Part 21 Report - 1996-400

 
 
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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