TXX-9029, Responds to NRC Re Violations Noted in Insp Repts 50-445/89-57 & 50-446/89-57.Corrective Actions:Storage Facilities for Instrumentation & Control Work Packages Improved to Provide Acceptable Protection for Documents

Responds to NRC Re Violations Noted in Insp Repts 50-445/89-57 & 50-446/89-57.Corrective Actions:Storage Facilities for Instrumentation & Control Work Packages Improved to Provide Acceptable Protection for Documents

ML20064A210
Person / Time
Site:	Comanche Peak
Issue date:	08/20/1990
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-90295, NUDOCS 9008270185
Download: ML20064A210 (4)

Text

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-lllllllllr 1llllllll Log # TXX-90295 File # 10130 L ll IR-89-57

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Ref. # 10CFR2.201 nlELECTRIC August 20, 1990

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L- U. S. Nuclear Regulatory Commission Attn: Document Control Desk

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Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK SIL6 SLECTRIC STATION (CPSES)

. DOCKET NOS. 50-445 ANu 50-446

- NRC INSPECTION REPORT NO. 50-445/89-57; 50-446/89-57

REVISED RESPONSE TO NOTICE OF VIOLATION 4 b

O Ref: 1)- TV Electric lette- logged TXX-89721 from Mr. W. J. Cahill, Jr.

to NRC, dated September 27, 1989 F 2) TU Electric letter logged TXX-89773 from Mr. W. J. Cahill, Jr.

to NRC, dated October 27, 1989 Gentlemen:

Reference 1) provided TV Electric's response to Notice of Violation 445/8957-V-01. In that response TV Electric stated that by October 9, 1989, it would revise its procedures to provide for an objective of completing the j work package post work review process within thirty dr.s. In Reference 2), TV Electric stated that the procedural revision describeo above had been completed on October 11, 1989. As a result of subsequent changes to the CPSES records management. program, the objective has been upgraded to a requirement I and the allowable post work review period has been lengthened to sixty days.

These changes, which are=in accordance with the CPSES FSAR, (Section lA(B)

Regulatory Guide 1.88) have been made to establish more definitive criteria for the post work review period while allowing sufficient time for a thorough review. TU Electric's response to the subject Notice of Violation has been revised to reflect these changes and to update the status of other actions discussed in the original response. Revision bars in right margin of the attached revised response denote the changed portions of the text.

Sincerely, ly

. William J. Cahill, Jr.

VPC/c1d Attachment c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3)

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Attach' ment to TXX-90295 .

Page liof 3 s

Notice of Violation (446/8957-V-01)

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Appendix B of 10CFR50, Criterion XVII,'" Quality Assurance Records," requires, in part, that records be maintained to furnish evidence of activities affecting quality and that records shall be identifiable and retrievable. q p

H L ANSI N45.2.9-1974, Section 4.2,. " Timeliness," requires a specific submittal

! plan be established between the purchaser and supplier for quality assurance J ll records to assure their availability. l l= 1 TU Electric implementing procedure Nuclear Engineering and Operations (NEO) l L 2.13, " Management of Nuclear Power Plant Records," Revision 3, effective July i L 1, 1988, paragraph 6.3.1, states that organizations who process and store document, prior to' turnover and acceptance by TV Electric Records Management <

shall provide for the control, preservation, and safekeeping of documents as .

defined in the Records Management Program Manual (RMPM).

Implementing procedure dE0 2.33, " Turnover of Nuclear Power Plant Records,",

, Revision 3, effective July 1, 1988, paragraph 4.6, states, in part, that-L Section 1 (procedures) is= applicable to all NE0 organizations.

The RMPM procedure RMP-1.2.1, Revision 5, Section 4.0, effective August 3, ,

L1988, requires that provision be made for the preservation, safekeeping, and storage of documents.

Contrary to the above, the Instrument and Control'(!&C) organization (an NE0 i organization) did not provide adequate preservation, safekeeping, and storage.

of an extensive number (appears to be hundreds) of completed work packages that were awaiting' final- review for an excessive periodlof time (up to 2-years) prior to turnover and acceptance by TU Electric Records Management. In addition, the procedures establishing the submittal rian (records turnover splan) for tne Instrumentation and Control (I&C) records did not include an adequate method to ensure their timely availability to the Records Management Organization. y t

Response to Notice of Violation (445/8957-V-01) r

'TU Electric accepts the alleged violation and the requested information follows. .

1. Reason for Violation The Instrument and Control (I&C) documents which are the subject of the Notice of Violation consisted of work packages for activities such as instrument calibration checks, that had been completed in the field and

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- were.in the post work review phase (up to two years). It is implicit in' the procedures'for the turnover of documents to Records Management that'

- documents be processed and turned over in a reasonable amount of time.

i However, the records releasing organizations did not assure that records 2

turnover occurred in a timely manner.. Consequently, the subject I&C documents were allowed to accumulate during the post work review process.

The CPSES procedure concerning intermediate storage areas provides  !

. guidelines for the preservation and safekeeping of documente. Although- .

not' required by-ANSI-N45.2.9, these guidelines provide measures for the- (

protection of the subject documents.- However. these guidelines were not L referenced in Operations Departmental implementing procedure and were not t adhered to by personnel responsible for the documents.

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2. Corrective Steos Taken and Results Achieved

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The storage facilities for I&C work packages have been improved to provide acceptable protection for the subject documents. The backlog of work packages in the post work review phase has been reduced to be in accordance with the requirement identified in Section 3 below. l The status and storage provisions for documents genereted by other Nuclear Operations Department record releasing orcmizations have also been

, reviewed. As a result, changes were made in the storage provisions-for documents to improve protection for the documecte t.at satisfies the TU i Electric procedural. guidelines. Other backlogs of documents awaiting processing and turnover to Records Management have been reduced to be in accordance with the requirement identified in Section 3 below. ,

Due-to the _ unique nature of construction documents, tiie program for

. control of, construction documents.was governed by differ 2nt procedures.and organizations than the Nuclear Operations Department program. Prior to fuel load, all Unit I construction documents designated to become OA records were either turned over to TU Electric Records Management in p~ accordance with the established procedures or were submitted for protection, safekeeping, and retrieval in an owner controlled ANSI-N45.2.9 facility or auditable duplicate file. For these reasons TU Electric does ,

not consider thattconcerns described in this violation-apply to Unit 1 '

construction documents.

3 .- Corrective Steos Which Will be Taken to Avoid Further Violations

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The_ Nuclear Operations Department administrative procedure (s) for control of? records _has been revised to rtquire that each records releasing. l .

organization de:ignate a records coordinator whose responsibilities '

include' assuring adequate storage of documents per CPSES guidelines. A .'

requirement to complete the post work review process within sixty days has been proceduralized.

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3 . Attachment to!.TXX-90295 Th J:,. i Page.3;of.3c j, c i- '

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c  ; n, 3 To provide additional assurance that work packages are processed ~through ithe post work review phase in a timely manner the. program for tracking

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> Work Ordersihas been enhanced tosfacilitate locating and statur.ing Work 1 Orders which are in the post work review. phase, and to clarify lthe routing g of Work _ Orders that'have-been completed in-the field. .,

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Full; compliance has.been. achieved.

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