ML20207F110
| ML20207F110 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/30/1986 |
| From: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8701050449 | |
| Download: ML20207F110 (2) | |
See also: IR 05000445/1985014
Text
,r , ,
DEC 301986
In Reply Refer To:
Dockets: 50-445/85-14
50-446/85-11
Texas Utilities Generating Company
ATTN: Mr. W. G. Counsil
Executive Vice President
400 North Olive, L.B. 81
Dallas, Texas 75201
Gentlemen:
Your letter of May 16, 1986, in response to our letter and attached Notice of
Violation and Notice of Deviation dated March 6, 1986, was acknowledged by our
letter of June 16, 1986. As a result of review made during followup inspection
of your corrective actions, we find that a clarification is required relative
to your response to item D in the Notice of Violation. Specifically, the stated
reason for the violation correctly indicated th t TUGCo Nuclear Engineering
(TNE) Procedure THE-AD-4 was not followed concerning maintenance of duplicate
copies of engineering documents. The response does not address or consider,
however, that the NRC inspector was informed by an engineering supervisor during
the inspection that, due to organizational changes, Procedure CP-El-18.0-4,
Revision 0, had been deleted and shipment was made without a procedure being
in effect. In that this information is believed to have a bearing on the
scope of required steps to avoid recurrence (i.e., was training given to
engineering personnel concerning procedures in existence in the organization
to which they transferred?), you are requested to review this matter and
provide a supplemental response within 20 days of the date of this letter.
Sincerely,
t
6 MdL//
E. H. Johnson, Director
Division of Reactor Safety
and Projects'
cc:
Texas Utilities Electric Company
ATTN: G. S. Keeley, Manager
Licensing
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas 75201
/
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. _ - _ _ _
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Texas Utilities Generating Company 2
Juanita Ellis
President - CASE
1426 South Polk Street
Dallas, Texas 75224
Renea Hicxs
Assistant Attorney General
Environmental Protection Division
P. O. Box 12548
Austin, Texas 78711-2548
Administrative Judge Peter Bloch
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Elizabeth B. Johnson
Administrative Judge
Oak Ridge National Laboratory
P. O. Box X. Building 3500
Oak Ridge, Tennessee 37830
Dr. Kenneth A. McCollom
1107 West Knapp
Stillwater, Oklahoma 74075
Dr. Walter H. Jordan
881 Outer Drive
Oak Ridge, Tennessee 37830
Anthony Roisman, Esq.
Executive Director
Trial Lawyers for Public Justice
2000 P. Street, N.W. Suite 611
Washington, D.C. 20036
Texas Radiation Control Program Director
>cc to DMB (IE01)
bec distrib, by RIV:
'RPB * MIS System
- RRI-OPS *RSTS Operator
- RRI-CONST *R&SPB
- T. F. Westerman, RSB DRSP
L. Chandler, 0GC *RSB
- RIV File J. Taylor, IE
- D Weiss, RM/ALF J. Conklin, IE
- l. Barnes, CPTG * Project Inspectoe
- w/766
. _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
' *
,. Log # TXX-4779
Filo # 10130
IR 85-14
' d5-11
TEXAS UTILITIES GENERATING COMPANT
ABETW AV TOWER e 400 NORT,6 OLIVR dBTREE f. B.R. e 8 e BDALLAs. TEXAR 78308
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Mr. Eric H. Johnson, Director
Wr2P885 %n
Division of Reactor Safety and Projects t D'
-
U. S. Nuclear Regulatory Commissior.
611 Ryan Plaza Drive, Suite 1000 -
Arlington, Texas 76012
SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
,
DOCKET NOS. 50-445 AND 50-446
RESPONSE TO NRC NOTICE OF VIOLATION
INSPECTION REPORT NO.: 50-445/85-14 AND 50-446/85-11
Dear Mr. Johnson:
We have reviewed your letter of March 6, 1986, concerning the inspection by
Mr. T. F. Westerman and others of the Region IV Comanche Peak Group during
the period Septe..ber 30 through October 31, 1985. This inspection covered
activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for
Comanche Peak Stear Electric Station Units 1 and 2.
We requested and received a four week extension in providing our response
during a telephone discussion on April 7, 1986. We requested and received
an additional two week extension during a telephone discussion on May 2,
1986. We have provided our response to the Notice of Violation and the
Notice of Deviation in the attachments to this letter. To aid in
understanding our response, we have repeated the Notice followed by our
response.
Very truly yours,
7
W. G. Counsil
JWA/arh
c- Region IV (Original + 1 copy)
Director, Inspection and Enforcement (15 copies)
U. S. Nuclear Regulatory Commission
Washington, D.C. 20555
Mr. V. S. Noonan
Mr. D. L. Kelley
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? NRC Notice of Violation
Item A (445/8514-V-01)
4
Criterion XVII of Appendix B to 10CFR Part 50, as implemented by Section
3.8, Revision 4, of the Operations Administrative Control and Quality
Assurance Plan, requires that (1) sufficient records shall be maintained
to furnish evidence of activities affecting quality, and (2) that the
records shall include the results and acceptability of tests end analyses,
and the action taken in connection with any deficiencies noteo.
