ML20035C225

Recommends Issuance of Full Power OL for Comanche Peak Steam Electric Station Unit 2.Basis for Recommendation Contained in 930201 Readiness Assessment & Addl Info Submitted

ML20035C225
Person / Time
Site:	Comanche Peak
Issue date:	03/29/1993
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML20035C218	List: ML20035C225
References
NUDOCS 9304060353
Download: ML20035C225 (7)

Text

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Enclosure'4.

. NUCLEAR REIULATORY ColHISSION f

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sii avam romaa oniva, spire,ies 3g anumerow,renas met 14een n 29 m Docket No. 50-446 l

MEMORANDUM FOR: Thomas E. Murley, Director Office of Nuclear Reactor Regulation

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FROM:

James L. M11hoan, Regional Adminqstrator

SUBJECT:

CDMANCHE PEAK STEAM ELECTRIC STA710N UNIT 2.

FULL-POWER LICENSE RECOMMENDAT10N-1 The Region IV staff and I recommend the issuance of a full-power operating license for Comanche Peak Steam Electric Station ICPSES) Unit 2.

The bases-1 for this recommendation are contained in a readiness assessment which was provided to you on February 1,1993, prior to the, low. issuance of the low-power.

license and the additional infomation provided be

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The construction and preoperational test inspection programs have been completed.

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The start-up test and operations inspection, programs.have~been initiated and an NRC master inspection-plan.for Unit ) has been developed and.

-i approved. The NRC resident inspectors, augmented by Regional staff,;.

provided around-the-clock coverage of fuel loading, initial' approach to criticality, and power ascension below 5. percent of rated power.:NRC i

inspectors also observed mode changes, zero power start-up tests, normal' day-to-day operations,.and maintenance acti rities. Two issues were-identified during initial Itcensed operations as. discussed in Attachment I to this memorandum. Those issJes have been-satisfactorily i

resolved.

In addition, a regional readines s assessment team inspection j

was conducted March 25-28,.1993, to evaluate the licensse's performance.

i during initial critical operations. The team concluded that TU Electric-l has implemented appropriate measures includ'Ing management oversight, l

The. operations,engineeringandmaintenancelorganizationsdemons corrective actions, and self-assessments to support plant operations.

i common resolve for the safe conduct of plank operations

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direct observation and evaluation of licensite performance, we believe that TU Electric's performance to date demohstrates their readiness to 1

operate the plant above 5 percent power.

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The CPSES oversight Panel-met on March 11 and 28, 1993, to perform an evaluation of licensee performance, and to feview the results of the

-l readiness assessment team inspection and th,e around-the-clock inspection 1

is ready to conduct dual unit operations, gel concluded that.TU Ele coverage of the low power testing. The pa j

including power operation of Unit 2.

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9304060353 930330 PDR-ADOCK 05000446 F

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i 83/29 43 14:4a R IU US WC FTS 72EHE8 902 Thomas E. Murley l 4.

Region IV staff were requested by memorand a dated December 3, 1992, to i

identify any issues that could impact the ssuance of a license for i

CPSES Unit 2.

There were no concerns expr ssed by any Region IV e

personnel relative to the issuance of a lo -power license for Unit 2.

Since the issuance of the low-power licens, no concerns have been expressed to Region IV management.

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Acceptable progress has been made in addressing those items identified inmyFebruary1,1993,memorandumasbeinglincompleteatthetimeof low power licensing.

Resolution of the remaining open items is not deemed necessary to support issuance of a ull-power license.

' provides the status of those tems.

NRC inspectors will continue to implement an augmented inspection and evaluation program to monitor the licensee's performance during the period of power escalation to full-power. This will include:

Around-the-clockinspectioncoveragetomonlitorthelicensee's 3

performance during important tests and during parts of power a

escalation.

Witnessing selected start-up tests and revi, ewing the start-up testing results.

Reviewing the licensee's self-assessment t be performed at the 50 percent power plateau.

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WithrespecttothestaffrequirementsmemoranduiconcerningtheMarch16, 1993, discussion on full-power operating licenstr}g for Comanche Peak (Unit 2),

it is our understanding that your staff is responding to the Commission's request for additional information.

