ML20126J317

Notice of Violation from Insp on 921011-1125.Violation Noted:Contract Personnel Observed to Operate Polar Crane in Vicinity of Reactor Vessel Head Contrary to Listed Procedural Requirements

ML20126J317
Person / Time
Site:	Comanche Peak
Issue date:	12/31/1992
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20126J302	List: IR 05000445/1992047 ML20126J298 ML20126J317
References
50-445-92-47, NUDOCS 9301060116
Download: ML20126J317 (3)

Text

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APPENDIXA NOTICE OF VIOLATION TU flectric Docket No. 50-445 Comanche Peak Steam Electric Station, Unit 1 License No. NPF-87 During an NRC inspection conducted on October 11 through November 25, 1992, violations of NRC requirements were identified. in accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CfR Part 2 Appendix C, the violations are listed below:

A. Comanche Peak Steam Electric Station Technical Specification 6.8.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33 Revision 2, February 1978.

Regulatory Guide 1.33, Appendix A, paragraph 9a, recommended that maintenance that can affect the performance of safety-related equipment should be planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Maintenance Department Administration Procedure MDA-308. Revision 6,

" Crane and Electric Holst Operator Certification Program," requires the use of guide ropes to control freely swinging loads when manual guidance is required for protection of equipmrtnt. The procedure also requires care during lifting to ensure the lead does not contact any obstructions or that there is no sudden accelera'. ion or deceleration of the load.

Contrary to the above, on November 4,1992, the inspectors observed contract personnel operating the polar crane in the vicinity of the reactor vessel head contrary to the procedural requirements-as follows:  !

(1) The guide ropes were not long-eaough to control swinging loads around the reactor vessel head.

(2) While lowering the stud removal lifting rig, it became entangled with electrical cabling-for a stud detensioning hoist.

(3) While ~the reactor vessel stud lifting rig assembly was being maneuvered'into place over the reactor vessel studs, it was ---

allowed to freely swing and lightly impacted the upper vessel head structure.

(4) As the lifting rig was being repositioned, the rig snagged an I-beam extending from the refueling cavity liner.- The crane operator continued to raise the load and it became detached. The 9301060116 921231--

PDR ADOCK 05000445-G PDR

lifting rig swung abo . in an uncontrolled manner and contacted the reactor vessel head assembly.

This is a Severity level IV violation. (Supplement 1) (445/9247-01)

B. Comanche Peak Steam F.lectric Station Technical Specification 6.8.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Appendix A, paragraph 96, recommended that maintenance which can affect the performance of safety-related equipment should be planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

(1) Station Administration Manual Procedure STA-612, Revision 2,

" System Cleanliness Control and Cleaning," Section 6.7.2, requires austenitic stainless and/or nickel alloy steels be wire brushed with stainless steel brushes.

Contrary to the above. on November 2 and 4, 1992, maintenance technicians were observed using carbon steel wire brushes on stainless steel 'aody-to-bonnet studs for Containment Spray Valves CT-0026 and CT-0028.

(2) Maintenance Department Administration Procedures MDA-405, Revision 3, "Connrol of Tools in the Radiological Controlled Area"; and MDA-4(1, Revision'1, " Control of Tools," requires tools used on stainlest steel to be kept segregated from tools used on carbon steel.

Contrary to the above, on November 4, 1992, the inspectors found unsegregated tools in the Unit 2 radiological controlled area tool room. On November 9,1992, stainless and carbon steel tools in the Unit I containment tool room were found stored in the same bins.

This is a Severity level IV violation. (Supplement- 1) (445/9247-02)

Pursuant to the prcvisions of 10 CFR Part 2.201, TU Electric'is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region IV, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation; (2) the corrective steps that have been taken and the results achieved; (3) the

corrective steps that will be taken to avoid further violations; and (4)_the-date when full-compliance will--be achieved. .If an adequate reply'is not received within the time specified in this Notice, an order or demand for-information may be issued as to why_ the license should _not be modified, suspended, or_ revoked, or why such other action as may be proper should tw. be-taken. Where good cause is shown, consideration will be given to extenv."

the response time.

Dated at Arlington, Texas, this 3/ 4 day of h b 1992