ML20154C139
| ML20154C139 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/30/1998 |
| From: | Tapia J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| 50-445-98-03, 50-445-98-3, 50-446-98-03, 50-446-98-3, NUDOCS 9810060163 | |
| Download: ML20154C139 (4) | |
See also: IR 05000445/1998003
Text
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UNITED STATES
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[ p, NUCLEAR REGULATORY COMMISSION
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aj REGION IV
4 611 RYAN PLAZA DRIVE SUITE 400
oU ARUNGTON, TEXAS 76011 8064
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SEP 3 01998
Mr. C. L. Terry
TU Electric
Senior Vice President & Principal Nuclear Officer
ATTN: Regulatory Affairs Department
.P.O. Box 1002
Glen Rose, Texas 76043
SUBJECT: RESPONSE TO NRC NOTICE OF VIOLATION
(INSPECTION REPORT 50-445/98-03; 50-446/98-03)
Dear Mr. Terry:
Thank you for your letter dated August 3,1998, in response to our July 2,1998, letter and
Notice of Violation (50-445/9803-01,50-445/9803-03,50-445(446)/9803-04,
50-445(446)/9803-05, and 50-445/9803-07) concerning several issues, including: failure to
meet the requirements for the design of the emergency core cooling system switchover, failure
to comply with 10 CFR 50.59 requirements pertaining to Unreviewed Safety Questions,
inadequate control of reactor vessel water level during reduced inventory, and failure to identify
and correct conditions adverse to quality involving fire doors. We have reviewed your reply and
find it responsive to the concerns raised in our Notice of Violation. We will review your
corrective actions during a future inspection.
As indicated in your response, TU Electric believes that Violations 50-445/9803-01 and
50-445/9803-03 met the criteria for enforcement discretion and, therefore, should not be cited.
During a meeting held on July 20,1998, you indicated that the violations were identified
independently from the NRC resident inspectors, and that timely and appropriate corrective
actions had been initiated. Your staff reemphasized the activities surrounding the reduced
inventory level problem, the corrective actions taken, and additional commitments made to
alleviate any further incidents of the identified concern. Also provided, was a demonstration,
through the use of a mock-up, of the water level problems encountered during reduced reactor
vesselinventory. After consideration of the items discussed above, the NRC concurs that i
TU Electric has met the requirements of NRC Enforcement Manual,Section VI.B.2.b, Credit for
actions related to identification. These nori-repetitive, licensee-identified and corrected
violations will be treated as non-cited violations, consistent with Section Vll.B.1 of the NRC
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Sincerel , .
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seph . Tapia, C li f
Project Branch A
Division of Reactor Projects
9810060163 980930
PDR ADOCK 05000445
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TU Electric -2 ' l
Docket' Nos.: 50-445,
50-446 i
License Nos.: NPF-87 l
- NPF-89 1
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CC:
Mr. Roger D. Walker
TU Electric -
Regulatory Affairs Manager-
P.O. Box 1002
. Glen Rose, Texas 76043 '
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Juanita Ellis
President - CASE
1426 South Polk Street
Dallas, Texas 75224
- TU Electric , l
Bethesda Licensing . _
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. - 3 Metro Center, Suite 610 :
Bethesda, Maryland 20814 -
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George L. Edgar, Esq. '
1800 M. Street, NW 1
Washington, D.C. 20036
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.. G. R. Bynog, Program Manager /
Chief Inspector
.. Texas Department of Licensing & Regulation 1
Boiler Division
" P.O. Box 12157, Capitol Station .
. Austin, Texas 78711
II
Honorable Dale McPherson
County Judge
P.O. Box 851
' Glen Rose, Texas 76043
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, ' Texas Radiation Control Program Director .
~1100 West 49th Street
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Johh Howard, Director: i
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Environmental and Natural Resources Policy .
. Office of the Governor
i . P.O. Box 12428
. Austin, Texas 78711 *
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=. = Log # TXX-98176
AUG _4 - ,
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File # 10130
l 1UELECTRIC IR 98-03
q_ Ref. # 10CFR2.201
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c. w nny August 3,1998
Senior Mce President
& PrincipalNuclear 0))fcer
U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Washington, D.C.~20555
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SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 and 50-446
NRC INSPECTION REPORT NUMBERS 50-445/98-03 and
50-446/98-03
RESPONSE TO NOTICE OF VIOLATION
Gentlemen:
TU Electric has reviewed the NRC's letter dated July 2,1998, concerning the
inspections conducted by the NRC Resident inspectors during the period of March 29
through May 9,1998. Attached to the report was a Notice of Violation.
