ML20094L414
| ML20094L414 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/09/1992 |
| From: | Walker R TEXAS UTILITIES CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20094L411 | List: |
| References | |
| NUDOCS 9203250202 | |
| Download: ML20094L414 (5) | |
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- T u - 92118 Fi1e il 10130 r
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% llliam J. Cahill, Jr.
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U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington. DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
UNIT 2 DOCKET NO. 50 446 NRC INSPECTION REFORT N0. 50 445/91 67: 50 446/91-67 RESPONSE TO NOTICE Of VIOLATION Gentlemen:
TU Electric has reviewed the NRC's letter dated February 10, 1992, concerning the inspection conducted by the NRC staff during the oeriod December 9 13, 1991, and January 6-9 1992.
This inspection covered activities authorized by Construction Perritt No, CPPR-127.
Attached to the February 10, 1992, letter was a Notice of Violaticn.
l TV Electric hereby responds to the Notice of ViolJtion (446/9167 01) in the attachment to this letter.
Sincerely, 1
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William J. Cahill, Jr.
By:_
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Roger D. Walker Manager of Nuclear Licensing l
JG/ds Attachment l
c Mr-. R. D Hartin.-Region IV-Resident inspectors, CPSES (2')
Mr. H. B. Fields, NRR 9203250202 920319 ADOCKOS00g5 PDR 0
400 N. Ouve stnet LB. 81 Danas ydc C SsY.Tesas 75201 J
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e Attachment to TXX+92118 Page 1 of 3
@TICE OF VlQLATI0tt (446/9167-01) 4 Ouring an NRC inspection conducted on December 9-13. 1991, and January 6-9, 1992, a violation of NRC requirements was identified. In accordance with the ' General
- Statement of Policy and Procedure for NRC Enforcement Actions.* 10 CfR Part 2.
Appendix C (1991), the violation is listed below:
- Criterion V of Appendix-B to 10 CFR Part 50 requires that activitier affecting quality be accomplished i n accordance with procedures appropriate to the circumstance, Contrary to the above, eight Unit 2 preoperational test procedures were found to contain numerous-format and content errors and were determined to be inadequate and not appropriate to the circumstance for which they were written.
. RESPONSE TO NOTICE OF VIOLATION (446/9167-01)
TV Electric accepts the violation and the requested information follows:
1.
Reason for Violation Startup management performed a review of-numerous approved preoperational test procedures including those identified in NRC Inspection Report No.
50-445/91-67: 50 446/91-67.
An evaluation of the errors in format and content led to the following conclusi'ons.regarding the reasons for the
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-conditions noted in the Notice of Violation:-
The Stadup Administrative Procedures used to develop,- review and approve Preoperational Test Procedures contained insuf ficient detail.
Test-Procedure reviewers concentrated on aspects of the-procedure pertinent _to their scope of responsibility (i.e., design, operation, testability, _ etc. ),
but no one assured.. that all aspects. of the procedure were adequate The Joint '. Test ' Group - did 'not consistently assure that comment incorporation was thorough and accurate, i
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Attachment to TXX 92118 Page 2 of 3 2.
- [orrective'$teps Talen an_d Results Achtgred The Manager of Startup placed an administrative hold on all approved Preoperational lest Procedures.
A review of the two conpleted Preoperational Tests was performed.
The test results were found to be satisfactory.
Startup personnel involved in test procedure development, review and approval have been counseled regarding the importanco of-attention to detail in_ procedure format and content.
The Manager of Startup has personally counseled members of Joint Test Group regarding the scope of their responsibility, particularly in regard to technical accuracy.
3.
Corrective Steos Te en to Prec1nde Recurrence Startup'Hanagement has initiated a comprehensive corrective action program which includes:
Issuing a Preoperational Test Procedure Writers and Reviewers Guide.
This guide is designed to provide sufficient detail to assure clear and consistent format so as to minimize the potential for errors similar to those identified in the Notice of Violation.
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A review of all Preoperational Test Procedures to assure f ormat conforms to the writer and reviewers guide and to assure technical adequacy.
I A comparison of Unit 2 to Unit 1 Preoperational Test Procedures for
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technical content, 1
A review end revision of Startup Administrative Procedures to clarify the' process for development, review and approval of Preoperational Test Procedures.
.The formation of _ - a _ Test Procedure Review Group within-Startup-t comprised - of Senior Startup Engineers with extensive experience developing and implementing preoperational_ tests. Review by members L
of this group.is designed to assure procedures are technically adequate, consistent in format and flow wM1-for ease of performance.
l Increased. Quality - Assurance involvement to - include a technical surveillance of selected Preoperational Test Procedures.
A field walkdown cf select Preoperationall Test Procedures which are complex to assure testability, t
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1 AttBChment to IXX*92118 l' age 3 of 3 4
08te of Full Compliance The process for develepment, review and approval of Preoperational Test Procedures is presently in full compliance wit h this corrective action
- program, All Unit Preoperotional Test Procedures issued for implementation since t he Det ember NRC Inspect ion have been developed and/or will be reviewed and approved in accordance with this corrective action program prior to peformance of the test.
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FEB I O 1992 Docket Nos. [0-445 50-446 License No. NPF-87 f
Construction Permit No. CPPR-127 TV Electric ATTN:
W. J, Cahill, Jr., Executive Vice President, Nuclear Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Gentlemen:
SUBJECT:
NRC INSPECTION REPORT NO. 50-445/91-67; 50-446/91-67 (NOTICE OF VIOLATION)
This refers to the inspection conducted by Messrs. D. L. Kelley, R. B. Vickrey and R. M. Latta of this office on December 9-13, 1991, and January 6-9, 1992.
The inspection included a review of activities authorized for your Comanche Peak Steam Electric Stxtion f acility.
At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed report.
The areas examined during the inspection are identified in the report and included the review of Unit 2 preoperational test procedures and the review of the quality assurance audit of Unit 2 startup activities.
Based on the results of this inspection, certain of your activities appeared to be in violation of NRC requirementt, as specified in the enclosed Notice of Violation (Notice).
The violation is of concern because it indicates an inadequate review of preoperational test procedures for Unit 2.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your o sponse.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR Part 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enciosures will be placed in the NRC Public Document Room.
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- previously concurred
- concurred via telecon 4