View source for TXX-4980, Forwards Response to Enforcement Action 86-009,App B,Item I.B.4.a & Revised Pages A32,A43,B2,B9,B12,B18, & B23, Containing Minor Clarifications & Editorial Corrections. All Bunker Ramo EPA Modules Will Be Replaced by 861231

{{Adams
| number = ML20212M704
| issue date = 08/25/1986
| title = Forwards Response to Enforcement Action 86-009,App B,Item I.B.4.a & Revised Pages A32,A43,B2,B9,B12,B18, & B23, Containing Minor Clarifications & Editorial Corrections. All Bunker Ramo EPA Modules Will Be Replaced by 861231
| author name = Counsil W
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = Taylor J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE)
| docket = 05000445, 05000446
| license number = 
| contact person = 
| document report number = EA-86-009, EA-86-9, TXX-4980, NUDOCS 8608270063
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 7
}}

=Text=
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Log # TXX-4980
  .                                                                                                            File # 10118 TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER . 400 NostTH OLJVE ETREET. I.R. SI
* DAILAN. TEXAS 75301 August 25, 1986 a'M7A?A"."IA Mr. James M. Taylor, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D.C.            20555

==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 EA N0. 86-09

==Dear Mr. Taylor:==

Our response to EA 86-09, dated August 4,1986, inadvertantly omitted Appendix B Item I.B.4.a. Attached is our response to this item. Also attached are revised pages A32, A43, B2, B9, B12, B18 and B23, which contain minor clarifications and editorial corrections.
Very truly yours,
                                                                                                  'l41 W. G. Counsil BSD/amb Attachments c - Mr. Robert D. Martin Regional Administrator, Region IV U. S. Nuclear Regulatory Commission THE STATE OF TEXAS               :
COUNTY OF DALLAS                 :
l l            I hereby swear that the above stated information and the referenced attachments are true and correct to the best of my knowledge and belief.
                                                                                /                      &1 fllkr Subscribed and sworn to before me, a Notary Public in and fodW, on thisas9 day of (Ja.Kud,1986.
My commission expires               1/f
                                                  /
                                                              ,198f _
_ Notary Public 1-I po7) 8608270063 86082 PDR            ADOCK 05000445 PDR                 ,       _ _ _ _        _       _ _ _ _ _ _ _ _ _               _.

ALLEGED VIOLATION - APPENDIX B. ITEM I.B.4.a 10 CFR Part 50, Appendix B, Criterion X as implemented by the TUGC0 QAP, Section 10.0, Revision 1, dated July 31, 1984, requires that a program for inspection of activities affecting quality 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.
An inboard cable support assembly was not present for EPAs lE76, lE77, lE78, and 1E79 even though Quality Control inspections had verified these installations.
TUEC RESPONSE (1) Admission or Denial of Allened Violation:
We admit the alleged violation.
: 2) Reason for Violation:
The lack of specificity in the traveler regarding installation of the inboard support assembly in Step 4m and the failure of the inspector to verify that the support was consistent with the drawing were the reasons for the violation.
(3) Corrective Stens Taken and Results Achieved:
This deviation will be corrected with the replacement of all Bunker Ramo EPA modules.
(4) Corrective Stens to Avoid Recurrence:
Travelers prepared for the replacement EPA modules by engineering will clearly convey installation and inspection requirements to minimize the possibility of error. Present procedures regarding the preparation of construction travelers will be reviewed to determine if there is a need to revise them in light of this violation and any necessary revisions will be completed by August 31, 1986.
(5) Date When in Full Compliance:
December 31, 1986 PAGE B181

1983, Quality Procedure CP-QAP-12.1 Revision 7 was issued July 29, 1983, which required QC to verify support dimensions at the time of QC acceptance of the final engineering-issued support drawing. It was decided at that time to not conduct a backfit inspection of previously inspected and engineering as-built supports as there was a low probability of any dimensional deviations requiring rework.
In October 1983 QC Instruction QI-QAP-11.1-28 Revision 23 was issued which brought finite dimensional compliance back into the construction QC scope for new installations. Following the SRT inspection in April 1984, QI-QAP-11.1-28 was again revised to provide a checklist with specific QC signoffs for dimensional compliance.
Engineering survey and analysis of the cited supports indicated that the deviation on two of the supports was in the conservative direction and the loads decreased. For the other two supports, the evaluations indicated load increases with a maximum of 13%; however, the margin of safety was still at least 8 to 1. As-built drawings for the cited supports have been revised to indicate the as-installed dimensions.
ISAPs VII.b.3 and VII.c are addressing component supports and will provide additional response to this issue.
(4) Corrective Steos to Avoid Recurrence:
To further enhance the component support inspection process, QC Instruction QI-QAP-11.1-28 Revision .30 was issued April 15, 1985. This revision requires finite recording by QC of required versus actual dimensions for each dimension on a support drawing which is not specificially addressed by the Engineering 79-14 As-Built Program. This program is applicable to all Unit 2 safety related component supports.
(5) Date When in Full Compliance:
The program is now in full compliance. Unit 2 has been in full compliance since April 15, 1985. Compliance will be addressed in ISAPs VII,b.3 and VII.c. l PAGE A32