Contrary to the above:
1. A significant number of instances of missing data entries was noted
in water chemistry records covering the period March 1983 through
September 1985, with respect to the chemistry sampling frequency
requirements of Procedures trim-501, " Chemistry Control of the
Primary Cooling Water Systems." No annotations were made in the
records to explain why the samples were not taken.
'
2. Review of the water chemistry records showed instances of failure to
make required entries to indicate when the Shift Supervisor was
notified in regard to out-of-specificiation chemistry results.
. 3. The records did not identify what corrective actions were taken
after entry of out-of-specification results.
4. Inadequate reviews were performed of the acceptability of water
chemistry data, as evidenced by the presence of review and approval
signatures on forms containing discrepant data results.
Response to Item A
Notice of Violation 445/8514-V-01 is written in four parts, each of which
is addressed separately.
.
Part 1
1. Reason for Violation:
An investigation by the Chemistry and Environmental Engineer
A confirms instances of missing entries on Chemistry data sheets, with
no explanation in some cases. In many cases there are explanations
on data sheets preceding the ones with missing data; explanations
such as system drained, not in service, or problem with analytical
equipment. Chemistry personnel failed to document the continuing
situation on subsequent data sheets when data was unavailable.
CHM-501 and CHM-508, the governing procedures cited in this part of
the Violation, require the recording of data on appropriate data
sheets. However, no guidance is provided concerning documentation
of samples not taken, or there is no requirement to document the
reason samples are not taken in the comments section of the data
sheet.
__
1 6
/ NRC Notice of Violation
Item A (445/8514-V-01)
(Continued)
.
2. Corrective Action Taken:
A. Chemistry section forms have been evaluated. The following
improvements were identified and will be incorporated:
All data sheets associated with the CHM-500 series proce-
dures will have the same general lay-out;
Parameter limits will be highlighted in red ink;
Sample data and time columns will be clearly delineated;
Where applicable, a chemical addition column will be
included; and
,
Each form will include the following note; " Circle out-of-
specification parameters."
.
The following corrective actions are in progress or will be
completed pending approval of CHM-500 series procedures.
B. Chemistry data sheets (forms) associated with the following
procedures are being revised:
Procedure No. Revision No. Procedure Title
CHM-501 1 Chemistry Control of the
-
CHM-502 1 Chemistry Control of the
Water Treatment System
CHM-503 1 Chemistry Control of the
Condensate System
- CHM-504 1 Chemistry Control of the
Feedwater System
CHM-505 1 Chemistry Control of the
Secondary Support System
CHM-506 1 Chemistry Control of the
Primary System
CHM-507 1 Chemistry Control of the
System
CHM-508 1 Chemistry Control of the
Primary Support System
.
t
p
. - - - , - ,- .- - ., . - . - - . . , , . - - . _ , - - , - _ , ~ , - - _ . -
_ ._,,_ , _ - . , .. - . --- --, ,---.- . . -
.
t .
.- NRC Notice of Violation
Item A (445/8514-V-01)
(Continued)
t
CHM-509 1 Chemistry Control of the
<
Primary Makeup System
CHM-510 1 Chemistry Control of the
Boron Recovery System
CHM-511 1 Chemistry Control of the
Safeguards System
CHM-517 1 Sampling and Analysis of
Liquid Waste Systems
CHM-519 1 Chemistry Control of the
Refueling Water
.
3. Corrective Steps to Avoid Recurrence:
A. The Chemistry section attended a training session on January 9,
,
1986, which addressed the following topics:
Procedure compliance;
Problems associated with existing data sheets;
Pending revisions to existing data sheets;
Consequences of missing surveillance item;
Consequences of not reporting an out-of-specification
. parameter;
Proper routing of data sheets;
4
Corrective action recommendations; and
!
l 3
Proper or key points to consider when filling out a data
,
sheet. The following items were addressed:
1. Ensure all data entries are clearly written;
- 2. Circle all out-of-specification parameters;
'
3. Ensure that data is reviewed against specified
limits;
4. Ensure that all footnotes are used correctly;
J
- 5. Fill in blanks;
6. Document systems that are not in service;
1
1
- . - - - - . - - - - - - . . ,
,,- - - - - , ,. - . -
.+- . ~ , . ~ - - - - - . ~ . - - , - - - , - ~ . - , . - . , , .
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e .
NRC Notice of Violation
'
.-
i Item A (445/8514-V-01)
(Continued)
t
- 7. Document reason for taking sample if not routine;
l 8. Utilize standard nomenclature.
i
Additionally, Chemistry directive 86-001 was issued to address these
,
Concerns.
!
! B. Upon approval of the above referenced procedures, implementation
i training will be provided to familiarize all Chemistry section
j personnel with the new data sheets (forms).
i
l 4. Date of Full Compliance:
- ,
'
A. Chemistry data sheets (forms) associated with the referenced
i CHM-500 series procedures will be revised by June 1, 1986.
B. Chemistry section personnel will receive additional training on
!
-
the revised data sheet forms by June 1, 1986.
