ML20058B048
| ML20058B048 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/17/1990 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-90551, NUDOCS 9010290371 | |
| Download: ML20058B048 (4) | |
Text
I tog # TXX 90551 m
File # 10130 lll::= =
907.8 IR 90 36
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IR 90-36
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Ref. # 10CFR2.201 nlELECTRIC wmi.m J. c.hm, Jr.
October 17, 1990 t,,w,,a n,,nr.+.,
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PFAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50 446 NRC INSPECTION REPORT NOS. 50 445/90-36; 50 446/90-36 RESPONSE TO NOTICE OF VIOLATION Gentlemen:
TU Electric has reviewed the NRC's letter dated September 17, 1990, concerning the inspection conducted by Mr. P. C. Wagner during the period August 20 through August 24, 1990. This inspection covered activities authorized by NRC Facility Operating License NPF 87 and NRC Construction Permit CPPR-127 for CPSES Units 1 and 2.
Attached to the September 17, 1990, letter was a Notice of Violation.
TV Electric hereby responds to the Notice of Violation in the attachment to this letter.
Sincerely, William J. Cahill, Jr.
By:
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H. D. Bruner-Senior Vice President JRW/daj Attachment c'- Mr. R. D. Martin, Region IV Residentinspectors,CPSES(3)
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Attachment to TXX 90551 Page 1 of 3 i
Notice of Violativi l
(445/9436-01)
During an NRC inspection conducted on August 20-24, 1990, a violation of NRC requirements was identified.
In acenrdance with the *neneral Statement of Policy and Procedure for MRC Enferce'nent Actions," 10 CCR Part 2 Appendix C (1990) (Enforcement Policy), the violation is listed below:
Criterion V of Appendix B, to 10 CFR Part 50, requires activities affecting quality to be prescribed by procedures of a type appropriate to the circumstances.
Contrary to the above, the licensee did not establish a procedure prescribing the administrative controls necessary to assure that the Anticipated Transient Without Scram Mitigation Actuation Circuitry (AMSAC) was operational. As the result of this inadequacy, on August 10, 1990, the AMSAC was left in the bypass position, thereby disabling the system for a period of approximately 10 days while the reactor was operating at full power.
(445/9036 01)
Response to Notice of Violation (445/903601) 10 Electric accepts the violation and the requested information follows.
1.
Reason for the Violation TV Electric has determined that the lack of administrative controls described in the Notice of Violation resulted from the following procedural deficiencies:
a.
The AMSAC system is enabled at 40% turbine power by an interlock which receives its input from first stage turbine pressure.
The plant operating procedure governing power increases provided instructions to l
verify that the interlock annunciator de-energizes upn reaching 40%
turbine power. The operating procedure provided no instructions to verify position of the AMSAC mode switch, b.
The main control board contains an "AMSAC Trouble" annunciator which energizes upon sensing any one of a number of AMSAC system problems, including placement of the AMSAC mode switch in bypass.
The associated alarm response procedure provided directions for determining the source of the sensed problem but did not provide any guidance concerning the importance of minimizing the time that the AMSAC system might be inoperable or actions that should be taken if operability cannot readily be restored.
These procedural deficiencies also resulted in a lack of appropriate sensitivity, on the part of some operators, to the importance of maintaining the AMSAC system operable during the events described below, t
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Attachment to TXX 90551 Page 2 of 3 On August 10, 1990, with the plant at approximately 507, power, the AMSAC system was placed in the bypass mode as part of a scheduled calibration of a steam generator, level instrument which provides input to the AMSAC logic i
circuit.: At the conclusion of the level instrument calibration, the calibration procedure instructed I&C technicians to inform operators that the switch could be returned to normal as required by plant conditions.
Because of a hardware deficiency in the AMSAC trouble alarm circuitry which results in ' frequent spurious alarms, operators elected to leave the system bypassed in an attempt to reduce these spurious alarms. Through routine reviews of the annunciator out of service log, operations personnel were aware that there was an outstanding work request on the alarm circuit and were, accustomed to seeing the annunciator lit. Consequently, subsequent shifts did not perform any investigation which would have detected the bypass condition. The AMSAC system remained bypassed until the condition was discovered on August 23, 1990.
2.
Corrective Steos Taken and Results Achieved Upon discovery that the AMSAC system was bypassed the mode switch was restored to normal. Operators were instructed on the importance of maintaining the system operable during operation above 40% power. A site deficiency document and Plant Incident Report were initiated, i
3.
Corrective Steos Which Will be Taken to Avoid Further Violations The plant operating procedure governing power operations has been changed to require verification of normal AMSAC switch alignment, and verification that system calibration is complete and current upon reaching 40% turbine power during power increases.
The response procedure for the AMSAC trouble alarm has been changed to require initiation of a site deficiency document if: 1) initial tr.M1eshooting and diagnostic actions by operators and !&C personnel fail to clear the alarm condition within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or 2)d within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
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if initial. actions indicate that-the alarm conditions cannot be cleare Operators have been made aware r.f the above described procedure changes.
Additionally, detailed.trainir.g on the change to the operating procedure governing power operation; has been included in the operator requalification training program.
' Additionally.the 11C procedures for calibration of the input signals to AMSAC have been changed to state that the. system should be left in the-nonnal mode when turbine power is greater than 40%. -This change also requires ficumentation of the as-left bypass. switch position and signoff by
-operation personnel. concurring with the as-left position.
. Although not a cause for the lack of administrative. controls cited in the violation, a design modification has been initiated which should reduce the number of spurious AMSAC trouble alarms. This modification will be.
completed consistent with the availability of naterial.
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Attachment to TXX-90551 Page 3 of 3 4.
Date When full Como11ance Will be Achieved The changes to the procedure governing power operations and to the AMSAC
uble alarm response procedure were effective August 25, 1990.
The m
associated on shift training and changes to the requalification program have bean completed.
The changes to the 1&C calibration procedures were effective September 7, 1990.
With these actions complete, TV Electric considers that full compliance has been achieved.
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