TXX-6396, Responds to NRC Re Violations & Deviations Noted in Insp Repts 50-445/86-22 & 50-446/86-20.Corrective Actions:Required Certification for Valve Bonnet Received from Vendor & Placed in Appropriate Receipt Insp Package

Responds to NRC Re Violations & Deviations Noted in Insp Repts 50-445/86-22 & 50-446/86-20.Corrective Actions:Required Certification for Valve Bonnet Received from Vendor & Placed in Appropriate Receipt Insp Package

ML20209H643
Person / Time
Site:	Comanche Peak
Issue date:	04/27/1987
From:	Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-6396, NUDOCS 8705040077
Download: ML20209H643 (20)

Text

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i g M Log # TXX-6396 MM File # 10130

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IR 86-22 IR 86-20

# IO*'"'*I MIELECTRIC waim c. c-mu Executive Ykt Preskknt April 27, 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 INSPECTION REPORT NOS. 50-445/86-22 AND 50-446/86-20 Gentlemen:

We have reviewed your letter dated March 18, 1987, concerning the inspection conducted by Mr. I. Barnes and other members of the Region IV Comanche Peak i Group during.the period July 1 through August 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 April 15, 1987, per a telecon with your Mr. I. Barnes, we requested and l received an extension as follows: Item A (445/8622-V-02; 446/8620-V-03)  ;

extended until May 15, 1987.

On April 20, 1987, per a telecon with your Mr. C. Hale, we requested and received an extension as follows: IR 50-445/86-22 and 50-446/86-20 (4 violations, 6 deviations) extended until April 24, 1987, with the following exception: 445/8622-V-02; 446/8620-V-03 extended until May_ 15, 1987.

On April 24, 1987, per a telecon with your Mr. D. Hunnicutt, we requested and received an extension as follows: IR 50-445/86-22 and 50-446/86-20 (4 violations, 6 deviations) extended until May 1,1987, with the followina ,

exception: 445/8622-V-02; 446/8620-V-03 extended until May 22, 1987. ~'

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8705040077 870427 PDR ADOCK 05000445.

O PDR-5 6of i 400 North Olive Street LB 81 Dallas, Texas 75201 _jjl'

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e TXX-63S6 April 27, 1987 Page 2 of 2 We hereby respond to the Notices of Violations and Deviations in the attachment to this letter.

Very truly yours, 1 W. G. Counsil

{  !

By*

G. S.'Kee' ley N Manager, Nuclear LiceWsing RDD/gj c - Mr. E. H. Johnson - Region IV

, Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV Mr. I. Barnes - Region IV 3

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Attachment.to TXX-6396 April 27, 1987 Page 1 of 18 NOTICE OF VIOLATION ITEM A (445/8622-V-02: 446/8620-V-03)

Criterion VII of Appendix B to 10 CFR Part 50, as implemented by Section 7.0, Revision 4, dated July 31, 1984, of the TUGC0 Quality Assurance Plan (QAP),

requires that objective evidence of quality be furnished by the contractor or subcontractor, and that inspection be made at the source or upon delivery.

Documented evidence that material and equipment conform to the procurement requirements is required to be available at the nuclear plant site. The documentation is also required to be sufficient to identify the specific requirements of codes or standards met by the purchased material.

Section III of the ASME Boiler and Pressure Vessel Code, as imposed by Purchase Order (P0) CP-0077 for main steam safety valves, specifies in paragraph NA-4932 of Subsection NA that records of all heat treatments be maintained by the owner as permanent records.

Contrary to the above, records of heat treatments were not available for disc insert N91124-55-0322, which is part of main steam safety valve CP-2MS-021, and spare disc inserts N91124-40-0141 and N91124-40-0139. All main steam safety valves and associated documentation were source inspected and released under Quality Assurance Release (QAR) 2725. The total shipment, including the spare disc inserts, was received and documented in Receipt Inspection Report (RIR) 13686 which referenced QAR 2725; however, it was not apparent that the spare parts were inspected in either the QAR or RIR (445/8622-V-02; 446/8620-V-03).

RESPONSE TO ITEM A (445/8622-V-02: 446/8620-V-03)

Response will be provided by May 22, 1987.

