ML20073H137
| ML20073H137 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/29/1991 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-91161, NUDOCS 9105060190 | |
| Download: ML20073H137 (6) | |
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1-Log # TXX 91161
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E Fi1e # 10130 Ref # 10CFP,2,201 g
April 29, 1991 wiltlam J. Cahm, Jr.
Eieciatiw rut /teshfarit V. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) UNIT 2 DOCKET NO. 50 446 HRC INSPECTION REPORT N05, 50 445/91-07; 50 446/91-07 REPLY TO A NOTICE OF VIOLATION Gentlemen:
TU Electric has reviewed the NRC's letter dated April 1, 1991, concerning the inspection conducted by Mr. R. M. Latta and others during the period February 1 through March 12, 1991. This inspection covered activities authorized by NRC Construction Permit CPPR-127 for CPSES Unit L.
Attached to the April 1, 1991, lette^ was a Notice of Violation.
The NRC's letter expressed concern about the enclosed Notice of Violation because it involved the programmatic aspects of the-Unit 2 corrective action program which are fundamental to the appropriate identification and resolution of potentially significant conditions adverse to quality.
TV Electric believes that overall, the Unit 2 program, whic'h is based in large part on the TU Evaluation (TVE) process, is functioning as intended and is in compliance with regulatory requirements. This belief is based on the positive results of program trending, Quality Accountability Program (0AP) feedback and actions, and ongoing performance-based statistics.
TU Electric also believes that overall, the Unit 2 procedures developed to identify and correct conditions adverse to quality are adequate.
However, based on the causes -identified in the attachment, inconsistent implementation of the procedures was identified.
TU Electric management has and will continue to monitor the overall adequacy of the Unit 2 program for identifying and correcting conditions adverse to quality.
In addition to the actions described in the attachment, the 0AP which constitutes a significant portion of the management monitoring process, in part, has focused on the threshold for identifying and resolving 9105060190 h45 FDR ADOCK PDR 400 Nonh Olive Street LB. 81 Dallas, Texas 75201 7
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TXX 91161 Page 2 of 2 potentially significant conditions adverse to quality.
The OAP will continue to focus on this area until TV Electric management is satisfied that a conservative threshold is consistently maintained.
TV Electric hereby responds to the Notice of Violation in the attachment to this letter Sincerely.
William J. Cah 11, Jr,
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TLH/bm Attachment c
Mr. R. D. Martin, Region IV Hr. M. B. Fields, NRR Resident Inspectors CPSES (2) i l
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Attachment to TXX 91161 Fage 1 of 4 NOTICE OF VIOLATION 440/9107 01 Criterio.1 XVI of Appendix B to 10 CFR Part 50, as implemented by Section 16.0 of the TV Electric Quality Assurance Manual, requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
Furthermore, for significant conditions adverse to quality - the measures shall assure that the cause of the condition is determined and that adequate corrective actions to preclude repetition are taken.
Comanche Peak Steam Electric Station, Unit 2, Procedure 2PP 3,05, Revision 1,
" Procedure for Pro;essing of TV Evaluation Forms (TVE) and Conditional Release Requests (CRRs)," Section 6.1.2.e, requires that a TVE form and.0 snall be initiated when a condition is identified which requires a determination of cause, an evaluation of generic implications, corrective actions, and preventive actions.
Contrary to the above, the resolution of three TVE forms were inadequate in that they failed to determine the cause, generic implications, and/or required corrective and preventive actions as noted below:
1.
TVE Form 90-163, dated November 7, 199[0], failed to address the cause and corrective actions for a programmatic deficiency where previously identified nonconforming material was released to the field for installation.
2.
TVE Form 91-337, dated January 9, 1991, failed to address the cause ai corrective actions for an unauthorized work activity for base metal repair for safety-related piping.
3.
TVE Form 90-172, dated November 12, 1990, failed to address all corrective actions for required weld repair of the fuel transfer tube in:luding an-evaluation of reportability.
Resoonse tQ Notice of Violation 446/9107 01 TV Electric accepts the violation and the requested information tollows.
1.
Reason for the Violation TV Electric's review of the TVE forms identified in the Notice of Violation resulted in the identification of the causes discussed below.
Some Unit 2 Project personnel did not appropriately understand the programs (i.e., the Quality Accountability, Programmatic /
Repetitive and Reportability Programs) developed to satisfy requirements for evaluating TVE form conditions considered to be other than routine in nature.
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JAttachment to TXX 91161
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-Engineering personnel, while providing adequate technical solutions to explicit TUE form conditions related to hardware, did not always evaluate, or cause others to evaluate personnel or program related conditions.
Some Engineering. personnel did not fully understand the 100FR50.55(e)-reporting criteria or their relationship to 10CFR50 Appendix B Criterion XVI.
