Text

Final Response to FOIA Request for Documents Re Insp Repts 50-445/87-27 & 50-446/87-20.App B Documents Encl.App a Documents Available in PDR
	ML20148J780
Person / Time
Site:	Comanche Peak
Issue date:	03/25/1988
From:	Grimsley D; NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
To:	Bauman L; GOVERNMENT ACCOUNTABILITY PROJECT
Shared Package
ML20148J786	List: ML20148J780; ML20148J804;
References
	FOIA-88-18 NUDOCS 8803300385
	Download: ML20148J780 (4)
	v • d • e

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U.S. NUCLEAR REGULATORY COMMISSION sac ro.A asoutst sveta,si

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INFORMATION ACT (FOIA) REQUEST

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ALAR 2 51988

DOCKET %V8tR Si vr emaw

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Ms. A h . G4P

PART 3.-RECORD) RELEASED OR NOT LOCATED ISee checked bones)

No agency records sub;ect to the reauest have been located

No additoral agency records subject to the request have been located

Agency records sub+ct to the request that are scentif +ed in Append a _ are already asadable for pubbc inspecton and copyeg en the NRC Pubhc Document Room,

1717 H Street, N W . Wasbegton, DC.

Agency records subrect to the request th*t s'e ident; fed in Appendiu __ a'e being made asadabbe for pubhc rspecten and copyng b the NRC Pubhc Document

Room.1717 H Street. N.W.. Wasm.cgton. DC, m a folder under the FOIA number and req uester narne-

The nonproprietary verson of the proposaus) that you agreed to accect m a telephone conversation uth a rnember of my staff 's now bemg made avadable for pubhc rspecton

and coving at the NRC Pubhc Docuraent Room.1717 H Street. N W . Washngton. OC , e a folder under this FOI A numt'er and requester name.

Enclosed is informaton on how you may obta.n access to and the charges for cooyng records placed m the NRC Pubhc Document Room,1717 H Street. N W.. ' 'egton, DC.

Agency recorcs subset to the request are enclosed Any appbcabte charge for copes of the records provWed and payrrent procedures are noted m the , section.

Records subsect to the request ease been referred to another Federal agencytest for review ar'd d rect respor se to you

in vew of NRC's resoonse to this request. no further acton a being taken on appeal 4tter dated

PART 11 A-INFORM ATION WITHHELD FROM PUBLIC DISCLOSURE

Certan informaton in tie requested records 4 besng mthheld from pubhc drsclosure pursuant to the FOIA enemotons described in and for tne reasons stated in Part 11, sec-

tons B, C. and D Any released portons of the documents for which only part of the record is bemg w'thheld are bemg made avadable for pubhc especton and copyng m

the NRC Pubhc Oocument Room.1717 H Street. N W.. Washington, DC m a folder under this FOIA number and requester name.

Comments

8803300385 080325

PDR FOIA PDR

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APPENDIX A

F01A-88-18

RECORDS MAINTAINED AMONG PDR FILES

NUMBER DATE DESCRIPTION AND ACN NO. OF PGS

1 11/12/87 NRC Ltr, Grimes to Counsil (TV Electric) 18

transmitting Inspection Report 50-445/87-27;

50-446/87-20. ACN 8711200160

2 12/31/87 NRC ltr, Grimes to Counsil (TV Electric) 31

transmitting NOV for Inspection Report

50-445/87-27; 50-446/87-20. ACN 8801140055

3. 2/1/88 TV Electric ltr, Counsil to Grimes (NRC), 7

responding to item 2 (TXX-88192) i

ACN 8802040357

4 8/7/87 TV Electric ltr (TXX-6629) 10 CFR 50.55(e) 1

iterim report SDAR: cP-87-33 on auxiliary

feedwater pump motor fans (AN0 8708120026) :

5. 10/7/87 1

TV Electric

interim ltr (TXX-6813)

report SDAR: 10 CFR 50.55(e))

CP-87-33 (8710140270

6. 11/30/87 1

TV Electric

interim ltr (TXX-7020)

report SDAR: 10 CFR 50.55(e))

