TXX-4819, Suppls Response to NRC Re Violations Noted in Insp Repts 50-445/85-13 & 50-446/85-09.Corrective Actions: Procedural Controls for Potentially Deleterious Matls Upgraded

Suppls Response to NRC Re Violations Noted in Insp Repts 50-445/85-13 & 50-446/85-09.Corrective Actions: Procedural Controls for Potentially Deleterious Matls Upgraded

ML20206T122
Person / Time
Site:	Comanche Peak
Issue date:	05/23/1986
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20206T121	List: ML20206T116 TXX-4819, Suppls Response to NRC Re Violations Noted in Insp Repts 50-445/85-13 & 50-446/85-09.Corrective Actions: Procedural Controls for Potentially Deleterious Matls Upgraded
References
TXX-4819, NUDOCS 8607070493
Download: ML20206T122 (5)

Text

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. Log # TXX-4819 M 4

File # 10130 IR 85-13 85-09 TEXAS UTILITIES GENERATING COMPANY MKYWAY TOWER . 400 NORTH OEJVE WTREET. I B. S1. DAIJ AS TEXAS 75301 May 23, 1986

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==L== 7 Mr. Eric H. Johnson, Director E 2IE Division of Reactor Safety and Projects y V. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76012

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 SUPPLEMENTAL RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NOS.: 50-445/85-13 AND 50-446/85-09

Dear Mr. Johnson:

We have reviewed your letter dated April 3,1986, requesting additional infor-mation regarding our response to Item B of the Notice of Violation (NOV) and Item A of the Notice of Deviation (NOD) transmitted with your letter of Decem-ber 24, 1985.

We requested and received a two week extension in providing our response in a phone discussion with Mr. Tom Westerman on April 23, 1986. We were granted a second two week extension during a phone discussion with Mr. Westerman on May 7, 1986. We were granted an additional one week extension by Mr. Westerman on May 21, 1986.

Attachment I to this letter responds to your Question (1) regarding Unit 1 operations procedural controls for potentially deleterious materials.

Attachment II responds to your Question (2) on the cause of the procedural weakness.

Regarding Item A of the N0D, Dr. Fred Webster with the help of Results Report Review Conmittee personnel reviewed the sampling aspects (i.e., population definition, sample selection, etc.) of all action plans as a part of the CPRT review of the Action Plans issued in Revision 3 of the CPRT Program Plan. This review was completed February 1, 1986, and no significant problems were identified.

Surveillance activities associated with Items C, D, and E will not be performed on a routine continuing basis.

Very truly yours, i 8607070493 860627 ADOCK 0500 5 fM

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Attachm:nt I Unit 1 Operations-Procedural Controls for Potentially Deleterious Materials Discussion:

In December, 1985, a working committee composed of representatives from Radia-tion Protection, Chemistry, Quality Assurance, Maintenance, Engineering and Technical Support was formed to develop a single station procedure for control-ling the use of deleterious materials in CPSES Plant Operations activities.

Procedure STA-626, " Administrative Control of Chemical Substances and Materi-als," was drafted to include the formation of a master list of approved materi-als for use by station personnel. The master control list in STA-626 will be developed by the committee through review of applicable construction specifica-tions, vendor manuals and the Consumable Control list maintained by TUGCo Nuclear Engineering. Procedure STA-626 is now in the review and approval cycle.

Prior to development of STA-626, maintenance activities in CPSES Plant Opera-tions were accomplished by approved procedures and instructions written to be in compliance with governing construction specifications, such as G&H 2323-MS-100 and ES-100. If a particular consumable material was used in safety related equipment and not specifically listed in approved documents, Engineer-ing approval was required prior to use of the material.

Quality-related maintenance activities are performed under STA-606, " Work Orders / Work Requests". Work Orders are reviewed by Maintenance Engineering and TUGCo Quality Control to assure that only approved solvents, lubricants and chemicals are used in maintenance activities. Review of Work Orders is per-formed using drawings, specifications and TUGCo Nuclear Engineering's Consumable Control List.

To further assure that consumables are properly controlled, Chemistry Section procedures specify chemicals to be used for chemistry control of systems.

Chemistry procedures were developed under the guidance of the Westinghouse Project Information Package. In addition, STA-608, " Control of Measuring and Test Equipment," specifically addresses the use of instruments containing mercury or aluminum in safety-related systems. Potentially deleterious materials purchased for use in quality-related applications are reviewed against applicable specifications by the Operations Support Department. TUGCo Quality Control inspectors perform a weekly housekeeping inspection which includes review of work activities to assure chemicals and materials are properly used.

For the above reasons, TUGCo Plant Operations has no basis to believe that a problem presently exists with safety-related plant equipment. To provide additional assurance, the following actions will be taken to control use of chemical substances and materials.

Corrective Action:

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1. A specific order has been issued to require use of Gibbs & Hill specifications when TUGCo approved instructions, procedures and design dccuments do not specify the chemical or solvent to be used. If the chemical or solvent is not found in the Gibbs & Hill Specification, the TUGCo Nuclear Engineering Consumable Control List is to be used.

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2. Procedure STA-606, " Work Orders / Work Requests," will be revised to require l

solvents and lubricants specified in Work Orders to be in accordance with Procedure STA-626, " Control of Chemical Substances and Materials."

! Prevention Action:

Procedure STA-626, now in the review and approval cycle, will centralize the administrative efforts necessary to ensure that chemical substances and materi-als are adequately controlled. This procedure was developed using INP0 crite-ria.

1 Date of Corrective and Preventive Action Imolementation:

1. Procedure STA-626 will be issued by September 1, 1986.

2. Procedure STA-606 will be issued by September-1, 1986.

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Attachment 11 Cause. of the Procedural Weakness Related to Control of Deleterious Material At the time of the NRC inspection an overall project control procedure for deleterious materials did not exist. Instead, individual site installation procedures were utilized to control deleterious materials used during the installation process and these procedures contained restrictions which were provided by specification requirements. Specific materials, such as mercury, were not addressed for specific tasks where the involvement of such materials was not anticipated. The large number of individual site procedures involved resulted in a program which was difficult to assess from an overall. standpoint and was susceptible to conflicts of different requirements. As discussed in our original response, a project control prgram, CP-CPM-9.2 now provides overall project . control for deleterious materials.

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