ML20140F027
See also: IR 05000445/1985011
Text
..
. _ _
_ _ _ _ _ _ . _ _ _ _ _ _ _
'4
In Reply Refer To:
MAR 12 W
Dockets:
50-445/85-11
50-446/86-06
Texas Utilities Generating Company
ATTN: Mr. W. G. Counsil
Executive Vice President
400 North Olive, L.B. 81
Dallas, Texas 75201
Gentlemen:
Thank you for our letters dated November 11, 1985, December 17, 1985, January 9,
1986, January 15, 1986, and February 13, 1986, in response to our letters dated
October 11, 1985, and December 19, 1985. As a result of our review, we have
no further questions regarding your response to the Notice of Violation and
Item B of the Notice of Deviation. We will inspect your corrective actions
during a future inspection. We continue to be in need of additior.al
information regarding item A of the Notice of Deviation as discussed with your
Mr. T. G. Tyler at the site on March 7, 1986.
Please provide the supplemental information within 20 days of the date of this
letter.
Sincerely,
f "! steed ny
I thnan
E. H. Johnson, Director
Division of Reactor Safety
and Projects
Texas Utilities Electric Company
ATTN:
J. W. Beck, Vice President Licensing
Quality Assurance and Nuclear Fuels
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas
75201
i
Renea Hicks
'
Assistant Attorney General
Environmental Protection Division
P. O. Box 12548
1
Texas Radiation Control Program Director
RIV:CPGk
DRSP k
TFWesterman:gb
EHJohnson
$/p /86
3/g/86
g[
8603280332 860312
l 'l
ADOCK 050 g 5
O
.
.
Texas Utilities Generating
2
Company
Sec to DMB (IE01)
bcc distrib. by RIi:
- RPS
- MIS System
- RRI-0PS
- RSTS Operator
- RRI-CONST
- R&SPB
- T. F. Westerman, CPTG
DRSP
V. Noonan, NRR
R. Martin, RA
S. Treby, ELD
- RSB
- RIV File
J. Taylor, IE
- D. Weiss, LFMB (AR-2015)
R. Heishman, IE
- w/766
.
.
.
Log # TXX-4619
TEXAS UTILITIES GENERATING COMPANY
F i1e # 10130 -
,
.amv vo-=. .
wo.w ouv=
r.=rr. i_.. .. . DMha. MEAS M .
IR 85-11
November 11, 1985
.
wuw a couait
[RECWTrVE VtCS P8ES' DENT
TM@EDWM 3
Mr. R. P. Denise
Division of Reactor Safety and Projects
U. S. Nuclear Regulatory Commission
NOV20125
,e
Region IV
611 Ryan Plaza ~ Drive, Suite 1000
j
,
-
Arlington, Texas 76012
g
SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET N05. 50-445 AND 50-446
RESPONSE TO NRC NOTICE OF VIOLATION
INSPECTION REPORT NO.: 50-445/85-11.
Dear Mr. Denise:
We have reviewed your letter dated October 11, 1985 concerning the
inspection conducted by Mr. T. F. Westerman and other members of the Region
IV Comanche Peak Group during the period June 22 - August 31,.1985. This
inspection covered activities authorized by NRC Construction Permits
CPPR-126 and CPPR-127 for Comanche Peak Units 1 and 2.
4
We have responded to the Notice of Violation in the attachment to this
letter. To aid in the understanding of our response, we have repeated the
Notice of Violation followed by the response. We consider the enclosed
information to he responsive to the Inspectors' findings.
With regard to Appendix B (Notice of Deviation) of your letter, we are
currently investigating these findings. The progress made to date has not
been sufficient to provide an adequate response and to properly address the
additional questions contained in the fourth paragraph of your letter. The
response to the Notice of Deviation is scheduled to be submitted by
December 11, 1985.
Very truly yours,
.
W. G. Counsil
JWA/grr
q9
Attachment
o
4 \\*
c-
Region IV (Original + 1 copy)
Director, Inspection and Enforcement (15 copies)
\\
U. S. Nuclear Regulatory Commission
9;
,
Washington, D.C.
20555
f
Mr. V. S. Noonan
- a
'
Mr. D. L. Kelley
l
a arvssion or rexas vrzurses ms.scasc couraur
.
- _ _ . __
.
- _ _ _ _ - _ _ _ _ - _ _ . _ _ _ _
_ _ _ .
___ _ _ _
_
.
.
.
.
.
.
ATTACHMENT
'
FAILURE TO REPORT NONCONFORMING
CONDITIONS IN A PROMPT MANNER
Failure to Report Nonconforming Conditions in a Prompt Manner:
)
Criterion XVI of Appendix B to 10 CFR Part 50 states, in part, " Measures shall
be established to assure that conditions adversa to quality, such as failures,
malfunctions, deficiencies. deviations, defective material and equipment, and
nonconformances are promptly identified and corrected. . .".
Paragraph 3.1.1 of Procedure CP-QP-16.0, Revision 17, dated July 1,1985, states,
in part, "When a nonconforming condition is identified, the individual shall
immediately apply a Hold Tag, when practical. . . .". Paragraph 3.1.2 of this
procedure states, in part, " Nonconforming conditions shall be reported on the
NCR form . . . .".
Contrary to the above, during a NRC witnessed reinspection on August 6-7, 1985,
of essential lighting system ESB1-42 (Unit 1, safeguards building, elevation 773
ft.) by an Evaluation Research Corporation (ERC) inspector and a TUGCO QC
inspector, nonconforming hardware items were identified with respect to design
document requirements. The identified nonconforming items were outside of
the defined ERC reinspection activity scope and the TUGCO inspector stated
that they would be documented on a NCR form. As of August .29,1985, a NCR
had not been written, a hold tag had not been applied and NRC followup established
that a documented record of the nonconforming items had not been maintained.
This is a Severity Level IV violation (Supplement II) (445/8511-V-01).
Corrective Steps which have been taken and the results achieved:
The Inspector involved has been instructed to document ' deviations from site
procedures
and
design
requirements
in
accordance
with
"Nonconformances", in a prompt, expeditious manner. The Inspector was further
advised that should future instance of work load prohibit timely reporting, his
immediate supervisor should be notified for initiation of appropriate action.
NCR # E-85-100993x has been initiated (8/30/85) to resolve the deficiencies
identified during ERC reinspections conducted on August 6-7, 1985
Corrective Steps which have been taken to preclude repetition:
To preclude further problems of this nature, Inspectors have been assigned to
support the CPRT Program on a permanent, full-time basis.
Date when full compliance was achieved:
Personnel assignments were effective on 9/2/85.
.
. . .
_. _