IR 05000445/1996017
| ML20148C349 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/12/1997 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| 50-445-96-17, 50-446-96-17, NUDOCS 9705150352 | |
| Download: ML20148C349 (4) | |
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l t** "' C ut UNITED STAT ES p
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REGloN IV
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611 RY AN PLAZA DRIVE. SUITE 400
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AR LINGioN, T E X AS 76011-8064
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MAY I 21997 i
j Mr. C. L. Terry
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TU Electric j
Group Vice President, Nuclear l
l ATTN: Regulatory Affairs Department P.O. Box 1002 Glen Rose, Texas 76043 l
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l SUBJECT: NRC INSPECTION REPORT 50-445/96-17;50-446/96-17 I
Thank you for your_ letter of April 14,1997, in response to our letter and Notice of
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Violation dated March 7,1997. We have reviewed your reply and find it responsive to the l
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j concerns raised in our Notice of Violation We have noted your concern pertaining to the
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length of time between events and your reference to NUREG-1600 " General Statement of
Policy and Procedures for NRC Enforcement Actions," Section Vll.B 2.(b). In a followup
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. telephone conversation on May 9,1997, we verified that you intended to reference i
i Section Vll.B.1.(b). This Section is not applicable in this case because the subject violation I
was not licensee identified. We will review the implementation of your corrective actions l
during a future inspection to determine that full compliance has been achieved and will be l
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l Sincerel,
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Th mas P. Gwynn Dir tor i
Division of Reacto ject
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Docket Nos.: 50-445
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50-446
' License Nos.: NPF-87 EJ000 i
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l 9705150352 970512
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PDR ADOCK 05000445 i
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.i TU Electric 2-
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cc:
Mr. Roger D. Walker
TU Electric
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Regulatory Affairs Manager l
P.O. Box 1002
l-Glen Rose, Texas 76043 i
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i Juanita Ellis
I President - CASE
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1426 South Polk Street I
Dallas, Texas 75224
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j TU Electric l
Bethesda Licensing
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3 Metro Center, Suite 610
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Bethesda, Maryland 20814 l
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George L. Edgar, Esq.
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l Morgan, Lewis & Bockius 1800 M. Street, NW l
Washington, D.C. 20036
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l G. R. Bynog, Program Manager /
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Chief Inspector
Texas Department of Licensing & Regulation l
Boiler Division P.O. Box 12157, Capitol Station Austin, Texas 78711 Honorable Dale McPherson County Judge P.O. Box 851 Glen Rose, Texas 76043 Texas Radiation Control Program Director 1100 West 49th Street Austin, Texas 78756
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John Howard, Director Environmental and Natural Resources Policy Office of the Governor
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P.O. Box 12428 i
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O MAY I 21997
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TU Electric
bec to DCD (IE01)
bec distrib. by RIV:
Regional Administrator Resident inspector (2)
DRP Director DRS-PSB Branch Chief (DRP/A)
MIS System Project Engineer (DRP/A)
RIV File Branch Chief (DRP/TSS)
DOCUMENT NAME: R:\\_CPSES\\CP617AK.ATG To receive copy of document, indicate in box: "C" = Copy without enclosures
"E" = Copy with enclosures "N" = No copy C:DRP/A D:DRP lJJ l
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RAKopriva;cQ y JITapia Qlj TPGwynn ( I"f
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05/ q /97 V
05/1 /97I; 05/ /y/97 L
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OFFICIAL RECORD COPY
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MAY I 21997
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TU Electric-3-bec to DCD (IE01)
bec distrib. by RIV:
Regional Administrator Resident inspector (2)
DRP Director DRS-PSB Branch Chief (DRP/A)
MIS System Project Engineer (DRP/A)
RIV File Branch Chief (DRP/TSS)
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DOCUMENT NAME: R:\\_CPSES\\CP617AK.ATG l
To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy C:DRP/A D:DRP ly)
l PE:DRP/A
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RAKopriva;crtd,/
JITapia Q l r
j TPGwynn ( Pf 05/ q /97 V
05/1/97 / l 05/ /y/97 L
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OFFICIAL RECORD COPY
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MM Log # TXX-97061 l
4 File # 10130
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C IR 96-04
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Ref. # 10CFR2.201 i
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i April 14,1997 (~~~h @ [f fl *gj i
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C. Lan Terry cw m rmano J
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V. S Nuclear Regulatory Commission M i 51997
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Attn:
Document Control Desk
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Washington..D.C.
