ML20029A779

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Forwards Insp Repts 50-445/90-47 & 50-446/90-47 on 901214-910221 & Notice of Violation
ML20029A779
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/26/1991
From: Collins S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: William Cahill
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML20029A773 List:
References
NUDOCS 9103040246
Download: ML20029A779 (3)


See also: IR 05000445/1990047

Text

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UNITED STAf ts

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ARLINGTON, TEXAS 76011

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rnclosure 2

Docket Nos. 50-445/90-47

60-446/90-47

License Nos. NPF-87

CPPR-127

TV Electric

ATTN:

W. J. Cahill, Jr. , Executive

Vice President, Nuclear

Skyway Tower

400 North Olive Street, L.8. 81

Dallas, Texas 75201

Gentlemen:

SUBJECT:

NOTICE OF VIOLATION (NRC INSPECTION REPORT NOS. 50-445/90-47;

50-446/90-47)

This refers to the staff's review of the dispute between TU Electric and

Citizens Association for Sound Energy (CASE) concerning scaling calculations

for Comanche Peak Steam Electric Station (CPSES), Unit 1.

The review was

performed in accordance with the ternis of the " Joint Stipulation" for Comanche

Peak, dated June 20, 1988.

The review was concluded with discussion of the

findings on February 21, 1991, at an exit meeting conducted with those members

of your staff identified in the enclosed inspection report.

Areas examined during the review are identified in the inspection report and

included docunentation provided by TV Electric and by CASE.

Based on the results of this review, and a managenent review of the " Final

Report Addressing Scaling for Comanche Peak Steam Electric Station Unit 1,"

(enclosed with the attached NRC inspection report) certain of your activities

appeared to be in violation of NRC requirements, as specified in the enclosed

NoticeofViolation(Notice). This violation involves a failure of TU

Electric's corrective action program in 1986 and 1987 to assure that alleged

deficiencies with scaling documentation for initial setup and calibration of

instrumentation loops were promptly pursued and identified. The NRC is

concerred that it required significant involvenent from a former employee and

from CASE over an extended period before the deficiencies with scaling

documentation were adequately identified and corrected.

This violation was considered for escalated enforcement action but, upon

completion of the review, was determined to represent a Severity Level IV

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violation in accordance with the examples in Supplement !! of 10 CFR Part 2

Appendix C.

This conclusion is based on NRC's view that the deficiencies in

the scaling documentation did not result in deficient construction or

construction of unknown quality for safety-related instrumentation loops

because of other elements of your quality assurance program which did confirm

that the design safety requirements were met. These other elements included

the final instrumentation loop calibration, the preoperational test program,

and quality assurance audit activities.

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9103040246 910227

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ADOCK 05000445

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TU Electric

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3ecause the corrective actions you have now completed have resulted in

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acceptable scaling-related docunentation, a written response to the Nutice of

Violation is not required. However, you are requested to provide a written

explanation of how scaling activities will be performed for CPSES Unit 2, to

assure that documentation problems are prevented or promptly identified and

corrected. Also, because of our concern with your delay in responding to an

employee's concern in this instance, we request that you provide a written

response describing how employee concerns will be handled to prevent delays and

to encourage prcept identification and correction of potential safety issues.

Please provide the reouested written responses within 60 days of the date of

this letter,

in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this

letter and its enclosures will be placed in the NRC Public Document Room.

The responses directed by this letter and the enclosed Notice are not subject

to the clearance procedures of the Office of Management and Budget as required

by the Paperwork Reduction Act of 1990, Pub. L. No. 96.511.

Sin (2 ,ely,

'

SamuelJ.Collns/D

ctor

Division of Rea or Projects

Enclosures:

1.

Appendix A - Notice of Violation

2.

Appendix 0 - NRC Inspection Report

50-445/90-47

50-446/90-47

cc w/ enclosures:

TV Electric

ATTN:

Roger D. Walker, Manager

Nuclear Licensing

Skyway Tower

400 North Olive Street, L.C. 81

Dallas, Texas 75201

Juanita Ellis

President - CASE

1426 South Polk Street

Dallas, Texas 75224

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TV Electric

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GDS Associates, Inc.

Suite 720

.

1850 Parkway Place

Marietta, Georgia 30067-8237

TV Electric

Bethesda Licensing

3 Metro Center, Suite 610

Bethesda, Maryland 20814

Jorden, Schulte, and Burchette

ATIN: William A. 8 cchette. Esq.

Counsel for Tex-La Electric

Cooperative of Texas

1025 Thoaas Jef ferson St. , N.W.

Washington, D.C.

20007

E. F. Ottney

P.O. Box 1777

Glen Rose Texas 76043

.iewman & Holtzinger, P.C.

'

ATTN: Jack R. Newman, Esq.

1615 L. Street, N.W.

Suite 1000

Washington, D.C.

20036

Texas Departnent of Labor & Standards

ATTN:

G. R. Bynog, Program Manager /

Chief Inspector

Boiler Division

P.O. Box 12157 Capitol Station

Austin, Texas 78711

Honorable Dale McPherson

County Judge

P.O. Box 851

Glen Rose, Texas 76043

Texas Radiation Control Program Director

1100 West 49th Street

Austin, Texas 78756

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