TXX-7037, Responds to NRC Re Violations Noted in Insp Repts 50-445/87-16 & 50-446/87-13.Corrective Actions: Nonconformance Repts Issued Between Aug 1986 & Aug 1987 Reviewed Per Brown & Root ASME QA Program
| ML20236X906 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/07/1987 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-7037, NUDOCS 8712100352 | |
| Download: ML20236X906 (5) | |
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M Log # TXX-7037
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File # 10130 C
T-IR 87-16 IR 87-13 7UELECTRIC Ref. # 10CFR2.201 WWiam G. Counsil i
zm., vw, presaw December 7, 1987 l
U. S. Nuclear Regulatory Commission l
Attn: Document Control Desk Washington, D.C. 20555 SilBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT N05.
50-445/87-16 AND 50-446/87-13 Gentlemen:
10 Electric has reviewed your letter dated October 23, 1987, concerning the ins)ection conducted by Mr. I. Darnes and other inspectors in the Comanche Peas 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 Dev.iation.
Notice of Violation Item C (445/8716-V-12) and Notice of Deviation (445/8716-D-01) were addressed in TV Electric letter TXX-6937 dated November 23, 1987.
On November 23, 1987, per a telephone conversation with Mr. R. F. Warnick, we requested and received an extension as follows: NOV Item A (445/8716-V-02; 446/8713-V-01) and NOV Item D (445/8716-V-10; 446/8713-V-09) extended until December 7, 1987.
We hereby respond to the above items in the attachment to this letter.
Very truly yours, W. G. Counsil RDD/grr Attachment c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3) 0f 8712100352 871207 PDR ADOCK 05000445 0
PDR I
MM North Othe Strees LB 81 Dallar, Texas 75201
Attachment-to TXX-7037 December 7, 1987 Page 1 of 4 NOTICE OF VIOLATION ITEM A (4457871FVTG2T 44678713-V-01)
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, "Mesures shall be established to assure that conditions adverse I
to quality...(be corrected and)... action taken to preclude repetition."
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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 problems) be identified, the cause established, and action taken to prevent repetition.
Contrary to be 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 (443/8716-V-02; 446/8713-V-01)
TV Electric agrees with the alleged violation and the requested information follows:
1.
Reason for Violation Two procedural requirements provide the controls to identify and prevent repetition of deficient conditions initially identified by NCRs.
First is the requirement for review of NCRs for potential need to issue Corrective Action Requests.
Second is the requirement to evaluate NCRs for adverse trends. The NCRs identified in the Notice of Violation were resolved as
" invalid" which precluded application of both of the procedural controls used to prevent repetition of deficiencies.
The reason for this violation was personnel error by the individuals who approved the resolution of the NCRs as " invalid" based on inappropriate or incomplete justification.
With the exception of NCR M-28567, the " invalid" resolution of the NCR's identified in the violation was the correct resolution, although the resolution was poorly justified on the NCRs.
NCR M-28567 was revised on November 25, 1986 to address the inappropriate initial " invalid" resolution which was due to misidentification of the affected equipment.
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Attachment to TXX-7037 l
December 7, 1987 Page 2 of 4 RESPONSE TO VIOLATION ITEM A (445/67T6-V-021 4467B7UW-01)_(CONT ' D[
2.
Corrective Steps Taken and Results Achieved All of the NCRs identified in the Notice of Violation were issued in accordance with the Brown and Root ASME Quality Assurance Program as it existed prior to issuance of NE0 3.06, " Deficiency Reporting." A review l
of NCRs issued between August 1986 and August 1987 in accordance with the Brown and Root ASME QA Program and which had been resolved as " invalid" was conducted to evaluate generic implications.
The review identified 37 NCRs which did not appear to provide adequate justification for resolution as " invalid." These finding were documented on a Brown and Root ASME Corrective Action Request (Number 70). Only one required further documentation to justify its resolution as " invalid" and it was addressed by issuance of DR C-87-04574. No hardware nonconfermance was left uncorrected by these NCRs.
A review is also being conducted of non-ASME NCRs which have been resolved as " invalid".
This review will provide assurance that similar deficient justifications do not exist in the TV Electric Construction non-ASME NCR process.
The results of these reviews will be evaluated to determine the need to expand the corrective actions.
3.
