TXX-6832, Revised Response to NRC Re Violations Noted in Insp Repts 50-445/85-16 & 50-446/85-13,per . Corrective Actions:Nonconformance Repts Ncr XI-708,issued on 851114,transferred to Ncr M-25650 on 860311

Revised Response to NRC Re Violations Noted in Insp Repts 50-445/85-16 & 50-446/85-13,per . Corrective Actions:Nonconformance Repts Ncr XI-708,issued on 851114,transferred to Ncr M-25650 on 860311

ML20235U987
Person / Time
Site:	Comanche Peak
Issue date:	10/09/1987
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-6832, NUDOCS 8710140367
Download: ML20235U987 (3)

Text

. _ _ _ _ _

A.

Log # TXX-6832

= File # 10130 L  : IR 85-16 IR 85-13

# I0 # *I nlELECTRIC October 9, 1987 William G. Counsli Esecutive Vks PresMent i

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 REVISED RESPONSE REGARDING INSPECTION REPORT 1' 50-445/85-16 AND 50-446/85-13 Ref: 1) NRC letter from E. H. Johnson to W. G. Counsil dated April 4, 1986

2) TV Electric letter TXX-4826 from W. G. Counsil dated June 16, 1986

3) TU Electric letter TXX-6697 from W. G. Counsil dated September 4, 1987 Gentlemen:

Reference (2) provided our original response to Notice of Violation (NOV) Item C (445/8516-V-13) of Inspection Report 50-445/85-16 and 50-446/85-13. In reference (3) TV Electric committed to revise our original response in order to. clarify our position. Accordingly, a revised response is enclosed. Since the entire response has been revised, no revision bars have been provided.

Very truly yours,

?L W. G. Counsil

.RDD:tgj c- Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) l l

Q*%*El &E G

l 29l

.800 Nonh Olne Strtst LB BI Dallas Texas 7201 9 IfI

Attachment to TXX-6832-

-( ~ October 9, 1987-w Page l'of 2 1

NOTICE OF VIOLATION ITEM C (445/8516-V-13) 1

.C. Criterion X of Appendix B to 10 CFR 50, as implemented by Section 10.0, Revision 1, dated July 31,'1984, of the TUGC0 QAP, states, in part, " A prograk for inspection of activities affecting quality shall be established and executed ... to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity."

l l Paragraph 5.1.2 in B&R Procedure CP-NDEP-200, Revision dated September 27, 1979, states, in part, "The final surface condition of plate and piping welds shall be visually inspected after completion of the weld for ...

fillet size (as applicable)." Revision 4 of Drawing CC-1+131-010-S43R requires welds on two sides for item 8 to' item 9, with a fillet size of L 1/4 inch. A weld fillet size of 1/4 is also specified for items 9 and'10.

4 l Contrary to the above, inspection of Unit 1 ASME Pipe Support No. CC 131-010-S43R, which had been previously inspected and accepted by Quality Control, identified the' presence of' undersize welds. A total weld length of approximately 20 inches was found to be undersize by a minimum of 1/16 l inch with respect to the item 8 to item 9 fillet' welds. A consecutive 2-

. inch segment was also present in these welds which was 1/8 inch undersize.

The vertical welds on the outside of the wide flange joining items 9.and 10 were also found to be undersize by a minimum of 1/16 inch for more than 25% of the weld length (445/8516-V-13).

REVISED RESPONSE l ITEM C (445/8516-V-13)

TU Electric agrees with .the alleged violation and the requested information follows:

l l' 1. Reason for Violation The reason for the violation was inadequate QC inspection of the as-built weld size to the weld size required by the associated design documents.

2. Corrective Steos Taken and Results Achieved To address the specific deficiencies identified in the violation, Nonconformance Report (NCR) XI-708 was issued on November 14, 1985. This NCR was subsequently transferred to NCR M-25650 on March 11, 1986. NCR M-25650 was dispositioned " accept as is" based on an evaluation of the as-built '

conditions.

3. Corrective' Steps Which Will be Taken to Avoid Further Violations The Issue' Specific Action Plan VII.c weld size reinspection

< Attachment to TXX-6832 m

) October 9, 1987 -

Page.2 of 2 conducted on Unit -l' by the third party did not indicate the quality of pipe -

support welds to be a problem area. The reinspection results indicated a very low incidence of undersized welds, and none were identified that were considered safety significant. TU Electric believes that these results demonstrate the isolated nature of this violation and adequately address the undersize weld issue for Unit I weld inspection activities. We also believe that these results are indicative-of the quality of work performed in Unit 2 since it was construe,ted and inspected using similar criteria and the same personnel.

$1nce initial inspection of the subject welds in 1979 and the final weld inspection in 1982, a number of revisions to the component support weld-inspection program have been made. These revisions were aimed at improving the quality of weld inspections and their documentation. For example:

With the issuance of QI-QAP-11.1-28 Revision 16 on December 15, 1982, a Weld Inspection Checklist (WICL) was required to be com)1eted by the QC Inspector (QCI) for each pipe support at the time of fabrication completion. Prior to this time, less stringent documentation requirements were applied. Completion of the WICL required the QCI to measure the actual weld size and record it on the WICL, initial and date the WICL, and sign and date the hanger design drawing and/or CMC. Since the hanger design drawing and/or CMC contained the design weld sizes, these provisions provided additional assurance that the inspectors were comparing the deposited weld size to the design weld size.

Revision 24 to QI-QAP-11.1-28 issued April 18, 1984 significantly expanded the scope of the Hanger Inspection Report completed for each hanger. This revision required the WICL to be completed for all Unit 2 supports regardless of the fabrication or installation status. Additionally, this revision was intended to assure objective evidence of QCI verification of each quantitative attribute considered relevant to the analysis by engineering.

Another significant change was implemented via Revision 11 of CP-QAP-12.1, l which was issued on June 28, 1984. That revision required Brown and Root N-5 package reviewers to assure that individual weld inspections were performed and documented correctly by verifying the inclusion of a completed WICL in the completed work package. That revision also required reinspection of any component support welds which were submitted for package review in accordance with this procedure and not previously documented on a WICL per QI-QAP-II.1-28.

These revisions have resulted in an improved program which enhanced the assurance that weld inspections are properly performed. The majority of the Unit 2' component support weld inspections have been performed with these controls. Throughout implementation of these improvements, the individuals responsible for implementing the changes have been trained in their application. j I- Date When full Compliance Will be Achieved 4.

NCR M-25650 was dispositioned on October 6, 1986, and will be closed prior to Unit I fuel load. Revision 11 to CP-QAP-12.1 was approved on June 28, 1984.

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