ML20059A589

Ack Receipt of 900730 Response to Violations Noted in Insp Repts 50-445/90-19 & 50-446/90-19

ML20059A589
Person / Time
Site:	Comanche Peak
Issue date:	08/15/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 9008230122
Download: ML20059A589 (2)

See also: IR 05000445/1990019

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AS:151990

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In Reply. Refer To:

Dockets: 50-445/90-19' w

50-446/90-19: .

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TV Electric- '

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ATTN:- W. J. Cahill', Jr.',- Executive .

p Vice President, Nuclear l

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400 North 0 live' Street,' L.B. 81e i

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L Dallas, Texas 75201 E

Gentlemen:' , j

Thank you for- your letter of July 30,1990,lin response- to our letter and

Notice of Violation dated June-29, 1990. We have reviewed your veply and find

it responsive to the concerns raised-in our Notice of Violation. We will:

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review the implementation of your corrective actions during a future inspection'- [

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to detennine that full compliance has been achieved and will be maintained.-  ;

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Sincerely,  ;

Samuel- J. Collins,. Director

Division of Reactor Projects' j

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TU Electric

ATTN: : Roger D. Walker, Manager,

L Nuclear Licensing-

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Skyway Tower .. .

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400 North Olive' Street,'L.B. 81-- ,

Dallas.. Texas 175201

Juanita Ellis

President - CASE ,

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1426 South Polk ~ Street

Dallas,, Texas 075224 ,

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GDS Associates,:Inc.

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1850 Parkway Place

Ma etta, Georgia- 30067-8237  :

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. Billie Pirner Garde, Esq.,

Robinson, Robinson,'et. al. '

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103 East College Avenue..

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Appleton : Wisconsin' 54911

TV Electric

Bethesda Licensing.

23 Metro Center, Suite 610 '

Bethesda, Maryland 20814

Heron,' Bdrch'ette, Ruckert, & Rottiwell '

. ATTN: William A. Burchette, Esq.

Counsel for., Tex-La Electric

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Cooperative.'of Texas

1025-Thomas Jefferson St'., N.W.-

Washington, D.C. 20007

E. F.10ttney

,P.O. Box:1777

Glen. Rose, Texas' 76043 ...

Newman & Holtzinger, P.C.-

-ATTN: Jack R. Newman, Esq .

1615;L. Street,:N.W. . ,

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iSuite 1000;

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, . Washington,D;C. 20036

Texas Dep'artment of Labor & Standards

ATTN:' G. R.' Bynog.. Program Manager / $

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Chief. Inspector ^

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Boiler Division l 1

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P.O. Box 12157, Capitol Station

Austin, Texas 78711 ,

Honorable George Crump. I

a County Judge >

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Glen Rose, Texas -76043 x j

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L ,; Texas Radiation Control Program Director

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ResidentInspector(2)'.

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MM Log # TXX-90271

h j_ File f.10130 .

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--. -IR 90 19.  !

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7t# ELECTRIC Ref.#l0CN2$01

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wai. J. c.hm. Jr. July 30,s1990

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U. S Nuclear Regulatory Co9 mission- !I-

Attn: Document Control Desk

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l Washington -DC '20555 N

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SUBJECT: COMANCNE PEAK STEAN' ELECTRIC STATION (CPSES)'

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DOCKET NOS.,50 445 AND 50 446

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NRC INSPECTION REPORT NOS. 50 445/90 19, 50 446/90 19 ~-

RESPONSE TO NOTICE OF VIOLATION'

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Gentlemen:

TU' Electric has reviewed the NRC's letter dated June 29, ' 19'9 0,~ concerning the-

. inspection conducted by the NRC staff.during the period May 3 through-

June 5, 1990. :This inspection' covered activitiqs authorized by-NRC-Facility

Operating. License NPF-87 and NRC Construction Permit CPPR-127 for CPSES-Units

I and 2. Attached to the June: 29, 1990, letter was a Notice'of Violation.

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TV Electric hereby responds to th'e Notice of Violation in the attachment to-

this letter.

Sincerely. -

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William J. Cahill, Jr. ,

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Attachment

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Resident Inspectors, CPSES (3)

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400 North Olive Street LB. 81 Dallas, Texas 73201 ,

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Astachment to TXX-90271 l

Page 1 of S. l

NOTICE OF VIOLATION. ITEM A i

(445/9019-V 02) l

Technical Specification Surveillance' Requirement'4.4.7 requires ttiat the a'

snecific activity of the reactor coolant shall be determined to be within the-

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. limits by performance'of the sampling and:enalysis program of Table 4.4.1.

Table'4.4.1 requires,.in part, that an isotopic analysisJfor iodine'be

rerformed between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following a thermal. power change exceeding 15;

percent of the rated thermal power within a-1 hour. period.

