TXX-6939, Responds to NRC Re Violations & Deviations Noted in Insp Repts 50-445/87-18 & 50-446/87-14.Corrective Actions:Package Flow Group Instituted Std Method for Designating Procedure Attachment on Package Inventory Cards
| ML20236X872 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/07/1987 |
| From: | Beck J, Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-6939, NUDOCS 8712100327 | |
| Download: ML20236X872 (13) | |
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MEE Log #.TXX-6939
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File # 10130
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IR 87-18 Ref #
C 2 01 wmiam c. counsu December 7, 1987 Eaccutive %cr President l
U. S. Nuclear Regulutory Commission l~
Attn:
Document Control Desk L
Washington, D. C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT NOS.
50-445/87-18 AND 50-446/87-14 Gentlemen:
TU Electric has reviewed your letter dated November 5,1987, concerning the inspection conducted by Mr.1. Barnes and other inspectors and consultants during the period September 3 through October 6,1987.
This inspection 1
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 l
Violation and Deviation.
We hereby respond to the Notice of Violation and Deviation in the attachment to this letter Very truly yours, l ). G C.
W. G. Counsil l
By:'J uW. Beck Vice President Nuclear Engineering RDD:grr i
Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) i 7
8712100327 871207
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PDR ADOCK 05000445 I
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G PDR 400 North Olise Strcel LB 81 Dallas, Texas 75201
Attachment to TXX-6939 December 7, 1987 Fage 1 of 12 NOTICE OF VIOLATION ITEM A (4F575718-V-04; 446/8714-V-03)
A.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TV Electric Quality Assurance Plan (QAP), requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings.
Section 5.0 of Brown and Root Procedure CP-CPM-7.1, Revision 3, " Package Flow Control" requires that the contents of documentation packages be verified as being complete and current by distribution satellite personnel prior to initial issuance of the package, and upon return or
- ompletion of work, the distribution satellite personnel are to assure the documents issued are returned.
The package inventory card is used by distribution satellite personnel to account for the documents contained in the documentation packages.
Contrary to the above, on September 16 and 17, 1987, the NRC inspector identified 10 electrical penetration assembly documentation packages, which had been verified by distribution satellite personnel as agreeing l
with the package inventory card, whose contents did not agree with the package inventory card.
The following documentation packages contained megger data sheets not listed on the package inventory card:
2E-16, 1[-
59 module E, 1E-43 module A, 1E-43 module B, 1E-43 module C, IE-52 module A, IE-52 module B, 1E-52 module C, 1E-52 module 0, and IE-55 module F (445/8718-V-04; 446/8714-V-03).
RESPONSE TO VIOLATION ITEM A ( M /87T8-V-04; 44678714-V-03)
TV Electric agrees with the alleged violation and the requested information follows:
1.
Reason for Violation The negger data sheets referenced in the notice of violation were provided as an attachment to procedure eel-22, " Installation of Conax Feedthrough/ Adapter Module Assemblies into Amphenol Sams Penetrations".
Megger data is recorded on these sheets in the field and the sheets are retained in the applicable Electrical Penetration Assembly (EPA) j documentation packages.
The documentation packages were not found to be i
missing any rnegger data sheets, however, the data sheets were not always
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entered on the Package Inventory Cards (PIC).
The failure of Package j
Flow Group (PFG) personnel to consistently enter the megger data sheets i
on the PIC resulted f rom uncertainty as to how to make the entry.
Unlike most entries on the PICS, the megger data sheets had no descriptive title, and were not part of a OC Inspection Report that would have provided a unique identi fier.
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, Attachment to TXX-6939 December 7, 1987 Page E of 12 NOTICE OF VIOLATION ITEM A (445/87W-V D~4TT46787F4W-03) (CONT'D)
Although PFG personnel failed to consistently enter the megger data sheets on the PIC, TV Electric believes that the PICS would have been corrected during the package review process.
After all work associated with a package is complete and prior to transmittal to the records vault, the package is reviewed in accordance with procedure CP-CPM-7.ll, "Non-ASME Q Documentation Package Revies." This procedure requires verification that the PIC includes all required documents.
In this manner, assurance is provided that the PICS are complete prior to vaulting of the package.
2.
Corrective Steps Taken and Resul_ts Achieved The PFG has instituted a standard method for designating procedure attachments on the PICS.
All EPA documentation packages have been reviewed and the PICS have been corrected to indicate the megger data sheets contained in the packages.
Since all documentation packages are I
reviewed per CP-CPM-7.11 prior to vaulting, no further package review is considered necessary.
