ML20044C435
| ML20044C435 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/17/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20044C434 | List: |
| References | |
| 50-446-93-02, 50-446-93-2, NUDOCS 9303230031 | |
| Download: ML20044C435 (2) | |
Text
Q.
APPENDIX A NOTICE OF VIOLATION TU Electric Docket: 50-446 Comanche Peak Steam Electric Station Construction Permit: CPPR-127 During an NRC inspection conducted January 4-30, 1993, violations of NRC' requirements were identified.
In accordance with the " General Statement of Policy and Procedure for the NRC Enforcement Actions," 10 CFR 2, Appendix C the violations are listed below:
A.
Criterion V of Appendix B to 10 CFR 50 states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
1.
Contrary to the above, during the period January 4-30, 1993, NRC identified that Procedures 15U-001, 15U-101B, 150-2408, 150-260B, and 150-280B, which would have been used in initial startup and power ascension testing, were inappropriate because they required the licensee's staff to conduct unspecified activities described as performance of " applicable" or " appropriate" portions of referenced procedures.
2.
The licensee specified that preoperational testing should be conducted in accordance with requirements given in CPSES Startup Administrative Procedure (SAP) CP-SAP-07B, "Preoperational Testing." SAP CP-SAP-07B required that deficiencies identified during preoperational testing be processed in accordance with requirements given in SAP CP-SAP-16.
Paragr.ph 6.8.1.8 of SAP CP-SAP-078 required that the test group supervisor shall approve a retest for performance by signing the " Required Ratest" block on the Startup Deficiency Report (SDR).
(a)
Contrary to the above, during 12 preoperational test results evaluations, the licensee identified numerous examples in which preoperational tests had not been conducted -in accordance with administrative requirements. - Specifically, there were hundreds of violations by startup test engineers of administrative requirements given in SAP CP-SAP-07B and/or SAP CP-SAP-16. These violations, which included errors such as the failure to record test activities in the applicable test. logs, the failure to ensure that appropriate procedure step signoffs were obtained prior to proceeding to subsequent procedure steps, and failure to initiate proper deficiency documentation for test discrepancies, occurred
' during preoperational testing in the timeframe of March to December 1992.
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(b)
Contrary to the above, the inspectors identified two instances (SDRs 2974 and 3033) in which the test group-supervisor approved retests for performance on October 2, 1992,-which was after the retests were performed on September 30, 1992.
This is a Severity Level IV violation (446/9302-01) (Supplement II).
B.
Criterion XVI of Appendix B to 10 CFR 50 and the licensee's approved quality assurance program, Revision 87, require that measures shall be established to assure that conditions adverse to quality are promptly r
identified and corrected.
Contrary to the above, the inspectors found on January 7, 1993, that the licensee's actions to prevent repetition of a violation of requirements pertaining to the administrative handling of documents was not effective because Procedure Change Notice 6 (effective November 21, 1992) to Procedure 50P-313. " Turbine Plant Cooling Water System," was not in the control room copy of the procedure. This is a repetition of a similar problem identified in Violation 446/9232-01.
This is a Severity Level IV violation (446/9302-02) (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby required to submit a written statement or explanation to the Regional Administrator, Region IV, with a copy to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved..
If an adequate reply is not received within the time specified in this Notice, an order or demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be-given to extending the response time.
Dated at Arlington, Texas this /75* day of@@ 1993.