TXX-6753, Forwards Revised Response & Addl Info Re Items B & C from Notice of Deviation from Insp Repts 50-445/86-26 & 50-446/86-22,per 870903 Request.Procedure Implementation Changes Will Be Made Prior to Senior Review Team Approval

Forwards Revised Response & Addl Info Re Items B & C from Notice of Deviation from Insp Repts 50-445/86-26 & 50-446/86-22,per 870903 Request.Procedure Implementation Changes Will Be Made Prior to Senior Review Team Approval

ML20236C548
Person / Time
Site:	Comanche Peak
Issue date:	10/23/1987
From:	Counsil W, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-6753, NUDOCS 8710270241
Download: ML20236C548 (7)

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. ' nlELECTRIC 9,7 y. kC 2 01-w.

wmi.m c. counnu -- J0ctober 23,-198'7-camive wce rmuent  ;

.U.'S.; Nuclear Regulatory Commission Attn:. Document: Control Desk b -

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Washington, D.:C.-20555 ga j

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SUBJECT:

- COMANCHE PEAK-STEAM ELECTRIC STATION (CPSES)

g. ' DOCKET NOS. 50-445'AND 50-446 @

REQUEST-FOR= ADDITIONAL INFORMATION REGARDING. C ,

INSPECTION REPORT:'50-445/86-26 AND-50-446/86-22

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Ref: 1) NRC letter.-from E. H.' Johnson to W. G. Counsil dated April 2,1987 -

2) TV Electric Letter TXX-6472 from'W. G. Counsil to NRC dated June:5, 1987.

Gentlemen:

Your-l_etter dated September.3, 1987, requested additional information on the subject inspection report with respect to Notice of' Deviation (N00) Item B

(445/8626l-D-03; 446/8622-D-01)~and Item C (445/8626-D-04; 446/8622-0-02).

On< September 23, 1987, per a telephone. conversation with your Mr. R. F.

Warnick, we requested and received an extension until October 7, 1987. On October 7,:1987,.'pera telecon with your Mr. Ian Barnes, we' requested'and received an extension until October 23, 1987.

In pursuing the request for additional information, we have determined that a revision to our original response was required to clarify our position.

Accordingly, a revised response, including the requested additional information, is enclosed. Since the entire response has been revised,- no revision bars have been provided.

We,hereby-respond to the above items in the attachment to this letter.

Very truly yours, hb W. G. ounsil b

8710270241 871023 PDR ADOCK 050004451"- I

& PDR By:

D. R. Woodlan Supervisor, Docket Licensing RDD:grr p

400 North Olive Street LB 8I Dallas, Texas 73208 di

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. i c- Mr. R. D. Martin, Region IV j Resident Inspectors, CPSES (3)

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L iAttachment to'TXX-6753' L

October 23,.1987 p Page 1 of 5-1 REQUEST FOR ADDITIONAL INFORMATION NMRE DFTHIATIF F TTEM B (445/8626-D-03; 446/8622-D-01)

NOD ITEM B ' 'I i

l, Your response to item B of the N00 indicates disagreement with the stated I deviation. Your response, however, fails to recognize that the ISAP.I.d 3

l. requirements were being' implemented prior to the SRT. approval or issuance of j

! the Results Report. Accordingly, .we request that you provide the information '

originally requested for this deviation.

i NOTICE OF DEVIATION .

i ITEM B (44578M 6-D-03; 446/8622-D-01)

8. Section 4.1.2 of ISAP 1.d.3, Revision 0, requires, in part, that ERC' perform an evaluation of the craft training procedures including training and retraining, and that the following items will be considered during_ 4 this evaluation: l

l "How craft personnel become aware of changes'in design and construction J requirements and how retraining occurs "  !

"llow craft personnel are informed and become knowledgeable of QA/QC )

requirements / criteria and changes to those requirements / criteria."

