IR 05000445/1986008

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Confirms Completion of Review of Insp Repts 50-445/86-08 & 50-446/86-06 in Accordance W/Jm Taylor 860626 Memo. Concurrence Provided on 870121
ML20244E622
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 01/21/1987
From: Spessard R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Johnson E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20237K807 List: ... further results
References
NUDOCS 8701280436
Download: ML20244E622 (8)
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4NitTED eTATES

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( ' NUCLEAR REGULATORY COMMIS$10N

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.I wasweesotow.c.cJsoses cooc* JAN 211987 MEMORANDUM FOR: Eric Johnson. Director Division of Reactor Safety and Projects '

' Region IV FRON:

R. Lee.Spessard, Deputy Director Divisfo'nof.!aspection Programs- '. -

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. Off1,ce.gf Inspection and Enforcement

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SusJECT: IRSPECTION REPORT REVIEW ASSISTANCE - COMANCHE PEAK

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This will. confirm thescompletion of.our review of Inspection.Raport  !

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60-445/8648; 50-446/864Ni in accordance with J. M. Taylor's memortadun to R. D.' Martin dated OUne 26, 198 .

l During the course of our review we met on several occassions with members of your staff and reached mutually acceptable resolution on matters of content and l

presentation. We also arovided copies of the report to NRR (Trasun11) and OGC p(Mizuno)forcomment. @th NRR and CGC had several comments. These have been coordinated and resiolved through further discussions with I. Barnes 21, and1987, S. Phillipsv Our concurrer.ce in the report was provided on January as noted on the a closed repor ,

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dDeputf; Director R. Lee Spessj;,

Division of . n sp,ection PrcSrams Office of Inspection and Enforcement

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Enclosure:

Inspection Report Pages cc w/o enclosure J. M. Taylor. IE R. D. Martin, RIY J. C. Partlow, IE

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SC*d 20:91 48/C2/20 ISNOD-DEN S3Sd3 WOBd

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064 Cr & f fi ckk V IN5PE_CTION REPORT ROUTE SHEET sdzo control N LICENSEE / VENDOR: / kdho __

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bb DOCXET NO.:

EN REPORT NO.:/ /'4F (. o INSPECTOR: _

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INSPECTION DATE($) PRIORITY

Branch Chief REPORT DE DATE

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1MITIAL/CATE NAN 0 WRITTEN DRAFT COMPLETED DATE REPORT Kt! LED:

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delete / archives REVIEW BY SECTION CHIEF .

DUE DATE AFTER 10 DAYS:

RETURN FOR REWORK (inspector) -

RESPONSE DUE - 30 DAYS:

REHORK CQFLETE . -

DRAFT REC'O -: DMU N TYPING TIME WORKING DAYS DRAFT TYPING COMPLETE ,

DRAFT REWEW BY SEC'Y/ INSPECTOR , .

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DRAFT REVIEW BY SECTION CHIEF

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nNAL REVIEW BR. SEC'Y/DIV. SEC'Y FINAL REVIEW BY INSPECTOR $f [/3 l nHAL REVIEW 8Y SECTION CHIEF

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WETU M FOR CORRECTIONS - DMU fjp/ { $3 MEU!ONS COMPLETE - QW ,

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y/y 2), l CORRECT 10x REVIEW INsP/ SECT. C ,,j.fqi i FfNAL REVIEW BY BR#iCH CHIEF

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O!VIS10N O! RECTOR REVIEW

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UN80 * W 88 NUCLEAR REGUt.ATORY COMMIS$lON

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. u In Reply Refer To:

Dockets: 50-445/86-08 .

