ML20005G548
| ML20005G548 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/09/1990 |
| From: | Garde B Citizens Association for Sound Energy, ROBINSON, ROBINSON, PETERSON, BERK, RUDOLPH, CROSS |
| To: | Charemagne Grimes Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20005G539 | List: |
| References | |
| NUDOCS 9001190315 | |
| Download: ML20005G548 (40) | |
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. Robinson,
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- 1 Robinson, Peterson, Berk,--
Rudolph, Cross & Garde Mary Lou Robinson: Attomeys at Law; N : Nila Jean Robinson los East College Avenue John C. Peterson -- Appleton, Wiscont.in 64911 J Avram D. Berk c (414)781 1817
> Michael Rudolph Green Day 494 9000
. Dan Cross ; _ Fax 7a0-8841 Billie Pirner Garde '
January 9, 1990-Christopher I. Grimes, Director
- Office of Special' Projects Comanche Peak Project Division
, U.S.cNuclear-Regulatory Commission sWashington, D.C. 20555-e w
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 FOR COMANCHE PEAK,'3Y CASE CONSULTANT JACK DOYLE FINAL REPORT, REV. O, DECEMBER 31, 1989
Dear-Mr. Grimes,
Citizens Association for Sound Energy (CASE) has submitted.
.to' Texas- Utilities Electric Company (TU Electric) a copy of a.
report by ' CASE's consultant Jack Doyle, entitled " Analytical Evaluation of Station _ Service Water System for Comanche Peak."- A copy of_that report'is being sent to you under separate cover for your consideration and review. The report is being submitted to the Office of-Special Projects (OSP) pursuant to Paragraph B.7 of the Joint Stipulation for the Staff's consideration as it continues to evaluate and reconsider enforcement action in regards'to the events and incidents surrounding the removal of-the plasite liner in the Station Service Water System (SSWS) in the Spring of .1988, the failure to identify the precursor
, events to the Auxiliary Feedwater System check valve failure-in l'See, September 23, 1989 letter from Billie Pirner Garde, CASE to Christopher Grimes, NRC; Re: Service Water System Enforcement Action (EA 88-310) Docket No. 50-445/446; Permit No.
CPPR-126.
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I May, 1989,2 and ultimatelf the readiness of TU Electric to receiv
- plant ~.g; permission to load tael and a license to operate- the I. BACKGROUND As you know, Mr. Doyle has been actively' involved in various aspects-of evaluating the safety of the Comanche Peak facility-since 1981, when he first_ worked in the frame analysis group at the ' plant, and later as a witness _-and techni consultant for
-CASE in the NRC operating license proceedings. gal Since the July, 1988- settlement, Mr. Doyle has been actively engaged in continuing to monitor the safety of Comanche Peak in support ofi CASE President Mrs. Juanita Ellis in meeting her obligations as a regulag member _ of the TU Electric Operations Review Committee (ORC). Throughout this time frame, Mr. Doyle has developed in -
depth knowl' edge ' of the design and construction of the- Comanche Peak. facility, and is in a unique position- to observe and evaluate. the institutional character .and competence of TU-Electric and its-various subcontractors.
CASE has relied heavily on the opinions and work of Mr.
2 See, September 23, 1989, letter from Billie-Pirner Garde, CASE-to Christopher Grimes, NRC; Re Auxiliary Feedwater System Check Valves, SDAR: CP-89-015, Docket No. 50-445/446; Permit No.
CPPR-126.
3 See, TU Electric letter from William Cahill to Christopher Grimes, . NRC dated January 5, 1990, regarding response to NRC Inspection Report 50-445/89-200, Comanche Peak Operational Readiness Assessment Team Inspection.
4 e t . . al . ,
See,'In the Matter of Texas Utilities Generating Company, (Comanche Peak Steam Electric Station,' Units 1 and 2; Docket 50-445/50-446) MEMORANDUM AND ORDER (Quality Assurance-for Design), December 28, 1983, pages 8-10, and CASE Exhibits 669, 669A, 683; see also, Exhibit C attached CASE /TU Settlement Agreement, attached to July 13, 1988, Licensing Board MEMORANDUM AND ORDER (Dismissing . Proceedings) and Tr. pps 25293-25295; ASLB Judge Bloch's comments at Tr. pps 25273-25274.
5 Mrs. Ellis is appointed to the Operations Review Committee
-pursuant to Section III of the Settlement Agreement between CASE, Mrs. Ellis, and TU Electric Company. The ORC is required by the Comanche ' Peak technical specifications and functions as an independent b.ody assigned the responsibility for review of various safety related matters including nuclear power plant operations, nuclear engineering, radioJogical safety and quality assurance practice.s among others.
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.Doyl e si nce his original involvement in the_ licensing hearings.
In fact, his opinion in the Summer of 1988'that TU Electric had turned around its . corporate attitude, (i.e., their approach to acknowledgement of past flaws and failures, a new corporate willingness to pursue issues and take appropriate corrective action) was: a key element in CASE's decision to exchange a contested ' operating ' license challenge for an active role in monitoring the implementation' of its corrective. action programs and- meetin - its' licensing requirements through the Joint Stipulation Mr. Doyle has continued to be involved with evaluating and monitoring TU Electric's implementation of its settlement and-regulatory commitments and reviewing various aspects of the plant's preparation for operations. It is in this capacity that he has performed this in-depth analytical evaluation of TU Electric's performance in identifying root causes and analyzing generic implications of various identified deficiencies in the SSWS.
This evaluation was prepared over a period of months using three phases of SSWS problems as a model in analyzing TU Electric'g analysis.
ability to accomplish and processes used to perform an The report is a major study of the breakdown of various TU Electric and contractor programs and processes designed to evaluate. problems and events such as the corrosion of the service water system. His report also studies how the inability of contract personnel to adequately evaluate the
' initial problems was compounded and repeated over the years by other contractors and TU Electric personnel until the discovery of a-hole;in-the service water system piping forced reevaluation of- previous assessments. Finally, the report analyzes . how TU Electric - still failed in a post-incident evaluation to come to grips with the system- f ailures that contributed to the pipe's being physically damaged and the potential impact of these failures on other plant systems and components.
6 See, for example, the comments of Mr. Doyle at the July 13, 1988, pre-hearing conference on this matter at pps 25,273 to 25,280..
7 CASE advised TU Electric by letter' on December 4, 1989, that Mr.'Doyle's draft report identified substantial programmatic deficiencies in TU's quality assurance program and other programs designed to address deficiencies. A copy of this letter was provided to the NRC staff under cover letter dated December 5, 1989. TU Electric and the NRC Staff were also made aware of Mr.
Doyle's work at a November 17, 1989, public meeting on the Auxiliary Feedwater check valve failure.
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, e II. PURPOSE
.s 'Mr.
Doyle's. report ~ concludes. in eseence, that the probable F rooticause of the multiple f ailures -in the -SSWS resulted from a f undamental. inability of TU L Electric personnel (as well as its contractors),to perform a thorough and accurate 1 analysis of the
.deficiencies incidents, events, system or component f ailures, and-identified
'i n order I
to prevent: the SSWS problems- from- ]
compounding..
(This inability or-unwillingness to fully grasp the l '
generic-implications of. events was repea.ted in the Spring of 1989 withLthe Auxiliary Feedwater check _ valve failure incident.)
y Af ter' consideration of Mr. Doyle 's evaluation, as well as
~1nput'from-its other consultants, CASE has reached the conclusion that ?TU -Electric must. .proceduralize a formal process for conducting root cause analysis and ,
evaluating generic :(
implications of incidents, : events, and deficiencies at the site j as part'of their station Operating Procedures. This program must include training and audit requirements. Finally, must be given the highest management priority and be demonstratedthis program functional and effective' prior to completion of construction.for ,
Unit II, pre-operational testing, and operation of Unit I. ]
CASE has already engaged in several' discussions wi th ' TU I Electr tc~ of ficials in
! ~
that regard, and is pleased that- TU Electric has apparently reached a similar conclusion to Mr,.-Doyle !
regarding the need .for. a procedura11 zed program to analyze root cause. .j This apparent recognition is buttressed by the October:
30, 1989,
" Root issuance of TU Electric Procedure No. STA-515, Rev. 0-Cause Analysis," and the .. lesson plan for training on this .
program.that-Mr. Doyle recently began to evaluate. TU Electric ]
and CASE:are currently engaged in discussions in an attempt to resolve the specific ' matters of disagreement in the fledgling jf program for. performing root cause . analysis. Hopefully, these j 1
-discussions Mr. Doyle, will lead to a final program procedure that CASE, and ;
believe - will avoid inadequate. and . misdirected provide TU Electric the mechanism to !
implication evaluations. root cause and. generic As a result of TU Electric's efforts on this issue, CASE is 'I not providing this report dispute, and is hopeful tonoyou in support of any pending dispute will be necessary.
lNonetheless, CASE believes that the results of Mr. Doyle's work and criticalthetoconclusions the NRC'she has reached evaluation on the of the safefacts reviewed operation of are the Comanche Peak facility, the competence of TU Electric personnel to operate the evaluation plant,soand the integrity of the decisionmaking and process necessary to safe plant operations. We urgeTUyou of to consider it carefully as you Electric management to operate the plant, andevaluate the readiness the appropriateness system failures and of enforcement action in regards to service water the auxiliary feedwater check valve 1- 4 b l
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III. BASIS AND ISSUES FOR CONSIDERATION CASE has submitted this report to the NRC for the purpose of its review and consideration under the rights of Paragraph B. 7 of the Joint-- Stipulation, and in furtherance of its various
- duties- to~ inform the public of the results of its activities toward protecting public health and-safety.
As ' the Staf 0 is well aware, without: the 1988 Settlement Agreement - and' Joint Stipulation, CASE would have pursued these issues-in. front of the Atomic Safety-and Licensing Board as part; of its proof prevail on the merits of Contention ~5. ghat..TUElectriccouldnot Although it is _ difficult to speculate on - the ',
hearing process had . no settlement - been reached, it is safe to
- assume that the report would probably have been submitted in the
"[. form of a Motion for Summary Judgment or Preliminary Proposed Findings of; Fact for the Board's consideration in reaching the ultimate determination on Contention 5'and the granting-or denial 1 of an operating license. In this regard the issues before the !
