IR 05000446/1992020
| ML20046C446 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/03/1993 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 9308110034 | |
| Download: ML20046C446 (5) | |
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trelTED STATES
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NUCLEAR REGULATORY COMMISSION CI
REGION IV
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50-445 50-446 Licenses:
NPF-87 NPF-89 IU Electric ATTN:
W. J. Cahill, Jr., Group Vice President Nuclear Engineering and Operations Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 SUBJECT:
NRC INSPECTION REPORT 50-446/92-201 Thank you for your letter of June 18, 1993, in response to our letter and Notice of Violation dated May 19, 1993. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation.
However, you indicate in your response to Notice of Violation A that the results of the surveillance activities have found satisfactory implementation of system lineup and status control. Our recent inspection activities, which were discussed in an exit meeting with Mr. J. J. Kelley on July 9 and will be documented in NRC Inspection Report 50-445/93-26; 50-446/93-26, have found a relatively high number of Operations Notification and Evaluation Forms reporting equipment mispositioning. This remains a significant area of concern. Although a reduction in personnel errors and associated mispositionings is evident, we do not consider this issue satisfactorily resolved and urge you to continue to focus efforts'toward improvement in this area.
We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincerely,
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A. Bill Beach, Dir c r
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Division of Reactor Proje ts cc:
(see next page)
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TU Electric ATTN: Roger D. Walker, Manager of Regulatory Affairs for Nuclear Engineering Organization Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Juanita Ellis President - CASE 1426 South Polk Street Dallas,- Texas 75224 GDS Associates, Inc.
Suite 720 1850' Parkway Place Marietta, Georgia 30067-8237
'TU 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.
Washington, 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.0. Box-12157, Capitol Station Austin, Texas 78711 Honorable Dale McPherson County Judge P.O. Box 851 Glen Rose, Texas 76043
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File # 10130
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IR 92-60
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Z IR 92-201
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Ref. # 10CFR2.201 TUELECTRIC 18,) 9 h June William J. Cahill, Jr.
Gremp Vk Presulent U.
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Nuclear Regulatory Commission f3 Attn: Document Control Desk
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Washington, DC 20555 i?
SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 NRC INSPECTION REPORT 50-446/92-201 RESPONSE TO NOTICE OF VIOLATION REF: 1)
TU Electric letter logged TXX-93150 from W.
J.
Cahill, Jr. to the NRC dated April 8,
1993 2)
NRC Inspection Report 50-446/92-201 Comanche Peak
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Operational Readiness Assessment Team Inspection
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dated March 9, 1993 Gentlemen:
TU Electric has reviewed the NRC's letter dated May 19, 1993, concerning the inspection conducted by the NRC staff during the period of January 4 through January 22, 1993.
Attached to the May 19, 1993, letter was a Notice of Violation (NOV) and a Notice of Deviation.
In accordance with the letter's request, TU Electric's response to Violations A and C are attached.
The letter dated May 19, 1993, requested that TU Electric docket the specific corrective actions taken to prevent recurrence for Violation 446/9260-01.
Those actions were defined in Plant Incident Report (PIR) 92-1663 which investigated a total of eight (8) events related to configuration control.
One event, mispositioning of CVCS valves, was discussed in Violation 446/9260-01.
Five (5) other events are discussed in Violations 445/92201-01; 446/92201-01.
Two events were not cited.
The specific actions taken to prevent recurrence to Violation
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,h TXX-93228 Page 2 of 2
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446/9260-01, which were generally described in the response are included in Attachment 1 in TU Electric's response to Violation A (445/92201-01; 446/92201-01).
Sincerely,
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William J.
Cahill, Jr.
TLH/ds l
Attachments c - Mr.
J.
L. Milhoan, Region IV Resident Inspectors, CPSES (2)
Mr. T.
A.
Bergman, NRR Mr.
B.
E.
Holian, NRR Mr. L. A.
Yandell, Region IV
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Attachment 1-to TXX-93228
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Page 1 of 5 t
(445/92201-01; 446/92201-01)
i A.
Criterion V of 10 CFR Part 50, Appendix B, requires that i
activities affecting quality shall be prescribed by procedures appropriate to the circumstances and shall be
accomplished in accordance with these procedures.
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Licensee Procedures ODA-410, " System Status Control",
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Revision 4; and STA-605, " Clearance and Safety Tagging",
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Revision 11, require that one of four methods be used to
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document component positions which are other than those i
specified in the system status file.
l Contrary to the above, from January 4-22, 1993, system and
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component alignment activities were not accott.plished in accordance with these procedures, as evidenced by the
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following licensee identified examples of components in
positions other than those specified in the system status
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file without additional documentation or justification.
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I 1.
From January 10-17, 1993, component cooling water drain i
Valves 2CC-136, 2CC-53, 2CC-163, 2CC-153, and 2CC-1039
were found open.
2.
On January 15, 1993, pressurizer relief tank drain Valve 1/2 8031 was found open.
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3.