20555
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REGION T/
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
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DOCKET NO. 50-445 and 50-446 NRC INSPECTION REPORT NOS. 50-445/96-17 and 50-446/96-17 i
RESPONSE TO NOTICE OF VIOLATION
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l TV Electric has reviewed the NRC's letter dated March 7, 1997, concerning
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i the inspection conducted by your staff which was completed on j
February 1, 1997.
The subject inspection report enclosed a Notice of Violation.
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The NRC inspection report 50-445(446)/96-17 states that the corrective i
actions taken to prevent repetition of the April 4,1993. Unit 2 grid
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synchronization event were not effective.
TU Electric wishes to note that
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the 1993 event transpired two years prior to the current violation, and.
during that time no violations have occurred which could have reasonably i
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been expected to have been prevented by our corrective actions for the 1993 event.
NUREG-1600, " General Statement of Policy and Procedures for NRC
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l Enforcement Actions " at S VII.B.2.(b) for " mitigation" appears to accept
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l two years or wo inspection periods in which no violations occur that could l
have been prevented by licensee's corrective action as a period that substantiates effective corrective actions.
Given the referenced NUREG, TV Electric's corrective actions for the 1993 event appear to be effective.
Notwithstanding, via Attachment 1. TU Electric accepts the violation and is responding to the specific Notice of Violation (445/9617-01).
l The response to the subject inspection report was due on April 7, 1997:
however, TU Electric requested an extension until April 14, 1997.
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extension was discussed with Mr. Larry Yandell of the NRC Region IV staff.
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i en-08%S
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P.O Box 1002 Glen RoseTexas 7600
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TXX-97061 Page 2 of 2 Should you have any comments or require additional information, please do not hesitate to contact Obaid Bhatty at (817)-897-5839 to coordinate this effort.
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Sincerely, l
e,3, Q C. L. Terry
- By:
Roger D. Walker
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Regulatory Affairs Manager
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Attachment Mr.Mh (K84010rjtV cc:
Mr. J.
a egion~IV'
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Resident Inspectors
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Attachment to TXX 97061 Page 1 of 3 RESPONSE TO THE NOTICE OF VIOLATION RESTATEMENT OF THE VIOLATION (50-445(446)/9617 01)
10 CFR Part 50. Appendix B. Criterion XVI, states in part that measures shall be established to assure that significant conditions adverse to
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quality are promptly identified and corrected and that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above the corrective actions taken to prevent repetition of a 1993. Unit 2 grid synchronization event were not effective. The resultant reactor coolant system transient resulted in plant operation
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below the minimum temperature for criticality. A similar event involving Unit 1. occurred November 16, 1996
RESPONSE TO THE VIOLATION (50 445(446)/9617-01)
TV Electric accepts the violation and the requested information is provided herein.
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Reason for Violation Event description:
On November 16. 1996 Comanche Peak Steam Electric Station (CPSES)
Unit I was in Mode 1 after completing its refueling outage number 5 (1RF05).
Reactor power was between 6% and 10%.
Shift Operations completed the preparatory steps to synchronize the main generator according to procedure IP0-003A " Power Operations" step 5.1.28.
The task was classified as an infrequent evolution.
The Unit Supervisor (US) performed a general pre-job brief on the evolution
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for synchronizing the main generator and initiating loading.
The brief discussed the governing procedure.
Neither the US nor the B0P Operator had plant experience initiating a generator load with a new core.
The US had performed the task once at core mid-life. The B0P Operator experience was based on simulator training during initial license training.
The B0P Operator!s task was to establish turbine speed at 1800 RPM, place the generator voltage regulator in service, energize the generator synchroscope and adjust turbine speed to obtain synchroscope rotation at 2 4 rpm in the fast direction, close one generator output breaker when the synchroscope reached the 12 o' clock
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Attachment to TXX 97061 Page 2 of 3 position, raise the speed reference device until a positive increase
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in turbine megawatts (MW) was observed, adjust reactive load by raising the generator voltage regulator reference value, then loading the min turbine to between 30 MW and 100 MW by raising the speed refe.
e device. These actions were outlined in procedure IP0-003A step 5.1.29.