. Board' would be similar to the situation during the post-denial'- j stage of the - Byron proceedings. (In the matter of Commonwealth- -
-Edison Company (Byron Nuclear Power Station, Units 1 and 2),. 1 Docket Nos. 50-454/455, INITIAL DECISION, January 13, 1984.) In j that case the Licensing Board denied Commonwealth Edison's i application for a license, in part, because the' Board could not l conclude that the quality assurance implications raised by a discrete ~ subcontractor failure and attendant quality assurance l programmatic breakdown had been adequately resolved and i- l l--
l 8 This report is. particularly appropriate to'be considered ;
i in connection-with the violation identified in Inspection Report l 50-445/89-23, 50-446/89-23, undated, and as yet unissued j publically, but which CASE believes must be issued and resolved <
prior to licensing.
9 The text in Contention 5 was: "The Applicants' failure to adhere to the quality assurance / quality control provisions i required by the construction permits for Comanche Peak, Units 1 and 2, and the requirements of Appendix B of 10 C.F.R. Part 50, j and-the construction practices employed, specifically in regard i to.. concrete work, mortar blocks, steel, fracture toughness testing, expansion joints, placement of the reactor vessel for f 4
Unit 2, welding, inspection and testing, materials used, craft labor qualifications and working conditions (as they may affect OA/QC) and training and organization of QA/QC personnel, have raised substantial questions as to the adequacy of the 1 construction of the facility. As a result, the Commission cannot
.make the findings required by 10 C.F.R. 50.57(a) necessary for g issuance of an operating license for Comanche Peak."
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corrected. Like the substantiated worker allegations on electrical-issues at the base of the-deniallin Byron,-Mr. Doyle's report ' substantiates a programmatic f ailure -in SSWS, covering-years,. and resulting in hardware defects in a critical safety system.
.In. Byron the Board refused to allow the Staff to make the Their refusal to ultimate decision on theauthority identifiedon-flaws.
contested issues to the delegate decisionmaking The Staff is both a party to the
- Staff does not apply here.
W ' Joint Stipulationi and the decisionmaker in regards to readiness 1 to. load f uel and recommend ; to the Commissionconduct approvalfurther for an operating license. .No- licensing board will evidentiary hearings on discrete issues of management's judgment and actions by TU Electric. In that capacity CASE believes it is critical that the. issues raised in this report are considered thoroughly by the Staff prior to any decision on fuel load and :
operation.
The report contains conclusions applicable to issues of both regulatory character and competence of TU Electric to manage.and operate Comanche Peak. Some of these conclusions are - very a Unfortunately, -the conclusions are not. ancient 1
negative.
-history, but seem to persist in the handling have of events over eroded the CASE's ,
past several months. These incidents confidence in various managers at TU Electric to respond to I
events,. identified deficiencies, and programmatic breakdowns as j '
a nuclear: plant.
- quality-minded- managers prudently operating CASE has raised these matters directly to TU Electric through*the j i
Joint Stipulation and regular management conferences, and in some cases rai the matters directly to the NRC through letters or l disputes.gd ;
i i
CASE- recognizes that the .NRC _ Staff must reach. a determination on whether TU Electric has met the regulatory l requirements of 10 CFR Part 50, as well as demonstrated the l
competence to-manage an operating plant. I The Code of Federal Regulations requires that applicants for during Quality Assurance compliance ;
a' license ~ establish as during design and construction.
- operation, as well N Specifically the regulations mandate the existence of 10 See, November 23, 1989 letter from Billie Pirner Garde to Documented Request Counsil and Christopher Grimes Re:
William G.
for Action (re: Thermo-Lag /50.57 dispute between CASE and TO Electric) Docket Nos. 50-445, 50-446.Action See, also, CASE's December concerning a quality 6, 1989 Documented Request for scaling calculations assurance and engineering breakdown in effort over the past five years.
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i i'. - Managerial and. administrative controls totbe F
b used to assure safe operation. Appendix B, Quali ty
- " Assurance . Criteria .f or Nuclear Power . Plants and Fuel Reprocessing Plants," sets forth the requirements ' for
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such controls'for nuclear power plants.-
The information on the controls'~ to be used for a y
,l F nuclear power plant'shall include a discussion of how the applicable requirements of Appendix B will be i
satisfied. 10 CPR, Part 50.34 (ll)(b)(6)(ii)
< and further~re' quires that, c
.(3)- To satisfy' the following requirements, the application shall' provide sufficient information to ,
demonstrate that the requirement has been' met. -This- ;
information is of .the type customarily required to satisfy paragraph (a)(1) of this section or to address t the applicant's. technical qualifications and management >
structure and competence.
(i) . Provide administrative procedures for evaluating operating, design and construction 0; experience . and for ensuring that' applicable important industry- experiences will be provided in a timely manner to those designing and constructing the plant. ;
-(I.C.5) ;
. (11). Ensure that the quality assurance (QA) list ;
required by Criterion II, App. B, '10 CFR Part 50 1
includes all. structures, systems, and components 7
important to safety. (I.F.1)
(iii)' Establish a quality assurance .(QA) program l'
based on consideration of: (A) Ensuring independence .;
of the organization performing checking functions.from the organization responsible for performing the q
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functions;- (B) performing quality- assurance / quality H control- f unctioning. at construction sites to the "
maximum feasible extent; (C) including QA personnel in the ' documented review of and concurrence in quality
'related procedures associated with design, construction and installation; (D) establishing criteria -for determining QA' programmatic requirements; (E) establishing qualification requirements for QA and QC personnel; (F) sizing the QA staff commensurate with its duties and responsibilities; (G) establishing procedures for maintenance of "as-built" documentation; and (H) providing a OA role in design and analysis
> activities. 10 CFR 50.34 xxvii (3)(1)-(iii)
It is CASE's position that demonstrated failures in 7
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fundamental regula tory programs and processes, such as the-4
_ quality assurance program and a. failure at accomplishing thorough root 1 cause-' analyses, are - predictors of whether a utility can safely operate a plant. -This view is-supported by NRC case law- '
. which states that " Plainly,.whether the plant was properly built bears,on'whether it _ can be operated saf ely. . . " ALAB-799, citing.
Union Electric Co. (Calloway Plant, Unit 1), ALAB-740, 18. NRC 343,-345 (1983).
In keeping with this_ approach, Mr. Doyle's report and evaluation- goes beyond hardware and technical issues and evaluates processes, i
The report's conclusions identify probable causes of certain !
-events-and defiencies with the SSWS-that can be characterized as- J
" Character and Competence Issues." Although neither the Atomic ~ }
Energy Act nor the Commission's case law provide a complete
. definition 1 of the term, several_ licensing boards have addressed ,
the ' issue and applied it to evaluating events, patterns, and -
-management actions in ge design, construction, and operation'of nuclear power plants. .In this' regard, CASE submits that ,
competence, as a separate issue of fitness to operate a-nuclear '
plant,.- has- been. defined to be the technical abilities of an applicant,'to meet healthand-safety.gs -regulatory requirements This includes and protect "the sufficiency public of staffing and resources, the quality of management, and the adequacy of a utility's organization." Id.
The Commission has determined that remedial measures are-appropriate to consider in eval the- competence of an applicant-for an operating license.gting Likewise, NRC case law has held that " character" which remains-a subjective set of traits, cannot be__ evaluated without regard to eval remedial measures taken to correct identified weaknesses.y ting The Appeals Board in the South Texas case agreed with the Licensing Board y that in order to evaluate " character" the Board .needed to a scrutinize the applicant's "... record of compliance with NRC-11 See, for example, In the Matter of Houston Lighting and Power Company, et. al. (South Texas Project, Units 1 and 2),
Docket Nos. 50-498/50-499 OL, DECISION, Atomic Safety and Licensing Appeal board, February 6, 1985, ALAB-799, 19 NRC 659; In the Matter of Metropolitan Edison Co., (Three Mile Island Nuclear Station, Unit No. 1) ALAB-738, 18 NRC 177, 190 (1983);
and ALAB-772, 19 NRC 1193, 1206 (1984).
12 ALAB-799, at .
13 Id., at .
14 Id., at .
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regulations, its response to non-compliances, and its candor in c dealing with the Commission, the Board, _the _ Staff and other l parties."- Id. )
1 CASE submits'that under the terms of the Joint Stipulation, j the:NRC Staff must. perform the role-of scrutinizing TU Electric's !
history of, performance, compliance, and candor, and .that their duty to do so in this. case, without benefit of a licensing board, is.even. greater than usual. CASE recognizes that TU Electric has 'l begun to undertake-some~ remedial l measures in response to quality assurgce programmatic
. CASE weaknesses identified by both-the NRC and
.We expect that the NRC will evaluate those remedial measures, the adequacy. of those efforts, the- information i
- - regardings SSWS disclosures and AFW events, and the commitment made by' top level TU Electric management to respond to identified Y weaknesses ~ in programs and personnel. However, we believe that the hour is-getting very late for instituting major-programmatic reforms.and.that such efforts must be scrutinized by the Staff to .,
insure - that they ~ are gt simply " window dressing" to be taken down after licensing. This scrutiny may give rise to a consideration Lof imposing a licensing condition on TU Electric requiring continuation of certain self-initiated programs and efforts. Although CASE stops short of suggesting that action at
.this time, it is very close to requesting the same.
CONCLUSION Since the beginning of its role under the Joint Stipulation, CASE often. finds itself in the role of an independent ombudsman.
E It . is CASE's belief that the observations and findings of its.
constiltants and representatives provide TU Electric' management l f actual information, analysis of f acts, and insight into the power plant from'a unique perspective. In most cases TU Electric responds to those observations with an open mind. Hopefully, they will respond to this report in a like manner. However, at
.this late date, CASE recognizes that ultimately the l'
responsibility for determining the readiness of TU Electric to 15 As- mentioned previously TU Electric has written a procedure- for root cause analysis, and has undertaken some corrective measures in response to - the thermo-lag incident and scaling calculation dispute. 1
- 16 Id., citing United Broadcasting Co. v. FCC, 565 F.2d 699 l (D.C. Cir. 1977), cert. denied 434 U.S. 1046 (1978), affirming p '
Application of United Television Co., 55 F.C.C. 2d 416 (1975) that upholds the denial of an FCC license because of a long history of persistent violations by the Applicant. The relevant finding was that the applicant's remedial measures were mere l " window dressing" and that no reliance could be placed on its promise of future compliance.
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1 operate.. the ' Comanche _ Peak plant in a manner consistent. with - 1 protecting the public health and safety-. lies exclusively-withithe-NRC,.and that the Comm,issioners-and-thengeneral public expect the Staff' to - -ca r ry- out- that responsibility conscientiously. and cognizant 'of-- all. available information. In: that vein CASE supplies this. report for your assistance ' in- carrying out. your -
regulatory responsibilities.- .
