ML20248B071
| ML20248B071 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/27/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89721, NUDOCS 8910030089 | |
| Download: ML20248B071 (6) | |
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3 Log # TXX-89721
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File # 10130 i
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IR 89-57 illELECTRIC Ref. # OCFR2.201
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- W. J. Cahill.
September 27, 1989 1
necursue vice1 resident i
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.
20555 i
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 NRC INSPECTION REPORT NO. 50-445/89-57: 50-446/89-57 RESPONSES TO THE NOTICE OF VIOLATION & THE UNRESOLVED ITEM Gentlemen:
TV Electric has reviewed the NRC's letter dated August 28, 1989, concerning the inspection conducted by Messrs. Burris, Bitter, Evans, Nelson, and Vickrey during the period July 17 through July 28, 1989. This inspection covered I
activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for.
CPSES Units 1 and 2.
Attached to the NRC's letter was a Notice of Violation (445/8957-V-01).
In addition, the NRC's letter requested that TV Electric
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respond in writing to an item involving procedure deficiencies (Unresolved
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Item 445/8957-U-02).
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TU_ Electric hereby responds to the Notice of Violation in Attachment A and to
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the Unresolved Item in Attachment B to this letter.
Sincerely, j
1 Sd*9V
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William J. Cahill, Jr.
l DAR/yxs Attachments
-c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) i
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Attachment A to TXX-89721 Page 1 of 2 1
NOTICE OF VIOLATION (445/8957-V-01)
Appendix B of 10CFR50, Criterion XVII, " Quality Assurance Records," requires, in part, that records be maintained to furnish evidence of activities affecting quality and that records shall be identifiable and retrievable.
ANSI N45.2.9-1974 Section 4.2, " Timeliness," requires a specific submittal
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plan be established between the purchaser and supplier for quality assurance
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records to assure their availability.
TU Electric implementing procedure Nuclear Engineering and Operations (NED) 2.13. " Management of Nuclear Power Plant Records," Revision 3, effective July 1,1988, paragraph 6.3.1, states that organizations who process and store documents prior to turnover and acceptance by TU Electric Records Management shall provide for the control, preservation, and safekeeping of documents as defined in the Records Management Program Manual (RMPM).
Implementing procedure NE0 2.33, " Turnover of Nuclear Power Plant Records,"
Revision.3, effective July 1, 1988, paragraph 4.6, states, in part, that Section 1 (procedures) is applicable to all NE0 organizations.
The RMPM procedure RMP-1.2.1, Revision 5. Section 4.0, effective August.3, 1988, requires that provision be made for the preservation, safekeeping, and.
Storage of documents.
1 Contrary to the above, the Instrument and Control (I&C) organization (an NE0-organization) did not provide adequate preservation, safekeeping, and storage of an extensive number (appears to be hundreds) of completed work packages that were awaiting final review for an excessive period of time (up to 2 years) ;rior to turnover and acceptance by TV Electric Records Management.
In addition, the procedures establishing the submittal plan (records turnover plan) for the Instrumentation and Control (I&C) records did not include an adequate method to ensure their timely availability to the Records Management Organization.
RESPONSE TO NOTICE OF VIOLATION (445/8957-V-01)
TV Electric accepts the alleged violation and the requested information follows:
1.
Reason for Violation i
1 The Instrument.and Control (I&C) documents which are the subject of the Notice of Violation consisted of work packages for activities such as instrument calibration checks, that had been completed in the field and were in the post work review phase (up to two years).
It is implicit in l
the procedures for the turnover of documents to Records Management that i
documents be processed and turned over in a reasonable amount of time.
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However, the records releasing organizations did not assure that records i
turnover occurred in a timely manner. Consequently, the subject I&C documents were allowed to accumulate during the post work review process.
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Attachmont A to TXX-89721 Page 2 of 2 The CPSES procedure concerning intermediate storage areas provides guidelines for the preservation and safekeeping of documents.
Although not required by ANSI-N45.2.9, these guidelines provide measures for the protection of the subject documents.
However, these guidelines were not referenced in Operations Departmental implementing procedure and were not adhered to.by personnel responsible for the documents.
2.
Corrective Steos Taken and Results Achieved The storage facilities for I&C work packages have been improved to provide acceptable protection for the subject documents.
The backlog of work packages in the post work review phase has been reduced to be in accordance with the objective identified in Section 3 below.
I The status and storage provisions for documents generated by other Nuclear 4
Operations Department record releasing organizations have also been reviewed.
As a result, changes were made in the storage provisions for documents to improve protection for the documents that satisfies the TU Electric procedural guidelines. Other backlogs of documents awaiting processing and turnover to Records Management were reduced to be in accordance with the objective identified in Section 3 below.
Due to the unique nature of construction documents, the program for control of construction documents is governed by different procedures and organizations than the Nuclear Operations Department program. TU Electric has committed that prior to fuel load, all Unit I construction documents designated to become QA records will be either turned over to TU Electric Records Management in accordance with the established procedures or will be submitted for protection, safekeeping, and retrieval in an owner controlled ANSI-N45.2.9 facility or auditable duplicate file. TU Electric Records Management is actively tracking this action and is providing periodic status reports to appropriate CPSES management.
For these reasons TV Electric does not consider that concerns described in this violation apply to Unit 1 construction documents.
3.
Corrective Steps Which Will be Taken to Avoid Further Violationt The Nuclear Operations Department-administrative procedure (s) for control of records will be revised to require that each records releasing organization designate a records coordinator whose' responsibilities include assuring adequate storage of documents per CPSES guidelines. The objective of completing the post work review process within thirty days will be proceduralized.
