ML20147D584

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Forwards Licensee Sixth Submission of Responses to Notices of Violation & Notices of Deviations for 880127-0225 Per ASLB 870812 Request.W/Certificate of Svc
ML20147D584
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/29/1988
From: Edgar G
NEWMAN & HOLTZINGER, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To: Bloch P, Jordan W, Mccollom K
Atomic Safety and Licensing Board Panel
References
CON-#188-5730 OL, NUDOCS 8803040057
Download: ML20147D584 (38)
v • d • e


Text

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Peter B. Bloch, Esquire Dr. Kenneth A. McCollom Chairman Administrative Judge -

Atomic Safety and Licensing 1107 West Knapp Board Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Elizabeth B. Johnson Washington, D.C. 20555 Oak Ridge National Laboratory P.O. Box X Building 3500 Dr. Walter H. Jordan Oak Ridge, Tennessee 37830 881 West Outer Drive Oak Ridge, Tennessee 37830 Re Texas Utilities Generating Company, et al.

Docket Nos. 50-445-OL and 50-446-OL

Dear Administrative Judges:

Enclosed herewith please find Applicants' sixth submission in response to the Board's request of August 12, 1987, for copies of Applicants' responses to "Notices of Violation" and "Notices of Deviations" issued by the NRC Staff. The enclosed responses cover the period January 27, 1988 to February 25, 1988.

Sine rely, f

George L. Edgar Enclosures

, cc: Service List 8803040057 080229

{DR ADOCK 0500 5 ()3 L

E'R P9 Log # TXX-88158 t

.- File # 10130

= = IR 87-11 IR 87-09 M/ ELECTRIC Ref # 10CFR2.201 ,

I,0,",ij7,U,, January 29, 1987 U. S. Nuclear Regulatory Comission ATTN: Document Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT NCS. 50-445/87-11 AND 50-446/87-09 REVISED DATE OF FULL COMPLIANCE FOR NOTICE OF v10LATION(NOV),ITEMA(445/8711-V-02,446/8709-V-02)

REF: TV Electric letter Txx-6777 from W. G. Counsil to NRC dated October 2, 1987 Gentlemen:

The referenced letter provided our response to Notice of Violation (NOV) Item A (445/8711-V-02: 446/8709-V-02), in that response we stated that by January 30, 1988, we would provide a description of additional corrective actions (if any) planned as a result of the ISAP VII.a.9 Results Report. Issuance of the Results Report has taken longer than expected. Accordingly our date for providing a description of any additional corrective actions is hereby revised to be no later than March 15, 1988.

Very truly yours,

.0 W. G. Couns 1 By:

D. R. Woodlan Supervisor, Docket Licensing RDD/mgt c - Mr. R. D. Martin, Region IV -

l Resident inspectors, CPSES (3) s 400 North We Streer LS 81 Deks. Tesss 13Mi

y .-

P9 Log

  • Tu 88136

_,, .-- File

  • 10130 IR 8513 TU: ._,. IR 85-09 w .m . , < . < .. . .., January 29, 1988-V. S. Nuclear Regulatory Comission Attn: Document Control Desk washington D. C. 20555

$UBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) 00CAET N05. 50-445 AND 50-446 INSPECTION REPORT N05. 50-445/85 13 AND 50-446/85-09 REvl5ED DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION, ITEM 0 REF: TV Electric letter Txx-6424 from W. G. Counsil to the USNRC dated May 6, 1987 Gentlemen:

The referenced letter provided our revised response to Notice of Violation, item 0 (445/8513-y 01). In that response we stated that electrical slee.a identification field verification activities for Unit 2 were scheduled for completion by January 31, 1988, with final design verification by March 31, 1988. To more efficiently utilize the resources available to CPSES, it has been necessary to reschedule completion of these activities.

Accordingly, our date for completion of both activities for Unit 2 (field verification followed by design verification) is hereby revised to be no later than Unit 2 fuel load.

Very truly yours, bbf W. G. Counsil By:

0. R. Woodlan Supervisor, Docka' I. i e: en s i ng PSB/grr c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3) 4cno Aorus ohn Streer LB 81 Dehas Toses ?!.'0!

M P9 Log # TXX-88158

,,, .- File # 10130

= = IR 87-11 IR 87 09 7UELECTRIC Ref f 10CFR2.201 72",h{n, January 29, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50-445 AND 50-446 INSPECTION REPORT NOS. 50-445/87-11 AND 50-446/87-09 REv! SED DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION (NOV), ITEM A (445/8711-V-02, 446/8709 V-02)

REF: TV Electric Letter TXX-6777 from W. G. Counsil to NRC dated October 2, 1987 Gentlemen:

The referenced letter provided our response to Notice of Violation (NOV) ltem A (445/8711-V-02; 446/8709-V-02). In that response we stated that by January 30, 1988, we would provide a description of additional corrective actions (if any) planned as a result of the ISAP Vll.a.9 Results Report. Issuance of the Results Report has taken longer than expected. Accordingly our date for providing a description of any additional corrective actions is hereby revised to be no later than March 15, 1983.

Very truly yours, b.b.

W. G. Couns 1 By:

D. R. Woodlan Supervisor, Docket Licensing RDD/mgt c - Mr. R. D. Martin, Region IV

  • Resident inspectors, CPSES (3) 000 Norsk Oton Streer LBof Deliss. Tesas 13.'0!

Log # TXX-88160 File # 10130 urun l" " 9

!"!?:!'

Ref f 10CFR2.201 January 29, 1987 WELEC E

% hem G. Coonsal Earren e s uo he~ sem V. S. Nuclear Regulatory Cocaission ATTN: Document Control Desk Washington, D.C. 20555

$UBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50-445 AND 50-446 INSPECTION REPORT NOS. 50-445/87-18 and 50-446/87-14 UPDATED RESPONSE TO NOTICE OF DEVIATION (N0D) 445/8718-D-10 REF:

TV Electric Letter TXX-6939 from W. G. Cour.sil to NRC dated December 7, 1987 Gentlemen:

ihe referenced letter provided our response to Notice of Deviation (N00) 445/8718-D-10 In that response we stated that by January 29, 1988, an update describing the results of our assessment of generic implications would be provided. Our updated response is attached. Those portion: of the response which have been revised are denoted by a revision bar in the right margin.

1 Very truly yours, W.G. W.0 W. G. Counsil By:

D. R. Woodlan Supervisor, Docket Licensing

. RDD/mgt Attachment I c - Mr. R. D. Martin, Region IV I J

Resident inspectors. CPSES (3) l 4

4 400 Norsk Otuw Surret LD 81 Denas. Teses HNI e

Attachment to TXX-88160 January 29, 1988 Page 1 of 4 NOTICE Or DEVIATION (445/8718-D-10 I Section 4.1, "Walkdown Guidelines," of Revision 1 to Impell Project Instruction (PI) 0210-052-004, states, in part, "The walkdown information will be documented using the checklists provided in attachment B.... Table 1 provides the acceptable tolerances to be used in the walkdown process.

"Guidelines are providedfor performing the conduit support and conduit routing walkdowns below....

"Item 5. Support Configuration

- Draw an as-built sketch

- Identify all structural /Unistrut member sizes, lengths...

"Item 6. Support Deficiencies

- Identify any gross deficiencies in the support...

