IR 05000445/1997020
| ML20203A711 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/19/1998 |
| From: | Tapia J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| 50-445-97-20, 50-446-97-20, NUDOCS 9802240098 | |
| Download: ML20203A711 (4) | |
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SUBJECT:
NRC INSPECTION REPORT 50-445/97-20; 50-446/97-20
Dear Mr. Terry:
Thank you for your letter of February 13,1998; in response to our letter and Notice of Violation dated January 16,1998. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will l-
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be maintained.
Sincerely, l
oseph I. Tapia, Chief Project Branch A Division of Reactor Projects Docket Nos.: 50-445 50-446 License Nos.: NPF-87 NPF-89 cc:
Mr. Roger D. Walker TU Electric Regulatory Affairs Manager P.O. Box 1002 Glen Rose, Texas. 76043 l
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9802240098 980219 PDR ADOCK 05000445 iie e r..
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TU Electric-2-
- Juanita Ellis
. President - CASE 1426 South Polk Street-Dallas, Texas 75224 TU Electric Bethesda Licensing 3 Metro Center, Suite 610 Bethesda, Maryland 20814
~ George L. Edgar, Esq.
Morgan, Lewis & Bocklus 1800 M. Street, NW
- Washington, D.C, 20036
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G. R. Bynog, Program Manager /
Chief Inspector Texas Department of Licensing & Regulation
- Boiler Division P.O. Box 12157, Capitol Station -
Austin, Texas 78711 Honorr ble Dale McPherson County Judge P.O. Box 851
- Glen Rose, Texas 76043 Texas Radiation Control Program Director 1100 West 49th Street Austin, Texas; 78756
= John Howard, Director Environmental and Natural Resources Policy Office of the Governor -
P.O. Box 12428 Austin, Texas 78711-
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TU Electric-3-FEB I 91998 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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Log # TXX 98024 C
File # 10130
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nlELECTRIC IR 97*20 Ref. # 10CFR2.201 c.ww February 13, 1998 Senior Mce Presidens
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U. S. Nuclear Regulatory Commission Attn:
Document Control Desk
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Washington, D.C. 20555
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u SUBJECT:
COMANCHE-PEAK STEAM ELECTRIC STUION (CPSES)
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DOCKET NOS. 50 445 and 50 446
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NRC INSPECTION REPORT NUMBERS 50 445/97 20 and 50 446/97 20 RESPONSE TO NOTICE OF VIOLATION REF:
1) TU Electric letter logged TXX 97250 from Mr. C. to the NRC dated November 24, 1997 2) TU Electric letter logged TXX 97262 from Mr. C. to
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the NRC dated December 10, 1997
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3) TV Electric letter logged TXX 97244 from Mr. C. to the NRC dated December 10, 1997 Gentlemen:
TU Electric has reviewed the NRC's letter dated January 16, 1998, concerning the ins)ections conducted by the NRC Resident Inspectors during the period of Octo)er 12 through Noventber 22, 1997.
Attached to the report was-a-Notice of Violation.
Via Attachment 2, TU Electric hereby responds to the Notice of Violation (50 446/9720 01, 50 446/9720 02, and 50 446/9720 04).
As noted in Attachment 1, this communication contains updates of commitments previously made to the NRC via references 1, 2, and 3.
3 S-O ? l l CONtANCHE PEAK STEAM ELECTRIC STATION P.O. Dos 1002 Glen Rose,Tetas 7toO.1002 L
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TXX 98024 Page 2 of 2 P
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Should you have any comments or require additional information, please do not hesitate to cont:tet Gary Herka at (254) 897 6613 to coordinate this effort,
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Sincerely
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C, L. Te GLH:g1m Attachments cc: Mr. E. W. Herschoff, Region IV
Mr. J. I. Tapia, Region IV
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Resident Inspectors
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Mr. T. J. Polich, NRR
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Attachment 1 to TXX 98024 Page 1 of 1 List of Commitments This communication contains the following commitments which will be completed as noted:
s CDF Number Commitment 27119 Similar ptocedure revisions for Unit I will be corpleted prior to entering Mode 6 for the next Unit i refueling outage.
27116 Integrated plant operating procedures. IP0 005A and B will l
be revised by March 15, 1998, to add appropriate provisions l.
to establish temperature and pressure conditions durinu cooldown which will not unnecessarily chall:nge LTOP
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actuation.
27123 Based cn the unlikely potential. of finding gaps in the Unit 1 containment sum) trash racks support structures which could exceed the )ounding' size, and therefore affect operability of the system. Unit 1 will be inspected prior to startup after the next refueling _ outage.
