TXX-6504, Responds to NRC Re Violations Noted in Insp Repts 50-445/87-20 & 50-446/87-17.Corrective Actions:Usage of Computer Listings of Controlled Documents & Copy Holders Assure Only Current Approved Documents Issued for Const

Responds to NRC Re Violations Noted in Insp Repts 50-445/87-20 & 50-446/87-17.Corrective Actions:Usage of Computer Listings of Controlled Documents & Copy Holders Assure Only Current Approved Documents Issued for Const

ML20235P769
Person / Time
Site:	Comanche Peak
Issue date:	07/13/1987
From:	Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-6504, NUDOCS 8707200618
Download: ML20235P769 (19)

Text

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- llllllllll"llllllllll Log # TXX-6504

• File # 10130

. 9 IR 86-20 r C IR 86-17 l Ref: 10CFR2.201 1UELECTRIC l

wmim c. coumn July 13, 1987 Executive We President i

U. S. Nuclear Regulatory Commission l 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. 50-445/86-20 AND 50-446/86-17 Gentlemen.

1 We have reviewed your letter dated March 30, 1987, concerning the inspection i conducted by Mr. H. S. Phillips and other members of the Region IV Comanche Peak  !

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. titached to your letter was a Notice of Violation (N0V).

On April 27, 1987, per a telecon with your Mr. I. Barnes, we requested and l

, received an extension to the due date for our response to this NOV until June 12, l 1987. On June 11, 1987, per a conversation with your Mr. Bob Warnick, we i

requested and received another extension until July 1,1987. On July 1, 1987, per a conversation with your Mr. Bob Warnick, we requested and received another extension until July 13, 1987.

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

Very truly yours, nd W. G. Counsil By: -

G. S. Keeley I

Manager, Nuclea . ng RDD/dl c - R. D. Martin, Region IV Resident Inspectors, CPSES (3) e7072006180%3}45 PDR ADOCK O j PDR p 400 Nonh Olive Stat LB 81 Dallas, Texas 75201 h i j

Attachment to TXX-6504 July 13, 1987

. Page 1 of 18 NOTICE OF VIOLATION

. ITEM A.1.a (445/8620-V-03a: 446/8617-V-03pl ITEM A.1.b (445/8620-V-03b: 446/8617-V-03b)

ITEM A.1.c.1 (445/8620-V-04a: 446/8617-V-04a)

ITEM A.1.c.2 (445/8620-V-04b: 446/8617-V-04bs A. Criterion V of Appendix B to 10CFR Part 50, as implemented by Final Safety Analysis Report (FSAR) Section 17.1.5 and Texas Utilities Generating Co.

(TUGCo) QA Plan (QAP) Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

1. Failure to Specify Documents / Revisions. Obtain Anoroval of Travelers and Describe Work Ocerations

a. Brown & Root (B&R) Procedure CP-CPM-6.3, Revisions 1 through 12, has consistently required that procedures and instructions, by number and revision, be included in the traveler.

Contrary to the above, 21 of 28 travelers reviewed failed to specify or include either the applicable work procedure reference; revision level of the drawing, specification or procedure; or both. For example, travelers R183-1051-5700, R179-182-2-5700, ME79-260-5700, and EE86-41073-2/4901 did not contain revision levels while MP85-4910-5500, EE84-40170-2/5501, HS86-4450-1-3100, and EE86-41073-2/4901 either did not reference the drawing or procedure (445/8620-V-03a; 446/8617-V-03a).

b. Paragraph 3.1.1 of CP-CPM-6.3 requires the discipline engineers or construction personnel to obtain Westinghouse (W) approval of the traveler if it involves Nuclear Steam System Supplier (NSSS) equipment.

Contrary to the above, 4 of 19 travelers for controlling work on major NSSS equipment did not include the signature of a M repre-sentative. Examples are ME79-260-5700, MW86-7510-2-5500, CE79-017-5500, and ME83-2959-5500 (445/8620-V-03b; 446/8617-V-03b).

c. Paragraph 2.2.1 of B&R Procedure CP-CPM-6.3, Revision 9, dated February 8,1982, states, in part, " General information normally included on the Operation Traveler is as follows: 1. Part, serial, or tag number and material description (s) where applicable

. . 3. Operation description, methods, procedures (instructions) by number and revision and other information as required to successfully complete the operation in accordance with applicable requirements . . . ."

Paragraph 3.1.2 of the above procedure stat m , in part, "The traveler package shall contain, or may reference, if normally available, the drawing, procedures, instructions, manufacturer's manuals, guidelines, etc. necessary to accomplish the activity . .

