ML20205H226

Ack Receipt of 870112 & 0312 Ltrs in Response to NRC 861017 Ltr Re Violations Noted in Insp Repts 50-445/86-03 & 50-446/86-02.Addl Info Requested Re Notice of Violation, Items D.1 & E & Notice of Deviation,Item D.1

ML20205H226
Person / Time
Site:	Comanche Peak
Issue date:	03/25/1987
From:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8704010001
Download: ML20205H226 (3)

See also: IR 05000445/1986003

Text

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WR 2 51987

In Reply Refer To:

Dockets: 50-445/86-03

50-446/86-02

TV Electric

ATTN: Mr. W. G. Counsil

Executive Vice President

400 North Olive, L.B. 81

Dallas, Texas 75201

Gentlemen:

Thank you for your letters of January 12, 1987 and March 12, 1987, in response

to our letter dated October 17, 1986. As a result of our review, we find that

additional information, with respect to Items D. I and E in the Notice of

Violation (N0V) and Item B in the Notice of Deviation (N00) is needed.

Specifically, for NOV, Item D.1, you did not address whether or not a review

was performed with respect to the support analysis (No. 01-CSM-2a-II on

conduit No. C23G04066) to assure that the reduced support capacity was

considered. Please piv/ide us with this information.

For NOV, Item E, it was identified that subsequent to your letter dated

January 12, 1987, additional HVAC organization realignment occurred. This

action affects your response provided in Item e, of paragraph 3., " Action to

Prevent Recurrence." Please provide the changes caused by this realignment with

respect to the Unit 2 HVAC support field verification program.

For N0D, item 0, base material defect inspection was not identified as an

attribute to be excluded as is required by ERC CPP-007. Your response that

accurate reinspection cannot be performed following application of coatings is

not consistent with your position regarding inspection for weld defects

through paint. Inspection of welds in the coated condition and after removal

of the coating was successfully demonstrated by ERC using QI-062. The

observed condition became acceptable in accordance with Ql-QAP-11.1-28 only

after the issuance of DCA-41710 which clarified acceptance criteria.

Therefore, please respond to the deviation as originally requested.

Your response to N00, Items C and D indicates disagreement with the stated

deviations. We have reviewed the additional information you have provided and

have inspected further the as-built condition of Verification Package

1-S-HVDS-075. Based on this review and further inspection, we agree that the

stated deviations did not occur and are withdrawing them.

We have no further questions regarding NOV. Items A, B, C, D.2, F, G, I, and

N00, items A and E, and will review your corrective actions during a future

inspection.

A

RIV/CPTG CPTG 56 DRSP

(EEllersHw:gb IUarnes EHJohnson

3d2/87 '3 /23 /87 $/gtl/87

0704010001 070325

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PDH ADOCK 05000445

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2 TU Electric 2

i With respect to NOV, Item H, the response time was extended until April 10

! 1987.

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Please provide the supplemental information within 20 days of the

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date of this letter.

, Sincerely.

' orlatna! $tened 8y

E. H. Johnson

l E. H. Johnson, Director

Division of Reactor Safety

3

and Projects

CC:

1 TU Electric

ATTN

G. S. Keeley Manager

Nuclear Licensing

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1 Skyway Tower

400 North Olive Street

i Lock Box 81

Dallas. Texas 75201

) Juanita Ellis

President - CASE

1426 South Folk Street

Dallas. Texas 75224

'

Renea Hicks

-i

Assistant Attorney General

i Environmental Protection Division

P. O. Box 12548

i Austin. Texas 78711-2548

Administrative Judge Peter Bloch (

U.S. Nuclear Pequiatory Comission

Washington, D.C. 20555

! Elizabeth B. Johnson  !

Administrative Judge

j Oak Ridge National Laboratory

, P. O. Box X. Building 3500

j Oak Ridge. Tennessee 37830

i

Dr. Kenneth A. McCollom

i 1107 West Kna)p

i Stillwater. 0(lahoma 74075 l

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TU Electric 3

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l Dr. Walter H. Jordan

l E81 Outer Drive

Cak Ridge, Tennessee 37830

l

Anthony Roisman, Esq.

Executive Director

Trial Lawyers for Public Justice

2000 P. Street, N.W. Suite 611

Washington, D.C. 20036 i

Texas Radiation Control Program Director

bectoDMB(IE01)

bec distrib, by RIV:

• RPB * MIS System

[ *RRI-OPS *RSTS Operator

i *RRI-CONST *R&SPB

l *T. F. Westerman, RSB DRSP

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V. Nocnan, NRR R. Martin, RA

L. Chandler, OGC *RSB i

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• RIV File J. Taylor, IE l

• D. Weiss, RM/ALF J. Conklin, IE i

• I. Barnes, CPTG * Project Inspector l

• R. Hall

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Log # TXX-6089

File # 10130

g. IR 86-03

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TEXAS UTILITIES GENERATING COMPANY 86-02

SKYWAY TOWER . 400 NORTH OLIVE ErTREET, l.B. 88 . DALLAS, TEXA5 78208

January 12, 1987

.1%". Lff.OL bk

Mr. Eric H. Johnson }, J/J' l 4 gN

Division of Reactor Safety and Projects ,

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U. S. Nuclear Regulatory Commission -

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611 Ryan Plaza Drive, Suite 1000 L

Arlington, Texas 76011

SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446

RESPONSE TO NRC NOTICE OF VIOLATIO1 AND

NOTICE OF DEVIATION INSPECTION REPORT NOS. 50-445/86-03

AND 50-446/86-02

Dear Mr. Johnson:

We have reviewed your letter dated October 17, 1986, concerning the inspection

conducted by Mr. I. Barnes and other members of the Region IV Comanche Peak

Group during the period December 11, 1985, through March 31, 1986. This

. inspection covered activities authorized by NRC Construction Permits CPPR-126

and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2. Attached

to your letter were Notices of Violation and Notices of Deviation.

On November 14, 1986, per a telecon with your Mr. T. Westerman, we requested

and received a three week extension. On December 5, 1986, we requested and

received a two week extension and on December 19, 1986, we requested and

received a three week extension. On January 9, 1987, per a telecon with your

Mr. D. Hunnicutt, we requested and received a three day extension.

We hereby respond to the Notices of Violation and Notices of Deviation in the

attachments to this letter.

Very truly yours,

h unJ5f

W. G. Counsil

By: *

G. S. Keeley

"'

(!

Manager,NuclearLiceYsing

GLB/gj

Attachments

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IF TXX-6089

January 9, 1987

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Page 2 of 2

c - Region IV (Original + 1 copy)

, Director, Inspection and Enforcement (15 copies)

U. S. Nuclear Regulatory Comission

Washington, D. C. 20555

Mr. V. S. Noonan

Mr. D. L. Kelley

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Y TXX-6089

Attachment 1

NOTICE OF VIOLATION

ITEM A (446/8602-V-08)

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 TUGCo Quality

Assurance Plan (QAP), requires that activities affecting quality shall be

prescribed by and accomplished in accordance with documented instructions,

procedures, or drawings.

Paragraph 2.5 of TUGCo Procedure CP-EP-4.6, " Field Design Change Control,"

Revision 10, dated April 16, 1984, states, in part, " Design

changes / deviations to specified engineering documents shall be documented

by revision initiated by an Engineering Change Request (ECR), a Design

Change Authorization (DCA) or a Component Modification Card (CMC)." DCA

18,016 required removal of wire strands using a wire stripper to reduce

wire size from #16AWG to #18AWG.

Contrary to the above, wire size reductions were implemented for Unit 2

termination cabinets, 2-TC22 and 2-TC23, by construction operation

travelers in a manner different than specified on DCA 18,016; no revision

to the DCA had been initiated, nor were either an ECR or CMC initiated.

RESPONSE TO ITEM A (446/8602-V-08)

,

1. Reason for the Violation:

We admit to the alleged violation for the reasons that follow.

A DCA is not intended or required to show the specific process for

implementing the change. Consequently when the traveler was. prepared, no

review of the DCA was considered resulting in an alternate method being

utilized.

2. Corrective Actions Taken:

The DCA (No. 18,016) was revised to delete the specifics regarding wire

size reduction. Also, to ensure the method used was acceptable, an i

engineering evaluation was performed on the cable in question with no ,

adverse effects regarding resistance, etc. being found.

3. Action to Prevent Recurrence:

The procedure CP-CPM 6.3 defines the traveler program and will be revised ,

to require that a review of the DCA be conducted prior to the traveler  :

being issued to ensure that if the DCA data contain specifics they are

incorporated into the traveler.  ;

4. Date of como11ance:

The revision to the procedure will be issued by January 9, 1987.

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TXX-6089

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Attachment 1

. Page 2 of 22.

NOTICE OF VIOLATION

ITEM B (446/8602-V-06)

i B. Criterion XVI of Appendix B to 10 CFR Part 50, as implemented by Section

16.0, Revision 0, dated July 1,1978, of the TUGC0 QAP, states, in part,

'

i " Measures shall be established to assure that conditions adverse to

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! quality, such as . . . deficiencies, deviations . . . are promptly

l identified and corrected."

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Contrary to the above, the measures established did not assure that the '

i following described condition adverse to quality was promptly identified

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or promptly corrected. The NRC inspector reviewed a sample of 70 Sample

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Recheck Request / Report forms, completed by the Inspection Process Control

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(IPC) group since July 1985, and identified 80 examples where QC

, inspectors had entered " SAT" inspection attributes in inspection reports

1

where "NA" (i.e., not applicable) was the correct entry. This condition

was identified in the monthly IPC reports beginning with the September

. report dated October 11, 1985. Subsequent IPC reports (October and

November) characterized this condition as both "a generic problem" and a

significant deficiency and requested that corrective action be taken as

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early as December 13, 1985. However, no apparent action has been taken to

i establish how long this condition may have existed before September 1985

nor has corrective action, in a generic sense, been taken.

