TXX-4253, Responds to NRC Re Violations Noted in Insp Rept 50-445/84-21.Corrective Actions:Deficiency Rept Completed, Operator Retrained & Sys Test Engineer Counseled on Startup Administrative Procedure Requirements

Responds to NRC Re Violations Noted in Insp Rept 50-445/84-21.Corrective Actions:Deficiency Rept Completed, Operator Retrained & Sys Test Engineer Counseled on Startup Administrative Procedure Requirements

ML20134J836
Person / Time
Site:	Comanche Peak
Issue date:	08/17/1984
From:	Clements B TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Bangart R NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
Shared Package
ML20134J823	List: ML20134J820 TXX-4253, Responds to NRC Re Violations Noted in Insp Rept 50-445/84-21.Corrective Actions:Deficiency Rept Completed, Operator Retrained & Sys Test Engineer Counseled on Startup Administrative Procedure Requirements
References
TXX-4253, NUDOCS 8508290493
Download: ML20134J836 (5)

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l TEXAS UTILITIES GENERATING COMPANY MMYWAY TOWEH

• 400 NORTil OLIVE 96THE:ET. L.11. M1

• DALLAh.TEXAM 75201

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August 17, 1984 TXX-4253 m

AUG I 71984 c Mr. Richard L. Bangart, Director Region IV Comanche Peak Task Force "

U.S. Nuclear Regulatory Commission Of fice of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Docket Nos.: 50-445 ~

50-446 Comanche Peak Steam Electric Station Response to NRC Noticos Of Violations Inspection Report No. 84-21 File No.: 10130

Dear Mr. Bangart:

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We have reviewed your letter dated July 18, 1984 on the inspection conducted by {

the Office of Inspection and Enforcement and by Mr. W. F. Smith regarding Comanche Peak, Unit 1. We have responded to the findings listed in the Appendix of that letter.

To aid in the understanding of our response, we have repeated the requirements and your findings, followed by our corrective actions. We feel the enclosed information to be responsive to the Inspector's findings. If you have any questions, please advisc.

Very truly yours, Billy R. Clements BRC:sse c: NRC Region IV - (0+1)

Director, Inspection & Enforcement (15 copics)

U.S. Nuclear Regulatory Commission 3

Washington, D.C. 20555 8508290493 841011 PDR ADOCK 05000445 G PDR s osvissax or rzzss ern.trses sz.scraic coursxr

NOTICE OF VIOLATION I .

Texas Utilitics Electric Company Docket: 50-445/84-21 Comanche Peak Steam Electric Station Construction Permit: CPPR-126 s.

Based on the results of an NRC inspection conducted during the period of June 14-16, 1984, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 49 FR-8583, dated March 8, 1984, the following violations were identified:

1. Critorion V of Appendix B to 10 CFR 50 states, in part, "Activitics affecting quality shall be prescribed by documented instructions, procedurcs, 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, on June 16, 1984, an operator proccoded to partially i open Station Service Water Chlorination Valve XSW-042 in violation of Step 5.4.1.6 of System Operating Proco, dure SOP-501A-(Rev. 0), " Station Service Water System," which requires XSW-036 to be opened. The operation was aborted and the valve restored to the shut position only after the NRC

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inspector pointed out the procedure violation. Subsequently, it was determined that the procedure was in error, thus was changed accordingly and the operation resumed by opening Valve XSW-042.

This is a Scvority Level IV Violation. (Supplement II-D) (445/8421-01)

Discussion The subject violation occurred during conduct of a preoperational test.

The CPSES Final Safety Analysis Roport (FSAR) requires trial use of plant operating procedures during the startup test program. The following is an execrpt from the CPSES FSAR, Section 14.2.9:

} 14.2.9 TRIAL USE OF PLANT OPERATING AND EMERGENCY PROCEDURES

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The plant operating emergency and surveillance procedures will be use-tested during the test program and will also be used in the development of preoperational and initial startup procedures to the extent practical.

The trial use of operating procedures serves to familiarize operating personnel with systems and plant operation during the testing phase and also serves to assure the adequacy of the procedures under actual or simulated operating conditions before plant operation begins.

Prior to fuel load, draft operating procedures may be utilized for equipment operation and may be informally altered to acct special test considerations.

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-Although the use of draft operating procedures and their informal alteration is' allowed by the FSAR, CPSES has chosen to.use approved procedures'to support testing activities in order to provide a controlled mechanism for documenting procedure deficiencies and changes. That mechanism is the temporary change process.

The operator involved-was using Syctem Operating Procedure SOP-501A, Rev.

O, 'to chlorinate the Station Serdice Water inlet. The procedure required the operation of, the _. chlorination inlet valve, XSW-036. The chlorination

' inlet valve is routinely operated and operators are familiar with 'its .

location and use. The operator opened the proper valve. However, the

. valve was tagged'XSW-042 instead of XSW-036 due to' renumbering between Revisions CP-1 'and 'CP-2 of the flow diagram. Because the procedure was in trial use as required Fy the FSAR, it had'not yet been revised to reflect the valve' number change. Therefore, even though the correct valve was operated, a violation of the procedure occurred in that the valve tagged XSW-042 was operated when the procedure called for the operation of valve XSW-036. It should be'noted that the. operator consulted with the System Test Engineer prior to-operating the valve to ensure 'thac the operation supported the' test in progress.

Corrective' Action The:on-dutyf Shif t. Supervisor initiated Deficiency Report 84-054 which was =

reviewed by.the Operations Quality Assurance Supervisor. The - De ficiency Report documented the violation of the procedure. Final disposition of the deficiency was completed on July 5, 1984, and documented appropriate retraining of the operator involved.