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.Section 4.1.3 of the ISAP also states, in part, " Based on this review (of l procedures), conclusions will be drawn by the QA/QC Review Team Leader as to the adequacy of both past and current practices used for craft selection and training. If current procedures are determined to be ,

inadequate, recommendations for improvement will be provided to TUGC0 j prior to the closure of this action plan." i I

In deviation from the above, ISAP 1.d.3 Results Report does not provide a l recommendation that TUGC0 revise the Bahnson Service Company's craft  !

training Procedure QCI-CPSES-013, " Indoctrination and Training of l Personnel," which does not assure that: (1) " craft personnel become aware of changes in design and construction requirements"; and (2) " craft requirements / criteria and changes to those requirements / criteria" (445/8626-D-03; 446/8622-D-01).

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Attachment to TXX-6753 October 23, 1987

.s_ Page 2 of 5 REVISED RESPONSE ITEM B (44578626-D-03; 4W/8622-D-Oll TV Electric agrees with the alleged deviation and the requested information follows:

1. Reaso_n for Deviation This deviation occurred because the ISAP I.d.3 Results Report did not recommend that TV Electric revise the Bahnson craft training procedure QCI-CPSES-013, " Indoctrination and Training of Personnel". The reasons for not making the recommendation are:

1 1) Revision 0 of ISAP 1.d.3 dated January 24, 1986, instructs the QA/QC l Review Team Leader to ..."If current procedures are determined to be inadequate, recommendations for improvement will be provided to TUGC0 prior to the closure of this action plan." The Action Plan Change i Request for Revision 0 of the ISAP dated August 27, 1986, removed this requirement. The Results Report was written according to the precepts of Revision 1 of the ISAP. At the time the NRC identified the alleged deviation, Revision 1 was not formally approved by the SRT, but was being used by the Issue Coordinator.

(TV Electric recognizes that this situation is not in accordance with Revision 3 of the CPRT Program Plan which was in effect at that time). This is discussed further in our response to N0D Item C l (445/8626-D-04; 446/8622-D-02).

2) Revision 1 of ISAP I.d.3 was designed to broaden the scope of adequacy assessment and to address use of results from other ISAPs.

Section 4.1.2 states, in part, ..."The assessment of craft personnel training pro procedures, interviewing grams was accomplished byand craft personnel, reviewing crafttraining observing training activities." Section 4.1.3 states, in part, ... The QA/QC Review "

Team used results of their activities to draw conclusions about the adequacy of past and current craft personnel training practices.

These conclusions may be modified if shortcomings in the training of craft personnel are determined..."

Based on the above, the net result of the analysis performed in I.d.3 indicated that adequate re-training did in fact occur for Bahnson personnel even through QCI-CPSES-013 lacked specificity regarding re-training of craft personnel. Therefore, ISAP I.d.3 did not recommend a revision to the Bahnson procedure. However, upon further consideration of this matter, TV Electric agrees that the Bahnson procedure should have been revised to state clearly how re-training should occur. This would provide assurance that training and re-training would continue to occur in a timely and prudent fashion.

However, since Bahnson is no longer onsite, revising their procedure is no longer a concern.

H' -Attachment'to-TXX-6753

,m W 10ctober'23, 1987

Page 3 of 5

2. Corrective Steps Taken and Results Achieved u

No corrective steps have been identified with regard to revising Bahnson  !

Training Procedure QCI-CPSES-013 since Bahnson_is no longer-performing j work at CPSES. 'HVAC construction work activity is currently controlled by l TV Electric procedure. ECC-1.16-1, " Orientation, Indoctrination and  !

Training of Fluor. Daniel Project Personnel." This procedure includes specific requirements for Project employee training and re-training. j Corrective steps taken for ISAP I.d.3 changes that were implemented prior I to SRT approval is addressed in our response to N00 item C (445/8626-D-04; i 446/8622-0-02). l l 3. Corrective Steps Which Will be'Taken'to Avoid Further Deviations Since Bahnson-is no longer onsite and HVAC' activities are controlled by TV Electric, no further action is required. ,

i The corrective steps required to prevent recurrence of the situation where- {

changes in ISAP implementation'are made prior to SRT approval are J addressed in the response to NOD ltem C.(445/8626-D-04; 446/8622-D-02). <

4. Date When Full Compliance Will Be Achieved I

The CPRT is now in full compliance.

