ML20114C740

Responds to NRC Re Violations Noted in Insp Rept 50-445/84-18.Corrective Actions:Sys Test Engineers Reinstructed,Personnel Trained & Insp Plan IP-33 Revised

ML20114C740
Person / Time
Site:	Comanche Peak
Issue date:	08/23/1984
From:	Clements B TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Bangart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20114C724	List: ML20114C740
References
TXX-#4272, NUDOCS 8501300483
Download: ML20114C740 (6)

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TEXAS UTILITIES GENERATING COMPAhT MKYWAY TOWER

• 400 N4 DHTIE OLIVE MTHEET. L.H. Mt * !)ALLAN. TEXAM 73201

. .s..u.. v n. ._ci r..u.nn.T..s August 23, 1984

.rxx #4272 3 M@[2 0MM  %

Mr. Richard L. Bangart, Director

. AUG 2 4884 Region IV Comanche Peak Task Force J p U.S. Nuclear Regulatory Commission Of fice of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Docket No.: 50-445 Comanche Peak Steam Electric Station Response to NRC Notice of Violation Inspection Report No. 84-18 File No. 10130

Dear Mr. Bangart:

We have reviewed your letter dated July 26, 1984 on the inspection conducted by Messrs. D. L. Kelley and W. F. Smith of activities authorized by NRC Construction Permit CPPR-126 for Comanche Paak Unit 1. We have responded to the finding listed in Appendix A ef that letter.

To aid in the understanding of our response, we have repeated the require rent and your finding followed by our preventative actions. We feel the enclosed information to be responsive to the Inspectors' finding. If you have any questions, please advise.

Yours very truly,

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, h BRC:msc Enclosure c: ~ NRCI5Ed~i$$E~EN3dd5N1Sopy)1 I

Director, Inspection & Enforcement (15 copies)

U.S. Nuclear Regulatory Commission j

Washington, D.C. 20555 l m P .

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A DEVISiON OF TEKAB l'TELETEES ELECTRIC COMPANY L_ _. i

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APPENDIX A NOTICE OF VIOLATION Texas Utilities' Electric Company Docket: 50-445 Coman'he c Peak Steam Electric Station Construction-Permit: CPPR-126 Based on the results.of an NRC inspection conducted during the period of May 1-31, 1984,- and in accordance with the NRC Enforcement Policy (10 CFR'Part 2,

' Appendix C), 49 FR-8583, dated March 8,1984, the following violations were identified:

A. Failure to Follow Procedures Criterion V of Appendix B to 10 CFR 50 states, in part, " Activities affecting qualityLahall 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 . . ."

1. Contrary to the above, during performance of the "A" Train emergency diesel generator auxiliary systems retest, ICP-PT-29-01, RT-1, it was noted that the test was being performed without all the prerequisites-being signed off. This is a violation of CP-SAP-21, " Conduct of' Testing."

2. Contrary to the above, it was noticed that " Hold Tags" were improperly removed from the "A" Train diesel engine, and the diesel'had been run without closing several nonconformance reports, or affixing " conditional release" tags to the diesel, which is in violation of STA-405, RS,

" Control of Nonconforming Materials."

3. Contrary to the above, an inspection report. relating'to implementation of the "A" Train emergency diesel generator. Owners' Group inspection of the turbochargers (I.P.-33) contained notations that the dimensions specified could not be taken because "the needed equipment was not available." . The letters "N/A" were put on the inspection report instead of revising the' applicable inspection plan and the inspection report criteria. This is a violation of QPM-004, " Inspection Report."

.This is a. Severity Level IV Violation. (Supplement II-D) (445/8418-01)

Response to Part A.I.

Corrective Steps Taken and' Results Achieved Upon identification of;the ; procedural violation, 'the System Test Engineer

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issued'a Test' Deficiency Report (TDR-2756) for failing=to follow procedures.