Region IV has reviewed and concurred in the response.

l In conclusion, we' find that CPSES, Unit 2, construction has been substantially completed in accordance with Construction Permit CPPR-127, the FSAR, and NRC regulations; that fuel loading, initial start-up, and operations to date have been conducted safely; and that TU Electric is re ady to safely operate Unit 2 j

above 5 percent power.

eeb mesL.Nilhoan i

egional Administrator l

Attachments: As stated i

cc w/ attachments:

(see next page) i i

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Ew2943 14842 O IU US NRC FTS 729-9279

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Thomas E. Murley :

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cc w/ attachments:

J. Taylor,(MS17G21)

J. Sntezek, (MS 17G21).

RIVCoordinator,OED0(MS17621)

R. Bernaro, (MS 6E6)

J. Partlow, MS 12G18)

W. Russell,((MS12G18)

J. Roe, (MS 13E4)

M. Virgilio, (MS 13A2)

S. Black, (MS 13H15)

B. Holian, (MS 13H15)

C. Rossi, (MS 9A2)

C. Grimes, (MS 11E22)

J. Montgomery l

A. Beach i

L. Callan S. Collins L. Yandell D. Graves I

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23/29/93 14:42 R IU US tRC FTS 720-8278 e04 ATTACMENT 1 ISSUES IDENTIFIED $1NCE LOW-POWER LICEN5ING Two issues were identified after the issuance of the low-power operating license that were of some potential significance and which were discussed in a staff note for the Commission on March 10, 1993.

The first issue involved the identification of a Borg-Warner pressure seal che et valve in the auxiliary feedwater system (Valve AF-106), that failed a st rveillance tast for back flow. The second issue involved the identification of noise on the reactor coolant system loose parts monitor that indicated the potential presence of a loose part in the reactor pressure vessel. The status of those issues is descriaed below:

BORG-WARNER CHECK VALVE AF-106 STATUS On March 8,1993, auxiliary feedwater check valvt AF-106 failed a back flow test. The valve was disassembled for maintenance and found to be rotated 10 degrees with respect to the disk seating surface., This resulted in the disk hanging approximately 1/2" off its seat at the lowar surface. The valve was reworked and reassembled, and satisfactorily back flow tested on March 11, 1993. TV's investigation indicated that a satisfactory back flow test was completed last fall. After the test was completdd, work instructions called for the installation of a block and key device ttjat was intended to aid maintenance personnel in properly aligning the vtive during future maintenance activities. However, it appears that some actior duri.g the installation of the block and key device caused the misalignment of the valve. At that time, no post work testing was required. As an immediate corrective action, the licensee determined that 25 of these check valved had the block and key device installed.

Fourteen of this number are safety-rs' lated, and all were back flow tested satisfactorily after installation of the c evice. The remaining 11 check valves were evaluated through the use of temperature monitors, radiographs, or back flow testing and determined 'to be satisfactory. All other Berg-Warner check valves installed in Unit 2 are bolted bonnet valves that are not susceptible to misalignment during reassembly. The licensee

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completed a root cause analysis of this failure on March 23, 1993.

It was concluded that the cause for the event was uncer ain, however, a contributing factor was the lack of verification of alignment 1during the process to install the block and key devices.

The NRC readiness assessment team reviewed the issue and concluded that TU Electric had conducted an appropriate root cause analysis. The corrective actions implemented wede found to address the conottioninwhichthevalvewasfoundandshouldpreventrecurrence. This same corrective action should also be effective in preventing similar problems on the Borg-Warner pressure seal check valves whdre the block and key devices are not installed.

100SE PARTS MONITOR ALARM On March 7, 1993, with Unit 2 in Mode 4, operatidns personnel identified a high noise alarm on the reactor coolant system loose parts monitor (LPM).

Subsequentevaluationofthisconditionbythelicensee'splantengineering organization, in consultation with the LPM manuf4cturer (Babcock and Wilcox),

and the Nuclear Steam Supply System vendor (Westinghouse), concluded that the

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LPM high noise alarm was attributable to flux th(mble tube vibrations.

Based i

en the technical analysis provided by Westinghouse, the licensee concluded l

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that there was no loose part present, that there were no short term safety.

concerns related to the flux thimble tube vibrati ns, and that the LPM system was acceptable for continued operation. NRR and egion !Y staff agreed with the licensee's conclusions. The licensee has an nspection and maintenance program, as required by NRC Bulletin 88-09, that will address v1bration of the bottom mounted incore flux thimbles.

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eLv29/93 14:43 O IU US HRC FTS 720-6278 Bas ATTACHMENT 2 STATUS OF OPEN ITEMS FOR COMANCHE PEAK UNIT 2 The low-power license recommendation letter dated February 1, 1993, provided the status of items that were not required to be completed prior to the issuance of the low-power operating license. The current status of those items is discussed below, and none of the issues remaining open needs to be resolved prior to full-power licensing.

