ML20151H685
| ML20151H685 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/15/1988 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-88396, NUDOCS 8804200472 | |
| Download: ML20151H685 (3) | |
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""" 9 Log # TXX-88396 file i 10130
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C IR 88-12 7UELECTR/C
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$*,*,h{d, April 15, 1988 U. S. Nuclear Regulatory Commission Attn: Document Control Oesk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
. DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT N05.
50-445/88-12 AND 50-446/88-10 Gentlemen:
TV Electric has reviewed your letter dated March 17, 1988, concerning the inspection conducted by Mr. H. S. Phillips, during the period February 3, 1988, through March 1,1988.
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, del &~'
W. G. Counsil RUD/gj Attachment c - Mr. R. D. Hartin, Region IV Resident Inspectors, CPSES (3) f
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Attachment to TXX-88396 April 15, 1988 Page 1 of 2 NOTICE OF VIOLATION ITEM A (44578812-V-01TT4578810-V-011 A.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3 of the TV Electric Quality Assurance Plan (QAP), states, in part, "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, or a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings...."
Paragraph 6.3.4.7, "Af fected Licensing Documents," of TV Electric Procedure ECE 5.01-03/R1 dated Decenber 1, 1987, states, in part, "Design changes may affect the text, tables, figures, charts, and/or drawings of one or more sections of a licensing document and may affect more than a single de:ument.
The Responsible Engineeer shall thoroughly review all related licensing documents to identify potential conflicts.
For a design change that affects the Final Safety Analysis Report (FSAR), an FSAR change request shall be prepared in accordance with Reference 3.9 and shall reference the DCA."
TV Electric response (R130.36) to NRC staff question (0130.36) of FSAR Volume XVI states, in part, "Elevation 830' 0" - seven block walls were evaluate.l.
Two were removed and replaced with seismic Category 11 Gypsum walls, two were modified to prevent a seismic Nteraction with ductwork, and three were found to be acceptable based on nn seismic interaction with safety-related equipment."
Contrary to the above, the responsible engineer did not "thoroughly review all related licensing documents to identify potential conflicts." For exemple, Design Change Authorization (DCA) 23040, Revision 3, conflicts with the FSAR statement.
...two walls were modified to prevent a seismic interaction with @ctwork," in that the DCA states, "no modifications required to muonry wall between Room 136 and 137; except for west wall of Room 139.
For technical justification see pages 3, 4, and 5."
As a result, Block 15 (Dons Design Change Affect a Licensing Document) was marked no and na FSAR change request was prepared (445/8612-V-01; 446/8810-V-01).
RESDONSE TO NOTICE OF VIOLATION 1 TEM'A-(44578812 V OlT'4~4678810TVT01)
TV Electric agrees with the alleged violetion and the requested information follows:
1.
Reason for Violation The vialation resulted from an oversight by the responsible engineer.
Although the design change was technically acceptable, the responsible engineer failed to review the Question and Response (Q & R) Section of the FSAR far conflicts with the DCA.
.o' Attachment to TXX-88396
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April 15, 1988 Page 2 of 2
'lESPONSE 10 NOTICE OF VIOLATION ITEM A (44578812TolT446783M-V-01)-~(Cont'dl 2.
Corrective Steps Taken and Results Achieved Deficiency Report (DR) C-88-00906 has been writ ten to document the failure to initiate an FSAR change request as required by ECE 5.01-03.
A sample of DCAs prepared by the responsible engineer is being reviewed to determine if similar errors have occurred.
If errors are identified additional DRs will be initiated.
FSAR response R130.36 was revised by Amendment 69.
DCA 23040 will be revised to reflect that the design change requires a change to the FSAR.
3.
Corrective Steps Which Will Be Taken to Avoid Further Violations The responsible engineer has been made aware of the need to include the Q
& R Section when conducting FSAR reviews required by ECE 5.01-03.
Training on Q & R Section of the FSAR will be provided for personnel currently preparing and reviewing DCAs.
Applicable TV Electric and contractor training programs will be enhanced to familarize personnel with the 0 & R Section.
We have surveyed previous deficiency reports and past surveillances that examined the implementation of the DCA program.
No other instances of DCAs conflicting with the Q & R Section of the FSAR have been identified.
Where instances of DCAs conflicting with other sections of the FSAR were identified, the conflicts were not significant and did not affect the function or design of components or systems.
For these reasons we do tiot consider additional actions to be warranted.
4.
Date When Full Compliance Will be Achieved DCA 23040 will be revised no later than June 15, 1988.
Training of personnel currently preparing and reviewing DCAs cnd enhancement of training programs will be completrd no later than July 15, 1988.
The review of DCAs prepared by the responsible engineer and the initiation of any required DRs will be completed no later than June 15, 1988.