ML20147E627

Responds to NRC Re Violations Noted in Insp Repts 50-445/87-30 & 50-446/87-22.Corrective Action:Startup Group Will Perform Complete Verification of Unit 2 Diesel Generator Control Panels as Part of Functional Test

ML20147E627
Person / Time
Site:	Comanche Peak
Issue date:	01/15/1988
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-88079, NUDOCS 8801210180
Download: ML20147E627 (5)

Text

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== Log i TXX-88079 r7 File # 10130

. C IR 87-30 r r IR 87-22 Ref. # 10CFR2.201 7UELECTR/C w mam c. coumii January 15, 1988 Execuan, ske Pres >Jent 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 NOS. 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 Permits 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 8 (445/8730-V-07) extended until February 15, 1988.

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

Very truly yours, 7kN W. G. Counsil ROD /mlh Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)

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- a Attachment to TXX-88079 January 15, 1988 Page 1 of 4 NOTICE OF VIOLATION IfEM A (445/8730-V-06)

A. Criterion III of Appendix B to 10 CFR Part 50, as implemented by Section 3.0, Revision 3, dated July 31, 1984, of the TV Electric Quality Assurance Plan (QAP), requires in part, that measures must be established to assure that applicable regulatory requirements and design bases, as defined in Part 50.2 and as specified in the license application, for those structures, systems and components to which this appendix applies, are correctly translated into specifications, drawings, procedures, and' instructions. The design control measures must provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods,.or by the performance of a suitable testing program. In addition, design changes, including field changes, must be subject to design control measures commensurate with those applied to the original design.

Contrary to the above, the NRC inspector identified two capacitors connected in parallel with a relay coil located in both Unit 1 emergency diesel generator control panels that were not shown on facility electrical drawings nor described in any associated documents (445/8730-V-06).

RESPONSE TO NOTICE OF VIOLATION ITEM A (445/8730-VTu61 l

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

1. Reason for Violation No documentation could be found which indicated that the capacitors were installed subsequent to receipt of the panels at CPSES. The wire markers and lugs used for the capacitor installations are identical to those used elsewhere in the vendor (IM0 Delaval) supplied control panel. A vendor representative has stated that the capacitors could have been vendor installed. However, the personnel who designed the circuit are no longer with Delaval and Delaval had no records of the capacitors being installed.

For the above reasons, TV Electric believes that the capacitors were vendor installed, and that the vendor failed to show the capacitors on the applicable drawings as required by the diesel generator purchase specification.

_ Attachment to TXX-88079 January 15, 1988 Page 2 of 4

2. Corrective Steps Taken and Results Achieved The subject capacitors were originally identified by our Startup Group during a point to point verification of control panel wiring performed as part of diesel generator functional testing. The Startup engineer noted that capacitors were not shown on the electrical drawings. He relocated the capacitors outside their cable bundle for easier visibility intending to further evaluate the apparent discrepancy. Subsequently, the NRC inspector observed the capacitors and informed TV Electric of his concern.

Test Deficiency Report (TDR) 5597 and Nonconformance Report (NCR) 87-02828 were written to document the discrepancy. The point to point verification of the wiring in both Unit I diesel generator control panels did not identify any other design discrepancies. The Unit 2 diesel generator panels were checked for the same capacitor installations and none were found. Our starti' group will perform a complete verification of the Unit 2 diesel generator control panels as part of the diesel generator functional test.

Our initial evaluation determined that, although the capacitors did not adversely affect operation of the diesel generator, they do not appear to serve a necessary function. As part of the disposition of NCR 87-02828, a functional test of a Unit I control circuit will be performed with the capacitors removed. Appro)riate actions will be taken based on the results of this test. We lave determined that failure (shorting) of the capacitors would not adversely affect starting, running, or stopping the diesel generator.

3. Corrective Steps Which Will be Taken to Avoid Further Violations We have determined that, except for the diesel generator sets, no other '

safety related components have been supplied by IM0 Delaval. Our Authorized Vendor List now requires the responsible engineering organization to evaluate Delaval safety related purchase orders and ,

specify additional quality verification / inspection by TV Electric QA for critical processes / activities. This measure should provide increased assurance of Delaval compliance with purchase specification requirements.

Issue Specific Action Plan (ISAP) Vll.a.9 has been implemented to address concerns regarding vendor compliance with procurement requirements. A report detailing the results of ISAP VII.a.9 is expected to be issued by February 15, 1988. By March 15, 1988 we will provide a description of additional corrective actions (if any) planned as a result of the ISAP VII.a.9 Results Report.

Attachment to TXX-88079

~.

January 15, 1988 .

Page 3 of 4 6

-4. Date When Full Compliance Will be Achieved The functional test ~of a Unit 1 control circuit with capacitors removed will be completed by January 29, 1988.

Unit 2 diesel generator functional testing, including a point to point verification of both Unit 2 diesel generator control panels, is scheduled ,

for completion prior to Plant Hot Functional Testing.

A description of additional corrective actions (if any) planned as a result of the ISAP VII.a.9 Results Report will be provided by March 15, 1988.  ;

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Attachment to TXX-88079 January 15, 1988 Page 4 of 4 NOTICE OF VIOLATION ITEM B (445/8730-V-07)

B. 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 TNE-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 comp'etion 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) ~

Response will be provided by February 15, 1988.

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