ML20116A888
| ML20116A888 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/28/1992 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-92533, NUDOCS 9210300196 | |
| Download: ML20116A888 (3) | |
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Log Il TXX-92533 File Il 10130 IR 92-37 TUFl ECTRIC Ref.
II 10CFR2.201 i
October 28, 1992 j
Wi!Ilam J. eahill, Jr.
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Gwup t% e toeskirnt U. S. Nuclear Regulatory Commission Atto:
Document Control Oesk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
NRC INSPECTION REPORT NOS. 50-445/92-37 AND 50-446/92-37 RESPONSE 10 NOTICE OF VIOLATION Gentirmen:
TO Clectric has reviewed the NRC's lette' dated September 28, 1992, the inspection was conducted by the NRC staff during the period of August 17 through August 20, 1992.
These inspections covered activities authorized by NRC Operating License NFP-87 and Construction Permit CPPR-127.
Attached to the September 28, 1992, letter was a Notice of Violation.
10 Electric hereby responds to the Notice of Violation ii. the attachment to this letter.
Sincerely, William J. Cahill, Jr.
JET /ds Attachment I
C-Mr. J. L. Milr,aan Region IV Resident inspectors, CPSES (2)
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J Attachment to TXX-92533 Page 1 of 2 NOTICE Of VIOLATION 445/9237-01 446/9237-01 10CFR Part 50, Appendix B, Criterion V, requires that activities affecting
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quality shall be prescribed by and accomplished in accordance with instructions, procedures, or drawings.
1.
CPSES Administrative Procedure STA-737 Boric Acid Corrosion Detection and Evaluation," Revision 0, paragraph 6.3 requires that, for each source of leakage identified, the systems engineer shall " Check to see if either a work request (WR) or an open work order exist which addresses the leakage, if not, initiate a WR noting the items determined in Section 6.2."
Contrary to the above, during a containment building walkdown and visual examination of principal locations for leakage and/or presence of boric
- acid crystals, conducted on October 3, 1991, 54 components were identified by the system engineers as displaying boric acid leakage and were correctly recorded on form 0PT-303A-2, "RCS Identified Leakage."
However, no documented evidence was made available to the inspector which would confirm that a verification had been made to assare that a WR or work order had been initiated for each source of 4dcntified leakage.
2.
CFSES Administrative Procedure STA-737, " Boric Acid Corrosion Detection and Evaluation," Revision 0, paragraph 6.4, subparagraph 6 4.1 requires that the systems engineer (s) list each principal location,.in accordance with Attachment 8.A. On the form OPT-303A-2.
As a minimum (if no-leakage found), the form should state, for each principal incation,_
condition "OK."
C'ntrary to the above, the documented results of the October 3, 1991, containment welkdown d, nN+ contain the above listing.
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Attachment to TXX-92533 Page 2 of 2 TU Electric accept $ the violation and the requested information follows:
(1) Erason for Violation The reason for the violation was error on the part of plant personnel to comply with requirements of the governing procedure, in performing the walkdown, plant personnel did not document-those principle locations which were observed to be free from boric acid crystals or corrosion.
In completing the records, the general work order which accomplished the cleaning of components within the containment was not recorded for those compor.ents where boron crystals were discovered.
(2) Corrsctive Steps Taken and Results Achieved An Operations Notification and Evaluation ONE form was generated to document that principle locations, where no leakage was discovered, had not been noted on the OPT-303A-2 form.
Additionally, a ONE Form was i
initiated to document the failure to record the applicable work order-number as required by STA-737.
(3) ac11gns Taken to Preclude Recurrence CPSES Administrative Procedure STA-737, " Boric-Acid Corrosion Detection and Evaluation" hss been revised to list all of the principle locations on the data sheet. This action serves as ar, aid in-the comprehensive documentation of all principle locations. The system engineer charged-with effecting this program was made cognizant of-the violation-and the procedural requirement to record associated work orders where sources of boric acid leakage is identified.
(4) Date On Which Full Compliance Will Be Achieved TV Electric is in full compliance, f
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