TXX-6899, Forwards Revised Response to Enforcement Action EA-86-009. Alleged Violation That Vendor Documents Re Electrical Penetration Assemblies Controlled by Gibbs & Hill Per Project Procedures Manual & Project Guide Denied

Forwards Revised Response to Enforcement Action EA-86-009. Alleged Violation That Vendor Documents Re Electrical Penetration Assemblies Controlled by Gibbs & Hill Per Project Procedures Manual & Project Guide Denied

ML20236H468
Person / Time
Site:	Comanche Peak
Issue date:	10/30/1987
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
EA-86-009, EA-86-9, TXX-6899, NUDOCS 8711040148
Download: ML20236H468 (6)

Text

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-- Log # TXX-6899 l

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.: _ File # 10118 _j O Ref. # 10CFR2.201 i

;nlELECTRIC 1

October 30, J1987 1 wmim c. couna - l em ,., % ere,wm l

U. S. Nuclear Regulat'or_v Commission 1 ATTN: Document ControllDesk* .

Washington, LUC 20555

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SUBJECT:

' COMANCHEPEAKSTEAMELECTRICSTATION(CPSES)

' DOCKET NOS. 50-445 AND 50-446 ENFORCEMENT ACTION (EA) NO. 86-09, APPENDIX B, ITEM I.B.2

i.

REFERENCES:

(1)' TV Electric Letter TXX-4946 from W. G. Counsil to J. M. Taylor, dated August 4,1986 j

-(2) TV Electric Letter TXX-6430 from W. G. Counsil 4 to the NRC dated May 6, 1987 .

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Gentlemen:

, Reference (1) and (2) provided our response to EA 86-09, Appendix B, Item 1.B.2. .A revised response is. attached. The changed portions of the text are  !

indicated by revision bars in the right margin._ A summary of the changes

-E .follows.

Section (3) of our response has been expanded to provide more detail and to clarify the scope of our vendor document review In addition, our previous statement that voided drawings. identified during the vendor review would be removed from the files, has been revised to reflect current practice. Our  :

current practice is to remove the voided drawings from the active files, stamp them appropriately, and retain them in the historical files.

Section (4) of our response indicated that implementation of the TNE-DC-5 series of procedures would prc tent recurrence of the violation. Our vendor review program has been revised and is governed by procedure ECE 5.19. This section of our response has been revised to describe this program.

8711040148 871030 PDR ADOCK 05000445

& PDR-400 North O!ive Stxet LB 81 D.nllas. Texas 7201 Ib

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TXX-6899 October 30,~1987 Page 2 of'2 l Section (5) has been revised to reflect our current schedule for full. 1 compliance.

Very truly yours, V7 W. G. Counsil BSO/gj l

c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)

Tile STATE OF TEXAS  :

COUNTY OF DALLAS:  :

There personally appeared before me W. G. Counsil, being duly sworn, did state that he is an Executive Vice President of TV Electric, that he is duly authorized to sign and file with the Nuclear Regulatory Commission this response to Enforcement Action (EA 86-09); that he is familiar with the q content thereof; and that the matters set forth therein are true and correct i to the best of his knowledge, information, and belief.

- 41MM W. G. Counsil Subscribed and sworn to before me, a Notary Public in and ford.L~, on this ?gday of se# , 1987. /

My commission expires a//L

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,19 9 ck. maw c/ev Notary Puplic l

_ _ _ _ _ _ _ _ _ _ _ _ _________-_- _- _ __ _-- _ 1

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. Attachment to TXX-6899 l October 30, 1987 Page 1 of 3 ALLEGED VIOLATION APPENDIX B ITEM I_.B.2

10CFR Part 50, Appendix,8, Criterion VI requires in part that measures be

!! established to control the issuance of documents, such as drawings, including changes thereto, which prescribe activities affecting quality. These measures assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used ,

at the location where the prescribed activity is performed.

The TUGC0 QAP, Section.6.0, Revision 0, dated July 1, 1978, requires in part that Gibbs & Hill be responsible for implementing quality assurance programs off-site that ensure appropriate documents are controlled and that changes required a's a result of comments, nonconformance, or engineering work are incorporated into revised documents.

Contrary to the above, at the time of this inspection, vendor documents were not appropriately controlled by Gibbs & Hill in that BRC drawings of record for installed EPAs had not been revised to reflect resolution of handwritten comments on the drawings pertaining to design acceptability and required rework.

