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Category:NOTICE OF DEVIATION/NONCONFORMANCE FROM A REGULATORY
MONTHYEARML20248A6681989-09-26026 September 1989 Notice of Deviation from Insp on 890802-0905.Deviation Noted:Applicant Did Not Replace Nonqualified Class 1E Diesel Generator Wattmeters W/Qualified Components,Per Util 880325 Commitment ML20147G7121988-03-0202 March 1988 Notice of Deviation from Insp on 880105-0202.Deviation Noted:Nonconformance Rept NCR-87-A00491 & QC Hold Point Not Trended as Required by FSAR to Identify Any Trend Adverse to Quality ML20149J6591988-02-12012 February 1988 Notice of Deviation from Insp on 871202-880105.Deviation Noted:Calculation Package Incorrectly Dated & Isometrics for Conduit Runs Incorrectly Depicted & Measured IR 07100104/20120011987-12-18018 December 1987 Notice of Deviation from Insp on 871104-1201.Deviation Noted:Baseplate Reported to Be 8 Inches Long Found by NRC Inspector to Be 9 Inches Long ML20237D7291987-12-16016 December 1987 Notice of Deviation from Insp on 871104-1201.Deviation Noted:Checklist Attribute 20.2 Incorrectly Verified as 3/4 Inches Npt ML20236L9191987-11-0505 November 1987 Notice of Deviation from Insp on 870903-1006.Deviation Noted:Performance Guidelines for Conduit Support & Routing Walkdowns Not Followed ML20236C6101987-10-23023 October 1987 Notice of Deviation from Insp on 870805-0902.Deviation Noted:Administrative Controls Not Contained in Procedure to Ensure Adequate Retesting of Sys or Design Features Which Have Been Maintained or Modified Following Testing ML20237G3081987-08-0505 August 1987 Notice of Deviation from Insp on 870301-0430.Deviations Noted:Rev 24 to B&R Procedure QI-QAP-11.1.28 Not Revised to Require QC Inspector to Assign Weld Number to Each Weld Shown on Design Drawing & to Document Weld Size ML20216C1801987-06-22022 June 1987 Notice of Deviation from Insp on 870101-0228 ML20214R9351987-06-0101 June 1987 Notice of Deviation from Insp on 861101-1231 ML20206E7981987-04-0202 April 1987 Notice of Deviation from Insp on 860901-1031 ML20205L2351987-03-30030 March 1987 Notice of Deviation from Insp on 860401-0531 ML20205D1021987-03-18018 March 1987 Notice of Deviation from Insp on 860701-0831 ML20207E0131986-12-22022 December 1986 Notice of Deviation from Insp on 860601-30 ML20207E1081986-12-22022 December 1986 Notice of Deviation from Insp on 860401-0531 ML20215J8321986-10-17017 October 1986 Notice of Deviation from Insp on 860201-0331 ML20212P7611986-08-29029 August 1986 Notice of Deviation from Insp on 851101-860131 ML20198E8501986-05-12012 May 1986 Notice of Deviation from Insp During Dec 1985 ML20197E5501986-05-0707 May 1986 Notice of Deviation from Insp on 860201-0331 ML20199K9721986-04-0404 April 1986 Notice of Deviation from Insp on 851101-30 ML20141P0541986-03-0606 March 1986 Notice of Deviation from Insp on 851001-31 ML20133M7301985-10-11011 October 1985 Notice of Deviation from Insp on 850801-31 1989-09-26
[Table view] Category:TEXT-INSPECTION & AUDIT & I&E CIRCULARS
MONTHYEARIR 05000445/19990151999-10-20020 October 1999 Insp Repts 50-445/99-15 & 50-446/99-15 on 990822-1002. Non-cited Violations.Major Areas Inspected:Operations, Maintenance,Engineering & Plant Support IR 05000445/19990141999-09-14014 September 1999 Insp Repts 50-445/99-14 & 50-446/99-14 on 990707-0821.Four Violations Occurred & Being Treated as Ncvs.Major Areas Inspected:Operations,Maint,Engineering & Plant Support IR 05000445/19990131999-08-18018 August 1999 Insp Repts 50-445/99-13 & 50-446/99-13 on 990720-23.No Violations Noted.Major Areas Inspected:Licensee Performance & Capabilities During full-scale,biennial Exercise of Emergency Plan & Implementing Procedures IR 05000445/19990101999-08-12012 August 1999 Insp Repts 50-445/99-10 & 50-446/99-10 on 990510-0628. Violations Noted & Being Treated as Ncvs.Major Areas