IR 05000445/1991002
| ML20029B046 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/15/1991 |
| From: | Barnes I, Mcneil W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20029B044 | List: |
| References | |
| 50-445-91-02, 50-445-91-2, 50-446-91-02, 50-446-91-2, NUDOCS 9103050288 | |
| Download: ML20029B046 (7) | |
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APPLt'DlX U.S. I:UCLEAR FECULATORY C0tililSS10!4 REG 1014 IV IGC Inspection Report:
50-445/91-02 Operating License:
HPF-87
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50-446/91-02 Construction Permit:
CPfR-127 Dockets: 50-445 50-446 Licensee: TV Electric Skyway Tower 400 North Olive Street Lock Cox 81 Dallas, Texas 75201 Facility i:ame:
Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 Inspection At: CPSES, Glen Rose, Texas Inspection Conducted: January 7-1}and22-25,1991 Inspector: f
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/h Pf Mcybill, Reac%r Inspector,11aterials Late and'Qt(alityProgramsSection,Divisionof Reactor Safety Approved:
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Ba Date f. Pro (nes/ Chief, veterials ana Quality
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grai(s Section, Division of Reactor Safety inspection Sunrnary inspection Conducted January 7-11 and 22-25, 1991 (Report 50 445/91-02)
Areas inspected: Routine, unannounced inspection of the corrective action program.
Results: The corrective action program was found to be comprehensive in nature and to utilize a consolidated or centralized system for reporting problems and documenting corrective actions.
Implementation was noted to be generally conservative in regard to input of potential problems and the program was found to be effective in terms of trending, timeliness, and resolution nf problems. A problem was noted dL: ring the inspection which 910305020s 910220 PDR ADOCK 05000445 G
pon
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indicated that additional guidance is needed with respect to use of a work order in place of initiation of an Operations Notification and Evaluation (ONE) Form. Review of changes to the guidance was idtntified (paragraph 2.3) as an inspector followup item.
Inspection Conduct January 7-11 and 22 25,1991 (Report 50-445/91-02)
Areas inspectea:
No inspection of Unit 2 was conducted.
Results:
Not applicable.
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i 3-DETAILS 1.
PEP 5Cks CONTACTED 1.1 TU_ ELECTRIC
- J. Ayers Operations cuality Assurance Maneger
- 0. Chatty, Licensing Coordinator
- R. Byrd, Operations Quality Control Manager l
- W. Cahill Executive Vice President E. Desir. Equipment History Engineer
- J. Gallman, Trend Anelysis Supervisnr
- T. Hope, Compliance Supervisor C. Homan, Work Control Center Program Engineer E. James, Mechanical Systems Engineering Supervisor
- J. Kelley, Plant Panager D. Keating, Staff Engineer G. McGee, Plant incident Report Coordinator E. Meaders, System Engineer H. Montgomery, System Engineer
- D. Pendleton, Assistant Project D. Reimer Systems Engineering Manager
- T. Robertson, Materials Management Organization Manager
- A. Scott, Vice President Nuclear Operations
- W. Stendebach, Senior Compliance Engineer
- P. Stevens, Technical Support Manager
- L. Strope Trend Analyst N. Terrel, Supervisor NSSS Mechanical Systems
- C Terry, Nuclear overview Director K. Tipton, Sy:. tem Engineer
- L. Walker, Licensing Engineer
- C, Welch, QA Specialist
- J. Vehlein, Operations CA Specialist 1.2 CASE
- E. Ottney, Program Manager 1.3 [RC
- l. Barnes, Section-Chief. Materials & Quality Programs Section, Division of Reactor Safety
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S. Bitter, Resident inspector
- D. Graves, Resident inspector j
W. Johnson, Senior Resident-Inspector i
- R. Latta, Senior Resident inspector
- T. Reis Project Engineer
- Denotes those attending the exit interview conducted on January 25, 1991.
