ML20207E083

Notice of Violation from Insp on 860401-0531

ML20207E083
Person / Time
Site:	Comanche Peak
Issue date:	12/22/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207E070	List: IR 05000445/1986007 ML20207E068 ML20207E083 ML20207E108 ML20207E151
References
50-445-86-07, 50-445-86-7, 50-446-86-05, 50-446-86-5, NUDOCS 8701020060
Download: ML20207E083 (4)

Text

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J APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Dockets: 50-445/86-07 Comanche Peak Steam Electric Station (CPSES) 50-446/86-05 .

Units 1 and 2 Permits: CPPR-126 )

CPPR-127 During an NRC inspection conducted on April 1 through May 31, 1986, six

' violations of NRC requirements were identified. The violations involved a corrective action report (CAR) that was closed before corrective action was "d -

complete, timely criteria for base metal defect inspections were not provided, }

temporary modification to cables was not properly documented, terminal blocks .*

were not identified, drawing errors were not identified during reviews and checks, and design changes were not reviewed by those responsible for the original design. 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

-Section 5.0, Revision 3, dated July 31, 1984, of the TUGCo Quality j_

Assurance Plan (QAP), requires that activities affecting quality shall be g prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.

Paragraph 3.2.3 of TUGCo Procedure CP-QP-17.0, Revision 6, states, in s part, " Corrective Action Reports shall remain open until all of the -

required corrective action has been completed." ".

Contrary to the above, CAR-049 was closed before corrective action was 5 completed and more importantly, ufore the corrective action was clearly i defined. CAR-049 was closed on January 16, 1986, on the basis of a memo ,

(C."DA-47,715) dated November 26, 1985, which stated that Unit 2 limit 7 switch terminations would be identified upon issuance of DCA-23,473; g however, this Design Change Authorization (OCA), issued on December 4, 2 1985,hadnorequirementtoidentifyorcorrectpreviouslyinstalledlim1S 3 switch terminations on Unit 2. _g n

This is a Severity Level IV violation (Supplement II) (445/8607-V-24).

i B. 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,

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states, in part, " Measures shall be established to assure that applicabie K regulatory requirements and the design basis . . . are correctly  ;

translated into specifications, drawings, procedures, and q instructions . . . . The design control measures shall provide for T verifying or checking the adequacy of design, such as . . . by the use of $_

alternate or simplified calculational methods . . . . The design control #

measures shall be applied to items such as . . . delineation of acceptance c criteria." ,

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Contrah toLthe above, on. Sept' ember 25.1985, TUGCo_ Nuclear g N Engineeringi(TNE).-in response to Evaluation Research Corporation's 1 Technical 1Information Request:(TIR) No.-TIR-017~ dated August 26, 1985, 4 7% g a, y - niprovided design information_which delineated;the_ acceptance criteria for ~

.. s g , ; base material defects (verifyingathe' adequacy onof'the

field fabricateddesign;information tanksLwas 1TNE's by the method use of- for

- 'd  : calculations. u However, as: of May ?15,1986, those-calculations:were .

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, Thisiis.'a Severity Level IV violation (Supplement i II) (445-8607-V-02).

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R$ - C. Criterion ~V2of; Appendix?B to-10 CFR'Part-50,.as implemented by .

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1 (Section'.5.0,1 Revision 3,: dated July 31,,1984 -of:the TUGCo.QAP, dated LJuly 31,41984,1 requires that- activities affecting quality _shall be '

,  : prescribed by and accomplished in accordance with documented; instructions,-

y proce.dures,for drawings of a type _ appropriate 1to the_ circumstances, b'l "

' :Paragr'phf4.0.ofRevision'6to)CPSESStartup!

a iProcedure CP-SAP-13; " Temporary System Modifications," dated December 9, Administrative 11985,istates, in part. " Temporary modification tags shall?beffilled'out

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and 'placed on all-modifications -re' quired to be' logged and tagged . . . , a

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Log Sheet shal.1 be filledLout . .l.7,fand lifted-' leads s, hall,be suitably "

i nsu,l a ted. " '

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• JParagraphi4.2.4 of.CPSES Station Administrative Manual > Procedure STA-602,

' " Temporary Modifications," Revision 1. dated March;5,1986,' states, in

.- _ 7 'part,'"Each temporary modification will be clearly identified with 'a e

_ Temporary Modification Tag . ._. -The tag normally will be hung on the S* (lifted' lead . ... or placed.as close to the modification as possible."

l Contrary;to the_above:

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LThe white conductor of: cable-EG123389 was'found lifted in Unit 1 Termination Cabinet'4 without being tagged, logged, or insulated.

