ML20149G212
| ML20149G212 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/09/1988 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CP-87-47, TXX-88215, NUDOCS 8802180173 | |
| Download: ML20149G212 (2) | |
Text
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__FE Loo # TXX-88215
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File # 10110
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% illiam G. coumil February 9, 1988 riumm,u m,a,,,
V. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.
20555
SUBJECT:
COMAllCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 CONSUMABLE MATERIALS REPLACEMENT PROGRAM SDAR: CP-87-47 (FINAL REPORT)
Gentlemen:
Please ignore our letter logged TXX-88008 dated January 15, 1988 (sent February 8, 1988).
The incorrect document was sent through a word processing error.
The following is the correct document.
On July 17, 1987, we verbally notified your Mr. 1. 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 detarmined to conservatively report this item under the provisions of 10CFR50.55(e).
The required infonnation follows.
DESCRIPTION OF DEFICIENCY The specific observation involves the substitution of a lubricant manufactured by TEXACO in safety and non-safety related applications.
The substitution was accomplished without certification t'y the equipment manufacturers that the material is acceptable for use, and without approval by the proper technical discipline.
This deficiency was caused by the use of unapproved methods for developing the plant lubrication list, and insufficient documentation of lubricant substitution evaluations.
This deficiency applies to all equipment requiring lubrication.
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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Page 2 of 2 i
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 i
Hardware Validation Program (PCHVP).
Supporting documentation will be available onsite following completion of the PCHVP.
Very truly yours, W. G. Counsil l
WJH/in1h c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3) t t
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