ML20206E793
| ML20206E793 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/02/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20206E792 | List: |
| References | |
| 50-445-86-26, 50-446-86-22, NUDOCS 8704130739 | |
| Download: ML20206E793 (3) | |
Text
APPENDIX A NOTICE OF VIOLATION t
Texas Utilities Electric Company Dockets:
50-445/86-26 50-446/86-22 Comanche Peak Steam Electric Station, Permits:
CPPR-126 Units 1 and 2 CPPR-127 During an NRC inspection conducted on September 1 through October 31, 1986, violations of NRC requirements were identified.
The violations involved cable pulling ropes left in Unit 1 conduits and cable trays, a log documenting potentially nonconforming items was discarded without the items being dispositioned, potentially nonconforming items being documented on request for inspection forms were not being effectively tracked or accounted for, and Bahnson Service Company welders were improperly certified.
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 V of Appendix B to 10 CFR Part 50, as implemented by the TUGCo Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Paragraph 3.1.2.e of TUGCo Procedure QI-QP-11.3-40, Revision 14, dated January 9, 1984, states, in part, " Verify that... all cable pulling aids have been removed (i.e., fish tape, tape rope, etc.)."
Paragraph 3.1.1.2.c of the above procedure, Revision 18, dated May 18, 1984, states, " Verify that... pulling aids (i.e., rollers, fish tape, tag rope) have been removed from raceway."
Contrary to the above, TUGCo inspectors performing post construction inspections failed to identify cable pulling ropes remaining in Class 1E conduit C12018896 and Class 1E cable tray T130ACG57 located in the Unit 1 reactor building and auxiliary building, respectively.
This is a Severity Level IV violation (Supplement II) (445/8626-V-02).
B.
Criterion IX of Appendix B to 10 CFR Part 50, as implemented by the TUGCo QAP, Section 9.0, Revision 5, dated November 20, 1985, states, in part,
" Measures shall be established to assure that special processes, including welding... are controlled and accomplished by qualified personnel
... in accordance with applicable codes, standards, specifications...."
Bahnson Service Company's Procedures DFP-TUSI-001, Revision 8, dated February 26, 1981, "Ductwork Fabrication Procedure," and DFP-TUSI-003, Revision 7, dated May 6, 1981, " Duct Support Fabrication & Installation 8704130739 8704o2 DR ADOCK 05000445 PDR
2 Procedure," require that all welders performing work on duct supports and seismic support systems shall be qualified to Section IX of the ASME Code.
Paragraph QW-301.2 in Section IX of the ASME Code states, in part, "Each manufacturer or contractor shall qualify each welder or welding operator for each welding process to be used in production welding...."
QW-301.4 states, in part, "Information regarding the essential variables and the test results obtained by each welder... shall be recorded on a Record of Performance Qualification Tests."
Contrary to the above, with respect to position limitations and qualified material. thickness ranges, Bahnson Service Company's welder performance qualification ~ records dated May 1979, June 1981, and March 1983, certify their welders as being qualified in more positions and material thickness ranges than allowed by the reported number of test results.
This is a Severity Level IV violation (Supplement II) (445/8626-V-08; 446/8622-V-05).
C.
Criterion XV of Appendix B to 10 CFR Part 50 requires that measures be established to prevent the inadvertent use of nonconforming items, and that these measures include procedures for identification, documentation, segregation, disposition, and notification to affected organizations.
Section 15.0, Revision 5, dated October 18, 1985, of the TUGCo QAP states, in part, "The identification, documentation, segregation, and disposition of nonconforming materials, parts, and components is outlined in written procedures....
The procedures, as a minimum... require investigation of the nonconforming item, decisions on their disposition, and preparation of adequate reports....
A nonconformance report is used to document deficiencies (nonconforming items) unless another method is prescribed by a specific procedure / instruction."
Contrary to the above, systems other than nonconformance reports exist.and have existed on-site which identify potentially nonconforming items, but no specific procedures or instructions have been developed that prescribe the method by which compliance with Criterion XV is achieved.
Examples of this violation are:
1.
From August 1985 through April 1986 the TNE Unit 1 Task Group conducted walkdowns of electrical conduit for the purpose of developing as-built isometric drawings.
Potentially nonconforming items that were identified, but outside the scope of this walkdown effort, were documented in a " Problem Log" for disposition at a later time.
The " Problem Log" was not defined or controlled by procedures or instructions.
This violation example is further complicated since the " Problem Log" was discarded when Ebasco assumed this walkdown
3 responsibility from the Unit 1 Task Group in May 1986 and there is no evidence of what the items on the log were or that any were dispositioned.
This is a Severity Level IV violation (Supplement II)
(446/8622-V-06).
2.
Currently the electrical conduit walkdowns being performed by Ebasco are prescribed in Procedure TNE-FVM-CS-014 Revision 3. "As-built Field Verification Method-Design Control of Electrical Conduit Raceways for Unit 2 Installation in Unit 1 and Common Areas, Class 1."
Potentially nonconforming items identified during these walkdowns that are outside the scope of this effort are documented on a form, " Request for Inspection," per Procedure TNE-FVM-CS-014.
While this procedure requires these items be documented, it fails to prescribe the method by which these items will be tracked, how they will be accounted for, or how disposition / follow-up will be assured.
This is a Severity Level IV violation (Supplement II)
(446/8622-V-07).
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 dcte 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, 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 your response time.
Dated at Arlington, Texas this 2nd day of April 1987 4
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