ML20148K276
| ML20148K276 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/11/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20148K264 | List: |
| References | |
| 50-445-97-12, 50-446-97-12, NUDOCS 9706170412 | |
| Download: ML20148K276 (4) | |
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ENCLOSURE 1 NOTICE OF VIOLATION l
i TU Electric Docket Nos.:
50-445
'50-446 f ~
Comanche Peak Steam Electric Station License Nos.:
NPF-87 j
NPF-89 i
During an NRC inspection conducted on April 21 through May 2,1997, four violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
9 A.
10 CFR 50.73(b)(5) states, "The Licensee Event Report shall contain reference to any previous similar events at the same plant that are known to the licensee."
Contrary to the above, Licensee Event Report 445/96-002-00, which described a slow closure event involving Feedwater isolation Valve 1-HV-2135, failed to include a description of numerous previous occasions where the same valve failed to stroke closed within the timeframe specified by the Technical Specifications.
This is a Severity Level IV violation (Supplement 1)(50-445/9712-02).
B.
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states that
" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."
Procedure STA-421, " Operations, Notification and Evaluation (ONE) Form,"
Revision 5, provides a mechanism for plant personnel to report conditions which potentially threaten the safe operation of the plant. Attachment 8.A of this procedure includes the following examples of conditions that should be reported on a operations, notification, and evaluation form:
Equipment malfunction, damage, or degradation, other than anticipated wear or situations remediated by routine maintenance.
Information from external sources (e.g., vendors, INPO, NRC) that indicates a potential adverse condition at Comanche Peak Station Electric Company.
t 9706170412 970611 i
l PDR ADOCK 05000445 G
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if 2-Contrary to the above, the licensee failed to provide measures to ensure that a condition adverse to quality was promptly identified and corrected and, in the fourth example, to determine the cause and take corrective actions for a significant condition adverse to quality.
1.
On May 14,1996, the Unit 2 safety injection system Train A Relief Valve 2-8853A was found leaking and was subsequently replaced; however, an operation, notification, and evaluation form was not initiated to evaluate the occurrence.
2.
In March 1996, the diaphragm for the reactor Makeup Water Pump Discharge Valve 2DD-0019 failed and was replaced under Work Request 3-95 322110-01; however, an operation, notification, and evaluation form was not initiated to evaluate the occurrence.
3.
Between July 6,1994, and May 6,1996, the licensee identified seven instances where diaphragm valves had failed or were in danger of failing because an internal fingerplate was installed upside down. However, the licensee did not take action to identify the location of each potentially improperly installed diaphragm valve and either inspect the valves or evaluate the adequacy of the installed configuration.
4.
Within Plant incident Report 96-055, the licensee identified numerous previous licensee failures to properly assess a slow closure condition of Feedwater Isolation Valve 1-HV-2315. This significant condition adverse to quality was identified by the licensee and reported within Plant incident Report 96 055; however, the licensee failed to determine the cause of this condition and failed to take corrective actions to preclude repetition.
5.
In March 1997, information was received from a motor-operated valves analysis and test system by Technical Notice MUTN 96-02 that previously provided error information related to the 3500 diagnostic system strain modules was nonconservative; however, an operation, notification, and evaluation form was not initiated to evaluate the occurrence.
This is a Severity Level IV violation (Supplement I) (50-445;-446/9712-03).
C.
10 CFR 50.59(a)(1) states, "... the holder of a license authorizing operation of a production utilization facility may (i) make changes in the facility as described in the safety analysis report... unless the proposed change... involves... an unreviewed safety question."
10 CFR 50.59(b)(1) states, "... the licensee shall maintain records of changes in l
the f acility... to the extent that these changes constitute changes in the f acility as described in the safety analysis report... These records must include a written l
l Iv l safety evaluation which provides the basis for the determination that the change... does not involve an unreviewed safety question."
l Contrary to the above, the licensee implemented the following design change notices, each of which involved a change to the drawings contained in the safety analysis report, without performing a written evaluation providing the basis for concluding that the change did not involve an unreviewed safety question.
DCN 10490, which changed the position of three valves in the post-accident sampling system.
DCN 10445, which removed the internals from several check valves in the instrument air system.
DCN 9013, which generically replaced ball volves with globe valves.
DCN 10174, which removed two valves from the feedwater system.
This is a Severity Level IV violation (Supplement I) (50-445;-446/9712-05).
D.
10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"
requires, in part, that activities affecting quality shall be prescribed by documented procedures and instructions appropriate to the circumstances.
Contrary to the above, Procedure RPI-608, " Quality-Related Control of Temporary Shielding," Revision 5, provided for installation nf lead shielding on safety and nonsafety-related piping systems, but f ailed e.- > vide appropriate instructions regarding the materials to be used as attacanient devices or the methods to secure the temporary shielding, such that, it did not adversely affect safety-related systems, structures, and components.
This is a Severity Level IV violation (Supplement 1)(50-445;-446/9712-06).
Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
1 Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the l
corrective steps that will be taken to avoid further violations, and (4) the date when full l
compliance will be achieved. Your response may reference or include previous docketed j
correspondence, if the correspondence adequately addresses the requred response. If an l
adequate reply is not received within the time specified in this Notice, an order or a
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i Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.
Where good cause is shown, consideration will be given to extending the response time.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.
Dated at Arlington, Texas, this 11th day of June 1997 1
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