ML20248C271

Requests Reclassification of Violations Noted in Insp Rept 50-445/88-47 & 50-446/88-42 on 880707-0802.Informs Case Believes Further Insp & Enforcement Review Appropriate

ML20248C271
Person / Time
Site:	Comanche Peak
Issue date:	09/23/1989
From:	Garde B Citizens Association for Sound Energy, ROBINSON, ROBINSON, PETERSON, BERK, RUDOLPH, CROSS
To:	Charemagne Grimes, Lieberman J, Taylor J NRC, NRC OFFICE OF ENFORCEMENT (OE), Office of Nuclear Reactor Regulation
References
EA-88-310, NUDOCS 8910030410
Download: ML20248C271 (8)

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Robinson, Robinson, Peterson, Berk, -

Rudolph, Cross & Garde Mary Lou Robinson Attorneys at Law Nila Jean Robinson . los East College Avenue

! John C. Peterson Appleton. Wisconsin 54911

~ Avrain D. . Berk (414)781-1817 Michael Rudolph Green Bay 494-9000

. Dan Cross Fax 7804841 -

Billie Pirner Garde September 23, 1989

' James M. Taylor, Acting Executive Director b.S. Nuclear Regulatory Commission Washington, D. C. 20555 Christopher 1. Grimes, Director Comanche Peak Project Division Office of Nuclear Reactor Regulation U.S. Nuclear. Regulatory Commission Washington, D.C.- 20555 l

l- James Lieberman, Director Office of Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Service Water System Enforcement. Action (EA 88-310)

Docket No. 50-445; Permit No. CPPR-126' Gentlemen:

i On January 9,1989, the Nuclear Regulatory Commission ("NRC") issued Inspection Report No. 50-445/88-47; 50-446/83-42 to Texas Utilities Electric Company ("TU Electric"). This inspection report referred to an inspection conducted on July 7 through August 2, 1988.at the Comanche: Peak Steam Electric Station, Gler Rose, Texas, of the station service water system (SSWS) coating removal. The inspection reportediviolations of various NRC-requirements identified during the inspection. 'It elso summarized TU Electric's review and evaluation of the coating removal activities'irom a  ;

l September 13, 1988 meeting, a September- 23, 1988 engineering report on the l SSWS coating removal project, and referenced additional information provided  ;;

in an enforcement conference held with.TU Electric officials and: members of the'NRC Staff on November 9, 1988..

Finally,nthe. Notice of Violation ("NOV.") reported that.after review of j the information presented in the engineering report, the public meeting, and i the enforcement conference, the NRC staff had been persuaded that the )

violations-'did not present' a significant regulatory concern and the i violations were downgraded from Severity Level'111 to Severity -Level IV. <

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l Shortly af ter issuance of the NOV, CASE informed the NRC that it took strong exception to the decision of the staff to downgrade the violations from Severity Level III to Level IV. As we indicated to you at that time, it was CASE's view that TU had not presented information at either the public meeting, the enforcement conference, or in the engineering report that justified the downgrade. It was our concern then, as it is now, that the downgrade decision was made at a management level without regard to a number of significant f actual details that were excluded from the final inspection report aji issued, but not excluded from the base of knowledge available to the NRC site inspection staff at the time their observations were recorded and recommendations made. In addition, as we informed you and TU, the findings from our independent review of all the information which provided the basis of the engineering report led CASE to the conclusion that TU had substantial forewarning by both Stone & Webster and the NRC Inspector that the activity could result in damage to the pipe if not properly implemented.

More importantly, it was CASE's concern that the NRC's downgrade decision represented a serious NRC management miscalculation of the appropriateness of regulatory laxness toward TU Electric. Again, it was our concern that the enforcement decision was' removed from the NRC site inspection staff at a time when their recommendations should have been heeded and deferred to. CASE believes that subsequent events at CPSES have demonstrated that our concerns were valid, and that the enforcement decision needs to be revisited on the basis of information not considered by the enforcement staff;[l/.

For the reasons discussed below, CASE believes it is appropriate for the NRC to conduct further inspection and enforcement review on this matter, and to consider the issuance of escalated enforcement action and imposed corrective action.

