ML20128N174
| ML20128N174 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/18/1993 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-93093, NUDOCS 9302230114 | |
| Download: ML20128N174 (9) | |
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File # 10010 TUELECTRIC February 18, 1993 William J. Cahill, Jr.
Group %. e President U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NO. 50-445/50-446 SELF-ASSESSMENT FOR POWER OPERATION ABOVE 5% AND AB0VE 50%
Gentlemen:
TU Electric has developed Unit 2 assessment plans which will provide management with a basis for the decision on when to proceed to power above 5% and above 50%. Elements of the plan include a self assessment'by each line organizaien, assessments by overview groups, a r';viee of performance indicators and comparison of Unit 2 performance to s'milar plants. An overview of these plans is provided for your inform:', ion in the attachment to this letter.
Sincerely, 4
h William J. Cahill, Jr.
JHG/ds c-Mr. J. L. Milhoan, Region IV Mr. L. A. Yandell, Region IV Mr. T. P. Gwynn, Region IV Resident Inspectors, CPSES (2) 9.20000 7
9302230114 900218
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PDR ADOCK 05000446 P
- 400 N. otive street LB. 81 Da!!as. Texas 75201 i
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Attachment to TXX-93093 Page 1 of 8.
1.
INTRODUCTION As part of an overall program to assure the initial startup of CPSES-Unit 2 is conducted safely, TU Electric is utilizing existing performance indicators in combination with additional self-assessments.
This information will be consolidaten in a report to p ivide TU Electric management with a basis for the decision on when to proceed above 5%-
power, and later, to proceed above 50% power..
The purpose of the assessment process is to demonstrate programs:
currently in place at CPSES are effective in controlling dual unit-operation.
In addition, due to the special requirements and conditions inherent in an initial startup program, these processes will be supplemented by special assessments to assure our readiness to proceed above 5% and 50% power and operate both units safely and effectively.
The self-assessments are being performed by line function departments 1
such as Operations, Maintenance and Engineering and are being supplemented by assessments from organizations with an overview role such as-the Independent Safety Engineering. Group (ISEG), Quality Assurance, and Plant Analysis.
Each department has identified actions which require completion prior to proceeding with power ascension beyond-5% and 50% power. For each identified action, the responsible department has developed and documented criteria for completion and evaluation. As activities are completed, the. responsible department representatives will sign off for each action identified on the readiness document signifying the completion criteria have.been met. -The self-assessments will be reviewedandevaluatedbytheStation.0perationsReviewCommittee-(SORC):
with final approval by the Vice President of Nuclear Operations prior to proceeding above the applicable power level.
A general description of some of: the -key elements of. the.self-assessment -
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plans and independent e.ssessments are provided below,.
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S Attachment'to TXX-93093.
-Page 2 of 8 II. LlHE. ORGANIZATION SELF-ASSESSMENTS A.
Pl. ANT GPERATIONS The following areas are being evaluated as part of the assessnent:
of Plant Operations:
1)
Elant Activities - Activities _and plant conditions for-each-unit will be evaluated to assure there is_no impact to the safe operation of either Unit. This review will include operatingstatus,LimitingCorditions'ofOperation(LC0's),
equipment out of service, on going naintenance, and surveillances. Also, operating experience since Unit 2 fuel load will be considered to assure any lessons. learned are-factored into continued operacional activitiesp 2)
Plant Backloa - This evaluation will assure there ar9 no open work backlog-items (i.e., Work Orders,: Engineering Technical Evaluations, ONE Forms, etc.) which could adversely impact safe and reliable operation of tb3 plant.or-taken in total, could adversely impact the plant or-overburden operations-resources. The combined Unit 1'and Unit 2 cacklog will be included in this review.
3)
Confiauration Control - This evaluation will assure operations personnel are fully aware of-plant configuration including Temporary Modifications, Clearances, and 0perating Configuration. Plant drawings and plant procedures located i
in the control room will be checked to provide confidence-tney are being maintained current.
4)
Shift Operations Trainina - A review will-be'made t' o
reassere requalification training is current'and includes power ascension activities and dual unit operation aspocts.
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This review will ensure personnel have completed'a review of Unit 1 Startup lessons learned:and non-routine plant evolutions,.
5) sinffina - This evaluation will reassure-qualified s:aff' are filling positions and control. room shif t manning is -
being-maintained in accordance with Technical Specifications. A review will be made to: assure,the control-room. staff is satisfactorily controlling in-plant operationt.:
personnel and activities. A review of use of overtime will:
be made to assure it is in compliance with Technical j
Specifications and FSAR' commitments.
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3; Attachment to TXX-93093
~ Page 3 of 8 B.
PLANT MAINTENANCE The following areas are being evaluated as part of the assessment of plant maintenance:
1) tillgrial Plant Condition - This evaluation will consist of.
plant walkdowns and a review of trend data for open work.and
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plant-housekeeping.
It will assure that the maintenance-program is effective in keeping the material condition of Unit 1 and Unit 2 such that there is no adverse impact on-safe and reliable dual unit operation.
