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Category:CORRESPONDENCE-LETTERS
MONTHYEARTXX-9924, Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span1999-10-22022 October 1999 Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span ML20217M5711999-10-20020 October 1999 Forwards Insp Repts 50-445/99-15 & 50-446/99-15 on 990822- 1002.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy TXX-9923, Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred1999-10-15015 October 1999 Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred ML20217E7951999-10-12012 October 1999 Forwards COLR for Unit 1,Cycle 8,per TS 5.6.5 ML20212L2891999-10-0101 October 1999 Discusses Closeout of GL 97-06, Degradation of Steam Generator Internals. Purpose of GL Was to Obtain Info That Would Enable NRC to Verify That Condition of Licensee SG Internals Comply with Current Licensing Bases TXX-9922, Forwards Revised COLR, for Cycle 5 for Unit 21999-10-0101 October 1999 Forwards Revised COLR, for Cycle 5 for Unit 2 ML20216J5571999-10-0101 October 1999 Provides Final Response to GL 98-01,suppl 1, Y2K Readiness of Computer Sys at Npps ML20212G0721999-09-24024 September 1999 Forwards Rev 4 to Augmented Inservice Insp Plan for CPSES, Unit 1. Future Changes & Revs to Unit 1 Augmented Inservice Insp Plan Will Be Available on Site ML20212H0461999-09-24024 September 1999 Forwards Rev 6 to CPSES Glen Rose,Tx ASME Section XI ISI Program Plan for 1st Interval on 990820 ML20212F7481999-09-24024 September 1999 Forwards SER Authorizing Relief from Exam Requirement of 1986 Edition ASME Code,Section XI Pursuant to 10CFR50.55a(a)(3)(ii) for Relief Request A-3 & 10CFR50.55a(g)(6)(i) for Relief Requests B15,16,17 & C-4 ML20212F1041999-09-23023 September 1999 Requests That NRC Be Informed of Any Changes in Scope of Y2K System Deficiencies Listed or Util Projected Completion Schedule for Comanche Peak Steam Electric Station,Units 1 & 2 ML20212E6661999-09-21021 September 1999 Advises That Info Contained in Application & Affidavit, (CAW-99-1342) Re WCAP-15009,Rev 0, Comache Peak Unit 1 Evaluation for Tube Vibration Induced Fatigue, Will Be Withheld from Public Disclosure ML20212D9111999-09-16016 September 1999 Informs That on 990818,NRC Completed Midcycle PPR of CPSES & Did Not Identify Any Areas in Which Performance Warranted Insp Beyond Core Insp Program.Core Insp Plan at Facility Over Next 7 Months.Insp Plan Through March 2000 Encl ML20212A7601999-09-14014 September 1999 Forwards Insp Repts 50-445/99-14 & 50-446/99-14 on 990707-0821.Four Violations Occurred & Being Treated as Ncvs.Conduct of Activities Was Generally Characterized by safety-conscious Operations & Sound Radiological Controls TXX-9921, Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC1999-09-10010 September 1999 Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC ML20211P3761999-09-0707 September 1999 Ack Receipt of Ltr Dtd 990615,transmitting Rev 30 to Physical Security Plan,Per 10CFR50.54(p).No NRC Approval Is Required ML20211L9871999-09-0303 September 1999 Forwards Rev 31 to Technical Requirements Manual. All Changes Applicable to Plants Have Been Reviewed Under Util 10CFR50.59 Process & Found Not to Include Any USQs TXX-9915, Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl1999-09-0303 September 1999 Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl ML20211K2231999-08-31031 August 1999 Forwards Txu Electric Comments of Rvid,Version 2 ML20211J3801999-08-27027 August 1999 Forwards Corrected TS Page 3.8-26 to Amend 66 to Licenses NPF-87 & NPF-89,respectively.Footnote on TS Page 3.8-26 Incorrectly Deleted ML20211G7301999-08-26026 August 1999 Forwards Revs 29 & 30 to CPSES Technical Requirements Manual (Trm). Attachments 1 & 2 Contain Description of Changes for Revs 29 & 30 Respectively ML20211G1081999-08-26026 August 1999 Responds to NRR Staff RAI Re Util Mar 1999 Submittal for NRC Review & Approval of Changes to CPSES Emergency Classification Procedure ML20211G3441999-08-25025 August 1999 Forwards Response to NRC RAI on LAR 98-010 for Cpses,Units 1 & 2.Communication Contains No New Licensing Commitments Re Cpses,Units 1 & 2 ML20211B2861999-08-18018 August 1999 Forwards Insp Repts 50-445/99-13 & 50-446/99-13 on 990720- 23.No Violations Noted.Insp Included Implementation of Licensee Emergency Plan & Procedures During Util Biennial Emergency Preparedness Exercise ML20211C4661999-08-18018 August 1999 Discusses Proprietary Info Re Thermo-Lag.NRC Treated Bisco Test Rept 748-105 as Proprietary & Withheld It from Public Disclosure,Iaw 10CFR2.790 ML20210U3981999-08-17017 August 1999 Forwards Monthly Operating Repts for July 1999 for CPSES, Units 1 & 2,per TS 6.9.1.5.No Failures or Challenges to PORVs or SVs for Plant Occurred ML20211C0991999-08-17017 August 1999 Forwards Rev 3 to ASME Section XI ISI Program Plan,Unit 2 - 1st Interval, Replacing Rev 2 in Entirety ML20211C4571999-08-16016 August 1999 Forwards Omitted Subj Page of Contractor TER TXX-9919, Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 9908021999-08-16016 August 1999 Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 990802 ML20210R6561999-08-13013 August 1999 Forwards Response to NRR 990805 Telcon RAI Re License Amend Request 98-010,to Increase Power for Operation of CPSES Unit 2 to 3445 Mwth & Incorporating Addl Changes Into Units 1 & 2 TS ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210S6411999-08-12012 August 1999 Informs That Wg Guldemond,License SOP-43780,is No Longer Performing Licensed Duties.Discontinuation of License Is Requested ML20210R2221999-08-12012 August 1999 Forwards Insp Repts 50-445/99-10 & 50-446/99-10 on 990510-0628.Violations Noted & Being Treated as Ncvs, Consistent with App C of Enforcement Policy ML20210N1101999-08-0404 August 1999 Provides Supplemental Info to Util 990623 License Amend Request 99-005 Re Bypassing DG Trips.Info Replaces Info Contained in Subject Submittal in Attachment 2,Section II, Description of TS Change Request ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210J2301999-08-0202 August 1999 Forwards Amend 96 to CPSES Ufsar.Replacement of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,Rev 2 ML20210J6071999-08-0202 August 1999 Forwards line-by-line Descriptions of Changes in Amend 96 to CPSES UFSAR Transmitted by Util Ltr TXX-99166,dtd 990802. Replacment of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,rev 2 TXX-9916, Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 9907271999-08-0202 August 1999 Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 990727 TXX-9918, Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-9906301999-08-0202 August 1999 Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-990630 ML20210K2321999-07-29029 July 1999 Forwards