TXX-6917, Responds to Violations Noted in Insp Repts 50-445/87-13 & 50-446/87-10 on 870708-0804.Corrective Actions:Procedure Will Be Revised to Contain Requirement to Obtain Review of New Startup Work Permit for Adequacy
| ML20236M436 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/06/1987 |
| From: | Counsil W, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-6917, NUDOCS 8711130128 | |
| Download: ML20236M436 (3) | |
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M Log # TXX-6917
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File # 10130 3.
d IR 87-13
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IR 87-10 R*'
- IOCYR**20I TUELECTRIC November 6, 1987 William G. Coumil Decutine Vece itesi&nt 1
U. S. Nuclear Regulatory Commission Attn:
Docurrent Control Desk Washington, D. C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO INSPECTION REPORT NOS.
50-443/87-13 AND 50-446/87-10 Gentlemen:
TV Electric has reviewed your letter dated October 7,1987, concerning the inspection conducted by Mr. I. Barnes and other inspectors and consultants during the period July 8 through August 4, 1987.
This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2.
Attached to your letter was a Notice of Violation.
We hereby respond to the Notice of Violation in the attachment to this letter.
Very truly yours, d 6>-
W. G. Counsil By:
D. R. Woodlan Supervisor, Docket RDD/tgj Attachment c-Mr. R. D. Nartin, Region IV Resident Inspectors, CPSES (3) l e71113012e 871106 DR ADOCK 0500 5
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400 North Olive Street LD 81 Da'tas, Texas 75201
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Attachmentito TXX-6917'
-November 6,L19871 i
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(445/8713-V-01) s.
- Criterion'V of. Appendix B to 10CFR Part 50, as implemented by Section 5.0, Revision.3, dated July 31, 1984, of the TV Electric Quality Assurance Plan (QAP), requiresothat activities affecting quality. shall be prescribed by a' d n
i accomplished in accordance with documented instructions, procedures, or-drawings of a type appropriate to the circumstances.
Section 4.2-4 of CPSES Startup Administrative Procedure CP-SAP-6, Revision 9,.
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" Control of Work on Station Components After. Release.From Construction to TUGCO," dated March 10,.1983, requires with respect to processing of a Startup1 Work Permit (SWP)', thatfTUGC0 Startup "... provide a step-by-step (operation
.r sequence). description.of work to be. performed including any.-reference.to required procedures; design. documents or instruction manuals..."
l Contrary to the above, Startup Work Permit (Construction Operation Traveler)
Z-2214, issued to. perform a hydrostatic test.on the' discharge vent' cover'and the' suction drain cover on Positive Displacement _ Charging Pump TBX-CSAPPD-01, ifailed to provide a.. description of the. applicable torque requirements
- t specified by the vendor-instruction manual for reinstallation 'of these.
. pressure boundary. covers (445/8713-V-01).
RESPONSE TO' (445/8713-V-01)
TV Electric agrees with the alleged. violation and.the requested information followsi 1.
Reason for Violation The purposeLof the Startup Work. Permit..(SWP Z-2214)- was to remove the pump's vent and' drain piping to perform a hydrostatic test of that piping.
The bolting of flanged connections in other piping-systems has no specified torque requirements..Since the cover plates were welded to the piping system and bolted to the pump casing, it was not apparent that the cover plates (flanges) should have been considered as.part of the pump equipment. Consequently, the pump vendor manual was not referred to during the preparation of the SWP and the designation of these cover plates as~ pressure boundary components with torque requirements was overlooked.
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Corrective Steos Taken and Results Achieved:
l Upon notification of the problem and review of the vendor manual, the
. Westinghouse site organization was contacted to determine the
. applicability of the bolt torquing procedure, relative to Section 2.2 of
-the procedure which states; "This procedure.is limited to lubricated external threads and dry collar."
It was confirmed that the cover plates l
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'l Attachment to TXX-6917 November 6, 1987
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i should have been torqued as stated. With that confirmation, non-
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conformance reports were initiated identifying the flanges as not having been torqued following reinstallation-under the SWP in January 1984, although the pump was subsequently operated in preoperational testing in June 1984, without evidence of leakage. These NCRs have not yet been i
dispositioned.
i To determine the scope of the violation, a review of surveillance reports ca Startup activities since 1982 was conducted. This review determined that 10 surveillance were-conducted on the activity of work control, with eight of the 10 specifically addressing the use of SWPs.
A total Of 307 SWPs were reviewed during the surveillance and various problems were found with 65 of the 307 SWPs. All 65 SWPs were evaluated with respect to this violation; that is, specification of vendor manual requirements contained in the work instructions. This evaluation completed on October
'21, 1987, determined that within the sample of 65 SWPs where vendor manual I
requirements applied to the work being performed, requirements were either specified on the SWP or directions provided which referred the individual to the manual (for example, disassemble in accordance with technical manual xyz).
Based upon this evaluation, the scope of the violation is determined to represent an isolated case.
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Corrective Steos Which Will be Taken to Avoid Further Violations:
i Revision 13 of CP-SAP-6, " Control of Work on Station Components After Release from Construction to Startup," Section 4.2.4 will contain a requirement to obtain a review of each new SWP for adequacy of instruction by the individuals group leadee. The group leader is certified by CP-SAP-19, " Indoctrination / Training / Qualification Requirements for Startup Personnel," to Level IV, the highest qualification level for Startup Personnel.
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Date When Full Comoliance Will
.chieved:
Full compliance will be achieved with the issuance of CP-SAP-6, Revision 13, which will be November 30, 1987, a
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