View source for TXX-4585, Responds to NRC Re Violations Noted in Insp Rept 50-445/85-06.Corrective Actions:Maint Administrative Procedure MDA-201 Being Revised,Deficiency Rept DR-85-078 Processed & Rev 2 to Procedure STA-404 Issued

{{Adams
| number = ML20137A755
| issue date = 10/11/1985
| title = Responds to NRC Re Violations Noted in Insp Rept 50-445/85-06.Corrective Actions:Maint Administrative Procedure MDA-201 Being Revised,Deficiency Rept DR-85-078 Processed & Rev 2 to Procedure STA-404 Issued
| author name = Counsil W
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = Denise R
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION IV)
| docket = 05000445, 05000446
| license number = 
| contact person = 
| document report number = TXX-4585, NUDOCS 8511260094
| title reference date = 09-12-1985
| package number = ML20137A734
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 6
}}

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Log # TXX-4585 File # 10130 TEXAS UTILITIES GENERATING COMPANY esKYw AY TOWER e 400 NORT,0 OLIVR SFTERET. L.M. El e DA1.8.A2, TEXAfB 78301 October 11, 1985 wsLLIAM O COUN51L tattuYlvt vsCE P#ES'DE'ef
                                                                                                                                                                                         . l TZg :;
Mr. R. P. Denise                                                             f;dj           '
                                                                                                                                                                                             -" w I, Division of Reactor Safety and Projects                                      i     '
U. S. Nuclear Regulatory Commission                                          l         g l 5l985 lUIl r; Region IV                                                                       L Office of Inspection and Enforcement                                                                     ll
,                                                                                         611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012                                                       ,
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==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)                                                        ,
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NO.: 50-445/85-06 l                                                                                         

==Dear Mr. Denise:==

1 We have reviewed your {{letter dated|date=September 12, 1985|text=letter dated September 12, 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.
We have responded to the findings listed in Appendix A of that letter.
1 To aid in the understanding of our response, we have repeated the Notice of Violation followed by our response. We feel the enclosed information to be l
responsive to the Inspectors' findings. If you have any questions, please advise.
Very truly yours, 8511260094 851107                                                 '
                                                                                                                                                                         /              '
gDR ADOCK 0             y5                                        g       f/p4f l                                                                                                                                                                  . G. Counsil JWA/grr l                                                                                         Enclosure c- Region IV (Original + 1 copy)
Director, Inspection and Enforcement (15 copies)
U. S. Nuclear Regulatory Commission Washington, D.C. 20555 r
i                                                                                               Mr. V. S. Noonan Mr. D. L. Kelley r u \\n15                                                                   , . . . . . . . . . _ , - , - ~ ~ . . _
1

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NRC Notice of Violation 445/8506-03 Violation:
Failure to Provide an Adequate Procedure 10CFR50, Appendix B Criterion V states, in part, that " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." Section 13.1 of the applicant's Operations Administrative Control and Quality Assurance Plan similarly requires activities which affect quality-related components to be carried out in accordance with written approved procedures.
(1) Contrary to the above, the applicant's maintenance administrative procedure MDA-201, " Electrical and Mechanical Maintenance Procedures and Instructions" provides inappropriate instruction in that Section 4.3.7.3 leaves it to the option of the procedure writer to number the steps and to so state if the exact sequence is essential. This conflicts with Section 4.5.3 which requires approved change to the procedure if the exact sequence of steps within a section or subsection must be changed.
(2) Contrary to the above, Maintenance Action Request MAR-85-0292. Revision 1 changed the sequence of performing Mechanical Maintenance Instruction MM1-302, " Reactor Coolant Pump Inspection," without an approved change to MMI-302 as required by Section 4.5.3 of MDA-301.
(3) Contrary to the above the applicant failed to provide a procedure for removal of the broken seal ring from No. 2 Reactor Coolant pump.
(4) Contrary to the above, Deficiency Report 85-012 did not provide corrective actions as required by Section 4.7 of Station Administrative Procedure STA-404, " Control of Deficiencies," to prevent recurrence of unapproved changes to Mechanical Maintenance Instructions.

===Response===
Each of the four parts to Notice of Violation 445/8506-03, issued for " Failure to Provide an Adequate Procedure," is discussed below.      CPSES TUGCo Operations' action taken and proposed action to correct the cause of the Viointion and prevent recurrence is stated after the general discussion.
Part No. I Contrary to the above, the applicant's maintenance administrative procedure MDA-201, " Electrical and Mechanical Maintenance Procedures and Instructions" provides inappropriate instruction in that Section 4.3.7.3 leaves it to the option of the procedure writer to number the steps and to so state if the exact sequence is essential. This conflicts with Section 4.5.3 which requires approved change to the procedure if the exact sequence of steps within a section or subsection must be changed.

