ML20205L926

Notice of Violation from Insp on 860701-0831

ML20205L926
Person / Time
Site:	Comanche Peak
Issue date:	03/30/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20205L898	List: IR 05000445/1986020 ML20205L894 ML20205L926 ML20205L966
References
50-445-86-20, 50-446-86-17, NUDOCS 8704020225
Download: ML20205L926 (5)

Text

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APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Dockets: 50-445/86-20 50-446/86-17 Comanche Pesk Steam Electric Permits: CPPR-126 Station, Units 1 and 2 CPPR-127 During an NRC inspection conducted on July 1 through August 31, 1986, two violations of NRC requirements, one with three examples, were identified. The violations involved: A. the failure to specify proper documents / revisions, obtain approval on travelers, and describe work operations; failure of Quality Assurance / Quality Control (QA/QC) to adequately monitor / assure implementation of the traveler system; and the failure to maintain a traveler package at the work location; and B. the failure to correct steam generator spin numbers and documentation. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below:

A. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Final Safety Analysis Report (FSAR) Section 17.1.5 and Texas Utilities Generating Co. (TUGCo) QA Plan (QAP) Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be j prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

1. Failure to Specify Documents / Revisions, Obtain Approval of Travelers and Describe Work Operations 4

a. Brown & Root (B&R) Procedure CP-CPM-6.3, Revisions 1 through 12, has consistently required that procedures and instructions, by l number and revision, be included in the traveler.

Contrary to the above, 21 of 28 travelers reviewed failed to specify or include either the applicable work procedure reference; revision level of the drawing, specification or procedure; or both. For example, travelers R183-1051-5700, RI79-182-2-5700, ME79-260-5700, and EE86-41073-2/4901 did not contain revision levels while MP85-4910-5500, EE84-40170-2/5501, HS86-4450-1-3100, cnd EE86-410/3-2/4901 either did not reference the drawing or procedure (445/8620-V-03a; 446/8617-V-03a).

b. Paragraph 3.1.1 of CP-CPM-6.3 requires the discipline engineers or construction personnel to obtain Westinghouse (W) approval of the traveler if it involves Nuclear Steam System Supplier-(NSSS)

! equipment.

Contrary to the above, 4 of 19 travelers for controlling work on i major NSSS equipment did not include the signature of a W_

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2 representative. Examples are ME79-260-5700, MW86-7510-2-5500, CE79-017-5500, and ME83-2959-5500 (445/8620-V-03b; 446/8617-V-03b).

c. Paragraph 2.2.1 of B&R Procedure CP-CPM-6.3, Revision 9,_ dated February 8, 1982, states, in part, " General information normally

, included on the Operation Traveler is as follows: 1.'Part, serial, or tag number and material description (s) where applicable . . 3. Operation description, methods, procedures (instructions) by number and revision and other information as required to successfully complete the operation in accordance with applicable requirements . . . ."

Paragraph 3.1.2 of the above procedure states, in part, "The traveler package shall contain, or may reference, if normally available, the drawing, procedures, instructions, manufacturer's manual guidelines, etc. necessary to accomplish the activity Contrary to the above, missing or inadequate work operations were identified for two pieces of NSSS equipment and two Class 1E switches for NSSS equipment as follows:

(1) Travelers (ME83-2702-5700, ME79-260-5700, RI83-1051-5700) for safety injection system accumulator tanks (TCX-SIATAT-03; CP2-S1ATRT-01) failed to describe or include at least one of the following: equipment for loading and transporting, minimum 1-inch base to foundation clearance, leveling, and tightening of nuts to secure the tank to embedded bolts (445/8620-V-04a; 446/8617-V-04a).

(2) Travelers (EE82-1415-5801; EE83-0459-5801; EE84-40170-2-5501, part 1) for installing Class 1E switches on safety related valves failed to describe or include at least one of the following: caution to determinate gently to prevent damage, description of standard construction l practice or otherwise reference the determination /  !

termination instruction in EEI-8, specific torquing  !

requirements for back and top cover screws, and specific )

installation instructions as required by paragraphs 3.0, '

4.C, or 5.0 of instruction EEI-21 (445/8620-V-04b; 446/8617-V-04b).

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2. QA/QC Failed to Adequately Monitor Traveler System Implementation B&R Procedure CP-CPM-6.3, Revisions 0 through 12, states that the -

site QC or QA manager and construction superintendents or discipline engineers are responsible for the implementation of this procedure; however, the site QA/QC manager is responsible for monitoring the' implementation of the system. V s

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l Contrary to the above, QA/QC management'did not adequately monitor and assure the effective implementation of the traveler system as

evidenced by deficiencies identified in a sample of 21 of 28 J

travelers. The following are specific examples:

1- -a. Paragraph 3.6 of CP-CPM-6.3, Revisions 5 and 9, require revisions, regardless of their significance, shall be numbered and changes described after the last traveler operation.

Contrary to the above: '

Travelers RI83-1051-5700, Operation 5; ME83-2702-5700, Attachment No. I design dimension; and ME79-260-5700, Attachment

No. 1 manway elevation are examples of travelers which did_not have revision numbers or descriptions of changes.

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! Operation Nos. 2 and 5 on traveler RI83-1051-5700 for nitrogen l

! accumulator tank number 1 were revised after the traveler was l l approved. Operation No. 2 was a minor change; however, No. 5 l

! was a major revision as a step which had been left out was l j added. Such changes were not approved or noted as revisions

(445/8620-V-05a;446/8617-V-05a).

b. Paragraph 2.2.1 of CP-CPM-6.3, Revision 11, dated August 8,

1984, and Revision 12, dated July 14, 1986, requires the quality j control inspector to annotate-the-applicable inspection / revision i numbers on the traveler operation at the time of inspection.