To provide additional assurance that work packages are processed through the post work review phase in a timely manner, the program for tracking Work Orders has been enhanced to facilitate locating and statusing Work Orders which are in the post work review phase, and to' clarify the routing i
of Work Orders that have been completed in the field.
4.
Date When Full Como11ance Will be Achieved The procedural changes will be effective by October 9, 1989.
Attachment B to TXX-89721
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Page 1 of 3 UNRESOLVED ITEM (445/8957-U-02)
During this review, the team identified 197 concerns dealing with five different areas of the procedure review. These areas are format, procedure changes, consistency, procedure references, and technical adequacy.
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majority of these items are individually minor in nature; however, due to the l
large number of items identified, the team feels that the applicant should not only correct the individual concerns, but should take a closer look at the generic implications of these concerns.
Due to the large number of items identified, some of which appear to be violations of the applicant's administrative program, the team feels that it would be best to let the applicant track and resolve each issue with a follow-up inspection to be conducted by the NRC staff at a future date:
therefore, all of the items will be tracked as an unresolved item (445/8957-U-1 02), " Procedural Problems Found during PRT Inspection".
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RESPONSE TO UNRESOLVED ITEM (445/8957-U-02)
A.
Specific Concerns Each of the 197 concerns identified in Appendix C to the Inspection Report has been evaluated by appropriate groups within Nuclear Operations.
Records of the disposition of each concern are available for NRC review.
Procedure changes resulting from this evaluation have been identified and will be issued as described in Section C below.
B.
Generic Concerns To assess the generic implications of the concerns identified in the Inspection Report, the affected organizations within Nuclear Operations generated checklists based on the NRC identified concerns and reviewed i
i samples of their procedures against the checklists. The results of these reviews are summarized below.
The details and documentation of these reviews are available for NRC review.
1.
Mechanical Maintenance l
1 All Maintenance Department Administrative Procedures (HDA's) and approximately 10% of the working level procedures (HSH's) were reviewed.
All procedures reviewed were found to be technically adequate.
The format and other administrative discrepancies which were identified will be corrected by procedure revisions or changes as stated in Section C.
2.
Instrument and Control (I&C)
All I&C administrative procedures (ICA's) and approximately 10% of the working level procedures (INC's and ICI's) were reviewed.
All procedures reviewed were found to be technically adequate.
Although the review confirmed the existence of format and other administrative concerns similar to those identified by the NRC, the procedures are considered adequate for interim use.
Attachment B to TXX-89721 Page 2 of 3 The procedure governing preparation and review of I&C procedures has been revised to address these concerns.
Currently, the I&C Department is concentrating its procedural resources on technical i
procedure changes. The procedural revision to ICA-114 will assure i
that format and other administrative concerns are addressed when the procedures are revised to incorporate accumulated changes or during the biannual review.
3.
Radiation Protection I
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All Radiation Protection administrative procedures (Rad. Prot.
STA's) and working level procedures (RPI's) were reviewed. All procedures reviewed were found to be technically adequate.
j Frocedure changes to correct format and other administrative j
discrepancies have been identified and will be issued as stated in j
Section C.
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4.
Chemistry and Environmental Approximately 15% of the Chemistry and Environmental procedures
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l (CHM's, CLI's, ENV*s) were reviewed. All procedures reviewed were 1
l found to be technically adequate.
Procedure. changes and revisions I
necessary to correct the identified format and other administrative discrepancies have been identified and will be issued as stated in Section C.
5.
Electrical Maintenance All Maintenance Department Administrative procedures (MDA's) and approximately 10% of the working level procedures (MSE's) were j
l reviewed. All procedures reviewed were found to be technically adequate. The format and other administrative discrepancies which were identified have been corrected by procedure revisions or changes.
6.
Doerations All Plant Operations administrative procedures (STA's. 0DA's) and all working level procedures (ABN's, ALM's, 50P's, IP0's, OPT's, 0WI's TDM's, TRA's. ETP's, and RWS*s) were reviewed. The majority of discrepancies identified were administrative (format, labeling, etc.) in nature.
All procedure changes and revisions resulting from the review have been identified and will be issued as stated in Section C.
7.
General All procedures under the control of the above organizations were reviewed to identify those with greater than five changes and those where procedure clarity has been compromised by changes.
These will be revised as stated in Section C.
. Attachment B to TXX-89721 Page 3 of 3 All procedures under the control of the above organizations were reviewed to determine their biannual review status. Those few.
(approximately five) that have not been reviewed within the last two years have been identified and will be reviewed as stated in Section C.
To assure the technical and administrative acceptability of new Nuclear Operations procedures and procedure reviews, elements from the checklists described in Section B above will be incorporated into departmental administrative procedures which control the preparation and review of procedures as stated in Section C.
The sample reviews described above confirmed the results of the NRC inspection (i.e., overall, the procedures are technically. adequate,-
but they contain format and administrative discrepancies). The reviews also confirmed that despite the format and administrative concerns, the procedures are usable. The change to departmental-administrative procedures will assure that any existing unidentified format or administrative discrepancies will be addressed when Nuclear Operations procedures are revised in response to accumulated procedure changes or biannual review requirements.
C.
Comoletion Schedule The Mechanical Maintenance, Radiation Protection, Chemistry and Environmental, and Electrical Maintenance procedure changes and revisions described above will be issued no later than November 1, 1989.
The I&C procedure changes and revisions described above will be issued as stated in Section B.2.
For Operations procedures necessary to support fuel load the changes and revisions described above will be issued no later than Unit I fuel load.
The remainder of the Operations procedure changes and revisions identified above will be issued no later than November 1, 1989.
The biannual review that have not been reviewed within the last years.as described in Section B.7 will be completed no later than Unit I fuel load.
Incorporation of checklist elements into the departmental administrative procedures as described in Section B.7 will be completed no later than November 1, 1989.
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