ML20244C778

Notice of Violation from Insp on 890308-0404.Violation Noted:Qc Inspectors Not Equipped Nor Trained to Measure Listed Insp Attributes to Tolerance Required by post-const Hardware Validation Program

ML20244C778
Person / Time
Site:	Comanche Peak
Issue date:	04/14/1989
From:	Warnick R Office of Nuclear Reactor Regulation
To:
Shared Package
ML20244C772	List: ML20244C771 ML20244C778 ML20244C780
References
50-445-89-19, 50-446-89-19, NUDOCS 8904200410
Download: ML20244C778 (2)

Text

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c' APPENDIX A NOTICE OF VIOLATION TU Electric Dockets: 50-445/89-19 .

50-446/89-19 l Comanche Peak Steam Electric Station Permits: CPPR-126 Units 1 and 2, Glen Rose, Texas CPPR-127 During an NRC inspection conducted on March 8 through April 4, 1989, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation is listed below:

A. Criterion II of Appendix B to 10 CFR Part 50, as implemented

-by Section 2.0, Revision 0, of the TU Electric Quality Assurance Manual requires that the quality assurance program "take into account the need for special controls, processes, test' equipment, tools, and skills to attain the required quality, and the need for verification of quality by inspection and test. The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained."

Contrary to the above, Quality Control inspectors were not equipped nor trained to measure the following inspection attributes to the tolerance required by the Post-Construction Hardware Validation Program:

1. Valve stem orientation is required by Procedure AQP-11.5 "ASME Component Installation Verification" (referenced by CPE-SWEC-FVM-EE/ME/IC/CS-090) to be measured to within i 5 degrees. This requirement is based on the principle that the precision of measurement must at least be equal to the tolerance defined by the acceptance criteria. QC '

valve stem orientation measurement methods demonstrated to the NRC were not correct. For example, in three specific cases valve stem orientation measurements taken by QC were out-of-tolerance while those taken by an engineering su5vey er w were accegtable (i.e., one example: QC 34 ; survey crew 51.3 ; and drawing 51,).

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2. The linear distance either side of the low elevation 'l coupling of the incore instrument tubing to the first developed arc is required by Procedure AQP-11.5 to be measured to within i 2 inches. The use of a straightedge and 0.01-inch feeler gauge as was demonstrated by QC to the NRC introduced a minimum tangential error of 1.7 inches with respect to the 12-foot (nominal) radius arc. The tangential' error is increased by a flattening of.the arc near the tangent point. Seven measurements taken by the NRC inspector differed from those recorded by the QC inspector by more than the allowed i 2 inches.

As indicated by these errors, the failure by QC to measure the tangential point of the tubing arc correctly has introduced an automatic error into measurement accuracy.

This is a Severity Level IV violation (Supplement II)

(445/8919-V-01; 446/8919-V-01).

Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby

_ 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 Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION F&annaJz Dated at Comanche Peak Site this 14th day of April 1989

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