TXX-6472, Responds to NRC Re Violations Noted in Insp Repts 50-445/86-26 & 5-446/86-22.Corrective Actions:Nonconformance Repts Written to Document Specific Welder Qualification Deficiencies & Corrective Action Request Issued

Responds to NRC Re Violations Noted in Insp Repts 50-445/86-26 & 5-446/86-22.Corrective Actions:Nonconformance Repts Written to Document Specific Welder Qualification Deficiencies & Corrective Action Request Issued

ML20214T702
Person / Time
Site:	Comanche Peak
Issue date:	06/05/1987
From:	Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-6472, NUDOCS 8706100384
Download: ML20214T702 (19)

Text

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- Log # TXX-6472

--- 9 File # 10130

-. __. IR 86-26

= r IR 86-22

" # I0" *I lilELECTRIC

,,, June 5, 1987 I muine Vwe Vrraknr 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 INSPECTION REPORT NOS. 50 445/86-26 AND 50 446/86-22 Gentlemen:

We have reviewed your letter dated April 2,1987, concerning the inspection conducted by Mr. I. Barnes and other members of the Region IV Comanche Peak Group during the period September 1 through October 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, Deviations and one Unresolved item.

On April 27, 1987, por a telecon with your Mr. I. Barnes, we requested and received an extension as follows: IR 50 445/86-26 and 50 446/86 22 (3 violations, 5 deviations and I unresolved item) extended until June 5, 1987.

We hereby respond to the Notice of Violations, Deviations and one Unresolved Item in the attachment to this letter.

Very truly yours, I h asJ $

W. G. Cot sil Dy:

07 Kii6 Toy /

RDD/gj Hanager, Nuclea7T niing c - Mr. R. D. Martin - Region IV CPSES Resident inspectors - 3 copies tr/06100304 U/0605 l DH ADUCK 0000 44U .

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ten htth Olar Sotert iIt nl IktIne, Teens H:01

l Attachment to TXX-6472

• June 5, 1987

. Page 1 of 18 NOTICE OF VIOLATION ITEM A (445/8626-V-02)

A. Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGCo Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, l

or drawings of a type appropriate to the circumstances.

I Paragraph 3.1.2.e of TUGC0 Procedure QI-QP-ll.3-40, Revision 14, dated l January 9,1984, states, in part, " Verify that . . . all cable pulling aids have been removed (i.e., fish tape, tape rope, etc.)."

l Paragraph 3.1.1.2.c of the above procedure, Revision 18, dated May 18, 1984, states, " Verify that . . . pulling aids (i.e., rollers, fish tape, I tag rope) have been removed from raceway."

l Contrary to the above, TUGC0 inspectors performing post construction l inspections failed to identify cable pulling ropes remaining in Class IE 1 l conduit C12018896 and Class IE cable tray T130ACG57 located in the Unit I reactor building and auxiliary building, respectively (445/8626 V-02).

RESPONSE TO ITEM A (445/8626-V 02)

On June 4, 1987, per a telecon with Mr. Bob Warnick, TV Electric requested an I extension for NOV Item A (445/8626 V-02) until July 13, 1987. This extension l 1s needed in order to evaluate procedures that deal with post construction inspection of electrical equipment.

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Attachment to TXX-6472

. June 5, 1987 Page 2 of 18 NOTICE OF VIOLATION ITEM B (445/8626-V-08: 446/8622-V-05)

8. Criterion IX of Appendix 8 to 10 CFR Part 50, as implemented by the TUGCo QAP, Section 9.0, Revision 5, dated November 20, 1985, states, in part,

"Heasures shall be established to assure that special processes, including l welding . . . are controlled and accomplished by qualif ted personnel . . .

in accordance with applicable codes, standards, specifications. . ."

Bahnson Service Company's Procedures DFP-TUSI-001, Revision 8, dated i February 26, 1981, "Ductwork Fabrication Procedure," and DFP-TUSI-003,

! Revisien 7, dated May 6, 1981, " Duct Support Fabrication & Installation Procedure," require that all welders performing work on duct supports and seismic support systems shall be qualif ted to Section IX nf the ASME Code.

Paragraph QW-301.2 in Section IX of the ASME Code states, in part, "Each manufacturer or contractor shall qualify each welder or welding operator for each welding process to be used in production welding . . . ." QW-301.4 states, in part, "Information regarding the essential variables and the test results obtained by each welder . . . shall be recorded on a Record of Performance Qualification Tests."

