ML20216C180

Notice of Deviation from Insp on 870101-0228

ML20216C180
Person / Time
Site:	Comanche Peak
Issue date:	06/22/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20216C144	List: ML20216C139 ML20216C180 ML20216C252
References
50-445-87-02, 50-445-87-2, 50-446-87-02, 50-446-87-2, NUDOCS 8706300233
Download: ML20216C180 (2)

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APPENDIX A

, NOTICE OF DEVIATION TU Electric--

- Dockets: 50-445'/87-02 L

50-446/87-02 h* Comanche Peak Steam Electric Station, Permits: CPPR-126

. Units 1 and 2 CPPR-127 J Base'd on the results of an NRC inspection conducted on January 1 through H

February 28, 1987, two deviations from commitments were identified. The..

-deviations consisted of several concrete pours'not being identified on the' Population Items List and documents missing from the Issue-Specific Action Plan (ISAP)LVII.c project files. 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 .' ERC document QA/QC-RT-1628, Revision 1, " Population Items List Concrete Placement," states, in part, that the list ". . . includes all safety-related concrete pours in Unit 1, 2 and areas common to both units." Attachment 6.3 of ERC Procedure CPP-005, Revision 3,' states, in L part, "The'ResponsibleLQA/QC Discipline Engineer . . . Provides the. basis

.for accepting the list as valid." In addition, "The QA/QC Lead Discipline Engineer and the QA/QC Engineering Supervisor review Population Items Lists _ to ensure: that they are complete, accurate, and consistent with the requirements of this procedure."'

In deviation from the above, NRC inspection of the Population Items List for concrete placement revealed the following discrepancies:

1. Pour Nos. 205-9810-039 through 205-9810-056 are shown as block-out type pours-in the east diesel generator foundation, Unit 2, on Drawing SSB-20655, Sheet 1, Revision 5. -Pour Nos. 205-9810-040 and 205-9810-048 through 205-9810-056 were not on the Population. Items-List and no corresponding pour cards could be obtained in the TU Electric Records Center. Pour Nos.'205-9810-039 and 205-9810-041 through 205-9810-047 were on the Population ItemsLList but were i assigned on drawings at least twice and are shown, for example, on Drawings SSB-20605, Sheet 1, Revision 7, and SSB-20618, Sheet 1, Revision 2, to be concrete curbs, removable slabs, etc.; not bl oc k-outs.

2. Pour No. 205-4822-003 is shown as a shielding wall for the Primary Sampling room on Drawings SSB-20605, Sheet 4A, Revision 0, and SSB-20605, Sheet 4, Revision 0. This pour number was not on the Population Items List.

.The above discrepancies indicate that the Population Items List is not entirely complete and accurate and does not include all safety-related concrete pours. The ERC review of the Population Items List to ensure accuracy and completeness was inadequate (445/8702-0-03; 446/8702-D-03).

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B.- - Section 5.3.1 of Revision 2 to ERC Procedure CPP-004, " Project Working Files," dated December-17, 1985, for ISAP VII.c states, in part, "The Records' Administrator.shall review each document. received for filing for

. physical quality.(e.g'., reproducibility, legibility, condition) and

. completeness. (e.g. .. number, file location, sequence of attachments, etc.)."

In deviation from the above, NRC inspection of the Population Items List for electrical cable, revealed that the records administrator failed to

identify that pages 813 and 814 of.the Electrical' Management System cable i

population listing and the list 'of. Essential and Emergency Lighting circuits were missing from the cable population. listing (445/8702-D-04; 446/8702-D-04).

TU Electric 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)thecorrectivestepswhichhavebeentakenandtheresults 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 22nd day.nf June 1987 s