"Item 7. Hilti Kwik Anchor Bolt information

- Identify letter stamp and Projection Length of all anchor bolts on supports...."

The following examples, identified by the NRC durin the post construction hardware validation program PCHVP)(g inspection module,and review Train C of Conduit Less Than or Equal to 2", are in deviation from the above criteria:

(1) For analysis tag A-03173 in Room 206, Impell incorrectly recorded the length designator on the end of a 1/4" diameter Hilti Kwik bolt as being an "E" stamp (3 1/2" long). The NRC ins designator to be a "0" stamp (3" long). pector observed the length (2) For analysis tag A-03173 in Room 206, it was determined during the NRC inspector's inspection that an 1/8" gap exists between the 3/4" diameter conduit and the conduit support shim plate, thus invalidating its three-way restraint design function. This invalidates all portions of the Impell analysis where this three-way support was considered.

(3) For analysis tag A ? ;U7 in Poom' 206, Impell had recorded that the projected length of the 1/4" diameter Hilti Kwik bolt was 3/4'. The subsequent NRC faspection determined this length to be 1 1/8". The specified allowable tolerance was 1/4".

(4) For Calculation No. A-03451 in Room 54, Impell had recorded on RFI No.

RF1-E5-1-1043, that Hilti kwik bolt No. I was located 4 1/2" from the top edge of the Unistrut channel. The NRC inspector, how e , determined the bolt to be located 3" from the edge. The specified allowable toleranre was 1/4".

e

Attachment to TXX PS160 January 29, 1988 Page 2 of 4 (5) For Calculation No. A-03138 in Room 54, Impell had recorded that the projected length of the 1/2" diameter Hilti Kwik bolt for support A-03145/NQ-08290 was 1". The subsequent NRC inspection determined this length to be 1 1/2". The specified allowable tolerance was 1/4" (445/8718-D-10).

In addition to the deviation specified above, the NRC inspectors have identified other discrepancies of a similar nature. These discrepancies have been presented as Open Items in NRC Inspection Report 50-445/87-25; 50-446/87-

19. The Open items are restated below:

"While performing the walkdown for Calculation L2-5-1-EC-130, the NRC inspector identified a discrepancy in the Impell work, it involved the span length between supports 2-23955 and 2-23956. Impell had recorded this span length as 40" while the NRC inspector detemined it to be 47 1/2." Subsequently, Impell stated that the level 6 interaction evaluation determined that there were no safety-related equipment, systems, or components in the room. Accordingly, no interactions (either acceptable or unacceptable) will occur in this room and the conclusions initially arrived at would not be affected. The NRC inspector concurred with this explanation; however, a detemination must still be made as to whether this error was an isolated case and what impact, if any, it would han with.on This other walkdowns that the identified individuals were involved

' subject is an open ites pending the making of this determination (445/8725-0-02).

"While performing the field walkdown on the Request for Field Information (RFI) data for the i.evel 5 calculation A 00631, the NRC inspector identified a discrepancy. It involved the span distance between supports A-00632 (N/Q-07192) and A-00633 (N/Q-07191). Impell had recorded this dimension as 11 1/2" while the NRC inspector determined it to be 35 1/2".

U)on notification of this discrepancy, Impell informed the NRC ins)ector t1at this error had occurred on Revision 0 of the calculation whici had been superseded by Revision 1 which states, "Supports in this calculation have been qualified by level 6." The Level 6 evaluation showed that no safety-related equipment existed in the vicinity of these su) ports. The NRC inspector verified that the supports were qualified.by tie Level 6 support interaction evaluation;..however, a determination must still be made as to whether this error was an isolated case and what impact, if any, it would have on other walkdowns that the identified individuals were involved with. This subject is an open item pending this determination (445/8725-0-03).

6

i Attcchment to TXX-88160 Jcnuary 29, 1988 Page 3 of 4 ,

l UPDATED RESPONSE TO DEVIATION (445/8718 0-10)

TV Electric agrees with the alleged deviation and the requested information follows: ,

1. Reason for Deviation The five discrepancies identified in the Notice of Deviation and the two discrepancies identified in the Open Items all resulted from inaccurate recording and checking of walkdown data un the part of personnel.
2. Corrective Steps Taken and Results Achieved The discrepant conditions described in items 1 through 4 of the Notice of Deviation were examined in the field by Impell personnel. The results of the examination confirwed the NRC inspectors observation in each case.

The applicable walkdown forms and calculations have been revised accordingly. In each case, the qualification status of the conduit support did not change.

The discrepant condition described in item 5 of the Notice of Deviation was examined in the field by Impell personnel. The results of the examination showed that the projection length of the 1/2 inch Hilti bolt I was 13/8 inches instead of 1 inch as recorded on the RFl. The applicable walkdown forms and calculations have been revised accordingly.

The qualification status of the support did not change.

The discrepant conditions described in Open items 445/8725-0-02 and -03 were examined in the field by Impell personnel. The results of the examination confirmed the NRC inspectors observation. However Impell had subsequently determined that for both cases, there was no s,afety related equipment in the vicinity per the t.evel 6 support interaction  ;

evaluation. He' ice, the discrepant calculations were rendered  !

unnecessary.

3. Corrective Steps Which Will be Taken to Avoid Further Deviations i Those engineers that are still on site who were involved in the walkdowns r that resulted in items 1 through 3 of the Notice of Deviation, as well as

- all other personnel involved in the structural integrity group have been retrained on the importance of documenting walkdown data accurately.

The Comanche Peak Manager of Civil Engineering has met with several groups involved in structural walkdowns, including the Impell Train C personnel. Examples of recently identified walkdown discrepancies were presented and the importance of accurate recordino .unt i hm. king of walkdoan data was re-emphasized. '

Impell train C project instructions have been reviewed for areas that could be misinterpreted which potentially affect the accuracy of field measurements. Clarifications have been made to instructions to improve measurement consistency when measuring spans with bends. Clarification has also been given to Train C project personnel regarding the need for documenting the use of conservative values when exact values are difficult or impossible to obtain.

~

Attachment to TXX-88160 January 29, 1988 Page 4 of 4 To assess the generic implications of walkdown discrepancies identified by the NRC, Impell has conducted a study and issued a report on the accuracy and adequacy of Train C walkdown data. The study included a review of audits and surveillances performed by various independent organizations. It was noted that no major deficiencies have been identified and that none of the deficiencies affected the qualification status of any Train C supports. The study also included a sample reinspection which covered 78 supports and encompassed a total of 5,271 attributes. The attribute discrepancy rate was found to be approximately 1.9% of which only 0.7% were unconservative. None of the discrepancies resulted in the disqualification of the affected conduit systems. Furthermore, it was demonstrated that Train C conduit systems generally exhibit large safety margins between demand and ultimate capacity.

Based on these results TV Electric does not consider edditional reinspection to be warranted. However, we are concerned with such errors and are endeavoring to reduce personnel errors through the training described above.

4. Date When ?ull Compliance Will be Achieved The Impell retraining of Train C walkdown personnel was completed by December 18, 1987.

The meeting of walkdown personnel with the Manager of Civil Engineering was held January 20, 1988.

, The clarification of Impell instructions was completed by January 22, 1988.

The Impell Accuracy and Adequacy of Walkdown Information Report was completed January 26, 1988.

(

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=

~.

