ML20195D215
| ML20195D215 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/31/1988 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-88758, NUDOCS 8811040269 | |
| Download: ML20195D215 (3) | |
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M FE Log i TXX-88758 File # 10130
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IR 88-59 C
Ref. #
C 2 01 j
l 3C:jg October 31, 1988 c
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O. S. Nuclear Regulatory Cona;ission Atta: Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STA110N (CPSES) 00CKET NOS. 50-445 AND 50-446 RESP 0f!SE T0 hRC INSPECTION REPORT NOS.
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50-445/88-59 AND 50-446/88-55 Gentlemen:
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TU Electric has reviewed your letter dated September 30, 1988, concerning the inspection conduc'te.] by Mr. II. H. Livermore and a NRC t.onsultant during the period August 3 through September 8, 1988.
This inspection covered activities i
autharized 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 Vit./
W. G. Counsil i
RDD/mlh Attachment
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l' c - Mr. R. D. Martin, Region IV Restlent inspectors, CPSES (3) 9 i.
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Attachment to TXX-88758 October 31, 1988 Page 1 of 2 NOTICE OF VIOLATION
-(T457Msrv 03T-Criterion V of Appendix B to 10 CFR Part 5;, as implemented by Section 5.0, Revision 3 of the TV Electric Quality Assurance Plan (QAP), states, in pnt,
" Activities af fecting quality shall be prescribed by documented instrt ct ions, procedurci, or drawings, or a type approprNte to the circumstances and shall be accomplished :n accordance with these instructions, procedures, or drawings Instructions for Attachment 5, "Flex Conduits," Revision 3, to Field Verification Method (FVM) CPE-SWEC-FVM-EE/ME/IC/CS-089 states, in part, "All flex conduit... will be verified for proper type, only the unsat flex conduit will be listed on data sheet."
Contrary to the above, the following conditions were identified for room 150A:
1.
Conduit C03G10245 was listed on the data sheet as Amertite lype VF (Unsatisfactory) though it is actually Sealtite Type UA (Satisfactory).
2.
Conduit C03G06656 was not listed though it is Amertite Type VF (Unsatisfactory).
f.ESPONSE TO NOTICE t1F VIOLATION 94578859W-of- ~
TV Electric agrees with the alleged violation and the requested information follows:
1.
Reason for Violation This violation was the result of a failure by personnel to implement the requirements of FVM CPE-SNEC-F\\M-EE/MC/IC/CS-089 (rVM-089), "Flex Cor.du i t s. "
To detcemine the extent of this violation, the results of a TV Electric QA audit, SWEC QA surveillance and additional reverifications of rooms originally walked do.cn by individuals other than those responsible for the deficien'ies noted in this violation were reviewed.
No unsatisfactory findings were noted in SWEC QA surveillance CS-87-0120 or TV Liectric Audit ATP-88-0122.
The room reverification identsfied only a few deficiencies and did not indicate any weakness in the overall implementation of FVM-089 requirements.
Based on this review TU Electric considers the deficiencies identified in this violation to be limited to the performance of thc individuals who conducted the FVM-089 walkdown of room 150A.
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Attachm:nt to TXX-88758
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- October 31, 1988 Dage 2 of 2 NOTICE OF VIOLATION
~1[4W885PT-Tlf 2.
Corrective Steps Taken and Results Achieved Deficiency Report (OR) C-88-03735 was init:ated to resolve the deficiencies identified in the F'/M-089 nalkdown of room 150A.
The disposition of this DR required a complete resvalkdown/ reverification of flexible conduit in the rooms which were originally walked down by the individuals res>onsible for the identified deficiencies.
The orioinal walkdown data sleets were marked "superseded' and the walkdown packages supplemented by data sheets from the reverification /rewalkdown.
Flexible conduit deficiencies identified were documented on nonconformance reports (NCRs), including room number 150A, twenty rooms were rewalke.1/ reverified and NCRs were initiated fcr deficiencies omitted in the original walkdown of ',even of these rooms.
The actions required by the dispesition of OR C-88-03735 were completed by August 31, 1988.
3.
Corrective Steps Which Will be Taken to Avoid Further Violati_ons Since TVM-089 field walkdowns of flexible conduit have been completed, including the reverifications required by OR C-88-03735, and the individuals respensible for the deficiencies noted in this violation are no longer involved in electrical PCHVP activities, TV Electric considers the actions described in 2 above to be suf ficient to prevent further violations.
4.
Date When Full Compliance j[ill be Achieved full compliance was achieved by the completion of actions required by OR C-83-03735 on August 31, 1988.