ML20127D753
| ML20127D753 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/10/1992 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 9209150156 | |
| Download: ML20127D753 (5) | |
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ccr I n !OO2 Docket-Nos. 50-445 50-446 License No NPF-87 Construction Permit No. CPPR-127 TV Electric ATTN: W. J. Cahill, Jr., Group Vice President Nuclear Engineering and Operations Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Thank yo'u for your letter of May 26, 1992, in response to our letter and Notice of Violation dated April 23, 1992. We have reviewed your reply and find it responsive to the concerns raised in oitr Notice of Violatior..
On July 6 1992, the Citizens Association for Sound Energy 4 CASE) forwarded it's Interim Report Regarding Wrong Unit / Wrong Valve incident. CASE requested that the report be considere_d in determining the acceptability of your response to Notice of Violation-(445/9208-02,446/9208-02) Item B.2. The report was forwarded ~ to Region IV via a letter from J. Ellis to T. P. Gwynn dated July 6, 1992.
After reviewing;the CASE report, we concluded that your response to item B.2 fully satisfies the requirements Lstablished in the NRC's enforcement policy and' consider your corrective actions taken and those propo;3d, if properly implemented, adequate to reasonably preclude recurrence of the wrong unit / wrong valve incident. _ Howevar, separate and apart from the enforcement action, the NRC believes that the issues raised by CASE merit your consideration as called for under the joint stipulation.
_W e will review the implementation of 'your corrective actions during a future inspection to determine that full compliance has been achieved and will be l maintained.
L Singp ly,
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TV Electric , 4 CC:
1TV Electric -
ATTN: Roger: D. Walker, Managerfof Regulatory Affairs _for Nuclear Engineering-Organization '
Skyway Tower 400 North Olive Street, L.B. 81 Dallas,: Texas 75201 Juanita-Ellis
- President : CASE-1426 South Polk Street-Dallas, Texas _75224 GDS. Associates, Ince
' Suite 720
.1850 Parkway _ Place Marietta,. Georgia 30067-8237 TV. Electric
- t. Bethesda- Licensing:
>3; Metro: Center,LSuite!610
, lBethesda, Maryland 20814 Jorden,-Schulte, and Burchette ATTN: William A. Burchette, Esq.
Counsel for Tex-La Electric Cooperativenof Texas-1025 Thomas Jefferson 'St. ,: N.W.
-Washington,:D.C. 20007 Newman- & Holtzinger, P.C.
ATTN:-:-Jact R. Newman,;Esq.-
1615 L. Street , N,W.
Suite 1000 Washington,cD.C. -20036 I Texas Department of Labor &; Standards ATTN: G. R=. Bynog, Program Manager /
Chief. Inspector' Boiler-Division -
P.O.RBox 12157, Capitol-Station.
Austin, Texas 78711
.' Honorable Dale McPherson -
County'Judgej
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P.O._ Box 851
- Glen Rose,7 Texas- 76043-
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Texas' Radiation Control: Program Director ,
' 1100 West-49th Street .
Austin,1 Texas 18756
-Owen'L, Thero, President Quality . Technology Company 4 Lakeview Mobile Home Park, Lot 35 4793-E. Loop 820 South Fort Worth, Texas 76119
- W. G. Counsil-Vice Chairman TV Electric 2001 ~ Bryan Tower, - Suite 1900 -
-Dallas,' Texas- 75201 Lance-Terry,' Chairman.
Operations Review Committee (0RC)
TV -Electric--CPSES, Mail . Zone E01 P. O. Box 1002-Glen Rose--Texas -76043
' George L*. Edgar, Esq.
Newman'& Holtzinger, P.-C.
11615 L: Street, N. W.
Washington,.D. C. 20036 Susan'Se Palmer-Stipulation Manager (TV Electric --LCPSES _
P. 0. Box:1002:-- Highway 56-Glen Rose;JTexas 76043
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_: File # 10130
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'R 92-0B Pef. 4 1CCFP2.201 TUE C TPiC May 26, 1992 Williern J. Calilll. h.
Go .e s we tendret U. $. flutlear Regulatory Commissi:n Attn: Document Control Desk Washington, DC 20555 s
SUBJECl: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AhD 50-406 NRC lt1SPECT10N REPORT N05. 50-445/92-08 and 50 446/92--05 PESPONSE TO NOTICE CF .- !OL AT ION Gentlemen:
TU Electric has reviend the NRC's letter dated April 23, 1992, the inspection conducted bv the NRC staff during the period February 2 through March 21, 1992. These inspections covered activities authori:ed by NRC Operating License NFP-87 and Construction Permit CPPR-127. Attached to the April 23, 1992, letter were two Notices of Violation.