Insp Repts 50-445/99-12 & 50-446/99-12 on 990530-0710.No Violations Noted ML20210G5861999-07-29029 July 1999 Forwards fitness-for-duty Program Performance Data for Six Month Period of Jan-June 1999 ML20210J0121999-07-27027 July 1999 Forwards Summary of Methodology for Determination of NDE Measurement Uncertainty,In Response to Recent Discussions with NRC Re LAR 98-006 Concerning Rev to SG Tube Plugging Criteria TXX-9917, Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES1999-07-26026 July 1999 Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES ML20210F3121999-07-26026 July 1999 Responds to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, ML20210D8231999-07-23023 July 1999 Forwards Safety Evaluation of Relief Requests Re Use of 1998 Edition of Subsections IWE & Iwl of ASME Code for Containment Insp ML20210D3211999-07-21021 July 1999 Provides List of Estimates of Licensing Actions,In Response to Administrative Ltr 99-02,dtd 990603 ML20210C2931999-07-21021 July 1999 Supplements 880323 Response to NRC Bulletin 88-02, Rapidly Propagating...Sg Tubes, Non-proprietary WCAP-15010 & Proprietary Rev 0 to WCAP-15009, CP Unit 1 Evaluation for Tube Vibration... Encl.Proprietary Rept Withheld ML20209H0111999-07-16016 July 1999 Forwards Relief Request C-4 to CPSES Unit 2 ISI Program for Approval ML20210C3331999-07-16016 July 1999 Forwards Exam Repts 50-445/99-301 & 50-446/99-301 on 990618- 24.Exam Included Evaluation of Six Applicants for Senior Operator Licenses ML20209H2551999-07-16016 July 1999 Forwards ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2 & Containment ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2,per ASME Boiler & Pressure Vessel Code,Section Xi,Paragraph IWA-6230 1999-09-07
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARTXX-9924, Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span1999-10-22022 October 1999 Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span TXX-9923, Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred1999-10-15015 October 1999 Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred ML20217E7951999-10-12012 October 1999 Forwards COLR for Unit 1,Cycle 8,per TS 5.6.5 ML20216J5571999-10-0101 October 1999 Provides Final Response to GL 98-01,suppl 1, Y2K Readiness of Computer Sys at Npps TXX-9922, Forwards Revised COLR, for Cycle 5 for Unit 21999-10-0101 October 1999 Forwards Revised COLR, for Cycle 5 for Unit 2 ML20212G0721999-09-24024 September 1999 Forwards Rev 4 to Augmented Inservice Insp Plan for CPSES, Unit 1. Future Changes & Revs to Unit 1 Augmented Inservice Insp Plan Will Be Available on Site ML20212H0461999-09-24024 September 1999 Forwards Rev 6 to CPSES Glen Rose,Tx ASME Section XI ISI Program Plan for 1st Interval on 990820 TXX-9921, Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC1999-09-10010 September 1999 Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC ML20211L9871999-09-0303 September 1999 Forwards Rev 31 to Technical Requirements Manual. All Changes Applicable to Plants Have Been Reviewed Under Util 10CFR50.59 Process & Found Not to Include Any USQs TXX-9915, Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl1999-09-0303 September 1999 Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl ML20211K2231999-08-31031 August 1999 Forwards Txu Electric Comments of Rvid,Version 2 ML20211G1081999-08-26026 August 1999 Responds to NRR Staff RAI Re Util Mar 1999 Submittal for NRC Review & Approval of Changes to CPSES Emergency Classification Procedure ML20211G7301999-08-26026 August 1999 Forwards Revs 29 & 30 to CPSES Technical Requirements Manual (Trm). Attachments 1 & 2 Contain Description of Changes for Revs 29 & 30 Respectively ML20211G3441999-08-25025 August 1999 Forwards Response to NRC RAI on LAR 98-010 for Cpses,Units 1 & 2.Communication Contains No New Licensing Commitments Re Cpses,Units 1 & 2 ML20210U3981999-08-17017 August 1999 Forwards Monthly Operating Repts for July 1999 for CPSES, Units 1 & 2,per TS 6.9.1.5.No Failures or Challenges to PORVs or SVs for Plant Occurred ML20211C0991999-08-17017 August 1999 Forwards Rev 3 to ASME Section XI ISI Program Plan,Unit 2 - 1st Interval, Replacing Rev 2 in Entirety TXX-9919, Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 9908021999-08-16016 August 1999 Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 990802 ML20210R6561999-08-13013 August 1999 Forwards Response to NRR 990805 Telcon RAI Re License Amend Request 98-010,to Increase Power for Operation of CPSES Unit 2 to 3445 Mwth & Incorporating Addl Changes Into Units 1 & 2 TS ML20210S6411999-08-12012 August 1999 Informs That Wg Guldemond,License SOP-43780,is No Longer Performing Licensed Duties.Discontinuation of License Is Requested ML20210N1101999-08-0404 August 1999 Provides Supplemental Info to Util 990623 License Amend Request 99-005 Re Bypassing DG Trips.Info Replaces Info Contained in Subject Submittal in Attachment 2,Section II, Description of TS Change Request TXX-9918, Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-9906301999-08-0202 August 1999 Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-990630 ML20210J2301999-08-0202 August 1999 Forwards Amend 96 to CPSES Ufsar.Replacement of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,Rev 2 ML20210J6071999-08-0202 August 1999 Forwards line-by-line Descriptions of Changes in Amend 96 to CPSES UFSAR Transmitted by Util Ltr TXX-99166,dtd 990802. Replacment of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,rev 2 TXX-9916, Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 9907271999-08-0202 August 1999 Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 990727 ML20210G5861999-07-29029 July 1999 Forwards fitness-for-duty Program Performance Data for Six Month Period of Jan-June 1999 ML20210J0121999-07-27027 July 1999 Forwards Summary of Methodology for Determination of NDE Measurement Uncertainty,In Response to Recent Discussions with NRC Re LAR 98-006 Concerning Rev to SG Tube Plugging Criteria TXX-9917, Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES1999-07-26026 July 1999 Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES ML20210F3121999-07-26026 July 1999 Responds to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, ML20210C2931999-07-21021 July 1999 Supplements 880323 Response to NRC Bulletin 88-02, Rapidly Propagating...Sg Tubes, Non-proprietary WCAP-15010 & Proprietary Rev 0 to WCAP-15009, CP Unit 1 Evaluation for Tube Vibration... Encl.Proprietary Rept Withheld ML20210D3211999-07-21021 July 1999 Provides List of Estimates of Licensing Actions,In Response to Administrative Ltr 99-02,dtd 990603 ML20209H2551999-07-16016 July 1999 Forwards ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2 & Containment ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2,per ASME Boiler & Pressure Vessel Code,Section Xi,Paragraph IWA-6230 ML20209H0111999-07-16016 July 1999 Forwards Relief Request C-4 to CPSES Unit 2 ISI Program for Approval ML20209G0721999-07-13013 July 1999 Forwards Monthly Operating Repts for June 1999 for CPSES, Units 1 & 2,per TS 6.9.1.5.No Failures or Challenges to PORVs of SV Occurred During Reporting Period ML20209F0681999-07-0909 July 1999 Informs That Effective 990514,TU Electric Formally Changed Name to Txu Electric.Change All Refs of TU Electric to Txu Electric on Correspondence Distribution Lists ML20209E0421999-07-0909 July 1999 Forwards Response to NRC Request for Addl Info on LAR 98-010.Attachment 1 Is Affidavit for Info Supporting LAR 98-010 ML20209B6021999-06-30030 June 1999 Submits Second Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Readiness Disclosure for Reporting Status of Facility Y2K Readiness Encl ML20195J6981999-06-15015 June 1999 Provides Addl Info Related to Open Issue,Discussed in 990610 Conference Call with D Jaffe Re ISI Program Relief Request L-1 Submitted by Util on 980220 ML20196A4921999-06-15015 June 1999 Forwards Rev 30 to Physical Security Plan.Rev Withheld,Per 10CFR73.21 ML20195J0491999-06-14014 June 1999 Submits Response to RAI Re Implementation of 1.0 Volt Repair Criteria ML20195J0651999-06-14014 June 1999 Submits Response to RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety Related Power Operated Gate Valves 05000445/LER-1999-001, Forwards LER 99-001-00, Some Electrical Contacts for RCS Pressure Relief Valves Were Not Included in Surveillance Testing Procedures. New Licensing Commitments Identified in Attachment 11999-06-0808 June 1999 Forwards LER 99-001-00, Some Electrical Contacts for RCS Pressure Relief Valves Were Not Included in Surveillance Testing Procedures. New Licensing Commitments Identified in Attachment 1 ML20195F0091999-06-0808 June 1999 Forwards Response to RAI Re Units 1 & 2 ISI Program for Relief Requests E-1 & L-1.Communication Contains No New Licensing Basis Commitments Re Cpses,Units 1 & 2 ML20207E1921999-05-28028 May 1999 Submits Updated Request for NRC Staff to Review & Approve Certain Changes to CPSES Emergency Plan Submitted in 981015 & s Prior to Changes Being Implemented at CPSES ML20207E1711999-05-28028 May 1999 Supplements 990526 LAR 99-004 as TU Electric Believes Extingency Exists in That Proposed Amend Was Result of NOED Granted to Prevent Shudown of CPSES Unit 1 ML20207D9841999-05-26026 May 1999 Requests That NRC Exercise Enforcement Discretion to Allow Cpses,Unit 1 to Remain in Mode 1,power Operation,Without Having Performed Svc Test,Per SR 4.8.2.1d on Unit 1 Battery BT1ED2 ML20195B6351999-05-25025 May 1999 Submits Response to RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety Related Power Operated Gate Valves TXX-9912, Forwards Txu Electric (Formerly TU Electric) CPSES Emergency Preparedness Exercise Scenario Manual for 990721-22,Graded Exercise1999-05-21021 May 1999 Forwards Txu Electric (Formerly TU Electric) CPSES Emergency Preparedness Exercise Scenario Manual for 990721-22,Graded Exercise ML20206U1981999-05-20020 May 1999 Forwards Form 10K Annual Rept,Per 10CFR50.71(b). Communication Contains No New Licensing Basis Commitments Re Cpses,Units 1 & 2 ML20196L1931999-05-20020 May 1999 Forwards MOR for Apr 1999 for Cpses,Units 1 & 2.During Reporting Period There Have Been No Failures or Challenges to Power Operated Relief Valves or Safety Valves TXX-9911, Forwards non-proprietary & Proprietary Responses to RAI Re LAR 98-010 by Incorporating Attached Changes Into CPSES Unit 2 OL NPF-89 & CPSES Units 1,OL NPF-87 & 2 TS to Increase Licensed Power.W & Caldon Proprietary Responses Withheld1999-05-14014 May 1999 Forwards non-proprietary & Proprietary Responses to RAI Re LAR 98-010 by Incorporating Attached Changes Into CPSES Unit 2 OL NPF-89 & CPSES Units 1,OL NPF-87 & 2 TS to Increase Licensed Power.W & Caldon Proprietary Responses Withheld 1999-09-03
[Table view] Category:UTILITY TO NRC
MONTHYEARML20059K6141990-09-17017 September 1990 Submits Documentation of 900906 Telcon Re Addl Util Candidate for Licensed Operator Generic Fundamentals Exam Section ML20059G8761990-09-10010 September 1990 Forwards Rev 8 to Physical Security Plan.Rev Withheld (Ref 10CFR73.21) ML20059F8461990-09-0404 September 1990 Responds to NRC Re Violations Noted in Insp Repts 50-445/90-22 & 50-446/90-22 on 900606-0705.Corrective action:OPT-467A Changed to Provide Addl Prerequisite Info Re Solid State Protection Sys Switch Lineup During Testing ML20059E4981990-08-31031 August 1990 Forwards Revised Radial Peaking Factor Limit Rept for Cycle 1 Per Tech Specs Through Amend 1 & ML20059E4201990-08-30030 August 1990 Forwards Objectives & Guidelines for 1990 Emergency Preparedness Exercise Scheduled for 901113 ML20028G8281990-08-29029 August 1990 Forwards Comanche Peak Unit 1 Semiannual Radioactive Effluent Release Rept,900403-0630 & ODCM TXX-9030, Forwards Endorsements 40 & 4 to Nelia Policy NF-274 & Maelu Policy M-90,respectively & Endorsements 10,11,12,13,14 & 15 to Maelu Policy MF-1311990-08-27027 August 1990 Forwards Endorsements 40 & 4 to Nelia Policy NF-274 & Maelu Policy M-90,respectively & Endorsements 10,11,12,13,14 & 15 to Maelu Policy MF-131 ML20059F4381990-08-23023 August 1990 Forwards Public Version of Revised Emergency Plan & Corporate Emergency Response Procedures,Consisting of Rev 1 to EPP-313,Rev 7 to CERP-101,Rev 7 to CERP-102 & Revised Forms.W/Dh Grimsley 900906 Release Memo TXX-9029, Responds to NRC Re Violations Noted in Insp Repts 50-445/89-57 & 50-446/89-57.Corrective Actions:Storage Facilities for Instrumentation & Control Work Packages Improved to Provide Acceptable Protection for Documents1990-08-20020 August 1990 Responds to NRC Re Violations Noted in Insp Repts 50-445/89-57 & 50-446/89-57.Corrective Actions:Storage Facilities for Instrumentation & Control Work Packages Improved to Provide Acceptable Protection for Documents ML20058P0571990-08-13013 August 1990 Forwards, Comanche Peak Steam Electric Station Unit 1 Control Room Simulator 10CFR55 Certification Initial Rept ML20058N2311990-08-0909 August 1990 Forwards First Half 1990 fitness-for-duty Program Performance Data,Per 10CFR26.71(d).Point of Contact for Personnel,Random Testing Program Results & Confirmed Positive Tests Summary & Mgt Summary Included in Data ML20059A5831990-08-0404 August 1990 Responds to Info Request Made During 900802 Meeting Re Inadvertent Safety Injections on 900726 & 30 & Results of 100% Power Plateau Testing TXX-9024, Provides Status of Exam Activity & Revised Completion Schedule for Portion of Exam.Util Deferred Preoperational Testing of Facility Spent Fuel Pool Cooling & Cleanup Sys Until