50-446/86-06

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Texas UtilitiesJanerating Company ATTN: Mr. W.' 61!Couns11 Executive.Vice' President i 400 North Olive, L.B. 81 )

Dallas,.TX 75201 s

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This refers to .tho' construction inspection conducted by Mr. H. S. Phillips and other members af 4ho Region IV Cocanche Peak Group during the period April 1 ';

through Mcy 31, 1986, of activities authorized by NRC Construction Persiits CPPR-126 and CPPR-227 for the Comanche Peak Steam Electric Station, Units 1 and 2, and to the discussion of our findings with you and. ether members of your staff at the conclusion of the, inspectio Areas of ' construction examined duNng tt# inspection included plant status and

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general. construction inspections; Brown & Root (fGR) audits.of site activities; Unit 2 electrical cable, tray, and instrumentation insta11atien; and Unit 2 <

pipe supports / restraints. Within these-areas,"tha inspection consisted of selective exccination of pro:edures and representative 2 records, interviews with personnel, and observations by the inspectors. The inspection findings are documented in the enclosed inspection repor ll During this inspection, it was found that certain of your activities were in violation of NRC requirements. Consequently, you are required to respond to

, in accordance with the provisions of tMse Sectionviolatione, 2.201 of the in NRC's writingRules

. of Prectica," Part 2, Title 10, Code of Federal RegJ1stione. Your response should be based on the specifics contained in the Notice of Violation enclosed with this lette Also during this inspection, it was found that certain of your activities i

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a;6.rtd to deviate from coeniitsants's.sde to the NRC. Thsse:itacis.and references to the cocaitamnts are identified in the enclosedIctica of ' ....

Deviation. You are requestsd to r4spond to these devictiNis in writing." Ycur responce should be based on the spt ,1fics contain,d in the Estuc of D-Niation

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enclored with this letta ' '

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We here also exacined actions you Mve taken with regard to previou:1  ;

id:ntified inspection findings. Thi status of th::c itc s is id:ctif ed in paregrcph 3 of the en:losed report, f 2 2d

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> BC*d CO*91 48/C2/20 i).SNOD-38N 53SdD.WOM3 ,

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Texas Utilities Generating Company b The responses directed by this letter and the accompanying Notices are not subject to the clearance procedures of the Office of Manager.ent and Budget'as required by the Paperwork Reduction Act of 1980, PL 96-51 '

Should you have any questions concerning this inspectioc, we will t,e pleased to discuss them with yo '

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E. H. Johnson, Director s Division of Reactor Safety and

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l Projects Enclosures:

1. Appendix A - Notice of. Violation 2. Appendix B - Notice of Deviation ,

3. Appendix C - NRC Inspection Report 2 50-445/86-08 50-446/86-06-4. Appendix 0 - B&R Matrix of Annual Audits -

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cc w/ enclosure: t -

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Texas Utilities Electric Company ATTH: G. S. Keeley, Manager, '

Licensing Skyway Tower '

400 North Olive Street Lock Box 81 Dallas, Texas 75201 , ,

i Juanita Ellis ~

President - CASE 1426 South Polk Street Dallas, Texas 75224 '

Renea Hicks Assistant Attorney General Environmental Protection Division P. O. Box 22548 Austin, Texas 78711-2548 Administrative Judge Peter Bloch U.S. Nuclear Regulatory Comission Washington, D. f 3 3)

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j APPEN01X A NOTICE OF VIOLATION 1 Texas Utilttias Electric Company Dockets: 50-445/86-08 50-446/86-06 Consanche Peak Steam Electric Permits: CPPA-126 CPPR-127 j Station,- Units 1 and 2 During an NRC inspection conducted on /pril 1 through May 31,-1986, two violations of NRC requirements were identified. The violations involved:

failure of. Brown & Root Ix:. , (EA) to fully perform annual audita of their ASME~

4A Program during 1980, 1982, and 1904, and ta provide adequate documentation of audits of , field design chcaces and special processes; and failure of TUGCo to adoquately follow up on the corrective action coss:itments for an audit

deficienc In accordance with the 5G'neral Statement of Policy and Procedure

\, for NRC Enfoxesent' Actions," 10 CFR Nrt 2, Appendix C (1966), the violations are listed tmlow:

' Criterion XVIII of Appendix 3 to 10 CFR Part 50, as impiamented by TUGeo

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Quality Assurance Plan (QAP) Sectiog 18.0, Revision 2 dated July 31,

