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Uhrrt3 STATES ~
*s N NUCtEAR REGULATORY COMMISSION b, y,48 REGION IV
, ,, 611 AYAN PLAZA DRIVE. SUITE 1000 ARUNGTON, TEXAS 76011 i FEB 2 31987 l
MEMORANDUM FOR: Robert D. Martin Regional Adminis trator Region IV . l FROM: I
- H. S. Phillips 1 Senior Resident Inspector i Comanche Peak Construction
SUBJECT:
'd NoEcurrence With NRC Report t 86-08/06 '
On February February 18, 1987, we met to discuss I. Barnes' 9, 1987, memorandum dated he knew I did not agree.in which Barnes asked me to sign a report with which of our dicussions, We also discussed.my response. I understand that your policy allowL As a resuJL me disa the option of not signing / concurring providad I give my reasons for I also understand that this will not professional opinion at a later date6 preclude offering a different greeing, have elected to not sign or concur on this report because:if the issue I is not re (1) violations were dropped and will not inspector according to an underst,anding reached. (2n by another be writte violation written inRIV management 86-08/06, (3) has mishandledfor and over a year the issua delayed one to.se on my report from May until the Es'rnes present; failed to provide commente provided with RIV. me andspecific (4) thecomments to identify differences pei.e., he never directly final report barely resembles the r inspection IE agreement I documented because someone else wrote it. I did not agree with T. Westerman's unresolved; however, I wrote Report it directive to write a aviolontias Report 86-03/02 as directed in Draft 1 of up in Report 88-03/02 (February 86-06/04 inspection) was postponedand , it finally showed As it has caus finally the original violation ahows up(February March inspe,ction) inspection) which is not yet issued. in 86-08/06ae(April-May unresolved and the report because I am embarassed As a result I cannot concur with violation February 1986,one year after I identitied a violation o them. rictwhich (TUE) a is 248 In cgreed; i.e. I identified Drown a violation with which TUE management assurance pro, gram as&they Root Inc. (D&R) failed to sudit their quality Appendix B to 10 CFR Part 50 indid not audit li of lo of the criteria of 1980. pages Roport.) 1-11 of my June 26, 1986. (I previourly discussed thic on March 1988 and lotI would have preferredtestimvay, the Ac.;ac!mont B of the OIt,
.the cause and corrective TUE perform a moreext ise'vance of tac violation in steps necessary but. ensim rovi.cw to determinx um wir. plashed between I
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l~ r . j, 2 eno.aupervisor.who wanted little or nothing and by another who wanted too much inspection which resulted in my finding additional violations and examples which TUE could have identified in response to the proposed Notice of ' Violation. the single violation was not issued.In other words I did TUE's work becauso In March 1986, I. Barnes assumed the position that Westerman (Promoted) vacated and after dicussing the violation which Westerman did not want violation. Inwritten Barnes addition reversed he directed methe decisionaand to perform verysaid it is a detailed inspection of the B&R audit program for a 6 year period (1980-1986) which resulted in my identifying addit'ional examples where B&R failed-to audit their program to control organization, field design changes, nonconforming
' identification and. items, inspections, control of items,calibration, test. control, instructions / drawings / procedures, document ~ control, handling,& storage, Procurement document control, control of p cuch as welding. Two other violations and control of special processes were identified concerning TUE
.end BAR managements' cudit program which failure to correct serious deficiencies earlier in a in their was identified heveral years Management Analysis Corporation (MAC) audit report. 'This allowed the cudit program to remain deficient until-1986 and perhaps even now. In addition, I found that B&R never effectively audited field design change. control. l These failures to audit have allowed hardware and engineering deficiencies to go underected and is probably responsible for the current dilemma. ,
On or about May 30, 1988, and prior to the meeting with TUE l nanagement, I submitted a written draf t Notice of Violation tc Barnes-who reviewed it and he did not disagree with the findings. On June 3 1986, I presented disagree with the the violations to TUE management and they did not violations. Barnes was at this meeting and onsite continuously thereafter but never mentioned this report. On or about June 30, 1986, the report was tranmitted by computer to Barnes. I nosumed it was acceptable until September'4, 1986, when George Gower. l Office of Inspection And Enforcement, (IE) came to site and said Barnese considered the report to be unacceptably documented. Now, i thr'e months later, I was shocked that Barnes and Gower wanted to change the report and drop two violations. Then on October 15, 1986, Barnes met with me for about 5 minutos to give me my annual appraisal and he made a couple of gencral comments about this report but never gave me specific comments that requested, I orally or in writing. I was given a fully successful l rating (down from the three previouc excellent r. stings by two other supervisors for 1983-1985). i In 24 years a a professional, I have ! never had an unacceptuhle remark than 6 months, decided to include the in an apprad:al but Barnes, in less ! words unacceptable in the
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, supervisors narrative. Again, Barnes never said anything from March with ease. There is onlyreport to October 15 about this or S-6 others which had been issued two words to describe being told this_15 days after the rating period; i .e., improper and unprofessional. .
Naturally I find it hard to believe my 25 previous sup3rvisors and managers were wrong and Barnes is correct. Barnes' failure to provide comments did not comply with the agreement reached in the IE Memorandum dated June 28, 1986, which established procedures for handling Comanche Peak. reports identifying diffe'rences . while the OIA investigation was in process. Barn'os refused to provide me feedback or comments on this report and others however, receiving his comments 1.s the only way that differences can;be identified. listed and sent to IE, as required by the memorandum. I personally believe his refusal to comment and holding the draft l'and draft 2, of 86-08/06 which were submitted on June 30, 1986, and September 11, 1986, re.spectively, were tactics to delay and use this report as an excuse to discredit my. performance because I had openly dicussed unacceptable RIV management conduct and practices first with RIV supervisors and then with NRC Office of Investigation and Audit (OIA).
.I disagreed September with dropping of two violations from my report in 1980, and now. Draft 2 was written as RIV and IE comments instructed; i.e.,*I dropped two violations because they-said anothor inspector would.take care of the violations when he inspected this area as a followup on my findings previously documented in NRC Report 84-32/11, an inspection conducted in September 1984. (The violations in report 84-32/11 identified serious deficiencies in the TUE corporate management of their QA and audit program. Two years passed and I became dissatisfied with the other inspector's followup of my items in this report when I found that no response to 1984 violations was available in May 1986 to describe TUE's corrective action L concerning to the BkB auditthis report.
