IR 05000445/1993022

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/93-22 & 50-446/93-22

ML20056D564
Person / Time
Site:	Comanche Peak
Issue date:	08/10/1993
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 9308170078
Download: ML20056D564 (4)

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f Fg NUCLEAR REGULATORY COMMISSION f I #? ( j REGION IV h, 8 611 RYAN PLAZA DRIVE, SulTE 400

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AUG I O 1993 Dockets: 50-445 i 50-446 Licenses: NPF-87

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NPF-89 TV Electric ATTN: W. J. Cahill, Jr., Group Vice President Nuclear Engineering and Operations Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 SUBJECT: NRC INSPECTION REPORT 50-445/93-22; 50-446/93-22 Thank you for your letter dated July 23, 1993, in response to our letter and Notice of Violation dated June 30, 1993. We have reviewed your reply and

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find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a- future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely,

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A. Bill Beach, tir c or Division of Re ct Pr jects cc:

TU Electric ,

ATTN: Roger D. Walker, Manager of Regulatory Affairs for Nuclear Engineering Organization Skyway Tower

400 North Olive Street, L.B. 81 Dallas, Texas 75201 9308170078 930810 dh)

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Bethesda Licensing j 3 Metro Center, Suite 610 Bethesda, Maryland 20814 Jorden, Schulte, and Burchette 'i ATTN: William A. Burchette, Es ;

Counsel for Tex-La Electric  :

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Cooperative of Texas 1025 Thomas Jefferson St., Washington, D.C. 20007 Newman & Holtzinger, ,

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Texas Department of ~ Licensing & Regulation ATTN: G. R. Bynog, Program Manager /

Chief Inspector ,

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P.O. Box 12157, Capitol Station Austin, Texas 78711 .

Honorable Dale McPherson County Judge  ;

P.O. Box 851 Glen Rose, Texas 76043 Texas Radiation Control Program Director 1100 West 49th Street Austin, Texas 78756 >

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7 Log # TXX-93267

,., ;!O m j - 2 File # 10130 C

Z Ref. # IR 93-22 TllELECTRlC 10CFR2.201

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M it.'imm J. Cahill, J c . ,,,,,, r.u r,,,.*,,, July 23, 1993 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 NRC INSPECTION REPORT NOS. 50-445/9322; 50-446/9322 RESPONSE TO NOTICE OF VIOLATION Gentlemen:

TV Electric has reviewed the NRC's letter dated June 30, 1993, concerning the inspection conducted by the NRC staff during the period of April 28, 1993, through May 29, 1993. Attached to the June 3J, 1993, letter was a Notice of Violation (NOV).

TU Electric hereby responds to the Notice of Violation (445/022-01; 446/9322-01) in the attachment to this lette

Sincerely,

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p <-CofW #)cb William J. Cahill, J ff By: d @ '

Roger D. Walker Manager of Regulatory

Affairs Nuclear Production OB:tg Attachment

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cc m Mr; J. L. Milhoan, Region IV Mr. L. A. Yandell, Region IV Resident Inspectors, CPSES (2)

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Attachment to TXX-93267 Page 1 of 3 NOTICE OF VIOLATION (445/9322-01; 446/9322-01)

Comanche Peak 5 team Elec*.ric Station Technical Specification 6.8.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A to Regulatory Guide 1.33, paragraph 9a, requires that maintenance that can affect the performance of safety-related equipment be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Paragraph 9b requires the development of preventive maintenance (PM) schedule Station Administration Manual Procedure STA-677, Revision 2. " Preventive Maintenance Program," Section 6.4.6, requires that delinquent PM work orders be evaluated by plant engineering. A technical evaluatiot.shall be issued addressing the effect of the PM's delay on equipment operabilit Contrary to the above, on May 26, 1993, the inspectors identified that an annual inspection of the safety-related Control Room Air-Conditioning Unit X-03 had not been accomplished since January 1991, and a technical evaluation had not been issued addressing the effect delaying the PM had on equipment operability.

, RESPONSE TO NOTICE OF VIOLATION (445/9322-01; 446/9322-01)

TU Electric accepts the violation and the requested information follows: Reason For Violation Comanche Peak Steam Electric Statio~n Administration procedure STA-677,

" Preventive Maintenance Program" defines a delinquent Preventive Maintenance (PM) as one that is not completed by a date that is 25 percent of its assigned frequency beyond its original due date. The PM for inspection of the Control Room Air-Conditioning Unit X-03 was an event driven (e.g., Outage) PM and had no defined frequency. The frequency field in the PR-ISM software was blank (NULL), but appeared as zero on data base reports. This led the responsible work organization i to believe that the PM could not become delinquent; and therefore, a l need for a " Technical Evaluation" was not required for this PM work orde Additionally, the existing methods for identifying and tracking delinquent PM work orders did not include considerations for event driven, condition driven, and other non-normal PM activitie !

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Attachment to TXX-93267 Page 2 of 3 Corrective Steps That Have Been Taken And The Results Achieved A Technical Evaluation (TE) concerning the effects of the late performance of the PM for control room air-conditioning Unit X-03 was performed. The evaluation concluded that the late performance of the PM did not result in significant degradation in the equipment condition or reliabilit An Independent Safety Engineering Group (ISEG) surveillance was being conaucted during the Inspection Report 445/9322 inspection period. The scope of this surveillance was to review the TEs performed on PM activities that were anticipated to become delinquent to determine the acceptability of such evaluation ISEG noted concerns similar to the NRC's finding that, typically, some TEs did not address the effect on equipment operability for a delay in PM activitie ONE Form 93-1155 was initiated to document the issue regarding the PM activity and the failure to perform a less than adequate evaluation of effect on equipment operabilit Additionally, eighty-eight (88) PM work orders that were originally scheduled for Unit 1 outage IRF02 but were not yet closed were identified as potentially delinquent. These PM work orders were reviewed to verify that a TE had been completed or that no TE was required. The cognizant organization verified that an adequate TE had been issued for each PM activity which was delinquent. Methods for identifying and tracking delinquent PM work orders has been improved to include non-norral and event / condition driven PM activitie . Corrective Steps That Will Be Taken To Preclude Recurrence In order to preclude recurrence procedure STA-677, " Preventive Maintenance Program" will be enhanced to provide the following: Definition of when normal, event driven, and condition driven PM activities become overdue and delinquen Definitio'n of when a TE is warrante Definition of the requirements for issuing, processing,

, evaluating, and closing a TE associated with the PM progra An improved methodology has been developed and implemented to identify and track overdue and delinquent PM work orcers to assure that TEs are completed when warrante .F

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Attachment to TXX-93267 Page 3 of 3 .;

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4 Date When Full Compliance Will Be Achieved TV Electric is in full complianc The enhancements to STA-677 is expected to be complete by.th'e end of the !

third refueling outage for Unit ;

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