ML20148J780
| 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: |
| References | |
| FOIA-88-18 NUDOCS 8803300385 | |
| Download: ML20148J780 (4) | |
See also: IR 05000445/1987027
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U.S. NUCLEAR REGULATORY COMMISSION
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RESPONSE TO' RE
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INFORMATION ACT (FOIA) REQUEST
ALAR 2 51988
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DOCKET %V8tR Si vr emaw
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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
BAUMANB8-18
$'GNATLa - aECTOA 04Y '
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APPENDIX
A
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)
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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)
TV Electric ltr (TXX-6813) 10 CFR 50.55(e))
1
5.
10/7/87
interim report SDAR:
CP-87-33 (8710140270
TV Electric ltr (TXX-7020) 10 CFR 50.55(e))
1
6.
11/30/87
interim report SDAR:
CP-87-33 (8712040262
TV Electric ltr (TXX-7063) 10 CFR 50.55()e)
4
7
12/14/87
final report SDAR:
CP-87-33 (8712280033
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Re:
FO! A. 88 -18
APPEN0!x
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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
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RECORDS MAINTAINED IN THE PDR UNDER THE ABOVE REQUEST NUMBER
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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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UNITED STATES
NUCLEAR REGULATORY COMMISSION
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WASWNGTON D. C. 20555
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DEC 3 l 1987
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Dockets:
50-445; 50-446
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Permits:
CPPR-126; CPPR-127
3 j,d
Texas Utilities Electric Company
ATTN:
Mr. W. G. Counsil
Executive Vice President
400 North Olive Street, Lock Box 81
Dallas, Texas
75201
Gentlemen:
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-445/87-27f
50-446/87-20)
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 three violations identified in the enclosed Notice of Violation
(NOV) concern your failure to identify and correct the rotation of
the fans on the auxiliary feedwater pump motor.
Over a period of
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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Texas Utilities Electric Company
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DEC 31 1967
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The violations are considered to be significant because the
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
concluded that no action statement for a limiting condition for
operation would have been entered had the plant been in operation.
Because of the lack of safety significance, the violations were not
considered for escalated enforcement action.
In accordance with the "General Statement of Policy and Procedure
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
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
and Budget as required by the Paperwork Reduction Act of 1980,
Pub. L. No.96-511.
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Sincerely,
ffYWY
Christopher I. Grimes, Director
Comanche Peak Project Division
Office of Special Projects
Enclosures:
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
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.
1.
THE SPECIFICATION FOR PROCUREMENT AND INSTALLATION OF THE
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
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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
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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.
(3)
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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
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ADVERSE EFFECTS AND FAILED TO ASSURE PHYSICAL INSPECTION OF THE UNIT
1 INSTALLATIONS.
RESPONSE:
' DESIGN ENGINEERING REVIEW WAS NOT COMPREHENSIVE
--A FIELD CHECK WAS NOT PERFORMED, THEREFORE THE DEFICIENCY
WAS NOT DOCUMENTED.
'HOWEVER, THE DESIGN ENGINEER DID:
--APPROVE REWORK OF THE U2 FANS
--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
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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
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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
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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
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--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
--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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prod >_LLA.
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RESPONSE:
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' 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
--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
REQUEST (TDCR) 4187 AND THE RESULTANT DESIGN CHANGE AUTHORIZATION (DCA)
34953.
THERE WAS NO INTERDISCIPLINARY REVIEW OR SPECIFICATION REVIEW
PRIOR TO DCA ISSUANCE.
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RESPONSE:
' DESIGN CONTROLS WERE ADEQUATE
--STARTUP IDENTIFIED AND DOCUMENTED PHASE CHANGE CORRECTLY
--TDCR USED CORRECTLY FOR DRAWING CHANGE REQUEST
--IDR AND SPECIFICATION REVIEW FOR SUBSEQUENTLY ISSUED DCA WAS
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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.
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.
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NO ACTION STATEMENT FOR A LIMITING CONDITION FOR OPERATION
TOUID HAVE BREN ENTERED HAD THE PLANT BREN IN OPERATION.
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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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