TXX-4619, Responds to NRC Re Violations Noted in Insp Rept 50-445/85-11.Corrective Actions:Inspector Instructed to Document Deviations in Accordance w/CP-QP-16.0 in Prompt Manner

Responds to NRC Re Violations Noted in Insp Rept 50-445/85-11.Corrective Actions:Inspector Instructed to Document Deviations in Accordance w/CP-QP-16.0 in Prompt Manner

ML20151L774
Person / Time
Site:	Comanche Peak
Issue date:	11/11/1985
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20151L767	List: ML20151L763 TXX-4619, Responds to NRC Re Violations Noted in Insp Rept 50-445/85-11.Corrective Actions:Inspector Instructed to Document Deviations in Accordance w/CP-QP-16.0 in Prompt Manner
References
TXX-4619, NUDOCS 8601020384
Download: ML20151L774 (2)

Text

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Log # TXX-4619 TEXAS UTILITIES GENERATING COMPANY File # 10130 SKYWAY TDWER 4e0 ImmTH OUVM STREET t B. 51

• DA1.us. TEXAN Mao. IR 85-11 Nov~ ember 11, 1985 wkuAu o coum Mr. R. P. Denise Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission NOV201985 .

Region IV '

611 Ryan Plaza Drive, Suite 1000 ~ ~

Arlington, Texas 76012

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT N0.: 50-445/85-11

Dear'Mr. Denise:

We have reviewed your letter dated October 11, 1985 concerning the inspection conducted by Mr. T. F. Westerman and other members of the Region IV Comanche Peak Group during the period June 22 - August 31, 1935. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak Units I and 2.

We have responded to the Notice of Violation in the attachment to this

' letter. To aid in the understanding of our response, we have repeated the Notice of Violation followed by the response. -We consider the enclosed information to be responsive to the Inspectors' findings.

With regard to Appendix B (Notice of Deviation) of your letter, we are-currently investigating these findings. The progress made to date has not been sufficient to provide an adequate response and to properly address the additional questions contained in the fourth paragraph of your letter. The response to the Notice of Deviation is scheduled to be submitted by December 11, 1985.

Very truly yours,

/W. G. Counsil JWA/grr Attachment c- Region IV (Original + 1 copy)

Director, Inspection and Enforcement (15 copies)

U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. V. S. Noonan .i

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Mr. D. L. Kelley 8601020384 e51219 PDR ADOCM 05000445 g PDR

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, t .o ATTACIIMENT FAILURE TO REPORT NONCONFORMING CONDITIONS IN A PROMPT MANNER Failure to Report Nonconforming Conditions in a Prompt Manner:

Criterion XVI of Appendix B to 10 CFR Part 50 states, in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. . .".

Paragraph 3.1.1 of Procedure CP-QP-16.0, Revision 17, dated July 1,1985, states,

-in part, "When a nonconforming condition is identified, the individual shall immediately apply a IIold Tag, when practical. . . .". Paragraph 3.1.2 of this procedure states, in part, " Nonconforming conditions shall be reported on the NCR form . . . .".

Contrary to the above, during a NRC witnessed reinspection on August 6-7, 1985, of essential lighting system ESB1-42 (Unit 1, safeguards building, elevation 773 ft.) by an Evaluation Research Corporation (ERC) inspector and a TUGCO QC inspector, nonconforming hardware items were identified with respect to design document requirements. The. identified nonconforming items were outside of the defined ERC reinspection activity scope and the TUGCO inspector stated that they would be documented on a NCR form. As of August 29,1985, a NCR had not been written, a hold tag had not been applied and NRC followup established that a documented record of the nonconforming items had not been maintained.

This is a Severity Level IV violation (Supplement II) (445/8511-V-01).

Corrective Steps which have been taken and the results achieved:

The Inspector involved has been instructed to document deviations from site procedurcs and design requirements in accordance with C P-Q P-16.0 "Nonconformances", in a prompt, expeditious manner. The Inspector was further advised that should future instance of work load prohibit timely reporting, his immediate supervisor should be notified for initiation of appropriate action.

NCR # E-85-100993x has been initiated (8/30/85) to resolve the deficiencies identified during ERC reinspections conducted on August 6-7, 1985 Corrective Steps which have been taken to preclude repetition:

To preclude further problems of this nature, Inspectors have been assigned to support the CPRT Program on a permanent, full-time basis.

Date when full compliance was achieved:

Personnel assignments were effective on 9/2/85.