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.CORRECTIVEACTIONPROGRAH____(92720}
2.1 Objective
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The objective _of this inspection was to determine whether the licensee has
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developed a comphrensive corrective action program to identify,-to follow, and to correct sbfety-related problems.
2.2 Program from review of the corrective action program procedures (see Attachment), the inspector ascertained that a consolidated or centralized system had been
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established for reporting problems and documenting corrective actions. With the exception of those problems for which there was a simple,amedy (e.g.,
Yhlve packing IFaks), problems were reported on Operations butification and Evaluation (ONE) Forms. Problems for which there was 0-simple remedy wers corrected by initiation of a work request (WR) and subsequent issue-of a:
correctivemaintenanceworkorder(WO). Disposition of ONE Forms was performed
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by a Work Control Center coninittee, with the primary disposition categories ano
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L method of processing being as follows:
Resolution of hardware problems which could be corrected by maintenance
was achieved by.use of a WR and WO in accordance with Procedure
%606.
Procedural problems (e.g., noncompliance or inadequacy), which in the
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.past were docuenented on deficiency reports (DRs), were processed in accordance with Procedure STA-422.
Prograninatic/ repetitive conditions (P/RCs), such as a negative trend or
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Lcudit finding, were processed in accordance with Procedure STA-422.
_ Hardware failures which 'id not require an operability determination, and
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which in the past were documented on nonconformance reports (NCRs), were
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identified _as requiring design / engineering resolution and processed in accordance with Procedure STA.422.
Hardware failures t1 -
.ted operability were identified as plant
incident-reports-(PIRt.-
processed in accordance with Procedure STA-422.
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Problems which required analysis, but did not constitute an adverse
condition to quality or safety, were identified as a technical evaluation and processed in accordance with Procedure STA.504 Based on the categorization, the processing and close out of ONE Forms was different. A root cause analysis was required for those problems identified as-P/RC and PIR. The ONE Ferm was closed upon issuance of the appropriate documentation for WO, TE, and other dispositions. ONE Forms categorized as DR, P/RC, NCR, and PIR were not-closed until implementation of all corrective
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actions -had been verified by Nuclear Overview.
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-5-Root cause ana'i,31s of a problem was perfortced using at least one of eight methods identified in STA-515. The sight methods used were a simplified root cause tree analysis called direct derivation, barrier analysis, change analysis, event and causal factors analysis, root cause code tree, ranagement oversight and risk tree analysis (MORT), human performance evaluation system (HPES), and fault trees analysis. A PIR :as categorized into one of four levels of severity and risk. The type and number of root cause analysis methods used was a function of the categor ization of the PIR. The lower the categorization, meaning the higher prebebility of and more severe the consequence, the more perr-r**1 and rigorous the nethods of analysis that were used.
In 1990, the inspector ascertained that 2370 ONE forms were issued with all but 265 being closed as of this inspection. The most frequent categorics were:
DR - 28 percent ;E - 18 percent, NCR - 14 percent, and noltiple categories -
13 percent. P!ks were 7 percent and the most frce.uent severity categories of the PIRs were: ;
01 percent and 4 - 33 percent.
2.3 Implementation The implementation of the corrective action program was verified by inspection of the inputs to the ONE program, review of the tineliness of corrective actions, review of the effectiveness of corrective actions, and rcview of the trending cf corrective action data.
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'he input of problems into the corrective action program was verified by the inspector through a review of reports made to the Institute of Nuclear Power
)perations Nuclear Plant Reliability Data System (NPROS). Tbc FPRDS reports were based on a review of corrective maintenance W0s, it was noted that about 25 percent of the NPRDS reported hardware failures appeared to be associated with ONE Forms. A review by the inspector of the NPROS reports of failures, for which ONE Forms had not been initiated, found one case where it would appear that a ONE Form should have been issued. This case, which is oiscussed below, utilized a W0 as corrective action for the problem without issue of e
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ONE Form. The inspec+or noted that direct use of a WO results in linited root cause analysis, trend 1og, and generic review of the problem.
