ML20197E308
| ML20197E308 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/19/1997 |
| From: | Kelley J TEXAS UTILITIES CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-445-97-18, 50-446-97-18, EA-97-550, IR-97-18, TXX-97273, NUDOCS 9712290227 | |
| Download: ML20197E308 (8) | |
Text
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llllllln:: lll-EE Log # TXX-97273
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File # 10130-r r
IR 97-18 0"
- 01 1UELECTRIC' December 19, 1997 C, l.ame Terry c,,,., % r,,,w,.,
U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC C'. "10N (CPSES)
DOCKET NO. 50-445 and 50-446 NRC INSPECTION REPORT NUMBERS 50-445/97-18 and 50-446/97-18 RESPONSE TO NOTICE OF VIOLATION l
REF:
1)
TV Electric letter, log pd TXX-97208 Licensae Event Report 445/97-006-00 from C. L. Terry to U.S. Nuclear Regulatory Commission dated September 26, 1997 2)
TV Electric letter, logged TXX-97215, Supplement Licensee Event Report 445/97-006-01 from C. L. Terry to U.S Nuclear Regulatory Commission dated October 18. 1997 TV Electric has reviewed the NRC's letter EA 97-550. dated November 21, 1997, concerning the inspections conducted by the NRC Resident Inspectors during the period of August 31 through October 11, 1997.
Attached to the report was a Notice of Violation.
Via Attachment 1 TU Electric hereby responds to the Notice of Violation (50-445(446)/9718-03 and 50-445(446)/9718-04).
This communication contains no new licensing basis commitments regarding CPSES Units 1 and 2.
I S6DI b i.l ll l.ill.il.llllilli l
9712290227 971219 PDR -ADOCK 05000445 G
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P. O. Box 1002 Glen Rose Texas 7600 s.
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'TXX-97273 Page 2aof 2 Should you have any comments or require additional information, please do not hesitate to contact Obaid Bhatty at-(254) 897-5839 to coordinate this effort.
Sincerely, C. L. Terry By:
James J. Kelley, Jr.
Vice President of Nuclear Engineering and Support MJR/0AB/oab Attachment cc: Mr. E. W. Merschoff, Region IV Mr. J.1. Tapia, Region IV Resident Inspectors 4
- ~
Attachment to TXX-97273 Page 1 of 6 RESPONSE TO THE NOTICE OF VIOLATION RESTATEMENT OF THE VIOLATION (445(446)/9718 03)
A.
10 CFR Part 50, Appendix B, Criterion V, requires, in part, that ictivities affecting quality be prescribed by documented instructions of a
_ype appropriate to the circumstances and that the irstructions include quantitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Cr.atrary to the above,
- 1. Procedures INC-7841X. "ACOT/CHAN CAL [ analog channei operational test / channel calibration] Catalytic Recombiner X-01 Feed Gas Hydrogen and Oxygen Analyzer, CH 1127A." Revision 4. and !NC-7845X. "ACOT/CHAN CAL Catalytic Recombiner X-01 Product Gas Hydrogen and Oxygen Analyzer.
CH 1128A." Revision 5, were inappropriate to the circumstance: in that they failed to include instructions for performing standardi c. ion of the detectors prior to performing the surveillance tests.
As a consequence, this activity was not consistently performed.
- 2. h ocedures PPT-SX-7520A, " Control Room Ventilation Filter Test CPX-VAFUPK-21," Revision 0, and PPT-SX-75228 " Control Room Ventilation Filter Test CPX-VAFUPK-22." Revision 0, included acceptance criteria which waa outside of the design basis. As a consequence the pressurization unit flow rate was left aDove the design basis limit on two occasions, frain A was lef*.ith a flow rate of 817 cfm from September 11, 1994, until January 12. 1996.
Train B was left with a flow rate 817 cfm from July 15, 1996 until August 8, 1997.
RESPONSE TO THE VIOLATIQN (445: 446/9718 03)
TV Electric accepts the violation, the response as requested is provided below:
- 1. Ei3 son for Violation TU Electric believes that the reasons fnr violation for the two events are:
ACOT/CHAN CAL Catal.vtic Recombiner Hydrogen and Oxygen Analyzer Procedures During the Sepcember 30, 1997 testing of the feed gas hydrogen and oxygen analyzers for Catalytic Recombiner X-01 of the waste gas holdup system, the NRC inspector noted that although the activity was not part of the procedure, the technicians had " standardized" the detectors prior to performir ; the surveillance test.
