ML19354D765
| ML19354D765 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/10/1990 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Charemagne Grimes Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19354D764 | List: |
| References | |
| NUDOCS 9001190388 | |
| Download: ML19354D765 (10) | |
Text
{{#Wiki_filter:h,[, m ,y e_ + E~C A S E==- '(CITIZENS ASSN. FOR SOUND ENERGY). r E 4 I l .e '.A. January 10, 1990 h Mr. Christopher I, Grirnes, Director Comanc he Peak Proj ect Division j Office of' Nuclear Reactor Regulation .U. S. Nuclear Regulatory Commission Washington, D. C, 20555
SUBJECT:
Texas Utilities Electric Cornpany, e_,t_ al. j (Comanche Peak Steam Electric Station, Units 1 and 2) t-Docket No.: 50-445/446-OL Analytical Evaluati,on of Station Service Water System f or Comanshe Peak, by CASE Consultant Jack Doyle Final Repor t, Rev. O. December 31, 1989 Revised Paces
Dear-Mr. Grimes:
.This letter transmits a f ew revised pages of the " Analytical Evaluation of Station Service Water System f or. Comanche Peak," prepared by CASE Consultant i Jack Doyle, dated December 31, 1989, which was f orwarded to you and TU l -Electric yesterday (January 9, 1990), A portion at the end of the ROOT CAUSE PROCEDURES section was inadvertently omitted. Please replace previously-sent pages _ ES-32 and ES-33 with revised pages ES-32 and ES-33, and pages 208 and 209 with revised pages 208, 209, and 210. Please accept our apologies f or any inconvenience. Si nc e r ely. CASE (Citizens Association f or Sound l Energy) .36 J Mrs. ) Juanita Ellis President 1 9001290388 900109 -,4 DR ADOCK 05000443 ' PNU o
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[.i r ,t [ . m: , < cc f Mr < William Couns11.. Vice Chairman. TU Electric h' (c1 ' !/ - Mr. Dennis Crutchfield As sis tant. Director' 'of of : Special Pr oj ec t s. NRC. j Mr. R'.~ G...Warnick Assistant Director f or Inspection Program.. Comanc he ' ] ~ ' Peak-Pr oj ect Division.- NRC: Dr. - Aus af ' Hus ain. Chairrear, s Operations Review Committee (ORC). TU-j n Electric I-: - Mr. = W, J. Cahill, Jr -. Ex aveLVice President. TU-Electric o + [- Wr. George L. Edgar. Esq t. man & Holtzinger. P. C. Es Susan Paliner.; Stipulation Manager.. TU Electric 4' ?! e;- +< ,e v h. f:'. 1 1 I f e t A ,o. ,w-4 4 E -I'.' l b' -.-,\\t P I. h K.: l-{,; h 'A i 'g. J 2 i 2 j i L
P_ J } must consider the development of a procedure to face and evaluate ~ problems. This should address front-end as well as back-end applications. In addition, because of the nature of the process which more often than not conflicts with the biases and political considerations of the user, it is essential that a training program be established. This program should be mandatory for all personnel associated with addressing problems. L Additionally,.in order to apply front-end application, it is L equally as important to train those who are developing I programs for design enhancements, monitoring programs, I preventative maintenance programs, and the like. As noted above, because the Root Cause procedure requires a radical departure from the. current thought g processes utilized in the writing of reports, serious thought should be given to obtaining outside assistance in establishing both the procedure and the training l methodologies. 1. L Finally; as a result of the impact of improperly L downgrading the plasite liner from a safety class component I to a non-safety classification, all components, elements, l systems etc. which have previously been downgraded must now I. be re-evaluated. Such re-evaluation, which must be completed I prior to full power operation, must include: l 1.0 Development of a procedure which addresses, but is l not limited to, the following: i l a. The establishment of a checklist. l b. Determination if the decision to downgrade from safety to non-safety has been properly evaluated. l c. Determination if the decision to downgrade from safety to non-safety has introduced the potential for impacting related or other safety components, elements or systems. l i d. Has the decision, to downgrade, introduced an unfulfilled requirement for a monitoring program. I 2.0 Perform a historical evaluation to preclude, to the L extent possible, the incorporation of potential l undesired and unanticipated causes, such as occurred as a result of the downgrading of the SSWS liner in 1980. ES-32 FINAL REPORT, Rev. O f E
ri PURPOSE OF RECOMMENDATIONS The~ purpose of this report was to determine if there. were problems associated with the responses to the SSWS issues since the 1980 initiation of questions on this system. The report indicates that there were in fact serious problems to be found. While.a number-of these problems may have been corrected due to a new management at CPSES, one problem remains and that is that there is no proper Root Cause analytical procedure in place at CPSES. The concern on this point centers on a simple fact which is as.follows: When the failure was to properly evaluate Root Cause as relates to construction problems, the results were extra costs for repetitive corrective action programs and embarrassment. However, the plant at that mode was benign 1 and the only impact on the public was confusion of what was happening over the years. This shortly will no longer be the case. If improper or inadequate Root Cause analyses occur during the operational mode, the results may not be associated with a forgiving facility. It is noted that CPSES has taken steps in the direction of developing procedures and training as relates to Root Cause evaluation over the past number of months, and while these do not appear to be sufficient in depth to answer the l Root Cause issue, it is at least a beginning and it is hoped that this report will assist TU in their Root Cause evaluation efforts. ES-33 FINAL REPORT, Rev. O