2)
Staffina - This evaluation will reassure.that qualified a
staff are filling required positions.
The review will-assure adequate staff is available to effectively support dual unit operation and that training qualifications are current to support on going maintenance requirements for both un'its.
C.
ENGINEERIfB (SystemEngineering,DesignEngineering-and--
MaintenanceEngineering)
The following areas are being evaluated for CPSES Engineering:
1)
Work Activities - An evaluation will be made to' assure that on-going or planned activities for System Engineering and/or Maintenance Engineering in the plant for Unit 1 or Unit 2 do not adversely impa::t the safe and reliable operation of either unit.
2)
Backloo - This' evaluation will assure that there are no open engineering backlog items which could adversely affect-safe and reliable operation of the plant _or taken in total, would adversely impact the plant or overburden engineering.
resources. For Design Engineering, particular attention will be given to open design change related-documents wish-regard to plant impact. The review will assure the. combined =
backlog for Unit 1 and Unit 2 does not exceed station-expectations.
3)
Transition-- This evaluation will assure _that prior.to-exceeding 5% power, the engineering reorganization and transition to support operation of Unit 1 and Unit 2 is complete to the extent that all tasks have been assigned _and are being effectively handled. This review is also-designed to assura controls are in place to preclude errors:due to missed responsibilities or comtr.itments.-
Att'achment to TXX-93093
-Page 4 of 8
' 4) 51affina - This evaluation will reassure that a_dequate-staffing of qualified personnel are available to support:
Plant Operation and Unit 2 Initial-Startup.' for' System
' Ergineering and Maintenance Engineering, particular attention will be given to on-going workload since their-activities more directly-impact the day-to-day operation of' the plant. For Maintenance Engineering,-a review will.
assure that personnel involved in the initial!Startup Test.
Program are trained and qualified for continued test program, activities.
D.
LICENSING / COMPLIANCE The-following areas are being evaluated as part'of the assessment-of Licensing / Compliance:
1)
CommitmeD,t Review - An evaluation will be made to assurez-the commi. ment status is current and that regulatoryL commitments are being tracked and resolved in a-timely
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manner.
2)
Rfgorlable Items - This evaluation will include.a review of the number and. nature of Unit 2 1 2 actuations, reactor trips and other Licensee-Event Reports.
_A comparison of' this in'ormation will be~made to Unit 1.and other similar plant second unit initial startup performance as an indication of Unit 2 performance.
3)
Staffina - This evaluation will reassure that Licensing is.
sufficiently staffed'to support dual-unit activities.
E.
PLANT SUPPORl (Security, Fire Protection, and IndustriaT Safety)
The following areas are being valuated as_part of the assessment of Plant Support:
1)
Performance Indicators.- This_ evaluation will include a review of the number and nature of security violations, fire..
protection impairments, and-injury reports to discern the impact-of dual unit operation on security, fire protection
-and industrial safety.
j 2)
Staffino - Thit evaluation will provide reassurance that the Plant Support Organization is sufficiently staffed to"
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support dual-unit activities with qualifico personnel..
Attention will-be devoted to assure-the transition of-daily?
routines for security and fire protection personnel:to dual:
unit operation has been effective.
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Att'achment to TXX-93093 Page 5 of 8 F.
WORK CONTROL The'following areas-are being_ evaluated as part of the assessment _
of Work Control:
1)
BAcLl_qg - This evaluation will assure thct the amour.t of open maintenance does not exceed station ~_ expectations; This review will consider the number and nature of open work-for. -
Unit 1 as well as Unit 2 so that backlog _does not create an adverse impact to the safe operation of_either. tait. Also trend data vill be reviewed to identify problem areas which need to be corrected prior-_to proceeding.
2)
Schedulina - This evaiaation will-provide confidence that the scheduling process continues to be effective in coordinating and tracking open work activitiesion a daily basis for both units.
3)
Staffina.- This evaluation will' reassure that qualified staff are filling require' positions. The review will assure adequate staff is available to effectively cupport dual u' it operation and that training qualifications are.-
current to support on-going requirements for both units.
G.
CHEMISTRY The following areas are being-evaluated as part of the assessment of Chemistry:
1)
RQrk Load - This evaluation will provide-assurance thatithe chemistry staff is able to continue time'y support in obtaining--and analyzing samples as required for dual unit operation coincident with initial startup test-requirements.,
2)
Staffina - This evaluation will reassure that qualifie'd-
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staff are filling required positions. This review will also.
assure appropriate personnel. are familiar _with the: Initial ~
Startup Test program. The revi>w will assure adequate staff is available to-effectively support' dual unit operation and that training qualifications are current to support _on-going activities for both units.
H.
.BADIATION PROTECTION The following areas are being evaluated as part of the assessmentL of Radiation Protection:
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Attachment'to TXX-93093-Page:6.of 8 1)
RaJioloaical Controls
--This evaluation will-assure 1that' the abilitycto conduct;surveillances,= control.accessJverify_
shielding:and control radiological work-activities-is f
satisfactory for-continued Unit 2 power. ascension Gctivities:
toincident with Unit 1 operation..