TU Electric hereby responds to tre Notices of Violation in the attacnments to this letter.
In addition, during an NRC Resicent inspector's exit meeting conducted Aoril 24, 1992, TU Electric commit'ed to provide information involving corrective actions relative to the disasseroly of a wrong valve by maintenance -
personnel. This information is dncluded in the attached response.
Sincerely.
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, fyAds~llhi.,/b'lsiinU', d William J. Cahill, JrJ
-JET /tg Attachments c- Mr. R. D. Martin, Region IV ,G Resident insoectors, CPSES (2)
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- Attachment 1 to TXX-92243 Page 1 of 2 NOTICE OF VIOLATION (445/9208-01 (446/9208-01 Criterion V of Appendix B to 10 CTR Part 50, as implemented by Section 5.0 of the TV Electric Quality Assurance Manual, states, in part, " Activities affecting quality shall be prescribed by documented instructions, procecut 3 or drawings, of a type appropriate to the circumstances and snall be accomplished in accordance with tnese instructions, procedures, or drawings,"
(A) Maintenance Section of Metranical Manual Frocedure MSM-CO-8801, Revision 3, "Borg-Warner Check Valve Maintenance " Steps 8.2.1.10 and S.3.1.22.
specify the removal of the weld wnich retains the arm pin in the swing
. arm prior to removing the swing _ arm pivot pin, Contrary to the above, the NRC inspectors determined througn the review of Operations Notification Evaluation Form 92-227 and TU Evaluation Form
. 91-3054,_that the arm pins on Valves 1AF-0075, IAF-0078, 2FW-201, and 2FW-202 and other Units 1 ana 2 Borg-Wanner-swing check valves were improperly removed by snearing of the associated arm pins with dynamic force.
RESPONSE TO NOTICE OF VIOLATION (445/9208-01)
(446/9208-01)
TV Electric accepts the violation and the recuested information 'ollows:
. (1) . Peason For Violation TU Electric performed a comprehensive review of the applicable documents
-and interviewed cognizant personnel, i t was concluded by this raview that. the_ cause for this violation was the perception by craf t personnel that the procedure allowed the latitude to remove the pin in an
-alternate _ method.-
_ (2) Corrective Steos Taken and Petults Achieved Deficiency. documents for Unit 1 and Ur.it 2, were issued to address both the- programmatic issues as well as to evaluatc the possible-residual effects on the hardware. A task team was appointed by CPSES management
-to-resolveLthe-procedural and hardware implications. Evaluations concluded' chat'the disassemoly technique was not detrimental to the 1 operability of the valve. The practice of e 71oying disassemoly metnods
_oi Borg Warner' check valves Other than_tl n' delineated in the procedure:was-prohibi'.ed by_ Maintenance through the issuance nf a' letter to_the Mechanical Maintenance supervisors. Similar direction was-also a,a _ , ~ _ . - . w.- ~ ~ ,, - - ~ . - - . . . . . - -.a--
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i Attachment 1 to TXX-92243 i Page 2 of 2 i
t provided to appropriate Unit 2 personnel in a memorandum from tne Unit 2 Startup Manager. ,
(3) forrective Steps Taten to a void - rurther violations ;
i The Unit 2 Startup Mechanical craft and supervision shall receive training on compliance with' approved work packages. This training shall emphasize the process to be followed when a procedural step cannot be performed. The Maintenance cepartment shall prcrnulgate a " Lessons Learned" to Maintenance w $onnel to ensure craft and supervision are sensitive to the importante of assuring work activities reflect accurately the steps-specified in the work documents. -
(4) Date When Full Compliance Will Be achieveQ ;
full compliance will be achieved by July 31, 1992.
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i Attacnment 2 to TXX-92243 Page 1 of 5 NOTICE OF V10LA110N (50-445/9208-02)
(50-446/9208-02)
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0 of the TU Electric Quality Assurance Panual, states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, proceQures, or drawings." -
(B.1). Station Administrative F tc a * " - In6 " Work Recucsts and Work Orders," Revision 17, Se :( s ; at' in part. "QC is responsible for reviewin, s sna q w ,.k Ordcrs.'