Respectfully submitted,.
M. b Billie Pirner Garde l
~ Attorney for CASE :
cc :- William G. Counsil'
- Vice-Chairman
'TU' Electric
.2001 Bryan Tower -i Dallas,.TX175201 i
Dr.~Ausaf Husain
. Chairman,' Operations Review Committee (ORC)
TU Electric.
'400 North Olive Street, LB 81
' Dallas,-TX 75201 :
Susan Palmer
-Stipulation' Manager TU Electric
-Comanche-Peak Steam Electric Station P.O.' Box 1002 Hwy. 56
' Glen Rose, TX 76043 Dennis M. Crutchfield Associate Director for Special Projects Offi'ce of Nuclear Reactor Regulation i U.S. Nuclear Regulatory Commission 11555 Rockville Pike 1 White Flint North--Mail Stop 7D24
~
Rockville, MD 20852 i Bob Warnick Assistant Director for Inspection Program '
Comanche Peak Project Division O.S.'. Nuclear Regulatory Commission o Comanche Peak Steam Electric Station ,
Glen-Rose, TX 76043 L George Edgar Newman & Holtzinger, P.C.
l 1615 L Street, N.W., Suite 1000 !
I' Washington, D.C. 20036 i
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Attcchment # 5A:
! CASE CONCERN No. ~89-0031 Page 1 of 10' F
Date Submitted to TV Electric: Seotember 22. 1989 '
p TU Response Due:Date (as requested by CASE): October 2,1989 >
Preliminary Discrepancy Category: (check all applicable)
SAFETY RELATED y NON-SAFETY RELATED x HOUSEKEEPING HARDWARE y IMPORTANT TO SAFETY x MAINTENANCE y DOCUMENTATION PROCEDURAL DEVIATION x(CAR) ACCESS TRAINING -X OUALIFICATIONS TESTING X ,
CODE DEVIATION. STANDARD-DEVIATION CALIBRATION X {
s 10CFR50.55(e) 1.1&iii PART 21 PROCUREMENT A .;
FSAR DEVIATION- U-2 ENHANCEMENT X STORAGE.
- f SECURITY TRENDING ~I-OSHA HORKER SAFETY. MANAGEMENT DEFIC.- X -0THER
~f s' 0'A PROGRAMATIC BREAKDOWN YES - 10CFR50, 10CFP50.55(e) 10CFR50, APPENDIX B', CRITERION introcuction.2.III.v Vli.VI.i.ir..
A,xil.,XV,AVI.AVIll WRONG-DOING INTIMIDATION / HARASSMENT P00R INDUSTRY CONSTRUCTION PPACTICE X i POOR MANAGEMENT PRACTICE X DISCIPLINE (S) INVOLVED ~ o u a i i t :. Assurance. M6TE.1&c.Testina, a Gua il t' control. Enaineerino T01 W.G. COUNSIL
~
FROM: *' -
ON-SITE PROJECT MANAGER-CASE CONSULTANT-CASE Please~ provide your response to CASE with supporting references
, and copies offthe documents / requirements that substantiate your i evaluation results-and conclusion.
I If the responding organiza-tion / person . considers .a meeting with CASE to be beneficial f or clarity of the CASE CONCERN, please advise CASE. j CASE PERCElVED POTENTIAL DISCREPANCY (Use Continuation Sheets when necessary)
- 1.
SUBJECT:
TEFLON TAPE ISSUE CONCERN: Teflon tape has been used extensively over
,, long periods of -ime (years) at Comanche Peak Uuclear Power Station in soite of the Nuclear Regulatory Commission's recommendation that it not be used, and in spite of the fact that TU Electric issued 2 Corrective Action Recoru (CAR) in 1987, a Stop Ucrk Order in 1989, and another CAR in 1989 (which perhaos finally stopped the use of Teflon tape but the corrective action for past use has not as yet been implemented / corrected).
I NOTE: Teflon Tape is an unaoproved mechanical thread sealant.
- Multiple NCRs issued but not referenced in this C ASE Concern.
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' CONTINUATION. SHEET Page 2 of 10
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TCASE;CONCERNENo.- 89-0031 1.,..
p ~ REFEREN CE :-
- A'. 10CFR50',. Appendix B, Criterion: Introduction, states in_part:
. . . As' used in this appendix,#' quality _ assurance'- I comprises all those planned and systematic actions { '
necessary to provide adequate confidence that a...
component will perform satisfactorily in service.,
... Quality assurance includes quality control, which comprises those quality assurance-actions related to the physical characteristics of a material... component... which provides.a means i to control the quality of the material, ...com- ;
ponent', ...to. predetermined requirements." l 1
~
10CFR50,: Appendix-B, Criterion:
I, Organization, 3 States in-part:
...The-quality assurance functions are those l of (a)' assuring that an appropriate quality assurance program is established and effectively. j
-executed and.(b) verifying, such as by checking, .;
auditing, and inspection, that' activities affect- 1 ing the safety-related functions have b'een correctly performed."-
- 10CFR50, Appendix B, Criterion: III, Design Control, states in part:
f
... Measures shal1 be established to assure that applicable regulatory requirement and the design basis,-...are correctly translated into specifica-tions, drawings, procedures, and instructions.
... Measures shall also be established for the selection and review for suitability of applica- -
tion of materials... that are essential to the safety-related functions of the structures...".
10CFR50, Appendix B, Criterion: V, Instructions, Procedures, and Drawings states in part:
. . . Activities af f ecting quality shall be prescribed.. and shall be accomplished in accordance with..."
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- CONTINUATION. SHEET- Page 3
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3,4- ,
'. JCASE CONCERN.No. .
89-0031 1
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, J 10CFR50, Appendix.B. Criterion: VII, Control of-1
. Purchased Material, Equipment, and , Services states =
in.part:-
- m ' "
... Measures shall-be established-to assure
- that purchased material, ... conform to the
,. ,( pr.ocurement documents. These measures shall .
.n ,. include ... examination of products-upon
- 1 1
, Q -delivery."
10CFR50,-Appendix B, Criterion: VIII, Identification and Control of Material, Parts, and Components states
- , - in part: >
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.These identification and control measures
,l , .shall be designed to prevent the use of in-correct or defective materials..."
- 10CFR50, Appendix B,. Criterion: IX, control of Special Processes states in-part:
... Measures shall be established to assure that special processes, ...are controlled and accomplished by qualified personnel using ',
qualified procedures..."
10C.FR50, Appendix B, Criterion: X, Inspection states in part:
...-A program for inspection ...shall be ... executed
...to verify conformance with the documented in-
- structions, ... Examinations, ...of material ...shall be performed ...to assure quality."
10CFR50, Appendix B, Criterion: XIII, Handling, h Storage and Shipping states in part:
w
... Measures shall be established to control the handling, storage, ... cleaning ...of ... equipment
, in accordance with work and inspection instructions to prevent damage or deterioration".
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}N 10CFR50, Appendix B Criterion:- XV, Nonconforming ,
Materials, Parts, or Components states in part: 'l
... Measures shall be established to control i'
.- e, materials,~...which'do,not-conform to requirements
' k_
. . . . t'o prevent thei r" i nadve rter;t use or i ns tall a ti on. "
'l e '
L' 10CFR50, Appendix B, Criterion: XVI, Corrective- ,
. Jg Action states.in part: J r ;e , : *
... Measures shall be established to assure that ~!
+ conditions adverse- to quality, . . .are promptly
' i~ identified and corrected. ...The measures shall assure that-the cause of the condition is deter-
. .,a ;[, ,
mined and corrective action taken to preclude
- 4 '"
- repetition."
- n !,
4 10CFR50, Appendix B, Criterion: XVIII, Audits states ;
in part:
y
... Follow up action, including re-audit of deficient- areas, shall be taken where indicated."
j
- B. LCAR-87-043 .;
CAR-87-007 PDR-062, CPRT QA/QC Program Deficiency Report op a NCR M621, Revision 2, dated 6/2/77 :
Stop Work Order 89-002
~C AR- 8 9- 0 081 CPSES-I-1018, Revision 3, para. 1.11.5 CPSES-M-1041G,-para. 5.1.21 and Appendix A FVM-1C-069 71)G- 8 9- 15 (Multiple NCRs issued that are not referenced in this CASE Concern.)
t y BACKGROUND DATA:
$ The use of this unapproved mechanical thread sealant, Teflon Tape, at Comanche Peak Nuclear Power Station as documented on Non-Con-predates formance January Report (30, 1981,NCR) M621, Revision 2, dated 6/2/77, l_
and as reported by CPRT Recommendation E-11 of Correc-tive Action Report (CAR)-87-043, Revision 1.
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- CONTINUATION SHEET .Page 5 of 10
-CASE' CONCERN No. 89-0031 e
e
'The Nuclear Regulatory Commission (NRC) also acknowledges that Teflon Tape is not to be used, at'least in' sensitive areas, in nuclear. power plant construction (as verbally acknowledged to CASE and TU-Auditors).
- . The use of an unapproved mechanical thread sealant is compounded by the fact that TU Electric has allowed (or failed to' prevent) the improper appli-cation of the. Teflon Tape which has a high potential to contaminate a system and'even cause malfunctions, ,
i.e., the Teflon Tape was being misapplied by wrap-
-ing the tape over the ends of the hardware which immediately cut off the tape (over the ends) when thread engagement was performed - causing.the " cut-off" Teflon Tape to enter / fall into the system. '!
TV Electric was cognizant of the Teflon Tape being ,
an unapproved mechanical thread sealant, as evidenced- '
by the, References under B., and should have been aware 3 of the inherent dangers of the misapplication of the i Teflon' Tape. ,
. CAR 87-043 remained open for approximately two years, during which Teflon Tape was being used and was being 1 misapplied.
CAR 87-043 was closed on June 5, 1989 indicating correc- ,
~
tive action was implemented and complete. However, on June 30, 1989, a. CASE representative observed the con-
-tinued use of Teflon Tape at Comanche Peak. At this time it was not known to CASE of the existence of. CAR 87-043. The technical discussion, between the CASE j Representative and the TV Auditor, that followed CASE's :
observation resulted initially in a " difference of l opinion". The issue was subsequently taken verbally to the NRC/OSP by the TV Auditor since the CASE Repre-sentative recalled the NRC's evaluation of the use of Teflon Tape in the nuclear industry. The NRC did a limited research and verified that the use of Teflon Tape was inappropriate for most uses in nuclear plant construction.
