ML20059K356
| ML20059K356 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/13/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 9009210266 | |
| Download: ML20059K356 (3) | |
See also: IR 05000445/1990022
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' In Reply Refer To:-
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- 50 445/90-22
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50-446/90-22
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- TU Electric.
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JATTN:
W. Ji Cahill, Jr., Executive
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Vice President, Nuclear
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Skyway Tower
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400 North Dlive Street, L.B. 81
' Dallas. Texas 75201
Gentlemen:
Thank you for your letter of September 4,1990, in response to our letter
and Notice of Violation dated August 3, 1990. We have reviewed your reply end
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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
to determine that full compliance has been achieved and will be maintained.
Sincerely.
(
InIobOSOA
Samel J. Collins, Director
Div!sion of Reactor Projects
cc:
TU Electric
ATTN:
Roger D. Walker, Manager,
. Nuclear Licensing
Skyway Tower
400 North Olive Street, L.B. 81
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Dallas, Texas 75201
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Juanita Ellis
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President:- CASE
1426 South Polk Stniet
'. Dallas, Texas' 75224
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GDS Associates, Inc.
Suite 720
1850 Parkway Place
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Marietta, Georgia 30067-8237
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-Billie Po ner Garde, Esq.
Robinson. Robinson, et. al.
103 East College Avenue
Appleton, Wisconsin 54911
=TV Electric
Bethesda Licensing
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.3 Metro Center, Suite 610.
' Bethesda, Maryland 20814
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Heron, Burchette, Ruckert, & Rothwell
. ATTN: : William A. Burchette,_Esq.
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Counsel for Tex-La Electric -
--Cooperative of Texas
1025 Thomas Jefferson St., N.W.
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Washington, D.C.
20007
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E. F. Ottney
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P.O. Box 1777
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u Glen Rose,' Texas;'76043
~Newman & Holtzinger, P.C.
ATTN:- Jack R.-Newman, Esq.
1615 L. Street, N.W.
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Suite 1000-
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' Washington, D.C. ' 20036
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, Texas' Department of Labor & Standards
ATTN:
.C. R. Bynog, Program Manager /
Chief Inspector.
Boiler Division
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P.O.- Box 12157,' Capitol Station .
- Honorable George Crump -
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County Judge-
Glen-Rose. Texas 76043
Texas Radiation Control Program Director
1100 West.49th Street.
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R. D. Martin
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Project Engineer (DRP/B)
DRSS-FRPS
Lisa Shea, RM/ALF
MIS System.
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Lop # TXX-90315
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Fi e # 10130
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IR 90-22
Ref. # 10CFR2.201
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nlELECTRIC
September 4, 1990
Wimsm J. C abm, Jr.
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U. S. Nuclear Regulatory Commission
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Attn: Document Control Desk
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COMANCHEPEAKSTEAMELECTRICSTATION(CPSES)g\\'
SUBJECT:
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DOCKET NOS. 50 445 AND 50 446
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NRC INSPECTION REPORT NOS. 50 445/90 22; 50-446/90 22
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RESPONSE TO NOTICE OF VIOLATION
Gentlemen:
TU Electric has reviewed the NRC's letter dated August 3,1990, concerning the -
inspection conducted by the NRC staff during the period June 6 through July 5,
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 August 3,1990 letter was a Notice of Violation.
TU Electric hereby responds to the Notice of Violation in the attachments to
this letter.
Since, rely,
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William J. Cahill, Jr.
VPC/vid
Attachments
c - Mr. R. D. Martin, Region IV
Resident Inspectors, CPSES (3)
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400 North Olive Street L.B. 81 Dallas, Texas 75201
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Attachment I to TXX-90315
Page 1 of 2
Notice of Violation. Item A
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(445/9022-V-02)
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Technical Specification (TS) 6.8.la requires that written procedures shall
be established, implemented, and maintained covering the activities
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referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February
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1978.
