IR 05000445/1992060

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/92-60 & 50-446/92-60 on 930311

ML20036A362
Person / Time
Site:	Comanche Peak
Issue date:	05/04/1993
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 9305110130
Download: ML20036A362 (4)

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h UNITED STATES NUCLEAR REGULATORY COMMISSION

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611 RYAN PLAZA oRIVE, SUITE 400 i

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ARLINGTON, TEXAS 760118064 g

41993 Dockets: 50-445 50-446 Licenses: NPF-87 NPF-89 TV Electric ATTN:

W. J. Cahill, Jr., Group Vice President Skyway TowerNuclear Engineering and Operations 400 North Olive Street, L.B. 81 Dallas, Texas 75201 SUBJECT:

NRC INSPECTION REPORT 50-445/92-60; 50-446/92 60

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Thank you for your letter of April 8,1993 and Notice of Violation dated March

, in response to our letter 11. 1993.

find it responsive to the concerns raised in our NWe have reviewe j

otice of Violation.

review the implementation of your corrective actions du i We will r ng a future inspection to determine that full compliance has b maintained.

een achieved and will be

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Sincerely,

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x Bill Beach, Director W

Division of ReactorQrojects,

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i TU Electric j

v ATTN:

Roger D. Walker, Manager of Regulatory Affairs for Nuclear Skyway TowerEngineering Organization 400 North Olive Street, L.B. 81 Dallas, Texas 75201

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9305110130 930504 PDR ADOCK0500g5 G

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TV Electric-2-Juanita Ellis President - CASE 1426 South Polk Street Dallas, Texas 75224 GDS Associates, Inc.

Suite 720 1850 Parkway Place Marietta, Georgia 30067-8237 TV Electric Bethesda Licensing 3 Metro Center, Suite 610 Bethesda, Maryland 20814 Jorden, Schulte, and Burchette ATTN: William A. Burchette, Esq.

Counsel for Tex-La Electric Cooperative of Texas 1025 Thomas Jefferson St., N.W.

8ashington. D.C.

20007 Newman & Holtzinger, P.C.

ATTN:

Jack R. Newman, Esq.

1615 L. Street, N.W.

Suite 1000 Washington. D.C.

20036 Texas Department of Licensing & Regulation ATTN:

G. R. Bynog, Program Manager /

Chief Inspector Boiler Division P.O. Box 12157, Capitol Station Austin, Texas 78711 Honorable Dale McPherson

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County Judge P.O. Box 851 Glen Rose. Texas 76043 Texas Radiation Control Program Director 1100 West 49th Street Austin, Texas 78756 Deen L. Thero, President Quality Technology Company P.0. Box 408

• 201 West 3rd Lebo, Kansas 66856-0408

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MAY - 41993 TV Electric-3-bEEtWIDM8MIE01)Tfl l i i bcc distrib. by RIV:

J. L. Milhoan Resident Inspector (2)

DRP Section Chief (DRP/B)

Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS RIV File Project Engineer (DRP/B)

Section Chief (DRP/TSS)

DRS 100008

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E -4IE TU Electric-3-bcc to DMB (IE01)

bcc distrib. by RIV:

J. L. Milhoan Resident Inspector (2)

DRP Section Chief (DRP/B)

Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS RIV File Project Engineer (DRP/B)

Section Chief (DRP/TSS)

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Log # TXX-93150 PM File # 10130

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C IR 92-60

Ref. # 10CFR2.201 TUELECTRIC

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April 8',:1993- --

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u imam J. cahili, Jr.

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U. S. Nuclear Regulatory Commission Attn: Document Control Desk j

Washington. DC 20555 SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 NRC INSPECTION REPORT 50-445/92-60: 50-446/92-60 RESPONSE TO NOTICE OF VIOLATION REF:

1) TV Electric letter logged TXX-93001 from W. J. Cahill, Jr. to the NRC dated January 30, 1993 2)

NRC memorandum from James L. Milhoan, Region Administrator, Region IV to Thomas E. Murley, Director, Office of Nuclear Reactor Regulation, dated March 29, 1993 Gentlemen:

TV Electric has reviewed the NRC's letter dated March 11, 1993, concerning the inspection conducted by the NRC staff during the period December 6. 1992, through January 30, 1993.

This inspection covered activities authorized by NRC Operating License NPF-87 and Construction Permit CPPR-127.

Attached to the March 11, 1993, letter was a Notice of Violation.

