ML20207E108

Notice of Deviation from Insp on 860401-0531

ML20207E108
Person / Time
Site:	Comanche Peak
Issue date:	12/22/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207E070	List: IR 05000445/1986007 ML20207E068 ML20207E083 ML20207E108 ML20207E151
References
50-445-86-07, 50-445-86-7, 50-446-86-05, 50-446-86-5, NUDOCS 8701020064
Download: ML20207E108 (6)

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APPENDIX B NOTICE OF DEVIATION Texas Utilities Electric Company Dockets: 50-445/86-07 Comanche Peak Steam Electric Station, 50-446/86-05 Units 1 and 2 Permits: CPPR-126 CPPR-127 Based on the results of an NRC inspection conducted on April 1 through May 31, 1986, ten deviations from commitments were identified. The deviations consisted of failure to maintain Evaluation Research Corporation (ERC) Quality Assurance (QA) manuals current, failure of Senior Review Team (SRT) to assure quality of Comanche Peak Response Team (CPRT) activities, the documented Overview Quality Team (0QT) program was not definitive, ERC audit status and action logs were not maintained current, corrective action was not implemented as committed, three instances of errors made during reinspection by ERC, spare conductors were inappropriately included in reinspection sample, five instances of errors made in the overview inspection function, and no criteria for valve disassembly / reassembly for five months in 1983. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the deviations are listed below:

A. Paragraph 2.0 of Procedure ERC-QA-01, " Preparation, Maintenance and Control of E&ESD Quality Assurance Manual," Revision 0, states, "This procedure applies to the preparation, distribution, maintenance, and control of the E&ESD Quality Assurance Manual." Furthar, paragraph 5.1 states that, "The E&ESD Quality Assurance Department shall prepare, maintain, and control the Quality Assurance Manual.

In deviation from the above, the ERC E&ESD Quality Assurance Manuals have not been maintained and controlled. The following omissions from controlled copies of this manual were identified: Revision 1 of ERC-QA-007, " Corrective Action Request"; and all revisions of ERC-QA-028,

" Performance of Overview Inspections" (445/8607-D-07).

B.Section III, paragraph K of the CPRT Program Plan states, in part, "The CPRT SRT is committed to assuring the quality of CPRT Program activities and results. The SRT's commitment to quality is manifested in the CPRT Program principals and the CPRT Third-Party Quality Assurance Program described in Appendix G."

A further expression of this commitment is found in the Counsil to Noonan letter dated February 28, 1986, that states, in part, "To support the Senior Review Team in fulfilling its responsibilities, the Overview Quality Team (0QT) has been established . . . ."

In deviation from the above, the following weaknesses have been identified that collectively indicate lapses by the Senior Review Team (SRT) in assuring the quality of CPRT Program activities.

8701020064 PDR 861222 G

ADOCK 05000445 PDR

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($p , Sli..  ? Appendix T G~toithe CPRT Program Plan states that a series of Policies-M '

. .and Guideline ~s had been. developed;'however, these Policies and C,

• @ .':  ; Guidelines (six in'all) exist only in draft, are' dated February 28,.

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1985 L have no apparent control, but. appear to be issued for use by.

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o CPRT personnel. ,

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1. i' L _ 2.3 LAttachment 1 of Appendix G to the CPRT Program Plan describes how and' lwherelQA: elements applicable to the Issue Specific Action Plans are

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? addressed.~ ;For..the QA element of " Instructions, Procedures, and Drawings," the-appropriate guidance-is stated as being in Section 5.3 t ,

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of," General Policy for Conduct of Action Plans," one of the six draft:

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lnspections,Policies and Guidelines; examinations', however, and tests and theSection 5.3 only QA' element foraddresses

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instructions', procedures,'and drawings is not addressed in the s

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13. 1The charter and objectives of.the 0QT is documented in the " Overview y" . . Quality-Tean-Program for Comanche Peak Response Team Activities,"

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dated February 20, 1986. This document is. intended to support the n ~SRT-in fulfilling its responsibilities; however, there is no evidence m', iof.SRT review and approval of the current version or the preceding versioni(January 1986) of the.0QT program. - Further, the currently W-

. idocumented OQT program is not as comprehensive.as the one described '

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in the Counsil to Noonan letter dated August 16, 1985. See also

. Notice of Deviation, Item C, pertaining to the 0QT (445/8607-D-05).

