ML20234B341

Ack Receipt of Listed Ltrs in Response to Violations Noted in Insp Repts 50-445/86-07 & 50-446/86-05.Corrective Steps Taken Re Item a Inadequate.Bases for Statement in on Item E Requested

ML20234B341
Person / Time
Site:	Comanche Peak
Issue date:	09/11/1987
From:	Warnick R NRC OFFICE OF SPECIAL PROJECTS
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8709180368
Download: ML20234B341 (4)

See also: IR 05000445/1986007

Text

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SEP 1 1 1987 l

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.In Repl y Re f er To:

Dockets: 50-445/86-07

50-446/86-05

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TU Electric

ATTN: Mr.:W. G. Counsil

5 Executive Vice President j

400 North Olive Street, Lock Box 81  !

Dallas, Texas 75201

v.

Gentlemen:

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Thank you for your letters dated February 18, March 6, March 27,

May l', June 1, July 15 and July 31, 1987, in response to our

letter dated December 22, 1986. As discussed with Mr. J.

Streeter and other members of your staff on August 13, 1987, we j

find that additional information is needed with respect to Notice j

- of Violation (NOV) Item A and Notice of Deviation (NOD) Item E. j

Specifically, with respect to NOV Item A, the corrective steps

taken appear inadequate in light of the reason given for the

violation. Please perform or provide the basis for not

performing a technical evaluation of all 48 closed Corrective l

- Action Reports (CARS) to assure that they have been properly  ;

dispositioned. Additionally, please inform us of actions taken

to ascertain whether this problem exists in CAR systems used by 3'

other groups, such as, Brown & Root.

With respect to NOD Item E, please provide the bases for the

statement in your February 18, 1987, response (TXX-6222)

indicating that the welding on the seismic arrestor brackets has J

been determined to be acceptable. Additionally, your response 1

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identified that your letter TXX-3657 would be supplemented to

document why lack of welding documentation doe.s not constitute a "

significant condition adverse to quality TXX-3657 was

supplemented by TXX-6526. Please clarify the statements in

supplement, TXX-6526, relative to control of bracket materials

and welding by the valve manufacturer.

As discussed with Mr. D. Ferguson of the Comanche Peak Response

Team (CPRT) and other members of CPRT and your staff on August I

. 20, 1987, please identify the actions taken in regard to NOD Item /

I.3 to avoid recurrence of further errors by the identified ERC {

inspector.

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B709180368 870911 ,

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PDR ADOCK 05000445 {

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Regarding NOD Item H,,your response indicates that you deny a

deviation exists because spare conductor terminations were

included in the sample population. We continue to disagree that

a spare conductor, whether landed or unlanded, can be considered

an " essential Class 1E" conductor as required by the Program

Plan. However, in that the development of populations has been a

subject of NRC inspection and additional functioning conductors

were subsequently sampled to correct the noted condition, no

further response is requested.

Your response to NOV Item C.2 indicates that you deny this part l

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of the violation based on the results of a records search. In

light of the additional information which has now been provided,

we agree that this example was not a violation. We will verify

the information you provided and evaluate the acceptability of

the work practices used for this example in a subsequent report.

Regarding NOD Item I.4, your response for corrective steps taken

addresses Revision 2 of QI-035. We believe that this is an error

and should reference QI-037.

Your response to NOV Item D indicates that you deny the violation

because the terminal blocks (tbs) were identified under the

covers. We agree that TB identification is available when the

cover is removed and, accordingly, no longer consider this item

to be a violation.

Your response to NOD Item F indicates that you deny the deviation

because the QC inspector certification was contained in the

pennanent plant records vault (PPRV). It is our understanding

that the missing QC inspector certification for instrumentation

tubing installation was subsequently located in a welder

certification file in the PPRV. Since the certification '

documentation has now been located, we agree that a leviation

does not exist. We will verify that the appropriate

documentation is available in the correct file during a

subsequent report.

Your response to NOD Item G indicates you deny the deviation that

document reviews were incomplete. Your review showed that

Revision 3 of Design Change Authorization (DCA) 17,762 deleted

the five cables which were found to be spliced. Revision 2 of

the DCA, which authorized splicing these cables, had been

reviewed by the NRC inspector. We agree that a review of the

current design documents would not have identified these cables

as being spliced. Since no formal program exists for the correct

method of documenting spare conductors and cables, and we know of

no regulatory requirement for such a program, we agree that no

deviation exists.

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SEP l i 1987

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Please provide the supplemental information within 20 days of the

date of this letter.

Sincerely,

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'ORIGINEL EIGN

R. F. Warnick, Assistant Director

for Inspection Programs

Comanche Peak Project Division

Otfice of Special Projects

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