ML20012B774

Responds to NRC 900216 Ltr Re Violations Noted in Insp Repts 50-445/90-03 & 50-446/90-03.Corrective Action:Personnel Reminded of Need to Conservatively Rept Deficiencies & to Advise Mgt of Any Questions Re Reportability

ML20012B774
Person / Time
Site:	Comanche Peak
Issue date:	03/09/1990
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-90095, NUDOCS 9003160258
Download: ML20012B774 (4)

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File # 10130 C- .- -IR 90-03 r C IR 90-03' TUELECTRIC Ref. # 10CFR2.201-March 9, 1990 wmi. J. c.hm, Jr.

Executive Vke President U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

SUBJECT:

_ COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 '

NRC INSPECTION REPORT NOS. 50-445/90-03; 50-446/90-03 RESPONSE T0 h0TICE OF VIOLATION l

Gentlemen:

TU Electric has reviewed the NRC's letter dated February 16, 1990, concerning the inspection conducted-by the-NRC staff during the period January 3 through _

February 6, 1990. This inspection covered activities authorized by.NRC Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2. Attached to the February 16, 1990, letter was a Notice of Violation.

TU Electric hereby responds to the Notice of Violation, Item B (445/9003-V-03), in the attachment to this letter. TU Electric's response to l Notice of Violation, Item A (445/9003-V-01; 446/9003-V-01), will be submitted  !

by March 19, 1990, i Sincerply,

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William J. Ca ill, Jr.

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Attachment- :j

.- l c _Mr. R. D. Martin, Region IV j u Resident-Inspectors, CPSES (3) ]

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' Attachment to;TXX-90095-  ;

Page 1 of >3 NOTICE OF VIOLATION; ITEM B l (445/9003-V-03)

Criterion XVI of Appendix B to 10 CFR Part E0 as.im)lemented by Section 16 of *

, - the TU Electric Quality Assurance Manual requires t1at measures shall be .

l established to assure that conditions adverse to quality are promptly.

identified and corrected. Furthermore, for significant conditions adverse to quality, the measures shall assure that the cause of. the condition is J determined and that- adequate corrective actions to preclude repetition are e taken. -i The Code of Federal Regulations 10 CFR Part 50.55(e) requires that the Commission be notified of each deficiency found in construction, which, 4

, were it to have remained uncorrected, could have adversely affected the safety of operations and which represents:

P (iv) A significant deviation from performance specifications which will require extensive evaluation or repair to establish the adequacy of. .

the structure systehl or Component to meet the criteria and basis stated in the safety analysis, or to otherwise establish the adequacy of the structure, system, or component-to perform its-intended safety function.

CPSES Nuclear Engineering and Operations Procedure NE0 9.01, Revision 4 Section' 6.4.1.2 requires that evaluations for reportability under 10 CFR

-50.55(e) shall be documented on or attached to Reportability Evaluation +

Forms (REFs) and shall provide justification as to why an adverse condition is or is not reportable.-

l Contrary to the:above, Plant' Incident lie' port 89-243, which . identified the L -)resence'of foreign material in theicontainment spray system which could H 1 ave blocked'a horizontal containment spray header and resulted in an L unanalyzed condition'during plant operations, wes inadequately reviewed for'reportability on SN-463. As a result of this . inadequate review, the L root cause of.this condition and the generic implications were not_

L; adequately addressed. Furthermore, the corrective actions were inadequate in' that the. applicant l failed to properly examine other related areas that may have contained similar debris.

? RESPONSE TO NOTICE OF VIOLATION. ITEM B (445/9003-V-03) r-TU' Electric accepts. the violation and-the requested information follows.

' 1. Reason for Violation TV Electric has reviewed the basis for the original determination of non-p reportability of the deficiency described in Plant Incident Report 89-243.

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'. Attachment to TXX-900951 '

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This review disclosed that the original reportability determination  !

assumed that the existence of the debris, were it to have-remained.  ;

b  : uncorrected, could=have adversely affected the safety of operations by i m --impacting the operability of one train of the Containment Spray System. 3 F However, the: adequacy of this system to perform its-intended safety- -

function was re-established.by removal of the debris and washdown/ rinsing to provide adequate confidence that there was no additional debris. These actions were not believed to constitute extensive evaluation, extensive

- redesign or extensive repair. Based on a review of the cleanliness

., controls in .effect during the 1ast known work which could have introduced 's the debris into the system, and the successful demonstration of thel .

adequacy of these controls when applieri to similar work,'it.was concluded that the existence of-the debris resultedtfrom isolated personnel error s- and-did.not represent a significant breakdown in any portion of the  ;

L 1 Quality Assurance Program. Consequently, the personnel involved in the -

original .reportability determination concluded that the condition, though -

L . significant, was not; reportable pursuant to-10CFR50.55(e). 3

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- However, since-the deficiency could have rendered one train of the

- , l Containment Spray System inoperable, and since it is unlikely that the ,

deficiency would have been detected by routine surveillance testing, the 4 intent-of 10CFR50.55(e) would have been more appropriately satisfied by .

E' conservatively reporting the deficiency.

L L 2. : Corrective'Steos Taken and Results Achieved 1 -

-The debris.in;the Containment Spray System has been reported pursuant to 10CFR50.55(e)'per TU Electric letter TXX-90065, dated' February 7, 1990.

'Th:s report addressed the root cause of the deficiency through an ,

4 assessment of. the cleanliness controls'in effect at the time the deficiency was~ believed to haveL occurred, and.through an assessment of L existing cleanline'ss controls. As also stated:in the report, an

-inspection of the:other train of the Containment Spray System was performedito assess.the extent of the deficiency. No debris.was found in

, the other train of the Containment Spray System. ,

l D To assess the extent of.the condition described in the Notice of H , Violation, a review was. conducted of a sample of recently identified E

• potentially: reportable conditions which were subsequently determined to be .

not reportable per 10CFR50.55(e). None of these conditions were.found to be reportable per 10CFR50.55(e).

3.: Corrective Steos Taken and Results Achieved

.CPSES management has reminded personnel involved in the 10CFR50.55(e) .

reportability determination process of the need to conservatively report L; deficiencies and to advise management of any questions regarding reportability.

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Attachment to TXX-900951  : l Page:3 of 3, j

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~ A review committee ~ previously formed -to evaluate the' thoroughness of- l corrective: actions. foa. reportable issues will review future 10CFR50.55(e) l reportability evaluat 'ons of conditions which 'are initially considered.to-

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9-be potentially reportable, but are subsequently: evaluated as not g reportable.- ,

4. Date When Full Como11ance Will be Achieved

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Full compliance has been: achieved.

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