ML20086D633
| ML20086D633 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/22/1991 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-91428, NUDOCS 9111260185 | |
| Download: ML20086D633 (5) | |
Text
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ss. wi Log IXX-91428 r
file # 10130 r
IR 91-41 TU!:1 f.CIRiG November ?P, 1991
% litiam J. enhill. Jr, broug he rren.kar U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D. C.
20555
SUBJECT:
CDMANCHE PEAK STE AM ELECTRIC ST A110N (CPSES), UNil 1 DOCKEl 110. 50-445 NRC INSPECT 10!i REPORT NOS. 50-445/91-41; 50-446/91-41 RESPONSE 10 IJ0ilCE OF V10L A110N Gentlemen.
10 Electric has reviewed the NRC's letter dated October 10, 1991, concerning the inspection conducted by the IJkC staff during the period August 14 through September 24, 1991, lhis inspection covered activities authorized by NRC Operating L icense NPf -B7 and Construction Permit CPPR-l?7.
Attached to the October 10, 1991, letter was a Notice of Violation (NOV)
On November 5,1991, per a conversat ion between Mr. 1. Reis (NRC) and Mr. R. D. Walker (lU [lectric), we requested and received an extension in providing the response to this NOV until November P4, 1991.
IU Electric hereby responds to the Notice of Violation (445/9141-01) in the attachment to this letter.
Sincerely,
,h/! /
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William J. Cahill, Jr.
OB/tg Attachment c - Mr. R. D. Martin, Region IV Resident Inspettors, CPSES (?)
T. A. Bergman, NRR L, A. Yandell, Region IV
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4 Attachment to TXX-91428 Page 1 of 4 HOLICL_0E_Y10Lal10N (445/9141-01)
Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained, covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978.
Regulatory Guide 1,33 Section 8.b(1)(r) indicates that auxiliary feedwater system testing should be covered by written procedures.
Section 1 lists administrative procedures which should be provided.
Procedures OPT-206A " Auxiliary feedwater System Operability Test"; STA-205,
" Changes to Procedures"; and STA-605, "Clearence and Safety Tagging," have been established by the licensee in accordance with Technical Specification 6.8.1.
Contrary to the above, the following examples of failure to properly implement procedures were identified:
o On September 13, 1991, two valves in the auxiliary feedwater system were determined to be in a position contrary to that required following tne performance of the Surveillance Test OPT-206A.
Both suction and discharge local pressure gauge isolation valves,1 AF-146 and 1 AF-147, l
respectively, for the Unit I turbine driven auxiliary feedwater pump were found closed, o
On September 12, 1991, the annunciator response procedure for residual heat removal pump motor current fluctuations had not been placed in the main control board copy of annunciator response procedures as recuired by Procedure STA-205.
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On September 17, 1991 Train A of the engineered safety features primary plant exhaust filtration system was rendered inoperable when fire protection water was introduced into the exhaust filter chartii ' bed.
This incident occurred following the licensee's failure to ensure the adequacy of a safety clearance tagout as required by Procedure STA-605.
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Attachment to TXX-91428 Page 2 of 4 KSP_0MSL10EILCLDF V10LAU0]i (445/9141-01) 10 Electric accepts the violation and the requested information follows:
1.
Reason for ViolatiqD The review of the three examples listed in the violation, associated documents and interviews with the cognizant personnel revealed the following causes:
a.
For the two valves in the auxiliary feedwater system which were determined to be in the closed position, the Surveillance Test Procedure assumed these valves to be open to allow local indication.
If these valves were closed, they would not render the Terry Turbine inoperable as the indication is only local.
Interviews with the Auxiliary Operator (AO) concluded that the A0 followed the procedure which requires the valves to be closed, the pump to be started and the valve to be throttled to get steady indication on the local test gage.
Typically the valves are throttled to 1/4 turn open, lhe test was then completed and required data was taken.
However, the Surveillance Test Procedure did not include instructions for the A0 to re-open the valves fully; thus the valves were left in the test position.
b.
With regard to the annunciator response procedure for residual heat removal pump motor current fluctuations which was not placed in the main control board copy, there are two controlled manuals for the main control board, control copy 011A and control copy 011B.
Control Room personnel received procedure updates for control copy 011A from the Procedure Group.
When the procedure update became effective the update was inserted in control copy 011A, but not in the 0118.
It could not be concluded whether the controlled copy of the procedure change for 011B was sent for update or was misfiled. A recent audit performed on September 12, 1991, cid not find it misfiled, therefore no specific root cause could be determined. Additionally, the aforementioned audit did not identify other anomalies, i.e., missing PCNs or misfiling of the PCNs.
It is therefore concluded that this was an isolated condition.
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Attachment to TXX-91428 Page 3 of 4 c.
With regard to the introduction of fire protection water into the exhaust filter charcoal bed, it was determined that there are several causes which contributed to this violation.
Personnel reviewing the clearance request did not perform an adequate review, incorrect assumptions were made by the reviewers, and there was less than adequate communication between the maintenance crew, supervision, and the control room personnel.
Additionally, work control and clearance procedures were not adequately followed.
A common element to each of the examples of this violation was the insufficient attention to detail on part of the personnel involved.
2.
Corrective StgDs Taken and Results Achieved Corrective action documents (i.e.
O!1E Forms) were initiated for each example to address the cited conditions.
Specific actions taken for each example were; a.
A Procedure Change Notice (PCN) was issued to more clearly describe the steps to re-open the test root valves as part of restoration.
Additionally, surveillance test procedures that install test gages were reviewed and PCNS were issued for the applicable procedures to include steps to re-open root valves as part of restoration, b.
A copy of the missing procedure update was placed in the control copy 011B.
This issue was addressed in Operations Lessons Learned documents.
Additionally, the Operations Shift Attendants responsible for updating the controlled manuals were made aware of the violation and additional guidance for updating each controlled manual has been provided.
c.
With regard to the less than adequate procedural compliance and communication which led to introduction of water into the exhaust filter charcoal bed, the cognizant personnel have been counseled.
Additionally, the personnel involved with the review and approval of the suoject clearance have been reinstructed as to the requirements and their responsibilitles when reviewing and issuing clearances,
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Attachment to TXX-91428 Page 4 of 4 3.
Corrective Actions Taken to Preclude Recurrence Applicable procedures have been revised, and cognizant personnel involved have been counseled and reinstructed._ Additionally, the corrective / preventive actions have been relayed to the affected departments to enhance awareness to procedural compliance and attention
-to detail.
1 TV Electric shares the NRC concerns that these examples of incidents may indicate a larger problem.
TV Electric management-issued an instructional _ memorandum prior to the current refueling outage regarding procedural compliance and attention to detail.
TV Electric' will also monitor performance in this area to determine-if_an adver_se trend exists.
Additional corrective actions will be taken as appropriate.
4 QLte When Full Compliance Will Be Achieved f
Full compliance has been achieved.
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