ML20141C880
| ML20141C880 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/09/1984 |
| From: | Clements B TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Bangart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20141C868 | List: |
| References | |
| TXX-#4354, NUDOCS 8604070336 | |
| Download: ML20141C880 (7) | |
Text
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TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWEN e 400 MORTH OLIVE MTREET. L.R. 88
- DALLAN, TEXAM T3301 November 9, 1984 mm.
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TXX #4354 mu m
Docket No.:
50-445 L g@MOWMi L
Mr. Richard L. Bangart, Director Region IV Comanche Peak Task Force NOV-9M M j U.S. Nuclear Regulatory Commission
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Office of Inspection and Enforcement L-1 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
Dear Mr. Banga'rt:
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NO. 84-22 We have reviewed your letter dated October 11, 1984 on the inspection conducted by Mr. J. E. Cummins and Mr. H. S. Phillips of activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak, Units 1 and 2.
We are hereby responding to the Notice of Violation listed in Appendix A of that letter.
To aid in the understanding of our response, we have repeated the Notice of Violation followed by our response. We feel the enclosed information to be responsive to the Inspectors' findings.
If you have any questions, please
-advise.
Yours truly, W
BRC:kh c: NRC Region IV - (0 + 1 copy)
Director, Inspection and Enforcement (15 copies)
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. V.,S. Noonan 8604070336 860402 PDR ADOCK 05000445 G
PDR A DEVINION OF TEXAN t'TILITIEN ELEt'TNit' t't,ME'ANY a
APPENDIX A NOTICE OF VIOLATION Texas Utilities Generating Company Docket:
50-445/84-22 Comanche Peak Steam Electric Construction Permit: CPPR-126 Station, Unit 2 Based on the results of an NRC inspection conducted during the period of May 19, 1984 through July 21, 1984 and in accordance with the NRC Enforce-ment Policy (10 CFR Part 2, Appendix C), 49 FR 8583, dated March 8, 1984, the following violations were identified:
A.
Failure to Maintain a Positive Pressure on Electrical Penetrations 10 CFR Part 50, Appendix B, Criterion V requires that, " 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, procedures or drawings."
Alarm Procedure X-ALB-13B has been established in accordance with Criterion V and requires specific actions to be taken when the Unit I electrical penetration low nitrogen pressure alarm is received.
Contrary to the above, on June 19, 1984 the NRC inspector observed that Alarm 2.6 (which monitors Unit 1 electrical penetration nitrogen pressure) was in an alarm condition and determined that the actions required by Alarm Procedure X-ALB-13B had not been performed.
Response
Although Alarm 2.6 (X-ALB-13B) was in an alarm condition at the time of the deficiency, it should be noted that many annunciators were being tested at that time. This testing meant that many annuncistort were simultaneously rounding, causing unnecessary noise in the control room.
Therefore, some of the above annunciators were silenced and the annunciator for Alarm 2.6 (X-ALB-13B) was inadvertently silenced during this process.
The purpose of the positive nitrogen pressure on the seal is to prevent corrosion of the electrical assemblies due to moisture accumulation.
In accordance with the Bunker Ramo Corporation vendor manual (CP-0460-001), the electrical penetrations are not required to be maintained at a positive pressure unless the penetration assembly has a surface temperature below the dew point of the surrounding air or is otherwise subjected to moi 8ture.
Given the ambient air temperature at the time of the violation and the air temperatures in the buildings adjacent to the electrical penetration, the surrounding air temperature of the penetrations could not have been below the dew point. Also, due to the relative short time that the penetrations were not under a positive nitrogen pressure, any moisture accumulation could not have occurred.
)
Page 2 Corrective Action The annunciator in question was verified to be correct, and the Shift Supervisor immediately took -the appropriate actions to valve in a full nitrogen bottle and repressurize the penetrations on June 19, 1984.
In addition, he contacted the responsible Startup Engineer for the system and was advised that it was unlikely that any moisture accumulation had occurred.
' Preventive Action In accordance with. Procedure OWI-104, Revision 2, the operators are now required to check the electrical penetration nitrogen pressure once per shift.
