ML20199H013

Notice of Violation from Insp on 970831-1011.Violation Noted:Thermometer IC1473,was Used During Performance of Procedure PPT-SX-7505A on 970807

ML20199H013
Person / Time
Site:	Comanche Peak
Issue date:	11/21/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20199H018	List: IR 05000445/1997018 ML20199H013 ML20199H024
References
50-445-97-18, 50-446-97-18, NUDOCS 9711250358
Download: ML20199H013 (2)

Text

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ENCLOSURE.1.

NOTICE OF VIOLATION j 1

TU Electric-Docket Nos.: 50 445 Comanche Peak Steam Electric Station 50 446  ;

Licenso Nos.: NPF 87 i NPF 89 l l

During an NRC inspection conducted on August 31 through October 11,1997, three violations of NRC requirements were identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:

- A. 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality be prescribed by documented instructions of a type appropriate to the  !

circumstances and that the instructions include quantitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above,

1. Procedures INC 7841X, "ACOT/CHAN CAL lanalog channel operationel ,

test / channel calibration) Catalytic Recombiner X 01 Feed Gas Hydrogen and Oxygen Analyzer, CH 1127A," Revision 4, and INC 7845X, "ACOT/CHAN CAL Catalytic Recombiner X 01 Product Gas Hydrogen and Oxygen Analyzer, CH 1128A," Revision 5, were inappropriate to the circurr. stances in that they failed to include instructions for performing standardization of the detectors prior to performing the surveillance tests. As a consequence,  !

this activity was not consistently performed.

' 2. Protiedures PPT SX 7520A, " Control Room Ventilation Filter Test CPX VAFUPK 21," Revision 0, and PPT SX 75228, " Control Room Ventilation Filter Test CPX VAFUPK 22," Revision 0, included acceptance criteria which was outside of the design basis. As a consequence, the pressurization unit flow rate was left above the design basis limit on two occasions. Train A was left with a flow rate of 817 cfm from September 11, 1994, until January 12,1996. Train B was left with a flow rate of 817 cfm '

.from July 15,1996, until August 8,1997.

This is a Severity Level IV violation (Supplement l} (50 445/9718-03:

50 446/9718 03).

B. Technical Specification 6.8.1 requires, in part, that the licensee establish, implement and maintain procedures covering the activities referenced in Appendix A .

of Regulatory Guide 1.33. Revision 2, February 1978. Appendix A requires specific procedures for each surveillance test listed in the Technical Specifications.

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2-Procedure PPT SX 7505A, " Control Room Pressurization Test Train A," Revision 0, implemented the surveillance requirements of Technical Specification 4.4.7.7.1).

Section 7.0 of the procedure required the use of a temperature indicating device accurate to

• 2*F.

Contrary to the above, Therrnometer IC1473, which had a colibration accuracy of 12.2*C (equivalent to 4*F), was used during the performance of Procedure PPT SX 7505A on August 7,1997.

This is a Severity LevelIV violation (Supplement 1)(50-445/9718-04; 50 446/9718 04).

Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, R9gion IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violatio... (1) the reason for the violation, or, if contested, the basis for dispt'ing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action, as may be proper, should not be taken.

Where good cause is shown, consideration wiP be given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, an:1 provide the legal basis to support your request for withholding the information from the public.

Dated at Arlington, Texas this 21st day of November 1997 1