Log i TXX-88162

" 9 Fi1e # 10130 1 = IR 87-31 r --

IR 87-23

' '*C' '0' 1UELECT'11C T,,*dN,$ , January 29, 1988 U. S. Nuclear Regulatory Commission ATTH: Document Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK S12AM ELECTRIC STATION (CPSES)

DOCKET N05. 50-445 AND 50-446 INSPECTION REPORT N05. 50-445/87-31 AND 50-446/87-23 UPDATED RESPONSE TO NOTICE OF DEVIATION (NOD) 445/8731-D-03 REF: TV Electric letter TXX-88081 from W. G. Counsil to NRC dated January 18, 1988 Gentlemen:

The referenced letter provided our response to Notice of Deviation (N00) 445/8731-0-03. In that resporse we stated that by January 29, 1988, an update describing the results of our essessment of generic implications would be provided. Our updated response is e ucched. Those portions of the response which have been revised are denoted by a revision oar in the right margin.

Very truly yours, W. G. Counsil By: O&,) /(m>__-

J6hn W. Beck ~ _

Vice President,

, Nuc'. ear Engineering RCD /mgt Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) 400 North Olive Stren LB 81 Dollst. Tous H201

Attachment to TXX-88162 January 29, 1988 Page 1 of 4 NOTICE OF DEVIATION

' (4457B731-0-03)

Section 4.1, "Walkdown Guidelines" of Revision 2 to Impell Project Instruction (PI) 0210-052-004 states, in part, "The Walkdown infonnation will be documented using the checklists provided in Attachment B . . . . Table 1 provides the acceptable tolerances to be used in the walkdown process.

"Guidelines for perfonning the conduit support and conduit routing walkdowns are provided below:

"Item 5. Support Confiauration

- Draw an as-built sketch

- Identify all structural /Unistrut member sizes, lengths . . ."

"Item 7. Hilti Kwik Anchor Bolt Infonnation

- Identifv letter stamp and projection length of all anchor bolts on supports . . ."

"Conduit Routing Checklist" "Item 1 Conduit Isometrics

- Draw an as-built sketch showing conduit routing . . .

- Detennine span lengths" Section 4.1.4, "Seismic Evaluation of Train C Conduit Supports," of Revision 3 to Impell PI 02310-052-003, states, in part, ". . . SSE support loads are generally calculated by multiplying the conduit tributary mass times the equivalent static acceleration . . . ." Paragraph 4.3.4 further states,

. . . for interaction of . . . loads, the following interaction . . .

equation shall be used . . . ."

The following examples, identified by the NRC during inspection and review of the post construction hardware validation program (PCHVP) module, Train C Conduit less Than or Equal to 2", are in deviation from the above criteria:

1. On the Type 7 support A-02456/NQ-16508, the NRC inspector idar+ifiso several discrepancies. The baseplate was reported to be 8" long but was foundbytheNRCinspectortobe9"long. Impell also repcrted that the anchor volts were 1/2" Hilti Kwik bolts; however, they were frand to be -

1/2" Hilti Super Kwik bolts. Impell reported that the Heison studs were 1/4" diameter while the NRC inspector determined these bolts to be 3/8" diameter.

Attachment to TXX-88162 January 29, 1988 Page 2 of 4 NOTICE OF DEVIATION (CONT'0)

(445/8731-D-03)

2. On the support identified as detail "B", a Type 7 support, impell reported that the anchor bolts were Hilti Kwik bolts; however, the NRC inspector determined that they were Hilti Super Kwik bolts.
3. On the isometric provided on page 4 of 8 in Appendix A of Calculation /oroblem No. A-02603, Impell reported a length of conduit between the Type 5 support identified as A-02628 and an adjacent Type 5 support as 21"; however, the NRC inspector determined this length to be 12 1/2".
4. In Calculatten/ Problem No. A-02454, while perfoming the load calculation for the northeast / southwest direction for support A-02605, the engineer neglected to include a 14" length of conduit between the support being evaluated and an adjacent support.
5. On the Type 5 support evaluation for support A-02605-NO-16507, the calculated embedment length for the Hilti Kwik bolt was found to be incorrect. Furthermore, the interaction check for the "finger" clamp exceecled the allowable and was justified by adding a note which stated that the calculation is conservative; however, this support is the same support mentioned in paragraph 4 above for which the load calculation is incorrect (445/8731-D-03).

UPDATED RESPONSE TO NOTICE OF DEVIATION (4437873TT)-03)

TU Electric agrees with the alleged deviation and the requested information follows:

1. Reason for Deviation The discrepancies identified in the Notice of Deviation resulted from inaccurate recording, checking and calculating of Train C (nun-safety related) 2 inch and under conduit walkdown data on the part of personnel involved.

i 2. forrective Steps Taken and Results Achieved The discrepant conditions described in the Notice of Deviation were -

examined in the field by Impell personnel. The results of the examination confirmed the NRC inspectors observation in each case. The information in the applicable walkdown forms and calculations have bean ravisad accordingly. In each case, the qualification status of the conduit system did not change. Deficiency Report C-87-4800 has been written to document I walkdown discrepancies. '

i 1

4 Attachment to TXX-88162 January 29, 1988 Page 3 of 4 UPDATED RESPONSE TO NOTICE OF DEVIATION (CONT'0)

(445/8731-0-03)

3. Corrective Steps Which Will be Taken to Avoid Further Deviations Those engineers that are still onsite and are involved in the subject walkdowns, as well as all other personnel involved in the Impell structural integrity group have been retrained on this subject, emphasizing the importance of error free walkdown data.

The Comanche Peak Manager of Civil Engineering has met with several groups involved in structural walkdowns, including the Impell Train C personnel.

Examples of recently identified walkdown discrepancies were presented and the importance of accurate recording and checking of walkdown data was re-emphasized.

Imoell Train C project instructions have been reviewed for areas that could be misinterpreted which potentially affect the accuracy of field measurements. Clarifications have been made to instructions to improve meosureme;it consistency when measuring spans with bends. Clarification has etso been given to Train C project personnel regarding the need for ducumenting the use of conservative values when exact values are difficult or impossible to obtain.

To assess the generic implications of walkdown discrepancies identified by the NRC, Impell has conducted a study and issued a report on the accuracy and adequacy of Train C walkdown data. The study included a review of audits and surveillances performed by various independent organizations.

It was noted that no major deficiencies have been identified and that none of the deficiencies affected the qualification status of any Train C supports. The study also included a sample reinspection which covered 78 supports and encompassed a total of 5,271 attributes. The attribute discrepancy rate was found to be approximately 1.9% of which only 0.7%

were unconservative. None of the discrepancies resulted in the disqualification of the affected conduit systems. Furthermore, it was demonstrated that Train C conduit systems generally exhibit In ge safety margins between demand and ultimate capacity. Based on these results TV Electric does not consider addit.ional reinspection to be warranted.

However, we are concerned with such errors and are endeavoring to reduce

, personnel errors through the training described above, l

1 L

i l

l l

Attachment to TXX-88162 January 29, 1988 Page 4 of 4

4. Date When Full Compliance Will be Achieved The correction of identified walkdown discrepancies was completed by December 30, 1987.

The Impell retraining of Train C walkdown personnel was completed by December 18, 1987.