Contrary to the above, with respect to position limitations and qualified n'atorial thickness ranges, Bahnson Service Company's welder performance qualification records dated May 1979, June 1981, and March 1983, certify their welders as being qualified in more positions and material thickness ranges than allowed by the reported number of test results (445/8626 V 08: ,

446/8622 V 05). l RESE0RSL10_IlttLil (445/8626 V 081 446/8622 V 05)

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

1. Reason for Violation i The violation was caused by a failure of Dahnson Service Company (BSC) personnel to properly document test results as required by DSC procedures

, DFP-TUSI 001 an't DfP TUSI-003.

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. Attachment to TXX-6472 i June 5, 1987 Page 3 of 18 NOTICE OF VIOLATION RESPONSE TO ITEM B (445/8626-V-08: 446/8622-V-05) CONT'D I

2. Corrective Steos Taken And Results Achieved i Nonconformance Reports (NCRs) M86 202501, M86-202635, M86-104764, M86-104765 and M86-105297 were written to document the specific welder qualification discrepancies. These NCRs have been transferred to NCRs CM-87-3419, CM-87-3541, CM 87-3543, CM-87-3542, CM-87-3364, respectively. As stated in the disposition of these NCRs, the subject welders were found to

have met the necessary qualifications. Upon closure, of these NCRs, l copies will be placed in the BSC welder qualification record.

i 3. Corrective Stoos Which Will Be Taken To Avoid Further Violations BSC has been relieved of all responsibility for HVAC engineering, construction, and quality control. Ebasco has assumed responsibility for j all HVAC systems engineering and design activities. Daniel Construction Company and TU Electric have assumed responsibility for construction and i

l quality control activities, respectively. Prior to the commencement of HVAC welding activities, the Daniel welder qualification procedure will be reviewed by Ebasco Welding Engineering and by TU Electric's Level !!!

welding inspector.

4. Date When Full Compliance Will Be Achieved full compliance will be achieved upon closure of the above referenced NCRs and placement of copics in the BSC welder qualification record. We ,

. anticipato completion of these actions no later than July 6,1987. l l

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, , Attachment to TXX-6472 -

June 5, 1987 Page 4 of 18 l NOTICE OF VIOLATION l

ITEM C. 1 (446/8622-V-06) i C. Criterion XV of Appendix B to 10 CFR Part 50 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.

Section 15.0, Revision 5, dated October 18, 1985, of the TUGCo QAP states, in part, "The identification, documentation, segregation, and disposition of nonconforming materials, parts, and components is outlined in written procedures. . . . The procedures, as a minimum . .. require investigation of the nonconforming item, decisions on their disposition, and preparation of adequate reports . . . . A nonconformance report is used to document deficiencies (nonconforming items) unless another method is prescribed by a specific procedure / instruction."

Contrary to the above, systems other than nonconformance reports exist and have existed on-site which identify potentially nonconforming items, but no specific procedures or instructions have been developed that prescribe the method by which compliance with Criterion XV is achieved. Examples of this violation are:

1. From August 1985 through April 1986, the TNE Unit 1 Task Group conducted walkdowns of electrical conduit for the purpose of developing as built isometric drawings. Potentially nonconforming items that were identified, but outside the scope of this walkdown effort, were documented in a " Problem Log" for disposition at a later time. The

" Problem Log" was not defined or controlled by procedures or instructions. This violation exam)1e is further complicated since the "Probicm Log" was discarded when E)asco assumed this walkdown responsibility from the Unit 1 Task Group in May 1986 and there is no evidence of what the items on the log were or that any were dispositioned (446/8622 V 06).

ESE0NSL.ID_.111M C.1 (446/8622-V-06)

TV Electric accepts the alleged violation and the requested information 1 follows: ,

1. Ecnon_f.or Violation l The informal log was developed by the TUGCo Nuclear Engineering (TNE) Unit 1 Task Group Loader to provido a consistent method for documenting

! potential nonconformancos. Those potential nonconformances were noted while performing as built field verification of conduit and conduit sup) orts. The log was discarded at the time the THE Unit 1 Task Group was dis)anded because the Group Loador was told that another field verification of the same conduit and supports would bo performed by Ebasco. 110 thereforo assumed the log would not be of any further uso, in retrospect, the log contents should fiave boon turned over to Ebasco supervision or QA/QC for evaluation in accordanco with CP-QP 16.0 to determino if actual nonconformances existed.

. Attachment to TXX-6472 June 5, 1987 Page 5 of 18 l

NOTICE OF VIOLATION RESPONSE TO ITEM C.1 (446/8622-V-06) CONT'D

, 2. Corrective Steos Taken And Results Achieved Since the log was discarded it it not possible to identify the entries.

