TXX-6211, Suppls 860402 Response to Violations Noted in Insp Repts 50-445/85-07 & 50-446/85-05.Corrective Actions:Project Directive Issued Emphasizing Requirements for Properly Documenting Design Alternatives Prior to Const Activities

Suppls 860402 Response to Violations Noted in Insp Repts 50-445/85-07 & 50-446/85-05.Corrective Actions:Project Directive Issued Emphasizing Requirements for Properly Documenting Design Alternatives Prior to Const Activities

ML20209B714
Person / Time
Site:	Comanche Peak
Issue date:	01/28/1987
From:	Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-6211, NUDOCS 8702040106
Download: ML20209B714 (5)

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Log # TXX-6211 File # 10130 IR 85-07

- IR 85-05

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January 28, 1987 ben utiw Ik e l>esidens U. S. Nuclear Regclatory Commission ATTN: Document Cortrol Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT NOS.: 50-445/85-07 AND 50-446/85-05 SUPPLEMENTAL REQUEST FOR INFORMATION TO NRC NOTICE OF VIOLATION (NOV) ITEMS 1, 2.A AND 2.B REF: TUGC0 LETTER TXX-4727 FROM W.G. COUNSIL TO E. H. JOHNSON DATED APRIL 2, 1986.

Gentlemen:

We have reviewed your letter dated December 30, 1986, requesting additional information to our response referenced above regarding NOV 445/8507-01 and 446/8505-01 (Item 1), 445/8507-02 (Item 2.a) and 445/8507-03 (Item 2.b). We hereby respond to the request for supplemental information in the attachment to this letter.

We requested and received an extension until January 26, 1987, in providing our response during a telephone conversation with Mr. I. Barnes on January 15, 1987. We requested and received an extension until February 16, 1987, in providing our response to NOV 445/8507-03 (Item 2.b) during a telephone conversation with Mr. I. Barnes on January 23, 1987. We requested and received an extension until January 28, 1987, in providing our response during a telephone conversation with Mr. I. Barnes on January 26, 1987.

Very truly yours, Md

__ W. G. Cou sil 8702040106 870128 j / j gDR ADOCK0500py5 G. S. Keeley Manager,Nuclearw/ wnsing RSB:lw V Attachment c - Mr. Eric H. Johnson, Region IV Mr. D. L. Kelley, RI-Region IV Mr. H. S. Phillips, RI-Region IV 0\

7 4 400 North Olhe Strect I..H. 81 Dallas fem 75201 vk

Attachment to TXX-6211 January 28, 1987 Page 1 of 4 NOTICE OF VIOLATION ITEM 1 (445/8507-01 AND 446/8505-01)

SUPPLEMENTAL REQUEST FOR INFORMATION We find that the corrective steps taken and results achieved do not indicate that the installation of the replacement RTE-Delta Potential Transformer tiltout assembly was reinspected and accepted. Also, there is no indication that these deficiencies were documented on a nonconformance report for Units 1 and 2.

SUPPLEMENTAL RESPONSE TO ITEM 1 In our previous response we noted the deficiencies involving the Unit 1 RTE-Delta Potential Transformer Tiltout assemblies were corrected using startup work permits. We failed to note that inspections and the acceptance of completed work are inherent in the startup work permit program. We have confirmed these activities were accomplished as documented on the completed work permits (Z-2912 & Z-2914).

As noted in our review of a previous NRC finding (445/8407-01), the program for managing 10CFR21 defects was not positively controlled. In some cases, and in the case of the RTE-Delta 10CFR21 notice involved in this finding, the deficiencies were corrected without nonconformance reports.

Under our current program, the Site Coordinator, whose responsibilities are specified in Procedure NE0-CS-1, " Evaluation of and Reporting of Items / Events Under 10CFR21 and 10CFR50.55(e)," is responsible for assuring proper deficiency documentation, including NCRs, are issued.

Our previous response incorrectly indicated that the Unit 2 10CFR21 deficiencies were corrected in August 1985. The work was actually completed in September 1985 and QA/QC review of the work packages was completed in April 1986.

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Attachment to TXX-6211 January 28, 1987 Page 2 of 4 NOTICE OF VIOLATION ITEM 2.a (445/8507-02)

SUPPLEMENTAL REQUEST FOR INFORMATION The described corrective steps taken do not indicate whether a nonconformance report was written for Units I and 2. Follow up by the NRC inspector identified that the drawing which was used for the activity (i.e.,

Westinghouse Drawing 1457F29) had been reviewed and stamped by Gibbs and Hill, signifying apparent approval of a drawing which allowed use of grout instead of Class E concrete. Accordingly, it is requested that the stated reason for the violation be reevaluated, in that the engineering interface or review may have contributed to causing this violation. Please also identify the design change authorization, if any, that permits use of grout rather than Class E concrete in Unit 2, in that the referenced design change DCA-21,179 would appear to be applicable to Unit 1 only. In your corrective steps to avoid recurrence, you stated that operational travelers issued during the same time frame for similar type installations would be reviewed for similar deficiencies. Please clarify how this action is pertinent to precluding recurrence. Your response also indicated that any corrective actions deemed necessary, as a result of this review, would be reported to Region IV by April 15, 1986. In that no supplementary response has been received by Region IV, please identify whether or not your review determined corrective actions were necessary.

