ML20247N100
| ML20247N100 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/28/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89529, NUDOCS 8908020277 | |
| Download: ML20247N100 (3) | |
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Log # TXX-89529 l
File # 10130 r
Z Ref. # 10CFR2.201 1
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nlELECTRIC.
July 28, 1989 Wmiam J. Cahl't. Jr.
Esenunve Vicel' resident -
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 REVISED RESPONSE TO NRC INSPECTION REPORT
'3 50-445/89-32: 50-446/89-32 REF: 'TU Electric. letter TXX-89452 from W. J. Cahill to USNRC, dated July 10, 1989 Gentlemen:
The referenced' letter provided TU Electric's response to Notice of Violation (NOV) 445/8932-V-01.
In that response, TU Electric stated that by required reading of the subject test deficiency report (TDR) and a draft of the TU Electric response, startup personnel nad been made aware af the occurrence described in the TGV, and reminded of the importance of making conservative decisions when wrmining whether s deficiency has occurred.
Also TV Electric stated inat via. memo, Quality Assurance surveillance personnel have been reminded of the impoetance of formally reporting procedural deviations.
Although the information described above has been conveyed to the subject personnel, the mechanisms used were different ft om that described in the refererced letter. At.cordingly, TV Electric's response has been revised to more accurately describe the appropriate actions.
Revision bars in the right margin indicate the changed portions of TU Electric's attached revised response.
Sincerely, William J. Cahill, Jr.
DAR/ddm Attachment c - Mr. R. D. Ma.* tin, Region IV Resident Inspectors CPSES (3)
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8908020277 890728 DR ADOCK 0500 5
400 North Olive Street LB SI LGu, a aos 73201
Attachment to TXX-89529 July 28, 1989 Page 1 of 2 NOTICE OF VIOLATION (445/8932-V-01)
Criterion V of Appendit B to 10CFR 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 NOA.3.23, Revision 2, " Surveillance Program,"
states, " Identified unsatisf actory 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 en 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."
l-Paragraph 6.2.7.9.1 of Procedure TDA-303, Revision 0, " Conduct of Testing" states, " Testing shall be performed in accordance with approvea test procedures and instructions".
Paragraph 6.1.6 of TDA-306. Revision 0, o
" Control of Deficiencies and Nonconformances," states in part. "When an approved test procedure / instruction is not complied with, a TDR shall be processed...."
Centrary to the above, Surveillance Report 05-89-0041 noted that a step of an approved Test Procedure ICP-PT-44-01 SFT, could not be or was not performed as vritten. The surveillance report noted that the Startup Test engineer would include the occurrence in the summary of the test report: however, neither a test deficiency rt: port (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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.1 flj.>. Attachment'toTXX-89529
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July 28, 1939 i
Page 2 of 2
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l RESPONSE TO NOTICE OF VIOLATISH (445/S932-V-01)
TU Electric agrees to the violation and the requested information follows.:
1,___ Reason for the Violation:
i Step _7.1.2) of Test Procedure 1-CP-PT-44-01 SFT, states "Open Valve 1-HV-2397 1
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 f rom t.he Control Board) had been satisfied, the STE considered that compliance 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 0A surveillance personnel who were-observing the test noted the occurrence and using similar reasoning to that of the STE did not note the occurrence as a Surveillar9ce Deficiency.
2.
Corrective Stet,s Taken and Results Achieved:
A Test Deficiency Report has been issued to document the occurrence.
1 Corrective Steps Which Will be Taken to Avoid Further Violations:
Through discussion and lecture, startup personnel have been made aware of this occurrence and reminded of the importance of making conservative decisions when determining whether a deficiency has occurred and a deficiency document is required.
Subsequently, these actions were enhanced by required reading of the TDR and TU Electric response per TXX-89452. QA surveillance personnel have been reminded of the importance of formally reporting procedu?al deviations. This reminder has b6ec reinforced during the morning " Plan of the Day" 0A Surveillance staft' meeting, furthermore, the surveillance supervisor has been directed to place additional emphasis during the review of all surveillance reports to assure any procedural deviation identified in the report (s) are properly documented as a surveillance deficiency per N0A 3.23.
4.
Dale When Full ComDliance Will be Achieved:
Full compliance has been achieved.
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