In addition, the Operations Supervisor has reminded the Shift Supervisors of the need for control room personnel to be particularly aware of all plant alarm conditions during the startup testing phase.
This was an isolated incident and should not recur.
Date of Corrective Action Implementation Corrective action was taken on June 19, 1984.
B.
Failure to Notify the NRC as Required by 10 CFR 50.55(e) 10 CFR Part 50.55(e) requires that, "The construction holder of the permit shall notify the Commission of each deficiency found in design and construction, which, were it to have remained uncorrected, could have affected adversely the safety of operations of the nuclear power plant at any time throughout the expected lifetime of the plant, and which represents:
"A significant deficiency in construction of or significant damage to a structure, system or component which will require extensive evaluation, extensive redesign, or extensive repair to meet the criteria and bases stated in the safety analysis report or construction permit or to otherwise establish the adequacy of the structure, system or component to perform its intended safety function".
10 CFR Part 50.55(e)(2) requires that, "The holder of a construction permit shall within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notify the appropriate Nuclear Regulatory Commission Regional Office of each reportable deficiency."
Contrary to the above, between February and May of 1383, the licensee identified a common failure of three out of four of the Unit I safety-related inverters that necessitated a modification to the ferroresonant output transforr.er in each of the inverters, but the failures were not reported to the NRC until February of 1984.
Response
This issue addressess a deficiency reported in January of 1984 dealing with Westinghouse supplied GE ferroresonant transformers. The chronological course of events culminating in the issue of a potentially rep'ortable
Page 3 condition under the provisions of 10CFR50.55(e) is attached (see Attachment A).
A review of the events indicated that the condition was routinely identified in the testing program, properly evaluated to determine the actual cause 'and extent of the failure, and -identified and dispositioned at the proper level. Considering the requests involving unique plant applications and operating history, a comprehensive evaluation concluding that the product was defective was not evident until receipt of the in-house examination results from the manufacturer.
The particular issue identified in the inspection report was controlled in accordance with the CPSES program for identification and resolution of deficiencies observed in the construction and testing phase.
C.
Failure to Obtain Work Authorization to Break Brand Industrial Services,
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Inc. (BISCO) Seals and Reflect Actual "As-Built" Configuration on Drawing SG-873-108T-1 10 CFR Part 50, Appendix.B, Criterion V requires that, " 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, procedures or. drawings."
Texas Utilities Generating Company (TUGCO) Quality Assurance (QA) Plan, Section 5.0, Revision 2, dated May 21, 1981, requires that construction activities be performed in accordance with documented and prescribed instructions, procedures and/or drawings.
Contrary to the above, on July 14, 1984, the NRC inspector visually inspected and determined that fire rated penetration seals had initially been properly installed by BISCO, but had subsequently been removed by unknown construction personnel who did not process a penetration seal removal request (PSER) as required by Brova & Root, Inc. (B6R) Procedure CP-CPM-6.10, Revision 11, dated, February 16, 1981.
Specifically, Internal Work Release 0217RA and "As-Built" Drawing SC-873-103T-1 show authorized rework and actual configuration on the referenced drawing; however, Seal Trace 5003 had subsequently been broken and damaged when additional cable was run through this seal. No PSRR was processed and the "as-built" drawing showed the seal r.s completed.
Response
This item of nonccmpliance deals with control of a fire-rated penetration seal which had bcen broken and reworked without proper adherence to the construction control program.
Ccerective and Preventive Action Concerns relative to penetration seal installations have recently been observed by project quality assurance. A recent audit of the penetration seal supplier and a corrective action report, both issued in approximately the same time frame as the NRC review, have resulted in the following
Page 4 programmatic actions to assure positive control of penetration seal activities, a.
Construction reindoctrination of CPSES rules and policies. Althcugh initiated independently by the contractor, several points in the reindoctrination effort deal with specific issues involved in the penetration seal program.
b.