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!. RESPONSE TO ITEM B (446/8602-V-06) t

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j 1. Reason for the Violation

We admit to the alleged violation for the reascns that follow.

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The practice of entering " Sat" on Inspection Report (IR) attributes when

l the attribute has more appropriately "N/A" was implemented due to

i instructions given to QC Inspectors by a field QC Supervisor. The

'l supervisor instructed his subordinate inspectors to status all IR

attributes as " Sat" whenever the attribute was not unsatisfactory. The ,

practice was considered acceptable by the supervisor since it could not i

lead to describing an unsatisfactory attribute as satisfactory. This

action was taken to avoid the incorrect use of "N/A" when " Sat" or "Unsat"

was more appropriate. Since the practice was not implemented by all

supervisors, inconsistent documentation resulted. For example, when only

one hilti bolt was located in a room or area, the minimum spacing to other l

hilti's was considered " Sat" by some QC Inspectors and "N/A" by other I

inspectors.

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j The IPC program identified examples where IPC personnel considered the

" Sat" status of these IR attributes to be unacceptable, even though

I unsatisfactory installations were not identified. These items were

reported as unsatisfactory on Surveillance Recheck / Request Report (SRRR).

l' QE reviewed SRRRs on an ongoing basis as surveillances were completed and

i the reports received. As stated in the details of the NRC IR, QE

j concluded that the entry of " Sat" when N/A was applicable, did not render

! the quality of the item unacce> table and, therefore, did not warrant NCR

! issuance. This practice was, iowever, considered undesirable from a

! consistent documentation standpoint. This view was shared by QC

i Nanagements however, since nonconforming conditions were not involved,

i actions to resolve the inconsistency in documentation practices was not

j promptly initiated.

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TXX-6089

Attachment 1

Page 3 of 22

NOTICE OF VIOLATION

ITEM B (446/8602-V-06) CONT'D

RESPONSE TO ITEM B (446/8602-V-06) CONT'D

2. Corrective Action Taken

Actions taken to resolve inconsistent IR completion involved informal

training of QC Inspectors at the request of the Site QC Supervisor (letter

TUQ-3511 dated 12/10/85). This request emphasized the need to assure

consistent entry of " Sat /Unsat" vs. "N/A" or irs based on the October 1985

IPC Report. As this instruction was not totally effective in resolving

the inconsistencies, formal classroom training was initiated in February

1986 and completed in May 1986. It was not and is not considered

necessary to determine the extent or duration this inconsistency existed

since the issue involves inconsistent IR completion only, and does not

alter the status of QC accepted items.

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3. Action to Prevent Recurrence

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The training described above should prevent recurrence of this violation.

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Ongoing Quality surveillances and trending would identify further

inconsistencies of this nature. The Surveillance Inspection program in

effect since January 1986, has not identified further inconsistencies of

this type.

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4. Date of Comoliance

CPSES is currently in full compliance.

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i TXX-6089

. Attachment-1

Page 4 of 22

NOTICE OF VIOLATION

ITEM C (446/8602-V-20)

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C. Criterion X of Appendix B to 10 CFR Part 50, as implemented

by Section 10.0, Revision 1, dated July 31, 1984, of the TUGC0 QAP,

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states, in part, "A program for inspection of activities affecting quality

shall be established and executed . . . to verify conformance with the

documented instructions, procedures, and drawings for accomplishing the

activity."

Contrary to the above, the following conditions which had been inspected

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and accepted by the applicant's inspection program, were identified as

being nonconforming during independent inspection of Unit 2 conduit

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supports:

! 1. Section 3.3.1 in Revision 7 of TUGC0 Instruction QI-QP-11.10.1A

i states, in part, "The QC inspector shall inspect the support for

l the following: Member (s) shape . . . size and dimensions."

Inspection revealed a 1/2" thick shim plate installation on one

support and a 5/8" thick shim plate installation on another

support for which the applicable drawings required the use of a

5/8" thick and 1" thick shim plate, respectively.

i' 2. Section 3.5.1 in TUGC0 Instruction QI-QP-11.10-1A, Revision 7,

! states, in part, " Conduit spans shall be as indicated on the

isometric draw g. Conduit span Tolerance is +/-3

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(inches).

Inspection revealed a measured span length of one conduit run as

being 3/4" over the allowable tolerance shown on the isometric

j drawing.

} 3. Section 3.4 in Revision 20 of TUGC0 Instruction QI-QP-11.2-1 ,

j specifies that where embedded plates are occupied by attachments

i within 12" of a Hilti, the minimum clearance between a 3/8" and

j t 1/2" Hilti bolt and a Nelson stud will be 5-7/8" and 6-1/2",

i respectively.

i Ins)ection revealed two supports in which the Hilti bolts were

i wit 11n 12" of an attachment but the minimum clearances between a

! 3/8" and 1/2" Hilti bolt and the Nelson studs were 5 3/8" and 4-

1 3/8",respectively,

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j 4. Section 3.2.3 in Revision 7 of TUGC0 Instruction QI-QP-11.10-1A

. states, in part, "Each support inspected on a raceway system shall

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be assigned a number shown on the engineering isometric drawing

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included in the conduit system work packages. . . ."

l Inspection revealed one support in which its identification number

! did not match the applicable isometric drawing support

l identification number.

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TXX-6089

i Attachment 1

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Page 5 of 22

4

NOTICE OF VIOLATION

} ITEM C (446/8602-V-20) CONT'D

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! 5. Section 3.9 in Revision 7 of TUGC0 Instruction QI-QP-11.10-1A

i states, in part, "The QC Inspector shall verify the conduit

i supports have been installed in accordance with the requirements

of the isometric drawing . . . ." It further requires the use of

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i an inspection report to document inspection results. Step (V) 1.b

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in the inspection report states, " Verify conduit configuration."

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Inspection revealed a conduit span bend opposite to that which was

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shown on the applicable isometric drawing, and step (V)1.b had

been signed off as being acceptable.

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j RESPONSE TO ITEM C (8602-V-20) ,

1. Reason for the Violation:

j We admit to this alleged violation for the reasons that follow.

i This violation is a result of isolated QC Inspector errors. Inaccurate

l dimensional measurements were made along with the misidentification of a

.i conduit support during the inspection verification process. The

i deficiencies involved seven separate attributes identified in 234 conduit

j~ supports.

i 2. Corrective Action Taken:

NCRs were initiated for each of the nonconforming conditions identified in

j this violation.

f 3. Action to Prevent Recurrence:

!

i Each of the QC Inspectors involved with acceptance of the discrepant

l installations identified have been made aware of their errors. To

i determine the need for further corrective action, the performance of these

j inspectors was evaluated through review of Quality Surveillance

) reinspection results. Based on this review it has been determined that

i the involved inspectors have demonstrated a high degree of accuracy in the

performance of inspections and that no further corrective action is

needed.

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l 4. Date of Comoliance:

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l The compliance will be achieved when the NCRs are closed. It is

j anticipated that these NCRs will be closed by February 23, 1987.

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TXX-6089

Attachment 1

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Page 6 of 22

NOTICE OF VIOLATION

ITEM D (446/8602-V-21)

D. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section ,

5.0, Revision 3, of the Tugco QAP, requires that activities affecting

quality shall be prescribed by and accomplished in accordance with  ;

documented instructions, procedures, or drawings.

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Contrary to the above, the following conditions were identified with

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respect to Unit 2 conduit supports in which the prescribed activities were '

not accomplished: .

l 1. Section 2.4 in Tugco Procedure TNL-AB-CS-2, Revision 0, states, in

! part, "The Field Engineer shall prepare a field isometric

indicating the general routing and location of supports, and . . .

, shall include span lengths and configurations . . . decision  :

points and locations . . . . Decision points are considered as '

places on a typical drawing for which two or more options are

, acceptable for the same location."

Independent inspection revealed a decision point which had not

been included in the isometric drawing by the Field Engineer. One

support was observed in which a 3/8" Hilti bolt had been

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installed. The applicable typical drawing specified a 1/2" Hilti

t bolt with the option of using a 3/8" Hilti bolt, provided the

i support capacity was reduced. The absence of this information

i could possibly preclude the required reduction in support capacity

j by the Design Engineer.

RESPONSE TO ITEM D.1 (446/8602-V-21)

1. Reason for the Violation

4

We admit to the alleged violation for the reasons that follow.

i Due to an unclear note (No. 4) on drawing 2323-S2-0910, Sh. CSM-2a-II,

Rev. 3, engineering walkdown failed to identify the 3/8" Hilti-Kwik Bolt

j (HKB) on the isometric drawing.

! 2. Corrective Action Taken

, The isometric drawing no. 2323-S2-0910, Sh. 04066, Sk.01 has been revised

to show the 3/8" HKB.

3. Action to Prevent Recurrence

Note 4 on drawing 2323-S2-0910, Sh. CSM-2a-II has been rewritten to state,

in part, ".. 3/8" Hilti-Kwik bolt may be used for 2" diameter thru 5"

diameter conduit only where specified on the isometric or individual

, support drawing," (change will be incorporated on Rev. 5) per disposition

j of NCR #M-86-201023, Rev. 1.

