ML20116F041
| ML20116F041 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/05/1992 |
| From: | William Cahill, John Marshall TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-92505, NUDOCS 9211100146 | |
| Download: ML20116F041 (3) | |
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E IR 92-33 Ref.
- 10CFR2.201 November 5, 1992 William J. CahlH. Jr.
Gnwp Vwe Presidener U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, OC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNIT 2 DOCKET NO. 50 446 NRC INSPECTION REPORT N05. 50-445/92-33: 50-446/92-33 RESPONSE TO NOTICE OF VIOLATION Gentlemen:
TV Electric has reviewed the NRC's letter dated October 6,1992,- concerning the inspection conducted by the NRC staff during the period September 8 through September 10, 1992.
This inspection covered activities authorized by NRC Operating License NPF-87 and Construction Permit CPPR-127.
Attached to the October 6. 1992 letter was a Notice of Violation (NOV).
TV Electric hereby res:
ds to the Notice of Violation (446/9233-01) in the attachment to this letter.
Sincerely, William J. Cahill, Jr.
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By:
J. S. Marshall Generic Licensing Manager OB/ds Attachment c-Mr. J. L. Milhoan, Region IV Resident Inspectors, CPSES (2) 090105 9211100146 921105 j
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4tX1 N. Olive street L.B. 81 Dallas, Texas 75201
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- ~to_TXX-92505 Page 1 of-2' NOTICE OF VIOLATIO3 (446/9233-01) 10 CFR Part 50, Appendix B Criterion V, as implemented by Section 5 of the TV Electric Quality Assurance Manual, states, in part, that activities affecting quality shall be prescribed by documented procedures and shall be
- accomplished in accordance with these procedures.
' Procedure 2PP-3.05,
- Procedure for Processing of TV Evaluation Forms (TVE) and Conditional Release Requests, "Section 4, defines a
" Programmatic / Repetitive Condition
- as "[a] condition which requires evaluation beyond that required for individual nonconformances or
- deficiencies.. These conditions require a determination of cause,'an evaluation of generic implications, corrective action, and preventive action.
(Attachment 8,0)".
Procedure 2PP-3.05, Attachment 8.C. contains instruction for the RIO to determine if the *TUE [has] potential impact or impose differences'to-Unit 1.
If yes, enter TE/0NE Form /DM number '
a)
Contrary to the above, the licensee failed to identify, in.TVE 92-5633.
Revision 1, the multiple loose instrument fittings as a condition that would require evaluations beyond that required for individual nonconformances or deficiencies.
b)
Contrary to the above, the licensee failed to identify, in TUE 92-5633, Revision 1, a condition-that had potential impart to Unit 1.
RESPONSE TO NOTICE OF VIOLATION (446/9233-01)
TU Electric accepts the violation and the requested information follows:
1.
Reason for Violation a)
As a result of five (5) TUE forms which identified loose ECSA fittings and a walkdown of twenty-nine (29). additional ECSAS' TUE 92-5633 was issued to document the need for an evaluation as a programmatic / repetitive condition. 'TUE 92-5633 was the subject of l
e spec.ial-Quality Accountability meeting at which it was determined that further evaluation or" root cause analysis'was not necessary since the total population was known'and it was believed that all deficient ECSAs would be identified and reworked.
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. to TXX-92505 Page 2 of 2 b)
It was determined through personnel interviews that verbal communication regarding this issue did occur with Unit 1 personnel.
However, this was not documented on a Technical Evaluation (TE) form as required by procedure.
This lack of documentation was caused by the engineer believing a TE was not required because the Unit 1 specification contained a process for correcting the condition if identified.
2.
Corrective Steps Taken and Results Achieved The conditions noted on TUE 92-5633 were upgraded to programmatic / repetitive and documented on TUE 92-6300.
In addition, the f ailure to write a TE was documented on TUE 92-5633, Revision 1, and TE 92-1944 was issued.
The description in the Notice of Violation should have referred to TE 92-5633 Revision 0 instead of Revision 1.
TU Electric reviewed additional TUE forms identified within the quality accountability meeting notes, and did not find other TUE conditions which should have been categorized as programmatic / repetitive conditions.
3.
Corrective Action Taken to Preclude Recurrence An assessment of the Unit 2 nonconformance and corrective action process was performed to assure compliance with regulatory requirements, Quality Assurance Program requirements and licensing commitments. The assessment was performed by an independent reviewer not associated with the Unit 2 corrective action program.
Root cause determination and oeneric implication evaluation were part of this assessment.
This evaluation concluded that the threshold for initiation of a programmatic / repetitive TUE form, in this case, was too high.
- However, it was concluded that overall the TUE program was in compliance with applicable requirements and commitments.
This assessment is available for review at CPSES.
A memorandum from the Unit 2 Project Manager has been issued to re-emphasize management's expectation regarding procedure compliance and proper documentation of actions taken for deviations found during construction activities.
4 Date When ComDliance Will Be Achieved Full compliance has been achieved.
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