Via the attachment to this letter, TU Electric hereby responds to the Notice of Violation
(50-445(446)/9803-04,50-445(446)/9803-05, and 50-445/9803-01,50-445/n803-03,
50-445/9803-07).
TU Electric accepts the violations, and TU Electric specifically notes full agreement
with the necessity for heightened awareness and attention to detail when in reduced '
inventory operations. However, as discussed at the July 20,1998 management
meeting with the NRC related to mid-loop level monitoring issues, TU Electric believes
that violations 50-445/9803-01 and 50-445/9803-03 met the criteria for enforcement
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discretion, and therefore should not be cited. In discussions with the NRC Resident
Inspector subsequent to the July 20,1998 meeting, he agrees that the violations were
identified independently from the NRC Resident inspectors, and that timely and
appropriate corrective actions had been initiated. At the July 20 meeting, Mr. Gwynn
(NRC Region IV) encouraged TU Electric to reiterate the basis for these violations not
being cited in the response to the Notice of Violation. The following is provided to
support this conclusion, which we believe is also consistent with the intent of the
newly issued Enforcement Guidance Memorandum 98-006.
Although he did not suspect that the test instruments had not been vented when he
directed that they be placed in service, the Shift Manager was well aware of the
potential for some air in the instrument lines (based on experience) prior to the mid-
loop level perturbations and he specifically cautioned the operators during the course
of his brief for drain down operations that they might see erratic indication on some
instruments. In addition, he made the operators aware that both the narrow range
level indication, which is the primary indication in mid-loop operations, and the
ultrasonic level indication would be reliable. The operators did see level indication
perturbations in the wide range and extended wide range indications, and due in part
COMANCHE PEAK STEAM ELECTRIC STATION
P.O. Box 1002 Glen Rose. Texas 76043-1002
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Page 2 of 3
to the caution from the Snift Manager, they were ready to control the plant evolution.
Reliable level indication was always avail 6ble and was used to control the evolution.
A conservative and appropriate decision was made to stop the change in inventory
until the erratic indication on the wide range and extended wide range levelindicators
was understood and corrective actions were initiated to resolve the indication
discrepancy.
The issues associated with this event were documented on two separate corrective
action documents, teams were appointed to investigate the issues, and TU Electric
believes that these teams identified the cited violations independent of the NRC's
identification of the violations. The NRC Senior Resident inspector was in the Control
Room when the mid-loop level perturbations occurred, and TU Electric understands
that there may be disagreement related to whether the violations were discovered by
TU Electric or the NRC Resident inspector as part of his immediate followup from his
control room observations. TU Electric feels that a reasonable interpretation of the
NRC's Enforcement Policy in this area is that the NRC intended to allow licensees the
opportunity for their corrective actions to function prior to taking enforcement actions.
TU Electric believes the NRC's current Enforcement Policy has sufficient flexibility in it
to endorse the application of the non-cited violation provisions of that policy in
situations where the indications are that the licensee would have identified and
corrected the violation as part of their corrective action program when the
identification of the violations are a part of followup actions to a self disclosing event.
TU Electric believes that they did discover the cited violations at issue in this case
independent from the NRC, however, we would certainly argue that even if we may not
have identified the violation first, it was only because of the immediate involvement of
the NRC Resident Inspector in the issue prior to completion of our corrective action
program for the issue. TU Electric believes that any other interpretation of the NRC
Enforcement Policy other than the one expressed above with respect to self
identification of violations in these situations leaves the licensee in the untenable
position of having to expedite the corrective action process to identify and document
any potential violations prior to the NRC Resident inspector, or risk the assertion that
the violations were not discovered by the licensee's corrective action program.
TU Electric acknowledges administrative errors in both configuration management and
procedural controls which contributed to the erratic indication experienced. TU
Electric believes that despite these administrative configuration management and
procedural control issues, the Comanche Peak mid-loop level instrumentation has
consistently performed it's function during reduced inventory operations due to stable
mid-loop level indications always being available via the ultrasonic monitor and the
primary level indication.
TU Electric again wishes to note that they do strongly agree with the NRC's statement
in the cover letter to inspet tion Report 98-03 that reduced inventory operations
require special attention a id a higher level of awareness. TU Electric also believes
that this special attention and awareness was present prior to commencing reduced
inventory operations as evidenced by our briefs and preparations, and during and after
the level indication perturbations as evidenced by our conservative decisions and
actions to address the issues.
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This communication contains the following new commitments which will be completed
as noted:
fJ)f Number Commitment
27155 A lessons learned on this event will be issued reminding Shift
Operations personnel that off normal conditions created as part of
a corrective action should be clearly indicated so the corrective
action in not inadvertently undone.