CP-87-33 (8712040262 ;

7 12/14/87 4

TV

final Electric

report SDAR:ltr (TXX-7063) 10 CFR 50.55()e)

CP-87-33 (8712280033

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Re: FO! A. 88 -18

APPEN0!x B

RECORDS MAINTAINED IN THE POR UNDER THE ABOVE REQUEST NUMBER

NUMBER DATE DESCRIPTION AND ACN NO. OF PGS

1 undated TV Electric presentation slides from 16

enforcement conference of 12/8/87, with

annotations by C, Grimes

2. 12/11/87 Comanche Peak Project Division site priority 3

workload list for 12/14-18/87

3. 1/1/88 Memo for Grimes from Warnick, Major 3

accomplishments for December 1987

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Re: FOI A. 88 -18

APPENDIX B /

RECORDS MAINTAINED IN THE PDR UNDER THE ABOVE REQUEST NUMBER '

NUMBER DATE DESCRIPTION AND ACN N0. OF PGS

1 undated TV Electric presentation slides from 16

enforcement conference of 12/8/87, with

annotations by C. Grimes

2. 12/11/87 Comanche Peak Project Division site priority 3

workload list for 12/14-18/87

3. 1/1/88 Memo for Grimes from Warnick, Major 3

accomplishments for December 1987

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NUCLEAR REGULATORY COMMISSION

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Dockets: 50-445; 50-446

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Permits: CPPR-126; CPPR-127

Texas Utilities Electric Company

ATTN: Mr. W. G. Counsil

Executive Vice President

400 North Olive Street, Lock Box 81

Dallas, Texas 75201

Gentlemen:

SUBJECT:

50-446/87-20) NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-445/87-27f

This refers to the inspection conducted during the period from

October 7 through November 3, 1987, at the Comanche Peak Steam

Electric Station (CPSES) of activities authorized by NRC

Construction Permits CPPR-126 and 127. During that inspection,

four potential violations were identified, as described in the

referenced inspection report which was issued to you by letter

dated November 12, 1987.

An enforcement conference was held at the

site office of the Comanche Peak Project Division on December 8,

1987, to discuss the inspection findings.

The NRC has considered the information presented during the

enforcement conference and is issuing this Notice of Violation for

three violations as described in Enclosure 1. As a result of

information presented, we have withdrawn one of the potential

violations identifjed in the referenced inspection report.

Enclosure 2 provides a summary of the potential violations

documented in the referenced inspection report and the NRC staf f

position on each potential violation. A copy of the slides used by

TU Electric during the discussion is included ac Enclcsure 3.

The

(NOV)three violations identified in the enclosed Notice of Violation

concern your failure to identify and correct the rotation of l

the fans on the auxiliary feedwater pump motor. Over a period of l

years, several opportunities to correct this problem were missed.

The first violation resulted from failure to adequately evaluate

this deficiency when it was identified in Unit 2 in 1986. The

second violation resulted from failure of personnel to follow the

test procedures which specified that when the direction of motor

rotation was changed that the fans must also be reversed. The

third violation resulted from failure to clearly rpecify the

direction of rotation of the motor and the pump with respect to

each other when the pumps and motors were purchased.

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The violations are considered to be significant because the i

multiple failures resulted in the Unit 1 auxiliary feedwater pumps

and motors being accepted for service with the motor fans installed

backwards. The Westinghouse evaluation concluded, based on Unit 1

preoperational test results of the AFW pumps with the reversed

motor blower fans, that the motor qualification specifications :

would not be exceeded for the qualified life. TU Electric also I

concluded that no action statement for a limiting condition for

operation would have been entered had the plant been in operation. l

Because of the lack of safety significance, the violations were not I

considered for escalated enforcement action. l

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In accordance with the "General Statement of Policy and Procedure I

for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), two

of the violations described in the enclosed Notice have been

classified as Severity Level IV and one violation has been

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classified as severity Level V.

You are required to respond to this letter and should follow the

instructions specified in the enclosed Notice when preparing your

response. In your response, you should document the specific

actions taken and any additional actions you plan to prevent

recurrence.