However, based on discussions with the Group Leader and because of the i following considerations, TU Electric believes the potential l nonconformances were subsequently corrected or were of such a minor nature i

that the ability of the conduit and its supports to perform their safety I functions would not have been affected.

1 - Less than 15 conditions were noted in the log.

- The Task Group Leader believed that many, if not all, of the potential nonconformances existed due to ongoing work unrelated to the field verification effort.

- The potential nonconformances were all considered minor. As an example, the Group Leader noted that the log indicated a missing torque seal on a litlti bolt. Another example included a possibly incorrect washer on a base plate bolt.

- The log was used to document potential nonconformances outside the scope of the field verification (the term "out-of-scope" was defined to mean applicable to the equipment being examined, but outside the defined attributes for the as butiding field vertftcation effort).

Since Ebasco re performed and is continuing to re-perform the fleid verification using more extensive criteria, many of the potential nonconformances, would have been or will be identified and corrected.

The possibility existed that many of the potential nonconformances would have been acceptable based on general drawing notes which defined alternate acceptance critoria.

TU Electric believes that no additional corrective actions beyond those described above are needed for existing fleid conditions.

3. Corrective Steos Which Will De Taken To Avoid Further Violations After the informal log was discarded, Ebasco performed field verifications using " Requests for Inspection" (RFI) forms to document potential nonconformances. RFis and tho informal log were intended to serve the <

same function. Use of RFis was subsequently identified by NRC as a violation (Re: 50/446/8622 V 07) of 10CFR50, Appendix B., Criterion XV.

Actions to preclude recurrence for both violations are similar and are discussed in the responso to 50 446/8622 V 07,

4. Date_When full Comollance Will De Achieved l Full compilance will be achieved as stated in the response to Notice of .

Violation 50 446/8622 V.07. l l

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, Attachment to TXX-6472 June 5, 1987 Page 6 of 18 NOTICE OF VIOLATION ITEM C.2 (446/8622-V-07)

C. Criterion XV of Appendix B to 10 CFR Part 50 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.

Section 15.0, Revision 5, dated October 18, 1985, of the TUGCo QAP states, in part, "The identification, documentation, segregation, and disposition of nonconforming materials, parts, and components is outlined in written procedures . . . . The procedures, as a minimum . . . require investigation of the nonconforming item, decisions on their disposition, and preparation of adequate reports . . . . A nonconformance report is used to document deficiencies (nonconforming items) unless another method is prescribed by a specific procedure / instruction."

Contrary to the above, systems other than nonconformance reports exist and have existed on-site which identify potentially nonconforming items, but no specific procedures or instructions have been developed that prescribe the method by which compliance with Criterion XV is achieved. Examples of this violation are:

2. Cu*rently the electrical conduit walkdowns being performed by Ebasco are prescribed in Procedure TNE-FVM CS-014, Revision 3, "As-built Field Verification Method-Design Control of Electrical Conduit Raceways for Unit 2 Installation in Unit I and Common Areas, Class 1." Potentially nonconforming items identified during these walkdowns that are outside the scope of this effort are documented on a form, " Request for Inspection," per Procedure TNE-FVM CS-014. While this )rocedure requires these items be documented, it fails to prescriae the method by which these items will be tracked, how they will be accounted for, or how disposition / follow up will be assured (446/8622-V-07).

RESPONSE TO ITEM C.2 (446/8622-V-07)

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

1. Reason For Violation Proper controls were not established which specified methods for identifying, tracking and assuring proper evaluation and disposition of potential nonconformances. The procedure used by Lead Contractors to develop Field Verification Methods (FVM) TU Electric procedure ECE DC-24, did not define specific methods for documenting potential out-of-scope nonconformances identified during field verifications.

. Attachment to TXX-6472 June 5, 1987 Page 7 of 18 NOTICE OF VIOLATION RESPONSE TO ITEM C.2 (446/8622-V-07) CONT'D

2. Corrective Steos Taken And Results Achieved To correct this program deficiency, Corrective Action Request (CAR-110) was issued to Engineering on December 5, 1986. Initially, the problem was thought to be isolated to Ebasco. Investigation indicated that Ebasco had used several different documents to identify potential out-of-scope nonconformances identified during field verifications performed in accordance with FVMs. The documents and applicable FVM are listed below.