1 TUEC RESPONSE j (1) Admission or Denial of Alleged Violation:

We deny the alleged violation that the vendor documents related to the electrical penetration assemblies (EPAs) were controlled by G8H of fsite in j a manner contrary to the TUGC0 Quality Assurance Program. Those documents  !

were controlled by G&H in accordance with controls in the G&H Project )

Procedures Manual and Project Guide. For all of the examples identified j by the NRC, G&H comments are clearly discernible on the " Office Copy l sepia retained in G&H files and the office copy routing sheet which is i attached to each drawing provides a record of the drawing review and reviewer's signature (s). The Vendor Document Register maintains a record of the vendor drawing transmittal, revision, previous submittals, vendor letter number and date, drawing approval status and G&H transmittal letter i back to the vendor (and concurrently to the field). The Vendor Document index also provides the current status of all drawings; however, voided drawings are not included in this index. We do not believe having vendor drawings in the files with comments on them of the nature of those identified by the NRC is a violation providing there is traceable evidence of review and disposition of the comments.

We admit that the status of vendor drawing files at the site were not maintained current as were the G&H corporate copies of vendor drawings.

Additionally, we admit that TUGC0 failed to resolve one handwritten comment as requested by G&H.

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- 3L A'ttachment'to TXX-6899-

-October 30, 1987-n, Page 2:of 3.

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(2)ReasonforViolation it The NRC review'of~the Bunker Ramo drawings revealed there were thi'r teen. y H 1L . drawings that contained some. type'of handwritten comments. Our subsequent review' revealed that:

60 Nine of those drawings had been voided by the vendor after the

' drawingst had been reviewed and connented upon by.G&H and entered A ' '

< into the document control system. Site personnel failed to notice b that the.nine drawings had been voided by:the vendor and removed ,

from the G&H Vendor Document Index. Had they noticed that fact, they would have removed the voided drawings from the site files.

O Three of the' drawings were subsequently approved af ter the connents were resolved and the change in drawing-status to

" Approved" was accomplished in accordance with a project instruction which required crossing out the previous comment on the. drawing or otherwise noting its deletion, and reissuing.the

. drawing as a "G&H Revision". Comments thus only provided clarification-and the basis for drawing re-status and had no-

-impact.on the technical' content of the. drawing. Site files did

,not clearly indicate the status of these drawings.

0 One drawing contained a comment regarding'a discrepancy with the specification which required resubmittal by the vendor. This open item was noted in the project correspondence r: elative to vendor document closeout by GBH wherein G8H requested TUGC0 to' resolve the. comment. The outstanding comment had no impact on procurement and did not; require any~ rework in the field. Site personnel failed to resolve the connent due to oversight.

The reason for the above vendor drawing issues was the lack of well defined interface' controls between the G&H corporate office and the site to assure vendor drawing files at the site were maintained current.

(3) Corrective Steps Taken and Results Achieved A. review of vendor drawings pertaining to safety related specifications is underway as part of the corrective action for CAR-055. This review assures that any handwritten comments contained in safety related vendor drawings in the active f-iles are properly dispositioned. The review also assures that voided drawings that may still be in the active files are identified, stamped appropriately and removed from the active files. As 1 specified in procedure ECE 5.19 " Review of Vendor Documents," submittals '

of later revisions of vendor documents are reviewed against the previously approved vendor documents, at which time any handwritten comments from the superseded drawings are dispositioned.

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. Attachment to TXX-689,9, M

' q# u October 30, 1987 '

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,f Page 3 of~3 c(j (4) Corrective Steps to Avoid Recurrence L Gibbs.& llill no longer controls vendor documents. The current procedure . 'V for control of vendor docueents is ECE 5.19, " Review of Vendor Documents."

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This. procedure requires that CPE Procurement Engineering receive' vendor j

,. documents and coordinate their review. Based on the results of the vendor '

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% document technical! review, theLdocumcht;is assigned to one of six idifferentcategories; Approved,ApprhvedWithComments,NotApproved,for .

V 3-Information Only, Void, or Superseded. , The document is stamped to i

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indicate the appropriate category sn,that personnel are aware of the '

document's status. When a document is r uised or voided, procedure ECE l 2.13-11 " Document Control Instructions," requires that all controlled  :

copy holders be notified. The h_otper;is notified to either return the 4

drawing or< destroy it. The aperthre card is stamned void or superseded- l 4

and placed in the appropriate cardi!)le. ,

(5) Date When'in Full Compliance  !

January 31, 19d8.

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. Outgoing Correspondence bec (1): '

\ / ,. j M. D. Spence.I

• E. Kerly Y D. W. Stonestreet

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A W. G. Counsil

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R. W.' Ackley J. C. Kuykendall  ; (t ' B. Tartt

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• R. E. McCaskill s 1 J. S. Marshall s

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• J. P. McGaughy

• K. C. Warapius .'

R. L. Cloud J. W. Muffett 1 H. M. Warren (3)

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• fi.H. Williams L. Rietrich L. D. Nace 'D / $ *

'I.G.Woodlan W. S. Eggeling PIMS R. A. Woohdrid%/ i 3* J. Ellis L. E. Powell 4 dJY '

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W. D. Fenoglio R. L. Ramsey ,

R. M. Fillmore J. D. Redding ,e ,

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October 25, 1987

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