ML20150C971
| ML20150C971 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/18/1988 |
| From: | Counsil W, John Marshall TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-88325, NUDOCS 8803230019 | |
| Download: ML20150C971 (4) | |
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-m Log # TXX-88325 File # 10130
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IR 87-30 1R 87-22 7t/ ELECTRIC Ref. # 10CFR2.201 March 18, 1988 wmi.. c. comii Enerunvr Vwe />ruden 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 REVISED RESPONSE TO NOTICE OF VIOLATION (N0V)
ITEM B (445/8730-V-07)
REFERENCE:
10 Electric Letter TXX-88220 f rom W. G. Counsil to NRC dated February 16, 1988 Gentlemen:
The referenced letter provided our response to Notice of Violation (NOV) 445/8730-V-07.
In that response we stated that Sheet 3 of the vendor (Delaval) supplied drawing 09-500-76001 was the only sheet that had been replaced by a THE drawing. We have subsequently determined that Sheets 1 and 2 of the vendor drawing had also been replaced by 1NE drawings.
Sheets 1 and 2 depict instrument tubing isometric layouts and were overlooked because our interest was focused on the wiring-diagrams which were the subject of the violation. Since the violation resulted from Sheet 3 being kept active, but not current, the replacement of Sheets 1 and 2 (which were made inactive in 1986) by THE drawings does not materially affect our response. Our response has been revised to accurately reflect the status of Sheets 1 and 2 of the vendor drawing.
Additional information regarding the point to point wiring verification was requested by the NRC inspector.
This infonnation has also been provided in our revised response.
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TXX-88325 March 18, 1988 Page 2 of 2 Attached is our revised response.
Those portions of the response which have been revised are denoted by a revision bar in the right margin.
Very truly yours, b
(d o 6, Cou s se l W. G. Counsil By:
J. S. Marshall Generic Licensing Manager RDD/clk Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) l l
Attachment to TXX-88325-March 18,1988 Page 1 of 2 NOTICE OF VIOLATION ITER B (4457H730-V-MJ 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 i
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/18 and 10X) on Drawings 09-500-76001, Sheet 3 and THE-El-0067, Sheet 96 (445/8730-V-07).
RESPONSE TO NOTICE OF VIOLATION l
LIER ~B7445787WTD7T TV Electric agrees with the alleged violation and the requested information follows:
1.
Reason for Violation i
Sheet 96 of Drawing THE-El-0067 was prepared by our engineering i
contractorand issued in 1984.
Sheet 96 of the THE drawing was intended to be a replacement for Sheet 3 of the vendor (Delaval) supplied drawing 09-500-76001.
Except for Sheets 1 and 2 (which were made inactive in 1986),
Sheet 3 of the vendor drawing was the only sheet of that drawing replaced by a THE drawing.
Since Sheet 3 of the vendor drawing was to be replaced it was not kept current.
However, except for the period from 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 i
Change Authorizations (DCAs) that were incorporated in the original issue i
of Sheet 96 of the THE drawing, or DCAs that are currently outstanding against Sheet 96 of the TNE drawing.
The results of the comparison provide assurance that Sheet 96 of the THE drawing has been kept current and accurate.
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5 Attachment to TXX-88325 March 18.1988 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.
Except for an unrelated discrepancy discussed in item A of this Notice of Violation (undocumented capacitors found in DG control panel) no wiring discrepancies were identified.
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 4
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, i
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 "THE" 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.
Exam)les of such drawings are the Westinghouse elementary wiring drawings and t1e Westinghouse fluid system flow diagrams.
Deficiency Report (DR) C-88-00872 has been written to provide corrective action for this condition.
i; 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 vender 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 diesei 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-88-00872 will be dispositioned no later than June 15, 1988.
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