27156 A review of time-sensitive operator actions and associated
equipment limitations assumed in the design and licensing basis
will be conducted a 1 the applicable Design Basis Documents
(DBDs) will be rev as needed, to document these in the
operator interface sections. Calculation reviews will be included,
as appropriate. System Engineering and Operations Support will
review these changes in accordance with existing design control
procedures to ensure the ERGS are consistent.
27157 Future troubleshooting related to reduced inventory level indication
issues, if necessary, will be conducted in a more appropriately
controlled and coordinated manner. This would include, as
appropriate, having specific steps in the procedure related to the
timing of installation, filling, venting, and operation of the
temporary instrumentation.
The CDF number is used by TU Electric for the internal tracking of CPSES
commitments.
Should you have any comments or require additionalinformation. please do not
hesitate to contact Gary Merka at (254) 897-6613 to coordinate this effort.
Sincerely,
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C. L. Terry
GLM:gim
Attachment
cc: Mr. E. W. Merschoff, Region IV
Mr. J.1. Tapia, Region IV
Resident inspectors
Mr. T. J. Polich, NRR
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Attachment to TXX-98176
Page 1 of 13
RESPONSE TO THE NOTICE OF VIOLATION
RESTATEMENT OF THE VIOLATION 1
(50-445(446)/9803-04)
A. 10 CFR Part 50, Appendix B, Criterion lil, " Design Control," requires, in part, that
design control measures provide for verifying or checking the adequacy of design,
and that design changes be subject to design control measures commensurate
with those applied to the original design.
Contrary to the above, four examples were identified, where the licensee failed to
meet this requirement for the design of the emergency core cooling system
switchover from the refueling water storage tank to the containment recirculation i
sumps: 1
1
1. The licensee changed Emergency Response Guideline Procedures EOS-1.3A, i
Revision 6, and EOS-1.38, Revision 1, " Transfer to Cold Leg Recirculation," by l
adding nine additional steps and failed to revise Calculation 16345-ME(B)-389,
"RWST Setpoints, Volume Requirements and Time Depletion Analyses,"
Revision 1, which was based on a sequence of six steps to shift suction from
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the refueling water storage tank to the containment sumps for the emergency
core cooling system pumps. As a re-sult, the licensee did not verify the
adequacy of the design when they failed to account for the additional water
volume required to complete the switchover added by the additional steps.
2. Westinghouse Letter WPT-3358, dated July 16,1980, and referenced in
Calculation 16345-ME(B)-389, provided the outflow requirements during
switchover and specified that sufficient volume be provided below the empty
alarm to allow sufficient time for operator action to shut off any pump still
taking suction from the refueling water storage tank while providing adequate
net positive suction head and maintaining sufficient height above the refueling
water storage tank outlet nozzle to minimize the possibility of vortex formation.
The licensee failed to verify the adequacy of design in that neither Calculation
16345 ME(B)-320," Vortex Potential at Charging Pump Outlet in RWST,"
Revision 0, nor Calculation 16345-ME(B)-389, Revision 1, accounted for
operator response time in determining the empty alarm setpoint.
3. Calculation 16345-ME(B)-389, Revision 1, used 60 seconds for accomplishing
switchover of the containment spray system from the refueling water storage tank
(RWST) to the containment sumps as a design basis to determine the RWST
empty level alarm.
The licensee failed to verify the adequacy of design in that the opening and
closing times for the containment spray system valves to the RWST and to the
containment sumps was 120 seconds.
4. In Calculatior.16345-ME(B)-389, Revision 2, the licensee reduced the total
analyzed instrument uncertainty from 13 inches to 7 inches when determining
the RWST volume available to complete switchover to cold leg recirculation
based on the erroneous assumption that the total uncertainty was not affected by
instrument setpoint drift.
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The licensee failed to verify the adequacy of design in that the reduction in ;
uncertainty was not valid and the resultant calculation did not ensure sufficient ;
water between the switchover setpoint and the empty alarm. :
This is a Severity Level IV violation (Supplement 1) (50-445(446)/9803-04). .
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l RESPONSE TO THE VIOLATION .
l (50-445(446)/9803-04)
TU Electric accepts the violation, the response as requested is provided below: i
1. Reason for Violation
[ TU Electric believes that the reasons for each of the four examples of the violation are: i
. Emergency Response Guideline Procedures
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i The Emergency Response Guideline Procedures (ERG) EOS-1.3A and EOS-1.3B
L for " Transfer to Cold Leg Recirculation" are based on the Westinghouse Owners !