On January 4, 1993, postaccident sampling system Valve 2WP-0254 was found open.
4.
On January 17, 1993, safety injection system instrument isolation Valve 1FI-0928B and its equalizing valve were found open.
5.
On January 14, 1993, two fire protection sprinkler isolation valves, XFP-114 and XFP-115, were found shut.
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l Attachment 1 to TXX-93228 j
Page 2 of 5 l
Response Violation A (445/92201-01; 446/92201-01)
TU Electric accepts the violation and the requested information f
follows:
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1.
Reason for Violation
In all of the events, individuals failed to provide or
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request thorough technical reviews of work documentation i
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and/or systems status documentation.
This common aspect, inadequate attention to detail, is considered the primary l
root cause.
The environment created by the total transition to operations programs, which included activities performed
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under the Startup and Operations programs, was a secondary
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cause.
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Events 2, 4 and 5 cited above were similar because more
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thorough technical reviews of clearances and ongoing work by Operations personnel may have prevented them.
During Event 2,
an activity was stopped in progress and was later l
forgotten.
Subsequent Operations activities related to the i-Reactor Coolant Drain Tank and Pressurizer Relief Tank indicated the valve 1/2-8031 had not been closed when the previous activity had been stopped.
During the.
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investigation of Event 4 it was discovered that new valves had been installed using a design change but. Operations
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personnel did not-establish the valves' positions after the l
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operating procedures were updated and issued.
During the-investigation of Event 5 it was discovered that Operations programs did not provide adequate controls for ensuring the
review of Procedure Change. Notices against system lineups.
Additionally, Operations personnel did not note the "as found" position of the two valves on the valve lineup discrepancy sheet.
Event 1 was caused by an inadequate impact review of a clearance and its revisions.
In addition, controls were not in place or were not followed which could have tracked system status and valve manipulations as they occurred.
These controls included updating clearances, using shift
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orders, following inplace procedures-for valve alignments, assessing the impact of final construction work on recently aligned systems and using computer methods to identify l
component status.
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Attachment 1 to TXX-93228 Page 3 of 5
The reason for the mispositioning of sample valve 2WP-0254
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(Event 3) was not clearly determined.
CPSES personnel believe the cause was a test procedure that initially positioned the valve but did not specifically restore the valve to the closed position as required.by the system
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operating procedure (SOP).
Rather it required restoration via a clearance release.
2.
Corrective Actions Taken and Results Achieved As previously stated, CPSES personnel investigated a number of configuration control events in PIR-92-1663 including the
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events identified in this violation.
The investigation was performed by a task team and was followed up by an independent review lead by Plant Overview personnel.
The PIR was closed on February 8, 1993.
The corrective actions listed in this section and in section 3 may apply to a single event, to more than one event, or to the event discussed in violation 446/9260-01.
o Operations personnel reviewed the Fire Impairment Log to determine if a Fire Impairment existed during the time the valves (XFP-0114 and 0115) were being installed up to the time the valves were repositioned
on 01/17/93.
The review determined that Fire Impairment 92-X-552 was in place from August 29, 1992 y
to October 27, 1992 for installation of valves
XFP-0114 and XFP-0115.
o OWI-103, " Locked Valve Verification", Unit 1 and Common lineups were verified and an audit was completed on 01/19/93.
Unit 2 was completed prior to Mode 6 (Initial Startup).
Operations personnel reverified selected safety related o
valve lineups for systems defined in IPO-001B, " Plant Heatup from Cold Shutdown to Hot Standby", to assure components were in proper configuration.
3.
Corrective Actions to Prevent Recurrence The following long term actions were taken to prevent recurrence of the cited events.
o Operations Support personnel formalized the method for Shift. Operations notification of required procedure upgrades based on plant configuration changes by revising ODA-207 " Guidelines for the Preparation and Revision of Operations Procedures."
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Attachment 1 to TXX-93228 Page 4 of 5 operations personnel issued a Lessons Learned which o
discussed the problems associated with not backing out
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of procedures for evolutions that have a problem.
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addition, Operations Management discussed procedure i
backout controls with the Unit Supervisor involved in
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Event 2.
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ODA-407, " Guidelines on Use of Procedures", and i
ODA-410 " System Status Control"-were changed via PCN to
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provide a method of documenting problems in the Unit
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Log to explain why a procedure / evolution was suspended
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and what action is needed to resume an activity.
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o Operations Management issued, via Shift Orders, a requirement that system realignments occur following
major rework or continued problems with system draining,
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Operations issued a Lessons Learned to clarify that the o
Senior Reactor Operator (SRO), when accepting a l
clearance, review the clearance and ensure the problems
are incorporated into the clearance and that the Plant j
Reliability and Integrated for Management (PRISM)
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System is updated.
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o A Shift Order dated, 01/21/93, instructs operators to initiate a ONE Form for components found out of
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I position without a reasonable explanation.
operations issued a Lessons Learned and Operations l
o Guideline #3 which discusses configuration control, CPSES events, recent industry events and operator
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standards.
