ML20058D026
| ML20058D026 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/26/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 9011050274 | |
| Download: ML20058D026 (3) | |
See also: IR 05000445/1990036
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Docket fles. 50-445/90-36
50-446/90-36
License Nos. NPF-87
CPPR-127
TV Electric
ATTH:
W. J. Cahill, Jr., Executive
Vice President, Nuclear
Skyway Tower
400 North Olive Street, L.B. 81
Dallas, Texas 75201
Gentlemen:
Thank you for your letter of October 17, 1990, in response to our letter-
and Notice of Violation dated September 17, 1990. We have reviewed your reply
and find it responsive to the concerns raised in our Notice of Violation. We
will review the implementation of your corrective actions during a future
inspection to determine that full-compliance has been achieved and will be
maintained.
Sincerely,
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Samuel J. Collins, Director
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Division,of Reactor Projects
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TU Electric
ATTN: Roger D. Walker, Manager,
Nuclear Licensing
Skyway Tower
400 North Olive Street, L.B. 81
Dallas, Texas 75201
Juanita Ellis
President - CASE
1426 South Polk Street
Dallas, Texas 75224
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GDS Associates, Inc.
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Marietta, Georgia 30067-8237
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Billie Pirner Garde, Esq.
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Robinson, Robinson, et. al.
103 East College Avenue
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Appleton, Wisconsin 54911
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TV Electric
Bethesda Licensing
3 Metro Center, Suite 610
Bethesda, Maryland 20814
Heron, Burchette, Ruckert, & Rothwell
ATTH: William A. Burchette, Esq.
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Counsel for Tex-La Electric
Cooperative of Texas
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1025 Thomas Jefferson St., N.W.
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Washington, D.C.
20007
E. F. Ottney
P.O. Box 1777
Glen Rose, Texas' 76043
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Newman & Holtzinger, P.C.
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ATTN: Jack R. Newman, Erq.
1615 L. Street, N.W.
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Suite 1000
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Washington, D.C.
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Texas Department of Labor & Standards
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ATTH:
G. R. Bynog, Program Manager /
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Chief Inspector
Boiler Division
P.O. Box 12157, Capitol Station
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Honorable George Crump
County Judge
Glen Rose, Texas 76043
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Texas Radiation Control Program Director
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R. D. Martin
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Log # TXX-90551
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File # 10130
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IR 90-36
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IR 90-36
Ref.-# 10CFR2.201
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w miam J. c.hm, Jr.
October 17, 1990
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U. S. Nuclear Regulatory Commission
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SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES).
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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:
TV Electric has reviewed the NRC's letter dated September 17, 1990, concerning
the inspection conducted by Mr. P. C. Wagner during the perio<i 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. Br0ner-
Senior Vice President-
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Attachment
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Resident Inspectors, CPSES (3)
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400 North Olive Street
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Attachment to TXX-90551
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Page 1 of 3
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(445/9036-01)
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During an NRC inspection conducted on August 20-24, 1990, a violation of NRC
requirements was identified.
In accordance with the " General Statement of
Policy and Procedure for NRC Enforcement Actions," 10 CFR 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
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quality to be prescribed by procedures of a type appropriate to the
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circumstances.
Contrary to the above, the licensee did not establish a procedure
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prescribing the administrative controls necessary to assure that the
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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)
Resoonse to Notice of Violation
(445/9036-01)
TU 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 froni 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
verify that the interlock annunciator de-energizes upon 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
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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.
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Attachment to TXX-90551
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Page 2 of 3
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On August 10, 1990, with the plant at approximately 50% 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
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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, or.rators elected to leave the system.
bypassed in an attempt to reduce these spurious alarms.- Through routine
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reviews of the annunciator out of service log, operations personnel were
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aware that there was an outstanding work request on the alarm circuit and
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were accustomed to seeing the-annunciator lit. Consequently, subsequent
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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.
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2.
Corrective Steos Taken and Results Achieved-
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Upon discovery that the AMSAC system was bypassed the mode-switch was
restored to normal, Operators were instructed on:the importance of
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maintaining the system operable during operation above 40% power. A site
deficiency document and Plant-Incident Report were initiated.
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
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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
troubleshooting and diagnostic actions by operators and I&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)_ if initial' actions
indicate that the alarm conditions cannot be cleared within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
Operators have been made aware of the above described procedure changes.
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Additionally, detailed training on the change to the operating procedure
governing power operations has been included in' the operator requalification
training program.
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Additionally, the I&C procedures for calibration ofithe input- signals to
AMSAC have been changed to state that the system should be left in the
normal mode when turbine power is greater than 40%. This change also
requires documentation of the as-left bypass switch position and signoff by
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operation personnel-concurring with the as-left position.
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Although not a cause for the lack of administrative controls cited in the
violation, a design modification has beenl initiated which should reduce the
number of spurious AMSAC trouble alarms. This modification will be
completed consis'ent with the availability of material.
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Attachment to TXX-90551
Page 3 of 3
4.
Date When Full Comoliance .9tJI be Achieved
The changes to the procedure governing power operations and to the AMSAC
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trouble alarm response procedure were effective August 25,.1990. The
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associated on-shift training and changes * to the requalification program have
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been completed.
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The changes to the I&C calibration procedures were effective September 7,
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1990.
With these actions complete, TV Electric considers that full compliance has
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been achieved.
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