TXX-4694, Responds to NRC Re Violations Noted in Insp Repts 50-445/85-13 & 50-446/85-09.Corrective Actions:Project Control Program Will Be Revised to Note Application of Approved Substances & Survey Will Be Performed

Responds to NRC Re Violations Noted in Insp Repts 50-445/85-13 & 50-446/85-09.Corrective Actions:Project Control Program Will Be Revised to Note Application of Approved Substances & Survey Will Be Performed

ML20155A443
Person / Time
Site:	Comanche Peak
Issue date:	02/21/1986
From:	Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20155A172	List: ML20155A170 TXX-4694, Responds to NRC Re Violations Noted in Insp Repts 50-445/85-13 & 50-446/85-09.Corrective Actions:Project Control Program Will Be Revised to Note Application of Approved Substances & Survey Will Be Performed
References
TXX-4694, NUDOCS 8604080470
Download: ML20155A443 (9)

Text

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Log # TXX-4694 File # 10130 IR 85-13 TEXAS UTILITIES GENERATING COMPANY IR 85-09

&KYWAY TOWER

• 400 NORTH OLIVE EFFREET. L.B. St

• DAILAS. TEXAS 78308 February 21, 1986 WILLIAM G. COUNSIL Mr. Eric H. Johnson, Acting Director l Division of Reactor Safety and Projects E2'E i U. S. Nuclear Regulatory Commission f Region IV U a; V, 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 INSPECTION REPORT NOS.: 50-445/85-13 AND 50-446/85-09

Dear Mr. Johnson:

We have reviewed your letter dated December 24, 1985, concerning the inspection conducted by Mr. T. F. Westerman and other members of the Region IV Comanche Peak Group during the period August 23, through September 30, 1985. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2.

We requested and received two extensions of two weeks each in providing our response during telephone discussions on January 23, 1986, and February 7, 1986, between yourself and Mr. John Marshall of TUGCO. These extensions were necessary because of holiday delays and the number of issues to be addressed.

We have responded to the Notice of Violation and have provided a partial response to the Notice of Deviation in the attachments to this letter. To aid in understanding our response, we have attached the Notice of Violation and Notice of Deviation. We consider the enclosed information to be responsive to the inspector's findings.

Very truly yours, W 6Ls:l W. G. Counsil JWA/gj /

Attachments By:_ [ '

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5 M$ag brea Licensing g 40Bo g g6 G

LC-O30 & a ouvussou or r xas uruzzrues #1xcrsuc coursur v

h c'- Region IV (Original + 1 copy)'

Director, Inspection and Enforcement (15 copies)

U.S. Nuclear Regulatory Commission i

Washington, D.C. 20555 Mr. V. S. Noonan Mr. D. L. Kelley I

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A_PPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Comanche Peak Steam, Units Electric1 and 2Station Dockets: 50-445/85-1 Permits: CPPR-126 50-445/85-0 CPPR-127 five violations of NRC ugust requirementsDuring 23 throu an provisions for control of e deleteriousinspection pipe support dimension, inade 30, 1985, installed components, incomplete and materials unauthorized breaking of an accepted fl

" General Statement of Policy missing and angePr joint.con,duit identification, 10 CFR Part 2, Appendix C (1985)

A. ocedure for NRC EnforcementIn a Criterion V of Appendix B , the violations are listed below: Actions,"

Quality 1981, Assurance requires Program QAP) that activities (to 10 CFR Part 50, a,ffecti as documented instructions, procedures Section 5.0, Revision 2, dated C0 May instructions, procedures, omplished

s. in or drawingthe accordance with thesee cap Site Procedure shall assign a QI-QAP-11.1-28 number to each states th the Q dimensionalat specific dimension inspection report and shall record the attribute identified as a actual measurements on this was recorded on the QC inspection reContra assigned and no measurement result dimension shown on pipe support dr dimension was independently port for awing checked the wall-to b

AF-2-006-412-533A. pipe centerline when the drawing showed it ytoNRC, be 11h i When this it was found to be 13 -inches nches.

This is a Severity 1.evel V violati B.