Prior to First Off Loading of Spent Fuel1990-08-0303 August 1990 Provides Status of Exam Activity & Revised Completion Schedule for Portion of Exam.Util Deferred Preoperational Testing of Facility Spent Fuel Pool Cooling & Cleanup Sys Until Prior to First Off Loading of Spent Fuel TXX-9022, Forwards Detailed Descriptions of Changes in Amend 79 to FSAR for Comanche Peak Steam Electric Station1990-07-31031 July 1990 Forwards Detailed Descriptions of Changes in Amend 79 to FSAR for Comanche Peak Steam Electric Station TXX-9027, Responds to NRC Re Violations Noted in Insp Repts 50-445/90-19 & 50-446/90-19.Corrective Action:Specific Activity within Tech Spec Limits.No Further Corrective Action Required1990-07-30030 July 1990 Responds to NRC Re Violations Noted in Insp Repts 50-445/90-19 & 50-446/90-19.Corrective Action:Specific Activity within Tech Spec Limits.No Further Corrective Action Required ML20055J1571990-07-27027 July 1990 Submits Info Re Replacement of Borg-Warner/Intl Pump,Inc Check Valve Swing Arms,Per .Swing Arms in ASME Code Class 2 Check Valves Will Be Replaced During First Refueling Outage ML20056A0461990-07-24024 July 1990 Requests Regional Waiver of Compliance for Containment Pressure Transmitter 1-PT-934 During Coming Outage TXX-9023, Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. No Subj Transmitters in Existence at Facility1990-07-18018 July 1990 Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. No Subj Transmitters in Existence at Facility ML20055G6351990-07-17017 July 1990 Submits Results of Remote Shutdown Panel Environ Survey ML20055F9391990-07-13013 July 1990 Advises That Operators Have Gained Significant Experience in Operating Plant Under Wide Range of Conditions & Have Demonstrated Necessary Proficiency to Safely Operate Unit ML20055F9371990-07-13013 July 1990 Submits Info Re Revised Acceptance Criteria for THERMO-LAG Fire Barrier,Per 900705 Telcon.On Exposure to Heat Flux at Surface of Barrier,Listed Mechanisms Activated.Fire Testing Demonstrates That Panels Qualified W/Variation in Thickness ML20044A7001990-06-26026 June 1990 Responds to Generic Ltr 90-04, Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements or Corrective Actions. Util Will Implement for Unit 2 Activities Performed for Unit 1 ML20044A1411990-06-20020 June 1990 Forwards Endorsements 4 & 5 to Nelia Certificate N-90, Endorsements 5 & 6 to Maelu Certificate M-90 & Endorsements 34,35,36,37,38 & 39 to Nelia Policy NF-274 ML20043H7031990-06-18018 June 1990 Discusses Mod/Rework to Auxiliary Feedwater Sys Check Valves Mfg by Bw/Ip Intl,Inc.All But One Affected Check Valve modified.Motor-driven Auxiliary Feedwater Pump Discharge Valve Check Valve Body Replaced ML20043H2181990-06-15015 June 1990 Forwards Response to 900515 Request for Addl Info on Emergency Preparedness.Ongoing Emergency Preparedness Programs Address Concerns Raised by Citizens for Fair Util Regulation ML20043G3131990-06-15015 June 1990 Forwards Addl Info Re Pressurizer Surge Line Thermal Stratification & leak-before-break Evaluation & Nonproprietary Suppl 3 to WCAP-12247, Supplementary Assessment... & Proprietary Suppl 3 to WCAP-12248 ML20043C5671990-06-0101 June 1990 Discusses Identification of Slave Relays Tested Using Alternative Methodology,Per 900402 Commitment.Encl Tabulation Identifies Test Type,Applicable Procedures & Equipment & Impact of Improper Documentation ML20043E7131990-06-0101 June 1990 Responds to NRC 900517 Notice of Violation & Imposition of Civil Penalty in Amount of $25,000.Corrective Action:Qc Mgt Counseled Level III Inspector & QC Supervisor on Importance of Good Communications W/Receipt Inspectors ML20043C4501990-05-31031 May 1990 Advises That Util Revised FSAR Section 15.1.2 & Question/ Response 32.108,per 10CFR50.59 ML20043B5471990-05-25025 May 1990 Provides Status of Facility Design & Const Activities,Per Request.Detailed Design Work Will Resume in June 1990.Const Activities Expected to Increase Signficantly by Jan 1991 ML20043B5481990-05-23023 May 1990 Provides Clarification of 890710 Commitment Re Power Ascension Program.Cooldown Portion of Remote Shutdown Test Performed During Preoperational Testing,Per FSAR & Reg Guide 1.68.2 ML20043D1711990-05-21021 May 1990 Forwards Public Version of Revised Emergency Plan Procedures,Including Rev 8 to EPP-109,Rev 7 to EPP-112,Rev 4 to EPP-116 & Rev 6 to EPP-121.W/DH Grimsley 900604 Release Memo TXX-9018, Advises of Completion of Implementation of Requirements of Generic Ltr 89-13, Svc Water Sys Problems Affecting Safety- Related Equipment1990-05-21021 May 1990 Advises of Completion of Implementation of Requirements of Generic Ltr 89-13, Svc Water Sys Problems Affecting Safety- Related Equipment ML20043B0981990-05-15015 May 1990 Forwards Radial Peaking Factor Limit Rept for Cycle 1, Containing F(Xy) Limits for All Core Planes Containing Bank D Control Rods & All Unrodded Core Planes ML20042F2851990-05-0303 May 1990 Supplemental Response to Generic Ltr 90-01, Request for Voluntary Participation in NRC Regulatory Impact Survey. ML20042F3861990-05-0303 May 1990 Responds to NRC 900410 Ltr Re Violations Noted in Insp Repts 50-445/90-10 & 50-446/90-10 on 900206-07 & 0226-0302. Corrective Action:Memo Issued Emphasizing That Discrepancies Should Be Brought to Attention of Site Organizations ML20042F3021990-05-0202 May 1990 Responds to NRC 900402 Ltr Re Violations Noted in Insp Repts 50-445/89-23 & 50-446/89-23.Util Does Not Believe That Circumstances Described in 900402 Ltr Constitutes Violation of 10CFR50.9(a) ML20042F3051990-05-0202 May 1990 Provides Revised Response to Generic Ltr 88-17 Re Loss of DHR ML20042E4581990-04-12012 April 1990 Responds to Inconsistencies in Terminology & Labelling Identified During NRC 890118 & 19 Audit of Facility Dcrdr. Util Believes Control Room Inventory Requirement of Suppl 1 to NUREG-0737,satisfied ML20042E0701990-04-10010 April 1990 Discusses 900305 Meeting W/Nrc in Rockville,Md Re Offsite Power Availability for Automatic Switch Co Solenoids for MSIV in Event of Nonmechanistic Main Steam Line Crack in Superpipe Region ML20012F5011990-04-0303 April 1990 Forwards Corrections to 891016 Response to Emergency Diesel Generator Engine Requirements.Lengths of Two Pairs of Bolts Above Crankpin Shall Be Measured Ultrasonically Before Detensioning & Disassembly of Bolts ML20012F3221990-04-0202 April 1990 Discusses ESF Sys Slave Relay Alternate Test Methodology. Implementation Schedule for Design Mods to Relay Will Be Submitted by 900601 ML20042D8081990-03-29029 March 1990 Forwards Proposed Change to FSAR Section 13.4 Re Station Operations Review Committee.Similar Change Submitted in 900328 Ltr for Chapter 6 of Facility Tech Specs ML20012F0411990-03-28028 March 1990 Forwards marked-up