TXX-6447, Responds to NRC 870408 Request for Addl Info Re Violations & Deviations Noted in Insp Repts 50-445/86-15 & 50-446/86-12. Failure of Overview Insp to Note Inconsistency Was Oversight.Overview Inspector Received Addl Training
| ML20214G368 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/19/1987 |
| From: | Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-6447, NUDOCS 8705270040 | |
| Download: ML20214G368 (8) | |
Text
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M Log # TXX-6447 File # 10130 IR 86-15
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IR 86-12
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May 19, 1987 U. S. Nuclear Regulatory Commission 3
Attn: Document Control Desk Washington, D.C.
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SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 REQUEST FOR ADDITIONAL INFORMATION REGARDING INSPECTION REPORT: 50-445/86-15 AND 50-446/86-12 REF:
- 1) NRC Letter from E. H. Johnson to W. G. Counsil dated December 22, 1986.
- 2) TV Electric Letter TXX-6250 from W. G. Counsil to NRC dated February 2, 1987.
Gentlemen:
Your letter dated April 8,1987, requested additional information with respect to Item F.3 in the Notice of Violation (N0V) and Items B.2, C and D in the Notice of Deviation (N00) of Inspection Report 50-445/86-15; 50-446/86-12.
On April 27, 1987, per a telecon with your Mr. I. Barnes, we requested and received an extension until May 18, 1987.
On May 18, 1987, per a telecon with your Mr. I. Barnes, we requested and received an extension as follows:
Item F.3 (445/8615-V-08; 446/8612-V-08) extended until June 8, 1987.
On May 18, 1987, per a telecon with your Mr. Phil Wagner, we requested and received an extension as follows: Request For Additional Information Regarding IR 50 445/86-15 and 50-446/86-12 extended until May 22, 1987, with the following exception: Item F.3 (445/8615-V-08; 446/8612-V-08) extended untti June 8, 1987.
Where revised responses are provided, the revised sections are denoted by a revision bar in the right margin.
0705270040 870519 PDR ADOCK 0500 5
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TXX-6447 May 19, 1987 Page 2 of 2 We hereby respond to the above items in the attachment to this letter.
Very truly yours, b
W. G. Ccunsil By:
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G. S. Keeley Manager,NuclearLTcep/,
ing-RDD/gj Attachments c - Mr. R. D. Martin - Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV Mr. I.
Barnes, Region IV 1
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Attachment to TXX-6447 May 19, 1987 Page 1 of 6 RE0 VEST FOR ADDITIONAL INFORMATIQH MQTICE OF VIOLATION ITEM F.3 (445/8615-V-08: 446/0612-V-08)
NOV Item F.3: Your response was applicable to the use of "non-standard" forms only. The violation applied equally to the current and previous " standard" forms used to request fabricated items.
Please provide the previously requested information concerning both current and previously used " standard" forms.
NOTICE OF VIOLATION ITEM F.3 (445/8615-V-09: 446/8612-V-08)
F.
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 documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Contrary to the above:
B&R Procedures CP-CPM-7.3A, Revision 0, and CP-CPM-8.1, Revision 3, did not provide instructions relative to defining what information must be included on written requests to the onsite fabrication shop for fabricated items.
For example, the onsite fabrication shop has received requests for fabricated items en three-part memos that did not specify whether the item was Q or non-Q, ASME or non-ASME, its location and intended use, and whether it was temporary or permanent. This information is necessary to assure compliance with QA requirements.
(445/8615-V-08; 446/8612-V-08)
REVISED RESPONSE TO ITEM F.3 (445/8615-V-08: 446/8612-V-08)
In pursuing the requested additional information, we have determined that a revision to our original response is required to clarify our position.
Accordingly, a revised response, including the requested additional information will be submitted by June 8,1987.
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Attachment to TXX-6447 May 19, 1987 Page 2 of 6 RE0 VEST FOR ADDITIONAL INFORMATION i
NOTICE OF DEVIATION ITEM B.2 (445/8615-D-04)
N00 Item B.2: Your response did not provide the " Reason for Deviation" regarding the overview inspectors failure to compare results and identify apparent inconsistencies, nor did paragraph 2, " Corrective Steps Taken and Results Achieved," describe those corrective steps taken with respect to the overview inspectors failure to identify these same discrepancies.
Please provide this information.
NOTICE OF DEVIATION ITEM B.2 (445/8615-D-04)
B.
Section 4 of Revision 4 to ERC Procedure CPP-009 for Issue-Specific Action Plan No. VII.c states, in part, " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions...."
Section 4 of 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 Inspections of work performed in accordance with Reference 3.1 (CPP-009)...." Section 5.4.2 of ERC-QA-28 states, in part, " Based upon each accept / reject criterion specified in the referenced QI/ Effective Change Notice (s), the OI (Overview Inspector) denotes whether the item is (un) acceptable...."
