ML20035A140
| ML20035A140 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/22/1993 |
| From: | William Cahill, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-93117, NUDOCS 9303240148 | |
| Download: ML20035A140 (11) | |
Text
- " Letter and attachments are being retransmitted.
The original transmittal was sent without Attachment 1."
Log
- TXX-93117 y7 File # 10130 IR 92-62 Ref.
- 10CFR2.201
=
r TUELECTRIC W!liam J. Cahat. Jr.
a.<,u. v.a emae U. 5. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555 5UBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET N05. 50-445 AND 50-446 NRC INSPECTION REPORT NO. 50-445/92-62: 50-446/92-62 RESPONSE TO NOTICE OF VIOLATION Gentlemen:
TV Electric has reviewed the NRC's letter dated February 19, 1993, concerning the special inspection conducted between December 14. 1992, and January 21. 1993.
This inspection was conducted to review programmatic and implementation issues regarding the station temporary modification program.
Attached to the February 19, 1993, letter was a Notice of Violation (NOV).
This notice identified violations regarding the technical and administrative implementation of the station temporary modification program. TV Electric accepts these violations.
In response to these issues. TU Electric initiated interim corrective actions to assure that temporary modifications in place were properly reflected on plant drawings and consistent with existing plant conditions, and that future temporary modifications could be implemented safely.
Additionally. TV Electric established an Evaluation Team which identified causal f actors, preventive actions, and generic implications for the issues.
The results of the Evaluation Team were presented to your staff during a January 15, 1993, management meeting. Actions regarding the generic programmatic weaknesses identified by the Evaluation Team are summarized in.
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Page 2 of 2
, provides TU Electric's reply to the Notice of Violation pursuant to 10CFR2.201 and the terms of the notice.
Sincerely.
)
William J. Cahill, Jr.
i N M.W By:
Roger"D. Walker Manager of Regulatory Affairs for NEO OBitg Attachments c-Mr. J. L. Milhoan, Region IV Mr. L. A. Yandell, Region IV Resident Inspectors. CPSES (2)
Mr. T. A. Bergman. NRR Mr. B. E. Holian NRR l
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Page 1 of 2 SUMKARY OF TU ELECTRIC ACTIONS
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As a result of the Evaluation Team investigation of problems with temporary modifications, TU Electric is taking the following actions to address potential generic implications:
1.
Identify and evaluate programs likely to be challenged by planned activities so that changes and/or enhanced performance monitoring can be undertaken to orevent or provide early detection of problems.
2.
Review other programs like the temporary modification program which may create the potential for incompatibilities in plant activities and establish controls to prevent such problems.
3.
A task team has reviewed the design modification and minor modification processes to determine if either has any of the specific problems identified with the temporary modification process and actions are being taken as appropriate.
4.
Reemphasize evaluation of corrective action effectiveness as part of Nuclear Overview's routine duties.
5.
Nuclear Overview is coordinating an integrated effort to evaluate ONE Forms, Plant Incident Reports, and Industry Operating Experience Reports open longer than six months to assure appropriate priorities have been assigned to closing these items.
6.
Nuclear Overview will routinely review Overview findings open greater than 90 days to determine whether corrective actions are proceeding on a schedule consistent with the importance of the items and report the i
results to Senior Management.
)
With regard to specific temporary modification issues, TU Electric will:
j 1.
Improve the methodology for assuring that temporary modifications are reflected on vital station drawings; 2.
Improve the coordination and scheduling of temporary modifications and other activities which are potentially impacted (such as clearances) to assure compatibility; 3.
Require additional engineering review to assure the technical adequacy of temporary modifications; 4.
Improve the field visibility of temporary modifications to provide increased assurance that personnel will recognize when temporary modifications are installed;
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Page 2 of 2 5.
Enhance the procedure on temporary modifications to more clearly define responsibilities, accountabilities, and management expectations.
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RESTATEMENT OF VIOLATION A (445/9262-01: 446/9262-01) 1 Criterion VI of Appendix B to 10 CFR Part 50 and Comanche Peak Steam Electric Station Final Safety Analysis Report. Amendment 81. Section 17.2.6
- Document Control.* state that measures shall be established to control the issuance of documents such as instructions, procedures, and drawings which prescribe all activities affecting quality.
