TXX-6468, Responds to NRC Re Violations Noted in Insp Repts 50-445/86-22 & 50-446/86-20.Corrective Actions:Documentation Supplied W/Purchase Order CP-0077 Reviewed for Compliance & Receipt Insp Program Reviewed for Adequacy of Instruction

Responds to NRC Re Violations Noted in Insp Repts 50-445/86-22 & 50-446/86-20.Corrective Actions:Documentation Supplied W/Purchase Order CP-0077 Reviewed for Compliance & Receipt Insp Program Reviewed for Adequacy of Instruction

ML20215H123
Person / Time
Site:	Comanche Peak
Issue date:	06/15/1987
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-6468, NUDOCS 8706240010
Download: ML20215H123 (3)

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RIELECTRIC June 15, 1987 i mmun c. counsu i

Esecutive Vice Preskkne U. S. Nuclear Regulatory Commission . l

. Attn: Document Control Desk d?

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l Washir.gton, 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. 50-445/86-22AND50-446/86-20 Gentlemen:  !

We have reviewed your letter dated March 18, 1987, concerning the inspection conducted by Mr. I. 8arnes and other members of the Region IV Comanche Peak Group during the period July. I 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. Attachedsto your letter were Notices of Violations and Deviations.

On April 24, 1987, per a telecon with your Mr. D. Hunni:utt, we requested and received an extension for'445/8622-V-02; 446/8620-V-03 until May 22, 1987. s On May 22, 1987, per a telecon with Mr. Shannon Phillips, we requested and received an. extension for 445/8622-V-02; 446/8620-V-03 until June 15, 1987.

We hereby respond to the Notice of Violation in the attachment to this letter.

Very truly yours, x W. G. Counsil RDD/dl Attachment c - R. D. Martin, Region IV Resident Inspectors, CPSES (3) h N DO J G

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400 Nonh Olive Street LB 81 Dallas, Texas 75201

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f q7:' Attachment to TXX-6468-d June 15, 1987 Page 1 of 2

. NOTICE OF VIOLATION n

ITEM'A-(445/8622-V-02: 446/8620-V-03) d ( '

' Ac' Criterion VII of Appendix C. to 10 CFR Part 50, as implemented by Section 7.0, Revision 4, dated July'31,1984, of the TUGCo Quality Assurance Plan 1 4 (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 l 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 l P.urchase 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 l V

mein steam' safety valves and as~sociated' documentation were source .!

.',' inspected and released under Quality Assurance Release (QAR) 2725. The total. shipment, including the spare disc inserts, was received and s

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. s(445/8622-V-02; 446/8620-V-03).

RESPONSE TO ITEM A JM5/8622-V-02: 446/8620-V-03) 3, TU Electric agrees to the alleged violation and the requested information

, follows: J j

1. Reason For.;Mj_olation j QC receiving inspection personnel failed to verify that heat treatment results for valve disk inserts furnished under Purchase OrdeP (P0) CP-0077 i and Sp'ecification 2323-MS-77 were documented on the Certified Material Test Reports (CMTR) supplied with these items. The reason for this failure cannot be conclusively determined. .

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Attachment to TXX-6468 June 15, 1987 Page 2 of 2 l

NOTICE OF VIOLATION RESPONSE TO I1EM A (445/8622-V-02: 446/8620-V-03) CONT'D

2. Corrective Steps Taken And Results Achieved Documentation supplied with the main steam safety valves and spare parts furnished under P0 CP-0077 for both Unit 1 and 2 (20 valves each) has been reviewed to verify compliance with P0 requirements. As a result of this review, nonconformance documents NCR-M-28324 and CDRs 87-4161, 87-4162 and 87-5655 were initiated to resolve discrepancies identified. These discrepancies included: additional disk insert CMTRs which did not specify that heat treatment was performed, results of magnetic particle tests of Unit 1 valve springs were not available, and all Unit I disk insert serial numbers were not referenced on the Certificate of Compliance.

3. Corrective Steos Which Will Be Taken To Avoid Further Violations The current Receipt Inspection Program was reviewed to determine the adequacy of the inspection instruction contained for material received when source inspection is waived, as occurred with the main steam safety valve spare parts by Quality Assurance Authorization Number 38 dated October 2, 1978. The current Receipt Inspection Program contains sufficient instruction to prevent recurrence of this violation.

The revision (Revision 1) of ISAP VII.a.9 discussed in the details of the NRC inspection report has been completed. ISAP VII.a.9 Revision 1 was implemented on September 18, 1986 and includes provisions for review of vendor-supplied documents. Based on the results of ISAP VII.a.9 further corrective steps may be initiated.

4. Qate When Full Comoliance Will Be Achieved The schedule for completion of ISAP VII.a.9 is August 31, 1987. Further response delineating any required additional corrective action will be provided by October 1, 1987. The nonconformance documents identified as a result of the main steam safety valve document review described above will be dispositioned by September 18, 1987.

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