IR 05000445/1985007

Ack Receipt of 860402,870128,0220 & 0327 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/85-07 & 50-446/85-05

ML20213A032
Person / Time
Site:	Comanche Peak
Issue date:	04/22/1987
From:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8704270351
Download: ML20213A032 (12)

Text

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o In Reply Refer To: NR 22 E Dockets: 50-445/85 07 50-446/85-05 TU Electric ATTN: W. G. Counsil

. Executive Vice President 400 N. Olive L.B. 81 Dallas, Texas 75201

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Gentlemen:

Thank you for your letters of April 2,1986, January 28, 1987 February 20, 1987, and March 27, 1987, in response to our letters dated February 3,1986, and December 30, 1986. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. !ic will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely, Original Signed byr R.E.HALU E. H. Johnson, Director Division of Reactor Safety and Projects

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cc:

TU Electric  ;

G. S. Keeley, Manager,

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ATTN:

Nuclear Licensing .i Skyway Tower 400 North Olive Street l Lock Box 81 Dallas, Texas 75201 Juanita Ellis President, CASE 1426-South Polk Street Dallas, Texas 75224

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/DRSP RIV/RRI t 21//7 SPhillips:lc RIV/CPTg IBarnes //EHJohnson 4/M/87 &/tt/87 f h//87 8704270351 870422 -

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PDR ADOCK 05000445 0 PDR

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TU Electric -2-Renea Hicks Assistant Attorney General Environmental Protection Division P.O. Box 12548 Austin, Texas 76711 - 2548 Administrative Judge Peter Bloch U.S. Nuclear Regulatory Commission

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Washington, D. C. 20555 Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, Oklahoma 74075 Dr. Walter H. Jordan 881 Outer Drive Oak Ridge, Tennessee 37830 Anthony Roisman, Es Executive Director Trial Lawyers for Public Justice 2000 P. Street, N.W., Suite 611 Washington, D. Texas Radiation Control Program Director bec: to DMB(IE01)

bec distrib by RIV:

RPB MIS System RRI-0PS RSTS Operator RRI-CONST R&SPB DRSP R. Martin, RA RIV File J. Taylor, IE J. Konklin, IE L. Chandler, OGC D. Weiss,LFMB(AR-2015) RSB I. Barnes, CPTG

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Log # TXX-6211 File # 10130

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IR 85-07

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IR 85-05

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w ,,,, c. %, January 28, 1987 t w w,,e ra.e n ,sca,, FEB - 31987 ! ,

U. S. Nuclear Regulatory Commission "-

ATTN: Document Control Desk Washington, DC 20555 SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT NOS.: 50-445/85-07 AND 50-446/85-05 SUPPLEMENTAL REQUEST FOR INFORMATION TO NRC NOTICE OF VIOLATION (NOV) ITEMS 1, 2.A AND REF: TUGC0 LETTER TXX-4727 FROM W.G. COUNSIL TO E. H. JOHNSON DATED APRIL 2, 198 ,

Gentlemen:

We have reviewed your letter dated December 30, 1986, requesting additional information to our response referenced above regarding NOV 445/8507-01 and 446/8505-01 (Item 1), 445/8507-02 (Item 2.a) and 445/8507-03 (Item 2.b). We hereby respond to the request for supplemental information in the attachment to this lette We requested and received an extension until January 26, 1987, in providing our response during a telephone conversation with Mr. I. Barnes on January 15, 1987. We requested and received an extension until February 16, 1987, in providing our response to NOV 445/8507-03 (Item 2.b) during a telephone conversation with Mr. I. Barnes on January 23, 1987. We requested and received an extension until January 28, 1987, in providing our response during a telephone conversation with Mr. I. Barnes on January 26, 198 Very truly yours,

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W. G. Cougsil

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G. S. Keeley Manager, Nuclears .evsing vu/

RSB:lw V Attachment c - Mr. Eric H. Johnson, Region IV Mr. D. L. Kelley, RI-Regicn IV Mr. H. S. Phillips, RI-Region IV n m/ n r/I I J 'Jf #