The meeting of walkdown personnel with the Manager of Civil Engineering was held Jcnuary 20, 1988.

The clarification of Impell instructions was completed by January 22, 1988.

The Impell Accuracy and Adequacy of Walkdown Information Report was completad January 26, 1988.

e

,,, , , , . - , ~ - - - - - - - -e ------ , -

M 5E

Log # TXX-88165 File i 10130

= = IR 87-11 IR 87-09 TUELECTRIC Ref. # 10CFR2.201 william G. Counsil Lsecunn het bruarm January 29, 1988 U. S. Nuclear Regulatory Comission Attn: Document Control Desk Washington, D. C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT NOS. 50-445/87-11 AND 50-446/87-09 REVISED DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION (NOV), ITEM A (445/8711-V-02; 446/8709-V-02)

REFERENCE:

(1) TV Electric Letter TXX-6777 from W. G. Counsil to NRC dated October 2,1987 (2) TV Electric Letter TXX-7015 from W. G. Counsil to NRC dated November 30, 1987 Gentlemen:

l

' In Reference (2) we stated that reseoval of unauthorized splices and wire nuts from the Unit 1 and Unit 2 chiller panels per NCRs CE-87-10026 and -9610 would be completed no later than January 20, 1988. The Unit I work has been delayed by the need for a larger connection box cover. The Unit 2 work has been rescheduled in order to more efficiently utilize available resources.

l Accordingly, our date for removal of unauthorized splices from the Unit 1 l chillers is hereby revised to be no later than March 31, 1988. Our date for

' removal of unauthorized splices and wire nuts from the Unit 2 chillers is hereby revised to be no later than Unit 2 hot functional testing.

Very truly yours, i W. G. Counsil l

l ,

By: M.

Jpo W. Beck, Vice President i

i Nuclear Engineering RDD/mlh l

c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3)

MIO North ohvr Surret LBII Dellas. rew 7H01

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Log # TXX-88192

- File # 10130 3 --

IR 87-27 IR 87-20 1UELECTRIC Ret, o 10CFR2.201 William G. Counsil Earn,uve >we bewm February 1, 1988 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05, 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT N05.

50-445/87-27 AND 50-446/87-20 Gentlemen.

TV Electric has reviewed your letter dated December 31, 1987, concerning the inspection conducted during the period from October 7 through November 3, 1987. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2. Attached to your letter was a Notice of Violation.

We hereby respond to the Notice of Violation in the attachment to this letter.

Very truly yours, ,

! N. (9 W. G. Counsil By:

l 0. R. Woodlan Supervisor, Docket Licensing l RDD/mlh l Attachment c - Mr. R. D. Martin, Recion IV Resident inspectors, f.I'5E'. ' :'

I t

l _ .. - - -

Attach;ent to TXX-88192 February 1, 1988 Page 1 of 6

. NOTICE OF VIOLATION ITEW1

1. Criterion XVI of Appendix B to 10 CFR Part 50, as implemented by Section 16.0, Revision 0, of the TV Electric Quality Assurance (QA) Plan, requires measures to be established to assure that conditions adverse to quality; such as, deficiencies, deviations, and nonconformances be promptly identified, corrected, the cause of the condition determined, and corrective action taken to preclude repetition.

Contrary to the above, the applicant failed to take adequate corrective action when the deficient condition was identified on at least two separate occasions.

Ingersoll-Rand Company Letter 031-36281 dated June 22, 1978, to Gibbs &

Hill identified that the direction of rotation indicated on the auxiliary feedwater pump motor was opposite that of the pump. A Brown & Root speed letter dated June 28, 1978, transmitting the Ingersoll-Rand letter to construction for action, stated that the motors / pumps should be placed on hold when received on site and should be checked out and corrected as needed.

The reversed f an on the Unit 2 auxiliary feedwater (AFW) pump motor and a statement that this same condition could exist in Unit I were documented on Test Deficiency Report 4870 dated June 20, 1986.

Until asked by the hRC on May 19, 1987, the applicant failed to detennine the cause of the reversed fan on the Unit 2 AFW pump motor and failed to take adequate corrective actions to identify and correct the same deficiency which existed in Unit 1.

RESPONSE TO NOTICE OF VIOLATION ITEM 1 TV Electric accepts the alleged violation and the requested information follows:

1. Reason for Violation For clarity the two examples of inadequate corrective action are addressed

., separately below in the order in which they are presented in the Notice of Violation.

(1) The addressee of the speed letter is no longer on site and no evidence of an appropriate nonconformance document has been found.

We have concluded that rasponsible personnel failed to write a nonconformance document upon receipt of the Ingersoll-Rand letter and associated speed lettei in 1978. ,

(2) The system engineer who reviewed Test Deficiency Report (TOR) 4870 for Unit I applicability based his evaluation on the satisfactory Unit 1 Auxiliary Feedwater (AFW) motor operational test results.

From these results he correctly concluded that the AFW motors

  • l Attachment to TXX-88192 February 1,1988 Page 2 of 6 RESPONSE TO NOTICE OF VIOLATION 1TEH T lcont'd) received suf ficient cooling to perform their intended safety function. The design engineer who reviewed TDR 4870 based his ,

evaluation on an absence of deficiency documents on the Unit 1 AFW motors. However, both the system engineer and the design engineer failed to have the motor field checked to determine if the cooling f ans rotated backwards.

2. Corrective Steps Taken and Results Achieved (1) Proper rotation of the Unit 1 and Unit 2 AFW motors has been established. Due to work on electrical power supplies, proper rotation of the AFW pump motors will have to be reverified.

Following completion of the power supply work, proper motor rotation will be verified per XCP-EE-9, "Initial Motor Rotation and Run in."

(2) The fans on the Unit 2 AFW motors have been properly oriented. The Unit 1 AFW motors have been removed for various maintenance work including re-orienting the fans.

A review of motor requirements (manuals, drawings) was performed to ensure that cooling fans on other safety-related motors would be installed with proper rotation. Twenty-four of these motors were found to have fans designed to rotate in either direction. Four other motors were found to have unidirectional fans. These four motors were field checked and found to have proper fan rotation.

TV Electric has confirmed, via a review of pre-operational test results that, although the fans were rotating backwards, the AFW motors received sufficient cooling to perfom their intended safety function. Therefore, had the plant been in operation, the reversed fan rotation would not have required entering an action statement for a Technical Specification Limiting Condition for Operation. TV Electric has also concluded that, had proper fan rotation been critical to the performance. of the AFW pump motor, pre-operational testing would have detected inadequate cooling and the fan

, orientation would have been corrected.

, 3. Corrective Steps Which Will be Taken to Avoid Further Violations (1) Our programs for control of vendor correspondence, review of vendor documents, control of nonconformances, and control of deficiencies have all been revised since 1978. These programs are currently governed by procedures ECE 1.05. "Correspondence Control." ECE 5.19-03, "Vendor Document Pa"ian VOC and VDI," NE0-3.05, "Reporting and Control of Nonconformw n," and NE0-3.06, "Reporting and Control of Deficiencies," respectively. These progra'ms provide assurance that such vendor correspondence is routed to the appropriate organization, properly reviewed, and nonconformance or deficiency documents issued where appropriate. Personnel have been trained on these programs.

