ML20091H763
| ML20091H763 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/27/1991 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20091H730 | List: |
| References | |
| NUDOCS 9112240116 | |
| Download: ML20091H763 (5) | |
Text
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.4 MFE Log
- TXX-91410 File # 10130
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IR 91-51 Ref.
- 10CFR2.201 7t/ ELECTRIC November 27, 1991 "0-4?/1"*
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U. S. Nuclear Regulatory Commission W 29lm a
Attn:
Document Control Desk Washington, D. C.
20555
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SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION 'CPSES)-UNil 1 DOCKET NO. 50-445 NRC lNSPECTION REPORT NDS. 50-445/91-51; 50-446/91-51 RESPONSE TO NOTICE OF VIOLATION Gentlemen:
TV Electric has reviewed the NRC's letter dated October 28, 1991, concerning the inspection conducted by the NRC staff during the period September 30 thr0 ugh October 4, 1991.
This inspection covered activities authorized by NRC Operating License NPF-87 and Constructicn Permit CPPR-127. Attached to the October 28, 1991, letter was a Notice of Violation.
TV' Electric hereby responds to the Notice of Violation (445/9151-01) in the attachment to this letter.
Sincerely, f
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William J. Cahill, Jr.
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Attachments c - Mr. R. O. Martin, Region IV Mr. T. A. Bergman, NRR L. A. Yandell, Region IV Resident inspectors, CPSES (?)
9112240116 911217 PDR ADOCK 05000445-O PDR 400 N. Olive Sinet LB,81 Dallas, Tene 75208 U j
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. to TXX-91410 Page 1 of 1 UNITED STATES OF AMERICA NUr, LEAR REGULATORY COMMISSION In the Matter of
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Texas Utilities Electric Company Docket Nos. 50-444 and 50-446 (Comanche Peak Steam Electric Station. Unit 1 & 2)
AFFIDAVIT William J. Cah'11. Jr. being duly sworn, hereby deposes and says that he is Group Vice President, Nuclear of TV Electric, the lead Applicant herein; that he is duly authorized to sign and file with the Nuclear Regulatory Commission this response to Notice of violation 50-44b/91-51; 50-446/91-51 for the captioned facility; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, triformation and belief.
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William J, CaMill. Jr.
Group Vice President, Nuclear STATE OF TEXAS
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COUNTY OF SOMERVM4 Subscribed and sworn to before me, on this 27th day of November
, 1991.
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' to TXX-91410 Page 1 of. 3 HQ11CE_OF VIOLATLDH (445/9151-01; 446/9151-01) 10 CFR 50.49(f) requires that "each item of electric equipment important to safety must~be quali'ied by":_ testing identical equipment under the same or similar conditicas-with supporting analysis; testing a similar item with supporting analysis; experience with identical or similar equipment under similar conditions with support.ng analysis; or, analysis with partial test data.
10 CFR 50.49(j) requires that "{a) record of the qualification... must be maintained in an auditable form... to permit verification that each item of electric equipment important to safety... is qualified for it's application...."
Environmental qualification data package EEQSP-ES-100-03, Revision 2, Supplement 2, " Harsh Environment Okonite T-95 and No. 35 Splicing Tape,"
issued on August 10, 1929, provided information to be used to determine the qualification of V-type splices without jacketing tape in the crotch of the splice.
Contrary tc the above, on October 3, 1991, Supplement 2 of data package EEQSP-ES-100-03 did not contain sufficient information to demonstrate the qualification of the-subject splices in accordance with 10 CFR 50.49.
RESPONSE TO NOTI.EE OF VIOLATI.QH (445/9151-01; 446/9151-01)
TU Electric accc
'1e violation and the requested information follows:
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1.
Reason for Violation A one time deviation Design Change Authorization (OCA) 94555 was issued against CPSES Unit 2 Specification CPES-E-2004 for dual '/oltage Motor Operated Valves (MOVs). The subject DCA authorized installation of "V"-tyoe splices without jacketing tape in the crotch of the splice.
A review of the qualification package EEQSP-ES-100-03 Revision 2, its Supplements 1,2 and 3, and associated documentction and interviews with
-cognizant personnel concluded that package EEQSP-ES-100-03, Revision 2, through Supplement 2 issued on August 10, 1989, appeared to allow the subject configuration, consistent with information in the possession of TV Electric at that time.
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- s. to TXX-91410
-Page 2 of 3' However, as part of.its corrective actions for Notice of Vio stion 445/8960-V-02, which was issued for inadequate installation of multi-wire splices, TV Electric issued DCA-78713 R/12 against Electrical Specifications ES-100, to address the additional limitations on Okonite i
tape and to clarify installation details for in-line and "V"-configuration-taped splices.
Specifically, the configuration of two, three and four wire "V" splices were to be treated th6 same as an in-line cplice: i.e., the jacketing tape was to be applied continuously from one cable. cver the bolted _ connection and continuing onto the next conductor (s) following the "V" configurat<w.
Subsequently, on October
- 18. 1969, Supplement 3 was added to Equipment Qual 4ication (EQ) package EEQSP-ES-100-03-to address this change.
Based on this infermation, the following conclusions have bet.'1 reached regarding the reasons for the condition noted in the Notice of Violation:
.A)
-(he Unit 1 procedure used to develop, revise and supplement EQ packages was silent with reg Fd to voiding changed, superseded or deleted information wnen r.ew supplements are issued. As a result, when supplement 3 to EEQSP-ES-100-03 was issued, the information indicating that the subject configuration was qualified through supplement 2 was not clearly voided.
B)
F n onnel performing the interdiscipline review on DCA 94555 using pauage EEQSP-ES-100-03 failed to identify that information in supplement-3 superseded prior information on-the qualification of the subject splices.
2.
Corrective St90s Taken'and Results Achieved TU Evaluation Form (TUE) No. 91-2326 was issued to_ document the-condition allowed by DCA-94555 to the Electrical Specification
- CPES-E-2004. OCA-94555 was revised to rework affected valves listed in the DCA, and required:the taping to comply with the specification and the EQ package through supplement 1.
The subject EQ packaoe was clarified to clearly state the qualified configurations ellowed.
An-interface meeting was held with TV Electric EQ group and Unit 2-EQ personnel to enhance communication regarding the EQ packages, their applicability to Unit 2, and to enhance +h' Sthodology for EQ package updates.
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~ Attachment 2'to TXX-91410' Page 3 of 3 3.
Corrective Actions Taken to Preclude Recurrence The procedure governing the preparation of EQ packages will be revised to clarify the use of supplements and.for voiding information which is no longer app'licable due to the newly issued-supplements.
Additionally, a review of all of the EQ packages was performed.
No other similar situations were identified which could have resulted in tne misapplication of the package.
This reviri indicated that__
incorporation of a-record of change sheet wouh enhance-the usability of the packages.
This enhancement will be incorporated in the EQ package preparation procedure. A backfit to the EQ packages will be performed to comply with the revised procedures, by January 31, 1992.
4.
Date When Full ComDlience Will Be Achieved Full compliance will be achieved Dy January-31, 1992.
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