1C. " Appendix G of the CPRT Program Plan states, in part, "The measures

. " contained herein are based upon the relevant criteria and principals  ;

contained in 10 CFR Part'50, Appendix B."

, Criterion XVIII of 10 CFR Part 50, Appendix B, states, in part, "A comprehensive system of planned and periodic audits shall be carried out r

to verify compliance with all aspects of the quality assurance program

. . . audits shall be performed in accordance with the written procedures or check lists . . . Follow-up' action, including reaudit of deficient

-- areas, shall be taken . . ." The OQT appears to be the principal group established to implement this criterion in whole or part relative to the overall CPRT effort.

' - i In deviation from;the above, the currently documented 0QT program:

'(1) lacks.a system of planned activities related to 0QT audits and reviews and has no clear review and audit responsibility-pertaining to all aspects of CPRT activities; (2) has'no definitive procedure (s) describing the

-responsibilities and authority of the 0QT; and (3) has no procedural controls for the 0QT or SRT that require the timely followup and resolution of identified deficiencies (445/8607-D-06).

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1 h.~ fSection 5.5.1 of Procedure ERC-QA-18,'RevisionLO, " Administration of g _

l Quality Assurance Auditing," states', "The QA Audit administrator logs and

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• g 1; tracks findings'of deviation resulting from audits. Follow-up actions

include

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,/ y :5.5.1'.1? . Maintenance of an Audit [ Status' Log? t o. reflect the current status f 'of.each audit.- See~ Attachment 6.5.  :

5.'5.-l.2  !

Maintenance of an'AuditiAction Request (AAR) status log showing

'( the current status of-each AAR that has been issued."

, " In deviation from'the above,1the Audit" Status-Log did not contain the audit closure date for audit ERC 85-03 even though the findings and audit owere closed on March 21,:1986, as documented in a letter from the audit V*# ;b ' ' l team leader to the QA/QC Review, Team' Leader. Further, neither the current

_ . Estatus nor the audit findings for audit reports ERC 86-01 and 86-02 have

• ', been maintained on the AAR Log'(445/8607-D-08).

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E.c Section'16.0, Revision 0,--'of'the TUGCo's-Quality Assurance Plan states, in v; .part',~"In'the case of significant conditions adverse to quality, which are

. reportable ~to'NRC'under the provisions of 10 CFR Part 50.55(e), measures

.are taken.to assure that-the cause of the condition ~is determined and

' corrective ~ action 11s~ implemented'. . . .'!

. /TUGCo letter TXX-3657' dated April 21, 1963, submitted to NRC in accordance with:10 CFR Part 50.55(e), identified a significant condition adverse to quality:(no objective evidence is available documenting acceptable weld 1

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1 quality on seismic arrestor brackets) and stated that the corrective actions would be to discard and replace the arrestor brackets, and that Jthe corrective action would proceed immediately.

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Indevi$tionfrom'.the-above,thecommittedcorrective.actionshadnotbeen implemented as'of the end of.thisLinspection period (445/8607-D-01).

"F . Section 4 of CPRT-Project Procedure CPP-009, Revision 3, states, in part,

.  :" Qualified QA/QC Review Team personnel perform field reinspections of

_ specific hardware items and reviews of appropriate documents in accordance

, s . 'withfapproved instruction . . . ."

R 3Section 5.1.2 of.ERC Procedure QI-013, Revision 5, dated February 4, 1986, states, in'part, " Verify by review of the inspector certification files

-that each person who' signed as a QC inspector on the Instrument Tubing

- Manufacturing Record Sheet is certified to QI-QP-11.8-1 or -5, whichever was in effect at the time the record sheet was signed."

