ML20149L336
| ML20149L336 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/25/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20149L321 | List: |
| References | |
| 50-445-97-12, 50-446-97-12, NUDOCS 9707310278 | |
| Download: ML20149L336 (6) | |
See also: IR 05000445/1997012
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The inspectors reviewed Work Order 3-95-322110-01, dated March 1996, which
stated that the finger plate on Diaphragm Valve 2DD-0019 (Reactor Makeup Water
Pump 2-01 discharge valve) had been installed upside down causing the diaphragm
to tear. The inspectors determined that the licensee had not written a operations,
notification, and evaluation form for this adverse condition.
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," states, " 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."
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
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procedure includes examples of conditions that should be reported on a operations,
notification, and evaluation form. The above example is consistent with these
examples and, therefore, should have been documented on an operations,
notification, and evaluation form.
The failure to identify this condition adverse to quality in accordance with
Administrative Procedure STA-421 was considered to be the second example of a
violaticn of Criterion XVI (50-445;-446/9712-01).
The inspectors also discussed with the licensee the six operations, notification, and
evaluation forms and one work order that were initiated for incorrect finger plate
installations and the resultant torn diaphragms. The inspectors asked the licensee
what actions had been taken to ensure that other similar valves, both safety and
nonsafety, installed in the plant were not affected by improper installation of the
finger plates. The licensee stated that they had not completely reviewed the
generic implications associated with incorrect installation of the finger plates.
Based on this concern, the licensee initiated Operations, Notification, and Evaluation
Form 97-435, during the inspection on May 2,1997. The form reviewed the
generic implications of the finger plates and also attached a listing of approximately
500 diaphragm valves, in both safety-related and nonsafety-related systems, where
the potential existed for incorrect installation of the finger plates. The licensee
performed an operability review and determined that the valves were operable based
on the f act that there had not been a failure of a diaphragm valve for over a year
and that some of the valves had been opened and had not failed. The inspectors
considered the operability review to be justified pending the additional actions the
licensee intended to take to fully assess the situation.
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The licensee's f ailure to take adequate corrective action to review the generic
implications of the diaphragm failures wa.s the third example of a violation of
Criterion XVI (50-445:-446/9712-01).
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9707310278 970725
ADOCK 05000445
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On January 17,1996, the operators again noted that Valve 1~-HV-2135 was
in a mid-position following a Unit 1 trip. Again, an operations, notification,
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and evaluation form was not processed and less than adequate action was
taken to troubleshoot the valve failure. As a result, the inoperable condition
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of Valve 1-HV-2135 was not identified, and the unit was restarted. Had the
event of January 22,1996, not occurred, the inoperable condition of
Valve 1-HV-2135 would most likely not have been discovered for an
extended period of time.
The inspectors observed that Plant incident Report 96-055 reported, but did not
evaluate the consequences of the above events and several others that occurred
during the approximate 3-year period during which Valve 1-HV-2135 was
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intermittently inoperable. As a result, corrective actions were not taken addressing
the deficiencies that permitted this safety significant condition to go uncorrected for
an extended period of time.
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," states, " 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."
The licensee's f ailure, on numerous previous occasions, to properly assess the root
cause oi the f ailure of Feedwater Isolation Valve 1-HV-2135 to stroke closed within
design parameters resulted in this valve being inoperable for an extended period of
time. Because the timely closure of this valve is assumed within the safety analysis
of the plant to prevent overcooling of the reactor or to isolate a faulted steam
generator, the failure to earlier identify and correct this condition represented a
significant condition adverse to quality. Although Plant Incident Report 96-055
identified this significant condition adverse to quality, it failed to determine the
cause of the condition or to take corrective action to preclude repetition.
This issue was identified as the fourth example of a violation of 10 CFR Part 50,
Appendie. B, Criterion XVI (50-445;-446/9712-01).
b.3 Ellis and Watts Coolina Coil Fan Motors durina Tornado - NRC Inspection
Report 99901308/9601 documented a vendor audit of Ellis and Watts, Division of
Dynamics Corporation of America. This inspection report documented a concern
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regarding the cooling coil f an motors purchased by Comanche Peak, in that, the
fans had not undergone a proper commercial-grade dedication by the vendor.