TUGC0 QAP, Section 13.0, Revision 1 Cri

, dated JulyPart 50, as implemented by measuresand cleaning, be established preservation toofcontrol 31, 1984,the h material andandling, s work and inspection instructions to p revent damage or deterioration Revision 8, dated July 5, 1984Section 2.17 of Gibbs .

contamination of reactor defines the actions to mit be taken coolant equipment low melting point metals and their csurfaces; e.g.

ompounds, prohibition,of use ofprohibition of l

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instruments containing mercury, and restriction of halide content of products such as machining coolants, seals, and plug materials.

Contrary to the above, implementing site procedures do not address prohibition of use of instruments containing mercury, do not provide necessary craft guidance for contamination control, or include provisions to assure that procured consumables are in compliance with specification requirements.

This is a Severity Level IV violation (Supplement II) (446/8509-V-02).

C. Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 QAP, Section 5.0, Revision 2, dated May 21, 1981, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Brown & Root Procedure MCP-10, paragraph 3.6, Revision 9, dated July 2, 1985, requires that items stored in place shall merit additional protection if construction work threatens the integrity of equipment and includes a prohibition in regard to placing work platforms or scaffolds on permanent plant installations, such as a pipe, tray hangers, etc., without written engineering authorization. '

Contrary to the above:

1. On September 25, 1985, the NRC inspector observed in Room 16 (854 feet elevation) a wooden two by four which was laid across .

3/4-inch pipe RC-2-095-501R-2 to serve as a work platform, but there was no evidence to indicate that engineering had authorized this temporary platform.

2. On September 24, 1985, the NRC inspector observed at the 905 feet elevation that welding had taken place above the reactor pressurizer and associated piping without adequately protecting the equipment, as evidenced by the presence of weld spatter on weld no. 42 in 6-inch line RC-2-096-2501R-1.

This is a Severity Level IV violation (Supplement II)

(446/8509-V-03).

D. Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 QAP, 5,ection 5.0, Revision 2, dated May 21, 1981, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and

3 shall be accomplished in accordance with these instructicns, procedures, or drawings.

Paragraph 3.1.1, subparagraphs b and c, of TUGC0 Procedure QI-QP-11.3-8, Revision 0, issue date July 7,1978, " Identification and Color-Coding Inspections," require that conduit designation shall be applied with black ink or paint and that identification of conduit be verified at both sides of all walls and slabs through which conduit passes.

Paragraph 3.1.1, subparagraph b, of TUGC0 Procedure QI-QP-11.2-23.7, Revision 1, issue date January 5, 1980, " Verify Conduit Identifications,"

similarly requires that conduit be identified on both sides of all walls and slabs through which conduit passes. Subparagraph c. of this paragraph states, in part, " Groups of embedded conduits which are flush with the surface of walls, floors and manholes shall be identified on the surface or the wall, floor, or manhole by attaching an identification template near the conduit bank. . . ."

Contrary to the above, the following examples of incomplete and missing conduit identifications were noted in the Unit 1 lower cable spread room, auxiliary building, and safeguards building:

1.

Two conduits attached to embedded conduit wall sleeve TSW-A-020 were not identified on the identification template and one conduit which was identified on the template as being present did not, in fact, exist.

2.

Two banks of embedded conduit wall sleeves below sleeve TSW-A-023 had no form of identification.

3. At tray section T14GCDH27, there were four floor sleeves which were not identified by either identification template or conduit marking.

4. At tray section T24WAEF, there were two floor sleavas with an incomplete identification template; i.e., the template contained only the letters TFS.

5. Below battery pack CPI-ELBPSG-187 (Circuit ESB7-11), there were two floor sleeves which were not identified.

6. At a tray section above junction box JBIA-1332, the embedded conduit wall sleeves were not identified by either identification template or marking.

7. Ihree of five floor sleeves at tray section T220ABA41 were unmarked.

8. Four floor sleeves at tray section T120ABB23 were unmarked.

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Conduits attached to embedded conduit wall sleeve TSW-A-030 were not l identified on tha identification template which was present.

This is a Severity Level IV violation (Supplement II) (445/8513-V-01).

E.

Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP, Section 5.0, Revision 2, dated May 21, 1981, requires that activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Paragraph 3.5.2.1 in Revision 7 of Brown & Root Procedure CP-CPM 6.9E states, in part, "When it becomes necessary to break an inspected flanged joint for any reason, the responsible craft QA/QC foreman.Building Superintendent shall be notified by This notification will be by the foreman completing an IRN (Item Removal Notice) in accordance with CPM 6.10. . . ."

Paragraph 3.11 states, in part, " Flanged pipe joints shall be tightened sufficiently to prevent leakage."