J.
IAL , . 1
[y% e' j CONTINUATION SHEET- 'Page 6 ' of 10 m s gy . u
- n . CASE CONCERN No.. 89-0031 ,' DLj ,
i i
' Af ter the observation by CASE- on June 30, 1989, th 't?
' Teflon Tape was being used and was being misapplied.
TU1 Electric issued Stop Wore Urder (SWO)89-002 and t
, subsequent CAR 89-008 (as required by the.SWO). TU Electric Quality Assurance verbally notified approu -
priate personnel of the SW0' pertaining to the use of 'I Teflon Tape to be immediately stopped. ,
3 ,
It was'further. observed-by the CASE Representative.
^
J that even af ter -the SWO had been issued TV ElectricD and-its contractors continued to use Teflon Tape and continued to misapply the tape. Upon' investigation.
it was determined that not only were operations, test,B and construction personnel u nawa re: of the SWO, but .
also the QA Surveillance Group, and other persons.in--
ternal to Quality Assurance Audit Group, were unaware- [
. Dof the SWO,-and verbal notification of the SWO. ;
CONCLUSION:
CASE's conclusion, based upon personal involvement with this issue / concern, and after research into the historical facts and circumstances involving this 4 issue / concern, is:
1)- Teflon Tape, an unapproved mechanical thread sealant,.has been used extensively in the L construction of Comanche Peak Nuclear Power L' Station for-an indeterminate number of years, L but up to 1989,
- 2) The integrity of the hardware where Teflon Tape has-been applied is indeterminate; and, if considered in some areas to be " acceptable" i for use, the misapplication of the Teflon Tape causes the integrity of the hardware to be indeterminate.
- 3) There is evidence of a QA Programatic break-down in that, three CARS, one SWO, one Program Deficiency Report, and one NCR had to be gen-erated before the unapproved use of Teflon Tape could be (as purportedly is the case) stopped, (Reference CASE Concern 89-0015).
t
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9' CONTINUATION SHEET. Page 7 of 10 l u,y v 4
+
.c ~, ,
89-0031' J ;
'3 .CASELCONCERN No. ,
l5 : I
, o4 ) JTU Electric 'has anf inadequate and ineffective-Stop Work Order Program (Reference CASE Concern l 0005.1). .
5)- TV' Electric does not meet the intent of 10CFR50, Appendix-B, Criterion- XVI, by promptly ident -
-ifying 'and correcting nonconformin.g. condi- ,
. s tions:. in fact, the non-conformance continued .,
b over two years while waiting for; (and after) '
the closure of ' CAR 87-043 (Reference CASE Concern'89-0024 and 89-0037).
u AdditionalT) CASE concludes, based upon our evaluation / '
analysis.of.the current and historical conditions, and i
-based-upon our interpretation.of 10CFR50, Appendix B ;
(Reference),-the-following assessments:
A " quality assurance program apparently was.not [
effective,in assuring that Teflon Tape could not ";
-be. introduced into a safety-related system (s),
thereby preventing satisfactory performance once =t
- the system (s) were in' service and subjected to the conditions which'would introduce failures in stainless-steel applications. ' Measures were n not apparently in effect to identify that the physical material characteristics of Teflon-Tape were deterimental to-stainless steel under certain- circumstances (radiation, heat, stress), i and'that=the use of Teflon Tape.in plant systems must be controlled, ,
q k The ' quality assurance functions apparently were L not effectively executed in preventing (once identified) through its checking, auditing, and
-inspection programs, the continued use of Teflon Tape in permanent plant safety-related systems.
s u Once the use of Teflon Tape was identified by TU r
Electric Engineering to be detrimental to stainless steel applications in permanent plant safety-related equipment, appropriate design measures were not apparently correctly translated into procedures and instructions Ltraining) to prevent misapplication of the material.
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%I I-' -CONTINUATIONLSHEET P a g e JL_o f 10 I
.u . e 1 CASEl CONCERN'No. 89-0031' .
4 -I
Once.it-was determined by-TV Electric project personnel that the use of Teflon Tape was re-stricted, the applicable documents.apparently ,
F were-not. issued to prevent unauthorized use of t- the tape in permanent plant safety-related systems.
~
The restricted use of Teflon Tape was.not apper-ently adequately relayed to the suppliers of safety-related components, nor were those re- .
strictions verified during receipt of those com- :
ponents (which continued to use Teflon Tape) to t prevent introduction of-Teflon Tape into perman-ent, plant' safety-related equipment.
Teflon Tape. containers and/or dispensers were-
. not identified to prevent its use-in permanent .
plant safety-related equipment.
CASE perceives the installation of Teflon Tape i to fall;into the category of a special process.
The correct installation of Teflon Tape (i.e., .
initial wrap; starting back from threaded end '
to prevent' cutting offLof wrapover tape and ;
- dropping into' tubing / device;. minimizing excess application; and, being wrapped-in the direction 1 ofLtightening) cannot be verified after installa- :
tion;.therefore, special process controls'must !
be in place to assure proper. application of the tape.
- The Projects QC inspection activities did not verify conformance - to certain documents (i .e. ,
~
l CPSES-I-1018 Rev. 3, para. 1.11.5; CPSES-M-1041G, l L
L para. 5.1.21 and' Appendix A; CAR's87-007 and 87-043), and allowed potentially dangerous conditions to exist after inspection acceptance, i.e. FVM-IC-
' 069,did not inspect for all areas where the use of Teflon Tape could result in fluoride concentrations collecting in stainless steel joint crevices that could cause cracking.
m <
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' CONTINUATION SHEET 1 Page 9 of 10
_s . .
LCASE CONCERN ~No.
0031 t
. Teflon Tape was not removed from the, threads of [
n M&TE after calibration so that it'would not be installed in permanent plant equipment.
e Teflon Tape, a nonconforming material, was' not controlled to prevent its inadvertent use or t installation into plant equipment.
. t CAR-87-043 was closed two years after initiation and did not identify all the areas of Teflon Tape
. usage nor.did it. prevent the continued and unap-proved use of the tape. Stop. Work Order 89-002 ;
was' issued ~following closecut of CAR-87-043 but was not' effective in preventing the. continued and unauthorized use of Teflon Tape. .
-The project' Audit programs conducted by TV Electric and its contractors,'were not effect- .I ive in preventing and identifying the continued use of Teflon Tape in temporary and permanent plant equipment.
l.
L -RECOMMENDATION:
Based on-the-data contained within this CASE Concern, CASE recommends the following:
- 1) Prompt and correct closure of CAR 89-008, by 4 a) Revising procedures to prevent the 3 unapproved use of Teflon Tape, 1
L b) Revising procedures to control the issuance of Teflon Tape for " approved" uses, c) Developing an insbection plan to ident-ify and evaluate all uses of Teflon Tape at Comanche Peak Nuclear Power Station.
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pI CONTINUATIONiSHEET Page-10 of_LQf
' CASE l CONCERN:No.- 89-0031 ,
. I Ik t
.{
'2)LEvaluate other procured items for similar .;
generic. implications in other areas, i.e. .
. uncontrolled use ofEchlorides. J i
- 3) Perform a~. Vendor / Supplier Audit and/or i
m Surveillance to ascertain the.inappro--
l priate use of Teflon. Tape; to include how.the manufacturer applied the Teflon j Tape if its use was evaluated as being- 1
.o acceptable to use. ;
h 4) Label-(strictly control) Teflon Tape containers and dispensers to prevent
'theLtape from being used in permanent plant' safety related equipment. ..
- 5) Train. personnel on"the proper applica-
, -tion of Teflon Tape where its use His I acceptable, and develop, or revise, ;
applicable procedures
- 6) Develop (or revise). Quality Control Receiv-ing Inspection Procedures and/or Checklists to. include. criteria.for the inspection for .
the unacceptable 'use of' Teflon Tape on com- 1 ponents/ equipment supplied by Vendors. ]
- 7) Train Quality Control Inspectors on the L
criteria-applied to the acceptable and L unacceptable use of Teflon Tape.
The CAR and SWO remain unclosed at this time; the.refore,
'the above' conclusion and recommendations are not represent- 1" ative of' CASE's final conclusion and recommendation pending the closure of the CAR and SW0.
NOTE: TV Electric may upon their final l evaluation and closure of subject documents, arrive at the same or similar conclusion and I recommendation as CASE. 1 1
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.A.;,qn. J, x > >.p, i noT i c,i u; si rec +i Tu. etec ;ce es ciw sto:
-- attachment # so-:'
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188 ELECTRIC
(
' November 21, 1989
. m c. cw
' ve camaman r s ,
'Mrs.-Juanita Ellis President, CASE 1426, south Polk Scroot o-..
Dallas .TX 75224'
~
- Subjoct: ..Toflon Tape lasue
' CASE Concern No - 89 0031 .
Dear'Mrsn Ellis:
on ' Sep tembe r. 22, 1989'TU Electric received from CASE the subject concern, regarding the use of Teflon cape ac comanche Peak. Steam Electric.
JStation. Enclosed is a restatement of CASE Concern No; 89 0031 followed by
., :the;-TU ElectricLresponse.
Very truly oura , - ,
W . 'G Counsil
-Enclosure
'ec: 'B. P. Carde p
1 1
2001 Brym Tower Dauas. Teus 7 Dot
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(< 0,1 j CASE ConcernI '
)'at-7i . . . : Teflonitape has been usedl4xtensively = over long periode of time .
it;not be used,~andlin spite of the. fact 7 ,'
,~' commission'a reco.mmendation tha*.:
that TU tiectric -issued 2: Corrective Action Reports (CARS) in 1987, a $ top' 0; '
. Verk Order;in -1989, and'another CAR. in 1949 (which perhaps finally l stopped
' tholuse of- Teflon tape but thi correctiva action for past use has not yet-
- been implemented / corrected)
Qm NOTE:/ Teflon tape is an unapproved ~ mechanical thread sealant.
! TU tiectric Response:: ,.
Backaround:
d'
-Tha;following is a lieting of specifications addr6ssing Toflon tape an
~
"g' : changes desling with Teflon' tape use at CPSES:
o MS-100 -- "Pipint Erection Specification" is-Ms.100 Rev. 0, KaEch 1, :1976 stated, "the use of Teflon
. Thetapecontractor prohibited in the containment and in Class 1 systems.shall' not use Teflon has . been approved byLthe owner * .
