ML20212P755

Notice of Violation from Insp on 851101-860131

ML20212P755
Person / Time
Site:	Comanche Peak
Issue date:	08/29/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20212P745	List: ML20212P742 ML20212P755 ML20212P761 ML20212P783 ML20212P801 ML20212P837
References
50-445-86-01, 50-445-86-1, 50-446-86-01, 50-446-86-1, NUDOCS 8609030261
Download: ML20212P755 (3)

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APPENDIX _A NOTICE OF VIOLATION Texa's Utili' ties Electric Company Dockets: 50-445/86-01 Comanche Peak Steam Electric Station, . 50-446/86-01 Units 1 and 2 Permits: CPPR-126 CPPR-127 i

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During an NRC inspection conducted on November 1, 1985, through January 31, 1986, two. violations of NRC requirements were identified. .The violations involved nonconforming conditions not being identified in accordance with QA program l requirements and failure to perform field testing of cable reels. In accordance with the " General Statement of Policy and Procedure'for NRC e Enforcement Actions,"'10 CFR Part 2, Appendix C (1985), the violations'are listed below:

A. 1 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. It

! further requires that nonconforming items be reviewed and accepted,-

rejected, repaired, or reworked in accordance with documented procedures.

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Section 15.0 of Revision 5 to the TUGCo Quality.' Assurance Plah (QAP) '

states, in part, "The identification, documentation, segregation, 'and. .

disposition of nonconforming' materials, parts, or components'is outlined .

in written procedures . . . ." A nonconformance report'is used,to i-document deficiencies unless another method is-~ prescribe'd by>a

specific

procedure / instruction. .Nonconformance; reports . . . ;are made available to TUGCo for evaluation . . . (and) TUGCo QA assures' that periodic 7

evaluations of these reports are forwarded to -TUGCo;managsment identifying trends adverse to quality." ' '

Section 3.9 of Revision 3 to the TUGCo Oper'a tions Admin'istMative' Control ,

and Quality Assurance Plan states, in part, " Material, parts and components which are determined to be nonconforming, shall be identified

and reported. Nonconformance' reports shall be prepared which identify and'

• l de' scribe the nonconformance, the disposition of the nonconformance, and the . . ._ acceptability of the item after the disposition has been completed . . . ."

Contrary to the above, established procedures for handling of n . nonconforming =storial::, parts, or components were not effectively

' implemented as evidenced by the following observed conditions:

. 1. Deviation Reports (DRs) generated by ERC'to document nonconforming conditions did not, in all cases, result in the initiation of.

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- 8609030261 060029 ADOCK 05000445 PDR g PDR ,

r nonconformance reports (NCRs) by the TUGCo QA/QC Coordinator as .

required by Revision 1 to Procedure CP-QP-16.3 dated August 28, 1985.

2. The TUGCo QA/QC Coordinator failed to initiate NCRs as required by Revision 1 to Procedure CP-QP-16.3 dated August 287 1985,.for numerous ERC identified out-of-scope observations '"

which were subsequently repaired or reworked.

3. Nonconforming items identified by the TUGCo QC Inspection Process Control Group, and subsequently reworked and repaired, were not documented on NCRs as required by Revision 9 of Procedure STA-405 dated November 11, 1985, but rather on three part office memos.

4. A large number of nonconforming items have not been physically identified with signs, barriers, or hold tags as required by Revision 25 of Procedure CP-QAP-16.1 dated August 17, 1985.

5. Deficiency Notifications (DNs), as required by Revision 4 of Procedure N61-1 dated December 10, 1985, are to be used only for documenting deficient conditions identified during repair or replacement of mechanical components previously accepted by TUGCo.

However, numerous instances have been identified where DNs have also been used to improperly document nonconformances and effect the issuance of work requests and work orders.

6. Failure to initiate required NCRs impacts on the validity of the monthly trend analysis report required by Revision 1 of Procedure QI-QP-17.0-1. The report is required to contain potentially adverse trends, which are based on the number of NCRs issued during the report period.

This is a Severity Level IV violation (Supplement II) (445/8601-V-12; 446/8601-V-03).

B. 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 QAP, 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 6.15.1(t) of Gibbs and Hill Electrical Erection Specification 2322-ES-100, Revision 2, dated October 15, 1980, requires:

(1) that field tests shall be performed by the Contractor on all cable reels in accordance with the manufacturer's recommendations, and (2) that the owner will witness these tests.

Cor.trary to the above, the specified field tests of cable reels were neither prescribed by implementing procedures nor performed.

This is a Severity Level IV violation (Supplement II) (445/8601-V-14; 446/8601-V-04).

l 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 date 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, the corrective steps which have been taken and the results achieved, the corrective steps which will be taken to avoid further violations, and the date when full compliance will be achieved. Where good cause is shown, consideration may be given to extending your response time.

4 Dated at Arlington, Texas, this 29th, day of August 1986 L

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