Station Administrative Procedute ,iA-606, ' Work Requests and Work Orders," Revision 17. Step 6.6,3 9, states, in part, " Perform work
- in accordance with the instructu ns and in the sequence listed."
Station Administrative Procedere STA-607, " Housekeeping Control,"
Revision 12 Step 6.3.3.2, states, in part, "After the system is opened, if the work group memDer(s) leaves the area, the pressure boundary opening shall be capped, plugged, or sealed." Attacnment
- 8.A to STA-607 requires that personnel accountability logs te maintained during the activity.
Station Administration Procedure STA-731. "ASME Section XI Repair and' Replacement Activities," Revision 3. Step 2.3, states, in part, "On a piping system prior to ASME Ill b 5 Certif kation, the piping to component connection is under the jurisdiction of ASME Section 111 and cannot be-completed uncer this section.'
Procedure CPSES-P-2018, " Field Fabrication and Erection of Pipe Supports," Revision 0, Step 6.8.1.7 states, '.n part, " Lumber shall not be used except as shoring or wedges in sleeves." l Step 6.8.5.4, states, in part, " Engineering approval is required prior to a modification to existing temporary supports."
Contrary to the above, on February 23, 1992, Valve 2HV-4516 was removed from its installed position utilizing a rigging configuration which was'not in conformance with the work document.
The pipe openings were not sealed following valve removal and personnel accountability-logs were.not maintained. The temporary supports originally installed utilized lumber and were removed without engineering approval. Contracted motor operated valve quality control personnel were utilized to witness the disassembly of the valve flange fasteners as opposed to the reauired ASME quality control personnel and construction personnel performed activities outside the scope of their work document.
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Attachment 2 to TXX-92243 Page 2 of 5 l l
(B.2) Startup Work Authorization No. 52270 specified maintenance to be !
performed on Valve 2CS-704BA. ,
Contrary to the above, en March 17, 1992, construction personnel !
aisassembled and reassemoled a Unit I valve 1CS-7048A, ,vhen the i work document specified a Unit 2 valve. 2CS-7048A. j i
i RESPONSI TO NOTICE OF VIOLATION 50-445/9208-02) 50-446/9208-02)
TV Electric accepts the violation and the requested information follows:
(1 tem B.1.)
(1) Peason for Violation The personnel responsible for implementing the work documents issued to repair valve 2HV-4515 failed to properly adhere to the requirenents of the prescribed station administrative procedures. Additionally, lack of attention to detail and oversight regarding non-routine dual unit interface. requirements led to this violation.
v The specific causes, contributing factors and corrective actions are stated in section 2 below.
(2) Correctivo Stens Taken and Pesults achieved The event resulted from'a Unit 2 startup maintenance activity wnich physically removed valve 2HV-4515 from the Unit 2 Component Cooling Water:(CCW) system. This portion of the Unit 2 CCW system is within the Unit 1 CCW stress boundary. -The-events surrounding the removal of 2HV-4515 potentially impacted Unit 1 CCW system operability and cou'.d
'have prevented _ Unit 1 from satisfying technical specification requirements, therefore a deficiency document was generated to evaluate Unit 1 operability. The evaluation determined that the CCW System was ;
operable. Due to the seriousness of this event and the need to fully
- understand how it occurred. TV Electric management established a task team. The causes, contributing factors and corrective actions taken are as folinws:
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Attachment 2 to TXX-92243 l Page 3 of 5 Rigging Configuration Hot in Conformance With Work Documents (and)
Construction Work Performed Outside of Scope Initially, the Motor Operated Valve Contractor (MOVATS) was assigneo to ;
remove valve 2HV-4515 via work order. A Technical Evaluation was issuea with the work order to provide rigging instructions. After several attempts to remove the valve f ailed, anothEr work order was issued to cut associated piping to facilitate valve removal. At the time the second work order was initiated, a Brown & Root Superintendent was requested to perform the work. After evaluating the as-built cor.cition of the valve, the Superintendent believed the valve could be removed without cutting adjacent piping. The valve was subsecuently removed via rigging. However, at the time, this method was unauthorized. In addition, the method for rigging the valve was not in accordance with the Technical Evaluation instructions previously specifiea by Engineering.
