ML20081K434
| ML20081K434 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/24/1991 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CP-87-123, TXX-91193, NUDOCS 9106270200 | |
| Download: ML20081K434 (2) | |
Text
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f a _._7 Log # TxX 91193 file # 10110 908.3 71/ ELECTRIC Ref # 10CFR50.55(e)
Willista J, cahllt. Jia June 24, 1991
,--,r....
U. S. Nuclear Regulatory Commission Attn Document Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAH ELECTRIC STATION (CPSES)
UNIT 2 DOCKET NO. 50-446 TERHINATION$ NOT PER DRAW 1HG SDAR CP-87-123: SUPPLEMENTAL REPORT Gentlemen On January 11, 1988 TV Electric notified you via Txx-88049 of a reportable deficienc; involving wire terminations which were not completed in accordance with design drawings, As part of the corrective action identified in that letter, TU Electric stated that subsequent to March 2, 1987, design changes would not be implemented by a drawing revision.
This letter describes the mechanism for documenting and controlling design changes on Unit 2.
The cause of the Unit I deficiency was the issuance of drawings to the field which contained design changes not documented on a Design Change Authorization (DCA),
i.e.,
the practice of issuing design changes by direct drawing revision instead of using a separate DCA.
Changes made directly as drawing revisions were not readily identifiable for implementation by Construction.
Therefore, corrective action included implementation of procedural requirements which stated that design changes to drawings shall be accomplished only by DCA or stand alone design change nonconformance report (NCR).
Both the DCA and design change NCR were integral parts of the work control process.
The Unit 2 controlling procedure states that drawings may be revised to incorporate new design without the initiation of a design change document.
However, the procedure also requires that the " REMARK 5" column of the drawing block describe drawing changes.
For new designs, the preparer is required to identify that new design details have been added including any backfit requirements due to generic changes.
Finally, the procedure requires that during the drafting process thanges to the drawing be noted by enclosing the change in a " cloud", except for some component tar number revisions incorporation of as-built dimensions; and changes made a<.
a result of the initial incorporation of the Unit i design.
All previous clouds and revision number triangles are to be removed and a new or updated title block added.
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TXX-91193 Page 2 of 2 Additionally, Construction /Ouality procedures require current revisions of primary documents to be referenced during Construction Work Document (CWD) development, upon release to the field for work activities, during work activities, upon inspection / verification of work activities, and upon final documentation review of CWD contents by OC/CE.
The definition of primary documents includes drawings. DCAs, and deficiency documents.
Finally, SCOPE (the project tracking system) is used to provide work status information.
Design Documents issued for construction are entered into both SCOPE and the design database, DCC/DCA.
Association ties are made between primary documents and components.
Work is completed by component, and upon completion of all work on all components associated with a given primary document, the primary document is statused as complete and closed, in summary, these measures for contiolling drawing revisions and the work control process provide adequate assurance that the deficiency reported by SDAR CP 87 123 will not recur in Unit 2.
Sincerely, j
$'1
'l William J. Cahill Jr.
JTC/bm c
Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (2)
Mr. H. B. Fields, NRR
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