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i 1 4 g Attachment'to TXX-6753-7,,

C October 23,.1987:

Page'4lof 5 3

,1 REQUEST FOR ADDITIONALINFORMATION NOTICE 0F DEVIATION ITEM C (445/8626-D-04; 446/8622-D-02)

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N00 ITEM C: ,

L Your. response to Item C of the NOD does not address how the SRT was aware of:

.ISAP changes which were made in,the Results' Reports. In addition,' you state

. corrective action was taken with the SRTlon May 20, 1987.1 Either this date is-in. error.or your corrective actions,were not timely. Therefore, we requesti that.you revise your response to this deviation to address the above two-concerns.

NOTICE OF DEVIATION ITEM'C (445/8626-D-04; 446/8622-D-02)-

C. The W. G. Counsil letter (CPRT 207) to the NRC, dated January 27, 1986, regarding CPSES. submittal of Revision 3 of the Comanche Peak Response Team (CPRT) Program Plan;and ISAPs, committed that, "...further substantive-modifications to'these' documents (CPRT Program Plan ISAPs)lwill require

- the approval of the Senior Review Team prior to implementation."-

Change Notice.001 to Comanche Peak Project Procedure CPP-024,;" Issue

Specific Action Plan Revision," dated April 4, 1986, requires that "...the-SRT approves substantive changes prior to implementation."

In devi'ation from the above, substantive changes to ISAP I.d.3 were  !

implemented prior to approval by-the Senior Review Team (SRT). For example, in April.1986 the Special Evaluation Team's effort was transferred'to Quality Assurance / Quality Control (QA/QC): Review Team

. personnel and the issue coordinator was changed; however, the SRT did not

- approve these and other changes until August- 1986 (446/8626-D-04; 446/8622-D-02).

REVISED. RESPONSE ITEM C (44678MB D 047 44Ti/8622-0-02)

-TV Electric agrees with the alleged deviation and the requested information follows:.

1. ' Reason for Deviation All substantive changes to CPRT Action Plans are approved by the SRT. l However, on occasion, Action Plan changes have been implemented prior to receiving formal SRT approval, which is inconsistent with the guidance delineated in CPRT-207, PAG-01 and CPP-024. Therefore, on occasion, the SRT has deviated from program requirements by not formally approving l substantive changes to Action Plans prior to their implementation. These deviations have occurred due to an oversight by the SRT.

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a Attachment';to TXX-6753 'l

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,y Page 5 of 5 1

j .. 2.. Corrective: Steps Taken and Results Achieved '

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The SRT has now formally a proved the substantive changes to'ISAPs as:

delineated in. PAG-01, Revi ion 4. Any ISAP I.d.32 action plan changes that.

E have~been implemented and later included within the action. plan'results 1

. report have also been documented on Action Plan Change Requests.  !

The SRT,is made aware of' proposed changes to action plans through Action i v ' Plan Change Requests,per. PAG-01. . The Action Plan. Change Requests clearly i

- identify proposed changes to' action plans, provide -justification for the.-

. changes and document: approval by the SRT.

TV Electric was firstLinformed of this deviating condition by.the NRC during the NRC' exit meeting. held.on October 9, 1986. Further information - l "was'obtained from the NRC to clarify the deviating condition during-

,0ctober and. November 1986. An SRT meeting was. held on. January 27, 1987, l

Ltoiclarify thel intent of PAG-01-regarding " substantive changes." Based on d

the results of the-SRT meeting PAG-01'was revised (Revision 2 2/3/87) to. , H further define; substantive changes. TV Electric officially. received NRCL j

., Inspection Report 445/8626 and 446/8622 identifying this' deviation on 4 April 2,1987, and a meeting was held with the SRT on May 20, 1987, to

-discuss the response to this N0D. .The SRT agreed that, in accordance with procedural requirements, any future substantive changes to ISAPs that have 4 not yet been completed will be fonnally approved by the SRT prior to ]

implementation of the changes. 4 3'. Corrective Steps Which Will Be Taken to Avoid Further Deviations Presently,.the investigative activities of-all action plans have been completed or nearly-' completed. .The completed action. plans have had their  !

respective results reports approved by SRT and issued. Any future.

substantive changes to ISAPs will:be formally approved by the SRT prior to implementation in accordance with procedural requirements. ]

4. Date When Full Compliance Will Be Achieved ;l The SRT is now in full compliance.

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