TXX-6937, Responds to NRC Re Violations & Deviation Noted in Insp Repts 50-445/87-16 & 50-446/87-13.Corrective Actions:Nonconformance Rept 81-A01243 Written to Document Missing Cotter Pins
| ML20236S950 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/23/1987 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-6937, NUDOCS 8711300201 | |
| Download: ML20236S950 (7) | |
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FE log.# TXX-6937l
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File # 10730.
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IR 87-16 1
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- wmiam c. counsu November 23, 1987 l
Eucutne Vw P,rsident 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 RESPONSE TO NRC INSPECTION REPORT NOS.
50-445/87-16 AND 50-446/87-13 Gentlemen:
TV' Electric has reviewed your letter dated October 23; 1987,- concerning the inspection conducted by Mr. I. Barnes and other inspe tors in the Comanche l
Peak Project Division during the' period August 5 through September 2,1987.
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'and Deviation.
On November 23, 1987, per a telephone conversation with Mr. R. F. Warnick,'we requested and received an extension as follows:
ItemA(445/8716-V-02;
.446/8713-V-01) and Item B (445/8716-V-10; 446/8713-V-09) extended until.
December 7, 1987.
We hereby respond to the Notice of Violation and Deviation in the attachment to this letter.
Very truly yours, 1714t W. G. Counsil RDD:grr
- Attachment i
C-Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3) 0 1
8711300201 871123 PDR ADOCK 05000445.
I{
G PM 400 North Obvc Street LB 81 Dallas, Texas 73201
Attachment-to TXX-6937 i
November 23,l1987.
'Page 1 of 6-
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t NOTICE 0F VIOLATION ITEM A (445/8716-V-02: 446/8713-V-01).
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' A.
Criterion XVI-of ' Appendix B to 10 CFR Part 50, as implemented.by. Section 16.0,; Revision 0,-of-the TV Electric Quality-Assurance (QA) Plan, requires, " Measures shall be established to assure that conditions adverse to quality...(be corrected.and)... action taken;to preclude repetition."
Nuclear Engineering and Operation Procedure NEO 3.06, " Reporting and-Control of-Deficiencies," implements this criterion by requiring deficiencies (principally programmatic, not directly related to hardware
'j problems) be identified, the cause established,'and action taken to prevent repetition.
Contrary to th'e above, numerous nonconformance reports (NCRs) have been invalidated with no further action required,'when action to prevent-repetition appears to have been necessary.
Examples of these NCRs. include M-21940, M-26470,'M-26471, M-20857, M-21861, M-28567, M-21982, and M-26189-(445/8716-V-02;446/8713-V-01).
RESPONSE TO VIOLATION ITEM A (445/8716-V-02:-446/8713-V-01)
Response will be provided.by December 7, 1987.
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Attachment to TXX-6937 November 23, 1987 Page 2 of 6-NOTICE OF VIOLATION ITEM B (445/8716-V-10: 446/8713-V-09)
B.
Criterion VII of Appendix B to 10 CFR Part 50, as implemented by Section 7.0, Revision 3, dated July 31, 1984, of the TU Electric QA Plan, requires that, " Measures shall be established to assure that purchased material,... conform to the procurement documents. These measures shall include provisions, as appropriate, for... inspection at the contractor or subcontractor source,..."
Such measures were established and implemented concerning TV Electric purchase order CPF-13820-S, Supplement 1, for 264 jackshafts (components in 6.9kv circuit breakers) from BBC Brown Boveri, Inc.
A TU Electric trip report, dated June 9, 1987, documents an inspection of these jackshafts at the vendor's plant prior to shipment. The 264 jackshafts shipped from the vendor's plant had been inspected and accepted by TV Electric as complying with new welding acceptance criteria previously approved by TV Electric engineering. One of these criteria was, "The 3/16" fillet weld can be a minimum of 1/8"..."
Contrary to the above, during an NRC inspection of five jackshafts, onsite awaiting installation, one jackshaft (item number 273) was found with a fillet weld less than 1/8" over a length of 9/16".
Subsequent to this NRC inspection, conducted September 1,1987, TU Electric initiated inspections to identify any other jackshafts out of the 264 shipped that did not comply with the welding acceptance criteria (445/8716-V-10; 446/8713-V-09).
RESPONSE TO VIOLATION ITEM B (445/8716-V-10: 446/8713-V-09)
Recponse will be provided by December 7, 1987.
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i Attachment to TXX-6937 November 23, 1987 Page 3 of 6 NOTICE OF VIOLATION ITEM C (445/8716-V-12)
C.
Criterion XVI of Appendix B to 10CFR Part 50, as implemented by Section 16.0, Revision 0, of the TU Electric QA Plan, states in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition..."
TV Electric, in response to Corrective Action Report (CAR) 65X, which identified a missing cotter pin as a Construction Deficiency, established 1
the Hardware Validation Program (HVP) for safety-related pipe supports.
l Included in this program is a required verification that locking devices are present and correctly installed.
Contrary to the above, the sway strut rear bracket load pin on safety-related pipe support CC-1-295-006-C53R, Revision 4, was observed on August 21, 1987, to have two missing cotter pins although this support had been reworked by craft and acc.epted by QC in accordance with the HVP (445/8716-V-12).