Contrary to the above, flange no. 6 in Unit 2 piping system BRP-SW-2-018, which was installed, inspected and accepted using Construction Operation Traveler No. MP-82-4117-0400 dated April 20, 1982, was observed in a broken condition as evidenced by loose nuts on 4 of the 12 studs, thus impairing its ability-to sufficiently prevent leakage. Further, there were no available IRNs authorizing any activity which would require the breaking of this flanged joint.

This is a Severity Level IV violation. (Supplement II) (446/850'9'V-04).

Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is hereby required to submit to this office within 30 days of the date of the letter transmitting including this Notice, a written statement or explanation in reply, for each violation:

(1) the reason for the violations if 1dmitted; l (2) the corrective steps which have been taken and the results achieved; (3) corrective steps which will be taken to avoid further violations; and (4) the date when full compliance will be achieved.

consideration will be given to extending the response time.Where good cause is shown, l

i Dated in Arlington, Texas, this 24th day of December,1985

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_ APPENDIX B l

NOTICE OF DEVIATION l

1 Texas Utilities Electric Company (TVEC) Docket: 50-445/85-13 Comanche Peak Steam Electric Station, Unit 1 Permit: CPPR-126 Based on the results of an NRC inspection conducted on September 1-30, 1985, of Comanche Peak Response Team (CPRT) activities, three deviations from  ;

conrnitments to the NRC were identified. The deviations involved inclusion of non-ASME pipe supports and base plates in the Issue-Specific Action Plan (ISAP)

No. V.d ASME population; issue of reinspection verification packages containing missing, incomplete, and/or incorrect documents; and failure of ERC inspectors to note conditions which violated drawing requirements. In accordance with the

" General Statemect of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1985), the deviations are listed below:

A. Paragraph 4.1 in CPRT ISAP No. V.d states, in part, ". . .the absence or presence of unauthorized or undocumented plug welds in ASME pipe supports and base plates will be verified. . . ." Paragraph 4.1.1 states, in part, "Two random samples of ASME pipe supports and base plates will be selected for inspection. One sample will be drawn from the population representing Unit 1 and common and the second sample from the population representing Unit 2. The Sample Plan will be based on identifying, with a 95%

confidence, a rate of detectable plug welds of 5% or greater. The smallest random sample which will achieve this confidence level and rate

... is 60 ...."

Contrary to the above, a review of the 2 selected random samples which were inspected revealed that the 2 random samples contained just 39 and 35 ASME pipe supports and base plates, respectively (445/8513-D-01).

B. Paragraph 5.1 of Procedure CPP-007, Revision 1 entitled " Preparation of checklists and Data Base Reports," states, in part, " Responsible QA/QC Discipline Engineers review the latest Gibbs and Hill, Brown and Root, and subcontractor design documents relating to the population. As applicable, the latest installation procedures, construction drawings (including as-builts) and manufacturer's prints and manuals are also reviewed."

Paragraph 5.2.1 of the above procedure states, in part, "On receipt of the memorandum with attachments, the QA/QC Lead Discipline Engineer reviews the documents for accuracy, completeness, and conformance with this procedure. . . ."

Contrary to the above requirements, verification packages have been issued by the discipline engineers to inspectors with missing, incomplete, and/cr incorrect documents. Examples identified by NRC inspectors include the following:

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1. Verification Package No. I-S-LBSR-047 for large bore pipe supports had an incorrect checklist. The responsible QA/QC discipline engineer wrote "NA" for not applicable on the checklist for Richmond inserts, when in fact, Richmond inserts were present as listed on the bill of materials and shown on the design drawing.

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2. Verification Packages Nos. I-S-LINR-6 and I-S-LINR-51 for the containment liner and tank stainless steel liner had incorrect checklists. The responsible QA/QC discipline engir.eer wrote "NA" for not applicable on the checklists for two base naterial local centour attributes. The attributes were found during the physical inspection to be inspectable. New checklists were requested by the ERC inspector.

3. Verification Packages Nos. I-E-EEIN-029 I-E-EEIN-042 and I-E-ININ-005 were missing documents required for physical inspections. For the first two packages, generic design change authorizations had been issued but were not specifically identified <

or included in the verifict. tion packag's. e For the third package. l l three documents required to determine tubing size were not included in the verification package.