Part 2
1. Reason for Violation:
j There have been instances of failure to make required entries to
j indicate that the Shift Supervisor was notified in regard to out-of-
i specification Chemistry results. Some of these instances are
i failure to notify the Shift Supervisor for each sample for a
, continuing condition, specifically the pH depression.
i
These deficiencies are procedurally related because CHM-508,
Revision 0, required the notification of the Shift Supervisor but
i did not require documentation of this notification on the data
i sheet. Also data sheet CHM-508-1 did not require identification of
out-of-specification conditions or notification of the Shift
'
3
{ Supervisor. CHM-501, Revision 0, did not require immediate
notification of the Shift Supervisor upon verification of an out-of-
! specification condition and the time of notification be recorded on ,
the appropriate data sheet. This problem is aggravated by the
listing of Mode 1 limits on data sheet CHM-501-1 for steam
,
generators so it is not readily apparent which values are out-of-
! specification. This is a contributing factor to personnel errors
.; during shutdown conditions.
- 2. Corrective Action Taken
,
i The data sheets are being revised to show the appropriate limits for
i the appitcable condition.
i
,
i
.
'
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' '
. NRC Notice of Violation
Item A (445/8514-y-0lT
(Continued)
-
CHM-508 has been revised to include the requirement to immediately
notify the Shift Supervisor in the event of an out-of-specification
condition and to document this notification on the data sheets.
3. Corrective Steps to Avoid Recurrence:
The corrective action, with Chemistry section personnel training,
should prevent this part of the Violation from reoccuring.
4. Date of Full Compliance:
CHM-508 was revised October 15, 1984. Chemistry data sheets (forms)
will be revised by June 1, 1986.
. Part 3
1. Reason for Violation:
Investigation confirms that the Chemistry data sheets do not
-
typically indicate the corrective actions taken for out-of-
specification chemistry.
This deficiency is procedurally related because CHM-501 and CHM-508
indicate that the Chemistry Supervisor will investigate out-of-
specification chemistry and determine the corrective action to be
taken. There is no guidance to document corrective actions in other
administrative procedures or on the data sheets.
This deficiency was also identified in TUGC0 Corporate QA Audit
. TUG-76 as Deficiency No. 1.
2. Corrective Action Taken:
Guidance provided by the revised procedure CHM-104 provides
necessary corrective action. This corrective action was the result
, of TUGC0 QA Audit TUG-76.
3. Corrective Steps to Avoid Recurrence:
The training provided under the Part 1 Preventive Action should
prevent this deficiency from reoccurring.
4. Date of Full Compliance:
Procedure CHM-104 was revised on May 24,, 1985. Personnel training
was completed on January 9, 1986.
.
.- -- - _ _ . _ _ _
_ _ _ . .
. .
.
NRC Notice of Violation
Item A (445/8514-V-01)
(Continued)
,
Part 4
1. Reason for Violation:
CHM-101, Revision 1 (5-12-82), " Chemistry / Radiochemistry
Administrative Control," states that records produced by technicians
shall be independently reviewed by a qualified person and forwarded
to the Chemistry and Environmental Engineer or his designee for
approval.
CHM-101, Revision 2 (12-8-83), states that Chemistry and
Environmental Supervisors are responsible for reviewing data sheets
and that Staff Chemists are responsible for approving data sheets.
2. Corrective Action Taken:
A qualified person will review all past CHM-501-1 and CHM-508-1 data
sheets. This review will be performed to determine if there is any
,
significant chemistry concern indicated which has not been
identified and resolved. Also, a representative selection based on
the number of records generated from other procedures utilized
during the January 1983 to September 1985 time period will be
reviewed. If similar problems are found to exist in the selected
'
records, then a full review will be conducted. Deficient or
nonconforming conditions discovered during these reviews will be
documented in accordance with station procedures.
3. Corrective Steps to Avoid Recurrence:
.
All Chemistry and Environmental Supervisors and Staff Chemists have
been reminded of their administrative responsibilities.
4. Date of Full Canpliance:
- All required document reviews will be complete by August 1, 1986.
_ ._ . . _ . _ _ _ __ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ _ _
.__ .
. _ . - . - _. _ _ . _ - . . . . . .
i
e .
- Notice of Violation
\ Item B (446/8511-V-01)
s Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0
Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31,
1984, requires that activities affe: ting quality shall be prescribed by
documented instructions, procedures, or drawings of a type appropriate
to the circumstances and shall be accomplished in accordance with these
instructions, procedures, or drawings.
Paragraphs 2.3 and 3.1.1.1 of Brown & Root (B&R) Procedure CQ-QAP-16.2,
Revision 25, require that nonconformances be identified, documented by
completing the NCR form, and dispositioned. Paragraph 3.19.5.2 of B&R
Procedure CP-CPM 6.9D, Revision 6, states, in part, with respect to NCRs
for minimum wall violations, ". . . Welding engineering shall review
the conditions stated on the NCR . . . ."
Contrary to the above, repair of a minimum wall violation associated
with weld 21-2 in component CC-2-RB-053 was noted on October 9, 1985,
from record review to have been performed without documenting the
'
condition on an NCR form.
.
Response to Item B
'
1. Reason for Violation:
A QC Inspector failed to follow QI-QAP-11.1-26 which requires the
initiation of a Nonconformance Report (NRC) for minimum wall
-
violation (MWV).
