ML20115C271
| ML20115C271 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/13/1992 |
| From: | William Cahill, Walker R TEXAS UTILITIES CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-92476, NUDOCS 9210190256 | |
| Download: ML20115C271 (4) | |
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Log
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- IR 92 32 E
3 Ref.
- 10CFR2.201 1UELECTRIC October 13, 1992 u mum J. c.un. Jr.
o,, v.a n,,,.n r U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNIT 2 00"'.ET NO. 50- 44 6 NR. INSPECTION REPORT NO. 50-445/92-32: 50-446/92-32 RESPONSE TO NOTICE OF VIOLATION Gentlemen:
TV Electric has reviewed the NRC's letter dated September 16, 1992, concerning the inspection conducted by the NRC staff duriag the period August 17 20. I'/92.
This inspection covered activities authorized by Construction Permit No. CPPR 127 Attached to the September 16, 1992, letter was a Hotice of Vialation.
10 Electric hereby responds to the Notice of Violation (446/9232-01) in the attachment to this letter.
Sincerely, h'
1 William J. Cahill, Jr.
By:
S h' f
Roger D. Walker Manager of Regulatory Affairs for NE0 JG/tg Attachment c-Mr. J. L. Milhoan. Region IV Mr.
L.
A.
Yandell. Region IV Resident inspectors, CPSES (2)
Mr. B. E. Holian. NRR 00G;)
9210190256 92?.013
-/f h l
PDR ADOCK 05000446 400 N. Olnt Sircel LB Ki DaHat. Texas 752nl G
PDR L
Atta'chment to TXX-92476 Page 1 of 3 NOTICE OF VIOLATIOR (446/9232 01)
Criterion V of Appendix B to 10 CFR Part 50 and the licensee's approved q
ty assurance program description, devision 85, require that activities atieCling quality shall be prescribed by doc' Tntad procedures and shall be accomplished in accordanca with these procedures,
' The following examples ~ of the f ailure to follow procedures were observed:
1.
Procedure CP SAP 26, "Startup Operating Instructions
- Revision 2, paragraph 6,3, requires expired startup operating instructions to be logged out of the index and discarded from control room files, Contrary to the above, the inspector found_on August 17, 1992, that 9 of a sample of 19 startup operating instructions were expired but not logged out and discarded f rom control room files (i.e., 2-92-RC-501-HFT-SOP-101D, expiration date August 10, 1992:
2-92-RH 501-HFT-SOP 102B, expiration date August 11, 1992:
2-92 PC $01-HFT-SOP 108B, expiration date Augrst 16, 1992; 2 92-51 04, expiration date April.25,1992: 2 92 RH-01, expiration date April 25, 1992; 2 92 RH-02, expiration date March 29, 1992: 2 92-RH 04, expiration date February _15, 1992; 2-92-RH 07, expiration date-July 6, 1992; and 2 92-RH-08, expiration date July 5,1992),
2.
Procedure 00A-104, " Operations Department Document Control," Revision 7, with Procedure Change Forms 1 through 4, paragraph 6,6,1, requires the control room to maintain such procedures as prerequisite testing
- procedures.
Contrary to the above,=the inspector found on-August 18, 1992, that the file of prerequisite testing procedures in the control room:
(a) did-not contain the current revision of Procedure XCP-ME-7, which was issued July 24, 1992: (b) contained Procedure XCP ME-10, which had-been deleted on August 26, 1991: and (c) did not contain Procedure XCP-ME-17, which was issued Hay 7, 1992.
3.
Procedure CP-SAP-078, 'Preoperational' Testing,' Revision-1, paragraph 6,3,1, requires the cont rol room to have a copy of approved test procedures.
Contrary to the above, the inspector found on August-18, 1992,. that four of _ a sample of 15 preoperational test procedures in the control room were missing at least one change notice (i.e., Change 1 of PT-07-02, which was issued-August 10, 1992: Changes 2 and 3 of PT-39-01, which were:lisued August _6 and 7, 1992, respectively; Change 6 of PT 74 02, which was issued July 27, 1992: and Change 6 of PT-90-03, which was-issued July 20, 1992),
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Atta'chment to TXX 92476 Page 2 of 3 r
4.
Procedure CP-SAP-07B, *,'reoperational Testing,' Revision 1, paragreph 6.4,6, requires the startup test engineer to take an approved test procedure change to the startup records center for marking of the I
document as the ' Official Test Copy
- and distribution of copies.
Contrary to the above, the inspector found on August 19. 1992, that Test L
Procedure Change 3 to Test Procedure PT-39 01, which was approved on August 7, 1992, had not been taken.to the startup records center for marking as the ' Official Test Copy
- and distribution of copies.
ELSfQME TO NOT111_OF V10LATI.QJti (446/9232 01) 10 Electric accepts the violation and the requested information follows:-
1.
Reason for Violation The violation cited four examples of the failure to follow procedures.
a.
The_first three Were examples of improper control of procedures retained in the control room for use by operations and test personnel.
The reason for the lack of control of these procedures -is that no individual was assigned respon!.ibility and accountability'for this task.
b.
The fourth example recounts a situation where a test engineer f ailed to process a test procedure change notice in a timely manner.
This problem occurred because the engineer failed to give adequate attention _to cetails of the administrative procedure governing test procedure changes.
2.
Correttive Stets Taken and Results Achieved a.
A review and evaluation has been completed for those procedures cited in the violation which are retained in-the control room.
Those procedures which were no longer needed in the control room have:been removed.
Those procedures which remained were. updated in accordance with.
administrative procedures such that only current and valid copies were
- retained, b.
The test procedure change (number 3r to test procedure 2CF PT 39 01 has been taken to the records-center and processed in accordance with administrative procedures.
'3.
Corrective Steos to Prevent Recurrence a.
Operations management has assigned an individual to the-control room on an interim basis to resolve the t alof problems identified in the
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J Atta'chment to TXX 92476 Page 3 of 3 violation regarding control and maintenance of control -room. documents.
This individual will review documents to assure t. hat their present-status is-current..in addition. this individual will review the administrative handling of these documents ~and identify changes required to preclude recurrence of similar problems.
Finally, when any required changes have been implemented, this individual will' monitor the status i
of thesefdocuments until management -is confiderst that underlying problems which led to this violation have been resolved, b.
A review of ongoing preoperational test procefares was conductea to determine the extent of the problem regardinrc untimely processing.of i
test procedure changes, No other-exemples w3re found.
Based on this, this problem is considered an isolated occurrence.
The test engineeri involved has been counseled regarding the-importance of timely processing of test procedure changes.
4.
Date When Full Comoliance Will Be Achieved
~
Full ompliance has been achieved.
Any changes identified to preclude.
recurrence of similar problems will be implemented by November 30,L 1992, i
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