ML20059F846

Responds to NRC Re Violations Noted in Insp Repts 50-445/90-22 & 50-446/90-22 on 900606-0705.Corrective action:OPT-467A Changed to Provide Addl Prerequisite Info Re Solid State Protection Sys Switch Lineup During Testing

ML20059F846
Person / Time
Site:	Comanche Peak
Issue date:	09/04/1990
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-90315, NUDOCS 9009120032
Download: ML20059F846 (7)

Text

.. _. _ _ _ _ _ . _ . . . _

s  ;

. 'e , __

e b

i-M

== Log: # TXX-90315 File # 10130 j

L "..

t

=-

IR 90-22 (

Ref. f.'10CFR2.201 <

nlELEC7RIC . ,

September 4, 1990  :

?$T!i?$"N, '

U. S. Nuclear.. Regulatory Commission ,

Attn: Document Control Desk t Washington, DC 20555- t t

SUBJECT:

COMANCHE-PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 i NRC INSPECTION REPORT NOS, 50-445/90-22; 50-446/90-22 RESPONSE TO NOTICE OF. VIOLATION-  !

Gentlemen: -f TU Electric has reviewed the NRC's letter dated August 3,11990, concerning.the.

inspection conducted;by the NRC staff during the period June 6 through July ~ ,

1990. This inspection covered activities authorized by NRC facility Oper-+  !

License NPF-87 and NRC Construction Permit CPPR-127: for CPSES Un ' :.... t-Attached to the August 3,1990 letter was a Notice of Violation, q TU Electric hereby responds to-the Notice of Violation in.the attachments.to i this letter.

Since, rely, L

7 ,

William J.:Cahill, Jr.-

VPC/vid Attachments c - Mr. R. D. Martin, Region.IV  !

Resident Inspectors, CPSES (3) l:

l i

0'00 g[ ]

9009120032 900904 / p i' PDR ADOCK 05000445 400 North Olive Street L B. 81 Dallas, Texas 75201 I G PNU ..a ,t

>g' , .

J m

,  % .. q f i 1

' Attachment,1-to TXX-90315? ' '

Page 11of 2 Notice of: Violation. Item 'Al  ;

(445/9022-V-02) l j

A. TechnicalSpecification(TS 6.8.la requires that written procedures shall

, be established, implemented), and maintained covering the- activities referonced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

. Regulatory Guidell'.33, Appendix A, Section '8.b, states that specific procedures for. surveillance' tests should be written, including .l

implementing procedures > for each surveillance required by TS.  ;

i Procedure OPT-467A " Train A Safeguards Slave Relay K609 Actuation Test," l was established in accordance with-TS 6.8.1.a.

Contrary to the'above, Procedure OPT-467A was inadequate in that it did not provide sufficient' guidance'regarding the solid state protection system switch lineup to allow testing of the desired slave relay under the existing' plant' conditions in Mode 5 or(to prevent-an inadvertent automatic start of a motor-driven auxiliary feedwater pumpt Response to Notice of Violation. Item A

.(445/9022-V-02)

TU Electric accepts the violation and the requested information follows.

.l. Reason for~the Violation.

~~

The' cause of ',he' inadvertent 'auiomatic start 'of' a motor-driven auxiliary -

feedwater pump was -attributed;to inadequate: personnel performance.

Operations personnel

procedure >(S0P-711A)qfailed'to

' attachment which adequately utilizeSolid verifies correct a system State-operating  !

Protection System switch alignment., Contributing to this occurrence was 1 the fact that the slave relay actuation test-procedure (0PT-467A), which I was in progress just prior to the event, did not contain sufficient prerequisite'information to ensure successful test completion. The OPT did not referenceiOP-711A, which requires the' operator:to verify the-correct: position of/ switches S602 and S604 prior to test performance.

. This procedural omission] as well' as; the event = and detailed corrective actions', were .discussediin' LER-90 018.