The Operational Readiness Assessment Team (ORAT) identified weaknesses in the areas of configuration control (syst4m status control),

procedures, and corrective actions which thle licensee indicated would receive necessary attention prior to fuel load.

In the area of system toMode6andrevisedthecontrollingprocelduretoensurepositivestatus contro reviews and system walkdowns that the licenls confimed by procedure system status control. Region IV inspector see had taken appropriate procedures in question and committed to perl form a complete procedure corrective actions.

In the procedure area, the licensee revised the review (approximately 700 procedures) over the next two yearn Region IV inspectors confirmed that the specific procedure deficiencias operators who had not received training req luired by procedures were identified were corrected by the licensee. The contract auxiliary removed from plant duties. Also, the inspectors verified that the work performed by the contract auxiliary operato'rs was reviewed by the licensee, and that the operators were reass'igned to tasks authorized by managementandcommensuratewiththeircurr{enttraining. With regard to corrective actions, the licensee completed ; evaluation of the four items identified by the ORAT. Region IV inspectors determined that post-test thatanextensivefieldverificationofabn{eappropriateS requirements on a feedwater check valve wer applied and ormal proceduies was being completed by the licensee on the committed schedule. Overall, Region IV is satisfied that the ORAT concerns have been satisfactorily addressed.

All TMI items, except the Safety Parameter Display System (SPDS),

were verified complete prior to low-power 1,1 censing. The SPDS was operational, but a required assessment afte,r 30 days of operation had not been completed.

By letter dated Mgrch 22, 1993, the licensee indicated that no ssecific date fer the start of 30-day assessment had been establisaed, but that t,he assessment would start within 60 days after fuel load (Apri'7, 1993). This is the same approach used for Unit 1, and the Reg on finds it acceptable.

Thermo-Lag fire barrier material was verif ed as installed prior to low-power licensing; however, not all Thermo-Lalg installations had completed a 30-day cure time.

In addition, 13 (box enclosure) installations that wereconfigureddifferentlyfromtestedcodfigurationshadnotbeen adequately justified by analysis or testing. These installations i

resulted in the implementation of fire wate pendingcompletionofthecuretimeandco;hesasacompensatorymeasure figuration upgrades.

Currently, the 30-day cure time has passed for all of the installations completed prior to the issuance of the low-power license. Also, as discussed in draft Supplemental Safety Eval,uation Report 27 (to be March 4, 1993, established a seven-day cure,e), testing performed on published concurrent with full-power licens i

time as acceptable for i

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all future installations. With regard to the box enclosure configurations, all were subsequently foun acceptable after the staff's review, and these upgrades were certified omplete by TU Electric on March 10, 1993. Fire watches are no longe required with regard to these two specific issues.

Identified weaknesses regarding the control of temporary modifications as discussed in Inspection Re, port 50-445/92-62; 50-446/92-62, have been effectively addressed by interim actions taken by the licensee.

At the time of low-power licensing, the Region IV staff perceived the lack of a sense of ownership by the Un1lt 2 operations staff that was being rapidly dispelled as the two; ion. units were brought together under a single operating organizat Since issuance uf the low-power license, two special inspect 1;;ons were conducted that looked, in part, at this issue. The inspection of the licensee's personnel error reduction program in Februa'ry 1993, and the augmented inspection of Itcensee performanc's during initial low-power operations during March 25-25, 1993, determined that the plant staff has exhibited an increased sense of ownership of Unit 2 commensurate with that seen on Unit 1.

Test and retest deferrals discussed in Attgehment 13.2 of the February 1,1993, low-power license recommendation letter have been successfully completed in accordance With the licensee's completed consistent with plant operational l, requirements.

schedule.

The remaining deferred tests are scheduled to be Region IV continues to track the completion of these deferred tasks.

All NRC items required to be completed arior to exceeding S percent power have been completed.

Tie r;emaining open items identified in the Inspection Followup System are being tracked for completion at the appropriate time.

Atthistime,therearefouroutstandinga$egationspertainingtothe construction and operation of the CPSES fa 111ty. The Region IV Allegations Review Panel convened on March 11, 1993, and determined that the resolution of the pending allegations as not necessary to support the issuance of a full-power license.

No a,dditional allegations have been received for Comanche Peak since March' 11, 1993.

