ML20202F583
| ML20202F583 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/13/1998 |
| From: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-445-97-20, 50-446-97-20, TXX-98024, NUDOCS 9802190246 | |
| Download: ML20202F583 (8) | |
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Log # TXX 98024 C
C File # 10130 1UELECTRIC IR 97 20 Ref. # 10CFR2.201
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' February 13, 1998 Senior Mce Pvt.sident
& PrincipalNuclear Oplcer U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50 445 and 50 446 NRC INSPECTION REPORT NUMBERS 50 445/97 20 and 50 446/97 20 RESPONSE TO NOTICE OF VIOLATION REF:
- 3) TV Electric letter logged TXX 97244 from Mr. C. L. Terry to the NRC dated December 10, 1997 Gentlemen:
TV Electric has reviewed the NRC's letter dated January 16, 1998, concerning the inspections conducted by the NRC Resident Inspectors during the period of October 12 through November 22, 1997.
Attached to the report was a Notice of Violation.
Via Attachment 2, TV Electric hereby responds to the Notice of Violation (50 446/9720 01, 50 446/9720 02, and 50 446/9720 04). As noted in. this communication contains updates of commitments previously made to the NRC via references 1, 2, and 3.
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TXX 98024 Page 2 of 2 Should-you have any comments-or require additional information, please do not-hesitate to contact-Gary.Herka at_(254) 897 6613 to coordinate this effort.
Sincerely.
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- cc: Mr. E.-W. Herschoff, Region IV Hr. J. I. Tapia. Region IV Resident Inspectors Mr..T..J. Polich, NRR 4
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Attachment I to TXX 98024 Psge-1 of-1 List of Commitments 4
This communication contains the'following commitments which will be completed as noted:
CDF Nn=her Commitment 27119 Similar procedure revisions for Unit I will be completed prior to entering Mode 6 for the next Unit i refueling outage..
27116 Integrated plant operating procedures. IPO 005A and B will be revised by March 15, 1998, to add appropriate provisions to establish temperature and pressure conditions during cooldown which will not unnecessarily challenge LTOP actuation.
I 27123 Based on the unlikely potential of finding gaps in the Unit 1 containment sump trash racks support structures which 4
could exceed the bounding size, and therefore affect operability of the system.' Unit I will be inspected prior to startup after the next refueling outage.
The CDF number is used by TU Electric for the internal tracking of.CPSES commitments.
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, Attachment 2 to TXX 98024 Page 1 of 5 1
RESPONSE TO THE NOTICE OF VIOLATION RESTATEMENT OF THE VIOLATION (50 44b/9720 01)
A, 10 CFR Part 50, Appendix B, Criterion V " Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by instructions of a type appropriate to the circumstances.
Contrary to the above, Procedure IP0 005B, " Plant Cooldown from Hot Standby to Cold Shutdown," Revision 2, was not appropriate to the circumstances in that the-procedure did not raq" ire that pressure be maintained below the reactor coolant system pressure and temperature-limits specified in Technical Data Manual TDH 301 B, "RCS Temperature
& Pressure Limits," Revision 5.
As a consequence, on October 25, 1997, both power operated relief valves opened when pressure was allowed to remain above the limit.
RESPONSE TO THE VIOLATION (50 446/9720 01)
TU Electric accepts the violation, the respcase as requested is provided below (TV Electric initially addressed this event via reference 1):
4 1.
Reason for Violation -
TU Electric believes that the reason for the violation was less than comprehensive reviews of procedure IPO 005B, " Plant Cooldown from Hot i
Standby to Cold Shutdown" during the initial preparation-and subsequent revisions of the procedure.
2, Corrective Steos Taken and Results Achieved Once Reactor Coolant System (RCS) pressure was below the corresponding pressure setpoint for the Low Temperature Overpressure Protection (LTOP) power operated relief valves (PORVs), the operator took manual control and closed the valves terminating the RCS depressurization.
The operator closed the valves to limit the discharge of RCS inventory to the pressurizer relief tank and over concern for personnel within the containment building, RCS parameters were stabilized at 340*F and 500 psig. The PORVs performed as required.
3.
Corrective Actions Taken to Preclude Recurrence Integrated Plant Operating procedures IP0 005A and B will be revised by March 15, 1998, to add appropriate provisions to establish temperature and pressure conditions during cooldown which will not unnecessarily challenge LTOP actuation.
4.
Date of Full Comoliance TV Electric will be in full compliance by March 15, 1998.
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. to IXX 98024
'Page 2 of 5 RESTATEMENT OF THE VIOLATION (50 446/9720 02)
B.
Technical Specification 3,9.4. " Containment Building Per.etrations,"
states, in part, that, during core alterations, a minimum of one door-in the personnel airlock is capable of being closed' and that each penetration providing direct access from the containment atmosphere to
.the outside atmosphere shall be closed.
Contrary to the above, on November 10, 1997, during Unit 2 core-alterations, the containment airlock pressure equalization valves for both personnel airlock doors were open and were not capable of being closed. This provided direct access-from the containment atmosphere to the outside atmosphere, 3
RESPONSE TO THE VIOLATION (50 446/9720 02)
- TJ Electric accepts the violation.- the response'as requested is provided below (TV Electric initially addressed this event via reference 3):
1.
Reason for Violation TU Electric believes that the reason for the violation was less than adequate procedures governing Personnel Airlock (PAL) operation and -
containment integrity verification related to the PAL during refueling operations..The CPSES Unit 2 PAL operating procedure only allows-proper operation of the equalization valves if the door 1s-opened and closed utilizing a singular method. The acceptance criteria for Unit 2 PAL operability does not specifically require verification of hydraulic equalization valve position prior to declaring-the Unit 2 PAL operable.
