ML20011E279

Advises That Util Ready for Issuance of OL Authorizing Fuel Load & Operation Up to 5% Rated Power for Unit 1.Design, Const & Preoperation Testing of Unit Complete in Accordance W/Fsar

ML20011E279
Person / Time
Site:	Comanche Peak
Issue date:	02/08/1990
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-90066, NUDOCS 9002130090
Download: ML20011E279 (7)

Text

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leg # TXX-90066 File # 10010 C C nlELECTRIC February 8, 1990 Whem J. CeWR, Jr.

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e U. S. Nuclear Regulatory Commission Attn: Document Control Desk Vashington, D. C. 20555 SUBJEUT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NO, 50 445 REQUEST FOR IDW POWER OPERATING LICENSE Centlemen:

Texas Utilities Electric Company (TU Electric) is ready for the issuance of the Operating License (OL) authorizing fuel load and operation up to 5% rated power for Unit 1 of the Comanche Peak Steam Electric Station (CPSES).

As of this date, the design, construction and preoperation testing of Unit 1 is complete in accordance with the Final Safety Analysis Report (FSAR) and TU Electric docketed correspondence. A proposed set of Technical Specifications have been developed by the NRC Staff and certified by TU Electric which are consistent with CPSES Unit 1 as built.

During the period of January 22, 1990, through February 2, 1990, an Operational Readiness Assessment Team (ORAT) visited CPSES Unit 1. This team e found that, in its judgement, the unit was ready to begin operations, subject to the resolution by TU Electric of several areas of concern. Those areas which, per the ORAT, are related to fuel load are complete as described in the attachment to this letter. Actions are underway to resolve the remaining items in a timely manner.

An area specifically discussed by the ORAT and by Dr. Thomas Murley, Director, Office of Nuclear Reactor Regulation, was the identification and correction of problems. TU Electric responded to this matter in a letter (TXX-90060) datod February 2,-1990, to Dr. Murley. This letter identified existing programs, additional improvements and our goal of excellence. These are ongoing efforts which are underway. As stated in the letter, "We will continue an aggressive search for'better ways to reach our objectives."

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l TXX 90066 February 7,'1990 Page 2 of 2 If any additional information or documentation is required, do not hesitate to

' contact me or my staff.

L Sincerely, I

i William J. Cahill, Jr.

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By:(JohnW. Beck Vice President, Nuclear Engineering DRU/grp At tachme.it -

c - Dr. T. M.-Murley, Director, NRR Mr. D. M. Crutchfield, NRR-OSP Mr. C. 1. Crimes, NRR OSP Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)

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s Attachment.I'to TXX-90066 l f Page 1 of 5_  !

OPERATIONAL READINESS ASSESSMENT TEAM ,

I FUEL LOAD ITEMS l

E ' Following the completion of the Operational Readiness Assessment Team (ORAT) inspection at Comanche Peak,.the inspection Team Leader identified a number of-areas of concern which required resolution prior to the issuance of an  ;

operating license. These issues were subsequently discussed in a conference

! call conducted en February 5,1990 involving the ORAT Team Leader and other b members of the team, Mr. R. F. Warnick, Assistant Director for Inspection Programs, Comanche Peak Project Division, and Mr. A. B. Scott, Vice President, Nuclear Oprations and unembers of the Comanche Peak staff. Each of the items

.is identified below along with the actions taken to resolve them.

Documentation substantiating completion of the identified actions is being-made available to the onsite NRC inspection staff.

a. Area of Concern:

There are numerous valves in the Instrument Air System which are not numbered or labeled. These valves need to be properly identified and labeled to assure that the Instrument Air System is properly aligned and operated. Prior to issuar,ce of an operating license, those Instrument Air valves which are required to be positioned or operated to support operation up to 5 percent power must be appropriately identified and labeled.

oesolution:

Walkdans of those portions of the Instrument Air Systein required to support operation to 5 percent power were performed to identif3 all velves not labeled and those valves not having corresponding designators on-appropriate system drawings. Design Change Notices were_ prepared to  :

assure proper designation of all such valves on the drawings and corresponding identification tags were installed in the field. These installations were then verified to be correct in accordance with the updated drawings.

b. erea of Concern:

H The applicant's Operations Quality Assessment Team (0QAT) identified that independent verification of instrument valve lineups was not being performed. This issue was apparently resolved to the satisfaction of the 0QAT by the applicant's Instrument and Control Department by referencing certain procedures which required independent verification of instrument valve lineups. However, as a result of the ORAT review of this issue, it was identified that the procedures referenced as a basis for closure of the OQAT finding were not being implemented. Three concerns were identified:

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4 Attachment 1 to TXX-90066 '

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+ 1. Independent verification of instrument valve lineups was not-being performed, with the result that the status of _the lineups was ~  :

indeterminate.

2. The Instrument and Control Department provided a resolution to an OQAT observation without appropriately verifying its correctness or -

implementation ~.

A 3. _The 0QAT accepted a proposed resolution to an observation without 6 properly verifying its status. ,

As a result of these concerns, three actions were identified by ORAT as necessary prior to issuance of an operating license.

g 1. Complete valve lineups, including independent verification, for all 7'

instruments in systems for which independent verification of valve lineups is required (27 systems).

