ML20042F386

Responds to NRC 900410 Ltr Re Violations Noted in Insp Repts 50-445/90-10 & 50-446/90-10 on 900206-07 & 0226-0302. Corrective Action:Memo Issued Emphasizing That Discrepancies Should Be Brought to Attention of Site Organizations

ML20042F386
Person / Time
Site:	Comanche Peak
Issue date:	05/03/1990
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-90174, NUDOCS 9005080264
Download: ML20042F386 (5)

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- . - . Log' # TXX-90174 F '"""

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.- IR 90-10

,, L = = IR 90-10 q n/ELEC7RIC- 903.6

,, Ref. # 10CFR2.201:

W. J. csWI 'f May 3, 1990 1~

Letrutive ?'ict (* resident Q UT S. Nucles R'egulatory Commission Attn: Document Control Desk' r

' Washington, D. ^. 20555 4

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SUBJECT; ' COMANCHE PEAK STEAM ELECTRfC STATION (CPSES)

, DOCKET:NOS.,50-445 AND 50-446 4 .NRC' INSPECTION REPORT NOS. 50-445/90-10; 50-4 N/90-10 s RESPONSE TO NOTICE OF VIOLATION

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Gentlemen:' >

f TU Electric has reviewed the NRC's letter dated April 10,. 1990, concerning the j

@ inspection conducted by the NRC staff during the period February 6, 7, and-

February 26 - March 2, 1990. This-inspection covered activities authorized by  ;

. . y" s NRC Constructilon Permits CPPR-125 and CPPR-127 for CPSES Units 1 and 2. L Att' ached to the' April 10, 1990, letter was a Notice of Violatinn.

4*3 TU Electric hereby responds to the Notice of Violation, Item B '

(445/9010-V-02), in the' attachment to this-letter. As stated.in your a Apri) 10, 1990, letter, Notice of Violation, Item A (445/9010-V-01) was .  ?

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resolved during the insraction and no written response is required..

g Sincerely,

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' William J. Cahill, Jr.  ;

CBC/daj j

< c.- Mr. R. D. Martin, Region IV.

Resident inspectors, CPSES.(3)

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1 Attachment to TXX-90174 Page 1l of 4 '

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.RQJ_1LE_OF VIOLATI h ITEM B  !

(445/9010 V-0**)

Criterion XVI of Appendix B to 10 CFR 50, as implementsd by Section 16, g' ' gra Revision 1.0 'of the Texas Utilities Electric Company (TV) Quality Assurance

- Manual, states in part, " Measures shall be established to assure that conditions' adverse nto quality, such as. . .- deficiencies,. . . and non -  ;

V .conformance are promptly identified."

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t Contrary to ihe above, on or about December 7, 1989, TU received Westinghouse memorandum MED-PCE-8447. dated November 28, 1989, which addressed questions to i the licensee's engineering staff regarding Jh.a documented compliance of Unit 1  :

reactor coolant system Lorm-4 piping field weld 12-A, to the- ASME code u' recluirements.for nondestrutive testing. . As an apparent consequence of a R series of' omissions, failures, errors and procedural inadequacies; positive 4' - '

identifica' ion and correction.of failure to radiograph field weld 12-A as  :

required by the ASME code, was- not resolved until February 16, 1990.

RESPONSE TO NOTICE OF VIOLATION ITEM B (445/9010-V-02)

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TU: Electric accepts the violation and the requested information follows. [

1. Reason for the Violation c

k ' Westinghouse memorandum MED-PCE-8447 (received by CPSES engineering on

& December 7,1989) requested copies of radiographic test'(RT) results for W

weld 12-A. On December 11, 1989 engineering personnel responded that CPSES documents indicated tha.t only visual. and dye penetrant inspections r

X .were required. The engineering' personnel involved did not investigate whether the ASME Code required radiography of the weld.

I On Thursday, January 25, 1990, another Westinghouse memorandum, NED-PED-8671, was received by engineering. This memorandum recommended that weld M. 12-A be radiographed in order to comply with ASME Code requir6:nents. The engineer who received this memorandun had not been involved in tasponding -

to the previous memorandum and recognized that a deviation from A;ME Code m requirements existed. The engineer initiated a site deficiency document a

(ONE form) on. Monday, January 29, 1990, and made his supervisor aware of ,

the condition. The engineer and his supervisor took no further action.