Contrary to the above, missing or inadequate work operations were identified for two pieces of NSSS equipment and two Class 1E switches for NSSS equipment as follows:

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I Attachment to TXX-6504 1 July 13,1987 '

Page 2 of 18 NOTICE OF VIOLATION 1 ITEM A.1 CONT'D i (1) Travelers (ME83-2702-5700, ME79-26B&OO, RI83-1051-5700) for safety injection system accumulator tanks (TCX-SIATAT-03; CP2-SIATRT-01) failed to describe or include at least one of the following: equipment for loading and transporting, minimum 1-inch base to foundation clearance, leveling, and tightening of nuts to secure the tank to embedded bolts (445/8620-V-04a; 446/8617-V-04a).

l (2) Travelers (EE82-1415-5801; EE83-0459-5801; EE84-40170-2-5501, part

1) for installing Class- IE switches on safety-related valves failed to describe or include at least one of the following:

caution to determinate gently to prevent damage, description of standard construction practice or otherwise reference the determination / termination instruction in EEI-8, specific torquing l requirements for back and top cover screws, and specific i installation instructions as required by paragraphs 3.0, 4.0, or 5.0 of instruction EEI-21 (445/8620-V-04b; 446/8617-V-04b).

i RESPONSE TO ITEM A. 1 TU Electric accepts the alleged violation and the requested information follows:

1. Reason For Violation The findings noted in this violation involve.the control of activities documented by Construction Operation Travelers controlled in accordance with Procedure CP-CPM-6.3, " Preparation, Approval, and Control of Operation Travelers." This procedure is intended to specify the interface I of participating organizations and include the means by which construction 1 activities are sequenced and accomplished. The traveler is the mechanism-by which unique directions are provided to construction personnel and is used in conjunction with established construction procedures.

As a result of this violation and ongoing evaluations of ou, engineering and construction practices, we have concluded that although the current and historical revisions of the procedure have provided sufficient detailed guidance to properly control related engineering and construction  ;

activities, compliance with procedure CP-CPM-6.3 is not easily verified. '

2. Corrective Steps Taken And Results Achieved The specific traveler discrepancies described in the Notice of Violation have been evaluated. The need for corrective action regardir.g the individual travelers is discussed below. Our planned actions to clarify traveler requirements, and to facilitate verification of compliance with these requirements, are presented in section 3.

Attachment to TXX-6504 )

July 13,1987 l Page 3 of 18 I

2. Corrective Stens Taken And Results Achieved - Item A.1.a Regarding the failure to reference procedures and drawings:

I Procedure CP-CPM-6.3, Revisions 0 through 12 has consistently stated that information normally required on the operation traveler includes operation description, methods, procedures (instructions) by number, and other information as reauired to successfully complete the  !

operation in accordance with applicable requirements. As a result, it '

was not required that all travelers contain references.to specific procedures and drawings. A technical assessment of eight travelers identified in the inspection report as failing to reference procedures i and drawings has confirmed that sufficient information was provided in l

the travelers to accomplish the required task in accordance with applicable requirements. Corrective steps are not considered necessary for these travelers.

l Regarding the failure to indicate revision levels of drawings, specifications, and procedures referenced on travelers:

Revision 11 to CP-CPM-6.3 (effective August 8,1984) deleted the 1 requirement to indicate the revision level of procedures and '

instructions which are referenced on the traveler. The following travelers (which were identified in tables 2 and 3 of Appendix C of the Inspection Report as being in noncompliance for failure to indicate revision level) were written after August 8,1984 and do not l l require revision levels for the references.

MW86-7528-2-5501 ME85-4872-5500 EE86-41073-2/4901 EE84-40170-2/5501 EE86-40692-2/5701 HS-86-4450-1-3100 HS-86-4293-1-4900 EC85-JB2C-4870 MP85-4910-5500 Corrective steps are not considered necessary for these travelers.

The remaining twelve travelers identified in tables 2 and 3 of Appendix C which were written prior to August 8, 1984, violated CP-CPM-6.3 in that revision levels were not given when procedures and instructions were referenced. This portion of the violation was caused by a failure to follow procedure on the part of personnel  !

writing and reviewing the travelers. The CPSES document control program,. as originally implemented in March 1977 by Revision 5 to DCP-1 03, "CPSES Document Control Program," provides assurance that the twelve travelers written prior to the effective date of Revision 11 to CP-CPM-6.3 (August 8, 1984) were' performed in accordance with the latest revision of the procedures and drawings referenced on the travelers.

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Attachment to TXX-6504 July 13, 1987 Page 4 of 18

2. Corrective Steos Taken And Results Achieved - Item A.l.a (CONT'D)

Through the use c,f computer listings of- controlled documents and copy holders, DCP-03, Rev. 5, assured that only current, approved documents were issued to construction activities. The procedure also required notifying controlled copy holders of changes to controlled documents.

