ML20246P340
| ML20246P340 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/21/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89149, NUDOCS 8903280199 | |
| Download: ML20246P340 (3) | |
Text
~
.y
~
i mammmmmmum
==
F7 Log # 'TXX-89149
.-~
Fi1e 10130
._.r r
IR 89-03 Ref.
10CFR2.201 7UELECTRIC March 21, 1989 W. J. Cahill L,ecunve Mce President U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.
20555 l
l
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT NOS.
50-445/89-03 AND 50-446/88-78 i
Gentlemen:
1 TV. Electric has reviewed your letter dated February 22, 1989, concerning the inspection conducted by Mr. C. J. Hale and an NRC consultant during the period January 11 through February 7,1989.
This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 l
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.
i l
Sincerely, i
William J. Cahill, Jr.
BSD/bsd Attachment c - Mr R. D. Martin, Region IV Resident Inspectors, CPSES (3)
I l
8903280199 890321 PDR ADOCK 05000445 Q
PDC f
400 North Olive Street LB 81 Dallas, Texas 75201 l
's Attachment to TXX-89149 March 21, 1989 Page 1 of 2 NOTICE OF VIOLATION i
(445/8903-V-04; 446/8903-V-03) i Paragraph 50.55(e)(1) of 10CFR Part 50 states, in part, "If the permit is for construction of a nuclear power plant, the holder of the permit shall notify the Commission of each deficiency found in design and construction, which, were it to have remained uncorrected, could have affected adversely the safety of operation...at any time throughout the expected lifetime of the plant...."
To assure such deficiencies are evaluated for deportability, the applicant implemented Procedure NE0 9.01, " Evaluation and Reporting of Adverse Conditions Under 10 CFR 21 and 10 CFR 50.55(e)" which states in paragraph 6.1.2, "All TV Electric organizations under the EVP, NEO (Executive Vice l
President, Nuclear Engineering and Operations) shall develop lower-level implementing procedures, as required, to evaluate Adverse Conditions for deportability." Adverse conditions are defined to include such terms as deficiency, defect, and deviation.
Contrary to the above, Procedure AAP-16.1, " Controlling Nonconforming Items,"
i Revision 5, authorizes the use of "Unsat Inspection Reports" for documenting l
and correction of certain deficiencies; however, this procedure does not l
direct the required evaluation for deportability be performed nor is there evidence that such evaluations have been or will be performed.
4 l
RESPONSE TO NOTICE OF VIOLATION (445/8903-V-04;446/8903-V-03)
We admit the violation and the requested information follows.
1.
Reason for the Violation Brown & Root (B&R) procedure AAP-16.1, " Controlling Nonconforming Items,"
did not provide sufficient direction to assure that deficiencies documented on "Unsat inspection Reports" (Unsat irs), which were initiated outside of the scope of planned inspection activities, were reviewed for deportability in accordance with site procedure NE0 9.01, " Evaluation and Reporting of Adverse Conditions Under 10 CFR 21 and 10 CFR 50.55(e)."
2.
Corrective Steps Taken and Results Achieved Deficiency report (DR) C-89-00323 was initiated to identify and correct the above procedural deficiency and to obtain deportability review of those Unsat irs initiated to document deficiencies outside the scope of l
planned inspections.
', o
'l f
' Attachment ti TXX-89149 March 21, 1989 Page 2 of 2 3,
Corrective Steps Which Will-be Taken to Avoid Further Violations B&R procedure AAP-16.1'will be revised to require that nonconformance.
reports -(NCRs).be' initiated, per NE0 3.05 " Reporting and Control.of Nonconformances," for deficiencies identified which are not within the scope of planned inspections.
NE0 3.05 requires that.NCRs be evaluated j
for' deportability per NE0 9.01.
In-addition, site procedures'which.
contain nonconformance identification methods will be reviewed-to assure compliance with the deportability" evaluation requirements of NE0'9.01.
4.
Date of Full Compliance The revision of B&R procedure AAP-16.1'will be complete and implemented by March 31, 1989.
The review of Unsat irs described in Item 2 will'be complete by April'28,.
1989.
The review of site procedures described in Item 3 will be complete by--
April 7, 1989.
l l
l l
l
_ _ _ _ _ _ - - _ _ _ - -