Inspected:Engineering & Plant Support IR 05000445/19990121999-07-29029 July 1999 Insp Repts 50-445/99-12 & 50-446/99-12 on 990530-0710.No Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support IR 05000445/19993011999-07-16016 July 1999 Exam Repts 50-445/99-301 & 50-446/99-301 on 990618-24.Exam Results:Six Applicants for Senior Operator Licenses Passed Exams IR 05000445/19990111999-06-22022 June 1999 Insp Repts 50-445/99-11 & 50-446/99-11 on 990418-0529.No Violations Noted.Major Areas Inspected:Operations, Maintenance,Engineering & Plant Support IR 05000445/19990081999-06-0909 June 1999 Insp Repts 50-445/99-08 & 50-446/99-08 on 990503-11.Noncited Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support IR 05000445/19990091999-05-12012 May 1999 Insp Repts 50-445/99-09 & 50-446/99-09 on 990419-23.No Violations Noted.Major Areas Inspected:Reviewed Implementation of Liquid & Gaseous Radioactive Waste Effluent Mgt Program IR 05000445/19990071999-05-11011 May 1999 Insp Repts 50-445/99-07 & 50-446/99-07 on 990307-0417.No Violations Noted.Major Areas Inspected:Aspects of Licensee Operations,Maint,Engineering & Plant Support IR 05000445/19990061999-04-30030 April 1999 Insp Repts 50-445/99-06 & 50-446/99-06 on 990329-0402.No Violations Noted.Major Areas Inspected:Planning & Preparation,External Exposure Controls & Quality Assurance of Radiation Protection Activities IR 05000445/19990031999-04-0707 April 1999 Insp Repts 50-445/99-03 & 50-446/99-03 on 990124-0306.No Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support IR 05000445/19990051999-03-19019 March 1999 Insp Repts 50-445/99-05 & 50-446/99-05 on 990222-26.One Violation Noted.Major Areas Inspected:Implementation of Solid Radwaste Mgt & Radioactive Matls Transportation Programs IR 05000445/19990011999-03-0909 March 1999 Insp Repts 50-445/99-01 & 50-446/99-01 on 990208-12.No Violations Noted.Major Areas Inspected:Licensed Operator Requalification Program IR 05000445/19990021999-01-10010 January 1999 Insp Repts 50-445/99-02 & 50-446/99-02 on 990119-22.No Violations Noted.Major Areas Inspected:Operational Status of Licensee Emergency Preparedness Program IR 05000445/19980081998-12-30030 December 1998 Insp Repts 50-445/98-08 & 50-446/98-08 on 981025-1205.No Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support Re Licensee Emergency Response Organization IR 05000445/19980151998-11-19019 November 1998 Insp Repts 50-445/98-15 & 50-446/98-15 on 981102-06.No Violations Noted.Major Areas Inspected:Radiation Program Activities,Including External & Internal Exposure Controls & Controls of Radioactive Matl & Contamination IR 05000445/19980071998-11-19019 November 1998 Insp Repts 50-445/98-07 & 50-446/98-07 on 980913-1024.No Violations Noted.Major Areas Inspected:Aspects of Licensee Operations,Engineering,Maint & Plant Support IR 05000445/19980161998-10-29029 October 1998 Insp Repts 50-445/98-16 & 50-446/98-16 on 981019-23.No Violations Noted.Major Areas Inspected:Testing & Maint, Protected Area Barrier & Detection Aids,Vital Area Barriers & Detection Aids & Security Sys Power Supply IR 05000445/19980141998-10-21021 October 1998 Insp Repts 50-445/98-14 & 50-446/98-14 Has Been Canceled.No Insp Rept Will Be Issued IR 05000445/19980061998-09-30030 September 1998 Insp Repts 50-445/98-06 & 50-446/98-06 on 980802-0912.No Violations Noted.Major Areas Inspected:Aspects of Licensee Operations,Engineering,Maint & Plant Support IR 05000445/19980121998-09-16016 September 1998 Insp Repts 50-445/98-12 & 50-446/98-12 Cancelled IR 05000445/19980051998-08-20020 August 1998 Insp Repts 50-445/98-05 & 50-446/98-05 on 980621-0801.No Violations Noted.Major Areas Inspected:Licensee Operations, Engineering,Maint & Plant Support IR 05000445/19980041998-07-16016 July 1998 Insp Repts 50-445/98-04 & 50-446/98-04 on 980510-0620.No Violations Noted.Major Areas