!. - Group Technical Guideline and had previously undergone extensive industry and
NRC review. The additional steps added to the procedure were technically
justifiable for response to an emergency. However, the System Engineering ,
reviews conducted prior to initial licensing on each unit for technical accuracy of the '
. ERG failed to identify that the procedure contained additional actions not included ,
in the plant specific design calculations and the response to an NRC question in the
FSAR. This oversight was due to the failure to recognize and verify time-dependent
operator action requirements. :
. Inclusion of Operator. Response Times in ECCS Pump NPSH Celculation
The calculation performed prior to initial licensing on each unit inappropriately
neglected operator response time. This oversight was due to the failure to identify
time-dependent operator action requirements. TU Electric believes that this
violation was self-identified and that appropriate corrective actions were taken.
. Containment Spray System Switchover Timing ,
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The calculation performed prior to initial licensing on each unit made assumptions
without proper consideration for the opening times of the containment spray sump
suction valves when calculating the RWST empty alarm setpoint. Nominal or
- typical times were assumed without confirming or referring to the actual installed
valve times. This oversight was due to the failure to identify and verify time-
dependent operator action requirements including the equipment limitations. TU '
Electric believes that this violation was self-identified and that appropriate
corrective actions were takenc
. RWST Level Instrument Uncertainty
TU believes that the methodology used in addressing the RWST Level Instrument
uncertainty was appropriate and that Revision 2 of Calculation 16345-ME(B)-389
correctly addressed instrument drift in the analysis of entry into EOS 1.3A and EOS
1.38 in accordance with existing procedures on receipt of a one out of four (1/4)
RWST Low-Low alarm. This assumption was confirmed by discussions with the
._ operators and examination of procedures. The minimum RWST switchover volume
available assuming the worst instrument drift and uncertainty of all four channels
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Attachment to TXX-98176
Page 3 of 13
was used in the analysis of the latest entry into the procedure and the earliest
" empty" alarm based on fullloop uncertainty including drift.
The calculation of the minimum available volume for this specific case was correct
and has been retained.
However, the calculation did not identify or address a hypothetical situation where
instrument drift and other uncertainties of one channel is indicating significantly
lower than actual and three channels are indicating significantly higher than actual.
In this case, the operator might disregard a valid 1/4 alarm and wait for the two out
of four (2/4) alarm to enter the procedure. This would hypothetically result in a
smaller available switchover volume if the operator also did not disregard the
corresponding " Empty" alarm. This condition was reported on a ONE Form and the
calculaticn was conservatively revised to address the issue and to calculate a new
(smaller) available switchover volume. By starting the switchover later, the required
switchover volume was also reduced by a reduction in the tank head. The revised
calculation concluded that adequate switchover volume was available between
existing setpoints even in the case of delayed entry into the switchover procedure.
Nevertheless, the calculation revision identified procedural enhancements which
provided design margin for this new, smaller available switchover volume.
TU Electric does not believe that the above hypothetical case is realistic because
routine surveillance of the four level channels would identify such a condition. It is
an operator practice to request re-calibration when one of the channels drifts out of
a nominal band with the other channels. Since the condition would not be
something which could occur unexpectedly after an accident, it would also be
expected that if the 1/4 low-low alarm were disregarded in favor of the other three
channels of level indication, then the operator would also disregard the 1/4 empty
alarm. This case would result in more water available for switchover (i.e. would be
bounded by the analysis of entry into the procedure on a 1/4 alarm).
In summary, design control and interface procedures were followed, reanalysis
shows that an adequate switchover volume was maintained, and the hypothetical
case could actually result in a larger available switchover volume bounded by the
previous calculation.
2. Corrective Steos Taken and Results Achieved
. Emergency Response Guideline Procedures
A Operations Notification and Evaluation (ONE) Form was issued to document the
deficient condition. Procedures EOS-1.3A and EOS-1.3B have been revised in
agreement with revised calculation 16345-ME(B)-389. Both the procedure and the
calculated water volume for the completion of the ECCS transfer are acceptable.
. Inclusion of Operator Response Times in ECCS Pump NPSH Calculation
The NPSH/ Vortex calculations and the RWST setpoint calculation were revised
during corrective action for the Containment Spray Switchover Timing issue, below,
to include operator response times. Procedures EOS-1.3A and EOS-1.3B have
been revised in agreement with revised calculation 16345-ME(B)-389. Both the
procedure and the calculated water volumes for the completion of the ECCS and
containment spray pump protection cautions are now acceptable.