  • 4 2984, and FSAR, Section 17.0, reaaires that a comprehensive, system o1 planned

' and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance iregram to determine the effectiveness of

'the program, and that. they be per.~oroad in accordance with procedures or checklists, and that results be f etenented, and followup action, including

.raaudit of deficient areas, shall be take . Failure ti Fully Audit the i R asp /QA Procram g i

i FSAR, Section 17.1.18, "Au"'.s," requires that planned and periodic audits be performed to ver' e cocpliance with all aspcets of the quality assurance program 1 to detaraine the effectivenes B&R ASME/QA Manuals in eff; _ t since November 19, 1976, to the present

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require the B&R QA manager '.a Msure that their ASME QA program is audited at least annuall CentrerJ' to the above, B&R '1ed to annually audit tte entire

< ASI'.E/CA program as evidenc . the failure to audit 12 of 20

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, sections of the QA Manual G0, 6 sections in 1582, and 8 sections

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l in 1984 (445/8608-V-01; 44 's-Y-01). Failure to Provide Aoeouat etr station to Seexet Irplemntation of Bah Audit Progry i B/Jt QA Manus 1, Section 1 Iswed Septerber 17, 1981, requires that i

. ocasuns. be sstablithed fc n audit pregrzc the.t will provide objective evidar.ce of coct et with th: QA unuc1; coepitance with pertinent specifications, i.us, a >d procedercs; and t m2thod of ,

I ke4 ping managem:nt informed of QA progrc.n effectivenes a (3y) 4

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g..-. l CP'd 90:91 49/C2/20 J.SM00. DEN $3Sd3 WON 3 l l

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l Contrary to the above:  !

1 B&R failed to provide adequate documentation in audit reports and/or checklists to show that the implementation of field design change procedures.and controls were audited (445/8608-V-02; 446/8606-V-02). B&R^ failed to provide adequate documentation in audit reports and/or checklists to show that the implementation of special process procedures and controls ware audited (445/8608-V-03i

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446/8606-V-03).

This is a Severity Level IV violation. (Supplement II) Criterion XVI of Appendix B to 10'CFR Part 50, as implemer.ted by FSAR, )

'Section 17.0, and TUGCo QAP, Section 16.0, Revision 0, dated July 1, 1978, J requires that conditions adverse to quality be promptly identified,- 1

. reported, and correcte Failure to Verify Correction of An Audit Deficiency

FSAR, Section 17.1.16, states that'TUGCo require measure be established to assure that conditions adverse to quality are promptly identified,

. reported, and correcte .

'TUGCo Procedure CQI-CS-4.6, Revision 3,* dated August 8, 1982, states in

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i part, " Verification of implementat. ion of corrective actions shall be {

accomplished by appropriate means." j

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Contrary to the above, Audit Deficiency No.1 of TUGCo QA Audit TCP-51 l (September 1982) was ireproperly closed out. That is, the auditor did not j verify the implementation of commitments to correct the dcficiency prior l to closing the audit firding. Records show that in this case TUGCo had Initiated plans for resolving the audit deficiency over an extended period of time, and eventually resolved the audit deficiency through review of the operation travelers (445/8608-V-06; 446/8606-V-08).

This is a Severity Level V violation. (Supplement II)

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Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is

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hereby required to submit to this office, within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reasons for the violations if indmitted, (2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending your response tim Dated at Arlington, Texas, this . day of : 1987

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APPENDIX 8 HOTIcE OF DEVIATION Texas utilities Electric Company Dockets: 50-445/86-08 50-446/86-06 Comanche Peak Steam Electric Station Permits: CPPR-126 Units 1,and 2 CPPR-127

' Based on the results of an NRC inspection conducted during April 1 through

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May 31 1986 one deviation from your commitments was identified. The deviation con,sisted of failure to establish proper criteria for supplemental audits of site activities. In accordance with the " General Statement of Polic and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), y the deviation is listed below:

FSAR, Section.17.1.2 commits to the establishment of an audit p ran in accordance with AmerIcan National Standard Institute (ANSI)

Draft 3.0, Revision 0. Paragraph 3.4.3 of this standard describes criteria N4 as to when supplemental audits are performe '

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In deviation from the above: , , TUGCo audit Procedure DQP-QA-35, Revision 0, left out the following supplemental audit criteria of paragraph 3.4.3 of the ANSI N45.2.1 Paragraph 3.4.3.1 requires assessment of contractor's QA progran prior to contract award, and . Paragraph 3.4.3.5 requires assessment of item quflity or program effectiveness, when required (445/8608-D-04; 446/8605-D-04).