The Task Team determined that the Superintendent removed the valve via rigging because he believed the work orders intent (remove the valve) was being met. Although the Task Team believed the rigging instructions
-were clear, the Superintencent stated that he misuncerstood the ,'
technical evaluation instructions. The individual has been counseled on the importance of following prescribed instructions, i
Hon-Scaled Pipe Openings and Personnel Accountability Log The evaluation team found that the work area had been posted Zone !!! in '
accordance with STA 607. However, both Construction and Contracted MOVATS personnel overlooked tne requirement to cover the opened pipe upon_ leaving the work area anc maintain the personnel accountability log. Personnel authori:'ed to perform work in the Operation's controlled area have received instruction on STA-607 requirements. An engineering evaluation has determined that the piping througnout the valve removal r process, was adequately and rigidly supported by the existing permanent supports.
Temporary Supports <
The chronology within the Task Team Evaluation indicated that the temporary supports had been removed from the pipe for a minimum of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. However, the evaluation could not determine who removed the supports.
The Supervisor responsible for the installation of the temporary supports was-aware of the applicaole site specification requirements and had been properly trained. T he responsible work group has been -
retrained.
__ _. __ _-_ ._ - _.a. _ . - -
Attachment 2 to TXX-9??43 Page 4 of 5 ASME Code Jurisdiction Hisapplication Althougn STA-731 provided tne necessary guidance for Code jurisdictional -
control of work, the personnel responsible for development / issuance of the work package did not implenent the requirements of STA-606 in inat they did not verify the jurisdictional status of the item as required by ,
STA-731. STA-606 recuires applicable work packages to be developed in accordance with STA-731, wnicn requires that installation and removal !
activities of items from systems wnich nave not been ti-5 certified be performed by the Construction Contractor. Therefore, work was erroneously assigned to MOVATS instead of Construction.
Coincident with this violation, a deficiency document was issued documenting two other instances in which valves were removed by MOVATS l from a_ system under construction jurisdiction. The work planning group personnel have been' reinstructed to assure proper preparation and screening of' work orders witn respect to the responsible work organizations and their respective Code areas. ,
(3) Corroctive Sten.i_Taken to Avoid Further Violaticns As detailed above, procedure ennancements, retraining and personnel counseling will prevent recurrence of this deficiency.
(4) Date When Full Comnliance Wil' 9e Achieved TV Electric is in_ full compliance.
( tem B.2.)
-(1)- Peason for Violation-The individuals involvea-in tnis activity failed to perform a positive t verification of the component-cn which they were to work. Thus, work was performed 'n the wrong component. ,
(2) Corrective Steps Taken and Oesults Achieved TU Electric : management _suspenced Unit 2 disassembly /reassemnly_ work activities'on permanent-plant ecaipment within the Unit 1 Operations Controlled _ Area to assess the event. Deficiency documents for both Units were issued. Applicable Construction. Startup and Quality Control '
personnel were briefed ano a' Task _ Team was established to_ determine root
-cause and provide Corrective /Creventive actions.
' Construction work in the operation controlled area was alloweo to-i proceed after a_two party ccrponent verification process was established.
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Attachment 2 to TXX-92243 Page 5 of 5 (3) Corrective Steps Taken to At eid rurtner Violations The following actions will preclude recurrence: ;
a) Construction and Startup work packages now contain sign-of f steps l for two party verification of correct components, b) Construction work rolling over to a new crew (e.g. day shift to night shift.) receives the same level of documented verification as described above.
c). Highly visible clearance tag verification sheets are required to be included in construction work packages requiring clearances.
d) For Prerecuisite Testing. Startup personnel ensure that the correct loop, panel, or component is verified by a two party verification process prior to commencement of testing.
e) CPSES organizations with physical field work activities will review and revise (as applicable) work control programs to ensure that proper verification requirements are included in work documents, f) Appropriate disciplinary actions have been taken for the individuals involved in these incidents.
g) Quality Assurance has conducted surveillances of the two party verification process utilized during Unit 2 completion. the Unit
-Interface Program, and the Unit 2 Labeling Program.
(4) Date When Full Comoliance Will Be Achieved TU Electric will be in full compliance by June 30, 1992.
Additional Information A separate event regarding maintenance disassembly work on valve 1-HV-2400-A0 (versus 1-HV-2400A-AO) was discussed during an NRC exit meeting on April 24, 1992. During this meeting, TV Electric committed to document our corrective actions. To accument the incident, an Operations Notification and Evaluation (ONE) form was generated and the work order revised to reinstall the tubing. To preclude recurrence, maintenance personnel were informed of the details of the' incident and provided instructions on the verification of work steps.
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