ML20236C596

Notice of Violation from Insp on 870805-0902.Violation Noted:Nonconformance Repts Invalidated W/No Further Action Required When Action to Prevent Repetition Necessary & Cotter Pins Missing from Sway Strut Rear Bracket Load Pins

ML20236C596
Person / Time
Site:	Comanche Peak
Issue date:	10/23/1987
From:	NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20236C585	List: ML20236C582 ML20236C596 ML20236C610 ML20236C631
References
50-445-87-16, 50-446-87-13, NUDOCS 8710270262
Download: ML20236C596 (3)

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,1 APPENDIX A ., +o NOTICE OF VIOLATION TU Electric Dockets: 50-445/87-16 50-446/87-13 Comanche Peak Steam Electric Station, Permits: CPPR-126

' Units 1 and 2 CPPR-127 i .

As a result of the inspection cor, ducted on pygust 5 through September 2, 1987, and in accordance with the " General Statement of Pblicy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,

,,7 4 Appendix C (1987), the following violations were identified-  !

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Crit $)r, ion XVI of Appendix D'to 10 CFR Part 50, as implemented A. /

~ by'/ Eection 16.0, Revision 0, of the YU Electric Quality Asshrance (QA) Plan, requires, " Measures shall be established to assure that conditions adverse to quality.!.(be corrected and)... action taken to preclude repetition."

Nuclear Engineering and Operation Procedure NEO 3.06, < II

" Reporting and,Cr.'idrol of Deficiencies," implements this criterion by redniring deficiencies (principally programmatic, not.directly related to hardware problems) be identified, the causessst'abliched., and action taken to prevent repetition.

. h-Contrary to the above, numerous nonconformance reports (NCRs) have been invalidated with no further action required, when action to prevent repetition appears te have been necessary.

Examples of these NCRs include M-21940, M-26470, M-26471, M-20857, M-21861, M-28567, M-21982, and M-26189.

This is'a Severity Level IV violation.(Supplement II)

(445/8716-V-02; 446/8713-V-01). ,

} j B. CriterionVIIoffAppendixBto.10'd)2PartSh,asimplemented/ ,

by section 7.0, Revision 3, dated July 31, 1,984, of the TU Electric'QA-Plan, requires that, "Measur.es shall be established to assure that purchased material, . . . conform

- fo'the procurement documents. These measures shall include ,

, provisions,Jas appropriate, for . . . inspection at the contractor br, subcontractor source,.. . .. " Su6h measures were established and implemented concerning TU Electric purchase order CPF-13820-S, Supplement 1, for 264 jackshafts (components in 6.9kV circuit breakers) from BBC Brown Boveri, Inc.

8710270262 071023 PDR ADOCK05000gS i

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i , , 2 1 o j u i A TU Electric trip report, dated June 9, 1987, documents an

. inspection of these jackshafts at the vendor's plant prior to shipment. The 264 jackshafts shipped from Nhe, vendor's plant had been inspected and accepted by TU ElectrIchas complying .

with new welding acceptance criteria previously approved by i TU Electric engineering. One of these criteria was, "The '

3/16" fillet weld can be a minimum of 1/8". . . .

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2 contrary to the above, during an NRC inLbection of five <

jackshafts, onsite awaiting installation', one jackshaft (item 1 number 273) was found with a fillet weld floss than 1/8" over'a

'.ength of 9/16". Subsequent to this NRC' inspection, conducted September 1, 1987, TU Electric initiated inspections to identify any other jackshafts out of the 364 shipped that did not comply with the welding acceptance qciirria.

ThisisaSeverityLevelIVviolation(SuppkementII)

(445/8716-V-10; 446/8713-V-09).

t C. Criterion XVI of Appendix B to 10 CFR Bart 50, as implemented u by Section 16.0, Revision 0, of_the TV EToptric QA Plan, states in part, " Measures shall be established to assure that conditions adverse to quality, such as failudes, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identKfied and corrected. In the case of significant conditions atverge to quality, the measures shall assure that the cause,of che' condition is j determined and corrective action taken to p.eclude

'6 repetition . . . . "

TU Electric,.in response to Corrective Action Report (CAR) ,*

65X, which identified a missing cotter pin as a Construction '[ ?

Deficiency, established the Hardware Validation Program (HVP) for safety-related pipe supports. Included in this program is 3 a required verification that locking devices and present and

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correctly installed.

Contrary- to the above, the sway strut tear bramperl load pin on safety-related pipe support CC-1-295 006-C53R, Revision 4, was observed on August 21, 1987, to have two missing cotter pins although this support had been reworked'by craft and accented i

by QC in accordance with the HVP. '

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This is a Severity Level IV violation (Suppleme'nt II) ,

(445/8716-V-12). j ,

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1. u Pursuant sto the provisions of 10 CFR 21201, TU Electric is hereby s

requ br& to submit to this office, within 30 days of the date of f . thq letier tr&'nymitting this Notice, a written statement or explanatiqq' in , reply, including for each violation: (1) the reasons i?) the violations if admitted, (2) the corrective steps which havW been taken and,the results achieved, (3) the corrective steps which will be takes to avoid further violations, and (4) the N date when full compliance will be achieved. Where good cause is chown, consideration will be given to extending your response time.

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