I Attachment to TXX-88192 {

February 1,1988 Page 3 of 6 RESPONSE TO NOTICE OF VIOLATION ITEM 1 (Cont'd)

(2) The circumstances involved in this violation have been discussed with System Engineers. The System Engineers have been retrained on the importance of thoroughly investigating potential nonconformances and deficiencies.

The "design engineer" function is now performed by Comanche Peak Engineering (CPE) and engineering contractors. Appropriate personnel in these organizations will be trained on the circumstances involved in this violation and the importance of thoroughly investigating potential nonconformances and deficiencies.

4. Date When Full Compliance Will be Achieved The training of appropriate CPE and engineering contractor personnel will be completed no later than April 1, 1988.

Reorientation of the Unit 1 AFW fans and reinstallation of the motors will be complete by June 1, 1988.

e 5

--,p. , - - - , - , - . -

Attachment to Txx-88192 February 1,1988 Page 4 of 6 NOTICE OF VIOLATION ITEM 2

2. Criterion V of Appendix 8 to 10 CFR Part 50, as implemented bv Section 5.0, Revision 3, dated July 31, 1984, of the TU Electric Quality Assurance Plan (QAP), requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.

Paragraph 6.0 of TV Electric Prerequisite Test Procedure XCP-EE-9, Revision 6, requires a review of the Westinghouse instruction which states that the blower fan must be reversed if-power leads are reversed. That instruction also states that Westinghouse should be contacted when the direction of motor rotation is changed because unidirectional fans were used. Paragraph 4.15 and 7.7 of the test procedure requires the verification of correct termination and motor rotation.

Contrary to the above, test requirements and Westinghouse instructions were not followed when Unit 1 AFW motors were tested in 1982. As a result, the unidirectional fans in the AFW setors were not reversed when the power ieads of the motors were changed to reverse the direction of motor rotation.

RESPONSE TO NOTICE OF VIOl.ATION ITEM 2 TV Electric accepts the alleged violation and the requested information follows:

1. Reason for Violation Startup personnel overlooked the requirements in the Westinghouse manual note to reverse the orientation of the fan when changing the direction of motor rotation. Regarding the alleged failure to contact Westinghouse, the last sentence of the note states, "Refer to the nearest Westinghouse sales office for assistance." If startup personnel had reversed the fan orientation, Westinghouse assistance would not have been required.
2. Corrective Steps Taken and Results Achieved

, The fans on the Unit 2 AFW motors have been properly oriented. The Unit 1 AFW motors have been removed for various maintenance work including re-orienting the fans.

As stated in our response to item 1 of this Notice of Violation, we have determined that similar fan rntation discrepancies do not exist for other safety-related motors. We hava also deter:nined.that the raversed f an

, rotation would not have preeunted the AFW motors from performing their intended safety function and that reversed fan Totation would not have resulted in entry into a Technical Specification Action Statement. We have concluded that, had proper fan rotation been critical, pre-operational testing would have detected the reversed fan orientation.

l

Attachment to TXX-88192 F eb rua ry 1, 1988 Page 5 of 6 RESPONSE TO NOTICE OF VIOLATION ITEM 2

3. Corrective Steps Which Will be Taken to Avoid Further Violations Startup test engineers have been instructed concerning this violation and have been cautioned to be particularly observant of motor rotation requirements.

A change to Startup procedure XCP-EE-9, "Initial Motor Rotation and Run,"

is being prepared which will require initiation of a Test Deficiency Report if the rotation direction of a motor is different from the arrow indication specified by NEMA requirements. This will provide assurance that an adequate technical review is performed and documented when motor rotation must be changed from that specified by the vendor.

4. Date When Full Compliance Will be Achieved The change to XCP-EE-9 will be made effective no later than March 15, 1988.

Reorientation of the Unit 1 AFW fans and reinstallation of the motors will be complete by June 1, 1988.

e

Attachment to TXX-88192 February 1, 1988 Page 6 of 6 NOTICE OF VIOLATION ITEM 3

3. Criterion III of Appendix B to 10 CFR Part 50, as implemented by Section 3.0, Revision 4, dated November 20, 1985, of the TV Electric Quality Assurance Plan requires that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions and that design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews.

Contrary to the above, the applicant failed to assure that design requirements were correctly translated into specifications, drawings, procedures, and instructions in that the rotational direction of the AFW pump / motor combination was not clearly and consistently described. For example, the motor specification attached to GH letter 6639, dated January 29, 1976, shows that Westinghouse proposed a clockwise rotation as viewed from coupling end. Pump bid package Specification 2323-MS-7 specified counter clockwise from the outboard end. While Revision 1 of pump Specification 2323-MS-7 attached to TV Electric Purchase Order CP-0007 dated May 2,1975, specified counter clockwise rotation without identifying from which end of the pump.

RESPONSE TO NOTICE OF VIOLATION ITEM 3 TV Electric accepts the alleged violation and the requested information follows:

1. Reason for Violation The specifications for the motor driven Auxiliary Feedwater (AFW) pumps and motors did not clearly specify the direction of rotation.
2. Corrective Steps Taken and Results Achieved Design (,hange Authorizations (OCA)-62373 and -62374 have been issued to change Specifications 2323-ES-10, "Electrical Motors," and 2323-MS-7,

, "Auxiliary Feedwater Pumps," respectively. These DCAs change the specifications to clearly indicate the direction of motor and pump rotation.

3. Corrective Steps Which Will be Taken to Avoid Further Violations All specifications associated with safety-related system structures and componer.ts are being reviewed and updated. Although the review is not being conducted in respons- i.. this specific vi'olation, it will provide assurance of the overall ad-pin y of the specifications.
4. Date When Full Compliance Will be Achieved The specification review associated with safety-related system structures and components will be complete by September 1,1988.

(,

(

= =

FE Log i TXX-88199 Fi1e # 't%99 TPK r r IR 86-03 86-02 7UELECTRIC Ref. , 10CFR2.201

  • l,"'"

,, tfy,","1,, February 4, 1988 U. S. Nuclear Regulatory Comission Attn: Document Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NO. 50-445 REVISED DATE OF FULL COMPLIANCE FOR NOTICE OF DEVIATION ITEM B (445/8603-0-18)

Gentlemen:

( The TV Electric response to Hotice of Deviation (N00) Item B (445/8603-0-18)

(reference TXX-6997 dated November 25, 1987) stated that full compliance would be achieved by December 31, 1987; however, as of this date, the review of attributes for each construction work category (CWC) has not been completed.

A more extensive review of the attributes for the CWCs is being performed than was originally scheduled. This more extensive review has resulted in the date of compliance not being achieved as scheduled. Our revised schedule is to attain full compliance by March 15, 1988.

Very truly yours, W. G. Counsil By: .

JpnW. Beck Vice President, -

Nuclear Engineering .'

GLB/grr c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3)

(,

M l"" 9 Log # TXX-88218

.._- .-- Fi1e # 10130 C C IR 87-32 1R 87 24 1UELECTRIC p,1,onocyp2:201 w a m c.cou.ii February 24, 1988 zu~,, a s aa ne,.a.,

U. 5. Nuclear Regulatory Cceission Attn: Document Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT N05. 50-445/87-32 AND 50-446/87-24 Gentlem?n:

TV Electric has reviewed your letter dated January 25, 1988, concerning the inspection conducted by Mr. C. J. Hale and NRC consultants during the period December 2,1987 through January 5,1988. This inspection covered activities authorized by NRC Construction Peruits CPPR-126 and CPPR-127 for CPSES Units 1 and 2. Attached to your letter was a Notice of Violation and a Notice of Deviation.

