TXX-8913, Responds to NRC Re Violations Noted in Insp. Corrective Action:Renewal of CPs Added to Licensing Milestone Tracking Sys

Responds to NRC Re Violations Noted in Insp. Corrective Action:Renewal of CPs Added to Licensing Milestone Tracking Sys

ML20248G840
Person / Time
Site:	Comanche Peak
Issue date:	03/30/1989
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
EA-88-278, TXX-89137, NUDOCS 8904130597
Download: ML20248G840 (3)

Text

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Log # TXX-89137 ,

_""" "C File # 10118

= C. EA 88-278 - .;

Ref. # 10CFR2.201 j 7t/ ELECTRIC l

w.J.c.bm March 30, 1989 Execunvr Yke President

~ U. S. Nuclear Regulatory Commission

. Attn: Document Control Desk Washington, D. C. 20555 niBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NO. 50-445 REPLY TO NOTICE OF VIOLATION EA 88-278 CONSTRUCTION PERMIT LAPSE REF: TV Electric letter TXX-4680 dated January 29, 1986 Gentlemen:

We have reviewed your letter dated February 28, 1989. We hereby respond to the Notice of Violation in the attachment to this letter.

Sincerely,

+$ M William J. Cahill, . Jr. l BSD/bsd Attachment c - Mr. R. D. Martin, Region IV i Resident Inspectors, CPSES (3)  !

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/pl I 400 North Olive Street LB 81 Dallas, Texas 75201 (  :

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i Attachment to TXX-89137 March 30, 1989 Page 1 of 2 NOTICE OF VIOLATION i EA 88-278 l 10CFR50.10(b) states that no person shall begin the construction of a production or utilization facility on a site on which the facility is to be operated until a construction permit has been issued.  ;

10CFR50.55(b) states that if construction of a facility is not completed by the latest completion date, the permit shall expire and all rights thereunder shall be forfeited.

10CFR2.109 provides that if a timely application is made at least thirty days prior to the expiration date, the existing license will be deemed not to have expired.

Contrary to the above, Construction Permit CP'R-126 expired on August 1, 1985 and although the applicant failed to file a cimely request for extension as provided by 10CFR2.109, activities at Unit 1 for which a construction permit is required continued until at least January 29, 1986, at which time the ap nicant filed for an extension. The extension was approved by the staff on Fe)ruary 10, 1986.

RESPONSE TO NOTICE OF VIOLATION EA 88-278 1

1. Response to the Notice of Violation i

TV Electric admits the violation.

2. Reason for Violation As TV explained at the time it filed for an extension of the Construction Permit, and as noted by the NRC in its transmittal letter of February 28, 1989, the inadvertent failure to file for an extension occurred at a time when TV Electric was involved in the development of extensive corrective action programs which had not been fully implemented at the time the application for an extension of the Construction Permit was dte to be filed. In addition, at the same time TV Electric was involved in the restructuring of its management organization including personnel changes and changes in responsibilities of persons in all facets of the organization. Although TV Electric made a concerted and successful effort to track technical commitments and issues, licensing issues were tracked separately and the extension o' the construction permit was overlooked.

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' Attachment.to TXX-89137-March 30,-1989 Page 2 of 2

3. Corrective Steps Taken and Results Achieved The renewal of. Construction Permits'was added to the licensing milestone tracking system. The status of all licenses and permits (including Construction Permits) are tracked internally and reported to upper-4 management on an, annual basis. .In addition, a tickler system has been.

established'to. ensure that responsible organizations are. notified in writing before renewal dates su as to assure no renewal date is missed.

As noted in the NRC's transmittal letter,' the various corrective action programs in management implemented policies by'and procedures."TU Electric "resulted in considerab

4. Corrective Steps Which Will be Taken to Avoid Further Violations TV Electric will maintain a licensing action tracking system which will preclude recurrence of this problem in the; future.

5. .Date When Full Compliance Will be Achieved s Action has beenscompleted. TV Electric letter, TXX-4680 of January 29,: 1986, was the application for extension of.the lapsed permit.

Extension on.the Unit 2 license was requested in accordance with-10CFR2.109 and granted. Subsequently extensions on both' unit construction permits and Special Nuclear Material Licenses have been requested on time and: granted.

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