ML20247G603

Notice of Violation from Insp on 890405-0502.Violation Noted:Shift Test Engineer Failed to Obtain Shift Supervisor Permission to Perform Class 1E Inverter Test & Operator Failed to Perform Two Steps During Realignment of Pump

ML20247G603
Person / Time
Site:	Comanche Peak
Issue date:	05/18/1989
From:	Warnick R Office of Nuclear Reactor Regulation
To:
Shared Package
ML20247G577	List: IR 05000445/1989024 ML20247G572 ML20247G603
References
50-445-89-24, 50-446-89-24, NUDOCS 8905310022
Download: ML20247G603 (3)

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i APPENDIX A NOTICE OF VIOLATION l

TU Electric Dockets: 50-445/89-24 50-446/89-24 Comanche Peak Steam Electric Station Permits: CPPR-126 Units 1 and 2, Glen Rose, Texas CPPR-127 During an NRC inspection conducted on April 5 through May 2, 1989, a 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 (1988), the violation is listed below:

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

This violation is composed of four examples of failure to follow procedures. These four examples are discussed as follows:

1. CPSES Test Department Administration (TDA) Manual Procedure TDA-304, Revision 0, Section 6.2, states that the test engineer must obtain the shift supervisors approval to initiate preoperational tests. Furthermore, Section 6.1 requires the test engineer to obtain the shift supervisor's approval to implement changes to preoperational test procedures.

Contrary to these requirements, the shift test engineer (STE) who was performing Preoperational Test 1CP-2T-01-02, "118 Volt Class 1E AC Inverters," discovered that he had failed to obtain the shift supervisor's permission to perform the test.

Furthermore, he had not obtained the shift supervisor

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approval to implement three temporary procedure changes.

2. CPSES TDA Manual Procedure TDA-303, Revision 0, Section 6.2.7, requires that preoperational testing be performed in accordance with approved test procedures and instructions.

Contrary to these requirements, during the conduct of Preoperational Test Procedure 1CP-PT-37-01, " Auxiliary Feedwater System (Motor-Driven Pump)," the required test equipment (a comparator and associated equipment) was removed from the flow transmitter prior to completion of the required testing and before implementation of the restoration section.

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3. CPSES TDA Manual Procedure TDA-303, Revision 0, Section 6.2.7 requires that preoperational testing be performed in accordance with approved test procedures and instructions.

Contrary to this requirement, while attempting to perform Step 7.3.7 of Preoperational Test Procedure 1CP-PT-64-03,

" Turbine Runback and Peactor Control," a bistable switch was manipulated in the process control Cabinet No. 2 instead of in the process control Cabinet No. 1 as the procedure directed.  ;

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4. CPSES Operations Department Administration (ODA) Manual i Procedure ODA-407, Revision 1, Section 6.1 requires that plant systems and subsystems be operated in accordance with written approved procedures during normal, abnormal, and emergency conditions except as allowed by the procedure (ODA-407).

'Furthermore, Section 6.1 of ODA-407 requires that any  ;

individual who cannot follow an operating procedure as written, i shall place the system or component into a safe or stable  !

condition and notify the shift supervisor immediately. l Finally, Section 6.1 of ODA-407 states that if the desired or anticipated results in a step are not achieved, the individual should not proceed.

Contrary to these requirements, while performing Steps 5.5.3.1 and 5.5.3.2 of CPSES System Operating Procedure SOP-304A, Revision 5, an equipment operator failed to perform these two steps in the specified order during realignment of the-turbine driven auxiliary feedwater pump. The procedure specifically states that the turbine driven auxiliary feedwater pump discharge valve be closed prior to opening the recirculation valve.

These four examples of failure to follow procedures are collectively a Severity Level IV violation (Supplement I) (445/8924-V-01).

Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby required to submit a written statement or explanation to the U. S. l Nuclear Regulatory Commission, ATTN: Document Control Desk,  !

Washington, DC, 20555, with a copy to the Assistant Director for inspection Programs, Comanche Peak Froject Division, Office of Special Projects, within 30 days of the date of the letter trans-aitting 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.

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3 L If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license )

. should not be modified,. suspended, or revoked or why such other 1 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

& Vl00 Y Dated at Comanche Peak Site this 18th day of May 1989