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Containment Spray System Switchover Timing
A ONE Form was issued to document the deficient condition. The RWST setpoint
calculation has been revised appropriately accounting for the opening time of the
containment spray sump suction valves. Procedures EOS-1.3A and EOS-1.3B
have been revised in agreement with revised calculation 16345-ME(B)-389. Both
l- the procedure and the calculated water volumes for the completion of the ECCS
and containment spray pump transfer from inject'on to recirculation are now
acceptable. A new Low-Low alarm setpoint has been established based on these
calculations.
.
RWST Level Instrument Uncertainty
The calculations impacted by the RWST levelinstrument uncertainty error have
been revised appropriately accounting for all potential operator responses.
3. Corrective Actions Taken to Preclude Recurrence
. Emergency Response Guideline Procedures
Current procedures require System Engineering review of changes to ERGS. A
review of time-sensitive operator actions and associated equipment limitations
assumed in the design and licensing basis will be conducted and the applicable
l Design Basis Documents (DBDs) will be revised, as needed, to document these in
l the operator interface sections. Calculation reviews will be included, as
i
appropriate. System Engineering and Operations Support will review these
changes in accordance with existing design control procedures to ensure the ERGS
are consistent.
I . Inclusion of Operator Response Tirnes in ECCS Pump NPSH Calculation
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Calculation reviews will be included, as appropriate, to support the verification of
time-sensitive operator actions described above.
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Containment Spray System Switchover Timing
Calculation reviews will be included, as eapropriate, to support the review of time-
sensitive operator actions described abos e.
. RWST Level Instrument Uncertainty
No additional corrective action is required since the calculation has been revised to
- address the issue and the current setpoints were found to be acceptable.
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4. Date of Full Comoliance
TU Electric is in full compliance. The review and revision of the applicable DBDs to
include time-sensitive operator actions will be completed by December 31,1998.
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Page 5 of 13
RESTATEMENT OF THE VIOLATION
(50-445(446)/9803-05)
B.10 CFR 50.59(a)(1), in part, permits the licensee to make changes to the facility and
procedures as described in the safety analysis report without prior Commission
approval provided the change does not involve a change in the technical specifications
or an Unreviewed Safety Question (USQ).10 CFR 50.59(a)(2) defines a proposed
change as a USQ if a malfunction of a different type than any evaluated previously in
the safety analysis report may be created.
10 CFR 50.59(b)(1) requires, in part, that records of changes to the facility must
include a written evaluation which provides the bases for the determination that the
change does not involve an USQ.
Contrary to the above,
1. On January 3,1997, the licensee made a change to procedures ss described
in the safety analysis report which involved an USQ. Final Safety Analysis
Report (FSAR) Table 6.3-7 listed six manual operator steps required to
switchover the emergency core cooling system from injection. FSAR Table
6.3-11 stated that 90,166 gallons were required to complete the switchover
and that this was based on 30 seconds of operator response time for each
step. Section 6.3.2.8 stated that 94,179 gallons were available for
switchover.10 CFR 50.59, Evaluation 97-001, Revision 0, was generated to
evaluate the impact of going from six manual operator steps to the 15 steps
listed in Emergency Response Guidelines Procedures EOS-1.3A, Revision 6,
and EOS-1.313, Revision 1," Transfer to Cold Leg Recirculation." The results I
of the evaluation disclosed that the additional water volume required by the I
nine additional steps was not available. The licensee shortened the assumed i
operator response time from 30 seconds to less than 15 seconds in order to i
provide the required volume. This change increased the probability of
occurrence of a malfunction of equipment important to safety, and therefore, i
did involve a USQ which was not approved by the Commission. l
2. As of December 19,1996, Emergency Response Guidelines Procedure EOS- ,
1.3, " Transfer to Cold Leg Recirculation" had been revised to include I
additional steps to perform the manual actions required to switchover the
emergency core cooling system pumps from injection to recirculation. This
revision changed the facility as described in FSAR Table 6.3-7 and no written
safety evaluation was prepared to provide the bases for the determination
that the changes did not constitute a USQ. As a result, Table 6.3-11 was not
accurate in that it underestimated the water volume required to complete the
manual switchover.
This is a Severity Level IV violation (Supplement 1)(50-445(446)/9803-05).
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RESPONSE TO THE VIOLATION
(50-445/9803-05)
TU Electric accepts the violation, the response as requested is provide ( !xww.