program Based it wason my recent findings'[86-08/06) relative evident that TUE had not taken effective corrective action on 84-32/11 and other audit reports and l likewise f or E&R concerning the b1AC audit of B&R. ) I initially l disagreed with dropping the violations from my report but finally i agreed to do it if the other inspector would write the violations. Subsequently, I wrote draft 2 as Gower instructed but when it was reviewedapproach. Gower's by Barnes and perhaps others, he apparently dicagreed with
g d crist'48/CE/20 1SH03-3dN S3Sd3 WOdd --- l l 4 On October 22, 1986 Gower came back to site to start draft 3. This I time he wrote almost all of the redraft and gutted the details and said if this did not work they would have to send someone else, Draft 3 was finished and provided to Gower that day. The report was presented for my signature about February 10, 1987. I refused to concur or sign the. report because when I talked to the inspector who was supposed to write the violations (which were dropped) in his report he told me he had no intention of writing the violations. He 1986 told me this about January 6 and again on February 21, I reacted to this by writing a memorandum to Barnes which said I would neither sign nor concur with the report. The chain reaction of errors, delays, and problems was caused by
.identified supervision's failure to allow me to write the one concise violation in February 1986. TUE representatives are aware of the
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j inept handling of this report and the violation which has not been issued for over a year. 1 It is emharassing. This is very similiar to - the handling
;the OIA report.
of other concerns which I discussed in Attachment B of ;
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'H . S . Ph llips Senior Resident Inspector
Enclosures:
Draft 1, 88-03/02, 3/19/86 Draft 1, 86-06/04, 4/9/86 Draft 1, 86-08-06, 6/30/86 Final Report 86-08/06 IE memo 6-26-86 Phillips' memo 1-31-86 cc w/ enclosure L. Zech Chairman, NRC V. Stello. EDO I I. Barnes, RIV CPTG B. Gower, IE ! l I
a a vv~vv w av var eo c a n n a ,--~ ~ ,j *- 9 ORAFT 2, 1 3/19/86 APPENDIY C CONSTRUCTION INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection-Reports 50-445/86 Permits CPPR-126 - 50-446/96-02 CPPR-127 Docket 50-445 ..
, Category: A2 50-446 Applicant:
Texas Uti1i tis ., E3 ectri e Company (TUEC) Skyway Tower N o T G (dA.f e d A[:L ) f $'7) 400 North Olive Street S " V * # "* ( V'O l8 i eh g (v e r a. ia e64M. , d c~_.t Lock Box 01 dec w ,44 (1 3);qlg,(. bui (,v d $ cars N % { Dallas, Texas i 75201 8L I
- F# SolVM N Y W# **'M d*e r e c.4*e y t No Wrn $4 s'$ Yh./ sve-9 A W ( h .' , i . A 3 = , n.c s i e A.
over he#4.' d 6v 4fs'> a-Fccility Names V s e (nr.i . M Comanche Peak Steam Electric Station b w.i aSFs.d h (CPEES) Units 1,& 2 m a r 4,, C K b is*v c hJ .'<:n {
*Z.t., t97(- IQCl,..o% c.,dde.'lth, Innpection Ats Glen Rose, Texas b i 9 ID fI *'# 5 I
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MO [-0 W d Yd 3'( #* eh vio I a-%, . Intptction Conducteda February 1-20, 1986
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pp:ct Leec2/20 ,ino_ow SJlf? NMM C PAGE 2
.nspectors: _
H. S. Phillips, Senior _ Inspector Resident Reactor Date , l (SRRI), Construction, Region IV CPSES Grcup (Paragraphs 1, 2,.3, 4, 5, 6, .* 7, and 8) .
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Consultant
- EG&G-J. H. McCleskey .
(Paragraph 4 and 6) s,7 __ s, Ravicwsd bya _ s I. Barnes, Group Leader, Region V. . g IV CPSES Group .
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no DCA's against this drawing. If the request is made f or drawing 2323-S1-0537, Figure 13, Revision 2, which contains instructjen f or Figure 18, DCA 18728 is identified.
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. Tne applicant corrected the oversight with RevinionA e
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y, ' 19894,therefore,theNRCinspectorconsiders'this.;1' r . :v ~ sea lh. .; . < ;.
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Reactor Coolant (RX) Leon Pine Weldino ,
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The NRC inspector determined that Westinghouse house furnished'the. i< loop piping through three purchase orders with material suppliers and . fabricators. The design bases for the loop is described in F5hR, l
- s Volume XV, Section 5.0.
A design / operating pressure ef, 2485/2235.psig
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and a design temperature of.650 F are required to provide coolant j boundary integrity. The reactor fnlet and outlet ~ piping has a nominal 271/2 and 29 inches diameter, respectively. Circumferential and nozzle to runpipe weldments require radiography (Rhh and penetrant testing .(PT) to assure quality work except no RT t o r equired for nozzles less than 6 incheq. l l Records must be maintained during the welding of the Rx loop piping and part of the records that must be maintained are qaality annurcnce audits of ASME III, Division 1 work activities. The i.21 ding uterted in July 1980 and was completed in September 1981. During'this pc.-icd, the Broun &c Root Inc. Houston office was responsible 4or. audits of ACKE work acti vi ti es. Audit CP-17 dated Dec'embcr 3, 19GC, conteined statements by the auditors that previous tudit fi ndin( r. in CF-16 ht.d 9 ys ......o .
