ML20199J539
| ML20199J539 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/02/1998 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20199J510 | List: |
| References | |
| NUDOCS 9802050337 | |
| Download: ML20199J539 (11) | |
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Attachment 2 to TXX 98021 Page 1 of 11 COMANCHE PEAK STEAM ELECTRIC STATION k
1 COMMITMENT MATERIAL CHANGE EVALUATION REPORT 0002 FEBRUARY 2, 1996 AUGUST 1, 1997 TEXAS UTILITIES ELECTRIC COMPANY jaa290gg;gggggt,\ j
Attachment 2 to TXX 98021 Page 2 of 11 Attached Commitment liaterial Chanaes .
CHCE 96 01 CHCE 96 08 CHCE 96 11 CHCE 96 13 CHCE 97 01 CHCE 97 02 CHCE 97 03 CHCE 97 05
Attachment 2 to TXX 96021 r Page 3 of 11 -
CHCE 96 01 Commitment Number: 14823 Deletion: or Revision: _x_
Source Document: TXX 4494, GL 85 02 Original Commitment
Description:
14823 When a pressure boundary is breached, housekeeping cleanliness control .
i requirements are established commensurate with the systems importance to safety.
Procedures implementing requirements for personnel, material and tool accountability for these designated areas are in force. Access and egress from :
zones requirement personnel and/or material and tool accountability is controlled 't and monitored by an individual assigned responsibility for this function, i 14822 It is the responsibility of tho QA section personnel or Responsible Work Organization (RWO) independent verifiers to verify the housekeeping / cleanliness
. control requirements are being maintained to establish procedural requirements.
Revised Commitwent'
Description:
(Italics) -
Procedures to preclude introduction of foreign material into plant systems (including the primary and secondary sides of steam generators whenever they are opened) have been developed and implemented at CPSES. These procedures include provisions for detailed accountability of personnel, tools and equipment used during an operation, controls over foreign objects such as eye glasses and film badges, cleanliness requirements. This is the responsibility of the GA section personnel or RWO independent veriffers to verify the housekeeping / cleanliness control requirements are being maintained to establish procedural requirements.
Justification for Change:
Combining commitments does not reduce the original level of quality assurance, invoke an increase in accident consequence, create a new accident or reduce the margin of plant safety.
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4 Attachment 2 to TXX 98021 Page 4 of 11 CHCE 96 08 Commitment Number: 24796 Deletion: or Revision: _ x_
Source Document: TXX 90031. TXX 90268 SSER 24 See: APP C.C.4, Pg: 41 and GL 89 13 3riginal Commitment
Description:
The Component Cooling Pump, Containment Spray and Safety Injection pump lube oil <
coolers will not be tested. However, lube oil temperature will be recorded during monthly surveillance runs of the associated pumps and the trends will be analyzed -
quarterly. In addition, these heat exchangers will be visually inspected at least ,
once every three years. Service water flowrates to these components will be tonitored on a weekly basis to verify that the flow rates meet design requirements.
Revised Commitment
Description:
(Italics)
The Component Cooling Pump, Containment Spray and Safety Injection pump lube oil coolers will not be tested. However, lube oil temperature will be recorded during quarterly surveillance runs of the associated pumps and the trends will be '
analyzed quarterly. In addition, these heat exchangers will be visually inspected 1 at least once every three years. Service water flowrates to these components will be monitored on a weekly basis to verify that the flow rates meet design requirements.
Justification for Change:
The CCP, CT and SI pump surveillance runs were quarterly at the time the commitment was made and are quarterly at present. The procedure for performing the surveillance clearly indicates the periodicity is quarterly.
The lube oil temperature recorded in surveillance tests were committed to be analyzed quarterly. The analysis is required if any actions would be taken and the frequency of the analysis is unchanged. Generic Letter 89 13. Recommended Action II, concerns verifying heat transfer capability of all safety related heat exchanger cooled by service water. This. commitment combining monitoring lube oil temperatures and inspecting the CCP, CT and SI pump lube 011 coolers complies with the generic letter as an acceptable alternate to testing.
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Attachment 2 to TXX 98021 1 Page 5 of 11 l
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CHCE 96 11 Commitment Number: 18385. 18387, 18390 Deletion: x or Revision: ,
Source Document: TXX 88406. TXX 88657 Original Cocaiteent
Description:
I 183M [CPSES) will revise the appropriate procedures to require the Assistant '
RPM's review and approval of significant radiation protection activities beyond the routine activities carried out by the Radiation Protection Supervisors or the health physicists or engineers on his/her staff. In addition, the Assistant RPM ,
responsibilities include developing, reviewing, and approving radiation protection programs and procedures.