>- Ms 100,wan revised July 9,1976 (Rev. 2) .- to state, "the use of Teflon. tape-is. prohibited in the plaat*.
x DCA 3950 Rev. O, was-tasued March 6, 1979 to MS-100 Rev. 3 to allow 1 -
use, of Teflon tape for temporary installations, . including temporary connections to permanent piping or equipment for .testin6 purposes. f
' -It further required -that all Teflon tape must be removed ' rom permanent piping or equipment after its use.
f
- . DCA 9564 was issued January 30,1981 to MS 100 to allow the use o
- Teflon' tape for oxygen manifolds at the catalytic hydrogen recombiners. This DCA allowed a one time deviation and no other changes were made.
'Ms 100 was revised July 9,1987 (Rev. 9) to state, 'The use of Teflon tape is prohibited for all installations whether permanent or temporary. Exceptions to this are as follows:
' a. Reactor Coolant Pump Lubrication Oil System I b. Reactor Head Stud constoners i
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o- ' MS.101- *hchanical' Erection Soecification' V<
MS 101 Rev.' 0, becember 5. '1975 stated, ' Installation of all piping, A valves and piping accessories' furnished with aquipment shall comply with the applicable, provisions' of Piping traction specification 2323 MS.100 for the systee of which the equipment is a part. In the case where two 4 or more systems are involved,1the more restrictive specification shall apply".
' ' - DCA 3951 Rev. O was issued March 6, 1979 against MS-101'to allow the use of Teflon tape for temporary installations, including-temporary connections to permanent piping or equipment for testing
. purposes. All Teflon tape was to be removed from pernaanent' piping or equipment after its use. The use of Teflon tape was prohibited for permanent installation.
- DCA 3951 Rev. 1,was issued May 24, 1982 against MS-101 co incorporate allowance for use of Teflon tape on stud sensioners for hydraulic and air ficcings per Westinghouse memorandum' TEX-M 739.
- MS-101 was revised May 15, 1987 (Rev. 5) to prohibit Teflon tapa for permanent installations. However, it could still be used on stud tensioners and the revision also allowed its use on' the reactor coolant pump motor flywheel labyrinth scal vent pipes per .
Westinghouse memorandua ThX.M 589.
o MS.625, " Ins trument Tubing and Fittings (Nuclear Safery Related)"
This specification as issued in 1975 prohibited the use of Teflon tape.
- DCA 13839 was issued in July 1984 to allow the use of Teflon tape in the Turbine Building and Circulating Water Intake Structure.
o MS-626. " Procurement of Non Nuclear Safety Related Tubinz Fittings and Valves" This Jpecification As issued in 1976 prohibited the use of Teflon tape.
o CPES I 1018, " Installation of Piping /Tubirg and Instrumentation"
-This specification compiled all installation criteria from Ms 625 sad
-MS-626 into a coasson document. It was issued July 7,1987. MS.625 and MS-626 are now procurement specifications. This specification prohibits the use of Teflon tape in all plant areas with the exception of Teflon tape installad in. the Turbine Building and Circulating Water Intake Structure prior to July 1987.
- DCA 72528 revised Specification CPES I 1018 on September 29, 1988 to prohibit the use of Teflon tape in all pipin6/ instrumentation systems associated with the Turbine Generator.
2 m
, jpg916'90 10:52 FROM TV E LEC ? CPEE S ENG E:1. D PAGE.OD5-35
- g. '
p o CPES.M 10410. ' Chemical /Consuaable Products' This specification was issued on July- 7.1988 to control the use of -
-t- Teflon tape on stainless steel applications. However, it allowed Teflon tape on the exceptions described in DCA 3950, Rev. O and DCA 3951, Rev.
~
0 and Rev. 1.
. Controlled Macarial Approval Roquesta (CMARa) TUS.143 89 and .
TUE.20189 issued August 2,1989 and August 16, 1989, ree7ectively were issued to expand specific uses provided Teflon tape does not
-come into direct contact with permanent plant equipment.
To TV Electric's knowledge the NRC has not issued any written recommendation or prohibition regarding the use of Teflon tape.
Discuasion:
_In 1977, during receiving inspection activities certain vendor supplied' equipment was Jdentified that had Teflon tape on flex line fittings.
Nonconformance Report NCR.M 621 was issued on May 12,~ 1977, for this condition.
. Discovery of Teflon tape use in' the Safeguard and Auxiliary buildings during a QA surveillance resulted in the issuance.of DR.86109 on July 16, 1986.
.The disposition of-DR.86-109 required each Operations System Engineer to walkdown' his assigned instrumentation system. The scope of this walkdokn was
-to identify the presence of Teflon tape in the assigned systaa, with emphasis s
on vendor supplied skid mounted equipment. DR 66 109 identified 8 instances where Teflon cape was applied to safety related instruments. The Teflon tape was, removed from'5 instruments, with the remaining 3 instruments being dispositioned *use as is." ' None of the instances was determined to be safety significant.
on occober 31,1986, tha Comanche Peak Response Team (CPRT) during its documentation review issued Recommendation E 11. " Unidentified Sealant *,
- which resulted in the issuance of Corrective Action Request (CAR) 87 007,
" Unidentified Thread Sealant *. During the CPRT reinspection efforts governed by Issue Specific Action Plan (ISAP) VII.a.9, " Adequacy of Purchased and Safety.Related Material and Equipment," an out of. scope deviation was noted for the' use of Teflon tape on a vendor supplied instrument. CPRT issued Program Deviation Report (PDR) 62 for this deviation on February 5,1987. TU Electric issued CAR 87 043 to evaluate the use of the unapproved threa.1 sealant. No other similar deviations were identified during ISAP VII.a.9 implementation. Additionally, no deviations related to the use of Toflon
. tape were ' identified during ISAP VII.c, " Construction Reinspection /
Documentation Review", reinspection activities.
CPRT Recoma ,ndation E-11 was revised on March 20, 1987, by the CPRT to incorporate PDR.62. This revision of E 11 indicated that Teflon tape was an unapproved sealant which was found on a vendor supplied instrument. CPRT stated thac the use of unapproved sealant hau Itaited generic Luplications
.s 3 l
1
W'a t . u u t, '
c ir 11; 's0.toi52 FROM TV ELECcCPLEi. Elm ELD since it only applies to instrument installations with thruded tubin6 l
< connections (i.e., threadad connections are not utilized in any other safety
& related fluid carrying systems). It was recossended by CPRT that TU Electric o F.ngineering make 'an evaluation of the- sealant applicetion in instrumentation systests to determine .if prior use of the improper sealant was a problea.
Jacause CARS- 87 007 and 87 043 both addrened the thressd sealant issue, CAR 87 007 was incorporated into CAR 87 043 to provide a coma +n di,sposition of the; 5eneric concerns for the use of all thrud ualants. .
As part of the corrective action for CAR 87 043, Enginuring performed a
-walkdown of the Reactor Coolant and Residual Heat Removal Systsas. A total of 342 joints were verified for visible signs of Teflon tape. No Teflon tape
' was observed in any of the joints. Furthermore, as additional corrective action'for CAR 87 043 Enginu ring personnel performed a walkdown controlled
= by. Tivid Verification Method (TVM) 069, " Safety /Non Safety Related Instrumentation and Tubing Connected to ASME III Fluid Systems and ANSI Safety Class Instal 14tionsa , of all instrument installations (over 400) connected to ASME III piping or ANSI Safety Class 1, 2, or 3 installations in Unit 1 and Common. Each of the installations has an sver*S* Of 2 5 fittin&s which were disasnembled and verified for the presence of Teflon tape. As indicated by NCR trend data, eleven apparent instances of the use of Teflon tape vere identified and documented on NCRa' during the perfortsance of TVM-069. Review of the dispositions of these NCRs revealcd that 6 were dispositioned "Use-As Is" stating that they were not nonconforming conditions because the sealant identified by the walkdown personnel was Grafoil tape which is an acceptable sealant under the criteria of Specification CPES I 1018. The remaining 5 NCRs were reworked by removing the Teflon tape, even though they were determined not to be safety significar.t.
Instrumentation attached to non-safety related installations was excluded from the walkdown because it was determined by Engineering that even if Teflon tape was used in these installations it would pose no threat to the safe operation of the plant.
Additionally, radiation monitoring and safety related plant sample lines which have threaded pipe connections were excluded from the IVM 069 walkdown because they have been reworked since 1987 in accordance with various Design Modification Request Construction (DMRCs). The work performed under the DMRCs included QC verification and was in accordance with Specification
- CPES I 1018, " Installation of Piping / Tubing and Instrumentation", which controlled Teflon tape use. Therefore, reasonable assurance exists that Teflon' cape was not applied to these installations.
The use of Teflon capo during the two year period between issuance and closure of CAR 87-043 was controlled by Specifications MS-100, MS 101, CPEs-1-1018 and CPES-N 1041G. The two years between issuance and closure were required for completion of FVM 069 to determine the extent of the use of Teflon tape and were consistent with the Fost Construction Hardware Validation Program (PCHVP) schedule. The corrective actions discussed above were impicsented and verified for proper closure of CAR 87-043 for Unit 1 and connon only (closure date June 1, 1989). CAR 87 043 romains open for Unit 2.
0
V '. 1, .. 4 , . . . , . , ..w., . .. . . . . . .. ...... . i
, a baring perioriaance of audit 70c.891S (June 19,1989 throuGh June 28,1989) the use of Teflen tape was identified in the following areas: l m' 1. Primary Chemistry Sample Line (PI 4240) for Hydrogen Analyzer drain elevation 410'. t
- 2. Au.xiliary Food Vater flectric Pump Room for the pressure indic.ator on IA7059.
- 3. Secondary $6mpie Room 115 Auxiliary building . elevation 773'.
[
- 4. Condensate Polishing Deatneraliser Turbine building elevation '
410'. '
i' As a result of these findings, Stop W rk Order ($VO) 89 002 was issued, and as required by Ng0 3.25,
- Scop Work Order *, and NEO 3.01,
- Corrective Action * , CAR 89 008, *Use of Teflon tape', was issued.
None of the foregoing uses were in a safety related application. The I proposed corrective action plans issued to resolve the conditions were '
provided by Nuclear Operations on October 5,1989. The corrective actions I for the deficiencies are as follows: ,
i o The Teflon tape associated with the Hydrogen Analyzer in the Primary Chemistry Sample line drain was removed. Teflon tape should not l u e been used in this application as this is not a threaded connection. ;
o The pressure indicator on 1AF059 was a temporary gauge m installed by Startup for testing. The Teflon tape was removed. ,
l o Teflon tape use in the secondary Sample Room and at the l Condensate Polishers vu approved via CMARs.
l.