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7[ PAGE 19 k . . sy ( J,{ not been corrected and there is no indication that a supplemental audit was performed after audit CPe17. not corrected involved: no surveillance ofThese deficiencies which were wel di ng h personnel / certification and no monthly trending report , prepared. , pages 3-5 of On time to auditsaudit CP-27 it was stated that the auditors did not hav 1 3 a implementation of owner design changes and authori zed inspection were not evaluated, material. traceability for hanger and component support modification and salvage related to special processes'and design control was not evaluated sufficiently to ass ure conformance with applicable 1 odes and standards. 'Despite this otatement that the annual audit could not be completed, cudit was performed. no follow up The audit checklist for special processes' infers that welding in the fabrication sh'op was checked but no v cf field installation welding. In the absence of . erificati on surveillance which the NRC has previously confirmed titis audit would not effectivey l determine that special processes in the field are prop 2rl y controlled. On page 20 of 26 of the audit checklist, the auditor remarked that there was no way to verify that the QA records storage f acility is constructed to protect contents from destruction by fire, flood, tornadoes, insects, rodents, temperature and humidity except to take the supervisors word on it. He further stated that thcre was no objective evidence of vault being 4-hour f acility for fire, flood, etc. This finding is identical to the findings in NRC Inspection R port No. 25-14/11.' This statement infers that the auditor was comeway prevented from confirming that the fecility met the records requirements ef AN5! N45.2,9 Draft. yet, this octisfactory. characteristic is narkoc! The NRC inspector M r.o f ound that the aucit and gi w c r .- -
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PAGE 20 LM [, checklist did not contain characteristics for the following 10 CFR ! Appendix B Criteries procurement document control, control of purchased materi al / equipment / servi ces, identification of material / parts / components, inspection, test control, control of measuring / test eguipment and nonconformances. It appears that these creas were also not audited annually. B&R QA Manual Section 19 0 states that the entire program shall be Cudited annually. It also requires the use of checklists. During the review of this procedure the NRC inspector found that this document Coes not reference the applicants commitment to ANSI N45.2.12
" Requirement for Auditing of Quality Assurance Programs for Nuc1' ear Power Plants" and does not contain,all of the requiremen.ts of this d cument. One specific example is the requirement to perform extra cudits under certain conditions described in paragraph 3.4.3.; i.e.,
af ter significant changes to the QA [arogram, .When the quality of an item is in feopardy, when independent assessment of program effectiveness is considered necessary and when it is necessary to verify implementation of required corrective actions. The NRC inspector determined that It o f E V Cv: k ok N i '~ 4U BLR scheduled and performed the l cudit at the normal required frequency but they perform:td no supplemental or extra audits when in fact some of the above conditions cxisted. For example, the NRC inspector reviewed the fil e f or Audit ' CP-le and found that this and it neither clearly identifies the 10 CFR 50, Appenoix B criteria nor QA manual sections thet wort. audited. Further, the audit checklist whsch contained cht.rccteri sti cs f or each ( () 1
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criterion was not completed by inserting satisf actory, unsatisf actory, not audited or not applicable and appropriate comments / objective . evidence on the audit area. The adequacy of the applicant's audit. system ~ (which the contrat: tors
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audit program is a 'part of,) was determined to be insdsq previous NRC inspection which was documented irt NRC Raport No. _ 84-32/11. The violations identified in that report are still open and a final response will be made after the applicant Comnnche Peak response Ream completes their work. T'hfs response should also consider and evaluate prime contractor and site subcor, tractor audits . This item is : unresolved (445/8603-U-01, 446/0602-U-01). . 3 No violations or deviationu were identified. s a ~ 6. Safety Rel ated Cemeenents. Unit 2 . i Durino the general inspection in paragraph 1, the NRC inspector ebserved virtually all safety related equipment in both units to determine that the subject equipment was protected while stored in places except where access was blocked by construction in Unit 2 and , come locked areas in Unit 1, Two specific safety rel Ated compcncnts were exemined more closely as follows. c. Component Cooling Water (CCH) pumpn. Tabic 17A-1 of FGr.R Volurc XIV, Gection 17. 0 l i st thotic pumpe e s AC 'C III, Class 3 and 1 Sci smi c Category I. The CCW system provides cn interocdi ato I G)
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.PECTION DATE(5) PRIORITY j Branch Chief l ORT DUE DATE INITIAL /DATE 1.'RITTEN DRAFT COMPLETED d OATE REPORT M EO. jjgy 3 jg7f3 delete / archives IEW SY SECTION CHIEF ; 00E DATE AFTER 10 DAYS: ETURN FOR REWORK . ingpector). . EWORK COMPLETE
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50-446/86-04 F Q yd ' M q. Texan Utilities Generating Company ATTNs Mr. W. G. Counsil - Executive Vice President 400 North Olive, L.B. 81 ' Dallas, TX 75201 Gsntlomens This refers to the inspection conducted by Mr. T. F. Westerman and other members of,the Rwgion IV Comanche Pa.4 Uroup during the period Fcbrucry 1 through March 31, 1986 of act i vi ti es covered by NRC ' Construction Permits CPPR-126 and CFFR *JC7 f or the Comanche Peak Steam and to tho discussion of our findtngs l Elsetric Static,)n. Units 1 and 2. with you and other members of your sta+f at the conclusion of the inspection. Araos of construction' examined during th@ snspection included applicant action on IE Bulletin s, 'r.tr u c t ur a l steel, reactor coolant loop and support welding, mechanical componente, and electrical v:ab12/ component. Within these areas, tho i nt'ipocti on consi sted of asisctive examination of proce9ures and repr esentati ce records, interviews with personnel, ant; observatjont, by thc- i nspectors. These finding's are documented in the enclowd inspection report. Within the scope of the innpmetion, no vi ol ations or deviationn were identified. One unresolved item is idontified in p ar t:ieg3rdi.J_i v of the e nclosed action report. 7?IE.~1Tiifi70ncerns th3 Brown h Root nuJc rt. programT in ich is a af of Tex as Uti'11 ti es audi t program. SinceAiolations in NRC
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worn previ ctpfly idc*ntified'in your audi t pr ogram as' doc'umentedgl yrt thi_S 44errr dos report 84-72/11, it i s,Afery * ~~' i mpcir tan t thnt you tt enti ory? --r -- W2 have also examined actions you have I.ola.n with regard te previously idontified inspection finding. Tho -star.us of thesce i tems i ts
.dantified in paragraph two of the enclov+rl r eport . .In accordance with 10 CFR 2.7'?o W . s i.w e of tntu letter ond thu enclosure will be placead in the NE Public. Doc.omsen t r oom ur. l es s you notify this offico, by telephcmo. vo t h i n 10 cAyc of the dat e of thir.
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PI'd By:gt L8/c2/20 ISNO3-3EN sagd 3 uoMd PAGE 4 CONSTRUCTION INSPECTION REPORT U. $. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report: 50-445/86-06 Permit; CPPR-126 50-446/86-04 .CPPR-127 Docket 50-445 Category A2 50-446 Applicants Texas Utilit'ien Electri.c Company Skyway Tower (TUEC) 400 North'Olivo Street Lock Box 01 - DaIIas, Texas 75201 Fccility Name Unito 1 &2 Comanche Peak Steam Electric Station (CPSES) t Inspsetion At Gian Rose, Texas Incpcetion Conducted: February 1-March 31,'1986 Inspectors: , _ . . . _ H. S. . , _ _ _ Phillips. Senior GenidGnt Reactor Date Inspector CPSES Group (SRRI), Construction, Region IV (Paragraphs !. 2, 3, 4, 5, 6, 7, and G) Consultant: EGtG-J. H. McGicckey (Paragraph 5 arid 7) L5) 4
DU"G Gb' ' D U 68#GB#G8 68N98N8M 88888 12983 t i PMl! 5
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2% . _ - oviewed by _ , _ , , _ , , , _ _ _ I. Barnes. Group Lnodor, Region IV Date CPEES Group Approved: __ -, T. F. Westerman, Chiet, Region IV Date CPGES Group k cuw t . / f l/t $Qb) Inspection Summarv 1Dg_ecti oD CRDApCt ed; Febr_!Jfrv 1 -Mar.r,f) ,hHfh Wepat '50 44T,/ 86-04 Ar eas In,itp.g.,q,tg: Routine, unannounced inspections of Unit 1. Thim included plant tour of the auxiliary building, innpection of applicant action on previously ident.ified items, and Inspection and Enforcement (IE) Bulletins. The inspottinn involved 2C inspector-hours ensite by one NRC inspector. Results: Within three areas inspect ef, no violations or deviations wsro identified. I n sm e_sf.16n Gpf d uc t ed s., rehrutery 1-March 31. 1404. (F2RSC>,0 MMEh .01).