Deficiency Report (DR) C-87-2754 has been written to document the failure to specify reference revision levels on the twelve travelers.

ITEM A.l.b (445/8620-V-03b: 446/8617-V-03b)

The requirement to obtain Westinghouse approval if the traveler involves NSSS equipment was added to procedure CP-CPM-6.3 by Revision-7 which became effective June 6, 1980. Travelers ME79-260-5700 and CE79-017-550 were issued and completed prior to this date, and therefore did not require Westinghouse approval'. Traveler MW86-7510-2-5500 involved work on a pressurizer insulation support ring which is not NSSS equipment. Westinghouse approval was not considered necessary. Traveler ME83-2959-5500 was signed by a Westinghouse representative as required by Revision 10 of CP-CPM-6.3. Corrective steps are not considered necessary for these travelers.

ITEM A.l.c.1 (445/8620-V-04a: 446/8617-V-04a)

Regarding the failure to describe or include equipment for loading and transporting:

Traveler RI83-1051-5700 described the equipment for loading and transporting tank CP2-SIATRT-01. Traveler ME83-2702-5700 governed work performed after loading and transporting tank CP2-SIATRT-01.

Traveler ME79-260-5700 did not describe the equipment for loading and transporting tank TCX-SIATAT-03 since these requirements were specified in traveler RI79-182-2-5700. Corrective steps are not considered necessary for these travelers.

Regarding the failure to include the minimum 1-inch base to foundation clearance:

Traveler ME79-260-5700, Step 2 described the 1-inch clearance requirement for tank TCX-SIATAT-03. Base to foundation clearance requirements were not applicable and were not described in travelers RI83-1051-5700 or ME-2702-5700 since tank CP2-SIATRT-01 is mounted on top of tank CP2-SIATRT-02. Corrective steps are not considered necessary for these travelers.

Regarding the failure to include leveling instructions:

Traveler ME79-260-5700, Step 3, provided leveling instructions for tank TCX-SIATAT-03. The levelness of tank CPS-SIATRT-01 was established by leveling the supporting tank CP2-SIATRT-02. Leveling of tank CP2-SIATRT-02 was performed per another traveler, ME83-2703-5700. Corrective steps are not considered necessary for these travelers.

Attachment to TXX-6504 July 13, 1987 Page 5 of 18

2. Corrective Steos Taken And Results Achieved - Item A.1.c.1 (CONT'D)

Regarding the failure to describe tightening of nuts to secure the tank to embedded bolts:

Tank CP2-SIATRT-01 is not secured by the use of embedded bolts. Tank CP2-SIATRT-01 is secured to the top of tank CPP-SIATRT-02.

Requirements for tightening of bolts to secure the tanks to each other is specified in Step 2 of traveler ME83-2702-5700. Tank TXC-SIATAT-03 is secured to the foundation per procedure MCP-1 which was referenced on traveler ME79-260-5700. Procedure MCP-1 provides requirements for installing anchor nuts. Per specification 2323-MS-101, " Erection of Mechanical Equipment," no torque values were required. Corrective steps are not considered necessary for these travelers.

Item A.1.c.2 (445/8620-V-04b: 446/8617-V-04b)

Regarding the failure to include a caution to determinate gently to prevent damage:

The use of caution to prevent damage when determinating conductors that are to be re-used is a standard practice. It is not considered necessary to specify good workmanship in procedures and instructions.

Although this caution was included in traveler EE82-1415-5810, it was not required. Similarly, the inclusion of similar cautions in travelers EE83-0459-5801 and EE84-40170-2-5501 was not considered necessary. Corrective steps are not considered necessary for these I travelers.

Regarding the failure to include a description of standard construction l practice or otherwise reference the determination / termination instructions in EEI-8:

Procedure EEI-8, " Class 1E and Non-Class 1E Cable Termination," does not contain instructions for the determination of conductors. Normal determination of conductors is within the craft capability and written technical instructions are not considered necessary.

I Procedure EEI-8 provides the standard construction practices for terminating conductors. The craft personnel who perform conductor terminations receive specific training to procedure eel-8. In the absence of additional specific instructions, craft personnel refer to EEI-8 for direction. Therefore, it was not necessary to specifically reference eel-8 in travelers EE82-1415-5801 and EE84-40170-2-5501.

Traveler EE83-0459-5801 referenced EEI-8 even though it was not necessary. Corrective steps are not considered necessary for these travelers.