^ B&R audit Procedure CP-QAP-19.1, dated October 10, 1984, does not agree with TUGCo Procedure DQP-QA-15 or ANSI N45.2.12 because C'A changed the l coenitment for supplacental audit criteria from "are performed" to "may be l performed" (445/8608-D-05, 445/8006-0-05). l Texas utilities Electric Company is hereby requested to subeit to this office, within 30 days of the letter transmitting this Notice, a written statement or explanation in reply, including for each deviation: (1) the reason for the deviation if adattted, (2) the corrective steps which have been taken and the resuits achieved, (3) the corrective steps which will be taken to avoid further i

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daviations, and (4 the date when full compliance will be achieved. M are cause is show, con) sideration will be given to extending the response tico. g!

Dated at Arlin;; ton, Texas, this day of 1987 l

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CP*d 40891 LB/C2/20 ISNO3-DMN S3Sd3 WOdd

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  • t e11 RYAN PLAZA DFtlVt. SUfTE 1000

%, , ' aRuMOTON.TEXa8 79011 october 31, 1986 *

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MEMORANDUM: Jan Barnes,: Chief I Comanche Peak Task Group

'FROM: H. S. Phillips, j

Senior' Resident Inspector Comanche Peak construction SUBJECTS . Review Of Inspection Rep' orts Price to the March.4, 1986 exit with TUGCO I found one cri sp violation concerning . Brown & Root's f ailure to audit their QA program in 1980 and 1982. I advised Tom Westerman that I considered it a violation and, I ocked if he agreed. He replied that it was not and wanted it written

'co an unresolved item. Subsequently, you took his place and I asked y u what to do about.it and you said that you considered it a violation. Further, you asked me to additionally review the other "

cudit years and I understood this to mean a comprehensive review and write a detailed report. I was unable * 4o complete the review in March Beccuse, as I reported to you, the complete files were in 'the B&R Houston of fice. The review.was finally completed in April and I wrote o Gotailed Notice of Violation which I intended to present at the oxit. I gave it to you for your review and subsequently presented it

,ct the exit. I submitted the typed draft report dated June 30, 198 v,On Ccptember 2, 1986 George Gower came to site and went,o.ver the

'trcpert and. asked me to drop two failure to.take correct:ive action violations, as Clif Hale would take care of these areas. He then gave no directions to write one big violation against Criterion XVIII-Audi t s. I revised the report per directions and was very surprised when I received extensive comments on it in an October 22, 1986 Goeting with George Gowe Frca late May to October 22, I was unaware' of any comments that you mado. Until October 15, 1986 when you discussed this report in general torGo, I thought you approved of the comprehensive review and draf t ropert. In fact, I performed and documented Inspection 86-20/17 in cin11ar fashion. After learning of the comments, George arid I revised Repert 86-08/06. I called you Octcoor 24 and requested you to hold Reptet 86-20/17, as 2 intend to r evi ew i t in light of the comments recoi.ved and revise it.

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If I had been permitted to write the crisp violation in the February, l ;

1 bolieve that would have taken care of the violation, as' TUGCQ would I

'h0Vo looked at the other years and given their response. It was not my -

criginal intent to make such a comprehensive inspection but thought you had some purpose in asking me to look at' other audit year .Ragcrdless, I intend.to go for conciseness in the future unless ethcrwise dArecte ;39' ,

H. S. Phillips, Sr. Resident Inspector ,

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ccs.Coorge,Gower

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