ML20058A104
| ML20058A104 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/10/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058A100 | List: |
| References | |
| 50-445-90-31, 50-446-90-31, NUDOCS 9010250282 | |
| Download: ML20058A104 (2) | |
Text
,.
APPENDIX A NOTICE OF VIOLATION TV Electric Docket:
50-445/90-31 Comanche Peak Steam Electric Station Operating License:
NPF-87 Unit 1, Glen Rose, Texas.
h During an NRC inspection conducted during August 7 through September 18, 1990, two violations of NRC requirements were identified. The violations involved failure to follow an alarm response procedure and work order instructions.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part P., Appendix C (1990) (Enforcement Policy), the violations are listed below:
A.
Technic.1 Specification 6.8.1.a requires, in part, that written procedures shall be established, implemented, and maintained for activit'es referenced in Appendix A of Regulatory Guide 1.33, Revisim February 1978.
Paragraph 5 of Appendix A of Regulatory Guide 1..
quires procedures for abnormal, off-normal, and alarm conditions. Alarn acrJure ALM-0081A, Revision 2, Annunciator No. 2.9, provides initial and <ubsequent operator actions for a No. 2 steam generator (SG) feedwater no.zle high flow alarm condition, which includes the requirement to log at 15-minute intervals feedwater flow and feedwater split flow bypass flow.
Contrary to the above, from August 13-30, 1990, logs of No. 2 SG feedwater flow and feedwater split flow. bypass flow were not maintained at 15-minute intervals when the No. 2 SG feedwater nozzle high flow alarm was in an alarm condition. As a result, the licensee was unable to definitely determine the total time that an actual high flow condition existed.
ALM-0081A states that the total time that an actual high flow condition should be allowed to exist between eddy current inspections of the steam generator tubes is 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.
This is a Severity Level IV violation.
(Supplement I) (445/9031-01) 8.
Technical Specification (TS) 6.8.1.a requires that written procedures shall be established, implemented, and maintained fnr activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, Section 9.a states, in part, that maintenance that can affect the performance of safety-related equipment should be performed in accordance with written procedures or documented instructions appropriate to the circumstances.
Station Administration Manual Procedure STA-606, " Work Requests and Work i
Orders," Revision 14, Section 6.6.2.9, requires that work be performed in accordance with the instructions.
Section 6.6.2.13 requires that the work package be revised if the intent of the work instructions must be changed.
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Contrary to the above, the following two examples of failure to follow work order instructions were identified:
On August 14, 1990, oil was not drained from the oil cooler of the Train A centrifugal charging pump, as required by the work instructions in Work Order C90-5224. The work order was not revised to reflect the change in work scope nor was the fact that the oil cooler was not drained noted in the work order.
On September 6,1990, the bearings of the Train A residual heat i
removal pump were not flushed as required by the work instructions in i
Work Order P90-4254.
The work order was not revised to reflect the change in the scope of work to be performed.
This is a Severity Level IV violation.
(Supplement I) (445/9031-03)
Pursuant to the provisions of 10 CFR 2.201, TV Electric is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV, and if applicable, a copy to the NRC Resident Inspector, 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 may be issued to show cause why the license should not bo 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 i
response time.
Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this respm se shall be submitted under oath or affirmaticn.
Dated at Arlington, T xas this/fdday ofg, -
1990