ML20245E073

Notice of Violation from Insp on 890503-0606.Violation Noted:Neither Test Deficiency Rept Nor Test Procedure Change Processed to Document or Correct Deviation from Test Procedure Instruction

ML20245E073
Person / Time
Site:	Comanche Peak
Issue date:	06/19/1989
From:	Warnick R NRC
To:
Shared Package
ML20245E072	List: ML20245E069 ML20245E073 ML20245E076
References
50-445-89-32, NUDOCS 8906270316
Download: ML20245E073 (2)

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l APPENDIX A NOTICE OF VIOLATION TU Electric Docket: 50-445/89-32 Comanche Peak Steam Electric Station Permit: CPPR-126 Unit 1, Glen Rose, Texas During an NRC inspection conducted on May 3 through June 6, 1989, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Acti~ons," 10 CFR Part 2, Appendix C (1988), the violation is listed below:

. Criterion V of Appendix B to 10 CFR Part 50 states, in part, that activities.affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances, and shall be accomplished in accordance with these procedures.

Paragraph 6.4.1 of Procedure NQA 3.23, Revision 2, " Surveillance Program," states, " Identified unsatisfactory conditions involving quality-related items / activities shall be documented on the Surveillance Report as deficiencies unlecs one of the following actions has been taken:

"a. The unsatisfactory condition had been reported previously via an appropriate corrective action document.

"b. The unsatisfactory condition had no apparent generic )

implications and was corrected as allowed by applicable  :

governing procedures prior to issuance of the surveillance i report.

"c. The unsatisfactory conditicn was documented for resolution i in accordance with methods established in applicable governing procedures."

Paragraph 6.2.7.9.1 of Procedure TDA-303, Revision 0, " Conduct of Testing," states, " Testing shall be performed in accordance with approved test procedures and instructions." Paragraph 6.1.6 of 1 TDA-306, Revision 0, " Control of Deficiencies and Nonconformances," I states in part, "When an approved test procedure / instruction is not complied with, a TDR shall be processed . . . .

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i a . Contrary'to theLabove, Surveillance Report 0S-89-0041 noted that-a "Otep ofian approved Test Procedure, 1CP-PT-44-01 SFT, could not be

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or was not' performed as written. The surveillance report noted that the Startup Test engineer would include the occurrence in the cummary of the test: report; however, neither a test deficiency

-report 1(TDR) nor-a test procedure change was processed to document-

.or correct the unsatisfactory conditions; i.e., deviation from a testsprocedure' instruction, therefore a surveillance deficiency should have been' written. The failure to follow the requirements of

. Procedures NQA:3.23, TDA-303, and TDA-306 is a violation.

This is'a Severity-Level IV violation (Supplement II)

,(445/8932-V-01).

Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby l required to submit a written statement or explanation to the U. S.

Nuclear Regulatory Commission,' ATTN: Document Control' Desk, Washington, DC, 20555, with a copy to the Assistant Director for Inspection Programs, Comanche Peak Project Division, Office of l Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this 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 if admitted, (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 b tthis' Notice,.an: order may be issued to show cause why the license y 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.

FOR THE NUCLEAR REGULATORY COMMISSION I

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. Dated at Comanche Peak Site this 19th day of June 1989 i

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