ML20210J939
| ML20210J939 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/30/1999 |
| From: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20210J913 | List: |
| References | |
| NUDOCS 9908050147 | |
| Download: ML20210J939 (9) | |
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l COMANCHE PEAK STEAM ELECTRIC STATION
! COMMITMENT MATERIAL CHANGE EVALUATION REPORT 0003 9900050147 990802 PDR ADOCK 05000445 R PDR
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Attachment 2 to TXX-99182 Page 2 of 9 CMCE
SUMMARY
OVERVIEW l
l The following information is presented as an overview for the attached CMCE Summaries.
1 CMCE Exit Type / Process:
The information provided, identifies the exit point on the form and an explanation of the exit point. Only those exit points specifically identified on the CMCE Summary forms are included in this presentation. The information is for reference only.
CMCE Exit Point Description Total Number in Identifier This Report 3C The original commitment was necessary for 1 compilance with an Obligation or based on responses to LERs/NOVs/NCVs or identifies method for obligation compliance. The revised commitment preserves compliance and has been implemented 4B The original commitment was explicitly credited as 3 either (1) the basis for a safety decision in an SER, (2) made in response to an NRC Bulletin or Generic Letter, or (3) explicitly listed in an NRC Confirmatory Action Letter and the commitment has been implemented.
SB The original commitment was made to minimize 1 recurrence of an adverse condition and the revised commitment is necessary to minimize recurrence of the adverse condition (recurrence of the condition has not occurred in the last two years).
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Attachment 2 to TXX-99182 Page 3 of 9 A compilation of CMCE Summary (s) information is provided below to assist in CMCE review processes.
CMCE Summary Compilation:
CMCE No. CMCE Exit Commitment Commitment Commitment Description Point No. Action Source 96-01 4B 14823 Revision TXX-4494 Housekeeping Practices 96-02 48 08068 Revision ANSI-N18.7-1976 Use of an Independent Verifier 96-08 4B 24796 Revision TXX-92268 Surveillance Testing Change 96-11 3C 18385 Deletion TXX-88657 Removal of 18387 Assistant RPM 18390 Position 97-02 5B 26492 Deletion IR-445/9242 Engineering l Training 1LER-92-029-00 Program l
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to TXX-99182 Page 4 of 9 CMCE
SUMMARY
CMCE 01 Commitment Number: 14823_
Commitment Revision CMCE Type & Exit Process: 4B The original conunitrnent explicitly credited as either (1) the basis for a safety decision in an SER, (2) made in response to an NRC bulletin, Generic Letter, (3) response un listed in an NRC Confirmatory Action Letter or a NOV as a long term corrective action.
Include the following information as summary criteria:
Source Document (Level 0): GL-85-02 TXX-4494_Att.1.B Revised Commitment Description (From CMCE):
l 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 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 th section personnel or RWO independent verifiers to verify the housekeeping / cleanliness control requirements are being maintained to establish procedural requirements.
Justification for Change ( This is to include any identified rationales and conclusions noted in the CMCE): {
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The original response provided details regarding the Housekeeping practices in affect at CPSES during the construction phase and personnel accountability was required per ANSI N45.2.3-1973. Per FSAR section l A(B), Regulatory Guide 1.39 discussion, CPSES is committed to ANSI N18.7-1976 with respect to Housekeeping practices during the operations phase. ANSI N18.7-1976 does not require that Housekeeping provisions include personnel accountability.
Preparer: [ , Date: 7/ 7//99 9 Page _i_ of _1_
Attachment 2 to TXX-99182 Page 5 of 9 CMCE
SUMMARY
CMCE 02 Commitment Number: 08068_
Commitment Revision CMCE Type & Exit Process: 4B The original commitment explicitly credited as either (1) the basis for a safety decision in an SER, (2) made in response to an NRC bulletin. Generie Letter,(3) response under 10CFR50.54(f) listed in an NRC Confirmatory Action Letter or a NOV as a long term corrective action.
Include the following information as summary criteria:
Source Document (Level 0): FSAR 1(AN)/1(AB)
RG 1.038, Section C ANSI N18.7-1976 Revised Commitment Description (From CMCE):
Inspection and test results shall be documented in a suitable test report or data sheet. Each report shall identify the item to which it applies the procedures or instruction followed in performing the task and the identification of the following:
- a. Conditions encountered which were not anticipated, including non-conformance
- b. Identity ofinspector/ independent verifier or tester
- c. Completion date.
Justi(1 cation for Change ( This is to include any idennfled rationales and conclusions noted in the CMCE):
The addition of an independent verifier during work practices enhances the QC function by assuring veriiication of required work steps regardless if the procedure has a QC hold point or not. The addition also adds to the overall safety assessment of work practices and increases the margin ofplant safety.