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TXX-6089 i

. Attachment I l

Page 7 of 22 '

NOTICE OF VIOLATION

ITEM D (446/8602-V-21) CONT'D

RESPONSE TO ITEM D.1 (446/8602-V-21) CONT'D

3. Action to Prevent Recurrence (Cont'd)

NCR #M-86-201023 will specify listing of all CSM-2a-II supports used on 2"

thru 5" diameter conduit and reinspection to verify that:

a. 1/2" HKB are used, or

b. 3/8" HKB are used and are shown on the isometric or individual

support drawing.

No further action is necessary to prevent recurrence.

4. Date of Comoliance

Compliance will be achieved when NCR #M-86-201023 is closed. It is

anticipated that the NCR will be closed by March 15, 1987.

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TXX-6089

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Attachment 1

Page 8 of 22

NOTICE OF VIOLATION

ITEM D (446/8602-V-21) CONT'D

D. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section

5.0, Revision 3, of the Tugco QAP, requires that activities affecting

quality shall be prescribed by and accomplished in accordance with

documented instructions, procedures, or drawings.

Contrary to the above, the following conditions were identified with

respect to Unit 2 conduit supports in which the prescribed activities were

not accomplished:

2. Section 3.3.1.1 in Revision 14 of Tugco Instruction QI-QP-11.21-1

requires that the welding symbol for an intermittent fillet weld

be in accordance with standard welding symbols of AWS 2.4-79.

Inspection revealed the existence of intermittent fillet welds on

11 conduit supports in which the applicable, typical support

drawing did not depict an intermittent fillet weld symbol.

RESPONSE TO ITEM 0.2 (446/8602-V-21)

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1. Reason for the Violation

We admit to the alleged violation for the reasons that follow.

The typical support drawing detail CSM-6C-I depicts an intermittent fillet

weld utilizing the dimensional / hatching method in lieu of providing the

applicable information within the welding symbol. This method of

detailing welding requirements is recognized by AWS 2.4-79, paragraph

4.4.1. Although TUGC0 Instruction QI-QP-11.21-1, Revision 14 states that

the standard welding symbols will be in accordance with AWS 2.4-79, the

procedure does not explicitly address the acceptable practice of utilizing

the dimensional / hatching method. Only examples of commonly used standard

welding symbols from AWS 2.4-79 are referenced. Additionally, weld

lengths and locations are as depicted on CSM-6C-I.

2. Corrective Action Taken

It has been the intent of the procedure to include some of the most

commonly used weld symbols to facilitate the inspection process, not to

include all possible weld symbols from AWS criteria which may be used.

TUGC0 Instruction QI-QP-11.21-1 will be clarified to state that standard

welding symbols as referenced in the procedure are only " typical" as

allowed by AWS 2.4-79. Additionally, a subsequent revision of drawing

2323-S2-0910 sheet CSM-6C-I, more clearly depicts the weld location using

the dimensional / hatching method described above.

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TXX-6089

Attachment 1

Page 9 of 22

NOTICE OF VIOLATION

ITEM D (446/8602-V-21) CONT'D

RESPONSE TO ITEM D.2 (446/8602-V-21) CONT'D

2. Corrective Action Taken Cont'd

Concurrently, an engineering evaluation was conducted with the following

results:

Due to the generic nature of drawing 2323-S2-0910, Sh. CSM-6C-I, Rev. 3,

the plate size (at the welds in question) can vary up to l'-6" max. In

order to accurately communicate the welding requirements for this joint

design, the engineer utilized the weld symbol to specify the weld size and

minimum length. The typical centerline for acceptable weld spacing for

this generic application was identified separately on the sheet. This is

an acceptable industry practice which meets the intent of AWS 2.4-79.

To assure that the engineering requirements were met during installation,

as-built sketches were made of the eleven (11) supports identified in the

NRC report. An engineering evaluation of these as-builts has verified

that all eleven are in compliance with the welding requirements specified

by this typical drawing.

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3. Action to Prevent Recurrence

The revision of QI-QP-11.21-1 as addressed in the Corrective Action taken

will prevent recurrence of this condition.

4. Date of Comoliance

QI-QP-11.21-1, Revision 17 will be revised by January 30, 1987.

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TXX-6089

Attachment 1

. Page 10 of 22

NOTICE OF VIOLATION

ITEM E (446/8602-V-17)

E. Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section

10.0, Revision 1, dated July 31, 1984, of the TUGC0 QAP, states, in part,

"A program for inspection of activities affecting quality shall be

established and executed . . . to verify conformance with the documented

instructions, procedures, and drawings for accomplishing the activity."

Contrary to the above, the following examples from Unit 2 HVAC duct

support inspections were observed where the Bahnson inspection program

failed to identify nonconformances with the documented instructions,

procedures, and drawings:

1. Section 9.1 in Revision 1 of Bahnson Procedure WP-TUSI-001 states,

in part, with respect to intermittent welds, " Weld increments-

shall begin and terminate within 1/8" of the ends of the joints or

length . . . ." Seven HVAC duct supports, however, inspected by

the NRC had intermittent fillet welds which did not begin or

terminate within 1/8" of the ends of the joints.

2. Section 6.5 in Revision 5 of Bahnson Procedure QCI-CPSES-011

states, in part, with respect to welding, "The Quality

Representative shall make certain that the size, length, and

. location of all welds conform to the requirements of QCI-CPSES-014

and DFP-TUSI-003, and to the detailed drawing . . . ."

Independent inspection identified the following conditions in

three HVAC duct supports:

a. A 2" long, 1/4" fillet weld required by the drawing was

measured as being 1/8" for the full length,

b. Two, 2-1/2" long,1/8" fillet welds required by the

drawing between the two lateral braces and the main

support were missing.

c. Two,1-1/2" long,1/8" fillet welds required by the

drawing were measured as being 1-1/4" long.

3. Section 6.6 in Revision 5 of Bahnson Procedure QCI-CPSES-011

states, in part, " Weld profiles shall meet the following

requirements:

The faces of fillet welds may be slightly convex, flat, or

slightly concave . . . Welds shall be visually examined to

determine if the following defects are evident: ...

Undercut shall not exceed 1/32" for materials thicker than

1/4"."

One support was identified in which two welds exhibited 1/16"

undercut for 50 percent of the weld lengths on members which were

1/2" thick. The support also had a 1/4" and a 3/8" weld in which

grinding of the weld produced excess convexity, resulting in an

unacceptable weld profile.

- .. - - . . -. . = . _ .- .

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'TXX-6089

Attachment 1

Page 11 of 22

4

NOTICE OF VIOLATION

ITEM E (446/8602-V-17) CONT'D

l 4. Note 2 in Attachment 4 of Revision 10 to Bahnson DFP-TUSI-004

, states, in part, "Where the embedded steel plates are occupied by

attachments within the minimum distance shown above (12"), the

i minimum clearance from 1" Hilti anchors to . . . the edge of the

!

embedded plate and only 3/8" from the edge.

RESPONSE TO ITEM E (446/8602-V-17)

i

j 1. Reason for the Violation

We admit to the alleged violation for the reasons that follow.

Our review indicates the violation occurred as a result of inadequate

implementation of procedures on the part of the HVAC contractor charged

with the responsibility for design, fabrication, and QC activitie:;.

2. Corrective Action Taken

! For each specific discrepancy noted in the Violation, a nonconformance

!

report (NCR) or Deficiency and Disposition Report (DDR) has been issued

,

for evaluation and disposition.

Note, as indicated in paragraph 3, the engineering responsibility for this

area has been reassigned. DDR's are the technical nonconformance

i documents used by the current responsible architect / engineering

! contractor.

i

j 3. Action to Prevent Recurrence

! In order to correct the conditions noted in this violation the following

corrective measures are being implemented:

j a. The project organization and responsibilities for Unit I and

i Common HVAC activities have been realigned. Engineering and QC

! activities previously performed by Bahnson have been assumed by

l Ebasco and TUGCO, respectively.

! b. Field verification efforts include all Unit I and Common Seismic

j Category I duct supports.

,

! c. Engineering evaluations will be performed to ensure compliance

with FSAR commitments.

l

!

d. Construction rework will be performed, as deemed necessary, by the

engineering evaluations of field verified information to assure

compliance with FSAR criteria for the affected supports. .

I *

l e. To assure Unit 2 installations comply with prescribed

requirements, Unit 2 HVAC supports will be field verified. The

as-built effort will be conducted by Bahnson, with QC verification

'

by TUGCO. Ebasco has been given responsibility for the adequacy

of the as-built verification effort and design.

All discrepancies will be documented by Nonconformance Reports.

_ _ _ _ _ _ _ _ - - . _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . . . _

.

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TXX-6089

Attachment 1

Page 12 of 22

NOTICE OF VIOLATION

ITEM E (446/8602-V-17) CONT'D

-

RESPONSE TO ITEM E (446/8602-V-17) CONT'D

4. Date of Comoliance

The procedure revisions and retraining were completed December 31, 1986.

The balance of preventative actions will be completed by May 1987 for Unit

I and September 1987 for Unit 2.

,

o

!

!

,

4

1

l I

i

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.

.- . - _ - - . - _ _ . . . - - - . _ - . - . .. . _ . . _ .

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TXX-6089

Attachment 1

Page 13 of 22

NOTICE OF VIOLATION

ITEM F (445/8603-V-04)

F. Criterion III of Appendix B to 10 CFR Part 50, as implemented by Section

3.0, Revision 4, dated November 20, 1985, of the Tugco QAP, states, in

part, " Measures shall be established to . . . include provisions to assure

that appropriate quality standards are specified and included in design

documents and that deviations from such standards are controlled . . . The

design control measures shall provide for verifying or checking the

adequacy of design . . . Design changes, including field changes, shall be

subject to design control measures commensurate with those applied to the

original design . . . ."