Specifically, the dedication plans did not address verification of a critical
characteristic of the f an motors involving their capability to operate during tornado
conditions at a reduced pressure of 11.7 psia.
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The f ailure to identify a condition adverse to quality in response to receipi of the
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adverse vendor information is considered the fifth example of a violation of
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Criterion XVI (50-445;-446/9712-01).
b.5 Shelf Life of Diaphra,qms - The inspectors reviewed Operations, Notification, and
Evaluation Forms '37-409 and 97-420, dated April 25 and 29,1997, respectively,
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which concerned various actuator diaphragms stored in the warehouse that had
developed cracks. The majority of the diaphragms had been purchased from Fisher
Controls and Copes Vulcan.' The inspectors also reviewed Procedure ECE 6.08,
" Determination of Shelf Life," Revision 0, which identified that nitrile elastomer
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diaphragms had a shelf life of 14 years based on an Electric Power Research
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institute guideline. However, the inspectors noted that the manufacturer had
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recommended a shelf life of 2 years for the diaphragms, which could be extended to
6 years if certain conditions were met. The licensee was currently reviewing the
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issue to determine whether a revision to the shelf hfe of the diaphragms was
needed. This issue was identified as an inspection followup item
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(50-445;-446/9712-03).
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c.
Conclusions
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Generally, the licensee's performance in the dispositioning of operations,
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notification, and evaluation forms was good. In particular, the treatment of generic
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concerns was comprehensive. Some exceptions were noted, including a violation
for failure to take adequate corrective actions and for failing to initiate a necessary
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operations, notification, and evaluation form.
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E2.4 Maintenance Alterations
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Inspection Scope (40500)
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The inspectors selected a sample of maintenance alterations that were assigned to
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engineering for resolution, as listed in the attachment to this inspection (eport. The
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inspectors reviewed the maintenance alterations and arranged meetings with
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licensee personnel to discuss questions that arose during the reviews.
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Observations and Findinos
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The inspectors reviewed Procedure ECE 5.01-07, " Maintenance Afteration
Evaluations," Revision 2, which provided the method and criteria for determining if
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the change was a maintenance alteration or a modification to the plant. According
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to the licensee, the maintenance alteration process met at least the minimum
requirements of 10 CFR Part 50, Appendix B, Criterion lit, " Design Control."
However, the level of detail from an administrative and budgetary perspective was
less than that used in the design modification process.
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10 CFR 50.59(b)(1) states that, " . . the licensee shall maintain records of changes
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in the f acility . . . to th'; extent that these changes constitute changes in the facility
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as described in the safety analysis report . . . These records must include a written
safety evaluation which provides the basis for the determination that the change
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. . does not involve an unreviewed safety question."
The failure to perform and document a safety evaluation for the four design change
noticus was identified as a violation (50-445;-446/9712-04).
During the inspection and at the exit meeting, the licensee disagreed with the
proposed violation because this practice had been accepted in previous NRC
inspections. With regard to this discussion, the licensee indicated the following:
(1)
There had been previous NRC inspections of the licensee's 10 CFR 50.59
procedures and guidelines, and that all of these inspections had come to
positive conclusions with respect to the licensee's implementation of
(2)
Inspection Report 50-445;-446/93-32, Section 2.2.2, describing the review
of Temporary Modification 92-1-05, constituted a review and acceptance of
the licensee's definition of a " trivial change."
With regard to example (1), the inspectors noted that NRC acceptance of a position
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is not conferred by the lack of reference to an issue within a report. As such,
licensees should not conclude that every undocumented element of a reviewed
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program has been accepted by the NRC.