Document f_VM 3-part memo FVM-CS-010 RFI FVM-CS-014 DF FVM-CS-016 RMF FVM-CS-029 RFI FVM-CS-033 TMF FVM-CS-036 Two other Ebasco FVMs (FVM-CS-001 and FVM-CS-007) were determined to be adequate and were excluded from the CAR. FVM-CS-001 had been addressed in response to CAR-053. Potential nonconformances identified by FVM-CS-007 had been documented on Nonconformance Reports (NCRs).

During December, 1986, CP-QP-16.0, " Reporting Construction Deficiencies",

was revised to allow the use of Construction Deficiency Reports (CDR).

All of the above listed FVMs, with the exception of FVM-CS-029, were revised to require the use of these CDR forms.

FVM-CS-029 had been revised to change the scope to that of an in-process, uninspected, status. Therefore, RMFs, in conjunction with travelers, will continue to identify and initiate any necessary rework found during the field verification. At the completion of field verification, a 100% QC inspection will be performed.

Although FVM-CS-014 requires the use of a CDR for all potential nonconformances, inspection attributes are as-built and the design j verification process evaluates the adequacy of the conduit systum 1

inclusive of any potential in-scope deficiencies. In addition, QC inspection verifies any data which falls outside the generic allowables to which QC had previously inspected.

ECE DC-24, "As Duilt Package Preparation", was changed April 8, 1987 to require the use of NCRs or other approved methods for documenting out-of-scope findings. This procedure was superseded in May, 1987 by ECE-511.ll.

However, the requirement for documenting out-of-scope findings did not change during this conversion process. None of the FVMs listed above were i changed as a result of this revision since they required a CDR for all

deficiencies or the deficiencies were processed as described above.

Appropriate TV Electric and Ebasco personnel have been trained to the new procedure and applicable FVHs.

. Attachment to TXX-6472 June 5, 1987 Page 8 of 18

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i NOTICE OF VIOLATION i RESPONSE TO ITEM C.2 (446/8622-V-07) CONT'D

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2. Corrective Steos Taken and Results Achieved (Cont'd)

Ebasco is presently converting the above listed documents, except RMFs, to CORs.

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

The scope of CAR-110 has been expanded to include Impe11 and Stone and

Webster FVM programs. Actions similar to those taken for Ebasco (i.e.,

. Procedure revision, applicable training and conversion of previously used l documents to appropriate corrective action documents) will be taken as J necessary.

4. Date When Full Comoliance Will Be Achieved Ebasco will complete the conversion of previously used documents to appropriate corrective action documents by July 1, 1987. Any required +

4 changes to Stone and Webster or Impell FVMs, applicable training and 1 conversion of documents will be completed by August 15, 1987.

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Page 9 of 18 ,

1 NOTICE OF DEVIATION l ITEM A (445/8626-D-01) 1 A. Paragraph 5.1.1 of ERC Procedure CPP-020, Revision 1, dated September 23, 1985, states, in part, "Should any QA/QC Review Team personnel observe an apparent defect or discrepancy which is out-of-scope, they are to prepare a memorandum . . . . This memorandum shall be addressed to the TUGCo QA Coordinator . . . ."

In deviation from the above, an ERC inspector failed to write an out-of-scope memorandum for a pull rope found in conduit C12018896 during the ERC ,

inspection for Verification Package I-E-EEIN-024 (445/8626-D-01). l RESPONSE TO ITEM A ,

(445/8626-D-01)  ;

i TU Electric agrees with the alleged deviation and the requested information )

follows:

1. Reason For Deviation '

On September 9,1985, ERC performed a reinspection for Verification Package I-E-EEIN-024. An NRC inspector was present during this reinspection. The ERC inspector noticed a pull rope in an adjacent conduit and did not prepare an out-of-scope memorandum because the inspector believed that cable pulling activities were still in progress ,

and not yet complete. Subsequent to this inspection, it was determined '

that a post construction inspection had been performed for conduit C12018896. Furthermore, cable pulling activities were complete and the 1 pull rope should not have been left in the conduit. Therefore, this deviation occurred as a result of the ERC inspector failing to determine at the time of the reinspection that the conduit had been inspected and was complete.

2. Corrective Steos Taken And Results Achieved An out-of-scope memorandum identifying the pull rope will be prepared by l June 30, 1987.

3. Corrective Steos Which Will Be Taken To Avoid Further Deviations No corrective steps will be taken to avoid further deviations since the reinspection program is virtually complete.

TV Electric prepared nonconformance report E-86-1038835 to address the pull rope in conduit C12018896. The pull rope was subsequently removed as evidenced by CPSES Inspection Report No. E-10097556, dated 11/13/86.

