented and reviewed by the applicable Project Engineers to determine if they require review by the Option Review Committee.
(86-10-02)
RESPONSE TO ITEM B (99900509/86-01-02)
We admit to the Nonconformance and the requested information follows:
1.
Reason for Nonconformance Although the procedures in effect at the time of the audit (CPPP-6 and CPPP-9) generally described the activities to be performed and r
assigned responsibilities for the performance of these activities, the procedures did not contain specific details regarding the processing of proposed modifications through the Project Engineer to the Options Review Committee by use of the Proposed Modification Report (PMR) form.
2.
Corrective Steos Taken and Results Achieved As noted in the inspection report, the arogram nonconformance was currently under review by SWEC during tie inspection. The " draft project memorandum" has been subsequently issued per Project Memorandum PM 106 dated September 9, 1986 to provide direction for the review of proposed modifications.
Although noted to the contrary in PM 106, these requirements will be incorporated into CPPP 6 " Pipe Stress / Support Requalification Procedure - Unit 1" and CPPP-9 " Pipe Stress / Support As Built Procedure
- Unit 2".
Training of applicable personnel will be conducted in accordance with the SWEC training and indoctrination program.
3.
Corrective Steos Which Will Be Taken To Avoid Further Nonconformances j
The corrective action taken as described above in conjunction with that taken to address Item A is sufficient to prevent recurrence. No further action is necessary.
4.
Date When Full Comoltance Will Be Achieved The procedural revisions and training will be completed no later than April 10, 1987. All other corrective measures have been completed.
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i File # 10002 I
CONNITNENT TRACKING 0UTG0ING C0RRESP0NDENCE EVALUATION SHEET DUCURENT IDENTIFICATION Title /
Subject:
Response to the Notice of Nonconformance Log No. TXX-6314 SWEC Vendor Inspection Report. Docket No.
File No. 10131 99900509/86-01 Date 03/16/87 ITEM TRACKING
- Item Tracking its h.
Descrintion 1yg31 Document /h.
01 Project Memorandum PM-126 program control require-IA LCR ments will be incorportated into the applicable CPPPs.
02 SWEC will conduct a review of all Stress Analysis IA LCR (SA), Pipe Support Certification (PSC), and Pipe Modification (PSM) memoranda issued prior to PM-126 to assure proper transmittal, receipt, and l
accountability.
03 Training of apslicable personnel will be conducted in IA LCR 87-accordance witi the SWEC training and indoctrination program.
04 A review of all other forms used to transmit design IA LCR 87-related information will be conducted by SWEC to assure the implementation of proper controls. Also, all forms identified will have corresponding procedures governing their use and application.
l 05 The requirements of PM-106 will be incorporated into IA LCR 87-l CPPP 6 and CPPP-9 procedures.
06 The procedural revisions, program review, and train-IA LCR 87-ing will be completed no later than April 10, 1987.
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- ltem Types: DB - Design Bases 00 Description Only EA - External Action OB - Operational Bases IA - Internal Action COMPLETED BY:
REVIEWED BY:
Initials DAR Date03/16/87 Initials W Date 3__/ S/
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(_____-_-______.
Outgoing Correspondence bec (1):
M. D. Spence S. D. Karpyak A. B. Scott A
W. G. Counsil G. S. Keeley/
C. E. Scott J. W. Beck J. S. Marshall
- L. K. Sterchi R. W. Ackley
- R. P. Klause P. B. Stevens
- R. E. Ballard J. E. Krechting J. F. Streeter J. L. Barker J. C. Kuykendall
- B. Tartt
- W. R. Burchette
- D. F. Landers
- J. L. Vota
- J. H. Butts
- R. P. Lessey
- E. L. Wagoner R. D. Calder
- 0. W. Lowe H. M. Warren (2)
F. Camp D. M. McAfee/
- N. H. Williams R. E. Camp P. E. Halstead D. R. Woodlan
- R. L. Cloud
- R. E. McCaskill R. A. Wooldridge 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. Ramsey
- J. Garibaldt J. D. Redding J. B. George D. M.Reynerson R. L. Grubb
- N. S. Reynolds H. A. Harrison
- K. L. Scheppele R. T. Jenkins H. C. Schmidt R. A. Jones March 2, 1987
- - First Class Mail