These measures shall assure that documents, including changes are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed.
Contrary to the above, on December 30, 1992, it was identified that established procedures were not adequate to assure that documents, including i
changes, were distributed to and used at the location where the prescribed activity is performed.
Specifically, vital station Drawing M1-0259. " Boron Recycle System." located in the Work Control Center was not marked up to show the additional piping and valves installed by Temporary Modification 92-1-103. Revision 1.
Vital station drawings located in the Clearance
[
Processing Center were not marked up to show any temporary modifications
}
j applicable to Units 1 or 2.
RESPONSE TO VIOLATION A (445/9262-01; 446/9262-01)
TV Electric accepts the violation and provides the following information, as requested:
1.
Reason for the Violation These errors were attributable to less than adequate procedural controls to assure that the drawings posted with active Temporary Modifications (TMs) were maintained at the locations where the prescribed activity was being performed.
Additionally, the responsibilities for coordinating these activities were not clearly defined, nor clearly understood by
-l personnel involved.
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Corrective Steos Taken and Results Achieved i
TV Electric initiated ONE Forms to document the conditions identified.
The subject vital station drawings were updated to correctly reflect the i
status of the subject Temporary Modifications.
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Corrective Steos Taken to Avoid Further Violation TU Electric has taken the following interim actions:
A dedicated system engineer has been assigned as the TM coordinator.
The TM coordinator provides to the Operations department a report listing the vital station drawings which are impacted by TMs in a timely manner. _The Operations shift administrative staff checks impacted vital station drawings (as required) to ensure that the updates are maintained. TU Electric will keep these interim actions in place until the actions discussed in Attachment 1 on specific temporary modification issues are in place.
TU Electric will enhance its procedures based on recommendations from i
the Evaluation Team to improve the methodology for assuring that TM information is made available to the users, including more clearly defining responsibilities and accountabilities.
4.
Date of Full Compliance l
The enhancements to the TM procedure will be complete prior to the third refueling outage for Unit 1.
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. to TXX-93117 Page 3 of 7 RESTATEMENT OF VIOLATION B (445/9262-02: 446/9262-02)
Criterien XVI of Appendix B to 10 CFR Part 50 and Comanche Peak Steam Electric Station Final Safety Analysis Report. Amendment 85. Section 17.2.16. ' Corrective Action." state that measures shall be established to assure that conditions adverse to quality, such as failures. malfunctions, deficiencies deviations. defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above. established measures were not adequate to assure that deficiencies with the implementation of the temporary modification program were promptly identified and corrected to preclude repetition of significant conditions adverse to quality.
1.
The corrective actions taken to preclude repetitive deficiencies with
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maintaining vital station drawings updated to reflect active temporary modifications were not adequate.
On July 10. 1992. Operations Notification and Evaluation (ONE) Form 92-651 identified that vital station Drawing M1-0235 was not properly updated to reflect Temporar:
Modification 92-1-13.
The corrective BCtions taken did not preclude subsequent occurrences as identified on ONE Form 92-821. dated August 19, 1992; ONE Form 92-981, dated October 8. 1992:
ONE Form 92-1561. dated December 7. 1992: and ONE From 93-082. dated January 8. 1993.
2.
The cause for safety-related Transformer CPI-ECTRET-02 remaining energized on November 11. 1992, after Clearance 1-92-01073 was implemented, was not determined and corrected to preclude a repetition of the problem on December 3. 1992, when Transformer CPX-EPMCNB-21 remained energized after Clearance X-92-02849 was implemented.
l Following the second event. corrective actions again were not implemented to identify and correct the temporary modification implementation deficiency which resulted in the transformers remaining energized.
3.
Plant Incident Report 91-0555 dated April 18. 1991, had not been dispositioned to resolve implementation problems with the temporary modification program, t
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Prompt corrective actions were not taken to resolve a temporary modification configuration control deficiency identified on ONE Form 92-0668, dated July 14, 1992.
It was identified that, although two isolation points had been installed on a steam generstor drain line.
only one was documented and removed when the temporary modification was closed.
