ML20207R791
| ML20207R791 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| 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) | |
See also: IR 05000445/1986001
Text
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In Reply Refer To:
MAR - 6 INT
. Dockets: 50-445/86-01
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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
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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
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8703180141 870306
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TU Electric
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Renea Hicks
Assistant Attorney General
Environmental Protection Division
P. O. Box 12548
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
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Log # TXX-6173
File # 10130
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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
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WILLIAM G COUNSIL
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Mr. Eric H. Johnson, Director
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Division of Reactor Safety and Projects
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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
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Attachment to TXX-6173
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January 9, 1987
Page 1 of 5
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.
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Attachment to TXX-6173
January 9, 1987
Page 2 of 5
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
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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
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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
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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.
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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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