3.
Corrective Steps Which Will be Taken to Avoid Further Violations The PFG Group Leaders have instructed their group personnel on the standard methods to be used for designating procedure attachments on the PICS.
4.
Dato When Full Compliance Will be Achieved The instruction of PFG personnel on the standard method for designating l
procedure attachments on PICS was completed by October 9, 1987.
The review of EPA packages and correction of PICS was completed by October 16, 1987.
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.Attachmc-nt to TXX-6939 December 7, 1987 Page 3 of-12 I
NOTICE OF VIOLATION IiEHT[445787187~091
.B.
Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section i
i 10.0, Revision 1, dated July 31, 1984, of the TV Electric QAP states, in part, "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity...
Examinations, measurements, or tests of material or products processed shall be performed for each work operation where necessary to assure quality.
Engineering and Construction Engineering Procedure ECE 9.04-04, which is part of the post construction hardware clidation program, addresses the reinspection /walkdown of accessible attributes.
It also requires the identification of inaccessible attributes so that an engineering evaluation will be performed.
Contrary to the above, the following condition was identified:
The adjacent weld distance attribute for pipe support WP-X-AB-050-003-3 was documented as being satisfactory on the associated Adjacent Weld Checklist.
However, this attribute is inaccessible due to the presence of Bisco seal material in the penetration that the pipe runs through.
The acceptance of this inaccessible attribute by QC precluded the required engineering evaluation from being performed (445/8718-V-09).
RESPONSE TO VIOLATION ITEM B (445/8718-V-09)_
TV Electric agrees with the alleged violation and the requested information follows:
1.
Reason for Violation The cause of the deficiency was a lack of adequate direction in Inspection Procedure CP-QAP-12.1 for the disposition of Hardware Validation Program (HVP) supplemental attributes which are determined to be inaccessible.
2.
Corrective Steps Taken and Results Achieved To address the specific concern identified in the Notice of Violation, Nonconformance Report (NCR) M-87-A01921 was issued on September 29, 1987.
This NCR will resolve the issue as it relates to this specific Adjacent Weld Checklist attribute.
Due to the nature of the deficiency identified on NCR M-87-A01921, Deficiency Report C-87-3884 was issued to address programmatic concerns.
The disposition of the DR identified the cause described above, and Procedure CP-QAP-12.1 has been modified to specifically address the initiation of a NCR for HVP supplemental inspection checklist attributes which are inaccessible.
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. Attachment to TXX-6939 December 7, 1987 Page 4 of 12 NOTICE 0F VIOLATION ITEM 8'T44578718-V-09)-(CONT'D)
During a'recent routine inspection surveillance of ASME pipe support' l
packages, it was noted that QC verification of some attributes haa been inappropriately documented and/or performed.
The results of these examinations, the issuance of DR C-87-3884 and the similar issues raised in NRC Notice of Violation 445/8718-V-08 resulted in issuance of Corrective Action Request (CAR) 87-78.
This CAR was issued to address the programmatic deficiencies and assure that additional HVP activities were conducted in accordance with project requirements.
All HVP pipe support packages placed in the Interi;n Records Vault prior to November 15, 1987, will be reviewed by ASME QC personnel to identify and resolve any package deficiencies in accordance with the process defined in the response to CAR 87-78.
J.
Corrective Steps Which Will be Taken to Avoid further Violations To prevent further violations CP-QAP-12.1, " Mechanical Component Installation Verification," was revised on November 15, 1987, to specifically address the initiation of NCRs for HVP supplemental inspection checklist attributes which are inaccessible.
Training of the ASME QC personnel responsible for implementation of this procedure has been conducted.
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Date When Full Compliance Will be Achieved l
The review of pipe support packages placed in the Interim Records Vault prior to November 15, 1987, is anticipated to be completed by December 31, 1987.
CAR 87-78, NCR M-87-A01921 and DR C-87-3884 will be l
c'iosed by January 31, 1988.
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. Attachment to TXX-6939
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December 7, 1987
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NOTICE OF VIOLATION ITEM C (445/8718-V-08)
C.
Criterion XV of Appendix B to 10 CFR Part 50, as implements by Section l
15.0, Revision 5, dated July 31, 1984, of the TV Electric %P, states, i
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" Measures shall be established to control materials, parts, or components l
which do not confonn to requirements in order to prevent their 1
inadvertent use or installation.
These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition, and notification to af fected organizations.
Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures."
