TXX-6616, Revises Response to Notice of Deviation Item B,Per NRC 870325 Request for Addl Info Re Insp Repts 50-445/86-03 & 50-446/87-02.Corrective Actions:Value of Data Obtained by Earlier Insps of Welds Through Coatings Being Addressed

Revises Response to Notice of Deviation Item B,Per NRC 870325 Request for Addl Info Re Insp Repts 50-445/86-03 & 50-446/87-02.Corrective Actions:Value of Data Obtained by Earlier Insps of Welds Through Coatings Being Addressed

ML20238D788
Person / Time
Site:	Comanche Peak
Issue date:	09/08/1987
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-6616, NUDOCS 8709110395
Download: ML20238D788 (5)

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- 1R 86-03 86-02 7UELECTRIC Ref # 10CFR2.201 Wmiarn ba. Cwevil . a

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S U.gS. Nuclear Regulatory Commission ,

j i i Attn: Document Control Desk Wa#Mr,gton, D. C. 20555 SUBJ7.CTi COMANCHEPEAKSTEAMELECTRICSTATION(CPSES[

DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT 50-445/86-03 AND 50-446/8E 02 il/

REVISED RESPONSE TO NOTICE OF DEVIATION ITEM 3 ^

REF: TUGC0 Letter TXX-608' 9 from W. G. Counsil to E. H. Johnson dated '

4 January 12, 1987.

p Gent.lemen: ,

-Your letter to W. G. Counsil of March 25, 1987, requested additicnal )

.isiormation regarding Inspection Report 445/86-03 and 446/86-02 Notice of j Deviation item B (445/8603-F18). Extensions were requested and granted via . i telephone conversations. with Mr.1. Barnes on August 5,1987, August 12, 1987 4 and August 17, 1987. '7ais issue has been trevaluated with regard to your L request; our revised response is attached. [

o Very t,ruly yours, ,

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/ c - Mr. R. D. Nrt.in, Region IV Resident inspectors, CDSES (3)

B709110395 870909

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Attachment to TXX-6616

[ f"Lc . September 8, 1987 w  %, Page 1 of 3

_', NOTICE OF DEVIATION IfrWVT443786D3-U:B) l B. Paragraph 5.1 of ERC Procedure CPP-007, Revision 2 states, in part," Responsible 0A/0C discipline engineers review the latest . . . Brown l <? & Root . . . documents relating to the population. Subsequently, the engineer develops a list of safety significant attributes that are common to the population and which can be reinspected . . . ."

ll Paragraph 3.4.4.3 in Brown & Root, Inc. Instruction 01-0AP-11.1-28, 1 Revision 31, identifies requirements for base material inspection and states, in part, "The depression depth produced by grinding shall not exceed . . 1/32" for material less than 3/8" thick (structural shapes)."

, f, In deviation from the above, the responsible OA/QC discipline engineer

/ failed to identify and incorporate into ERC 01-029 this base material f / inspection attribute. As a result, ERC inspection of Verification Package L No.1-S-LBSN-065 failed to identify that grinding on base material in excess of 1/32" existed on item 3 of pipe support MK No. CT-1-008-001-S225.

REQUEST FOR ADDITIONAL INFORMATION N0 LICE OF DEVIATION if[M B (4457BT03 T B) i For N00, Item B, base material defect inspection was not identified as an attribute to be excluded as is required by ERC CPP-007. Your response that accurate reinspection cannot be performed following application of coatings is not consistent with your position regarding inspection for weld defects through paint. Inspection of welds in the coated condition and after removal of the coating was successfully demonstrated by ERC using Ql-062. The observed condition became acceptable in accordance with ,

QI-QAP-11.1-28 only after the issuance of DCA-41710 wSich clarified  ?

0 acceptance criteria. Therefore, please respond to the deviation as originally requested. j 1

REVISEDRESPONSE10ITEMB(445/8603-D-18] {

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10 Electric admits to the deviation and the requested information follows:

, ,g 1.\ Reason for the Deviation The reinspection for base material defects due to grinding was not i identified as an attribute in QI-029. Furthermore, base material defect  !

inspection was not identified as an attribute to be excluded in Ql-029 as J required by ERC's procedure CPP-007. The failure to exclude this attribute (characteristic) per the requirement of CPP-007 was an omission by the ERC QA/QC Discipline Engineer.

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Attachment to TXX-6616 o September 8,1987 '

i Page 2.of 3

1. Reason for the Deviation (cont.) '

Regarding the " grinding on base metal in excest of 1/32"," since ,the attribute was not identified as an item to be inspected, the ERC impector failed to identify the defect. -

2. Corrective Action Taken ERC Quality Instruction 01-029 addresses the rM nspection of large-bore non-rigid pipe supports. The attributes for this population were identified and discussed in a memorandum apended to 01-029. This memorandum identified the source of the attributes, identifito.those attributes (or characteristics) that nere excluded fro:1 reinspection and o provided the justification for these exclusions. Tne mer,wandun his beerL revised to identify base metal defcets as a characteritt.ic of the welding attnbute that relates to the population but has been excluded frce the o reinspection being performed per Q1-029. The detailsd justification for this exclusion is also included in the revi<.ed memorandunw EkC Quality Instructions01-027 and 01-019, which address the reinspecucyt of large-bore rigid and small-bore pipe supports, respectively, are also being modified in the same manner as QI-029. '

In summary, the reinspection of base metc.1 defects was excluded for ail pipe supports covered by the ASME Code Subsection Hr because thew types of defects frequently become undetectable upan the applicatio1 of iarmus-coating systems that potentially serve to mask defects should tNy exist. O While excessive grinding may be readily detectable after initial' ,

installation is complete, it cannot be accurately reinspected following '

the application of the aforementioned coatings. Once coatings have been applied, it is very difficult to distinguish between nurkings due to grinding versus other potential causes. 'While the ASME Code Subsection NF stipulates that grinding to remove wcld defects may not encroach on minimum base metal thickness, there is no Code requirement to inspect for other types of defects in base metal that are not a result of the weldicq process. Thus, this attribute is made inaccessible by the application of coatings.

Due to NRC inspector concerns regarding the excessive grinding, on Out-of-Scope observation was written for Verifications Package No.1-5-l.BSN-065.

A Nonconformance Report (NRC), No. CM-87-05486 Was subsequently issued.

The NCR is expected to be dispost Hned by Unit 1 fuel load.

3. Action To Prevent Recurrence A review of the attributes that were included and those that were excluned in the Quality Instruction for each hardware construction work categoiy

l. (CWC) is being conducted as a part of the QuaMty of Construction (QOC)

! collective evaluation effort. This review wi .1 eraure that the list of attributes for each CWC is complete and that n e attributes which were not reinspected were properly excluded.

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4. Date Of Full toap,ligge i The value ut' the data obtained by earlier inspections of welds through

-3 coatings is being addressed in the appropriate CPRT Results Reports and il Project reports. TU Electric will complete the review of the attributes and achieve full compliance by November 30, 1987.

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