2. Corrective Action Taken:
,
A review was conducted to determine the method used to identify
and correct the MWV and concluded that the repair process used was
i
- technically adequate and would not have been altered regardless of
the document used to record the MWV (i.e., Unsatisfactory IR
.
attribute vs NCR). While we believe that the violation is a iso-
! lated occurence we are confident that any other similar minimum
) wall violation would have been likewise adequately dispositioned.
A 3. Corrective Steps to Avoid Recurrence:
All applicable QE's and QC Inspectors were retrained in the speci-
fic QI-QAP-11.1-26 program requirements relative to welded
repairs associated with MWV's. Additionally, construction proce-
dure CP-CPM-6.90 will be revised to clarify the requirement that an
NCR must be generated whenever a MWV is identified. Appropriate
Weld Engineering personnel will be trained to the revised
CP-CPM-6.90 requirements.
(
4. Date of Full Compliance:
May 16, 1986.
I
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_ _
i .
-
Notice of Violation
Item C (446/8511-V-02)
-
Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0
QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that
activities affecting quality shall be prescribed by documented
instructions, procedures, or drawings of a type appropriate to the
circumstances and shall be accomplished in accordance with these
instructions, procedures, or drawings.
Paragraphs 3.1.1.1 of B&R Procedure DCP-3, Revision 18, states, in part,
" . . . Issuance and receipt of controlled design changes are documented
on the Document Distribution Log . . . by signature or_ initial of the
file custodian and dated." Paragraph 3.2.2.5 of this procedure
additionally requires that the face of a retained superseded document
must be stamped " VOID."
Contrary to the above:
1. Satellite document control center 307 was noted on October 14,
1985, to be in possession of a controlled copy of Component
Modification Card 96181 for which receipt had not been signed for
and dated on the Document Distribution Log.
,
2. A copy of superseded Design Change Authorization (DCA) 21446,
Revision 0, was noted on the same date to be present in two
packages for Drawings 2323-El-1702, Sheet 002, Revision 2. Both
copies of DCA 21446, Revision 0, were not stamped " VOID" on the ,
face of the document.
Response to Item C - No. I
1. Reason for Violation:
Failure to properly i;nplement procedure.
2. Corrective Action Taken:
The Document Distribution Log was corrected by the inclusion of
proper initial and date. The Document Distribution Log was
- reviewed and there were no other violations of this nature
identified.
< 3. Corrective Steps to Avoid Recurrence:
! Appropriate DCC personnel were reinstructed in the proper receipt
acknowledgement of design changes. DCP-3 rev. 19 paragraph
3.1.1.1 includes verification responsibilities by DCC personnel to
,
ensure acknowledgment of design changes is documented.
4. Date of Full Compliance:
March 31, 1986.
l
1
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--. . -
- .
.' Notice of Violation
Item C (446/8511-V-02)
(Continued)
.
Response to Item C - No. 2
,
1. Reason for Violation:
Failure to properly implement procedure.
2. Corrective Action Taken:
The drawing package contents were immediately corrected. It was
determined that the drawing was not used in the performance of
plant work. Monitoring a sample of drawing package contents
revealed that no drawings or design changes were found to be out
of revision.
3. Corrective Steps to Avoid Recurrence:
'
Personnel were reinstructed in the need to assure up-to-date
contents in drawing packages, including the marking of superseded
drawings as " void".
, 4. Date of Full Compliance:
April 1, 1986.
.
!
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_ -. __ _ _ _ - - _ _ _ - _ _ _ _ _ --__
' '
.
Notice of Violation
Item _D (446/8511-V-(T3)
Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP,
Section 5.0, Revision 3, dated July 31, 1984, requires that activities
affecting quality shall be prescribed by documented instructions,
procedures, or drawings of a type appropriate to the circumstances and
shall be accomplished in accordance with these instructions, procedures,
or drawings.
Section 17.1.17 of the Final Safety Analysis Report, Volume XIV,
Amendment 50, dated July 13, 1984, commits to procedures requiring that
records be controlled and accounted for during transfer between
organizations.
Contrary to the above, original sole copy design records were ascertained
on October 16, 1985, to have been shipped to Stone and Webster
Engineering Corporation, New York, without the establishment and
implementation of procedures that address required control and inventory
.
measures.
I
Response to Item D
'
1. Reason for Violation:
Conditions noted in the violation are the result of a failure to
follow established procedures for control of engineering documents.
TUGC0 Nuclear Engineering (TNE) Procedure TNE-AD-4 specifies that
duplicate copies of engineering documents prepared or processed by
TNE shall be maintained at the site or Gibbs & Hill /New York, as
applicable.
1
In 1985, Stone & Webster Engineering Corporation (SWEC) assumed
l . design responsibility for pipe supports. In order to consider and
'
incorporate, where possible, existing information into SWEC
designs, TUGC0 initiated shipment of pipe support design records
offsite.
2. Corrective Action Taken:
Measures to establish compliance with TNE procedure TNE-AD-4 and ,
,
subordinate TNE instruction TNE-AD-4-6 (issued specifically for '
,
l transmittal and duplicate retention of pipe support calculations)
have been implemented for pipe support records previously forwarded
to SWEC. These efforts, involving the return of copies and
complete accountability, were completed in February 1986.
