ML20198E838
| ML20198E838 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/12/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20198E698 | List: |
| References | |
| 50-445-85-18, 50-446-85-15, NUDOCS 8605280295 | |
| Download: ML20198E838 (4) | |
Text
w APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Dockets:
50-445/85-18 Comanche Peak Steam Electric Station 50-446/85-15 Units 1 and 2 Permits:
CPPR-126 CPPR-127 During an NRC inspection conducted on December 1-31, 1985, four violations of NRC requirements were identified.
The violations involved failure to certify inspectors in accordance with procedural requirements, excessive conduit length between an end device and its associated junction box, inadequately established design change control measures with respect to assuring performance of required actions, and absence of required identification on thermo-lagged raceways.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are listed below:
A.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGCo Quality Assurance Plan (QAP), 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 3.6.2.b of TUGCo Procedure CP-QP-2.1, Revision 18, states,
" Field Practical Examinations are administered by a cognizant individual certified to a Level III in that activity." Paragraph 3.8 of this procedure requires that waiver documentation for on-the-job training (0JT) specify those procedures for which the individual is certified that form the basis of the OJT waiver.
Contrary to the above:
1.
A field practical examination for civil inspection instruction QI-QP-11.0-15 was administered to an inspector by a Mechanical Level III who was not certified in the activity of this procedure.
The field practical examination was conducted on August 8, 1985, as documented on Attachment 8 of CP-QP-2.1.
2.
0JT waiver forms in four inspector certification files failed to specify the procedures that formed the basis for the waiver; i.e.,
forms dated October 2 and October 28, 1985, for procedure QI-QP-11.10-2A; form dated September 5, 1985, for procedure QI-QP-11.0-15; and form dated November 1, 1985, for procedure QI-QP-11.10-1A.
This is a Severity Level IV violation (Supplement II) (445/8518-V-03; 446/8515-V-02).
B.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31,.1984, of the TUGCo QAP, requires that activities affecting quality shall be prescribed by documented 8605280295 860512 PDR ADOCK 05000445 G
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instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Paragraph 4.4.5 of Gibbs and Hill (G&H) Electrical Erection Specification 2323-ES-100, Revision 2, dated October 15, 1980, requires electrical conduit installation to be in accordance with Drawings 2323-El-1701 and 2323-El-1702.
Detail 18C of Drawing 2323-El-1701 limits the maximum length of conduit from an end device to its associated junction box to 15 feet.
Contrary to the above, the installed conduit lengths for primary coolant sample supply and return isolation solenoid valves 1HV-4631A and 1HV-4631B were observed to be approximately 30 feet.
This is a Severity Level IV violation (Supplement II) (445/8518-V-01).
C.
Criterion III of Appendix B to 10 CFR Part 50, as implemented by Section 3.0, Revision 4, dated November 20, 1985, of the TUGCo QAP, states, in part, " Measures shall be established for the identification and control of design interfaces and for coordination among participating design organizations.
These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces.
Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design Contrary to the above, design change control procedures did not provide for necessary review by and coordination among design interfaces with respect to performance of actions required by design change authorization (DCA) statements / justifications.
For example, DCA 13,023 dated April 20, 1982, replaced a general prohibition in G&H Specification 2323-MS-625 of contact of instrument tubing with galvanized surfaces with only a prohibition for tubing contact where redundant counterparts are routed through the same fire zone.
The DCA engineering justification was based on performance of a damage study walkdown of safety-related tubing in fire zones and accomplishment of required corrective actions.
Engineering damage study walkdown procedures did not, however, require such a walkdown to be performed and the required DCA actions were not accomplished.
This is a Severity Level IV violation (Supplement II) (445/8518-V-15).
D.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGCo QAP, 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.
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3 Brown and Root Procedure CP-CPM 10.3, Revision 9, dated July 2, 1985, requires all thermo-lagged raceways to be permanently identified in accordance with G&H Specification 2323-ES-100.
Paragraph 2.26.5 of G&H Specification 2323-ES-100, Revision 2, dated October 15, 1980, requires use of an alphanumeric code designation and color coding for safety-related conduits and cable trays.
Contrary to the above:
1.
No identification or color codir.g existed on the following thermo-lagged cable trays and conduits:
a.
Cable trays T14GADG02-03, T13GACN02-03, and TI2GA3Q15-16 in Room 214 of the Unit 1 Auxiliary Building; b.
conduit near conduit C1301S570 near the entrance to Rooms 78 and 79 of the Unit 1 Safeguards Building; c.
conduit to cable tray T130 SCC in Room 88 of the Unit 1 Safeguards Building; d.
cable tray T13GACD99 in Unit 1 Safeguards Building at elevation 790 feet (additional numbering problems existed in the adjacent tray section); and e.
conduit which was partially identified as C14Y14 in the Unit 1 Safeguards Building at elevation 832 feet.
2.
No color coding existed on the following thermo-lagged cable trays (designated by letter T) and conduits (designated by letter C):
a.
Unit 1 Safeguards Building T120SBC33, C13015570, C1305968, T12GSBG10 b.
Unit 1 Auxiliary Building C13G13636 C13G15200 C14030880 C14030881 T13GACD10, 24, 26, 38, and 99 T12GABF33 and 36 T130ACA35, 42, and 75 T120ABA13 and 17 T14YAEH19, 20, and 25 T14WAEF19 and 20 This is a Severity Level V violation (Supplement II) (445/8518-V-11).
4 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 the violations if admitted, (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 the response time.
Dated at Arlington, Texas this 12th day of May, 1986.
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