. Attachment'to TXX-6396 April 27, 1987 Page 2 of 18 NOTICE OF VIOLATION ITEM B (445/8622-V-04)

Criterion XV of Appendix B to 10 CFR Part 50, as implemented by Section 15.0, Revision 5, dated October 17, 1985, of the QAP, requires that measures be established to prevent the inadvertent use of nonconforming items, and that these measures include procedures for identification, documentation, segregation, disposition, and notification to affected organizations. It further requires that nonconforming items be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures.

Paragraph 2.3.2 in TUGC0 Nuclear Engineering Instruction TNE-AD-5-2, Revision 7, states, in part, with respect to the dispositioning of NCRs, "The disposition shall clearly state what actions are necessary to resolve the nonconforming condition identified ...."

Contrary to the above, NCRs M-23175N, Revision 1, and M-23178N, dealing with installed bonnets on diaphragm valves, were incorrectly dispositioned and closed relative to necessary actions to resolve the identified nonconforming condition. The NCRs identified that the bonnets were not traceable to a Manufacturer's Data Report Form NPV-1 and that documentation was not available to show that the required ASME Code hydrostatic test had been performed. Part of the disposition on both NCRs, relative to justifying the acceptability of the bonnets, was the -

statement, "An acceptable bonnet hydro test was performed during the ,

System / Subsystem Hydro Test." The disposition statement is incorrect in ,

that the bonnets were isolated by the diaphragm from hydrostatic pressures during system /cubsystem tests. (445/8622-V-04)

RESPONSE TO ITEM B (445/8622-V-04)

TV Electric accepts the alleged violation and the requested information follows.

1. Reason for Violation l l

The violation resulted from an error by the individual who specified the '

dispositions of the subject Nonconformance Reports (NCRs). The individual failed to recognize that a system / subsystem hydrostratic test with the valve diaphragms installed would not subject the valve bonnets to test pressure.

2. Corrective Steos Taken and Results Achieved Revision 2 to NCR M-23175N was issued and closed on October 17, 1986. As documented by this revision, the required certification for the subject valve bonnet has been received from the vendor and placed in the appropriate receipt inspection package.

. Attachment'to TXX-6396 April 27, 1987

• Page 3 of 18 '

-- . g-NOTICE OF VIOLATION RESPONSE TO ITEM B (445/8622-V-04) CONT'D , *

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Revision 1 to NCR M-23178N was issued on November 19, 1986. Per this revision a new valve bonnet with the required certification documents has

been ordered from the vendor. The old valve bonnet,will be scrapped.

L A review of a sample of previously dispositioned NCRs was conducted as part of the corrective action for Corrective Action Report (CAR)-062.

This CAR had been previously issued to address the adequacy of NCR 1 . dispositions. The rediew effort provided assurance that the disposition of NCRs processed at CPSES has not resulted in any safety concerns.

3 Additionally, Stone and Webster Engineering Ccrporation has commenced a review of NCR's dispositioned prior to the implementation of corporate 4

procedure NE0 3.05, " Reporting and Control of Nonconformances." The purpose of this review is to determine the technical adequacy of NCR dispositions affecting engineering requirements for NCR's that are not the subject of other engineering reverification efforts. This review is being i conducted in conjunction ~with a previously identified concern under the

provisions 10CFR50.55(e) and is being tracked by Significant Deficiency Analysis Report (SDAR) CP-86-48. _

3. Corrective Steos Which Will Be Taken To Avoid Further Violations The individual who specified the disposition of the subject NCRs has been made aware of the error.

I The improper disposition of the two NCR's occurred in July of 1986. On December 22, 1986, corporate procedure NE0 3.05 and Revision 8 to

, implementing procedure ECE-AD-5-2, " Processing of Nonconformance-Reports,"

l were made effective. These procedures require an independent engineering review of " repair" or "use-as-is" dispositions. The disposition category "other," which was used on the subject NCRs, has been eliminated. A 4 review by the Engineering Discipline Unit Manager was also added by these i procedures. Thus, our revised NCR program provides additional reviews to -

detect the type of error which resulted in this violation.- Training on NE0 3.05 and Revision 8 to ECE-AD-5-2 has been completed.

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4. Date When Full Compliance Will Be Achieved Replacement of the valve bonnet per NCR M-23178N will be completed no

later than November 30, 1987.