18387 The Assistant RPM will be given stop work Authority where RAD Protection 1ssues involve.
182M The assistant RPM also has the following responsib111 ties: 1. Supervising the r3diation protection staff health physicists and engineers. 2. Ensuring that radiation protection programs and procedures are being properly implemented.
- 3. Analyzing trends in radiation work performance of station personnel '
contamination and exposure control, and job exposures, and taking necessary actions to correct adverse trends. 4. Reviewing and approving the station radiation protection training program. 5. Directing the evaluation and disposition of problems, incident reports and quality assurance issues that relate to radiation protection to ensure appropriate action is taken. 6. Participating on the Station ALARA Review Group (SARG) as a member addressing, evaluating and implementing, as appropriate ALARA concerns to enhance radiation safety at CPSES.
- 7. Communicating directly to the Manager, Plant Operations or the VP, Nuclear Operations or, any unresolved or urgent radiation protection related issue.
Revised Commitment
Description:
(Italics)
None Justification for Change:
The existence of an Assistant RPM docs not affect any plant system does not reduce.
the original level of quality assurance, invoke an increase in accident consequence, create a new accident or reduce the margin of plant safety. The Assistant RPM poJit 4r was required in 1988 because the existing RPM did not meet RG 1.8 criteria. The current RPM and any future RPM will meet the regulatory guidance criteria for the position. All commitments for an Assistant RPM will be deleted.
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Attachment 2 to TXX 98021 Page 6 of 11 i
CMCE 96 13 Commitment Number: 14823 ,
Deletion: or Revision:_,x_
Source Document: TXX 4494, Generic Letter 85 02 Original Commitment
Description:
Procedures to preclude introduction of foreign material into plant systems (including the primary and secondary sides of steam generators whenever they are These procedures include
-opened) have been developed and implemented at CPSES.
provisions for detailed accountability of personnel, tools and equipment used during an operation, contr:1s over foreign objects such as eye glasses and film badges, cleanliness requirements. It is the responsibility of the QA section
>ersonnel or Responsible Work Organization's independent verifiers to verify the 1out1 keeping / clean 11 ness control requirements are being maintained to establish
-procedural requirement:;.
, Revised Commitment
Description:
(Italics)
Procedures to preclude introduction of foreign material into plant systems (including the primary and secondary sides of steam generators whenever they are >
opened) have been developed and implemented at CPSES. These procedures include provisions for detailed accountability of fdeleted personnel] tools and equipment used during an operation, controls over foreign objects such as eye glasses and film badges, cleanliness requirements. It is the responsibility of the QA section personnel or Responsible Work Organization's independent verifiers to verify the housekeeping / cleanliness control requirements'are being maintained to establish procedural requirements.
Justification for Change:
The original response provided details regarding the housekeeping practices in affect at CPSES during construction and personnel accountability was required per ANSI N45.2.3 1973. Per Regulatory Guide 1.39 discussion in the FSAR, CPSES committed to ANSI N18,7 1976 for housekeeping >ractices during operations. N18.7 does not require personnel accountability for 1ousekeeping activities. The revision of the commitment does not reduce the original level of quality assurance, invoke an increase in accident consequence, create a new accident or
. reduce the margin of plant safety.
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Attachment 2 to TXX 98021 Page 7 of 11 CNCE 97 01 Page 1 of 2 ,
Commitment Number: 23558
, Deletion: or Revision: _x_,
! Source Document: TXX 89645. TXX 90058 Original Commitment
Description:
In order to preclude recurrence, appropriate maintenance procedures will be revised b conduct continuity checks whenever a breaker is removed from its connected
. position. Additionally, Westinghouse has recommended inspection of the W 2 cell switch internal structure every ten years. Due to plant experience at CPSES which identified s) ring deformation at six to seven years, TUE will revise tha procedures to inspect t1e switch internal structure every five years, while continuing Westinghouse recommended continuity checks. The appropriate maintenance procedure
-revisions will be completed prior to Unit 1 and 2 fuel loads.
The second corrective action stated in the letter was to perform continuity checks
' each time a breaker is removed from its connected position. This action is no longer required, since our evaluation of the applications of the cell switches concluded that failure of the cell switches at CPSES would not adversely affect platit safety.
The third and last corrective action stated in the letter was to perform inspections every five years. These periodic inspections will be performed as normal preventive maintenance. The results of the first inspections will determine whether future inspections are warranted.
Revised Commitment
Description:
(Italics)
NOTE:. The first two corrective actions have not changed.
The third corrective action of TXX-89645 was to perform inspections every five years. The results of the first inspection will determine whether future inspections are warranted. These periodic inspections have been performed on Unit 1 1E 480v swt tchgear and part of linit 21E 480v switchgear. The results of the inspections have found few problems with the W-2 cell switches. Based on these findings and that the reevaluation which found the failure of these cell switches would not adversely affect plant operations or safety; the requirement to inspect the W-2 cell switches independently from the breaker is no -longer necessary and'should be tied to the periodically scheduled-breaker
. preventive maintenance, Where the in?pection of the W2-cell switch should not exceed 7 years.