1 Attachment to TXX-6504 July 13, 1987 Page 6 of 18 ]

2. Corrective Action Taken And Results Achieved - Item A.1.c.2 (CONT'D)

Regarding the failure to include specific torquing requirements for back and top cover screws:

Traveler EE84-40170-2-5501 requires torquing the front (top) and back (bottom) cover screws to 20 in-lbs. in Step 10. Traveler EE83-0459-5801, Step 2, requires torquing the back (bottom) cover screws to 20 (

in-lbs. Step 3 of this traveler requires determination in accordance 1 with procedure EEI-21, " Installation Requirements for NAMC0 Limit Switches," which specifies torquing the front (top) cover screws to 20 in-lbs. Traveler EE82-1415-5801, Step 6, requires torquing the front (top) screws to 20 in-lbs. Since the limit switches covered by this j traveler are outside containment, there are no torque requirements for the back (bottom) cover screws as currently specified in eel-21.

Corrective steps are not considered necessary for these travelers.

Regarding the failure to describe or include specific installation f instructions as required by paragraphs 3.0, 4.0 or 5.0 of instruction EEI- 1 21: j Traveler EE83-0459-5801 referenced procedure EEI-21 and is in compliance with technical requirements. The EEI-21 requirements which j were not included in travelers EE84-40170-2-5501 and EE82-1415-5801 j were either not applicable, were general workmanship practices, or in excess of the minimum technical requirements. Traveler EE84-40170 ]

5501 (which is similar to EE82-1415-5801) has been the subject of an J engineering assessment which has concluded that sufficient information was provided to accomplish the required task in accordance with applicable requirements. Corrective steps are not considered necessary for these travelers.

3. Corrective Steos Which Will Be Taken To Avoid Further Violations We are continuing to evaluate Procedure CP-CPM-6.3 and will revise the procedure. Our assessment of this procedure will address the following considerations regarding traveler preparation implementation, and ease of verification:

1. The need to reference existing procedures, instructions, drawings, and specifications to the maximum extent practicable.

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2. Measures to ensure that the latest revision levels of referenced docu;nents are used to perform the activities covered by the traveler, and to ensure the revision levels are documented.

3. Clarification of what constitutes NSSS equipment.

4. Cross referencing travelers that are performed sequentially on a specific component or set of components.

5. Development of a list of procedures that provide " standard construction practices" for various commonly performed operations.

Such "self-invoking" procedures would not have to be specifically referenced on travelers.

Attachment to TXX-6504 July 13,1987 Page 7 of 18

4. Date When Full Comoliance Will be Achieved Corrective actions required by DR C-87-2754 will be completed no later than October 30, 1987.

Procedure CP-CPM-6.3 will be revised no later than September 30, 1987.

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Attachment to TXX-6504 ,

July 13, 1987 j Page 8 of 18 j NOTICE OF VIOLATION 1 ITEM A.2 (445/8620-V-05: 446/8617-V-05) i A. Criterion V of Appendix B to 10CFR Part 50, as implemented by Final Safety 4 Analysis Report (FSAR) Section 17.1.5 and Texas Utilities Generating Co.

(TUGCo) QA Plan (QAP) Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

2. 0A/0C Failed to Adeouately Monitor Traveler Svstem Implementation B&R Procedure CP-CPM-6.3, Revision 0 through 12, states that the site QC or QA manager and construction superintendents or discipline engineers are responsible for the implementation of this procedure; however, the site QA/QC manager is responsible for monitoring the implementation of the system.

Contrary to the above, QA/QC management did not adequately monitor and t assure the effective implementation of the traveler system as evidenced by deficiencies identified in a sample of 21 of 28 travelers. The following are specific examples:

a. Paragraph 3.6 of CP-CPM-6.3, Revisions 5 and 9, require revisions, regardless of their significance, shall be numbered and changes described after the last traveler operation.

Contrary to the above:

I Travelers RI83-1051-5700, Operation 5; ME83-2702-5700, Attachment No. I design dimension; and ME79-260-5700, Attachment No. 1 manway elevation are examples of travelers which did not have revision numbers or descriptions of changes.

Operation Nos. 2 and 5 on traveler RI83-1051-5700 for nitrogen accumulator tank number 1 were revised after the traveler was approved. Operation No. 2 was a minor change; however, No. 5 was a major revision as a step which had been left out was added.

i Such chang..s were not approved or noted as revisions (445/8620-V-05a; 446/Eo17-V-05a).

b. Paragraph 2.2.1 of CP-CPM-6.3, Revision 11, dated August 8, 1984,  :

and Revision 12, dated July 14, 1986, requires the quality control inspector to annotate the applicable inspection / revision numbers on the traveler operation at the time of inspection.

Paragraph 3.1.2 of CP-CPM-6.3, Revisions 11 and 12, requires the quality control inspector to record the design document revision level used at the time of final inspection.

