ML20128B604
| ML20128B604 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/29/1993 |
| From: | William Cahill, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-93039, NUDOCS 9302030110 | |
| Download: ML20128B604 (5) | |
Text
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d Log
File # 10130 1R 92-47 7UELECTRIC Ref.
- 10CFR2.201 January 29, 1993
)
William J. Cahill, Jr.
Grour nce ?renidru U. S. Nuclear Regulatory Commissior, 4
Attn: Document Control Desk Washington, DC 2055!i
SUBJECT:
COMANCHEPLAKSTEAMELECTRICSTATION(CPSES)
DOCKET N05. 50-445 AND 50-446 NRC INSPECTION REPORT NO. 50-445/9247; 50-446-9247 RESPONSE TO NOTICE OF VIOLATION Gentlemen:
TU Electric has reviewed the NRC's letter dated December 31, 1992, concerning the inspection period rsf October 11 through November 25, 1992.
This inspection covered activities authorized by the NRC operating license NPF-87 and construction permit Chl-127.
The December 31 letter included two Notices of Violation for which a response was requested.
The requested response is provided in tre enclosed attachment.
Sincerely, W
vh Jh-William J. Cahill, Jr.
By:
Roger D. Walker Manager of Regulatory Affairs for NE0 JET /tg Attachment c - Mr. J. L, Hilhoan, Region IV Hr. B. E. Holian, NRR Hr. T. A.-Bergman, NRR Resident Inspectors, CPSES (2)
MOO 53 9302030110 930129 jDR ADDCK 0500o445 PDR
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k Attachment to TXX-93039 Page 1 of 4 e
M01ELDf_XIDLM103 (445/9247-01)
Comanche Peak Steam Electric Station Technical Specification 6.8.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, paragraph 9a, recommended that maintenance that can affect the performance of safety-related equipment should be planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Maintenance Department Administration Procedure MDA-308, Revision 6. " Crane and Electric Hoist Operator Certification Program," requires the use of guide ropes to control freely swinging loads when manual guidance is required for protection of equipment. -The procedure also requires care 4
during lifting to ensure the load does not contact any obstructions or that there is no sudden acceleration or deceleration of the load.
Contrary to the above, on November 4, 1992, the inspectors observed contract personnel operating the polar crane in the vicinity of the reactor vessel head contrary to the procedural requirements as follows:
(1) The guide' ropes were not long enough to control swinging loads around the reactor vessel head.
(2) While lowering the stud removal lifting rig, it became entangled with electrical cabling for a stud detentioning hoist.
(3) While the reactor vessel stud lifting rig assembly was being maneuvered into place over the reactor vessel studs, it was allowed to freely swing and lightly impacted the upper vessel head structure.
(4) As the lifting rig was being repositioned, the rig snagged an I-bean extending from the refueling cavity liner. The crane operator continued to raise the load and it became detachto.
The lifting rig swung about in an uncontrolled manner and contacted the reactor vessel head
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Attachment to TXX-93039 Page 2 of 4 BESPONSE TO 445/9247-01 TV Electric accepts the violation.
1.
Reason for the Violation The reason for the violation was an error on the part of contractor personnel for failing to implement the requirements established in plant procedures to control heavy lifts. The intent of the rigging procedure was not adequately effected by contractor personnel in that tag lines were of insufficient length to provide adequate control.
In addition.
communication during the rigging process was not properly implemented for the circumstances of the lift.
2.
Corrective Stens Taken and Results Achieved immediately following notification of the event described in the inspection report, the lifting operations in question were temporarily suspended. Longer tag lines were installed to assure more positive control of the stud removal device. Headphones were employed to provide for more effective communication. An additional spotter was located at elevation 860' of the reactor building, an intermediate point in the lifting evolution, to improve the ability to monitor this rigging operation.
An Operations Notification and Evaluation (ONE) form was generated to document the occurrence and facilitate corrective actions.
TheIndependentSafetyEngineeringGroup(ISEG)interviewedinvolved personnel in an effort to provide an-understanding of the incident. The results of this surveillance are documented in an ISEG field note.
3.
C.orrective Steps Taken to Avoid Recurrence Contractor personnel involved in stod replacement activities were reinstructed in " Heavy lifting" activities to emphasize the requirements of governing plant procedures. This training will be provided to contractor personnel in the future prior to commencing similar activities.
4.
Date When Full CompliADce will be Achieved TU Electric is in full compliance-F M
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. Attachment to UX-93039 Page 3 of 4 HQIICLOLY10LM108 (445/9247-02)
Comanche Peak Steam Electric Station Technical Specification 6.8.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33 Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, paragraph 9a, recommended that maintenance which can affect the performance of safety-related equipment should be planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
(1) Station Administration Manual Procedure STA-612, Revision 2. " System Cleanliness Control and Cleaning," Section 6.7.2, requires austenitic stainless.and/or nickel alloy steels be wire brushed with stainless steel brushes.
Contrary to the above, on November 2 and 4, 1992, maintenance technicians were observed using carbon stcel wire brushes on stainless steel body-to-bonnet studs for Containment Spray Valves CT-0026 and CT-0028.
(2) Maintenance Department Administration Procedures MDA-405, Revision 3,
" Control of Tools in the Radiological Controlled Area"; and HDA-401
- i Revision 1, " Control of Tools," requires tools used on stainless steel to be kept segregated from tools used on carbon steel.
Contrary to the above, on November 4, 1992, the inspectors found unsegregated tools in the Unit 2 radiological controlled area tool room.
On November 9, 1992, stainless and carbon steel _ tools in the Unit 1 containment tool room were found stored.in the same bins.
E!PONSE TO 445/9247-02 TV Electric accepts the violation.
1.
Reason for the Violation-The reason for_ the violation was failure on the-part of plant personnel to properly implement the requirements for tool storage and usage that were established in plant procedures and specifications. Although the procedures were adequate-in the defin_ition of proper too1Dusage, personnel responsible for designation of tools for use on stainless steel were not specifically trained to this procedure.
Attachment to TXX-93039-Page 4 of 4 2.
Corrective Steos Taken and Results Achieved AnOperationsNotificationandEvaluation(ONE)heimpactofcarbon-form was gene address both the corrective actions as well as t steel brush use on stainless components. All carbon steel brushes marked for use on stainless steel were removed from storage areas throughout the plant. The design engineering department-evaluated the usage to date and determined the effects to be inconsequential.
3.
Corrective $teos Taken to Avoid Recurrence Supervisors within the mechanical maintenance department were trained-to the requirements governing tool use on stainless components. A
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memorandum was generated to provide notification of the proper:
requirements to other plant departments, which utilize brushes in th'eir work activities.
4.
Date When Full Compliance will be Achieved TV Electric is in full compilance.
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