ML20128B021
| ML20128B021 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/01/1993 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-93077, NUDOCS 9302020376 | |
| Download: ML20128B021 (13) | |
Text
o 5
$$$3fjbid! Log # TXX-93077 rm File I! 10010 February 1, 1993 71/ ELECTRIC wun.m J. c.hm. Jr.
om., wma.
U. S. Nuclear Regulatory Commission Attn: Document Contro' ~ esk Washington, DC 20555
SUBJECT:
COMANCH: PEAK STEAM ELECTRIC STATION (CPSES) __
DOCKET NOS. 50-445 AND 50-446 CONCERN RESPONSES AS 10ENTIFIED BY THE FOLLOWlHG SUBJECTS:
a Unit 2 System Turnover Process b Unit 1 B15C0 Fire Seals for 16-18 inch Piping Penetration c) Unit 2 Containment Spray System Spray Hozzle Completion d) Unit 1 Plant Procedures implementation Gentlemen:
The noted concerns were received by TV Electric management for review and assessment. Concern (a) identified as RIV-93-A-0003, and (b) ider,tified as RIV-93-A-0004 were received in writing from the Nuclear Regulatory Commission (NRC). Concern (c) identified by title, and concern (d) identified by title, were verbally transmitted from Mr. L. Yandell of the NRC to TU Electric management. _
A synopsis of the text of each of the concerns are as follows: >
CDEfJ1R_A Unit 2 system turnovers from construction to operations were not conducted as required. For example, emergency lighting walkdown personnel were directed to hurry-up activities.
CONCERN B Unit 1 BISCO fire seals for 16-1B inch mechanical piping penetrations did not have adequate qualification tests to support the fire rating.
CONCERN C During the assembly process of the Unit 2 Containment Spray system, post flushing activities, pipe caps may have been dropped into and left inside piping / spray nozzles after test completions.
0200:7 l
fSPES$A 388884% b 400 N. Ouve Sutet LD. 81 Danas, Texas 75201
.; e j i
i i
. TXX-93077 I Page 2 of 2
-CONCERN O Due to reduction of plant personnel at Comanche Peak Steam Electric Station - j (CPSES), specific procedures implementing deficiency identification. '
technical review,_ performance monitoring / trending and reporting; may not be i effectively implemented which may lead to inadvertent oversite of open i items.
All concerns were investigated by a combination of site management, task teams and NRC inspectors. The review of the_ concerns and resulting investigations (per the attached documents), did not identify any new issues. In the case of Concern'A.-a task team had been formed to investigate emergency lighting open items identified via.ONE. Form 93-123 prior to the concern being issued. The supportive documentation and results -
of the investigations are available for inspection at Comnche Peak Steam Electric Station.
Responses have been prepared as. identified in Attachment 1 and Enclosures of this letter for each of the concerns.
Sincerely.
A g,-
William J. Cahill, Jr.
NSH/ds Attachment Enclosures c - Mr. J. L. Milhoan, Region IV-Resident Inspectors, CPSES (2)
Mr. T. A. Bergman, NRR Mr. B. E. Holian, NRR
Atta'chment 1-to TXX-93077 Page 1 of 1 I Response to Concern A is documented in TU Electric Memorandum dated January 27,1993;""ConcernRIV-93-1-0003"(Enclosure 1).
Response to Concern B is documented in TV Electric Memorandum entitled l
" Response to Pipe Penetration Fire Seal Concerns",-(Enclosure 2). It should i be noted that Mr. Mike = Murphy (NRC) inspected fire barrier material on '
January 30, 1993. He reported no concerns during his' inspection.
1 Response to Concern C is documented in TU Electric Memorandum CPSES-9301860, dated January 29, 1993; " Containment Spray System Spray Nozzle Completion" (Enclosure 3). 4 Response to Concern D is documented in TU Electric Memorandum dated .
January 27, 1993, entitled " Letter to William B. Jones" (Enclosure 4).- It should be noted that other actions are being taken in conjunction with . ,
Concern 7 (as indicated in the enclosure). Monitoring and assessment;of the-concern is being performed as follows:
a) An Engineering staff assistant has been tasked.with conducting, in conjunction with the engineering managers, a comprehensive Engineering-Back-log review, and then developing a realistic reduction goal, and j
plan to achieve that goal for 1993.
b) Another staff assistant has been tasked with conducting a.self appraisal to determine if those personnel responsible for parforming technical support functions, understand the scope of that responsibility, and are-properly trained to perform the-functions.-
c) . The-proposed t1993 Engineering Budget provides ' funds for..antractor support of-design nodifications so that permanent staff can better perform level-of-effort type work to support two unit operations.