In accordance with Section 2.790 of the NRC's "Rules of Practice,"

Part 2, Title 10, Code of Federal Regulations, a copy of this

letter and its enclosures will be placed in the NRC Public Document

Room.

The responses directed by this letter and the enclosed Notice are

not subject to the clearance procedures of the of fice of Management l

and Budget as required by the Paperwork Reduction Act of 1980, 1

Pub. L. No.96-511.

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Sincerely,

ffYWY l

Christopher I. Grimes, Director

Comanche Peak Project Division

Office of Special Projects

Enclosures:

1. Notice of Violation

2. Analysis of Apparent violations

3. December 8, 1987, Meeting Presentation

cc w/ enclosures:

See next page.

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AFW FAN MOTORS AGENDA ,

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I. MOTOR FAN DESCRIPTION OF OPERATIONS I

II. EXECUTIVE SUMMARY

III. EVALUATION OF PROPOSED VIOLATIONS

IV. CONCLUSIONS

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EXECUTIVE SUMMARY

TU ELECTRIC HAS REVIEWED THE PROPOSED VIOLATIONS. OUR REVIEW HAS

IDRNTIFIED FOUR ISSUES WHICH REPRESENT POTENTIAL VIOLATIONS.

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1. THE SPECIFICATION FOR PROCUREMENT AND INSTALLATION OF THE l

AFT MOTOR AND FAN ASSEMBLIES WAS INCOMPLETE.

2. THE DISPOSITION AND ASSESSMENT OF THE TEST DEFICIENCY REPORT

DOCUMENTING THE UNIT 2 FAN INSTALLATIONS WAS NOT COMPREHENSIVE.

3. PROJECT PERSONNEL FAILED TO ISSUE PROPER DOCUMENTATION FOR

THE DEFICIENCY IDENTIFIED IN THE PUMP SUPPLIER'S (I-R) LETTER.

4.

A VENDOR TECHNICAL MANUAL REQUIREMENT REGARDING FAN DIRECTION

WAS OVERLOOKED.

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OUR EVALUATION HAS INDICATED IN THE EVENT THESE DEFICIdNCIES

HAD REMAINED UNCORRECTED, NO CONDITION ADVERSE TO THE SAFETY l

0F PLANT OPERATIONS WOULD EXIST. A DETAILED EVALUATION OF THE

TEST DATA SUPPORTS THIS CONCLUSION. IN ADDITION, NO ACTION

STATEMENT FOR A LIMITING CONDITION FOR OPERATIONS WOULD HAVE j

BEEN ENTERED HAD THE PLANT BEEN IN OPERATION.

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WE HAVE CONCLlTDED THAT IN THE EVENT FAN INSTALLATION ORIENTATION

FORTHEAFWPUMPMOTORHADBEENCRITICALTOTHkPERFORMANCEOF

THE AFW PUMP, THE PREOPERATIONAL TEST PERFORMED WOULD HAVE

DETECTED AND RESULTED IN CORRECTION OF THE FAN INSTALLATION.

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THEREFORE, USING THE CRITERIA SPECIFIED IN 10CFR PART 2

APPENDIX C, SUPPLEMENT I FOR REACTOR OPER TIONS AND

SUPPLEMENT II FOR FACILITIES UNDER CONSTRUCTION, THE

PROPOSED VIOLATIONS INDIVIDUALLY OR COLLECTIVELY DO

NOT MEET THE CRITERIA FOR ESCALATED ENFORCEMENT ACTION.

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FINDING A:

CORRECTIVE ACTION (DEFICIENCY NOT FIELD INSPECTED)

PROPOSED VIOLATION _ ( 4 4 5 /8 7 2 7 -V- C '.1)_:_ TUE FAILED TO TAKE

ADEQUATE CORRECTIVE ACTIONS. SPECIFICALLY, NO ACTION WAS

TAKEN ON THE UNIT 1 AFW MOTOR FAN INSTALLATION AFTER DEFICIENT

CONDITIONS WERE IDENTIFIED IN UNIT 2 AND PROVIDED TO THE

.

RESPONSIBLE UNIT 1 ORGANIZATION VIA MEMO.

