TXX-6466, Forwards Revised Response to NRC Re Violations Noted in Insp Repts 50-445/86-15 & 50-446/86-12.Corrective Actions:Procedure Neo 3.05, Reporting & Control of Nonconformances, Made Effective on 861222
| ML20214J344 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/22/1987 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-6466, NUDOCS 8705280015 | |
| Download: ML20214J344 (3) | |
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Log # TXX-6466 File # 10130 IR-86-15 r
r IR-86-12
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*I 1UELECTRIC May 22, 1987 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT NOS. 50-445/86-15 AND 50-446/86-12 REVISED RESPONSE FOR NOTICE OF VIOLATION (N0V) ITEM C (446/8612-V-03)
REF:
1)
NRC Letter from E. H. Johnson to W. G. Counsil dated December 22, 1986.
- 2) TV Electric Letter TXX-6250 from W. G. Counsil to NRC dated February 2, 1987.
Gentlemen:
In pursuing the corrective steps as delineated in our response (Reference 2) to Item C (446/8612-V-03), we have determined that a revision to our original response, including a new Date of Full Compliance, is required. We hereby submit our revised response in the attachment to this letter. The original Notice of Violation has been included to aid in understanding our revised response.
Those portions of the response which have been revised are denoted by a revision bar in the right margin.
Very truly yours, tf[(W W. G. Counsil RDD/gj Attachment J
c - Mr. R. D. Martin - Region IV CPSES Resident Inspector - 3 copies N[ $DO O
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Attachment to TXX-6466 4
May 22,.1987 i
Page 1 of 2 NOTICE OF VIOLATION ITEM C (446/8612-V-03)
C. _ Criterion III of Appendix B to 10 CFR.Part 50, as implemented by Section 3.0, Revision 3, dated July 31, 1984-of the TUGC0 QAP, requires in part, that measures must be established to assure that applicable regulatory requirements and design basis, as defined in Part 50.2 and as specified in the license application, for those structures,' systems, and camponents to which this appendix applies, are correctly translated.into specifications, drawings, procedures, and. instructions. The design control measures must provide for verifying or checking the adequacy of design, such as by -the -
performance of. design reviews, by.the use of alternate or simplified 4
calculational methods, or by the performance of a suitable testing program.
In addition, design changes,l including field changes, must be 4
subject to design control measures commensurate with those applied to the original design.
j Section 1.6 of Appendix B to Gibbs- & Hill (G&H) Specification 2323-ES-100 Revision 2, and Section 3.6.1 of B&R Procedure ECP-19A, Revision 2, both require NEMA Type 4 enclosures in the reactor building.
1 Contrary to the above, enclosures are installed in the Unit 2 reactor building which have been modified. The modifications occurred with no design control and without verification that the modified enclosures meet j
the design requirements.
(446/8612-V-03)-
REVISED RESPONSE TO ITEM C (446/8612-V-03)
We admit to the violation and the requested information follows:
1.
Reason For Violation The violation was caused by. improper implementation of a design change by both engineering and construction personnel in that; 1) engineering i
personnel directed a design change via an NCR and 2) construction personnel accepted the NCR as sufficient authorization to perform work without the design change and subsequent design authorization. At the 3
time the violation occurred, implementation of design changes via NCRs was a.
not permitted by TU Electric's design control program, i
-The design change which was improperly implemented consisted of a minor l
fastener alteration to upgrade the NEMA Type 12 electrical enclosure to a NEMA Type 4 for use in the reactor building.
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Attachment to TXX-6466 May 22, 1987 Page 2 of 2 REVISED RESPONSE TO ITEM C CONT'D (446/8612-V-03) 2.
Corrective Steos Taken And Results Achieved Corrective Action Report.87-26 was issued March 27, 1987 to document the improper design change implementation.
Since'the design change was not properly controlled, all NEMA 4 enclosures (installed and in the warehouse) will be examined to identify those enclosures which have been modified from NEMA 12 enclosures. Nonconformance Reports (NCRs) will be written on the modified enclosures. The outdoor enclosures will be examined per instruction CPE-FVM-EE-054, " Instruction to Acquire Data for Weatherproofing of all Outdoor Class IE Terminal / Junction Boxes and Associated Conduit Fittings." Additional instructions will be issued governing examination of the indoor enclosures and the enclosures in stock in the warehouse.
3.
Corrective Steos Which Will Be Taken To Avoid Further Violations A new corporate procedure, NE0 3.05, " Reporting and Control of-Nonconformances," was made effective December 22, 1986. This procedure allows design changes to be implemented via NCRs, and provides the-necessary controls. Training of engineering and construction personnel on NE0 3.05 and/or its implementing procedures has been completed.
4.
Date When Full Compliance Will Be Achieved The issuance of instructions, examination of enclosures and resolution of NCRs will be completed by October 15, 1987.
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