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400 North Othe Street I..B. 81 Dallas Te as 75201

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Attachment to TXX-6211

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. NOTICE OF VIOLATION ITEM 1 (445/8507-01 AND 446/8505-01)

SUPPLEMENTAL REQUEST FOR INFORMATION We find that the corrective steps taken and results achieved do not indicate that the installation of the replacement RTE-Delta Potential Transformer tiltout assembly was reinspected and accepted. Also, there is no indication that these deficiencies were documented on a nonconformance report for Units 1 and SUPPLEMENTAL RESPONSE TO ITEM 1 In our previous response we noted the deficiencies involving the Unit 1 RTE-Delta Potential Transformer Tiltout assemblies were corrected using startup work permits. We failed to note that inspections and the acceptance of completed work are inherent in the startup work permit program. We have ~

confirmed these activities were accomplished as documented on the completed work permits (Z-2912 & Z-2914).

As noted in our review of a previous NRC finding (445/8407-01), the program for managing 10CFR21 defects was not positively controlled. In some cases, and in the case of the RTE-Delta 10CFR21 notice involved in this finding, the deficiencies were corrected without nonconformance report Under our current program, the Site Coordinator, whose responsibilities are specified in Procedure NE0-CS-1, " Evaluation of and Reporting of Items / Events Under 10CFR21 and 10CFR50.55(e)," is responsible for assuring proper deficiency documentation, including NCRs, are issue Our previous response incorrectly indicated that the Unit 2 10CFR21 deficiencies were corrected in August 1985. The work was actually completed in September 1985 and QA/QC review of the work packages was completed in April 198 l l

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Attachment to TXX-6211

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January 28, 1987 Page 2 of 4

NOTICE OF VIOLATION i ITEM 2.a (445/8507-02)  !

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SUPPLEMENTAL REQUEST FOR INFORMATION l The described corrective steps taken do not indicate whether a nonconformance report was written for Units 1 and Follow up by the NRC inspector identified that the drawing which was used for the activity (i.e.,

Westinghouse Drawing 1457F29) had been reviewed and stamped by Gibbs and Hill, signifying apparent approval of a drawing which allowed use of grout instead of Class E concrete. Accordingly, it is requested that the stated reason for

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the violation be reevaluated, in that the engineering interface or review may have contributed to causing this violation. Please also identify the design change authorization, if any, that permits use of grout rather than Class E concrete in Unit 2, in that the referenced design change DCA-21,179 would appear to be applicable to Unit I only. In your corrective steps to avoid recurrence, you stated that operational travelers issued during the same time frame for similar type installations would be reviewed for similar deficiencies. Please clarify how this action is pertinent to precluding-recurrence. Your response also indicated that any corrective actions deemed necessary, as a result of this review, would be reported to Region IV by April 15, 1986. In that no supplementary response has been received by Region IV, please identify whether or not your review determined corrective actions -

were necessar SUPPLEMENTAL RESPONSE TO ITEM As a result of discussions with the NRC Resident Inspector, and our review of the Violation, we have determined that a revision to our response is require The revised response below provides the supplemental information requeste . Reason for Violation We admit to the Violation, ano the required information follow This violation was the result of inadequate design review of the

. Westinghouse equipment drawing by the primary on-site design group after~

the drawing had been received on-site. The drawing, which specified the

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use of grout, disagreed with the Gibbs and Hill, Inc. civil drawing which

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specified Class "E" concrete. Subsequently, this disparity was overlooked when an operational traveler was developed which specified the use of grout without formal design concurrence on incorporatio !

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Attachment to TXX-6211 l

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January 28, 1987  !

Page 3 of 4 )

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- SUPPLEMENTAL RESPONSE TO ITEM 2.a CONT'D Corrective-Action Taken After reviewing grout card No. 186, which documented the material used in the actual installation, and the results of.the compressive strength test

for the grout used in this application, a design change (DCA-21,179) was

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used to document acceptance of the installation. These actions were

, initiated after identification of the condition via an NRC Inspection i Report item.