4. Date When Full Como11ance Will Be Achieved Full compliance will be achieved by June 30, 1987.

. Attachment to TXX-6472 June 5, 1987 Page 10 of 18 NOTICE OF DEVIATION ITEM B (445/8626-D-03: 446/8622-D-01)

B. Section 4.1.2 of ISAP I.d.3, Revision 0, requires, in part, that ERC perform an evaluation of the craft training procedures including training and retraining, and that the following items will be considered during this evaluation:

"How craft personnel become aware of changes in design and construction requirements and how retraining occurs."

How craft personnel are informed and become knowledgeable of QA/QC requirements / criteria and changes to those requirements / criteria."

Section 4.1.3 of the ISAP also states, in part, " Based on this review (of procedures), conclusions will be drawn by the QA/QC Review Team Leader as to the adequacy of both past and current practices used for craft selection and training. If current procedures are determined to be inadequate, recommendations for imprevement will be provided to TUGC0 prior to the closure of this action plan."

In deviation from the above, ISAP I.d.3 Results Report does not provide a recomnendation that TUGC0 revise the Bahnson Service Company's craft training Procedure QCI-CPSES-013, " Indoctrination and Training of Personnel," which does not assure that: (1) " craft personnel become aware of changes in design and construction requirements"; and (2) " craft personnel are informed and become knowledgeable of QA/QC requirements / criteria and changes to those requirements / criteria" (445/8626-D-03; 446/8622-D-01).

RESPONSE TO ITEM B (445/8626-D-03: 446/8622-D-01)

TU Electric disagrees with the alleged deviation for the following reasons:

The Notice of Deviation quotes a superseded part of Section 4.1.3 of ISAP I.d.3. The wording of this Section was revised by change documentation dated August 27, 1986. The applicable version is in the Results Report, which states, "...The QA/QC Review Team used results of their activities to draw conclusions about the adequacy of past and current craft training practices. These conclusions may be modified if shortcomings in tne training of craft personnel are determined to be the root cause of any construction deficiencies or adverse trends identified by other ISAPs. A review of the root causes of any construction deficiencies and adversa trends and, if appropriate, a reassessment of the adequacy of past training will be conducted by the Collective Evaluation Group after the results reports of other ISAPs are issued."

Attachment to TXX-6472 June 5, 1987 Page 11 of 18 NOTICE OF DEVIATION RESPONSE TO ITEM B (445/8626-D-03: 446/8622-0-01) CONT'D The assessment of craft training procedures, as reported in the ISAP I.d.3 Results Report, was accomplished by either interviewing craft personnel, observing training and field activities, or reviewing training procedures.

The Issue Coordinator for ISAP I.d.3 determined which method (s) to use for the various aspects of craft personnel training.

Items that were considered during this assessment included (1) how craft personnel become aware of changes to construction requirements and how retraining occurs, and (2) how craft personnel become aware of QA/QC requirements / criteria and changes to those requirements / criteria. For example, changes to QA/QC requirements / criteria were addressed in craft construction procedures if construction requirements were affected. This was verified during interviews and noted in the I.d.3 Results Report.

Training or retraining on changes to construction procedures, caused by design, construction, or QA/QC requirement changes, was covered by Bahnson procedure QCI-CPSES-013. This assessment was determined by interviewing craft personnel and reviewing appropriate training records.

Procedural training was covered by Bahnson procedure QCI-CPSES-013. The following assessment was made by ISAP I.d.3: (1) Paragraph 6.3.1 addressed the method (s) of training. Bahnson training included subsequent revisions to construction procedures. (2) Paragraph 6.3.2 addressed the types of construction procedures included in procedural training. (3)

Paragraph 6.5.1 required training to be documented on Training Records, (this included the procedure and revision number). Therefore, QCI-CPSES-013 assured that appropriate craft personnel were trained (retrained) to procedure revisions, as appropriate.

As stated in the Results Report for ISAP I.d.3, training to procedures and their revisions was being performed. This was determined by interviewing craft personnel and reviewing appropriate training records.

Section 4.5 of the ISAP provides the acceptance criteria for the adequacy of craft training. The requirements are delineated in ANSI N45.2-1971.

These requirements state that personnel performing activities affecting quality shall be trained and indoctrinated to assure that suitable proficiency is achieved and maintained. Procedural training covered by Bahnson procedure QCI-CPSES-013 was found to meet the acceptance criteria.