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Discussion:
Paragraph 4.3.7.3 in MDA-201, " Electrical and Mechanical Maintenance Procedures and Instructions," Revisions 2 and 3, was Paragraph 4.1.7.3 in Revision 1 and Paragraph 4.1.5.3 in Revision 0. This paragraph has always read as follows:
                    "The steps of the Maintenance Procedure (Maintenance Procedure /
Instruction in revision 2 and 3) should be numbered and follow the exact sequence of performing the maintenance. If the exact sequence is not      I essential, the procedure (procedure / instruction in Revision 2 and 3) should so state."
* Paragraph 4.5.3 was not added until Revision 2 of MDA-201.      Paragraph 4.5.3 in revisions 2 and 3 reads (in part) as follows:
                    " Changing the sequence of steps within a section or subsection shall be considered a temporary change . . ."                                         {
When Paragraph 4.5.3 was added in Revision 2, Paragraph 4.3.7.3 was not changed accordingly. Because Paragraph 4.3.7.3 used the word "should", the writer of the instruction did not have to number the steps; therefore, the steps could be worked in any sequence which is in conflict with Paragraph
             .4.5.3 which states a temporary change must be processed for any sequence change.
Part No. 2 Contrary to the above, Maintenance Action Request MAR-85-0292, Revision 1 changed the sequence of performing Mechanical Maintenance Instruction MMI-302, " Reactor Coolant Pump Inspection," without an approved change to MMI-302 as required by Section 4.5.3 of MDA-301.
Discussion:
Earlier revisions of MDA-201, " Electrical and Mechanical Maintenance Procedures and Instructions" did not totally preclude a revision of a MAR being written to change the sequence of steps of a procedure / instruction.
Paragraph 4.5.3 was not added until Revision 2 of MDA-201. Paragraph 4.5.3 does not allow a MAR revision to change the sequence of a procedure /
instruction.
Procedure revisions that change established work practices require extensive training to make all personnel aware of any subtle changes. In this case, even though Maintenance personnel were initially trained on the requirements of MDA-201, Revision 2, the training was apparently not sufficient to reflect the new requirement. Additional training has been conducted to assure that work order revisions do not change the sequence of procedures / instructions.

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Part No. 3 Contrary to the above the applicant failed to provide a procedure for removal of the broken seal ring from No. 2 Reactor Coolant pump.
                . Discussion:
The MAR specified the cleanness level and the MMI had Hold Points designated to verify that the cleanness level was maintained. The Quality Control Inspector had the flexibility to utilize any inspection method available to ensure that the cleanness level had been maintained per the MAR requirements.
A procedure to remove the broken seal ring was not appropriate for the circumstances because cicaning is considered a skill normally possessed by a qualified mechanic and the cleanness level (i.e, acceptance criteria) was specified on the MAR with Hold Points already established. Therefore, these actions supported by the following observations, were appropriate for the situation.
Maintenance Action Request (MAR) 85-0292 reference MMI-302, " Reactor Coolant Pump Seal Inspection," an approved TUGCo Maintenance Instruction.
Step 3.8 of MMI-308, a prerequisite, states, " Establish and maintain an adequate level of cleanness in accordance with STA-607, " Housekeeping Control" and STA-612, " Cleanness Control." The level of cleanness shall be established on the MAR."
Step 5.2.8 details how to remove the No. I seal runner, Step 5.2.8.11 (the last step) has a QC Hold Point to verify that the cleanness was maintained in Step 5.2.8.
                    - The seal ring was broken on 1/23/85 while Maintenance personnel were attempting to disassemble the pump in accordance with MAR 85-0292.
Ceramic chips from the broken seal ring were removed on 1/23/85 from the top of the seal runner and the seal runner was then removed in accordance with MMI-302.
Quality Control personnel performed an inspection of the annulus area on 1/23/85, per Step 5.2.8.11, utilizing fibre optics. The annulus was inspected to the requirements specified in MAR 85-0292.
Maintenance personnel vacuumed the annulus area to remove the ceramic chips identified by Quality Control.
Quality Control reinspected the annulus on 1/24/85 per Step 5.2.8.11 and verified that the cleanness level was per the MAR.
1

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Part No. 4 Contrary to the above, Deficiency Report 85-012 did not provide corrective actions as required by Section 4.7 of Station Administrative Procedure STA-404, " Control of Deficiencies," to prevent recurrence of unapproved changes to Mechanical Maintenance Instructions.
Discussion:
TUGCo Deficiency Report DR-85-012 was processed under STA-404, Revision 1, issued February 23, 1982. Following discovery of the Violation by the NRC Resident Inspector, STA-404, Revision 2 was issued to change the reporting of        '
deficiencies and require more complete information from the assignee, enabling the QA reviewer to better evaluate deficiency responses. Specifically, the procedure now requires the following to be addressed in a deficiency response:
A. A statement of cause of the deficiency.
B. An analysis of any generic considerations resulting from the             !
deficiency.                                                              '
C. A statement of actions to correct the deficiency.
D. A statement of actions to prevent recurrence of the deficiency.
               -In retrospect, the Quality Assurance review of DR-85-012 was primarily directed to assure that no physical damage occurred to the Reactor Coolant Pump as a result of falling chips from the broken seal ring. This was verified directly by conversation and documentation supplied by the responsible TUGCo Quality Control Inspector. This included an investigation of the sequence of events provided in the discussion of Part No. 3 of this Violation.
When the procedural inadequacy, allowing unapproved changes to Mechanical Maintenance Instructions, was brought to the QA reviewer's attention, Deficiency Report 85-078'was issued to document the concern. The response to DR-85-078 was subsequently evaluated to requirements of the new STA-404, Revision 2.
Actions Taken to Correct and Prevent Recurrence of the Violation Corrective Action:
: 1. Maintenance Department Administrative Procedure, MDA-201, is presently         '
being revised to ensure all maintenance activities are accomplished as specified in the approved procedure / instruction.        Any changes required will be accomplished in accordance with approved methods. In addition, all references to "should" in Paragraph 4.3.7.3 will be changed to "shall".
: 2. TUCCo Deficiency Report DR-85-078 has been processed and will be closed when the corrective actions described above have been verified. Station Administrative Procedure STA-404, Revision 2, requiring response information described in the Part No. 4 discussion was issued June 4, 1985.
l

,e *3 Preventive Action:
: 1. Maintenance personnel will be trained to requirements of the new revision to MDA-201. Training will emphasize the correct method to change the sequence of steps in procedures / instructions.
Date'of Completion:
: 1. The date of full compliance will be November 15, 1985.
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