In deviation from the above, the ERC inspector failed to identify, during

.the review for Verification Package R-E-ININ-079, that the QC inspector was not certified to the appropriate procedure when he signed the tubing record sheet for pressure transmitter 1-PT-4520 (445/8607-D-03).

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, 'M  : G. !SAction1152fofCPRTIssue.SpecificActionPlanTISAP)I.a.2," Inspection M< Reports , A Butt-Splices," states,;in part, '.' Review all drawings and design

& 4 change us ~ mnts involving butt-splices of: safety related cables..in the i,' w - (controltroom and_ cable: spreading room of-Unit _1 to assure that the splices i pp ;are! documented-in the design document "

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n # 1 JInldeviationfromthe'above,CPRTReviewersfailedtoreviewallLdesign

. ,w - bchange documents as. evidenced by the fact.that cables A0102707, E0106963,

E0111093, E0106993 and E0111179 were found to contain splices which were

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. M cnotoshown on;the drawings.'. These splices had been' authorized by Design w w ,

- Change' Authorization ~(DCA)-17,762, Revision 2, and inspection reports m zdocumented that these:spli ces were installed. ~None of these splices were, j-E '"" howedesign tand change documents:(445/8607-D-15).ver; identifi.ed by the CPRT

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H; 'Section 4.1.1, " Inspection Program," of CPRT ISAP I.a.4,' " Agreement

, 'Between Drawings and Field Terminations," Revision 4, dated January 24,.

. ;1986, states,-in part, "An inspection program employing random sampling

.will be initiated.which will enable a determination to be made with

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' reasonable assurance of whether the essential Class IE. conductors in the

' control' room and cable spreading room which interface with the Alternate m *

-Shutdown Panel are terminated in accordance with the applicable drawings."

?. 5'  ; Section 4.1.1.2, "Randon Sampling,'.' of this procedure states,- in part,-

" Based'on the' preliminary determination of a population size of 3812, the

, minimumsample:sizeaccordingtoAppendixDis300witharejectionnumber

, of zero (i.e.,'the critical. region is one er more deficiencies found in the' sample). .If one (1) deficiency is found, a root cause evaluation of the deficiency will be performed, and a sample expansion in accordance j g :with Appendix D will'be undertaken."

In deviation from the above, the random' sample (approximately 338) inspected in this-program included approximately 50 spare conductors which were.not terminated nor shown to be terminated on the applicable drawings

" and,:accordingly, could not be considered to be essential Class 1E conductors which~ interface with the Alternate Shutdown Panel (445/8607-D-19).

I. Section.4 in Revision 4 to CPRT Project Procedure CPP-009 states, in part,

" Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance i=,

[ with approved instructions . . . ."

O f Section4inRevision2toERCQualityAssuranceProcedureERC-QA-28,/QC

" Performance of Overview Inspections, states, in part, " Qualified QA

. Review Team personnel assigned to the on-site QA Representative perform Overview Inspections of work performed in accordance with Reference 3.1

(CPP-009)~. . . ." Section 5.4.2 of ERC-QA-28 states, in part, " Based

upon each accept / reject criterion specified in the referenced QI/ effective Change Notice (s), the 01 (Overview Inspector) denotes whether the item is (un) acceptable . . . ." Section 5.4.3 of ERC-QA-28 states, in part, "The t

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>e 1 OI-compa'res the:results'of the Overview Inspection with the results of the l'

,, l initial reinspection / documentation review to identify any apparent inconsistencies .= .:..."