The applications identified above where Teflon tape has been used were reviewed by Engineering eM determined not to affect the safety of plant operations since the Teflon tape was not usod in a safety related application and th areas of use involved low temperature and lack of -
. radiation fields. These environmental effects on Teflon tape can be briefly summarized as follows.
l' The thermal stabilicy of Teflon has boon studied extensively including physical property effect.s as well as the release of products of
- l. decompositi:a. Teflon tape suffers essentially no chemical degradation below 400 degrees Fahrenheit and is typically assigned a maxiama service temperature of 500 degrees Fahrenheit by its manufacturera. Above 400
~
l-degrees Fahranheit, decomposition may become increes'.agly more significant
- from an outgassing standpoint but it still has a endi effect below 750 degrees Fahrenheit. Release of de composition products which naay liberate fluorina was not reported to occur, even under extended exposure up to 750 degrees Fahrenheit. TV Electric reviewed the Industry operating Experience Reports and concluded that there have been no cases doewaented which lead to fluoride stress corrosion as a result of Teflon tape intrusions.
5
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L- -
l 7fd4 13 ' 50 ' 10 : %1 ' F &0ri VU E LE C CFit E E14G 9LD PAGE,DCL i ; .
High energy radiation has been demonstrated to affect the properties of Teflon by breaking the large polymer solecule into smaller parts, thus reducing the melocular wei@c (scissioning). This results in a redaction in l such proporties as eloggetton and tensile strength, bginning at L approximately 2 7 x 10 rada when irradiated in air. However, Teflon is reported to retain as such as fif ty percent of gta origgnal elon6ation and tenaile strength af ter radiation exposure of 10 and 10 rada, respectively.
As addressed previously, a detortoration in certain properties af ter
- application should have little or no tapact on maintaining a thread seal. 2 Subsequent to the issuance of SVO 89 002, it was observed thet Startup and
-M&TE personnel were not fully aware of t.he Stop Work order boundaries. ,
Startup immediately suspended Any further use of Teflon tape and M&TE t suspended use until Revision 1 of SWO 89 002 was issued. 411owing controlled !
use of Teflon tape in H&TE applications. To provide assurance that the use of Teflon tape by teartup had not comprosateed IVM 069 and as part of CAR 89 008, a sample walkdown of 60 randomly selected instruments was performed ;
by Quality Control Inspectors. This sample was taken from the population of instruments which were previously inspected during the implementation of i IV M 69. The risults of the walkdovn did not reveal any evidence to indicate '
that instrument fittings had been reworked with Teflon tape as a thread :
saalant before or after the Isauante of $WO 89 002. '
Swo.89 002 was lif ted on November 3,1989. Corrective and preventive actions are docunaanted in CAR 69 008, which was closed on November 11, 1989.
Conclusion Teflon tape is a controlled mechanical thread sealant at CPSES. Valkdowns by m Engineering under CAR 87 043 and IVM.069 and by Operation System Engineers under DR7 86109 identified a low nua.bar of uses of Teflon tape, which were determined not to be safety significant. The Teflon tape identified during T00 891$ was not installed in permanent safety related applications and, therefore,- had no effect on plant safety. The additio. sal Qu lity control walkdowns did not identify any evidsuce of Teflon tapo in field. installed safety related joints. Trarefore, control of Teflon tape use is considered acceptable. The issuance of SWo.89 002 and additional corrective and preventive actions taken pursuant to CAR.89 008, including additior.a1 '
training, have led to enhanced controls of Teflon tape at CPSES. No further actions are deemed necesst ry, ,
he following CASE conclusions are presented in pages 6 through 9 of Ccncern 89 0031. Each CASE conclualon is followed by a TV Electric response.
- 1. CASE conclusion Teflon Tap., an unapproved mechanical thread sealant, has been used extensively in the construeriu of Comanche Peak Nucicar power Station for an indeterminate number cf yes.rs, but up to 1989.
6
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JAt/ ~ 11 '90 10:54' FF0M 70 ELEC CFfES~ENG BLD FME .005 fwsmary Response 1 l
Teflon tape is an approved mechanical thread sealant; however, the' une J w of Teflon tape is restricted / controlled by specifications MS 100, j MS 101, CPgS b1018, and CPES.M 10410. a
.Taflon Tape has not been used extensively at CpSES as docussented by the !
results of the Engineering walkdowns per CAR 87 043 and IVM 069, i Operations Systems Engineer Walkdowns under DR.86109, QCI sample walkdown por CAR 89 008, and also as documanced in the CPRT Aesults Reports for 1 SAP VII.c and VII.a.9.
- 2. ,qASE conclusion
,. The integrity of the hardware where Teflon Tape has been applied is !
indeterminate; and, if considered in some areas to be **cceptable* for ;
use, the misapplication of the Teflon Tape causes the integrity of the hardware to be indeterminate.
Sumesrv Respot.se The areas identified which contained Teflon tape where it was prohibited were recorded on deficiency documents per FYM 069 and DR.66109. The integrity of the hardware was not affected by the use of Teflon tape. '
The NCR dispositions were implemented prior to testing of the systems. '
The acceptable testing of the safety related systems demonstrated that if the tape was misapplied,,it did not affect the performance of the safety related instruments or systems. The Teflon tape identified r during 70C.89 1$ was not installed in safety related applications and r' has been evaluated to show that it has no effect on sofo plant
[ operation, l
- 3. Cast Conclusion There is evidence of a QA Programmatic breakdown in that, three CARa, one SWO, one Program Deficiency Report, and one NCR had to be generated before the unapproved use of Teflon Tape could be (as purportedly is t.he ,
case) stopp+d, (Reference CASE Concern 89 0015).
Summary Response The following describes the relationship of these docu:eents: ,
CAR 87 007 was issued to address the use of unapproved thread sealant as identified by the third party (CPRT ). TU Electric combined CAR 87 007 and CAR 87 043 to provide a disposicion of the generic concerns of the '
use of all thread sealants and consumables and' the controls of such
, consumable s . The $VO was issued due to isolated non.4afety related occurrences, a.sd, as demonstrated above, none of these documents resulted in identification of conditions indicative of less than adequate controls for the use of Teflon tape.
--. I
i l
In summary one NCE was issued in 1977 for Teflon tape use ein a vender l supplied item, one CAR was issued to evaluate the use of Teflon tape which per the corrective action identified 5 nonconforming conditions, .'
' ' ' and DR.66109 identified 8 additional non. conforming conditions, 3 of ,
which were dispositioned *use as.is. ' TU tlectric has controlled the '
use of Teflon tape, although some violationa occurred in implementation '
of specifications. They were isolated and their impact was not significant from either a sofocy, quality of construction, or '
. programmatic standpoint. The non.conformance documenta collectively i identified 11 safety related conditions over a period of 12 years where Teflon tape was removed and do not provide evidence of a QA programmatic e breakdown. '
4 CASE Conclusion '
TU Electric has an inadequate and ineffective Stop Work Order program (Reference CASE Concern 89 0015.1). :
Summary Respor.se '
i TU Electric is aware that eone groups were not fully cognisant of the issuance of FWO 89 002. TU Electric initiated enhancements to the notification process to assure that all affected organizations and personnel receive timely notification of the issuance of SWOs. TV .
Electric will also assure that the affected crganizations and personnel '
remain cognizant of the status of SW0s affecting them.
- 5. CAsc Conclusion 1
,~.,
TU Electric does not meet the intent of 10CrR$0, Appendix B, Criterior. '
XVI, by promptly identifying and correcting nonconforming conditions: in i
fact, the non.conformance continued over two years while waiting for !
(and af ter) the clonure of CAR 87 043 (Reference CASE Concern 89 0024 l and 89 0037).
l Summary ResDonse
' CAR 87 007 was issued to address CFRT QA/QC Recommendation E 11 dated October 31, 1986. Upon issuance of CAR 87 007 TU Engineering commenced ;
en evaluation of the sealant application in instrumentation systems to determine if. prior use of the improper sealant was a problam. However, prior to the issuance of Recommendation E.11 TV Electric evaluated the sealant probles when verbally notified by the CPET. SWCC psrformed a '
physical verification of the instrument in question and stated that the MERCOID level /preature switches in the Containsent Spray System (CSS) do l not perform any safety function. Additionally, releasing the pressure on the instrument side will not cause failure of the diaphra6m, and the integriry of the process pressure boundary vill be maintained. The evaluation was made on September 24, 1986, and stated that the reported condition vill not result in the inability of the affected item to perform its intended safety related function. ,
1 8
m
i
.. j i
' ' h.
N above dieeussion' indicates t. hat the condition was promptly J identified and evaluated. Use of Teflon tape during the two year period 2 J
was controlled by Specificatter.e'MS.100, Ms.101, CFEs.l.1014, and
- CPES.M.1041C. car 87 043 remained open pending cospistion of TVM 069 in i accordance with the project schedule. The results of FYW.069 walkdowns 6 did not identify a significant use of Teflon tapa nor indicate any QA program breakdown. Rather they provided a positive indication that j
Teflon tape use was controlled, l
- 6. CASE Conclusion ,
f A quality assurance program apparently was not effective in assuring that Teflon tape could not be introduced into a safety-related i system (s), thereby preventing satisfactory performance once the I system (s) were in service and subjected to the conditions which would '
introduce failures in stainless steel applications. Measures were not apparently in effect to identify that the physical material characteristics of Teflon Tape were detrimental to stainless steel under certain circumstances (radiation, heat, stress), and that the use of Teflon Tap in plant systems must be controlled. ,
Summary Response TU Electric was aware of the Westinghouse Report WCAP.7626 ' Stress l~
Corrosion Testing', dated December 1970 and of the importance of i avoiding steuse of Teflon tape as evidenced by Specifications MS 100, Ks.101, MS 625, CPIS.I.1016 and CPES M 1041C which have controlled the use of Teflon tape in safety related applications as stated in the response to CASE Conclusion a$ above. Teflon tape has been adequately
^ $
controlled at CPSES. ;
- 7. CASE Conclusion ,
N quality assurance functions apparently were not effectively executed in preventing (once identified) throu6h its checking, auditing and ,
inspection programs, the continued use of Teflon Tape in permanent plant safety.related systems.
