ML20085C722
| ML20085C722 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/03/1991 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-91346, NUDOCS 9110110003 | |
| Download: ML20085C722 (3) | |
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Log // TXX-41346 1UELECTRIC FMe il 1013U Ref. // 10Cf R2.201 October 3. 1991 Wilham J. Cahill, Jr.
henung ske bru, lent U. S, iluclear Regulatory Commission Attn:
Document Control Desl'.
Washington, D. C.
20555
SUBJECT:
COMAllCHE PEAK STEAM [LECTRIC STA11011 (CPSES), UNIT 2 DOCKET NO. 50 446 IIRC lilSPECTION REPORT N05. 50-445/91-38: 50-446/91-38 REPLY TO A Il0llCE OF VIOLATION Gentlemen:
10 f'ectric has reviewed ilRC's letter dated September 6, 1991, concerning the inepection by Mr. R. M. Lat'.a and other members of the Region IV statf during the period July 17 through August 27 1991, of activities authorized ior Comanche Peak Steam Electric Station. Unit 2 and the attached flotice ci Violation.
TU Electric hereby responds to the Notice of Violation in the attachment to this letter.
Sincelely, b
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,p William J. Cahill, Jr.
JDR:TLH:bm c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (2)
Mr. M. B. tields NRR i
[jVf h' ' t 9110'110003 911003 PDR ADOCK 05000446 f
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n PDR 400 North O!ive Street L.B. 81 Dall.is, Texas '5201 i
a Atta hment to TXX-91346-Page 1 of 2 NOTICE-OF VIOLATION 446/9138-01
- rriterion V of Appendi'x B to 10 CFR Part 60, as implemented by Section 5,0'of the TU Electric Quality Assurance Manual, states, in part, ' Activities.
af fecting quality -shall be prescribed by documented instructions, procedures or drawings, of a type appropriate-to the circumstances and shall be dCComplished.in aCCordance with these instructions, procedures, or drawings."
^
Construction Traveler TCX-RCPCRV-01-77055 referenced Step 8.8.14 of Procedure HSM-CO-990), " Reactor Vessel Head Removal. aim Installation," which stated that the'high-and lownload-alarm setpoints are to_ be adjusted to plus and minus 5
-percent, respectively,' of the~ load cell reading when'the head was lifted.
Cont rary' to the apove,-_ on August 12,1991, the low-load-elarm setpoint was not adjusted to-the proper _value in-acco' dance with the referenced procedures.
during the reactor vessel head-removal.
RESPONSE TO NOTICE OF VIQ M UAM 446/9138-01
- TV LElectric accepts the violation and the requested infermation fol!ows:
1.
Reason for The-Violation Const ructien-Traveler TCT-RCPCRV-01-77055, developed to liit the reactor 4
vessel hea
'uired the load cell alarms to be set after the lift began.
However -'as 6 ecaution the_ low" load and high-load alarms were both_ set and verified p, f or-to the lif t.
The engineer in charge had the alarms set at +5% and -5% of the vessel head's estimated weight (based on Unit 1 vessel head weight) and wns to check'the setpoint after-the lift began Before the actual lift-began, on attendant engineer re-zeroed the 5%
l alarm setpoint du' ring a discussion with an ubserver.
The alarm was re-zeroed to'show the obscrver that the actual alarm condition could be cleared (the alarm was annunciating as'it should have at the time because the-lift had not begun).
Although the attendant engineer knew that the alarms had been set, he did not recognize that_this step had been previously verified by a construction engineer.
The attendant engineer became distracted and failed to have the alarm reset to the -5% value, As the lif t began, the engineer. in charge looked at the load cell reading and
-noted that'the estimated-weight 1338,000 lbs) and the actual weight-(335,000 lbs) varied slightly (less than 1% of the total weight). The engineer believed that this minor-diffecerce did not warrant resetting either alarm.
ine engineer also knew that vessei head weight was being monicored-constantly by two different people and that if the load cell ind'cated weight fluctuated, the lift would be terminated and the cause
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At t.acInnent t o TXX-91346 Page 2 of 2
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investigated before the low-or high-load-alarms were reached.
- However, had the alarms been checked as required by the work rackage the engineer in charge would have noted that the % alarin had been re-zeroed and therefore it could have been reset before continuing the lift.
2.
C._9rret tdve St eDs Tak en and Result s Ac hieved The following steps were taken to correct this deficiency:
A.
A TV Electric Evaluation form ( TUE) was written to ident'fy the procedural non-compliance and that the lower alarm limit had been re-zerced prior to the lift of the reactor vessel head.
Addi t i oria l l y,
10 Electric determined the same procedural non-compliance had occurred during the lift of the upper vessel internals however, both alarms had remained active Corrective action included re-instructing the engineer in charge on the applicable sections of the procedure and the need for increased attention to detail.
The TUE e
Form has been closed.
B.
A Technical Lyaluation (TE) was written to identif y the need f or linit 1 personnel to evaluate the procedural steps of HSM-CO-9901 and 9902.
The evaluation concluded that na prscedure change was necessary because the alarms are used as lockups to direct visual inspection.
In addition, Lased on past experience, the crane used for the lift in some cases must be Jogged during initial cable tensioning which may cause inadvertent alarms These unnecessary alarms can be e l i mi r, a t ed if they are set after the lift is started.
The TE has been closed.
e torrective Steps 1.it en To Avoid Fut3her Viola ([pjji k
3.
The engineer in charge of the vessel head lift and the attendant engineer have read and understand the HOV and tha TV Electric's response.
In addition, the ottendant engineer was counseled concerning the manipulation of the alarm setpoints.
The Construction Work Document (CWD) which provided Instruction. for the subseque'it lift of lower reactor vessel internals was revised to assure that the alarms were set prior to the ltft and verified after the lift began.
The deficiency was discussed and evaluated as part of the Quality Accountability Program to assure that management was aware of the de f icienc y, its causes and corrective actions.
4.
EsLtjdOlnt_failllomo1ian fy Wi11 Be_AM igyd full compliance has been acnieved.
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