ML20205D102
| ML20205D102 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/18/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20205C998 | List: |
| References | |
| 50-445-86-22, 50-446-86-20, NUDOCS 8703300333 | |
| Download: ML20205D102 (3) | |
Text
APPENDIX B NOTICE OF DEVIATION Texas Utilities Electric Company Dockets:
50-445/86-22 50-446/86-20 Comanche Peak Steam Electric Station Permits:
CPPR-126 Units 1 and 2 CPPR-127 Based on the results of an'NRC inspection conducted on July 1 through August 31, 1986, six deviations from commitments to the NRC were identified.
The deviations consisted of objectivity forms and evaluations that had not been completed for certain members of the Comanche Peak Response Team (CPRT) staff; an Evaluation Research Corporation (ERC) documentation package review had failed to identify four inspectors and two welders involved in the package being reviewed; ERC overview inspection failed to identify deviating conditions and unsatisfactory decisions made by the initial ERC inspector; ERC identified eight deviations on a pump but did not tag the pump; diaphragm valves were purchased to other than the Final Safety Analysis Report (FSAR) committed version of the ASME Code; and ERC engineering did not identify all safety significant attributes on the inspection checklist for mechanical equipment installation.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the deviations are listed below:
A.
TUGCo letters dated January 15 and April 1, 1986, were submitted to the NRC in response to NRC Inspection Report 50-445/85-11; 50-446/85-06.
Commitments in these letters with respect to Item A of the Notic'e of Deviation included, "The completed objectivity criteria forms... for the Senior Review Team, Review Team Leaders and support staff are available in the CPRT central file... ;" and "... appropriate CPRT parties will fill out forms documenting their review of completed objectivity forms....
These forms will be completed by the end of April 1986."
In deviation from the above, (1) support staff for the CPRT Program Director and personnel on the records review committee have not completed their objectivity criteria forms, (2) the review of the completed objectivity forms by the appropriate CPRT party had not been completed for the CPRT Program Director, and (3) review of the TERA Review Team Leader's i
form was not completed until July 17,1986,(4t3/8622-D-01; 446/8620-D-01).
B.
Paragraph 4.1.2.2 of Issue-Specific Action Plan (ISAP) VII.b.1, Revision 2, states, in part, " Review the completed fabrication packages for the selected pieces for adequacy of... fabrication and inspection sign offs."
Items 6 and 7 of the checklist used to implement the above review require the ERC documentation reviewers to list all inspectors and welders 8703300333 070310 ADocK0500g5 on
l 1 involved with the package being reviewed, together with related information such as dates work was performed, certifications, and qualifications.
In deviation from the above, an ERC document reviewer's completed checklist for documentation package RH-1-063-010-522R did not list four inspectors and two welders that had performed work related to the package being reviewed, nor was the required information provided (445/8622-D-03; 446/8620-D-04).
C.
Table 3.2-1 in Section 3 of Amendment 56 to the CPSES FSAR requires that Class 2 and 3 valves meet the requirements of the 1974 Edition of Section III of the ASME Code.
In deviation from the above, Westinghouse Purchase Order (PO) 546-CCA-191000-XN specified the applicable code requirement to be the Summer 1972 Addenda to the 1971 Edition of Section III of the ASME Code for the procurement of Class 2 and 3 ITT Grinnel diaphragm valves.
The vendor furnished valves in accordance with this requirement as evidenced by the NPV-1 form for Valve Tag 1-7046 which states, "The material, design, construction, and workmanship complies with ASME Code Section III, Class 3, 1971 Edition, Summer 1972 Addenda: (445/8622-D-06).
D.
Section 4.3.3 of ISAP VII.c states, in part, "For each population, attributes which have safety-significance will be determined...
Justification for not including attributes in the reinspection or documentation review checklists which have been identified as nonsafety significant will be documented and retained, detailed instructions for the verification of the attribute, including definitive accept / reject criteria, will be established...."
In deviation from the above, ERC engineering, during review of historical documentation pertaining to Verification Package I-M-NEIN-107, failed to address the following work activities with respect to safety significance, (1) thread engagement for Richmond insert stud bolts used for equipment anchoring, (2) torquing requirements which were documented by construction operation travelers, and (3) installation of oil cooler piping which was documented by a construction operation traveler.
There was no documented justification for not including these attributes in the checklists nor were detained instructions established for attribute verification (445/8622-D-09).
E.
Section 5.1 of ERC Procedure CPP-010, Revision 7, states, in part, with respect to ISAP VII.c, " Inspectors shall identify the hardware associated with each (construction) deviation by attaching a tag in a conspicuous location...."
In deviation from the above, the NRC inspector observed that positive displacement pump TBX-CSAPPD-01, Verification Package I-M-MEIN-107, was not tagged even though eight deviation reports had been issued with respect to noncomplying nut torque requirements and mechanical coupling alignment (445/8622-D-10).
. F.
Section 4 of ERC Procedure CPP-009, Revision 4, states, in part, with respect to ISAP 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...."
Section 4 in Revision 2 to ERC Quality Assurance Procedure ERC-QA-28,
" Performance of Overview Inspections," states, in part, " Qualified QA/QC Review Team personnel assigned to the onsite QA Representative perform Overview Inspection of work performed in accordance with Reference 3.1 (CPP-009)...."
Section 5.4 states, in part, " Based upon each accept /
reject criterion specified in the referenced QI/ Effective Change Notice (s), the OI (Overview Inspector) denotes whether the item is (un) acceptable... The 01 compares the results of the Overview Inspection with the results of the initial reinspection / documentation review to identify any apparent inconsistencies...."
In deviation from the above, Overview Inspection Package I-M-B-SBCO-121 failed to identify two unsatisfactory decisions made by the initial ERC inspector. During an NRC inspection, two conditions were identified of pipe-to-hanger clearance violations of Section 5.2.6 in Revision 2 of QI-026. The initial ERC reinspection as well as the overview inspection failed to identify these deviating conditions (445/8622-D-14).
Texas Utilities Electric Company is hereby requested to submit to this office, within 30 days of the date of this letter transmitting this Notice, a written statement or explanation in reply, including for each deviation:
(1) the reason for the deviation 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 deviations, and (4) the date when full compliance will be achieved. Where good tause is shown, consideration will be given to extending the response time.
Dated at Arlington, Texas this 18th day of March 1987