1. Reason for Violation
TU Electric believes that the reasons for each of the two examples of tSe violation
are:
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Improper Unreviewed Safety Question (USQ) Determination
The 10 CFR 50.59 evaluation (SE-97-001) concluded that an Unreviewed Safety
Question (USO) did not exist in spite of an identified " slight increase" in the
probability that one low head ECCS pump and the intermediate and high head
pumps would be temporarily stopped in the event of a large break LOCA and the
specific single active failure of an RWST tank isolation valve. It concluded that this
was not an increase in the probability of a malfunction of equipment important to
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safety as previously evaluated in the FSAR because one RHR pump would continue
to perform the ECCS safety function. It noted that the safety function would be
, maintained even if all pumps were temporarily shut down to complete transfer. The
l bounding malfunction previously evaluated in the FSAR is loss of an entire
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electrical train, in the subject scenario, both trains of pumps are operating at run
, out. Any consequential failure of a pump would be bounded by the single failure
criterion. The subject evaluation was performed in responce to an attempt to
support an operability /inoperability decision. During this decision process,
assumptions were manipulated from those contained in the existing licensing basis
of record at that time. The preparer and reviewer understood that the 50.59
evaluation was not changing the facility or procedures under 10CFR50.59 and
would not be implemented. This type of "50.59/ operability evaluation" was
unprecedented and the preparer believed that engineering judgement and a
qualitative evaluation would be acceptable for the interim while corrective action
was being determined and implemented. The resulting conclusion of the evaluation
was that a USQ did not exist as documented and approved via the procedural
requirements and regulatory interpretations in existence at CPSES.
As stated in the inspection report, "the additional steps added by the changes and
the reduced response time required by these steps could reasonably increase the
probability of occurrence of a malfunction of equipment important to safety . . ."
However, the preparer and reviewers of the evaluation believed the consequences
of the malfunctions were already bounded by the existing licensing basis. As stated
previously, the evaluation was used to support an operability call as was TU
Electric's understanding of the regulatory expectation for degraded and non-
conforming conditions at the time of performance of the evaluation based on the
draft NRC positions put forth in NUREG-1606 related to 'de-facto' changes. It
should be noted that this guidance has been superseded via revision to Generic
Letter 91-18 and under the latter guidance no 10CFR50.59 evaluation would have
been called for in this instance. Accordingly, the evaluation did not support plant or
procedure changes and was not intended to support these changes when prepared.
The inappropriate conclusions as viewed by the NRC were specific to this
evaluation and are not indicative of programmatic weakness or breakdown.
. Lack of 10 CFR 50.59 Evaluation for changes to EOS-1.3A/B
As background, the procedure became discrepant from the FSAR prior to the
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issuance of the operating license for CPSES Unit 1 and therefore the application of
10CFR50 59 to this change was not required. The fact that a significant portion of
the " procedure" for transfer to cold leg recirculation was contained within the
Question and Response (O & R) section of the FSAR contributed to the emergency
response procedure /FSAR discrepancy. Specifically, the time and outflow analysis
that is currently contained within Table 6.3-11, was contained in the Q & R section.
l Therefore, during the development of the emergency operating procedure the
j information contained within Table 6.3-7 was considered by the reviewers to be the
l required steps as opposed to the entirety of the steps in the transfer process. It
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should also be noted that the applicable Q & Rs were rolled into the appropriate
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Page 7 of 13
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FSAR sections during Amendment 91 in April 1994. These misconceptions led to
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additional steps being added in accordance with the Westinghouse Owner's Group
Technical Guidelines, without due consideration of the overall effect on the
licensing basis.
With the procedure discrepant from the FSAR, future revisions to the EOS
procedures compared the changes within that revision to the licensing basis during
the required 10 CFR 50.59 review. As only the current changes were focused upon
as the activity being screened for compliance with the guidance of 10 CFR 50.59,
the existing discrepancy was never identified and therefore a full evaluation for the
existence of an Unreviewed Safety Question (USQ) did not occur.
2. Corrective Steos Taken and Results Achieved
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Improper Unreviewed Safety Questien (USQ) Determination
Per TU Electric's originalintentions, the subject evaluation was revised and
approved based on actual plant changes prepared as corrective action for the non-
conforming condition as opposed to support of operability of the initially identified
condition. The current plant design basis and procedures are in agreement
consistent with the originallicensing basis of CPSES, including operator response
times, with no USQs in existence. The FSAR is current in accordance with the
applicable regulatory requirements for the corrective action for ECCS transfer from
injection to cold leg recirculation.
. Lack of 10 CFR 50.59 Evaluation for changes to EOS-1.3A/B
The steps required to transfer from ECC3 injection to cold leg recirculation have
been thoroughly analyzed, including sequence, flows, volumes, setpoints and
timing. The procedures have been revised and evaluated for the existence of a
USO. The current plant design basis and procedures are in agreement consistent
with the original licensing basis of CPSES with no USQs in existence.
