TXX-6134, Responds to NRC 861117 Request for Addl Info on Violation & Deviation Noted in Insp Repts 50-445/85-18 & 50-446/85-15. Corrective actions:CP-QP-2.1 Revised to Eliminate Need for Min OJT & OJT Waivers & Verification Package Reinspected
| ML20212E725 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/12/1986 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| TXX-6134, NUDOCS 8701050418 | |
| Download: ML20212E725 (5) | |
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Log # TXX-6134 File # 10130 L'
IR 85-18 TEXAS UTILITIES GENERATING COMPANY 85-15 SKYWAY TOWER 400 NORTH OLIVE 5'REET. LB. 81. DAILAR. TEXAS 75351 December 12, 1986 E'2*"Lf?Eli 3@@gg i
Mr. Eric H. Johnson, Director Division of Reactor Safety and Projects DEC i 9m U. S. Nuclear Regulatory Commission i
i 611 Ryan Plaza Drive, Suite 1000 L
LS Arlington, TX 76011
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
[
DOCKET NOS. 50-445 AND 50-446 l
INSPECTION REPORT NOS.: 50-445/85-18 AND 50-446/85-15 t
SUPPLEMENTAL RESPONSE TO NRC NOTICE OF VIOLATION (NOV)
ITEM A AND NOTICE OF DEVIATION (N0D) ITEM C REF:
TUGC0 Letter TXX-4848 from W. G. Counsil to E. H. Johnson dated July 9, 1986
Dear Mr. Johnson:
We have reviewed your letter dated November 17, 1986, requesting additional information on Inspection Report Nos. 50-445/85-18 and 50-446/85-15 NOV Item A and N0D Item C.
We hereby respond to the request for supplemental information in the attachment to this letter.
We requested and received an extension until December 12, 1986 in providing our response during a telephone conversation with Mr. T. F. Westerman on December 8, 1986.
Very truly yours, M
W. G. Counsil RSB/amb Attachment c - NRC Region IV (0 + 1 copy)
Director, Inspection & Enforcement (15 copies)
U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Mr. V. S. Noonan Mr. D. L. Kelley gOh t
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$1 i Attachment to TXX-6134 December 12, 1986 Page 1 of 4 NOTICE OF VIOLATION ITER A (445/8518-V-03 AND 446/8515-V-02)
SUPPLEMENTAL REQUEST FOR INFORMATION Specifically, the 0JT waivers for the inspectors' certifications referenced in i
NOV, Item A, were provided on the basis of "..
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 0JT and previous related inspection activity...." The terminology used on the cited waivers,
" previous related inspection activity," does not comply with the criteria contained in Procedure CP-QP-2.1, Revision 18, for assuring " comparable" or
" equivalent" competence to that gained from the waived 0JT; i.e., paragraph 3.8 requires documented assurance of previously certified experience in either the waived activity or in procedures (as specified on the waiver) of sufficiently similar activity. Accordingly, provide those actions planned or taken to assure correction of the referenced inspector certifications and any other waivers granted on like bases. We have no further questions concerning 2
your action to prevent recurrence.
SUPPLEMENTAL RESPONSE TO ITEM A DISCUSSION:
We continue to disagree that this is a violation.
Paragraph 3.8 of CP-QP-2.1 Rev. 18 states, a waiver of 0JT must be documented on a waiver form to provide assurance that the individual does have comparable or equivalent competence to that which would have beon gained from the OJT. The paragraph offers examples of the basis upon which a waiver of OJT may be granted. Apparently, the examples were considered by the NRC Inspector to be the only allowable basis for waiving 0JT.
The sole purpose of 0JT is to prepare an individual to successfully complete a L-III proficiency demonstration.
Paragraph 3.8 establishes the following parameters regarding 0JT:
1.
OJT is reduced on a case-by-case basis.
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Waivers are documented on a waiver form to provide assurance 2.
that the individual's competence is not diminished by reduced or waived 0JT.
3.
Waivers are approved by the Certifying Authority.