The QC inspectors did not annotate the inspection procedure / revision level for HS86-4450-1-3100, MP85-491-5500, HS86-4293-1-4900 and HS86-4450-1-3100 (446/8617-V-05b).

t m_.______ _ _ _ _ _ _______-

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Attachment to TXX-6504 July 13, 1987 Page 9 of 18 NOTICE OF VIOLATION ITEM A.2 (445/8620-V-05: 446/8617-V-05) CONT'D C. Paragraph 3.2 of B&R Procedure QI-QAP-11.1-39, Revision 4, states, in part, "QCI shall verify . . . b. The top of the concrete foundations are free of oil, grease, and foreign materials."

l No operation for assuring foundation cleanliness was described on traveler ME83-2702-5700 for setting the nitrogen accumulator tank No. 1 (tank 1). Another example was identified on ME79-260-5700 for setting safety injection accumulator tank No. 3 (446/8617-V-05c).

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d. Paragraph 3.4.1 of QI-QAP-11.1-39, Revision 4, states, in part, "QCI shall verify that equipment is positioned, oriented and set I to elevation as shown on Level / Location / Elevation / Record (Attachment 1)." Paragraph 5.0 states, in part, ". . . . QC1 shall sign and date . . . . Record (Attachment 1)."

Attachment 1 of ME83-2702-5700 was not signed and dated by the QCI to show that the nitrogen tank 1 was installed as required (446/8617-V-05d). l

e. Paragraph 3.4.2.2 of QI-QAP-11.1-39, Revision 4, states, in part, "b. All equipment excluding rotating equipment and heat exchangers may be set using a carpenter's level placed on the base or machined surface, as appropriate. The equipment shall be shimmed so that the bubble is contained between the two closest lines on the level. NOTE: for a. and b. above, equipment setting requiring 3 grout, a minimum of grout space of one inch shall be provided at j the point of minimum clearance between the equipment bases and concrete foundation."

Neither a minimum clearance was specified on traveler ME83-2702-  !

l 5700 for tank 1, nor was the applicable construction Procedure l MCP-1, Revision 3, referenced (445-8617-V-05e). '

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Attachn.ent to -TXX-6504 July 13, 1987 Page 10 of 18 NOTICE OF VIOLATION ITEM A.2 (445/8620-V-05: 446/8617-V-05) CONT'D

f. Paragraph 3.4.3 of QI-QAP-11.1-39 states, in part, "QCI shall verify that anchor bolt threads are not damaged prior to and during the setting of equipment."

Traveler ME83-2702-5700 for tank 1 neither specified the inspection of anchor bolt threads in the operational steps nor addressed the tightening of the bolts (446/8617-V-05f).

NOTICE OF VIOLATION RESPONSE TO ITEM A.2 (445/8620-V-05: 446/8617-V-05)

TV Electric accepts portions of Examples 2.a and 2.b of the violation; however, TV Electric disagrees with the stated general . basis for the overall violation and the remainder of the examples for the reasons that follow:

l General Basis l Regarding the general basis for the violation concerning QA/QC monitoring of the implementation of the traveler system, the provisions of the referenced procedure were not completely described in the violation. The provision from Procedure CP-CPM-6.3 Revision 12, Section 2.1, " Responsibility," which was summarized in the violation states:

"The B&R Site QA Manager is responsible for monitoring the implementation of the system through the assignment of QC inspection points and consultation with the ANI for selection of ANI inspection points for ASME-related activities. TUGC0 QA is responsible for the assignment of QC inspection points for non-ASME activities."

The QA/QC responsibility described by the above paragraph includes the review of the Operation Traveler prior to traveler implementation to determine the need for, and assignment of, QC inspection hold points to assure important l

activities are satisfactorily accomplished. It does not require any other QA/QC monitoring of the traveler system implementation.

Example 2.a (445/8620-V-05a; 446/8617-V-05a)

None of the matters addressed in this example were in violation of Paragraph 2.1 of CP-CPM-6.3 since the activities described occurred subsequent to QA/QC review of the travelers.

Regarding the change to Attachment 1 of traveler ME79-260-5700, it was made prior to review and issue of the traveler and was not a revision. Therefore, the change was not in violation of CP-CPM-6.3.