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BACKGROUND In July 1988, a one-half by three-eighths-inch hole was discovered in one of the ten (10) inch supply lines to the Emergency Diesel Generators.

The supply line is part of the Comanche Peak Steam Electric Station service ,

water system (SSWS). The SSWS is a safety-related cooling wat'; system. 1 The system functions during normal operations by providing t .ing to the component cooling water heat exchangers, and during accident conditions it is supposed to cool certain equipment necessary to mitigate the consequences of an accident.

11/ CASE does not attempt to address here the information apparently forwarded to the NRC Staf f by H. Shannon Phillips which was reported in  ;

the local press on September 22 and 23, 1989.

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The hole in the pipe was the result of a dry sandblasting operation to remove an improperly applied and f ailing protective coating liner from the inside of the carbon and stainless steel piping. Coatings at the plant were originally applied in the 1970's. Although the coatings were supposed to be applied in accordance with 10 CFR, Part 50, Appendix B, the site proceedures failed to control the paint coatings process. Subsequently the coatings repairs were downgraded. However, all coatings _which could have a safety impact were to be a controlled activity. The deterioration and failure of the coatings inside the piping posed a safety risk which was discovered and acknowledged in 1985 by TU and the NRC. The risk resulted from detachment (flaking) of the Plasite liner which could cause unacceptable blockage of the SSWS flow to the Component Cooling Water Heat Exchangers (CCWHX's) and other vital equipment.

In addition to the immediate problem of the deteriorating coatings which had to be removed, the corrosion and erosion damage to the piping itself raised questions about the system reliability and longevity.

l This situation was the subject of a study and recommen tion by Stone and Webster Engineering Corporation to TU Electric, which uitimately decided upon removal of the liner through dry sandblasting by an unapproved vendor who was not required to comply with regulatory requirements of 10 CFR, Part 50, Appendix B.

The removal process began in April 1988, and was completed in July i 1988, allegedly without incident. However, when the piping system was filled with water, a hole was discovered.

Subsequently, TU Electric developed a recovery plan consisting of a technical evaluation of the originally discovered hole and other damage in the SSWS piping and a determination of those actions necessary to return the SCWS to its design condition, and an evaluation of the root cause and generic implications of the process and administrative controls applied to the sandblasting operation. TU Electric concluded in its September 23, 1988, report (TXX-88699 and enclosures) that the hole in the pipe occurred when the dry sandblaster stalled for several minutes in one place while the sandblast gun was being manually pulled through the pipe and getting " stuck" on the build-up of sared. TU further concluded that the stalling was limited to a small portion of 10-inch piping in one train of the SSWS, early in the removal process, and that the operation was thereaf ter modified to eliminate stalling of the sandblaster. TU made videotapes of the entire inside of the piping system to dete.rmine all additional damage caused by the sandblaster, l

or excessive erosion or corrosion of the pipe.

I' l As a result of the testing, three sections of pipe where damage was determined to be the most extensive were removed from the' system. On the 3 basis of examination of the pipe, the videos, wall thickness tests, and l related reviews, TU Electric determined that the SSWS, although obviously in j need of replacement prior to the 40 year expected system life, was 3

acceptable for service once the plant went into operation. Further, TU concluded that the erosion / corrosion testing program would adequately monitor the condition of the piping.

With respect to the failure of the administrative, management, and process controls utilized throughout the events leading up to the discovery of the hole ia the pipe, TU only evaluated the controls applied to the sandL'asting operation itself. TU Electric concluded that appropriate management decisiors trere made regarding technical processes,' management resources, and pre-implementation project planning. - It is TU's. position that there were several " shortcomings" that contributed to the problems during implementation, including the failure to pre-qualify the sandblasting process in order to determine if any problems (like stalling) would occur, and the failure to insure that the coating removal project was a process c ntrolled by the TU Electric Quality Assurance Program.

TU Electric concluded in its report on this subject that this was an isolated case with maximum generic implication limited to those specialty contractors who did not have an approved quality assurance program, but who were hired to perform quality-related work under TU's Quality Assurance Program. These were called the Code V vendors.