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Arean Inscec3 M Routine, announced,and unannounced inspections of Unit 2. This included plant tours and inspection of applicant action on previously identified items, IE Bulletins, structural steel mat eri al and installation, coolant inop and support welding, mechanical components, and electrical cable and components. The innpection involved 198 inspector hours onsite by one NRC insps+ctor and one consultant. Results: Within the seven nraes inspo'cted, no violations or deviations were identified. l l l 1 (t0)
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^ improperly processed but were not. The first DCA 18728 compl etely changed drawing 2323-S1-0537, Figure 18, Rev. 2.
The second DCA 19894, Rev. O, was used against drawing 2323-51-0537, Figure 18, Rev. 2, to provide Jam nuts or spoiled threads f or bolts installed in slotted holes which was an NRC open item for seismic category steel structures. DCA 19894 was subsequently revi sed (to Revision 1) to eliminate the drawing from its list because the drawing revised. by DCA 18728 no longer contained slotted holes. DCA's which are issued must use original drawings for , reference to maintain traceability. When the DCA was first issued, the fact that the revised drawing did not have slotted bolt holes was overlooked. If a request is made to identif y the DCA's whi ch have been i ssued against drawing 2323-E1-0537, Figure 18, Revi si on 2, the resultant list will show no DCA's against this drawing. If the request is made for drawing 2323-61-0537, Figure 13, Revision 2, which contains instruction for Figure 18, DCA 18728 is identified. The applicant' corrected the oversight with Revision 1 of DCA 19894, therefore, the NRC inspector considers this item ' closed. 6.
's Reactor Cool ant (RX) Loen Pioe Weldino .
The NRC inspector determined that Westinghouse furnished the Rx loop piping through three purchast orders with material suppliers and fabricators. The design FSAR, Volume IV, Section 5.0. bases for the loop is described in 2495/2235 psig and a design temperature,A design /operatgng of 650 F arepressure of required to provide coolant boundary integrity. The reactor inlet and outlet piping has a nominal 27 1/2 and 29 inches diameter, r espec ti vel y. Circumferential and nozzle to runpipe weldments require radiography (RT) and penetrant testing (PT) to assure quality work except no RT is required f or nozcles less than 6 inches. Records must be maintained during the welding of the Rx loop
.pipine and part of the records'that must be maintained are quality assurance audits of ASME III, Division 1 work activiti es.
The RX loop September welding started in July 1980 and was completed in 1981. During thi s period, the Brown & Root Inc. Houston activities, office was responsible for audits of ASME work
- a. B&R Audit Recutrements
- B&R be shall QAaudited Manualannual Sectionl y.19.0Itstaten that the entire program al so requires the use of checklists. DurinQ the review o< thss procedure the NRC inspector found that this docummit does not reference the applicant's commi tment to ANSI N45.2.12 " Requirement for Auditing of Quality Assurance Programs for Nuclear Power Plants" document.and does not contain all of the requirements of this One specific example is the requirement to
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41*d 0S851 48/C3/30 1 SHOD-DdN S3Sd3 WOdd PAGE.16 perform extra audits under curtain conditions described in paragraph 3.4.3 3 1.e.. after significant changes to the OA program, wi'en the quality of an item is in jeopardy, when independent assessment of program effectiveness is considered necessary and when it is necessary to verify implementation of required corrective actions.
. b. Audit CP-17 Dated December 3. 1980 (1) This audit contained statements by the auditors that previous audit findings in CP-16'had not been corrected and there is no indication that a supplemental audit
,g [4f vre was performed after. audit CP-17. .These deficiencies which were'not corrected involved no surveillance of welding personnel / certification and no monthly trending report was prepared.
(2) On.pages 3-5 of audit CP-17 the auditors stated that they did not have time to audit the f ollowing parts of
- the QA program or the areas were not sufficiently audited. They statedu "In addition to the areas (Design 4 46/v
\l: 0 Control and Authorized Inspector) not evaluated, the team believes that material traceability for hanger and component support modification and salvage, related to special processes and design control, was not evaluated sufficiently to assure,conformance with epplicable codes and standards." Despite this statement that the j annual audit could not be completed to anrure I I
compliance to requirements and codes, management required no f ollow-up or supplemental audits to be performed. It was not audited until the next annual audit was due about a year later and since.no checklist is avai 'l bl e for CP-18, the NRC inspector al so cannot determine if it was adequately audited this year. This statement shows that the entire OA program was not l
. audited.
(3) The audit checklist for special processes shows that welding in the fabrication shop was checked but there appears to be no verification of field installation welding in the reactor, safeguards, diesel generator, V,g{ A (On or auxiliary building areas. In the absence of surveillance, which the NRC has previously confirmed, this audit would not effectively determine'that special processes in the field are properly controlled at a time when welding activity was very high. (4) On page 20 of 26 of the audit checklist, the auditor remarked that there was no way to verify that the OA records storage facility is constructed to protect contents from destruction by fire, f l ood ', tornedoes, insects. rodents, temperature and humidity except to s/,o(ktf" take tne supervisors word on it. se further statee
. (#1)
SI'd TG:GI LS/C2/20 ACNOD-DON SDSd3 WOdd
/
PAGF 17 that there was no objectivo evidence of vault being 4-hour facility for fire, flood, etc. This finding is identical to the findings in NRC Inspection Report No. 95-14/11 .nd other reports mace by. TUGCO CA consultants. This statement was someway prevented infers that the auditor from confirming that the facility I met the records' requirements of ANSI N45.2.9 Draft Revi si on 0, yet, this characteristic is marked 15, satisf actory. It appears that this block should have been marked unsatisfactory. The auditor'certainly must not lookjust take theevidence. at objective super.viser's word for it but must (5) The.NRC-inspector also found that the audit and fcheckli ollowingst10 didCFR not Appendix contain characteri B Criteria stics f or the procurement document control, control of purchased
, p' h skd material / equipment / services, identification of V
mat eri a,1/ par ts/ c omp onent s, inspection, test control,, contr ol of measur irig/ test equipment and nonconformances. It appears that these areas were also not audited annually., c. Audit CP-1B Dated October 16. 1991 The NRC inspector reviewed this audit file and found that this audit neither clearly identifies the 10' CFR 50, j vre Appendix B criteria nor QA manual sections that were audited. Further, the audit checklist which
\y &( p s
contained characteristics for each criterion was not completed by markinct satisf actory, unsati sf actory, not audited or not applicable. Also appropriate comments / objective evidence concerning the audited areas was not documented. d. B&R Audits For 1993-1995__ Theconducted
- 30) NRC inspector evaluated subsequent al2 B&R audits (CP-19 through to CP-19. The following observations were made:
(1) No checklist are in the official flies. These must be obtained from the B&R Houston office to conplete this r evi ew. YtdiAg,gr(2) ~~ It appears that all 10 CFR 50 Appendix B Criteria and the B&R OA manual sections were not audited. l (3) There is no indicatacn as to how many discrete project I procedures enc work activities were audited. No NRC findings ) can be mede untti the checklists are i received from the Housten, Texas of fi ce and thi u inf ormation is reviewed and evaluated. (lI)
l PAGE 18 e. TUGCO Audit Proorns The NRC inspector evaluated the TUGCO audit program located in Dall as, Texas in. August 1984 and documented violations for an inadequate audit effort in NRC Report 84-32/11. Since the BLR audit program is part of TUGCO's comprehensive audit program (as required by 10 CFR 50 Appendix B and FSAR
.jks(,h Section 17.1.18, Audits), TUGCO's corrective action for pd these violations 'should have specifically considered audi t functions which were delegated to all site contractors.