In the disposition of the corrective action, the System Test Engineer ^was instructed in the' requirement to-ensure the procedure wasl conducted in  ;

accordance iwith the ' requirements of CP-SAP-21 " Conduct 'of Testing." i 1

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-Corrective Steps Taken to Avoid Further Violations As documented on SIM-84170 all System Test Engineers were instructed to perform a comprehensive review of test prerequisites to ensure system readiness, proper test performance and data acquisition.

Date of Full Compliance All Corrective and Preventive Actions have been completed as of August 13, 1984.

Response to Part A.2.

CPSES Plant Operations personnel have performed an investigation to determine

. the nature of a violation attributed to STA-405, Revision 5, " Control of Nonconforming Materials, " in the Notice of Violation.

It is important to note that Revision 6 of STA-405 was issued on May 18, 1984, prior to testing the Diesel Generator _on May 24. With this in mind, an understanding of the differences between Revisions 5.and 6 is necessary.

STA-405, Rev. 5, required a nonconformance report (NCR) to be completely closed by final review of the Operations Quality Assurance Supervisor that documentation was complete and adequate before " hold tags" could be removed and the nonconforming item put back in service. Revision 5 also had the provision that a " conditional release" could be granted, allowing equipment to be operated prior to final closure of the NCR. Conditional releases were issued only after an engineering evaluation considered safety implications of the requested release.

As stated, Revision 6 of STA-405 was issued on May 18. This revision allows removal of " hold tags" after verification by a Quality Contro1 ' Inspector that an engineering approved disposition has been accomplished. This practice allows equipment to be placed in service before final. review of the NCR for documentation requirements by the Operations Quality Assurance Supervisor.

Revision 6 also differs from Revision 5 by discontinuing the use of conditional releases in favor of partial dispositions. The partial disposition receives the same engineering and quality reviews as the conditional release, but does not require an additional form.

Basic dif ferences between Revisions 5 and 6 of STA-405 have been outlined and their relation to this Violation will become apparent. Due to the unique nature of the Diesel Generator Recertification Program, the station nonconformance system was utilized to document any irregularity requiring engineering evaluation.

As a result, over sixty NCR's were written under Revision 5 of STA-405, several of which had not been dispositioned when Revision 6 was issued on May 18. To allow the transition between revisions, CPSES Special Order No. X-SO-84-010 was issued on May 23 to allow NCR's generated under Revision 5 to be closed in accordance with its provisions or Revision 6, when practical.

After a test run of the Train A Emergency Diesel Generator on May 24, the NRC Resident Reactor Inspector identified several open NCR's which may have needed r

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-P:g1e 3-conditional releases. TUGCo Deficiency Reports DR-84-034 and-034 and DR-84-037 were issued to document the apparent procedure violation. Subsequent investigation of NCR's ' identified on the deficiency. reports determined that all but one had

-been handled conectly, as allowed by Special Order No. X-SO-84-010, including NCR-84-097 cited by the NRC Resident Reactor Inspector. The one exception was NCR-84-108 and action taken'is described below.

Corrective Steps Taken and Results Achieved

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A hold tag was placed'on the diesel to prevent further running until NCR-84-108 was closed. An investigation determined that this NCR involved capscrews for the Diesel' Exhaust Manifold. The disposition of this NCR was to reject part o.f the capscrews, replace them with screws from Train B and use the remainder of the capscrews "as-is." This disposition was approved by Engineering and Quality Assurance prior to starting the diesel, but had not been completely closed as required by Revision 5. The' disposition ~ required the Train B capscrews, which were removed for use on Train A, to be replaced and the NCR could not be closed out until the replacement parts arrived.from the vendor and were, installed on the Train B Diesel. Running of the' diesel with the outstanding NCR was a violation of the procedure, .but had no impact on the quality or the safe operation-of the Train A Diesel. At no time was the Train A Diesel run with nonconforming or questionable parts.