The NRC's inspection activities in regard to this matter began in Spring of 1988, before the sandblasting operation began, when NRC Resident Inspector Shannon Phillips routinely reviewed the activities being planned and expressed a variety of concerns and questicas to the TU personnel involved with reviewing the operation. Mr. Phillips, who had some doubts about the operation, raised his issues to TU personnel who did not act on, consider, or respond to his concerns.

Subsequent to the discovery of the hole in the pipe, the NRC formally began the inspection which is the subject of Enforcement Action 88-310. i CASE began its own review of the process and the technical aspects of j the problems in the fall of 1988. CASE consultant Jack Doyle has viewed the videotapes of the piping and done a walkdown and review of the TU Electric corrosion /ercsion testing program. In addition, he has reviewed the associated documentation with the testing and discussed the project and its results with SWEC and TU Project officials.

In addition to Mr. Doyle's technical review, CASE has completely reviewed all available relevant material on the history of the problem and the implications for other programmatic deficiencies stemming from, or similar to, the problems in this case. )

l Our review and inspection efforts to date have led CASE to conclude:

(1) that the potential safety problea posed by the hole in the pipe and j other pipe damage t.as probably been remedied for the immediate safe i operability of the system; (2) that the erosion / corrosion monitoring and

- verification program, if implemented prudently and correctly, has the L  !

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ability to determine the extent of damage to pipe wall' thickness during the operation of the plant; and (3) that the recent elimination of the Code V )

program will probably remove the potential of similar problems in other safety-related projects.

However, it also appears that actions were motivated by the discovery of the hole in the pipe after completion of the Plasite removal process, and that a serious management attitude problem and mindset existed throughout q the entire timeframe of 1985 through July 1988, and that this mindset was  ;

further exacerbated throughout the regulatory review process (July-November, j 1988), and that the residual effect of this attitude has existed since the ]

beginning of the year and persists at the plant today. This attitude has resulted in other hardware problems with potential safety impact and is  !

evident in many of the day-to-day decisions.as the plant nears fuel load.

i As a result of this, it is imperative that the NRC revisit this issue immediately.

BASIS OF llPGRADE REQUEST According to the January 9, 1989, NOV, the NRC initially considered the collective significance of the violations at a Severity Level III. However, after review of the information presented by TU through the engineering report and supplement, the public meeting, and the enforcement conference, the NRC management concluded that the violations identified did not fit "the examples" in Supplement II of the Enforcement Policy (10 CFR Part 2.

Appendix C). NOV Letter, at page 1.

The criteria for a Level III violation on a construction site are:

"1) 0A Program deficiency relating to a single work activity-(e.g.,  ;

structural, piping, electrical, etc.) involving multiple examples of deficient construction.

"2) Inadequate preoperational testing to demonstrate design safety .

requirements."

It is CASE's view that sufficient information always existed within the Nuclear Regulatory CommiEsion staff that demonstrated that this issue presented a significant regulatory concern. It also appears that TU was well aware of accurate and complete information on the development of this problem and did not fully inform the NRC.

The most significant issue not fully disclosed to the NRC management, and apparently not considered by enforcement staff, deals with the Code V j program. TU conceded throughout the Fall of 1988 to both CASE and the NRC that the programmatic problems that resulted in the procurement of services without adequate Quality Assurance criteria were limited to Code V vendors t

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only. TU did not disclose that there were six Code V service procurement involving specialty work on safety-related equipment on the Comanche Peak site. In one instance the activity (steam generator nozzle measurement) was actually completed before the purchase order was finalized.

A September 30, 1988 TU Electric Memorandum (NE-22156) to L. D. Nace from W. G. Guldemond concludes that the following shortcomings existed in procurement documentation and prequalification testing:

"1) Unlike' Service Water coating removal, all involved well developed and previously employed processes. Consequently, no pre-qualification testing was required.

"2) Unlike Service Water coating removal, the verification plan for each explicitly required that TU Electric Quality Assurance monitor Vendor activities. With the' exception of one procurement (6R-345086; CPF-14/220-S) which does not appear to have been finalized, Quality Assurance contractor Surveillance Reports exist demonstrating that the activities were properly conducted. 1 However, in the case of Steam Generator Nozzle measurement and inspection, the activity was completed before the purchase order was finalized.