SUPPLEMENTAL RESPONSE TO ITEM 2.a As a result of discussions with the NRC Resident Inspector, and our review of the Violation, we have determined that a revision to our response is required.

The revised response below provides the supplemental information requested.

1. Reason for Violation We admit to the Violation, and the required information follows.

This violation was the result of inadequate design review of the I

Westinghouse equipment drawing by the primary on-site design group after the drawing had been received on-site. The drawing, which specified the use of grout, disagreed with the Gibbs and Hill, Inc. civil drawing which l specified Class "E" concrete. Subsequently, this disparity was overlooked when an operational traveler was developed which specified the use of

, grout without formal design concurrence on incorporation.

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Attachment to TXX-6211 January 28, 1987 Page 3 of 4 SUPPLEMENTAL RESPONSE TO ITEM 2.a CONT'D

2. Corrective Action Taken After reviewing grout card No. 186, which documented the material used in the actual installation, and the results of the compressive strength test for the grout used in this application, a design change (DCA-21,179) was used to document acceptance of the installation. These actions were initiated after identification of the condition via an NRC Inspection Report item.

After further review of this matter, two DRs (C-86-12 and C-86-13) were issued December 29, 1986, to ensure appropriate drawing changes were made; to formally document acceptance of the grout used in these and other nearby installations; and to specifically identify the root cause of this deficiency.

3. Action to Prevent Recurrence Operational travelers, grout cards, and drawings used during the same time frame were reviewed for similar installations. The operational traveler review completed on May 15, 1986, indicated that other drawings used for similar installations did not contain the same disparity as discussed in Item 1 above. However, the review revealed that grout was used in seven other installations in Unit I and eight installations in Unit 2 due to differences between drawings 2323-SI-0550, 2323-S2-0550, and 1457F29. The grout used in these other fifteen installations was evaluated and found to have a compressive strength in excess of Class "E" concrete. DCA-21,179 and DCA-26,101 issued November 8, 1986, and November 26, 1986, respectively, were used to document acceptance of the installations in Unit 1 and Unit 2, respectively. Based on the specific nature of the discrepancies and the results of our review, this violation is considered to be an isolated occurrence.

A Project Directive was issued on July 17, 1986, reemphasizing, a) the requirements for properly documenting design alternatives prior to initiating construction activities, and b) the precedence of design versus vendor documents.

The review of vendor drawings (except for Fire Protection and HVAC drawings) is performed by Stone and Webster Corporation (SWEC) in l accordance with SWEC Procedure PP-053, " Review of Vendor Drawings." The l review of vendor HVAC drawings is performed by Ebasco in accordance with l TUGC0 Procedure ECE-DC-5, " Vendor Document Review." These vendor drawings are reviewed against design drawings to resolve any discrepancies. The review of vendor Fire Protection drawings is performed by Impell l Corporation in accordance with Impell Procedure IMP-FP-19, " Vendor l Document Review." SWEC Procedure PP-053 and Impell Procedure IMP-FP-19 will be revised to clarify and specifically require the review of vendor drawings to insure compliance with design drawings.

4. Date of Comoliance CPSES is currently in full compliance. SWEC Procedure PP-053 will be revised and issued by February 27, 1987. Impell Procedure IMP-FP-19 will

! be revised and issued by April 30, 1987.

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Attachment to TXX-6211 January 28, 1987 Page 4 of 4 NOTICE OF VIOLATION ITEM 2.b (445/8507-03)

SUPPLEMENTAL REQUEST FOR INFORMATION With respect to the corrective steps taken, please describe what formal actions were taken (e.g., specification revision) to justify the change in output voltage from 10 +/- 2v to 12 +/- 2v on the revised Westinghouse Quality Release. Your response also fails to provide any actions taken to assure that other equipment received from this vendor, irrespective of time frame, did not exhibit similar documentation deficiencies.

SUPPLEMENTAL RESPONSE TO ITEM 2.b TU Electric Quality Assurance is in the process of obtaining related information from the vendor and reviewing site documentation. We anticipate submitting our response no later than February 16, 1987.

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