TXX-8816, Updates 880118 Response to Notice of Deviation 445/8731-D-03 Noted in Insp Repts 50-445/87-31 & 50-446/87-23.Corrective Actions:Impell Train C Project Instructions Revised & Rept Issued on Accuracy of Train C Walkdown Data

Updates 880118 Response to Notice of Deviation 445/8731-D-03 Noted in Insp Repts 50-445/87-31 & 50-446/87-23.Corrective Actions:Impell Train C Project Instructions Revised & Rept Issued on Accuracy of Train C Walkdown Data

ML20196A060
Person / Time
Site:	Comanche Peak
Issue date:	01/29/1988
From:	Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-88162, NUDOCS 8802040240
Download: ML20196A060 (5)

Text

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_ t.og # TXX-88162 r7 File # 10130

._., IR 87-31 1R 87-23 NELECTRIC II,OSdAU, January 29, 1988 U. S. Nuclear Regulatory Commission ATTH: Document Control Desk Washington, D.C. 20555 4

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05, 50-445 AND 50-446 INSPECTION REPORT N05. 50-445/87-31 AND 50-446/87-23 VPDATED RESPONSE TO NOTICE OF DEVIATION (N00) 445/8731-D-03 REF: TV Electric Letter TXX-88081 from W. G. Counsil to NRC dated January 18, 1988 Gentlemen:

The referencel letter provided our response to Notice of Deviation (N0D) 445/8731-D-03. In that response we stated that by January 29, 1988, an update describing the rest:lts of our assessment of generic implications would be provided. Our updated response is attached. Those portions of the response which have been revised are denoted by a revision bar in the right margin.

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Very truly yours, W. G. Counsil Vice President, Nuclear Engineering RDD/mgt Attachment c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3)

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Attachment to TXX-88162 January 29, 1988 Page 1 of 4 NOTICE OF DEV!ATION

~(44578731503F-Section 4.1, "Walkdown Guidelines" of Revision 2 to Impell Project Instruction (P!) 0210-052-004 states, in part, "The Walkdown infonnation will be documented using the checklists prcvided in Attachment B . . . . Table 1 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 7. Hilti Kwik Anchor Bolt Information

- Identify letter stamp and projection length of all anchor bolts on supports . . ."

"Conduit Routing Checklist" "Item 1 Conduit Isometrics

- Oraw an as-built sketch showing conduit routing . . .

- Determine span lengths" Section 4.1.4, "Seismic Evaluation of Train C Conduit Supports," of Revision 3 to Impell PI 02310-052-003, states, in part, ". . . SSE support loads are generally calculated by multiplying the conduit tributary mass times the equivalent static acceleration . . . ." Paragraph 4.3.4 further states,

. . . for interaction of . . . loads, the following interaction . . .

equation shall be used . . . ."

1 The following examples, identified by the NRC during inspection and review of the post construction hardware validatier, program (PCHVP) module, Train C 1

Conduit less Than or Equal to 2", are in deviation from the above criteria:

1. On the Type 7 support A-02456/NQ-16508, the NRC inspector identified several discrepancies. The baseplate was reported to be 8" long but was found by the NRC inspector to be 9" long. Impell also reported that the onthor bolts were 1/2" Hilti Kwik bolts; however, they were found to be 1/2" Hilti Super Kwik bolts. Impell reported that the Nelson studs were 1/4" diameter while the NRC inspector determined thoso bolts to be 3/8" diameter.

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Attachment to TXX-88162 January 29, 1988 Page 2 of 4 -

NOTICE OF DEVIATION (COPT'D)

(4457873FF-33T~

2. On the support identified as detail "B", a Type 7 support, impell reported that the anchor bolts were Hilti Kwik bolts; however, the NRC inspector determined that they were Hilti Super Kwik bolts.

3. On the isometric provided on page 4 of 8 in Appendix A of Calculation / Problem No. A-02603, Impell reported a length of conduit between the Type 5 support identified as A-02628 and an adjacent Type 5 support as 21"; however, the NRC inspector determined this length to be 12 1/2".