"3) Each procurement required that the vendor submit procedures for approval. With the exception of the Steam Generator Nozzle measurements and inspection, and the one procurement which was not finalized, these procedures were incorporated into quality-related work process control documents which were reviewed by Quality Assurance prior to work performance. Given that Steam Generator Nozzle Measurement and inspection did not involve physical work on hardware, and that the results were required to be documented in a l special vendor report to TU Electric, this exception is acceptable.

"4) Detail was found to be lacking in the verification plans for each procurement. Those associated with chemical cleaning did require  ;

Chemistry to take periodic samples, but did not specify san,ple j type or frequency.

i "5) The procurement documents did not clearly define the relationship between the organizations involved and the TU Electric Quality Assurance Program. However, in the case -of Purchase Orders 661-74340 and 661-74038, Operations prepared special temporary procedures which clearly delineated the duties and responsibilities of the parties involved.

"6) None of the procurement explicitly addressed the identification and disposition of nonconforming conditions.

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"7) The procurement for protective coating application to the Component Cooling Water Heat Exchangers (CPF-13597-S) permitted activities'which should have fallen under the auspices of ASME Section XI. This was not addressed in the procurment or the implementing work order." (Emphases added.)

On the basis of the memo, there is no indication that the procedural deficiencies were ever cross checked against the hardware work performed in order to determine whether deficiencies or failures existed in the field work performed by the vendors.

It is obvious on the face of the identified programmatic deficiencies that TU Electric's paperwork review of inspection and surveillance reports alone and some work packages or final reports could not demonstrate reasonable assurance that the work activities were actually performed satisfactorily.

More to the point, even if some documentation existed in-each of these areas to indicate successful completion, it is not a reliable conclusion because no QA requirements were ever established, procedures'were non-existent or inadequate, inspection activities were non-existent or inadequate because no uniquely defined process controls were established, and there was no process for identifying deficiencies.

In addition to the Code V programmatic deficiencies, there was apparently specific factually incorrect or incomplete information provided to the NRC through the enforcement conference materials. For example, there was a serious error in understanding the NRC's requirements in regards to coating applications during the initial application stage. This programmatic flaw, identified repeatedly to Brown & Root by Paint Coatings QC inspectors in 1983, ultimately led to paint coating failures throughout the entire plant and the determination that paint coatings had not been-procured or applied in accordance with 10 CFR, Part 50, Appendix B criteria.

In 1983 the NRC issued IE Bulletin 83-24 regarding industry-wide problems in the coatings area. Meanwhile, TU was required to undergo a series of paint coatings inspections and reviews by NRC Region IV, the Construction Appraisal Team, the Special Assessment Team, the Technical Review Team, Brookhaven National Laboratories, and ultimately by the utility following the issuance of SSER #9. TU Electric apparently never understood and applied the correct criteria to determine the difference between safety-related and non-rafety related work. This historical inability to fully recognize root causes that reflect adversely on quality of systems and j processes is a significant concern to CASE, and should have been recognized as a significant regulatory concern.

l Other inconsistencies or omissions between information presented at the I public meetings, in the engineering report, and in the enforcement  !

conference are found in the numerous materials presented to CASE for review I

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_ , .' s ,7 of this matter. These include the additional damage caused by the sp ' blaster to the piping in Train B.

CONCLUSION CASE is extremely concerned that the NRC's handling of this matter has allowed this significant problem to escape full regulatory consideration.

In its present form, it will'not be considered in the SALP report, nor will its implication be considered prior to fuel load. Therefore, on the basis of the information contained herein, we respectfully request that you-reconsider classification of this event.

Sincerely, d .h.

Billie Pirner Garde,

. Attorney for CASE cc:

U. S- NRC:

Robert F. Warnick, OSP, NRC TU Electric:

Dr. A. Husain, ORC Chairman, TU Mr. William G. Counsil, Vice President, TU Mr. W. J. Cahill, Vice President, TU Ms. Susan Palrar, Stipulation Manager, TU

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