Section 5.4.3 of ERC-QA-28 states, in part, "The 01 compares the results of the Overview Inspection with the results of the initial reinspection / documentation review to identify any apparent inconsistencies...."
In deviation from the above, the following errors were identified concerning the results of overview inspections:
2.
Paragraph 5.2.1 in Section 5.0 of QI-037, Revision 1, states, in part,
" Verify that pipe clamp halves are parallel...." In addition, of QI-037 states, in part, " S' dimensions on the same side of the clamp at points 1, 2 and 3 shall be within 1/16" of each other to be acceptable. Also, the clamp shall not be more than 1/16" out of parallel from side to side at points 1, 2 and 3 to be acceptable."
Measurements for S1 recorded by the initial ERC inspector showed a difference between points 1 and 3 of 1/8", which was 1/16" out of tolerance. Similarly, measurements recorded for S2 showed a difference between points 1 and 3 of 5/32", which was 3/32" out of tolerance. The corresponding values for the out of tolerance conditions recorded on ERC deviation report I-S-PS7N-095-DR1 were 1/32" and 1/16", respectively. The deviation report incorrectly identified the degree of being out of tolerance. The overview inspection failed to identify and resolve these discrepancies (445/8615-D-04).
Attachment to TXX-6447 May 19, 1987 Page 3 of 6 NOTICE OF DEVIATION REVISED RESPONSE TO ITEM B.2 (445/8615-D-04)
We admit to the deviation and the requested information follows:
1.
Reason for Deviation A review by ERC of deviation report I-S-PS7N-095-DR1 revealed that a mathematical error had been made by reinspection which resulted in an inaccurate description of the out of tolerance condition. The failure of the overview inspection to note the inconsistency was an oversight.
2.
Corrective Steos Taken and Results Achieved ERC performed an independent review of all completed Overview and associated Reinspection packages to ensure that all inconsistencies between the verification packages had been appropriately addressed.
3.
Corrective Steos Which Will Be Taken To Avoid Further Deviations The Overview Inspector discussed the above described mathematical error with reinspection. Deviation report I-S-PS7N-095-DR3 was initiated on September 16, 1986, superceding I-S-PS7N-095-DR1.
Deviation report I-S-PS7N-095-DR3 provides an accurate description of the out of tolerance condition.
Overview inspectors received additional training classes on July 9,1986, and July 31, 1986, specifically addressing concerns identified by the NRC and similar ERC audit findings.
4.
Date When Full Compliance Will Be Achieved Full Compliance was achieved on September 30, 1986.
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Attachment to TXX-6447 May 19, 1987 Page 4 of 6 RE0 VEST FOR ADDITIONAL INFORMATION NOTICE OF DEVIATION ITEM C (445/8615-D-05: 446/8612-D-06)
N0D Item C: Your response indicates that a deviation does not exist relative to the identification that an electrical inspector's recertification to CP-QP-11.3 did not specify the activities or restrictions which were applicable to the recertification. NRC review of a form entitled, "CPSES Level II Certification Listing All Applicable CP-QP-11.3 Procedures," for the inspector in question showed that the form was incomplete with respect to specifically denoting those procedures to which the inspector _was certified or restricted from. Accordingly, please provide the previously requested information.
NOTICE OF DEVIATION ITEM C (445/8615-D-05 AND 446/8612-D-06)
C.
Section 4.1 of ISAP No. I.d.1, Revision 2, states that for Phase I,
" Training, qualification, certification and recertification files for all electrical QC inspectors, for all current ASME inspectors, and for the remaining current non-ASME inspectors will be reviewed against project requirements...." to identify those inspectors whose certifications or qualifications were questionable.
In deviation from the above, the ERC Phase I review failed to identify lapses in recertifications of TUGC0 electrical inspectors.
ERC Phase 1 review also failed to identify that an electrical inspector's recertification to CP-QP-11.3 did not specify the activities or restrictions which were applicable to the recertification (445/8615-D-05; 446/8612-D-06).
NOTICE OF DEVIATION REVISED RESPONSE TO ITEM C (445/8615-0-05 AND 446/8612-D-06)
We admit to the deviation and the requested information follows:
1.
Reason for Deviation ERC has reviewed the NRC concern for the electrical inspector's certification records and agrees that a lapse had in fact occurred for a period of approximately eight (8) days for QI-QP-11.3-28, and approximately six (6) days for QI-QP-11.3-29, 40, and 44. The ERC failure to identify this discrepancy was due to an apparent oversight, therefore, a deviation does exist. However, confusion exists as to the exact date of recertification due to the many dates contained on the training forms.