3. Corrective Actions Taken to Preclude Recurrence
. Improper Unreviewed Safety Question (USQ) Determination
The CPSES Review Guide for performing 10CFR50.59 reviews has been revised to
be consistent with the new guidance for addressing degraded and non-conforming
conditions as forwarded by Generic Letter 91-18 Supplement 1, dated October 8,
1997, and the associated guidance in NEl Guidance Document NEl 96-07. This
new guidance does not require that a 10CFR50.59 review be performed for
degraded and non-conforming conditions (de-facto changes) while they are in the
corrective action phase, unless additional compensating actions, in themselves,
require it. When following the new guidance, although operability is still addressed,
a 10CFR50.59 review is only performed if the disposition of the non-conforming
condition will result in a final configuration that is different from that described in
the "SAR" implementation of the new guidance will help preclude recurrence of
this type of violation associated with non-conforming conditions in the future
because no evaluation to determine if a USQ exists would be required.
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Page 8 of 13 l
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Lack of 10 CFR 50.59 Evaluation for changes to EOS-1.3A/B j
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As previously discussed in TXX-97049, dated February 21,1997, TU Electric
System Engineers will review the applicable sections of the FSAR that relate to
their areas of responsibility, and will complete and document these reviews by
October 18,1998. Any discrepancies will be documented and addressed as
required. The primary purpose of this review will be to reconfirm that the as-built
configuration and design documentation of their individual systems and structures
are consistent with the FSAR descriptions and the accident analysis assumptions in
Chapter 15 of the FSAR.
4. Date of Full Comoliance
TU Electric is in full compliance.
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Attachment to TXX-98176 !
Page 9 of 13
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RESTATEMENT OF THE VIOLATION
(50-445/9803-01)
l C. Technical Specification 6.8.1 states, in part, that written procedures be established,
I implemented, and maintained as recommended by Appendix A of Regulatory
l Guide 1.33, Revision 2. Regulatory Guide 1.33 specifies that procedures for
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operating safety-related pressurized water reactor systems, such as the reactor
coolant system, include instructions for filling, venting, and draining.
Contrary to the above, on April 18,1998, Integrated Plant Operating Procedure IPO-
010A, " Reactor Coolant System Reduced Inventory Operations," was used to install
temporary reactor coolant level instrumentation during reduced inventory operations
but did not include instructions for filling, venting or operating the temporary
'nstrumentation attached to the reactor coolant system and, as a result, a partialloss
of reactor coolant system level indication occurred.
This is a Severity Level IV violation (Supplement 1)(50-445/9803-01)
RESPONSE TO THE VIOLATION
(50-445/9803-01)
TU Electric accepts the violation, the response as requested is provided below:
1. Reason for Violation
TU Electric believes that the reason for the violation was an inadequate revision of
Integrated Plant Operating Procedure IPO-010A," Reactor Coolant System Reduced
Inventory Operations" prior to the sixth refueling outage on Unit 1. The procedure was
revised prior to the Unit 1 outage to add a prerequisite step for installing test gauges
on the Reactor Coolant System (RCS). The gauges were to be used as a tool to assist
in determining the cause if a discrepancy in level was encountered during initial drain
down of the RCS. The step added to the procedure did not contain enough details
related to the intended location or operation of the test gauges and consequently the
wide range and extended wide range mid-loop levelinstruments were adversely
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affected by air introduction into the sensing lines when the test gauges were valved
! into the RCS. Stable mid-loop levelindications were always available and were used
to control the evolution via the ultrasonic monitor and the primary level indication.
2. Corrective Steos Taken and Results Achieved
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The prerequisite step for installing test gauges on the RCS has been removed from
IPO-010A. Lessons Learned related to this occurance were issued to Operations and
Maintenance personnel to provide awareness of the circumstances of this occurance.
3. Corrective Actions Taken to Preclude Recurrence
Future troubleshooting related to reduced inventory levelindication issues, if
necessary, will be conducted in a more formally controlled and coordinated manner.
This would include, as appropriate, having specific steps in the procedure related to
the timing of installation, filling, venting, and operation of the test instrumentation.
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Attachment to TXX-98176 :
Page 10 of 13
4, Date of Full Comollance
TU Electric is in ' full compliance.
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Attachment to TXX-98176
Page 11 of 13
RESTATEMENT OF THE VIOLATION
(50-445/9803-03)
D. Technical Specification 6.8.1 states, in part, that written procedures be established,
implemented, and maintained as recommended by Appendix A of Regulatory
Guide 1.33, Revision 2. Regulatory Guide 1.33 specifies, in part, that procedures be
developed for planning and performing maintenance that can affect the performance of
safety-related equipment.