In response. a review was conducted of
Attachment to TXX-9 273 Page 2 of 6 operational and mLintenance practices associated with the performance of catalytic recunbiner hydrogen and oxyoen analyzer ACOT/ Channel Calibration surveillance procedures which con,:luded that the hydrogen analyzer was typically " standardized" prior to performing the ACOTs and then again when the analyzer was placed into service, but without a step in the procedure to do so.
Standardization allows the hydrogen analyzer to determine the detector membrane permeability of the sensors.
When out of service the hydrogen analyzer is typically placed on a dry purge gas.
During that time the permeai)ility of the membrane changes. When placed back in service, the sensors are in a high humidity environment and the readings between the feed and product gas sensors may differ.
If the readings differ by more
'han 1 percent. TU Electric performs a standardization.
However, this requirement was not procedural 1 zed.
TU Electric's review further concluded that the calibration procedure for the hydrogen analyzer required a significant amount of system knowledge to perform and that the applicable procedures should be revised to include pre-calibration checks and sensor standardization. consistent with current practices and system operating requirements.
Based on the above review, this violation resulted from the common practice of " standardization" of the detectors which was considered to be
" tool box" knowledge (not a procedural method) available for use when-needed by the performing technician.
Control Room Ventilation Filter Test Procedures Technical Specification surveillances 4.7.7.1d.(1), 4.7.7.19 and 4.7.7.1h require the Control Rcom Heating. Ventilating, and Air Conditioning Emergency PressJrization units to pass their respective surveillance acceptance criteria while operating the unit with a flow rate of 800 cfm 210%.
On August 8. 1997, during the performance of a Train A Control Room emergency pressurization unit test, a calculated intake air flow of 888 cfm was obtained which exceeded the test conditions of 800 10% by 8 cfm.
A deficiency document was initiated, and the test was subsequently completed satisfactorily following damper adjustments. The technicians performing the test discussed the test initial results with the Shift Manager.
The individuals questioned the difference between the two flow values in Technical Specifications 4.7.7.1d.(1), 4.7.7.1g and 4.7.7.1h of 800 110% versus Technical Specification 4.7.7.1j which requires the emergency pressurization unit train be able to maintain a positive pressure of 20.125 inches water gauge during the pressurization mode of operation at a makeup flow rate of s800 cfm.
The technician and his supervisor performed a review of past work orders te assess whether any "as left" calculated values from the testing for Technical Specification 4.7.7.1d.(1), 4.7.7,19 and 4.7.7.1h exceeded 800 cfm. which would invalidate the Technical Specification 4.7.7.1j makeup flow value of s800 cfm. Two occurrences were identified where the "as left" flows exceeded 800 cfm (botn calculated at 817 cfm).
A new
-Attachment to TXX-97273 Page 3 of-6 deficiency document w6s initiated on Augus' 28, 1997 to address this condition.
Because these "as left" flows invalidated the Technical Specification 4.7.7.1j ruakeup flow value of _s800 cfm. this condition was determined to be reportable as a condition outside of Technical Specifications on August 29. 1997.
On September 30, 1997, during a review of this event it was discovered that during the time period that the plant was outside the Technical specification value of 800 cfm on each occasion, the opposite Train was taken out of service for a total of 6 days. 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 41 minutes.
Because the test configuration is different for the surveillances, the surve111 onces requiring flows of 800 110% and the one requiring flaws s800 cfm have been typically done at different times, but within the required frequencies.
Although the cognizant persennel identified the appropriate acceptance criteria as specified in each of the CPSES Technical Specification survel'rces in the implementing test procedures, they did not recognize that the low rata criteria for both surveillances measures the system flow rate 4.c that the acceptance criterias should not conflict.
Specifically, there were no requirements in the procedures to ensure that the "as left" flows from the procedure implamenting Technical Specification 4.7.7.1d.(1). 4.7.7.19 and 4.7.7.1h were s800 cfm as required by Technical Specification 4.7.7.1j.
In summary. TV Electric believes that the above listed examples are a result of less than comprehensive procedures.
