ML20141P053
| ML20141P053 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/06/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20141P047 | List: |
| References | |
| 50-445-85-14, 50-446-85-11, NUDOCS 8603180497 | |
| Download: ML20141P053 (4) | |
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APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Dockets: 50-445/85-14 50-446/85-11 Comanche Peak Steam Electric Permits: CPPR-126 Station, Units 1 and 2 CPPR-127 During an NRC inspection conducted on October 1-31, 1985, six violations of NRC requirements were identified.
The violations involved failure to maintain sufficient chemistry records, a minimum wall violation not being documented on a nonconformance report (NCR), inadequate issue control for design documents, l
absence of procedures for controlling offsite shipment of original design l
records, signing of inspection reports by a noncertified electrical inspector, and revision of drawings without required review and approval actions.
In l
accordance with the " General Statement of Policy and Procedure for NRC l
Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are listed below:
l A.
Criterion XVII of Appendix B to 10 CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative Ccntrol and Quality Assurance Plan, requires that (1) sufficient records shall be maintained to furnish evidence of activities affecting qua'.ity, and (2) that the records shall include the results and acceptaoility of testr and analyses, and the action taken in connection with any 6ficiencies noted.
Contrary to the above:
1.
A significant number of instances of missing data entries was noted in water chemistry records covering the period March 1983 through September 1985, with respect to the chemistry sampling frequency requirements of Procedures CHM-501, " Chemistry Control of the Steam Generators," and CHM-508, " Chemistry Control of the Primary Cooling Water Systems." No annotations were made in the records to explain why the samples were not taken.
2.
Review of the water chemistry records showedcinstances of failure to make required entries to indicate when the Shift Supervisor was notified in regard to out-of-specification chemistry results.
3.
The records did not identify what corrective actions were taken after entry of out-of-specification results.
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y 4.
Inadequate reviews.were performed of the acceptability of water chemistry data, as evidenced by the presence of review and approval signatures on forms containing discrepant data results.
This is a Severity i.evel IV violation (Supplement II) (445/8514-V-01).
B.
Criterion V of Appendix B to 10 CFR Part 50, as. implemented by TUGC0 Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31, 1984, 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.
Paragraphs 2.3 and 3.1.1.1 of Crown and Root (B&R) Procedure CQ-QAP-16.2, l
Revision 25, require that nonconformances be identified, documented by completing the NCR form, and dispositioned. Paragraph 3.19.5.2 of B&R l
Procedure CP-CPM 6.9D, Revision 6, states, in part, with respect to NCRs I
for minimum wall violations, "... Welding engineering shall review the conditions stated on the NCR...."
Contrary to the above, repair of a minimum wall violation associated with weld 21-2 in component CC-2-RB-053 was noted on October 9, 1985, from l
record review to have been performed without documenting the condition on an NCR form.
This is a Severity Level IV violation (Supplement II) (446/8511-V-01).
C.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, 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 3.1.1.1 of B&R Procedure DCP-3, Revision 18, states, in part,-
"... Issuance and receipt of controlled design changes are documented on the Document Distribution Log....by signature or initial of the file custodian and dated." Paragraph 3.2.2.5 of this procedure additionally requires that the face of a retained superseded document must be stamped
" VOID."
Contrary to the above:
1 1.'
Satellite document control center 307 was noted on October 14, 1985, to be in possession of a controlled copy.of Component Modification Card 9G181 for which receipt had not been signed for. and dated on the Document Distribution' Log.
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6
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'E d 4 2.
A copy of superseded Design Change Authorization (DCA) 21446, e
Revision 0, was noted on the same date to be present in two packages for Drawing 2323-El-1702, Sheet 002, Revision 2..Both copies of DCA 21446, Revision 0, were not stamped "V0ID" on the face of the
- document.
" This is a Severity Level IV violation (Supplement II)
(446/8511-V-02).
i D.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, 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.
Section 17.1.17 of the Final Safety Analysis Report, Volume XIV, Amendment 50, dated July 13, 1984, commits to procedures requiring that records be controlled and accounted for during transfer between organizations.
Contrary to the above, original sole copy design records were ascertained l
on' October 16, 1985, to have been shipped to Stone and Webster Engineering Corporation, New York, without the establishment and implementation of procedures that address required control and inventory measures.
l This is a Severity Level IV violation (Supplement II) (415/8514-V-02, 446/8511-V-03).
E.
Criterion VI of Appendix 8 to 10 CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative and Quality Assurance Plan, requires that (1) measures shall be established to control.
l the issuance of documents such as drawings, including changes thereto; and (2) the measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized parsonnel.
Paragraphs 2 and 4 in Revisions 7 and 8 of Station Administration Manual Procedure No. STA-405 require that all documented nonconformances, in l
which "use-as-is" dispositions are recommended, be forwarded to TUGC0 Operations Results Engineering group for review to determine if as-built
.ocumentation changes are needed.
Paragraph 4.0 in Revision 0 of Nuclear Operations Engineering Manual Ihstruction No. N0E-201-5 requires that proposed drawing changes be submitted to the Operations Superintendent for review, approval, and authorization to distribute the revised drawing.
1 I
V.
a Contrary to the above, nine as-built drawings were revised and distributed by TUGC0 Nuclear Engineering to reflect NCR identified undersize welds, without receiving TUCG0 Operations review, approval, and authorization to distribute the revised drawings.
This is a Severity Level IV violation (Supplement II) (445/8514-V-03).
F.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, 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 i
instructions, procedures, or drawings.
Paragraph 3.0 of Procedure CP-QP-2.1, Revision 14, dated October 17, 1983, states, in part, "... inspection personnel... shall have experience in and shall have completed a technical training course and examination in the area of inspection responsibilities." Paragraph 3.7 of this procedure states, in part, "... Inspection personnel shall be certifieJ by the l
TUGC0 site QA supervisor as being qualified to perform their a: signed tasks."
1 Contrary to the above, it was noted on October 21, 1985, during review of docunentation for Class 1E lighting system conduit EAB1-1 that the electrical inspector, who had signed inspection reports E-1-0024951 and E-1-0027419, had not been certified to the applicable Procedure 01-QP-11.2-25. Revision 17, dated February 13, 1984, " Inspection of New Installations for Class IE Lighting Systems."
This is a Severity Level IV violation (Supplement II) (445/8514-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 this Notice, a written statement or explanation in reply, including for each violation:
(1) the reason for l
theviolationsifadmitted.(2)thecorrectivestepswhichhavebeentaken 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 the response time.
.a Dated at Arlington, Texas this 6th day of March, 1986.
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