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. Attachment'to TXX-6396 April 27, 1987

- Page 4 of 18 s

NOTICE OF VIOLATION

ITEM C (446/8620-V-02)

Criterion III of Appendix B to 10CFR50, as implemented by Section 3.0, Revision 4, dated November 20, 1985, of the TUGC0 QAP, states, in part,

" Measures shall be established to assure that applicable regulatory requirements and the design basis ...are correctly translated into specifications, drawings, procedures, and instructions ...The design control measures shall provide for verifying or checking the adequacy of design, such as by the ... performance of suitable testing program ..."

• Memorandum No. BSC-2156, which references Section 6.2. Of Revision 8 to Bahnson Service Company (BSC) Procedure DFP-TUSI-003, states, "The following i shall be considered a part of the subject procedure: All groove welds on the.

seismic duct hanger detail drawings shall be shown as square groove welds.

l Unless otherwise stated the weld shall be considered partial penetration. No 3 size will be shown. Per the attached test results a penetration of not less i than 1/8" (0.125") is achieved. These test results with coupons are retained in DCC."

Contrary to the above, the following conditions were identified:

1. The original test program documentation did not assure that testing was performed in such a manner so as to provide for a correct assessment of the depth of partial penetration. Further, the test coupons were not

retained in the Document Control Center (DCC) and could not be located.

2. Macroetch testing, witnessed by the NRC inspector, was performed on five l additional weld samples which were welded with a 3/32" electrode in the vertical position using BSC Welding Procedure Specification BSC-20. The results of this testing revealed a maximum partial penetration of 0.047", i which is 0.078" less than the claimed penetration used for analysis.

(446/8620-V-02).

! RESPONSE TO ITEM C (446/8620-V-02)

TU Electric accepts the alleged violation and the requested information follows:

1. Reason for Violation Bahnson welding and quality control procedures did not provide adequate controls for installation activities associated with seismic HVAC duct supports. Specifically, fit-up gap requirements were not specified nor were fit-up inspections of full or partial penetration welds required.

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Attachment'to TXX-6396

- April 27, 1987 Page 5 of 18 NOTICE OF VIOLATION RESPONSE TO ITEM C (446/8620-V-02) CONT'D

2. Corrective Steos Taken and Results Achieved Existing square groove welds will be considered nonstructural welds incapable of supporting design loads. All square groove welds will be identified and modifications made where necessary to meet structural design requirements. For new HVAC support installations and/or those subject to rework, Ebasco is preparing construction procedures which will specify fit-up gap requirements and ensure fit-up inspections of full and partial penetration welds.

- 3. Corrective Steos Which Will Be Taken To Avoid Further Violations As a result, in part, of this NOV and similar program deficiencies, CAR-111 was issued citing inadequate engineering, construction, and quality control programs for Bahnson HVAC ductwork and equipment at CPSES, Units 1 and 2. Resolution of CAR-111 requires that all Unit 1 and Common HVAC ductwork and supports in Category I buildings will be field verified, design verified, and reinspected in accordance with procedures TNE-FVM-CS-029, " Field Verification Method Procedure for Seismic HVAC Duct and Duct Hanger As-Built Verification in Unit I and Common Areas," QI-QP-11.14-14,-

" Verification / Inspection of Seismic HVAC Systems," and QI-QP-11.14-1,

" Inspection of Site Fabrication and Installation of HVAC Systems, 2

Structural and Miscellaneous Steel." Ebasco has ' assumed responsibility for

all engineering and design activities associated with this effort. TU j Electric has assumed responsibility for the quality control programs. A similar action plan is being developed for the Unit 2 HVAC system.

1 Bahnson has been relieved of all responsibility for engineering,

) construction, and quality control activities at CPSES as a result of the j deficiencies identified in CAR-111 and reported pursuant to 10CFR50.55(e)

(SDAR: CP-85-54).

4. Date When Full Comoliance Will be Achieved The corrective action program for Unit I and Common HVAC as described above is scheduled to be completed by March 1988. The corrective action program for Unit 2 is scheduled to be completed by July 1988, i

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Attachment'to TXX-6396 April 27, 1987 Page 6 of 18 NOTICE OF VIOLATIO3 ITEM D (445/8622-V-16: 446/8620-V-07)

D. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 QAP, requires that activities affecting quality shall be prescribed by and accomplished in accordance with the documented instructions, procedures, or drawings of a type appropriate to the circumstances.