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Attachment to TXX-6504 July 13, 1987 i Page 11 of 18 l l

RESPONSE TO ITEM A.2 (445/8620-V-05: 446/8617-V-051 CONT'D Examole 2.b (446/8617-V-05b)

None of the matters addressed in this example were in violation of Paragraph 2.1 of CP-CPM-6.3 since the activities described occurred subsequent to QA/QC review of the travelers. j i Regarding the travelers mentioned in the violation, failures to reference the procedure and/or design document revision level used for final inspection were not in violation of Paragraph 3.1.2 of CP-CPM-6.3 for the reasons that follow:

Procedure CP-CPM-6.3 Revisions 0 through 12 consistently stated that information normally reouired on the operation traveler includes operation description, methods, procedures (instructions) by number, and other information as reouired to successfully complete the operation in accordance with applicable requirements. However, travelers may be_ issued as " stand alone" instructions provided they contain sufficient information to accomplish the desired task in accordance with pertinent requirements, therefore references are not required for all travelers. I With the exception of traveler EE83-0459-5801, the travelers identified by the NRC inspector contained the appropriate inspection instruction thereby I eliminating the need for procedure reference, or referenced a specific inspection report which did identify the procedure and revision level used for inspection.

The travelers cited as not containing design document revision level were implemented for verification of tolerance modifications imposed after  !

initial construction and inspection. The required pipe clearances were specified on these travelers and the attached Component Modification Cards referenced the specific implementing travelers.  :

Examole 2.c (446/8617-V-05c)

Regarding traveler ME83-2702-5700, the referenced provision of QI-QAP-11.1-39 is applicable to the setting of equipment on concrete foundations and is not applicable to this installation because Nitrogen Accumulator Tank 1 was set on top.of Safety Injection Accumulator Tank 2.

Regarding traveler ME79-260-5700, the referenced criteria was not in effect at the time Safety Injection Accumulator Tank 3 was installed. QC Instruction QI-QAP-11.1-39 Revision 0 was issued February 3, 1983. Grout was placed under Tank 3 on August 29, 1979 as documented on Grout Placement Card Number 021 and Grout Inspection Report (IR)-C-3840. Attribute 2 on the IR from QI-QP-11.0-6 documents the surface condition of the tank foundation as acceptable prior to grout placement. The criteria referenced by the NRC inspector was included in QI-QAP-11.1-39 Revision 0 as an added assurance that concrete surfaces would-he acceptable prior to grout operations.

Attachment to TXX-6504 j July 13,1987 Page 12 of 18 RESPONSE TO ITEM A.2 (445/8620-V-05: 446/8617-V-05) CONT'D l Example 2.d (446/8617-V-05d)

The referenced provisions of QI-QAP-11.1-39 are applicable to the setting of equipment on concrete foundations and are not applicable to this installation because Nitrogen Accumulator Tank 1 was set on top of Safety Injection Accumulator Tank 2. The verification of level / location / elevation was unnecessary since these attributes were predetermined by the Safety Injection Accumulator Tank 2 installation.

Example 2.e (446/8617-V-05e)

The referenced provision of QI-QAP-11.1-39 is applicable to setting of equipment to achieve sufficient clearance between the equipment base and the concrete foundation to facilitate subsequent grout placement. Traveler ME83- j 2702-5700 provides instruction for the installation and inspection of the d Nitrogen Accumulator Tank 1 on top of Safety Injection Accumulator Tank 2.

Since grout is not required between the tanks, a minimum clearance is not necessary and this attribute was not included on the traveler. 1 Examole 2.f (446/8617-V-05f) l l

The referenced provision of QI-QAP-11.1-39 is applicable to equipment settings i involving anchor bolts (i.e., bolts embedded in concrete) and is not 1 applicable to this installation of Nitrogen Accumulator Tank 1 on top of Safety Injection Accumulator Tank 2. Due to this configuration, anchor bolts were not involved in attaching the tanks. Bolting materials that were used to >

join the tanks are specified on traveler ME83-2707-5700 by type, size and grade, including required torque valves.

RESPONSE TO ITEM A.2 (446/8617-V-05)

For the portions of Examples 2.a and 2.b which TV Electric accepts, the requested information follows:

1. Reason For Violation Examole 2.a The failure to properly process revisions to travelers ME83-2702-5700 and RI83-1051-5700 was the result of personnel failing to comply with the requirements of Section 3.3 -of Revision 9 to CP-CPM-6.3, which was in effect at the time the travelers were worked. The change made to Step 2 of traveler RI83-1051-5700 consisted of correction of an obvious typographic error (change " Reactor Building #1" to " Reactor Building #2").

The change to Step 5 of traveler R183-1051-5700 consisted of adding a sentence to temporarily locate the subject tank until it could be installed in its permanent location. The change to Attachment #1 of traveler ME83-2702-5700 consisted of correcting two design dimensions which were provided for comparison against actual dimensions.

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Attachment to TXX-6504 July 13, 1987 Page 13 of 18

, RESPONSE TO ITEM A.2 (446/8617-V-05) CONT'D Example 2.b Regarding traveler EE83-0459-5801 mentioned in the details of the NRC inspection report, the QC inspector failed to reference the revision of QI-QP-11.3-47 in effect at the time of limit switch installation inspection.