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With regard to example (2), the inspectors noted that the discussion in
Section 2.2.2 of the inspection report did not review and approve the licensee's
design change program with respect to " trivial changes". The inspection
documented that a safety evaluation had not been performed for a temporary
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modification to the reactor vessellevelinstrumentation, which involved a clear
change to the facility as described in the licensing basis documents. The inspectors
noted that the change should have been implemented as a " trivial" type change
because the change had no potential safety impact. The inspectors were concerned
about the need to carefully follow administrative procedures to ensure that changes
to the facility were properly evaluated. The inspectors also were concerned that the
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change had been accomplished as a temporary modification vice a permanent
change to the facility; however, they concluded that this error was isolated ano of
minor safety significance. Nevertheless, these views and concerns cannot be
reasonably construed to be NRC approval of the licensee's program for use of
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" trivial changes". The example represented an isolated instance, which was not
reviewed by the Office, of Nuclear Reactor Regulation. Therefore, the inspectors
concluded that this current violation is appropriate.
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supervisor told the inspectors that blue, plastic tie wraps should be used in radiation
areas (and had, in f act, tested blue tie wraps for tensile strength in response to this
issue). Personnel in the tool room stated that blue, plastic tie wraps were issued for
installing shielding in the radiation controlled area. Finally, the acting radMtion
protection manager stated that the only distinction between blue and white tie
wraps were for foreign material exclusion control in containment where only blue tie
wraps were to be used.
Procedure RPI-608, " Quality-Related Control of Temporary Shielding," Revision 5,
dated May 26,1994, allowed for the installation of lead shielding on both safety
and nonsafety-related systems. Attachment 2 to Procedure RPl-608, " Shielding
installation Guidelines," stated that plastic tie wraps were acceptable as securing
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devices. However, the attachment failed to specify the type or size of the tie-wraps
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to use and failed to provide guidelines on how to correctly secure the temporary
shielding, such as the maximum spacing between the attachments. The inspectors
concluded that Procedure RPI-608 was inadequate to control the installation of
temporary shielding and ensure that the temporary shielding did not adversely affect
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safety-related components.
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10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"
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requires, in part, that activities affecting quality shall be prescribed by documented
procedures and instructions appropriate to the circumstances.
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The failure of Procedure RPl-608 to provide adequate installation instructions for the
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installation of temporary shielding was identified as a violation of 10 CFR 50,
Appendix B, Criterion V (50-445:-446/9712-05).
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V. Manaaement Meetinas
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Exit Meeting Summary
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The inspectors presented the inspection results to members of licensee ma1agement
at the conclusion of the inspection on May 2,1997. The licensee acknowl3dged
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the findings presented. The licensee oisagreed with two of the proposed vialations
involving the failure (1) to provide informatior, regarding previous failures of a valve
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discussed in Licensee Event Report 96-02 and (2) to perform a safety evAation
for several plant changes which the licensee classified as " trivial changes". As
discussed in Sections 03.1 end E2.4 of the inspection report, we have concluded
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that (1) the information omitted from the Licensee Event Report was clearly within
the scope of the intent of the existing regulations, and (2) our previous inspections
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did not approve the licensee's method of implementing " trivial changes".
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The inspectors asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was
identified.
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Supplemental Information
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INSPECTION PROCEDURES USED
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iP 40500
Effectiveness of Licensee Controls in Identifying, Resolving, and
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Preventing Problems
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Followup - Engineering
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ITEMS OPENED, CLOSED, AND DISCUSSED
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Opened
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50-445;-446/9712-01
Failure to identify and Correct Conditions Adverse to
Quality
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50-445/9712-02
Inadequate Licensee Event Report
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50-445; 446/9712-03
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Diaphragm Shelf Life
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50-445;446/9712-04
Inadequate 10 CFR 50.59 Evaluation
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50-445;-446/9712-05
Inadequate Temporary Shielding Installation Procedure
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Closed
50-445;-446/9310-07
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Run Efficiency for Motor-Operated Valve Opening
Analysis
50-445;-446/9505-01
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Thermo-lag issues-
50-445;-446/9601-02
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Unit 2 Refueling Water Storage Tank Degradation
50-445:-446/9710-02
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Inadequate Temporary Shielding
LIST OF DOCUMENTS REVIEWED
PROCEDURES
STA-421
Operations Notification and Evaluation (ONE) Form, Revision 5
STA-422
Procassing of Operations Notification and Evaluation (ONE) Forms,
Revision 12
STA-504
Technical Evaluation, Revision 11
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