ML20246N535
| ML20246N535 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/14/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89452, NUDOCS 8907190391 | |
| Download: ML20246N535 (3) | |
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' ?4 MbE L. Log '# TXX-89452
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File # 10130
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Ref. # 10CFR2.201 1UELECTRIC li WHEam J. Cahul, Jr.
Extewive Vice President i:.
O. S.- Nuclear : Regulatory Commission Attn:. Document Control Desk Washington, D. C.
20555'
SUBJECT:
COMANCHE PEAK' STEAM ELECTRIC STATION (CPSES)'
DOCKET NOS.'50-445 AND 506446 RESPONSE TO NRC INSPECTION REPORT NO. 50-445/89-32; 50-446/89-32 Gentlemen:-
TU Electric has reviewed the NRC's letter dated June 19, 1989.concerning the inspection conducted by Mr. C.' Hale and other NRC Inspectors and NRC Consultants during the period May 3 through June 6. 1989. This. inspection covered ' activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for CPSES Unit I and 2.
Attached to the NRC's letter was a Notice-of'
-Violation.
TU Electric hereby responds to the Notice of: Violation in the attachment to this letter.
Sincerely, f
,),
William J. Cahill, Jr.
DAR/vid Attachment c - lir. R. D. Martin, Region IV Resident Inspectors, CPSES (3) h I h CM 05000445 72 890714 G
PNV 5
400 North Olive Street LB81 Dallas, Texas 75201
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Attachment to TXX-89452
' July 14, 198 Page 1 of 2 NOTICE OF VIOLATION (445/8932-V-01) l l
Criterion V of Appendix B to 10CFR Part 50 states. in part, that activities l
affecting quality shall be prescribed by documented procedures of a type l
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, " Identification unsatisfactory conditions involving quality-related items / activities shall be documented on the Surveillance Report as deficiencies unless 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 report.
C.
~ The unsatisfactory condition was documented for resolution 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 TDA-306 Revision 0,
" Control of Deficiencies and Nonconformances," states in part "When an approved test procedure / instruction is not complied with, a TDR shall be processed...."
Contrary to the above. Surveillance Report OS-89-0041 noted that a step of an approved Test Procedure ICP-PT-44-01 SFT, could not be or was not performed as written. The surveillance report noted that the Startup Test engineer >:ould include the occurrence in the summary of the test report: however, neither a test deficiency report (TDR) nor a test procedure change was processed to document or correct the unsatisfactory conditions:
i.e., deviation from a test procedure instruction, therefore a surveillance deficiency should have been written. The failure to follow the requirements of Procedure N0A 3.23, TDA-303, and TDA-306 is a violation.
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fd-r Attachment to TXX-89452 July 14, 1989 Page 2 of 2 RESPONSE TO NOTICE OF VIOLATION (445/8932-V-01)
TU ' Electric agrees to the violation and the requested information follows:
la Reason for'the Violation:
Step 7.1.27 of Test Procedure 1-CP-PT-44-01 SFT, states "Open Valve 1-HV-2397 by momentarily placing 1-HS-2397 on ICB-08 to '0 PEN'."
In performing this step, the Startup Test Engineer (STE) and the Reactor Operator (RO) determined that to open valve 1-HV-2397, it.would be necessary to hold-the switch in the open position until the open indication was received.
Approximately five seconds were required for the valve to reach the open position. The STE considered that the term " momentarily" provided sufficient latitude to hold the switch in the required position for a short duration, five (5) seconds.
Additionally, since the intent of the step-(opening the valve from the Control Board) had been' satisfied, the STE considered that compl19nce with the
_ procedure had been achieved.
Based on his knowledge of the valve control circuitry and the test objective the STE knew that the occurrence did not indicate a hardware deficiency nor did it invalidate any test results.
For-the above reasons, the STE did not consider that a deficient or non conforming condition existed and did not initiate a Test Deficiency Report. The STE noted the occurrence in the test report so that the procedure wording could be improved if the test was repeated. The OA surveillance personnel who were observing _the test noted the occurrence and using similar reasoning to that of the STE did not note the occurrence es a Surveillance Deficiency.
2 C,prrective Steos Taken and Results Achieved:
A Test Deficiency Report has been issued to document the occurrence.
3.
Corrective Steos'Which Will be Taken to Avoid Further Violatioqi:
By required reading of the TDR and e draft of this letter, startup personnel have been made aware of this occurrence and reminded cf the importance of making conservative decisions when determining whether a deficiency has occurred and a deficiency document is required.
Via memo, Quality Assurance Surveillance personnel have been reminded of the importance of formally reporting procedural deviations.
4.
Date When Full Como11ance Will be Achieved:
Full compliance has been achieved.