LD-96-014, Part 21 Rept Re Response to NRC Notice on Nonconformance. Licensee Will Direct Cognizant Personnel Reviewing Deviation or Failure to Comply for Basic Components Delivered to Customers,To Document Whether/Not Facts Indicate Evaluation

Part 21 Rept Re Response to NRC Notice on Nonconformance. Licensee Will Direct Cognizant Personnel Reviewing Deviation or Failure to Comply for Basic Components Delivered to Customers,To Document Whether/Not Facts Indicate Evaluation

ML20107L955
Person / Time
Site:	Millstone
Issue date:	04/26/1996
From:	Brinkman C ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, ASEA BROWN BOVERI, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-PT21-96 LD-96-014, LD-96-14, NUDOCS 9604300099
Download: ML20107L955 (2)

Text

. - - . ~ .-. . . . . . - .- - . -. . _ - - - - . . _. .._- .

1. ABB ASEA BROWN BOVERI April 26,1996 LD-96-014 -'

U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 l

Subject:

Reply to a Notice of Nonconformance

Reference:

NRC Notice of Nonconformance to Combustion Engineering, Inc. I dated February 28,1996

Dear Sir:

This letter provides Combustion Engineering's (ABB-CE's) response to the referenced Notice of Nonconformance. The time for responding to the Notice was extended at ABB-CE's request to April 30,1996.

, , s.

i ABB-CE has reviewed the identified nonconformance and will modify its future record i keeping practices to be 'in accord with the interpretation of 10 CFR 21, Reporting of Defects and Noncompliance, represented in the Notice of Nonconformance.

The attachment provides details of the ABB-CE resolution for the identified nonconformance.

Please do not hesitate to call me or Dr. lan Rickard at 860-285-9678 if you have any questions or wish to further discuss this topic.

Very truly yours, COMBUSTION ENGINEERING, INC.

1 9604300099 960426 V Charles B. Brinkman gR PT21 ENVC

{ Director, Nuclear Licensing j cc: M; R. Johnson (NRC)

S. D. Alexander (NRC)

~ R; S. Siuoek - ~0 '

1- 1. C. Rickard ABB Combustion Engineering Nuclear Power 4

-- =r. c- ms e w

= . = ,,,,

w. m7 cwem wsm s j g 1

-.-v, ,oc-- , , , - , --

i

. v..

Response to Notice of Nonconformance 1.0 Nonconformance 1.1 Statement of Nonconformance The nonconformance, stated in Section 1.4 of the inspection report, found that:

1 Contrary to the requirements of Criterion V of 10 CFR Part 50, Appendix B, ABB-CE old not l

(with regard to reactor head studs supplied to Millstone-2 in 1990) and, as a matter of stated l

[

practice or policy, routinely does not document negative Rndings in evaluation of deviations or failures to comply in the manner prescdbed by the procedures when the devistions or failures to comply are obviously not saliety signiRcant (i.e., could not create or are not related to a substantial safety hazard) or appear not to be safety signiRcant upon initial review.

Criterion V of 10 CFR 50 Appendix B provides that:

Activities affecting quality shall be prescribed by documented instructions, grocedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. j l

1.2 Reason for Nonconformance ABB-CE's existing procedure for implementing 10 CFR 21 lacks sufficient detail regarding documentation of the decision not to submit a deviation or failure to comply for further evaluation pursuant to 10 CFR 21 if, on initial review, the cognizant engineer believes that such deviation or failure to comply does not have the potential to create a substantial safety hazard. This lack of detail led to the nonconformance.

2.0 Corrective Actions and Results Achieved ABB-CE will direct all cognizant personnel reviewing deviations and failures to comply for basic components delivered to ABB-CE customers to document whether or not the facts indicate a further evaluation under the 10 CFR 21 implementing procedure is warranted.

3.0 Corrective Actions to Avoid Further Noncompliance l ABB-CE believes that the action described above will resolve the identified nonconformance. ABB-CE will incorporate that action as a permanent change to the 10 CFR 21 Implementing procedure.

4.0 Date when Corrective Actions will be Completed i

The corrective action described in Section 2 will be completed by June 28,1996. ABB-CE will also initiate a revision to its 10 CFR 21 implementing procedure and expects that such revision will be completed by September 30,1996.

4

.