ML20149K102

Final Deficiency Rept CP-87-07 Re Items Procured to Improper Code Class.Initially Reported on 870406.Procedure ECE-602-12 Issued to Control Future Procurement of Spare Parts for safety-related Components

ML20149K102
Person / Time
Site:	Comanche Peak
Issue date:	02/19/1988
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CP-87-07, CP-87-7, TXX-88168, NUDOCS 8802230357
Download: ML20149K102 (2)

Text

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nlELECTRIC wai.. c. co a February 19, 1988 Execustw Vke Pressdent U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION DOCKET NOS. 50-445 AND 50-446 ITEMS PROCURED TO IMPROPER CODE CLASS 50AR: CP-87-07 (FINAL REPORT)

Gentlemen:

On April 6,1987, we verbally notified your Mr. C. Hale, of a deficiency involving items procured to improper code cla:s. Our most recent interim report was logged TXX-6436, dated May 6, 1987. We are reporting this issue under the provisions of 10CFR50.55(e). The required information follows.

Description This deficiency was discovered as a result of investigations ennducted for Corrective Action Request (CAR)86-002.

Nonconfonnance Raports (NCRs) 86-0043, PE-86-00054, 86-0073 ano 56-0021 (Rev. 1) identified relays, terminal blocks and oil level switches which were procured with a 0-code "C" instead of a 0-code "A" as required. The documentation requirements imposed in these instances may not have been suf ficient to assure that the quality of the item purchased was equivalent to the quality of the item as provided under the original equipment specification, or as required to maintain equipment qualification.

The cause of this deficiency has been determined to be misinterpretation of l the term "identical components" as specified in Regulatory Guide 1.89. Due to the comprehensive procurement engineering review implemented on August 1, 1985, under procedure N0E-204, this deficiency is limited to the procurement i of safety related spare parts prior to August 1, 1985.

Safety Implications l l

Installation of items which were not procured to the required QA code "A" for I safety related components could result in inadequate qualification of the Sfected Class 1E components. As a result of the extensive evaluation required to address the sigificance of these deficiencies, we have conservatively determined this issue to be reportable under the provisions of 10CFR50.55(e). Therefore, in the event this condition had remained i uncorrected, the safe operation of the plant could have been adversely ( j

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TXX-80168 February 19, 1988 Page 2 of 2 Corrective Action To prevent recurrence of this deficiency, procedure ECE-6.02-12 (formally N0E-204) has been issued to control the future procurement of spare parts for safety related components.

t A spare parts review has been initiated as a means of addressing deficiencies in the spare / replacement parts procurement engineering review process prior to August 1, 1985. This review is being implemented in conjunction with the parts level Q-list development program. In the review, actual requirements imposed upon past purchases of spare / replacement items are compared and ree.onciled to the Q-list requirements. Where deficiencies are identified, they are documented and resolved in accordance with our established programs for deficiencies and nonconformances.

Corrective actions for both Units 1 & 2 are currently scheduled for completion by September 1, 1988.

Very truly yours, Gi?t '

W. G. Counsil DAR/grr c-Hr. R. D. Hartin, Region IV  ;

Residentinspectors,CPSES(3) 1 P

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