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, . 2. Th'e black conductor'of cable EG106004 was found lifted in Unit 1 Control' Room Relay Rack No. 2 without being tagged or logged. This

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conductor was subsequently reconnected without documentation of the nonconforming condition.

' :This ista Severity Level IV violation (Supplement II) (445/8607-V-21).

W -D. Criterion V of Appendix B to 10 CFR Part 50, as implemented by f Section 5.0, Revision 3, of the TUGCo QAP dated July 31, 1984, requires o Jthat' activities affecting quality shall be prescribed by and accomplished lin:accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.

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4- Drawing-2462-1005, sheet 1, Revision CP-1, requires that identification be E .provided' adjacent to " components."

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Contrary to the above, except for TB-53, -54, -55, the terminal ~ blocks in y _

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• 1' Control' Room Panel .CP1-ECPRCR-01 were not identified.

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? g K.This11sia: Severity Level V violation (Supplement II) (445/8607-V-20).

c E. iCriterionVifAppendixBto:10CFRPart50,asimplementedby iSection '5.0, Revision'3 of the TUGCo" QAP dated ' July 31, 1984, requires e  ;' sthatJactivities affecting quality shall be prescribed by and accomplished fin;accordance with documented instructions, procedures, or drawings of a W -

type appropr.iate-to the circumstances.

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L . Paragraph;2.1.3 of TNE Procedure TNE-DC-7, Revision 16, dated February 14,-

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. 71986, " Preparation-and Review of Design Drawings,'! requires that completed drawings shall be checked for accuracy and compliance. Paragraph 2.1.4 also: requires an engineering review for technical accuracy upon completion

, ,- of-the; drafting / design check.

' Contrary to the above, drawings were-not appropriately reviewed / checked

ifor, accuracy. 'The following drafting errors were involved with w, unsatisfactory:itemsLidentified during inspections related to ISAP I.a.4:

,y1 1. Drawing 2323-El-0172, ~ sheet 17, identified cable EG120248 as EG20248.

'2. .The white conductors of-cables EG109964, EG109975, EG109963, and EG109764 wereinot shown on Drawing 2323-El-0156, Revision CP-1.

3. LDrawing 2323-El-0156, Revision CP-7, shows the green conductor of cable EG118347 landed at terminal TCA-5; the conductor actually installed is white with a black stripe. This drawing also showed the

z. orange' conductor of cable EG130012 landed at terminal TCA-7; the conductor' physically installed was black from cable EG118347A. There was no " cloud" on the drawing to indicate that this was a design change.

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4. Drawing 2323-El-0172, sheet 17, Revision CP-4, did not identify the

, color'of the conductor to be landed at TB2-31.

Thi.s is a Severity Level IV violation (Supplement II) (445/8607-V-22).

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F. ' 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, ". . . . Design changes, including field changes, shall l be subject to design control measures commensurate with those applied to 1the original design and approved by the organization that performed the original. design . . . ."

' , Contrary to the above, field design changes, pertaining to the  !

installation of stainless steel shims between the reactor coolant system l

[ ~ crossover leg piping and saddle blocks, were not submitted to the i

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.. organization that performed the original design for review and approval.

9 y JIn addition,:the traveler which was used to implement the design change

did 'not document alliof the changes that occurred.

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1. {This is a Severity Level IV violation l(Supplement II) (445/8607-V-04).

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? Pursuant to th'e, provisions of 10.CFR 2.201, Texas Utilities Electric Company is T' .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, Lincluding for each violation:- (1) the reasons for the violations if admitted, T 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

1. 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,l Texas

. - -this 22nd day ~of December 1986 s

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