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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/84-32 & 50-446/84-11.Corrective Actions for Items 1 & 2 Will Be Reviewed W/Comanche Peak Response Team Program Plan
	ML20132G865
Person / Time
Site:	Comanche Peak
Issue date:	07/30/1985
From:	Hunter D; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Spence M; TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
	NUDOCS 8508050167
	Download: ML20132G865 (2)
	v • d • e

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JUL 3 01985

In Reply Refer To:

Dockets: 50-445/84-32

50-446/84-11

Texas Utilities Electric Company

ATTN: M. D. Spence, President, TUGC0

Skyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas 75201

Gentlemen:

Thank you for your letter of March 11, 1985, in response to our letter and

Notice of Violation dated February 15, 1985. We have reviewed your reply and

find it addresses the concerns raised in item 3 of our Notice of Violation.

We will review your corrective actions for items 1 and 2 as part of our

examination of tne Comanche Peak Response Team Program Plan. We will

review the implementation of your corrective actions during a future inspection

to determine that full compliance has been achieved and will be maintained.

Sincerely,

,,ortsnal Sippd @

D.R guNTER,

Dorwin R. Hunter, Chief

Reactor Project Branch 2

cc:

Texas Utilities Electric Company

ATTN: B. R. Clements, Vice

President, Nuclear

Skyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas 75201

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TXX-4435

Dorwin R. Hunter, Chief

Reactor Project Branch 2

U.S. Nuclear Regulatory Commission

Office of Inspection & Enforcement

611 Ryan Plaza Drive, Suite 1000 Docket Nos.: 50-445

Arlington, TX 76011 50-446 T W '/

COMANCHE PEAK STEAM ELECTRIC STATION

RESPONSE TO NRC NOTICE OF VIOLATION

INSPECTION REPORT 84-32

FILE NO.: 10130

Dear Mr. Hunter:

We have reviewed your letter dated February 15, 1985 regarding the inspection

conducted under the Resident Inspection Program by H.S. Phillips of activities

authorized by NRC Construction Permit CPPR-125 for Comanche Peak Units 1 and 2.

Our review of the findings cited in the Notice of Violation under Appendix A to

your letter indicates that two of the findings are siiailiar in nature to those

identified by the NRC Technical Review Team (TRT). In accordance with one of

your proposed response options, we have elected to respond to findings 1 and 2

of the Notice of Violation as part of the Comanche Peak Response Team Action

Plan.

We are providing a response to Finding No. 3 in Appendix A of your letter. To

aid in the understanding of our response, we have repeated the finding from the

Notice of Violation followed by a summary of our corrective actions. The

documentation of specific corrective actions is available at the TUGCo QA Dallas

office for your Inspector's review.

If you have any questions, please advise.

Very truly yours,

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TXX-4435

3/11/85

Page 2

ATTACHMENT

FAILURE TO PROPERLY CERTIFY A

VENDOR COMPLIANCE INSPECTOR

Failure to Properly Certify a Vendor Compliance Inspector

Criterion V of 10 CFR 50, Appendix B, states in part, " Activities affecting

quality shall be prescribed by documented instructions, procedures, or drawings,

of a type appropriate to the circumstances and shall be accomplished in

accordance with these instructions, procedures, or drawings."

TUGC0 Procedure DQP-VC-4, Revision 6, dated January 5, 1984, requires that Level

II inspectors (Corporate QA) shall attend and satisfactorily complete nonde-

structive testing courses including eddy current testing.

Contrary to the above, one of six inspector's files had no documentation to show

that the inspector had attended and completed an eddy current testing course.

Subsequent, discussions revealed that he had been certified without meeting this

requirement. The vendor compliance supervisor stated that this inspection skill

is not needed since there is no present vendor work activity which would require

this skill; therefore, this procedure was revised and the requirement omitted

during this inspection.

This is a Severity Level V Violation. (Supplement II) (445/8432-05;

446/8411-05)

Corrective Steps which have been taken and the results achieved:

The certification of the inspector without the required eight (8) hour training

was an oversight. A review of all six (6) Vendor Compliance Inspector's work

reflected no instance where eddy current testing was involved. The procedure

revision discussed below was processed to reflect our actual inspection needs.

Corrective steps which have been taken to avoid further violations:

As there is no present nor planned vendor work activity which would require this

skill, TUGCo Procedure DQP-VC-4 has been revised by deleting the requirement for

an eight (8) hour training course in eddy current testing. Should the need for

a familiarity with eddy current testing arise, the Vendor Compliance Supervisor

will take the necessary action to either train or obtain a qualified inspector.

Date when full compliance will be achieved:

Procedure DQP-VC-4 was revised August 27, 1984.

L ___--._____________.__-_-__.___._.____J

ML20132G865

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