RESPONSE:

' ACTIONS TO ASSESS DEFICIENCY SAFETY SIGNIFICANCE WERE TAKEN.

--PREOPERATIONAL TEST DATA REVIEWED

--TEST DATA CONFIRMED FAN WOULD PERFORM INTENDED

SAFETY FUNCTIONS (TEMPERATURE RISE WAS WITHIN

ACCEPTANCE CRITERIA)

' FANS COULD HAVE BEEN FIELD CHECKED TO CONFIRM HARDWARE

DEFICIENCY, BUT TEST DATA CCNFIRMED THAT SAFETY FUNCTION

WAS UNAFFECTED (SEE ITEM C).

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FINDING B:

CORRECTIVE ACTION (PROBLEM REPORT CONTENT)

PROPOSED VIOLATION (445/8727-V-01Bli AFTER IDENTIFICATION BY THE NRC

INSPECTOR, THE TUE PROBLEM REPORT INADEQUATELY EVALUATED THE UNIT 2

DEFICIENCIES. AS A RESULT, THE PR FAILED TO ADDRESS CAUSE AND CORRECTI)

ACTIONS TO PRECLUDE RECURRENCE, THE INADEQUATE EVALUATION IN 1986,

THE LACK OF DEFICIENCY DOCUMENTS IN 1986, DETECTION OF THE UNIT 1

INSTALLATION, AND ACTION ON VENDOR (X AND I-R) INFORMATION.

RESPONSE:

' PROBLEM REPORT WAS PROPERLY USED

--DOCUMENTED A VARI ATION FROM NORMAL AND EXPECTED OPERATIONS

(PRINCIPAL FUNCTION)

--WORI ORDERS WERE ISSUZD TO REWORK U1 FANS

--A DR WAS ISSUED INDEPENDENT OF PR

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FINDING C: INADEQCATE CORRECTIVE ACTION

PROPOSED VIOLATION (445/8727-V-01C: 446/8720-V-01A): ENGINEERING

EVALUATION OF THE UNIT 2 AFT MOTOR FAN TDR WAS INADBQUATE. SPECIFICAILY ,

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THE EVALUATVR DID NOT CONTACT THE MOTOR SUPPLIER (T) TO CONSIDER POSSIBLE i

ADVERSE EFFECTS AND FAILED TO ASSURE PHYSICAL INSPECTION OF THE UNIT

1 INSTALLATIONS.

RESPONSE:

' DESIGN ENGINEERING REVIEW WAS NOT COMPREHENSIVE

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--A FIELD CHECK WAS NOT PERFORMED, THEREFORE THE DEFICIENCY

WAS NOT DOCUMENTED.

'HOWEVER, THE DESIGN ENGINEER DID:

--APPROVE REWORK OF THE U2 FANS I

--VERIFY SAFETY FUNCTION OF AFV FAN TAS NOT IMPAIRED it rr.M Gr.d

' CORRECTIVE ACTION

--REVISED SPECIFICATIONS 2323-ES-1D and 2323-MS-7

' ACTION TO PRECLUDE RECURRENCE

--SAFETY RELATED INSTALLATION SPECIFICATIONS HAVE BREN REVIEWED

--PROCUREMENT SPECIFICATIONS ARE BEING REVIETED

--TRAINING WILL BE CONDUCTED TO STRESS THOROUGHNESS OF

CORRECTIVE ACTIONS BY ENGINEERING

--ENGINEERING DEPARTMENT HAS UNDERGONE REORGANIZATION 5 } 2.G

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FINDING D: CORRECTIVE ACTION (FOLLOWUP ON I-R IAT*ER)

PROPOSED VIOLATION (445/8727-V-01D: 446/8720-V-01B): ACTIONS FERE

NOT TAKEN AS A RESULT OF VENDOR IDENTIFIED DEFICIENCIES. SPECIFICALLY,

ALTHOUGH A SPEED LE' ITER WAS ISSUED BY B&R IN (1978) TO PLACE AFFECTED

COMPONENTS ON HOLD UPON RECEIPT, G&H, TUE & B&R FAILED TO CORRECT AFW

MOTORS FOR PUMP ROTATIONAL INCONSISTENCIES IDENTIFIED IN A LE' ITER

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RESPONSE:

' ACTIONS TO PLACE AFT UNITS IN "HOLD" OR "NONCONFORMING" STATUS l

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NOT PERFORMED

' SPECIFICATION NOT CHANGED BY ENGINEERING

' CORRECTIVE ACTION TAKEN

--DCAs WRITTEN TO CHANGE SPECIFICATION !

