Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
ACCESSION #: 9604300099
ABB
ASEA BROWN BOVERI
April 26, 1996
LD-96-014
U.S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, DC 20555
Subject: Reply to a Notice of Nonconformance
Reference: NRC Notice of Nonconformance to Combustion Engineering,
Inc. dated February 28, 1996
Dear Sir:
This letter provides Combustion Engineering's (ABB-CE's) response to the
referenced Notice of Nonconformance. The time for responding to the
Notice was extended at ABB-CE's request to April 30, 1996.
ABB-CE has reviewed the identified nonconformance and will modify its
future record keeping practices to be in accord with the interpretation
of 10 CFR 21, Reporting of Defects and Noncompliance, represented in the
Notice of Nonconformance.
The attachment provides details of the ABB-CE resolution for the
identified nonconformance.
Please do not hesitate to call me or Dr. Ian Rickard at 860-285-9678 if
you have any questions or wish to further discuss this topic.
Very truly yours,
COMBUSTION ENGINEERING, INC.
Charles B. Brinkman
Director, Nuclear Licensing
cc: M. R. Johnson (NRC)
S. D. Alexander (NRC)
R. S. Siudek
I. C. Rickard
ABB Combustion Engineering Nuclear Power
Combustion Engineering Inc. 1000 Prospect Hill Road
Post Office Box 500
Windsor, Connecticut 06095-0500
Telephone (203) 688-1911
Fax (203) 285-9512
Telex 99297 COMBEN WSOR
Response to Notice of Nonconformance
1.0 Nonconformance
1.1 Statement of Nonconformance
The nonconformance, stated in Section 1.4 of the inspection report, found
that:
Contrary to the requirements of Criterion V of 10 CFR Part 50,
Appendix B, ABB-CE did not (with regard to reactor head studs
supplied to Millstone-2 in 1990) and, as a matter of stated practice
or policy, routinely does not document negative findings in
evaluation of deviations or failures to comply in the manner
prescribed by the procedures when the deviations or failures to
comply are obviously not safety significant (ie., could not create
or are not related to a substantial safety hazard) or appear not to
be safety significant upon initial review.
Criterion V of 10 CFR 50 Appendix B provides that:
Activities 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
instructions, procedures, or drawings. Instructions, procedures, or
drawings shall include appropriate quantitative or qualitative
acceptance criteria for determining that important activities have
been satisfactorily accomplished.
1.2 Reason for Nonconformance
ABB-CE's existing procedure for implementing 10 CFR 21 lacks sufficient
detail regarding documentation of the decision not to submit a deviation
or failure to comply for further evaluation pursuant to 10 CFR 21 if, on
initial review, the cognizant engineer believes that such deviation or
failure to comply does not have the potential to create a substantial
safety hazard. This lack of detail led to the nonconformance.
2.0 Corrective Actions and Results Achieved
ABB-CE will direct all cognizant personnel reviewing deviations and
failures to comply for basic components delivered to ABB-CE customers to
document whether or not the facts indicate a further evaluation under the
10 CFR 21 implementing procedure is warranted.
3.0 Corrective Actions to Avoid Further Noncompliance
ABB-CE believes that the action described above will resolve the
identified nonconformance. ABB-CE will incorporate that action as a
permanent change to the 10 CFR 21 implementing procedure.
4.0 Date when Corrective Actions will be Completed
The corrective action described in Section 2 will be completed by June
28, 1996. ABB-CE will also initiate a revision to its 10 CFR 21
implementing procedure and expects that such revision will be completed
by September 30, 1996.
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