Section'1.3 of ANSI N45.2.12, Draft 3 Revision 0-1973 states that audit work may be delegated but the plant owner 5 retains responsibility.for assuring overall effectiveness of the program. It also states: "In no way shall the performance of audits by an organization operate to dimichish the responsibility'of any other organization or contractor for audit of his designated porti'on of the quality assurance program. The i tems described in paragraphs ba,-e. concerning audits are unresolved 446/8604-U-01) pending the completion of this revi ew. (445/8606-U-01, No violations or deviations were identified.
- 7. Safety Related Comoonents. Unit i and 2 During the general inspections in paragraph 4, the NRC inspector observed virtually all safety related equipment in both units to determine whether the subject equipment was protected while stored in place (except where access was blocked by construction '
in Unit 2 and some locked areas in Unit 1). Two speeffic safety related components were examined more closely as follows.
- a. Component Cooling Water (CCW) pumps Unit I and 2. Table 17A-1 of FSAR Volume XIV, Section 17. 0 l i st these pumps as ASME III, Cl as s 3 and Seismic Category I. The CCW system provides an intermediate barrier between r adi oac ti ve heat sources and the Service Water System (SWS). It removes heat !
f rom various plant components and must operat e during all phases of plant operation. Each system has two 100 percent capacity CCW pumps to provide redundancy. The inspector performed an inspection of two ! Bingham-Will amette pumps af ter learning from craftsmen that these pumps were in the proccus of tear-down. Startup perscnnel were contacted to review this work and it was determined that linear indications were found on the cant impe11ers mace from ASTM A216, Grade WCB. According to the j documents rev3ewed, these cricks appeared to be casting shrinkage cracks. i BLR had iceued nonconformance report N-20,613 and 20,614 dated January 24 1966. Bingham-Willamette Company letter dated Janua y 9, 1985, l l '() .
. 02*d 22:C1 48/C2/20 15NO3-SMu s9949 u o_hgg,,, l l ,, i l
1 I A rs Reply Refer To: Docket: 50-445/G6-00 DRAI i 1 50-446/06-06 6/30/H6 T Texas Utilities Generating Company ATTNs Mr. ; W. G. Counsil j h Executive 400 North Olive, 1. . B . 81 Vice President ! Dallas, TX 75201 l Eentl emen s This refers to the
'Phillips and other members ofconstruction inspection conducted by Mr. H. G.
the Region IV Comanche Peak Group during the period April 1 through May 31, 1986, of activities authorized by NRC Construction Electric Permi ts CPPR-126 and CPPR-127 f or the Comanche Peak Steam Station, -{ Units 1 and 2, and to the discussion of .our findingu < with you and other members of inspection. your staff at the conclusion of the Areas of construction examined during the inspection included a review of activi ties, action on previous findings, plant status, Brown & Root . audits cnd pipeofsupports site activities, electrical cable / instrumentation installation
/ restraints. ,
consisted of selective examination ofWithi,n these areas, the inspection records, procedures and representati ve The inspection fi'ndings are documentedinterviews with personnel,? and' obse in the enclosed.Jnspection report.
?.
During in violation thisofinspection, NRC requirements. it was found that certain of' your activi ti es wore Consequently, you are required to respond to those violations, in writing, in accordance with the provisions Title 10, Code of Section of Federal 2.201 of the NRC's " Rules of Practice," Part 2, Regulations. the specifics contained Your response should be based on lotter. in the Notice of Violation enclosed with this ( C1 so during thi s inspection, i t was found that certain of your acti vi ties cppeared the NRC. to deviate These items from accepted industry standards / commitments made to identified in the enclosed Noticeandof respond references to che Deviation. Youstandards / commitments a arn requested to j to,these deviations in writing. the specifics contained the the Notice ofYour response nhould be based on lctt er. Deviati on encl osed wi th this We have also examined identified inspection findings. actions you have taken with regard to previousl y in paragraph 3 of the enclosed report. The status of these items is identified ;
\ / Si mn .
02*d 2G G1 LS/C2/20 ISNOS-SMN SEGd7 uosg _ , _ Ira Reply Refer:To: Docket DRAI i 1 50-445/G6-00 6/30/H6 50-446/86-06 . Texas Utilities Generating Company ATTN: Mr.. W. G. Counsil Executive Vice President 400 North Olive, L.B. 81 Dallas, TX 75201 Gentlemen This ref ers to the construction inspection conducted by Mr. H. S. Phillips and other members of the Region.IV Comanche Peak "roup during the period April 1 through May 31,: 1996, of activities aut' ori zed by NRC Construction Electric PermitsUnits Station, CPPR-126 1 and and CPPR-127 for the Comanche Peak Steam 2,- and to the discussion of .o it- findings with you inspection. and other members of your staff at the conclusion of the s Areas of - construction examined during the inspection inc.luded a review o4 cctivities, action on previous findings, plant status, Brown & Root cudits of site activities, electrical cable / instrumentation installation, cnd. pipe supperts/ restraints. With4n these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel,1 and' observations by the inspectors. The inspection fi'ndings are documented in the enclosed dnspection report. During this inspection, it was found that certain ofN your activi ties wore in violation of NRC requirements. Consequently, you ar e required to respond to these violations, in writing, in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Your response should be based on the letter. specifics contained in the Notice of Violation enclosed with this 1 Also during this inspection, it was found that certain of your activities cppeared the NRC. to deviate from accepted industry standards / commitments made to These items and references to the standards / commitments are identified in the enclosed Notice of Deviation. You arn requested to rospond- to. these deviations in writing. Your response should be based on the 1ctter. specifics contained the the Notice of Deviation enclosed with this W3 have also examined actions you have taken with regard to previously identified inspection findings. The status of these items is identified in paragraph 3 of the enclosed report. l I () m ,. . . . . . **- '
12 d CG3G1 48/CG/20 1SNOD-DON S2Gd3 -' 2 The response directed by this letter and the accompanying Noti co a E. not subject to the clearance procedures of the Office of Managemont and Budget as required by the Paperwork Reduction Act of 1980, PL'96-511.. Should you have any questions concerning this inspection s we will be pleased to discuss them with you. Sincerely,
~
1 E. H. Johnson, Director Division of Reactor Safety
~
and Projects Enclosures _ 1. Appendix A - Notice of Violation
- 2. Appendix B - Notice of Deviation
[ 3. Appendix C - NRC Inspection Report 3 50-445/86-00 0
~
50-446/96-06 . _m. *
- E-~{ cc w/ enclosure
=
~"
J e 4 Texas utilities Electric Company
._ . k ATTN: J. W. Beck, Manager, ~
._., C Licensing .
.. Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 '
Juanita Ellis President - CASE 1426 South Polk Street Dal l as, Texas 75224
~
Renea Hicks Assistant Attorney General Environmental Protection Di vi si on P.O. Box 12548 Austin, Texas 70711-2548 Texas Radiation Control Program Director I I L)
4 6.t?)EN.LQU !.'t NOTICE OF VIOL AT 1pN, . Texas utilities Generating Company Dockets: 50-445/86-08 50-446/86-06 Comanche Peak Steam Electric Permits: CPPR-126 Station, Units 1 and 2 CPPR-127 During an NRC inspection conducted on April 1-May 31, violations of NRC requirements 'were identified. The vi1986
' Texas Utilities Generating Company's (TUGCo) failure tooltake-ef+ective ations invol ved:
and comprehensive corrective action'on audit program d=ficienciens failure of Brown & Root Inc. to perform annual audits of the entire QA program during 1980, 1982, and 1984; failure of StR to audit the QA Manual and implementing procedures to a sufficient depth to assure control of field design changes, special processes, and inspection cctivi t,1 es' 4 rom 1900 through 1985; failure of D&R to develop /use checklists which provido objective evidence of complianco; failure to cdequately audit special processes inside the reactor, auxillary, cafeguards and diesel generator buildings from 1980-19651 failure at shR to correct audit program deficiencies identified by consultant audits which remained deficient from 1990-19853 failure of B&R to correct doficienci instrument es identi fi ed in audit CP-16 3 failure of TUGCo to address installation criteria in a procedures and f ailure of TUGCo to
- dEf Adequately i ci ency. f ollowup on the correctivb action commitments f or an audit In accordance with the'" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985),
the viol ations are li sted below l A. Criterion XVI of Appendix B to 10 CFR Par t 50, as implemented by Final Saf ety Analysi s Report (FSAR). Section 17.1.16 and Texas Utilities Generating Company (TUGCO) Quality Assurance Plan (OAP)
.Section 16.0, Revision 0, dated July 1, 1978, requires that condi ti ons adverse . to quali ty be promptl y i dent $ fi ed, corrected. reported, and FSAR Section 17.1.16, "Correcti ve Acti on", states that TUGCo requires that measures be established to assure that conditions adverse to quali ty are promptly identi f ied, reported, and corrected.
Responsibility f or performing corrective action is assigned to contractors, applicable subcontractors, and vendors so that each is alert to those conditions adverse to quality within his own area of ac ti vi t y.
- 1. TUGCo f ailed to take adequate and ef f ecti ve corrective action concerning audit deficiencies identifiad,in P. S. Lobban (a consulting engineer for TUGCo) Report dated February 4, 1982 concerning the site audit progrsms which included contracter audit programs.
(I9)
oc c .m _ - _ _ _ _ _ - - _ _ - - - - - - - - - U 2. 1UGCo 4.si)eri t o t .s kt- ca.wruhans) ve c.ar 6 <'cti vc' ac.t a on concer ning W2 te contractor C 4udit progr an>s M tce the NHC Construction Appraisal Team (Cal) report dated spril 11, 1984 40und that a si te contractor
- c audit program had been ineffective in detecting and obtaining correcti ve action in saf ety rel ated mechanical and electracal. components for heating, ventilation, and air conditioning (HVAC). That is, TUGCo did not adequately evaluate other si te contractors' audit programs (including the Brown and . Root Inc. site audit program) to assure that similar de'ficiencies did not ' exist in other areas of the site audit program.
As a result of TUGCo*s-failure,te take adequate corrective action on audit deficiencies identified but not limited to the above examples, the BLR audit program has'been deficient from 1980 through'1986 as evidenced by the noncompliance described in Violations B and C below and Deviation No. 2 in Appendix B Notice of Deviation. This is a Severi ty Level IV violation (Suppl ement II) (445/8608-V-01; 446/8606-V-01). B. Cri terion XVI11 of Appendix B ko 10 CFR Part GO as iniplemented by TUGCo QAP Section 18. 0, Revi sion 2,. dated Jul y . 31, 1984 and ISAR Section 17.0, requires that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with 613 aspects of the quality assuranse progr am to determine the effectiveness of the program,a,nd be performed in acccedance with procedures or checklists, results be documented, and followup action, including reaudit of duficient areas, shall be takon. 1. FSAR Section 17.1.18, " Audits", r equi res that plannod .and periodic audits be performed to varity compliance w2th all aspects of the quality asr.ur ance program and to dotermino the \ effectiveness. Brown & Root Inc. OA Manual Section 39.0 ssnuud Septemcer 17,1981 and implementing procedures uAP-lu.1 dated July 14, 1975 and subsequent r evis2 cns and CP-OAP+-19.1 dated Octobur 15,1984 (which superceded GAP-18.14 require the BLR QA manager to assure that the entire QA program is audited annual l y. Contrary to the above, Brown t Root Inc. failed to audit the entire ASME/CA program to dotermine program effectiveness for calendar years 1980, 1982, and 1984. (4 45/8608 -V-04 ; 446/8606-V-04)
, 2. FSAR Section 17.1.5, " Instructions, Procedures, and Drawings", requires that saf ety rel ated activit ios be accomplished in accoccance os 19 those occumento and thecugh auditing, as described in 17.1.10. 1UGCo determinos that
/ty)
6 quel s ty rel ated et ti vs t i on M e iset.4,n.p t : uhed in Accordance utth , those approved instruction, peccedures, and drawings. B&R DA Manual Section 19.0 issuod contember 17. 1981 requiren that measures be established for an audit program that will provide objective evidence c4 compliance with the GA manual; compliance with pertinent specifications, codes, and procedures; and a method of keeping management. informed of QA program effectiveness. Contrary to the above B&R f ailed to adequatel y audit the site ASME'QA manual, specifications, codes, and procedures to assute QA program ef f ectiveness ar. f ollows (445/0608-V-08; 446/8606-V-OB): , s. S&JLffAL1 sd,qto, audit the QA Manual and procedures; 1.e., 6nor t g gimpleme 7;d Yng procedures for41QOgdesign indicated that neither the QA Ma control (f i el d changes) and the Authorized Inspector interface activities were audi ted. Also, the C&H auditorn inf ormed managemorit in this report that the aron of meterial tracuabilsty f or-hanger and component support niadi f i e nti on ( r el ate'd to speci al processes and design control) were not sufficiently audited ta assure compliance. with applicable codes and standards.' There is no evidence that these areas
. recei ved emphasis curing (subsequent) audits.