3. Corrective Steps to Avoid Recurrence:
v
TNE-AD-4-6 was issued November 25, 1985, establishing a program for
'
transmittal requirements for pipe support design records. In
addition, TNE-AD-4 will be reviewed and revised, if required, to
assure the adequacy of measures prescribing the offsite transmittal
of engineering documents.
!
l
l
, _ _ _ _ . _ . _ . _
_ _ _ _ -. __ __ _. _ _ . _ . _ _ .
.' Notice of Violation
Item D (446/8511-V-02)
(Continued)
4. Date of Full Compliance:
As noted in items 2 and 3, all measures have been completed with
the exception of the review / revision of Procedure TNE-AD-4. These
measures will be accomplished no later than May 22, 1986.
4
i e
o
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9
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"
~
-
Notice of Violation
Item E (446/8514-V-03)
Criterion VI of Appendix B to 10 CFR Part 50, as implemented by Section
3.8, Revision 4, of the Operations Administrative and Quality Assurance
Plan, requires that (1) measures shall be established to control the
isruance of documents such as drawings, including changes thereto; and
(2) the measures shall assure that documents, including changes, are
reviewed for adequacy and approved for release by authorized personnel.
Paragraphs 2 and 4 in Revisions 7 and 8 of Station Administration Manual
Procedure No. STA-405 require that all documented nonconformances, in
which "use-as-is" dispositions are recommended, be forwarded to TUGC0
Operations Results Engineering group for review to determine if as-built
documentation changes are needed.
Paragraph 4.0 in Revision 0 of Nuclear Operations Engineering Manual
Instruction No. N0E-201-5 requires that proposed drawing changes be
submitted to the Operations Superintendent for review, approval, and
. authorization to distribute the revised drawings.
Contrary to the above, nine-as-built drawings were revised and
distributed by TUGC0 Nuclear Engineering to reflect NCR identified
undersize welds, without receiving TUGC0 Operations review, approval, and
'
authorization to distribute the revised drawings.
Response to Item E
1. Reason for Violation:
The condition noted in the violation is the result of the issue of
pipe support drawings by TNE documenting acceptance of "Use-As-Is"
conditions prior to the proper disposition of several TUGC0
. Operations' NCR's.
Prior approval of drawings which document the "Use-As-Is"
disposition of NCR's by TUGC0 Operations is a requirement of
Station Administration Manual Procedure STA-405.
3
Please note the following in regards to Appendix "A", item E, third
i
paragraph of the subject NRC Inspection Report. Procedure
l N0E-201-5 does not require "non-vital" drawings, such as BRH (pipe
support) drawings be submitted to the TUGC0 Operations
,
Superintendent prior to issue by PSE (Pipe Support Engineering).
l
However, the generic issue of whether such drawings should be
classified as " vital" and therefore be submitted to the TUGC0
Operations Superintendent is being processed by TUGC0 Deficiency
Report (DR-86-007) whose disposition is yet outstanding.
- 2. Corrective Action Taken
The pipe support drawings noted in the finding were subsequently
I reviewed by TUGC0 Operations. Approval has been documented by
closure of the correspending TUGC0 Operations' NCR's, completed
December 19, 1985.
i
. - - - .. ..-- . _ -
"
,- Notice of Violation
Item E (446/8511-V-02)
(Continued)
'
3. Corrective Steps to Avoid Recurrence:
As a result of this specific finding, TNE Procedure TNE-AD-4-5
Revision I was issued November 11, 1985. Procedures which describe
TNE and TUGC0 Operations interface arrangements applicable to pipe
supports were reviewed to assure consistency. No additional
conflicts were noted. Adherence to these interface requirements
should preclude further violations of this nature.
4. Date of Full Compliance:
As noted above, full compliance has been achieved.
.
I
+
.
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- '
'
.
Notice of Violation
Item F (446/8514-V-04)
Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP,
'
Section 5.0, Revision 3, dated July 31, 1984, requires that activities
affecting quality shall be prescribed by documented instructions,
procedures, or drawings of a type appropriate to the circumstances and
shall be accomplished in accordance with these instructions, procedures,
or drawings.
Paragraph 3.0 of Procedure CP-QP-2.1, Revision 14, dated October 17,
1983, states in part, ". . . inspection personnel . . . shall have
experience in and shall have completed a technical training course and
> examination in the area of inspection responsibilities." Paragraph 3.7
of this procedure states, in part, ". . . Inspection personnel shall be
certified by the TUGC0 site QA supervisor as being qualified to perform
their assigned tasks."
Contrary to the above, it was noted on October 21, 1935, during review of
-
documentation for Class 1E lighting system conduit EAB1-1 that the
electrical inspector, who had signed inspection reports E-1-0024951 and
E-1-0027419, had not been certified to the applicable Procedure
QI-QP-11.2-25, Revision 17, dated February 13, 1984, " Inspection of New
.
Installations for Class IE Lighting Systems."
Response to Item F
1. Reason for Violation:
Oversight by QC Supervision which allowed the inspector in question
to inspect to QI-QP-11.3-25 prior to final sign-off of his
certification.