Conclusions concerning Bahnson training may be modified if other ISAP's determine shortcomings in the training of craft personnel. This reassessment, if appropriate, will be conducted by the Collective Evaluation Group.  ;

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Attachment to TXX-6472 June 5, 1987 Page 12 of 18 NOTICE OF DEVIATION ITEM C (445/8626-D-04: 446/8622-D-02)

C. The W. G. Counsil letter (CPRT 207) to the NRC, dated January 27, 1986, regarding CPSES submittal of Revision 3 of the Comanche Peak Response Team (CPRT) Program Plan and ISAPs, committed that,". . . further substantive modifications to these documents (CPRT Program Plan ISAPs) will require the approval of the Senior Review Team prior to implementation."

Change Notice 001 to Comanche Peak Project Procedure CPP-024, " Issue Specific Action Plan Revision," dated April 4,1986, requires that ". . .

the SRT approves substantive changes prior to implementation."

In deviation from the above, substantive changes to ISAP I.d.3 were implemented prior to approval by the Senior Review Team (SRT). For example, in April 1986 the Special Evaluation Team's effort was transferred to Quality Assurance / Quality Control (QA/QC) review team personnel and the issue coordinator was changed; however, the SRT did not approve these and other changes until August 1986 (445/8626-D-04; 446/8622-D-02).

RESPONSE TO ITEM C (445/8626-D-04: 446/8622-D-02)

TU Electric agrees with the alleged deviation and the requested information follows:

1. Reason For Deviation All substantive changes to CPRT Action Plans are approved by the SRT.

However, on occasion, Action Plan changes that have been implemented are approved along with the Action Plan Results Report. This practice is inconsistent with the guidance delineated in CPRT-207, PAG-01 and CPP-024.

Therefore, on occasion, the SRT has deviated from program requirements by not formally approving substantive changes to Action Plans prior to their implementation. These deviations have occurred due to an oversight by the SRT.

2. Corrective Steos Taken And Results Achieved The SRT has formally approved all substantive changes to ISAP's.

3. Corrective Steos Which Will Be Taken To Avoid Further Deviations This deviation was discussed with the SRT on May 20, 1987 and all future substantive changes to ISAP's will be formally approved prior to implementation.

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. Attachment to TXX-6472 June 5, 1987 Page 13 of 18 RESPONSE T0_IIEM_C (445/8626-D-04: 446/8622-D-02) CONT'D

4. Date When Full Compliance Will Be Achieved The SRT is now in full compliance.

NOTICE OF DEVIATION ITEM D (445/8626-D-06)

D. Paragraph 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 as records in the ISAP file.

For each safety-significant attribute identified, detailed instructions for the verification of the attribute, including definitive accept / reject criteria, will be established . . . ."

In deviation from the above, ERC engineering failed to identify certain work activities and attributes associated with fabrication and installation of HVAC ducts and plenums which occurred prior to 1982.

These activities / attributes included: (1) welded nuts on the interior of seismic volume extractors, and (2) crimps used for attaching various l

accessories; such as, grills, registers, and associated sealant material.

The failure to identify these activites/ attributes precluded determination of safety significance. Further, there was no justification for not l

including these activities / attributes in the reinspection or documentation review checklists (445/8626-D-06).

i RESPONSE TO ITEM D (445/8626-D-06)

TV Electric disagrees with the alleged deviation for the following reasons:

1 We agree with the NRC that ERC engineering did not establish inspection '

criteria based on the project requirements in effect at the time construction work activities were performed. The reinspection instruction for HVAC Ducts and Plenums, QI-039, and the documentation review instruction, QI-040, were based on current procedures, including:

1) Ductwork Fabrication Procedure, DFP-TUSI-001, Revision 12, dated 04/16/85,

2) Ductwork Accessory Installation Procedure, DFP-TUSI-008, Revision 7, dated 08/08/84,

3) Ductwork Fabrication Inspection Procedure, QCI-CPSES-002, Revision 8, dated 06/05/85, and

4) Visual Weld Acceptance Criteria, NCIG-01, Revision 2, dated 05/07/84.

Attachment to TXX-6472 June 5, 1987

. Page 14 of 18 RESPONSE TO ITEM D (445/8626-D-06) CONT'D By design, ERC Quality Instructions were developed using the latest approved project or contractor procedures. This guidance was delineated in Comanche Peak Response Team (CPRT) Project Procedure CPP-007, " PREPARATION OF CHECKLISTS AND DATA BASE REPORTS", Revision 2. It required the ERC QA/QC discipline engineer to review the latest Gibbs & Hill, Brown & Root, and subcontractor design documents relating to the population. As applicable, the latest installation procedures, construction drawings, and manufacturers prints and manuals were also reviewed. Therefore, QI-039 and QI-040 were prepared using the latest procedures and documents available. The latest procedures did not specify welded nuts or crimps. The ERC reinspections were performed to current requirements affecting the hardware.