Pages of Facility Draft Tech Specs & Bases (NUREG-1381) Provided W/Low Power OL ML20012E6051990-03-27027 March 1990 Forwards Endorsements 1-4 to Maelu Certificate M-90, Endorsements 1-9 to Maelu Policy MF-131,Endorsements 29-33 to Nelia Policy NF-274 & Endorsements 1-3 to Nelia Certificate N-90 ML20012E6531990-03-27027 March 1990 Provides Final Response to Reporting Requirement 2 of NRC Bulletin 88-008, Thermal Stresses in Piping Connected to RCS, for Unit.Nde Requirements of Action 2 Not Considered Applicable to Unit ML20012E1911990-03-23023 March 1990 Forwards Comanche Peak Steam Electric Station Unit 1 Cycle 1 Startup Physics Tests Control Rod Worth Predictions Utilizing TU Electric Control Rod Swap Methodology. ML20012E1581990-03-23023 March 1990 Clarifies 880624 Response to NRC Generic Ltr 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants. ML20012D0201990-03-19019 March 1990 Advises That Allegations Provided to NRC by Former Util Employee Unsubstantiated,Based on Investigation by Util Safeteam Organization ML20012E2181990-03-19019 March 1990 Responds to Generic Ltr 89-19 Re USI A-47, Safety Implication of Control Sys in LWR Nuclear Power Plants. Util Determined That Loss of safety-related Inverters 1 or 2 Would Involve Coincidental Opening of Main Feedwater Valves 1990-09-04
[Table view] |
Text
. 8 Log # TXX-5048 File # 10130 TEXAS UTILITIES GENERATING COMPANY IR 86-01
.KYWAY TOWER . m NORTH OWVE STREET, t.B. 88
- DMMS, TEXAMMS 86-01 October 13, 1986
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Mr. Eric H. Johnson Director i OCT I 41986 !
Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission - '
S 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION AND NOTICE OF DEVIATION INSPECTION REPORT NOS.: 50-445/86-01 AND 50-446/86-01
Dear Mr. Johnson:
We have reviewed your letter dated August 29, 1986, concerning the inspection conducted by Mr. T.F. Westerman and other members of the Region IV Comanche Peak Group during the period November 1, 1985, through January 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 was a Notice of Violation and Notice of Deviation.
We requested and received a two week extension in providing our response during a telephone conversation on September 29, 1986.
We hereby respond to the Notice of Violation and Notice of Deviation in the attachment to this letter.
Very truly yours,
$50 5 / '?7D W. G. Counsil RSB/gj Attachments c-Region IV (Original + 1 Copy)
Director, Inspection & Enforcement (15 copies *)
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. V.S. Noonan Mr. D.L. Kelley 1
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Attachment to TXX-5048 ' .
., Page 1 October 13, 1986 -
' ~~
NOTICE DE VIOLATI0fl .
ITEMS a.1 THROUGH a.1 (445/86Q1-Y-11 AN.D 446/8601-1-01)
A. Criterion XV of Appendix B to 10 CFR Part 50 requires thatineasures be established to prevent the inadvertent use of nonconforming items, and that these measures include procedures for identification, documentation, l segregation, disposition, and notification to affected organizations. It !
further requires that nonconforming items be reviewed and accepted, '
rejected, repaired, o. reworked in accordance with documented procedures.
Section 15.0 of Revision 5 to the TUGCo Quality Assurance Plan (QAP) states, in part, "The identification, documentation, segregation, and disposition of norconforming materials, parts, or corrponents is outlined in written procedures...." A nonconformance report is used to document deficiencies unless another method is prescribed by a spectfic. _ .
procedure / instruction. Nonconformance reports , . . are made available to TUGCo for evaluation ....(and) TUGCo QA assures that periodic evaluations of these reports are forwarded to TUGCo management identifying trends-adverse to quality." -
Section 3.9 of Revision 3 to the TUGCo Operations Administrative Control and Quality Assurance Plan states, in part, " Material, parts and ,
components which are determined to be nonconforming, shall be identified -
and reported. Nonconformance reports shall be prepared which identify and describe the nonconformance, the disposition of the nonconformance, and the . . . acceptability of the item after the disposition has been completed . . . ."
Contrary to the above, established procedures for handling of ,_
nonconforming materials, parts, or components were not effectively implemented as evidenced by the following observed conditions: ,
- 1. Deviation Reports (DRs) generated by ERC to document nonconforraing conditions did not, in all cases, result in the initiation of nonconformance reports (NCRs) by the TUGCo QA/QC Coordinator as required by Revision 1 to Procedure CP-QP-16.3 dated August 28, 1985.
- 2. The TUGC0 QA/QC Coordinator failed to initiate NCRs as required by Revision 1 to Procedure CP-QP-16.3 dated August 28, 1985, for numerous ERC identified out-of-scope observations which were subsequently repaired or reworked.
- 3. Nonconforming items identified by the TUGCo QC Inspection Process Control Group, and subsequently reworked and repaired, were not documented on NCRs as required by Revision 9 of Procedure STA-405 dated November 11, 1985, but rather on three-part office memos.
- 4. A large number of nonconforming items have not been physically identified with signs, barriers, or hold tags as required by Revision 25 of Procedure CP-QAP-16.1 dated August 17, 1985.
Attachment to TXX-5048 Page 2 October 13, 1986 NOTICE QE VIOLATION ITEMS A.1 THROUGH A.1 (445/ alm-Y-12 AND 446/ alm-Y-M)-CONT'D
- 5. Deficiency Notifications (DNs), as required by Revision 4 of Procedure N61-1 dated December 10, 1985, are to be used only for documenting deficient conditions identified during repair or replacement of mechanical components previously accepted by _TUGCo. However, numerous instances have been identified where DNs have also been used to improperly document nonconformances and effect the ismance of work requests and work orders.
- 6. Failure to initiate required NCRs impacts on the validity of the monthly trend analysis report required by Revision 1 of Procedure QI-QP-17.0-1. The report is required to contain potentially adverse trends, which are based on the number of NCRs issued during the report period.
RESPONSE IQ ITEMS a.1 THROUGH 8.1
- 1. Reason for Violation Item 1 - The requirements of CP-QP-16.3 were not implemented for DRs generated when the component identified fell under the scope of ASME Section XI program.
Item 2 - CP-QP-16.3 R1 required an evaluation to be done on out-of-scope observations to determine whether they warrant the issuance of an NCR.
There have been instances where the evaluation did not require the issuance of an NCR when in fact an NCR should have been issued.
