ML20059K358

Ack Receipt of 900820 Revised Response to Violations Noted in Insp Repts 50-445/89-57 & 50-446/89-57

ML20059K358
Person / Time
Site:	Comanche Peak
Issue date:	09/13/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 9009210268
Download: ML20059K358 (2)

See also: IR 05000445/1989057

Text

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In Reply Refer To:

. Dockets:- 50-445/89-57

50-446/89-57

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TV Electric .

ATTN: W. J. Cahill, Jr., Executive

Vice President, Nuclear

Skyway Tower

400 North Olive Street, L.B. 81 '

Dallas, Texas 75201

?- Gentlemen:

.Thank you for your letter of August 20, 1990, informing us of your

revised response to our letter dated August 28, 1989. We have no further

. questions at this time 'and will review your corrective action during a future

inspection.

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Sincerely.

Ton 7dhnson

1. amuel

S J. Collins, Director

\ Division of Reactor Projects

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TU Electric

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ATTN: Roger.D. Walker, Manager, s

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Nuclear Licensing

Skyway Tower' .

400 North Olive Street, L.B. 81

Dallas. Texas- 75201

'Juanita Ellis-

President - CASE

1426 South Polk Street

Dallas, Texas 75224

GDS. Associates, Inc.o

Suite 720

1850 Parkway Place

Marietta, Georgia. 30067-8237

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Appleton, Wisconsin 54911

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TU Electric

Bethesda Licensing-

3 Metro Center, Suite 610 l

Bethesda, Maryland - 20814 ,

Heron, Burchette, Ruckert, & Rothwell j

ATTN:' William A. Burchette Esq. l

Counsel for Tex-La Electric-  ;

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Cooperative of Texas

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1025 Thomas Jefferson-St., N.W.  !

Washington, D.C. 20007 c

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Newman & Holuis.7er, P.C. j

ATTN: ' Jack R. New,24n, F ;q.

1615 L. Street, N.W. ]

Suite'1000 .

Washington, D.C. 20036

Texas Department of' Labor & Standards ,

ATTN: G. R. Bynog, Program Manager /

' Chief Inspector.

Boiler Division .

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P.O. Box 12157 Capitol Station

Austin, Texas 78711 ,

lionorable George Crump

County Judge .j

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> Glen Rose,. Texas. 76043

Texas Radiation Control Program Director--

1100 West 49th Street

Austin, Texas 78756

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R. D. Martin *ResidentInspector(2) .

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DRSS-FRPS. Lisa Shea, RM/ALF

MIS' System *RSTS' Operator

RIV Files

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Log # TXX-90295

__ File # 10130

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L IR-89-57

Ref. # 10CFR2.201

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nlELECTiiC

August 20, 1990

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V. S. Nuclear Regulatory Commission { '

Attn: Document Control Desk .

Washington, D.C. 20555 ,

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SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446

NRC INSPECTION REPORT NO. 50-445/89-57: 50-446/89 57

REVISED RESPONSE TO NOTICE OF VIOLATION

Ref: 1) TV Electric letter logged TXX-89721 from Mr. W. J. Cahill, Jr.

to NRC, dated September 27, 1989

2) TV Electric letter logged TXX-89773 from Mr. W. J. Cahill, Jr.

to NRC, dated October 27, 1989

Gentlemen:

Reference 1) provided TU Electric's response to Notice of Violation-

445/8957-V-01. In that response TV Electric stated that by October 9,1989,

it would revise its procedures to provide for an objective of completing the

work package po t work review process within thirty days. In Reference 2), TV

Electric stated that the procedural revision described above had been

completed on October 11, 1989. As a result of subsequent changes to the CPSES

records management program, the objective has been upgraded to a requirement

and the allowable post work review period has been lengthened to sixty days.

These changes, which are in accordance with the CPSES FSAR, (Section 1A(B)

Regulatory Guide 1.88) have been made to establish more definitive criteria

for the post work review period while allowing sufficient time for a thorough

review. TU Electric's res)onse to the subject Notice of Violation has been

revised to reflect these c1anges and to update the status of other actions

discussed in the original response. Revision bars in right margin of the

attached revised response denote the changed portions of the text.

Sincerely,

= . ,

William J. Cahill, Jr.

VPC/cid

Attachment

c - Mr. R. D. Martin, Region IV

Resident inspectors, CPSES (3)

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Attachment to TXX-90295

? Page 1 of 3

Notice of Violation

(445/8957-V 01)

Appendix B of 10CFR50, Criterion XVil, " Quality Assurance Records," requires,

in part, that records be maintained to furnish evidence of activities

affecting quality and that records shall be identifiable and retrievable.