where the material has been used in linear supports, since DCA 14,741 has been voided. These efforts will be completed by August 29, 1986.
: b. Corrective Action Request (CAR)062 has been previously issued to address inappropriate dispositions to NCRs by Engineering and Quality Engineering, and the approved corrective action (retraining personnel, revising identified NCRs, and random sampling of NCRs dispositioned use-as-is and repair) is being implemented.
: c. CPRT is addressing the adequacy and implementation of CPSES nonconformance and corrective action programs, both past and present, as ISAP VII.a.2.
(4) Corrective Steps to Avoid Recurrence:
: a. Several revisions have been made to CP-QAP-16.1 (Revision 11 was in effect at the time of the violation) subsequent to the period during which the violation occurred which added assurance that similar violations would be precluded. Some of these revisions provided for improved management oversight a follows:
o   Revision 12, 12/9/82, required the QA Manager, or designee, to review all NCRs for significant events in lieu of Quality Engineering.
Additionally, this revision placed the Authorized Nuclear Inspector (ANI) on distribution for all voided NCRs, required the ANI's review of all proposed use-as-is dispositions, and required QE to review all NCRs for potential corrective action.
o   Revision 17, 8/3/83, required the QA Manager, or designee, to approve voiding an NCR in lieu of any Quality Engineer.
o   DCN 1 to Revision 22, 12/6/84, specifically prohibited QA approval of use-as-is disposition which violated ASHE Code criteria.
o   Revision 25, 8/1/85, now requires Engineering to review all NCRs for significant events potential reportability in lieu of the QA Manager.
: b. Nuclear Engineering procedures'(TNE-AD 5-X) require substantive engineering justification for use-as-is dispositions (i.e. , referencing construction procedures would no longer be considered sufficient justification).
: c. CPSES is reviewing the identification and segregation provisions of CP-QAP-16.1 to determine if strengthening the provisions is necessary.
This effort will be completed by August 29, 1986.
(5) Date When in Full Compliance:
The program is now in full compliance.      Compliance will be addressed in ISAP VII.a.2 and CAR-062.                                                              l PAGE A43

(2) Reason for Violation:
Alchough we do not agree with some of the examples of the findings in NRC Inspection Report 50-445/85-19, the number of the examples with which we do agree leads us to conclude that the Unit 1 CTH as-built program was not properly implemented.
The intent of the Unit 1 CTH as-built program was to provide two independent measurements of the as-built attributes      This was to be accomplished by a team consisting of walkdown personnel and a QC inspector. The walkdown personnel were to take the first measurement and reflect their findings on the CTH drawing via a " red-lining" process. The QC inspector was to take the second measurement to verify the accuracy of the first measurement and the red-lined drawing. This process was described in an engineering procedure (TNE-AB-CS-1) and an associated inspection procedure (QI-QP-11.10-9); however, TNE-AB-CS-1 also described the inspection process detailed in QI-QP-11.10-9.
The as-built process described above was developed based on experience gained from the Unit 2 CTH as built pcogram. The Unit 2 program provides for walkdown engineers to take the first measurement and red-line the drawing. The drawing is then revised before the QC inspector verifies that the drawing accurately reflects the field condition. Any discrepancies found by the QC inspector are documented as unsatisfactory conditions on inspection reports and are resolved by rework and/or revisions to the drawing and reinspected by QC.      When developing the Unit 1 program, it was thought that the Unit 2 process could be expedited by having the engineers and inspectors work as a team and resolve any differences on the spot and thereby avoid the need for a second drawing revision.
Although the governing Unit 1 procedures (TNE-AB-CS-1 and QI-QP-11.10-9)           l conveyed that the intent of the as-built process was to provide two measurements, they did not preclude the engineer and inspector from taking their measurements simultaneously. In other words, one of them could hold the measuring device with both persons observing the measurement. This "two sets of eyes" concept was viewed by most QC personnel as satisfying the program intent for two independene measurements to be taken and as being in conformance with the procedure.
Although there were some exceptions, the as-built process was not implemented as intended. Not even the "two sets of eyes" concept was followed in most cases. The process that evolved for most of the teams was that the QC inspector took the neasurement and told the engineer and the engineer recorded the measurement (i.e., red-lined the drawing).      The process was very susceptible to errors. For example, after the QC inspector took the measurement and told the engineer who red lined the drawing, the QC inspector could not possibly remember accurately all of the dimensions he had taken when he later reviewed the red lined drawing for accuracy. Additionally, noise and clarity of speech could affect the accuracy of the communications between the inspector and engineer.
PACE B2

