ML20207R791

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Ack Receipt of 861013,1104 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/86-01 & 50-446/86-01
ML20207R791
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 03/06/1987
From: Johnson E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Counsil W
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8703180141
Download: ML20207R791 (2)
v • d • e


See also: IR 05000445/1986001

Text

, _ _ - _ _ _ . _. .

. i

In Reply Refer To: MAR - 6 INT

. Dockets: 50-445/86-01 ,

50-446/86-01

TU Electric

ATTN: Mr. W. G. Counsil

Executive Vice President

400 North Olive, L.B. 81

Dallas, Texas 75201

Gentlemen:

Thank you for your letters of October 13, 1986, November 4, 1986, and

,

~ January 9,1987, in response to our letters dated August 29, 1906, and

December 3, 1986. We have reviewed your reply and find it responsive to the

concerns raised in our Notice of Violation. We will review the implementation

of your corrective actions during a future inspection to determine that full

compliance has been achieved and will be maintained.

Sincerely.

OMut Ebe'#7?d U

t, H. Johnso9. Johnson

.

E. H. Johnson, Director

Division of Reactor Safety

and Projects

cc:

TU Electric

ATTN: G. S. Keeley, Manager

i Nuclear Licensing

Skyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas 75201

Juanita Ellis

President - CASE

1426 South Polk Street

Dallas, Texas 75224

l

RIV/CPTG Y8 DRSP k

IBarnes:gb EHJo nson

5 / //87 3/g)/87 l\

8703180141 870306 f

PDR ADOCK 05000445

0 PDR

-., _ . _ _ _ - - - -

- . - - . - . _ _ . . _ _ _ . . - . _ - - - - . - _ _ - .

. .

TU Electric -2-

Renea Hicks

Assistant Attorney General

Environmental Protection Division

P. O. Box 12548

Austin, Texas 78711-2548

Administrative Judge Peter Bloch

U.S. Nuclear Regulatory Consission

Washington, D.C. 20555

Elizabeth B. Johnson

Administrative Judge

Oak Ridge National Laboratory

P. O. Box X. Building 3500

Oak Ridge, Tennessee 37830

Dr. Kenneth A. McCollom

1107 West Knapp

Stillwater, Oklahoma 74075

Dr. Walter H. Jordan

881 Outer Drive

Oak Ridge, Tennessee 37830

Anthony Roisman, Esq.

Executive Director

Trial Lawyers for Public Justice

2000 P. Street, N.W. Suite 611

Washington, D.C. 20036

Texas Radiation Control Program Director

bectoDMB(IE01)

bec distrib. by RIV:

  • RPB * MIS System
  • RRI-0PS *RSTS Operator
  • RRI-CONST *R&SPB
  • T. F. Westerman, RSB DRSP

V. Noonan, NRR R. Martin, RA

L. Chandler, 0GC *RSB

  • RIV File J. Taylor, IE
  • D. Weiss, RM/ALF J. Conklin, IE
  • I. Barnes, CPTG * Project Inspector
  • R. Hall

__

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

7_

.

File # 10130

IR 86-01

TEXAS UTILITIES GENERATING COMPANY IR 86-01

NKYW AY TOWER = 400 NORTH OLIV E NTRE,T. l.B. 85 8) ALIAS. TEXAM 7520B

January 9, 1987 - t

\

WILLIAM G COUNSIL

,.e

Mr. Eric H. Johnson, Director )c i 3 l 391R (glU

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Division of Reactor Safety and Projects }.

U. S. Nuclear Regulatory Commission

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-}

611 Ryan Plaza Driye, Suite 1000

Arlington, TX 76011

SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS.: 50-445 AND 50-446

INSPECTION REPORT NOS. 50-445/86-01 AND 50-446/86-01

SUPPLEMENTAL RESPONSE TO NRC NOTICE OF VIOLATION (NOV)

ITEM A AND NOTICE OF DEVIATION (N00) ITEMS B AND C

REF: 1. TUGC0 Letter TXX-5048 from W. G. Counsil to E. H. Johnson dated

October 13, 1986.

2. TUGC0 Letter TXX-6070 from W. G. Counsil to E. H. Johnson dated

November 3, 1986.

Dear Mr. Johnson:

We have reviewed your letter dated December 3,1986, requesting additional

information to our responses referenced above regarding NOV 445/8601-V-12 and

446/8601-V-03 (Item A) and N0D 445/8601-D-17 (Item 8.1), 445/8601-0-20 (Item

B.2), 445/8601-D-19 (Item B.3), and 445/8601-D-18 (Item C). We hereby respond

to the request for supplemental information in the attachment to this letter.