Paragraphs 3.1.7 and 3.1.8 of Procedure MCP 10, Revision 9, " Storage and Storage Maintenance of Mechanical and Electrical Equipment," states, in part, " Items in storage (outside) shall have all covers, caps, plugs, or other closures intact ... Carbon steel piping material or structural tubing shall not be capped."

Contrary to the above, during an NRC inspection on July 10, 1986, of outside pipe storage on the north side of Warehouse C, four pieces of

, stainless steel pipe (Heat Nos. 670757, 05826, 713577, and F11744) were found with pipe end covers or caps not intact and several pieces of carbon steel pipe were found that were capped. The pipe fabrication shop also had stainless steel piping and tubing stored in the Warehouse C area, as well as in an area behind the Welder's Qualification Training Center, that had damaged, loose, and deteriorated tape for end coverings. (445/8622-V-16; 446/8620-V-07).

RESPONSE TO ITEM D (445/8622-V-16: 446/8620-V-07)

TV Electric accepts the alleged violation and the requested information follows:

1. Reason for Violation The portions of the violation concerned with missing or damaged caps on stainless steel piping were caused by a failure of personnel to maintain the material protection provisions of procedure MCP-10, " Storage and Storage Maintenance of Mechanical and Electrical Equipment." Some of the materials used to cap the pipes can deteriorate with time and exposure.

Warehouse personnel performing periodic surveillances inadvertantly overlooked the damaged and missing caps.

The portion of the violation concerned with improper capping of carbon steel pipe was caused by the failure of warehouse personnel performing surveillances to note the four installed caps during their surveillance of all onsite material.

The following is submitted to address NRC concerns expressed in Appendix C of the Inspection Report regarding a statement by the Warehouse Manager.

. Attachment'to TXX-6396 April 27, 1987 Page 7 of 18 NOTICE OF VIOLATION RESPONSE TO ITEM D (445/8622-V-16: 446/8620-V-07) CONT'D The prohibition involving capping carbon steel pipe was added to procedure MCP-10 in February of 1985. It is believed that the subject pipe was received with caps installed prior to that time, since current practice is to remove any vendor installed caps. The Warehouse Manager's explanation of these events to the NRC inspector was not adequate in that it resulted in the inspector believing that the current practice is to leave vendor s installed caps installed on carbon steel piping.

2. Corrective Steos Taken and Results Achieved

! The Warehouse Manager who accompanied the NRC inspector has overseen the re-installation of caps on the stainless steel piping and has had the caps removed from the carbon steel piping. No NCRs were 4ssued as the conditions were corrected immediately.

3. Corrective Steos Which Will Be Taken To Avoid Further Violations Warehouse personnel have been retrained on the requirements of MCP-10 concerning capping of stainless steel and carbon steel pipe, and specific surveillance requirements.

Pipe fabrication shop personnel have been retrained on the requirements of MCP-10 concerning capping of stainless steel and carbon steel pipe.

Document Change Notice No. I has been issued to MCP-10, Rev. 9 to authorize several methods for capping stainless steel pipe. The change will allow warehouse personnel to utilize alternate and improved methods for keeping caps in place.

4. Date When Full Compliance will be Achieved Full compliance had been achieved prior to April 1,1987.

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Attachment'to TXX-6396 April 27, 1987 Page 8 of 18 l

NOTICE OF DEVIATION ITEM A (445/8622-D-01: 446/8620-D-01)

TUGC0 letters dated January 15 and April 1, 1986, were submitted to the NRC in response to NRC Inspection Report 50-445/85-11; 50-446/85-06. Commitments in these letters with respect to Item A of the Notice of Deviation included, "The completed objectivity criteria forms...for the Senior Review Team, Review Team Leaders and support staff are available in the CPRT central file..."; and

... appropriate CPRT parties will fill out forms documenting their review of

, completed objectivity forms....These forms will be completed by the end of April 1986."

In deviation from the above, (1) support staff for the CPRT Program Director and personnel on the records review committee have not completed their objectivity criteria forms, (2) the review of the completed objectivity forms by the appropriate CPRT party had not been completed for the CPRT Program Director, and (3) review of the TERA Review Team Leader's form was not completed until July 17, 1986 (445/8622-D-01;446/8620-0-01).

