ML20198S088
| ML20198S088 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/16/1998 |
| From: | Tapia J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| 50-445-97-18, 50-446-97-18, NUDOCS 9801260061 | |
| Download: ML20198S088 (4) | |
See also: IR 05000445/1997018
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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HEGION N
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' 611 RYAN PLAZA DRIVE SUITE 400
ARLINGTON, TEXAS 76011-8064
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JAN I 61998
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Mr. C. L. Terry
TU Electric
Senior Vice President and
' Principal Nuclear Officer
ATTN: Regulatory Affairs Department
P.O. Box 1002
Glen Rose, Texas 76043
SUBJECT: NRC INSPECTION REPORT 50-445/97-18; 50-446/97-18
. Dear Mr. Terry:
Thank you for your letter o' December 19,1997, in response to our letter and
Notice of Violation dated November 21,1997. We have reviewed your reply and find it
responsive to the concerns raised in our Notice of Violation. We will review the
implementation of you. corrective actions during a future inspection to determine that full
compliance has been achieved and will be maintained.
Sincerely,
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. eph I. Taple, C lef
Project Branch A
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Division of Reactor Projects
Dodket NosL: 5 01445;50-446
License Nos.: NPF-87; NPF-89 '
=cc:
Mr. Roger D. Walker
.-TU Electric -
P?gulatory Affairs Manager
T.0. Box 1002 :
Glen Rose, Texas 76043
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9901260061 990116
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Juanita Ellis
President - CASE
1426 South Polk Street
- Dallas, Texas 75224
h ^.lectric
Bothesda Licenshg
3 Metro Center, Suite 610
3ethesda, Maryland ' 20814
George L Edgar, Esq.
1800 M - Street, NW
- Washington, D.C. 20036
G. R. Bynog, Program Manager / -
Chief Inspector -
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Texas Department of Licensing & Regulation
Boiler Division
P.O. Box 12157, Capitol Station
Honorable Dale McPherson
County Judge
P.O. Box 851
~ Glen Rose, Texas 76043
Texas Radiation Control Program Director
1100 West 49th Street
Austin,7"xas 78756
John Howard, Director
Environmental and Natural Resources Policy
Office of the Governor
P.O. Box 12428 -
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- TU Electric
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JAN I 61998
bec distrib. by RIV:
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Regional Administrator
Resident inspector (2)
DRP Director
DRS-PSB
Branch Chief (DRP/A)
MIS System
Project Engineer (Dhd/A)
RIV File
Bre.nch Chief (DRP/TSS)
,
230119
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DOCUMENT NAME: R:\\_CPSES\\CP718AK.HAF.
To receive copy of document. Indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
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OFFICIAL RECORD COPY
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TU Electric
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JAN I 61998
bec to DCD (IE01)
bec distrib. by RIV:
Regional Administrator
Resident inspector (2)
DRP Director
DRS-PSB
Branch Chief (DRP/A)
MIS System
Froject Engineer (DRP/A)
RIV File
Branch Chief (DRP/TSS)
DOCUMENT NAME: R:\\_CPSES\\CP718AK.HAF
To receive copy of document, indicate In bo{C" = Copy without enclosu,as "E" a Copy with enclo ures "N" = No copy
RIV:PE:DRP/A
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RAKopriva;jes jegDJITapia L
01/o7/98
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OFFICIAL RECORD COPY
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Log # TXX 97270
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File i 10130
IR 97-18
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RIELEC7RIC'
December 19, 1997
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U. S. Nuclear Regulatory Commission
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Attn:
Document Control Desk
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Washington _0.C. 20555
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SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
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DOCKET NO. 50-445 and 50-446
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HRC INSPECTION REPORT NUMBERS 50-445/97-18 and 50-446/97-18
RESPONSE TO NOTICE OF VIOLATION
REF:
1)
TV Electric letter, logged TXX-97208. Licensee Event Report
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445/97-006-00 from C. L. Terry-to U.S. Nu-lear Regulatory
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Commission dated September 26, 1997
2)
TU Electric letter, logged TXX-97215, Supplement Licensee
Event Report 445/97-006-01 from C. L. Terry to U.S. Nuclear
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Regulatory Commission dated October 18, 1997
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TU Electric has reviewed the NRC's letter .
