ML20005D891
| ML20005D891 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/21/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89852, NUDOCS 9001020162 | |
| Download: ML20005D891 (4) | |
Text
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.o. w b' MEE Log # TXX-89852
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File # 10130 IR 50 445/89-40 IR 50 446/89-40 7UELECTR/C 10110 SDAR CP 87 081 Ref. # 10CFR2.201 WWhm J.OAW, Jr.
becutive Vke President U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50 445 AND 50 446 NRC INSPECTION REPORT NOS. 50 445/89 40; 50-446/89-40 RESPONSE TO NOTICE OF VIOLATION Gentlemen TU Electric has reviewed the NRC's letter dated November 28, 1989, concerning the inspection conducted by Mr. W. D. Johnson and Mr. S. D. Bitter during the period October 4 through November 7, 1989.
This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2.
Attached tn the NRC's letter was a Notice of Violation.
TU Electric hereby responds to the Notice of Violation in the attachment to this letter.
Sincerely, A-William J. Cahill, Jr.
WJH/smp Attachment c - Mr. R. D. Martin. Region IV Resident Inspectors, CPSES (3)
Assistant Director for Inspection Programs.
Comanche Peak Project Division.
Office of Special Projects 9001020162 891221 PDR ADOCK 05000445 O
PDC T2ol P. O. Box 1002 Glen Rose, Texas 76043-1002
'(
q Attach;ent to.TXX 89852 i
Page 1 of 3 i
p J
(445/0940-V 01)-
j Criterion V of Appendix B to 10 CFR Part 50 requires, in part, that activities affecting quality be accomplished in accordance with the appropriate i
procedures.
Comanche Peak Steam Electric Station Test Department Administration Manual j
. Procedure TDA-306, " Control of Deficiencies and Nonconformances," requires, in paragraph 6.1.1, that nonconformances and deficiencies identified by test personnel during test conduct be reported on a test deficiency report (TDR).
l l
Contrary to the above, during implementation of Prerequisite Test Instruction XCP-EE-20, " Continuity and Termination Verification," loose terminal screws identified W test personnel during performance of terminal verifications were
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not reported on a.TDR or by using any other reporting system.
l RESPONSE TO NOTICE OF VIOLATION l
(445/8940-V-01) l TV Electric agrees with the violation and the required information follows.
1.
Reason for the Violation The corrective action program for construction deficiency SDAR CP-87-081, "Weidmuller Terminal Block Connections", required the inspection of all Weidmuller terminal blocks for loose connections and that instances of 1.
loose connections would be evaluated for reportability.
Initially, the L
terminal blocks were to be inspected using Post Construction Hardware Validation Program (PCHVP) Procedure CPE-SWEC-FVM-EE-90.
However, instead of using PCHVP Procedure'CPE-SWEC-FVM-EE-90, the inspection was performed during implementation of Prerequisite Test Procedure XCP-EE-20
" Continuity and Termination Verification".
TU Electric described this change of the corrective action in its letter logged TXX-89729 and dated October 9, 1989.
Although the test program procedure did ensure the j
tightness of terminal screws, the "as-found" condition of those found l
loose was not documented. As a result, it was not possible to evaluate them later to determine if they represented a reportable condition.
1
4 Attach ent to TXX-89852-
.,Page 2 of 3 The Startup procedure which prescribes the requirements for documentation of test deficiencies contains a provision regarding minor deficiencies found during prerequisite testing (i.e., testing which precedes the preoperational tests).
In accordance with that provision, minor deficiencies which can be corrected by " calibration, adjustment, or replacement of consumable materials" need not be documented on a Test Deficiency Report (TDR) as test deficiencies.
Because the procedure does not specify-what types of deficiencies can be treated in this manner, test personnel inappropriately applied this provision to the loose terminations.
As a result, the loose terminations were not recorded on a TDR or other document.
Additionally, personnel responsible for implementing this procedure and approving test results were not aware of the specific commitment to document and evaluate for reportability loose terminal screws.
2.
Corrective SteDs Taken and Results Achieved TU Electric agrees with the NRC conclusion that any existing deficiencies L
would have been corrected by procedure XCP-EE-20.
No additional action is necessary regarding loose terminal screws.
Other types of minor deficiencies which may have been handled similarly, would also have been corrected as required by controlling procedures.
The Startup Program Prerequisite Testing and Preoperational Testing provides adequate assurance that hardware configuration "as left" by Startup is in compliance with design requirements.
L Other site programs were reviewed to determine if other procedures exist l
which allow correction of minor deficiencies without documenting the deficiency.
No significant concerns were noted.
3.
Corrective Steos Which Will be Taken to Prevent Further Violations Because the Unit 1 Preoperational Test Program is in the final stage of completion, and component prerequisite procedures such as XCP-EE-20 are no longer in use, it would not be effective or practical to apply corrective steps to the Unit 1 Startup Program.
Unit 2 Startup procedures will be revised to provide clarification with regard to docuruentation of deficiencies.
In addition, training on this subject will be provided to personnel involved in Unit 2 preoperational testing activities.
t- +
Attach:ent to TXX-89852
.Page 3 of 3
'?l 1.-
Those who were involved in revising the corrective actions for the Weidmuller terminal block connection deficiency have been briefed regarding this violation. The purpose of this briefing was to point out the importance of assuring that changes to deficiency corrective action programs receive proper review so that all aspects of the corrective-action requirements are preserved.
4.
Date of Full Comoliance Full compliance for Unit I has been achieved.
Full compliance for Unit 2-will be achieved prior to recommencing Unit 2 test activities, f
f,
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