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• L Attachment to.TXX-90174 0 Page 2 of 4  ;

During the period from January 29, 1990 through February 13, 1990, the ONE

'p- Form was.:dispositioned to perform the. required RT and_ assigned to the ASME-QC' group to accomplish the disposition. The ASME QC group determined that

~a-Work Request was required to remove . insulation to facilitate. performance of the RT. LASME -QC_ made several unsuccessful attempts to have a' Work ,

,  ;< Request initiated. Eventually, the Technical Support System Engineer was

. contacted. . After verifying:that an RT was' required by the ASME Code, the

-System Engineer, initiated the required Work Request. However, the Work  ;

Request was assigned.a " routine" priority. Upon becoming aware of the  ;

? Work Request, the' Manager of Projects recognized the significance of the '

' deficiency'and expedited performance of the RT.

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'TU Electric's review of the above described events has identified the L' following as causing the failure to promptly identify and correct the lack of /3ME. required RT. -  ;

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L The engineering' personnel who. responded to Westinghouse memorandum MED-PCE-8447sdid not adequately pursue resolution of the apparent a

_ discrepancy between the Westinghouse memorandum and the 1 nondestructive examinations which were specified by the site J' documents. Site ASME Code engineering personnel were not immediately contacted to determine the applicable ASME Code requirements.

The engineer who initiated the ONE Form'and his supervisor did'not  ;

alert appropriate management personnel when they determined that a ,

deviation from ASME Code requirements existed. ,

The ONE Form was assigned to a Construction organization, ASME QC, to accomplish'the disposition. The system in which the weld was s located.was in the custody _ of. the Operations Department and therefore a Work Request was required to remove insulation for the:

l RT. As a Construction organization, ASME QC is not under the l

, jurisdiction of Operations procedures and does not issue Work Requests. As a result, several days elapsed before the required Work Request was initiated.

L." There was no mechanisia to assure that the System Engineer was notified of the deficiency in' a timely manner. Had the System 1 Engineer been aware of the deficiency earlier he could have  ;

expedited initiation of the Work Request.

Tne priority assigned to the Work Request was not appropriate for the condition. Resolution of this deviation from the ASPE Code should have received a higher priority than " routine."

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4 TAttachment to TXX-90174 ,

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2.-  % rrective Steos Taken and Results Achieved '(

An RT of weld 412-A was performed on February 16, 1990; A Plant Incident'-

Evaluation was written to address the generic implications and . 1 preventative actions pertaining to the failure to perform an ASME. required- J RT. The corrective actions for this evaluation included a review of ' "

documentation which detemined that ASME required RT's had been performed :

-on other similar welds.

3. f.prrective Stpos Which Will be Taken to Avoid'Further Violations .,

. A memorandum has been issued to engineering personnel emphasizing dat s potential discrepancies ' involving Codes or Stt.ndards tshould be brought to 1 the attention of the site-organizations responsible for implementation of the Codes or Standards.  ;

The engineering personnel who were involved in the response to .

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Westinghouse memorandum MED-PCE-8447 are no longer on site. The: engineer who initiated'the ONE' form and his supervisor have been made aware of:this violation- and of the necessity of notifying appropriate CF3ES Management personnel when deficiencies requiring urgent action are identified. ~ q Additionally, ONE Forms involving engineering are' currently reviewed at the Engireering' Plan of the Day meetings and by the Engineering Managers _ .

to assure that resolution of significant deficiencies is. expedited.- These. 'j

<- reviews will continue until the Engineering Managers have assurance that an adequate level of sensitivity exists regarding deficiencies which require prompt management attention. L A Nuclear Engineering and Operations (NE0) Policy Statement >has bee'n .

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-issued emphasizing that problems and concerns must be' properly documented and communicated to appropriate management. Additionally, the' Policy-Statement emphasizes that: each individual is expected to aggressively seek l 4 out problems.and pursue them to resolution. TEngineering ~ personnel haves >

been trained on this Policy Statement.: y

, A procedure change has been initiated which will assign the Work Control- j C Center the responsibility for initiation'of Work Requests which are -

required to accomplish ONE Form dispositions.

A memorandum has been issued emphasizing that System Engineers are to-remain cognizant of open. items involving their assigned systems and to ,

assure such items are identified to appropriate management and technical '!

personnel. A database listing the open items affecting plant ' systems is  ;

available for periodic review by System Engineers.

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1 Attachment to TXX-90174'

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The: review of new ONE forms has been enhanced by the addition of.

engineering: personnel to the review group that assigns-ONE-Forms to '

• responsible orgnizations for disposition. This enhancement provides ,

t.Jditional assurance that ONE Forms and any resulting Work Requests-involving significant technical issues receive a priority.r.ommensurate~' , >

with potential impact on current'and planned plant evolutions.- ql

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4. Date .When Full Comoliance Will be Achieved o

, The _ procedure change described above will. be issued by May 25,'1990.- ,]

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