Paragraph 3.1.2 of CP-CPM-6.3, Revisions 11 and 12, requires the quality control inspector to record the design document revision level used at the time of final inspection.

The QC inspectors did not' annotate the inspection

procedure / revision level for HS86-4450-1-3100 MP85-4910-5500, i HS86-4293-1-4900, and EE85-JB-2C-4870 while proper design document revisions. inspected were not annotated for l HS86-4293-1-4900 and HS86-4450-1-3100 (446/8617-V-05b).

i c. Paragraph 3.2 of B&R Procedure QI-QAP-11.1-39, Revision 4,

, states, in part, "QCI shall verify . . . b. The top of the i concrete foundations are free of oil, grease, and foreign materials."

, No operation for assuring foundation cleanliness was described on traveler ME83-2702-5700 for setting the nitrogen accumulator.

I tank No. 1 (tank 1). Another example was identified on

ME79-260-5700 for setting safety injection accumulator tank No.3(446/8617-V-05c).

! d. Paragraph 3.4.1 of QI-QAP-11.1-39, Revision 4, states, in part, "QCI shall verify that equipment is positioned, oriented, and i

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. set to elevation as shown on Level / Location / Elevation / Record (Attachment 1)." Paragraph 5.0 states, in part, " . . QCI shall sign and date . . . Record (Attachment 1)."

Attachment 1 of ME83-2702-5700 was not signed and dated by the QCI to show that the nitrogen tank 1 was installed as required (446/8617-V-05d).

e. Paragraph 3.4.2.2 of QI-QAP-11.1-39, Revision 4, states, in part, "b. All equipment excluding rotating equipment and heat exchangers may be set using a carpenter's level placed on the base or machined surface, as appropriate. The equipment shall be shimmed so that the bubble is contained between the two closest lines on the level. NOTE: for a. and b. above, equipment setting requiring grout, a minimum of grout space of one inch shall be provided at the point of minimum clearance between the equipment bases and concrete foundation."

Neither a minimum clearance was specified on traveler ME83-2702-5700 for tank 1, nor was the applicable construction Procedure MCP-1, Revision 3, referenced (445-8617-V-05e).

f. Paragraph 3.4.3 of QI-QAP-11.1-39 states, in part, "QCI shall verify that anchor bolt threads are not damaged prior to and during the setting of equipment."

Traveler ME83-2702-5700 for tank 1 neither specified-the inspection of anchor bolt threads in the operational steps nor addressed the tightening of the bolts,(446/8617-V-05f).

3. Failure to Maintain Traveler Package at Work Area-Paragraph 3.2 of B&R Procedure CP-CPM-6.3, Revision 11, dated August 8, 1984, states, in part, "The traveler package shall remain in the work area until the work has been completed and accepted by QA/QC or until the end of the shift, which ever is first . . . ."

l Contrary to the above, on July 2, 1986, the NRC inspector observed the heat treating of mainsteam spool piece MS2-RB-29-1 at the 905 ,

elevation in reactor building No. 2 and found that the traveler work )

package was not in the work area. It was later located in the welding rod shack which is outside the reactor building (446/8617-V-06).

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

B. Criterion XVI of Appendix B to 10 CFR Part 50, as implemented by Section 17.1.16 of the FSAR and by TUGCo QA Plan (QAP) Section 16.0, l Revision 0, dated July 1,1978 require the prompt identification, reporting, and correction of failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances. l l

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5 4 Failure to Correct Steam Generator Spin Numbers and Documentation

} TUGCo QAP Section 16.0 states in part, " Documented measures are used to 1 assure that conditions adverse to quality such as failures, malfunctions,

, deficiencies, and nonconformances, are promptly identified and corrected as soon as practicable, and that appropriate action be taken to correct the cause of the condition."

Contrary to the above:

On August 1, 1986,~the NRC inspector found that steam generator spin

! No. TCX-RCPCSG-01 which is shown on Gibbs & Hill, Inc.,

Drawings 2323-A2-502, Revision 5, 2323-A2-0503, Revision 4, and 2323-0504, Revision 4 as being located in reactor coolant loop No. 4 was incorrect.

The steam generator with this spin number.is actually in loop No. 1.

! TUGCo correspondence in 1980 showed that management was aware of this condition and asked Westinghouse Electric Corporatian to correct this deficiency and design documents. Further inspection revealed the

_ following

1. From 1980 to August 20, 1986, TUGCo failed to issue a nonconformance report (NCR) to identify this condition which existed for all four steam generators and failed to tag the steam generators with a hold

, tag to indicate that the name plates and documentation were

incorrect. An NCR was issued after the NRC inspector identified this j problem and discussed it with the site management.

2. From 1980 to August 1986, TUGCo failed to take prompt corrective i action concerning these deficiencies. That is, to either revise FSAR, Volume I, Figure 1-2-18, Amendment 10, 1980; Volume VI, Figure 5.1-1 (2 sheets), " Flow Diagram Reactor Coolant System"; and

, the Gibbs & Hill drawings referenced above, or require Westinghouse to exchange the name plates and revise their documentation to match the as-built condition.

This is a Severity Level IV violation (Supplement II)(446/8621-V-07).

3 Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is hereby required 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 violation: (1) the reasons for the violations if admitted, the corrective steps which which have been taken and the results achieved,

the corrective steps which will be taken to avoid further violations, and the date when full compliance will be achieved. Where good cause is shown, a consideration will be given to extending your response time.

Dated at Arlington, Texas

this 30th day of March 1987 i

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