. 2. Corrective Action Taken:
NCR E-85-101639 was initiated to address this violation. In
addition, 800 Inspection Reports completed by 163 QC Inspectors
during the past six months were reviewed to determine if further
violations of this nature had occured. All of the reports reviewed
, were completed by QC Inspectors certified to the activity
inspected.
3. Corrective Steps to Avoid Recurrence:
QC Supervision is issued a weekly list which identifies the
certification capabilities and status of their personnel, for use
in inspaction assignments. Based upon the above review results
this action is sufficient to avoid recurrence of this violation.
Inspections performed prior to June 1985 are subject to CPRT action
, item VII.c.
4. Date of Full Compliance:
,
May 5, 1986.
i
.,. - . _
_ __ _ __ _ _
- -_ _ _ _ _ _
/ Notice of Deviation
Item A (445/8514-D-01)
,
Section 4.1.6 of ERC Comanche Peak Project Procedure (CPP) CPP-012,
"QA/QC Interface with Construction /TUGC0" states,
"The QA/QC Records Administrator controls requests for
equipment / services and distributes and controls requests for
technical information."
Contrary to the above, the QA/QC Records Administrator does not receive
copies of requests to provide for control of these documents
(445/8514-D-01).
With respect to item A in the Notice of Deviation, the NRC has
ascertained subsequent to this report period that ERC logs for tracking
of equipment / service requests have not been utilizing procedurally
required unique numbers for individual requests. Accordingly, please
address this as part of your response to item A in the Notice of
Deviation.
Response to Item A
,
1. Reason for Deviation:
As the NRC identified, the QA/QC Records Administrator does not
control requests for equipment / services from the Constructor /TUGC0.
Due to a misunderstanding of the NRC's concern at the time of the
finding, it was not explained that such requests are tracked by a
computerized log maintained by the Inspection Supervisor or his
designee.
Subsequent NRC investigation confirmed the presence of this
tracking mechantsm. Consequently, the original NRC concern was
-
resolved. However, the NRC inspector subsequently identified a
related concern: the log did not show a unique number for each
,
equipment / services request as required by CPP-012.
The function of the equipment / services tracking mechanism is to
ensure that all necessary equipment / services (i.e. scaffolding,
- painting or lagging removal, etc.) are installed or performed
before inspection takes place and are maintained until inspection
is completed. All open equipment / services requests (ESRs) are
maintained in a folder associated with the verification package
with which they are identified. The computer tracking mechanism
l tracks the status of the most recently opened ESR. This function
is served satisfactorily by the mechanism currently in place (the
same mechanism in place at the time of the NRC inspection).
l Changes to the mechanism used to track open ESRs are not required
l since no failures to perform the intended function exist. However
- procedure CPP-012 must reflect current practice.
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- -- _ _ _ _ __ ,_.__ . . _ , _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ .
. _ - . - . _-- _ - - . _ .
' "
/ Notice of Deviation
Item A (4(5/8514-D-01)
(Continued)
i
2. Corrective Action Taken:
ERC Comanche Peak Project Procedure CPP-012 was revised March 11,
'
1986, to remove reference to the ESR log.
3. Corrective Steps to Avoid Recurrence:
,
The action to correct the reported condition serves as action to
prevent recurrence.
.,
4. Date of Full Compliance:
March 11, 1986.
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Notice of Deviation
Item B (445/8514-D-02)
.
Section 4.1 of CPRT Issue-Specific Action Plan (ISAP) No. VII.c Revision
0, dated June 21, 1985, states, in part,
-
" . . . Where required, documentation reviews will be utilized to
supplement the reinspections for attributes which are
nonrecreatable or inaccessible. . , ."
Section 4.1.3 of the ISAP states, in part,
-
"
. . . The inspection procedure will provide detailed instructions
to the inspectors and/or documentation reviewers for performing the
reinspections and/or documentation reviews. . ."
Contrary to the above, the following examples were noted of inadequate
procedural guidance and document reviewer performance in regard to
,
nonrecreatable and inaccessible attributes:
1. Quality Instruction (QI)01-013, Revision 4, lists no specific
attributes, but instead specifies that the inspector verify
installations in accordance with one or more of a listing of TUGC0
,
procedures; i.e., QI-QP-11.8.1, -5, -6, and -8. The list of
appropriate procedures does not, however, indicate the applicable
revision number of each procedure. In that the number of
nonrecreatable or inaccessible inspection attributes can vary from
revision to revision of a procedure (e.g. Revisions 0 and 1 of
TUGC0 Procedure QI-QP-11.8-8), the absence of guidance on
applicable procedure revision numbers does not constitute detailed
instructions.
2. During the documentation review of Verification Package No.
R-E-CDUT-064, in accordance with QI-009, Revision 0, there was no
-
evidence that a documentation check was made of inaccessible
attributes for conduit C13016037 that were caused by the
installation of separation barrier material (445/8514-D-02).
Response to Item B
F
1. Investigation:
01-013 " Documentation Review for Instrumentation
Equipment /R-E-ININ" does not, in fact, list specific attributes for
the inspector to verify. The purpose of the documentation review
governed by QI-013 is to provide inspector qualification
information as input to ISAP I.d.1. The intent of QI-013 is to
verify the inspector who signed the inspection report (IR) being
reviewed was certified to the appropriate revision of the Quality
Instruction (QI) that was in place at the time of the inspection.