2. Line organizations must validate the adequacy of all proposed resolutions for 0QAT observations.

3. OQAT must review its closure of pre-fuel load observations to assure that a valid basis for closure exists.

Egf.olution:

I Complete instrument valve lineups, including independent verification, have been performed on the 27 systems for which independent verification of valve lineups is required. Each line manager has completed a review-of his/her responses to 0QAT observations. The results of these reviews were submitted via memoranda to the Plant Manager. With minor t

clarifications to a few responses, and the one incorrect response on the

- instrument valve lineups, all responses were found satisfactory. The

!_ OQAT reviewed its acceptance of completed 0QAT fuel load observations-and verified that, with the exception of the instrument valve lineups, appropriate action has been taken to verify the adequacy of the responses accepted, c .

l: c. Area of Concern:

L The ONE Form process used to document and disposition items classified 'as pNt incid1nts does not appear to be effectively implemented insofar as l tN causes of problems sometiines appear to be superficial or focus on synptoms, corrective actions do not consistently address all causal factors, and generic implications are not consistently addressed. Prior to the issuance of an operating license, two actions must be taken:

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i Attachment 1 to TXX-90066 ,

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1. The ONE Form procedure must be revised with respect to items'. '

classified as plant incidents to assure proper identification of causes, corrective actions, and generic implications..

2. All previously dispositioned ONE Forms must be reviewed to assure

. that the issues were a>propriately addressed or, if the evaluation did not appear to be tiorough, that the'. issue did not impact operability.

Resolution:

Three actions have been taken to address this issue:

1. Procedure STA-422, " Processing of Operations Notification and:

Evaluation (ONE) Form," has been revised to require a standard format for evaluations which specifically addresses causes, corrective actions, and generic implications for all ONE Form conditions designated as plant incidents.

L 2. The Vice President, Nuclear Operations has issued a directive that at

! least one individual trained in root cause analysis will-participate L in the preparation of all ONE Form responses designated as plant L incidents,. and that all such evaluations will be reviewed for proper designation of cause by the Plant Evaluation group. This review is to continue until such time as it is determined that the line l organizations are performing adequate evaluations. These provisions are not being applied to plant incidents investigated by Evaluation .

Teams based on the noted thoroughness of evaluations conducted by t such teams to date.

.3. Previously dispositioned nonconformances, deficiencies, and plant h incidents documented on ONE Forms were reviewed for thoroughness and l operability impact. None of the conditions reviewed for which ,

, . thoroughness appeared to be lacking impacted operability. The ,

L. evaluations of dispositions of nonconformances and deficiencies were l determined to be adequate. In those cases where a potential lack of l thoroughness was ioentified for plant incidents, the issues will be re-evel d ed in accordance with items 1 and 2 above by March 9, 1990.

d. . Area of Concern:

Existing procedures do not adequately address verification of correct electrical lineups beyond power supply breakers. Specifically, provisions are not provided to assure that fuses and low voltage AC and DC circuit breakers are installed / positioned as required to assure equipment operability. Prior to issuance of an operating license, the y '

applicant must establish that fuses and low voltage circuit breakers are installed / positioned as required.

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- Attachment I to TXX-90066 .

,  ; Page 4 of 5 Resolution:

All. AC. and DC low voltage circuit breakers have been aligned and 4 independently verified. A walkdown has been performed of all fuses - ,

identified on device level one-line drawings. The discrepancies '

identified during this walkdown have been documented for resolution.

Proper. configuration has been established for the class.1E circuits -:

subject to this walkdown. Proper configuration has been established for the non-class IE circuits subject to this walkdown with the exception of.  ;

a few minor items which will be resolved prior to close of business on .

February 8, 1990.

e. Area of Concern:

A number of discrepancies in the material condition of the plant were identified during plant walkdowns conducted by the ORAT. The:e  ;

discrepancies must be dispositioned prior to issuance of an operating

' license. >

Resolution:.

All _of the discrepancies identified by the ORAT and provided to TU  ;

Electric have been-dispositioned either by correcting the identified condition or by appropriately documenting the condition and prioritizing resolution based on the requirement to support planned plant operations.

l , f. Area of Concern: 'i l' Problems with procedures that are identified during procedure h implementation are not being consistently documented so that they can be corrected in a timely manner. Prior to issuance of an operating license, management needs to communicate its expectations more clearly regarding verbatim procedure compliance and the need to document and correct identified proceou-al problems in a timely fashion.

ResolutiQD:

L The Plant Manager has issued a directive to all operating departments stressing the need for verbatim procedure compliance,. and the need to change procedures prior to proceeding with an activity when procedure problems are identified. Further, the directive emphasizes the need to document all comments on procedures to assure timely resolution. This directive has been discussed with department managers and supervisors for dissemination to their personnel. ,

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g. Area of Concern:

A discrepant material condition was identified during the performance of '

a " troubleshooting" work order. The condition was not brought to the attention of. the Control Room at the time of discovery so that an .

operability review could be performed.- Instead, the work order was t revised to allow correction of the condition and the Control Room was not =

made aware-of the revision.  ;

Resolution:

The procedure governing work requests and work orders has been revised to require that all changes adding corrective maintenance to work orders ,

which did not previously authorize corrective maintenance be reviewed by the Shift Supervisor. The change specifically addresses the need for Shift Supervisor review of changes to " troubleshooting" work orders to E allow corrective maintenance. Affected personnel have been briefed on this procedure change. . 1 l

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