TXX-4287, Responds to NRC Re Deviation Noted in Insp Rept 50-445/84-15.Corrective Actions:Spec 6.5.1.6 Changed to Require Station Operations Review Committee Review of Only Administrative Procedures
| ML20135A243 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/27/1984 |
| From: | Clements B TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Bangart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20135A225 | List:
|
| References | |
| TXX-4287, NUDOCS 8509100069 | |
| Download: ML20135A243 (3) | |
Text
l TEXAS UTILITIES GENERATING COMPANY NKYWAY Tt pWEH
- Soo NOHTil OR.IVE MTHEET L.II. Mi
August 27, 1984 TXX #4287 3m@M0WM3 r~
\\
y AUG 3 01984 h
__j&
Mr. Richard L. Bangart, Director Region IV Comanche Peak Task Force U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Docket No.:
50-445 Comanche Peak Steam Electric Station Response to NRC Notice of Deviation Inspection Report No. 84-15 File No.:
10130
Dear Mr. Bangart:
We have reviewed your letter dated July 30, 1984 on the inspection conducted by Messrs. D. L. Kelley and W. F. Smith of activities authorized by NRC Construction Permit CPPR-126 for Comanche Peak, Unit 1.
We are hereby responding to the Notice of Deviation listed in Appendix A of that letter.
To aid in the understanding of our response, we have repeated the Notice of Deviation followed by our response. We feel the enclosed information to be responsive to the Inspectors' finding.
If you have any questions, please advise.
Yours truly, a
BRC:msc c: NRC Region IV - (0 + 1 copy)
Director, Inspection & Enforcement (15 copies)
U.S. iiuclear Regulatory Commission Washington, D.C.
20555 Mr. T. A. Ippolito e
8509100069 850906 PDR ADOCK 05000445
.,r(j O
PDR i
A DSViol0N or TEKAN E!TELETIER ELECTRIC COMI ANY A
APPENDIX A NOTICE OF DEVIATION Texas Utilities Electric Company Docket:
50-445/84-15 Comanche Peak, Unit 1 Construct ion Permit : CPPR-126 Based on the results of an NRC inspection conducted during the period of March 1 through April 30, 1984, and in accordance with NRC Enforcement Policy (10 CFR Part 2, Appendix C), 49 FR 8583, dated March 8, 1984, the following deviation was identified:
Deviation From a Commitment to NRC The FSAR, Page 1 A(B)-14, in response to question Q421.19 commits the licensee to Regulatory Guide 1.33, Revision 2, February, 1978. The Regulatory Guide endorses ANSI N-18.7-1976, as an acceptable method of compliance with the program requirements of Appendix B to 10 CFR 50.
The licensee's commitment took no exceptions nor proposed an acceptable alternative to this commitment for the area of safety-related maintenance instructions; thus, all provisions of the Regulatory Guide and ANSI Standard as they pertain to PWR's apply.
In deviation from the above, the licensee has developed a program and specific maintenance instructions that have not been reviewed and approved by the Station Operations Review Committee (445/8415-01).
Corrective and Preventive Steps Taken Regulatory Guide 1.33, Rev. 2, and its endorsement of ANSI N18.7-1976 does not require the Station Operations Review Committee (SORC) to review all station procedures and instructions. However, the CPSES Technical Specifications (Proof and Review), in Specification 6.5.1.6, did require SORC review of applicable procedures listed in Appendix A of Regulatory Guide 1.33, Rev. 2.
Changes to Specification 6.5.1.6, which require the SORC to review only administrative procedures, have been submitted to the Nuclear Regulatory Commission.
In addition, Specification 6.8.2 has been changed to define instructions as follows:
"Some activities may be controlled by the use of instructions.
Instructions provide directions for specific activities within a particular department or section that do not affect the operability of the plant."
Specification 6.5.3, entitled Technical Review and Control, has been added which requires that:
All procedures and instructions be reviewed by a qualified individual or a.
group other than the individual or group who prepared the procedures or instructions; b.
Procedures and instructions be approved by the appropriate supervisor; c.
SORC approve the instruction approval process; and L__
4 e
,9 Page 2 d.
Each person responsible for approving instructions determine the need for any cross-disciplinary review and see that such review is accomplished prior to instruction approval.
In order to clarify the review, approval, and use of instructions, similar changes have been submitted to the FSAR (Sections 13.5 and 17.2) and the Operations Administrative Control and Quality Assurance Plan (Section 13.1).
Station Procedure STA-209 was issued and establishes the requirements for review and approval of instructions. This procedure requires that departments or sections needing instructions must first write a procedure which is SORC approved detailing the format, review, and approval process for those instructions.
STA-209 also requires that all safety-related instructions be reviewed by the Operations Quality Assurance Section prior to approval.
This review assures that station requirements concerning instructions are being complied with.
Date of Full Compliance All changes have been submitted. These changes si.ould be approved by September 15, 1984.
r l
L