.1 These actions were discussed with Mr. Larry Vande11; Mr. Pat Gwynn, Ms. Suzanne Black (NRC personnel) and Mr. Lance Terry, Vice-President of.
Nuclear Engineering and Support, Mr.'. Roger Walker, Manager of Regulatory.
Affairs for'NE0, of TU Electric.
+
i s
e a
L. --' _. _ _ _ *___.a.__m--______A_.--_.a._----
.--_aa- e-ha ___.r s' -- cir _.e
- - - w. --- . -+ es.,m_.,-e- em su.-yv c-a W* e
l t"!TUELECTRIC OFFICEMEMORANDUM l ,
l l January 27,1993 TO: C.L. Terry l SU13 JECT: Concern RIV-93-1-0003 l
Turnover acceptance of a systent by the Plant Manager meant that Plant ,
Operations took the responsibility of using the Nuclear Operations programs )
- and procedures to control activities affecting the system (reference Section '
4.1 of STA-802). The program for turnover of systems from l construction /startup to Operations was governed by STA-802. A key purpose of this procedure was to define a consistent method for conducting l the turnovers by defining the scope of the reviews and documentation ,
i required, as well as the responsibilldes of die various organizations involved. !
Section 1.0 of Ole precedure states that "This procedure is not intended to 1 verify construcuan, engineering, or quality assurance activities. Such l activities remain the responsibility of the appropriate organizations". i Although our goal was to complete all work prior to system turnover, it was fully expected that there would be open items on the systems after turnover acceptance.
Some significant issues have been identified, after system acceptance, however, in the emergency lighting system. These issues are being addressed by ONE Fonn 93-123. A Task Team was formed to address the root cause and generic implications of these issues. The Task Team has i issued a report on their findings and recommendations. The report
! identifies that, in fact, the hatteries for the emergency lighting were disconnected afin turnover of the system to operations, and therefore are not indicative of a weakness in the turnover process. It should also be noted that the Pre turnover walkdowns may not have identitled all the issues which have been identified subsequent to system acceptance (e.g., burned-out lamps), In general, however, the number and significance of open activities at the time of acceptance, and subsequent to acceptance, have been small. This is a good indication that the Unit 2 constructjon/startup programs were effective. All required surveillances are completed and a.
Preventative Maintenance program per STA-677, is in place to routinely check the operational readiness of the equipment prior to declaring the system operational.
The system turnover process occurred over a period of weeks (normally 6-8 weeks. Each of the systems was walked down, deficiencies identified, and then the issues were worked off until it was determined that Operations was ready to assume responsibility for the system.
4 RIV-93 1-0003 Page 2 of 2 Personnel involved in the turnover process followed these requirements with each system and were not pressured to bypass the process, mu.Lb CL Duerk J. Reimer Manager System Engineering DJR:blw Attachment
4 a
4 9
Page 1 of 2 RESPONSE TO PIPE PENETRATICN FIRE SEAL CONCERNS The results of a comprehensive NRC review of reports, inspection findings, and allegations of penetration seals were published in NRC Information Notice No. 88-04, dated February 5, 1988.
IN 88-04 identified a number of weaknesses in the implementation of - NRC requirements and guidelines - related to fire barrier penetration. seal design qualification. Typical examples included: incomplete, inadequate,. or non-existent fire test documentation; seal installations which did not , satisfy all qualification requirements of acceptable fire test documentationi installed seal configurations or design parameters which were significantly different from the fire test documentation; esals improperly installed or not installed where required and plant modifications performed .without - adequate, = associated ~
technical reviews.
Supplement 1 to IN 88-04 was issued August 9,1988, to emphasize problems caused by potential misapplication of silicon (low density) foam seal material at Diablo .
l Canyon and Davis-Hesse. IN 88-56 was issued August - 4, 1988, referenced - in ?
Supplement 1 to IN 88-04, and addresses installation non-conformances (voids, shrinkage, and lack of f111) of silicon foam seals.