Inspected:Operations, Engineering,Maintenance & Plant Support IR 05000445/19983011998-07-10010 July 1998 Insp Repts 50-445/98-301 & 50-446/98-301 on 980619-26.No Violations Noted.Major Areas Inspected:Operations.All 9 License Applicants Passed Exam ML20236G9321998-07-0202 July 1998 Notice of Violation from Insp on 980329-0509.Violation Noted:Four Examples Were Identified,Where Licensee Failed to Meet Requirement for Design of ECCS Switchover from Refueling Water Storage Tank to Containment Recirculation IR 05000445/19980031998-07-0202 July 1998 Insp Repts 50-445/98-03 & 50-446/98-03 on 980329-0509. Violations Noted.Major Areas Inspected:Operation,Maint, Engineering & Plant Support IR 05000445/19980131998-06-26026 June 1998 Insp Repts 50-445/98-13 & 50-446/98-13 on 980615-19.No Violations Noted.Major Areas Inspected:Licensee Physical Security Program IR 05000445/19980021998-04-24024 April 1998 Insp Repts 50-445/98-02 & 50-446/98-02 on 980215-0328. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support ML20217F6051998-04-24024 April 1998 Notice of Violation from Insp on 980215-0328.Violations Noted:Corrective Actions Were Not Sufficient to Identify That Excessive Leakage in ECC Sys Check Valves During Unit 1 Cycle 6 Required Unit 1 Safety Injection Pumps Be Started ML20216H3501998-04-16016 April 1998 Insp Repts 50-445/98-11 & 50-446/98-11 on 980323-27.No Violations Noted.Major Areas Inspected:Physical Security Program IR 05000445/19980011998-03-19019 March 1998 Insp Repts 50-445/98-01 & 50-446/98-02 on 980104-0214. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support ML20248L8831998-03-19019 March 1998 Notice of Violation from Insp on 980104-0214.Violation Noted:Licensee Failed to Document Heat Related Degredation of Unit 2,Train B Solid State Safeguards Sequencer IR 05000445/19970211998-02-11011 February 1998 Errata to Insp Repts 50-445/97-21 & 50-446/97-21,correcting Errors in Insp follow-up Sys Number Associated W/Items Described in Rept IR 05000445/19970231998-01-30030 January 1998 Insp Repts 50-445/97-23 & 50-446/97-23 on 971123-980103.No Violations Noted.Major Areas Inspected:Operations, Engineering,Maintenance & Plant Support IR 07100012/20110221998-01-16016 January 1998 Notice of Violation from Insp on 971012-1122.Violation Noted:Procedure IPO-005B,rev 2,not Appropriate to Circumstances in That Procedure Did Not Require Pressure Be Maintained Below Rc System Pressure & Temp Limits ML20198S1891998-01-16016 January 1998 Insp Repts 50-445/97-20 & 50-446/97-20 on 971012-1122. Violations Noted.Major Areas Inspected:Operations, Maintenance,Engineering & Plant Support ML20198R6571998-01-16016 January 1998 Notice of Violation from Insp on 970922-25.Violation Noted: on 961029,licensee Made Changes to Emergency Plan,W/O Commission Approval,That Decreased Effectiveness of Plan & Did Not Continue to Meet Planning Standard 50.47(b)(2) ML20198N2071998-01-14014 January 1998 Notice of Violation from Insp on 970608-0719 & Subsequent Inoffice Reviews Concluded on 971114.Violation Noted: Procedures OPT-102A & 102B Did Not Include Appropriate Quantitative Acceptance Criteria ML20199H0131997-11-21021 November 1997 Notice of Violation from Insp on 970831-1011.Violation Noted:Thermometer IC1473,was Used During Performance of Procedure PPT-SX-7505A on 970807 ML20199H0241997-11-21021 November 1997 Insp Repts 50-445/97-18 & 50-446/97-18 on 970831-1011. Violations Noted.Major Areas Inspected:Operations,Maint & Engineering PNO-IV-97-067, on 971117,medical Emergency Declared in Unit 1 Electrical Switchgear Room.Licensee Issued Stop Work Order for Electrical Maint While Investigation Conducted.Nrc Resident Insp Staff Will Be Following Licensee1997-11-17017 November 1997 PNO-IV-97-067:on 971117,medical Emergency Declared in Unit 1 Electrical Switchgear Room.Licensee Issued Stop Work Order for Electrical Maint While