We requested and received an extension until January 9, 1987 in providing our

response during a telephone conversation with Mr. T. F. Westerman on

December 18, 1986.

Very truly yours,

bh, hundl

W. G. Coun il

By:

G. S. Keeley

/

.

Manager, Nuclear L ensing

RSB/amb

Attachment

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January 9, 1987

Page 2 of 2

c - NRC Region IV (0 + 1 copy)

Director, Inspection and Enforcement (15 copies)

U. S. Nuclear Regulatory Commission

Washington, D. C. 20555

Mr. V. S. Noonan

Mr. D. L. Kelley

    • ' '

Attachment to TXX-6173

-

January 9, 1987

Page 1 of 5

NOTICE OF VIOLATION

ITEMS A.1 THROUGH A.6 (445/8601-V-12 AND 446/8601-V-03)

SUPPLEMENTAL REQUEST FOR INFORMATION

With respect to Item A.1, you did not provide the " Reason for Violation"

regarding your failure to implement the requirements of Procedure CP-QP-16.3

for Deviation Reports (DRs) which were generated for non-ASME components;

e.g., HVAC equipment. Additionally, in regard to " Corrective Action Taken,"

please confirm that the review of DRs was not limited to just those associated

with ASME equipment. With respect to Item A.4, staff review of Procedure

CP-QAP-16.1, Revision 25, finds that the document literally requires that

nonconforming items identified on nonconformance reports (NCRs) are to be

clearly identified with signs, barriers, and/or hold tags. Accordingly, while

we have no questions concerning the subsequent revision made to this

procedure, we do not concur with your stated reason for disagreement with this

finding. Therefore, please provide the information required by the NOV for

this item.

With respect to Item A.6, your response indicates that you have restricted

consideration of the violation to Comanche Peak Response Team (CPRT)

activities only. The fact that you acknowledged in the " Reason for Violation"

for Item A.3, the existence of conditions outside of CPRT activities which

were not documented on NCRs, supports the stated violation. Therefore, please

provide the information required by the NOV for this item.

SUPPLEMENTAL RESPONSE TO ITEM A.1

The TUGC0 initial response to this item only addressed the failure to initiate

NCR's for items falling under the ASME Section XI program since this was the

only activity identified through the TUGC0 review of the QA/QC Coordinator's

DR/NCR log where other than NCR's were written for DR's received from ERC.

NCR's were initiated for all ERC DR's generated for non-ASME components.

It appears that the absence of an NCR number in the QA/QC Coordinator's log

led the NRC inspector to believe than an NCR was not intended to be initiated.

This was not the case. The DR number and date received were entered in QA/QC

Coordinator's log upon receipt for tracking purposes and to assure action was

taken. Subsequent to NCR issuance, the log was updated to reflect the

corresponding NCR number, date issued and identification of the NCR initiator.

We acknowledge that during December 1985 and January 1986 some NCR's were not

issued for up to 30 days after DR issuance. This was due primarily to the

large number of DRs being generated and the holiday work schedule. We do not

consider the delays to be excessive.

As you requested, TUGC0 confirms that its review of DR's encompassed all DR's

rather than being limited to only those associated with ASME equipment.

r

.. ,.

Attachment to TXX-6173

January 9, 1987

Page 2 of 5

NOTICE OF VIOLATION

ITEMS A.1 THROUGH A.6 (445/8601-V-12 AND 446/8601-V-03)

SUPPLEMENTAL RESPONSE TO ITEM A.4

1. Reason for Violation:

Upon further review, TUGC0 agrees that a literal reading of the tagging

criteria in CP-QAP-16.1, Revision 25, required the identification of all

nonconforming items with signs, barriers, and/or hold tags. However, this

was not the intent. The intent was to identify items not yet installed to

prevent their inadvertent use or installation. It was not intended to

identify items installed and functioning properly since the NCR provides

adequate control of those items.

2. Corrective Action Taken:

CP-QAP-16.1, Revision 27, dated August 13, 1986, was issued to require the

placement of hold tags on nonconforming items, where practicable,

regardless of the stage of component processing. However, on December 22,

1986, a revision to the nonconformance identification and processing

procedures was implemented by TUGCO. CP-QP-16.0, "Nonconformance", and

its daughter instructions currently provide nonconformance identification

requirements which include initial identification of nonconforming

conditions on Construction Deficiency Reports (CDR). Tagging criteria is

now contained in QI-QP-16.0-8, Revision 0, dated December 22, 1986.