ANSI N45.2.9-1974, Section 4.2, " Timeliness," requires a specific submittal

plan be established between the purchaser and supplier for quality assurance

records to assure their availability.

TU Electric implementing procedure Nuclear Engineering and Operations (NEO)

2.13. " Management of Nuclear Power Plant Records," Revision 3, effective July

1, 1988, paragraph 6.3.1, states that organizations who process and store

documents prior to turnover and acceptance by TU Electric Records Management

shall provide for the control, preservation, and safekeeping of documents as

defined in the Records Management Program Manual (RMPM).

Implementing procedure NE0 2.33, " Turnover of Nuclear Power Plant Records,"

Revision 3, effective July 1, 1988, paragraph 4.6, states, in part, that

Section 1 (procedures) is applicable to all NEO organizations.

The RMPM procedure RMP-1.2.1, Revision 5, Section 4.0, effective August 3,

1988, requires that provision be made for the preservation, safekeeping, and

storage of documents.

Contrary to the above, the Instrument and Control (l&C) organization-(an NEO

organization) did not provide adequate preservation, safekeeping, and storage

of an extensive number (appears to be hundreds) of completed work packages

that were awaiting final review for an excessive period of time (up to 2

years) prior to turnover and acceptance by TU Electric Records Management. In

addition, the procedures establishing the submittal plan (records turnover

plan) for the Instrumentation and Control (I&C) records did not include an

adequate method to ensure their timely availability to the Records Management

Organization.

Resoonse to Notice of Violation

(445/8957-V-01)

TV Electric accepts the alleged violation and the requested information

follows.

1. Reason for_ Violation

The Instrument and Control (I&C) documents which are the subject of the

Notice of Violation consisted of work packages for activities such as

instrument calibration checks, that had been completed in the field and

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Page 2 of 3  ;

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were in the post work review phase (up to two years). It is implicit in i

the procedures for the turnover of documents to Records Management that I

documents be processed and turned over in a reasonable amount of time.

However, the records releasing organizations did not assure that records  !

turnover occurred in a timely manr.er. Consequently, the subject I&C i

documents were allowed to accumulate during the post work review process.

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The CPSES procedure concerning intermediate storage areas provides  ;

guidelines for the preservation and safekeeping of documents. Although

not required by ANSI-N45.2.9, these guidelines provide measures for the

protection of the subject documents. However, these guidelines were not i

referenced in Operations Departmental implementing procedure and were not  !

adhered to by personnel responsible for the documents. '

2. Corrective Steos Taken and Results Achieved i

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The storage facilities for I&C work packages have been improved to provide i

acceptable protection for the subject documents. The backlog of work

packages in the post work review phase has been reduced to be in

accordance with the requirement identified in Section 3 below, l -

, The status and storage provisions for documents generated by other Nuclear

Operations Department record releasing organizations have also been .

reviewed. As a result, changes were made in the storage provisions for '

documents to improve protection for the documents that satisfies the TU

Electric procedural guidelines. Other backlogs of documents awaiting  :

processing and turnover to Records Management have been reduced to be in ,

accordance with the requirement identified in Section 3 below. i

Due to the unique nature of construction documents, the program for

control of construction documents was governed by different procedures and l

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organizations than the Nuclear Operations Department program. Prior to

fuel load, all Unit I construction documents designated to become QA (

records were either turned over to TU Electric Records Management in 4

accordance with the established procedures or were- submitted for

protection, safekeeping, and retrieval in an owner controlled ANSI-N45.2.9 l

facility or auditable duplicate file, For these reasons TU Electric does i

not consider that concerns described in this violation apply to Unit '4

construction documents.

3.

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Corrective Steos Which Will be Taken to Avoid Fe=ther Violations

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The Nuclear Operations Department administrative procedure (s) for control

of records has been revised to require that each records releasing L

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organization designate a records coordinator whose responsibilities i

include assuring adequate storage of documsnts per CPSES guidelines. A

requirement to complete the post work review process within sixty days has

been proceduralized,

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Attachment to TXX-90295

Page 3 of 3 j

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To provide additional assurance that work packages are processed through 1

the post work review phase in a timely manner, the program for tracking l

Work Orders has been enhanced to facilitate locating and statusing Work l

Orders which are in the post work review phase, and to clarify the routing  :'

of Work Orders that have been completed in the field.

4. Date When Full Comoliance Will be Achieved i

Full compliance has been achieved.

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