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After further review of this matter,~.two DRs (C-86-12 and C-86-13) were issued December 29, 1986, to ensure appropriate drawing changes were made;

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to formally document acceptance of the grout used in these and other

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nearby installations; and to specifically identify the root cause of this

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' Action to Prevent Recurrence

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! Operational travelers, grout cards, and drawings used during the same time

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frame were reviewed for similar installations.- The operational traveler

review completed on May 15, 1986, indicated that other drawings used for similar installations did not contain the same disparity as discussed in Item 1 above. However, the review revealed that grout was used in seven other installations in Unit I and eight installations in Unit 2 due to

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. differences between drawings 2323-SI-0550, 2323-S2-0550, and 1457F29. The grout used in these other fifteen installations was evaluated and found to l have a compressive strength in excess of Class "E" concrete. DCA-21,179

, and DCA-26,101 issued November 8, 1986, and November _26, 1986,

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respectively, were used to document acceptance of the installations in Unit I and Unit 2, respectively. Based on the specific nature of the

. discrepancies and the results of our review, this violation is considered to be an isolated occurrence.

l A Project Directive was issued on July 17, 1986, reemphasizing, a) the i requirements for properly documenting design alternatives prior to j initiating construction activities, and b) the precedence of design versus vendor documents.

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The review of vendor drawings (except for Fire Protection and HVAC

. drawings) is performed by Stone and Webster Corporation (SWEC) in '

accordance with SWEC Procedure PP-053, " Review of Vendor Drawings." The review of vendor HVAC drawings is performed by Ebasco in accordance with TUGC0 Procedure ECE-DC-5, " Vendor Document Review." These vendor drawings are reviewed against design drawings to resolve any discrepancie The review of vendor Fire Protection drawings is performed by Impell e Corporation in accordance with Impell Procedure IMP-FP-19, " Vendor

; Document Review." SWEC Procedure PP-053 and Impell Procedure IMP-FP-19 l

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• will be revised to clarify and specifically require the review of vendor

[ l drawings to insure compliance with design drawing ? Date of Comoliance i

CPSES is currently in full complianc SWEC Procedure PP-053 will be i revised and. issued by February 27, 198 Impell Procedure IMP-FP-19 will i be revised and issued by April 30, 1987.

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Attachment to TXX-6211

. January 28, 1987 Page 4 of 4 o .

NOTICE OF VIOLATION ITEM 2.b (445/8507-03)

SUPPLEMENTAL REQUEST FOR INFORMATION With respect to the corrective steps taken, please describe what formal actions were taken (e.g., specification revision) to justify the change in output voltage from 10 +/- 2v to 12 +/- 2v on the revised Westinghouse Quality Release. Your response also fails to provide any actions taken to assure that other equipment received from this vendor, irrespective of time frame, did not exhibit similar documentation deficiencie SUPPLEMENTAL RESPONSE TO ITEM TU Electric Quality Assurance is in the process of obtaining related information from the vendor and reviewing site documentation. We anticipate submitting our response no later than February 16, 198 '

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= Log # TXX-6284 P9 File # 10130

- -- C IR 85-07 r C IR 85-05 7tlELECTRIC Ref # 10CFR2.201 DwI ,Yjr,,a,,,, February 20, 1987 U. S. Nuclear Regulatory Commission 3[Q@$Ok l t- i, i; ATTN: Document Control Desk is '

I Washington, DC 20555

[ S 24N L. h SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) L- 'h ,

DOCKET NOS, 50-445 AND 50-446 i INSPECTION REPORT NOS.: 50-445/85-07 and 50-446/85-0a SUPPLEMENTAL REQUEST FOR INFORMATION TO NRC NOTICE OF VIOLATION (N0V) ITEMS 1, 2.a and REF: 1) TV Electric Letter TXX-4727 from W. G. Counsil to E. H. Johnson dated April 2, 1986 2) NRC letter from E. H. Johnson to W. G. Counsil dated December 30, 1986 3) TV Electric Letter TXX-6211 from W. G. Counsil to NRC dated January 28, 1987 Gentlemen:

We reviewed your letter (Reference 2) requesting additional information on the subject inspection report, and responded to the NOVs in our letter TXX-6211 (Reference 3). In our response to NOV 445/8507-03 (Item 2.b), we stated that TV Electric Quality Assurance was in the process of obtaining related information from the vendor and reviewing site documentation, and we anticipated submitting our response no later than February 16, 1987. We requested and received an extension in providing our response to NOV 445/8507-03 (Item 2.b) until February 20, 1987, during a telephone conversation with Mr. I. Barnes on February 17, 1987. We hereby respond to Item 2.b in the attachment to this lette .

Very truly yours,

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W. G. Counsil RSB:lw Attachment c - Mr. E.'H. Johnson, Region.IV~

Mr. D. L. Kelley, RI - Region IV l Mr. H. S. Phillips, RI - Region IV Omd1 qw < v7Tl (fh(fY& 00'- 1

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400 North Olise Street I..li 81 I)aila3, Texas 75201

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Attachment to TXX-6284 February 20, 1987 Page 1 of 2 NOTICE OF VIOLATION ITEM 2.b (445/8507-03)

SUPPLEMENTAL REQUEST FOR INFORMATION With respect to the corrective steps taken, please describe what formal actions were taken (e.g., specification revision) to justify the change in output voltage from 10 +/- 2v to 12 +/- 2v on the revised Westinghouse Quality Release. Your response also fails to provide any actions taken to assure that other equipment received from this vendor, irrespective of time frame, did not exhibit similar documentation deficiencie SUPPLEMENTAL RESPONSE TO ITEM Further evaluation of the apparent violation revealed a need to revise our original response. Accordingly, the following revised response is submitte . Reason for the Violation The root cause of the out-of-tolerance condition was a relocation of the Westinghouse subtier supplier's test facility in 1978. A change in the local power level from 240v nominal at the old test facility to 277v nominal at the new location was not initially detected. This change affected the test result output. The supplier representative failed to detect the apparent out-of-tolerance condition noted on the test report prior to release of the equipment from the subtier suppliers shop (Halmar Electronic Corporation) and subsequent shipment to CPSE The out-of-tolerance conditions noted on the test report was not detected by CPSES QC receiving inspection personnel because Westinghouse supplied non-ASME equipment is receipt accepted based on the Westinghouse Quality Release (QR) being complete and general conformance verification to purchase order requirement . Corrective Steos Taken and Results Achieved j Westinghouse Engineering performed a review of test data for all Electric Hydrogen Recombiner (EHR) Silicon Controlled Rectifier (SCR) panels tested during the period May 13, 1975 to March 8, 1981, bracketing the period during which the 240 to 277 volt plant power transition effect on test results may not have been recognized. The result of the documentation ,

review for the 209 SCRs revealed an additional out-of-tolerance condition I of the same nature, which has been documented on a Westinghouse Deviation Notice (DN). The Westinghouse Engineering review has established that there was no adverse effect on the performance or function of the equipment as a result of the deviatio ,  !

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.- Attachment to TXX-6284 February 20, 1987 Page 2 of 2 NOTICE OF VIOLATION ITEM 2.b (445/8507-03)

SUPPLEMENTAL RESPONSE TO ITEM 2.b - CONT'D Corrective Steos Taken and Results Achieved - Cont'd The output voltage specification was changed and documented in Halmar test procedure TP-001 and approved by Westinghouse Engineering per Westinghouse DN No. 26961 to compensate for the change in the test power suppl . Corrective Steos Which Will Be Taken to Avoid Further Violations Westinghouse's revaluation revealed only two panels out of 209 manufactured in the given time period to exhibit this out-of-tolerance condition. Therefore, this is considered a limited incident of personnel error by Westinghouse's subvendor (Halmar) specific to these panel These errors were not identified in the Westinghouse surveillance review of the test data due to the sampling nature of this review. Since the time period of this issue, but not as a result of this apparent violation, Westinghouse subtier supplier generated documentation has been subjected to increased frequency and depth of review by Westinghouse prior to authorization for shipmen . Date When Full Comoliance Will Be Achieved CPSES is presently in complianc *