--MOTOR PHASE WAS VERIFIED DURING PREREQUISITE TESTING

--FANS HAVE BREN ORIENTED PROPERLY

' ACTION TO PRECLUDE RECURRENCE

--TNE-DC-5-1 (ECE 5.19-03) "VENDOR DOCUMENT REVIEW VDC AND VDI"

ISSUED. BACEFIT OF VENDOR CORRESPONDENCE IN PROGRESS.

--TNE-AD-4-9 (BCE 1.05) "CORRESPONDENCE CONTROL" FOR CONTROL OF

VENDOR CORRESPONDENCE

(NCR) AND 3.06 (DR) DEVELOPED FOR ENHANCED CONTROL

f OF DEFICIENCIES

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FINDING B: STARTUP TEST ACTIONS

PROPOSED VIOLATION (445/8727-V-02): TUE FAILED TO VERIFY CORRECT

TERMINATION AND MOTOR ROTATION PER PROVISIONS OF THE PREREQUISITE TEST

PROCEDURE XCP-EE-09. TUE FAILED TO REVERSE THE BLOWER FAN WHEN THE

LEADS WERE REVERSED PER THE .W_INSTRUCTION MANUAL FOR THE AFT PUMP MOTORS.

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RESPONSE:

PROCEDURE XCP-EE-09 WAS NOT FOLLOWED (FANS FERE NOT REVERSED)

--VENDOR MANUAL REQUIREMENTS TERE OVERLOOKED

' CORRECTIVE ACTION _

--STARTUP PERSONNEL YERE COUNSELED

ACTION TO PRECLUDE RECURRENCE

--THE STARTUP PROCEDURES WILL BE CHANGED TO REQUIRE A TDR IF MOTOR

ROTATION IS DIFFERENT FROM THE ARROW INDICATION PRESCRIBED PER

NEMA

--STARTUP PERSONNEL WILL BE TRAINED

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FINDING F: WORK INSTRUCTION ADEQUACY

PROPOSED VIOLATION (445/6727-V-03: 446/8720-V-02): TUE FAILED TO PROVIDE

ADEQUATEINSTRUCTIONSFORTHEhNSTALLATI0h0FTHEAFWPUMPSANDMOTORS.

THENRCINSPECTORCOULDFINDNOPR0bEDURE,DETAILEDINSTRUCTIONOR

DRAWING THAT CONTAINED SUFFICIE INFORMATION TO ASSURE THAT THE MOTOR,

PUMP AND FAN WERE INSTALLED OR CORRECT ROTATION.

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RESPONSE:

' INSTALLATION WORK===.INSTRUCTIONS WERE ADEQUATE

--TRAVELERS, CHECKLISTS, CONNECTION CARDS AND QC INSPECTION WERE

PREPARED 4 IMPLEMENTED

--IDR NOT REQUIRED FOR INSTALLATION

--PHASE ROTATION NOT REQUIRED FOR INSTALLATION (PERFORMED DURING

STARTUP PREREQUISITE TESTING)

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FINDING G: SPECIFICATION REVIEW

PROPOSED VIOLATION (445/8727-V-04A: 446/8720-V-03A: TUE FAILED TO

DESCRIBE CONSISTENT ROTATIONAL DIRECTION FOR THE AFT PUMP / MOTOR COMBINATIOh

IN SPECIFICATION 2323-MS-7 (PUMP) AND SPECIFICATION 2323-ES-1D (MOTOR).