Preparer: w 2 M Date: 7 / 7 / /F99 Page _1_ of _1_
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to TXX-99182 Page 6 of 9 CMCE
SUMMARY
CMCE 08 Commitment Number: 24796 Comeritment Revision CMCE Type & Exit Process: 4B ne original cornmitment explicitly credited as either (1) the basis for a safety decision in an SER, (2) made in response to an NRC bulletin, Generic Letter,(3) response under 10CFR50 listed in an NRC Confirmatory Action Letter or a NOV as a long term corrective action.
Include the following information as summary criteria:
Source Document (Level 0): GL-89-13 TXX-90031 TXX-92268 Revised Commitment Description (From CMCE):
The Centrifugal Charging Pumps, Containment Spray and Safety Injection pump lube oil coolers will not be tested. However, lube oil temperature will be recorded during quarterly surveillance mns 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 monitored on a weekly basis to verify that the flow rates meet design requirements.
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Justification or Change { This is to include any identified rationales and conclusions noted in the CMCE):
The Centrifugal Chargir:g Pumps, Containment Spray and Safety Injection pump surveillances were originally on a quarterly basis at the time the conunitment was made. The lube oil temperatures recorded in surveillance runs were committed to be analyzed quarterly. The analysis is performed when any required action would be taken and the frequency of analysis is unchanged. Generic Letter 89-13, recommended action II concerns verifying heat transfer capability of all safety related heat exchangers cooled by Service Water. TXU's commitment combining monitoring tube oil temperatures and inspection routinely the Centrifugal Charging {
Pumps, Containment Spray and Safety Injection pmnp lube oil coolers, complies with the G.L. as l an acceptable attemative to testing.
Preparer: k #x. Ab1 Date: J_/ 7/ fF Page _i_ of _1_
to TXX-99182 Page 7 of 9 CMCE
SUMMARY
CMCE 11 Commitment Numbers: 18385,18387,18390 Commitment Deletion i CMCE Type & Exit Process: 3C ne original commitm-nt was necessary for compliance with an (1) obligation (ie. law, rule, regulation, order or license condition),(2) based on certain responses to LERs/NOVs , or (3) identifies method (s) for obligation compliance?
Include the following information as summary criteria:
Source Document (Level 0): TXX-88406 TXX-88657 LCR-88-873 Commitment Descriptions (From CMCE):
18385 I TU Electric [TXU) 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 Radiation Protection issues [are) involve [d).
18390 The assistant RPM also has the following responsibilities:
- 1. Supervising the radiation protection staffhealth 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 ofproblems, incident reports and quality assurance issues that relate to radiation protection to ensure appropriate action is taken to address such issues.
- 6. Participating on the Station ALARA Review Group (SARG) as a member addressing, evaluating and implementing, as appropriate, ALARA concems to enhance radiation safety at CPSES.
- 7. Communicating directly to the Manager, Plant Operations or the VP, Nuclear Operations on any unresolved or urgent radiation protection related issue.
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Attachment 2 to TXX-99182 '
Page 8 of 9 Justification for Cbange ( This is to include any identified rationales and conclusions noted in the CMCE):
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The three commitments described above were deleted due to elimination of the Assistant Radiation Protection Manager (ARPM) position. The reduction in plant staffing to eliminate the 1 ARPM does not affect utility commitment nor affects safety related activities since the current Radiation Protection Manager (RPM) and any future RPM will met regulatory requirements for i
experience and education and training. '
2 Preparer: ,
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Date: 7 / 7/ff )
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1 Attachment 2 to TXX-99iB2 Page 9 of 9 ;
CMCE
SUMMARY
f CMCE 02 Commitment Number: 26491,26492 Commitment Deletion CMCE Type & Exit Process: 5B The original commitment made to minimize recurrence of an adverse condition j (ie. a long-term corrective action stated in an NRC Licensee Event Report (LER) OR external non-NRC agency document).
Include the following information as summary criteria: 3
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Source Document (Level 0): INSRPT-445/8945, Observation 2 INSRPT-445/9262 1LER-92-029-00 Commitment Description (From CMCE):
26491 Engineering will hold annual training in Self Verification for all engineering personnel.
26492 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.
Training will be provided to Engineer in the procedures for the outage related activities which i they are assigned to. !
Justification for Change ( This is to include any identified rationales and conclusions noted in l
the CMCE):
The primary focus of the Inspection Report, LER and responses was deficiencies in the temporary modification program. The requirement to enhance outage training listed in LER 92-029, page 6, was appropriate as an immediate response to the incident.
Outage training needs are assessed by each organization as they plan an outage. Groups using loaned personnel, particularly for testing, routinely provide training in order to ensure that personnel are qualified to perform their duties.
Retaining this commitment is not necessary to prevent recurrence of the deficiencies identified in l the temporary modification program; therefore, this commitment is deleted, i
Preparer: [ , Date: 7/ 7 / @
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