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4. Verification Package No. I-S-PS7N-187 contained two rather than tha required number of four forms to document inspection of snubber brackets. The inspection package also contained a form for pipe clamp inspection although a pipe clamp did not exist (445/8513-D-02).

C. Paragraph 5.0 of ERC Project Procedure No. QI-027 Revision 0, identifies the applicable inspection notes to be used, and requires that the reinspection checklist is to be used by the inspector to document the inspection results.

Note 30, an identified inspection note states, "In the course of inspection the inspector shall note any item not covered by reinspection / verification which appears out of the ordinary as related to the construction of the inspected item cr sucrounding area. Note such in the remarks column of inspection checklist."

I Contrary to the above, the ERC inspectors failed to identify and note an cut-of-the-ordinary condition in the remarks column of the inspection checklist for ASME pipe support MK No. CT-1-053-436-C52R; i.e., the existence of four 9/16" diameter holes in item 2 of the pipe support that were not shown on the applicable drawing.

Texas Utilities Electric Company is hereby requested to submit to this office, within 30 days of the date of this Notice of Deviation, a written statement or explanation in reply, including for each deviation: (1) the reason for the deviations if admitted, (2) the corrective steps which have been taken and the I . . . . .

3 results achieved, (3) corrective steps which will be taken to avoid further deviation from commitments made to the Comission, and (4) the date when full compliance will be achieved.

Consideration may be given to extending your response time for good cause shown.

Dated in Arlington, Texas, this 24th day of December, 1985 i

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Response to Notice of Violation Item A (446/8509-V-01)

We do not feel that this item on. is a violati At the time the apparent deficiency was id response that provided the dimension by the Brown in question was not &anager Root Site QA Mentified to this item was was a location Checklist. dimension However, after discussin as identified in itan attribute verifie em A.2. of th

".....e attached QC the QC QI-QAP-11.1-28.

inspector to measure this dimen,siattrib he incorrectly agree.each dimens on appeared to violate the words of Subsequent to this discussion, he verified it and all the QC program.

QC personnel were inspector to measure this dimensi cognizant of t

n. e requirements of A.I.

on did not violate the inspectio BRH AF-2-006-412-S33A inspector on 4/27/85. in completing the Component Rev.0S used ev.2, were and CMC 86747 by the QC j Field Engineering and CMC-86747 Rev dimension. .

a 0 iAt that time, t inspector did not contain the CMC's isFor unknown rea was notthe within aware that the dimension QI-QAP-ll.1-28 revised. had be Therefore, en requirement ofsuedhe again dimension fcr pipe location. and well withinplus/minus the 23231 MS inch 100of the revise tolerance of plus/minus 2 inches The complete support package a is avail bl e for review by your inspector.

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Response to Notice of Violation Item 8 (446/8509-V-02) 1.

Reason for the Violation control of chemical substances need to orbe stren The current and existing procedures may be used in acc requirements val. and may not be used elsewhere without o- Engin 2.

Corrective Steps Which Have Been Taken and Results Achieved In order to strengthen the project control program,.,CP-CPM-9 2 the application of approved substances." Control oeof Che for the identification of noncompliances by nonconformance ports.

rePro Upon issuance of the revised procedure, an in-depthe made survey will of applicable directions. plant structures to ensure compliance with presc issuance of the procedure in accordance program.

raining with the 3.

Corrective Steps Which Will Be Taken to Avoid Further Viola:f by the implementation of construction recurrence es. This surveilla program will be further supported by the training specified abov trending activities for related nonconformance reports e and

4. Date When Full Compliance Construction Procedure than March 7,1986.

completed by March 21,The survey 1986.

CP-CPM-9.2 oislater for compliance and training scheduled will be I

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Response to Notice of Violation i

Item C (446/8509-V-03) 1.

Reason for the Violation The two findings noted were confirmed followin the NRC.

group responsible for these items.Further investigation could n e individual or permanent installed equipment.a lack of awareness by cra ance of protecting 2.

! Corrective Steps Which Have Bcen Taken and Result

! s Achieved.

1 of October, 1985.Both of the conditions e identified were correct d These staff findings meeting were on Cctober 1 discussed with all Supe i tNo damage . { w 1985. r n endents at the weekly the integrity of permanent installationsvision to prec for discussion at the weekly safety meeting These findings were a topicc encies January 27, 1986.

with the craft personnel on 3.

