ML20058M248

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Notice of Violation from Insp on 900606-0703.Violations Noted:Procedure OPT-467A Inadequate,Work Crew Opened Unit 2 Reactor Coolant Pump Seal Water Return Filter Instead of Correct Filter & Deficiency Not Promptly Identified
ML20058M248
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/03/1990
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058M247 List:
References
50-445-90-22, 50-446-90-22, NUDOCS 9008100025
Download: ML20058M248 (2)


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7' APPENDIX-A 4

s NOTICE OF VIOLATION TV Electric Dockets:. 50-445 50-446 Comanche Peak Steam Electric Station Operating License:- NPF-87 Construction Permit:.CPPR-127

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.During an NRC inspection conducted June 6 through July 3,1990, three-violations of NRC requirements were identified. The violations involved an inadequate surveil. lance procedure, inadequate corrective action for an identified deficiency, and maintenance on an unauthorized component.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR'Part 2, Appendix C. (1990) (Enforcement Policy), the

violations are listed below:

A.

Technical Specification (TS).6.8.la requires that written procedures shall be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Appendix A, Section 8.b,. states that specific procedures for surveillance tests.should be written, including implementing procedures for each surveillance required by TS.

Procedure OPT-467A, " Train A Safeguards Slave Relay K609 Actuation Test,"

was established in accordance with TS 6.8.1.a.

Contrary to the above, Procedure OPT-467A was inadequate in that it did not provide sufficient guidance regarding the solid state protection system switch lineup to allow testing of the desired slave relay under the existing plant conditions in Mode 5 or to prevent an inadvertent automatic start of a motor-driven auxiliary feedwater pump.

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L This is a Severity Level IV violation (Supplement I) (445/9022-02).

B.

Criterion V of Appendix B of 10 CFR Part 50 requires, 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 drawngs.

Station Administration Manual Procedure STA-606, " Work Requests and Work Orders," Revision 14, Section 6.6.2.9, requires that work be performed in accordance with instructions and in the sequence listed.

Contrary to the above, on June 26, 1990, the work crew opened the Unit 2 reactor coolant pump seal water return filter instead of the correct filter when working under Work Order C90-3176 which authorized work on the Unit 2 reactor coolant filter.

This is a Severity Level IV violation (Supplement II) (446/9022-01).

9008100025 900803 PDR ADOCK r_isOOO4 C.

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= Criterion XVI of. Appendix B of 10 CFR Part 50 and the licensee's' quality assurance program at described in Section 17.2.16 of the Facility Safety.

- Analysis Report (FSAR) requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failure,-

o malfunctions, deficiencies, deviations, defective material and-equipment,

.and nonconformances are promptly identified and corrected.

Contrary to the above, a deficiency was not promptly identified and

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corrected in that the technical disposition.of operations notification and.

evaluation (ONE) Form _ FX90-110 failed to adequately quantify the reported flange misalignment. This resulted in' an indeterminate residual stress condition in the flow. orifice flanged joint immediately upstream of-1 Auxiliary Feedwater Check Valve IAF-093.

Specifically, the technical disposition which allowed the acceptance of 1

th: r.eported misalignment was inadequate -in that it f ailed to properly -

conside.- the actual displacement of the flange which was physically restrained by the presence of. several flange fasteners left in place in

- the flanged joint, i

~ This is a Severity Level IV violation (Supplement I) (445/9022-03).

' pursuant to the provisions of 10 CFR 2,201, TV Electric is hereby required to

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submit to this office, within 30 days of the date of the letter transmitting j

this Notice, a written. statement or explanation in reply, including for each j

violation:

(1) the reason for the violation if admitted...(2) the. corrective j

steps that nave been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full i

compliance will be achieved. Where good cause is.shown, consideration will be 4

given to extending the response time.

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'c Dated at Arlington, Texas

.1 this 3 M day of d 1990 i

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