RESPONSE TO ITEM A (445/8622-D-01:446/8620-0-01)

TV Electric denies (2) in the Notice of Deviation for the following reason which provides clarification to the January 15, 1986, letter (TXX-4667) 1 referenced above:

CPRT Program Plan, Revision 3,Section VII. "CPRT OBJECTIVITY GUIDANCE",

states, in part..."With the exception of the Chairman of the SRT and the CPRT Program Director, the CPRT third-party organization is comprised of personnel who are affiliated with organizations external to TUEC...The CPRT Program Director, ...provides day to day coordination of CPRT activities on behalf of the SRT." Therefore, as stated by exception in the CPRT Program Plan, Revision 3, the CPRT Program Director and the Chairman of the SRT are exempt from completing Objectivity forms.

TV Electric accepts the alleged items (1) and (3) in the Notice of Deviation and the requested information follows:

1. Reason for Deviation Item (1): This deviation occurred as a result of the CPRT Program Director's interpretation that objectivity forms were not required for those support personnel who were not directly involved with the third party review of CPSES.

- -Attachment'to TXX-6396

, April 27,~1987 i Page 9 of 18 NOTICE OF DEVIATION RESPONSE TO ITEM A (445/8622-D-01: 446/8620-D-01) CONT'D Item (3) A review of the completed Objectivity form for the TERA

, Review Team Leader (RTL) was not completed by the CPRT

Program Director until July 17, 1986.' This deviation

., occurred because the TERA RTL Objectivity form was not i received by the CPRT central file until late June.of 1986.

! However, the TERA RTL was approved by the SRT in Revision j 1 to the CPRT Program Plan dated 11/16/84.

2. Corrective Steos Taken and Results Achieved ,

i Item (1): All technical support staff for the CPRT Program Director

as well as the Results Report Review Committee have j completed objectivity forms. These forms are contained in

the CPRT file.for NRC review. l

[ Item (3): No corrective steps are necessary since the objectivity review was performed and completed on July 17, 1986.

3. Corrective Steos Which Will Be Taken To Avoid Further Deviations A review of the CPRT central file (5.A, 5.B, and 5.C) was performed on

, March 23, 1987, to ensure that all SRT members, (excluding the Chairman j and the Program Director), RTLs, and CPRT support staff had approved Objectivity forms contained in the file. The review indicated that personnel records were in compliance with the CPRT Program Plan.

i 4. Date When Full Comoliance Will Be Achieved i

j Full compliance had been achieved prior to April 1, 1987.

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Attachment'to TXX-6396 April 27, 1987 Page 10 of 18 NOTICE OF DEVIATION ITEM B (445/8622-D-03: 446/8620-D-04)

Paragraph 4.1.2.2 of Issue-Specific Action Plan (ISAP) VII.b.1, Revision 2, states, in part, " Review the completed fabrication packages for the selected pieces for adequacy of... fabrication and inspection sign offs".

Items 6 & 7 of the checklist used to implement the above review require the ERC documentation reviewers to list all inspectors and welders involved with the package being reviewed, together with related information such as dates work was performed, certifications, and qualifications.

In deviation from the above, an ERC document reviewer's completed checklist for documentation package RH-1-063-010-S22R did not list four inspectors and two welders that had performed work related to the package being reviewed, nor was the required information provided (445/8622-D-03; 446/8620-0-04).

RESPONSE TO ITEM B (445/8622-D-03: 446/8620-D-04)

TV Electric accepts the alleged deviation and the requested information follows:

1. Reason for Deviation The failure to list four inspectors and two welders on the ERC document reviewer's checklist for documentation package RH-1-063-010-S22R was due to an oversight on the part of the ERC document reviewer.

2. Corrective Steos Taken and Results Achieved Documentation Package RH-1-063-010-S22R was corrected at the time of discovery to include the four inspectors and two welders. Additionally, all document reviews that were performed by the responsible ERC document reviewer were re-reviewed by another ERC VII.b.1 document reviewer.

3. Corrective Steos Which Will Be Taken To Avoid Further Deviations

. No additional document reviews were performed by the responsible ERC document reviewer for ISAP VII.b.I or any other ISAP. Therefore, no other corrective steps were taken since this deviation was considered to be an isolated case.

4. Date of Full Comoliance August, 1986.

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. Attachment'to TXX-6396 i April 27, 1987 Page 11 of 18 NOTICE OF DEVIATION-ITEM C (445/8622-D-06)

Table 3.2-1 in Section 3 of Amendment 56 to the CPSES FSAR requires that Class 2 and 3 valves meet the requirements of the 1974 Edition of Section

III of the ASME Code.