Procedures CP-QAP-12.1, paragraph 6.1.2, Revision 20, dated July 10, l
1987, states, in part, "For defective or flawed material or components, an NCR must be generated...."
Contrary to the above, a nonconformance report (NCR) was not issued for a high strength capscrew (item 15 of pipe support CC-1-SB-001-001-3) which broke during installation before the specified design torque value was achieved.
This precluded an investigation and engineering evaluation of the nonconforming item (445/8718-V-08).
RESPONSE TO VIOLATION fHrF(44578718-V-6B)
TV Electric agrees with the alleged violation and the requested information follows:
1.
Reason for Violation The reason for this violation was an inadequate procedure which did not adequately address the issuance of an NCR for defective or flawed material.
2.
Corrective Steps Taken and Results Achieved Following identification of this issue by the NRC, a Nonconformance Report (M-87-A10852) was issued to address the specific installation identified.
This NCR has been dispositioned to have the applicable hanger reworked to the original design.
To address the programmatic concerns, a Deficiency Report (C-87-3885) was initiated.
This DR initiated a review of the controlling procedure and determined that it did not adequately define the terms " flawed" or
" failed" material.
This procedure, CP-QAP-12.1, " Mechanical Component Installation Verification," has been revised to expand the definition of
" flawed material."
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. Attachment to IXX-6939 December 7,1987 Page 6 of 12 NOTICE OF VIOLATION
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ITEM C T4457Ml8-V-08TTCONT'DJ During a recent routine surveillance of ASME pipe support packages it was noted that QC verification of some attributes had been inappropriately documented and/or performed.
The results of these examinations, the issuance of OR C-87-3885, and similar issues raised in NRC Notice of Violation 445/8718-V-09 resulted in issuance of Corrective Action Request (CAR) 87-78.
This CAR was issued to address +he programmatic deficiencies and assure that additional Hardware Validation Program OlVP) activities were conducted in accordance with project requirements. All HVP pipe support packages placed in the Interim Records Vault prior to November 15, 1987, will be reviewed by ASME QA personnel.
This review will resolve any package deficiencies in accordance with the process defined in t'ne response to CAR 87-78.
3.
Corrective Steps Which Will be Taken to Avoid Further Violations Procedure CP-QAP-12.1 was revised on November 15, 1987, to expand the definition of " flawed material." The ASME QC personnel responsible for applying this revised definition have been retrained in its application.
4.
Date When Full Compliance Will be Achieved The review of pipe support packages placed in the Interim Records Vault prior to November 15, 1987, is anticipated to be completed by December 31, 1987. CAR 87-78, NCR M-87-A10852 and DR C-87-3885 will be closed by January 31, 1988.
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' Attachment to TXX-6939
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December 7, 1987 Page 7 of 12
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NOTICE OF VIOLATION ITEM D (4T5/8718-V-02; 44676714-V-01)
D.
Criterion XVI of Appendix B to 10 CFR Part 50, as implemented by Section 16.0, Revision 0, dated July 1, 1978, of the TV Electric OAP, states, in part, " Measures shal1 he established to assure that conditions adverse to quality, such as... deficiencies, deviations and nonconformances...are promptly identifieo and corrected."
Section 17.1.15 of the CPSES FSAR, states, in part, "A nonconformance report (NCR) is a document used for documenting, controlling, and correcting a condition..."
The disposition of such a document, NCR M 2320, Revision 3, required that for the 3" steam generator hold-down bolts:
(1) Bolts with gaps greater than.010 inch shall be shimmed.
(2) The tabs on stainless steel shims shall be held up against the bolt head with 3/4" wide carbon steel banding.
The banding shall be tight enough to prevent removal by hand.
(3) A copy of the material documentation for the shims shall be attached to the NCR.
Disposition of NCR M-2320 was completed and verified complete by'QC inspection on November 25, 1981.
Contraiy to the above, the NRC inspector found the following not accomplished during a field inspection on September 11, 1987:
(1) shims required to be installed under two of the Unit 2 steam generator hold-down bolts were found to be missing; (2) banding required to be installed to hold the shim material in place for the Unit 2 steam generator hold-down bolts was found to be missing from two bolts and was improperly placed for an additional six bolts; ar.d (3) documentation of the shim material identity was not included in the NCR M-2320 (445/8718-V-02; 446/8714-V-01).
RESPONSE TO VIOLATION ITEM D (44F/8718-V-02; 446/8714-V-01)
TV Electric agrees with the alleged violation and the requested information follows:
1.
Reason for Violation Based on review of documentation and discussions with personnel involved, the sunject shims and bands were installed as required by NCR M-2320 Rev.