Regulatory Guide 1.33, Appendix A, Section 8.b, states that specific
procedures for surveillance tests should be written, including
implementing procedures for each surveillance required by TS.
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Procedure OPT-467A, " Train A Safeguards Slave Relay K609 Actuation Test,"
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was established in accordance with TS 6.8.1.a.
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Contrary to the above, Procedure OPT-467A was inadequate in that it did
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not provide sufficient guidance regarding the solid state protection
system switch-lineup to allow testing of the desired slave relay under the
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existing plant conditions in Mode 5 or to prevent an inadvertent automatic
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start of a motor-driven auxiliary feedwater pump.
Response to Notice of Violation. Item A
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(445/9022-V-02)
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TV Electric accepts the violation and the requested information follows.
1.
Reason for the Violatiqn
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The cause of the inadvertent automatic start of a motor-driven auxiliary
feedwater pump was attributed to inadequate personnel performance.
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Operations personnel failed to adequately utilize a system operating
procedure (SOP-711A) attachment which verifies correct Solid State
Protection System switch _ alignment. Contributing to this occurrence was
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the fact that the slave relay actuation test procedure (OPT-467A), which
was in progress just prior to the event, did not contain sufficient
prerequisite information to ensure successful test completion. The OPT
did not reference SOP 711A, which requires the operator to verify the
correct position of switches $602 and S604 prior to test performance.
This procedural omission, as well as the event and detailed corrective
actions, were discussed in LER-90-018,
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2.
Corrective Steos Taken and Results Achieved
OPT-467A was changed to provide additional prerequisite information
regarding Solid State Protection System switch lineup during testing and
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normal operation. Action taken which addressed the root cause of the
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event was addressed in LER-90-018.
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Attachment I to -TXX-90315
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Page 2 of 2.
3.
Corrective Steos Which Will be Taken to Avoid Further Violations
A review of other slave relay test procedures was performes .o identify
similar procedural inadequacies.
Procedures with similar weaknesses were
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changed such that prerequisttes now place the system in a configuration
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which accommodates test performance.
4.
Date When Full Como11ance Will be Achieved
Full compliance has been achieved.
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Attachment 2 to TXX 90315
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Page 1 of.2
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Notice of Violation. Itga.]
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(446/9022-V-01)
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B.
Criterion V of Appendix B of 10 CFR Part 50 requires, in part, that
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activities affecting quality shall be prescribed by documented
instructions, procedures, or drawings, of a type appropriate to the
circumstances and shall be accomplished in accordance with these
instructions, procedures, or drawings.
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Station Administration Manual Procedure STA 606, ' Work Requests and Work
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Orders," Revision 14, Section 6.6.2.9, requires that work be performed in
accordance with instructions and in the sequence listed,
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Contrary to the above, on June 26, 1990, the work crew opened the Unit 2
reactor coolant pump seal water return filter instead of the correct -
fi' ar when working under Work Order C90-3176 which authorized work on the
Un c 2 reactor coolant filter.
Response to Notice of Violation. Item B
(446/9022 V 01)
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TU Electric accepts the violation and the requested information follows.
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Reason for the Violation
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A Mechanical Maintenance work crew began work on the Unit 2 reactor
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coolant pump seal water return filter but failed to verify that the
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component. tag number matched that of the component identified on the Work-
Order. This resulted in work being performed on the wrong component.
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This occurrence was influenced by a sequence of events which led the work
crew involved in the Unit 2 filter replacement training exercise to
incorrectly presume that the filter worked was correct since the exercise
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was being conducted as training for the replacement of the Unit I reactor
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coolant pcmp seal water return filter.
2.
Corrective Steos Taken and Results Achieved
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ONE form, FX-90 1798, was initieted to document the failure to follow Work
Order instructions. Mechanical Mainicr.=cc ;::.sonnel involved in the Unit
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2 reactor coolant pump seal water return filter work were reminded of ohe
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importance of Work Order compliance and the need for attention to detail
in performance of assigned tasks,
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Attachment 2 to TXX 90315
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Page 2 of 2
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3.