Item 3 - TUGC0 QC Inspection Process Control Group, used IPC-3 which did not require that an NCR be issued when the inspectors noted a deficiency that was out-of-scope from the inspector's checklist. Instead, 3-part memos were used to notify personnel of deficiencies in order to effect l corrections.
(
Item 4 - We do not agree with the alleged violation because QP-QAP-16.1 R25 did not require the application of a hold tag in all cases. The items were being controlled since whether or not hold tags were placed on the items, further processing of the items was controlled through work package holds. However, a revision to CP-QAP-16.1 has been made which now requires the placing of hold tags on nonconforming items where practicable regardless of the stage of component processing. If a hold tag is not placed, the initiator must provide a brief justification on the NCR.
Item 5 - This violation resulted from deviating from the requirements contained within N61-1' dated 12/10/85. In several instances, DRs were i
received from ERC (that were associated with the N61-1 program) and TUGCo incorrectly used DNs to process these DRs.
y Attachment to TXX-5048 Page 3 October 13, 1986 RESPONSE TQ _LTJMS. A.1 THROUGH A.6 CONT'Q Item 6 - We disagree with this violation. Quality Instruction QI-QP-17.0-1 " Preparation and Distribution of Trend Reports" contains criteria for the identification of Potential Adverse Trends (PAT) during the monthly NCR trend results. evaluation. Since.the objective of the Trend Program is the timely identification of activities which may require corrective action, NCRs initiated per CP-QP-16.3 " Processing CPRT Deviation Reports /Out of Scope Observations" are excluded from the Trend '
Program due to the inability to clearly identify current program weaknesses based on analysis of deficiencies not related to present conditions or requirements. 'In order to clearly exclude these NCRs from trending, these NCR numbers are suffixed with an "X" and do not have a specific Trend Code applied. Trend Reports provided for management review therefore contain evaluation results pertinent to ongoing construction and inspection / testing activities.
The CPRT Program Plan describes methods used by CPRT to develop, approve and document corrective action for deviatior.s or deficiencies identified by CPRT. Methods used include identification of adverse trends through the evaluation of related observations and/or deviations. For these items, CPRT provides reports of adverse trends or areas requiring TUGCo management review and action as appropriate.
- 2. Corrective Action Taken Item 1 - A review of DRs received.was conducted and NCRs were issued for all DRs not previously documented on NCRs.
Item 2 .CP-QP-16.3 R2 now requires that all out-of-scope observations be documented on NCRs regardless of the described condition. All out-of-scope observations have been reviewed to determine if NCRs were issued for them. NCR0 have now been issued for all out-of-scope observations.
Item 3-- NCR E-86-200637 R3 was generated to disposition all items listed on the 3-part memos.
Item 5 - Per CP-QP-16.3 R2, DNs may no longer be used to process DRs.
NCRs are used te-document deficiencies regardless of the stage of component processing. All previous DRs have been addressed as noted in Item 1 above.
Attachment to TXX-5048 Page 4 October 13, 1986 RESPONSE IQ ITEMS A.1 THROUGH 8 6 CONT'D
- 3. Action tg Prevent Recurrence Item 1 - CP-QP-16.3 Rev. 3 was revised to delete the reference to N61.1.
This revision unequivocally requires that all DRs received be documented in accordance with CP-QP-16.0 "Nonconformances" or CP-QAP-16.1 " Control of Nonconforming Items".
Items 2 - Same as corrective action noted above.
Item 3 - The Inspection Process Control Program was replaced by the Inspection Surveillance Program, which requires NCRs to be generated on all deficiencies noted.
Item 5 - Same as corrective action noted above.
- 4. Raig ,qf Full Comoliance:
Item 1 - CPSES is currently in full compliance.
Items 2 - CPSES is currently in compliance with CP-QP-16.3.
Item 3 - CPSES is currently in compliance with the Inspection Surveillance Program.
Item 5 -~CPSES is currently in compliance with the CP-QP-16.3.
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Attachment to TXX-5048 Page 5 October 13, 198:
NOTICE OE VIOLATION JJEM B (445/8601-V-14 AND 446/8601-V-04)
B. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 QAP, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Paragraph 6.15.1(t) of Gibbs and Hill Electrical Erection Specification 2323-ES-100, Revision 2, dated October 15, 1980, requires: (1) that field tests shall be performed by the Contractor on all cable reels in accordance with the manufacturer's recommendations, and (2) that the owner will witness these tests.
Contrary to the above, the specified field tests of cable reels were neither prescribed by implementing procedures nor performed.
RESPONSE J_Q JTEM B It is our opinion that the conditions described in this Notice of Violation item are not a violation. None of the manufacturers that have supplied cable reels to CPSES have recommended that any field tests be run on cable reels.
CPSES procurement documents invoke and reference all applicable specifications and/or testing which is required of our manufacturers. The required certification / documentation is transferred to CPSES with the shipment of cable and is reviewed for acceptability by receiving inspection and quality control. Site procedures invoke additional acceptance testing of the individual conductors and cables after installation. These tests are more stringent than testing in the bulk reel form.
The requirements in paragraph 6.15.1(t) of electrical erection specification 2323-ES-100 are meaningless because no cable reel field tests have been recommended and are redundant because.all necessary testing is already being accomplished by the manufacturer.
In order to eliminate this redundancy in the specification, the paragraph in question was removed from the specification by design change DCA-24088 issued January 24, 1986.
Attachment to TXX-5048 Page 6 ;
October 13, 1986 NOTICE QF DEVIATION IT_EM A (445/8601-D-Q4)-
A. FSAR Section 10.4.9.1 states that the Auxiliary Feedwater (AFW) System is capable of supplying the minimum required flow to at least two steam generators against a back pressure equivalent to the accumulation pressure of the lowest set main steam safety valve plus the system frictional and
~
static losses.
FSAR Table 14.2-2, Sheet 51, Test Method No. 3 commits the applicant to verify through preoperational testing that the hydraulic performance of each AFW pump meets design requirements and is within limits assumed in the appropriate accident analysis.
In deviation from' the above, preoperational tests ICP-PT-37-01, " Auxiliary Feedwater System (Motor Driven Pumps)," and ICP-PT-37-03, " Auxiliary Feedwater System (Turbine Driven Pumps)," failed to test the AFW pumps against a back pressure determined using main steam safety valve accumulation pressure, but instead incorrectly used the safety valve set pressure. This amounts to a less conservative 36 psi reduction in the back-pressure during this test. Consequently, the pump capacity data recorded in the above completed test packages are incorrect for the maximum back pressure test.
RESPONSE TQ JJTJ_M A CPSES Engineering is still evaluating the Notice of Deviation, the tests and requirements for the Auxiliary Feedwater Purrps. We intend to provide a complete response by November 3, 1986.
Attachment to TXX-5048 Page 7 October 13, 1986 NOTICE 0E DEVIATION JTEM B.1 (445/8601-D-ll)
- 8. Section 4 of Revision 3 to CPRT Procedure CPP-009 states, in part,
" Qualified QA/QC Review Team personnel perform field inspections of-specific hardware items and reviews of appropriate documents in accordance with approved instructions ..."
