ML20247E043
| ML20247E043 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/19/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89477, NUDOCS 8907260061 | |
| Download: ML20247E043 (4) | |
Text
4 r
h M
Log # TXX-89477
~
C F1ic # 10130 C
C IR 89-35 Ref # IOC R2 201 E,$,[,7,$j,'/,
July 19, 1989 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE T0 NPC INSPECTION REPORT N05.
50-445/8935: 50-446/8935 Gentlemen:
TUElectrichasreviewedtheNRC'sletterdated! June 19, 1989, concerning the inspection conducted by Mr. H. S. Phillips durit the period May 3 through
. lune 6, 1989. This inspection covered activitics authorized by NP.C Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2.
Attached to the June 19, 1989, letter was a Notice of Violation.
TU Electric hereby responds to the Notice of hiolation in the attachment to this letter.
l l! Sincerely, William J. Cahill, Jr.
CBC/mgt Attachment c - Mr. R. D. Martin. Region IV Resident Inspectors, CPSES (3) 1 8907260061 890719 DR ADOCK 050004 5 1y
d l
Attachment to TXX-89477 July 19, 1989 Page 1 of 3 NOTICE OF VIOLATION (445/8935-V-01)
Criterion III of Appendix B to 10CFR Part 50 and Section 3.0 of TV Electric OA Hanual require that design changes, including field design changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design.
Contrary to the nbove, in 1987, TU Electric Maintenance substituted carbon steel Grade 5 l+1ts for silicon bronze bolts in the Auxiliary Feedwater Pump Hotor without documenting, reviewing, and approving the change to the design.
RESPONSE TO NOTICE OF VIOLATION (445/8935-V-01)
TU Electric agrees with the Violation and the requested information follows:
1.
Reason for Violation During a maintenance activity to correct the reversed unidirectional fans on the Auxiliary Feedwater Pump Motors, the Maintenance Engineer permitted Grade 5 carbon steel bolts to be substituted for Westinghouse supplied silicon bronze bolts. The bolt substitution had been suggested by a Westinghouse field service representative who was witnessing the activity.
The Maintenance Engineer documented the substitution with a Maintenance Engineering Evaluation (MEE) that was subsequently approved by the Maintenance Engineering Supervisor. The Maintenance Engineer and the Maintenance Engineering Supervisor did not fully carry out Operations procedures for the control nf item substitution of material, parts and components.
As a result, bolts of material other than that specified were used to secure the Auxiliary Feedwater (AFW) pump motor fans to the rotors.
There is no evidence that either the engineer, or his supervisor, was trained on these applicable design control procedures prior to implementing the bolt substitution.
2.
Corrective Steps Taken and R sults A_c_hieved.
f Subsequent to this event, a Deficiency Report (DR) was written to document the failure to follow procedures.
l
e Attachment to TXX-89477 July 19,'1989 Page 2 of 3 The Westinghouse. Design Group was queried as to the acceptability of this substitution. Westinghouse replied that silicon bronze is the specified material for securing the' fans to the' rotor and that their application is safety-related, but the use of Grade 5 carbon steel bolts is considered
. acceptable as long as the bolts are. replaced prior to fuel load.
Westinghouse further stated that there is no history of problems with-silicon bronze bolts and knew of no reason for their. field service representative's recommendation to replace them with Grade 5 carbon steel.
In addition. Westinghouse recommended that any future ' substitution of parts only be made if. approved through proper engineering channels and not as the, recommendation of a-field service representative.
As a result of. statements from Westinghouse, the Grade 5 carbon steel bolts in the AFW motors are being replaced with silicon bronze bolts consistunt with the project schedule to support fuel load.
Pending this replacement, an evaluation is being performed of the installed carbon
. steel bolts for conformance to quality requirements.
Both the replacement process and the evaluation are being controlled by Nonconformance Reports (NCR's), The report TXX-89286, dated May 22, 1989, notified the NRC that Significant Deficiency Analysis Report CP-89-010 would address the safety significance of the carbon steel bolts.
To preclude the possibility that other improper substitutions were made by Maintenance personnel and documented wftn NEE's, the following actions have been taken:
0 In excess of 600 HEE's written by Maintenance personnel have been screened to identify any other instances of improper substitution.
Forty-five (45) potentially suspect MEE's were identified and are being evaluated by Design Engineering.
O Upon completion of the Design Engineering evaiuation, any parts substitutions made that constitute a change to design will be.
documented and controlled by Nonconformance Reports (NCR's) and the appropriate corrective action taken.
3.
Corrective Steos Which Will be leken to Avoid Further Violations Operations procedures formerly in place for control of substitutions have been retired and programmatic changes now require written design engineering approval (currently a Design Change Authorization (DCA)) prior to. substitution of parts.
The procedure governing Maintenance Engineering Evaluations has been retired.
1 4
Attachment to TXX-89477 July 19 1989 Page 3 of 3 As part of the response to NRC Notice of Violation 445/8924-V-01, Nuclear Operations is implementing a training program to promote procedural compliance and sensitivity to documentation of deficient conditions.
This program was described to the NRC in TV Electric letter TXX-89430, dated j
June 26, 1989.
4.
Date of Full Comnliance:
Full compliance will be achieved after replacement of the carbon steel bolts with silicon bronze bolts, completion of the Design Engineering review of suspect MEE's, initiation of any resulting NCR's, and completion of the training specified in TXX-89430. These actions are scheduled for completion by October 1, 1989.
L
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - -.. - - - - _ _ _ _ _ _ _ _