On-April 21, 1990, a reactor trip occurred, and during that event it was noted that the steam generator feedwater recirculation control valve failed. The control valve failure was ascertained to have occurred because of the failure of a subcomponent, the electropneumatic converter; the cause of the failure was line vibrations. The corrective action to the problem was to issue a WO to reconfigure the converter to a wall acunt. The inspector questioned the potential generic implication of the converter's f ailure because the same type of converter was also used on safety-related valves.
In addition, it was ascertained that the Secondary Plant Reliability Self-Assessment Task Team had also issued a recommendation (3.c) that all applications of this type of converter be reviewed in regard to potential failures.
In response to the inspector's question, a walkdown by system engineers of two nuclear steam supply systems (residual heat removal and main steam) was performed which l
found no similar problems with this type converter in other applications. The i
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licensee has initiated a change to Procedure STA-421 to provide better guidance on when a WO without a OllE form may be used for corrective actions.
Review of tht change to the procedure and assessment of its effectiveness were identified
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as en inspector. followup ittra (445/9102-01).
The timeliness of corrective action for problems was verified by the inspector through a review of the 1990 OllE forms that had been dispositioned as K0s.
It was found that the percentage of these W0s that were in an open status (work incomplete) was almost the same as that for U0s from a'l sources, not just corrective action. The reasons for open status of the W0s that were corrective action for a'ONE form appeared to be appropriate (such as awaiting the next refueling outage). The existing controls were found to be assuring the timeliness of corrective actions.
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The effectiveness of corrective actions was verified by the inspector by a review of the root cause determinatices for 1990 plRs.
It was noted that there appeared to be very little repetition in type of causes or work unit responsible for the p1Rs. The lack of _ repetition appeared to indicate that-problems are not recurring but were being effectively resolved af ter initial identification.
A system was found in place to trend data such a W0s, ONEs, PIRs and similar documents. A plant Perfortnance Overview Report on trending results was issued on a regular basis. The data-base for corrective actions, root causes and component failures was being developed, and it would appear that as this data base grows, it will provide an excellent source of information, particulerly for component failures.
Potential trends, which were nnted by the inspector during the review of the HPRDS data, were verified to be also found in the data
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base of the trending system. For example, the inspector ascertained that negative trends exhibited by Barton flow and level ircicators were being detected by the -trending system. The trending system appeared to be effective in identification of negative trends. Nc violations or deviations were identified during this ins ~ tion.
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alt INTERVIEW-An exit _ interview was conducted on January 25, 1991, with those personnel-denoted in paragraph 1 in which the inspection findings were sungnarized. No information was presented to the inspector tact was identified by the licensee as proprietary.
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ATTAC) MENT PROCEDURES HE0 2.01, " Identification, Evaluation and Reportino of Defects and lloncompliance Under 10 CFR 21," Revision 0 NEO 3.01, " Corrective Action," Revision 5 NEO 4.06, " Routine and !{onroutine Reporting to Regulatory Agencies," Revision 6 NE0 9.01, " Evaluation and Reporting of Adverse Conditions Under 10 CFR 21 and 10 CFR 50.55(e)," Revision t.
STA-421, " Operations flotification and Evaluation (OliE) Form," Revision 1 STA-422, " Processing of Operations Notification and Evaluation (OilE) Forms,"
Revision 3 STA-423 " Evaluation Team," Revision 2 STA-504, " Technical Evaluation," Revision 7 with PCN 1 STA-512. " Failure Analysis," Revision 0 with PCN 1 STA-513. " Human Performance Evaluation System," Revision 15 with PCN 1 STA-514 "fluelear Plant Reliability Data System (NPRDS) Program," Revision 0 STA-t06, " Work Requests and Work Orders," Revision 15 with PCN REI 502, " Equipment History Trending," Revision 1 fl0A 2.11, " Trend System," Revision 3 NQA 3.07, " Quality Assurance Audit Program," Revision 6 with DCNs 1 and 2
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