TXX-6386, Responds to Violations Noted in Insp Repts 50-445/85-18 & 50-446/85-15.Date of Full Compliance for Notice of Violation,Item C Revised.Corrective Actions:Design Change Authorization 13023 Revised

Responds to Violations Noted in Insp Repts 50-445/85-18 & 50-446/85-15.Date of Full Compliance for Notice of Violation,Item C Revised.Corrective Actions:Design Change Authorization 13023 Revised

ML20206N174
Person / Time
Site:	Comanche Peak
Issue date:	04/14/1987
From:	Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-6386, NUDOCS 8704200415
Download: ML20206N174 (3)

Text

_ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _

t Log # TXX-6386 M File'# 10130

=M IR 85-18 L

__. 5 IR 85-15

= = Ref # 10CFR2.201 nlELECTRIC April 14, 1987 William G. Counsil Executive Vice Preuknr U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 4

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT N0S.: 50-445/85-18 AND 50-446/85-15 REVISED DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION (N0V) ITEM C REF: 1) TUGC0 Letter TXX-4848 from W. G. Counsil to E. H. Johnson dated July 9, 1986.

2) TUGC0 Letter TXX-6134 from W. G. Counsil to E. H. Johnson dated December 12, 1986.

Gentlemen:

In pursuing the corrective steps as delineated in our response (Reference 1) to NOV 445/8518-V-15 (Item C), we have determined that an update to the Date of Full Compliance is required. We hereby submit our revised response as follows. The original Notice of Violation and the TV Electric response are provided below. Those portions of the response which have been revised are denoted by a revision bar in the right margin. The original date of full compliance was August 15, 1986.

NOTICE OF VIOLATION ITEM C (445/8518-V-15)

C. Criterion III of Appendix B to 10 CFR Part 50, as implemented by Section 3.0, Revision 4, dated November 20, 1985, of the TUGC0 QAP, states, in part, " Measures shall be established for the identification and control of design interfaces and for coordination among participating design organizations. These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces. Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design. . . ."

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, 9 400 Nonh Olive Street LB 81 Dallas. Texas 75201 \

TXX-6386 April 14, 1987 Page 2 of 3 NOTICE OF VIOLATION ITEM C (445/8518-V-15) - CONT'D Contrary to the above, design change control procedures did not provide for necessary review by and coordination among design interfaces with respect to performance of actions required by design change authorization (DCA) statements / justifications. For example, DCA 13,023 dated April 20, 1982, replaced a general prohibition in G&H Specification 2323-MS-625 of contact of instrument tubing with galvanized surfaces with only a prohibition for tubing contact where redundant counterparts are routed through the same fire zone. The DCA engineering justification was based on performance of a damage study walkdown of safety-related tubing in fire zones and accomplishment of required corrective actions. Engineering damage study walkdown procedures did not, however, require such a walkdown to be performed and the required DCA actions were not accomplished.

REVISED RESPONSE TO ITEM C

1. REASON FOR VIOLATION Inadequate interface control and coordination at the time the DCA was written was the reason for the violation. Informal communication between discipline leads was not adequately followed up to ensure procedures were written to address the concern. Design review of the DCA was performed by Gibbs & Hill in New York without verification of the adequacy of site

procedures to ensure that the requirements of the DCA were met.

2. CORRECTIVE ACTION TAKEN DCA 13023 Revision 2 is in the process of being issued. The revision adds the required design control to the I&C Construction drawings to preclude any future construction activity violating the design requirements for the post-fire required instrumentation. Any changes to the instrument list of required instrumentation will result in changes to the I&C design documents via the DBD (Design Basis Document) interdiscipline review (IDR) i process. An Engineering Walkdown will be performed to identify the nonconforming conditions to the revised DCA's requirements. A complete review is in progress of all CPSES erection specifications and _ their associated design change documents.

3. ACTION TO PREVENT RECURRENCE The present site design review efforts, the formulation of a detailed design basis document program and significant improvements to the IDR process should prevent similar violations.

TXX-6386 April 14, 1987 Page 3 of 3 REVISED RESPONSE TO ITEM C - CONT'D

4. DATE OF FULL COMPLIANCE Revision 2 to DCA 13,023 was issued June 23, 1986.

Fire protection DBD ME-20 will be issued no later than July 30, 1987.

The engineering walkdown is being performed and will be completed by June 30, 1987.

The review of the CPSES erection specifications was completed by August 18, 1986.

Very truly yours, W. G. Counsil By: >

G. S. Keeley "

Manager, Nuclear L[ censing RSB/mlh c - Mr. E. H. Johnson - Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV