05000445/LER-2004-002, Regarding Condition Prohibited by Technical Specifications

Regarding Condition Prohibited by Technical Specifications

ML041590316
Person / Time
Site:	Comanche Peak
Issue date:	05/28/2004
From:	Blevins M TXU Energy, TXU Generation Co, LP
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CPSES-200401280, TXX-04086 LER 04-002-00
Download: ML041590316 (8)

LER-2004-002, Regarding Condition Prohibited by Technical Specifications

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
4452004002R00 - NRC Website

text

V TXU

-.4401 TXU Energy Comanche Peak Steam Electric Station P.O.Box 1002 (EO1)

Glen Rose,TX 76043 Tel: 254 897 5209 Fax: 254 897 6652 mike.blevins@txu.com Mike Blevins Senior Vice President & Principal Nuclear Officer Ref: I OCFR50.73(a)(2)(i)(B)

CPSES-200401280 Log # TXX-04086 May 28, 2004 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 CONDITION PROHIBITED BY TECHNICAL SPECIFICATIONS LICENSEE EVENT REPORT 445/04-002-00 Gentlemen:

Enclosed is Licensee Event Report (LER) 04-002-00 for Comanche Peak Steam Electric Station Units I and 2, "Missed Surveillance on Loss of Power Emergency Diesel Generator Start Instrumentation."

This communication contains the following new commitment which will be completed as noted:

Commitment Number 27315

Commitment

The seven affected functions on Unit 2 will be verified via Technical Specification channel calibrations prior to completion of the eighth refueling outage.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance

- 2z2-Callaway Comanche Peak Diablo Canyon Palo Verde South Texas Project Wolf Creek

TXX-04086 Page 2 of 2 Sincerely, TXU Generation Company LP By:

TXU Generation Management Company LLC, Its General Partner Mike Blevins By: R do2¢60w Rafael ores Vice President of Nuclear Operations GLM/gm Enclosure c -

B. S. Mallett, Region IV W. D. Johnson, Region IV M. C. Thadani, NRR Resident Inspectors, CPSES

r En6losure to TXX-04086 NRC FOR.MI 366 U.S NUCLEAR REGUtLATORY COMMISSION APPROVED BY OMB NO. 31504 104 (7-2001)

EXPIRES 07131/2004

, the NRC may not conduct or sponsor. and a peon is not required to respond to. the information collection.

Facility Name (I)

Docket Number (2)

Page (3)

COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 05000445 1 OF 6 Ttle (4)

CONDITION PROHIBITED BY TECHNICAL SPECIFICATIONS Event Date 5 LER Number (6)

Repofl Date (7)

Other Facilities Involved (8)

Month Day Year ye Sequential Revision Month Day Year Facility Name Docket Numbers Number Number CPSES UNIT 2 05000446 04 02 04 04 002 00 05 28 04 05000 Operating I This repon is ubrittel purmiant tothef rementuofl10CFR (Ch ek alt that apply)

(I 1 Etode(9) 6 7

202201(b) 202203(aX3X)

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20.2201 (d) 20.2203(aY3Yiil 50.73(aV21XiilA) 50-73(a)(2viiiv(A) 20.2203(a)(1) 20.2203(a)X4) 50.73(a)X2)ii)XB)

I 50.73(aX2)Xviii)XB) 20.2203(aX2Xi) 50.36(cX2Xi)XA) 50.73(a)X2Xiii)

I 50.73(aX2)Xix)A) 20.2203(a)X2Xiii)

- 50.36(cXl2i) 50.73(aX2)Xv)XA) 50 7.72(a) 4x 20.2203(a)X2Xiii) 50.36(c)I(2X)

__50.73(a)X2XivXA)

S73.7 1(aX2X4) 20.2203(a)X2)iv) 50.46(a)X3)ii)

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I20.2203(a)X2)v) 50.73(a)X2)Xi)A)

__50.73(aX2)XvX)Q OTHER II20.2203(a)X2Xvi)

IX I50.73 (a)X2)XiXB)

I-50.73(aX2XvD)

Specify in Abstract below or I__III__________-

__I___

__I in NRC Formn 366A Licensee Contact For This LEK (12)

I.

I I

YES I (If YES. complete EXPECTED SUBMISSION DATE)

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On April 2, 2004, Comanche Peak Steam Electric Station Unit 1 was in Mode 6 during the tenth refueling outage and Unit 2 was in Mode 1 operating at 99.2 percent power. At 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />, while reviewing proposed changes to response times in the Technical Requirements Manual, it was discovered that Technical Specification (TS) Surveillance Requirement (SR) 3.3.5.3 had not been completed within the required frequency for all of the functions specified in TS Table 3.3.5-1.

TXU Generation Company LP (TXU Energy) believes that the cause of the event was less than adequate review of a change to the TS SR 3.3.5.3 frequency due to personnel errors in the review process and inadequate procedure referencing. Corrective actions include performing a risk assessment on Unit 2, performing the required TS surveillance tests on Unit 1, and issuing a Lessons Learned.

All times in this report are approximate and Central Standard Time unless noted otherwise.

INKL Ui-t.5u m %f(7-ZWI)

Enclosure to TXX-04086 NRC FORMI 366A U.S. NUCLEAR REGULATORY CO.M.MISSION (1.2001)

LICENSEE EVENT REPORT (LER)

Fality Name (I)

Docket LER Number(6)

Page(3)

Yearii Smeiuni Reasson COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 05000445 Numbe Number 050045 04H_ 002 _

00 I2 OF 6

NARRATIVE

(If more spae isrequired use dditional copies of SUMMARY OF THE EVENT, INCLUDING DATES AND APPROXIMATE TIMES Technical Specification (TS) 3.3.5 covers a number of undervoltage functions depicted in TS Table 3.3.5-1, including preferred and alternate offsite source bus undervoltage, 6.9 kv bus loss of voltage and degraded voltage, and 480 degraded and low grid undervoltage functions. SR 3.3.5.3 specifies the performance of a channel calibration on the Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation listed in TS Table 3.3.5-1 every 18 months. SR 3.3.5.4 requires verification that the LOP DG start Engineering Safety Features (ESF) response times are within limits every 18 months on a staggered test basis. The allowable values for the undervoltage relay setpoints are contained in TS Table 3.3.5-1, and the response time values are contained in Technical Requirements Manual (TRM) table 13.3.5-1.

The TS definition for a channel calibration specifies in part "the CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY." The Bases for SR 3.3.5.3 specifies in part "A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy."

NRC FOR.P-366A (1.2001)

.En6losure to TXX-04086 NRC FORNM 366A U.S. NUCLEAR REGULATORY COMMISSION (1-2001)

LICENSEE EVENT REPORT (LER)

Facility Name (I)

Docket LER Number (6)

Page(3)

Year Sequential Revision COMANCHE PEAK STEAM ELEC5RIC STATION UNIT I is Number um N

OF 6 NARRATIVE (If more spwe is required use additional copies of (If more spac I required, use addional copies of (If more space. requred use additional copies of NRC Fono 366A) (17)

C.

SAFETY CONSEQUENCES AND IMPLICATIONS

The seven affected functions on Unit 1 were verified successfully by performing the required TS channel calibrations during the recently completed tenth refueling outage. The seven affected functions on Unit 2 will be verified via TS channel calibrations prior to completion of the eighth refueling outage. As required by TS SR 3.0.3, an evaluation was performed that determined that the impact of these missed surveillances on plant risk is very small, thus extending the surveillance to the end of the current cycle for Unit 2 is not risk significant.

All of the affected channels that have been tested demonstrated that the channels would have performed their intended safety function, if required. This is consistent with the historical performance of this type of relay at CPSES, where less than one percent of the relay settings were found to be beyond the allowable value. There were no safety system functional failures associated with this event.

Based on the above, it is concluded that this event did not adversely impact the safe operation of CPSES or the health and safety of public.

IV.

CAUSE OF THE EVENT

TXU Energy believes that the cause of the event was less than adequate review of a change to the preventive maintenance database frequency for these Agastat timing relays due to personnel errors in the review process and because of inadequate procedure referencing. As previously discussed, a Technical Evaluation was generated in 1994 to answer a question which had been raised related to SR 3.3.5.3 and SR 3.3.5.4. Personnel involved had less than adequate knowledge of the requirements of the procedure for TS questions and, therefore, the procedure governing review and approval of this type of change was not followed. In addition, the procedure governing Technical Evaluations did not prohibit, address, or reference to the correct procedure for questions regarding TS. As a result, personnel with a more detailed knowledge and understanding of the definition and scope of a "channel calibration" with respect to TS were not formally part of the review. Those involved in the review arrived at the wrong conclusion.

11-1. 1-11 ranruesFodI-l

, En6losure to TXX-04086 NRC FOIC^t 366A V..

N UCLEAR REGULATORY COMMISSION (1.2001)

LICENSEE EVENT REPORT (LER)

Facility Name (I)

Docke LER Numbe (6)

Page(3)

Yea Seclucal Revision COMANCHE PEAK STEAM ELECTRIC STATION UNIT I 05000445 N04mer0 H

00 6 OF 6 NARRATIVE (If more space is required. use additional copies of NRC Form 366A) (17)

TXU Energy believes that the Technical Evaluation would have received an adequate review, reached the correct conclusion, and this event would not have occurred had the correct review process, as required by the procedure that was in effect at the time, been followed.

V.

CORRECTIVE ACTIONS

The seven affected functions on Unit 1 were verified by successfully performing the required TS channel calibrations during the recently completed tenth refueling outage.

The seven affected functions on Unit 2 will be verified via TS channel calibrations prior to completion of the eighth refueling outage. Per TS SR 3.0.3, an evaluation was performed that determined the impact of these missed surveillances on plant risk is very small, thus extending the surveillance to the end of the current cycle for Unit 2 is not risk significant.

In accordance with the CPSES Corrective Action Program, the following actions will be taken:

1. A Lessons Learned describing this event will be issued to Regulatory Affairs, Engineering, Maintenance, and Operations personnel.

2. Training will consider adding this event to the TS training modules operating experience module or other appropriate locations for personnel needing a better understanding of "channel" and "channel calibration" as used within TS.

3. A review will be conducted to ensure that previous changes to the TS scheduling database did not extend the test frequencies for electrical components beyond the TS requirements.

4. The Corrective Action Program procedure will be revised to clarify that any question involving the meaning of TS requirements must be referred to Regulatory Affairs for resolution.

VI.

PREVIOUS SIMILAR EVENTS

There has been one other missed surveillance event in the last two years (see LER 446/02-002). However, the details/causes are sufficiently different from the event described in this LER such that the previous corrective actions could not have prevented this event.