TXX-4586, Responds to NRC Re Violations Noted in Insp Rept 50-445/85-02.Corrective Actions:Test Deficiency Rept 4254 Written to Document Violation & Sys Test Engineers Will Be Reinstructed in Verbatim Requirements Imposed by Deviation

Responds to NRC Re Violations Noted in Insp Rept 50-445/85-02.Corrective Actions:Test Deficiency Rept 4254 Written to Document Violation & Sys Test Engineers Will Be Reinstructed in Verbatim Requirements Imposed by Deviation

ML20138H370
Person / Time
Site:	Comanche Peak
Issue date:	10/10/1985
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20138H362	List: IR 05000445/1985002 TXX-4586, Responds to NRC Re Violations Noted in Insp Rept 50-445/85-02.Corrective Actions:Test Deficiency Rept 4254 Written to Document Violation & Sys Test Engineers Will Be Reinstructed in Verbatim Requirements Imposed by Deviation
References
TXX-4586, NUDOCS 8510290021
Download: ML20138H370 (2)

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Log # TXX-4586 File # 10130 TEXAS UTILITIES GENERATING COMPANY RKYWAY TOWER e 400 NORTH OLIVE ftTMEET. L.B. 5 R . DALLAN. TEXAM 7830 t October 10, 1985 WILLIAM G COUNSIL Enscunvt vict PetsiotmT

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Mr. R. P. Denise i LI i Division of Reactor Safety and Projects DCT I S i2 aq U. S. Nuclear Regulatory Commission Region IV -

"d' Office of Inspection and Enforcement '

611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NO.: 50-445/85-02

Dear Mr. Denise:

l We have reviewed your letter dated September 11, 1985 concerning 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.

j We have responded to the findings listed in Appendix A of thr. letter.

To aid in the understanding of our response, we have repeaNd the Notice of Violation followed by our response. We feel the enclosed information to be responsive to the Inspectors' findings. If you have any questions, please advise.

l Very truly yours, -

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W. G. Counsil JWA/grr Enclosure c- Region IV (Original + 1 copy) l Director, Inspection and Enforcement (15 copies)

U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. V. S. Noonan 8510290021 851023 Mr. D. L. Kelley ADOCK O 5 j i

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Response

The specific instances cited in the Notice of Violation and from Inspection Report Item 8502-05 (1) and (3) have been reviewed and found to be examples of non-compliance with CP-SAP-21 which requires procedure changes to be implemented in accordance with CP-SAP-12.

Further, each instance was reviewed to determine its impact upon the conclusions drawn from the results of the identified tests. As indicated in the Notice of Violation and re-verified during this response development, the changes performed had a sound, technically correct, basis and as such, there were no impacts upon the completed tests.

Additior. ally, CP-SAP-21 and'CP-SAP-12 were reviewed to determine the adequacy of their procedural requirements. Both procedures were found to provide . explicit instructions as to when procedure deviations are required.

,,s ,,, Corrective Steps Taken A Test Deficiency Report (TDR No. 4254) has been written to document this

' violation and it supplements these two data packages with clarifying information relative to this violation.

Additionally, instruction in CP-SAP-21 requirements was the subject of an earlier (March 1985) action item. Among the particular sections to be

. emphasized were the requirements for generating and approving test procedure deviations. Although, there has been minimal preoperational test performances since that time, it is anticipated that the training received was sufficient to increase the overall awareness for proper handling of test procedure deviations.

Action to Prevent Further Occurrence:

Although both tests were performed by different STEs within the same functional group, in an effort to further increase the awareness level, all STEs will participate in a re-instruction in the verbatim requirements imposed by a deviation to a test procedure. Additionally, appropriate Startup personnel will be made aware of the seriousness of the failure to comply with approved procedures.

Date of Full Compliance:

The October clarification 18, 1985. of the test data packages will be in full compliance by The actions to prevent further occurrences will be in full compliance by October 11: 1985.

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APPENDIX A l

NOTICE OF VIOLATION 4

Texas Utilities Electric Company Docket: 50 14E " 15 .

Comanche Peak Steam Electric '

Construction Pern.. .. c R-126 Station, Unit 1 Based on the results of an NRC inspection conducted during the period of January 1,1985, through February 28, 1985, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 49 FR 8553, dated March 8,

~ . - ~ 1984, the-following violation was identified:

Failure to follow orescribed orocedures 10 CFR 50, Appendix "B", Criterion V requires that, " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accompiished in accordance with these instructions, procedures, or drawings."

Contrary to the above, System Test Engineers (STEs) failed to ccmoly with the administrative requirements of Startuo Administrative Procedure CP-SAP-12. " Deviations to Test Instructions / Procedures." During routine inspection _ of the completed preoperational test data package for ICP-PT-29-01, " Diesel Generator Auxiliary Systems," the NRC inspector noted several instances where the STE failed to make chances in accordance

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with CP-SAP-12. Errors in the procedure were either left uncorrected, or in some cases, errors were corrected by unauthorized pen-and-ink changes. Example of this can be found on step 7.3.12 cnc on data sheets 2, 6, 10 and 14. Examples of this practice were found in other completed preocerational test data packages wnich were brought to the attention of  !

the acclicant's representative. In each case the practice dic not cause the outc:me of the test to be adversely affected; however, acministrative recuirements in this regard are not being satisfied.

This is a Severity Level V Violation. (Supplement I:.E) (145/3502-05).

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Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is hereby required to submit to this office, within 30 days of the dates of this notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

Dated: 6EE 11 m

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