The CDF number is used by TV Electric _for. the internal tracking of CPSES commitments.
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Attachment 2 to TXX 98024 Page 1 of 5 RESPONSE TO THE NOTICE OF VIOLATION RESTATEMENT OF THE VIOLATION (50 446/9720 01)
A, 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by instructions of a type appropriate to the circumstances, Contrary to the above. Procedure IP0 005B, " Plant Cooldown from Hot Standby to Cold Shutdown," Revision 2, was not appropriate to the circumstances in that the procedure did not require that pressure be maintained below the reactor coolant system pressure and temperature limits specified in Technical Data Hanual TDH 301 B. "RCS Temperature
& Pressure limits," Revision 5.
As a consequence, on October 25, 1997, both power operated relief valves opened when pressure was allowed to remain above the limit.
RESPONSE TO THE VIOLATION (50 446/9720 01)
TU Electric accepts the violation, the response as requested is provided below (TU Electric initially addressed this event via reference 1):
1.
Reason for Violation TV Electric believes that the reason for the violation was less than comprehensive reviews of procedure 190 000B, " Plant Cooldown from Hot Standby to Cold Shutdown" during the initial preparation and subsequent.mvisions of the procedure, 2.
Corrective Steus Taken and Results Achieved Once Reactor Coolant System (RCS) pressure was below the corresponding pressure setpoint for the Low Temperature Overpressure Protection (LTOP) power operated relief valves (PORVs), the operator took manual control and closed the valves terminating the RCS depressurization.
The operator closed the valves to limit the discharge of RCS inventory to the pressurizer relief tank and over concern for personnel within the containment building. RCS parameters were stabilized at 340'F and 500 psig.
The PORVs performed as required.
3.
Corrective Actions Taken to Preclude Recurrence Integrated Plant Operating procedures IP0 005A and B will be revised by March 15, 1998, to add appropriate provisions to establish temperature and pressure conaitions during cooldown which will not unnecessarily challenge LTOP actuation.
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Date of Full Como11ance TU Electric will be in full compliance by March 15, 1998.
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Attachment 2 to TXX 98024 Page 2 of 5 RESTATEMENT OF THE VLOMT108 (50 446/9/20 02)
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Technical Specification 3.9.4, " Containment Building Penetrations,"
states, in part. that, during core alterations, a minimum of one door in the personnel airlock is capable of being closed and that each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be closed.
Contrary to the above, on November 10, 1997, during Unit 2 core alterations, the: containment airlock pressure equalization valves for both personnel airlock doors were open and were not capable of being closed. This provided direct access fron, the containment atmosphere to the outside atmosphere.
RESPONSE TO THE VIOLATION (50 446/9720 02)
TU Electric accepts the violation, the response as requested is provided below (TV Electric initially addressed this event via reference 3):
1.
Reason for Violation TV Electric believes that the reason for the violation was less than adequate procedures governing Personnel Airlock (PAL) operation and containment integrity verification related to the PAL du-ing refueling operations.
The CPSES Unit 2 PAL operating procedure only allows proper operation of the equalization valves if the door is opened end closed utilizing a singular method.
The acceptance criteria for Unit 2 PAL operability does not specifically require verification oi'
hydraulic equalization valve position prior to declaring the Unit 2 PAL operable.
2.
Corrective Steos Taken and Results Achieved The hydraulic equalization valve for the outer door was closed, the
_ positions of the other equalizing valves (both manual and hydraulic)
were. verified, and the outer door was determined to be capable of closing and maintaining containment integrity in accordance with Technical Specifications. The containment integrity surveillance required by the Technical Specifications for refueling operations was reperformed.
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Corrective Actions Taken to Preclude Recurt.enta The operating procedure for the Unit 2 PAL has been changed to include instructions for o)eration of the airlock such that either door can be closed with or wit 1out electrical power and the associated equalizing
. valves for the door will be closed or verifien to be closed prior to considering the containment closed / secure. The refueling containment integrity verification procedure for CPSES Unit 2 has been revised to
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Attactw nt 2 to TXX 98024 Page 3 of 5 require that all of the equalizing valves for a PAL door are verified closed or capable of being closed prior to crediting that door as capable of closure for containment closure purposes.
Similar procedure revisions for Unit I will be completed prior to entering Mode 6 for the next Unit 1 refueling outage.
4.
Date of Full Como11ance TU Electric is in full compliance. As noted above, procedure revisions for Unit I will be completed prior to entering Mode 6 for the next Unit I refueling outage.