TV Electric understands the concerns identified in the letter pertaining to the control and status of plant systems and abnormal operating procedures.

TV Electric believes the actions identified in the enclosed response to the Notices of Violation and the actions defined in Reference 1 provide additional assurance that system status and operating procedures are correct and are being properly maintained.,

A number of these actions were reassessed during the NRC Operational Readiness Assessment Team (ORAT)

inspection which occurred from March 24 through March 28, 1993.

Comments by the inspectors during the exit meeting on March 29, 1993, relevant to configuration control and procedure adequacy were positive.

TV Electric's assessment of these areas indicates that the enhanced controls have been effective.

The conclusions are supported by NRC Region IV's recommendation (Reference 2) that CPSES Unit 2 be issued a full-power operating license in which Region IV provides that the ORAT concerns have been satisfactorily addressed.

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TXX-93150 Page 2 of 2 The March 11. 1993, letter also identified commitments made by TU Electric

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during the January 29. 1993, exit meeting.

The commitments as stated in the

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letter are correct.

Valve lineup verifications on the Unit 2 safety-related systems were performed prior to entering Mode 6 and field verifications of the Unit 2 and common abnormal operating procedures were performed prior to entering specified operating modes.

TU Electric hereby responds to the Notice of Violation (NOV) in the attachraents to this letter, i

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Sincerely

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William J. Cahill. Jr.

By:

M Ro'ger"D. Walker Manager of Regulatory Affairs t

TRT:ds Attachments c - M J. L. Milhoan. Region IV

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Resident Inspectors. CPSES (2)

l Mr. T. A. Bergman, NRR

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Mr. B. E. Holian. NRR l

Mr. L. A. Yandell, Region IV

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Attachment 1 to TXX-93150

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Page 1 of 3

i VIOLATION A (445/9260-01)

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10CFR Part 50. Appendix B, Criterion V.-states..in part, that activities affecting quality shall be accomplished in accordance with procedures of a type appropriate to the circumstances.

Operations Department Administrative Procedure ODA-410. " System Status

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Control ' Revision 4. Section 6. states, in part, that the. documentation of the position of components other than that specified in the system status file will be maintained within the document controlling the activity that

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repositioned the component.

Contrary to the above, on December 30.'1992. several valves in the Chemical and Volume Control System were not in the positions specified by the document controlling the activity that repositioned the component.

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Response to Violation A

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(446/9260-01)

i TV Electric accepts the violation and the requested information follows:

1.

Reason for Violation In December 1992. TV Electric management had the Nuclear Overview Organization perform an independent investigation to determine how the valves,were positioned in the as-found condition.

The investigation identified seven cases of mispositioned valves or valves missing remote operator covers. The investigation found the following, a.

2-8471A CCP 2-01 Suction Valve (found closed) - The valve was closed during an authorized system flush.

An operator discovered the valve in the closed position after the flush had been completed but before the system was restored. Therefore, the valves position was explainable.

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2CS-8419, VCT Drain Valve (found open) - The valve was part of an authorized clearance which positioned it open.

However, the clearance did not require the valve to be restored in accordance with the 50P ' valve lineup position of. closed.

Therefore, the-valves position was explainable.

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Attachment 1 to TXX-93150 Page 2 of 3

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Remote Operator Valve Covers (found removed) - Although the c.

covers were removed, the investigation revealed the valves r

had not been mispositioned and the covers were removed as

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part of maintenance to find and correct. leakage.

2.

Corrective Actions Taken and Results Achieved The following corrective actions were initiated immediately following

the event:

A team was assembled from the Nuclear Overview Organization to 2.

perform an independent investigation of these events. The team was to determine if sufficient evidence existed to substantiate a l

generic concern of unauthorized manipulation of station

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components.

The investigation concluded that unauthorized l

i manipulation was not a generic concern relative to the events.

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A ONE Form and Plant Incident Report (PIR) were generated to document this event.

i A root cause analysis was performed by a l

Task Team. Task Team results are discussed throughout this response.

Valve lineups were performed for the following Unit 1 systems to c.

assure correct positioning with its operating procedure.

RHR Train A OPT-203A

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SI Train A OPT-204A CT Train A & B OPT-205A

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SSW Train A OPT-207A CCW Train A OPT-208A

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BA Flow Path OPT-202A ECCS/CVCS OPT-201A I

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Valve lineups were performed for CVCS in Unit 2 using the 50P.

3.

Corrective Actions to Prevent Recurrence The Task Team assembled to determine the root cause also a.

investigated valve mispositionings in seven other similar events in other systems.