To do this the document reviewer records the inspector's name, the
QI number, and the revision of the procedure n;ted on the IR. Then
the inspector certifications are reviewed to aetermine if the
inspector was certified to the appropriate revision at the time of
signing the IR.
,
. _ _ _ , _ _ _ _ _
.
. .
Notice of Deviation
Item B (445/8514-D-01)
,
(Continued)
This is an appropriate way to verify inspector certifications.
Consequently, no deviating condition is believed to exist.
Regarding use of document reviews to supplement reinspections for
inaccessible attributes, the NRC finding is correct, based on
Revision 2 of the CPRT Program plan. However, in the ensuing time
period, Revision 3 of the CPRT Program Plan, including a revised
ISAP VII.c was issued. ISAP VII.c as now written dictates that,
after the sixty inspections have been concluded for the population
sample, any attributes which were found to be inaccessible will
cause additional samples to be selected from the population and
inspected only for those attributes which were inaccessible in
preceding inspections. Document review will only be used for non-
recreatable attributes unless sixty occurrences of the attribute
are not accessible from the population as a whole. Consequently,
. the programmatic change in Revision 3 resolved this finding.
2. Corrective Action Taken:
.
No corrective action for items 1 and 2 are planned.
3. Corrective Steps to Avoid Recurrence:
No corrective steps for items 1 and 2 are applicable
4. Date of Full Compliance:
February 24, 1986.
.
F
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' '
. Notice of Deviation
Item C (445/8514-D-03)
QI-009, Revision 0, " Document Review of Conduit /R-E-CDUT", requires the
'
ERC inspector to:
-
verify that inspection reports signed by electrical inspectors were
dated after their date of certification and prior to their date of
expiration, and,
- document-the SBM inspection report (IR) and/or latest construction
operation traveler number at the bottom of the checklist.
Contrary to the above:
'
- Review of ERC accepted documentation for conduit C14R13047 showed
thair the ERC inspector failed to identify that the certification to
the applicable Procedure QI-QP-11.3-23 had lapsed for the TUGC0
electrical inspector signing IR-E-46087.
. -
The ERC completed inspection record checklist for conduit C13016037
in Verification Package No. R-E-CDUT-064 did not contain
documentation of the SBM IR or latest construction operation
traveler number (445/8514-D-03).
1
- -
Response to Item C
1. Reason for Deviation:
A review of verification Package No. R-E-CDUT-064 and R-E-CDUT-070
confirmed the NRC findings. This was determined to be an
inspection error.
2. Corrective Action Taken:
.
- (DR) Deviation Report R-E-CDUT-070-DR1 was written by the
inspector.
- The number for the latest construction operation traveler was
added to the applicable checklist on 11/21/85.
"
.
- The inspector was given additional training on 11/8/85.
Reinspection of 25% of this inspector's work involved 28
verification packages and was completed before 11/21/85. The
results of the 25% reinspection has been evaluated and based
upon the minor nature of the discrepancies identified, no
further actions was deemed necessary on the Inspector's past
performance.
3. Corrective Steps to Avoid Recurrence:
An overview Inscection Program has been implemented to reinspect a
sample of each Inspector's work on a continuing basis. Action is
ongoing to analyze results of the Overview Inspection program,
gather pertinent inspector error data from other sources (NRC
reinspections, etc.), and to effect required additional formal
training of inspectors.
-.
'
.
- Notice of Dnviation
Item C (445/8514-D-01)~
(Cont ~inued)
'
4-. Date of Full Compliance:
Corrective action was completed by November 21, 1985. Preventive
action involves an ongoing program.
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Notice of Deviation
Item D (4M;$514-D-01)
.
Section 4 of CPP-009, Revision 3, states, in part, with respect to ISAP
No. VII.c, " Qualified QA/QC Review Team personnel perform field
reinspections of specific hardware items and reviews of appropriate
documents in accordance with approved instructions . . . ."
Contrary to the above, the following examples were noted where field
reinspections of hardware items were not performed in accordance with
approved instructions:
1. Attribute 4.5 in Section 5.0 of QI-055 Revision 0, states with
respect to spring nuts, " Verify that the serrated grooves align
with the channel clamping ridge." Checklists for support No. 0070
(Verification Package No. I-S-INSP-007) and support No. 028
(Verification Package No. I-S-INSP-028) were signed by two separate
ERC inspectors that this attribute was acceptable. NRC inspectors
showed, however, that the spring nut serrated grooves did not align
with the channel clamping ridge on both of these supports.
2. Section 5.3.4.C in QI-027 states with respect to dimensional
tolerances not shown on design drawings, " Component member length
. +/-1/2 inch."
The bill of material on Revision 2 of drawing No. CT.1-097-402-C52R
in Verification Package No. I-S-LBSR-023 shows item No. 4 (2
pieces) to be 7 3/4 inches long. The applicable inspection
checklist used during the ERC reinspection of this pipe support
shows the installed configuration to be acceptable. NRC inspect-
tion determined, however, the actual length dimensions of the two
pieces to be 6 5/8 inches and 6 1/2 inches, respectively, both of
which are under the indicated minimum dimension of 7 1/4 inches.
