ML20206E798

Notice of Deviation from Insp on 860901-1031

ML20206E798
Person / Time
Site:	Comanche Peak
Issue date:	04/02/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20206E792	List: IR 05000445/1986026 ML20206E788 ML20206E793 ML20206E798 ML20206E812
References
50-445-86-26, 50-446-86-22, NUDOCS 8704130740
Download: ML20206E798 (3)

Text

APPENDIX B NOTICE OF DEVIATION 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 Based on the results of an NRC inspection conducted on September 1 through October 31, 1986, deviations from commitments to the NRC were identified. The deviations consisted of an Evaluation Research Corporation (ERC) inspector failed to write an out-of-scope memorandum documenting a potentially nonconforming condition, ERC's craft training procedure review failed to identify the lack of a Bahnson personnel retraining requirement and thus failed to recommend procedure improvement, substantive changes to an Issue-Specific Action Plan (ISAP) were made and implemented prior to approval by the Senior Review Team, ERC engineering failed to identify all the HVAC activities and attributes to be included in review and inspection checklists, and ERC inspections in the HVAC area were based on documents different than those used for the inspection of record. 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. Paragraph 5.1.1 of ERC Procedure CPP-020, Revision 1, dated September 23, 1985, states, in part, "Should any QA/QC Review Team personnel observe an apparent defect or discrepancy which is out-of-scope, they are to prepare a memorandum . . . . This memorandum shall be addressed to the TUGCo QA Coordinator . . . ."

In deviation from the above, an ERC inspector failed to write an out-of-scope memorandum for a pull rope found in conduit C12018896 during the ERC inspection for Verification Package I-E-EEIN-024 (445/8626-D-01).

B. Section 4.1.2 of ISAP I.d.3, Revision 0, requires, in part, that ERC perform an evaluation of the craft training procedures including training and retraining, and that the following items will be considered during this evaluation:

"How craft personnel become aware of changes in design and con'truction requirements and how retraining occurs."

"How craft personnel are informed and become knowledgeable of QA/QC requirements / criteria and changes to those requirements / criteria."

Section 4.1.3 of the ISAP also states, in part, " Based on this review (of procedures), conclusions will be drawn by the QA/QC Review Team Leader as to the adequacy of both past and current practices used for craft selection and training. If current procedures are determined to be inadequate, recommendations for improvement will be provided to TUGC0 prior to the closure of this action plan."

g413074o870402 G ADOCK 05000445 PDR

2 In deviation from the above, ISAP-I.d.3 Results Report does not provide a recommendation that TUGCo revise the Bahnson Service Company's craft training Procedure QCI-CPSES-013, " Indoctrination and Training of Personnel," which does not assure that: (1) " craft personnel become aware of changes in design and construction requirements"; and (2) " craft personnel are informed and become knowledgeable of QA/QC requirements / criteria and changes to those requirements / criteria" (445/8Q6-0-03; 446/8622-D-01).

C. The W. G. Counsil letter (CPRT 207) to the NRC, dated January 27, 1986, regarding CPSES submittal of Revision 3 of the Comanche Peak Response Team (CPRT) Prograa Plan and ISAPs, committed that, ". . . further substantive modifications to these documents (CPRT Program Pian ISAPs) will require the approval of the Senior Review Team prior to implementation."

Change Notice 001 to Comanche Peak Project Procedure CPP-024, " Issue Specific Action Plan Revision," dated April 4, 1986, requires that

". . . the SRT approves substantive changes prior to implementation."

In deviation from.the above, substantive changes to ISAP I.d.3 were implemented prior to approval by the Senior Review Team (SRT). For example, in April 1986 the Special Evaluation Team's effort was

- transferred to Quality Assurance / Quality Control (QA/QC)' review team personnel and the issue coordinator was changed; however, the SRT did not

. approve these and otner changes until August 1986 (445/8626-D-04; 446/8622-D-02).

D. Paragraph 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 t.een identified as s

nonsafety-significant will be documented and retained as records in the ISAP file. For each safety-significant attribute identified, detailed

instructions for the verification of the attribute, including definitive

! accept / reject criteria, will be established . . . ." .

In deviation from the above, ERC engineering failed to identify certain work activities and attributes associated with fabrication and installation of HVAC ducts and plenums which occurred prior to 1982.

These activities / attributes included: (1) welded nuts on the interior of seismic volume extractors, and (2) crimps used for attaching various accessories; such as, grills, registers, and associated sealant material.

The failure to iaentify these activities / attributes precluded determination of safety significance. Further, +.here was no justification for not including these activities / attributes in the reinspection or documentation review checklists (445/8626-D-06).

E. Section 2.0 in Revision 1 of both QI-035 and QI-036 requires that reinspection and documentation review be performed on only those duct supports which have been installed and final QC accepted by Bahnson

3 Service Company (BSC). Section 5.0 in QI-036 requires the initiation of a deviation report (DR) for any applicable HVAC duct support attributes identified as not having been inspected by BSC.

In deviation from the above, the following conditions were identified:

1. The documentation review verification packages issued to ERC

-inspectors for Unit 1 and common HVAC duct supports, contained the applicable BSC inspection reports and the BSC detail drawings which were supposed to represent the installed and final QC accepted supports.

2. The NRC inspector identified that the BSC inspection reports were dated as much as 5 years prior to the initial issue of the detail drawings.

3. There was no evidence of inspections performed by BSC QC to verify the duct support configuration to the detail drawing.

4. It was further determined that BSC QC used typical drawings for their inspections. These drawings can be dissimilar to the detail drawings provided to ERC. As a result, the ability of ERC to identify attributes not inspected by BSC was affected; thus initiation of all required DRs was precluded (445/8626-D-07). ,

Texas Utilities Electric Company is hereby requested 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 deviation: (1) the reasons for the deviations if admitted, (2) the corrective steps which have been taken and the results achieved, (3) corrective steps which will be taken to avoid further deviations, 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 2nd day of April 1987

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