TXX-6693, Responds to Notice of Violation from Insp Repts 50-445/87-07 & 50-446/87-06 on 870301-0430.Corrective Actions:Directive Issued on 870603 to All Engineering & Const Organizations Re Identification of Reportable Conditions Per 10CFR50.55(e)

Responds to Notice of Violation from Insp Repts 50-445/87-07 & 50-446/87-06 on 870301-0430.Corrective Actions:Directive Issued on 870603 to All Engineering & Const Organizations Re Identification of Reportable Conditions Per 10CFR50.55(e)

ML20238C427
Person / Time
Site:	Comanche Peak
Issue date:	09/03/1987
From:	Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
EA-87-122, TXX-6693, NUDOCS 8709100093
Download: ML20238C427 (5)

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Log # IXX-6693

-  : File # 10130 EA 87-122 1UELECTRIC

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• A wmiam c. counsis Fnecudvr Vice Preshkat September 3, 1987 U. S. Nuclear Regulatory Commission Attn: Dor:ument Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 REPLY TO A NOTICE OF VIOLATION (INSPECTION REPORT NO. 50-445/8707; 50-446/8706)

ENFORCEMENT ACTION 87-122 Gentlemen:

lie nave reviewed your letter dated August 4,1987, concerning the insaection conducted by Mr. H. S. Phillips and other members of the Comanche Pea < Project Division during the period from March 1 through April 30, 1987. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2. Attached to your letter was a Notice of Violaticn.

YourletterdatedJuly 31, 1987, transmitted Inspection Report 50-445/87-10; 50-446/87-08. Section 2.a of that report discussed a management meeting between TV Electric and the staff concerning the untimely submittal of a 10CFR50.55(e) report. As indicated in that section, TL' Electric had considered seeking an exemption from 10CFR50.55(e) requirements in certain areas. We no longer intend to request such an exemption. Our corrective actions concerning the untimely submittal of a 10CFR50.55(e) report are contained in the attached Response to Notice of Violation.

We hereby respond to the Notice of Violation. Our efforts to develop a comprehensive and coordinated plan to track, evaluate and report significant construction deficiencies are described in the attachment to this letter.

Very truly yours, W. G. Co,nsil 870910GD93 B70903

, PDR ADCCK 05000445 By: b+ -

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G PDR G. S. Keeley % /-

Manager, Nucle'a ensing RDD/mlh c - Director, Office of Special Projects Mr. R. D. Martin, Region IV p Resident Inspectors, CPSES (3) 400 Nonh Olive .Stract 1,9 81 Dallas, Tens 75201

Attachment to TXX-6693 September 3, l'987 Page 1 of 3 NOTICE OF VIOLATION ENFORCEMENT ACTION 87-122 (445/8707: 445/8706) 10 CFR Part 50.55(e) requires, in part, that the Commission be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of each deficiency in design and construction which, were it to remain uncorrected, could have affected adversely the safety of operations at any time throughout the expected life of the plant, and which represents a significant deficiency in construction which will require extensive evaluation, extensive redesign, or extensive repair to meet the criteria and bases stated in the safety analysic report or to establish the adequacy of the structure or component to perform its intended safety function.

Contrary to the above, TV Electric Company did not report a construction deficiency within twenty-four hours of notification of its significance. By letter dated September 5,1986, Brown-Boveri notified TV Electric that deficiencies in the installation of Class 1E 6.9 kv switchgear could cause failure of the equipment in a seismic event. On February 13, 1987, approximately five months later, TV Electric notified the NRC of the deficiency. The deficiency required extensive repair to establish the adequacy of the components.

RESPONSE TO NOTICE OF ViG.ATION ENFORCEMENT ACTION 87-122 (445/8707: 446/8706)

TV clectric agrees with the alleged violation and the requested information follows:

1. Reason For Violatioji The violation was caused by the failure of personnel to document, in a timely manner, a deficiency (involving the Class 1E 6.9KV switchgear) as a i potentially reportable item in accordance with procedure NE0 CS-1, l

" Evaluation of and Reporting of Items / Events under 10CFR21 and 10CFR50.55(e)".