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P9 Log # TXX-6349 File # 10130 1 __

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Ref # 10CFR2.201 K' ELECTRIC wawnc.o.ma March 27, 1987 lim utive Vu e />rsalent RfG(b)h.~i19.//(M$

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U.S. Nuclear Regulatory Commission  ! 6 s [ MAR 3 01987

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ATTN: Document Control Desk i i-Washington, D.C. 20555 f, -

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SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT NOS. 50-445/85-07 AND 50-446/85-05 CLARIFICATION OF SUPPLEMENTAL RESPONSE TO NOV 445/8507-01 AND 446/8505-01 REF: 1) TUGC0 letter TXX-4727 from W. G. Counsil to E. H. Johnson dated April 2, 1986 2) TU Electric letter TXX-6211 from W. G. Counsil to the NRC dated January 28, 1987 Gentlemen:

In further review of our supplemental letter identified in Reference 2, we have determined that a clarification to the subject response is required. The supplemental request for information for Notice of Violation 445/8507-01 and 446/8505-01 (Reference 2) has been restated to aid in understanding our revised respons .

NOTICE OF VIOLATION ITEM 1 (445/8507-01 AND 446/8505-01)

SUPPLEMENTAL REQUEST FOR INFORMATION We find that the corrective steps taken and results achieved do not indicate that the installation of the replacement RTE-Delta Potential Transformer tiltout assembly was reinspected and accepted. Also, there is no indication that these deficiencies were documented on a nonconformance report for Units 1 and REVISED SUPPLEMENTAL RESPONSE TO ITEM 1 In our response, we noted the deficiencies involving the Unit 1 RTE-Delta Potential Transformer Tiltout assemblies were corrected using startup work permits. We fail rd to note that inspections and the acceptance of completed l work are inherent in the startup work permit program. We ha/e confirmed these '

activities were accomplished as documented on the completed work permits (Z-2912 & Z-2914).

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[ x) North Olne Street 1. H M t Da!!a. lexa 75201

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'*#. TXX-6349 MARCH 27, 1987

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REVISED SUPPLEMENTAL RESPONSE TO ITEM 1 - CONT'D As noted in our review of a previous NRC finding (445/8407-01), the program for managing 10CFR21 defects was not positively controlled. In some cases, and the case of the RTE-Delta 10CFR21 notice involved in this finding,-the deficiencies were corrected without nonconformance reports. Our current programs for reportability evaluation and nonconformance control are specified in procedures NE0 CS-1, " Evaluation of and Reporting of Items / Events under 10CFR21 and 10CFR50.55(e)," and NEO 3.05, " Reporting and Control of Nonconformances." Procedure NEO CS-1 requires personnel to notify the Site Coordinator upon receipt of 10CFR21 information. The Site Coordinator is required to transmit the documented information concerning a potentially significant item to the appropriate manager in the Nuclear Engineering and Operations group. Procedure NEO 3.05 states that Engineering and Operations are responsible for initiating or requesting Nonconformance Reports (NCRs),

where required, for identified nonconformances. These programs should ensure that 10CFR21 notifications are evaluated and any required NCRs are initiate Our previous response incorrectly indicated that the Unit 2 10CFR21 deficiencies were corrected in August 1985. The work was actually completed in September 1985 and QA/QC review of the work packages was completed in April 198 Very truly yours, 1 f&lka/

W. G. Counsil RSB/ef c- Mr. E. H. Johnson,: Region IV Mr. D. L. Kelley, RI - Region IV t Mr. H. S. Phillips, RI - Region IV '

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