Contrary to the above, verification or checking of a design change,

initiated to resolve a deviation from design documents, did not assure the

adequacy of either the design change' or the disposition of the

nonconformance report (NCR) which documented the deviation. NCR M-80-

00161, initiated on November 6, 1980, addressed the drilling through of a

" probable" template bar, a rebar, and notching another rebar. The

disposition was "Use-As-Is" and referenced DCA No. 9091. The solution in

the DCA stated that, "The condition as described is acceptable." However,

the described condition addressed just one cut bar.

-

RESPONSE TO ITEM F (445/8603-V-04)

1. Reason for the Violation

We admit the alleged violation for the reasons that follow.

The disposition of NCR M-80-00161 addressed authorization to cut a single

layer of concrete reinforcing steel. The disposition inadvertently failed

to address the remaining conditions due to the nature of the deviations

described as follows:

The bar cut at 2-1/2" depth is authorized by DCA 9091. The bar cut at 5-

1/2" depth is a template bar requiring no authorization for its cutting.

It has no structural significance and is used only for facilitating

installation. The template bar is a construction aide which does not (and

is not required to) appear on design drawings. Therefore, the cutting of

this bar is not a nonconforming condition. The bar notched at 7" depth is

the end of the tail of a bent bar. The cutting of such bars is

generically approved by DCA 243; no additional authorization is required

and hence this is not addressed in DCA 9091.

2. Corrective Action Taken

NCR M-80-00161 was revised in April 1986 in order to reference the

information noted above.

>

I

.

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l

TXX-6089

Attachment 1

Page 14 of 22

NOTICE OF VIOLATION

ITEM F (445/8603-V-04) CONT'D

RESPONSE TO ITEM F (445/8603-V-04) CONT'D

3. Action to Prevent Recurrence

The adequacy of nonconformance dispositions has been the issue of a site

initiated Corrective Action Request (CAR-062 dated March 4, 1986) and a

deficiency considered to be potentially reportable under the provisions of

10CFR50.55(e) (SDAR CP-86-48 dated June 16,1986).

The evaluation of these issues include,1) an assessment of the adequacy

of NCR dispositions, and 2) programmatic problems with revising NCRs.

A review of a random sample of NCRs has been conducted to determine the )

safety significance of actions resulting from completed dispositions.

This review has provided a high degree of assurance of the adequacy of the

dispositions of NCRs at CPSES. To further ensure that safety concerns do

not exist, a review program encompassing technical review of all

previously closed NCRs with " void," " repair" or "use-as-is" dispositions

is planned. ,

!

!

In order to maintain a high degree of confidence that NCR dispositions  !

will not result in safety concerns, an interdiscipline review effort has

-

)

resulted in new corporate procedures for controlling nonconformances and

deficiencies.

4. Date of Comoliance

The implementing procedures and the training of personnel on the new

procedures were completed December 22, 1986. The NCR review program will

be completed by June 30, 1987.

!

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TXX-6089

Attachment 1

Page 15 of 22  !

NOTICE OF VIOLATION

ITEM G (446/8602-V-14)

G. Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section

10.0, Revision 1, dated July 31, 1984, of the Tugco QAP, states, in part,

"A Program for inspection of activities affecting quality shall be

established and executed . . . to verify conformance with the documented

instructions, procedures, and drawings for accomplishing the activity."

Paragraph 2.0 in Revision 0 to Tugco Procedure TNE-AB-CS-3 requires

walkdown drawings to reflect history and methodology to produce as-built

drawings. It further requires the walkdown drawings to depict all the

necessary information required for subsequent QC verifications; i.e.,

support configuration dimensions and material sizes.

Paragraph 3.2.3 in Revision 5 to Tugco Instruction QI-QP-11.10-2A requires

the QC inspector to verify that the completed support is in accordance

with the as-built drawing.

Contrary to the above, the following conditions were identified with

respect to seven Unit 2 cable tray support drawings:

1. Walkdown drawings neither depicted all required information nor

~

included correct dimensional information necessary for subsequent

QC verification.

RESPONSE TO ITEM G.1 (446/8602-V-14)

1. Reason For the Violation

We admit to the alleged violation for the reasons that follow.

Review of the specific cable tray support installations noted in the

finding has indicated this condition is the result of errors in field

measurements obtained during the preparation of as-built drawings. In one

instance (CTH-2-9774), the finding resulted from a weakness in the

inspection procedure.

2. Corrective Action Taken

The following nonconformance reports were issued as a result of the

conditions noted in this violation

1

!

l

!

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-

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._ _ _ . _ _ . _ _ _ _ . _ _ .. _ . . _ _ _ .. _ . . _ .____ _ __

l

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TXX-6089 '

'

Attachment 1 i

Page 16 of 22 l

NOTICE OF VIOLATION I

ITEM G (446/8602-V-14) CONT'D

J

RESPONSE TO ITEM G.1 (446/8602-V-14) CONT'D

Sunoort NCR No. Disposition Closure

CTH-2-9774 M-85-201794 (12/17/85) Revise procedure 08-01-86

QI-QP-11.10-2A,

Rev. 5

CTH-2-10264 M-85-201804 (12/17/85) Revise drawing, 03-04-86

reinspect

l

l' CTH-2-10420 M-85-201805 (12/17/85) Revise drawing, 03-24-86

reinspect

i

! CTH-2-9850 M-85-201820 (12/18/85) Revise drawing, 02-07-86

! reinspect

CTH-2-11570 M-85-201802 (12/17/85) Revise drawing, 05-08-86

CTH-2-10119 M-85-201795 (12/17/85) Revise drawing, 03-08-86

l.

CTH-2-9825 M-85-201819 (12/10/85) Revise drawing, Superce- i

i reinspect ded by ,

j Rev. 1.

CTH-2-9825 M-85-201819 (02/14/86) Revised drawing, 02-28-86

j Rev. I reinspect

i

! Each specific finding (cable tray installation) has been documented by

l nonconformance report (NCR). Except for CTH-2-9774, disposition of the

NCRs resulted in revision to the drawing and re-inspection of the support.

i

For CTH-2-9774 (the support affected by the procedural weakness),

disposition of the nonconformance resulted in revision of the procedure

and re-inspection.

Additionally, since the preparation of the drawings noted in the findings,

i classroom instruction and the application of proper measurement techniques

has been established as a prerequisite for engineering personnel involved

in the preparation of CTH drawings.

! 3. Action to Prevent Recurrence

!

The only item of a recurring nature was as listed on NCR #M-85-201794

! (CTH-2-9774). Revision 06 of Procedure QI-QP-11.10-2A was issued on

j 2/24/86 and QC personnel were trained to this procedure revision.

! 4. Date of Comoliance

Compliance has been achieved, as described above.

, . - __ - - - .. - _ _ _ - -. - . . _ - _ - - - - . - . . - _. - - - - ., - _ - -

.-.- - - . - _ - . - _ . -. _ . . - -. .. ~ . - - -.

.

.

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TXX-6089

Attachment 1

Page 17 of 22

NOTICE OF VIOLATION

i

ITEM G (446/8602-V-14) CONT'D

G. Criterion X of Appendix B to 10 CFR Part 50, as implemented by Section

10.0, Revision 1, dated July 31, 1984, of the TUGC0 QAP, states, in part,

4 " A Program for inspection of activities affecting quality shall be ,

l established and executed . . . to verify conformance with the documented '

i instructions, procedures, and drawings for accomplishing the activity."

l '

Paragraph 2.0 in Revision 0 to TUGC0 Procedure TNE-AB-CS-3 requires

i walkdown drawings to reflect history and methodology to produce as-built

i drawings. It further. requires for subsequent QC verifications; i.e.,

i support configuration dimensions and material sizes.

Paragraph 3.2.3 in Revision 5 to TUGC0 Instruction QI-QP-11.10-2A requires

! the QC inspector to verify that the completed support is in accordance

with the as-built drawing.

, Contrary to the above, the following conditions were identified with

,

respect to seven Unit 2 cable tray support drawings:

.

1 2. QC inspectors accepted support dimensions which were different

i from those specified on the walkdown drawings.

i RESPONSE TO ITEM G.2 (446/8602-V-14)

!.

! 1. Reason for Violation

We admit to the alleged violation for the reasons that follow.

i With the exception of those discrepancies which pertain to supports CTH-2-

i 9774 and CTH-2-10420, the dimension verification discrepancies described

] in this violation are the result of isolated QC Inspector errors. The

reason for the violations associated with supports CTH-2-9774 and CTH-2-

j 10420 are as follows:

1

For CTH-2-9774, the QC inspector was required by Quality Instructions to

! verify that dimensions shown on "As-built" drawings were within the

j tolerances specified in QI-QP-11.10-2a. QC inspection has not been

, required to assure that all dimensions are included on the drawing. Since

i the dimensional information referenced in the finding was not on the "As-

i built" drawing, those dimensional verifications were not performed by the

l QC inspector.

,

For CTH-2-10420, the inspection method used by the inspector to measure

[ the distance between the welded attachments involved measuring the

i distance from the ing of the weld on the C-6 channel to the ing of the

weld attaching the conduit support to the embedded plate. This inspection

method was considered acceptable practice from approximately June 1985 to

l April 1986 due to the perceived conservatism achieved (i.e., greater

separation). However, this measuring method resulted in the plus side of

I

'

the 1" tolerance allowed by QI-QP-11.10-2a being exceeded on CTH-2-1042-

when measured from the f_ ara of the attached member to the f_tra of the

other welded attachment.