2. Corrective Steps Taken And Results Achieved Example 2.a The improperly processed traveler revisions were technically correct, and did not result in any hardware deficiencies, therefore, no corrective action is required for existing installations. DR-C-87-2750 was initiated to document the failure to process these traveler revisions in accordance '

with CP-CPM-6.3.

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Examole 2.b l Deficiency Report DR-C-87-2617 was initiated to resolve the failure to document the revision of QI-QP-11.3-47 used for verification of the limit

witch installation described on traveler EE83-0459-5801.

3. Corrective Steos Which Will Be Taken To Avoid Further Violations Example 2.a To ensure personnel understand the requirements governing traveler revisions and changes, Section 3.3 of CP-CPM-6.3 will be revised and clarified as required. Appropriate personnel will be trained in the revised requirements.

Example 2.b The QC procedure control program, as implemented by CP-QP-7.1, " Issuance and Control of Quality Procedures and Instructions," provides assurance l that inspections performed are in accordance with the latest revision of l the procedures referenced on the travelers. Further preventative action i may be initiated as required by the disposition of DR-C-87-2617. i l

' Attachment to TXX-6504 July 13, 1987  !

Page 14 of 18 i

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RESPONSE TO ITEM A.2 (446/8617-V-05) CONT'D

4. Date When Full Compliance Will Be Achieved Examole 2.a The revision to Procecure CP-CPM-6.3 will _ be issued and personnel' will be retrained by September 30, 1987. The disposition of DR-C-87-2750 is expected to be accomplished by October 12, 1987. l Example 2.b Full compliance will be achieved upon disposition of DR-C-87-2617 which is expected to be accomplished by October 12, 1987.

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Attachment to TXX-6504 July 13, 1987 Page 15 of 18 NOTICE OF VIOLATION ITEM A.3 (446/8617-V-06)

A. Criterion V of Appendix B to 10CFR Part 50, as implemented by Final Safety Analysis Repcrt (FSAR) Section 17.1.5 and Texas Utilities Generating Co.

(TUGCo) QA Plan (QAP) Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances a .d shall be accomplished in accordance with these instructions, procedures, or drawings.

3. Failure To Maintain Traveler Packaae At Work Area Paragraph 3.2 of B&R Procedure CP-CPM-6.3, Revision 11, dated August 8, 1984, states, in part, "The traveler package shall remain in the work area until the work has been completed and accepted by QA/QC or until the end of the shift, which ever is first . . . "

Contrary to the above, on July 2, 1986, the NRC inspector observed the heat treating of mainsteam spool piece MS2-RB-29-1 at the 905' elevation in reactor building No. 2 and found that the traveler work package was not in the work area. It was later located in the welding rod shack which is outside the reactor building (446/8617-V-06).

RESPONSE TO ITEM A.3 (446/8617-V-06)

TV Electric disagrees with the alleged violation for the reasons that follow:

Construction Operation Travelers were not used to direct the post weld heat treatment of the subject welds, therefore the requirements of CP-CPM-6.3 are not applicable Procedure CP-CPM-6.9D, " Welding and Related Processes,"

contains the provisions for controlling post weld heat treatment, and Construction Operation Travelers are not required. Procedure CP-CPM-6.9D does not require work packages to remain in the work area since the manipulations required are not complex and heat treatment may last several hours. Also, proper heat treatment can be verified from time vs. temperature charts, subsequent to the heat treating process.

Attachment to TXX-6504  !

July 13, 1987 Page 16 of 18 NOTICE OF VIOLATION ITEM B (446/8617-V-07)

B. Criterion XVI of Appendix B to 10 CFR Part 50, as implemented by Section 17.1.16 of the FSAR and by TUGC0 QA Plan (QAP) Section 16.0, Revision 0, dated July 1,1978 requires the prompt identification, reporting, and correction of failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances.

Failure To Correct Steam Generator Soin Numbers And Documentation TUGC0 QAP Section 16.0 states, in part, " Documented measures are used to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, and nonconformances, are promptly identified and corrected as soon as practicable, and that appropriate action be taken to correct the cause of the condition."

Contrary to the above:

On August 1, 1986, the NRC inspector found that steam generator spin No.

TCX-RCPCSG-01 which is shown on Gibbs &' Hill, Inc., Drawings 2323-A2-502, Revision 5, 2323-A2-0503, Revision 4 and 2323-0504, Revision 4 as being located in reactor coolant loop No. 4 was incorrect. The steam generator with this spin number is actually in loop No.1. TUGC0 correspondence in

, 1980 showed that management was aware of this condition and asked Westinghouse Electric Corporation to correct this deficiency and design documents. Further inspection revealed the following:

1. From 1980 to August 20, 1986, TUGC0 failed to issue a nonconformance report (NRC) to identify this condition which existed for all four steam generators and failed to tag the steam generators with a hold tag to indicate that the name plates and documentation were incorrect.