Attachment to TXX-6447 May 19, 1987 Page 5 of 6 NOTICE OF DEVIATION REVISED RESPONSE TO ITEM C (445/8615-D-05 AND 446/8612-D-06) CONT'D ERC agrees with the NRC that the form entitled, "CPSES Level II Electrical Certification Listing Of All Applicable CP-QP-11.3 Procedures" was incomplete at the time of the ISAP I.d.1 phase I review. The form did not contain the required check mark (s) identifying the applicable procedures and revisions the inspector was certified to perform. However, another form, attached to the above form, entitled, " Quality Department Quality Control Recertification" stated, in part,..."the above named individual is hereby recertified and authorized to perform inspections at CPSES in the areas listed below:...All Electrical Related Listed on Following Page excluding QI-QP-11.3-42." Both forms were contained in the inspectors certification file.
2.
Corrective Steos Taken and Results Achieved ERC has prepared a memorandum (QA/QC-RT-5506, dated January 20,1987) addressing lapses in inspector certifications. TU Electric has initiated a generic Nonconformance Report, NCR No. M-86-104861 to address breaks in periods of certification. Additionally, the quality training supervisor has initiated a review of the TU Electric non-ASME file for certification lapses which includes the aforementioned deviation.
TU Electric corrected the form entitled, "CPSES Level II Electrical Certification Listing of All Applicable CP-0P-11.3 Procedures", on June 9, 1986.
3.
Corrective Steps Which Will Be Taken To Avoid Further Deviations ERC has provided memos addressing this generic problem of lapses in inspector certification. TU Electric is addressing this concern on a case by case basis as evidenced by NCR M-86-104861.
A review was performed for various ISAP I.d.1 inspector certification packages and no further discrepancies of this type were identified.
Therefore, this deviation was considered to be an isolated case and no further action was necessary.
4.
Date When Full Comoliance Will Be Achieved CPRT compliance was achieved on January 20, 1987. TV Electric compliance is on-going as evidenced by generic NCR M-86-104861 dated November 4, 1986.
Attachment to TXX-6447 l
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May 19, 1987.
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Page 6 of 6 RE0 VEST FOR ADDITIONAL INFORMATION NOTICE OF DEVIATION ITEM D (445/8615-D-10)
N0D Item D:
It is our understanding that additional information is being provided concerning N00 Item D.
NOTICE OF DEVIATION ITEM D (445/8615-0-10)
D.
Section 5.2 of QI-010, Revision 3, states, in part, " Verify that the field assembly / modifications are complete and in accordance with the applicable drawings."
i j
In deviation from the above, NRC _ inspection of Verification Package No. I-E-EEIN-075, a Unit 1 diesel generator control panel, revealed that ERC inspectors failed to identify the following:
j 1.
A jam nut was loose on one of the six floor mounting bolts.
2.
Sheet 2 of component layout Drawing 52383 did not delineate installed relays R12A and R128 (445/8615-D-10).
REVISED RESPONSE TO ITEM D (445/8615-D-10)
We deny the deviation for the' reasons'that follow:
1.
The loose jam nut is not considered to be within the scope of QI-010,
" REINSPECTION OF ELECTRICAL EQUIPMENT /EEIN". However,-QI-066, 1-
" REINSPECTION OF EQUIPMENT SUPPORTS", verifies that bolting used in construction of the equipment support or attaching the support to the-i building structure or equipment meets criteria such as attachments, materials, engagement, surface contact and torquing. Therefore, jam nuts i
would be covered by QI-066 not QI-010.
Based on the loose jam nut being identified by the NRC, an out-of-scope observation (No. 1065) was prepared on January 14, 1987.
Subsequently, TV i
Electric prepared nonconformance report (NCR No. CM-87-560-X) on January 27, 1987.
2.
Relays 12A and 12B are not shown on Drawing 52383 but are documented on DCA 17854, Rev. 2.
The sketches attached to the DCA which show the-location of these relays do not specifically identify which relay (12A and 12B are identical) is installed in which side of panel CPI-MEDGEE-01A (left or right). However, the ERC inspector. was able to discern the correct panel side location for relays 12A and 128 by examining the wiring diagrams attached to the DCA.
Relay 12A is shown on a wiring diagram as part of the Channel 1 Class IE Start Circuit whereas relay 128 is shown on another wiring diagram as part of the Channel 2 Class IE Start Circuit.
.The Channel'l Start Circuit diagram includes the statement " Located in Enclosure Left Side of Panel";-the Channel 2 diagram says " Located in Enclosure Right Side of Panel". Thus, the ERC inspector was -able to verify dimensional. location for relays 12A and 12B in the left and right sides of the panel, respectively.
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