.These events are discussed in Inspection Report 50-446/92-201 and had been documented on ONE forms.

The team concluded that the events were caused by 1) lack of thorough technical reviews of in-process work clearances, 2) lack of thorough impact reviews for clearances, 3) the need to promptly backout of a procedure when appropriate (for shift change, when problems are encountered, etc.). 4) failure to take appropriate operator action when inconsistencies are encountered.

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Attachment 1 to TXX-93150 Page 3 of 3 b.

The team also identified numerous contributing factors and short term and long term corrective actions.

The intent of the corrective actions was to correct all causes and contributing factors associated with the CVCS event and those identified in other systems.

In general, the corrective actions included providing feedback to the operations staff on lessons learned,

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increased monitoring of plant configuration changes, procedure enhancements, increased and enhanced communications, and a restatement by management to all responsible personnel concerning who has the authority to operate plant equipment.

Date When Full Comoliance Will Be Achieved Full compliance has been achieved.

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Attachment 2 to TXX-93150 Page 1 of 1 VIOLATION B (446/9260-02)

i Appendix B of 10CFR Part 50, Criterion V, states, in part, that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances and that procedures shall include appropriate acceptance criteria for determiaing that important activities l

have been satisfactorily accomplished.

i Contrary to the above, the licensee did not incorporate valves 2RH-0031 and 2RH-0032 into the valve lineup in Procedure SOP-102B,

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" Residual Heat Removal System," and, consequently, the valves * positions had not been verified on

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the valve lineup contained in the active system status file.

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r Resoonse to Violation B

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(446/9260-02)

l TV Electric accepts the violation and the requested information follows:

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Reason for the Violation The two valves had previously been identified on the valve lineup performed during Hot Functional Testing and noted as missing in the l

System Operating Procedure (50P).

However, the 50P was not revised to l

include these two valves because of a lack of communication between l

Startup and Operations.

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Corrective Action Taken and Results Achieved The Unit 2 System Operating Procedure (SOP) Valve lineup for Residual Heat Removal (RHR) was revised to include the two vent valves.

3.

Corrective Actions to Prevent Recurrence A comparison was made between 50P valve lineups and the system flow diagrams for the following systems:

i Residual Heat Removal, Chemical Volume Control (CVC) System Safety. Injection, Reactor Coolant, Station

Service Water, Containment Spray, and Auxiliary Feedwater.

The comparison identified minor discrepancies which have been corrected.

i In addition, a review was made of the valve lineups performed during Unit 2 Hot Functional testing to determine if there were any other valves that may not have been incorporated into system operating

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procedures.

The review indicated that'four vent valves in the CVC

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System were similarly identified.during Unit 2 Hot Functional testing.

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The associated SOPS have been revised to include these four valves.

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Date When Full Comoliance Will Be Achieved

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Full compliance has been achieved.

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Attachment 3 to TXX-93150

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Page 1 of 1 i

VIOLATION C c

(446/9260-03)

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Appendix B of 10CFR Part 50 Criterion XVI, states, in part, that measures a

shall be established to assure that conditions adverse to quality, such as I

deficiencies, are promptly identified and corrected.

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Contrary to the above, following the identification of abnormal operating procedure deficiencies on two separate occasions, the licensee did not

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identify and implement effective corrective actions regarding additional abnormal operating procedural deficiencies..Specifically, Procedure ABN-

i 104, " Residual Heat Removal System Malfunctions," directed the operator to

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manipulate valves in Unit 2 when the valve numbers referenced in the

procedure were applicable only to Unit 1.

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ResDonse to Violation C (446/9260-03)

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TU Electric accepts the violation and the requested information follows:

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Reason for Violation

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Unit 2 ABNs were written-based on their Unit 1 counter parts: however, controls to identify differences between the two units did not preclude the noted errors.

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Corrective Action Taken and Results Achieved A walkdown was performed to compare the ABN against the actual plant installations.

Identified discrepancies have been corrected.

3.

Corrective Actions to Prevent Recurrence Additional reviews and walkdowns of the Unit 2 and Common ABN procedures have been performed to verify that components used in the ABNs-are correctly identified and located by procedure.

The ABNs were divided into three groups (Mode 6. Mode 4 and Mode 2) for this. review depending on complexity and mode requirements.

Errors were corrected prior to the mode for which the applicable procedure was required.

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Date When Full ComDliance Will be Achieved Full compliance has been achieved.

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