Corrective Steps Which Will Be Taken to Avoid F urther Violations.

through supervision. Craft awareness of these concerns will conti nue to be emphasized supervision will continue in orderr to prevent fu thMonitoring er violations.y 1986, to assess the effectiveness g.

of28,traininQuality ormed by March 4

Date When Full Compliance Will Be Achieved .

The full compliance date was January , 1986. 27 l

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i Responsg to Notice of Violation Item D (445/8513-V-01)

1. Reason for the Violation l

We have reviewed each of these findings and concludad that a lack of i understanding of the requirements for sleeve identifications was the cause of those findings. Many of the sleeves noted are unused and do not require identifications until they are utilized. T'iose sleeves which were found to have incorrect / incomplete identification are being corrected.

2. Corrective Steps Winich Have Been Taken and Results Achieved To ensure compliance within the ES-100 Specification regtfrements for sleeve identification, we will be oerforming walkdowns of all power and non-power through-wall and thruagh-floor sleeves. In addition, we have initiated a comparison review of ES-100, Drawing 2323-El-1701, DCA 21464 and Installation and Inscection procedures to ensure that design requirements are consistently implemented.

3. Corrective Steps Which Will be Taken to Avrid Further Violations Following the documentation review we will train personnel to ensure proper ur.derstanding of ?hese requirements. It is anticipated that the above actions will be completed by June 1, 1986.

Quality Surveillance of the activity will be performed by July 2, 1986, to ass 6ss the effectiveness of training.

4. Date When Full Compliance Will 8e Achieved The date of full compliance will be June 1, 1986.

Response to Notice of Violation Item E (446/8509-V'-04)

1. Reason for the Violations We have confirmed that an Item Removal Notice did not exist for this broken flange joint. Futher investigation did not reveal the reason or the individuals responsible for breaking open this flange joint.

2. Corrective Steps Which Have Been Taken and the Results Achieved.

A Non-conformance Report (NCR-M-18697) was written and the flange was repaired. No damage to any equipment resulted from this item.

3. Corrective Steps Which Will Be Taken to Avoid Further Violations.

Additional training was prescribed for construction personnel to provide additional emphasis regarding the proper documentation required for work on previously inspected components. This training was completed on February 5, 1986. -

Quality Surveillance of this activity will be performed by March 28, 1986, to assess the effectiveness of training.

4. Date When Full Compliance Will Be Achieved.

The date of full compliance was February 5, 1986.

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• I Response to Notica of Deviation Item A (445/8513 D-01) l

1. Reason for the Deviation Due.to a misunderstanding of the action plan by the personnel respon-sible for selecting the sample, the intent of the V.d action plan to inspect ASME supports was interpreted as being supports where ASME welding procedures were used during fabrication and erection rather than ASME,NF supports. At the time of the NRC inspection, the third-party overview had focused on the random sampling methodology, the inspection procedure and inspector training, and the initial field inspections.

A project report, which included the list of all pipe supports inspected, w'as in preparation .at the time of the NRC Inspection but had not yet undergone final review, It is quite likely that the devistign identified by the NRC inspection would have been detected by efther the project or the third-party during this final review.

2. Corrective Steps Which Have Been Taken and Results Achieved To correct the ide0tif f.ed discrepancy, additional NF pipe supports have been selected and inspected to achieve a sample of 60 ASME-NF supports in each unit.

3. Corrective Steps Which Wii. Be Taken to Avoid Further Violations The necessity of completing project checks and third-party overviews of key aspects earlier in the process has been reemphasiged to all affected parties.

4. Date When Full Compliance Will be Achieved The full compliance date was February 1, 1984.

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Rerponse to Notice of Deviation Item B (445/8513-D-02) and Item C Based on recent findings by the NRC as exemplified by these items and by Evaluation Research Corporation (ERC), while conducting internal sur-veillance activities, the Senior Review Team (SRT) suspended Quality of Construction (QOC) ISAP VII.c reinspection activities on January 8, 1986. '

The purpose of the suspension of activities was to evaluate the specifics of these two Notices of Deviation items and to assess, specify and imple-ment any necessary corrective actions. Until the ERC evaluation is complete and the SRT has concurred with the results, the specifics of these items cannot be addressed. It is anticipated that the ERC response will be finalized and approved ry the SRT in late February. A response to the spe-cifics of those deviations will be provided to NRC by mid-March 1986.

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