IR 05000445/1990010
| ML20024F913 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/19/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 9012270146 | |
| Download: ML20024F913 (3) | |
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DEC I 91990 Docket'Nos. 50-445/90-10 50-446/90-10 License Nos. NPF-87 CPPR-127
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t TV Electtic ATTN:
W. J. Cahill, Jr., Executive Vice President Nut; ear Skyway Tower 400 North Olive Street, L.B. 81
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I Dallas, Texas 75201
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Gentlemen:
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Thank you for your letter of May 3,1990, in response to our -letter and
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Notice of Violation dated April 10, 1990 We have reviewed your reply and
. have evaluated your corrective and preventive measures associated with the c
concerns. identified in Violation 445/9010-V-02, Item B.
Based on these
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reviews, which are documented in NRC Inspection Report 50-445/90-42; 50-446/90-42,- it was' determined thtt you had established cJequate corrective actions. Therefore, this. violation-is considered closed.
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Sincerely,
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Originel Signed By:.
Samuel J. Collins Samuel J. Ccilins, Director
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Division of Reactor Projects
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-TV Electric ATTN:
Ro9er.0. Walker, Manager
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Nuclear Licensing
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Skyway Tower
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. 400. North Olive Street,' L.B. 81
. Dallas, Texas 75201
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Juanita Ellis
--President.- CASE 1426 South Polk Street Dallas,-Texas 75224 6DS. Associates,:Inc.
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Suite 720-1850 Parkway Place Marietta, Georgia 30067-8237
. Billie Pirner' Garde, Esq.
Robinson, Robinson, et al.
103' East College Avenue
.Appleton, Wisconsin 54911
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TV Electric
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1Bethesda Licensing 3-Hetro Center, Suite 610 Bethesda, Maryland _ 20814 g
Heron, Burchette, Ruckert, & Rothwell ATTN: Willian A. Burchette, Esq.
f-Counsel for_ Tex-La Electric Cooperative of Texas
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1025 Thomas Jefferson-St,, N.W.
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Washingt:n, D.C.
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E. F. Ottney-P.O. Box'1777 Glen Rose, Texas 76043-
Y-Newman & Holtzinger, P.C.
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ATTH:--Jack R. Newman, Esq.
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1615 L. Street, N.W.
Suite-1000-
LWashington,_D.C. 20036 Texas Department of Labor & Standards
' ATTN:
G.5R. Bynog, Program Manager /
-Chief Inspector
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- Boiler Division-P.O. Box 12157,. Capitol Station c
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. Honorable George Crump County _ Judge
. Glen Rose, Texas.76043 Texas Radiation Control Program Director
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1100-West 49th Street Austin,-Texas 78756
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TU Electric-3-f-
bec to DMB (IE01)
bec distrib, by RIV:
R. D. Martin Resident Inspector (2)
Project Engineer (DRP/8)
DRSS-RPEPS Lisa Shea, RM/ALF MIS System RSTS Operator RIY Files
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-~==== M Log # TXX-90174
File i 10130
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C IR 90-10
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IR 90-10 1UELECTRIC 903 6 Ref. # 10CFR2.201 W.J.Cahm
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V. S. Nuclear Regulatory Commission
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Attn: Document Control Desk
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j SUBJECT:
COMANCHE PEAX STEAM ELECTRIC STATICN (CPSES)
DOCKET NOS. 50 445 AND 50-446 NRC INSPECTION REPORT NOS. 50 445/90-10; 50-446/90-10 RESPONSE TO NOTICE OF VIOLATION Gentlemen:
TU Electric has reviewed the NRC's letter dated April 10, 1990, concerning the inspection conducted by the NRC staff during the period February 6, 7, and February 26 - March 2, 1990. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2.
Attached to the April 10, 1990, letter was a Notice of Violation.
TU Electric hereby responds to the Notice of Violation, Item B (445/9010-y-02), in the. attachment to this letter. As stated in your April 10, 1990, letter, Notice of Violation, Item A (445/9010-V-01) was re olved during the inspection and no written response is required.
Sincerely,
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s William J. Cahill, Jr.
CBC/daj c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)
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I Attachment to TXX-90174L Page 1 of 4 NOTICE OF VIOLATION ITEM B (445/9010-V-02)
Criterion XVI of Appendix B to 10 CFR 50, as implemented by Section 16, Revision 1.0 of the Texas Utilities Electric Company (TV) Quality Assurance
Manual, states in part, " Measures shall_ be established to assure that conditions adverse to quality, such as... deficiencies,...- and non-
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conformance are promptly identified."
Contrary to the above,. on or about December 7,1989, TV received Westinghouse memorandum HED-PCE-8447, dated November 28, 1989,- which addressed questions to i_
the licensee's engineering staff regarding the documented compliance of Unit I reactor coolant system Loop-4 piping field weld 12-A, to the ASME code requirements for nondestructive testing.
As an apparent consequence of a-series of omissions, failures, errors and procedural inadequacies; positive
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identification and correction of failure to radiograph field weld 12-A as-required by the ASME code, was not resolved until February 16, 1990.
RESPONSE-T0 NOTICE OF VIOLATION ITEM B (445/9010-V-02)
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.i TV' Electric accepts the violation and the requested information follows.
