ML20034E447
| ML20034E447 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/19/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20034E446 | List: |
| References | |
| 50-445-92-62, 50-446-92-62, NUDOCS 9302260169 | |
| Download: ML20034E447 (3) | |
Text
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l APPENDIX A NOTICE OF VIOLATION l
Dockets:
50-445
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TU Electric Comanche Peak Steam Electric Station, Units I and 2 50-446 i
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License: NPF-87 l
i Construction Permit: CPPR-127 I
-i During an NRC inspection conducted on December 21, 1992, through January 21,
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1993, violations of NRC requirements were identified.
In accordance with the
" General Statement of-Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, the violations are listed below:
A.
Criterion VI of Appendix B to 10 CFR Part 50 and Comanche Peak Steam Electric Station Final Safety ~ Analysis Report, Amendment 81, i
Section 17.2.6, " Document Control," state that measures shall be i
establi.shed to control the issuance of documents such as instructions, procedures, and drawings thereto, which prescribe all activities 1
affecting quality.- These measures shall assure that documents, including changes,' are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed.
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Contrary to the above, on December 30, 1992, it was identified that i
established procedures were not adequate to assure that' documents, including changes, were distributed to' and used at the location where l
the prescribed activity is performed. Specifically, vital station Drawing M1-0259, " Boron Recycle System," located in the work control-l.
center was not marked up' to show the additional piping and valves-l installed by Temporary Modification 92-1-103, Revision 1.
Vital station 1
drawings located in the clearance processing' center were not markad~ up j
l to show any temporary modifications applicable to Units 1 or 2.
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This is a Severity Level IV violation. -(Supplement I) (445/9262-01; 446/9262-01) 1 B.
Criterion XVI of Appendix-B to 10 CFR Part 50 and Comanche Peak Steam i
l Electric Station Final Safety Analysis Report, Amendment 85, l
Section 17.2.16, " Corrective Action," state that measures shall be l
established to assure 'that condi_tions adverse to quality,'such as failures, malfunctions, deficiencies, deviations, defective material and' equipment, and nonconformances are promptly' identified and corrected.
In the case' of significant conditions adverse to quality, meas'ures shall assure'that the cause of the condition'is determined.and corrective action taken to preclude repetition.
Contrary to the above, established measures were not adequate to assure that deficiencies with the implementation of the temporary modification program were promptly identified and corrected to preclude repetition of significant conditions adverse to quality.
i 9302260169 930219
.PDR ADOCK 05000445 G
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1.
The corrective actions taken to preclude repetitive' deficiencies' with maintaining vital station drawings updated to reflect active temporary modifications were.not adequate. On July-10, 1992, 1
Operations Notification and. Evaluation (ONE) Form 92-651 1
identified that vital station Drawing M1-0235 was; not properly updated to reflect Temporary Modification 92-1-13. -The corrective actions taken~did not preclude subsequent' occurrences as identified.on ONE Form 92-821, dated August 19, 1992; ONE Form 92-981, dated October.8, 1992; ONE Form 92-1561, dated j
December 7,-1992; and ONE Form 93-082, dated January 8, 1993.
_j 2.
The cause for safety-related Transformer cpl-ECTRET-02 remaining
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energized on November 11, 1992, after Clearance 1-92-01073 was implemented, was not determined and corrected to preclude a j
i repetition. of the problem on December 3,1992, when Transformer CPX-EPMCNB-21 remained energized after Cle'arance X-92-02849 was implemented..Following the second event, j
corrective actions again were. not~ implemented to identify. and correct the temporary modification implementation deficiency which 1
resulted in the transformers remaining energized.
j 3.
P1 ant Incident Report 91-0555 dated ~Aprili18,1991, had not been dispositioned to resolve implementation' problems with the temporary modification 'progr_am.
l 4.
Prompt corrective actions were not.taken to resolve a temporary
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modification configuration control deficiency identified on'0NE Form 92-0668,-dated July '14,1992. ~It was identified that, j
although two isolation points had:been' installed on a steam generator drain line,_only one was documented'and removed when the_
1 temporary modification was closed. One of the corrective actions identified in ~ the ONE Form was'.to revise-Temporary l
Modification 91-1-052 to reflect the_ second isolation point.
l This corrective action was' not implemented and, on _ November 16,
- 1992, while attempting to drain' the. steam generator,"it was identified that the line was still isolated but not documented in any temporary modification.
i This is a Severity Level IV violation.
(Supplement I) (445/9262-02; l
446/9262-02)
C.
Technical Specification 6.8.la requires -that-written' procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A~ of Regulatory Guide 1.33, Revision 2,-dated
- February 1978..' Appendix A to Regulatory Guide-1.33, paragraph -la,-
requires.that' administrative procedures be. developed' for controlling equipment' status (e.g., locking and tagging).
Administrative Procedure _STA-605,' Revision 11, " Clearance and Safety =
Tagging," Section 2.2, establishes the applicability of-this procedure
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to identify the established forms, tags, and documents that are necessary for the users of this procedure to adequately impact, prepare, hang, log, and restore clearances...Section 4.2 defines the clearances as assurance that a component, subsystem, or system is isolated or configured as specified on the clearance report.
Contrary to the above, Administrative Procedure.STA-605, Revision 11,.
was not adequate to assure that users of the procedure identified the' documents that_ are necessary to adequately impact, prepare, hang, log and restore clearances as indicated by the following examples:
On November 11, 1992, Clearance Order 1-92-01073 was implemented to deenergize safe!"-related Transformer CP1-ECTR 5T-02; however, Temporary p
Modification 92-1-66 was not considered in the
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clearance report resulting in the transformer i
remaining energized.
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On December 3, 1992, Clearance Order X-92-02849 was implemented to deenergize nonsafety-related -
3 Transformer CPX-EPMLNB-21; however, Temporary Modification'92-1-30 was not considered in the clearance i
order resulting in the transformer remaining energized.
i This is a Severity level IV violation.
(Supplement I) (445/9262-03)
Pursuant to the provisions of 10 CFR Part 2.201, TU Electric is-hereby required to submit a written statement or explanation to the U.S. Nuclear l
Regulatory Commission, ATTN: Documen+ control' Desk, Washington, D.C. 20555, l
with a copy to the Regional Administrator, Region IV, and a copy to the NRC l
Resident Inspector at the facility that is the subject'of this Notice, within 30 days of the date of the letter transmitting this Notice of l
Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violat. ion:
(1) the reason for the violation, or, if contested, the basis.for disputing the violation, i
(2) the corrective steps that have been taken and the results achieved, j
(3) the corrective steps that will be-taken to avoid further violations,.
and (4) the date when full compliance will be achieved. LIf'an adequate reply:
i is not received within the time specified in this Notice,.an order or demand.
j for information may be issued as to why the license should not be modified,
-l suspended, or. revoked, _ or why such.other action _ as may be proper should not be j
- taken. Where good cause is shown,. consideration will be given to extending j
the response time.
Dated at frlington, Texas, i
this/ Q day of February 1993 i
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