One of the corrective actions identified in the ONE Form was to revise Temporary Modification 91-1-052 to reflect the second isolation point.
This corrective action was not implemented and, on November 16, 1992, while attempting to drain the steam generator, it was identified that the line was still isolated but not documented in any I
RESPONSE TO VIOLATION B (445/9262-02: 446/9262-02)
TV Electric accepts the violation and provides the following information, as requested:
1.
Reason for the Violation During the second refueling outage Nuclear Overview identified these issues as an adverse trend.
The issues were reviewed by management and it was concluded that these issues alone did not pose a significant plant configuration control issue.
Notwithstanding, TV Electric j
initiated a task team to review issues relating to TMs.
The task team's review of the ONE Form (relating to TMs) concluded that corrective actions taken to resolve the previously addressed issues appeared to be sufficient to correct specific deficiencies.
However, a root cause evaluation of these issues remained open.
TO Electric believes that the condition identified was caused by failure to fully recognize the commonality in causes of the individual events in a timely manner.
The ONE Form procedure did not clearly define the time limits for dispositioning the ONE Forms.
2.
Corrective Steos Taken and Results Achieved r
i The Evaluation Team has reviewed the ONE Forms.
These ONE Forms have been dispositioned. evaluation of generic implication and root cause analysis has been performed and appropriate corrective actions are in place.
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3.
Corrective Steos Taken to Avoid Further Violations t
The ONE Form procedure was revised apart from this violation as part of i
a Quality Assurance Audit, and now provides guidance on timely
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disposition of ONE Forms and Plant Incidents affecting safety.
Additionally, Nuclear Overview is coordinating a reevaluation of open ONE Forms, Plant incidents, and industry operating experience reports l
over six months old to assure appropriate prioritization.
4 Date of Full ComDliance TV Electric is in compliance.
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RESTATEMENT OF VIOLATION C (445/9262-03: 446/9262-03)
Technical Specification 6.8.la requires that written procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33. Revision 2, dated February 1978 Appendix A to Regulatory Guide 1.33, peragraph la. requires that i
administrative procedures be developed for controlling equipment status (e.g., locking and tagging).
Administrative Procedure STA-605, Revision 11, " Clearance and Safety Tagging," Section 2.2. establishes the applicability of this procedure to l
identify the established forms, tags, and documents that are necessary for the users of this procedure to adequately impact, prepare, hang, log, and restore clearances.
Section 4.2 defines the clearances as assurance that a component, subsystem. or system is isolated or configured as specified on the clearance report.
Contrary to the above. Administrative Procedure STA-605. Revision 11, was l
not adequate to assure that users of the procedure identified the documents that are necessary to adequately impact, prepare, hang, log and restore clearances as indicated by the following examples:
On November 11, 1992 Clearance Order 1-92-01073 was implemented to deenergize safety-related Transformer CP1-ECTR 5T-02: however, Temporary Modification 92-1-66 was not considered in the clearance report resulting in the transformer remaining energized.
On December 3. 1992. Clearance Order X-92-02849 was implemented to deenergize non-safety-related Transformer CPX-EPHLNB-21: however, Temporary Hodification 92-1-30 was not considered in the clearance order resultiag in the transformer remaining energized.
RESPONSE TO VIOLATION C (445/9262-03: 446/9262-03)
TV Electric accepts the violation and provides the following information, as requested:
1.
Reason for the Violation TU Electric believes that these events were caused by less than adequate implementation of existing requirements of procedure regarding real time impacting of activities.
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Corrective Stecs Taken and Pesults Achieved i
t TV Electric management took the folicwing interim actions.
Operations department now evaluates the impacts of TMs on all
- accepted" and
' prepared
- clearances prior to shift supervisor authorization for installation.
Evaluation is also performed by the Operations Department for
- accepted
- clearances for impact by installed TMs.
3.
Corrective Steos Taken to Avoid Further Violation TV Electric believes that the interim actions in place will prevent TV Electric is evaluating the need to enhance the procedure recurrence.
on impacting clearances, after evaluating the results of the interim actions.
4 Date of Full Comoliance i
The revision to the procedure on clearances if needed, will be completed prior to the third refueling outage of Unit 1.
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