3.
Subsequent to installation, some of the shims and bands were apparently dislodged by personnel working in or transiting the area.
The area of the steam generator lower support ring where the shims and bands were located is known to be an area where personnel walk and the shims and bands could have been easily stepped on and/or kicked loose.
Attachment to TXX-6939 December 7, 1987 Page 8 of 12 NOTICE OF VIOLATION ITEM D (445/8718-V-02; 4467117T UV-01) (CONT'D)
The QC inspection report which is included in the NCR M-2320 Rev. 3 package contains a sign-off that the QC inspector verified the material identification.
Also, the completed NCR and supporting documentation was reviewed and approved by a QC Supervisor, an Authorized Nuclear inspector and a Quality Engineer.
TV Electric, therefore, believes that the material documentation for the shims was lost subsequent to close out of the NCR.
2.
Corrective Steps Taken and Results Achieved NCRs 87-00041 through -00047 have been written to document the missing and improperly placed shims and bands, and the missing material documentation for both Unit 1 and Unit 2 steam generators.
Measures will be taken to ensure that the shims and bands are not damaged or dislodged after the deficient conditions are corrected.
3.
Corrective Steps Which Will be Taken to Avoid Further Violations On October 27, 1987, the Director of Engineering issued a memo directing that personnel be trained on protection of plant equipment.
I TV Electric has implemented a " package" concept for control of both ASME and Non-ASME documentation.
Documentation for individual components is kept in a single package and the contents are inventoried when the package is returned to. Paper Flow Group.
These measures facilitate prompt' identification of lost documentation and implementation of appropriate corrective actions.
The control of packages is governed by procedure CP-CPM-7.1, " Package Flow Control" and its appendixes.
Procedure CP-CPM-7.1 was made effective for Unit 1 and Unit 2 on December 15, 1986, and February 7,1984, respectively.
4.
Date When Full Compliance Will be Achieved Correction of the shim and banding deficiencies, and implementation of measures to prevent damage or dislodging of shims and bands will be completed no later than Plant Heatup for Unit 1 and Hot Functional Testing for Unit 2.
The training of appropriate Engineering and Construction field personnel on protection of equipment will be completed no later than December 18, 1987.
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Attachment to TXX-6939
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NOTICE OF DEVIATION (445/8718-0-10)
Section 4.1, "Walkdown Guidelines," of Revision 1 to Impell Project instruction (PI) 0210-052-004, states, in part, "The walkdown information will be documented using the checklists provided in attachment B.... Table I provides the acceptable tolerances to be used in the walkdown process.
" Guidelines for performing the conduit support and conduit routing walkdowns are provided below....
" Item 5.
Support Configuration
- Draw an as-built sketch
- Identify all structural /Unistrut member sizes, lengths...
" Item 6, Support Deficiencies
- Identify any gross deficiencies in the support...
" Item 7.
Hilti Kwik Anchorbolt Information
- Identify letter stamp and Projection Length of all anchor bolts on supports...."
The following examples, identified by the NRC during inspection and review of the post construction hardware validation program (PCHVP) module, Train C Conduit less Than or Equal to 2", are in deviation from the above criteria:
(1)
For analysis tag A-03173 in Room 206, Impell incorrectly recorded the length designator on the end of a 1/4" diameter Hilti Kwik bolt as being an "E" stamp (3 1/2" long).
The NRC inspector observed the length designator to be a "D" stamp (3" long).
(2)
For analysis tag A-03173 in Room 206, it was determined during the NRC inspector's inspection that an 1/8" gap exists between the 3/4" diameter conduit and the conduit support shim plate, thus invalidating its three-way restraint design function.
This invalidates all portions of the Impell analysis where this three-way support was considered.
(3) for analysis tag A-03177 in Room 206, Impell had recorded that the projected length of the 1/4" diameter Hilti Kwik bolt was 3/4".
The subsequent NRC inspection determined this length to be 1 1/8".
The specified allowable tolerance was 1/4".
(4) for Calculation No. A-03451 in Room 54, Impell had recorded on RFI No.
RFI-E5-1-1043, that Hilti Kwik bolt No. 1 was located 4 1/2" from the top edge of the Unistrut channel.
The NRC inspector, however, determined the bolt to be located 3" from the edge.
The specified allowable tolerance was 1/4".
. Attachment to TXX-6939 December 7, 1987 Page 10 of 12 (5)
For Calculation No. A-03138 in Room 54, Impell had recorded that the projected length of the 1/2" diameter Hilti Kwik bolt for support A-03145/NQ-08290 was 1".