4. In Calculation / Problem No. A-02454, while performing the load calculation for the northeast / southwest direction for sup) ort A-02605, 'he engineer neglected to include a 14" length of conduit )etween the support being evaluated and an adjacent support.

5. On the Type 5 support evaluation for support A-02605-NQ-16507, the calculated embedment length for the Hilti Kwik bolt was found to be incorrect. Furthermore, the interaction check for the "finger" clamp exceeded the allowable and was justified by adding a note which stated that the calculation is conservative; however, this support is the same support mentioned in paragraph 4 above for which the loart calculation is incorrect (445/8731-0-03).

UPDATED RESPON5E TO NOTICE OF DEVIATION (4457873T-DM1 TU Electric agrees with the alleged deviation and the requested information follows:

1. Reason for Deviation The discrepancies identified in the Notice of Deviation resulted from inaccurate recording, checking and calculating of Train C (non-safety related) 2 inch and under conduit walkdown data on the part of personnel involved.

2. Corrective Steps Taken and Results Achieved The discrepant conditions described in the Notice of Deviation were examined in the field by Impell personnel. The results of the examination confirmed the NPC inspectors observation in each case. The information in the applicable wal6down forms and calculations have be-o i

• v i wd accordingly, in each case, the qualification status of the conduit system did not change. Deficiency Report C-87-4800 has been written to document walkdown discrepancies. [

Attachment to TXX-88162

- January 29, 1988 Page 3 of 4 UPDATED RESP 0flSE T0 fl0TICE OF DEVIATI0ff (C0flT'D)

(445/8731-0-03)

3. Corrective Steps Which Will be Taken to Avoid Further Deviations Those engineers that are still onsite and are involved in the subject walkdowns, as well as all other personnel involved in the Impell structural integrity group have been retrained on this subject, emphasizing the importance of error free walkdown data.

The Comanche Peak Manager of Civil Engineering ht.s met with several groups involved in structural walkdowns, including the .mpell Train C personnel.

Examples of recently identified walkdown discrepancies vera presented and the importance of accurate recording and checking of walkdowii data was re-emphasized.

Impe,1 Train C project 'i.structions have been reviewed ice areas that could be misinterpreted which potentially affect the a: curt :y of field measurements. Clarifications have been made to instri,ctions to improve measurement consistency when measuring spanc with bends. Clarification has also been given to Train C project personnel regarding the need for documenting the use of conservative values when exact values are difficult or impossible to obtain.

To assess the generic implications of walkdown discrepancies identified by the f1RC, Impell has conducted a study and issuei a report on the accuracy and adequacy of Train C walkdown data. The study included a review of audits and surveillances performed by various independent organizations.

It was noted that no major deficiencies have been identified and that none of the deficiencies affected the qualification status of any Train C supports. The study also included a sample reinspection which covered 78 supports and encompassed a total of 5,271 attributes. The attribute discrepancy rate was found to be approximately 1.9% of which only 0.7%

were unconservative, fione c' the discrepancies resulted in the disqualification of the affected conduit systems. Furthermore, it was

! demonstrated that Train C conduit systems generally exhibit large safety margins between demand and ultimate capacity. Based on these results TV Electric does not consider additional reinspection to be warranted.

However, we are concerned with such errors and are endeavoring to reduce personnel errors through the training described above.

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Attachment to TXX-88162 l

- January.29, 1988

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4. Date When Full Compliance Will be Achieved l The correction of identified walkdown discrepancies was completed by l

December 30, 1987.

t j The Impell retraining of Train C walkdown personnel'was completed by )

l December 18, 1987.

The meeting of walkdown personnel with the Manager of Civil Engineering was' held January 20, 1988.

The clarification of Impell instructions was completed by January 22, 1988.

The Impell Accuracy and Adequacy of Walkdown Information Report was completed January 26, 1988.

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