ML20133M730
| ML20133M730 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/11/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20133M720 | List: |
| References | |
| 50-445-85-11, NUDOCS 8510280223 | |
| Download: ML20133M730 (2) | |
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l APPENDIX B NOTICE OF DEVIATION Texas Utilities Electric Company (TUEC) Dockets: 50-445/85-11 Comanche Peak Steam Electric Station, Unit 1 Permi t: CPPR-126 l Based on the results of an NRC inspection conducted during the period of
) August 1-31, 1985, of Comanche Peak Response Team (CPRT) activities, two 1 deviations from commitments to the NRC were identified. The deviations involved j a failure to comply with objectivity criteria reporting requirements and 4
instances where the location of incorporated revisions was not denoted in procedures. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the deviations are listed below:
A. Section VII, "CPRT Objectivity Guidance," of the CPRT Program Plan, Revision 2, states, in part, " . . . all five Review Team Leaders and those assisting the Review Team Leaders in various capacities, including issue coordinators, are experienced nuclear industry consultants who have
- not been previously involved with the CPSES activities that they are now reviewing. While these objectivity criteria are expected to be
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fully met, any exceptions will be promptly identified by the CPRT and provided to the NRC along with any necessary justification."
Contrary to the above, the issue coordinator for Issue-Specific Action Plans VII.a.1, VII.a.7, VII.a.8, and VII.b.1 (each associated with ASME activities to some degree) was a contract employee to Brown & Root from
! July 1980 to January 1981 whose duties included at least one Comanche Peak audit of ASME activities; however, this individual was not identified to the NRC with any justification regarding objectivity even though the j individual has been in the present position since May 1985 (445/8511-D-02).
- 8. Paragraph 5.2.4 of Procedure CPP-001, Revision 0, states, in part,
" Incorporated revisions shall be indicated by a side bar in the right hand
! margin opposite the revision . "
Contrary to the above, (1) CPP-016, Revision 1, was issued on August 9, 1985, and of the numerous changes made, five were not indicated by a side bar; (2) CPP-006, Revision 1, and CPP-009, Revision 1, were issued, respectively, on August 9 and August 13, 1985, with numerous changes, but
! not all changes were indicated by the required side bar; and (3) CPP-010, Revision 1, was issued on August 13, 1985, with none of the changes l indicated by the required side bar (445/8511-D-01).
l Texas Utilities Electric Company is hereby requested to submit to this office,
! within 30 days of the date of this Notice of Deviation, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to Os102%h PDR h p G
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- avoid further deviation from conmitments made to the Comission; and (3) the date when full compliance will be achieved. Consideration may be given to i extending your response time for good cause shown.
Dated: OCT 11885 i
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