The subsequent NRC inspection determined this length to be 1 1/2".
The specified allowable tolerance was 1/4" (445/8718-D-10).
In addition to the deviation specified above, the NRC inspectors have identifled other discrepancies of a similar nature.
These discrepancies have been presented as Open Items in NRC Inspection Report 50-445/87-25; 50-446/87-19.
The Open items are restated below:
"While_ performing the walkdown for Calculation L2-S-1-EC-130, the NRC inspector identified a discrepancy in the Impell work.
It involved the span length between supports 2-23955 and 2-23956.
Impell had recorded this span length as 40" while the NRC inspector determined it to be 47 1/2."
Subsequently, Impell stated that the Level 6 interaction evaluation determined that there were no safety-related equipment, systems, or components in the room.
Accordingly, no interactions (either acceptable or unacceptable) will occur in this room and the conclusions initially arrived at would not be affected.
The NRC inspector concurred 1
with this explanation; however, a determination must still be made as to whether this error was an isolated case and what impact, if any, it would have on other walkdowns that the identified individuals were involved with.
This subject is an open item pending the making of this determination (445/8725-0-02)."
"While performing the field walkdown on the Request for Field Information (RFI) data for the Level 5 calculation A-00631, the NRC inspector identified a discre It involved the span distance between supports A-00632 (N/0-07192)pancy.and A-00633 (N/Q-07191).
Impell had recorded this dimension as 11 1/2" while the NRC inspector determined it to be 35 1/2".
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Upon notification of this discrepancy, Impell informed the NRC inspector that this error had occurred on Revision 0 of the calculation which had been superseded by Revision 1 which states, " Supports in this calculation have been qualified by Level 6."
The Level 6 evaluation showed that no safety-related equipment existed in the vicinity of these supports.
The NRC inspector verified that the supports were qualified by the level 6 support interaction evaluation; however, a determination must still be made as to whether this error was an isolated case and what impact, if any, it would have on other walkdowns that the identified individuals i
were involved with.
This subject is an open item pending this I
determination (445/8725-0-03)."
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Attachment to TXX-6939 December 7, 1987 Page 11 of 12
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RESPONSE TO DEVIATION j'
(445/8718-0-10) i TV Electric agrees with the alleged deviation and the requested information follows:
1.
Reason for Deviation The five discrepancies identified in the Notice of Deviation and the two discrepancies identified in the Open Items all resulted from inaccurate recording and checking of walkdown data on the part of personnel.
2.
Corrective Steps Taken and Results Achieved The discrepant conditions described in items 1 through 4 of the Notice of Deviation were examined in the field by Impell personnel.
The results of the examination confirmed the NRC inspectors observation in each case.
The applicable walkdown forms and calculations have been revised accordingly.
In each case, the qualification status of the conduit support did not change.
The discrepant condition described in item 5 of the Notice of Deviation was examined in the field by Impe11 personnel.
The results of the examination showed that the projection length of the 1/2 inch Hilti bolt was 1 3/8 inches instead of 1 inch as recorded on the RFl.
The applicable walkdown forms and calculations have been revised accordingly.
The qualification status of the support did not change.
The discrepant conditions described in Open Items 445/8725-0-02 and -03 were examined in the field by Impell personnel.
The results of the examination confirmed the NRC inspectors observation.
However, Impell had subsequently determined that for both cases, there was no safety i
related equipment in the vicinity per the Level 6 support interaction evaluation.
Hence, the discrepant calculations were rendered unnecessary.
3.
Corrective Steps Which Will be Taken to Avoid Further Deviations Those engineers that are still on site who were involved in the walkdowns that resulted in items 1 through 3 of the Notice of Deviation, as well as all other personnel involved in the structural integrity group have been retrained on the importance of documenting walkdown data accurately.
Subsequent to the issuance of the Notice of Deviation and Open items discussed above, NRC inspectors have informed TV Electric of what appears to be additional Train C walkdown discrepancies.
Deficiency Report C87-4800 has been initiated and TV Electric is investigating these discrepancies and formulating appropriate actions to address any generic implications.
An update to this response will be submitted describing our additional corrective actions.
t Attachment to TXX-6939 December 7,1987 Page 12 of 12 i
NOTICE OF DEVIATION i
(44578718-D-10) (CONT'D) 4.
Dat_e When Full Compliance Will be Achieved An update to this response will be submitted describing our additional corrective actions no later than January 29, 1988.
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