ALLEGED VIOLATION - APPENDIX B. ITEM I.B.1.a.
10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 Quality Assurance Plan (QAP), Section 5, Revision 1, dated April 16, 1979, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropraite to the circumstances and be accomplished in accordance with these instructions, procedures, or drawings.
Paragraph 3.1.2 of Brown & Root (B&R) Procedure CPM-6.3, Revision 8, dated April 2, 1981, states, "The traveler package shall contain, or may reference if normally available, the drawings, procedures, instructions, manufacturer's manuals / guidelines, etc., necessary to accomplish the activity."
Contrary to the above, at the time of this inspection, January 1 - March 14, 1986, construction operation travelers for installation of electrical penetration assemblies (EPAs) lE76, 1E77, 1E78, and 1E79 referenced a type of inboard cable support assembly that was attached to the EPA header plate instead of the EPA nozzle as required by the applicable Bunker Ramo Corporation (BRC) Drawing 50022078, Revision F.
IUEC RESPONSE (1) Admission or Denial of Allened Violation:
We admit the alleged violation.
(2) Reason for Violation:
The cautien note in the traveler for the valve isolation tank electrical penetration assemblies (EPAs) is s modification of the caution note on a standard EPA traveler, which reails: "The outboard cable support fixture is attached to the header plate and must be fully supported at all times."
(emphasis added) There are differences between the standard penetrations and the tank penetrations. The first main difference is that the penetrations are reversed in orientation for the tank application. The second main difference is that there is no cable support fixture on the tank penetrations nimilar to the one on the standard penetrations. The inboard cable support is affixed after the p,netration is installed and it is attached to the nozzle and not the header plate. The engineer who prepared the valve isolation tank EPA traveler changed the word outboard to the word inboard in the caution note to reflect the change in orientation; however, the engineer failed to recognize the caution note should not have been present since there is no cabic support fixture similar to the one on the standard penetrations. The inboard cable support should have been installed later in accordance with the drawing under traveler Step 4m; however, Step 4m does not specifically require the support be consistent with the applicable drawing.
(See response (2) to Appendix A Item I.B.4.a for a related discussion.)
(3) Corrective Steps Taken and Results Achieved; This issue will be corrected with the replacement of all Bunker Ramo EPA modules.
PAGE B9

ALLEGED VIOLATION - APPENDIX B. ITEM I.B.1.c 10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 Quality Assurance Plan (QAP), Section 5, Revision 1, dated April 16, 1979, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and be accomplished in accordance with these instructions, procedures, or drawings.
Paragraph 6.5 of B&R Engineering Instruction EEI-22, Revision 0, dated October 4, 1982, and paragraph 3.1.3 of TUGC0 Instruction QI-QP-11.3-49, Revision 0, dated October 1, 1982, states, " Pigtail conductors must be supported a maximum of 36 inches from the penetration header plate or conductor support."
Contrary to the above, during this inspection, the pigtail conductors for the Conax     ,
modules in EPA lE14 were observed to be supported on the inboard side (inside the reactor containment building) at distances of 43 inches to 60 inches from the penetration header plate.
TUEC RESPONSE (1) Admission or Denial of Alleged Violation:
We admit the alleged violation.
(2) Reason for Violation:
The construction and inspection procedures properly stated that the maximum supported cable length should be 36". The procedures were not followed by craft and inspection personnel.
(3) Corrective Stens Taken and Results Achieved:
The cables in question and other similar cables subject to construction Procedure EEI-22 will be supported as required by reworking them.
(4) Corrective Stens to Avoid Recurrence:
Before the replacement EPA modules are installed both craft and inspectors will l be trained to the proper installation procedures.
(5) Date When in Full Compliance:
The cables will be reinspected and corrections made by December 31, 1986.
PAGE B12}}