ML20133E951

Notice of Violation from Insp on 850301-0430.Incomplete

ML20133E951
Person / Time
Site:	Comanche Peak
Issue date:	09/12/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20133E934	List: ML20133E931 ML20133E951 ML20133E966
References
50-445-85-06, 50-445-85-6, NUDOCS 8510100073
Download: ML20133E951 (2)

See also: IR 05000301/2004030

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APPENDIX A

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NOTICE OF VIOLATION

Texas Utilities Electric Company Docket: 50-445/85-06

Comanche Peak Steam Electric Permit: CPPR-126

-Station, Unit 1

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' Based on the results of an NRC inspection conducted during the period of

f March 1 - April-30, 1985, and in accordance with the NRC Enforcement Policy

(10 CFR Part 2, Appendix C), 49 FR 8583, dated March 8, 1984, the following

violation was identified:

Failure to Provide an Adequate Procedure

1

, 10 CFR 50, Appendix B, Criterion V states, in part, that " Activities

affecting quality shall be prescribed by documented instructions, i

. procedures, or drawings, of a type appropriate to the circumstances and  !

shall be accomplished in accordance with these instructions, procedures,

. or drawings." "Section 13.1 of the applicant's Operations Administrative l

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Control and Quality Assurance Plan similarly requires activities which

affect quality-related components to be carried out in accordance with  !

written approved procedures.  !

i (1) Contrary to the above, the applicant's maintenance administrative

procedure MDA 201, " Electrical and Mechanical Maintenance Procedure

and Instructions" provide inappropriate instruction in that

Section 4.3.7.3 leaves it to the option of the procedure writer to

number the steps and to so state if the exact sequence is essential.

This conflicts with Section 4.5.3 which requires approved change to

the procedure if the exact sequence of steps within a section or

subsection must be changed.

(2) Contrary to the above, Maintenance Action Request MAR 85-0292,

Revision 1 changed the sequence of performing Mechanical Maintenance

Instruction MMI 302, " Reactor Coolant Pump Inspection," without an

approved change to MMI 302 as required by Section 4,.5.3 of MDA 301.

(3) Contrary to the above the applicant failed to provide a procedure

for removal of the broken seal ring from No. 2 Reactor Coolant pump.

(4) Contrary to the above, Deficiency Report 85-012 did not provide

corrective actions as required by Section 4.7 of Station

Administrative Procedure STA-404, " Control of Deficiencies," to

prevent recurrence of unapproved changes to Mechanical Maintenance

Instructions.

I This is a Severity Level IV Violation. (SupplementIID)(445/8506-03).

Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is

hereby required to submit to this office within 30 days of the date of the

letter transmitting this Notice, a written statement or explanation in reply,

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Notice of Violation -

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including for each violation: (1) the reason for the violations if admitted,

the corrective steps which have been taken'and the results achieved,

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the corrective' steps which will be taken to avoid further violations, and

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.', the date when full compliance will be achieved. Where good cause is shown. -

consideration will be given to extending the response time. .

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a Dated ~ at Arlington, Texas,

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" i, f this 12th day of September, 1985. f

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