Corrective Steps Taken to Avoid Further Violations Training was conducted for all Maintenance Engineering Personnel and Maintenance Foremen. This training covered the proper handling of nonconformances by STA-405, Rev. 6. The training session incorporated a detailed discussion of DR-84-037 and was documented in accordance with Procedure TRA-401. The Deficiency Reports were reviewed by-Maintenance Supervisory Personnel, Maintenance Foremen, and Maintenance Engineering Personnel and documented in accordance with Procedure MDA-106, " Maintenance Document Review." Training was also conducted for QC inspection personnel in the area of STA-405 and QPM-004. This was preceded by the Manager, Plant Operation, who stressed the importance of the inspection program and demonstrated management involvement'in the program.

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. All actions concerning NCR-84-108 were completed August 7, 1984 Response to Part A.3.

i j Inspection Plans (IP's) were developed by the Tansamerica Delaval Diesel Generator Owners Group to standardize the recertification program- The IP's are written

generically to encompass the various TDI diesel generator designs and therefore, f are not 100% applicable to each generator type. In'many cases, the Inspection Report was utilized'as a tool for gathering informational data used in diesel-evaluation by the Owners Group. The inspection characteristic of IP-33 in question was the requirement for a dimensional measurement of the turbocharger.

I This requirement was questioned by the QC inspector'to an Owners Group representative-

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who evaluated and determined it not applicable to the CPSES diesel. The QC inspector marked the characteristic "N/A" on his inspection report with the notation "needed equipment was not available," but failed to qualify the

' notation by.also stating that he had discussed this characteristic.with the Owners Group representative.

TUCCo' Deficiency. Report DR-84-036 was written to document and evaluate this apparent procedural deficiency. and the following actions taken:

Corrective Steps Taken:and Results Achieved Inspection - Plan (IP-33) and Inspection Reports IR-84-0220 and IR-84-0415 have been properly revised deleting the turbocharger bearing dimensional check.

Corrective Steps Taken to Avoid Further Violations The Manger, Plant Operations and Quality Assurance Supervisor addressed the TUCCo Operations QC inspectors on June 1, 1984, and stressed the importance of the inspection. program. A training session following the management involvement discussed specifics of DR-84-036, including the importance of complete documentation by inspectors and the fact that .any changes to inspection reports be first approved by a Level III Inspector. The training involved' review of STA-405 and QPM-004 and stressed the importance of following all procedures

-and instructions.

Date of Full Compliance .

Actions taken to correct and prevent violations of this type were completed on June 12, 1984.

B. Failure to Provide Adequate Test Prerequisites Criterion XI of. Appendix B to 10 CFR 50 states, in part, ". . . the test program shall include, as appropriate, proof tests prior to installation, preoperational tests, and operational: tests during nuclear power plant'or~

fuel reprocessing plant operation of structures, systems, and components.

Test procedures shall include provisions for assuring that all prerequisities for the'given test have been met . . . ."

Contrary to the above, during the performance of the safety injection pump performance retest, ICP-PT-57-01,- RT-2, it was observed'that one of the prerequisites specified a requirement for the system to be lined up in' accordance with SOP-201A, which .is the safety injection system operating procedure. This line up will not support-the test. Therefore, the prerequisites were not adequate for performance lof the test, because a special lineup.(not specified) was necessary to support the' test.

This is a Severity Level V. Violation. (Supplement II-E) (445/8418-02)-

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Response

Corrective Steps Taken and Results Achieved Upon identification that the Station Operating Procedure was not adequate, a

,  : Test Procedure Deviation was generated and testing resumed.

Corrective Steps Taken to Avoid Further Violations All System Test Engineers were directed per SIM-84112 that prior to starting a test, they must review the current operating p' ocedures r to be used to ensure that the procedure to be used places the system into' the configuration required for the-test. A Test Procedure Deviation should be issued against the test procedure to compensate for incorrect operating procedures or to accommodate

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required system test configurations.

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Date of Full Compliance Corrective and Preventive Actions have been completed as of June 4, 1984.

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