An NCR was issued after the NRC inspector identified this problem and discussed it with the site management.

2. From 1980 to August 1986, TUGC0 failed to.take prompt corrective action concerning these deficiencies. That is, to either revise FSAR, Volume I, Figure 1-2-18, Amendment 10, 1980; Volume VI, Figure 5.1-1 (2 sheets), " Flow Diagram Reactor Coolant System"; and the Gibbs &

Hill drawings referenced above, or require Westinghouse to exchange the name plates and revise their documentation to match the as-built condition (446/8617-V-07).

RESPONSE TO ITEM B (446/8617-V-07) l TU Electric accepts the alleged violation and the requested information follows:

Attachment to TXX-6504 July 13, 1987 Page 17 of 18 NOTICE OF VIOLATION RESPONSE TO ITEM B (446/8617-V-07) CONT'D

1. Reason For Violation For information, in the following discussions the term SPIN number refers to the Westinghouse Standard Plant Identification Number. This number is unique to a given component location in a system. Thus if a component is replaced, the new component assumes the old component's SPIN number.

Also, the steam generator SPIN number stated in the violation is in error, TCX-RCPCSG-01 should be stated as TCX-RCPCSG-04.

Item 1 of the violation resulted from the failure of various personnel to recognize the need for a corrective action document.

Prior to installation it was determined that, based on the SPIN numbers shown on the label plates, the SG's could not be physically installed in the locations specified by the applicable drawings. To correct the problem, Westinghouse authorized (via letter TCX-M-015 dated April 28, 1980) reversing the locations of SG No. 01 and SG No. 04; and SG No. 02 and SC No. 03. The provisions of this letter were subsequently verified by Westinghouse letter WPT-3554 dated July 2,1980. Traveler ME80-2005-5500 directed installation of the SG's in accordance with letter TCX-M-015. Installation of the SG's was performed in May of 1980. Per Westinghouse letter WPT-3753 dated September 30, 1980, Westinghouse committed to revise the applicable Quality Releases (QR's), as-built drawings, and technical manuals, and to provide new label plates with SPIN numbers corresponding to the actual SG locations. The various personnel involved were thus aware that the as-installed SG location was technically required, vendor approved, and documented in the installation traveler.

They were also aware that action had been initiated to change the related documentation and to correct the SG label plates. However, they overlooked the need to issue a corrective action document that would ensure these actions were tracked to completion.

Item 2 of the violation resulted from the failure to issue a corrective action document as described above. A Westinghouse Purchase Order was issued in June of 1981 to provide new label plates and revise the documentation. Also, Comanche Peak Engineering and Westinghouse personnel were aware that these actions were incomplete. However, completion of these actions would have been expedited if they were tracked by a corrective action document.

2. Corrective Steps Taken And Results Achieve _d Nonconformance Reports (NCR's) M-28675, M-28676, M-28677, and M-28678 (all dated August 20, 1986) were written to document the SPIN number discrepancy. These NCR's were dispositioned to re-stamp the existing SG label plates with SPIN numbers corresponding to the actual SG location.

This action, which has been completed, is intended as an interim measure until the new label plates are installed. The applicable QR's, as-built drawings, and technical manuals have been revised. The installation of new label plates is being tracked in the Master Data Base system as items 17085, 17095, 17105 and 17115 under subsystem 2-5501.

Attachment to TXX-6504 i July 13, 1987 Page 18 of 18

.' NOTICE OF VIOLATION RESPONSE TO ITEM B (446/8617-V-07) CONT'D

3. Corrective Steos Which Will Be Taken To Avoid Further Violations Since the violation occurred over six years ago and resulted from ]

oversights by various personnel, preinstruction of specific individuals is '

not considered practical or beneficial.

Nonconformance reporting is currently governed by TV Electric procedure NE0-3.05 (Reporting and Control of Nonconformances). This procedure specifies that Engineering, Construction and Quality Assurance personnel are to initiate NCR's as required, when nonconforming conditions are identified. Training of Engineering, Construction and Quality Assurance personnel on procedure NE0 3.05, Rev. O, or its implementing procedures has been completed. Training of Engineering, Construction and Quality l Assurance personnel to revisions to these procedures is performed in accordance with the applicable training programs. TV Electric believes that current training programs adequately indoctrinate personnel on their responsibility to document nonconforming conditions.

4. Date When Full Comoliance Will Be Achieved The new SG label plates will be installed following the Unit 2 SG hydros and magnetic particle examination. Installation of the new label plates will be completed by July 31, 1988 based on the current Unit 2 construction schedule.

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