TXX-4458, Responds to NRC Re Violations Noted in Insp Rept 50-445/84-45.Corrective Actions:Hang Metal Tags Referencing Leg Instrument Valves for Transmitters W/Normal Sys Operating Pressure Greater than 500 Psig Identified
| ML20128F393 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/15/1985 |
| From: | Clements B TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20128F372 | List: |
| References | |
| TXX-4458, NUDOCS 8507080223 | |
| Download: ML20128F393 (5) | |
Text
W TEXAS UTILITIES GENERATING COMPANY M K YWAY 7t BW E R
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- D AI.L A m. TE A AM 13 20 8 BILLY R CLEMENTs April 15, 1985 TXX #4458 Docket Nos. 50-445 50-446 Mr. Dorwin R. Hunter Chief, Reactor Project Branch 2 U.S. Nuclear Regulatory Commission Region IV Office of Inspection and Enforce. tent 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
Dear Mr. Hunter:
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT No.:
50-445/84-45 We have reviewed your letter dated March 21, 1985 concerning the inspection conducted by Messrs. D. L. Kelley and W. F. Smith of activities authorized by NRC Construction Permit CPPR-126 for Comanche Peak, Unit 1.
We have responded to the findings listed in Appendix A of that letter.
To aid in the understanding of our response, we have repeated the Notice of Violation followed by our response. We feel the enclosed information to be responsive to the Inspectors' findings.
If you have any questions, please advise.
Yours truly,
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Director, Inspection and Enforcement (15 copies)
U.S. Nuclear Regulatory Commission Washington, D.C.
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NOTICE OF VIOLATION 445/8445-02 Failure to nrovide adequate orocedures accrooriate to circumstances 10CFR50, Appendix "B", Criterion V requires that, " 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."
Contrary to the above, an Instrunent and Control (I&C) technician received a first degree thermal burn on his forearm while attempting to fill the reference leg on a pressurizer level detector (1-LT-0460) during hot plant conditions using a procedure that did not contain sufficient detail to accomplish the task. The ISC technician was using Instruction No. ICI-2007, " Filling and Venting Level Transmitters and Level Indicating Switches (Wet Leg)" which is a generic procedure that provides general guidelines for filling and venting level instruments. This use of a generic procedure is inappropriate for the circumstances, and appears to have directly contributed to the technician receiving thermal burns because he connected the low pressure fill equipment incorrectly and manipulated the wrong valves. This action resulted in the low pressure fill equipment being blown off and releasing hot reactor coolant to the containment atmosonere.
The I&C technician received thermal burns to his arm from the hot reactor coolant.
Discussion ICI-2007, " Filling and "enting Level Transmitters and Level Indicating Switches (Wet Leg)"
was the governing procedure. The ICI-2007 " PURPOSE" states in part ".
to provide basic guidelines for filline and ventinc.
." both coerational and non-operational systems.
In this incident the system was operational and the key procedural guidelines were:
a.
Inspect for leaks (11.1.1) b.
Vent the transmitter (11.1.4)
Check reference leg pressure with a Heise gauge (11.1.10) c.
d.
Fill reference leg IAU 11.1.15 (high pressure fill rig) if system pressure is greater than 15 psig or IAU 11.1.8 (low pressure fill rig) if system pressure is less than 15 psig.
The pressurizer reference leg has a readily accessible vent valve on the upner level near the condensing pot; consequently, the technician intended to isolate the reference leg root valve and fill the reference leg from the transmitter up throuzh the vent valve.
The technician briefed the Shift Supervisor on the evolution and requested that the reference leg root valve be closed (Operations) and the transmitter be isolated /!C)*.
Following isolation, the system was inspected and one of the drain valves was noticed to be leaking (it was tightened). The transmitter was vented then lined up for nornal operation to see if the problem had been corrected. The transmitter was still indicating incorrectly, but the drain valve leak had been stopped.
c NOTE: All instrument valves down stream of the root valve are I&C's
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Response to violation 445/8445-02 (continued)
The I&C technician had Operations close the reference leg root valve again while he isolated the transmitter by shutting both isolation valves and both cutout valves (see
., attached drawing).
The vent valve cap was removed and the vent valve cracked open to depressurize the reference leg and to verify that the reference leg root valve was not leaking. The technician hooked up his low pressure fill rig to the process side test fitting instead of the reference side. The technician opened the process isolation valve instead of the reference isolation valve and was pumping up the fill rig when he noticed pressure was increasing (both cutcut valves had been shut in previous steps). The technician then opened the process cutout valve instead of the reference leg cutout valve and the fill hose blew off the test fitting. The hot water struck him on the upper arm causing a minor first degree burn approximately 2" in diameter. The technician shut the l
process isolation valve and notified the Shift Supervisor of the problem.
The contributing factors to the incident were:
1.
The reference leg valves were not adecuately identified.
2.
The procedure did not require the technician to verify system pressure prior to hooking up the low pressure fill rig.
Corrective Action:
Positively identify all reference leg instrument valves on Barton and Rosemount non-capillary electronic level transmitters for which normal system operating pressure is greater than 500 psig or normal system operatine temperature is greater than 200*F.
Specifically, hang metal tags that read "REF LEG" or "REFERE CE LEG" en the applicable valves for the following transmitters:
1-LT-0519 1-LT-0553 1-LT-0517 1-LT-0554 1-LT-0518 1-LT-0501 1-LT-0527 1-LT-0501F 1-LT-0528 1-LT-0502 1-LT-0529 1-LT-0502F 1-LT-0537 1-LT-0503 1-LT-0533 1-LT-0504 1-LT-0539 1-LT-0459 l-LT-0347 1-LT-0459F 1-LT-0348 1-LT-0460 1-LT-0549 1-LT-0461 1-LT-0551 1-LT-0462 1-LT-0552
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Preventive Action:
Revise ICI-2007 to require sequential perfornance of the procedure and to specifically apply' to Barton transmitters on crossuricer and steam cenerator level fastruments.
' Conduct training on the revised ICI-2007 following approval.
In addition to the above preventive action, the following procedures were reviewed to determine if similar procedural problems existed:
ICI-2004 threagh ICI-2009 ICI-2020 through ICI-2029 ICI-2040 INC-7322A and INC-7725A INC-7757A and INC-7760A
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There were no, other procedural errors that would result in a similar incident.
F Implementation Da'.e:
(a) The corrective action specified above was completed 1/24/85.
(b) The preventive action specified above will be complete by */26/85.
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