ML20235B944
| 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:
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Dockets: 50-445/86-08
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50-446/86-06
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TU Electric
ATTN:
Mr. W. G. Counsil
Executive Vice President
{
400 North Olive, Lock Box 81
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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.
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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
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also held additional discussions in a meeting with your staff on
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July 28, 1987.
The additional information presented in the
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response and explanations in the meeting now shows that follow-up
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on the audit deficiency was accomplished; however, the
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documentation at the time of the inspection was deficient as
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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
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complete as of that date.
The violation will not be withdrawn'
because.the documentation to complete the audit file did'not
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exist until over a year after your staff was made aware of the-
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violation at exit meetings on May 8, 1986 and June 3, 1986.
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With respect to Deviation 1, we have reviewed the new information
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in a meeting on July 6, 1986.
Although TU Electric staff members
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TU Electric
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were advised of this deviation and acknowledged the validity of
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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.
,
,
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
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Comanche Peak Project Division
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Office of Special Projects
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See next page.
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TU Electric
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cc w/ enclosure:
TU Electric
Bureau of Radiation Control
ATTN:
G. S. Keeley, Manager
State of Texas
]
Nuclear Licensing
1100 West 49th Street
Skyway Tower
78756
400 North Olive Street, L.B.81
Dallas, Texas
75201
Nancy H. Williams
'
CYGNA Energy Services
Juanita Ellis
Suite 390
President - CASE
2121 N. California Blvd
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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
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
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Oak Ridge, Tennessee
37830
Dr. Kenneth A. McCollom
1107 West.Knapp
"
Stillwater, Oklahoma
74075
Dr. Walter H. Jordan
Administrative Judge
'
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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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