Accordingly, Maintenance Department Administrative Procedure MDA-111,
" Troubleshooting Activities," Section 6.3.5 stated, in part, that test equipment and test
leads be (lsted as pre-approved for use or, that their use be evaluated using a
technical evaluation.
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Contrary to the above, the pressure sensing devices, which were test equipment used
for troubleshooting, were not pre-approved for use and no technical evaluation was
performed by engineering prior to their use on April 18,1998.
This is a Severity Level IV violation (Supplement 1)(50-445/9803-03)
RESPONSE TO THE VIOLATION
j (50-445/9803-03)
l TU Electric accepts the violation, the response as requested is provided below:
l
l 1. Reason for Violation
l TU Electric believes that the reason for the violation was a misinterpretation of the
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requirements of MDA-111," Troubleshooting Activities", by the Engineering personnel
involved in the troubleshooting activities. MDA-111 requires in Section 6.3.5 that test
equipment and test leads be listed in Attachment 8.A of the procedure as pre-approved
for use or their use be evaluated using a Technical Evaluation per STA-504, " Technical
Evaluations". Because Attachment 8.A referred exclusively to electronic equipment,
the personnelinvolved incorrectly assumed that the need to perform a Technical
Evaluation did not apply to mechanical equipment.
2. Corrective Steos Taken and Results Achieved
The personnel involved in the troubleshooting activities have been re-instructed to
- document any test equipment not listed on Attachment 8.A on a Technical Evaluation
j during future troubleshooting. .
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3. Corrective Actions Taken to Preclude Recurrence
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MDA-111 has been enhanced to include more guidance related to mechanical
troubleshooting, including instructions on filling and venting, the addition of a listing of
pre-approved mechanical equipment, and clarification on the requirements for a
Technical Evaluation of test equipment used in long term troubleshooting.
4. Date of Full Comoliance
TU Electric is in full compliance.
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Page 12 of 13
RESTATEMENT OF THE VIOLATION
(50-445/9803-07)
E.10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," requires, in part, that
conditions adverse to quality, such as deficiencies and nonconformances, be promptly
identified and corrected.
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! Contrary to the above, the licensee failed to identify and correct conditions adverse to
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quality involving fire doors for the Unit 1 uninterruptible power supply rooms in that,
from March 1997 to April 1998, the licensee failed to identify that the inability of the fire
doors to remain open on the fusible links impaired the ability of the doors to properly
l function during a tornado.
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l This is a Severity Level IV violation (Supplement 1)(50-445/9803-07)
RESPONSE TO THE VIOLATION
l (50-445/9803-07)
TU Electric accepts the violation, the response as requested is provided below:
1. E ga:Lon for Violation
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On March 21,1997, the subject fire doors were identified as not being able to close
and latch properly and fire impairments were issued to track the condition. A ONE
Form was subsequently initiated on August 11,1997 to correct the condition.
However, because the condition was considered to be a fire protection deficiency
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(failure to fully close and latch) the ONE Form did not address any potentialimpact the
! doors being closed may have had on the tornado venting analysis.
l The NRC Resident inspector indicated that his memory was that he had informed TU
l Electric Shift Operations personnel that the subject fire doors were closed and he
l questioned the impact on the tornado venting analysis in November 1997. Operations
l Control Room management does not specifically recall this discussion and corrective
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actions associated with the Resident Inspector's notification could not be identified.
On April 13,1998, the doors were again found to be closed by the Resident inspector
and a ONE Form and Technical Evaluation were initiated to evaluate the impact of the
l condition on the tornado venting analysis and the doors were physically tied open.
On April 18,1998, the Resident Inspector again identified that the subject fire doors
were closed. Corrective actions from the ONE Form initiated on April 13,1998
l involved physically holding the subject doors open to prevent adverse impact on the
tornado venting analysis, however, Operations Fire Protection personnel indicated that
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they had closed the doors because they believed that, even though fire impairments
j were in place on these doors, the doors would better serve their fire protection function
- if closed. The Operations Fire Protection personnelinvolved did not fully understand
the impact on the tornado venting analysis requirements if the subject fire doors were
closed.
2. Corrective Steos Taken and Results Achieved
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The physical condition involving the subject fire doors not fully closing and latching has
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been corrected by a modification. Operations Fire Protection personnel who perform
daily walkdowns of fire doors have been re-instructed on the importance of fire door
position and corresponding impact on the tornado venting analysis.
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3. C.orr.ective Actions Taken to Preclude Recurrence
A lessons learned on this event will be issued reminding Shift Operations personnel
that off normal conditions created as part of a corrective action should be clearly
indicated so the corrective action in not inadvertently undone.
4 Date of Full Comoliance
TU Electric is in full compliance.
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