We hereby respond to the Notice of Violation and Notice of Deviation in the attachment to this letter.

Very truly yours, CA W. G. Counsil ROD /clk Attachment c-Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3)

  1. 0 North Oh Sorres LB DI Dettas. Teses ?)'01 1

Attachment to TXXo88218 FQbruary 24, 1988

, Pago i of 4 NOTICE OF VIOLATION (445/8732-v-01; 446/8724-V-01)

Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TU Electric Quality Assurance Plan (0AP), requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.

TV Electric Procedure NE0 3.06, "Reporting and Control of Deficiencies,"

requires that the disposition of each identified deficiency include the determination of the cause or causes of the deficiency and the action necessary to prevent recurrence.

Contrary to the above, the disposition of four deficiency reports reviewed during this inspection (C87-949, C87-2761, C87-3235, and C87-3787) had not established the cause or causes of the deficiencies and therefore the stated action to prevent recurrence was indeterminate (445/8732-V-01; 446/8724-V-01).

RESPONSE TO NOTICE OF VIOLATION (445/8732-V-01; 446/8724-V-01)

TV Electric accepts the alleged violation and the requested information follows:

1. Reason for Violation The four deficiency reports (DRs) identified in the Notice of Violation were reviewed and the results of tnis review are as follows:

OR C87-949 was issued when an attribute on an inspection Report (IR) was changed from "N/A" to "Sat" by a QC Inspector other than the original inspector. The change was signed and dated at the time it was made. The inspector who made the change was qualified to perform the type of inspection described on the IR; however, he did not provide justification for not having the change made by the original inspector as required by N0A 3.09-001. The individual has stated that he is awsre of the requirements of N0A 3.09-001, and that the requirement was snyly overlooked in this instance.

OR C87-2761 was issued due to identification of a change to an IR by an unkncwn person. The inspector of record has included an inappropriate reference in the remarks section of the IR, and an unidentified individual had added the phrase "No Ref. Used." The inspector of record was reminded of the need to include the phrase on' future irs. A survey of similar irs was performed to determine the extent of unauthorized IR entries which demonstrated that the incidence of occurrence was low.

OR C87-3235 was issued due to the inclusion of a marked up copy of an NCR page in a work package. Thir ma,ked up page included reference to a cable which was not referenced in tr.e original NCR. The OR indicates that the copy was inadvertently included ir, cne w rk package. A review of other work packages required to contain copies of the same NCR was performed bj i l

l

Attachment to TXX-88218 February 24, 1988 Fago 2 of 4 I

, Paper Flow Group (PFG) personnel which indicated that the condition was isolated to the work package identified in the DR.

OR C87-3787 was issued when an inspector was requested to correct an earlier omission of the words "No Ref. Used" on an IR. The insper. tor made the appropriate corrections however did not include his signature and the  !

date as required by procedure. In discussion with the inspector, he  !

stated that he was familiar with the requirement; however, he had forgotten to include his signature and the date.

~

In each of the four cases described, a documentation error was made on an inspection report or in a work package which was identified by TV Electric and resulted in issuance of a Deficiency Report to describe the corrective actions taken. The cause described on each DR indicated that an error was made and/or an action occurred inadvertently.

The cause of this violation was inadequate direction to personnel regarding the degree of specificity required in documenting the cause or causes of the deficiencies.

2. Corrective Steps Taken and Results Achieved The four ors identified in the Notice of Violation have been reviewed to assure that the preventive actions are appropriate for the identified deficiency. In each case it was determined that the cause was addressed sufficiently to assure appropriate corrective measures were taken, and the actions taken are adequate to prevent recurrence based on the extent and nature of the deficiencies.
3. Corrective Steps Which Will be Taken to Avoid Further Violations As described in the NRC Inspection Report, the concern regarding unauthorized entries on documents was evaluated in an attachment to DR C87-2761. As described in the evaluation results, the incidence of occurrence was very small, and does not represent a condition requiring further corrective measures. The documents which were identified did not represent a safety concern or affect hardware. It was detemined that the ors identified the appropriate preventive action, and no additional specific actions were needed.

The QC Services Supervisor has issued a memorandum to his organization informing them of the nature of this violation. This group is responsible for providing QA concurrence with construction related OR dispositions, in this capacity, the group reviews the statement of cause and preventive i actions included on the OR based upon the deficiency description and l investigations when appropriate.

4. Date When Full Compliance Will Be Achieved Full compliance has been achieved.

Attachment to Txx-88218 February 24, 1988 Page 3 of 4

. NOTICE OF DEVIATION (445/8732-0-02)

Section 5.1.2, of Comanche Peak Review Team (CPRT) Procedure CPP-27, Revision 2, required that CPRT QA/QC engineers review design specifications and/or design drawings and develop a checklist of attributes that require reinspection and/or verification by documentation review. Those attributes not included on the checklist were to be identified and the justification for their exclusion documented on a memorandum.

Memorandum QA/QC-RT-6683 stated that supplemental Verification Package I-H-VII.a.9-050-01 was issued to inspect the pressure boundary materials and welds of the chiller unit, CP1-CHCICE-05.

Contrary to the above, supplemental Verification Package I-M-VII.a.9-050-01 did not identify for inspection eight groove welds specified by vendor Drawings 376-09354, 376-09355, 376-09356, and 376-09357; all at Revision D.

The verification package also failed to identify a fillet weld required by vendor Drawing 376-09087, Revision 0, sheet 5. These welds were required to have been included in the above supplemental verification package, but they were not and no memo justifying their exclusion was prepared (445/8732-0-02).

RESPONSE TO NOTICE OF DEVIATION

, (445/8732-0-02)

TV Electric accepts the alleged deviation and the requested information follows:

1. Reason for Deviation The ISAP OA/QC Engineer incorrectly determined that the identified welds were inaccessible. This is evident in memorandum QA/QC-RT-6683, dated 4/10/87, which states: "The welds not identified for inspection on the drawings are either inaccessible or are covered by insulation."
2. Corrective Steps Taken and Results Achieved Supplemental Verification Package I-M-VII.a.9-050-07 was issued on 12/09/87 for reinspection of the nine excluded welds. The inspection of these welds was completed on 12/17/87 and all nine welds were determined to be acceptable.

l

3. Corrective Steps Which Will be Taken to Avoid Further Deviations Supplemental Verification Package 1-H-Vil.a.9-051-01 contained the same error on an identical chiller unit. CP2-CHCICE-05. This error was corrected in conjunction with the discrepancy identified in this Notice of i Deviation. Furthennore, all other verification packages that had been prepared by the responsible ISAP QA/QC Engineer have been reviewed and no

, other discrepancies were identified. This review was completed by 1/19/88.

t

Attachment to TXX-88218 FGbruary 24, 1988 Page 4 of 4

4. Date When Full Compliance Will be Achieved Full compliance was achieved on January 19, 1988, with the completion of the review identified in item 3 above.

