TXX-4435, Responds to NRC Re Violations Noted in Insp Repts 50-445/84-32 & 50-446/84-11.Corrective Actions:Procedure Revised Deleting Requirement for 8-h Training Course in Eddy Current Testing

Responds to NRC Re Violations Noted in Insp Repts 50-445/84-32 & 50-446/84-11.Corrective Actions:Procedure Revised Deleting Requirement for 8-h Training Course in Eddy Current Testing

ML20126J025
Person / Time
Site:	Comanche Peak
Issue date:	03/11/1985
From:	Clements B TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20126J029	List: ML20128N340 TXX-4435, Responds to NRC Re Violations Noted in Insp Repts 50-445/84-32 & 50-446/84-11.Corrective Actions:Procedure Revised Deleting Requirement for 8-h Training Course in Eddy Current Testing
References
TXX-4435, NUDOCS 8506180501
Download: ML20126J025 (3)

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.... EPJ.M}J.".L"L*. ... March 11, 1985 TXX-4435 Darwin R. Hunter, Chief Reactor Project Branch 2 U.S. Nuclear Regulatory Commission Office of Inspection & Enforcement 611 Ryan Plaza Drive, Suite 1000 Docket Nos.: 50-445 Arlington, TX 76011 50-446 COMANCHE PEAK STEAM ELECTRIC STATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 84-32 FILE NO.: 10130

Dear Mr. Hunter:

We have reviewed your letter dated February 15, 1985 regarding the inspection conducted under the Resident Inspection Program by H.S. Phillips of activities authorized by NRC Construction Permit CPPR-125 for Comancne Peak Units 1 and 2.

Our review of the findings cited in the Notice of Violation under Appendix A to your letter indicates that two of the findings are similiar in nature to those identified by the NRC Technical Review Team (TRT). In accordance with one of your proposed response options, we have elected to respond to findings 1 ar.d 2 of the Notice of Violation as part of the Comanche Peak Response Tecm Action Plan.

We are providing a response to Finding No. 3 in Appendix A of your letter. To aid in the understanding of our response, we have repeated the finding from the Notice of Violation followed by a summary of our corrective actions. The documentation of specific corrective actions is available at the TUGCo 0A Dallas office for your Inspector's review.

If you have any questions, please advise.

Very truly yours, L ? O ). /

F.R.Clements B

BRC:tig Attachment A DivissirDN EDF TEXAS E*TELETEEN ELECTRIC COMPANT 8506180501 850529 PDR ADOCK 05000445 C PDR

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NRC Region IV (0 + 1 copy)

U.S. Nuclear Regulatory CommissionDirector, inspection &

Washington, DC 20555 Mr. V.S. Noonan /

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TXX-4435 3/11/85 Page 2 ATTACHMENT FAILURE TO PROPERLY CERTIFY A VENDOR COMPLIANCE INSPECTOR Failure to Properly Certify a Vendor Comoliance Inspector Criterion V of 10 CFR 50, Appendix B, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances.and shall be accomplished in accordance with these instructions, procedures, or drawings."

TUGC0 Procedure DQP-VC-4, Revision 6, dated January 5, 1984, requires that Level l

II inspectors (Corporate QA) shall attend and satisfactorily complete nonde-structive testing courses including eddy current testing.

1 Contrary to the above, one of six inspector's files had no documentation to show that the inspector had attended and completed an eddy current testing course.

Subseauent, discussions-revealed that he had been certified without meeting this requirement. The vendor compliance supervisor stated that this inspection skill is not needed since there is no present vendor work activity which would require this skill; therefore, this procedure was revised and the re,autrement omitted during this inspection.

This is a Severity Level V Violation. (Supplement II) (445/8432-05; 446/8411-05)

Corrective Steps which have been taken-and the results achieved:

The certification of the inspector without the required eight (8) hour training was an oversight. A review of all six (6) Vendor Compliance Inspector's work reflected no instance where eddy current testing was involved. Tne procedure revision discussed below was processed to reflect our actual inspection needs.

Corrective steos which have been taken to avoid further violations:

As there is no present nor planned vendor work activity which would require this skill, TUGCo Procedure DQP-VC-4 has been revised by deleting the requirement for an eight (8) hour training course in eddy current testing. Should the need for a familiarity with eddy current testing arise, the Vendor Compliance Supervisor will take the necessary action to either train or obtain a qualified inspector.

Date when full compliance will be achieved:

Procedure DQP-VC-4 was revised August 27, 1984.

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