b. BLR failed to audit the OA manual and procedures; i.e.,
' B&R OA Manual Section 4.0; " Design Control" issued September 17,1981 and implementing procedures for field changos which were in effect trem 1980 through 1985 were not audited to sufficient depth and were not audited at all in 1V80 and 1985. The audit reports f or thi s 6 year period do not document the audit of any i implementing procedures; i.e.,
CP-CFM-4.1 (1981) " Construction Request for Engineering Design Changes"; CP-CPM-9.13 (1984 Revision 10) " Modi fi cati on c+ Vondor Supplied Cetolog 3 Item"; GCP (no date) " Control of Finld SFotches"; WE1 4.n (1982) " Instruction for Control 01 WeJ di ng Engs neeri ng CMC's"; and CP-QAP-04.01 (1983) " Program for Repair / Alteration of ASMC-N Stamped Compenents". c. B&R failed to audit the OA manual and procedures; i.e., B&R QA Manual Section 10.0 " Control o+ Spe=ial Processes" issued September 17,1981 and implementing procedures which were in effect from 1990-1905 were not audited to sufficient depth and were not audited at all in 1984 The audit reports for this 6 year period reference approx 2mately 12 (CA manual sect 2cos, procedures, and construction procedures) of 76 applicable project documents (l ess may have beon audited). This activity represents a large part ci the ASME work activity (l91 l
ue a va-v- m- - - ~ _ - e
- pur 1 or med ior iUt3Co .nd a p.otias Audst c.1 1cm. th.o J.% c. ;
l the project documents pur year A *. ton l ow f or thi s ! 1 mportant . wor k acti vi t y.
- d. B&R failed to audit the CA manual and procedurns; i.e.,
BhR QA Manual Section 11.C, "Ex6mination, Tests, and i Inspections", issued September 17, 1981 and implementing procedures which were in effect from 1980 through 1985 were not audited to sufficient depth and were not audited at all in 1980. The audit reports for this 6 year period references 8 of 55 applicable project documents (less may have been audited). Thi s ASME work activity represents a large amount of work done for TUGCo and partial audit of less than 3% of the applicable project documents is too low f or this QA f unction which veri fies the quality of site work.
- 3. FSAR Section 17.1.18, " Audits", requires auditing checklists and examination of the essential characteristics of quality related activities and Section 17.1, " Organization", requires the.same of BLR as it statos that tho HLR CA program conforms with the overall TUGCo GA s program.
D&R audit implementing procedures QAP-18.1 (dated July 14, 1975) and CP-QAP-19.1 (which superceded QAP-18.1) dated October 10, 1994 require the use of checklist.and the evaluation of objective evidence that the QA program has been ef f ecti vely implemented. . Contrary to the above, i
- a. B&R failed to develop and use check 11'sto and provi de objective evidence for Soction 4.0 " Design Control" and Section 20.0 "Authoriced Nucloar Inspector Interface" in Audit reports CP-27 (1985) and CP-30 (1986).
)
- b. A checklist for Secti on 4. 0 was not de vel oped in CP-17 j (1980) and the handwritten notes for thic area were not accompani ed by the designators "s" and "u" for ,
satisfactory / unsatisfactory. The objecti ve evidence on l the right hand side of the checkli st to r.oto what was i specifically checked was about one-half complete for Audit l CP-18 and incomplete for page 12 of CP-21 (1983). 445/8608-V-06; 446/8606-V-06)
- 4. FSAR Section 17.1.9, " Control of Special Processes",
requires the prime contractors to control special processes through procedural controls examination, tests and inspections which are aucited to verify the adequccy of sclectod site and vender shop ectivities and the effectiveness of thc- Epocial procuss control proceduros being implemented.
~
(2 o) m __m.__ _
i B
' IJf<lV NA tbriocJ & c.t i can )?.C. 'AuJJt ". i w.uud Gupt.wniber 17, 1901 requires that audits be performed to assure compli.mco wi th pertinent specifications, codes, and pr ocedudres.
Contrary to the above, audits performed from 1980 throuch 1985 do not document the adequate audit of special processes inside the reactor, safeguarLs, aux 111ary, control and diesel generator buildings; i.e., actual field welding (in process or completed), in process non-destructive testing,-post weld heat treatment,,and bending and forming. That i s, for some processes no objective evidence was found while in other cases very
'little was f ound to demonstrate that controls were' ef f ectively implemented. (445/8606-V-07; 446/G606-V-07)
This is a Severity Level'IV viciation (Supplement II). C.- Criterion XVI of Appendix'B to 10 CFR'Part 50, as implemented by FSAR Section 17.0 and - TUGCo QAP Secti on 16.0, Revi si on 0, dated July 1, 1978 requires that conditions adverse to quality bo promptly identified, reported, and, corrected. FSAR Soction 17.1.14 states that TUGCo requires measures be established to assure that conditions adverse to quality aro promptly identified, reported *,s and corrected. Responsibility for perf orming cor rective action is assigned to contractors... so that each is alert to those conditions adverse to quality within his own area of activity. Brown & Root Inc.'(BLR) OA Manu'n1 Section 17.0 issued September 17,1991 states, in part, "This section establishes the method f or assuring _that conditions adverse to quality are;promptly... corrected and corrective action to preclude recurrence is implemented". Contrary to the above
- 1. Brown & Root Inc. f ailed to correct audit pr ogram deficiencies identified by Management Analysis Company (MAC) audits conducted ior Brown !< Root at the Houston, Te: as Corporate office and the Comanche Poal: s f. t e . The MAC findings, in June 1977 wores (1) Houston audit program is ineffective, and (2) site audit program is ineffective. Recent NRC inspection findings, as described in Violation B above, show that these audi t program def i ci encies were not corrected as the audit program continued to be ineffective and deficient through 1985 and part of 1986. (445/0600~V-09; 446/8606-V-09)
- 2. B&R audit CP-16 (1979) identified de41 ct encias that remained open for 2 years or mere af te r this audit was conducted. It is i apparent that corrective action WAs n o t, accomplished in a reasonable amount of time for importent findings such as "no surveillance of Welding persenne) / cort ificat i on" and "no monthly trend s'eports prepar od" . In cac ri t t i on , management took A ()
4 m.___._______________.____J
9 rio w.i i co uti Loch i ors, r erpos-t u ni ari J neom;11 et e eutta t in Cl" 17. (445/H606- V-Ob; 446/R606-V-031 Thi s i s a Seversty Level IV violation (Supplement II). D. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section_5.0, Revision 3, dated July 31, 1984, of the TUGCo QAP,
' requires that activities af f ecting : quality shall be prescribed by documented i nstructi ons, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
- 1. TUGCo Instruction, Q I - Q P - 1 1.. G - 5 , Revision 19, dated March 4, 1986, " Inspection of Instrumont Tubing Fabrication, Instal.l ati on, and Instrument Installation", Paragraph 3.2g, states, " Verify instrument installation is complete in accordance with applicable drawing".