2 ~. Corrective Steos Taken and Results Achieved l

0PT-467A was' changed to provide additional prerequisite information regarding Solid State Protection System switch lineup during testing and normalf operation. Action taken which addressed the root cause of the eventcwas addressedlin LER-90-018.

L

=-

( - . ,

- i .. [

1. j. ,

.,.. - . - t.

Attachment 1.to-TXX-903151 i Page 2 of/2 >

3; Corrective Steos' Which Will' be Taken to Avoid Further Violations--

~

A review of other' slave relay' test' procedures = was performed to identify '

similar procedural inadequacies. Procedures with similar weannesses were -  !

changed such-that prerequisites,now place the-system in a~ configuration.

'which accommodates. test performance.

4. ' Date When Full Compliance Will' be Achieved -

-Full, compliance has been achieved.

1 I

)

i I

l l

4 l

l l

l l

. _ _ - .- _ . - - . , . e

e , .

)

T l Attachment 2 to TXX-90315 -!

Page 1:of 2 q l

Notice of Violation. Item B (446/9022-V-01) ,

I B. Criterion V of Appendix B of 10 CFR Part 50 ' requires, in part, that 1 activities affecting; quality shall'be-prescribed by documented  ;

instructions, procedurest or, drawings, of a type ~ appropriate to the  ;

circumstances and shall_ be accomplished in accordance with these . 1 instructions ' procedures, or drawings.

Station Administration Manual- Procedure'STA'-606, " Work Requests and Work l Orders,"' Revision 14,.Section 6.6.2.9, requires =that work be performed in-accordance with' instructions and in the sequence listed.- '

i Contrary to the above, on: June 26, 1990, the wotk ctew opened the-Unit'2 l

. reactor coolant pump seal water < return filter instead of.the correct > .

' filter:when working under-Work Order:C90-3176 which authorized work on the 1

. Unit 2' reactor coolant filter. .

1 i

4 Response to Notice of Violation. Item B-  ?

_(446/9022-V-01) i ,

, l TV Electric accepts the violation and.the. requested information follows. j

~'i .I

, 1. Reason for the Violation 'i

. 1

. A Mechanical Maintenance work crew began work on th~e Unit .2 reactor.:

. coolant pump -seal water return filter but-failed to-. verify that the-component tag number matched:that'of the component identified on the Work  :

Order. This resulted in work being performed on;the wrong component."

This occurrence was influenced by a. sequence of events'which led the work-l_ ,

crew involved ~ in the Unit 2 filter replacement training exercise to' . I incorrectly presume that the filter worked:was correct since the ' exercise l was being conducted as training for the replacement of the Unit;l-reactor.

coolant pump seal water return- filter.

2. Corrective Steos -Taken and Results Achieved i

ONE-Form, FX-90-1798, was initiated.to document the. failure.to follow' Work' Order instructions. Mechanical Maintenance personne11 involved in the Unit -

2. reactors coolant pump seal' water return filter work were reminded of the  :

importance of Work Order compliance and the need for attention to detail-  !

in performance.of assigned tasks.,  ;

l 1,

I I

o  ;

l-I!

l~.  !

_ _ _ . . a.-. ., . . . . - . - . . .. .- .

y , ' . b

, 1 o

1

'Atttchment 2-to TXX-90315  !

1 Page 2 of 2 l

3. ' Corrective Steos Which Wiil' be' Taken to Avoid Further Violations,

!The Maintenance Manager issued a memorandum to shop supervisorsitoL i reemphasize the-importance of procedure and/or work instruction' compliance. This' memorandum directed the shop supervisors to discuss-ONE ,

Form FX-90-1798 with their maintenance work crews and reiterate the need for attention to detail, j In addition,-the Maintenance Department' requested an."Attent' ion'to Detail"'_ i training course be developed'by the Training Department and provided to o maintenance personnel as part of the Maintenance Department ongoing cycle-'

Training Program. Thereafter,' " Attention to Detail" training will be '

repeated.on a periodic basis. -

4. Date When Full Como11ance'Will be Achieved' The actions required by_the.Mainte' nance Manager's. memorandum and l develo> ment of Attention to Detail- training will be completed by q Septem)er 24, 1990. 1

. i

)

i 1

q u

i 1

y u

l l

l k . <

l l ~ - _ . . . _._. . . . . - . .. ___ _ - . - _ . . . _ -.- . . _ _ . . . .