Contrary to the above, on May 20, 1990, at 3:35 a.m.1 (CDT),:4:55:a.m. (CDT),

6:19 a.m. (CDT), and 3:25.p.m. (CDT). Unit 1 experienced power. changes that

exceeded 15 percent of rated thermal power, but no isctopic analysis for '

iodine was performed within-the specified time; interval ~.

RESPONSE TO NOTICE OF VIOLATION. ITEM A

(445/9019-V 02)

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TV Electric accepts the violation'and the requested information follows. '

L -1. Reason for the Violation

l As a result of the Steam Dump Valve testing conducted on May 20 and 21,

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reactor power changed in excess of'15 percent of: rated ~ thermal power.(RTP)

within one hour on eight separate occasions. . Review of reactor power

history revealed that the isotopic analyses; required by Technical

Specification (TS) 4.4 7 had been performed for only four of these eight

power changes. The missed surveillances.should have been performed by

0935, 1055, 1219 and 2125lon May'20.  ;

The root cause of the missed s'erveillances wasia' deficiency in the steam

dump capacity test procedure. -The procedure' stated that steam dump flow

would increase ^ reactor pover by 10 1 2. percent'for each bank of valves

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opened with generator output fixed. However,cthe changes in reactor power

observed were' greater than 15 percent during1the testing and the procedure

did not contain information to " trigger" the special condition

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y surveillance. ;l

Two other factors contributed to the violation. The Unit Supervisor

o involved in portions of the testing was aware of the changes in reactor .I

l power but did not associate those power changes 1with the need.to perform .I

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reactor coolant analyses for iodine. Additionally,-a misunderstood verbal

communication contributed to the surveillance missed at 2125 on.

l' Hay 20 for the change greater than=15 percent of RTP that occurred

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-Attachment to TXX-90271

Page 2 of 5

between 1455 and 1525 on May 20. A Unit Supervisor informed Chemistry at

1910 on May 20 that a change' greater than 13' percent of RTP withintone '

hour occurred at 1504.- A sample,-taken at 1720 as part of a 4pecial four- -

= hour frequency sampling program, was thought by the Chemistry Technician

involved to satisfy the time requirements imposed by the TS.: However,--the

time provided by the Unit Supervisor was the onset, not the conclusion, ofc

the power change. The-conclusion of the power change surveillance

actually occurred at 1525. Therefore, an additional sample should have

been taken after 1725 andiprior to 2125.

2. Corrective Steos Taken and Results Achieved

Results of samples taken on May 20 and 21 subsequent to'the-fourLmissed

on May 20. indicated that the specific activity was within TS limits.

Therefore, no.further corrective action is required.

3.

Lorrective Steos Which Will be Taken to Avoid Further Violations j

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The on shift. licensed operators were informed by Operations staff of the

missed special condition surveillances and were reminded.to remain

cognizant of power- changes and the need to perform' reactor coolant

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analysis for Iodine to meet 1TS requirements ' ;The Unit Supervisorcinvolved

in this event has been counselled on the importance of_ remaining cognizant '

of power changes and the need to perform reactor coolant analyses for

lodine to meet 15 requirements.

. Additionally, placards have been placed on the main control boards above

' the Control Rod in Hold-Out switch and below the generator. demand panel.

The placards caution the Operator to notify Chemistry of changes in excess

of 15 percent of RTP within a one hour period.

The test procedure on steam dump valves capacity will be revised to

include a " trigger" to the special condition surveillance to ensure i

inclusion in Unit 2 testing. .It-will also include a requirement for

Operations personnel to inform Chemistry personnel. of the time period the

reactor coolant sample is to be-taken to meet TS 4.4.7 surveillance

requirements.

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A review was'canducted'for the adequacy of " triggers" currently in place

for special condition surveillances and procedures revised as necessary.  !

Administrative procedures were revised to require Operations personnel to

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-include time requirements as necessar.y when requesting support from other

departments. Operation and test procedures were reviewed and revised as

necessary to include a " trigger" to the specialicondition surveillance if

the potential exists for a change in excess of 15 percent of RTP within ;I

one hour exists.

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Attachment to TXX 90271

Page:3 of 5,

To provide additional awareness of the special condition surveillance and

the need for clear communication. the Licensee Event' Report associated

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with this, event (LER-90 015 00)'.will'be reviewed by on shift licensed

operators.