Engineers did not, in all cases, provide enough detail in TVE form dispositions to _ explain the reasoning f or significance and i
reportability determinations or the methodology used to resolve technicci issues, 1
Quality Control and Engineering Assurance personnel responsible for conducting Quality Accountability Program (OAP) meetings, which evaluate significant TUE forms for cause and adequacy of corrective actions, had not. fully discussed with appropriate personnel the varying _ levels of significant conditions that can be identified and
-the expected input to QAP meetings.
Some confusion existed between the various= departments as to who could identify TVE forms for 0AP meeting review.
2.
Corrective Steps Taken and Results Achieved Each of the:TUE forms identified in the NRC inspection report were evaluated =foriproper disposition, thoroughness, and potential reportability..Two of'the conditions documented on-the TUE forms have
- been upgraded 1to a programmatic / repetitive status because-of generic
. hardware ~ implications 1or because-of additional-personnel related occurrences _-(TUE; forms 90 163 and 91 337, respectively).
The other TUE1 form (90-172)Lwasf revised and remains open for_ work completion.
None of the conditions on.these TVE forms represented a reportable condition pursuantito 10CFR50.55(e) or 10CFR21.- However, the evaluation did result
.in'the identification of the causes listed in Section 1.above'and prompted-the actions > described below,
-Ancimmediate. review of the.TVE and reportability program procedures was Jperformed by Unit 2 Engineering-Assurance-and Unit 2 Licensing to assure
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that'the procedures 1provided adequate user' guidance relative to 10CFR50 Appendix 0, Criterion XVI,'10CFR50.55(e) an~ 10CFR21.
As a result, one d
-minor.-change was made to.the.TUE_ process procedure.
The change consisted.
LofDrephrasing-th'e'" Potential Safety Significance" block on'the'TUE form to:"Potentially~ Reportable".to be consistent with the instructions in the
' body..of the procedure.
No other changes-were1 deemed necessary to the e
' procedures,fHowever, this review and-the evaluation of.the TUE forms in-question didfindicate the need for' training.
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i Attachment to TXX 91161 Page 3 of 4 Project Management directed that training be conducted immediately for Lead Discipline Engineers (LDE), the personnel responsible for review of TVE forms and for potential reportability determinations, to emphasize and supplement procedural and management requ'.rement:.
The LDE training covered a number of topics including the relationship between 10CFR50 Appendix B Criterion XVI and the reporting requirements of 10CFR50.55(e) and 10CFR21: the need for resolving both the technical condition described on the TVE f orm and, as necessary, the personnel or program related conditions; the need to more fully document nonconformance dispositions: the differences in procedural provisions for evaluating routine, significant and reportable conditions; a detailed explanation of the Quality Accountability Program function and feedback mechanisms; and a discussion of previous TUE foims in order to provide examples of the expected threshold for identifying conditions as significant and/or reportable.
This training was completed on February 27, 1991.
In addition, Construction Quality Assurance is presently performing an audit of the nonconformance process.
One of the audit checklist items requires an evaluation of the process for identifying and evaluating significant TVE forms.
This audit report will be issued by June 10,
- 1991, 3.
Corrective Steos Which Will Bf: Taken To Avoid further Violations in order to assess the effectiveness of the training described above, the Unit 2 Engineering Assurance Manager has begun reviewing dispositioned TVE forms. This review is intended to judge TVE form disposition adequacy, disposition narrative content, significance /reportability determinations and the need for TVE form input into the Engineering 0AP, Results of this procass are provided to the Engineering Manager and fed into the Engineering 0AP meetings.
This review has indicated that the quality of TVE disposition documentation has improved and that items of significance are being resolved appropriately.
Periodic review of TVE forms via the Engineering 0AP meetings will continue to assure that proper levels of documentation are maintained and that the significance threshold stays consistent with the Engineering Hanager's expectation.
The Hanager of Quality Control (00) has and will continue to conduct GAP meetings for the 00, Construction, and Procurement organizations to communicate and pursue the causes of selected deficient hardware, deficient programs and personnel errors.
During the past three months a greater number of TVE forn, conditions, considered to be of a lesser significance when compared to those of the past, have been evaluated in the OAP meetings, indicating that the Project as a whole has lowered the threshold for identifying TVE form conditions as significant.
The QC Hanager will continue to monitor this process to provide additional assurance that the desired consistency and conservatism is maintained.
Attachment to TXX 91161
_Page 4 of 4 The concepts provided in the Lead Engineers training sessions will be incorporated into the Engineerird fictrination Training as well as Refresher TUE-Process Training,
.. training courses will be modified and initiated by June 15. 1991.
In addition to the above actions, the Notice of Violation and content of this response were discussed during the QC and Engineering 0AP meetings and during the Startup and Operations staff meetings.
4.
Date When Full ComD11ance Will be Achieved TV Electric is in full compliance.
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