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Radioactive Waste Processing - This evaluation will provide.
assurance that the increase'in radioactive effluents produced by dual unit _ operation does not_ impair thefsafe-processing and handling of radioactive wastes.
3)
Staffino - This evaluation will reassure that qualified staff-are: filling required positions. The review ~will' assure adequate staff.is~available to affectively. support.
-i dual unit operation and'that-training. qualifications are current to support on-going-Radiation-Protection-requirements for both units.
I.
REACTOR ENGINEERING The following area is being evaluatsdLas part of_the assessment off Reactor Engineering:
1)
Staffina -' This evaluation will assure the Reactor Engineering' staff is continuing to provide adequateJsupport' to the Initial Test program.
III. INDEPENDENT ASSESSMENTS A.
ISEG - Initial Startuo (ISU) Surveillance-Proaram
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The ISEG - ISU Surveillance program provides at -compiehensive overview of plant _ activities associcted'with the Power = Ascension' Test program.
Coverage.is intended to be provided'seven days a week with a two man surveillance _ team on duty at all t1mes. Teams' are' designed to include both Operational and Startup test, experience.
Surveillance verification of-Initial Startup test activities will; be performed during each ISU test to provide reasonable assurance-testing.is' conducted in accordance withfthe approved ISU Test program, problem areas are identified and resolved in a timely manner, and test objectives are achieved effectively.
Notification points are assigned.in test procedures _so that the
-responsible surveillance team will be afforded the opportunity-to observe preselected test attributes. Although the focus of ISEG-ISU Surveillance will be on achieving test objectives, surveillance guidelines include observations of associated W
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- Pagn 7 of: 8 operating procedure. compliance as we11Las_ observing the.
effectiveness and coordination with_other. work l groups.-ilt.is-worthy.to-note that these surveillance personnel also'have the-authority to recommend to the Shift Supervisor or Senior:TU:
Management that~ activities be stopped =1f.they deem that course-appropriate for plant safety.
This surveillance ihformation is documented daily and repor'ted weekly.
This information will-be used as part of the assessment information and included with the report ~to SORC and the Vice President of Nuclear Operations.
8.
RJSK ASSESSMENT-9 An assessment team with members from the Independent Safety (ngineering Group and Plant Analysis conducted a review of the Initial Startup (ISU) schedule to determine if planned _ activities-could adversely impact Unit 1 operation.
The team's evaluation of planned activities covered important aspects cf two= unit operation such as various plant conditions in each unit, Technical Specification requirements, safety functions:
supported by common systems, normal cr' expected alignments, planned surveillances affecting availability and procedural or administrative controls over interfaces and~ crossties.-
From this review,'the team concluded that-planned ISU activities would not adversely impact Unit 1-operation. With particular attention to activities from-fuel load through 5% power, the team determined that_ safety functions could be maintained'available:and plant conditions could be established to support Unit'2 testing 1 while Unit 1 is operating.
ISEG w:11 conduct ongoing reviews of the Unit 2-!$U to. evaluate ~
4 changes in major activities and sequences ~from those already-reviewed NrISEG. Emerging work and implementation of' administrative controls' applicable toLunit. interfaces;will be assessed as appropriate on an ongoing. basis. The intent ofsthese reviews will be to determine potential impactoto; Unit'I and maintaining availability of safety systems for Unit 2; -At the 50%i plateau,-the team will ascertain whether, Unit 2 results:have~been satisfactorily considered with respect to continuation.of' testing.
The results of'these reviews will be provided to management on an L
-ongoing basis and-subsequently documentea.
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Attachment to TXX-9309?
Page 8 of 8 C.
QUALITY ASSURANCE /00ALITY COMIRQL The assessment in this area is focusing on quality control trend information.
This information provides excellent insight in many areas, including compliance with procedures, attention to detail, se'f-verificetion and professionalism.
In addition, an audit of the Initial Startup Test program will be performed after 5% power.
The results of this audit will be included in the assessment prior to proceeding above 50% power.
D.
PLANT ANALYSIS The evaluation in this area consists of an evallation of applicable Industry Operating Experience Reports (10ER's) and deficiency document trend data to determine if any issues affect the ability of the plant to safely transition from one to two unit full power operation.
New and open 10ER data will be reviewed for new or changed information relevant to two unit operation.
The trend data base will be assessed to identify emergent trends, such as personnel errors, which may be indicative of problems arising from the transition to dual unit operation. This information will be provided to management as part of the overall self-assessment process.
IV. CONCLUSION TV Electric believes this plan is thorough, comprehensive, and broad in scope.
It reflects evaluations by a broad cross section of CPSES personnel, it utilizes existing performance and evaluation programs as well as assessment criteria developed specifically for this purpose. TV Electric is confident that this plan will provide suf 3 icient information as a basis for the decision to safely proceed beyond 5% power and later, 50% power.
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