Cartective Steos Which Will be Taken to Avoid Furthtr Violations
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The Maintenance Manager issued a memorandum to shos super'eisors to
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reemphasize the importance of procedure and/or wort instruction
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compliance.- This memorandus directed the shop supervisors to discuss ONE
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Form FX 90-1798 with their maintenance work crews and reiterate the need
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for attention to detail.
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In addition, the Maintenance Department requested an " Attention to Detail'
training course be developed by the Training Department and provided to
maintenance' personnel as part of the Maintenance Department ongoing cycle
Training Program. .Thereafter, ' Attention to Detail' training will be
repeated on a periodic basis.
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4.
pate When Full Comoliance Will be Achieved
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The actions required by the Maintenance Manager's memorandum anC
development of Atter. tion to Detail training will be completed by
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September 24, 1990.
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Attachment 3 to TXI 90315
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Page 1 of 2
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Notice of Violation. Item C
(445/9022-V 03)
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Criterion XVI of Appendix B of 10 CFR Part 50 and the licensee's quality
assurance program as described in Section 17.2.16 of the facility Safety
. Analysis Report (FSAR) requires, in part, that measures shall be established
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to assure that conditions adverse to quality, such as failure, malfunctions,
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deficiencies, deviations, defective material and equipment, and
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nonconformances are promptly identified and corrected.
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Contrary to the above, a deficiency was not promptly identified and corrected
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in that the technical disposition of operations notification and evaluation
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(ONE) Form FX-90 Il0 failed to adequately quantify the reported flange
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misalignment.
This resulted in an indeterminate residual stress condition in
the flow orifice flanged joint immediately upstream of Auxiliary Feedwater
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Check Valve IAF-093.
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Specifically, the technical 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.
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Resnonse to Notice of Violation. I,Otgl
(445/9022-V-03)
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TU Electric accepts the violatson and the requested information follows.
1.
Reason for the Violation
A site deficiency document (ONE Form) was utilized to document the
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existence of a flange misalignment problem noted during performance of a
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maintenance activity on the Auxiliary Feedwater (AFW) System. The ONE
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Form described the misalignment as approximately 1/4 inch.
In
dispositioning the ONE Form, engineering personnel did not to visually
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. examine the nonconformance to precisely quantify the extent of
misalignment. The approximately 1/4 inch misalignment originally observed
was with flange fasteners still loosely installed. Subsequent removal of
the fasteners permitted the full misalignment to be precisely determined.-
Contributing to this occurrence was the fact that the governing
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maintenance procedure.did not clearly specify that misalignment be
measured with the flange loose but fasteners installed, and then again
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when the fasteners were completely removed. This lack of clarity in the
maintenance procedure was partly a reflection of a lack of specific detail
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in the governing specification.
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Attachment 3-to TXX-90315
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Page 2 of 2
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2.
Corrective Steos Taken and Results Achieved
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After complete removal of fasteners from the subject flange, additional
measurements were taken of the misaligt.nent and the lack of face
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parallelism, and documented on a separate ONE Form.
Engineering performed
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a computer analysis of this condition and detemined that the stresses due
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to the misalignment were well below allowable limits.
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3.
Corrective Steos Which Will be Taken to Avoid Further Violations
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A letter was issued to Design Engineering Organization personnel
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emphasizing the need for personal inspections of discrepant conditions
prior to dispositioning DNE Forms, and stressing that rigorous evaluations
of nonconfoming conditions are essential.
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The lack of clarity in the maintenance procedure and governing
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specification was documented on an additional ONE Form. The engineering
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specification has been revised to provide specific guidance for flange
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alignment with the fasteners removed and with the fasteners loosely
installed. Appropriate revisions to the mechanical maintenance procedure
are in progress.
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Date When Full Comoliance Will be Achieved
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The p scedure change described above will be issued by September 30, 1990.
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