ML20082M265
| ML20082M265 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/28/1991 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-91313, NUDOCS 9109050111 | |
| Download: ML20082M265 (3) | |
Text
.
l l
statimEWF _
l musasuur gummissans
.r
=
TUEl ECTRIC Log # TXX-91313 File # 10130 Ref. # 10CFR2.201 William J. Cahill, Jr.
""~""#"*"'
August 28, 1991 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNIT 2 DOCKET NO. 50-446 NRC INSPECTION REPORT NOS. 50/445/91-29; 50-446/91-29 REPLY TO A NOTICE OF VIOLATION Gentlemen:
TV Electric has reviewed the NRC's letter dated July 29, 1991, concerning the inspection conducted by the NRC staff during the period June 5 through July 16, 1991. This inspection covered activities authorized by NRC Operating License NFF-87 anJ Construction Permit CPPR-127.
Attached to the July 29, 1991, letter was a Notice of Violation.
TU Electric hereby replies to the Notice of Violation (446/9129-01) in the attachment to this letter.
Sincerely,
,/
William J. Cahill, Jr.
JAA/bm Attachment c-Mr. R. D. Martin, Region IV Hr. M. B. Fields, NRR Resident inspectors, CPSES (2)
..- r -n C.1 'o -
J 9109050111 910928 4p3 DR ADOCK 0500 400 North Olive Street Lit til Dallas. Texas 75201
s Attachment to TXX-91313 Page 1 of 2 ti!1UILDF V10LaH0]i (446/9129-01)
Criterion V of Appendix B to 10 CFR 50, as implemented by Sectinn 5.0 of the TV Electric Quality Assurance Manual, states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, o[f] 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."
Comanche Peak Steam Electric Station, Unit 2, Procedure 2PP-3.05, Revision 1,
" Procedure for Processing of TU Evaluation (TUE) Forms and Conditional Release Requirements (CRRs), " paragraph 4.24, defines "Use-As-Is" as "A disposition which may be assigned for a nonconformance when it can be established that the discrepancy shall result in no conditions adverse to saf ety and that the item under consideration will continue to meet all engineering functional requirements. This disposition requires technical justification by Engineering of the item's acceptability for use."
Contrary to the above, the technical justification provided in TUE forms90-023, 91-463, and 91-464, which provided for the bulk closures of approximately 550 nonconformance reports associated with commodity clearance violations, were not properly implemented in that there is no objective evidence to indicate that these deficiencies were specifically evaluated by engineering to preclude potentially adverse interactions due to seismically and thermally induced displacements.
REPLY 10 NOTifE Of VIOLATION (446/9129-01)
TV Electric accepts the viclation and the requested information follows:
1.
Reason for Violation This procedural violation resulted from efforts by the responsible engineering group to reconcile (with current programs) the Unit 2 commodity clearance nonconformance reports (NCRs) written in the 1987 to 1988 time frame.
In performing this reconciliation, the responsible engineering group assigned a disposition of "Use-As-Is" to the three TU Evaluation (TUE) forms that collectively captured these previously identified NCRs.
The technical justification provided for this disposition on these TUE forms gave a special definition to "Use-As-Is" that was not recognized at the time as being inconsistent with governing procedure 2PP-3.05. The "special definition" indicated that any of the clearance deviations documented on the original NCRs, that represented the potential for adverse interactions, would be independently
J
,t Attachment to TXX-91313 Page 2 of 2 i
identified and corrected by the commodity clearance program governed by 2-EAP-011, " Engineering Assessment Procedure - Commodity Clearance."
Following the commodity clearance engineering walkdowns conducted in Unit 2 (to baseline hardware status prior to recommencement of r
construction), a sampling of the original 550 NCRs was performed to provide additional assurance that the program had addressed these NCRs.
This was subsequently documented in Report PTR-0025, Rev. O, " Sampling i
Review of Commodity Clearance Nonconformance Reports." Following i
confirmation that the approach was technically sound, the three associated TUE forms were closed with a "Use-As-Is" disposition. This i
deficiency was limited'to the documentation of the NCR dispositions and l'
did not affect the technical adequacy of the Unit 2 commodity clearance program which was provided as the engineering basis for the disposition, i
r 2.
Corrective Steps Taken and Results Achieved The three TUE forms in question have been reopened by initiation of a new TUE form. The new TUE form will document the resolution of each 3
commodity clearance deviation for the 550 NCRs.
This TUE form will be dispositioned and closed in accordance with procedure 2PP-3.05.
3.
Corrective Steps Taken To Avoid Further Violations
{
To preclude recurrence, it has been emphasized via an Engineering Quality Accountability meeting that TUE Form dispositions must address resolution of each non-conforming condition, j
4.
Qate When Full Compliance Will Be Achieved Compliance with the requirements of procedure 2PP-3.05 was re-t established with the opening of TUE form 91-1778 on August 12, 1991.
i I
1 1
t
?
~
,