ML20042F302
| ML20042F302 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/02/1990 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-90168, NUDOCS 9005080134 | |
| Download: ML20042F302 (3) | |
Text
D lllllllll" llllllll tog # TXX-90168 File # 10130(IR 89-23)-
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10118(EA 88-3 E)
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.Ref. # 10CFR2.201 M/ ELECTRIC -
May 2, 1990
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U.- S. Nuclear Regulatory Commission i
Attn:
Document Control Desk l
Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK-STEAM ELECTRIC STATION (CPSES)
I DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NOTICE OF VIOLATION 445/8923-V-01 (NRC INSPECTION REPORT NOS, 50-445/89-23; 50-446/89-23)
Centlemen:
f TU Electric has reviewed your letter dated April 2,1990, concerning'the I
inspection conducted during the period April 5 through May 2, 1989, which -
covered the follow-up to TV Electric's response to violations associated with the Unit 1 Service Water Coating Removal Project and other Code V service procurements.. Attached to your letter was-a Notice of Violation. This letter:
constitutes TV Electric's response to the Notice of Violation.
-The subject of the-Notice of Violation, failure to ensure that the NRC'was provided complete information on an enforcement issue, is a serious matter to TV Electric.
It is our policy and practice to be candid and open with the NRC. When this issue was first raised by the NRC in April 1989, TU Electric initiated a review of the information' provided to the NRC prior to and during the Enforcement Conference on Service Water Coating Removal 1on November 9, 1988, and in'our response to Enforcement Action EA 88-310 (TXX-89070 dated February 8,1989).
Based on this review TU Electric concluded that it had provided complete information to the NRC.
The results of. this review were most recently discussed with the NRC during an Enforcement Conference conducted on January 30, 1990. While TU Electric acknowledged that its presentation at the November 9, 1988, Enforcement.
Conference and its written response to EA 88-310 could have been enhanced by explaining the lack of significance in the other Code V services procurement shortcomings rather than just presenting its conclusions, it was and continues to be TU Electric's. position that the information provided to-the NRC regarding other Code V services procurements was complete in all material respects. Therefore, TV Electric does not believe that the circumstances described in your April 2, 1990, letter constitute a violation of 10CFR50.9(a).
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400 North Olive Street LB81 Dallas, Texas 75201
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.TXX-90168 May 2, 1990 Page.2 of 3 l
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The bases for this' position are asL follows:
1.
TV Electric committed internally to complete a review of the Code V services procurements;other than Service Water Coating Removal' as part of its evaluation of that task. This commitment was shared with the'NRCD.
I during the September 13, 1988, Management Meeting 1on-Service Water Coatings o
Removal where it was' agreed that'the review.would be completed prior to October 1, 1988. The review.was completed and documented in memorandum j
1 NE-22156 on September 30,:1988. That memorandum and supporting'..
documentation was available to'the NRC att that time,- and was provided to:
CASE upon request. prior-to the November 9 -1988,. Enforcement Conference.
V" 2.
The results of the : review documented in -NE-22156 demonstrated that Code.V service procurements were suunsfully implemented with the level:of-detail con +ained in the procurement documents reviewed and inspite of thet 4
identified shortcomings. Therefore, the results of the review, although similar to the results identified in the review of Service Water Coating Removal procurement' documents, did not compromise the conduct' of the.
n procured activities and do not represent additional examples ~ of the' typesT of problems encountered during Service Water Coating Removal.
3.
The conclusions of the review of the other Code V services procurementsi performed in September 1988, and presented _during the November 9, 1988, Enforcement Conference and in the written response-to EA 88-310 were confirmed by a second independent. review conducted.by TU Electric Quality;
.The results of this second review were Assurance in April and May 1989.
provided to the NRC as an attachment to TXX-89847 dated-December,11, 1989.
4.
TU Electric formally responded to the violations contained in EA 88-?l0 via TXX-89070 on February 8, 1989.
As part of the corrective action portion of the response, the review of the other Code V. services 'was discussed, and the conclusions were' appropriately summarized. 'As has been TV Electric's practice, a package of documentation'was assembled to substantiate and expand upon the summary information~ provided in the-formal response.
This documentation package was= delivered-totthe NRC-Resident Inspectors without request to facilitate a more complete understanding of the formal response. NE-22156 was included.in this package.
Thus, complete information was provided to the NRC as part of the overall response to the violations.
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r TXX-90168 May 2, 1990 Page 3 of 3 o
TU' Electric recognizes the importance of providing complete information to. the NRC. This is reflected in the TV Electric " Principles-for Enhancing' Nuclear-Professionalism" issued on August'30,'1988, which is-contained in the Nuclear 1
. Engineering Policies and Procedures Manual. :In order to assure that the expectations of the NRC are understood,Lthe issues, identified in the Notice'of:-
I Violation have been discussed by the-Vice President of Nuclear Engineering-with those personnel contributingLto tho' response to +.he: violation on.the Service Water Coating _ Removal;procurementi-Sincerely,.
I
/
WilliamJ.;Cahill,LJr.
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I WGG/daj c - Mr. R. D. Martin, Region IV 3
Resident Inspectors, CPSES (3) j l
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