Preventive' Action The~ operator =has been reminded of the need to follow approved operating procedures when performing operating evolutions. In addition, he has completed. retraining involving procedures STA-205, " Temporary Changes to Procedures", and SOP-501A,' " Station Service Water System".

Furthermore, the Operations Supervisor met with each shift operating crew, including Supervisors, Reactor Operators and Auxiliary Operators to review '

,-- this incident and to emphasize the proper use 'and adherence to approved procedures.

Also, Special Order 1-50-84-003 specifies that all safety related. operating O activities _will be carried out-in accordance with approved procedures.

This Special Order is reviewed by the Shift Supervisor at ea :h shif t change. l l

Date of Full Compliance Corrective and preventive actions have been completed.

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2. Crithrion XI of Appendix B to'10 CFR 50 states in part, "

. ' . . the test program.shall include,-as. appropriate, proof test prior to installation, preoperational; tests, and operational tests during nuclear power plant or

-fuel. reprocessing plant operation of structures, systems, and components. .

Test. procedures shall include provisions.for assuring that all prercquisites for the given. test'have-been met, . . ."

a. Contrary'to the above, during the performance of the Dioscl Generator Control Circuit Functional'and Start Test, ICP-PT-29-02 RT-1, the NRC

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inspector noted~that there was no prercquisite-in the test' procedure to provide for; station service air so that Stop 7.1.6.7 can be performed-to operate the barring device, which requires service air to function. ,

'This'becamo apparent to the NRC inspector when he noticed the:scrvice >

aie piping was not connected to the barring device. In lieu of ,

service-air, the STE. utilized' temporary air from a portable air compressor, which is not addressed by the procedure.

-b. -Contrary to the above, the station service water flow balancing test procedure,-ICP-PT-04-01,- had no prercquisite requirement to ensure the flow gages used during Step 7.8 (Flow Adjustment) were properly filled  ;

.and vented. Failure to fill and vent those detectors just prior to -!

flow adjustment can cause crroncous flow gage indications. This can place the. flow data in question. As a result, during conduct of Step.

7.8~of the test, the service water flow gage for containment spray was pogged high with no flow. It was evident that the gage.was malfunctioning. ,

duc-to air binding or other mechanical' problem.

This is a Scvority Level IV-Violation. (Supplement II-E) (445/8421-02)

' Discussion 2a. As identified in the finding above, it is acknowledged'that one primary '

support system (Scrvice Air) was.not specified as a prercquisite requirement for conduct of the test. 'The purpose of the test section.

noted'was to demonstrate barring device operation in the " Maintenance-Mode," therefore an air supply was required. As no prcrcquisite existed requiring a specified air supply,'the System Test Engineer noted in the test' log that a temporary air compressor would be used to perform

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the step. -At that time, two deficient conditions existed: 1) the 4 service air prercquisite was overlooked during the original procedure review and approval, and 2) the STE failed to propecly document the

' addition of the-rcquired air supply;in accordance with Startup Administrative Procedure CP-SAP-12. The proposed corrective action bclow will address thosc~two deficient. conditions, since the operability of the barring device was satisfactorily demonstrated as required in-

.lCP-PT-29-01 RT-1, Step 7.1.6.7.

4 2b. Test Section 7.8 began June 16,.1984 at 0853. After establishing conditions required to perform the flow balance, (Steps 7.8.1 through 7.8.5) the balancing commenced at'1330. At 1500, the test chronological s

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log notes that all components were aligned and the subject flow indicator

-would not respond. TUGCo I&C personnel arrived to check the instrument at 1540. After attempting to fill and vent the instrument, it was ascertained that a three-way valve manifold was clogged. .At 1615, the test:was terminated with no data taken. On June 18, 1984, at 1950, the test section was resumed with a log entry stating that the I&C personnel placed the flow indicator in service after unclogging the

'.threc-valve manifold. . Test steps 7.8.1 through 7.8.5 were reperformed and the balance was. satisfactorily demonstrated at 2150.

Since the Service Water System was in service-for a significant length of time prior to conduct of the preoperational test, and the test procedure was.not used'for initial filling, venting and placing the system into operation,.it was not deemed necessary to verify instrument filling and venting as a prcrcquisite to ICP-PT-04-01. As indicated above, the erratic instrument was identified and the problem corrected prior to repeating the'applicabic-test steps and recording the required test data.

Thorofore, the test procedure and results are satisfactory.

, Corrective Action No rctests are required to correct the deficiencies described above. The dicscl generator cognizant System Test Engineer will be counseled on proper. utilization of Startup. Administrative Procedure requirements when procedural problems arc identified.

Preventive Action Each organization responsibic for review of preoperational test procedures has been instructed to ensure that test prercquisites roccivo a comprehensive r

review to ensure system readiness to test and correct component configuration to assure valid _ty of the test results. All Startup personnel responsibic

-for authorizing and performing preoperational tests'have been instructed to perform a comprehensiec review of test prercquisites prior to authorization of:the tests to be performed.

Since 'preoperational test procedures are not typically used for system filliag, venting and initial operation, we do not require that cach ,

preoperational test contain prcrcquisites for verifying proper filling and venting of the system cr instrumentation. However, for cases when preoperational test procedures are used to provide instructions for system filling, venting, etc., Startup Administrative Procedure CP-SAP-7 will bc >

revised to ensure that instructions are also provided for instrumentation filling and venting prior to test data acquisition.

Date of Full Compliance

' Corrective and Preventive Actions will be completed by August 15, 1984.

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