3. Section 5.0 in QI-012 states, in part, " Verify that the
piping / tubing and components . . . material agree with the Bill of
Materials shown on the Instrument Installation Detail drawing.
Tubing is marked with longitudinal color coded marks for
traceability. Use applicable drawing to identify tubing . . .
Verify that the installed tubing has the proper slope. The
A required slope for process wetted lines is one (1) inch per foot
minimum. This slope requirement may be reduced to 1/4 inch per
foot when physical layout is a problem. Verify that there is a
proper air gap. The minimum gap spacing shall always be 1/8 inch
to allow each instrument sensing line to expand independently at
all bends without striking adjacent sensing lines, other equipment,
concrete or steel building members."
The applicable inspection checklist used during the ERC
reinspection of instrumentation installation Verification Package
No. 1-E-ININ-026 showed that the above attributes were inspected
and accepted, as evidenced by the inspector's signoff (initials).
s .
. Notice of Deviation
Item 0 (445/8514-D-01
(Continued)
i
However, NRC inspection of the instrumentation installation
revealed:
(a) Six sections of tubing had no color coding for traceability;
(b) Ten sections of tubings, in which physical layout was not a
problem, had slopes of 7/16 inch to less than 1/4 inch per
foot and one section had reverse slope; and
(c) Two tubing sections had zero gap spacing between the high
pressure and low pressure legs and the concrete penetration.
4. Section 1.7 in QI-012 requires that: (a) tubing bend be verified to
have a minimum radius of four times the normal tube size by using
either a template, or by direct measurement calculations; and (b)
the measured and calculated values be entered into the Minimum Bend
Radius Record, with date and inspector's initials.
'
During NRC inspection of Verification Package No. I-E-ININ-04,
equipment tag No. 1-FT-156, it was noted that the inspection
checklist was dated and initialed, attesting to the fact that the
tubing bends had been verified as having a minimum radius of four
times the nominal tube size. However, review of the applicable
Minimum Bend Radius Record showed that the ERC inspector had
neither measured and calculated, nor used a template to verify
minimum bend radius. In addition, the following notes had been
entered by the ERC inspector: "Ist 90' bend from instrument (hi &
lo side) . . . cannot be measured with existing tools. Four (4)
other bends visually more than 90* to accommodate slope"
(445/8514-D-04).
Response to Item D
A 1. Reason for Deviation:
Reinspection confirmed the NRC findings.
Item 1 and_2
i
Inspector error.
Item 3
Inspector Error. Ongoing adjacent construction and housekeeping
activities (i.e., wiping down, climbing, ongoing work in
l
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s .. .
-
'
Notice of Deviation
Item D (44!i78514-D-01
(Continued)
\
.,
surrounding areas, etc.) prevent a firm determination as to whether
or not the NRC identified findir.gs existed at the time of the ERC
inspection but, enougl indication exists to justify retraining of
the inspectors as a step to assure recertification of these items
which may well have been inspector error.
Item 4
Inspector error. QI requires clarification to allow inspector to
indicate inaccessible bends.
,
2. Corrective Action Taken:
Item 1
Deviation Reports I-S-INSP-007-DR2 and DR3 dated November 18, 1985,
,
and I-S-INSP-028-DR2 dated November 8, 1985, were written to
document the misaligned spring nuts.
Twenty five percent of the work of both inspectors was reinspected.
The results of the reinspection were documented and evaluated by
inspcction supervision. A decision was made to reinspect 100% of
the spring nuts previously inspected by the first inspector. The
results of the reinspection indicated a high error rate. This
inspector's services were discontinued and 100% of his work was
reinspected. The retained inspector was retrained on November 12,
1985. All necessary reinspections were completed by December 5,
1985. Deviating conditions identified by the reinspections have
been documented in the applicable Verification Packages and DRs
initiated.
A general training session on Spring Nut inspection was given to
all non-affected in:pectors involved in the reinspection of this
attribute. This retraining has been documented.
.
i A
,
Item 2
Deviation Report I-S-LBSR-023-DR2 dated November 13, 1985, was
,
written to document the dimensional deviations. The responsible
'
inspector was the same one whose services were discontinued as
indicated above.
Item 3 and 4
The Verification Package documentation for ININ-026 has been
reinspected, I-E-ININ-004 was corrected, and DRs I-E-ININ-026-DR-2,
e
' " *
,e Notice of Deviation
Item 0 (445/8514-D-01
(Continued)
.
-4, and -5 were issued. In addition, revis; n 1 of QI-012 was
issued January 30, 1986, and now provides a basis for the
inspectors to indicate inaccessible bends. Due to problems noted
by ERC and those identified herein by the NRC, all ININ
Verification Packages issued prior to January 14, 1986, will be
reissued for reinspection.
3. Corrective Steps to Avoid Recurrence:
An Overview Inspection program has been implemented to reinspect a
sample of each Inspector's work on a continuing basis. Action is
ongoing to analyze results of the Overview Inspection program,
gather pertinent inspector error data from other sources (NRC
- reinspections, etc.) and to effect required additional formal
training of inspectors.
4. Date of Full Compliance:
'
Corrective action is complete with the exception of the total
reinspection of the ININ packages.
Preventive action involves an ongoing program.
.