In deviation from the above, Westinghouse Purchase Order (P0) 546-CCA-L 191000-XN specified the applicable code requirement to be the Summer 1972 Addenda to the 1971 Edition of Section III of the ASME Code for the procurement of Class 2 and 3 ITT Grinnel diaphragm valves. The vendor furnished valves in accordance with this requirement as evidenced by the NPV-1 form for Valve Tag 1-7046 which states, "The material design, construction and workmanship complies with ASME Code Section III Class 3, 1971 Edition, Summer 1972 Addenda" (445/8622-D-06).

RESPONSE TO ITEM C (445/8622-D-06)

TU Electric accepts the alleged deviation and the requested information follows:

1. Reason for Deviation The deviation was caused by an error in the Final Safety Analysis Report

(FSAR). The subject valves are technically acceptable. Westinghouse j' Purchase Order 546-CCA-191000-XN was issued on April 14, 1973. The FSAR commitment fails to recognize that Class 2 and 3 valves were ordered prior i to issuance of the 1974 Edition. of Section III of the ASME Code.

j 2. Corrective Steos Taken and Results Achieved i

i Deficiency Report (DR) C87-1980 has been written to document the discrepancy. Comanche Peak Engineering (CPE) has initiated preparation of an FSAR change request to correct the.FSAR error.

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3. Corrective Steos Which Will be Taken to Avoid Further Deviations CPE will review FSAR Table 3.2-1 for similar errors. Any additional

errors will be documented by DRs, and FSAR change requests will be initiated as required.

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4. Date When Full Comoliance Will be Achieved The review of FSAR Table 3.2-1 and the initiation of all DRs and change requests will be completed by June 1, 1987.

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The advance change to the FSAR will be provided by letter or an FSAR Amendment will be issued to correct Table 3.2-1 by June 30, 1987.

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Attachment.to TXX-6396 Ap'ril' 27,1987 Page 12 of 18 NOTICE OF DEVIATION ITEM D (445/8622-D-09)

Section 4.3.3 of ISAP VII.c states, in part, "For each population, attributes which have safety significance will be determined... Justification for not including attributes in the reinspection or documentation review checklists which have been identified as nonsafety significant will be documented and retained, detailed instructions for the verification of the attribute, including definitive accept / reject criteria, will be established..."

In deviation from the above, ERC engineering, during review of historical documentation pertaining to Verification Package I-M-MEIN-107, failed to address the following work activities with respect to safety significance, (1) thread engagement for Richmond insert stud bolts used for equipment anchoring, (2) torquing requirements which were documented by construction operation travelers, and (3) installation of oil cooler piping which was documented by a construction operation traveler. There was no documented justification for not including these attributes in the checklists nor were detailed instructions established for attribute verification (445/8622-D-09).

RESPONSE TO ITEM D (445/8622-D-09)

TV Electric accepts the alleged deviation and the requested information follows:

1. Reason for Deviation (1) During a review of verification package I-M-MEIN-107, Unit 1 positive displacement charging pump TBX-CSAPP0-01, the NRC noted that Richmond inserts had been used instead of imbedded anchor bolts in two of the twelve anchor bolt locations on this equipment. It was also noted that these two locations were reinspected as though embedded anchor bolts had been used and that QI-059, Reinspection of Mechanical Equipment Installation, does not include reinspection criteria for Richmond inserts.

QI-059 does not include any reinspection criteria specifically for Richmond inserts because it is highly unusual for such anchoring devices to be used on mechanical equipment. Furthermore, other populations [Large Bore Pipe Supports-Non Ridged (LBSN), Large Bore Pipe Supports-Ridged (LBSR), Small Bore Pipe Supports (SBPS),

large Bore Pipe Whip Restraints (PWRE), Structural Steel (STEL)]

were known to be inspecting these inserts in sufficient quantity to permit the adequacy of Richmond insert installation to be determined.