Corrective Steps Which Will be Taken to Avoid Further Violations The procedural allowance for the B&R Site QA Manager to delegate the authority for approval of " invalid" resolutions has been removed which will limit the applicat. ion of the " invalid" resolution to those specifically approved by the Site QA Manager.
To further improve the quality of Brown and Root ASME NCR resolution, the controlling administrative procedure (AAP-16.1) was revised on November 16, 1987, to require periodic sampling of each type of NCR classified by disposition. This review will verify the adequacy of the nonconformance descriptions and dispositions.
Based on the results of the review of ASME NCRs described above, the corrective actions described in CAR 70 are deemed adequate to address this issue.
The review of NCRs described in SDAR 86-48 (TV Electric letter TXX-6560 dated July 15,1987) will assure that concerns which could affect engineering requirements, and are not the subject of other reverification efforts, are addressed.
4.
Date When Full Compliance Will be Achieved All identified actions required to address the programmatic deficiencies identified have been completed.
The review of TV Electric Construction non-ASME NCR's resolved as " invalid" and the corrective actions for Brown 4
and Root ASME CAR 70 are anticipated to be complete by March 1, 1988.
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Additionally, the review of NCRs for impact on engineering requirements will be conducted as scheduled in our reports related to SDAR 86-48.
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Attachment to TXX-7037 December ~7, 1987 Page 3 of 4 NOTICE OF VIOLATION ITEM B (4457871b T 1 F 446/8713-V-09)
B.
Criterion vil of Appendix B to 10 CFR Part 50, as implemented by Section 7.0, Revision 3, dated July 31,1984, of the 10 Electric'QA. Plan, requires that, 'Heasures 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-13820-5, Supplement 1, for 264 jackshaf ts (components in 6.9kv' circuits breakers) f rom BBC Bronn Boveri, Inc.
A TV Electric trip report, dated Juae 9,1987, documents an inspection of these jackshaf ts at the vendor's plant prior to shipment.
The 264 jackshaf ts shipped from the vendor's plant had been inspected and accepted by TU Electric as complying with new welding acceptance criteria previously approved by TU Electric engineering.
One of these criteria was, "The 3/16" fillet weld can be a minimum of 1/8"..."
Contrary to the bove, during an NRC inspection of five jackshaf ts, 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 inspeciton, conducted September 1, 1987, TV Electric initiated inspections to identify any other jackshafts out of the 264 shipped that did not comply with the welding accptance criteria (445/8716-V-10; 446/8713-V-09).
RESPONSE TO VIOLATION ITEM B (44578716 TID,r446/8713-V-09)
TV Electric agrees with the alleged violation and the requested information follows:
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Reason for Violation This violation was an isolated occurrence of failure of the source inspector to identify a condition not in compliance with the specified acceptance criteria.
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Corrective Steps Taken and Results Achieved In addition to stating "(t)he 3/16" fillet weld can be a minimum of 1/8"
", the weld acceptance criteria also allow a "... gap in the circumferential weld that does not exceed 5/8 inch in length...."
Therefore, any undersized weld segment which does not exceed 5/8 inch in length is acceptable.
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Attachment to TXX-7037 December 7, 1987 Page 4 of 4 RESPONSE TO VIOLATION ITEM B (445/8716-V-10; d46/8713-V-09) (CONT'D)
The source inspection was performed using standard weld inspection methodology. The 210 jackshafts which had not been installed were subjected to a more detailed re-inspection at CPSES for size only, and the results were documented on NCR PE-87-0608 Rev.1.
Only one weld was identified which did not meet the above described acceptance criteria using standard weld inspection methodology.
This weld (item number 273) was determined to be undersize by approximately 1/32 inch over a length of 1.1/4 inch.
The re-inspection results formed the basis for the determination that this was an isolated occurrence of source inspector oversight. The remaining 54 jackshafts which were previously installed are being removed and will also be re-inspected.
These 54 jackshaf ts are identified on NCR PE-87-00619.
3.
Corrective Steps Which Will be Taken to Avoid Further Violations The inspector involved in this event was informed of the results of this investigation, No additional actions are deemed necessary.
4.
Date When full Compliance Will be Achieved Inspection activities related to the 54 jackshafts which were previously installed will be complete by February 26, 1988.
All other required actions are compiete.
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