Investigation Conducted.Nrc Resident Insp Staff Will Be Following Licensee PNO-IV-97-066, on 971115,new Fuel Damage Occurred.Licensee Suspended Fuel on-load & Conducting Investigation Into Why Damage Occurred.Licensee Expects Delivery of Replacement Fuel Assembly on 971123.State of Tx Informed1997-11-17017 November 1997 PNO-IV-97-066:on 971115,new Fuel Damage Occurred.Licensee Suspended Fuel on-load & Conducting Investigation Into Why Damage Occurred.Licensee Expects Delivery of Replacement Fuel Assembly on 971123.State of Tx Informed IR 05000445/19970221997-11-17017 November 1997 Insp Repts 50-445/97-22 & 50-446/97-22 on 971103-07.No Violations Noted.Major Areas Inspected:Maint ML20199E6481997-11-13013 November 1997 Insp Repts 50-445/97-21 & 50-446/97-21 on 971027-31.No Violations Noted.Major Areas Inspected:Licensee Physical Security Program Including Records & Repts,Test & Maint and Access control-vehicle PNO-IV-97-061, on 971027,Unit 1 Experienced Main Generator Lockout,Turbine Trip & Reactor Trip from 100% Power.Afw Manually Started Shortly Following Trip,In Anticipation of Automatic Initiation of AFW Sys.State of Tx Informed1997-10-30030 October 1997 PNO-IV-97-061:on 971027,Unit 1 Experienced Main Generator Lockout,Turbine Trip & Reactor Trip from 100% Power.Afw Manually Started Shortly Following Trip,In Anticipation of Automatic Initiation of AFW Sys.State of Tx Informed IR 05000445/19970191997-10-10010 October 1997 Insp Repts 50-445/97-19 & 50-446/97-19 on 970922-25. Violations Noted.Major Areas Inspected:Rev 25 to Comanche Peak Steam Electric Emergency Plan ML20211A1051997-09-19019 September 1997 Insp Repts 50-445/97-17 & 50-446/97-17 on 970720-0830. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support ML20211A0691997-09-19019 September 1997 Notice of Violation from Insp on 970720-0830.Violation Noted:On 970507,while Performing Procedure OPT-457B,licensed Operator Failed to Close Valve 2-8812A Per Step 8.8 ML20198G1821997-09-12012 September 1997 Notice of Violation from Investigation on 970606.Violation Noted:Mn Shook Submitted Falsified Info to NRC Re Being Denied Access to Nuclear Power Plant as Result of fitness-for-duty Policy 1999-09-14
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APPENDIX B NOTICE OF DEVIATION Texas Utilities Electric Company Dockets: 50-445/86-26 50-446/86-22 Comanche Peak Steam Electric Station, Permits: CPPR-126 Units 1 and 2 CPPR-127 Based on the results of an NRC inspection conducted on September 1 through October 31, 1986, deviations from commitments to the NRC were identified. The deviations consisted of an Evaluation Research Corporation (ERC) inspector failed to write an out-of-scope memorandum documenting a potentially nonconforming condition, ERC's craft training procedure review failed to identify the lack of a Bahnson personnel retraining requirement and thus failed to recommend procedure improvement, substantive changes to an Issue-Specific Action Plan (ISAP) were made and implemented prior to approval by the Senior Review Team, ERC engineering failed to identify all the HVAC activities and attributes to be included in review and inspection checklists, and ERC inspections in the HVAC area were based on documents different than those used for the inspection of record. 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 5.1.1 of ERC Procedure CPP-020, Revision 1, dated September 23, 1985, states, in part, "Should any QA/QC Review Team personnel observe an apparent defect or discrepancy which is out-of-scope, they are to prepare a memorandum . . . . This memorandum shall be addressed to the TUGCo QA Coordinator . . . ."
In deviation from the above, an ERC inspector failed to write an out-of-scope memorandum for a pull rope found in conduit C12018896 during the ERC inspection for Verification Package I-E-EEIN-024 (445/8626-D-01).
