ML20137Z232

Responds to NRC 841011 Request for Addl Info Re Violations Noted in Insp Rept 50-445/84-21.Corrective Actions:Startup Administrative Procedure CP-SAP-7 Revised to Provide Instructions for Instrumentation Filling & Venting

ML20137Z232
Person / Time
Site:	Comanche Peak
Issue date:	11/05/1984
From:	Clements B TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Bangart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20137Z208	List: IR 05000445/1984021 ML20137Z232
References
TXX-#4353, NUDOCS 8510080199
Download: ML20137Z232 (4)

Text

% ~o TEXAS UTILITIES GENERATING COMPANY MKYWAY TOWER

• 400 NORTH OLIVE MTHEET. L.H. R1

• DALLAN. TEXAM 75208 November 5, 1984 v.a . sit.t.y

.. . n, ... cte..u.ru.T..s mm r< .

TXX #4353 Docket No.: 50-445 T2@20W2  %

Mr. Richard L. Bangart Region IV Comanche Peak Task Force NOV - 91984 U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement - I 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION SUPPLEMENTAL RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT No. 84-21 In our letter of August 17, 1984 (reference TXX-4253), Texas Utilities Generating Company responded to the Notices of Violations identified in Inspection Report 84-21. By your letter dated October 11, 1984 to Mr. M. D.

Spence, the NRC staff requested additional information regarding one of these violations. We are hereby responding to that request for additional information.

To aid in the understanding of our response, we have repeated the Notice of Violation, our original response, and our revised response. We feel the enclosed information to be responsive to the staff's request. If you have any questions, please advise.

Yours truly, w

BRC:kh Enclosure c: NRC Region IV - (0 + 1 copy)

Director, Inspection and Enforcement (15 copies)

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 8510000199 BW ADOCK O5000445 Mr. V. S. Noonan PDR PDR G

A DEVENDON 09' TEXAN VTELITIEN ELECTRIC COME%NY

Page 1 of 3 NOTICE OF VIOLATION Texas Utilitics Electric Company Docket: 50-445/84-21 Comanche Peak Steam Electric Station Construction Permit: CPPR-126 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:

2. Criterion 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 nucicar 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 Diesel Generator Control Circuit Functional and Start Test, 1CP-PT-29-02 RT-1, the NRC inspector noted that there was no prcrcquisite in the test procedure to provide for station service air so that Step 7.1. 6. 7 can be per formed to operate the barring device, which requires service air to function.

This became apparent to the NRC inspector when he noticed the service air 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 prcrcquisite requirement to ensure the flow gages used during Step 7.8 (Flow Adjustment) were properly filled and vented. Failure to fill and vent these detectors just prior to flow adjustment can cause erroneous 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 pegged high with no flow. It was evident that the gage was malfunctioning due to air binding or other mechanical problem.

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

Original Response Discussion 2a. As identified in the finding above, it is acknowledged that one primary support system (Scrvice Air) was not specified as a prcrcquisite requirement for conduct o f t he test. The purpose of the test section noted was to demonstrate barring device operation in the " Maintenance Mode," there fore 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 the step. At that time, two deficient conditions existed: 1) the service air prcrcquisite was overlooked during the original procedure l

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Page 2 of 3 review and approval, and 2) the STE failed to properly document the addition of the required air supply in accordance with Startup i

Administrative Procedure CP-SAP-12. The proposed corrective action below will address these two deficient conditions, since the operability of .the barring device was satisfactorily demonstrated as required in e

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

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

would not respond. TUCCo 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 j test was terminated with no data taken. On June 18, 1984, at 1950, i

the tes: section was resumed with a log cotry stating that the I&C personnel placed the flow indicator in service af ter unclogging the three-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 4 operation, it was not deemed necessary to verify instrument filling and venting as a prcrcquisite to ICP-PT-04-01. As indicated above, the crratic instrument was identified and the problem corrected prior to repeating the applicable test steps and recording the required test data.

There fore , the test procedure and results are satisfactory.

Corrective Action No rotests are required to correct the deficiencies described above. The dicsci 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 j has been instructed to ensure that test prcrcquisites receive a comprehensive review to ensure system readiness to test and correct component configuration to assure validity of the test results. All Startup personnel responsible for authorizing and performing preoperational tests have been instructed to perform a comprehensive review of test prcrcquisites prior to authorization of the tests to be. performed. .

Since preoperational test procedures are not typically used for system filling, venting and initial operation, we do not require that cach preoperational test contain prercquisites for verifying proper filling and venting of the system or instrumentation. However, for cases when preoperational test procedures are used to provide instructions for system i filling, venting, etc., Startup Administrative Procedure CP-SAP-7 will be revised to ensure that instructions are also provided for instrumentation filling and venting grior to test data acquisition.

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-.- l Page 3 of 3 Date of Full Compliance Corrective and Preventive Actions will be completed by August 15, 1984.

Revised Response t

Preventative Action i

Startup Administrative Procedure CP-SAP-7 will be revised to ensure that instructions are provided for instrumentation filling and venting prior to test data acquisition.

I Full Compliance i

Full compliance with revised preventative actions will be completed by November 2, 1984.

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