__ _ _ _ . _ _ _ _ _ _ - . . _ _ __ _ ,_._ . - _ . _ _ _ . _ ._ _ _ _ _ _ .... _ -

.- __- .- - _- - - . . _ . . - - . - . . . .____ _ __ _ _ _ _

. .

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TXX-6089

Attachment 1

-

Page 18 of 22

! NOTICE OF VIOLATION

!

ITEM G (446/8602-V-14) CONT'D

RESPONSE TO ITEM G.2 (446/8602-V-14) CONT'D

!, 2. Corrective Action Taken

! Nonconformance Reports were initiated to address the dimensional

,

discrepancies. The dispositions required the drawings to be revised to '

show the "As-built" conditions with the exception of the following NCRs

0 NCR M-86-201794 addressing CTH-2-9774 was dispositioned "Use-as-

l

is." The disposition does not require the location of the

3/8"x4"x5" plate with respect to the C-6 channel to be on the

drawing, only that the weld requirement of the plate to channel is

, per design drawing. This weld dimensional requirement was

verified by QC at the time of the original QC inspection.

O Also, per the NCR disposition, DCA 24400 was issued April 2, 1986,

, to provide verification criteria when the dimensional location of

the tray clamp in relation to the C-6 channel is not shown on the

l drawing. QI-QP-11.10-2A has been revised to include this

criteria.

l-

0 NCR M-86-202657 was initiated to address the previous use of the

toe-to-toe method to measure the separation distance between

] welded attachments to embedded plates. CTH-2-10420 is addressed

in the NCR since it was inspected using this method. Further

! action will be taken as required by the NCR disposition.

, Subsequent clarification was received by Engineering whereby the

j separation measurements were to be verified using face-to-face,

) unless otherwise detailed on the design drawing. The clarified

i

method for measuring has been applied since April 1986.

1 3. Action to Prevent Recurrence

i

! Each of the QC Inspectors involved with acceptance of the discrepant

installations identified have been made aware of their errors. To

i determine the need for further corrective action, the performance of these

j inspectors was evaluated through review of Quality Surveillance

reinspection results. Based on this review it has been determined that

i the involved inspectors have demonstrated a high degree of accuracy in the

! performance of inspections and no further corrective action is needed.

l Per the disposition of NCR N-86-201794, no further action is required for

! the dimensional 3/8"x4"x5" plate-to-channel finding. However, the

revision of QI-QP-11.10-2a should prevent recurrence of the erroneous

j dimensional location of the tray clamp plate-to-the channel finding.

The clarification of attachment separation inspection methods used should

l prevent recurrence of this finding.

4. Date of Comoliance

! CPSES is presently in compliance, with the exception of NCR M-86-202657

which will be dispositioned by February 27, 1987.

l

I

i

_ _ _ _ _ _ _ _ _ _ , . _ . . . _ _ . _ . . _ _ _ _ _ _ . _ - _ . . . _ _ _ _ . _ _ . _ _ _ . _ _ _ , _ _ _ _ _ . . _ _ _ _ , _

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TXX-6089

Attachment 1

Page 19 of 22

NOTICE OF VIOLATION

ITEM H (446/8602-V-10)

H. Criterion IX of Appendix B to 10 CFR Part 50 states, in part, " Measures

shall be established to assure that special processes, including

welding . . . and nondestructive testing, are controlled and accomplished

by qualified personnel using qualified procedures in accordance with

applicable codes, standards, specifications, criteria, and other special

requirements."

Section CC-5521.1.1 of Code ACI-359, states, in part, "If the 12-in.

Radiograph in the 50-ft-long increment of weld does not meet the

acceptance standards, two 12-in. Films shall be taken at other locations

2

within the 50-ft-long increment . . . . If either of the second

radiographs does not meet the acceptance standards . . . the remaining

portion of the 50-foot increment of this weld shall be radiographed."

Contrary to the above, the required radiography of the remaining portion

of a 50' increment of weld was not performed even though one of the two

second 12" radiographs (No. 146T2) at seam P84 in the Unit 2 containment

liner did not meet the acceptance standards.

RESPONSE TO ITEM H (446/8602-V-10)

-

This alleged violation is under evaluation. We expect to send a report by

February 20, 1987.

1

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TXX-6089

,' Attachment 1

Page 20 of 22

NOTICE OF VIOLATION

ITEM I (445/8603-V-02)

1

I. Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGCo's

Final Safety Analysis Report (FSAR) Section 17.2, " Quality Assurance

During the Operations Phase," dated July 19, 1985, requires that

'

activities affecting quality be prescribed by and accomplished in

accordance with documented instructions, procedures, or drawings of a type

appropriate to the circumstances.

Operations Administrative Control and Quality Assurance Plan Section 3.9

4 states that, " Deficiency Reports (DRs) and nonconformance reports (NCRs)

! shall be reviewed periodically for adverse trends . . . Results of trend

l analysis shall be reported to the Manager, Nuclear Operations, Manager,

, Plant Operations, and Manager, Quality Assurance."

1

3 Contrary to the above, site operations trend analyses were performed on

DRs only for 1984 and 1985. Consequently, trend analyses for problems

identified on NCRs were not performed and thus not reported to the

required levels of management. Further, site procedures do not clearly

describe the conditions under which a DR or an NCR is to be written, nor i

i were DRs reviewed for potential conditions requiring an NCR prior to a '

June 1985 revision to the deficiency reporting procedure STA-404.

~

RESPONSE TO ITEM I (445/8603-V-02)

'

We admit to the alleged violation for the reasons that follow. i

Hgte: This violation consists of three discrete parts that are addressed

i separately in this response.

1

Part 1 .

1

". . . site operations trend analyses were performed on DRs only for 1984

and 1985. Consequently, trend analyses for problems identified on NCRs

were not performed and thus not reported to the required levels of t

l management."

1

a 1. Reason for the Violation

!

'

NCR dispositions (except use-as-is) are accomplished through the work

l control program and become part of equipment maintenance history. The

i

violation was caused by a misunderstanding of the requirement to trend

NCRs directly and not as part of the Equipment Maintenance history

) trending program.

l

<

2. LQInctive Action Taken

1

l As corrective action, all TUGC0 Operations NCRs have been reviewed and no

significant adverse trends were identified. Trend analysis performed on

1985 NCRs was reported to the appropriate levels of management by the 1985

Quality Assurance Annual Report.

__ , _ _ _ _ _ _ ____ _ __ _ _ _ _ . _ _ _ _ _ . . _ . _ _ , _ . . _ _ . _

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TXX-6089

Attachment 1

Page 21 of 22

NOTICE OF VIOLATION

ITEM I (445/8603-V-02) CONT'D

RESPONSE TO ITEM I (445/8603-V-02) CONT'D

Part 1 cont'd

3. Action to Prevent Recurrence

NCR trend analysis is now being conducted on a quarterly basis to prevent

further violations of this nature.

4. Date of Comoliance

Full compliance has been achieved.

Part 2

"

... site procedures do not clearly describe the conditions under which a

DR or an NCR is to be writ'$n ..."

1. Reason for the Violation

. At the time of inspection, procedures failed to clearly describe the

conditions for initiating a DR or NCR.

2. Corrective Action Taken

Recently issued Nuclear Engineering and Operations (NE0) procedures

clearly define the site guidelines for deficiency and nonconformance

reporting. Implementing procedures will be revised to include

requirements of the appropriate NE0 procedures.

3. Action to Prevent Recurrence

The corrective action should prevent recurrence of this part of the

Violation.

4. Date of Compliance

The procedures will be revised by January 15, 1987.

Part 3

"

... nor were DRs reviewed for potential conditions requiring an NCR prior

to a June 1985 revision to the deficiency reporting procedure STA-404."

1. Reason for the Violation

All prior revisions of STA-404, " Control of Deficiencies", have required

Quality Assurance to determine if the deficiency "may cause or has caused

a nonconformance." This part of the violation occurred because STA-404

did not require clear documentation of the review for noncoriforming

conditions.

_ _ ___ _.

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TXX-6089

Attachment 1

Page 22 of 22

NOTICE OF VIOLATION

ITEM I (445/8603-V-02) CONT'D

RESPONSE TO ITEM I (445/8603-V-02) CONT'D

Part 3 cont'd

2. Corrective Action Taken

STA-404 was revised in June 1985 to document the review for nonconforming

conditions by providing a "Yes/No NCR required" block on the DR form.

3. Action to Prevent Recurrence

To provide further assurance that a nonconforming condition did not go

undetected, all Deficiency Reports issued prior to June 1985 will be

reviewed.

4. Date of Comoliance

The review will be complete by January 15, 1987.

.

4

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TXX-6089

Attachment 2

Page 1 of 13

i NOTICE OF DEVIATION

j ITEM A (445/8603-D-14)

i

A. Paragraph 5.3.5(A) of Evaluation Research Corporation (ERC) QI-019,

j Revision 3, states, in part, " Verify that the clearance meets the

following criteria

. . . Where design shows 0-inch on one side and 1/16-

j inch on the other side, the sum of both gaps may_not exceed 1/8-inch or be

less than 1/32".*

1 *Where design shows 0" on bottom (in the gravity direction) then it shall ,

l be such with no allowable variation."

