ML19332C548

Responds to NRC 891013 Ltr Re Violations Noted in Insp Repts 50-445/89-72 & 50-446/89-72.Deficiency Rept Written to Document Condition & Initiate Corrective & Preventative Action Plan.Portion of Temporary Mod Re Unit 1 Removed

ML19332C548
Person / Time
Site:	Comanche Peak
Issue date:	11/20/1989
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-89795, NUDOCS 8911280251
Download: ML19332C548 (3)

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ip C C IR 89-72

1R'89-72 7t# ELECTRIC g,f, g.100FR2.201 EO,hMj, '

November 20, 1989 I f

. U. 3.' Nuclear Regulatory Commirsion '!

Attn: Document Control Desk 1 Washington, D. C. 20555  :

SUBJECT:

C0HANCHE PEAK STEAH ELECTRIC STATION (CPSES)

• DOCKET- NOS. 50-445 - AND- 50-446 > I NRC INSPECTION REPORT-NOS, 50-445/89-72: 50-446/89-72  :

RESPONSE TO NOTICE OF VIOLATION  ;

, Gentlemen:

TV Electric has' reviewed the NRC's letter dated October 13. 1989,. concerning  ;

the inspection conducted by Hessrs. K', D. Johnson and S. D. Bitter during the.

. period of September 6,throunh October 3,-1989. This inspection-covered'  ;

activities authorized by NRC Construction Permits CPPR-126 and CPPR-127-for

~CPSES Units 1 and.2. Attached to the NRC's letter was a Notice of Violation.

2 .TV Electric requested and received a two week extension in providing this i

response in a telephone conversation with Mr.-R. F..Warnick-on-

. November 13, 1989. ,

TV Electric hereby: responds to-the Notice of Violation in the att'achment to

.- thi s . l etter .

Sincerely, .

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Willian J. Cahill, Jr, n

RSB/gj Attachment c Hr. R. D. Martin. Region IV Resident Inspectors, CPSES (3)

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P. O. Box 1002 Glen Rose. Texas 4043-1002

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'4 : , s Attachment to TXX-89795 Page 1 of 2 j NOTICE OF VIOLATION (445/8972-V-02)

Criterion V of Appendix B to 10 CFR Pert 50, as implemented by Section 5.0, Revision 1, of the TU Electric Quality Assurance Manual, requires that activities affecting quality shall be prescribed by and accomplished in accordance with docurented instructions, procedures, or drawings.

Station Administration Procedure (STA) 602, " Temporary Modifications," Section 6.1.5, requires a technical review and Operations manager approval of any tempornry modifications which must remain installed af ter turnover.of a system >

from Startup to Operations. Section 6.3.4 of STA-802 " Acceptance of Station Systems and Equipment," contains similar requirements. ,

Contrary to the above, on September 20, 1989, the inspector found that the instrument. air system had been turned over to Operations, but still had a startup temporary modification installed. The review and approval required by Procedure STA-602 had not been, performed.

RESPONSE TO NOTICE OF VIOLATION (445/8972 V-02)

TV. Electric accepts the violation and the requested information follows:

1. . Reason for Violation Temporary modifications are presently installed on systems under Startup jurisdiction in accordance with Startup Administrative Procedure CP "AP-13. " Temporary System Mcdifications". However, when a temporary modification is to remain installed on a system after turnover to

. Operations, a technical review and Plant Manager approval is presently required in accordance with Station Administrative Procedure STA-602,-

" Temporary Modifications". ,

l The subject temporary modification was installed at the boundary of the Unit 1/ Unit 2 interface of the instrument air system. It consisted of a j blank flange with a valve and nipple to facilitate the-connection of an air hose. This hose was connected to some Unit 2 components.

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The startup engineer incorrectly identified and logged the installation as

! a Unit 2 temporary modification even though the flange was installed on the Unit 1 interface. As a result it was not recognized as pnrt of, nor l included in, the Unit 1 instrument air turnover package. In addition.

L during the walkdown process, the plant staf f system turnover engineer f ailed to identify the installed modification as part o' the Unit 1 instrument air system turnover.

As a result, this modification remained installed after system turnover to Operations but did not receive the required review and approval.

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Attachment to TXX-89795 Page 2 of 2

2. Correct'ive SteDs Taken and Results Achieved A Deficiency Report was written to document the condition and initiate the corrective and preventative action plan. The portion of the subject temporary modification affecting Unit I has been removed.

3. Corrective Steos Which Will Be Taken to Avoid Further Violations A review was performed of existing Startup temporary inodifications to identify any which impact Unit I systems. Two additional. modifications were_ found which involved Unit I systems. Both have been converted to Operations-temporary modifications.

Training has been conducted for plant staff system engineers to discuss lessons learned from this event, including the need to understand and carefully verify system. boundaries at the time of turnover.

Site programs, such as the' Unit 2 temporary modification program and

_ procedur?s which incorporate the locked valve guidelines, are being reviewed to ensure controls are in place to preclude inadvertent interaction with Unit I systems by personnel working on Unit 2. I f-weakne.sses are found, appropriate changes will be made to provide sufficient controls.

4. Date of Full Compliance Full compliance will be achieved prior to Unit I fuel load.

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