ML19263D603

Responds to NRC 790227 Ltr Re Violations Noted in IE Insp Repts 50-445/79-04 & 50-446/79-04.Corrective actions:in- Depth Review of Maint Program & Equipment Maint Record Revised

ML19263D603
Person / Time
Site:	Comanche Peak
Issue date:	03/20/1979
From:	Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19263D598	List: ML19263D603
References
TXX-2971, NUDOCS 7904130053
Download: ML19263D603 (5)

Text

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TENAS UTILITIES GENEIL\ TING CO.ilIRNY 2 tut IUW AN TOu EH 11 %f.LAN. T V A AM 7 Mot March 20, 1979 a ; cany TXX-2971 Mr. W. C. Seidle, Chief Reactor Construction and Engineering Support Branch U. S. Nuclear Regulatory Commission Office of Inspection & Enforcement 611 Ryan Plaza Dr. , Suite 1000 Docket Nos. 50-445/Rpt. 79-04 Arlington, Texas 76011 50-446/Rpt. 79-04 COMANCHE PEAK STEAM ELECTRIC STATION 1981-83 2300 MW INSTALLATION RESPONSE TO NRC INSPECTION REPORT N0. 79-04 DOCKET NOS. 50-445 & 50-446 FILE N0. 10130

Dear Mr. Seidle:

We have reviewed the report dated February 27, 1979 on the inspection conducted by Mr. L. D. Gilbert and other members of your staff, of the activities authorized by NRC Construction Permit Nos. CPPR-126 and 127 for the Comanche Peak facility. We have responded to the findings listed in Appendix A and B of that report.

To aid in the understanding of our response, we have repeated the requirement and your findings followed by our corrective action (s).

We believe the attached information to be responsive to the Inspectors' findings. If you have any questions, please advise.

Very truly yours,

~

)b R. J. Gary RJG:dla Attachment 7 9 0 413 o o fi3

Response to NRC Inspection Report 79-04 TXX-2971 Page 2 Appendix A NOTICE OF VIOLATION Based on the results of the NRC inspection conducted on February 5-8, 1979, it appears that certain of your activities wer! not conducted in full compliance with the conditions of your NRC Construction Permit No.

CPPR-126 as indicated below:

Failu:'; to Follow Equipment Maintenance Instructions 10 CFR Part 50, Appendix B, Criterion V requires that activ. ties affecting quality shall be accomplished in accordance with the prescribed instructions, procedures or drawings.

Brown & Root Storage and Maintenance Requirement No. 35-1195-MEI-10-783 requires that the shaft on Fan CPX-VAFNAV-37 be rotated sufficiently to lubricate the bearings every thirty days.

Brown & Root Storage and Maintenance Requirement No. 35-1195-MEI-10-473 establishes requirements for the storage and maintenance of the Positive Displacement Charging Pump TCX-CSAPPD-01. This procedure specifically requires that " unpainted carbon steel surfaces shall be maintained with preservative for duration of storage."

Contrary to the above:

1. On February 7,1979, the maintenance records for Ventilation Fan CPX-VAFNAV-37 indicated that the shaft had only been rotated twice (on September 12, 1978, and November 13,1978) during the five month period from September 12, 1978, through February 7, 1979.

2. On February 8, 1979, the underside of the Positive Displacement Charging Pump TCX-CSAPPD-01 was observed to be oxidized due to lack of preservative.

This is an infraction.

Corrective Steps Which Have Been Taken and Results Achieved:

1. Ventilation Fan CPX-VAFNAV-37 The Equipment Maintenance Record for the ventilation fan motor has been revised to incorporate the manufacturer's requirements for shaft rotation. (Minimum of every 3 months)

. Response to NRC Inspection Report 79-04 TXX-2971 Page 3 Corrective Steps Which Have Been Taken and Results Achieved: (Continued)

2. Positive Displacement Charging Pump TCX-CSAPPD-01 The affected area has been cleaned and protective coating applied.

Corrective Steos Which Will Be Taken To Avoid Further Noncompliances:

The Site Quality Assurance Staff is in the process of conducting an indepth review of the CPSES maintenance program. We anticipate completion of this effort by March 30, 1979 and will formulate appropriate preventive measures no later than April 18, 1979.

Date of Full Compliance:

Corrective actions were completed and verified on March 19 and February 27, 1979 respectively.

. Response to NRC Inspection Report No. 79-04 TXX-2971 Page 4 Appendix B NOTICE OF DEVIATION Based on the results of the NRC inspection conducted on February 5-8, 1979, it appears that certain of your activities deviate from commitments mada in your Final Safety Analysis Report (FSAR) as indicated below:

Failure to Achieve Adequate Separation Between Redundant Safety Related Wiring FSAR, Section 8.3.1.4.10 states, " Separation of redundant devices and components is accomplished by mounting them on physically separated control boards. Where this mounting is not feasible from a plant operational point of view, ..., separation is achieved by a six inch minimum airspace or by a fire retardant barrier." This FSAR commit-ment is also reflected in Gibbs & Hill Specification 2323-MS-605, Revi-sion 1, caragraph 3.6.7.2(e) for Main Control Boards.

Contrary to the above:

The IE inspector observed numerous areas in the Unit 1 Main Control Boards where the separation between redundant wiring is significantly less than six inches (two inches in some cases) without barriers. This finding has been reviewed with and confirmed by the licensee represen-tatives.

This is a deviation.

Corrective Action All of the Unit 1 main control boards were reinspected for compliance with the separation requirements by CPSES QA/QC personnel . Discrepancies noted were appropriately documented and then ccrrected by the supplier of the boards.

Corrective Action to Prevent Recurrence An audit was conducted of the supplier's facility. The audit identified deficiencies in the supplier's Quality Assurance / Quality Control function.

The deficiencies are being corrected in the supplier's facility through a program of re-indoctrination and re-emphasis on regulatory requirements, and by expanding existing Quality Control Checklists. In addition, TUGC0 QA will place special emphasis in the area of separation criteria at release inspections.

. Response to NRC Inspection Report No. 79-04 TXX-2971 Page 5 Date Corrective Action and Preventive Measures Have Been or Will Be Completed:

Corrective action for material at the site was completed and verified by March 8, 1979.

Preventive measures consisting of re-indoctrination and re-emptasis on regulatory requirements have been completed. Incorporation of expanded checklists by formal revision to the supplier's QA system will be completed by the end of April 1979.