ML19327B613
| ML19327B613 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/27/1989 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8911020275 | |
| Download: ML19327B613 (9) | |
See also: IR 05000445/1989030
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OCT' 2 71989
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In Reply Refer To:
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Dockets:
50-445/89-30
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50-446/89-30
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Mr. W. J. Cahill, Jr.
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Executive Vice President
'
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TU Electric
.
1
500 North Olive Street, Lock Box 81
-
Dallas, Texas
75201
a
Dear Mr. Cahill:
This refers to the inspection conducted by Mr. H. H. Livermore and
other members of the Augmented Inspection Team.(AIT)~during the
.,
period May 15 through June 16, 1989, concerning the check valve 1
S
failures which allowed back-flow through the auxiliary feedwater-
system during hot functional testing of ' Unit 1 at the Comanche : Peak
,
Steam Electric Station.
The team's findings were documented in
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Inspection Report 50-445/89-30; 50-446/89-30 and were discussed
with you and members of your staff on June 16, 1989.
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our report requested you to submit a response. summarizing lessons:
learned'and planned corrective. actions.
You were also asked to
address the weaknesses and recomendations identified' by the AIT
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and the time frame for corrective. actions.
Your response to our.
'
July 10, 1989, letter was submitted-to the NRC on' August 18, 1989,
,
by letter-TXX-89596.
A NRC request for clarification and.
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additional information was transmitted to you by our letter dated-
'
!
September 14, 1989.
Your response by letter TXX-89744' was: dated
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October 16, 1989.
The collective significance of the potential violations identified
l
in the enclosure to this letter suggest that,.at least'for-the
')
circumstances associated with this inspection,'your evaluations of'
1
equipment and personnel failures lack thoroughness and depth, and
your corrective actions were ineffective and untimely.
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consequently, we believe that it wculd~be useful to' meet with you
to discuss these findings.
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You should be prepared to discuss the findings and conclusions of-
]
the AIT inspection at a noticed meeting within two weeks in Glen
- i
Rose, Texas.
Immediately following the meeting, we plan to conduct a brief
l-
enforcement conference with your management to discuss these and.
CPPD:NRR
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W.
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other regulatory matters identified in Enclosure 1 to this letter.
At that conference please be prepared to present your assessment of
safety significance,. root cause(s), and your corrective actions.
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You will be informed in writing of the NRC decision on' enforcement
I
action when that decision is reached after the conference.
In
'
accordance with 10 CFR 2, Appendix C,
the enforcement conference
will not be'open to the public.
Your cooperation on this matter will be appreciated.
Original signed by
,
D. M. Crutchfield,-Associate Director
for Special Projects
Office of-Nuclear Reactor Regulation
Enclosure:
Enforcement conference issues and
,
related regulatory requirements.
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(Seeattached)
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 30805
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OCT 2 71989
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In Reply Refer To:
,
Dockets:
50-445/89-30
50-446/89-30
[
-!
Mr. W. J. Cahill, Jr.
Executive Vice President
TU Electric
l
500 North Olive Street, Lock Box 81
'
Dallas, Texas
75201
.
- 7
'
Dear Mr. Cahill:
,
i
This refers to the inspection' conducted by Mr.
H.'H. Livermore and
i
other members of the Augmented Inspection Team (AIT)'during the
. i
period May 15-through June 16,.1989, concerning'the check valve
failures which allowed back-flow through the auxiliary feedwater
system during hot functional testing of Unit-1 at the Comanche' Peak
-
Steam Electric Station.
The team's findings'were documented in
Inspection Report 50-445/89-30; 50-446/89-30 and were discussed
i
with you and members of your staff on June 16, 1989.
l
'
our report requested you to submit a response summarizing lessons
,
learned and planned corrective actions.
You were also asked'to
address the weaknesses and recommendations identified by the AIT
and the time frame for corrective' actions.
Your response to our
,
i
July 10, 1989, letter was submitted to the'NRC on August- 18, 1989,
.
by letter TXX-89596.
A NRC request for clarification and
- I
,
l
additional information was transmitted to you by our letter dated
,
September 14, 1989.
Your response by letter TXX-89744 was dated
,
I
october 16, 1989.
l
The collective significance of the potential violations identified
[
in the enclosure to this letter suggest that, at leastLfor the
-
circumstances associated with this inspeiction, your evaluations of
equipment and personnel failures lack thoroughness and depth, and
,
'
your corrective actions were ineffective and untimely.
.
Consequently, we believe that'it would be useful to meet with you
,
to discuss these findings.
You should be prepared to discuss the findings and conclusions of
,
the AIT inspection at a noticed meeting within.two weeks in Glen
Rose, Texas,
,
t
.
