ML20149E370

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Interim Deficiency Rept CP-87-47 Re Consumable Matls Replacement Program.Initially Reported on 870717.NEO 6.05 When Issued & Implemented,Will Provide Adequate Controls for Lubrication Activities
ML20149E370
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 01/15/1988
From: Counsil W
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CP-87-47, TXX-88008, NUDOCS 8802110023
Download: ML20149E370 (2)


Text

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January 15, 1988 U. S. Nuclear Regulatory Commission Attn:

Document Control Desk Wat,hington, D.C.

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SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION DOCKET N05. 50-445 AND 50-446 CONSUMABLE MATERIALS REPLACEMENT PROGRAM SDAR:

CP-87-47 (INTERIM REPORT)

Gentlemen:

On July-17, 1987, we verbally notified your Mr. I. Barnes of an apparent inadequacy involving the program for technical approval of replacement consumables. Our latest interim report was logged TXX-6950, dated November 13, 1987.

After further evaluation, we have determined that this item is reportable under the provisions of 10CFR50.55(e).

The required information follows.

DESCRIPTION OF DEFICIENCY The specific observation involves the substitution of lubricants manufactured by TEXACO in safety and non-safety related applications.

The substitution was accomplished without certification by the equipment manufacturers that the material is acceptable for use, and without approval by the proper technical discipline.

SAFETY IMPLICATIONS Use of a lubricant that does not meet equipment manufacturer's specifications could lead to the damage and/or failure of the equipment, thus adversely affecting plant operations.

Due to the extensive evaluation required to ensure the replacement lubricant is acceptable, we have conservatively concluded that this item is reportable pursuant to 10CFR50.55(e).

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TXX-88008 february 8,1988 Page 2 of 2 CORRECTIVE ACTIONS NE0 6.05, "Chemicals /Consumables and Lubricants Control Program," when issued and implemented for-site lubrication activities, will provide adequate controls via a lubrication specification and-implementing procedures for lubrication activities.

Training to the program for lubrication requirements will be required for all personnel associated with these activities.

We are conducting a review to determine which components are lubricated with substituted lubricants.

Corrective action will consist of documenting the approval of a substitute lubricant or replacing the substitute lubricant with the manufacturer's specified lubricant for each component. Our review is scheduled to be completed by July 15, 1988.

Implementation of NE0 6.05 is also scheduled for July 15,1988.

The approval / removal of substituted lubricants will be completed in conjunction with the Post Construction Hardware Validation Program (PCHVP).

Supporting documentation will be available onsite following completion of the PCllVP.

Very truly yours, S

W. G. Counsil WJH/mlh c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) 1

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