If during the reinspection program it was discovered that items were installed in any manner that deviated from the latest requirements (welded nuts or crimps used for attaching grills and registers), these would have been reported in accordance with CPRT Project Procedure CPP-010, " PREPARATION OF DEVIATION REPORTS", Revision 7. This procedure states, in part, "... Should an attribute deviate from specified acceptance criteria, the inspector / reviewer initiates a Deviation Report (DR). Subsequently, DRs are reviewed for validity and, as required, evaluated by the Safety Significance Group (SSEG) ... reviewed for root cause and generic implication ... and processed for reportability by TUGC0 ..." Therefore, justification for excluding these attributes (welded nuts and crimps) was not required.

NOTICE OF DEVIATION ITEM E (445/8626-D-07)

E. Section 2.0 in Revision 1 of both QI-035 and QI-036 requires that reinspection and documentation review be performed on only those duct supports which have been installed and final QC accepted by Bahnson Service Company (BSC). Section 5.0 in QI-036 requires the initiation of a deviation report (DR) for any applicable HVAC duct support attributes identified as not having been inspected by BSC.

In deviation from the above, the following conditions were identified:

1. The documentation review verification packages issued to ERC inspectors for Unit 1 and common HVAC duct supports, contained the applicable BSC inspection reports and the BSC detail drawings which were supposed to represent the installed and final QC accepted supports.

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. Attachment to TXX-6472 June 5, 1987 Page 15 of 18 NOTICE OF DEVIATION ITEM E (445/8626-D-07) CONT'D

2. The NRC inspector identified that the BSC inspection reports were dated as much as 5 years prior to the initial issue of the detail drawings.

3. There was no evidence of inspections performed by BSC QC to verify the duct support configuration to the detail drawing.

4. It was further determined that BSC QC used typical drawings for their inspections. These drawings can be dissimilar to the detail drawings provided to ERC. As a result, the ability of ERC to identify attributes not inspected by BSC was affected; thus initiation of all required DRs was precluded (445/8626-D-07).

RESPONSE TO ITEM E (445/8626-D-07)

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

1. Reason For Deviation During the course of the ERC VII.c reinspection effort, the population engineer reviewed the documentation provided by the HVAC contractor, Bahnson Services Company (BSC). This review included installation and inspection procedures, inspection reports, and available correspondence between the contractor, TUGCO, and the NRC. This review revealed that the HVAC contractor had been audited in 1983 by the NRC Construction Assessment Team (CAT). This audit identified that BSC did not " inspect the supports for proper location, proper configuration or member size and length. No (BSC) QA/QC verification or audit of the (BSC) drafting department's as-built efforts is performed." (RE: Docket Nos. 50-445/86-18 and 83-12). The population engineer reviewed TUGC0's response to the finding and after a cursory check, assumed that the response was adequate and that it had been accepted by the NRC.

The root cause and generic implications analysis evaluation performed for the unclassified trend identified for this population determined that the response to the 1983 NRC finding was, in fact, less-than-adequate. The corrective action for the finding never required BSC to inspect the dimensional attributes listed above in Unit 1 or Common areas. The only reinspections performed were for those supports located in Unit 2. In addition, the root cause analysis determined that the design drawings provided by Bahnson did not match the typical drawings that Bahnson used for installation.

Section 5.0 of QI-036 provides instructions for the ERC inspector to prepare deviation reports for any documentation review attribute (s) not inspected. ERC identified cases where discrepancies existed in the Bahnson inspection reports and where inspection documentation could not be located.

. Attachment to TXX-6472 June 5, 1987 Page 16 of 18 RESPONSE TO ITEM E (445/8626-D-07) CONT'D Further reviews determined that BSC did not successfully complete the corrective action required by TUGCO. Corrective Action Reports (CARS) that were to document completion of activities outlined in response to the CAT findings were never successfully closed.

At the time of these discoveries, however, the ERC reinspection effort had been completed. The decision was made to allow the affected deviations to remain valid because these deviations adequately identified the hardware deficiencies.

In summary, the reason for the deviation was the inability of the population engineer to detect the less-than-adequate response to the 1983 NRC finding prior to completion of the ERC reinspection effort.

2. Correction Steos Taken And Results Achieved No corrective action is necessary because the error committed by the population engineer did not affect the results of the reinspection effort.

The deviatinns that were evaluated identified the hardware and QA deficienctes.