In deviation from the above, the following example was noted where field reinspections were not performed in accordance with approved instructions:
- 1. Attribute 1.f in Section 5.2.6.2 of Quality Instruction (QI) QI-025, Revision 1, which states, in part, "All lines with operating temperatures below 2000F may be installed with a minimum of one inch clearance, including insulation, with respect to other piping," was signed off as acceptable by the.ERC inspector for Verification Package No. I-M-LBC0-038.
However, independent inspection showed an existing clearance of 0.75 inch between spool piece 2Q2 of drawing BRP-CS-1-SB-060 and the inspected line
, at a point 12~ inches above sleeve 3.
RESPONSE TQ IIEM B.1
~
- 1. Reason for Deviation ERC investigation confirmed the stated condition. A 0.75-inch clearance existed between spool piece No. 2Q2 on Drawing BRP-CS-SB-060 at a point 12 inches above sleeve No. 3 on the inspected line. The ERC inspector accepted this attribute when in fact a minimum 1-inch clearance was required.
- 2. Correctivq Action Taken 1
Deviation Report (DR) number I-M-LBCO-038-DR-1 was prepared on March 18, 1986, to document the existence of the pipe to pipe insulation clearance
, of 0.75-inch. Nonconformance Report (NCR) number M-25226N was generated as a result of the DR to disposition the above condition.
I
- 3. Action to Prevent Recurrenge In cases where inspector error was evident, the inspector and the lead i inspector or population engineer discussed specifics to determine why the error occurred. Actions.taken to address the error and preclude recurrence typically included one or more of the following, as neces::ary:
0 Documented retraining of the inspector (s) to the pertinent Quality
- Instruction (s),
O Clarification or revision of the Quality Instruction.
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.
m
' Attachment t'o TXX-5048 Page 8 October 13, 1986 RESPONSE IQ IIfM H.1 [QNI'Q An Overview Inspection Program was implemented to reinspect a sample of each Inspector's work. Action is ongoing to analyze the results of the Overview Inspection Program, which includes pertinent inspector error data
! from other sources (i.e., NRCl inspections, etc.).
- 4. Dala af Egil Comoliance i
Corrective action will be completed commensurate with the final disposition of~nonconformance report M-25226N. Results of the Overview Inspection Program are scheduled to be completed by October 31, 1986.
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Attachment to TXX-5048 Page 9 October 13, 1986 NOTICE DE DEVIATION JTEM B.2 (445/8601-D-2Q)
B. Section 4 of Revision 3 to CPRT Procedure CPP-009 states, in part,
" Qualified QA/QC Review Team personnel perform field inspections of specific hardware. items and reviews of appropriate documents in accordance with approved instructions ..."
In deviation from the above, the following example was noted where field reinspections were not performed-in accordance with approved instructions:
- 2. Attribute 1.f in Section 5.2.6.3 of QI-025, Revision 1, which requires that all lines with operating temperatures less than 2000F be installed such that an. air gap exists between the pipe, or pipe insulation, and other objects, was signed off as acceptable by the ERC inspector for Verification Package No. I-M-LBC0-144. However, independent inspection identified a portion of a pipe support in contact with the insulation of the inspected line at approximately 14 feet south of the 760 bend in the package.
RESPONSE TQ JTEM H.2
- 1. Reason For Deviation ERC investigation confirmed the trapeze hanger is touching the insulation on the inspected line. The ERC Inspector did not note this condition at the time of his original inspection.
- 2. Corrective Action Taken Deviation Report (DR) number I-M-LBC0-144-DR-3 was prepared on March 14, 1986, to document the clearance deviation. Based in part on this DR, Nonconformance Report (NCR) number M-23475N R-1 was generated to disposition this condition.
- 3. Action to Prevent Recurrence In cases where inspe.ctor error was evident, the inspector and the lead inspector or population engineer discussed specifics to determine why the error ocurred. Actions taken to address the error and preclude recurrence typically included one or more of the following, as necessary:
0 Documented retraining of the inspector (s) to the pertinent Quality Instruction (s),
O Clarification or revision of the Quality Instruction.
At the discretion of the lead inspector, formal and informal group meetings were held to discuss inspectors error on a generic basis. These discussions allowed appropriate information to be disseminated to various cognizant ERC inspectors.
An Overview Inspection Program was implemented to reinspect a sample of each Inspector's work. Action is ongoing to analyze the results of the Overview Inspection Program which includes pertinent inspector error data from other sources (i.e., NRC inspections, etc.).
__ _ _ _ _ _ - - - - _ _ _ _ _ _ _ _ _ J
Attachment to TXX-5048 Page 10-October 13, 1986 RESPONSE TQ IT1H H.2 - CONT'Q
- 4. Qitta gf Full Comoliance Corrective action will be completed coincident with final disposition of NCR M-23475N R-1. Results of the Overview Inspection Program are scheduled to be completed by October 31, 1986.
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,- -- , , . - ---.,.c ,,- - - - - - - . . - _ - -.- . --- . - , - -
Attachment to TXX-5048. Page 11 October 13, 1986 NOTICE QE DEVIATION JTE] B.3 (445/8601-D-J.9)
B. Section 4 of Revision 3 to CPRT Procedure CPP-009 states, in part,
" Qualified QA/QC Review Team personnel perform field inspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions ...."
In deviation from the above, the following example was noted where field reinspections were not performed in accordance with approved instructions:
- 3. Attribute 1.d in Section 5.2.4 of QI-025, Revision 1, which states, in
.part, " Ensure that the actual piping dimensions are in agreement with those shown on the piping isometric ....," was signed off as acceptable by the ERC inspector on December 9, 1985, for Verification Package No. I-M-LBC0-144. However, field survey measurements taken by Brown & Root on December 6, 1985, in response to an ERC request, showed the distance from the end of the containment penetration at field weld 18-A to the working point of the 760 bend as 10 feet 5 7/16 inches with respect to a distance (with a tolerance of +2 inches) indicated by the applicable Isometric Drawing BRP-CC-1-RB-046 of 10 feet 81/8 inches.
RESPONSE TQ ITEM B.3
.1. Reason for Deviation An ERC investigation confirmed the stated condition. The difference between the Brown and Root field survey results and the dimension shown on the isometric drawing exceeds the +2 in. Tolerance. The ERC Inspector did not note this condition at the time of his original inspection.
- 2. Corrective Action Taken Deviation Report (DR) I-M-LBC0-144 DR2 was prepared on March 14, 1986, to document the tolereance deviation. Based in part on this DR, Nonconformance Report (NCR) M-23475N R-1 was generated to disposition this condition.
.3. Action _t_q Prevent Recurrence In cases where inspector error was evident, the inspector and the lead inspector or population engineer discussed specifics to determine why the error ocurred. Actions taken to address the error and preclude recurrence typically included one or more of the following, as necessary:
0 Documented retraining of the inspector (s) to the pertinent Quality Instruction (s),
O Clarification or revision of the Quality Instruction.
At the discretion of the lead inspector, formal and informal group meetings were held to discuss inspector error on a generic basis. These discussions allowed appropriate information to be disseminated to various cognizant ERC inspectors.
