ML20236L885

Notice of Violation from Insp on 870903-1006.Violation Noted:Package Flow Control Procedures Not Followed for Electrical Penetration Assembly Documentation,Qc Accepted Inaccessible Weld Distance & Nonconformance Rept Not Made

ML20236L885
Person / Time
Site:	Comanche Peak
Issue date:	11/05/1987
From:	Warnick R NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20236L871	List: ML20236L868 ML20236L885 ML20236L919 ML20236L925
References
50-445-87-18, 50-446-87-14, NUDOCS 8711110100
Download: ML20236L885 (4)

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, APPENDIX A F" NOTICE OF VIOLATION .;

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' TUiElectric Dockets: 50-445/87-18 -

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, 50-446/87-14 ]

Comanche Peak Steam Elbetric Station Permits: CPPR-126 ,

Units 11.and:2r Glen" Rose, Texas. 'CPPC-127' {

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'During an NRC inspectionLconducted onlSeptember.3'through-

'- October 6, 1987, violations of NRC requirements:were-identified. f Infaccordance withithe " General Statement of Policy.and Procedure- .

" .for NRCs Enforcement-Actions," 10 CFR Part 2, Appendix lC (1987), the

, sfollowingfviolations are listed below: .

A. ' Criterion V oftAppendix;B_to 10 CFR Part 50, as implemented by .;

Section"S.0, Revision-3, dated. July 31, 1984, of the TU l Electric' Quality Assdrance Plan.(QAP), requirec that i activities.affecting quality shall be prescribed by and.

accomplished in accordance with documented instructions, .;

procedures, or drawings.

Sectibn5.0'ofBrownandRootProcedureCP-CPM-7,1 7 Revision 3, " Package Flow Control" requires that the contents of documentation packages be verified as being complete and current by! distribution satellite personnel prior to' initial ,

issuance of the package, and upon return or completion of i

, work, the distribution satellite personnel are to assure the j documents issued are returned. The package inventory card is j used by distribution satellite personnel to account for the j documents contained in the documentation packages. l

.i, Contrary to the above, on September 16 and 17, 1987, the NRC  !

t* . inspector identified 10 electrical penetration assembly  !

documentation packages, which had been verified by I distribution satellite personnel as agreeing with the' package inventory card, whose contents did not agree with the package 1 inventory. card. .The following documentation packages I contained megger data sheets not listed on the package j inventory card: 2E-16, 1E-59 module E, 1E-43 module A, 1E-43 I module B, 1E-43 module C, 1E-52 module A, 1E-52 module B, 1E-52 module C, 1E-52 module D, and 1E-55 module F.

This is a Severity Level V violation (Supplement II) I

(.445/8718-V-04; 446/8714-V-03).

8711110100 071105 PDR ADOCK 05000445 G- PDR a ______:_-_____---___-__ _____-___- _-_ __ _ _ - _ - - - - . _ - - . _ _ _ - _ -

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i B. Criterion X of Appendix B.to 10 CFR Part 50, as implemented by {

Section 10.0, Revision 1, dated ~ July 31, 1984, of the j TU Electric QAP states, in part, "A program for inspection of activities.affecting quality.shall be established and executed ]

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by or for the organization performing the activityzto verify  ;

conformance with the documented instructions,'proce'dures, and drawings for accomplishing the activity . . . . Examinations, measurements, or tests of material or products processed shall i be performed for each work operation where necessary to assure quality."

Engineering and Construction Engineering Procedure ECE

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.9.04-04, which is part of-the post construction hardware validation program, addresses the reinspection /walkdown of accessible attributes. It also requires the identification of inaccessible attribuces so that an engineering evaluation will be performed.

contrary to the above, the following condition was identified:

The adjacent weld distance attribute for pipe support WP-X-AB-050-003-3 was documented as being satisfactory on the associated Adjacent Weld Checklist. However, this attribute is inaccessible due to the presence of Bisco seal material in the penetration that the pipe runs through. The acceptance of this. inaccessible attribute by QC precluded the required engineering evaluation from being performed.

This is.n SeV5 rite Level IV violation (Supplement II)

(445/8718-V-09).

C. Criterion XV of Appendix B to 10 CFR Part 50, as implemented by Section 15.0, Revision 5, dated July 31, 1984, of the TU Electric QAP, states, " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or i installation. These measures.shall include, as appropriate, l procedures for identification, documentation, segregation,

'4 disposition, and notification to affected organizations.

Nonconforming items shall be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures."

Procedure CP-QAP-12.1, paragraph 6.1.2, Revision 20, dated July 10, 1987, states, in part, "For defective or flawed material or components, an NCR must be generated . . . ."

Contrary to the above, a nonconformance report (NCR) was not I

issued for a high strength capscrew (item 15 of pipe support CC-1-SB-001-001-3) which broke during installation before the specified design torque value was achieved. This precluded an

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I investigation and' engineering evaluation of the nonconforming L item. ,

6 1 This is'a Severity Level IV violation (Supplement II)

(445/8718-V-08). i i

D. Criterion XVI of Appendix B to 10 CFR Part 50, as implemented e l

Eby Section 16.0, Revision 0,. dated July 1, 1978, of the  :

TU. Electric QAP, states, in part, " Measures shall be 7- established to assure that conditiens-adverse to quality,;such j as . . . deficiencies, deviations and- . j nonconformances . . . are promptly identified and corrected."  !

i Section 17.1.15 of the CPSES FSAR, states, in part, "A nonconformance report (NCR) is a document used for i documenting, controlling, and correcting a condition . . . .

The. disposition of such a document, NCR M-2320, Revision'3, j required that for the 3" steam generator hold-down bolts:

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(1) Bolts with gaps greater than .010 inch.shall be shimmed. j i

(2) The . tabs cn1 stainless steel shims shall be held up against the bolt head with 3/4" wide carbon steel banding l l

The banding shall be tight enough to prevent removal by i hand. l (3) A scpy of the material documentation for the shims shali l be attached to the NCR. ]

Disposition of NCR M-2320 was completed and verified complete by QC inspection on November 25, 1981.

Contrary to the above, the NRC inspector found the following not accomplished during a field inspection on September 11, l

,1987: (1) shims required to be installed under two of the l Unit 2 steam generator hold-down bolts were found to be  !

missing; (2) banding required to be installed to hold the shim material in place for the Unit 2 steam generator hold-down bolts was found to be missing from two bolts and was ,

improperly placed for an additional six bolts; and l (3) documentation of the shim material identity was not included in the NCR M-2320.

This is a Severity Level IV violation (Supplement II)

(445/8718-V-02; 446/8714-V-01).  !

I Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby j required to submit a written statement or explanation to the U. S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Assistant Director for Inspection Programs, Comanche Peak Project Division, Office of i k

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Special Projects, within 30 days of.the date of the letter I transmitting.this Notice. This reply should be clearly. marked as a

" Reply to'a Notice of' Violation and should include for each . 3

' violation: (1):the reason for the violation'if admitted, (2)1the i corrective steps which have been taken and the'results achieved, f

.~(3)-the. corrective' steps which will be taken'to avoid further l m

violations, Land (4): the date.when full compliance will be' achieved. 1

.If an. adequate. reply is not received within the time specified in i this Notice, an. order may be-issued to'show cause why the license H should not be' modified,_ suspended, or revoked or why such other tI' action as may be(proper should not be taken. Consideration may be.

given to' extending the' response time for good cause shown. ,,

FOR THE NUCLEAR REGULATORY COMMISSION PfYaAO Dated at Comanche Peak Site

.this 5th day of November 1987 1

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