ML20196J144

Responds to NRC 880520 Ltr Re Violations Noted in Insp Repts 50-445/88-32 & 50-446/88-28.Corrective Actions:Personnel Reminded of Need to Fully Document Engineering Justifications When Dispositioning Nonconformance Repts

ML20196J144
Person / Time
Site:	Comanche Peak
Issue date:	07/01/1988
From:	Counsil W, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-88522, NUDOCS 8807060331
Download: ML20196J144 (4)

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== Log #.TXX-88522-F. File # 10130

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.= IR 88-32

- Z IR 88-28 Ref. # 10CFR2.201 7UELECTRIC July 1,1988 William G. Coumil .

^ Estrutive nre Pressdent U. S. Nuclear Regulatory Commission Attn: Document Contrei Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK SlEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE T0 INSPECTION REPORT NOS.

50-445/88-32 AND 50-446/88-28 Gentlemen:

TV Electric has reviewed your letter dated May 20, 1988, concerning the inspection conducted by Mr. P. Stanish and other NRC consultants during the period April 6 through May 3, 1988. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2. Attached to your letter was a Notice of Violation.

On June 20, 1988, per a telephone conversation with Mr. R. F. Warnick, we

!, requested and received an extension for NOV (445/8832-V-01) until l

July 1, 1988.

We hereby respond to the Notice of Violation in the attachment to this letter.

l Very truly yours,

.b W. G. Counsil By: E D. R. Woodlan Docket Licensing Manager RDD/grr Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)

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8807060331 0B0701 PDR ADOCK 05000445 I G PNU g 400 North Ohve Street LB81 Dallas. Tenas 7H01

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Attachment to TXX-88522

. July 1, 1988 Page 1 of- 3 NOTICE OF VIOLATION

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Criterion V of Appendix B to 10 CFR 50, as implemented by Section 5.0, Revision 0 of the TV Electric Quality Assurance Manual (QAM), states, in part, "Activi, ties.affecting quality shall be prescribed by documented instructions, procedures,.or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instruction, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptarice criteria for determining that important activities have been satisfactorily accomplished."

Appendix A, Revision 0 of the Unit 1 TV Electric 1987 Quality Assurance Manual defines "ase-as-is" as:

"A disposition which may be assigned for nonconformance when it can be established that the discrepancy shall result in no conditions adverse to safety and that the item under consideration will continue to meet all engineering functional requirements. This disposition requires technical justification by Engineering of the item's acceptability for use."

Nuclear Engineering Organization (NE0) 3.05, Reporting and Control of Nonconformances, Revision 3, paragraph 6.3.3,' states, in part, "Engineering shall review the nonconforming condition to determine the appropriate disposition . . . . If the NCR is dispositioned 'Use-as-is,'

ensure that the engineering bas's for technical acceptability is provided Contrary to the above, nonconformance report (NCR) CM-87-6087, Revision 1, whicS identifies 9 potentially nonconforming commodity clearance violations, with respect to installation of Residucl Heat Removal piping and pipe supports, was dispositioned "Use-as-is" by Engineering personnel and approved by quality assuraice personnel, although the basis for technical acceptability was not provided. Engineering personnel failed to establish that the discrepancies would result in no conditions adverse to safety and that the item would continue to meet all engineering

-functional requirements (445/8832-V-01).

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Attachment-to TXX-88522 s -

' July-1,,1988.

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Page 2;of 3

. RESPONSE TO NOTICE OF-VIOLATION (445/8832-V-01)

.TV; Electric agrees with the. alleged violation and'the requested information ,

follows:

1. LReason for Violation TV. Electric has initiated a program to define and implement comodity

. clearance requirements for plant systems. Specification CPSES-S-1021 "Commodity-Clearance" was developed to provide a clear and consistent >

statement of'these requiremente. Commodity clearance requirements.were

-removed from other existing installation specifications, refined, and consolidated in CPSES-S-1021. Using the guidance provided by CPSES-S-1021, an engineering walkdown is being performed to

' systematically evaluate and correct as necessary existing commodity clearance conditions. Upon completion of the walkdown, the commodity ,

= clearance, aspects of future construction activities are to be controlled by CPSES-S-1021 or~its equivalent.

In formulating the above described program, it was necessary to address approximately 600 commodity clearance related Nonconformance Reports (including NCR CH-87-6087).which had been previous _ly generated during post installation QC inspection of ASME piping. These NCRs had been written; based en commodity clearance requirements that were subsequently deleted from the piping specification and incorporated into CPSES-S-1021.

The NCRs were dispositioned "use-as-is, no longer a nonconformiag condition"-with an engineering justification that the requirements were no' longer contained in the piping specifications. This action was taken knowing'that the specific discrepancies would be re-evaluated during the

. procedurally controlled commodity clearance walkdown, and that it was

.unlikely the specific discrepancies would require re-work.

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E Since the discrepant conditions documented on the NCRs were to be re-

. evaluated during the comri;odity clearance walkdown, the "t,se-as-is, no l- longer a nonconforming condition" dispositioning and closure of the NCRs would not have resulted in any uncorrected hardware deficiencies.

However, the engineering justification did not provide a clearly

' documented link between the condition described in the NCRs and the commodity clearance walkdown program which was to provide further evaluation of the conditions.

l" 2. Corrective Steps Taken and Results Achieved New NCRs or NCR revisions as applicable will be initiated for the NCRs

-that documented comodity clearance discrepancies and were dispositioned "uce-as-is, no longer a nonconforming condition" without sufficient L technical justification.

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Attachment to TXX 88522-

. ' July'1,;1988 .i Page 3 of 3 x- s N-IN 3.. . Corrective Steps--Which Will be' faken to Avoid Further Violations- ,

.;. ;The personnel'invol0ed in'this occurrence have been reminded of the need

.to fully document engineering justifications when dispositioning NCRs

, "use-as-is, no longer a' nonconforming' condition."

4. -Date When Full' Compliance Will be Achieved The issuance of new-and revised NCRs as described above will be completed no later than August 15,,1988.

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