.-550, dated November 21, 1997,
concerning the inspections conducted by:the t:RC Resident Inspectors during the
period of August 31 through October 11, 1997. Attached to the report was a
Via Attachment 1 TV Electric hereby responds to the Notice of Violation (50-
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445(446)/9718-03 and 50-445(446)/9718 04). This communication contains no new
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licensing basis commitments regarding CPSES Units 1 and 2.
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Page 2 of 2
Should you have any comments or requit e additional information, please do not
hesitate to contact Obaid Bhatty at (254) 897-5839 to coordinate this effort.
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Sincerely,
C. L. Terry
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By- James J. Kelley, Jr.
Vice President of Nuclece
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Engineering and Support
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HJR/0AB/oab
Attachment
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cc: Mr. E. W. Merschoff, Region IV
Mr. J. I. Tapia. Region IV
Resident Inspectors
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Attachment to TXX-97273
Page 1 of 6
RESPONSE TO THE NOTICE OF VIOLATION
RESYATEMENT OF THE VI0if[10H
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(445(446)/9718 03)
A.
10 CFR Part 50, Apperidix B, Criterion V, requires, in part, that
activities affecting quality be prescribed by documented instructions of a
type appropriate to the circumstances and that the instructions include
quantitative acceptance criteria for determirnng that important activities
have Deer, satisfactorily accomplished.
Contrary to the above-
1. Procedures INC-7841X, 'ACOT/CHAN CAL (analog channel operational
te!',/ channel calibrationj Catalytic Recombiner X-01 Feed Gas Hydrogei
and Oxygen Analyzer, CH 1127A " Revision 4, and INC-7845X, "ACOT/CHAN
CAL Catalytic Recombiner X-01 Product Gas Hydrogen and Oxygen Analyzer,
CH 1128A." Revision 5, were inappropriate to the circumstances in that
they failed to include instructions for performing standardization of
the detectors prior to performing the surveillance tests.
As a
consequence, this activity was not consistently performed.
2. Procedures PPT-SX-7520A, " Control Room Ventilation Filter Test CPX-
VAFUPK-21," Revision 0, and PPT-SX-7522B, ' Control Room Ventilation
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Filter Test CPX-VAFUPK-22." Revision 0, included acceptance criteria
which was outside of the design basis. As a consequence, the
pressurization unit flow rate was lett above the design basis limit on
two occasions. Train A was left with 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 VIOLATION
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(445: 446/9718 03)
TU Electric accepts the violation, the response as requested is provided
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1 Reason for Violation
TV Electric believes taat the reasons for violation for the two events are:
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ACOT/CHAN CAL Catalytic Recombiner Hydrogen and Oxygen Analyzer Procedures
During_the September 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 detecters prior to .
performing the surveillance test.
In response, a review ,4as coM.Lcted of
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Attachment to TXX-97273
Page 2 of 6
operational and maintenance practices associated with the performance of
catalytic recombiner hydrogen and oxygen analyzer ACOT/ Channel Calibration
surveillance procedures which concluded 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
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to do 50.
Stanaardization 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
permeability of the membrane changes. When placed back in service, the
sensors are in a high humidity environment and the readings between the
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feed and product gas sensors may differ.
If the readings differ by more
than 1 percent. TU Electric performs a standardization. However, this
requirement was not proceduralized.
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TU Electric's review further concluded that the calibration procedure for
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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
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practices and system operating requirements.
Based on the above review, this violation resulted from the common
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practice of " standardization" of the detectors which was considered to be
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" tool box" knowledge (not a procedural method) available for use when
needeo by the performing technician.
Control Room Ventilation Filter Test Proceduras
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Technical Specification surveillances 4.7.7.1d.(1), 4.7.7.19 and 4.7.7.1h
require the Control Room Heating. Ventilat1ng, and Air Conditioning
Emergency Pressurization units to pass their respective surveillance
acceptance criteria while operating the unit with a flow rate of 800 cfm
110%.
Or August 6,1997, 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 800 110% by 8 cfm.
A deficiency document was initiated. 6nd the test was subsequently
conpleted 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.lg and 4.7.7.1h of
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800 110% versus Technical Specification 4.7.7.1j which requires the
emergency pressurization unit train be able to maintain a positive
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pressure of 20.125 inches water gauge during the pressurization mode of
operation at a makeup flow rate of sB00 cfm.
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The technician and his supervisor performed a review of past work orders
to 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 sB00 cfm. Two occurrences were identified where the "as
left" flows exceeded 800 cfm (both calculated at 817 cfm). A new
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Attachment to TXX-97273
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deficiency document was initiated on August 28, 1997 to address this
condition.
