ML20106A992
| ML20106A992 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/25/1992 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-92440, NUDOCS 9209300200 | |
| Download: ML20106A992 (3) | |
Text
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- 1xx 92440 9
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10130 IR 92-25 j p 9;. ;r, Pef.
10CiR2.201 y 7 7 (;g September 25, 1992 mm.n. < un. h t., w \\ v v r,t u ra II.
5, flut lea r Requl at or y temmiu.ivo Attn:
l'o c ume n t (ontr01 Dost Washington, DC 20S55
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50thit t i :
(OHAtiLHL PE AR S1t AM Lit 01PIC ST AT1011 (CPSES)
DOCKET 1105, 50 445 AliD 50 446 flPC IfiSPECT10!1 REPORT 1105 50-445/92-25 AtlD $0 446/92 '$
RLSlotiLE TO HOllli Of V10lAlluti Gentlemen:
1 tl [lectric has reviewed the f4RC's letter dated August 27, 1992, concerning the inspect ion conduc ted by the flRC staf f dur ing the period June 14 through August 1, 1992.
This inspection covered activities authorized by flRC Operatina License flFP-87 and Const ruction Permit CPPR 127.
Attached to the August 27, 1992, letter was a flotic e of Violation.
1 11 Electric her eby t esponds t o t he flotice of Violation in the attachment to thit letter Sincerely,
(*hh(I,,-,h'.0k l0,
~
William J. Cahill, Jr.
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9 p y Roger D. Walter r80038
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' Re d"' a t or v ^" a i's for 1100 GlH/bm At t ac hment c
Mr.
J.
L, Milhoon, Pegion IV Mt-B. t Holian, 11RP Resident inspectors, CPLES (2)-
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92o9300200 92o925
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Attaciment to TXX 92440 page 1 of 2 1
NOTICE Of V10 TAT 10N (446/9225 01)
Criterion V of Appendix B to 10 CfR part 50 as implemented by Section 5 of the 10 Electric Quality Assurance Manual, states, in part,
- Activities affecting quality shall be prescribed by procedures and shail be accomplished in accordance with these nrocedures.*
Operations Department Administrative p ocedure ODA 410, ' System Status Control ' Revision 4, Step 6.1.8, requires, in part, that lineups which are incomplete or have unresolved discrepancies should not be placed in the system status file until completed with all discrepancies resolved.
Step 6,1,9 requires, in part, that the discrepancy resolutions be clearly identified on the lineup and initialed and dated by the unit / shift supervisor.
Contrary to the above, on sluly 14, 1992, the inspector noted thit the inst romant air system valve and switch lineup was perf ormed and, while still incomplete, was reviewed, signed as complete, and placed in the system status file.
The integrated plant operating instruction was sijned as having the instrument air system lined up f or plant operations.
RESPONSE TO NOTICE OF VIOLATION (446/9225 01) 10 Electric accepts the violation and the requested information followst (1) Reason for Violation TV Electric performed a comprehensive review of the applicable-documents dnd interviewed cognizant personnel, it was concluded by this review-that the cause for this violation was a lack of attention to detail, by 2
Unit 2 Operations personnel, in dispositioning the valve lineup _
discrepancies along with a lack of familiarity, by Unit 2 Operations personnel, with maintaining the Startup Operating-Instructions (501s).
(2) [orrective Stens Talen and Results Achieved-The instrument air system valve lineup was immediately reperformed_to confirm the exact configuration and no valves were found to be 4
mispositioned.
However, additional valves were discovered which were-not listed in the Systems Operating procedure (50P).
Another lineup (including the additional valves) was performed and again, no mispositioned valves were discovered,. A review-of the -twenty-nine 50ps required to support plant heatup was performed prior to exceeding the 200 degrees f plateau and no mispositioned or ' additional *
-valves were identified.
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poue 2 of J A revlew of the twrotv-nine ' 0l': requiral to support Hnt iun(tiunal l e *, t i n g (Hil) was perfoemed prior to ot.eeding the %D dem ers F plateau and no rn i ', p n *, i t i o n e d n r "additinnal" valve
- were i rle n t i f i e d.
I I (of'ti(jYM b [X pl,. I.Q k.'/ O 1V A Y'I) I of (It ( 3 l,f,'}#$ Ifllk f
i operations 5tandinq order 9c on% he been issued to provide additional
'Inidante to OpA 407
- Guideline nn Uw of frocedures" an<t OpA-410 '5ystem
'.tatus Conttol*
hpe(ifically, thi standing ordar provides examples of difflioltiet ex per ient ed dur ing implementation of S0ps and 501s used to align Unit J s y *, t e m e, for HiI.
the '.tarniing order a l s o o f f e r t'. sol ut ions to these efemples and ptovides a focal point for initiatinq changet to pioredore' poviews of the admini st rat i ve control *, delineated in OpA 407 and ODA-410 have imen completed and procedural e n h a n t. e me n t ! di e beina implemented.
The need for inri e ated it t ent ion t o det all, bnth in the f i e l d a nd w i t h d nt_ nm"n t a t i on, has been emphasited t o Operat ions petsonnel by Oper at i ens m.inaqoment.
(4)
Pf.1"_ _W hen _I p i l Frmp.1ioncq Will J;.n A3h i e v gl roll.ompliance will b.
u ni..v..d by october 29, Ic92.