Immediately following the meeting, we plan to' conduct a brief
'
enforcement conference with your management to discuss these and
,.
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W. J. Cahill, Jr.
2
other regulatory matters identified in Enclosure 1 to this letter.
At that conference please be prepared to present your assessment of
safety significance, root cause(s), and your corrective actions.
You will be informed in writing of the NRC decision on enforcement
l
action when that decision is reached after the conference.
In
'
l
accordance with 10 CFR 2, Appendix C,
the enforcement conference
will not'be open to the public.
i
Your cooperation on.this matter will be appreciated.
,
.
.
. Crut h
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c ate Director
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.
,
for Special Proje
s
Office of Nuclear Reactor Regulation
"
Enclosure:
Enforcement conference issues and
2
related regulatory requirements.
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(Seeattached)
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W. J. Cahill, Jr.
OCT 2 71989
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cc w/ enclosure
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Roger D. Walker
TU Electric
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Manager, Nuclear Licensing
c/o Bethesda Licensing
TU Electric
3 Metro Center, Suite 610
Skyway Tower
Bethesda, Maryland
20814
400 North Olive Street, L.B. 81
Dallas, TX
75201
E. F. Ottney
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P. O. Box 1777
Juanita Ellis
Glen Rose, Texas
76043-
.
President - CASE
,
1426 South Polk Street
Jack R. Newman
O
Dallas, TX
75224
Newman & Holtzinger
1615 L Street, NW
Texas Radiation Control
Suite 1000.
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Program Director
20036
Texas Department of Health
i
1100 West 49th Street
George R. Bynog
Program Mgr./ Chief Inspector
Texas Dept. of Labor & Standards
GDS Associates, Inc.
Boiler Division
1850 Parkway Place, suite 720
P.O. Box'12157, Capito1' Station
Marietta, GA
30067-8237
78711
.,
Honorable George Crump
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County Judge
Glen Rose, Texas
76043
'
Ms. Billie Pirner Garde, Esq.
!
Robinson, Robinson, et al.
103 East College Avenue
Appleton, WI
54911
Regional Administrator, Region IV
U.S. Nuclear Regulatory Commission
611 Ryan Plaza Drive, Suite 1000
Arlington, Texas
76011
William A. Burchette, Esq.
Counsel for Tex-La Electric
Cooperative of Texas
Heron, Burchette, Ruckert & Rothwell
.
1025 Thomas Jefferson St., NW
20007
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50-445/h-j$i 50-446//9-50
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DISTRIBUTION:
Docket Files (50-445/446)
NRC PDR
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LPDR
CPPD-LA
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CPPD Reading (HQ)
ADSP
Reading
Site Reading File
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R. Warnick
,
J. Wiebe
H. Livermore
MIS System, RIV
RSTS Operator, RIV
i
RPB, RIV
RIV Docket File
J. Gilliland, RIV
L. Shea, ARM /LFMB
H. Thompson
C.
I. Grimes
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P. F. McKee
J. H. Wilson
J. Lyons
M. Malloy
J. Moore, OGC
M. Fields
D. Crutchfield
T. Quay
E. Jordan
B. Grimes
B. Hayes
C. Vandenburgh
J. Partlow
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Enclosure 1
Enforcement Conference Issues and Related Regulatory Requirements
1
1.
The following activity appears to be contrary.to
,
,
Criterion V of Appendix B to 10 CFR Part 50 as implemented by
I
Section 5.0, Revision 1, of the TU Electric Quality Assurance
7
Manual states, in:part, that activities affecting quality-
shall be prescribed by and accomplished in accordance with
procedures.
l
Criterion XVI of Appendix B to 10 CFR Part 50 as Laplemented
by Section 16.0, Revision 1, of the.TU Electric Quality
.,
Assurance Manual which states, in part, that measures shall
!
assure that significant conditions adverse to quality or plant
safety are promptly identified.and corrected to preclude
s
repetition.
CPSES Operations Department Administration (ODA) Manual'
Procedure ODA-407, Revision 1, Section.6.1, which requires
that plant systems and subsystems be operated in accordance
with written approved procedures during normal, abnormal, and
emergency conditions.
Standard Operating Procedure SOP-304A,
" Auxiliary Feedwater System," specifies steps necessary to
perform various operations and alignments of the auxiliary
The procedure specifically states
that valve 1AF054 be closed prior to opening valve 1AF055.
,
on May 5, 1989, while performing steps in Procedure SOP-304A
for system realignment,. valves 1AF054 and 1AF055 were opened
',
concurrently.
This improper sequence allowed a. reverse fluid
i
flow path from the steam generators to the condensate storage
/
tank via the AFW piping.
This event occurred in a' manner-
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nearly identical to that of the-April'23, 1989, event (see
l
Violation 445/8924-V-01).
