ML20149F288

Notice of Violation from Insp on 940529-0709.Violation Noted:Failure to Remove Field Work Request Tags from safety- Related Equipment Following Voiding of Action Requests or Work Orders

ML20149F288
Person / Time
Site:	Comanche Peak
Issue date:	08/04/1994
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20149F277	List: IR 05000445/1994015 ML20149F272 ML20149F288
References
50-445-94-15, 50-446-94-15, NUDOCS 9408100059
Download: ML20149F288 (2)

Text

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APPENDIX A NOTICE OF VIOLATION TV Electric Dockets: 50-445 Comanche Peak Steam Electric Station (CPSES) 50-446 Licenses: NPF-87 NPF-89 During in NRC inspection conducted on May 29 through July 9, 1994, one  :

violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

A. CPSES Technical Specification 6.8.1 states, in part, that written procedures shcIl 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 9.e, recommends that general procedures for the control of maintenance, repair, replacement, and modification should be prepared before reactor operation is begun.

Administrative Procedure STA-606, Revision 21, " Work Requests and Work Orders," Section 6.2.16, states that, upon the voiding of an Action )

Request, the work request tags should be removed from the component as '

appropriate. Section 6.3.2 states that, upon the voiding of a Work Order, the work request tags should be removea from the component as appropriate. Section 6.6.4.20 states that field work request tags l should be removed at the completion of work.

l Administrative Procedure STA-202, Revision 23, " Administrative Control of CPSES Nuclear Engineering and Operations Procedures,"

Section 4.1.4.6, states that the use of the term "should" in procedural steps indicates a firm CPSES management expectation that the step be performed and that any deviation is a departure from the norm and requires supervisory concurrence.

Contrary to the above, field work request tags were not removed from safety-related equipment following the voiding of action requests or work orders or the completion of work, and supervisory concurrence was not obtained for deviations from Procedure STA-606. As a result, the inspector identified three examples where the failure to appropriately remove work request tags presented a barrier to the identification of necessary work on safety-related equipment.

This is a Severity Level IV violation (Supplement 1)

(445/9415-01; 446/9415-01).

Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby required to l submit a written statement or explanation to the U.S. Nuclear Regulatory j Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy l 9408100059 940so4 l gDR ADOCK 05000445 PDR \

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l to the Regional Administrator, Region IV, 611 Ryan Plaza Drive, Suite 400, ,

Arlington, Texas 76011, 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 a Demand for Information may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Datedat.Arling[

this Q day of ton,Texa g, 994 i l

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