TXX-4679, Suppls Response to Violations Noted in Insp Rept 50-445/85-11.Corrective Actions:Qc Programmatic Controls Formalized to Document out-of-scope Observations

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Suppls Response to Violations Noted in Insp Rept 50-445/85-11.Corrective Actions:Qc Programmatic Controls Formalized to Document out-of-scope Observations
ML20140F051
Person / Time
Site: Comanche Peak Luminant icon.png
Issue date: 02/13/1986
From: Counsil W
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To: Johnson E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20140F030 List:
References
TXX-4679, NUDOCS 8603280344
Download: ML20140F051 (2)


Text

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e Log # TXX-4679

. File # 10130 TEXAS UTILITIES GENERATING COMPANY IR 85-11 SKYW AY TOWER e 400 NORTH UIJVE KFEEET, L.B. N B e DAILAN. TEXAh 78305 February 13, 1986 OUANEAS

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! zMr.;Eric;H. Johnson, Acting Director

" Division of-Reactor. Safety and Projects 2

U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) l DOCKET NO. 50-445 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT N0.: 50-445/85-11 l

Dear Mr. Johnson:

The attachment to this letter supplements and clarifies our response to

. Notice of Violation 50-445/85-11. Please consider this information in your evaluation of our response.

j Very truly yours,

, f%

W. F. Counsil JWA/ arm 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 Mr. D. L. Kelley hb DO G

[-QD N A DIVISION OF TEXAN UTil2 TIE!i ELECTNIC COMPANY

< * . e Attachment Supplemental Response to Notice of Violation -

50-445/85-11 Reason For Violation In our January 9, 1986, Supplemental Response on this issue we stated that "The TUGC0 QC Inspector involved with this issue made notes of the observations identified on August 6-7, 1985 with the intention of documenting these observations on an NCR form." The above sentence should be revised to read "The TUGC0 QC Inspector involved with this issue noted the observations identified..."

The incorrect statement in our January 9 response was the consequence of a misunderstanding between the involved inspector and the supervisor who l wrote the response. The inspector recalls observing the nonconforming con-ditions identified by the NRC inspector, mentally noting the conditions, and stating to the NRC inspector that he intended to initiate an NCR on the matter; however, the inspector does not have physical notes at this time and does not remembsr whether he made such physical notes. The inspector's failure to immediately initiate an NCR on the matter was an oversight on his part and his reassignment to other inspection duties contributed to his continuing to forget to initiate an NCR.

Discussion of Programmatic Implications In our January 9, 1986, Supplemental Response on the issue we described how out-of-scope. observations are documented by ERC inspectors and forwarded to TUGC0 QC for review and resolution for possible issuance'of an NCR. Those processes were formalized before the conclusion of the NRC inspection by the issuance of Procedure CPP-020, "Out-of-Scope Observations," Revision 0 on August 23, 1985, and Procedure CP-QP-16.3, " Processing CPRT Deviation Reports /0bservation Notices," Revision 1 on August 26, 1985.

We continue to believe that the failure of the QC inspector to initiate an '

NCR represents'an isolated case. That inspector has been counseled on this matter. Additionally, the formalization of our programmatic controls as described above should help preclude the recurrence of such events.

Furthermore, ERC inspectors have been required to read CPP-020 and QC inspectors have been reminded of the provisions of CP-QC-16.0, titled "Noncoeformances."

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