LIn' deviation from the'above, the following errors were identified

concerning the results of, overview inspections

. 1.1 cThe initial ERC reinspection and the.ERC overview inspection of

. structural steel Verification Package I-S-STEL-146 were not performed in accordance with Revisions 1 and 2 of QI-045, the approved

. instruction. . Attribute 83 :Section 5.1.B.3'of QI-045 states, " Verify visually,-thatthe'connectlonis' orientated,relativetothemember, w~ as specified on the design drawing." This attribute is identical in r =both Revisions 1 and 2 of QI-045. The-initial ERC reinspection was wrformed using Revision 1 of QI-045 and Attribute B3'was accepted.

tevision 2 of QI-045 was used for the~ERC overview inspection and Attribute B3 was again' accepted. In addition, ERC Overview Inspection ~ Report 35-006 for this verification package states that

' , "0verview' Inspection confirms that the initial reinspection / documentation review is: acceptable . . . ." NRC

= inspection,:however, showed that connecting plate C10-17 was

', . incorrectly oriented with respect to member C9-4; i.e., installed at 1the base of member C9-4 instead of at the top (445/8607-D-14).

2. - Overview Inspection Package 13-I-M-LBC0-148 failed to identify an s ' -

unsatisfactory decision made by the initial ERC inspector. NRC

' inspection identified three pipe to pipe clearances which were in violation of Section 5.2.6.2 of QI-025, Revision 3. The initial ERC reinspection as well as the. overview-inspection failed to identify i 1 these deviating conditions (445/8607-D-10).

3. . . Paragraph 5.2.1 in Section 5.0 of QI-037, Revision 0, states, in part, Verify that pipe clamp halves are parallel . . . ." In ,

-addition, Attachment 6.1 states, in part, ". . . dimensions on the c same side of the clamp at points 1, 2, and 3 shall be within 1/16" of each other to be acceptable. Also, the clamp shall be not more than 1/16" out of parallel from side to side at points 1, 2, and 3 to be acceptable."

For Verification Package I-S-PS7N-011, Attribute 2 (pipe clamp halves parallel).on the CPRT checklist was rejected by the initial ERC inspector, with measurement differences in excess of 3/16".

TheOIrejectedthesameattribute,butnotedthatthemeasurement differences were in excess of 1/16". The OI, during comparison of his inspection results with those of the initial ERC inspector,

, failed to identify the inconsistency with respect to the measurement differences. ,

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lin addition, NRC inspection revealed that Attribute 2 should not have been rejected,- in that an acceptable condition existed, with measurements being within 1/16"'of each other (445-8607-D-11).

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- 41. Paragraph 5.5.2 in Section 5.0:of QI-037,-Revision 0, states, in

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part,'" Verify that the cotter pins are the maximum size the hole will

. ' accommodate .. . . ." ' An NRC ' inspection of_ Verification Package

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. 'I-S-PS7N-056-'showed that the cotter pins on the clamp side were

'" -undersized. . No-ERC Deviation Reports were issued by the initial ERC

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_ inspector for. undersized cotter pins. Attribute 5.1 on the decision F ,

point summary for Overview Inspection Package 38-I-S-PS7N-056, lists p

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'" Cotter. Pins and Lock Washers in Place" as four correct decisions.

- 1The. inspection checklist identified no undersized cotter pins

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- 5.. .The-initial ERC' inspector and the 01 signed off as acceptable

~ Attribute 3 regarding spherical bearing gap for Verification 7

L Package I-S-PS7N-146. Independent inspection of this package

. revealed;that the spherical-bearing had been painted, precluding an F accurate l measurement of either the gap or the spacers u -(445/8607-D-13)..

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Section '4.1.2 of CPRT.ISAP VII b.2, Revision 1, states, in part, " Review

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applicable procedures,:for both construction and QC, to determine if they

= provided adequate controls of materials during valve disassembly and

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reassembly .:. . ."

-In deviation from the above, the review did not identify that a equate d 4 -controls were not provided,.in that procedures for disassembly and reassembly did not exist between January and June 19831(445/8607-D-26).

z Texas Utilities Electric Company is hereby requested to submit'to this office,

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'within 30 days of the date of this Notice, a written statement or explanation in reply, including for each deviation: (1) the reasons for the deviations if admitted. (2) the corrective steps which have been taken and the results

achieved; (3) corrective steps which-will be taken.to' avoid further deviations,

-and (4) the date when full compliance will be achieved. Where good'cause'is-shown,considerationwillbegiventoextendingthe;responsetime.

1 Dated at Arlington, Texas this 22nd day of December 1986