.I . ROOT ~CAUSE ANALYSIS 7 more often than not conflicts with the biases'and' political considerations of the user, it is essential that a training program be established. This program should be mandatory for all personnel associated with addressing problems. Additionally, in order to apply front-end application, it is equally as important to train those who are developing i programs for design enhancements, monitoring programs, preventative maintenance programs, and the like. q As noted above, because the Root Cause procedure requires a radical departure from the current thought processes utilized in the writing of reports, serious thought should be given to obtaining outside assistance-in j establishing both the procedure and the training methodologies. Finally; as a result of the impact of improperly downgrading the plasite liner from a safety class component to a non-safety classification, all components, elements, systems etc. which have previously been downgraded must now be re-evaluated. Such re-evaluation, which must be completed prior to full power operation, must include: 1.0 Development of a procedure which addresses, but is not limited to, the following: a. The establishment of a checklist. b. Determination if the decision to downgrade from safety to non-safety has been properly 208 FINAL REPORT, Rev. 0
i -ROOT CAUSE ANALYSIS'
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.i evaluated. c. Determination if the: decision to downgrade from safety to non-safety has introduced the b l, potential for impacting.related or other i i safety components, elements or' systems. j d.' Has the decision, to downgrade, introduced an unfulfilled requirement for a monitoring program. 2.0 Perform a historical evaluation to preclude, to the extent possible, the incorporation of potential undesired and unanticipated causas, such as + occurred as a result of the downgrading of the SSWS liner in 1980. PURPOSE OF-RECOMMENDATIONS r 'The purpose of this report was to determine if there were. problems associated with the responses to the SSWS issues since the 1980 initiation of questions on this system. The report. indicates that there were in fact serious problems to be1found. While a number of these problems may have been corrected due to a new management at CPSES, one roblem remains and that is that there is no proper Root Cause analytical procedure in place at CPSES. The concern on this point centers on a simple f act which 209 FINAL REPORT, Rev. 0
a l L,. 'L -ROOT CAUSE ANALYSIS 1 i f is!as follows: When the' failure;was to properly evaluate Root 'Cause as relates to, construction problems, the results were s extra costs for repetitive corrective action programs and embarrassment. However, the plant.at that mode was benign I and'the only impact on-the public was confusion of what was i happening over the years ~. This. shortly will no longer be the case. If improper or inadequate Root Cause analyses occur during-the operational mode, the results may not be associated with a forgiving dj facility. It is noted that CPSES has taken steps in the direction of developing procedures and training as relates to Root Cause evaluation over the past number of months, and while these do not appear to be sufficient in depth to answer the Root Cause issue, it is at.least a beginning and it is hoped that this report-will assist TU in their Root Cause evaluation efforts. i i 210 FINAL REPORT, Rev. 0 isf >-
Kg my 9 p =. o - Robinson, - Robtnson, :Peterson,= Berk,
- z f-Rudolph, Cross & Ciarde
.l . Mary lou Robinson. Attorneya at Law ..1 'i ! Nila Jean Robinson-los East College Avenue 7 ii ' John C. Peterson Appleton, Wisconsin 64911 Avrarn D. Berk ' .(414) 781 1817 Michael Rudolph - . Green Bay 494-9600 Dan Crosa - 4: Fax vaus41 : .,:i Billie Pirner Garde "B * ? January 9, 1990 .Mr. . William Couns11' ,Vice Chairman 'TU Electric 2001 Bryan Tower,J uite 1900 S Dallas -Texas 75201'
SUBJECT:
Texas Utilities Electric Company, et al. (Comanche Peak Steam Electric Station. Units 1 and 2) Docket No.: 50-445/446-OL: Analytical Evaluation of Station Service Water System f or Comanche Peak, by CASE-Consultant Jack Doyle Final Report, Rey, O. December 31, 1989 d
Dear Mr. Couns11:
This letter _ transmits the complete " Analytical Evaluation of Station Service Water System f or Comanche Peak,' prepared by CASE Consultant Jack Doyle, dated December 31, 1989. Mr.1 Doyl e' s report: studies. the complete multiple f ailures connected with the historical and current status of the Station Service Wat er System (SSWS). .The result of his. independent analysis as a determination of the most ' probable ~cause of the f ailur es. (Further refinement of secondary root cause would have required-considerable testing which was not undertaken for t his report.) The' report also evaluates the methodology used by.TU Electric and -its various contractors to determine the root cause of problems that foccurred over an eight (B) year time span at Comanche Peak. At' bottom, Mr. Doyle concludes that the multiple failures in t he SSWS t resulted f rom a fundamental inability of TU Electric personnel (as well as contractors) to perf orm a thorough and accurate root cause analysis of incident s, events, s ys t em or c omponent failures, and identified deficiencies 'y in order to understand the generic implication of those flaws. Although Mr. Doyle's report uses the SSWS insue es the basis of his study, the conclusion and findings must be extrapolated to the plant in its current -pre-operational phase. As Kr. Doyle properly points out throughout his 1
tls{ J i. report, the process failure of the SSWS a ssue might not have r esulted in danger to the publact however, "If improper or inadequate Root Cause analyses occur during the operational mode, the results may not be associated with a f orgiving f acility." (Final Report. Executs ve Summary, at page ES-32.) CASE believes that Mr. Doyle's exhaustave eff or t on this study provides valuable independant insight into the amplementation of various programs and processes at Comanche Peak, including an analysis of 'how f act s and inf ormation about the SSWS problem were misunderstood, underestimated, by-pas e ed, and s ometimes blat antly misinter pr et ed in light of contrary f acts an tesponse to identified deficiencies and r egulat ory C onc er ns. Although your December 20. 1989 letter on this subj ect indicates that you are not yet pr epar ed t o agr ee wit h Mr. Doyle's pr oc es s of s tudying t he past t o under s t and the pr es ent, you do apparently agree that there as a need f or TU Electric to establish a f ormal process f or analysis of root cause and generic implication. We believe that TU Electric must have such a program c in place and functional prior to operation. We will be happy to continue to pursue the development of t hi s pr ogram with you. We sincerely hope that TU Electric's program will meet the needs of the proj ect and that CASE will not have to raise t hi s issue in a f ormal dispute. However, you need to be aware of the fact that all of CASE's c onsult ant s agree with Mr, Doyle's conclusions and have advised that the development and successf ul implementation of such a program a s an abs elute requirement. In their view, of any, type of saf e operation of the facility. By separate letter, copies of t his report are being provided to the Nuclear Regulatory Conad s sion (NRC). (See January 9, 1990, letter from Billie Garde t o Chris Grimes.) Although, as you know. CASE has the right under paragraph B.3 of the Joint Stipulation to contact the NRC at any time f or any r eas on. in light of the history cf our discussions on t hi s mat t er, we believe an explanation is appropriate. Mr. Doyle has expended a substantial amount of time and erf f or t on this study f or CASE f or the public health and saf ety, and ultimately als o f or the benefit of TU Electric management. He is in a unique position to independently evaluate the decisions and actions of TU Electric personnel and their various contractors over the past eight (8) years, because he is antimately f emallar with the proj ect and its various management teams, s t yle s, and per f or manc e. Unlike the staffs of TU Electric or the NRC. he has had.the time, albeit not without interruption, to devote to the type of in-depth expert analytical proj ec t contained her ein. Because CASE has a duty to the public, t hr ough its c har t er as a public interest o r g a niz a t i o n devoted to activities that promote the public health and safety, and because of CASE's responsibility to insure t ha t the Joint Stipulation wor ks to protect public health and saf ety even without the f o r um of a contested licensing challenge. At is my opinion that CASE must provide t hi s report to the NRC f or their review and c onsideration in c onnec tion wit h on-going 2
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G4r r &^ ( i ns pec t i ons '. enf orcement, and licensing activities We hope that TU' e Electric management will read this. report with an open mind end consider the ~ a f' r ecommendations-and 'obs ervations.of Mr. Doyle -in the light that they. ar e ( --intendeda - that.: 1s ' t o pr ovide; additional anf ornation to as sis t TU Electric ~ + e -in meeting its obligations t o the public; as -the. operat or of a nuclear power. l -- pl a nt. n. Sincerely, c 0 Q /, encAL=a. - c., cs,,7 Billie P. Garde, Case Attorney A Dir ector of of Special Pr oj ecto, NRC
- _ c e t - Mr. - Denni s Cr utc hfi eld, L As s is t ant Kr, Chris topher I. ' Grimes, Dir ector. Comanche-Feak Pr ej ect Division.
Officeiof Nuclear Reactor Regulat2on. NRC -Mr.. R. G. War nick,. Assis tant? Dir ector.f or Inspect 2 on Pr ogram, Comanc he.- . Peak Pr oj ect Diva: Son..NRC Dr.L Ausaf Husain. Chairman, Operations Review Committee ~(ORC) TU Electric Mr,-W. J. Cahill, Jr., Executive Vice President. TU Electric Mr. George L. Edgar, Esq,-Newman & Holtzinger, P. C. Susan Palmer. Stipulation Manager TU Electric j e I 3 b .S 1 ,r.. 3 t m -x-- e .n}}