4. -Date When Full ComDliance Will'be Achieved

The Unit 2 test procedure revision on-steam dump valves capacity will be

issued prior to entering Mode lifor Unit 2. i

The LER review will be' completed.by August-20,'1990.- l

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i Attachment to TXX 90271 i

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l NOTICE OF VIOLATION'. ITEM'BL

(445/9019 V-03)

8. . Criterior. V of Appendix B of 10 CFR Part'50' requires that activities ,

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affecting quality,shall be prescribed by documented instructions,_ j

procedures, or drawings,-of a type-appropriate:to_the circumstances and D

shall be accomplished in accordance'with:these instructions,' procedures.:

or_ drawings. 'It also requires that' instructions -procedures, or drawings

shall include appropriate quantitative or. qualitative acceptance. criteria!  ;

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'for determining that.important activities have been satisfactorily '

accomplished,

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Contrary to the above. Testing Manual Procedure EGT 327A, Revision 0,

, " Steam Generator < Atmospheric-Relief _ Valve. Capacity Test," specified review }

l'- criteria of 2.5 ! I percent total' rated steam-flow for the acceptable  ;

capacity of each atmospheric relief valve (ARV).; This' corresponds to a  :

steam flow rate capacity of.approximately 227.100l pounds mass per hour  :!

(1bm /hr.) to 529.900 lbm./hr. _The~ actual acceptable. capacity of the.ARVs- '

as specified by Revision.3 of Design: Basis Document (DBD) ME-202 is j

779,000 lbm./hr. to 968,0001bm./hr. *

RESPONSE TO NOTICE OF VIOLATION.-ITEM B

-(445/9019-V 03)

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L TU Electric accepts the' violation and the requested information-follows: I

1. Reason for Violation

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At the time test procedure EGT 327A, Revision 0, was written, the"

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applicable Design Basis Document!(DBD ME-202)-supported use of 2.5 1 1

percent of rated steam flow as an' acceptable value for'the capacity of an

Atmospheric Relief Valve (ARV). . Subsequently, engineering personnel. began

preparat. ion of a Design Change ~ Authorization (DCA) to the DBD..which

provided a value equivalent to approximately 5.1' percent of rated steam -

flow as the required ARV capacity.'At the same time that the.DCA was being i

prepared, the Test Review Group.(TRG) was reviewing-the test procedure.

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The engineering member of the TRG, who_was responsible for ensuring that

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the test procedure was consistent with the DBD, belonged to-a different j

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engineering organization than that which was- preparing the DCA.- "

Consequently, the TRG' engineering representative was not aware of the

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planned change to the DBD and. approved the test procedure as written. .The '

DCA was issued five days'later. -Subsequent to issuance of the DCA, the

test procedure was formally approved.by the TRG and issued. Since the DCA-

had already been issued, the established mechanisms for identifying l

changes to test procedure: references (such as the DBD) which are issued'

after the test procedure has been approved, did not identify the'DCA as  !

affecting the test procedure. '

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Attachment to TXX 90271'

Page 5 of 5

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in summary, TU Electric: considers that the engineering review and approval

process for the test procedure allowed a unique sequence of events to

result in an_ issued test, procedure which was in:onsistent witn the DBD.-

2 .~ Corrective Steos Taken and Results Achieved >

When the test procedure was performed. discrepancies were noted 7 tween

the criteria in the test procedure and the ARY-flow. rates derived from the'

test-data. Investigation of these/ discrepancies identified the procedure

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problem described above andL problems in setting the ARV; stroke leagth. I

The stroke 1ength problems are described in Licensee Event. Report (LER)

90 016 00 transmitted;by~TV Electric letter TXX-90192, dated  !

June'22, 1990. The1 stroke!1ength problems were resolvedfas stated in the

LER and the test procedure was revised to provide criter,ia for ARV' flow

rates that were consistent with the -DBD.: .The ARV capacit) was determined

to be within the revised test procedure criteria, and met the DBD

requirements. '

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A review of other test procedures was conducted to determine if similar

differences between test criteria'and the applicable DBD's existed. A . i'

sample-of 10% of the power ascension tests was used; biasing the sample to-

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those tests performed to verify design numbers such as capacities. No

discrepancies were found during.this review. This same sample of test '

procedures _was then reviewed by theLcognizant. organization for accident

analyses.- This review was'~ conducted to determine if-the test-criteria

were consistent with assumptions.used in the applicable: accident analyses. J

Ho discrepancies were: identified.  !

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Corrective Stens Which Will Be Taken To Avoid Further Violations

Subsequent to issuance of the test procedure, but prior to~ identification

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of the test procedure discrepancy, the Unit 1 engineering organization was -i

restructured such that.the TRG engineering review of test procedures ir = '

performed by Project Engineering system engineers. Project Engineering j

system engineers either originate or review proposed changes to DBDs

involving their assigned system. Thus, they are aware of-any planned DBD

changes during'their review of test procedures. ,

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The Unit 2 engineering organization is aligned in a manner'similar to

Unit 1 in that the system engineers will originate or review proposed -;

changes to DBD's involving their assigned system as well as conduct the -i

engineering review of Test Procedures. Thus the organizatioral structure i

does not allow for a separate group without. system design .esponsibility

to provide engineering review of test procedures.

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4. Date When Full ComD11ance Will Be Achieved

Full compliance has been achieved.

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