ML20195F905

Notice of Violation from Insp on 881005-1101.Violation Noted:Inspector Indicated Adequate Thread Engagement, However,No Documentation Exists as Verification

ML20195F905
Person / Time
Site:	Comanche Peak
Issue date:	11/18/1988
From:	Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20195F904	List: ML20195F900 ML20195F905 ML20195F910
References
50-445-88-71, 50-446-88-67, NUDOCS 8811220407
Download: ML20195F905 (3)

Text

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APPENDIX A NOTICE OF VIOLATION TU Electric Dockets: 50-445/88-71 50-446/88-67 l Comancho Peak Steam Electric Station Permits: CPPR-126 l Units 1 and 2, Glen Rose, Texas CPPR-127 l

l l During an NRC inspection conducted on October 5 through November 1, 1988, violations of NRC requirements were identified. In l accordance with the "General Statement of Policy and Procedure for l NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the l violations are listed below:

l l A. Critorion V of Appendix B to 10 CFR Part 50, as implemented by I

Section 5.0, Revision 0 of the TU Electric Quality Assuranco Manual states, "Activitics affecting quality shall bc prescribed by documented instructions, procedures, or I drawinga, or a type appropriato to the circumstances and shall be accomplished in accordance with those instructions, procedures, or drawings. Instructions, procedures, or drawings zhs)1 include appropriato quantitative or qualitativo aCCoptanCO 771teria for determining that important activit10S havia been satisfactorily accomplished."

Contrary co the above, Post Constructio,. Hardware Validation Program (PCHVP) Procedu.rcs Field Verification Method (FVM)-081 and FVM-090 do not provide documented instructions appropriate for performing technical dispositions of inaccessible l

attributes exempted from reinspeccion by Design Chango Authorization (DCA) 58252. Furthermore, the "uso-as-is" disposition aa71gned to Non'onformanco Report (NCR) 87-02743 and other similar NCRs, may not be applicable for the affected components because the technical justification is dependent on a futuro evaluation.

This is a Severity Level IV violation ('3upr' sont II)

(445/8871-V-04).

B. Criterion X of Appendix B to 10 CFR Fart 50, .mplemented by Se'.. ion 10.0, Revision 0, of the TU Electric voclity Assurance Manual, states, in part, "A program for inspection of activities affecting quality shall be established and executed . . . to verify conformance with the documented l 8311220407 931118 t

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, instructions, procedures, and 1*4 wings for accomplishing the i i activity." l QAP 12.1, Attachment 7.12, requires that the inspector ensure that spring hangers have proper thread engagement. I c ontrary to the above, on spring hanger SI-1-336-001-S225, the  ;

i inspector indicated that there was adequato thread engagement; [

however,'no documentation exists co indicate how this was i

verified and thoro is no sight hole in the load coucling of ,

the spring to permit observation of the thread engagement.  :

$ This is a Severity Level IV violation (Supplement II)  !

j (445/887A-V-02).  !

g C. Criterion III of Appendix B to 10 CFR Part 50, as implemented ,

l by Section 3.0, Revision 0 of the TU Electric Quality t i'

Assurance Manual, states, in part, "Measures shall also bo .

established for the selection and review for suitability of f application of materials, parts, equipment, and processes that f are essential to the safety-related functions of the 3 structures, systems and components . . . . " l

) Paragraph 6.3.c of ECE-5.19, Revision 2, states, la part, "The l l RE (Responsible Engineer) assigned to perform the review of

• 1 the vendor document sPall ensure that the following Accms are considered as appropriato or applicabic l i  !

j "o The material , equipment, document, Service, or process is [

in compliance with CPSES design requirements . . . ." l

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Contrary to the r.bove, the NPSI sizo SRF-08 sway strut used i

{ with an SPC-08-100 piro clamp used on support  !

i SW-1-132-039-A43R does not provide the cicarance necessary to l l accommodate the amount of angular aisalignment racessary for maximum movement during operation.

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This is A Severity Level IV violation (Supplomont II)

(445/8371-V-03),

t Pursuant to the provisions of 10 FFR 2.201, TU Electric is hereby t iequired to submit a written statement or explanation to the U. S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, l, Washington, DC, 20555, with a copy to the Assistant Director for l Inspection Programs, Comanche Peak Project Division, Offico of Special Projects, within 30 days of the date of the letter i transmitting thir, Notice. This reply should be clearly marked 3'i a I "Reply to a Notice of Violation" and should include for chch violation (1) the reason for the violation if admitted. (2) the ,

corrective steps that have been taken and the results achieved, I (3) the corrective steps that will be taken to avoid birther violations, and (4) the date when full compliance will be achieved. {

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t If an adequato reply is not roccived within the timo specifiod in this Notico, an order nov bo issued to show causo why the licenso should not be mooified, suspended, or revoked or why such other 1 action as may be prop (r should not be taken. Where good cause is y shown, consideration will be given to extending the responso timo.  !

FOR THE NUCLEAR REGULATORY COMMISSION

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Dated at Comancho Peak Site  !

this 18th day of November 1988 j

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