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Attachment 2 to TU 98021 Page 8 ef 11 1
CMCE 97 11 Page 2 of 2 Commitment Number: 23558 Deletion: er Revision: _x__
- Justification for Change
Inspections which have been performed since the Unit I cell switch replacement (or the spring retainer assembly) found only 9 cell switch problems which required replacement. Seven of these were to replace the spring retainer assembly only.
The two cell switch replacements were done as a conservative measure, not because of failure.
As stated in TXX 90058, the reevaluation concluded that if any of the cell cwitches were to fail, it would not adversely affect the safety of )lant operations.
-Compliance is being preserved by continuing W 2 cell switc1 inspections during scheduled outages. The original inspection requirement is no longer necessary and 1s tied to the periodic scheduled breaker preventive maintenance plans.
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Attachment 2 to TXX 98021 -
Page 9 of 11 )
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CHCE 97 02 ,
Commitment Number: 26492 Deletion:_x__ or Revision:
Source Document: TXX 93117 TXX 93132, LER 92 029 00 Original Commitment
Description:
Engineering will enhance their procedural training-program for Engineering Outage Team personnel unfamiliar with procedures they do not normally use in their non outage task, i
J Revised Commitment
Description:
(Italics)
None 4
Justification for Change:
The primary focus of the Inspection Re) ort, LER and responses, were deficiencies in the temporary modification program. T1e requirement to enhance outage training listed in the LER was appropriate as an immediate response to the incident. Outage training.needs are currently assessed by each organization as they plan an outage.
Groups using loaned )ersonnel, particularly for testing, routinely provide training in order to ensure t1at temporary personnel are qualified to perform duties.
Retaining this commitment is not necessary to prevent recurrence of the deficiencies _ identified in the temporary modification program.
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Attachment 2 to-TXX 98021 Page 10 of-11
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4 CMCE 97 03 Commitment Number: 26491 Deletion:_x__ or Revision:
Source Document (Level 0): TXX 93117. TXX 93132, LER 92 029 00 Original Commitment
Description:
Engineering will hold annual training in self verification. for all engineering personnel.
-Revised Commitment
Description:
(Italics)
None Justification for Change:
The primary focus of the Inspection Re) ort, LER and responses, were deficiencies in the temporary modification program. T1e requirement to conduct self verification training listed in the LER was a)propriate as an immediate response to the incident. However, to conduct t1at particular training annually, regardless of actual training needs is not appropriate and deviates from the systematic approach-to training used at CPSES. Training needs are monitored by the Program Review Boards. Self verification is listed on the Engineering task list which is periodically reviewed to assess the need for continuing or recurrent training.
This ensures that the need for additional self verification training is
. periodically assessed, I
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Attachment'2 to TXX 98021 Page 11 of 11 i 4
CMCE 97 05 Commitment Number: 23486 Deletion: or Revision: _x__
Source Document: TXX 89596 Original Commitment
Description:
Shift log information TU Electric will take actions to improve the documentation of equipment problems in the shift log: 1) problems causing initiation of a PIR will i be referenced in the station log with its PIR number. 2) Technical Specification LCOs, will be tracked in the Unit log and will be discussed during the shift turnover process.
Revised Commi, ent
Description:
(Italics)
NOTE: Item 1 above was removed from the commitment.
Shift log information TU Electric will take actions to improve the documentation of equi > ment problems in the shift log: 1) Technical Specification LCOs, will be tracted in the Lnit log and will be discussed during the shift turnover process.
Justification for Change:
The problem originally identified in the source document and partially addressed by the commitment was, that based on the review of the 1989 AFW backflow events, improvements could be made in awareness by Operations personnel of operational events and equipment failures and of their implications for system operability.
The need for documenting problems causing initiation of a PIR in the station log along with the PIR number is determined to no longer be require because of the following practices: 1. Operations personnel attend the daily corrective action meeting and are part of the quorum required for-conducting this meeting. 2. Most PIR events are discussed at the plan of the day meeting and key Operations personnel attend this meeting. 3. All PIR packages are routed to the Operations Manager regardless of the event type. The determination of whether t; event meets 1 the PIR criteria is recorded in the station log. This information.is sually from I
other meetings and the station log has to be revisited to include updated PIR l information. This is a cumbersome process with little value added. Since Operations is notified of PIR events, meeting assessments and the final PIR report is distributed to the Operations manager, the deletion of the commitment does not negatively impact the ability of any system or component to perform its safety )
function.
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