TXX-6496, Forwards Revised Response to Violations & Deviations Noted in Insp Repts 50-445/86-15 & 50-446/86-12,per 870408 Request.Corrective Actions:Completed Work Packages for 91 ASME & quality-related non-ASME Support Assemblies Reviewed
| ML20214U181 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/05/1987 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 2.201, TXX-6496, NUDOCS 8706110084 | |
| Download: ML20214U181 (4) | |
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Log # TXX-6496 r--
FE File # 10130 IR 86-15
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IR 86-12 Ref # 10CFR2.201 H# ELECTRIC June 5, 1987 mm
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~ Emine Vke Preskknt
~U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington,.DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (LPSES)
DOCKETS NOS. 50-445 AND 50-446 REQUEST FOR ADDITIONAL INFORMATION REGARDING INSPECTION REPORT: 50-445/86-15 AND 50-446/86-12 ITEM F.3 REF:
- 1) NRC Letter from E. H. Johnson to W. G. Counsil dated December 22, 1986.
l 2, 1987.
- 3) TV Electric Letter TXX-6447 from W. G. Counsil to NRC dated May 19, 1987.
l 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 i
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. Ian Barnes, we requested and received an extension until May 18, 1987.
On May 18, 1987, per a telecon with your Mr. Ian Barnes, we requested and received an extension as follows:
Item F.3 (445/8615-V-08; 446/8612-V-08) i extended until June 8, 1987.
In pursuing the requested additional information, we have determined that a revision to our original response was required to clarify our position.
Accordingly, a revised response, including the requested additional information, is enclosed. Since the entire response has been revised, no i
revision bars have been provided.
We hereby respond to the above item in the attachment to this letter.
8706110084 870605 Very truly yours, PDR ADOCK 05000445 A
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PDR ounsil a
RDD/gj i
fgo c - R. D. Martin - Region IV CPSES Resident Inspector - 3 copies i
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i 400 North Olise Street LB 81 Dallas, Texas 75201 l'
Attachment to TXX-6496 June 5, 1987 Page 1 of 3 RE0 VEST FOR ADDITIONAL INFORMATION
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NOTICE OF VIOLATION ITEM F.3 (445/8615-V-08: 446/8612-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-08: 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 on 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_1 t
TV Electric agrees with the alleged violation and the requested information follows:
1.
Reason For Violation The violation was the result of an inadequacy in procedure CP-CPM-7.3A,
" Material Storage / Identification for Structural Fabrication." The majority of structural fabrication shop activities involve the fabrication l
of assemblies and sub-assemblies, and issuance of field fabrication material for safety and non-safety related conduit, cable tray, and ASME component supports (hangers). To a lesser extent, the structural fabrication shop also produces various other structural items and provides miscellaneous temporary and non-plant items.
Procedure CP-CPM-7.3A, Rev.
O, provided a standard form for requesting hangers or parts and also allowed the use of other non-standard forms. However, procedure CP-CPM-l 7.3A did not provide directions as to what circumstances required the use of the standard form or when non-standard forms were acceptable. Also the procedure did not specify the minimum information required on either the l
standard or non-standard form.
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Attachment to TXX-6496 Juna 5, 1987 Page 2 of 3 REVISED RESPONSE TO ITEM F.3 (445/8615-V-08: 446/8612-V-08) CONT'D The examples given in the Notice of Violation indicate that the l
fabrication requests should specify whether the item is Q or non-Q, ASME or non-ASME, its location or intended use.
The function of the fabrication requests is to notify the fabrication shop that work has been requested and to track the work to completion. Appropriate quality requirements are specified in controlled documents contained in the applicable work package. The field personnel requesting the work have the rcsponsibility to provide the fabrication shop personnel with sufficient information to fabricate the item in accordance with the requirements contained in the work package.
For example, fabrication of a base plate may only require that field personnel provide a simple sketch or written description, while the fabrication of a complete hanger assembly may require that field personnel provide the entire work package.
Regardless of the complexity of the requested part or assembly, it is the responsibility of the field personnel to ensure that the parts provided by the fabrication shop and the final assembly are in accordance with the controlled drawings and documents contained in the work package.
Additional assurance is provided by the QC post installation inspection which verifies such attributes as material traceability and assembly configuration. This inspection also verifies that the acceptability of any inaccessible attributes or shop welding has been documented by in-process QC inspections during fabrication.
2.
Corrective Steos Taken And Results Achieved A review of completed work packages for ninety-one ASME and quality-related non-ASME support assemblies has been performed per Issue Specific Action Plan (ISAP) VII.b.1, "Onsite Fabrication." As stated in the Results Report for ISAP VII.b.1, the deviations identified in the review were evaluated and determined to have no safety significant hardware effect on the component supports. Also, tne deviations were not attributed to inadequate or improper information provided on the shop fabrication requests.
3.
Corrective Steos Which Will Be Taken To Avoid Further Violations In response to this violation, procedure CP-CPM-7.3A was revised effective August 12, 1986, to require the use of the standard " Request for Hanger or i
Parts" forms.
Since the fabrication shop also produces items other than hangers, this revision has proven to be overly restrictive and impractical.
Procedure CP-CPM-7.3A will be revised to clarify when the standard form must be used and when alternate non-standard forms may be used. The revision will also specify the minimum information required for ASME and quality related items.
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Attachment to TXX-6496 Juns 5, 1987 Page 3 of 3 REVISED RESPONSE TO ITEM F.3 (445/8615-V-08: 446/8612-V-08) CONT'O Our review of this violation has determined that, although personnel are properly implementing the fabrication process described in Section 1 above, a clear statement of the responsibilities is needed. Accordingly, Procedure CP-CPM-7.3A will also be revised to specify the responsibilities of the construction field personnel regarding requests for items from the structural fabrication shop, and for ensuring the items provided are in accordance with the work package requirements.
4.
Date When Full Como11ance Will Be Achieved Procedure CP-CPM-7.3A will be revised and training performed by July 31, 1987.
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