RESPONSE:

' ROOT CAUSE OF DEFICIENCY (INCOMPLETE SPECIFICATIONS)~' ;

--SPECIFICATIONS (PUMP / MOTOR) DID NOT CONTAIN CONSISTENT

ROTATIONAL REQUIREMENTS

' CORRECTIVE ACTION

--EEVISED SPECIFICATIONS

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--OTHER SPECIFICATIONS AND REQUIREMENTS REVIEWED !

--CONFIRMED NO OTHER WOTORS AFFECTED (REVIET AND FIELD WALXDOWN)

ACTION TO PRECLUDE RECURRENCE

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--PROCEDURES NOT INCLUDE WORE SPECIFICITY (FOR INTERDISCIPLINE REVIET)

--TRAINING

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FINDING H: DESIGN CONTROL (1DCR & DCA)

PROPOSED VIOLATION (445/8727-V-04B: 446/8720-V-03B): TUE FAILED TO

SPECIFY MOTOR PHASE AND DIRECTION OF ROTATION ON TUGCO DESIGN CHANGE

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REQUEST (TDCR) 4187 AND THE RESULTANT DESIGN CHANGE AUTHORIZATION (DCA)

34953. THERE WAS NO INTERDISCIPLINARY REVIEW OR SPECIFICATION REVIEW l

PRIOR TO DCA ISSUANCE.

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RESPONSE:

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' DESIGN CONTROLS WERE ADEQUATE

--STARTUP IDENTIFIED AND DOCUMENTED PHASE CHANGE CORRECTLY

--TDCR USED CORRECTLY FOR DRAWING CHANGE REQUEST l

--IDR AND SPECIFICATION REVIEW FOR SUBSEQUENTLY ISSUED DCA WAS 1

NOT REQUIRED

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CONCLUSIONS

VALID VIOLATIONS (ITEMS C, D, E AND G) WERE OF NO

SAFETY SIGNIFICANCE.

OUR EVALUATION IiAS CONCLUDED THAT, HAD TH DEFICIENCY

GONE UNCORRECTED, NO CONDITION ADVERSE TO THE SAFrrY

OF PLANT OPERATIONS WOULD HAVE RESULTED.

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FURTHER, IF TH ISSUES AT HAND HAD BEEN TRULY SAFFTY

SIGNIFICANT, HISTING PROGRAMS WOULD HAVE DET5CTED

THE DEFICIENT CONDITIONS AND APPROPRIATE CORRECTIVE

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ACTION TAKEN. 1

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NO ACTION STATEMENT FOR A LIMITING CONDITION FOR OPERATION

TOUID HAVE BREN ENTERED HAD THE PLANT BREN IN OPERATION. 1

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THEREFORE, USING THE CRITERI A IDENTIFIED IN 10CFR2,

APP. C, SUPPLEIGNT I FOR REACTOR OPERATIONS OR SUPPLRMENT

II POR FACILITIES UNDER CONSTRUCTION, THE PROPO6ED

VIOLATIONS INDIVIDUALLY OR COLLECTIVELY, DO NOT MEET

TH CRITERIA FOR ESCALATED ENFORCEMENT ACTIONS.

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PROPOSED VIOLATIONS

SUBJECT

VIOLATION (s)

FINDING A: CORRECTIVE ACTION

445/8727-Y-01A

(DEFICIENCY NOT FIELD INSPECTED)

FINDING B: CORRECTIVE ACTION 445/8727-V-01B

(PROBLEM REPORT CONTENT)

FINDING C: CORRECTIVE ACTION 445/8727-V-01C

(INADEQUATE ACTIONS) ' 446/8720-V-01A

FINDING D: CORRECTIVE ACTION 445/8727-V-01D

(FOLLOW-UP ON I-R LETTER) 446/8720-V-01B

FINDING E: STARTUP TEST ACTION 445/8727-Y-02

(FAILURE TO IMPLEMENT)

FINDING F: WORK INSTRUCTION ADEQUACY 445/8727-V-03

446/8720-V-02

FINDING G: SPECIFICATION REVIEW 445/8727-V-04A

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446/8720-V-03A

FINDING H: DESIGN CONTROL

445/8727-V-04B

(TDCR 4 DCA)

446/8720-V-03B

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