ML20235B944

Ack Receipt of 870612 & 0803 Ltrs Informing NRC of Steps Taken to Correct Violations & Deviations Noted in Insp Repts 50-445/86-08 & 50-446/86-06.Response to Violation A.1 Acceptable.Violation A.2 Retained.Deviations Withdrawn

ML20235B944
Person / Time
Site:	Comanche Peak
Issue date:	09/14/1987
From:	Warnick R NRC OFFICE OF SPECIAL PROJECTS
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8709240289
Download: ML20235B944 (4)

See also: IR 05000445/1986008

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SEP I 41507

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In Reply Refer To: f

Dockets: 50-445/86-08 l

50-446/86-06  !

TU Electric

ATTN: Mr. W. G. Counsil

Executive Vice President {

400 North Olive, Lock Box 81  !

Dallas, Texas 75201

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Gentlemen:

Thank you for your letters dated' June 12, 1987, and August 3,

1987, in response to our letter dated March 30, 1987. We have

reviewed your response to Violation A.1 and find it acceptable.

i

Your response to item A.2, examples a and b indicates

disagreement with the stated violation that insufficient

documentation existed for our inspector to conclude that the

implementation of field design change procedures and' controls,

and special process procedures and controls were audited. Not

withstanding your disagreement, Brown and Root committed to

provide such documentation in the future and we find that

commitment acceptable. Although we agree that our determination

was subjective, we believe our inspection report and notice of

violation contain sufficient information for.us to stand'by our

initial conclusion. Therefore, item A.2 remains a violation.-

With respect to item B, the inspector reviewed your response and E

also held additional discussions in a meeting with your staff on l

July 28, 1987. The additional information presented in the q

response and explanations in the meeting now shows that follow-up i

on the audit deficiency was accomplished; however, the

documentation at the time of the inspection was deficient as f3

presented. A memo (QQM-182, June 5, 1987) was written to clarify

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the resolution of the deficiency and the audit file is considered j

complete as of that date. The violation will not be withdrawn'  ;

because.the documentation to complete the audit file did'not l

exist until over a year after your staff was made aware of the- l

violation at exit meetings on May 8, 1986 and June 3, 1986. ]

4

With respect to Deviation 1, we have reviewed the new information

in a meeting on July 6, 1986. Although TU Electric staff members )

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l were advised of this deviation and acknowledged the validity of

I this finding during the inspection and at the exit meeting

(June 3, 1986) at the conclusion of the inspection, other

TU Electric staff members recently pointed out that part of the

criteria for supplemental audits was described in

Procedure DQP-VC-11, " Vendor Evaluation Methods," at the time the

inspection was conducted. Therefore, we withdraw this deviation.

With respect to Deviation 2, we have reviewed your posi; tion as

stated in.the response and as clarified in the supplemental

response and find it acceptable. However, American National

Standards Institute (ANSI) N45.2.12, Draft 3, Revision 4, 1974,

(which was issued after your commitment to ANSI N45.2.12,

Draft 3, Revision 0 dated May 2, 1973), changed the wording from

supplemental audits are performed to suppleroental audits should

be performed. The Foreword-of ANSI 45.2.12, Draft 4, Revision 2,

states that this standard does not apply to Section III of

American Society of Mechanical Engineers (ASME) Boiler and

Pressure Vessel Code. Although you deviated from your specific

commitment (an earlier version of the ANSI), the intent.of the

ANSI standard was clarified and you were in ccmpliance with the

later version. Therefore, we are withdrawingithis item as a

deviation.

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We will review your corrective actions dt2, ring a future

inspection.

Sincerely,.

~ORIGINat SIGNED DY n. F. WNM  !

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R. F. Warnick, Assistant Director

for Inspection Programs >

Comanche Peak Project Division I

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Office of Special Projects

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TU Electric 3

cc w/ enclosure:

TU Electric

ATTN: G. S. Keeley, Manager Bureau of Radiation Control

State of Texas

Nuclear Licensing 1100 West 49th Street

]

Skyway Tower Austin, Texas

400 North Olive Street, L.B.81 78756

Dallas, Texas  :

75201 Nancy H. Williams '

CYGNA Energy Services

Juanita Ellis Suite 390

President - CASE 2121 N. California Blvd i

1426 South Polk Street Walnut Creek, CA 94596

Dallas, Texas 75224 '

Renea Hicks, Esq.

Assistant Attorney General

Environmental Protection Division

P.O. Box 12548, Capitol Station

Austin, Texas 78711-2548

,

Administrative Judge Peter Bloch

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555

Elizabeth B. Johnson

Administrative Judge

Oak Ridge National Laboratory

Post Office Box X, Building 3500

l Oak Ridge, Tennessee 37830

Dr. Kenneth A. McCollom

1107 West.Knapp "

Stillwater, Oklahoma 74075

Dr. Walter H. Jordan

'

Administrative Judge

I

' 881 West Outer Drive

Oak Ridge, Tennessee 37830

Anthony Z. Roisman, Esq.

'

,

Suite 600

1401 New York Avenue, N.W.

Washington, D.C. -20005

Ms. Billie Pirner Garde, Esq.

Government Accountability Project

Midwest Office

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104 East Wisconsin Avenue

Appleton, Wisconsin 54911

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