ML20246D985
| ML20246D985 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/21/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89591, NUDOCS 8908280358 | |
| Download: ML20246D985 (4) | |
Text
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Log
~ File # 10130
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IR 87-30
'"$$o1 1UELECTRIC g,g g
o August 21, 1989 3,
Decutive Vice President U. S. Nuc1' ear-Regulatory' Commission Attn:. Document Control Desk Washington,.D. C.
20555
SUBJECT:
COMANCHE PEAK: STEAM ELECTRIC STATION -
DOCKET NOS. 50-445 AND 50-446 REVI3ED RESPONSE TO NRC NOTICE OF VIOLATION (NOV) 445/8730-V-06 REF:
(1) TV Electric letter TXX-88079 from W. G. Counsil to USNRC dated January 15, 1989 Gentlemen:
Reference.(1).provided our' response to NOV 445/8730-V-06.
In that response we noted that although the subject capacitors did not adversely affect-the operation of the. diesel generator, a. functional test of the Unit I control circuits would be performed with the capacitors removed and appropriate actions would be taken based on the results of that test. This testing has been performed and we have determined that the capacitors did provide a necessary function.
Our' response has been' revised to incorporate this information and describe the resulting additional actions which have been taken. Our response has also been revised to update the status of other actions previously described in. Reference (1).
Revision bars in the right margin of the attached revised response indicate the changed portions of the text.
Sincerely, M
William J. Ca 11, Jr.
FAM/vid Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) l~
8908280358 890821 II go[
PDR ADDCK 05000445 O
PNU u 400 North Olive Street LB Si Dallas, Texas 75201 L.____'_
.' Attach entlto:TXX-89591
" August. 27, 1989-Paga:1 of 3.
j NOTICE OF VIOLATION ITEM A (445/8730-V-06)
A.
Criterion III of. Appendix B to 10CFR Part 50, as implemented by Section 3.0, Revision 3, dated July 31',1984, of the-TU Electric-Quality Assurance Plan (QAP),, requires in. part, that measures must i
be established to: assure that applicable regulatory requirements -and.
I design bases, as defined in Part 50.2 and as specified-in.the _
license 6pp11 cation, for those' structures, systems and components to j
which this' appendix _ applies, are correctly translated into specifications, drawings, procedures, and instructions. The design-l control measures must provide for verifying or checking the adequacy.
i 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 i
emergency diesel generator control _ panels that were not snown on l
facility electrical drawings nor described in any associated -
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'documer.ts (445/8730-V-06).-
RESPONSE TO NOTICE OF VIOLATION l
ITEM A (445/8730-V-06)
TU Electric agrees with the alleged violation and the requested information follows:
1 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 (IMO Delaval) u supplied control panel. A vendor representative has stated that the capacitors could have been vendor installed.
However, the personnel I
i who designed the circuit are no longer with Delaval and Delaval had no records of the capacitors being' installed.
For the above l
reasons, TU Electric believes that the capacitors were vendor i
installed, and that the vendor failed to show the capacitors on the applicable drawings as required by the diesel generator purchase specification.
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'Attgchzent to-TXX-89591' August 21, 1989 Page 2 of 3 2.
[gifgg1_ive Steos Taken and Results Achieved
~ Tne 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 evaluete the apparent discrepancy.
Subsequently,'the NRC inspector observed the capacitors and informed TU Electric of his concern. Test Deficiency-L 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 Startup Group will perform a complete verification of the Unit 2 diesel generator control panels as part of the diesel generator functional test.
i Our initial evaluation determined that, although the capacitors did not. adversely. affect operation of the diesel generator, they did not appear to serve a necessary function. As part of the disposition of NCR 87-02828, a functional test of a Unit 1 control circuit was performed with the capacitors removed.
It was determined that the capacitors delay the unlatching of relay TD-4 upon deenergization of the TD-4. power supply.
This delay provides assurance that the i
operation of TD-4 and other associated annunciator and auxiliary equipment relays is sequenced properly. We have determined that failure (shorting) of the capacitors would not adversely affect starting.. running, or stopping.the diesel generator.
A vendor approved design change has been installed in the Unit I diesel generator control circuitries which performs the same function as the removed capacitors. The same design change will be installed in the Unit 2 diesel generator control circuitries.
3.
[orrective Steos 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 IMO 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 TU Electric OA for critical processes / activities. This measure should provide increased assurance of Delaval compliance with purchase specification requirements.
Issue Specific Action Plan (ISAP) VII.a.9 has been implemented to address concerns regarding vendor compliance with procurement requirements. TXX-88310 from W. G. Counsil to the NRC, dated March 15, 1989, has been transmitted describing additional actions taken as a result of the ISAP VII.a.9 results report.
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' * "EAttaqhmeNt to TXX-89591'
- August' 216 1989 Page 3 of 3 4.-
Date When Full Compliance Will be Achieved
- Unit 1 compliance was established upon completion of the modification to control circuits described in paragraph. 2.
-Installation of the design change in the Unitt2-diesel generator contro1 > circuits will be' completed prior to Unit 2 Hot Functional Testing.
Unit 2 diesel generator-functionalEtesting.-including a point to point: verification of both Unit 2 diesel generator control panels, is scheduled for completion prior to Plant Hot Functional Testing.
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