ML20151A172

Interim Deficiency Rept CP-86-48 Re Adequacy of Nonconformance Rept Dispositions.Initially Reported on 860616.Review Indicates Nonconformance Rept Disposition Program Be Revised.Next Rept Expected by 881012

ML20151A172
Person / Time
Site:	Comanche Peak
Issue date:	07/13/1988
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CP-86-48, TXX-88548, NUDOCS 8807190274
Download: ML20151A172 (3)

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"""" E log # TXX-88548 File # 1011n 1 =

r = 917.1 7& ELECTRIC Ref. # 10CFh50.55(e)

July 13, 1988 w m m c.cou m Execu:ive Vke Presidric U. S. Nuclear Regulatory Commission Attn: . Document Control Desk Washington, D.C.- 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 ADEQUACY OF NONCONFORMANCE DISPOSITIONS SDAR: CP-86-48 (INTERIM REPORT)

Gentlemen:

On June 16, 1986, we verbally notified your Mr. C. Hale of a deficiency involving the adequacy of nonconformance report (NCR) dispositions. This is an interim report of a potentially reportat,le deficiency. Our last report was logged TXX-88507, dated Jure 10, 1988.

This issue was initiated as a result of concerns associated with the adequacy of NCR dispositions as noted during review of another potentially reportable deficiency.

Similar concerns associated with the adequacy of nonconformance report dispositions were also documented in site Corrective Arti7n Request CAR-062 issued March 4, 1986. These concerns have been determined to be limited to NCRs dispositioned prior to the current program 3rocedure, NE0 3.05 "Reporting and Control of Nonconformances," effective Decem)er 22, 1986.

CAR-062 was dispositioned on the basis of a random sample of 300 nonconfonnance reports taken from a total aopulation of a;. proximately 40,000 NCRs dispositioned prior to the start of t1e review in April 1986. This sample indicated that deficiencies existed including failure to properly classify the disposition (i.e., use-as-is, rework, repair, scrap, void or other), document the technical justification for the disposition, or fully

address the stated nonconformance. Although these deficiencies existed, the review identified no safety significant issues that had not been previously identified. Additionally it provided a statistical basis to conclude that there are.not likely to be unidentified safety significant issues in the unreviewed population of NCRs.

The review did, however, conclude with recommendations that the NCR disposition program be revised to clarify the program requirements and led to the gene"at'on and implementation (including appropriate training of pert innel) of NE0 3.05, "Reporting and Control of Nonconformances," on Dect aber 22,1986. This NE0 provided the basis for consistent, site-wide implementation of the NCR program utilizing clearer guidelines for disposition  :

classifications, necessary technical justification and thoroughly addressing f

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i IXX-88548 July-13, 1988 Page 2 of 3 .

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.the stated nonconformance. Two disposition classifications recognized by the previous NCR program "void" and "other" (found to be a contributing cause of inaccuracies and confusion) were eliminated under the.NE0. Additionally, it t was decided to perform further reviews of pre-NE0 3.05 NCRs. '

This further review effort involves NCRs initiated prior _to_ December 22, 1986, (implementation date of NE0-3.05, "Reporting and Control of Nonconformances")

and has been conducted in two phases:

Phase One/ Identification

1) Identify undispositioned NCRs which would receive evaluation and dispositioning under the newly implemented NE0 3.05 requirements, and exclude from further review.

2) Identify-(based on an engineering assessment of-the actual disposition), ,

those NCRs potentially affecting engineering requirements (use-as-is, repair or void) and not included -in one of the following design validation programs:

, Piping and Pipe Supports Equipment Qualification Cable Tray and Cable Tray Hangers Conduit HVAC Phase Two/Rev'.ew

1) NCRs which are determined to affect engineering requirements and were not covered under one of the programs abnve, are given a' detailed evaluation to ensure the disposition is technically adequate.

2) Technically adequate NCR dispositions that are not properly justified or documented are provided with an adequate justification and proper documentation. t

3) NCRs with inadequate dispositions are documented on appropriate deficiency documents and evaluated under the current site programs, including a review for safety significance (this step was described as phase III in ,

TXX-6560 dated July 15,1987).

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TXX-88548 July 13, 1988 Page 3 of 3 The Phase One and Phase Two rtviews conducted to date have not identified safety significant deficiencies, indicating that 100' review 4 of pre-NE0 3.05 NCRs may not be necessary. We are continuing our evaluation of this issue and expect to submit the next report by October 12, 1988.

'/ery truly yours s

/ $VlY W. G. Counsil GL8/grr c- Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)

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