Penetration seal verification. Under the direction of the Unit 1 Task Force Manager, teams comprised of building management, quality control and supplier personnel have performed a walkdown of areas within the Unit 1 security boundary. The purpose of the effort was to identify for resolution recognized exceptiens, violated and damaged seals. The results of this survey have been entered into the master data base for trackirg and completion purposes.
c.
Additional programmatic controls involving construction activities for Unit 2.
The program of work packaging currently implemented for Unit 2 activities provides clearer definition, control and accountability for all construction.
These ef forts represent positive actions to resolve the conditions addressed in the inspection report and preclude further concurrences.
The. specific process documents reflecting these actions can be reviewed by examination of CAR-038 and TUGCO QA Audit TBIS-5.
We have confirmed the specific seal addressed in the tracking item (Seal Trace 5003) is included in this program (MDB Item 8930-607A).
Date of Corrective aad Preventive Action Implementation
/
The dates of Corrective and Freventive Action Implementation will F/
determined by the current construction schedule.
j/
D.
Failure to Document the "As-Built" Configuration
/
10 CFR Part 50, Appendix B, Criterion X requires that the insp,Etion program of activities affecting quality shall be established sad conducted in a manner to verify conformance with the documented instru<ilons, procedures and drawings.
TUGCO QA Plan, Section 10.9 requires that inspections ver fy conformance with the documented instructions, procedures and drawing / for accomplishing the activity.
/
/
Procedure QI-QAP 11.1-28, Revision 25, paragraph 3.3.}'.'1, dat<c June ll, 1984 delineates and requires that Class 1, 2 and 3 cdaponent si pports be installed and inspected to assure that base platch are installed within + 1/4".
Contrary to the above, on July 14, 1984, the NRC, inspector visually inspected and measured Seismic Mechanical Shock Supptassor SI-1-071-002-S32K which is a part of the safety injection system, Specifically, nine dinensions on the support plate were fcund to -be 1/2" to 1-5/16" out-of-tolerance, J
I e
Paga 5
Response
During the NRC inspection, the inspector identified nine dimensions on the base plate which were out of tolerance.
In fact, the only item causing the out-of-tolerance conditions was the center line location of the I-beae attachment to the base plate.
This item has been identified on NCR M-14,557N.
Review by engineering indicated that the intended safety function of the support configuration is not impaired. The JJM; has been dispositioned stating the support is acceptable without repair or rework.
It has been determined that the subject support was properly inspected to the Construction and QA procedures in effect at the time of installation.
The procedures in effect at the time did not require verification of finite structural dimensions which were already a part of the Engineering 79-14 As-Built Program. The support had been inspected and analyzed under this As-Built Program and had been determined to be acceptable as-built.
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ATTACHMENT A C
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7 DATE DOCUMENT DESCRIPTION 2-22-83 TDR-629 Startup report documenting transformer failure during pre-op test.
2-22-83 TDR-630 Startup report documenting transformer failure during pre-op test.
5-26-83 TDR-1217 Sta'rtup report documenting transformer failure during pre-op test.
6-29-83 SU-83,392 Startup request to engineering noting possible' trend in trans-former failure. Engineering requested to evaluate failure and provide corrrective action-to mitigate or reduce occurrence.
Note: TDRs are programmatically trended by startup and evaluated for "reportability" by engineering.
6-29-83 CPPA-31,655 Engineering requests the supplier (Westinghouse) to evaluate failures..
7-11-83 TBX-M-1047. ^
Westinghouse response for action to facilitate review. Westinghouse notes failure rates at other facilities indicates possible unique application at CPSES lending to failure.
7-15-83 CPPA-32,053 Action initiated including ship-
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ment of transformers to manufacturer for testing.
7-28-83 SU-83,552 Operating history of the transformers 8-1-83 CPPA-32,354 forwarded to supplier as requested.
1-16-84 TBX-M-1138 Supplier / manufacturer test report received by engineering. Report indicates cause of the failure is' attributed to insufficient securing of internal transformer parts.
1-16-84 DRR-037 Engineering issued notice to site QA of identification of potential condition adverse to quality.
1-16-84 SDAR-CP-84-04 Deficiency reported and issued.
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