TXX-3658, Responds to NRC Re Violations Noted in IE Insp Repts 50-445/83-03 & 50-446/83-01.Corrective Actions:Light Poles Will Be Inspected & Items Designated non-nuclear safety-related Reviewed & Upgraded
| ML20023D366 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/25/1983 |
| From: | Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Madsen NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20023D364 | List: |
| References | |
| TXX-3658, NUDOCS 8305200419 | |
| Download: ML20023D366 (3) | |
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-I April 25, 1983 TXX-3658 Mr. G. L. Madsen, Chief Reactor Project Branch 1 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Docket Nos.:
50-445 Arlington, Texas 76012 50-446 COMANCHE PEAK STEAM ELECTRIC STATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NO. 83-03/01 FILE NO.:
10130
Dear Mr. Madsen:
We have reviewed your letter dated March 28, 1983 on the inspection conducted by your Senior Resident Reactor Inspector, Mr. R. G. Taylor, of activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak, Units 1 and 2.
We have responded to the finding listed in Appendix A of that letter.
To aid in the understanding of our response, we have repeated the requirement and your finding followed by our corrective action. We feel the enclosed information to be respcnsive to the Inspector's finding.
If you have any questions, please advise.
Very truly yours, RJG:aq Enclosures cc: NRC Region IV - (0 + 1 copy)
Director, Inspection & Enforcement (15 copies)
U. S. Nuclear Regulatory Commission Washington, DC 20555 8305200419 830518 PDR ADOCK 05000445 0
TXX-3658 April 25 1983 0
APPENDIX A NOTICE OF VIOLATION Texas Utilities Generating Company Docket: 50-445/83-03 Comanche Peak Steam Electric Station 50-446/83-01 Permits: CPPR-126 CPPR-127 Based on the results of an NRC inspection conducted during the period of October 1982 through February 1983, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 47 FR 9987, dated March 9, 1982, the following violation was identified:
Failure to Implement a Quality Assurance Program for the Fabrication and Installatb. of Electrical Underwater Floodlight Pole Assemblies Criterion II of Appendix B to 10 CFR 50 requires that the applicant shall identify the structures, systems, and components to be covered by the quality assurance program and that the program shall provide control over activities affecting quality of the identified structures, systems and components.
FSAR Section IA(b) commits the applicant to compliance with NRC Regulatory Guide 1.29 which in paragraphs 2 and 4 require the applicant to identify those structures, systems, and components whose continued function is not required (in a design basis accident) but whose failure could reduce the functioning of any plant feature identified in other paragraphs to an unacceptable level.
Contrary to the above, the Senior Resident Inspector-Construction has determined from investigation of allegations, observation of construction activities and review of design drawings that group of devices collectively identified as " Electrical Underwater Floodlighting Poles" (Drawing 2323-EL-0925-02) were not identified as required by l
Regulatory Guide 1.29 and were not included within the licensee's Quality Assurance Program. Mechanical failure of the devices in a seismic event could damage fuel during reactor core installation activities or in the spent fuel storage pools, although the possibility i
l of such mechanical failure of the pole assembly resulting in damaging fuel is very remote due to the design of upper and lower pole retention devices.
This is a Severity Level V Violation.
(Supplement II.D.)
l CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The drawing governing installation of the light poles has been changed via Design Change Authorization to reflect Seismic Category II requirements. This l
TXX-3658 April 25,1983 change causes the light poles to be inspected in accordance with the CPSES QA Program. Any discrepancies discovered have been or will be documented and resolved in accordance with established procedures.
CORRECTIVE STEPS WHICH HAVE BEEN OR WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Items designated "Non-Nuclear Safety Related" have been previously reviewed for applicable Seismic Category II requirements and upgraded as needed.
Considering the scope of the evaluation and subsequent results, adequate confidence has been established that appropriate QA Program controls are in effect.
DATE OF FULL COMPLIANCE The required drawing change was accomplished on February 4,1983.
Inspection activities are on-going and will be completed and resolved consistent with the project schedule.
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