At approximately 9:22 p.m., on November 16, 1996, after closing the i
generator output breaker, the BOP Operator started initiating a load increase by depressing the speed reference device. About 10 feet i
away, the US was observing the plant computer monitor for MWs. After approximately 15 seconds the 80P Operator noticed no MW increase.
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should be noted that on the simulator (as experienced by the BOP Operator) the effects of the push-button speed reference device were seen within a few seconds.
Since the BOP Operator was concerned about having a generator reverse power trip, he depressed the MW raise button on the speed reference device once more and watched for a MW increase.
After approximately 10 seconds, again the BOP Operator noticed no MW increase and depressed the MW raise button one more time.
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l After several seconds, load began responding to the B0P Operator's action.
MW load rapidly increased to about 150 MW with a
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corresponding Reactor Coolant System (RCS) response and alarms.
RCS temperature, pressure, and pressurizer level decreased rapidly to below 551*F the minimum temperature for critical operation per Technical Specification (TS) 3.1.1.4, 2219 psi, and 17% level respectively.
Chemical and Volume System (CVCS) letdown flow l
automatically isolated due to low pressurizer level.
l The US directed reduction of MW load. The B0P Operator lowered turbine load to about 40 MW for the next three minutes.
In parallel, rod withdrawal was initiated in increments to restore RCS temperature. The extra R0s took control of Steam Generator Le el v
Control (SGWLC) and rod control and monitored RCS parameters.
At approximately 9:30 p.m. on November 16, 1996, normal RCS parameters were restored, the TS 3.1.1.4 action statement was exited and CVCS letdown was restored.
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TV Electric Analysis:
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TU Electric believes that the corrective actions for the previous event were effective, this conclusion is based on the several
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successful restarts since the 1993 event.
However, the corrective i
actions for the previous events did not adequately consider the consequences of having a person whose experience and training are solely based on the simulator perform a sensitive task without being directly observed by a person experienced in the evolution. While Operating procedure IP0-003A contained cautions and direction on turbine loading as a result of the previous event, simulator and classroom training did not adequately prepare Operators to anticipate and respond to potential transient situations encountered during
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i beginning-of-life startups.
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' Attachment to TXX-97061
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Page 3 of 3
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Corrective Steos Taken and Results Achieved The US directed the reduction of turbine load and Main Feedwater
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flow.
The BOP Operator lowered turbine load to about 40 MW. At I
approximately 9:30 p.m., on November 16, 1996. normal RCS parameters were restored, the TS 3.1.1.4 action statement was exited and CVCS
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letdown was restored.
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Corrective Actions Taken to Preclude Recurrence The applicable procedure which provides guidance for synchronizing the main generator to the grid has been further enhanced to include
cautions for beginning of life operations to minimize temperature
transients induced in the RCS. A Simulator Action Request (SAR) was l
initiated and implemented to add a new temperature control (TC)
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malfunction to allow control of turbine load using the Speed i
Reference Device. The Turbine Generator model was modified to
provide an approximate 20 second time delay from the time the speed reference raise push-button is depressed until the time load is
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actually increased. All crews have been trained on this event.
TV Electric believes that these action will minimize the potential for j
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Date of Full Comoliance
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TU Electric is in full compliance, i
5, Additional Information CPSES TS 3.1.1.4 states that the RCS lowest operating loop temperature shall be greater than or equal to 551*F. The required action is to restore tem)erature within its limit within 15 minutes or be in Hot Standby wit 11n the next 15 minutes.
During this incident. CPSES was within the TS limiting condition for operation as RCS temperature was restored to greater than 551*F in less than 15 minutes.
l CPSES has been analyzed for a number of events which postulate an
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increase in heat removal from the RCS by the secondary system. This event is bounded by the more severe limiting RCS cooldown events
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presented in FSAR Section 15.1 " Increase in Heat Removal by the Secondary System." Had the turbine loading continued, the reactor l
would have eventually been tripped by the High Power Range Neutron
Flux - Low reactor trip function prior to the time that any fuel damage would have been predicted.
Hence, this transient had no i
impact on the public health and safety.
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