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Egnon for the Violation Westinghouse memorandum HED-PCE-8447 (received' by CPSES engineering on December 7,1989) requested copies of radiographic test _(RT) results for weld-12-A. On December 11, 1989 engineering personnel responded that CPSES documents indicated that only visual and dye-penetrant inspections-were required. The engineering personnel involved did not investigate whether the ASME Code required radiography of the weld.
On Thursday,LJanuary 25, 1990, another Westinghouse memorandum, MED-PED-
-8671, was received by engineering.: This memorandam recommended that weld -
- 12-A be radiographed in order'to comply lwith ASME Code: requirements. The
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engineer who received this: memorandum had not been involved in-responding'
to the previous memorandum and recognized that a deviation from ASME Code requirements existed.
The engineer initiated:a site deficiency document (ONE Form) on Monday, January 29, 1990, and-made his. supervisor aware of the condition.
The engineer and his supervisor took no further action.
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Attachment:to TXX-90174 Page 2 of 4 During the period from January 29, 1990 through February 13, 1990, the ONE Form was dispositioned to perform the required RT and assigned to the ASME
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QC group to-accomplish the disposition.
The ASME QC group determined that
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a Work Request was required to remove insulation to' facilitate performance
of the RT. ASME QC made several unsuccessful attempts to have a Work l
Request initiated.
Eventually the Technical Support System Engineer was contacted. After verifying that an RT was required by the ASME -Code, the
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System Engineer initiated the required Work Request.
However, the Work l
Request was assigned a " routine"_ priority'. Upon becoming aware of the.
Work Request, the Manager of ' Projects _ recognized the significance of the deficiency and expedited performance of the RT.
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TU Electric's review of the above described events has identified the following as causing the failure to promptly identify and correct the lack of ASME required RT.
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The engineering personnel who responded to Westinghouse memorandum l
MED-PCE-8447 did not adequately pursue resolution of the apparent l
l discrepancy between the Westinghouse memorandum and the q-nondestructive examinations which were specified by the site j
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documents.
Site ASME Code engineering personnel were not l
immediately contacted to determine the-applicable ASME Code-L requirements, u
The engineer who initiated the ONE form and his supervisor did not I
alert appropriate management personnel when they determined that a deviation from-ASME Code requirements existed.
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The'0NE Form was assigned to a Construction organization, ASME QC,
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to accomplish the disposition.- The system-in which the weld was L
located was in the custody of the Operations Department and
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therefore a Work Request.was required to remove insulation for the i
L RT. As a Construction organization, ASME QC is not under the y
jurisdiction:of Operations procedures and does not issue Work'
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L Requests.- As a result, several days elapsed before the required
Work Request was initiated.
L There was no mechanism to assure that the System Engineer was h
notified of the-deficiency-in a_ timely manner. Had the System L
Engineer been aware of the deficiency earlier he could have
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expedited initiation of the Work Request.
The priority assigned to the Work Request was not appropriate ior-the-condition.
Resolution of this deviation from the ASME Code
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should have received a higher-priority than " routine;"
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Attachment-to TXX-90174 Page 3 of 4 2.
Corrective Steps Taken and Results Achieved An RT of weld 12-A was performed on February 16, 1990. A Plant Incident
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Evaluation was written to address the generic implications and preventative actions pertaining to the failure to perform an ASME required
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RT. The corrective actions for this evaluation. included a review of documentation which determined that ASME required RT's had been performed-on other similar welds.
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Corrective Steos Which Will be Taken to Avoid Further Violations A memorandum has been issued to engineering personnel emphasizing that potential discrepancies involving Codes or Standards should be brought to l
the attention of the site organizations responsible for implementation of
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the Codes or Standards.
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The engineering personnel who were involved in the response to Westinghouse. memorandum MED-PCE-8447 are no longer on site. The engineer i
who initiated the ONE. Form and his supervisor. have been made aware of this
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violation and of-the necessity of notifying appropriate CPSES Management
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personnel wher deficiencies requiring urgent action are identified.
Additionally, ONE Forms' involving engineering are currently reviewed at
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the Engineering Plan of the Day meetings and by the Engineering Managers l
to assure that resolution of significant deficiencies is expedited. These
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reviews will continue until. the Engineering Managers have assurance th4t (.
an adequate level of sensitivity exists regarding deficiencies which.
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require prompt management attention.
A Nuct r Engineering and Operations (NEO) Policy Statement has been issued emphasizing that problems and concerns must be properly documented and communicated-to appropriate management. Additionally, the Policy Statement emphasizes.that each individual is expected to aggressively seek t
l out problems and pursue them to resolution.
Engineering personnel have
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been trained on this Policy Statement.
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.A p ocedure change has beca initiated which will. assign the Work Control-l Center the responsibility for initiation of Work Requests which are required to accomplish ONE Form-dispositions.
l A memorandum has been issued emphasizing that System Engineers are to.
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l remain cognizant of open items involving their assigned systems and to assure such items are identified to appropriate management and technical personnel.
-A database listing the open items affecting plant systems is available for periodic review by System Engineers.
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Attachment to TXX-90174
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The review of new ONE Forms has been enhanced by the addition of
engineering personnel to the review group that assigns CNE Forms to responsible organizations for disposition.
This enhancement provides additional assurance that ONE Forms and any resulting Work Requests involving significant technical issues receive a priority connensurate with potential impact on current and planned plant evolutions.
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Date When Full Comoliance Will be Achieved
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The procedure change described above will be issued by May 25, 1990.
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