Corrective actions.for the
April 23, 1989, event were inadequate to prevent recurrence on
,
May 5, 1989.
2.
The following activities appear to be contrary to:
L
Criterion XVI of Appendix B to 10 CFR Part 50 as implemented
by Section 16.0, Revision 1, of the TU Electric Quality
,
l
Assurance Manual'which states, in part, that measures shall
assure that significant conditions adverse to quality or plant
safety are promptly identified and corrected to preclude
repetition.
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a.
In 1985. Problem Report (PR)85-132 and Failure Analysis
Report (FA)85-001, Revision 0, stated that the bonnet
and retainer for check valve 1MS142 were incorrectly
installed and placed too low in the body preventing
'
proper closure of the check valve.
The' action to prevent
recurrence stated in FA 95-001, Revision 0, included
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revising the assembly procedure and correctly
reassembling the check valve.
Thus, in 1985 the
'
applicant had identified the root cause of the check
i
valve back-leakage problem and had formulated corrective
,
action which should have corrected the problem.
The
.
applicant failed to take this. appropriate corrective
!
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action in a timely manner.
Rather, the cause was changed
and the failure was attributed to harsh flow conditions.
'
The valve disc and stud were replaced and.the valve seat
F
was reconditioned.
A' reconsnended design review was ' not -
performed.
b.
During Hot Functional testing (HFT) on April 5, 1989, the
applicant identified significant back-leakage-from the
,
steam generators through three of the AFW. supply line
A Problem Report was not written,and
management was not informed.
Work requests were written
to repair the failed valves but.were not given proper
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priority attention.
The applicant failed to properly
evaluate the back-leakage and failed to provide adequate-
,
and timely corrective action to prevent recurrence.
As a
'
result, significant backleakage occurred on April 23 and
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May 5, 1989.
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c.
On April 19, 1989, AFW pump testing revealed that
miniflow check valve 1AF069 was experiencing.significant
+
back-leakage.
The individual. valve was reworked.
At the
'
time of valve rework, the applicant believed the problem
to be isolated.to valve 1AF069 which.had excessive axial
play.
Generic corrective action was not addressed and
the applicant failed to-identify the root cause'and to'
>
take adequate corrective action to prevent recurrence.
,
d.
The AIT notes that it took an inordinately long period of
time for the applicant to adequately identify the May 5
event and to report it as such,'especially considering
that it had a greater magnitude of severity than the-
'
April 23 event.- The AIT team and the applicant's task.
4
team were not notified of the second event until May 15,
1
1989.
The event was identified by'PIR 89-129 only
because the AIT persisted to question the event.
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c.
During physical disassembly of the system check valves.
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the AIT observed the following
(1)
Some of the 4-inch check valve bonnets did.not
appear to be installed with the disk assembly
parallel to the set ring.
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.
(2)
The bonnet spacers on several of the check valves
were deformed inward indicating over torquing of the
bonnet stud fasteners.
(3)
Correspondingly, for the 4-inch valves that
)
exhibited deformed bonnet spacers, the studs.were
also deformed (bent) inward which'also indicates
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overtorquing of the fasteners.
}
These potential deficiencies were not recorded by
i
nonconformance. reports (NCRs) or any other means that
would ensure. identification, disposition, and root cause
determination.
3.
The following activities appear to be contrary to:
1
Criterion XI of Appendix B to 10 CFR Part 50 as implemented by
Section 11.0, Revision 1, of the.TU Electric Quality Assurance.
.
Manual which states, in part, that testing shall demonstrate
{
that systems and components will perform satisfactorily in
r
service.
Contrary to'the above, the following examples were
'
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identified:
The applicant failed to perform post-modification and/or
a.
maintenance tests of Borg-Warner check valve internals
that were removed and reworked in 1983, 1985, and on
.)
April 5, 1989.
b.
Under the applicant's preoperational test program, no
testing was performed or planned, prior to plant
operation, to ensure the AFW check valves'were operable
and capable of' performing their intended function of
preventing back-flow.
The NRC staff believes that the collective significance of,the
'
foregoing pot'ential violations indicate that, at least for: the
circumstances associated with this inspection, your evaluations of
!
equipment and personnel failures were inadequate and,.similarly,
E
4
the.resulting corrective actions.were. ineffective. 'While actions
are usually taken to correct known deficiencies, the' actions are-
occasionally superficial or constrained to the-insnediate . problem.
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Further, it appears that-the large workload and schedule pressures
continue to be at least a contributing causal factor. HWe also
believe that these findings suggest that your quality assurance
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program is not sufficiently aggressive or inquisitive so as to
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anticipate and correct problems like these, before they occur.
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