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. Attachment'to TXX-6396 April 27, 1987 Page 13 of 18 l

NOTICE OF DEVIATION 1 RESPONSE TO ITEM D (445/8622-D-09) CONT'D Therefore, the LBSN, LBSR, SBPS, PWRE, and STEL~ populations have i already conducted sufficient Richmond insert reinspections to support conclusions for this particular construction work ,

activity. '

i (2) Step 1 of COT ME83-1532-4900, which was included in the package, states "Retorque nuts on cylinder heads and discharge valve covers per Attachment 1 to highest value in table." Attachment 1 is an excerpted generic procedure from the manufacturer's instruction <

manual that provides bolt torquing instructions and values for various bolt sizes and bolting patterns. The COT was included in 3~

the package because this attachment had information relevant to pedestal bolt torque, which was reinspected. This COT was annotated to explain that it only applied to head valve cover #9.

- The manufacturer's installation instructions and drawings make no a

mention of the field installation of these covers.

Because the above-mentioned COT used the word "retorque" and because it was limited to cover #9,- other Cots applicable to this i pump were reviewed in an attempt to discover the reason for

! retorquing this cylinder head cover. COT ME83-1533 described torque checks on the other cylinder head covers and included an explanatory note which stated that the work was being done because the cylinder head cover gasket on cover #9 had been replaced.

Other Cots were found which described the replacement of other pump componeints, e.g., oil seals.

The torque on cylinder head cover bolts was not included as an item to be checked during reinspection because the fact that the word "retorque" was used, coupled with the fact that COT ME83-1 1532-4900 was limited to cover #9, indicated to the package preparer that this particular evolution was a maintenance or i repair activity, and such activities were assumed to be outside l the scope of the QA/QC reinspection effort. Subsequent

discussions held to clarify the scope of this effort and ensure

! consistency among the various reinspection populations resulted in l the determination that completed repairs and modifications are i

construction activities subject to reinspection.

l (3) Available installation documentation for this pump was reviewed to 4 determine if the oil cooler had been installed on the pump skid by the manufacturer or if installation had been performed by Brown &

Root. Union Pump assembly drawing PCN753719B clearly shows the oil cooler in place adjacent to the pump baseplate and included a

note stating that oil cooler piping is furnished by Union Pump.

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Attachment.to TXX-6396 ApYil 27, 1987 Page 14 of 18 NOTICE OF DEVIATION RESPONSE TO ITEM D (445/8622-D-09) CONT'D However, another note on the same drawing indicates that the cooler is to be mounted immediately adjacent to the baseplate with the orientation as shown and describes the anchor bolts to be used. Revision 3 to Construction Operation Traveler (C0T) ME78-101-4901 states " oil cooler added on Attachment 2...", and Revision 4 to this COT states " install oil cooler piping per Union Pump drawing L-D6732 Rev. A..."

The note on drawing PCN7537198, regarding oil cooler piping furnished by Union Pump, was misinterpreted to mean that the oil cooler and associated piping had been preassemblied by the manufacturer. Since manufacturers' drawings of this type frequently describe assembly steps performed in the manufacturers' shop, as well as field installation steps, the other note on this drawing, regarding oil cooler mounting, was assumed to relate to shop assembly. The COT steps relating to oil cooler and piping installation were inadvertently overlooked.

2 Corrective Steos Taken and Results Achieved (1) There was no corrective action regarding Richmond inserts specifically for package I-M-MEIN-107. However, Richmond inserts have been identified as a Specific Technical Issue as a result of both ISAP V.b and the reinspection performed under ISAP VII.c. A reinspection program covering Richmond insert installation is being prepared by the CAP project to address this issue.

(2) & A review of all COTS, Design Change Authorization (DCAs), TU (3) Electric Maintenance Action Requests (MARS), and other documents describing repair or modification work performed on this pump was conducted and the verification package was reissued on June 6, 1986, with appropriate supplemental instructions as stated below.

Verification Package I-M-MEIN-107 was re-submitted to inspection on June 6, 1986, with appropriate supplemental instructions addressing the levelness, orientation, configuration, and anchoring of the oil cooler; the configuration of the oil cooler piping; and the tightness of the piping connections. Appropriate supplemental instructions were also included to address any repairs or modifications which were accessible for reinspection.

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, . Attachment to TXX-6396 April 27, 1987 Page 15 of 18 NOTICE OF DEVIATION RESPONSE TO ITEM D (445/8622-D-09) CONT'D

3. Corrective Steos Which Will Be Taken to Avoid Further Deviations (1) Regarding Richmond inserts, there is no action to prevent recurrence specifically for the MEIN population. However, the CAP reinspection program mentioned above will address Richmond insert installation.