Contrary to the above, GI-OP-11.6-5 does not specifically
., address the tightness of gland nuts on instrument isolation and drain valves, and, in addition 3 inspections were not appropriately performed in'accordance with the requirements of paragraph 3.29 of QI-QP-1'Ad . 8-5. As'a result the NRC inspector found loose gland nuts on isolation and draintvalves associated wi th pressure transmi tter 2PT-965, and flow transmitter 2FT-4560. Addi ti onal l y, the NRC inspector determined that the problem is wider in scope than the two cited examples.
5 (445/8606-V-12)
- 2. TUGCO Procedure DQP-AG-5 " Internal Au'dit Deficiency Followup /Closecut", Revision 1. dated April 23, 19E6 states. in part, "For deficiencies requiring verifica' tion, t he loam Leader is responsible for... verification of implementation of commitments...The results of the verification will be documented and will clearly delineate what objective evidence was reviewed to verif y implementation. . .
Contrary to the above, audits deficiency No. 1 of TUGCo 04 audit TCP-51 (Septemmer'19E2) was improperly closed out. Thet is, the auditor did not verify the implementation of commitments to correct the deficiency prior to closing the audit finding. (445/8408-V-10; 446/8606-V-13) This is a Severity Level IV violation (Supplement II) 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 vselotions (1) t he r easons '1'or the violations if admittod, (2) the corrective steps which have been l taken and the results achieved. (3) the encrecti ve steps. which will be taken to avoid further violations, and (4) the date when full cenplianco l C 2 2-) _ _ _ _________b
va a wu v. mm. _ _ __ _ _ _ l q, to will be achieved. Wteere good c:ause in shown, consideration all) be given to extending your- tesponse ti mte. '. Dsted at Arlington, Texas, this day of 1986 e 3 e 9 4 l l e
l 1 . . 11 AJTENDif Q N_QL CE OF,,Dgy)AT1pN , Towas Utilities Electric Company Dockets: 50-445/86-08 50-446/86-06 Comanche Peak Steam Electric Station Permits: CPPR-126
' Units 1 and 2 CPPR-127 Besed on the results of an NRC inspection conducted dur.ing' April 1-May 31, 1986, one deviation of your commitments to the NRC was identified.
The deviatier. consisted of' failure to establish prope'r criteria for supplemental audits of site activities. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Pcet 2, Appendix C'(1985), the deviation.is listed below: FSAR Section 17.1.2 commits to the establishment of an audit program in cccordance with American National Standard Institute (ANSI) N45,2.12 Draft 3.0, Revision O. Paragraph 3.4.-3 of this standard describ'es criteria an'to when supplemental audits are performed. In deviation from the above
- 1. 'TUGCo audit procedure DQP-QA-15, Revision 0, left out part of the supplemental audit criteria as described in paragraph 3.4.3 of the ANSI N45.2.12. (445YG608-D-033.446/B606-D-03)
- 2. B&R audit Procedure CP-QAP-10.1 (iscued in:1975) does not agree with TUGCo procedure or ANSI N45.2.12 because BLR changed the commitment for supplemental audit criteria from "are performod" to "may be performed". '(445/8608-D-02, 446/8606-D-02)
Texas Utilities Electric Company is hereby requested to submit to this office, within 30 days of the letter transmitting this Notice, a written statement or-explanation in rep!y, including for each deviation: (1) the
' reason for the devi at i on if admitted, (2) the corrective steps which havn bcen taken and the
\
9'f
6 a e
- 12 results achisved, (;5 ) the coc e cc t.1 ve s t cep s wh i ch will be talmn to avoid further dwviations, and (4) thr, data when full cotapAiance will bs, cchieved. Where good cause is shown, consideration will be given to extendinQ the response time.
Dcted at Arlington,. Texas, l this day of 39 ' l l
#e 4
e
.e f7h
13 , BEEENDIX C CONSTRUCTION INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION HCGION IV NRC Inspection Report: 50-445/e6-00 Permits: CPPR-126 50-446/06-06 CPPR-127 h Dockets: 50-445 Category: A2 50-446 Applicant Texas, Utilities Gener ating Company Construction Permit Skyway Tower Expiration Date,: 400. North Olivw Otreet Lock Box 81 Dal l as, Texas 75201 Fecility Names -Comanche Peak Steam Elactric Station (CPSEG), Units 1 L 2 s Inspection Att Glen Roue, Texas Inspection Conductedt April'1-May 31. 1,986
I In'cpectors: _ _ , _ , _ _ , , _ _ , , , , _ , , , , , ,
H. G. Phillips, senice Roz2 dent Reactor Date Inspector (SRRI), Construction, Region IV CPSEG Group (paragraphs 1, 2, 3. 4, $.e and 7) P. C. Wagner, Rcocetor Inspector, Region IV Date CPGES Group l
-(paragraphs 5.b, n.c. And 5.d) )
t j [. 2 &
-- - mm _ -- __ __ _ _ - - __ _____
1 l .. 14 1 1 P. Michaud, Reactor Inspector, Region IV Date
"*' (paragraph c)
Consultants Parameter - J. Gibson yparagraphs 5.b, 5.e, and 5.d) l 4 ' Approved By: _ I. Barnes, Chief, Region IV Date CPSES Group . h etion thuTSTCY. Insee.stion Cond3tc,t;p_df d py k 1-May 31. 1986 (6,ggprA 50-445'/06-08.)_ Areas Insp ec tgd,: Routinu, unannounced inspections of Unit 1 which included a review of. plant statun and plant tour of the safeguards, 1dingsg applicant action on'previoun electrical inspection findings; and, BLR audit o site ASME activities. control, and auxiliaryibw}f Results: Within 3 areas inspected, 3 viciations with multiple examples (f ailure of TUGCo to correct t.ite audit program deficionetes identified 7byiP. S. Lobbin and NRC reports, paragraph'4.b; failure of Bt<R to audi t
,{', qn' tire ASME/CA program, paragraph 4. c. (3) (a) ; failure of B&R to perform c'ddi t i on al audits for corrective action, paragraph 4.c. (3) (b); failure to une checklist / provide objective uvidence, paragraph 4. c. (5) (a); failuro to adequately audit in process welding and other special processes in roactor, auxillary, safequards, diesel generator, and electrical control buildings, paragraph 4. e. . ( 5) (b ) ; failure to audit to sufficient depth to cusure control of fiuld change control, special processes, and inspection 3 cctivities, paragraph 4.c.(5)(b): failure of DLR to take corrective {
i ceti on on audit program deficiencies identified by Management Analysis Corporation paragraph 4.d); and one deviation ~ (TUGCo CA procedure does not include all criteria 4er supplemental audits, paragraph 4.c.(2); and BLR QA procedure does not agree with supplopental audit criteria 4.c.(2)) wsre-identified. s . ! i Oi. . $ .:a .
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