Paragraph 3.4 of this procedure requires that " hold tags" be placed on

deficient items if:

a. The item is not installed; or,

b. Correction of the deficiency without QC witness would preclude

proper reinspection.

3. Action to Prevent Recurrence:

The clarification of the procedure requirements provided by CP-QAP-16.1,

Revision 27, and implementation of the current nonconformance

reporting / identification requirements prevents recurrence of this '

violation.

4. Date of Full Compilance:

CPSES is currently in compitance.

SUPPLEMENTAL RESPONSE TO ITEM A.6

1. Reason for Violation:

The TUGC0 initial response to this item was restricted to consideration of

CPRT-related activities because of the limited number of three-part memos

initiated by IPC involving nonconforming conditions. The reason for IPC

personnel issuing three-part memos in lieu of NCR's was the result of the

controlling IPC procedure (IPC-P3) not requiring that NCR's be issued when

the inspectors noted a deficiency that was out-of-scope from the

inspection checklist.

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.. . . . .

Attach:ent to TXX-6173

January 9, 1987

Page 3 of 5

NOTICE OF VIOLATION -

ITEMS A.1 THROUGH A.6 (445/8601-V-12 AND 446/8601-V-03)

SUPPLEMENTAL RESPONSE TO ITEM A.6 CONT'D

2. Corrective Action Taken:

As identified on NCR E86-200637, 53 out-of-scope three-part memos were

initiated by IPC. Quality engineering evaluation of those memos

determined that 30 of them documented nonconforming conditions which

should have been documented on NCR's. The nonconforming conditions

described on the 30 three-part memos have been documented on individual

NCR's and included in the monthly trend analysis report. All NCR's were

issued on or before 4/30/86. The initial failure to include those 30

items in the monthly trend analysis report did not impact the validity of

the monthly reports. This conclusion is based on the unrelated nature of

the nonconforming conditions and the relatively small number of the NCRs

as compared to the average number of 1300 NCR's trended each month.

3. Action to Prevent Recurrence:

As stated in the response to Item A.3, the Inspection Surveillance Program

required the initiation of an NCR for all discrepancies or concerns noted

during surveillance activities. However, on December 22, 1986, a revision

to the nonconformance identification and processing procedures was

implemented by TUGCO. CP-QP-16.0, "Nonconformances", and its daughter

instructions currently provide nonconformance identification requirements

which includes initial identification of nonconforming conditions on

Construction Deficiency Reports (CDR).

4. Date of Full Compliance:

CPSES is currently in compliance.

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Attachment to TXX-6173

January 9, 1987

Page 4 of 5

NOTICE OF DEVIATION

ITEM B.1 (445/8601-D-17)

ITEM B.2 (445/8601-0-20)

ITEM B.3 (445/8601-D-19)

SUPPLEMENTAL REQUEST FOR INFORMATION

With respect to items B.1, B.2, and B.3, please identify what specific

documented actions were taken to prevent recurrence for each of the three

stated examples.

SUPPLEMENTAL RESPONSE TO ITEMS 8.1, B.2, AND B.3

With respect to Items B.1, B.2, and B.3, documentation of action to prevent

recurrence is contained in appropriate ERC files. The specific documented

actions taken are meetings and discussions that took place between the

affected inspector and the lead inspector, overview inspector or the QA/QC

Population engineer. These documents are available for NRC review.

Additionally, an Overview Inspection Program was implemented to reinspect a

sample of each inspector's work. Results of the Overview Inspection Program

~

are complete and available for NRC review. The inspector for Verification

Package No. I-M-LBC0-038 had an overall error rate of 0.19%. The inspector

for Verification Package No. I-M-LBC0-144 had an overall error rate of 2.68%.

Based on these results and the documented discussions stated above, no further

action to prevent recurrence is required.

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Attachment to TXX-6173

January 9, 1987

Page 5 of 5

NOTICE OF DEVIATION

ITEM C (445/8601-D-18)

SUPPLEMENTAL REQUEST FOR INFORMATION

Please clarify whether surveillance and/or audits have specifically addressed

the work activities of the QA/QC engineer applicable to this deviation.

,

SUPPLEMENTAL RESPONSE TO ITEM C

With respect to Item C, ERC QA surveillance number II 85-20 specifically

addressed the work activities of the QA/QC engineer applicable to the Large

Bore Piping Configuration (LBC0) population. This surveillance is available

for NRC review.

.

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