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o The Manager, Operations discussed the importance of i
system status control with Station Managers during a
Plan of the Day (POD) meeting.
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o In February 1993, Operations Shift Advisors began i
monitoring shift implementation of the system status l
program.
The advisors also began routine reporting of i
their monitoring activities to the Manager, Operations.
i This monitoring process was continued for approximately
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four months and was then terminated.
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o ISEG and Quality Assurance increased overview activities in the area of lineup control and system
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status.
Since January 1993, surveillance results have
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indicated satisfactory implementation of system lineup j
and status control.
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e Attachment 1 to TXX-93228 Page 5 of 5 Operations personnel changed System Operating Procedure o
(SOP) 2.01B to clarify the isolation and equalization requirements for instrumentation associated with Event No.
4.
o P&T reviewed procedures that were implemented after SOP lineups were completed following Unit 1 RFO.
They found that procedures had either a specific restoration table that agreed with the SOP or that restoration was verified during clearance removal.
P&T reviewed completed procedures that had been o
implemented on Unit 2 on systems declared operational.
It was found that lineup restoration was either accomplished by a restoration table in the procedure itse]?, was restored as part of clearance removal, was restored as part of the locked valve program or did not involve manipulation.
One procedure (PPT-TP-92-21),
which had not been used, did not have a restoration table.
A PCN was issued to provide the required restoration steps prior to completing the test.
The Operations Design Modification Coordinator O
participates on a Design Modification Review Group (DMRG) to ensure that necessary Operations procedures are changed prior to system release for service and initial system lineup rather than changing the procedure when Operations accepts the DM.
4.
Date When Full Coroliance Will Be Achieved
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Full compliance has been achieve F1
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Attachment 2 to TXX-93228 Page 1 of 2 VIOLATION C (445/92201-03; 446/92201-03)
Technical Specification 6.8.1 states, in part, " Written procedures shall be established, implemented, and maintained covering the activities referenced below:"
"The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1989;"
Regulatory Guide 1.33, Appendix A, Revision 2, February 1978 recommends:
"8b.
Specific procedures for surveillance tests..."
"(1) Reactor Protection System Tests and Calibrations" Licensee Procedure OPT-445A, " Solid State Protection System (SSPS), Train
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Actuation Logic Test," Revision 2, (applicable to Unit 1) implements, in part, the surveillance test provisions of Regulatory Guide 1.33.
Step 9.3.3 of Procedure OPT-445A requires the transition to Procedure SOP-711A, " Solid State Protection," for completion of the task.
Contrary to the above, on January 18, 1993, personnel performing Procedure OPT-445A failed to properly perform Step 9.3.3, resulting in a Unit i reactor trip.
Response to Violation C (445/92201-03; 446/92201-03)
TU Electric accepts the violation and the requested information follows:
1.
Reason for Violation The root cause of the event was personnel error.
The Shift Technical Advisor (STA) did not monitor the restoration of the test lineup as closely as he had monitored the actual test.
The STA was reviewing the test results and did not pay close enough attention to prevent the mistake.
In addition, the test procedure did not make specific enough reference to the System Operating Procedure (SOP) for SSPS restoration.
This led the Reactor Operator (RO) and the STA to an incorrect set of instructions which in turn led to.
switch manipulation without the required trip blocks being establishe s,'
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Attachment 2 to TXX-93228 Page 2 of 2 The RO and STA were not sufficiently familiar with the Solid State Protection System (SSPS) circuitry and incorrectly assumed that sufficient trip blocks were in place so that the INPUT ERROR INHIBIT switch could be taken to NORMAL without a reactor trip occurring.
2.
Corrective Actions Taken and Results Achieved This event was documented on a ONE Form 93-00198.
Subsequently, the event was upgraded to a Plant Incident Report (PIR) and was reported to the NRC as required by 10CFR50. 73 ( a) (2 ) (iv), via LER 93-001.
The Unit responded properly to the trip signal.
The SSPS lineup was restored in accordance with plant procedures.
3.
Corrective Actions to Prevent Recurrence The RO and STA were counselled on the event.
A " Lessons Learned" was also issued to shift personnel concerning the details of the event.
Formal training has been developed to include aspects from this event and includes enhanced objectives and lessons for operator understanding of the SSPS circuitry.
The test procedure was enhanced to provide explicit l
procedure transitions to the SOP for the SSPS.
In addition, as stated in Reference 2, CPSES will also review Operations procedures for accuracy and detail of procedural references that require transition from one procedure to another during the completion of an evolution.
A note was placed with the verification attachments in the SOP stating that the attachments are to be used for verification only and not for actual switch manipulation.
A shift order stressed that the requirements in place for
" infrequent evolutions" include active monitoring until the evolution is complete and equipment is restored to a normal steady-state lineup.
The SOP for SSPS has been redefined as an " infrequent evolution" and now requires the same monitoring requirements as SSPS testing (e.g.,
evolutions performed by experienced personnel, prebriefing, direct supervisory involvement).
4.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
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