Subsequent to receipt of IN 88-04, TU Electric confirmed that procedural controls existed to ensure technical reviews of all penetration seal installations, as-well as proper installation of.the seales a formal Quality Assurance audit (ATP-:
88-82, cires March,1988) was performed on the penetration seal progrant and an engineering evaluation was performed to document the vendor fire tests required to support the penetration seal configurations installed- at -- CPSES and the i technical adequacy of the documentation to satisfy current NRC guidance, regulations and industry standards. The technical evaluations are found in engineering report ER-ME-038 and the assessment of CPSES with respect to IN 88-04 :+
is faund in Industry Operating. Experience Report IEN 88-04.-
~
Engineering report ER-ME-038 evaluates the 8!SCO fire test : which is used to- '
support fire seals used for pipe penetrations through fire barriers. BISCO:
tested an 8 inch pipe penetration with 12-inches of foam and without damusing.
This test was the basis for an engineering evaluation in ER-ME-038 to extend -
I qualification to smal).er and larger pipe sizes. This is an accepted practice for l fire seal qualtfica*. ion. The evaluation concludes that the test =is acceptable ,
L for all sizes as u',ed At CPSES and gives the justification for the acceptance. l L
In SSER 21, the staf f discusses their review and concurrence of 3ISCO fire seals
, used for Unit 1,-the fire tests in particular, and determined ". ..thatt all of the
' BISCO seals being installed at CPSES have passed ftre tests . This inspection item is now considered closed, as stated in NRC Inspection Report 50-445/87-22."
CPSES brawing M1-1901, Typical Detail 10, does show damming boards on both' sides l.
of si.15, con foam material used . for pipe penetrations - through' fire barriers.-
l' However, penetration seal vendors fire qualification tests sometimes vary to some f degree from the typical details provided by CPSES.
L L
i l
r F
l '
Ma n- +- ., .- .- =-2..*<uom er e .-v -
r=-w' m w -,<-*w e e-,-- ,w-, 4 w- w y =- e -*
_. . _ _ _ . - . -.m____._ _ _ _ - . . _ . . . _ . _ - _ . _ . . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ . _ _ . .
Page 2 of 2 RESPONSE To PIPE PENETRATION FIRE SEAL CONCERN 5 The Bisco fire test actually used to qualify their seals for pipe penetrations i was performed without permanont damming material and is the same as the pipe penetration seals installed in CPSES Unit i for all sizes of pipe. Therefore, "
no permanent dansaing material is required, nor normally used for Bisco " pipe seals." Bisco installed the seals to their qualification details, using their QA program, and they did not install seals using the M1-1901 details. Their fire -
tests are the b e,1c qualification documents which support the seals installed in Unit 1. These installations were reviewed and accepted by ?" Electric.
Unit 2 uses pipe seals supplied and installed by Peak Seals. The Unit 2 pipe seals utilize silicon foam material _with a lesser depth than B!sco's, and, therefore, does require permanent dansning material installed on both sides of the foam material, for walls, and the bottom side of the seal only, for floors. Unit 2 seals are evaluated in Engineering Report ER-ME-70 for acceptability.
f Ag l ^ ,
- c. . Beckett Principal Engineer'-
l l
t I
r l
u l
l l
.____._______________________________________..____D
CPSES- 9301860 SU- 93061 January 29,1993 No Response Required TO: Scott liarrison - C07
SUBJECT:
Containment Spray System Spray Nozzle Compittlon 03 13-92 Flush plan 2FP 4804-01 hand cleaned spray rings at 1058', 1063' elevations.
04 17-92 Flush plan 2FP-4804-02 completed hydrolazing on spray rings at 1021' and 1039' elevations.
06-17 92 Flush plan 2FP 4B03 03 completed flushing of ring headers below 905' elevation.
07 22-92 Completed installation of 754 nozzles,10 caps, per current design. Completion performed by SWA's, with STE cleannen inspection requhrd at cach nortle or cap installation. During preparation of pipe nipples for nozzle installation a few cases were noted where blue plastic " clean
- caps were found inside the pipe nipple. The caps were all removed and verified during STE cleanness inspection.
08-19 92 Completed air flow test of all CT system spray nor21cs per preop 2CP PT-4801, Rev. O and current system isometries. All nozzles were found to be clean, with no blockage.
10 22 92 Completed removal and capping of one spray nor.tle which caused inadequate clearance between the nuule and an adjacent pipe support as documented by TUE 92 6495. SWA 87398 performed this work, the STE verified pipe nipple cleanness prior to cap installation as documented in the work package.
After performing a document search for any nozzle work no other documents were found.