Summary Resoonse t
TV Electric's review collectively identified only 11 conditions over a period of 12 years, where the use of Teflon tape in safety related ,
application was detomined to be unacceptable. h occurrences of Teflon tape used as the bnais for issuing the SVO were not in safety related applications. brefore, TV Electric has not found evidence of ineffective QA program control of Teflon tape in safety related applications.
9
~.
. . . ~ . - . - , , . . . , . . _ - , , _ . . _ _ _ _ . _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
7 i 8. CASE Conclusion Once the wee of Teflon toe was identified by TV Electric Engir4 erin 6 CD be detrimental to stainio.s steel appiteations. in permanent plant safety related equipsont appropriate design measures were not apparently correctly translated into procedures and instructions (training) to prevent misapplication of the material.
Summary Response As discussed in the response to CASE Conclusion e6 above, the use of Teflon tops was controlled by applicable project specifications.
A misapplication of Teflon tape has not been identified that could prevent safety. relate 6 instruments from performing their intended functions. .This is evidenced by successful completion of extensive pre operational startup teocing and extensive hot functional testing.
Application techniqu6s for the use of Teflon tape have been incorporated as an attachment to CHARS. The isolated occurrence cited by CASE of misapplication in the M&TE Calibration Lab was on M&TE at.d was not directly connected to permanent plant equipment. Additionally, training was provided to 160 personnel as corrective action for CAR 89 006,
- 9. CASE Conclusion Once it vos determined by TU Electric project personnel that the use of Teflon tape was restricted, the applicable documente apparently were not issued to prevent unauthorized use of the tape in permanent plant safety.related systems.
,- ,$ummary Reeconse Use of Teflon tape et CPSES has been controlled since 1976. Refer to Sackground section of the response to this concern.
- 10. case conetusion The restricted use of Teflon Tape was not apparently adequately relayed to the suppliera of safety.related components, nor were those restrictiona verified during receipt of those components (which continued to use Teflon tape) to prevent introduction of Teflon Tape into permanent plant safety.related equipment.
Summary Response l
Teflon tape was a generic characteristic inspection attribute for receipt inspection of vendor supplied safety related equipsont as evidenced by the initiation of NCR.H.621 in 1977. Suppliers of safety related equipment are co6nizant of the CPSES specification requirements that prohibit the introduction of Teflon tape on safety related equipaent. Additionally, DR 86109 resulted in the Operations System Engineers performing a walkdown that emphasized vendor supplied skid i mounted equipment and removed Teflon capa whsra LC was not acceptable. l l
10 e ,
I s' .
- 11. Cast conclusion
- Teflon Tape containers and/or dispensers were not identified to prevent
,., its use in permanent plant safe ty related equipa.nt.
$"- *rv Esseense In respones to SVO 89 002. yellow labels are now affixed in a conspicuous place on the Teflon tape product to designate it as a'
' Controlled Chemical / Consumable Category !!I/ Restrictive Uso Refer to CPES M 1041C", eff6ctive September 26, 1989.
.12. CA$f Conclusion' CASE perceives the installation of Teflon Tape to fall into the category of a special process. The correct installation of Teflon tape (i.e.,
initial vrsp starting back from threaded end to prevent cutting off of vrapover tape and dropping into tubing /davice; ainimizing excess appitcation; and, being vrapped in the direction of tightening) cannot be verified af ter installation; therefore, special process controls must be in place to assure proper appitcation of the tape.
Summary Resoonse i
A special process is typically a procedure which cannot be repeated (e.g., welding, heat treatment, etc.) and changes the physical characteristics of a given element. Application of Teflon tape does not alter the physical or chemical proporties of the elements under normal operating cond'tions and is not considered by TV Electric to be a
-% special process. The application of Teflon tape can be reverified visually af ter fitting disassembly.
- 13. CASE Conclusion The Project's QC inspection activities did not verify conformance to certain documents (i.e. , CPSES 1 1018 Rev. 3, para.1.11.5; CPSES N 10410, para. 5.1.21 and Appendix A; CAR's 87 007 and 87 043),
and allowed potentially dangerous conditions to exist af ter inspection acceptance, i.e. TVM IC.069, did not inspect for all areas where the use of Teflon Tape could result in fluoride concentratiorm collecting in L stainless steel joint crevices that could cause cracking, i Summary Response l I
L As stated in the summary response to CASE Conclusion w3, TU Electric controlled the use of Teflon Cape. Although the results of FYM.IC.069 identified some procedural vioistions in implementation of safecy related Specifications MS 100, Ms.101, MS.625; CPES-I-1018 and CPES M 10410 they are isolated and their impact was not significant froa either a safety, quality of construction, or programaatic
! standpoint. As described above in the Discussion section. TVM IC 069 inspected the appropriate areas and determined chat tha use of Teflon tape was controlled and plant safety was not affected.
11 e ~ ev- - ,-- -
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6- ,
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- ) ;.
16 cAss conclusion i Teflon tape wu he.1 ren.oved froa the threads of M&TE 4f ter calibration to that it would not be installed in permanent plant equipment.
n
=
$ummary Roopense In addition to the aumaary response to CASE Conclusion me, STA 60s,
' Control of Measurits and Tset Equips,ent', section 4.1.9, was added August 4, 1989 to state, " Teflon tape .a.ay be used on MinTE and fleforence standards; however, it shall be properly applied and shall not come in direct contact with plant hardware surfaces (e.g., a pressure gauge niay not be connected to a plant test connection using Teflon tape). In addition, all M&TE/ Reference standard surfaces which have had Teflon tape applied and subsequently removed shall be cleaned".
- 15. CASE conclusion Teflon topo, a nonconforming material, was not controlled to prevent its inadvertent use or installation into plant equipment.
Summary Response Teflon tape has been controlled to prevent its inadvertent use or installation into plant equipment. Refer to Background, Discussion, and Conclusion section in this response.
16 CASE Conclusion CAR.87-043 was closed two years after inittacion and did not identify all the areas of Teflon Tape usage nor did it prevent the continued and unapproved use of the tape. Stop Work Order 89 002 wu issued following closecut of CAR.87 043 but was not offective in preventing the continued and unauthorized use of Teflon Tape.
Summary Response The programs were in. place and verified per the response of CAR 87 04). ,
l The conditions in Stop Work Order 89 002 as described in the Discussion '
section of this response, were isolated occurrences and the conditions are not adverse to safety. $ top Vork Order enhanceanents have been initiated as stated in the suamwry response to CASE Conclusion e4.
- 17. Cast Conclusion i The project Audit progra2s conducted by TV Electric and its contractors, j vere not effective in preventing and identifying t.he continued use of Teflon tape in camporary and permanent plant equipment. .
1
!. Su: nary Response I
L Refer to aumury responseu to CASE Conclusion.s a3, elo end e13.
i l 12
9
~.i . i The f:llowing is TU Electric's roep:ns6 t2 CASE roccamer.datisna en ptges 9 through 10 of Concern 89 0031.
.-~ 1. CASE Recommendatico ;
Prompt and correct closure of CAR 89 008, by a) Revising procedures to prevent the unarproved use of Teflon tape, b) Revising procedures to control the issuance of 76ficn tape for
- approved' uses,
]
1 e) Developing an inspoetion plan to identify and evaluate all uses of !
Teflon tape at Comanche Peak Nuclear Power Station.
Su--*rY.Resoonse l
Procedures and specifications have been in place to control use of i Teflon tape at CPsES since prior to 1977. Further enhancementa have I been made and are documented in CAR 89 00B which was closed on Novsaber 11, 1989. j Uses of Teflon in safety.related applications have been '
evaluated by. CAR 87 043 and CAR 89 006 as described in the Discussion section of this response. No additional actions are required.
- 2. CASE Recommendation Evaluate other procured itaas for similar generic implications in other areas, i.e. , uncontrolled use of chlorides, r Summary Response TU Electric's evaluation of the use of Teflon tape at CPSES, as described in this entire response, indicates that there are no generic implications. Additionally, Site Specifications MS 100 MS 101,- its,-!25, CPES-1 1018' and CPES N 10410 have controlled the procurement and use of halogenated compounda :p prevent stress corrosion cracking of stainless stesi as a result of contact with those compounda,
- 3. CASE Recommendation Perform a Vendor / Supplier Audit and/or Surveillance to ascertain the inappropriata use of Teflon tape; to include how the manufacturer ernlied the Teflon cape if its use was evaluated as being acceptable to use.
Summary Response Technical and Quality Requirements require vendors to sdhere to CPstS specifications and include Teflon tape restriction. The suamary response to CASE Conclusion slo discusses receipt inspection for Teflon tape en vendor supplied safety-related equipment. Also, the successful rmsults of sysrva testings did not provide any evidence of blockage or incorrect readings in the instruments. This provides additional assurance that misapplication by vendors did not occur.
-s 13
- - -~,--- -
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i
$ 4 CASE Recommendation !
Label (strictly control) Teflon tape containers and dispensers to l
prevent the tepe from being used in permanent plant safety related l aquipment. '
1
$' - rv Reso mo P Teflon tapa containers have been labeled as part of the corrective and
! preventive actions taken as a result of SWo.69 002. i
- 5. CASE Recommendation t Train personnel on the proper application of Teflon tape where its uss l is acceptable, and develop, or revise, applicable procedures. ,
Summary Resoonse !
Actions taken as a result of CAR 69 006 include training of appropriate paraonnel in the application and use of Teflon tape.
6 CASE Recommendation Develop (or revise) Qualtry Control Receiving Inapaction Procedures and/or Checklists to include criteria for the inspection for the unacceptable use of Teflon tape on components / equipment supplied by Vendors.
Summary Response QA Verification Plane contain the attribute to verify presence of Teflon tape on vendor supplied safety related piping / instrumentation items. ,
"his is documented in CAR 89 008. I
- 7. CASE Recommendation .
Train Quality control Inspectors on the criteria applied to the acceptable and unacceptable use of Teflon tape.
Summary Responao 7 Quality Control Inspostors (4CI) are trained to the specifications and/or the corresponding Quality Control procedcres which together
. define acceptable and unacceptable use of Teflon tape at CPSES. No additional training is required. ;
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OUAt.lTY ASSURANCE DEPARTMENT fAttcchment # SC !
$w'~" -
NONCONFORMANCE REPORT (NCR) gh.,n
C"P'5,1C,BH, X,XX, . .SU. .PO RT, !