2.
Corrective Steos Taken and Results Achieved The hydraulic-equalization valve for the outer doc" was closed, the positions of the other equalizing valves-(both manual and hydraulic) were verified, and the outer door was determined to be capable of closing and maintaining containment integrity in accordance with Technical Specifications. The containment integrity surveillance required by the Technical Specifications for refueling operations was reperformed.
3.
Corrective Actions Taken to Preclude Recurrence The operating procedure for the Unit 2 PAL has been changed to include instructions for operation of the airlock such that either door can be closed with or without electrical power and the associated equalizing valves for the door will be closed or verified-to be closed prior to considering the containment closed / secure. The refueling containment integrity verification procedure for CPSES Unit 2 has been revised to
, Attachment-2 to TXX 98024 Page 3 of 5-require that all of the equalizing valves for a PAL door-are verified closed or capable of being closed prior to crediting that door as capable of_ closure for containment closure purposes.
Similar procedure revisions for Unit I will be completed prior to entering Mode 6 for the next Unit I refueling outage.
4.
Date of Full Como11ance TV Electric is in full compliance. As noted above proce' dure revisions for Unit I will be completed prior to entering Mode 6 for the next Unit I refueling outage.
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, Attachment 2 to TXX 98024 Page 4 of 5 RESTATEMENT OF THE VIOLATION (50 446/9720 04)-
C.
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Actions,"
requires, in part, that conditions adverse to quality, such as nonconformances, be promptly identified and corrected.
On November 4,1994, the licensee identified structural gaps in both Unit 2 emergency core cooling sumps that exceeded the Final Safety Analysis Report descri) tion of 0.115 inches. On November 12, 1994, the licensee completed Worc Orders 1 94 078046 00 and 1 94 078047 00, which were issued to identify and repair any gap larger than 0.115 inches.
Contrary to the above 16 gaps which were conditions adverse to quality were not promptly identified and corrected in that eight gaps previously identified in 1994 and eight additional gaps that exceeded the Final Safety Analysis Report specification of 0.115 inches were identified in the Unit 2 emergency core cooling sumps on November 8,
- 1997, RESPONSE TO THE VIOLATION (50 446/9720 04)
TU Electric accepts the violation, the response as requested is provided below (TV Electric initially addressed this event via reference 2):
1.
Reason for Violation Although the work and design change documents for the corrective actions taken during the first refueling outage for Unit 2 in 1994 were closed, the actual completed actions were determined to have been incomplete with respect to the defined scope of work in the corrective action documents because work instructions (which included Design Change Notices and Work Orders) were not fully implemented.
Some previously identified gaps remained uncorrected, some identified gaps were not completely closed, and some new gaps were found.
Gaps that communicate through the containment sump trash rsck support structures were difficult to identify because gaps had indirect paths through the structure. Additionally, for this unique condition, the work instructions may not have provided the appropriate level of detail within the work documents to ensure that all gaps were corrected.
This situation may have also been impacted due to less than effective coordination of a work activity identified near the end of the refueling outage. Had the original work and design change documents provided more detailed directions for this unique condition, these corrective actions should have been fully implemented.
A!, part of preplanning, work instructions are required to provide sufficient detail to complete activities.
Furthermore, design change documentation should provide sufficient details to fully describe the
, Attachment 2 to TXX 98024 Page 5 of 5 change. Audits and surveillance of design changes and work planning are provided by the Nuclear Overview Department, Generic or programmatic problems have not been identified with these programs.
In addition, an NRC inspection of the CPSES corrective action program was recently conducted (see NRC Inspection Report 50 445(446)/97 12).
The results of this inspection found that corrective action and self assessment programs at CPSES are functioning well and are adequately supporting the safe operation of the plant. Therefore, this condition is determined to be an isolated incident because of the unique conditions related to this emergent work, 2.
Corrective Steos Taken and Results Achieved Immediate corrective actions were taken to ensure that this condition does not interact with the condition reported in LER 445/97 008 00 to prevent ECCS recirculation in the event of an accident, The gaps in the Unit 2 containment sump trash racks were repaired, inspected, and engineering verified to assure the work was satisfactorily completed during the current Unit 2 refueling outage.
Incomplete work in the Unit I containment sump trash rack support structures is not expected since Unit I corrective action was performed as a scheduled activity during the fourth refueling outage for Unit 1.
Based on the unlikely potential of finding gaps in the Unit 1 containment sump trash racks support structures which could exceed the bounding size, and therefore affect operability of the system.
Unit I will be inspected prior to startup after the next refueling outage, 3.
Corrective Actions Taken to Preclude Recurrence TU Electric engineering personnel have reviewed any possible generic implications of this condition and believe it to be an isolated occurrence because of the unique conditions, A sample review of comparable emergent and unique 1994 work documents implemented during the first refueling outage of Unit 2 related to completion of corrective actions was performed to determine if the appropriate level of detail was provided to the personnel for implementation and appropriate follow up review criteria were provided to ensure proper completion of the job such that the identified condition was fully addressed. The results indicated that the appropriate level of detail was provided to the responsible work organization, and that appropriate follow up criteria in the way of testing and acceptance criteria was provided to ensure the proper completion of the corrective action.
Furthermore, since 1994, organizational changes have occurred which provide for increased engineering ownership of the design of CPSES such that matters of similar urgency and uniqueness would receive additional assurance that corrective actions are fully addressed.
4.
Date of Full Comoliance TU Electric is in full compliance. As noted above, the Unit 1 containment sump trash racks support structures will be inspected prior to startup after the next refueling outage.