1 R ^
l
~d ~&
James E. Snyder - S01 Manager, Unit 2 Startup cc: CCS E06 i
I
. !"l1UELECTRIC OFFICEhfEhf0RANDUhi January 27,1993 TO: C.L. Terry
SUBJECT:
1.ctter to William B. Jones The concernee identifled several topics of discussion, each of the following paragraphs restates the concem and provides the response / corrective action.
Concern 1: " organizational changes that will require that most station procedures to be revised to support the changes".
Response 1: There have been organizational changes that will need to be reflected in Station Procedures. In most cases it was determined that these minor discrepancies could be incorporated into the next revision of the subject procedure (s).
If the organizational change impacted the technical adequacy of the procedure a revision was processed, Concern 2: "The implementation of many station procedures at Comanche Peak remains an open item. Procedures such as STA-421, ONE Form, STA-504, Technical Evaluation, STA-512, Failure Analysis, STA-736 Equipment Performance Monitoring, STA-514. NPRDS Reporting, REl-502, Failure Trending".
Response 2: The referenced procedures are fully implemented, in addition:
- STA 421, " Operations Notification and Evaluation (ONE) Form" has been in efTect since 12/12/89. This procedure has been audited / reviewed by CPSES Nuclear Overview, INPO and the NRC on several occasions. The conclusions of these audits / reviews is that STA-421 is a very comprehensive and effective nrogram.
- STA 504, ' Technical Evaluation" has been in effect since 12/12/89 in this basic configuration. The purpose states:
"This procedure provides the means for requesting and documenting technical information, evaluation or assistance within an organization, from one organization to another, or from unit to unit". This procedure has been highly eiTective in providing engineering assistance to Nuclear Operations.
l Page 1 of 5
d i
- STA-512. " Failure Analysis" was revised 5/28/92 to establish the current program. It has been identifled by TU Electric Management (reference ISEG Report CPSES-9238412) that this procedure does not provide clear guidance for when a formal failure analysis is required.
This comment is currently under evaluation.
- STA-736. "Equii'nent Performance Monitoring Program' was revised 10/14/92. The program is comprised of a number of separate programs (vibration monitoring, lube oil analysis, etc.) in conjunction with monitoring selected operaung parameters. Informal monitoring triggered by experience with the equipment under various conditions has also been effective. TU Electric is considering a transition to monitoring on a system and plant level with data collection at the equipment level to support implementation of the Maintenance Rule. The need for equipment level performance monitoring of operating parameters would be based upon system and plant performance trends. The necessary resources are being dedicated to define and determine the most effective transition to a performance monitoring program to support implementation of the Maintenance Rule.
- STA-514. " Nuclear Plant Reliability Data System (NPRDS)
Program" has been in effect since 8/10/89. TU Electric has been routinely submitting NPRDS reports to INPO since that time. During a recent INPO assessment, a weakness was identified associated with the completeness and quality of the NPRDS reports submitted to INPO. TU Electric has taken steps to resolve these issues, see Response 4 for more details.
- REl-502, " Equipment History Trending" has been in effect since 9/4/89. Failure trending is being implemented through reports issued quarterly and annually. Compute 1 zed equipment failure data is extracted from computer data bases and organized to enable evaluation by plant personnel. Formal evaluation of annual report data by System and Component Engineers is on going.
Further enhancements to STA-512, STA-736, STA-514, and REl-502 has been deferred pending changes associated with implementation of the industry wide NRC mandated Meintenance Rule.
Page 2 of 5
Concern 3: "Ihe number of ONE Forms, Technical Evaluation ... should be a matter of grave concern for the safety of the plant. Some of the items have been open for a year or two with certain review called for by procedures not performed".
Response 3: The number of open ONE Fonns and TE's has been evaluated / addressed by TU Electric Management. A Management Report which includes these numbers is published weekly and distributed to the responsible managers.
This report is reviewed by the subject managers with the Vice President of Nuclear Operations often in attendance.
Specifically, the older ONE Forms were screened for any potendal impact on safety; to date no impact has been identified. Station Ooals and Objectives have been established (e.g., total open ONE Forms for 2 Unit Operation should be less the 450). See Response 5, for additional action taken. As of January 24,1993, there were 6G8 open ONE Forms and 1031 open Technical Evaluations.
Concern 4: "the bacidog of failures not reporte to NPRDS, the bacidog of failure analysis not performed since commercial operation should be a matter of grave concern for the safety of the plant.
Some of the items have been open for a year or two with certain review called for by procedures not performed".
