ML20205L212

Notice of Violation from Insp on 860401-0531

ML20205L212
Person / Time
Site:	Comanche Peak
Issue date:	03/30/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20205L149	List: ML20205L145 ML20205L212 ML20205L235 ML20209A367
References
50-445-86-08, 50-445-86-8, 50-446-86-06, 50-446-86-6, NUDOCS 8704020140
Download: ML20205L212 (2)

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APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Dockets: 50-445/86-08 50-446/86-06 Comanche Peak Steam Electric Permits: CPPR-126 Station, Units 1 and 2 CPPR-127 During an NRC inspection conducted on April 1 through May 31, 1986, two violations of NRC requirements were identified. The violations involved:

failure of Brown & Root Inc., (B&R) to fully perform annual audits of their ASME QA program during 1980, 1982, and 1984, and to provide adequate documentation of audits of field design changes and special processes; and failure of TUGCo to adequately follow up on the corrective action commitments for an audit deficiency. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986),

the violations are listed below:

A. Criterion XVIII of Appendix B to 10 CFR Part 50, as implemented by TUGCo Quality Assurance Plan (QAP) Section 18.0, Revision 2, dated July 31, 1984, and FSAR, Section 17.0, requires that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program to determine the effectiveness of the program, and that they be performed in accordance with procedures or checklists, and that results be documented, and followup action, including reaudit of deficient areas, shall be taken.

1. Failure to Fully Audit the B&R ASME/QA Program FSAR, Section 17.1.18, " Audits," requires that planned and periodic audits be performed to verify compliance with all aspects of the quality assurance program and to determine the effectiveness.

B&R ASME/QA Manuals in effect since November 19, 1976, to the present require the B&R QA manager to assure that their ASME QA program is audited at least annually.

Contrary to the above, B&R failed to annually audit the entire ASME/QA program as evidenced by the failure to audit 12 of 20 sections of the QA Manual in 1980, 6 sections in 1982, and 8 sections in 1984 (445/8608-V-01; 446/8606-V-01).

2. Failure to Provide Adequate Documentation to Support Implementation of B&R Audit Program B&R QA Manual, Section 19.0, issued September 17, 1981, requires that measures be established for an audit program that will provide objective evidence of compliance with the QA manual; compliance with pertinent specifications, codes, and procedures; and a method of keeping management informed of QA program effectiveness.

8704020140 870330 PDR ADOCK 05000445 G PDR

2 Contrary to the above:

a. B&R failed to provide adequate documentation in audit reports CP-18 (1981), CP-21 and 24 (1983) and CP-27 (1985) and/or checklists to show that the implementation of field design change procedures and controls were audited (445/8608-V-02; 446/8606-V-02).

b. B&R failed to provide adequate documentation in audit reports CP-18 (1981) throughCP-31(1986) and/or checklists to show that the implementation of special process procedures and controlswereaudited(445/8608-V-03;446/8606-V-03).

This is a Severity Level IV violation. (Supplement II)

B. Criterion XVI of Appendix B to 10 CFR Part 50, as implemented by FSAR, Section 17.0, and TUGCo QAP, Section 16.0, Revision 0, dated July 1, 1978, requires that conditions adverse to quality be promptly identified, reported, and corrected.

Failure to Verify Correction of An Audit Deficiency FSAR, Section 17.1.16, states that TUGCo require measure be established to assure that conditions adverse to quality are promptly identified, reported, and corrected.

TUGCo Procedure CQI-CS-4.6, Revision 3, dated August 8, 1982, states in part, " Verification of implementation of corrective actions shall be accomplished by appropriate means."

Contrary to the above. Audit Deficiency No.1 of TUGCo QA Audit TCP-51 (September 1982) was improperly closed out. That is, the auditor did not verify the implementation of comitments to correct the deficiency prior to closing the audit finding. Records show that in this case TUGCo had initiated plans for resolving the audit deficiency over an extended period of thetime, and eventually operation resolved the audit travelers (445/8608-V-08; deficiency)through 446/8606-V-10 . review of This is a Severity Level V violation. (Supplement II) l 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 reasons for the violations if admitted,  ;

the corrective steps which have been taken and the results achieved, the corrective steps which will be taken to avoid further violations, and the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending your response time.

Dated at Arlington, Texas, ,

this 30th day of March 1987 l

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