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Log # TXX-93158 I

=M File # 10010-j

Ref. # 10CFR.50.57

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7UELECTRIC March 28,'1993 e

S William J. CaMft. Jr.

Group Ger Presodent i

U. S. Nuclear Regulatory Commission Attn:.00cument Control Desk Washington, DC 20555 i

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNIT 2 I

DOCKET NO. 50-446 READINESS FOR ISSUANCE OF THE UNIT 2 FULL POWER OPERATING LICENSING' REF:

1)

TU Electric letter logged TXX-93093 from William J. Cahill, Jr. to the NRC l

dated February 19, 1993 6

2)

TU Electric letter logged TXX-93011 from William J. Cahill, Jr. to the NRC

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dated January 8, 1993 3)

TU Electric letter logged TXX-93051 from William J. Cahill, Jr. to the l

NRC dated January 25, 1993 4)

TU Electric letter logged TXX-93140 from William J. Cahill, Jr. to the NRC dated March 22, 1993 Gentlemen:

TU Electric has completed and evaluated the low power physics testing and the additional testing that can be completed prior to proceeding above 5% reactor power. provides a listing of the testing that is described in i

Chapter 14 of the Final Safety Analysis Report (FSAR) which was conducted during Mode 6 through Mode 2 since the issuance of the CPSES Unit 2 low power operating license.

Additionally, TU Electric has performed a self-assessment of the readiness of l

CPSES Unit 2 for proceeding above 5% power in accordance with the description provided in Reference 1.

This self-assessment has'been reviewed and evaluated:

by the Station Operations Review Committee (50RC). The 50RC hss concluded t

that CPSES Unit 2 is ready for operation above 5% power.-

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TXX-93158 l

Page 2 of'2 f

TU Electric is at this time ready to receive an operating itcense for CPSES i

Unit 2 which authorizes operation up to 100% reactor. power.

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Sincerely, j

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William J. Cahill, Jr.

Enclosure c - Mr. J. L. Milnoan, Region IV Resident Inspectors, CPSES (2) i Mr. T. A. Bergman, NRR

Mr. B. E. Holian, NRR l

Mr. L. A. Yandell, Region IV

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Enclosure to TXX-93158 Page 1 of I l

A.

Deferred Preoperational Tests and Retests conducted _during Mode 6 through Mode 2.

(Reference 2. Reference 3, and Reference 4).

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Pressurizer Spray Valve Leak Tightness 2.

Power Operated Relief Valve (PORV) Leak Tightness 3.

Reactor Cavity Humidity Detectors 4.

Steam Dump Valve Stroke Verification 5.

Public Address and Emergency Evacuation Alarm System 6.

Main Stream Isolation Valve (MSIV) Stroke-Timing '

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Plant Computer Flux Mapping Module' 8.

Plant Computer Data Archive Capability 9.

Plant Computer Delta I Module

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Heat Ventilating and Air Conditioning (HVAC) System Flow Balance l

Test results for the tests listed above have been evaluated by the Test Review Group as acceptable for proceeding to full power.

B.

Initial Startup Tests conducted-during Mode 6 through Mode 2 (Reference.

FSAR Chapter 14 Table 14.2-3 and Figure 14.2-48).

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Reactor Trip System 2.

Boron Reactivity Worths 3.

Rod Drop Tests

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Reactor Coolant Flow Test i

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Reactor Coolant Flow Coastdown

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Control Rod Drive Tests 7.

Rod Position Indicators 8.

Moderator Temperature Reactivity Coefficient

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Control Rods Reactivity Worths 10.

Auxiliary Startup Instrumentation

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Chemical Tests

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Core Performance Evaluations

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Calibration of Nuclear Instrumentation

• 14 Radiation Survey

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Core Reactivity Balance

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Incore Nuclear Instrumentation l

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Reactor Coolant Leak Test 18.

Rod Control System Test _

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Test results for the testing listed above have been evaluated by the Test-Review Group as acceptable to proceed above 5% power.

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• Those items identified with an asterisk are complete for Mode 6 through

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Mode 2 but additional testing will continue as a normal part of power ascension testing. Those items not asterisked r e complete.

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3 DISTRIBUTION Docket File PDIV-2 R/F TMurley JPartlow JRoe MVirgilio SBlack 2Holian EPeyton j

NRR Mail Room (WITS 9300051) 12/G/18 MBridgers (WITS 9300051)

Jiaylor JSniezek HThompson JBlaha JMilhoan, Region IV WRussell FGillespie JKnubel, EDO 1

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