IR 05000446/1992201

Discusses Significant Findings of ORAT Insp 50-446/92-201 on 930104-22 & Provides Summary of Most Significant Findings in Advance of Insp Rept So That Appropriate Action & Timely Corrective Action May Be Taken

ML20128C043
Person / Time
Site:	Comanche Peak
Issue date:	01/29/1993
From:	Roe J Office of Nuclear Reactor Regulation
To:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 9302030286
Download: ML20128C043 (4)

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1. o UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINoTON. D.C. 20 TEE

% # Danuary 29, 1993 C Docket No. 50-446 Mr. W. Executive Vice President Texas Utilities Electric 400 North Olive Street, Lock Box 81 Dallas, Texas 75201

Dear Mr. Cahill:

c SUBJECT: SIGNIFICANT FINDINGS OF THE OPERATIONAL READINESS ASSESSMENT TEAM (0 RAT) INSPECTION (INSPECTION REPORT 50-446/92-201)

From January 4 to January 22, 1993, an ORAT lead by the Special. Inspection Branch of the Office of Nuclear Reactor Regulation (NRR) reviewed and evaluated applicable programs and activities at the Comanche Peak Steam Electric Station, Unit.2. The team discussed the details of the inspection findings with you and your staff during the inspection and at the exit meeting on January 22, 1993. The results of the inspection will assist the U. S.

Nuclear Regulatory Commission (NRC) in its determination of your capability and readiness to operate Unit 2. This letter provides a summary of the most significant inspection findings in advance of the inspection report so that you may take appropriate and timely corrective action.

The team evaluated programs and activities important to the safe operation of the plant, including operations activities, operating procedures, simulator training, maintenance. surveillance and testing, safety assessment and quality verification, and engineering and technical support.

.The team concluded that the depth and capability of your staff, your organizational structure and interfaces, and in-place programs are adequate to suppcrt dual unit operations. The team noted both strengths and weaknesses and brought these to your attention during the inspection. The individual team findings, when: viewed collectively, revealed three areas of weakness that exist in your operating programs. These three areas are discussed below:

1. Failureto establish positive control over system configuration for systems that were turned over to the operations department but not yet declared operational.resulted in valve misalignments and subsequent unexpected system responses.

During the inspection, valve misalignments were identified in the following systems:. component cooling water; auxiliary feed water;. post accident sampling; and primary cooling water (pressurizer relief tank).

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Mr. W. J. Cahill. -2- January 29, 1993 As discus' sed during the inspection, your corrective actions in this area will include:

a) Verification of vaive lineup for all safety-related systems prior to entering Mode 6.

b) Revision of the System Status Control procedure, ODA 410, to assure positive control of system valve lineup during all system evolutions, especially if the activity is suspended.

?. . Procedural inadequacies and failure to adhere to procedures resulted in the failure to perform post-maintenance testing on a main feedwater check valve, and allowed seven auxiliary operators to perform their duties without the required training.

Management needs to reemphasize the importance of procedural quality and the requirement of strict procedural adherence by personnel. As discussed during the inspection, we understand your corrective actions in this area include:

a) Completing the required post-maintenance test on the subject check valve to verify the bonnet flange leak tightness and the ability of the check valve to prevent backflow, b) Ensuring that contract auxiliary operator training is completed prior to the subject operators performing their specified duties, and verification of actions performed by any operators that have not completed the full complement of training.

3. While you have developed a comprehensive corrective action program, the team identified several examples where the implementation of the program appeared to be weak. Of specific concern was your failure to promptly correct errors in Procedure ABN-8038, Response to a Fire in the Control Room or the Cable Spreading Room.

Additional management attention should be directed to the timely implementation of corrective actions and the thoroughness of the corrective action program in identifying and correcting the root cause of repetitive problems. As dircussed during the inspection, we understand your corrective actions in this area include:

a) Performing a det&iled walkdown of ABN-803B to ensure this procedure

.can be performed satisfactorily, b) Performing detailed validations of other ABNs that rcquire equipment to be staged in areas to support operator actions.

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- Mr. W. January 29, 1993

- As. stated above,-the complete list and ' appropriate description of all inspection-findings will be provided in_ Inspection Report 50-446/92-201._ No

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response is required to this letter. It is our understanding that you have-initiated corrective actions in the three areas discussed in this letter. The implementation of your corrective actions to the areas of weakness noted above will be verified by NRC Region IV prior to Unit 2 fuel-load.

Original Signed By Jack W. Roe, Director Division of Reactor Projects, III/IV/V-cc: See next page Office of Nuclear Reactor Regulation Distributiqn:

JWRoe, NRR CERossi, NRR RPZimmerman, NRR EVImbro, NRR PSKo_1tay, NRR iDo'cket Filesia DRIL R/F RSIB R/F WTRussell, NRR NRC PDR Local PDR PDIV-2 Reading PDIV-2 Plant File MVirgilio SBlack BHollan EPeyton 0GC-ACRS (10)

LYandell, Region IV _

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0FFICE: SIB:DRIL:NRR C:RSIB:DRIL DD:DRIL:NRR D:DRIL:NRR NAME: PSKoltaNs[' EVImb b RPZid[eIman- M s.5 b 7 1-k DATE: '01////93 01//f/93- 01ef[93 01/Xf/93 0FFICE: D:NRRY'

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0FFICIAL RECORD FILE DOCUMENT.NAME: CPQLOOK

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Mr. W. January 29,-1993 cc:

Senior Resident Inspector Jack R. Newman, Esq.

U.S. Nuclear Regulatory Comission Newman & Holtzinger P. O. Box 1029 1615 L Street, N.W.

Granbury, Texas 76048 Suite 1000 Washington, D, C. 20036 Regional Administrator, Region IV U.S. Nuclear Regulatory Comission Chief, Texas Bureau of Radiation Control 611 Ryan Plaza Drive, Suite 1000 Texas Department of Health Arlington, Texas 76011 1100 West 49th Street Austin, Texas 78756 Mrs. Juanita Ellis, President Citizens Association for Sound Energy Honorable Dale McPherson 1426 South Polk County Judge Dallas, Texas 75224 P. O. Box 851 Glen Rose, Texas 76043 Owen L. Thero, President Quality Technology Company Lakeview Mobile Home Park, Lot 35 4793 East Loop 820 South Fort Worth, Texas 76119

Mr. Roger D. Walker, Manager Regulatory Affairs for Nuclear Engineering Organization Texas Utilities Electric Company 400 North Olive Street, L.B. 81-Dallas, Texas 75201 Texas Utilities Electric Company c/o Bethesda Licensing-3 Metro Center, Suite 610 Bethesda, Maryland 20814-William A. Burchette, Esq.

Counsel for Tex-La Electric Cooperative of Texas Jorden, Schulte, & Burchette 1025 Thomas Jefferson Street, N.W.

Washington, D.C. 20007 GDS Associates, Inc.

Suite 720 1850 Parkway Place Marietta, Georgia 30067-8237 9