ML20104B151

Responds to NRC Re Violations Noted in Insp Rept 50-446/92-23 on 920622-25.Corrective Actions:Load Cells Entered Into Measuring & Test Equipment Program & STA-608 Revised to Clarify Definition of Measuring & Test Equipment

ML20104B151
Person / Time
Site:	Comanche Peak
Issue date:	09/08/1992
From:	William Cahill, John Marshall TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-92415, NUDOCS 9209150011
Download: ML20104B151 (3)

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1. 1XX 92415

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Fi1e # 10130 TUELECTR/C

1. IR 92-23 Ref.

1. 10CFR2.201 September 8. 1992 Williarn J. Cahill, JJ.

Owege Vue hnielent U. S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50 445 AND 50-446 NRC INSPECTION REPORT N05. 50-445/92 23 AND 50-446/92-23 RESPONSE TO NOTICE 0F VIOLATION Gentlemen:

TU Electric has reviewed the NRC's letter dated August 7,1992, concerning the inspection conducted by the NRC staff during the period June 22 through June 25, 1992.

These inspections covered activities authorized by NRC Operating License NFP-87 and Construction Permit CPPR-127.

Attached to the August 7.1992, letter was a Hotice of Violation.

TV Electric hereby responds to the Notice of Violation in the attachment to this letter.

Sincerely, William J. Cahill, Jr.

By J. S. Marshall Generic Licensing Manager LRW/tg-Attachment-c--

Mr.

J.-L. Milhoan. Region IV Resident Inspectc... CPSES-(2) 9209150011-920908-

'i einnaa PDR-ADOCK 05000446 400 N. olive sirce: LB.si Danes,hxas n201 G

PDR

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1 Attachment to 1XX 92415 Page 1 of 2 r

NOTICE OF VIOLATION (446/9223 01)

Criterion XII of Appendix B to 10 CFR Part 50 and the licensee's approved quality assurance program description, Revision 85, require that measures for the control of measuring and test equipment (H&TE) shall be established to assure that procurement, handling, storage, scheduling, and calibration of M&TE and reference standards is in accordance with approved methods.

Procedure No. STA 608, ' Control of Measuring and Test Equipment,' Revision 15 with Procedure Change Notices 1 through 2, peragraph 6.3.3 requires that, when a vendor is used for equipment calibration. that records be provided to the Metrology' Laboratory for review and initiation of administrative controls such as equipment' tagging.

Contrary to the above -the inspector found on June 24, 1992, that six load k

l cells were in use which were not incorporatea into the M&TE Program.

L Preoperational Test No. 2CP PT-90-02, Transient Vibration Test during Operational Vibration Tests, identified in ' Table 9.4 that load cells TR-2 il 01, 02, 03, 04T, 04B, and 05 had been used on Apri1 12, 1992, which were-calibrated by the vendor, Teledyne Engineering Services.

However, the records of the calibration of these instruments were not submitted to the Metrology ~ Laboratory for: review and: Initiation 6f administrative controls for the instruments'such as tagging.

RESPONSE TO NOTICE OF VIOLATION (446/9223 01)

TU Electric. accepts the violation and the requested information follows:

1)

Reason for Violatiqn The load cells were not incorporated into the Heasuring and Test Equipment (M&TE) Program because they had been incorrectly classified as t

permanently installed operating equipment.

Therefore, applicable calibration records were not submitted to the Metrology Laboratory for review.

7 2)

Corrective Steos Taken and Results Achieved Corrective action documents were initiated for. Units 1 and 2 to evaluate-the condition and assess generic implications.

The load cells were t

entered intolthe H&TE Program; A project wide review of measuring and; test equipment revealed no instances, other than the load cells identified in'the inspection-report, where calibrated equipment had been j

misclassified.

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' Attachment to TXX 92415 l

Page 2 of 2 3)

CILrac t i vg. itfpf._11}_rLt o Av o i d rurther Violation.1 The definition of M&TE in STA-604 h3s been revised in order to provide further clarificatic, for temporarily installed instrumentation.

Applicable CPLES departments have been directed to ensure that equipment meeting the clarified procedural definition of M&TE is included in the program.

4)

[13te When Qill Compliance Will Be Achigy,e,d fu Electric is now in full compliance.

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