ML20148F744
| ML20148F744 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/24/1988 |
| From: | Counsil W, John Marshall TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-88334, NUDOCS 8803280276 | |
| Download: ML20148F744 (3) | |
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F 7 Log # TXX-88334 1
File # 10130 C
Z IR 88-01 711ELEC7RlC Ref #
C 2 01 March 24, 1988
%illiara G. counsil Enecwn b ut f>rsknr U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET N05. 50-445 AND 50-446 RESP 0f4SE TO NRC INSPECTICli REPORT NOS. 50-445/88-01 AND 50-446/88-01 i
Gentlemen:
TV Electric has reviewed your letter dated I,ruary 23, 1988, concerning the inspection conducted by Mr. C. J. Hale i.nd,ther inspectors and NRC consultants during the period January o, 1988 through February 2, 1988.
This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2.
Attached to your letter was a Notice of Violation.
We hereby respond to the Notice of Violation in the attachment to this letter.
Very truly yours,
(/l, {. (ou n c L l W. G. Counsil By:
J. S. Marshall Generic Licensing Manager RDD/clk Attachment c-Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3) h$k k6$
5 O
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400 %vth OMr Stre-i B 81 Dallas, Texas 73.'01
- i. '
Attachment to TXX-88334
'. March 24, 1988 Page 1 of 2 NOTICE OF V10LATI0f]
R45/8801-V-02;446/8801-V-02)
Criterion V of Appendix B to 10 CFR Part 50 states, in part, that activities affecting quality shall be prescribed by documented procedures, of a type appropriate to the circumstances, and shall be accomplished in accordance with these procedures.
Paragraph 6.7.3 of Procedure NQA 1.03 stated that flDE and inspection procedures require the approval of the discipline Level 111 inspector.
Paragraph 6.5.1 of Procedure NQA 1.03 stated, in part, that a document change notice (DCN) shall be forwarded to the appropriate Level 111 (if applicable),
the Section f1anager, and the Director, Quality Assurance for approval.
Contrary to the above, DCN 3 to Procedure HQA 3.09-5.01, "Inspection of Instrumentation Components," an inspection procedure, was issued without the approval of the discipline Level III inspector.
OCH 3 revised the technical content of inspection Procedure NQA 3.09-5.01 (445/8801-V-02; 446/8801-V-02).
RESPONSE TO NOTICE OF VIOLATION (445/8801-V-02; 446/8801-V-02)
TV Electric agrees with the alleged violation and the requested information follows:
1.
Reason for Violation The reason for this violation was insufficient procedural guidance regarding the need for appropriate level 111 approval of DCNs which af fect inspection and NDE activities.
2.
Corrective Steps Taken and Results.Schieved Deficiency Report (DR) C-88-00591 was initiated to identify DCNs which were implemented without level 111 approval.
Those OCNs which were implemented without level lil approval will be reviewed for technical adequacy by the Discipline Level Ill.
Those DCNs which are determined adequate will be accepted by the level 111 and this approval will be documented in the historical file associated with the 3rocedure.
If the Level 111 review identifies procedural inadequacies, t1ey will be identified and addressed via DRs.
Procedure NQA 1.03, Revision 4 was issued on February 11, 1988, to clarify the need for appropriate level Ill approval of DCNs.
3.
Corrective Steps Which Will be Talen to Avoid Future Violat_ ions NQA 1.03 will be further revised to incorporate a matrix which will identify the appropriate approval requirements for each NQA procedure and revisions thereto,
Attachment to TXX-88334 s
March 24,1988
.* Page 2 of 2 1
l l
4.
Date When full Compliance Will be Achieved The revision to NQA 1.03 and the review of DCNs described above will be completed by May 1, 1988.
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Attachment to TXX-88334 March 24, 1988 Page 2 of 2 4.
Date When Full Compliance Will be Achieved The revision to N0A 1.03 and the review of DCils described above will be completed by May 1, 1988.