~

+ .

y 4

Attachment'3 to TXX-90315

.Page 1;of 2' Notice of- Violation. Item' C .

(445/9022-V-03)

,. Criterion XVI of. Appendix B of'10'CFR Part 50 and the licensee's quality )

c assurance program as described in Section 17.2'16 of the Facility Safety-Analysis Re> ort:(FSAR) requires, in part,-that measures shall be established' to assure t1at conditions adverse to quality, such as failure, malfunctions,: '

deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and-corrected.

. Contrary to the above, ?a deficiency was.not promptly identified and corrected.-

in that the' technical disposition of operations notification and evaluation 1

.(ONE) Form FX-90;110 failed to adequately quantify the' reported flange , .

o misalignment. This resulted .in an indeterminate-residual stress condition' in' the' flow orifice flanged joint immediately upstream of Auxiliary Feedwater Check Valve IAF-093.

Specifically, the techuical disposition which allowed the. acceptance of the reported misalignment was inadequate in that it failed to properly consider -

the actual displacement of the flange which was physically restrained by the '

presence of several flange fasteners left in place in the flanged joint.'

i Response t'o Notice of Violation. Item C (445/9022-V-03)-

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

1. Reason for'the Violation A site deficiency document.(ONE Form) was utilized to document the existence of a flange-misalignment problem noted during performance of a

, maintenance activity on the Auxiliary Feedwater (AFW) System. The ONE Form described the misalignment asLapproximately 1/4 inch.- In dispositioning the ONE Form, engineering personnel did not to visually examine the nonconformance to precisely ouantify the extent of misalignment. - The approximately 1/4 ine's misalignment originally observed was with flange fasteners:still loosely installed. Subsequent removal of the fasteners permitted the fu111 misalignment to be precisely determined.

• Contributing to this occurrence was the fact that the governing maintenance )rocedure did not clearly specify that misalignment _ be measured wit 1 the flange loose but fasteners installed, and then:again when the fasteners were completely. removed. This lack of clarity-in the .

maintenance procedure was partly a reflection 'of a lack of specific detail in the governing. specification.

N 1

'i  % i y

, ., , 33 ,.-.w , ,

V. l -

1

^

w.  :

iAttachment 3 tos:TXX-90315' ,

j L Page 2'of 2. ]

i

,2.,-Corrective Steos Taken and Results Achieved' j After complete removal-'of. fasteners from the subject flange, additional-  ;

measurements were taken of the misalignment and-the lack of face .

l parallelism,-and documented on a separate ONE Form. Engineering performed. j a computer analysis of this condition and. determined that the stresses due H

1. ,to the misalignment were wel1 below allowable limits.- J

3. Corrective Steos Which Will' be Taken to Avoid Further Violations -

i AletterwasissuedtoDesignEnf.neeringOrganizationpersonnel emphasizing the need for persona inspections of discrepant conditions prior to dispositioning DNE Forms, and, stressing ~ that. rigorous. evaluations )

of nonconforming conditions /are essential. ~;

'The lack of clarity in the maintenance procedure and'governingi 1

' specification was documented on an additional ONE Form. The engineering 1 specification has been revised;to provide, specific guidance for flange j

, alignment with the fasteners removed and with the fasteners loosely .

u installed. Appropriate revisions to the mechani, cal maintenance procedure 1 are in progress.

1 4'. LDate When" Full -Comoliance Will' be Achieved ,

-J TNeprocedure'changedescribed'abovewil_1Ueissuedb'y[ September'30,1990.

t-

• (

k ts T

• )$

3

- - - - - _ _ . - . - . - _ . - - - - - , .w - --

. _ - . , . . -.,e., , y