Because these "as left" flows invalidated tha Technical Specification 4.7.7.1j makeup flow value of 5800 cfm. this condition was
determined to be reportable es 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 )lant was outside the Technical
spec;fication value of 800 cfm on eac1 occasion, the opposite Train was
taken out of service for a total of 6 days. I hour and 41 minutes.
Because the test configuration is different for the surveillances. the
surveillances requiring flows of 800 110% and the one requiring flows s800
cfm have been typically done at different times, but within the required
frequencies.
Although the cognizant personnel identified the appropriate
acceptance <riteria as specitted in each of the CPSES Technical
Specification surveillances in the implementing test procedures, they did
not recoghize that the flow rate criteria for both surveillances measures
the system flow rate and that the acceptance criterias should not
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conflict.
Specifically, there were no requirements in the procedures to
ensure that the "as left" flows from the procedure implementing Technical Specification 4.7.7.1d.(1) 4.7.7.19 dnd 4.7.7.1h were s800 cfm as
required by Technical Specifir.ation 4.7.7.1j.
In summary. TU Electric believes that the above listed examples are a result
of less than comprehensive procedures.
2. Corrective 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 unchanged by ve revision and
there is no imDact to the previous calibration / surveillance activities or
results.
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Control Room Ventilation Filter Test Procedures
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Immediate corrective action was taken to adjust (reduce) the air flow to
s800 cfm as required by Technical Specification 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.
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Attachment to TXX-97273-
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-Also: refer to the TV-Electric responses to Licensee Event Report 445/97-
006-00 and Supplement Licensee Event Report 445/97-006-01.
3. Corrective Actions Taken to Preclude Recurrence-
ACOT/CHAN CAL Catalytic Recombiner Hydrogen and' Oxygen Analyzer Procedures
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ACOT/CHAN CAL procedures have been revised to include instructions for
hydrogen. analyzer standardization when required and Gaseous Waste
Processing System orocedure has been revised to include hydrogen analyzer
standardizations w1en the equipment is placed in service.
Control Room Ventilation Filter Test Procedures
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To prevent recurrence, applicable procedures have-been revised to include
the requirement that the "as left" condition for each test satisfies all
the applicable surveillance requirements of the other related
surveilla6ces.
24. Date of Full Comn11ance
TU Electric is in full corpliance.
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Attachment to TXX-97273
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RESTATEMENT OF THE VIOLATION
(445(446)/9718 04)
B.
Technical Specification 6.8.1 requires, in part, that the licensee
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establish, implement and maintain procedures covering the activities
referenced in Appendix A of Regulatory Guide 1.33. Revision 2. February
1978.
Appendix A requires specific orccedures for each serveillance test
listed in the Technical Specifications.
Procedure PPT-SX-7505A, " Control Room Pressurization Test Train A."
Revision 0, implemented the surveillance requirements of Technical
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Specification 4.7.7.1j.
Section 7.0 of the procedure required the use of
a temperature indicating device accurate to 12*F.
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Contrary to the above, Thermometer IC1473, which had a calibration
accuracy of 12.2*C (equivalent to 14*F), was used during the performance
of Proced0re PPT-SX-7505A on August 7, 1997.
RESPONSE TO THE VIOLATI_QJ{
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(445(446)/9718 04)
TV Electric accepts the violation, the response as requested is provided
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below:
1. Reason for Violation
The reasons for violation are:
Following completion of the Control Room Pressurization Test, it was
discovered tnat the digital thermometer used in the test did not meet the
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accuracy requirements set forth in the procedure. The procedure called
for an accuracy of 12.0 *F and the instrument used had a " Limited Use"
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calibration sticker with an accuracy of i2.2 *C.
In this event, inattention to detail by not verifying the accuracies of
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the instrumentation as specified by the procedure led to the violation.
.2. Corrective Steos Taken and Results Achieved
U)on discovery, immediate actions were taken to recalculate airflow using
t1e instrument inaccuracies of the test equipment that was used in the test
and to verify that tne Technical Specification acceptance limit of 800 cfm
was not exceeded. No additional matters of concern were identified.
3. Corrective Actions Taken to Preclude Recurren.qe
.To preclude recurrence, a Lessons Learned memorandum was issued by the
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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
accuracies 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 Conoliangg
TV Electric is in full compliance.
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