SYST E M COMPONENT T,B X .RC E,S H, S, T AQ! SPIN /f DE N T NQ
, , , , , ,P A, ,14, 8,56, R.EV, E, _ i -. - , , , ,
l Q$4 AWING /$PE CtJ IC ATION NO. 1 _ E t ,u A L N
=6. PLANT Coot CODE COct A Ie1Clo!tIsI c ; aun.si l' H ; tun.iii l J ; ivn.oi 1 14 6 to i t s t. _
236051.. ... . ... O W.12. 0 CASE EXHIBIT PURCH A,$t ORDE R VIND
' n H) Y .s .
NUMBER CODE ,
t.F69 7073 -
t CP0603 03MS X 20 E,A i 29748 M6J1R2, f ,R N, s 1 1 a 1 A E A i A I iiI 8 I I I I I I I I f I iiif 1, r i f t 06Q277 a a f l MAR RIR VENDOR'S COUNT l UNITS PURCH'S RLS/ HOLD NO.l CODE INPUT I NUMBE R NUMBER Nf AT/*.OT/ BATCH NO. OU ANTIT Y ORNO. ST At us DATE !
se to po e t. _s t, % s,& t os 106 111 112 121 122 127 ial m oNG oN r on.Ath G C oNO.Tio N y A - Westinghouse eqJipment spec. G952835. Pg. 16 of 26. Para. 6.2.
C- N/A C- leflon tape used on fittings on all 20 units. Hold Tag #621 attached and units stored in warehouse C.
CA RECORD 1 NOTE: Rev. -1 issued to re-open this NCR. ,f&i nrview Rev. 2 issued to change disposition, drus . gt4 J.M; T
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! 6-2-77 A. W. McCreary l995<12i77 nato iMMgM lq.,o.,a,J f/ / , 7 S i . , c,. . ,o .. .. . u. o n o i o , o., ou var o o inconIcr.ve acr.o ns ousugag, r nu g,n;g
.C.- H. Gatche11 6120'77 DRequired WNot Required _ a,on, te bua p H oaspoot'soms newona n e r ai n ust Al is X scnAP See TBX-004 from Westinghouse PWR Div attached. .
See DCA 3950 attached.
- n. m E t arpnov A L: jiisi oATE:
o no. nc vie., , i.ov u a A '
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9:n oavo i..ngg..)V.a 7Ma. t Y,nsuG hs n e
, M M Ap.s + A v !ii sa si v a nie,ac AtioNe Wfxtory D unsatisixtory D Not Reg'd. -
, o, , lov anse /NlD / A $.$ k / m e y h bnoneocera.i.ae.vsneNr,colo 1'%& h_0. h W '/2 'pg 3-/2 -?f
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g BTOWnffROOI,Inc, P,EPORT NUMBER 0334j
( P OUALITY ASSURANCE DEPARTMENT
- RECEIVING INSPECTION REPORT
' C,Jjf... 5,qP.O.A,r Tfu,Rc,ESM,S...
i ,,,,,,,,,,,,,,.,,,,,,,,,,.
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ANT $ Y 11(M COMPONENT 1 AGr$PsN/IDE NT. NO. l DR AWING /f.PF Cif lCATION NO. KM[i 7 G- + J.
/ CODE CODE- CODI A I 48 IClDIiI& I 0 ; tunits I H; (Un.ii) l ., ; tun go i4 6 10 i t 16 17 55 _
v 90g y.6).In u a w........ aVEND t.h.
h PURCHA$f OFDER NUMBER CODE r gp r O Of.4 9 7073
((hijh 3MI. i e i e . e e ie ViNDOwg i i i COUNT iMMahh8s l UNITS bi PU RC H'S
%~di li e a_ k N_ Mil *di FtLL/ HOLD NO. l CODE INPUT h* M) FilR NUMaFn NUMetn Hr aT/t Ofili AtcH NO OV ANit T y OFI NO. STATUS DATE
~~
Ot 65 96 106 112 121 122 127 74 79 teo s 6
'~" 106-]1
'OFF L OADING INSPECTION: SAT. I UNSAT. NA RECEIVING INSPECTION:
'NDEiNDE REVIElv: N:A l CP - NDEP - '
SAT. UNSAT.
CP - N D E f' - -
. SAT. UNSAT.
'CHA RACTERISTIC INSPECTION: N!A CP - OCl -= l . I .j_. SAT. UNSAT.
- ACCEPTANCE TESTS: N/A V
'CO RROSIONMN VIRONMEN T PRO TEC TION; N!A !
- CL EANLINESS: N/A l SAT. UNSAT.
- SUPPORTIIVG DOCUMENTA TION A TTACHED ADDITIONAL INFORMATION/ REMARKS: Cfm "B ")L y b l u' Am, C "
guaaben Serirl Alu s e e :. - P O I V 8 % - s t ,* h ~ 30 (i)faplus T1pa v s a J e F Ple.x I, oa St 717"9 s .
l C';1UTHORIZED NUCL EA R INSPECTION 8 NOTIFICATION: DATE TIME: MEDIA N/A PHOJECT OA MGR !
100 ENGR, ANI WITNESS: SAT. UNSAT. WAIVED DATE. -
- ANI'S INITI ALS REQUIRED !
OC ENGR.flNSP. MM W" r-o
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It h H G&H FhN W. TUSl OTHFH I D TO: ' O. O O O- Xx2 O e. o. ran. CP-000J 236051 nEu No.
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DATE,
.. V E b.j31H:
np " nUl.ll' P 'UV j/ ['r U n ;1Ng A Uestinghouse Electric Corp. A L-0 ~ 7
- Ui, M l'ittsburgh, Pennsylvania
~
doprEn: F.o s._ _.
Pex.co Hydraulics Willits, California l'.mi.e f d 127 coinpH, O i uni o niat on.:nn.nnN tocatinN
- oom s i, _pyni ir r u _
I 1000 l'IP Hydraulic Cylinder (Snubbers) Whse C QA Rec.
20 ea. '
Spin #TCX-RCESil5
_ Consisting of:
1 l box 20 ca. IR::.co P/N C-670:05-1 Pivot Pin l 20 ea, itemco P/il C-670205-3 Pivot Pin 180 ea.11cmco P/it Z-700814 Cotter Pin . .
box Consisting of: (Field Equipment) 1 4 ca. PD16660. Reservoir Assy.
80 ea. PD 16662-03 Pipe Ciamp 3/4" ,
. 80 ca. PD 16662-04 Channel 40 ca. PD 16662-06 Ilose Clamp . . .,
20' ea. PD 16662-07 Ilose 3/4 -10, 4'0" long 20 gal PD 16662-00 Fluid SF 1154 _ __
16 ea. PD 16662-10 Tee! ...
m ew 9"j q',
4 ca. PD 16662-11 Straig&?.;-- Q' > "
8 ea. PD 16662-12 Union "" :
"h #v- W "' "
4 ea. PD 16662-13 Elbir.r S0 ca. PB 14542.04 Spater T.i.00. .
.$.M6 1' . .
.....s .. . . . . . .
I box Consisting of: (Tubin3D . : m : r1.:v.r.d'.od" O r" ;. ... i 140' 3/4 OD r ;049 PD' 166 62 05' ' "~ ~"'
X';UX'dXXX;XXWXXX3XXtl , , , ,,
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Certification Papers , ,3,bj,, ., . ,..9.iO._OJ 3 W '~-
1 J Tkt. #27315 .
{ set
< il0TE: THE SHIPME!!T IS lil GOOD CONDITION AND TrlE E IS tl0 EVIDEriCE LOAD SHIFT,11 UMP 111G, OR OTHER VISIBLE DAN GE.
g o c. cno cr. nv tu.. i.c v e. m exic cor.tr.cv
_. Gv/.lon Unrgrove ( 0)sgg )__, uB VM'? ,
u itt-ctivi:D ltY: XXXX dz.e m __ l
._e m _.truc DLLiVEHING t h a. 29CAnsuLn a u ssi '
F n NO. C Aft NO.
__3?,779 jd(5-10-77)
ACCIS. PAYAtt!
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-} NTAORANDUM Lf}If TEX-004 k k'ESTINC1100SE SITE
- TO: CPSES BROW & ROOT (QA) R. OSBORNE MAY 16 1977 Location Dept. Name Date SUBJEC'tt Monroe flydraulf e Shock Suppressors The subject equipment on QR 29748 per P.O. 236051 arrived on site with " Teflon" tape used as a thread sealant on the hydraulic lines. This is an apparent violation of the applicable Equipment Specification G-952835 Rev. O paragraph 6.2.
During installation of the shock suppressors the hydraulic lines and individual accumulators for each unit will be removed and discarded to permit installation of the pertaanent common accumulator system. During
- this removal the " Teflon" tape vill also be removed and discarded, there-for the Equipment Specification which is written for equipment in its in-service condition has not been violated as long as the final: instal-lation.to the common accumulator system does not include " Teflon" tape.
I r
ce; D. Ferg, Pk'R-SU R. Stayer, NSD ,
FROM Comanche P uk Site NSD-ISD- P.S. VAN TESLAAR bece+6 mn ~ De pt. Aswa,
,, , y _. - Figure 2.4-1 Page 1 of_
3; / i p'~; .
8 Ace)?-42/A 7 f ,,g', .
COMAtlCHE PEAX STEAM ELECTRIC STATION DESIGN CHANGE AUTHORIZATION />fg[
& g\% \ -
(WIEE) (WILLfl0T) '
BE INCORPORA.EAn {\.h IN DESIGN DOCUMENTS AUTHORIZATION 10. 3950 UW !
SAFETY RELATED DOCUMENT _ XYES__ _NO :
- 1. DESCRIPTION: DESIGN C'HANGE X YES NO A. APPLICABLE SPEC /D W/00CUfENT 2323-MS-100 3 f REV.
B. DETAILS _ _ PROBLEM: The wording of paragraoh 2.17.7 ' prevents use of Teflon tape for temocrary systems, testing, etc.
CHANGE:
Reviso paracranh 2.17.7 to read as follows: "The use of Teflon taoe is prohibited for pennanent installations. ,
However, it may be trsed for temporary installations, includino temnorary connections to pennanent pipino or ecuip-ment for testinn nurposes. Al1 Teflon tano must be removed fro's permanent nininn or eouioment af ter its use."
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- 2. - SUPPORT 1HG DOCUMEtiTATION
, f.b I..}U..._l l..---p, .. -
- 3. SIGNATURES: MWS:ch 3- -79 A. APPROVED BY:
. D #/xd G4 Represen d t v i
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B. #s,
, APPROVED BY:
Responsible Engineer 3[6[79' Date 4.,STANDARDDISTRIBbTION: i-g, e 9, e , = =
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