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Attachment to TXX-5048 .Page 12 October 13, 1986 RESPONSE IQ IIEM B.3 CONT'Q An Overview Inspection Program was implemented to reinspect a sample of each Inspector'.s work. ~ Action is ongoing to analyze the results of the Overview Inspection Program which includes pertinent inspector error data from other sources (i.e., NRC inspections, etc.).
- 4. Data 91 Full Comoliance Corrective action will be completed coincident with final disposition of NCR M-23475N R-1. Results of the.0verview Inspection Program are scheduled to be completed by October 31, 1986.
i Attachment to TXX-5048 Page 13 October 13, 1986 NOTICE DE DEVIATION ITEE E B.i (445/gg01-0-J3) 0 B. Section 4 of Revision 3 to CPRT Procedure CPP-009 states, in part,
" Qualified' QA/QC Review Team personnel perform field inspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions..."
In deviation from the above, the following example was noted where field reinspections were not performed in accordance with approved instructions:
- 4. Paragraph 6 on page 34 of Attachment 6.17 of QI-058 requires (for vendor safety wiring of attachment bolts between the forward bracket assembly and the snubber assembly) that the inspector shall verify that the lockwire is not damaged. Independent inspection showed for Verification Package No.
I-S-PS42-021 that the inspection checklist was accepted by the ERC inspector despite the presence of a broken lockwire.on the snubber adaptor plate.
RESPONSE TQ IIM B.4
- 1. Reason for Deviation Inspection for damaged lockwire was not included as an attribute on the QI-058 inspection checklist. However, Attachment 6.17 required that the inspector verify that the lockwire is not damaged. Therefore, the ERC inspector noted the broken lockwire as an out-of-scope observation in lieu of an in-scope ~ deviation.
- 2. Corrective Action Taken An out-of-scope observation (00S) number 289 was generated on November 11, 1985. Subsequently, Nonconformance Report (NCR) M-234474 was prepared and dispositioned to replace the broken lockwire on the snubber adapter bolts.
l This action is addressed via TUGC0 work request No. 7288.
In order to clarify inspection requirements, QI-037 and QI-058 are currently being revised to include the inspection of lockwire on snubber i adaptor plate bolts. In addition, 36 Verification Packages from the PS7N population and 11 Verification Packages from the PS42 population have been reinspected, via a supplemental inspection instruction, to verify that lockwires are installed and not damaged. This supplemental instruction will be included in QI-037 and QI-058.
Further, a Hardware Validation Program (HVP) has been initiated based on Corrective Action Requests (CAR) 65x through 69x. These CARS will be dispositioned by-TUGC0 by performing a 100% reinspection of pipe supports.
Many attributes will be examined including lockwire.
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Attachment to TXX-5048 Page 14 October 13, 1986 RESPONSE TQ ITEM B.4 CONT'D
~3. Action Tq Prevent Recurrence In addition to the lockwire reinspections required by supplemental instructions to QI-037 and 058, inspection for lockwire on snubber adapter plate bolts is required'by the ISAP VII.c Quality Instructions QI-019 and QI-029 under a separate attribute for safety wire.
TUGC0 Operations has issued procedures governing housekeeping and inspection of plant systems, structures, components and equipment turned over to Operations. These procedures are QAI-001, " Plant Housekeeping and Equipment Inspection Plan", and STA-607, " Housekeeping Control". Part of this monthly inspection requires the visual . inspection for loose, damaged, broken or missing parts / components on equipment.
- 4. Qate of Full Comoliance Corrective action will be completed commensurate with the final disposition of CARS 65x through 69x. ERC reinspection concerning the aforementioned populations are complete. Revisions to QI-037 and QI-058 are scheduled to be completed by October 31, 1986.
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Attachment to TXX-5048 Page 15 October 13, 1986 NOTICE DE DEVIATION ITEM L (445/g1Ql-D-18) i C. Section 4.0 of CPRT Project Procedure CPP-008, Revision 1, requires that verification packages provide the information necessary to conduct reinspections and document the results. Section 5.1.1 of this procedure 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, the engineer incorrectly indicated "N/A" for '
attribute 1.e on the checklist for Verification Package No. I-M-LBC0-038.
As a result, this attribute, dealing with assuring branch connections were in accordance with the piping isometric drawing, was not reinspected by ERC. Independent . inspection identified that the attribute was applicable for Verification Package No. I-M-LBC0-038 as evidenced by the observation of the presence of a branch connection RESPONSE IQ IIEM [
- 1. Reason for Deviation ERC investigation conf'rmed i that attribute 1.e in the ERC inspection checklist had N/A incorrectly inserted by the QA/QC engineer, and thus was not inspected. This attribute addresses assuring that branch connections are in accordance with the piping isometric drawing. The existence of a branch connection was confirmed on the piping isometric drawing bill of material.
- 2. Corrective Action Taken No corrective action has been planned for this deviation. The lack of reinspection of one branch connection will not affect the final conclusions drawn concerning branch connection installation. A statistically sufficient quantity of branch connections (approximately 115) have been inspected to permit the adequacy of branch connection installation to be determined.
- 3. Action to Prevent Recurrence The QA/QC engineer was instructed to take added precautions when l completing inspection checklists. Additionally, ERC inspectors have been instructed to correct a checklist when an error is found or return the list to the QA/QC engineer for correction. A memorandum dated May 28, 1986, confirmed the above instruction.
Attachment to TXX-5048 Page 16 October 13, 1986 RESPONSE TQ JJEM C CONT'Q In addition to the specific actions identified above, the following activities are ongoing on a generic basis to identify and correct inspection, engineering or program deficiencies to insure compliance with
'the Quality Assurance guidelines for the CPRT Program:
- 1) Surveillances are scheduled and performed routinely of CPRT activities per ERC-QA-15, " Performance of Project Surveillance". Specific elements of the surveillance practice are:
0 Monitoring ongoing work to determine what activities have been planned, what activities are in process, and what activities have been completed and accepted.
O Verify the work is being accomplished in accordance with I requirements. 1 0 Determining when independent inspections should be made and recommending conduct of those inspections.
O Determining when direct observation of the work performance or overview of inspections and tests should be made and arranging for !
the conduct of those observations. i 0 Performing and documenting observations or witnessing of inspections or tests performed by others.
O Determining when special audits of quality assurance activities should be performed.
O Initiating recommendations for corrective action based upon observations.
These surveillances are performsd through selected activities such as i monitoring of direct observation of work activities, quality trends, etc. Surveillance activities and their results are recorded. If any deviations are identified, the appropriate organization within ERC is notified to correct the deviation and submit a report describing corrective action taken or proposed. All deviations are logged and tracked until closed.
- 2) Audits are performed per ERC-QA-18, " Administration of Quality
~ Assurance Auditing". These audits verify the adequacy of the ERC Quality Assurance Program. Audit reports are prepared and if deviations from the Program Plan or Procedures are identified, the audited organization is notified to correct the deviation, review areas where similar deviations can occur and to initiate corrective action. All deviations are tracked until closed.
- 4. D& _o_f Full Compliance Quality Assurance surveillances and audits consist of an ongoing program.
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