ML20141P054

Notice of Deviation from Insp on 851001-31

ML20141P054
Person / Time
Site:	Comanche Peak
Issue date:	03/06/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20141P047	List: ML20141P046 ML20141P053 ML20141P054 ML20141P063 ML20141P072 ML20141P077 ML20141P083
References
50-445-85-14, 50-446-85-11, NUDOCS 8603180498
Download: ML20141P054 (4)

Text

APPENDIX B NOTICE OF DEVIATION 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 Based on the results of an NRC inspection conducted during the period of October 1 through 31, 1985, of Comanche Peak Response Team (CPRT) activities, four deviations from commitments to the NRC were identified. The deviations involved ERC equipment / service requests not being controlled as committed, inadecuate ERC document review and procedure criteria with respect to inspection attributes that are inaccessible or nonrecreatable, failure of ERC document reviews to both detect a lapsed electrical inspector certification and to record required information in a verification package, and inspection attributes being attested to as acceptable by ERC inspectors which were found by subsequent NRC inspection to be unacceptable. In accordance with the

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

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

A. Section 4.1.6 of ERC Comanche Peak Project Procedure (CPP) CPP-012 "QA/QC Interface with Constructor /TUGCO," states, "The QA/QC Records Administrator controls requests for equipment / services and distributes and controls requests for technical information."

Contrary to the above, the QA/QC Records Administrator does not receive copies of requests to provide for control of these documents (445/8514-0-01).

B. Section 4.1 of CPRT Issue-Specific Action Plan (ISAP) No. VII.C, Revision 0, dated June 21, 1985, states, in part, ". . . Where required, documentation reviews will be utilized to supplement the reinspections for attributes which are nonrecreatable or inaccessible . . . ."

Section 4.1.3 of the ISAP states, in part, ". . . The inspection procedure will provide detailed instructions to the inspectors and/cr documentation review s for performing the reinspections and/or documentation reviews Contrary to the above, the following examples were noted of inadequate procedural guidance and document reviewer performance in regard to nonrecreatable and inaccessible attributes:

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1. Quality Instruction (QI) QI-013, Revision 4, lists no specific attributes, but instead specifies that the inspector verify installations in accordance with one or more of a listing of TUGC0 procedures; i.e., QI-QP-11.8-1, -5, -6, and -8. The list of appropriate procedures does not, however, indicate the applicable revision number of each procedure. In that the number of nonrecreatable or inaccessible inspection attributes can vary from revision to revision of a procedure (e.g., Revisions 0 and 1 of TUGC0 Procedure QI-QP-11.8-8), the absence of guidance on applicable procedure revision numbers does not constitute detailed instructions.

2. During the documentation review of Verification Package No. R-E-CDUT-064, in accordance with QI-009, Revision 0, there was no evidence that a documentation check was made of inaccessible attributes for conduit C13016037 that were caused by the installation of separation barrier material (445/8514-D-02).

C. QI-009, Revision 0, " Document Review of Conduit /R-E-CDUT," requires the ERC inspector to: (1) verify that inspection reports signed by electrical inspectors were dated after their date of certification and prior to their date of expiration, and (2) document the SBM inspection report (IR) and/or latest construction operation traveler number at the bottom of the checklist.

Contrary to the above:

1. Review of ERC accepted documentation for conduit C14R13047 showed that the ERC inspector failed to identify that the certification to the applicable Procedure QI-QP-11.3-23 had lapsed for the TUGC0 electrical inspector signing IR-E-46087.

2. The ERC completed inspection record checklist for conduit C13016037 in Verification Package No. R-E-COUT-064 did not contain documentation of the SBM IR or latest construction operation traveler number (445/8514-D-03).

D. Section 4 of CPP-009, Revision 3, states, in part, with respect to ISAP No. VII.c, " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions . . . ."

Contrary to the above, the following examples were noted where field reinspections of hardware items were not performed in accordance with approved instructions:

1. Attribute 4.5 in Section 5.0 of QI-055, Revision 0, states with respect to spring nuts, " Verify that the serrated grooves align with the channel clamping ridge." Checklists for support No. 0070

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+ r (Verification Package No. I-S-INSP-007) and support No. 028 (Verification Package No. I-S-INSP-028) were signed by two separate ERC inspectors that this attribute was acceptable. NRC inspections showed, however, that the spring nut serrated grooves did not align with the channel clamping ridge on both of these supports.

2. Section 5.3.4.C in QI-027 states with respect to dimensional tolerances not shown on design drawings, " Component member length

+/-1/2 inch."

The bill of material on Revision 2 of drawing No. CT-1-097-402-C52R i in Verification Package No I-S-LBSR-023 shows item No. 4 (2 pieces) to be 7 3/4 inches long. The applicable inspection checklist used during the ERC reinspection of this pipe support shows the installed configuration to be acceptable. NRC inspection determined, however, the actual length dimensions of the two pieces to be 6 5/8 inches and 6 1/2 inches, respectively, both of which are under the indicated minimum dimension of 7 1/4 inches.

3. Section 5.0 in QI-012 states, in part, " Verify that the piping / tubing l and components . . . material agree with the Bill of Materials shown

.on the Instrument Installation Detail drawing. Tubing is marked with l longitudinal color coded marks for traceability. Use applicable I drawing to identify tubing . . . Verify that the installed tubing has i the proper slope. The required slope for process wetted lines is one (1) inch per foot minimum. This slope requirement may be reduced to i 1/4 inch per foot when physical layout is a problem. Verify that i

there is a proper air gap. The minimum gap spacing shall always be 1/8 inch to allow each instrument sensing line to expand independently at all bends without striking adjacent sensing lines, other equipment, concrete or steel building members."

The applicable inspection checklist used during the ERC reinspection of instrumentation installation Verification Package No. 1-E-ININ-026 showed that the above attributes were inspected and accepted, as evidenced by the inspector's signoff (initials).

However, NRC inspection of the instrumentation installation revealed: 1 (a) Six sections of tubing had no color coding for traceability; (b) Ten sections of tubings, in which physical layout was not a problem, had slopes of 7/16 inch to less than 1/4 inch per foot ,

and one section had reverse slope; and (c) Two tubing sections had zero gap spacing between the high pressure and low pressure legs and the concrete pentration. l

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4. Section 1.7 in QI-012 requires that: (a) tubing bends be verified to have a minimum radius of four times the nominal tube size by using either a template, or by direct measurement and calculations; and (b) the measured and calculated values be entered into the Minimum Bend Radius Record, with date and inspector's initials.

During NRC inspection of Verification Package No. I-E-ININ-04, equipment tag No. 1-FT-156, it was noted that the inspection checklist was dated and initialed, attesting to the fact that the tubing bends had been verified as having a minimum radius of four times the nominal tube size. However, review of the applicable Minimum Bend Radius Record showed that the ERC inspector had neither measured and calculated, nor used a template to verify minimum bend radius. In addition, the following notes had been entered by the ERC l inspector: "Ist 90' bend from instrument (hi & lo side) . . . cannot l be measured with existing tools. Four (4) other bends visually more than 90* to accommodate slope" (445/8514-D-04).

l Texas Utilities Electric Company is hereby required 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 results achieved. (3) corrective steps which will be taken to avoid further deviation from commitments made to the Connission, and (4) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

Dated at Arlington, Texas, this 6th day of March,1986

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