- 2. Correctii;; Steos Taken and Results Achieved ACOT/CHAN CAL Catalytic Recombiner Hydrogen and Oxygen Analyzer Procedures A ONE Form was issued to document the deficient condition.
A review of operational and maintenance practices as well as the ACOT/ Channel Calibration procedures associated with the waste gas analyzers was performed.
It was concluded that the applicable procedures should be revised to include pre-calibration checks and sensor standardization, consistent with current practices and system operating requirements.
The basic scope and intent of the procedures are enchanged by the revision anc there is no impact to the previous calibration / surveillance activities or results.
Control Room Ventilation Filter Test Procedures Immediate corrective action was taken to adjust (reduce) the air flow to sS00 cfm as required by Technical Specif1 cation 4.7.7.1j and the surveillance test was successfully completed. A ONE Form was issued to document the initial unsatisfactory condition.
An evaluation was conducted which concluded that the test procedures should be revised so that each surveillance measures the system flow rate and that the "as left" conditions for each test satisfy all the applicable surveillance requirements of the other related surveillances.
Attachment to TXX-97273 Page 4 of 6 Also refer to the TV Electric responses to Licensee Event Report 445/97-006-00 and Suppleinent Licensee Event Report 445/97-006-01.
- 3. Corrective Actions Taken to Preclude Recurrence ACOT/CHAN CAL Catalytic Recombiner Hydrogen and Oxygen Analyzer Procedures ACOT/CHAN CAL procedures have been revised to include instructions for hydrogen analyzer standardization when required and Gaseous Waste Processing System procedure has been revised to include hydrogen analyzer standardizations when the equipment is placed in service.
Control Room Ventilation Filter Test Procedures To prevent recurrence, applicable procedures have been revised to include the requirement that.the "as lef t" condition for each test satisfies all the applicable surveillance requirements of the other related surveillances.
- 4. Qate of Full Comoliance TU Electric is in full compliance.
, to TXX-97273
-Page'5'ofi6
-RESTATEMENT OF fHE-VIOLATION
-(445(446)/9718 04)
' B; ! Technical Specification 6.8. requires, in part. that the licensee --
' establish.:1mplement and maintain procedures covering the activities referenced.in Appendix A of Regulatory Guide 1.33, Revision 2. February 1978. Appendix A requires specific procedures for each surveillance test listed in the Technical Specifications.
Procedure PPT-SX-7505A, " Control-Room Pressurization Test Train A."
Revision 0, implemented the surveillance requirements of-Technical Specification 4.7.7.1L 'Section 7.0 of the procedure required the use of a temperature indicating device accurate to 2'F.
Contrary to the above, Thermometer IC14',a, which had a calibration accuracy of 12.2*C (equivalent to-4*F), was used during the performance of Procedure PPT-SX-7505A on August 7, 1997.
RESPONSE TO THE VIOLATION a
(445(446)/9718 04)-
TV Electric accepts the violation, the response as requested is provided below:
1, Reason for Violation N
The reasons for violation are:
.Following completion of the Control Room Pressurization Test, it was-discovered that the digital thermometer used in the test did not meet the accuracy' requirements set forth in the procedure. The procedure called for an accuracy of 12.0 'F an( the instrument used had -a " Limited Use"-
calibration sticker-with an accuracy of 12.2
- C.
.In this. event, inattention to detail by not verifying the accuracies of the instrumentation as specified by tne procedure led to the violation, 2 Corrective Steos Taken and Results Achieved Upon discovery,iimmediate actions were taken to recalculate airflow using
-the. instrument inaccuracies of the' test equipment that:was used in the test
- and to sverify that the Technical Specification-acceptance limit of 800 cfm
- was not exceeded. No additional. matters of concern were identified.
-3 Cprrective Actions Taken to Preclude Recurrencg To preclude recurrence, a Lessons Learned memorandum was' issued by the b '
c---
Attachment to TXX-97273 Page 6 of 6 System Engineering Manager emphasizing the need for System Engineering personnel to ensure the instruments used in any testing meet the required accuracles as described in the procedures and instruments that have a yellow " Limited Use" calibration tag be carefully reviewed to verify adequacy for the task at hand.
- 4. Date of Full Comoliance TU Electric is in full compliance.
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