IR 05000445/1993026
| ML20057F942 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/13/1993 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 9310200003 | |
| Download: ML20057F942 (4) | |
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NUCLEAR REGULATORY COMMISSIOM
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REGION IV
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611 RYAN PLAZA DRIVE, SUITE 400
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ARLINGTON, TEXAS 760118064
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OCT l 31993
Dockets: 50-445 50-446
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Licenses: NPF-87
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TV Electric
ATTN:
W. J. Cahill, Jr., Group Vice President i
Nuclear Engineering and Operations
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Skyway Tower i
400 North Olive Street, L.B. 81
.j Dallas, Texas 75201 l
i SUBJECT: NRC INSPECTION REPORT NO. 50-445/93-26; 50-445/93-26 i
Thank you for your letter of September 2,1993, in response to our-l letter and Notice of Violation dated August 3, 1993. We have reviewed your reply and 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 con.11ance has been achieved and will be maintained.
Sincerely,
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A. Bill Beach, Di c r Division of Reacto roj c s j
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TV Electric i
ATTN: Roger D. Walker, Manager of Regulatory Aff airs for Nuclear Engineering Organization Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201
9310200003 931013 PDR ADDCK 05000445 G
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TV Electric-2-Juanita Ellis President - CASE 1426 South Polk Street Dallas, Texas 75224 GDS Associates, Inc.
Suite 720
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1850 Parkway Place Marietta, Georgia 30067-3237 TV Electric Bethesda Licensing 3 Metro Center, Suite 610 Bethesda, Maryland 20814 Jorden, Schulte, and Burchette ATTN: William A. Burchette, Esq.
Counsel for Tex-La Electric Cooperative of Texas 1025 Thomas Jefferson St., N.W.
Washington, D.C.
20007 Newman & Holtzinger, P.C.
ATTN: Jack R. Newman, Esq.
1615 L. Street, N.W.
Suite 1000 Washington, D.C.
20036 Texas Department of Licensing & Regulation ATTN:
G. R. Bynog, Program Manager /
Chief Inspector Boiler Division 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 Owen L. Thero, President Quality Technology Company P.O. Box 408 201 West 3rd Lebo, Kansas 66856-0408
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-- File # 10130 Ref* # IR 93-26 1UELECTRIC 1ocep7.201 September 2, 1993 William J. Cahill. Jr.
Group Vice Presodem U. S. Nuclear Regulatory Commission Attn:
Document Control Desk II, Washington, DC 20555 SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NO. 50-446 NRC INSPECTION REPORT NO. 50-446/9326 RESPONSE TO NOTICE OF VIOLATION Gentlemen:
TU Electric has reviewed the NRC's letter dated August 3,1993, concerning the inspection conducted by the NRC staff during the period of May 30, 1993, through July 10, 1993.
Attached to the August 3, 1993, letter was a Notice of Violation (NOV).
TU Electric hereby responds to the Notice of Violation (446/9326-01) in the attachment to this letter.
Sincerely,
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William J. Cahill, Jr.
GLM:tg Attachment cc: Mr. J. L. Milhoan, Region IV Mr. L. A. Yandell, Region IV Resident Inspectors, CPSES (2)
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Attachment to TXX-93315 Page 1 of 2 NOTICE OF VIOLATION (446/9326-01)
Comanche Peak Steam Electric Ssation 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-relatea equipment be properly performed in accordance with written
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procedures and documented instructioris.
Section 6.1.8 of Procedure ECE 5.01-03. " Design Change Notices and Related Process Documentation," Revision 4. requires that any change to a Design Change Authorization undergo an engineering review and justification.
Contrary to the above, on June 16, 1993, the inspectors identified that the installation of the packing gland follower for Auxiliary Feedwater Pump 2-01 was not in accordance with the Design Change Authorization contained within maintenance work order instructions for the pump racking replacement.
The pump was released for operation by a mechanical maintenance manager without the required engineering review and justification.
RESPONSE TO NOTICE OF VIOLATION (446/9326-01)
TV Electric accepts the violation and the requested information follows:
1.
Reason for Violation TU Electric believes that the reason for the violation was the failure to
follow procedures. CPSES procedures require any change to a Design Change l
Authorization undergo an engineering review and justification.
Contrary to this requirement, upon completion of maintenance on Auxiliary Feedwater (AFW) pump 2-01, the applicable work documents were signed off by Maintenance with the pump in a different configuration from the Design Change Authorization without approval of the changes by engineering in the work package.
TU Electric's review of the corresponding work order and interviews with the cognizant personnel indicates that the suDject pumD was subsequently reworked and released to operations in accordance with the
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applicable design documents.
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Attachment to TXX-93315 Page 2 of 2 2.
Corrective Steps Taken and Results Achieved ONE Form 93-1594 was generated to document the failure to follow procedures. Auxiliary Feedwater Pump 2-01 was reworked to conform to the design requirements of the Design Change Authorization.
The cognizant a
personnel involved with this violation have reviewed this issue with the Maintenance Manager.
3.
Corrective Steos Taken Tnat Will be Taken to Preclude Recurrence TU Electric believes that this condition is an isolated occurrence, however, the following actions will be taken to prevent recurrence:
A Lessons Learned will be initiated by Maintenance to those groups that-perform work on safety related equipment to ensure personnel awareness that equipment is in compliance with the applicable design requirements prior tp returning the equipment to Operations.
Date of Full Comoliance TU Electric is in full compliance.
Maintenance will issue the Lessons Learned by October 1,1993.