Response 4: 'lhe bacidog of NPRDS failuic *eports is currently being addressed by the addition of five individuals, assigned speciflcally to prepare failure reports. NPRDS Program priorities have been established to improve and effectively address a recent INPO assessment of the NPRDS Program.
Priorities were established as follows:
- 1. Completeness of Reporting - TU Electric has modified the failure reporting process and has revised NPRDS equipment scoping to improve the ability to identify reportable failures.
- 2. Quality of Failure Reports - INPO concerns of quality have been addressed by requiring completed failure reports to be reviewed by experienced personnel prior to submittal to INPO.
- 3. Titr,liness - Significant effort is being made to reduce backlog, as previously noted, with a commitment to improve the level of identifying failures and place quality as a high priority.
The on going reduction of backlog coupled with complete and quality failure reporting, serve as essential prerequisites for achieving timeliness.
Page 3 of 5 )
Concern 5: "Probably a time limit is needed to close ONE Forms and Technical Evaluations".
Response 5: Station Procedure STA 422. " Processing of Operations Notillcation and Evaluation (ONE) Forms" was revised 10-23 92 and established the following:
"It is Management's expectation that all ONE Forms are to be dispositioned, corrective actions implemented, and the documentation completed, per this procedure, no greater than 90 days after initiation of the ONE Form.
Station Procedure STA-504. ' Technical Evaluation" was revised 08-24-92 to include the following:
- 1. Specifle Guidelines on how a TE shall n91 be used (e.g., to resolve a condition adverse to quality, to resolve a nonconforming condition, etc.)
- 2. Established a TE Review Committee to determine if the question / concern (Identifled on the TE) should be midressed by a TE. or some other means.
- 3. Provided methodology on how to administratively close TE's g: cater than one year old.
Concern G: "We have procedures to ensure that the Plant run safely. If we cannot follow the procedures we might as well do away with them" Response 6: Comanche Peak has very explicit directives / expectations with regard to procedure compliance. Procedures are to be adhered to or work is to be stopped and the procedure changed / revised. Failure to follow procedure is addressed by STA-422. " Processing of Operations Notification and Evaluation (ONE) Forms' step 6.1.1 states "Any individual discovering an actual or potential adverse condition, including human performance (HPES) concerns, should identify the condition in accordance with STA-421, which requires the condition to be documented on a ONE Fonn and the ONE Fcrm to be promptly delivered to the Shift Supervisor".
Concern 7: 'There are not enough System Engineers to support all the bacidog and nobody seems to care. The implementation of all the procedures suffers since the engineers do not have the time to perform all the required tasks".
Response 7: The System Engineering backlog did go up in the first three quarters of 1992 as a result of attrition (turnover). Unit 2 work load and increased responsibilities. There were 28 assigned System Engineers (utility) during this time frame, the Page 4 of 5
\.--..
4 organization was authorized for 30 Engineers. Le current approved permanent staff 1ng level for 2 Unit operation is 40 System Engineers. Engineering Management recognized the need to reduce the backlog and obtained authorizauon for contractor augmentadon, starting in the 4th quarter of 1992.
Currendy there are 29 uulity and 11 contractors assigned as System Engineers, in addtuon, there are 25 Engineers /
Technicians assigned to System Engineering to reduce the backlog and support the increased work load during Power -
Ascension Testing.
Concern 8: "Itc Plant is slowly going back to the management style of 1985, removed and lacking in real management technique. We do not want the plant to be prematurely shutdown or all die backlogs to increase until the implementation of all procedures become impossible."
Response 8: Comanche Peak Management has a reputation for being proactive and aggressive, this has not changed. It is still Senior Management expectations that ti e first line supervisors and managers be involved in the day-to-oay operaticn of Comanche Peak. Hence, to be aware / understand the issues and take appropriate action when required. There are a number of site reports and knowledgeable of thepublished important that keepe.g.,
issues (management backlog). aware Concern 9: "More engineers are probably needed to support operation of both units ... than TU Electric thinks".
Response 0: TU Electric did recognize that more engineers would be required in some areas as a result of 2 Unt'. operation. Interim action has been taken (i.e., contractor support) and long range plans are being developed.
Thank you for the opportunity to respond to these concerns.
h MG%
Duerk J. Reimer Manager. System Engineering bW 2 Matt W, Sunseri Manat;;r. Maintenance Engineering DJR:blw cc: J.W. Muffett Page 5 of 5 i
. _ - ..