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Attachment 2 to TXX 98024 Page 4 of 5 RESTATEMENT OF THE VIOLATION (50 446/9720 04)
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10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Actions,"
requires, in part, that conditions adverse to quality, such as nonconformances, be promptly identified and corrected.
On November 4,1994, the licensee identified structural gaps in both Unit 2 emergency core cooling sumps that exceeded the Final Safety Analysis Report descri) tion of 0.115 inches. On November 12, 1994, the licensee completed Worc Orders 1 94 078046 00 and 1 94 078047 00, which were issued to identify and repair any gap larger than 0.115 inches.
Contrary to the above, 16 gaps which were conditions adverse to quality were not promptly identified and corrected in that eight gaps previously identified in 1994 and eight additional gaps that exceeded the Final Safety Analysts Report specification of 0.115 inches were identified in the Unit 2 emergency core cooling sumps on November 8, 1997.
RESPONSE TO THE VIOLATION (50 446/9720 04)
TU Electric accepts the violation, the response as requested is provided below (TV Electric initially addressed this event via reference 2):
1.
Reason for Violation Although the work and design change documents for the corrective actions taken during the first refueling outage for Unit 2 in 1994 were closed, the actual completed actions were determined to have been incomplete with respect to the defined scope of work in the corrective action documents because work instructions (which included Design Change Notices and Work Orders) were not fully implemented, Some previously identified gaps remained uncorrected, some identified gaps.
were not completely closed, and some new gaps were found. Gaps that communicate through the containment sump trash rack support structures were difficult to identify because gaps had indirect paths through the structure. Additionally, for this unique condition, the work instructions may not have provided the appropriate level of detail within the work documents to ensure that all gaps were s erected.
This situation may have also been impacted due to less tun effective-coordination of a work activity identified near the end of the refueling outage. Had the original work and design change documents provided more detailed directions for this unique condition, these corrective actions should have been fully implemented.
As part of preplanning, work instructions are required to provide sufficient detail to complete activities.
Furthermore, design change documentation should provide sufficient details to fully describe the
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change. Audits and surveillance of design changes and work planning i
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are provided by the Nuclear Overview Department.
Generic or i
programmatic problems have not been identified with these programs, i
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In addition, an NRC inspection of the CPSES corrective action program i
i was recently conducted (see NRC-Inspection Report 50 445(446)/97 12).
The results of this inspection found that corrective action and self
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assasswent programs at CPSES are functioning well and are adequately j
supporting the safe operation of the plant. Therefore, this condition i
is determined to be an isolated incident because of the unique
conditions related to this emergent work, j
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Corrective Steos Taken and Results Achieved l
Immediate corrective actions were taken to ensure that this condition does not interact with the condition reported in LER 445/97 008 00 to
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prevent ECCS recirculation in the event of an accident. The gaps in
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the Unit 2 containment sump trash racks were repaired, inspected, and engineering verified to assure the work was satisfactorily completed
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during the current Unit 2 refueling outage.
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Incomplete work in the Unit I containment sump trash rack support
structures is not expected since Unit I corrective action was performed as a scheduled activity during the fourth refueling outage
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for Unit 1.
Based on the unlikely potential of finding gaps in the
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Unit I containment sump trash racks support structures which could
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exceed the bounding size, and therefore affect operability of the
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system. Unit I will be inspected prior to startup after the next
i refueling outage,
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Corrective Actions Taken to Preclude Recurrence l
TU Electric engineering personnel.have reviewed any possible generic implications of this condition and believe it to be an isolated occurrence because of the unique conditions, A sample review of
comparable emergent and unique 1994-work documents implemented during the first refueling outage of Unit 2 related to completion of i
corrective actions was performed to determine if the appropriate level
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of detail was provided to the personnel for implementation and appropriate follow up review criteria were provided to ensure proper
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l completion of the job such that the identified condition was fully addressed.
The results indicated that the appropriate level of detail
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was provided to the responsible work organization, and that
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appropriate follow up criteria in the way of testing and acceptance i
criteria was provided to ensure the proper completion of the corrective action. Furthermore, since 1994, organizational changes
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have occurred which provide for increased engineering ownership of the
--design of CPSES such that matters of similar urgency and-uniqueness would receive additional assurance that corrective actions are fully addressed.-
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Date of Full Como11ance
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-TU Electric is in full compliance.
As noted above. the Unit 1 containment sump trash racks support structures will be inspected prior to startup after the next refueling outage.
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