2. Corrective Steos Taken And Results Achieved On February 13, 1987, the Class 1E 6.9KV switchgear deficiencies were reported as SDAR CP-87-03, pursuant to 10CFR50.55(e).

Corrective Action Report (CAR)87-069 was issued Augu't 7, 1987, documenting the programmatic deficiencies involved in this violation.

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Attachment to TXX-6693 l Leptember 3, 1987 I Page 2 of 3 {

3. Corrective Steos Which Will Be Taken To Avoid Further Violations  !

The following actions will or have been implemented to preclude additional violations. )

1) June 6, 1987, the Vice President of Engineering and Construction issued a directive to all Engineering and Construction organizations concerning the identification of possible conditions reportable pursuant to 10CFR50.55(e). The directive stated that a " heightened sensitivity" to these requirements was required, and directed personnel to initiate programmatic measures et the earliest point a particular deficiency appears to be potentially reportable.

2)< To assure prompt identification of potentially reportable issues, program requirements have been revised to include immediate review of project deficiency documents for deportability. These reviews will be performed by either the operations Shift Supervisors or by CPE Engineering Assurance Regulatory Compliance personnel in accordance with procedures STA-503, " Plant Incident Report" and ECE 9.01-01,

" Review of Corrective Action Documents for Adverse Effects on Safe Plant Operation," respectively. These program requirements have been implemented for documents issued after July 25, 1987. These reviews will be performed independently and in parallel with the established processes for assessing deportability. These programs will result in notification of the NRC no later than thirty days after issuance of a deficiency document if the subject matter is determined to be potentially reportable.

The following procedures will be used to review the indicated deficiency documents:

STA-503 ECE 9.01-01 Work Requests Nonconformance Reports Work Orders Deficiency Reports Construction Deficiency Reports Test Deficiency Reports Corrective Action Requests

3) A program has been established to evaluate previously initiated operations and construction deficiency documents which were not yet  !

reviewed for possible deportability and were open as of July 25, 1987.

This program, conducted in accordance with ECE 9.01-01, will be completed no later than November 25, 1987. Deficiencies which could adversely affect the safety of plant operations will be promptly evaluated for deportability per NE0-9.01 (CS-1), " Evaluation and Reporting of Adverse Conditions Under 10CFR21 and 10CFR50.55(e)"

(formerly NE0 CS-1).

4) The pregram for identification and evaluation of potentially reportable conditions is being revised. The revised program will be governed by the following new or revised procedures:

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Attachment to TXX-6693 ,

September 3, 1987 '

Page 3 of 3 Number Title NE0-9 01 (CS-1) " Evaluation and Reporting of Adverse Conditions  !

(formerly Under 10CFR21 and 10CFR50.55(e)" l NE0 CS-1)

EC-9.01 " Evaluation and Reporting of Adverse Conditions Under 10CFR21 and 10CFR50.55(e)"

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ECE-9.01 "Eva' sating Adverse Conditions for Effect on Pl a- Operations, Significance, and Deportability" ,

I These procedures provide improved guidelines for evaluating conditions j which could adversely affect safe plant operation and determining the 4 deportability of such conditions. These improved guidelines will 1 assist personnel in the prompt recognition of reportable conditions.  !

4. Date When Full Comoliance Will Be Achieved The corrective actions required by CAR 87-069 will be completed no later j than September 18, 1987. Program procedures identified in item 3(4) above a will be issued no later than September 18, 1987. Review programs I described in items 3(2) and 3(3) above, are currently implemented. I Procedures STA-503 and ECE 9.01-01 governing the reviews described in i items 3(2) and 3(3) were revised / issued on July 27, 1987 and Aug st 11, J 1987, respectively, i

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