! Section II of ERC Description Memorandum QA/QC-RT-1436 addresses changes,

i reasons, and effects incorporated in Revision 3 of ERC QI-019 and states,

i in part, regarding paragraph 5.3.5(A), "Added clarifying information on

j allowable clearances for dead weight and 0" clearance supports . . . ."

i

1 Attachment A to the above ERC Description Memorandum lists previously

] issued reinspection packages and states that package I-S-SBPS-051 is not l

j affected by changes incorporated in Revision 3 of ERC QI-019. -

a

j In deviation from the above, independent inspection identified that

i clearances which had been correctly accepted by ERC for Verification

j Package No. I-S-SBPS-051, when inspected to Revision 1 of QI-019, were no

-

longer acceptable to the requirements _ of Revision 3 of QI-019. Drawing

CP-AA-040, Revision 0, shows clearance in the gravity direction of zero.

, Independent inspection measured a gap of 1/16" in the gravity direction,

1 and thus determined that the changes in Revision 3 did, in fact, affect

i the previous inspection of Verification Package No. I-S-SBPS-051.

1

i RESPONSE TO ITEM A (445/8603-D-14)

1. Reason For Deviation

!

{ We admit to the alleged deviation for the reasons that follow,

i

! The primary reasons for the deviation are imprecise guidance in QI-019 and

j inspector misinterpretation of that guidance. Prior to Revision 3, QI-019

. did not specifically address allowable clearances in the gravity direction

! for dead weight, box frame supports. Although these clearance

requirements were covered in ERC Inspector training, some confusion

! existed over eleven inspection packages in which the box frame support

i drawings showed the pipe in contact with the support but specified no

! allowable clearance value. ERC decided to revise QI-019 to reflect

I clearance requirements as taught in inspector training, and to reinspect

! those eleven packages. As a result, ERC Description Memorandum QA/QC-RT-

1436 (dated 2/10/86) was issued to describe the Revision 3 changes to

section 5.3.5(A) of QI-019. (The memo erroneously stated that no

previously issued packages were affected by the changes, when in fact

!

Attachment A to the memo listed the eleven (11) packages requiring ,

l reinspection. Recognizing the error in the memo, ERC issued Revision 1 to i

!

QA/QC-RT-1436 the same day, stating that the change to QI-019 did affect

the eleven (11) previously issued packages.) I

l

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TXX-6089

Attachment 2

Page 2 of 13

NOTICE OF DEVIATION

ITEM A (445/8603-D-14) CONT'D

1. Reason for Deviation (cont'd)

Subsequent to the issuance of QA/QC-RT-1436, listing the eleven (11)

packages to be reinspected, ERC became aware of past inspector confusion

over allowable clearances even when zero inches (0") clearance in the

gravity direction was specified on the drawing. ERC then issued

Supplemental Inspection Instructions requiring reinspection of all box

frame, dead weight supports in the small bore population. In total, 32

packages were reinspected resulting in 9 Deviation Reports regarding zero

clearance in the gravity direction. Package No. I-S-SBPS-051 was among l

those reinspected, and a clearance violation in the gravity direction was

noted on Deviation Report No. I-S-SBPS-051-DR3 and subsequently on NCR M-

23400N R-1. Attachment A to memo QA/QC-RT-1436 was not revised to reflect i

these reinspections.

2. Corrective Action Taken

Corrective Action has been completed with the issuance of Rev. 3 to QI-019

and with the reinspection of all affected packages as of May 30, 1986.

~ Revision 2 to QA/QC-RT-1436 was issued on November 11, 1986, and contains

a note referring to the reissuance of all affected packages.

3. Action to Prevent Recurrence

No action to prevent recurrence is contemplated for the Small Bore

population as reinspection efforts are complete and Rev. 3 to QI-019 has

been issued. As a result of CAR-16, ERC QI procedures were reviewed in

meetings between engineers and inspectors to ensure clarity and

consistency of the procedures. The need to clarify box frame support

clearance criteria in QI-019 was identified in a January 11, 1986, CAR-16

meeting.

4. Date of Comoliance

Compliance has been achieved, as described above.

I

(

_3_ase. -e..s .-J-..w . m ame. _ .-.m+a -.e ------m-- 4 .er 4 mi en-. +=.Lwe -e , 4. - J - - -

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. .

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TXX-6089.

Attachment 2

-

Page 3 of 13

,

NOTICE OF DEVIATION

i ITEM B (445/8603-D-18)

i B. Paragraph 5.1 of ERC Procedure CPP-007, Revision 2 states, in part,

" Responsible QA/QC discipline engineers review the latest . . . Brown &

Root . . . documents relating to the population. Subsequently, the

< engineer develops a list of safety significant attributes that are common

j to the population and which can be reinspected . . . .

Paragraph 3.4.4.3 in Brown & Root, Inc. Instruction QI-QAP-11.1-28,

Revision 31, identifies requirements for base material inspection and

'

i states, in part, "The depression depth produced by grinding shall not

exceed . . 1/32" for material less than 3/8" thick (structural shapes)."

In deviation from the above, the responsible QA/QC discipline engineer

i failed to identify and incorporate into ERC QI-029 this base material

i inspection attribute. As a result, ERC inspection of Verification Package 1

i No. I-S-LBSN-065 failed to identify that grinding on base material in

excess of 1/32" existed on item 3 of pipe support MK No. CT-1-008-001-

)i S22S.

RESPONSE TO ITEM B (445/8603-D-18)

We deny the alleged deviation for the-reasons that follow.

_

,

, Section 5.1 of CPP-007 states in part, " Responsible QA/QC Discipline

i Engineers review the latest Gibbs and Hill, Brown and Root, and

i

'

subcontractor design documents relating to the population. As applicable,

the latest installation procedures, construction drawings (including as-

i builts), and manufacturer's prints and manuals are also reviewed."

4

Section 5.2 of CPP-007 states in part, " Subsequently, the engineer

develops a list of safety-significant attributes that are common to the

'

population and which can be reinspected..."

l The ERC QA/QC Discipline Engineer did in fact review QI-QAP-11.1-28

Revision 3) for applicability in developing the QI-029 inspection

checklist. Inspection for excessive grinding due to welding defects on

i base materials was not included on the checklist for the following

i reasons. While excessive grinding may be readily detected after initial

i installation is complete, it cannot be accuratelv reinspected following

i application of coatings. In most cases, the grinding performed to remove

1 weld defects would not be detectable through paint at all. Further, while

! the ASME Code Subsection NF stipulates that grinding to remove weld

'

defects may not encroach on minimum base metal thickness, there is no code

requirement to inspect for other types of defects in base metal as a

! result of the welding process. Once coatings have been applied, it is

l difficult to distinguish between markings due to grinding versus other

i potential causes. Paint removal to inspect for potential excess grinding

i is impractical. In addition, paint removal methods also remove some base

metal in the process, making an accurate determination of the depression

j depth impossible. For these reasons, the ERC QA/QC discipline

I

. .

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_ . __ _.

.

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TXX-6089

Attachment 2

. Page 4 of 13

NOTICE OF DEVIATION

ITEM B (445/8603-D-18) CONT'D

RESPONSE TO ITEM B (445/8603-D-18) CONT'D

engineer concluded that inspection for excessive grinding of base metal

through paint is not a recreatable characteristic of the welding

attribute. In accordance with ISAP VII.c, attributes or subattributes

which are deemed not recreatable are not included on inspection

checklists.

However, due to NRC inspector concerns, the ERC inspector wrote an Out-of-

Scope observation for Verification Package No. I-S-LBSN-065 noting

potential excess grinding on the pipe support base metal. A

Nonconformance Report was subsequently issued and is currently being

evaluated to disposition the Out-of-Scope observation.

It should also be noted that the nominal flange thickness for this pipe

support (a W4 x 13 structural shape) is 3/8 inch. In accordance with QI-

QAP-11.1-28, a depression depth of 1/16 inch (the observed condition) is .

thus acceptable.

.

i

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j

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i

l

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.- . _-. . _ - _ ,

__ __

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TXX-6089

Attachment 2

Page 5 of 13

NOTICE OF DEVIATION

ITEM C (445/8603-D-17)

C. Section 5.2 of ERC Procedure CPP-022, Revision 0, states, in part, " Paint

shall be removed from the weld connections which have been inspected

through paint . . . . Results of these visual inspections shall be

documented and include, as a minimum, criteria utilized, (and) any

discrepancies." Section 5.2.D of ERC QI-062, Revision 0, states, " Verify

surface of welds are sufficiently free of overlap, abrupt ridges and

ripples so proper interpretation of radiographic and/or other required NDE

could be accomplished."

In deviation from the above, ERC quality inspection documented in

Verification Package No. I-S-NPBW-014 that the surface of welding which

attached item 1 to support steel identified on Drawing FW-1-019-901A-C57W

was acceptable. Independent inspection identified, however, that after

removal of coatings the weld surface was unacceptable. Subsequent to the

NRC inspection, ERC personnel issued a deficiency report documenting the

rejectable weld condition.

RESPONSE TO ITEM C (445/8603-D-17)

We deny the alleged deviation for the reasons that follow.

> - The surface of the subject weld (with paint on) was inspected per packages

I-S-PWRE-006 and I-S-NPBW-014. Weld surface irregularities were noted by

the inspectors and the attribute rejected in each package. The rejection

was documented on DR No. I-S-PWRE-006 DR2. (No DR was written for the

NPBW package, as the second part of the inspection called for weld surface

examination with the paint removed.)

Following paint removal, the weld surface could be more easily examined.

The weld surface attribute was accepted in I-S-NPBW-014 and later in

Overview Inspection Report No.24-008 (I-S-PWRE-006). Due to NRC concerns

about the weld surface, however, an independent Level III inspector was

brought to CPSES to examine the weld. The report by this Level III

inspector stated, "This writer found this weld to be acceptable except in

some cases where abrupt ridges and valleys were pronounced due in part to

limited grinding of the surface. It should be noted that this is a

judgement interpretation that would vary from weld to weld and in some

cases the final magnetic particle test may require additional surface

preparation influenced by the specific MT method used." The independent l

Level III inspector concluded: "It is evident that the magnetic particle

examination would be the last determining factor as to the adequacy of the

weld."

A review of the original magnetic particle examination of the weld

performed by Chicago Bridge and Iron indicated the acceptability of the

weld and weld surface. Based on the judgement of the ERC inspectors, the

independent Level III inspector report, and the acceptance of the weld in

the original NDE report, ERC concluded the weld surface was acceptable.

However, due to continuing NRC concerns regarding the interpretation of

the independent Level III inspector's report, Deviation Report No. I-S-

NPBW-014 DR1 was generated.

_ _ - _ . _.

_ _ _ __. - _ _ _ _ _

.

Page 6 of 13

C 445/8603-0 7 OM

RESPONSE TO ITEM C (445/8603-D-17) CONT'D

To resolve the issues, a Brown and Root Level III inspector performed a

Magnetic Partical Test on the weld. On the basis of the test report

(MT/PT Report #29023) the weld and weld surface were acceptable.

'

Therefore, no deviation exists. DRs No. I-S-NPBW-014 DRI and No. I-S-

PWRE-006 DR2 will be invalidated.

i

j

=

I

i

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, . _ _ _ . ,

- _ _ _ _ -_ . _ _ _ _ . , _ _ . _ - _ . . _ _ _ __

, , _ _ _ - _ _ _ _ , , _ _ _ _ ,

_ -_ -_

.

TXX-6089

Attachment 2

Page 7 of 13

NOTICE OF DEVIATION

ITEM D (446/8602-D-13)

D. Section 5.1.1 of Revision 2 to ERC Procedure CPP-008 states, in part,

"

. . . should an attribute appear on the generic checklist and not be

applicable to the specific item, the engineer indicates 'N/A' and provides

reasonable justification for the entry."

In deviation from the above, an independent inspection of Verification

Package No. I-S-HVDS-075, support DG-844-2K-1J, revealed that Sections

2F.1, ?F.2, and 2F.3 in the checklist for QI-035, dealing with embed

plates and spacing violations, had been "N/A'd" by the engineer.

Further, the noted justification for this entry was "No Embedded PLs."

However, independent inspection identified the existence of an embed plate

with dimensions of approximately 20' X 8".

RESPONSE TO ITEM D (446/8602-D-13)

We deny the alleged deviation for the reasons that follow.

Sections 2F.1, 2F.2, and 2F.3 for Verification Package No. I-S-HVDS-075

had been "N/A'd" by the ERC engineer. The justification for this entry

,~

was "No Embedded PLs". A subsequent review of this package by ERC has

! revealed that a deviation does not exist. The ERC Engineer correctly

N/A'd these attributes.

Quality Instruction (QI) 035, " Reinspection of HVAC Duct Supports"

delineates the inspection requirements to be performed for this population

(HVDS). Section 5.2.2F of this QI addresses Welded Attachments to

Embedded Plates. For the 2F. attributes to be inspected, the duct support

has to be attached (welded) to the embedded plates. Verification Package

No. I-S-HVDS-075 contains support DG-844-2K-lJ for inspection. Support

DG-844-2K-1J is not welded to an embed plate, therefore these attributes

(2F.1, 2F.2, and 2F.3) cannot be reinspected. Therefore, the ERC engineer

correctly N/A'd these inspection attributes.

During the course of this review and subsequent discussions with the NRC

it was brought to the attention of ERC that NRC had a concern with

Attribute 4C.3, "Hilti to Embedded Plate Edges". The ERC inspector had

originally accepted this attribute. QI-035, Section 4C.3 requires the ERC

inspector to " verify that the minimum distance of each Hilti anchor to any

adjacent embedded plate (or Nelson stud, if available) meets the

requirements of Attachment 6.17..." The required minimum for a 1-inch

Hilti to the edge of an embedded plate is 7-1/2 inches. Subsequent

inspection of attribute 4C.3 revealed a 1 inch Hilti installation 7/8-inch

from an embedded plate.

Verification Package No. I-S-HVDS-075, was reissued and a deviation report

, I-S-HVDS-075-DR4 issued by the ERC inspector on July 31, 1986, identifying

the discrepant condition. In addition, Nonconformance Report No. M-86-

202172X was issued on September 2, 1986 and has not yet been

dispositioned.

l

_ _. - - _ _

_ . . - - _ ..._ _ _ __ _ . _ _ _____ _ _ _ _ _ _ . _ _

.

1

TXX-6089

'

Attachment 2

,

Page 8 of 13

NOTICE OF DEVIATION

ITEM E.1 (446/8602-D-12)

l E. Section 4 of Revision 3 to ERC Procedure CPP-009 states, in part,

4

" Qualified QA/QC Review Team personnel perform field reinspections of

specific hardware items and reviews of appropriate documents in accordance

! with approved instructions . . . ."

l

l In deviation from the above, the following examples were noted where field

j reinspections of hardware items were not performed in accordance with

approved instructions

1

E.1. Attribute 2D. in Section 5.0 of Revision 0 to QI-035 states,

, " Verify member lengths and all other dimensions that describe the

!

lengths and positions of members on the support frame (+/- 1/2")." ;

! For Verification Package No. I-S-HVDS-075, Support D6-844-2K-lJ,

the ERC inspector signed the checklist that this attribute (20.)

l was acceptable. An independent inspection revealed, however, that

I there were several members for which no dimensional information

was provided in the drawing thus making it impossible to verify

required member lengths and all other dimensions that describe the

j

lengths and positions of those members.

.

RESPONSE TO ITEM E.1 (446/8602-D-12)

'

l. Reason for Deviation  :

!

! We admit to the alleged deviation for the reasons that follow. -

I The ERC inspector accepted attribute 2D for Verification Package No. I-S-

HVDS-075. Therefore, a deviation does exist. During the course of this  :

inspection, discussions were held between the ERC inspector and the HVDS j

j population engineer as to the acceptability of the dimensions for this i

4

duct support (DG-844-2K-IJ). The ERC inspector was instructed by the

! population engineer to verify only those dimensions and lengths available  ;

! on the drawing. The member whose lengths were not shown, spanned two '

l members. These members were verified, under the configuration attribute,

to ensure that they spanned the two members. However, a tolerance was not

j applied to the member length, because it was not considered safety

significant.  ;

Therefore, attribute 2D. was accepted for the aforementioned members. The  ;

acceptance was based on engineering judgement that the member length

1

attribute was not safety significant in those cases.

4

l 2. Corrective Action Taken

i

l The ERC population engineer has written a letter to the Design Adequacy

! Program (DAP) outlining that duct support detail drawings, in general,

i lack sufficient information concerning member lengths. Based on the

j finding, the ERC engineer is reviewing the HVDS Verification Packages to

determine the validity of previous deviation reports written against

,

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TXX-6089

Attachment 2

-

Page 9 of 13

NOTICE OF DEVIATION

ITEM E.1 (446/8602-D-12) CONT'D

RESPONSE TO ITEM E.1 (446/8602-D-12) CONT'D

!

2. Corrective Action Taken Cont'd

I attribute 20. Additionally, TUGC0 has undertaken a complete HVAC support

reverification program for Unit I and common.

3. Action to Prevent Recurrence

The DAP employs a systematic process for identifying and evaluating trends

, and generic implications. This systematic process implements the CPRT

commitment to investigate the generic implications of deficiencies in the

j area of design. The process is intended to:

i  ;

' - Identify and evaluate any trends in observations, or in deviations

from design criteria, or commitments that indicate a possibility of

i adverse impacts on the design of safety related systems, structures

l and components.

4

-

Determine whether identified deficiencies in design have generic

l, implications and effects and, if so, the extent of these effects.

-

Ensure that adverse impacts on hardware that result from generic i

j effects are evaluated and resolved. -

'

1

2

-

Identify corrective action necessary to preclude recurrence of each

i deficiency,

i

i 4. Date of Comoliance

! The DAP analysis is currently in process and is expected to be completed  !

! by June 1987. The TUGC0 HVAC support reverification program is expected  ;

,

to be completed by May 1987.

!

!

!

I

i

!

.

i

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TXX-6089

{- Attachment 2

Page 10 of 13

NOTICE OF DEVIATION

ITEM E.2 (446/8602-D-11)

i

j E. Section 4 of Revision 3 to ERC Proce' dure CPP-009 states,.in part,

j " Qualified QA/QC Review Team personnel perform field reinspections of

'

.

specific hardware items and reviews of appropriate documents in accordance

with approved instructions . . . ."

! In deviation from the above, the following examples were noted where field

i reinspections of hardware items were not performed in accordance with

l approved instructions:

! E.2. Attribute 3B. in Section 5.0 of Revision 0 to QI-035 states,

j " Verify that weld sizes meet the requirements of the duct support

i detail drawings." For Verification Package No. I-S-HVDS-037, .the

{ ERC inspector signed attribute 38. as being acceptable-and noted

i that all welds had been measured with a Fiber Metal Fillet Gauge.

j During an independent inspection, it has noted that there were two

skewed fillet welds on this support in which one-leg of the fillet

on each weld could not be measured with a Fiber Metal Fillet Gauge

or any other conventional method.

~

.+

'

.

RESPONSLTO ITEM E.2 (446/8602-D-11) ,

,

,

-

1. Reason for Deviation

i We admit to the alleged deviation for the reasons that follow.