J P

M EE Log # TXX-88219

._ , .- File # 10130 r r IR 86-22 IR 86-20 7UELECTRIC Ref # 10CFR2.201 wmim c.c m in February 15, 1988 im...., s .e neuenz U. S. Nuclear Regulatory Commission Attn: Docucent Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50-445 AND 50-446 INSPECTION REPORTS N05. 50-445/86-22 AND 50-446/86-20 REVISED DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION ITEM A (445/8622-V-02, 446/8620-V-03)

REFERENCE:

(1) TU Electric letter TXX-6993 from W. G. Counsil to NRC dated November 20, 1987 Gentlemen:

Reference (1) provided a revised date of full compliance to NOV Item A (445/8622-V-02; 446/8620-V-03), in that letter we stated that nonconformance documents would be dispositioned by February 15, 1988. Due to unanticipated delays in obtaining related information from the valve supplier (Crosby),

disposition and closure of these nonconformance documents is expected to be coniplete by April 15, 1988.

Additionally, Reference (1) stated that a response delineating any required additional corrective action that may result from ISAP Vll.a.9 would be provided by February 15, 1988. This was based upon an expected ISAP Vll.a.9 completion by mid January. Currently, publication of ISAP Vll.a.9 is not expected before early March 1988. Consequently, our response delineating any additional corrective action will be provided by April 15, 1988.

Very truly yours, W. G. Counsil

?00/ck C-Mr. R. D. Hartin, Region IV Resident inspectors, CPSES (3) 400 krth ohvr Strero LB 81 Delles. Toses 7H01

. M

=E Log # TXX-88220 1.-

j File # 10130 r C IR 87-30 1R 87 22 1UELECTRIC peg, o gncypg,gog u n= c. coona February 16, 1988 becunvrkwr hess4ros V. 5. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

SUBJECT:

C0HANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT N05. 50-445/87-30 AND 50-446/87-22 Gentlemen:

We have reviewed your letter dated December 16, 1987, concerning the inspection conducted by Mr. P. C. Wagner during the period from November 4 through December 1, 1987. This inspection covered activities authorized by NRC Construction Pennits CPPR-126 and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2. Attached to your letter was a Notice of Violation.

On January 12, 1988, per a telephone conversation with Mr. R. F. Warnick, we requested and received an extension as follows: Item B (445/8730-V-07) extended until February 15, 1988.

We hereby respond to the Notice of Violation in the attachment to this letter.

Very truly yours, (d.(sC M W. G. Counsil By: #

l 0. R. Woodlan Supervisor, Docket t.icensing ROD /ck l Attachment c-Hr. R. D. Hartin, Region IV l Resident inspectors, CPSES (3) l l

l 400 North Olns Streer LB SI Dettu Tew 1R01

Attachment to TXX-88220

. FQbruary 16, 1988 Page 1 of 2 NOTICE OF VIOLATION I ER B (445/8730-V-07)

8. Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3 of the TV Electric QAP dated July 31, 1984, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.

Paragraph 2.1.3. of THE Procedure THE-DC-7, Revision 16, dated February 14, 1986, "Preparation and Review of Design Drawings," requires that completed drawings shall be checked for accuracy and compliance.

Paragraph 2.1.4 also requires an engineering review for technical accuracy upon completion of the drafting / design check.

Contrary to the above, drawings were not appropriately reviewed / checked for accuracy as evidenced by the differences which existed between the two sets of electrical schematic drawings for the emergency diesel generator control panels. Examples of these differences were most evident in the circuitry for solenoids 6A and 6B and relay contact numbers and arrangements (i.e., RX/1B and 10x) on Drawings 09-500-76001, Sheet 3 and THE-El-0067, Sheet 96 (445/8730-V-07).

RESPONSE TO NOTICE OF VIOLATION ITEM B (445/8730-V-07)

TV Electric agrees with the alleged violation and the requested information follows:

1. Reason for Violation Sheet 96 of Drawing THE-El-0067 was prepared by our engineering contractor and issued in 1984. Sheet 96 of the THE drawin replacement for Sheet 3 of the vendor (Delaval)g was intended supplied to be a drawing 09-500-76001. Sheet 3 of the vendor drawing was the only sheet of that drawing replaced by a TNE drawing. Since Sheet 3 of the vendor drawing was to be replaced it was not kept current. However, except for the period f rom October 1986 to October 1987, Sheet 3 of the vendor drawing was kept as an active drawing even though it was not kept current.
2. Corrective Steps Taken and Results Achieved We have conducted a detailed comparison of Sheet 3 of the vendor drawing and Sheet 96 of the THE drawing. This comparison determined that discrepancies between the two sheets, including those described in the Notice of Violation, are accounted for by engineering changes and Design Change Authorizations (OCAs) that were incorporated in the original issue of Sheet 96 of the THE drawing, or DCAs that are currently outstanding against Sheet 96 of the THE drawing. The results of the comparison provide assuiance that 5heet 96 of the THE drawing has been kept current and accurate.

Attachment to TXX-88220 February 16, 1988 Page 2 of 2 As part of diesel generator functional testing, a point to point wiring verification was performed on the diesel generator control panel. This verification was performed using Sheet 96 of the THE drawing. This indicates that the failure to keep Sheet 3 of the vendor drawing current did not result in any hardware discrepancies.

Sheet 3 of the vendor drawing will be made inactive. There are ten additional vendor drawings associated with the diesel generator control circuitry that may not have been kept current because of replacement THE drawings. These ten drawings will also be reviewed and dispositioned as appropriate. A Vice Presidential directive was issued July 17, 1986, stating that where design and vendor documents conflict, the design document takes precedence. This directive provides assurance that the THE drawings will take precedence while the vendor drawings are being reviewed. Note that "TNE", as a drawing designator, is being replaced by the "ECE" designator. New documents are designated as "ECE", but the "TNE" designator will remain effective for previously issued drawings unless subsequently revised for technical reasons.

3. Corrective Steps Which Will be Taken to Avoid Further Violations We have determined that there are other vendor drawings that have equivalent THE drawings and that may not have been kept current with all design changes. Examples of such drawings are the Westinghouse elementary wiring drawings and the Westinghouse fluid system flow diagrams.

Deficiency Report (OR) C-88-00872 has been written to provide corrective action for this condition.

Our procedure for drawing control is being revised and renumbered. The new procedure ECE-5.05, "Preparation, Review and Approval of Design Drawings," will contain measures to assure that vendor drawings are voided if replacement ECE drawings are issued.

4. Date When Full Compliance Will be Achieved Sheet 3 of the vendor drawing will be made inactive no later than April 15, 1988.

The review and dispositioning of the ten additional diesel generator control vendor drawings will be completed no later than May 15, 1988.

ECE-5.05 will be issued no later than April 15, 1988.

DR C-88-00672 will be dispositioned no later than June 15, 1988.

' M FE Log # TXX-88222 File # 10130 r = IR 86-03 IR 86-02 7UELECTRIC Ref. # 10CFR2.201

%illiam G. Counul em ,,,, n, n,una, February 12, 1988 V. S. Nuclear Regulatory Commission Attn: Document Control'0esk Washington, D. C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT 50-445/86-03 AND 50-446/86-02 BASE METAL DEFECT REF:

(1) TV Electric Letter TXX-6964 from W. G. Counsil to NRC dated November 20, 1987 (2) TO Electric Letter TXX-7131 from W. G. Counsil to NRC dated December 31, 1987 Gentlemen:

The letter identified in reference 1 provided supplemental information concerning base material defects. The letter identified in reference 2 provided information relative to the Field Verification Method (CPE-CPE-FVM-ME-Il4) used to validate (for base material defects due to grinding) welds from a representative sample of 60 pipe supports. This work activity has been completed, and based on the inspection criteria delineated in the FVM, no adverse findings related to base material defects due to grinding were observed. A full report summarizing the inspection results is available on site for your review.