In all cases, the conditions identified above were met as evidenced by the L-III proficiency demonstration and Certifying Authority signatures.
4. Attachment to TXX-6134 December 12, 1986 Page 2 of 4 Each inspector who was granted an 0JT waiver per paragraph 3.8 of CP-QP-2.1 Rev.18 was also given and successfully passed a L-III proficiency demonstration prior to the waiver being approved by the L-III Quality Engineer. This demonstrated that the individual had the actual competence (not merely " comparable" or " equivalent") required to perform the task.
If an individual is able to demonstrate proficiency with less than the required amount of 0JT, then a waiver of any or all of the 0JT is appropriate.
In light of a passed proficiency demonstration, the individuals that received 0JT waivers do not require additional 0JT. The waiver form is simply used to explain why less than full 0JT was received. The waiver forms in question used words like "related" inspection activity rather than " equivalent" or
" comparable" inspection activity to justify the issuance of the waiver. This difference in terminology does not render these waivers unacceptable.
ACTIONS TAKEN:
CP-QP-2.1 has been revised to eliminate the need for minimum 0JT and 0JT waivers to avoid further misunderstanding of their intent or use. Corrections to any individual file is not required because the basis for certification is sound, fully documented and supported by written and proficiency examinations.
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Attachment to TXX-6134 l'
I
- Decemb2r 12, 1986 f-Page 3 of 4 NOTICE OF DEVIATION ITEM C (445/8518-D-04)
SUPPLEMENTAL REQUEST FOR INFORMATION With respect to your response to N00, Item C, you have failed to provide the reasons for:
(1) the QA/QC discipline engineer incorrectly indicating "N/A" for an applicable checklist attribute, and (2) his failure to provide the required justification for the "N/A" entry.
SUPPLEMENTAL RESPONSE TO ITEM C 1.
Reason for Deviation:
The reason for the deviation is engineering error. The ERC QA/QC discipline engineer inadvertently indicated "N/A - Component Not Shown On Isometric", for subattribute 1.1 - Mechanical Joint Location, in Verification Package No. I-M-SBCO-022, when in fact four bolted flanges did appear on the drawing and should have been inspected under this subattribute for dimensional location.
The ERC QA/QC discipline engineer did, however, provide the required justification for the "N/A" entry as described above.
2.
Corrective Action Taken:
Verification Package No. I-M-SBCO-022 was reinspected on February 6, 1986, for dimensional location o'f the four bolted flanges. The flange locations were found to be within allowable tolerances as specified in QI-026.
3.
Action to Prevent Recurrence:
The QA/QC discipline engineers were reminded to be more thorough when completing inspection checklists. Additionally, ERC inspectors were instructed by a May 28, 1986, memorandum to correct checklists when errors are found or return the list to the engineers for correction.
ERC final documentation review is required to verify that all "N/A" entries adjacent to attributes and subattributes are justified with an explanation.
ERC Engineering is performing a thorough review of SBC0 and LBC0 population attributes and subattributes which have been designated "N/A - Component Not Shown on Isometric". This review includes reading the applicable drawings to ascertain the validity of the attributes and subattributes marked "N/A" and the corresponding justification.
'[',+AttachmenttoTXX-6134 December 12, 1986 Page 4 of 4 Additionally, the overview inspection group reviewed packages selected for overview for completeness and accuracy.
If Package No.
I-M-SBC0-022 had been selected for overview, this error would likely have been detected by the overview inspector.
It should be noted that the inadvertent error, if undetected, would not have affected the sample reinspection conclusions.
Failure to include the attribute on this sample would not reduce the number of attributes below the required 60, since the attribute would be picked up on another sample, 4.
Date of Full Compliance:
Verification Package No. I-M-SBC0-022 was reinspected on February 6, 1986.
Final review of the SBC0 and LBC0 population working files should be completed by February,1987. The overview inspection program has been completed.
Inspection activities for the SBC0 population are complete and a sufficient quantity of samples for each attribute were obtained.
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