ML20207E083
| 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: |
| 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
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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,
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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:
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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.
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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
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Section 3.0, Revision 4, dated November 20, 1985, of the TUGCo QAP, 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
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Engineeringi(TNE).-in response to Evaluation Research Corporation's 4 7% g 1 Technical 1Information Request:(TIR) No.-TIR-017~ dated August 26, 1985, a,
y - niprovided design information_which delineated;the_ acceptance criteria for g, ; base material defects on field fabricated tanksL 1TNE's method for
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s (verifyingathe' adequacy of'the design;information was by the use of-
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- calculations. u However, as: of May ?15,1986, those-calculations:were Jncomplete: andfunapproved.:
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Thisiis.'a Severity Level IV violation (Supplement II) (445-8607-V-02).
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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! Administrative a
iProcedure CP-SAP-13; " Temporary System Modifications," dated December 9,
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11985,istates, in part. " Temporary modification tags shall?beffilled'out W' f
- and 'placed on all-modifications -re' quired to be' logged and tagged..., a Log Sheet shal.1 be filledLout..l.7,fand lifted-' leads s, hall,be suitably "
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3 JParagraphi4.2.4 of.CPSES Station Administrative Manual > Procedure STA-602,
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' " 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 (lifted' lead.... or placed.as close to the modification as possible."
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l Contrary;to the_above:
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LThe white conductor of: cable-EG123389 was'found lifted in Unit 1 I
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).
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-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 Jthat' activities affecting quality shall be prescribed by and accomplished o
lin:accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
- .7 Drawing-2462-1005, sheet 1, Revision CP-1, requires that identification be 4-E
.provided' adjacent to " components."
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^" E 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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K.This11sia: Severity Level V violation (Supplement II) (445/8607-V-20).
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iCriterionVifAppendixBto:10CFRPart50,asimplementedby c
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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. Paragraph;2.1.3 of TNE Procedure TNE-DC-7, Revision 16, dated February 14,-
71986, " Preparation-and Review of Design Drawings,'! requires that completed
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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:
1.
Drawing 2323-El-0172, ~ sheet 17, identified cable EG120248 as EG20248.
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'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 orange' conductor of cable EG130012 landed at terminal TCA-7; the z.
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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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 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
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~ 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.
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JIn addition,:the traveler which was used to implement the design change
- did 'not document alliof the changes that occurred.
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{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 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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