3. Corrective Steos Which Will Be Taken To Avoid Further Deviations The NRC finding discussed above does not require an action to prevent recurrence because the ERC reinspection effort is complete and an unclassified trend has been identified for all attributes in this population. As a result, a recommendation was made that requires a complete reinspection and reanalysis of all HVAC duct supports.

4. Date When Full Como11arce Will Be Achieved The TU Electric HVAC Program is scheduled for completion by March 1988 for Unit I and July 1988 for Unit 2.

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June 5, 1987 Page 17 of 18 UNRESOLVED ITEM (445/8626-U-05:446/8622-U-04)

During NRC review of the . . . SDAR's, the NRC inspector reviewed documentation (not required to be reviewed in the ERC effort on SDARs) which identified that six installed Hilti Kwik bolts had been modified in an unauthorized manner. The length designator stamped on the end of five of these bolts had been modified such that the indicated lengths of these bolts were longer than the actual lengths. The specific conditions of the bolts were: Five bolts with a length designator of 7" were actually 51/2" long; one bolt with a length designation of 7" was actually 11" long. These unauthorized modifications were found during a Hilti bolt reinspection program which was a part of SDAR CP-80-10. SDAR CP-80-10 addressed modifications to Hilti Kwik bolts in which the length and the holding ability of the bolts were changed by craft cutting off the mandrel portion of a Hilti Kwik bolt and grinding a new mandrel on the shortened stud, or craft cutting off the bottom mandrel of a double-mandrelled Super Hilti Kwik bolt and installing the resultant shorter bolt.

The Hilti bolt with modified length designations were not reported as part of SDAR CP-80-10. Documentation concerning whether these Hilti bolts were properly evaluated and whether the safety implications of the nonconformances (modifications to the length designators) were determined, could not be provided for NRC evaluation during this report period (445/8626-U-05;446/8622-U-04).

RESPONSE TO UNRESOLVED ITEM (445/8626-U-05:446/8622-U-04)

TU Electric has conducted an investigation of the specific hardware deficiency and the adverse condition that caused the deficiency. The investigation concluded that neither the deficiency nor its cause were considered significant or reportable. Therefore, documentation described in the NRC unresolved item would not have been generated.

The above conclusion was reached after contacting a number of people associated with the Hilti bolt inspection program during 1980 and 1981 and by i

review of relevant documentation. However, since the deficiency occurred over six years ago, not all personnel associated with the deficiency were available to discuss the deficiency.

The investigation assumed that the significance of the deficiency would have been reviewed from two aspects, as a specific hardware deficiency and as an adverse condition or process that caused the deficiency.

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June 5, 1987 Page 18 of 18 RESPONSE TO UNRESOLVED ITEM (445/8626-U-05:446/8622-U-04) CONT'D Concerning the first aspect, on December 29, 1980, the referenced bolts were initially identified as being shorter than indicated by their stamps. The bolts were determined to be undersized using ultrasonic test (UT) methods which were specified as part of corrective action for SDAR CP-80-10. The undersized bolts were documented, dispositioned and reworked as defined on NCR-E-81-00001 dated January 5, 1980. (Note: The 1980 date was confirmed to be a typographical error,1981 is the proper date. In addition, this NCR identified a sixth bolt that was longer than required. The stamp for this bolt was ground off and restamped with the proper designator ) Inspection Report, IR No. E21802, dated February 6, 1981 was issued to close the NCR.

This IR was the first document that alleged that the bolt stamps had been altered. NCR-E-81-00001 was closed March 4, 1981.

The bolts were intended to provide support for junction box JB2A178 and attached conduit. The box and conduit house train "C" non-safety instrumentation (temperature indication) cable associated with the CP2-CCAPCC-02 Component Cooling Water pump and motor. Since the cable has no safety function, this hardware deficiency would not have been considered significant and therefore not potentially reportable.

The second aspect of this concern, which could have been potentially significant, was the alledged altering of stamps (adverse condition) noted by IR No. E21802. The investigation concluded that management did not consider this aspect significant or reportable because it was an isolated occurrence.

The alledged altering of stamps was identified on February 6,1981. Previous to that date over 3300 Hilti bolts had been UT inspected with no noted occurrence of stamp alteration. This basis would have provided sufficient confidence that no significant breakdown in any portion of the QA program had occurred. Therefore, no reportability documentation would have been generated.

It should be noted that after the deficiency was identified, 8000 additional bolts were tested within HVAC and electrical areas as part of corrective action for SDAR CP-80-10. Our investigation revealeri no stamp altering was identified.

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