ML20140F027

Ack Receipt of 851111,1217,860109,15 & 0213 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/85-11 & 50-446/86-06.Corrective Actions Will Be Inspected During Future Insp

ML20140F027
Person / Time
Site:	Comanche Peak
Issue date:	03/12/1986
From:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML20140F030	List: ML20140F027 TXX-4653, Advises That Response to Findings Noted in Insp 50-445/85-11 Delayed Due to Planning & Participation in NRC Audits of Design Adequacy & Quality of Const Areas.Response Will Not Be Submitted Until 860115 TXX-4666, Responds to Request for Addl Info Re Response to Notice of Violation from Insp 50-445/85-11.Nonconforming Condition Outside Scope of Assigned Insp Will Be Noted by ERC Inspectors as out-of-scope Observation TXX-4667, Responds to Violations Noted in Insp Rept 50-445/85-11. Corrective Actions:Procedure CPP-001 Revised to Eliminate Need to Put in Side Bars Where Extensive Procedural Revs Made 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
References
NUDOCS 8603280332
Download: ML20140F027 (2)

See also: IR 05000446/1986006

Text

.. . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _

'4 *

In Reply Refer To: MAR 12 W

Dockets: 50-445/85-11

50-446/86-06

Texas Utilities Generating Company

ATTN: Mr. W. G. Counsil

Executive Vice President

400 North Olive, L.B. 81

Dallas, Texas 75201

Gentlemen:

Thank you for our letters dated November 11, 1985, December 17, 1985, January 9,

1986, January 15, 1986, and February 13, 1986, in response to our letters dated

October 11, 1985, and December 19, 1985. As a result of our review, we have

no further questions regarding your response to the Notice of Violation and

Item B of the Notice of Deviation. We will inspect your corrective actions

during a future inspection. We continue to be in need of additior.al

information regarding item A of the Notice of Deviation as discussed with your

Mr. T. G. Tyler at the site on March 7, 1986.

Please provide the supplemental information within 20 days of the date of this

letter.

Sincerely,

f

"! steed ny

I thnan

E. H. Johnson, Director

Division of Reactor Safety

and Projects

Texas Utilities Electric Company

ATTN: J. W. Beck, Vice President Licensing

Quality Assurance and Nuclear Fuels

Skyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas 75201

i

'

Renea Hicks

Assistant Attorney General

Environmental Protection Division

P. O. Box 12548

Austin, Texas 76711

1 Texas Radiation Control Program Director

RIV:CPGk DRSP k

TFWesterman:gb EHJohnson

$/p /86 3/g/86 g[

8603280332 860312 l

PDR

O

ADOCK 050 g 5 'l

. .

Texas Utilities Generating 2

Company

Sec to DMB (IE01)

bcc distrib. by RIi:

• RPS * MIS System

• RRI-0PS *RSTS Operator

• RRI-CONST *R&SPB

• T. F. Westerman, CPTG DRSP

V. Noonan, NRR R. Martin, RA

S. Treby, ELD *RSB

• RIV File J. Taylor, IE

• D. Weiss, LFMB (AR-2015) R. Heishman, IE

• w/766

. .

.

Log # TXX-4619

, TEXAS UTILITIES GENERATING COMPANY F i1e # 10130 -

.amv vo-=. . wo.w ouv= r.=rr. i_.. .. . DMha. MEAS M . IR 85-11

wuw a couait

November 11, 1985 .

[RECWTrVE VtCS P8ES' DENT

Mr. R. P. Denise

TM@EDWM 3

Division of Reactor Safety and Projects

U. S. Nuclear Regulatory Commission NOV20125 ,e

Region IV ,

j

611 Ryan Plaza ~ Drive, Suite 1000 -

g

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 NO.: 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,.1985. This

inspection covered activities authorized by NRC Construction Permits

CPPR-126 and CPPR-127 for Comanche Peak Units 1 and 2.

4

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 he 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

q9

Attachment 4 \*

o

c- Region IV (Original + 1 copy)

Director, Inspection and Enforcement (15 copies) \

U. S. Nuclear Regulatory Commission 9; ,

l

Washington, D.C. 20555 f  ;

Mr. V. S. Noonan #a '

Mr. D. L. Kelley

. l a arvssion or rexas vrzurses ms.scasc couraur

- _ _ . __

- _ _ _ _ - _ _ _ _ - _ _ . _ _ _ _ _ _ _ . ___ _ _ _ _

.

. . .

.

.

' ATTACHMENT

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 adversa 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 Hold 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

procedures and design requirements in accordance with CP-QP-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.

.

. . .

_. _