B. Section 4.1.2 of ISAP I.d.3, Revision 0, requires, in part, that ERC perform an evaluation of the craft training procedures including training and retraining, and that the following items will be considered during this evaluation:
"How craft personnel become aware of changes in design and con'truction requirements and how retraining occurs."
"How craft personnel are informed and become knowledgeable of QA/QC requirements / criteria and changes to those requirements / criteria."
Section 4.1.3 of the ISAP also states, in part, " Based on this review (of procedures), conclusions will be drawn by the QA/QC Review Team Leader as to the adequacy of both past and current practices used for craft selection and training. If current procedures are determined to be inadequate, recommendations for improvement will be provided to TUGC0 prior to the closure of this action plan."
g413074o870402 G ADOCK 05000445 PDR
2 In deviation from the above, ISAP-I.d.3 Results Report does not provide a recommendation that TUGCo revise the Bahnson Service Company's craft training Procedure QCI-CPSES-013, " Indoctrination and Training of Personnel," which does not assure that: (1) " craft personnel become aware of changes in design and construction requirements"; and (2) " craft personnel are informed and become knowledgeable of QA/QC requirements / criteria and changes to those requirements / criteria" (445/8Q6-0-03; 446/8622-D-01).
C. The W. G. Counsil letter (CPRT 207) to the NRC, dated January 27, 1986, regarding CPSES submittal of Revision 3 of the Comanche Peak Response Team (CPRT) Prograa Plan and ISAPs, committed that, ". . . further substantive modifications to these documents (CPRT Program Pian ISAPs) will require the approval of the Senior Review Team prior to implementation."
Change Notice 001 to Comanche Peak Project Procedure CPP-024, " Issue Specific Action Plan Revision," dated April 4, 1986, requires that
". . . the SRT approves substantive changes prior to implementation."
In deviation from.the above, substantive changes to ISAP I.d.3 were implemented prior to approval by the Senior Review Team (SRT). For example, in April 1986 the Special Evaluation Team's effort was
- transferred to Quality Assurance / Quality Control (QA/QC)' review team personnel and the issue coordinator was changed; however, the SRT did not
. approve these and otner changes until August 1986 (445/8626-D-04; 446/8622-D-02).
D. Paragraph 4.3.3 of ISAP VII.c, states, in part, "For each population, attributes which have safety significance will be determined . . . .
Justification for not including attributes in'the reinspection or documentation review checklists which have t.een identified as s
nonsafety-significant will be documented and retained as records in the ISAP file. For each safety-significant attribute identified, detailed
- instructions for the verification of the attribute, including definitive
! accept / reject criteria, will be established . . . ." .
In deviation from the above, ERC engineering failed to identify certain work activities and attributes associated with fabrication and installation of HVAC ducts and plenums which occurred prior to 1982.
These activities / attributes included: (1) welded nuts on the interior of seismic volume extractors, and (2) crimps used for attaching various accessories; such as, grills, registers, and associated sealant material.
The failure to iaentify these activities / attributes precluded determination of safety significance. Further, +.here was no justification for not including these activities / attributes in the reinspection or documentation review checklists (445/8626-D-06).
E. Section 2.0 in Revision 1 of both QI-035 and QI-036 requires that reinspection and documentation review be performed on only those duct supports which have been installed and final QC accepted by Bahnson
3 Service Company (BSC). Section 5.0 in QI-036 requires the initiation of a deviation report (DR) for any applicable HVAC duct support attributes identified as not having been inspected by BSC.
In deviation from the above, the following conditions were identified:
- 1. The documentation review verification packages issued to ERC
-inspectors for Unit 1 and common HVAC duct supports, contained the applicable BSC inspection reports and the BSC detail drawings which were supposed to represent the installed and final QC accepted supports.
- 2. The NRC inspector identified that the BSC inspection reports were dated as much as 5 years prior to the initial issue of the detail drawings.
- 3. There was no evidence of inspections performed by BSC QC to verify the duct support configuration to the detail drawing.
- 4. It was further determined that BSC QC used typical drawings for their inspections. These drawings can be dissimilar to the detail drawings provided to ERC. As a result, the ability of ERC to identify attributes not inspected by BSC was affected; thus initiation of all required DRs was precluded (445/8626-D-07). ,
Texas Utilities Electric Company is hereby requested 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 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, consideration will be given to extending the response time.
Dated at Arlington, Texas this 2nd day of April 1987
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