TXX-4992, Responds to NRC Requesting Addl Info Re Violations Noted in Insp Repts 50-445/86-16 & 50-446/85-13. Corrective Actions:Addl Calculations Performed to Show Design Change Acceptable & Engineering Personnel Counseled

Responds to NRC Requesting Addl Info Re Violations Noted in Insp Repts 50-445/86-16 & 50-446/85-13. Corrective Actions:Addl Calculations Performed to Show Design Change Acceptable & Engineering Personnel Counseled

ML20214N619
Person / Time
Site:	Comanche Peak
Issue date:	09/05/1986
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
TXX-4992, NUDOCS 8609160389
Download: ML20214N619 (3)

Text

. . Log # TXX-4992 File # 10130 IR 85-16 85-13 TEXAS UTILITIES GENERATING COMPANY NKYW AY TOWER . e00 NORTH OIJVE STREET, L.B. N1. DAI LAN. TEXAS 75201 September 5, 1986

= = : : ::.t. ~}$@BOMMA 9 SEP 5 G86 Mr. Eric H. Johnson, Director Division of Reactor Safety and Projects t Y U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76012

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NOS.: 50-445/85-16 AND 50-446/85-13

Dear Mr. Johnson:

We have reviewed your letter of August 12, 1986 and have provided the additional information you requested regarding Notice of Violation 445/8516-V-08 (Item A) in the attachment to this letter. We requested and received a two week extension in providing this information in a phone discussion with Mr. I. Barnes on September 2, 1986.

You also requested that we confirm that all references to training sessions, meetings, and discussions are appropriately documented and available for audit. Our responses have indicated when these items are formally documented.

In those cases where we have not indicated formal documentation, such as meetings and discussions, key personnel are available to confirm that these meetings and discussions took place as stated. We consider that training sessions should be documented and the confirming documents are available for your review.

We believe that our approach is consistent with 10CFR50 Appendix B and meets all applicable regulations.

Very truly yours, V

860916o389 860905 5 W. G. Counsil PDR ADOCK 0500 G

JWA/amb Attachments c - NRC Region IV (0 + 1 copy)

Director, Inspection &-Enforcement (15 copies)

U. S. Nuclear Regulatory Commission s Washington, D.C. 20555 g\

Mr. V.S. Noonan Mr. D.L. Kelley Q l

f. h

. . Additional Information to NOV 445/8516-V-08

1. NRC Concern

... [Y]our response failed to provide any action taken with respect to the failure.of the design review process to identify the technical inadequacy of Design Change Authorization 13,349."

Response /

A. Corrective Action Taken and Results Achieved As stated in our original response, the DCA was re-reviewed and additional calculations were done to show that the design change was acceptable. This re-review of the DCA was performed in accordance with project procedures which insure that the design change receives the same design control measures as' those applicable to the original

design.

B. Action to Prevent Recurrence As stated in the response to Concern No. 2, we believe the instance noted in this Violation is an isolated occurance. However, the engineering personnel involved in the review and processing of DCA 13349 will be counseled regarding the applicable design control.

measures.

In the event that the engineering review delineated in Part B of the response to Concern No. 2 determines this violation is widespread, additional corrective action will be formulated.

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Additional Information to NOV 445/8516-V-08 ,

2. NRC Concern

... ,[W]e do not consider that reliance ~so!Ely on personnel discussions provides and adequate basis for determining tnat the identified use of a grouted Richmond Insert was a single case. Accordingly, please describe those actions, planned or taken, which will st.bstantiate the c'onclusions

made from discussions with personnel."

Response

A. Corrective Action Taken and Results Achieved i

I In our previous response, the conclusion this issue "is not generic" was based upon extensive discussions with experienced engineering personnel who have been involved in the structural design of CPSES for several years. The calculations noted previously have confirmed the installation is acceptable.

B. Action to Prevent Recurrence To provide additional assurance the instance noted in the Violation was an isolated case, an engineering review will be conducted involving all design changes originated within the civil engineering discipline.

This review will provide an assessment of the review process, verify the technical adequacy of information provided by the originator of the design change, and support our position the instance cited was isolated. This review is scheduled for completion by November 7, 1986.

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