Very truly yours, 9 14 W. G. Counsil BSD/grr c - Mr. R. O. Martin, Region IV Resident inspectors, CPSES (3) ooo neth ohn surrer LB 81 Den u. Teses P R OI

M

=M Log # Txx-88246 1-j File # 10130 r = IR 87-18 IR 87-14 7UELECTRIC Ref. # 10CFR2.201 w n. c. co a February 19, 1988 in n .,< vca nam e s U. S. Nuclear Regulatory Comission Attn: Document Control Desk Washington, D. C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50-445 AND 50-446 INSPECTION REPORT 50-445/87-18 AND 50-446/87-14 REVISED OATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION (NOV) ITEM B (445/8718-V-09) AND (NOV)

ITEM C (445/8718-V-08)

REFERENCE:

1) TV Electric Letter TXX-6939 from 4. G. Counsil to NRC dated December 7, 1987
2) TV Electric Letter TXX-7139 from W. G. Counsil to NRC dated December 31, 1987 Gentlemen:

Reference (2) provided a revised date of full compliance to NOV Item B (445/8718-V-09) and NOV Item C (445/8718-V-08). In that letter we stated that CAR 87-78, NCRs M-87-A01921 and M-87-A01852, ors C-87-3884 and C-87-3885 would be clostd by February 19, 1988. These documents have been closed with the exception of CAR 87-78 and NCR M-87-A01852 (the above referenced letters had mis-identified the NCR as M-87-A10852). Currently, CAR 87-78 requires verification of corrective action completion prior to closure. The concern identified on NCR M-87-A01852 was transferred to NCR CM-87-11028, R1 for resolution. Our date for closure of the CAR and the NCR is revised to April 22, 1988.

Very truly yours, i

W. G. Counsil ROD /cik C-Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3) 400 North Ohwr 5stres LB 81 Deliss. Tous 73201

l===" 9 Leg # Txx-88253 1 C File # 10130 C C 1R 86-07 IR 86-05 nlELECTRIC p,1, o nocygg,gog wm . c.conui February 24, 1988 e w w,,,>.a ne n .,

U. S. Nuclear Regulatory Comission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50-445 AND 50-446 INSPECTION REPORT N05. 50-445/86-07 AND 50-446/86-05 REVISED DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION, ITEM E (445/8607-y-22)

REFERENCE:

1) TV Electric Letter Txx-7013 from W. G. Counsil to NRC dated November 30, 1987 Gentlemen:

The referenced letter stated that DCA 31,277, Rev. I would be incorporated into drawing 2323-El-0156 no later than February 24, 1988. The field work associated with this DCA is not yet complete. The required field work and subsequent incorporation of DCA 31,277, Rev.1 into drawing 2323-El-0156 is now estimated for completion no later than November 30, 1988.

Very truly yours, 4

W. G. Counsil ROD /clk c Mr. R. O. Martin, Region IV Resident Inspectors, CPSES (3) 400 North Olive Sorres LB 81 Dollas. Toses 13.'01 .

00LXETED

- UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION 18 FSB 29 P3:45 before the  ;

ATOMIC SAFETY AND LICENSING BOARD f0bkift b! fib [.

BRANCH

)

In the Matter of ) Docket Nos. 50-445-OL

) 50-446-OL TEXAS UTILITIES GENERATING )

COMPANY et al. )

) (Application for an (Comanche Peak Steam Electric ) Operating License)

Station, Units 1 and 2) )

)

CERTIFICATE OF SERVICE I, Thomas A. Schmutz, hereby certify that the foreaning

. Notices of Violations and Notices of Deviations were served this 29th day of February 1988, by mailing copies thereof (unless otherwise indicated), first class mail, postage prepaid to:

  • Peter B. Bloch, Esquire *B. Paul Cotter, Jr., Esq.

Chairma'. Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 I

  • Alan S. Rosenthal, Esq. Assistant Director for Chairman Inspection Programs Atomic Safety and Licensing Comanche Peak Project Division L Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission P.O. Box 1029 Washington, D.C. 20555 Granbury, TX 76048
  • / Asterisk indicates service by hand or overnight courier.

m -m.~ ___--,-,_----_-__._~-r, - _ - , . _ _ _ _ . . - - - - - - - _ _ , - , _ _ - - - - - - - - - _ _ ,,.v,_-- . . - - ,

s .

  • Juanita Ellis Robert D.- Martin President, Cass Regional Administrator, 1426 S'.iuth Polk Street Region IV Dallas, TX 75224 U.S.-Nuclear Regulatory Commission William R. Burchette, Esquire 611 Ryan Plaza Drive Eeron, Burchette, Ru c'Ae r t , Suite 1000

& Rothwell Arlington, Texas 76011 Suite 700 1025 Thomas Jefferson St., N.W. *Dr. Kenneth A. McCollom Washington, D.C. 20007 _ Administrative Judge 1107 West Knapp

  • William L. Clements Stillwater, Oklahoma 74075 Docketing & Service Branch U.S. Nuclear Regulatory Joseph Gallo, Esquire Commission Hopkins & Sutter Washington, D.C. 20555 Suite 1250 1050 Connecticut Avenue, N.W.

Government Accountability Project *Janice E. Moore, Esquire Midwest Office Office of the General Counsel 104 E. Wisconsin Avenue - B U.S. Nuclear Regulatory Appleton, WI 54911-4897 Commission Washington, D.C. 20555 Renea Hicks, Esquire Assistant Attorney General

  • Anthony Roisman, Esquire Environmental Protection 1401 New York Avenue, N.W.

Division Suite 600 Capitol Station Washington, D.C. 20005 P.O. Box 12548 Austin, Texas 78~01 Lanny A. Sinkin Christic Institute Robert A. Jablon, Esquire 1324 North Capitol Street Spiegel & McDiarmid Washington, D.C. 20002 1350 New York Avenue, N.W.

Washington, D.C. 20005-4798 Nancy Williams CYGNA Energy Services, Inc.

  • Elizabeth B. Johnson 2121 N. Crlifornia Blvd.

Oak Ridge National Laboratory Suite 390 P.O. Box X Building 3500 Walnut Creek, CA 94596 0.;k Ridge, Tennessee 37b),

David R. Pigott

  • Dr. Walter H. Jordan Orrick, Herrington & Sutcliffe 881 West Outer Drive 600 Montgomery Street Oak Ridge, Tennessee 37830 San Francisco, CA 94111

l:

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.* Robert A. Wooldridge, Esquire Worsham, Forsythe, Sampels

& Wooldridge 2001 Bryan Tower, Suite 3200 Dallas, Texas 75201

  • W. G. Counsil Executive Vice President Texas Utilities Electric -

General Division 400 N. Olive, L.B. 81 Dallas, Texas 75201

/ / >

r ..

dGb [/ &}'[fkV TR'omas A. Schrautz .

Dated: February 29, 1988 i

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