ML20115D230

Responds to NRC Re Violations Noted in Insp Repts 50-445/92-31 & 50-446/92-31 on 920719-0829.Corrective Actions:Mgt Expectation Re Procedure Compliance & Adequate Communication W/Control Room Reemphasized

ML20115D230
Person / Time
Site:	Comanche Peak
Issue date:	10/16/1992
From:	William Cahill, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-92504, NUDOCS 9210200294
Download: ML20115D230 (3)

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=""'".". Log # TXX-9?504 L

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File # 10130

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IR 92-31 Ref. # 10CFRI.201 TUELECTRIC October 16. 1992 Wilham J. Cahill, Jr.

Gwup Vice l'orsident U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 3UBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNIT 1 DOCKET N0. 50-445 NRC INSPECTION REPORT MS. 50-445/92-31: 50-446/92-31 RESPONSE TO NOTICE OF VIOLATION Gentlemen:

TV Electric has reviewed the NRC's letter dated September 24, 1992, concerning the inspection conducted by the NRC staff during the period July 19 through August 29, 1992. This inspection covered activities authorized by NRC Operating License HPF-87 and Construction Permit CPPR-127. Attached to the Septe.nber 24, 1992, lecter was a Notice of Violation (NOV).

TV Electric hereby responds to the Notice of Violation (445/9231-01) in the attachment to this letter.

Sincerely, N '1 Wil' i ari J . C ah 1 Jr.

By: ht@s

• 4 Roge# D' Walker Manager of Regulatory Affairs for NE0 OB/tg

'ttachm;nt c- Mr. J. L. Milhoan. Region IV Resident Inspectors, CPSE5 (2) 1 1

19:100

-!P Ad 9210200294 921016 400 N. OUve Sima LD. HI DaHas, Teus 75201 PDR ADOCK 05000445 G PDR

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, . Attachment to TXX-92504 l Page 1 of 2 1

. NOTICE OF VIOLATION

!- (445/9231-03) i Comanche Peak Steam' Electric Station Technical Specification 6.8.1' states, in -

part, that written procedures shall be. established . implemented, ard

'l maintained covering the applicablo procedures recommended in Appendix A of 4

Regulatory Guide 1.33, Revision , February 1978; l Regulatory Guide 1.33 Appendix A. par 6 graph 19.e recommended that .generel 1 procedures for_ the control of maintenance, repair,- and modification work sLould be prepared before reaucor operati:n is begun. These procedures should include information on areas such as the method for' obtaining. permission and clearance for operations- personnel to work and for logging such work.

Maintenance department administrative Procedure MDA-111, ' Maintenance-Department Troubleshooting A:tivities," Revision 0,-Section 6,2, established i, the requirements for controlling troubleshooting activities. Section 6.2.1' j required that, prior to performing troubitshooting a<.tivities, the. individual l_ obtain permissior to commence e-troubleshooting activity and also obtain j Verification Sheet Form STA-694-2 or equivalent,

Contrary to the above, on-August 25,.1992, at.10

54 ~,2 t roubl eshoot'i ng i activity was performed on Annunciator-Cabinet:LP1-EC1 s o-09, Bay 1. Power i Supply 22, without first having obtained permission fro... the unit supervisor j and without having obtained the. verification sheet. .The electrical maintenance technician had received permissior to enter the cabinet _ bay to

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i plan a corrective maintenance activity. .While assessing.the work 1 activity, i the electrical _ maintenance technician begar. -troubleshooting the. circuit and I removed a- fuse associated with the: power supply. When the~ fuse._was-replaced,-

a' loss of annuncictor logic power occurred-to approximately 40 percent of the 4 main control board annunciators. render;ng them _ inoperable. The'ennunciator l logic power supply was energized.at 11:57 a.m. thetsame day.

i RESPONSE T0' NOTICE OF VIOLATION

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(445/9231-01)

TU. Electric accepts the violation and the requested information follows:

l. Reason For-Violation TV Electric believes that this was an isolated incident with' respect to l

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obtaining permission prior to performing troub?eshooting octivities:

obtaining. verification _ sheet _ form $TA-694-2'or. equivalent: and less than-adequate self-verification process, -Additionally,-TV Electric i .l l l l

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, .Yttachment to TXX-92504 l Page 2 of 2 2

ackncw1 2dges' that during this incident supervisory oversight of_ a work -

activity did not con 31stently ensure that management's' expectation were t' met.

TV Electric performed a review of. Independent' Safety Engineering' Group's-l (ISEG) field notes and Nuclear.0verview Department's Trend Analysis- -

l Data, The purpose of this review was to determine if ( trend existed-in i the area of less than adequate self- verification f rom July 1992, through -

September 10, 1992. - This review did not identify an adverse. trend.

! Additionally, soma Quality Control and ISEG personnel _were requested to-i -- review this incident to. determine if- they had observed similar incidents regarding less than adequate self verification, no significant matters -

1 of concern-were identified.

2. Corrective Steos Taken and Results Achieved i TV CPSES maintenance management discussed this incident with the-i personnel involved, Land reemphasized management's expectation re"4 0109-j- procedure- compliance and adequate communication with

control . ro's n personnel.

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3. Corrective Action Taken to Preclude Recurrence l-l TV Electric has reemphasized management's expectation regarding j r icedure compliance, adequate communication;with the control . room f personnel, and self verification with. maintenance; supervision, i'

Station -Administration Procedure STA1 6945 " Station Verification Activities

• has been revised to cl~arifyfthe basis, requirements end methods for self verification and self-checking: activities performed on:

station equipment.

4. Date When ComDliance Will Be Achieved i.

( Full compliance has been achieved.

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