RESPONSE TO VIOLATION ITEM C (445/8716-V-12)
TU Electric agrees with the alleged violation and the requested information follows:
1.
Reason for Violation The subject pipe support was inspected and accepted in accordance with the Hardware Validation Program (HVP) in May of 1987. Although our findings cannot be confirmed, TU Electric believes that the subject cetter pins may have been removed during painting activities which are known to have occurred subsequent to the HVP inspection and prior to the NRC inspectors observation of missing cotter pins.
2.
Corrective Steos Taken and Results Achieved On August 26, 1987, Non-Conformance Report (NCR) 81-A01243 was written documenting the missing cotter pins. To determine the extent of the problem, a reinspection was initiated of 10% of the approximately 3000 pipe supports which had been inspected per the HVP. On September 4, 1987, after reinspecting 45 pipe supports, a loose jam nut was found on pipe support CC-X-079-004-A43R.
NCR 87-A01446 was written and the reinspection effort was terminated.
Based on the identification of an additional discrepancy relating to configuration control, further sampling was not considere1 necessary and Corrective Action Request (CAR)87-075 was initiated;
Attachment to TXX-6937 November 23, 1987 Page 4 of 6 RESPONSE TO VIOLATION ITEM C (445/8716-V-12) (Cont'd) 3.
Corrective Steos Which Will be Taken to Avoid Further Violations On September 9, 1987, the Director of Construction directed that the missing / loose pipe support hardware be investigated and personnel retrained as required.
On September 14, 1987, a Stop Work Order was issued for painting, insulating, and cleaning of safety related systems and components pending retraining of appropriate Construction Department personnel.
On September 15, 1987, Corrective Action Request (CAR)87-075 was issued to document the generic concerns raised by the discovery of the loose / missing hardware.
On September 18, 1987, following completion of the required training, the Stop Work Order of September 14, 1987, was lifted.
On October 27, 1987, a training memo was issued for sign-off by all Comanche Peak Engineering personnel.
This memo included instructions on l
the protection of permanent plant equipment, and was transmitted to all engineering contractors for training of their personnel.
4.
Date When Full Comoliance Will be Achieved Additional corrective actions for CAR 87-075 are currently being considered. An' update to this Response to a Notice of Violation will be submitted providing all additional corrective actions planned and our dates for completion of those actions. The updated response will be submitted no later than January 15, 1988.
Attachment to TXX-6937 November'23, 1987 Page 5 of,6-NOTICE OF DEVIATION (445/8716-D-01)
Appendix 1A(B) of the FSAR commits the applicant to Regulatory Guide 1.68, Revision 2, August 1978. Regulatory Position C.2 of Regulatory Guide (RG) 1.68 (Revision 2 of August 1978), requires, in part, the establishment of i
administrative controls to ensure adequate retesting of systems or design features maintained or modified during or following preoperational testing.
RG 1,68 requires that upon licensing, all safety related systems and design features must meet the preoperational test acceptance criteria as described in the FSAR with any and all exceptions identified to the NRC and appropriately justified.
In deviation from the above, Operations Administrative Procedure STA-623,
" Post Work Testing," Revision 1 of June 26, 1987, does not contain administrative controls to ensure adequate retesting of systems or design features which have been maintained or modified following preoperational l
testing (445/8716-D-01).
r RESPONSE TO DEVIATION (445/8716-D-01) l TV Electric agrees with the alleged deviation and the requested information j
follows:
1.
Reason for Deviation:
At the completion of Preoperational Test activities in the Fall of 1984, it was erroneously assumed that plant licensing was imminent and the only applicable test requirements from Regulatory Guide 1.68 would be those of testing for operability and tests deferred until after fuel load. When plant licensing was delayed, Nuclear Operations personnel failed to reevaluate Regulatory Guide 1.68 for requirements to maintain preoperational test requirements.
2.
Corrective Steos Taken and Results Achieved In the Spring of 1987, Project personnel realized the need to revalidate preoperational test criteria and initiated development of the Pre-Start 4
Test Program. As part of the Pre-Start Test Program, work ectivities i
performod on systems after completion of preoperational testing are being reviewed. The objective of this review is to identify testing needed to ensure that systems and design features still meet preoperational test l
acceptance criteria.
Testing needed to revalidate conformance to preoperational test acceptance criteria will be completed before fuel load or deferred if absolutely necessary to initial heatup. Station work control procedures are being revised to provide administrative controls for identifying and completing post-work testing, needed to validate preoperational test acceptance criteria, as required by Regulatory Guide 1.68.
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.Atiachment:toTXX-6937 November. 23,-1987 Page 6 of.,6--
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. ' RESPONSE IQ VIOLATI0t{
(445/8716-D-01) (Cont'd) 3.
Corrective Steos Which Will be Taken to Avoid Further Deviation-Translation of_ Pre-Start Test. Program requirements into project procedures and revision to existing station work control procedures will-provide the administrative ' controls for preventive' action.
4.
Date When Full Compliance Will be Achieved Procedures-delineating the Pre-Start Test Program will be issued by December 31, 1987.-
Revisions on changes to existing work control procedures will be complete by December 31, 1987..
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