(2) & (3) Regarding other accessory installations and equipment modifications / repairs, such as oil cooler installation and head bolt torquing, the action to prevent recurrence included the review of all MEIN packages. This review, identifying accessory installations, modifications, and repairs, has been completed and all MEIN packages have been reinspected.

4. Date of Full Comoliance December 31, 1986 l

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. Attachment'to TXX-6396  ;

April 27, 1987 Page 16 of 18 NOTICE OF DEVIATION ITEM E (445/8622-0-10)

Section 5.1 of ERC Procedure CPP-010, Revision 7, states, in part, with respect to ISAP VII.c, " Inspectors shall identify the hardware associated with each (construction) deviation by attaching a tag in a conspicuous location..."

In deviation from the above, the NRC inspector observed that positive displacement pump TBX-CSAPPD-01, Verification Package I-M-MEIN-107, was not tagged even though eight deviation reports had been issued with respect to noncomplying nut torque requirements and mechanical coupling alignment (445/8622-D-10).

RESPONSE TO ITEM E (445/8622-D-10)

TU Electric accepts the alleged deviation and the requested information follows:

1. Reason for Deviation Per the guidelines established in CPP-010, " PREPARATION OF DEVIATION REPORTS", ERC inspectors are required to attach a tag which identifies hardware associated with (construction) deviations. With respect to this particular deviation we have no reason to believe that ERC inspection personnel did not place deviation tags identifying the noncomplying conditions associated with pump TBX-CSAPPD-01. However, there were no ERC deviation tag (s) present at the time the NRC inspector reviewed Verification Package I-M-MEIN-107. Therefore, the ERC tags had fallen off or were inadvertently removed.

The purpose of placing ERC deviation identification tags on hardware is to assist TV Electric in identifying the deviating hardware for their control.

2. Corrective Steos Taken and Results Achieved Based on the Deviation Reports written by ERC, TV Electric placed hold tag (s) on TBX-CSAPPD-01 as evidenced by nonconformance report M-25151N.

3. Corrective Steos Which Will Be Taken To Avoid Further Deviations A memo will be prepared from CPRT to TV Electric emphasizing the nature and significance of ERC deviation tags.

4. Date of Full Como11ance June 1, 1987

. Attachment'to TXX-6396 April 27, 1987 Page 17 of 18 NOTICE OF DEVIATION ITEM F (445/8622-D-14) i Section 4. of ERC Procedure CPP-009, Revision 4, states, in part, with respect to ISAP VII.c., " 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 onsite QA Representative perform Overview Inspection of work performed in accordance with Reference 3.1 (CPP-009)...." Section 5.4 states, in part, " Based upon each accept / reject criterion specified in the referenced QI/ Effective Change Notice (s), the 01 (Overview Inspector) denotes whether the item is (un) acceptable...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, Overview Inspection Package I-M-B-SBCO-121 failed to identify two unsatisfactory decisions made by the initial ERC ins)ector.

During an NRC inspection, two conditions were identified of pipe-to-1 anger clearance violations of Section 5.2.6 in Revision 2 of QI-026. The initial ERC reinspection as well as the overview inspection failed to identify these deviating conditions (445/8622-D-14).

RESPONSE TO ITEM F (445/8622-D-14)

TU Electric accepts the alleged deviation and the requested information follows:  ;

1. Reason for Deviation Investigation by ERC confirmed the NRC findings.

Based upon a documentation review of available insulation installation / removal records associated with isometric RH-1-SB-011, it appears that this deviation was caused by inspector error. This documentation review identified several adjacent areas on the piping where insulation had been removed after the ERC inspection but prior to the-NRC inspection. However, no insulation removal activities were documented in the areas identified by the NRC.  ;

2. Corrective Steos Taken and Results Achieved Deviation Report (DR) I-M-SBCO-121-DR-3 was initiated on April 7, 1987, to document the clearance deviations, i

o Attachment'to TXX-6396 April 27, 1987 Page 18 of 18 NOTICE OF DEVIATION RESPONSE TO ITEM F (445/8622-D-14) CONT'D

3. Corrective Steos Which Will Be Taken to Avoid Further Deviations The findings were discussed with the responsible Overview Inspector and Reinspectors on August 4, 1986, and March 31, 1987, respectively.

4. Date of Full Comoliance Full compliance was achieved on April 7,1987.

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