TXX-4408, Responds to NRC Re Violations Noted in Insp Repts 50-445/84-40 & 50-446/84-15.Corrective Actions:Rev 6 to Procedure CP-QP-16.1 Re Significant Const Deficiencies Issued
| ML20137Z780 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/04/1985 |
| From: | Clements B TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20137Z758 | List: |
| References | |
| TXX-4408, NUDOCS 8510080368 | |
| Download: ML20137Z780 (3) | |
Text
. m..".'.'M I *M ".I."15, February 4, 1985 TXX-4408 Docket Nos. 50-445 50-446 S fel(h h f-Mr. Dorwin R. Hunter Chief, Reactor Project Branch 2
),I U.S. Nuclear Regulatory Commission, FEB 81985 Region IV Of fice of Inspection & Enforcement
,u Parkway Central Plaza Building 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011
Dear Mr. Hunter:
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NO: 50-445/84-40 and 50-446/84-15
Dear Mr. Hunter:
We have reviewed your letter dated January 9, 1985 on the inspection conducted under the Resident Inspection Program by Mr., J. E. Cummins and NRC contract personnel of activities authorized by NRC Construction Permits CPPR-125 and CPPR-126 for Comanche Peak, Units 1 and 2.
We have responded to the findings listed in Appendix A of that letter.
To aid in the understanding of our response, we have repeated the Notice of Violation followed by our response. We feel the enclosed information to be responsive to the Inspector's findings.
If you have any questions, please advise.
Yours truly, J
l BRC:kh Enclosure c: NRC Region IV (0 + 1 copy)
Director, Inspection & Enforcement (15 copies)
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 8510080368 850906 PDR ADOCK 05000445 Mr. V. S. Noonan G
PM A DEVEN10N OF TEXAN l'TELITIEN ELECTNIC COMi*ANY
a o-APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Dockets:
50-445/84-40 Comanche Peak Steam Electric Station, 50-446/84-15 Units 1 and 2 Construction Permits: CPPR-126 CPPR-127 Based on the results of an NRC inspection conducted during the period of October 21, 1984, through December 18, 1984, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 49 FR 8583, dated March 8, 1984, the following violation was identified:
Failure to Assign a Unique Identifier to a 10 CFR 50.55(e) Item 10 CFR 50, Appendix "B",
Criterion V requires that, " 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".
Non-ASME QA/QC Procedure CO-QP-16.1, Revision 5, Section 3.4 has been established in accordance with Criterion V and requires that a unique sequential identifier be assigned to reportable 10 CFR Part 50.55(e) items.
Contrary to the above, on October 26, 1984 the NRC inspector observed that the identifier CP-83-17 had been assigned to two different items.
The first item, ID number 117, was identified July 6, 1983.
This iten involved potential tiltout subassemblies by RTE-Delta.
The second item, ID number 118, was identified July 12, 1983. This item involved relief valves for containment cooling water side of the spent fuel pool cooling heat exchangers which were set at an incorrect back pressure.
This is a Severity Level V violation.
(Supplement II.E) (445/8440-01)
Discussion Our review of this matter found the following:
The SDAR identifier CP-83-17 was assigned to a potential problem with the Diesel Generator System RTE-Delta Potential Transformer Tiltout Subassemblies as a result of our receipt of a 10CFR21 report issued by Transamerica Delaval to the NRC on this equipment.
Following the issuance of SDAR CP-83-17 on this subject, it was concluded that since the item had been reported to the NRC under 10CFR21, it was not necessary to report the item under the requirements of 10CFR50.55(e) and therefore, the SDAR was voided. Log number CP-83-17 was subsequently reassigned to a second potentially reportable problem.
This was due to an incorrect assumption that the voiding of the first CP-83-17 SDAR in the site log satisfied the procedure requirements and the next sequentially numbered SDAR should, therefore, be CP-83-17.
~
-o As a result of this review, the site procedure for issuing unique identifier numbers to potentially reportable items have been revised to prevent the reuse of a voided SDAR log number.
Corrective and Preventive Action Taken Revision 6 to CP-QP-16.1, Significant Construction Deficiencies, was issued January 16, 1985 to incorporate guidance to prevent the re-assignment of voided SDAR log numbers. The appropriate site personnel have been trained in this procedure.
No other instance of a similar nature was identified during our review.
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