Appendix B of the NRC Inspection Report 445/86-03and446/86-d'2'

incorrectly identifies this deviation against Verification Package No. I-

'

'

,

S-HVDS-037. Hcwever, in Appendix C of the NRC Inspection Report,

1 Verification Package No. I-S-HVDS-075 is correctly identified forwhich

J the aforementioned deviation exists. Therefore, this response addresses

j the deviation as identified by the NRC in In:pection Report 445/86-03 and

j 446/86-02 for Verification Package No. I-S-HVDS-075.

'

The ERC inspector accepted attrib tm 38., Weld Size, for Verification

Package No. I-S-HVOS 075/ and roted on Attachment 6.2 that the welds had

I been measured using i'ibre M6tal Gages, a flashlight, and visual )

inspection. This inspection was performeo November 7,1985. ' On July 31, '

.

j

1 1986, Verification Package No. I-S-hTDS-075 was reissued with a "

1 supplemental instruction to reverify attribute 38. The ERC-ingactor  :

1

again accepted attribute 3B and poted on Attachment 6.2'tm the'

supplemental instruction that the welds had been measured with a

flashlight, Fibre Metal Fillet Gages, visual ins;oction, and skewed gages.

'

.

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,

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TXX-6089

Attachment 2

-

Page 11 of 13

NOTICE OF DEVIATIM

ITEM E.2 (446/8602-D-11) CONT'D

RESPONSE TO ITEM E.2 (446/8602-D-11) CONT'D

1. Reason for Deviation (cont'd)

Subsequent discussions with the ERC inspector revealed that a six inch

rule had also been used to verify the skewed weld leg size. The six inch

rule was used to measure the leg that had the member "end prepped." The

inspector apparently accepted the attribute on that basis. Based on

further discussions with the ERC inspector, NRC inspector, and TUGC0 QA/QC

personnel it was determined that the ERC Level III should verify attribute

38. The Level III inspector successfully measured one leg of the skewed

fillet weld using a skewed weld gage. The Level III inspector determined

that the second leg of the weld could not be measured in the manner

demonstrated by the ERC inspector. The measured leg size was 3/8-inch.

Measurement of the second leg was found to be indeterminate. Therefore, a

deviation does exist for Verification Package No. I-S-HVDS-075 attribute

38.

2. Corrective Action Taken

i~ ERC Deviation Report (DR) number I-S-HVDS-075-DR5 was prepared to document

the undersized weld.

.

<

3. Action to Prevent Recurrence

t

'

For Verification Package No. I-S-HVDS-075, where inspector error was

evident, the inspector and the lead inspector and population (ERC)

,

engineer discussed specifics to determine why the error occurred.

Documented evidence of these discussions is available in the file for NRC

review.

At the discretion of the lead inspector, formal and informal group

meetings were held to discuss inspector error on a generic basis. These

Miscussions allowed appropriate information to be disseminated to various

cognizant ERC inspectors.

,

An Overview Inspection Program was implemented to reinspect a sample of

each inspectors work. Results of the Overview Inspection Program are j

complete and are available for NRC review. The inspector for Verification

Package No. I-S-HUDS-075 had an overall error rate of 0.18% or 0.0018.

, This number is significantly less than one percent and is based on 3279 l

decision points reviewed by Overview Inspection with 6 in disagreement. l

l Based on these Overview results, we believe that no further action to

prevent recurrence is required.

4. DAtg of Comoliance

t

l Compliance will be achieved with the resolution of DR I-S-HVDS-075-DR5 by

l February 20, 1987.

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C

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. . _ _-

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TXX-6089

Attachment 2

Page 12 of 13

NOTICE OF DEVIATION

ITEM E.3 (445/8603-D-13)

E. Section 4 of Revision 3 to ERC Procedure CPP-009 states, in part,

" Qualified QA/QC Review Team personnel perform field reinspections of

specific hardware items and reviews of appropriate documents in accordance

with' approved instructions . . . ."

In deviation from the above, the following examples were noted where field

reinspections of hardware items were not performed in accordance with

approved instructions:

E.3. Attribute 1.f in Section 5.2.6.2 of QI-025, Revision 2, states, in

part, " Ensure that a minimum of 2 inches clearance is maintained,

including pipe insulation, with respect to other piping when one

or both lines have an operating temperature of 2000 F or

greater . . . ." For Verification Package No. I-M-LBC0-148, the

ERC inspector signed off this attribute as acceptable, even though

there were three cases where the minimum separation criteria were

not met and no documentation existed justifying this condition.

The three instances were as follows:

a. Line 2-CC-1-060-152-3 was in contact with the inspected

_ line at a location 6' 6" north of wall 7-S and 10' west of

wall D-S. The two lines were parallel and were in contact

for about 4'.

b. Line 2-CC-1-061-152-3 was in contact with the inspected

line at a location 12'6" north of wall 7-S and about 8'

west of wall D-S.

c Line 1-CC-1-062-152-3 was closer to the inspected line

than the allowable 2" at a location 6' 6" north of wall 7-

S and 7' 6" west of wall D-S.

l

RESPONSE TO ITEM E.3 (445/8603-D-13)

1. Reason for Deviation

We admit to the alleged deviation for the reasons that follow.

Investigation by ERC confirmed the above findings identified by the NRC.

Therefore, a deviation does exist for Verification Package No. I-M-LBC0-

148, attribute 1.f, which was incorrectly accepted by the ERC inspector.

2. Corrective Action Taken

Deviation Report (DR) number I-M-LBCO-148-DR-3 was prepared on August 28,

1986, to document the existence where the minimum separation criteria was

not met. Nonconformance Report (NCR) number M-25340N was generated as a

result of the DR to disposition the above conditions.

,

+ , I

- 1

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TXX-6089

. Attachment 2

Page 13 of 13

NOTICE OF DEVIATION

ITEM E.3 (445/8603-D-13) CONT'D

RESPONSE TO ITEM E.3 (445/8603-D-13) CONT'D

3. Action to Prevent Recurrence

In cases where inspector error was evident, the inspector and the lead

!

inspector or population engineer discussed specifics to determine why the

i error occurred.

Documented evidence of these discussions is available in the file for NRC

review.

3 At the discretion of the lead inspector, formal and informal group

,

meetings were held to discuss inspector errors on a generic basis. These

discussions allowed appropriate information to be disseminated to various

cognizant ERC inspectors. Additionally, this finding was discussed and

,

documented with all overview inspectors on June 10, 1986. The overview

<

inspectors were instructed to review in detail all NCRs in each overview

inspection package.

l

! An Overview Inspection Program was implemented to reinspect a sample of

}- each inspectors work. Results of the Overview Inspection Program are

complete and are available for NRC review. The. inspector for Verification

Package No. I-M-LBC0-148 had an overall error rate of 1.12% or 0.0112.

This number of errors is slightly more than one percent and is based on

2675 decision points reviewed by Overview Inspection with 30

disagreements. Based on the Overview Inspection, we believe that no

further action to prevent recurrence is required.

4. Date of Comoliance

Corrective action will be completed commensurate with the final

disposition of nonconformance report M-25340N which is expected by May 1,

1987.

l

_

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_ --_ __

,

Outgoing Correspondence bec (2):

M. D. Spence L. D. Nace

. W. G. Counsil V. S. Noonan

J. W. Beck D. F. Landers

R. W. Ackley L. E. Powell

,

R. E. Ballard PIMS

J. L. Barker R. L. Ramsey

W. R. Burchette J. D. Redding

J. H. Butts D. M. Reynerson

R. D. Calder N. S. Reynolds

Frank Camp K. L. Scheppele

R. E. Camp H. C. Schmidt

'

D. E. Deviney A. B. Scott

T. G. Dignan C. E. Scott

-

J. Ellis J. F. Streeter

B. Finkelstein B. Tartt

J. B. George A. Vietti-Cook

R. S. Howard E. L. Wagoner

R. T. Jenkins H. M. Warren (2)

R. A. Jones N. H. Williams

S. D. Karpyak D. R. Woodlan

G. S. Keeley/ R. A. Wooldridge

J. S. Marshall

J. E. Krechting October 20, 1986

J. C. Kuykendall

D. F. Landers

'

R. P. Lessey

0. W. Lowe

D. M. McAfee/

P. E. Halstead

R. E. McCaskill

J. P. McGaughy

D. D. Mosley 1

-

\

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._

Log # TXX-6337

P9 File # 10130

_. _-

:

'

. 1UELECTRIC

w a.. c.co ma March 12, 1987

Em urow ike />ruJrm

i

.

U. S. Nuclear Regulatory Commission IIk

ATTN: Document Control Desk MAR I 91987

V

Washington, DC 20555 J u,!

.-

SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446

RESPONSE TO NRC NOTICE OF DEVIATION

INSPECTION REPORT NOS.: 50-445/86-03 AND 50-446/86-02

,,

Gentlemen:

In a conversation with your Mr. I. Barnes on March 12, 1987, we advised

Region IV that the date for completion of the corrective action regarding

Notice of Deviation Response to Item E.2 446/8602-D-11 was being revised.

Specifically, the date of full compliance stated in the response was

February 20, 1987. DR I-S-HVDS-075-DR5 was not resolved until March 11,

1987. The date of full compliance, therefore, was achieved on March 11,

1987.

,

Very truly yours,

h.

W. G. Counsil

By: .

G. S. Keeley n/_

9/

Manager, Nuclear L yensing

RDD:lw

. c - Mr. E. H. Johnson, Region IV

Mr. D. L. Kelley, RI - Region IV l

Mr. H. S. Phillips, RI - Region IV

79 hShhb h

400 North Olne Street 1.11 81 Dallas, Tesas 75201 l

b

_. ._. . _ _ _ __

1