ML20212A658
| ML20212A658 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/20/1997 |
| From: | Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-445-97-17, 50-446-97-17, TXX-97220, NUDOCS 9710240120 | |
| Download: ML20212A658 (6) | |
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Log # TXX-97220
-2 F11e # 10130 C
C IR 97-17 1UELECTRIC' Ref. # 10CFR2.201 October 20, 1997
- c. L. ace Terry Gmup At Persidee U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C. 20555 l
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NO. 50-445 and 50-416 NRC INSPECTION REPORT NUMBERS 50-445/97-17 and 50-446/97-17 RESPONSE TO NOTICE OF VIOLATION REF.
TV Electric logged TXX-97217 to the NRC dated October 17, 1997 Gentlemen:
TU Electric has reviewed the NRL's letter dated September 19, 1997, concerning the inspections t.onducted by the NRC Resident Inspectors during the period of July 20 thrcugh August 30. 1997.
Attached to.the report was a Notice of Violation.
Via Attachment 1. TU Electric hereby responds to the Violations 50-445(446)/9717-01 and 50-445(446)/9717-04.
The response to Violation 50-445(446)/9717-06 is being sent separately by the above referenced letter.
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.
- 8. 3. " %
C. L. Terry By: @b 9710240120 971020 Roge'r D. Walker PDR ADOCK O$000445 Regulatory Affairs Manager G
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08:ob Attachment j
cc:
Mr. E. W. Merschoff Region IV Mr. J. I. Tapia, Region IV Resident Inspectors P. O. Box 1002 Glen Rme Texas 7600
m Attachment to.TXX-97220 Pagelliof_S l
i
- RESPONSE TO THE NOTICE OF VIOLATION 1 RESTATEMENT OF THE VIOLATION (445(446)/9717 01)
A.
Technical Specification 6.8.1 requires. in part that the licensee establish, implement and maintain procedures covering-the activities referenced in-Appendix A of Regulatory Guide 1.33 Revision 2. February 1978. Appendix A requires general plant operating procedures.for power operation, startup, shutdo,in of 3
safety-related systems and for conducting maintenance.
Procedure OPT-4578, " Train A Safeguards Slave' Relay K740-and K741-Actuation Test," Revision 2, Step 8,8 required that Valve 2-8812A be closed.
Procedure OPT-2148, " Diesel Generator Operability Test."
-Revision 4r Step 8.1.V.- required that the emesgency diesel generator be immediately loaded.
Procedure SOP-103A. " Chemical and Volume Control System,"
Revision 104 Step 5.3.10, required that the inlet and outlet
-valves of-the cation bed demineralizer be closed.
Contrary to the above:
=1.
On May 7 1997, while performing ProcedureLOPT-4578, a licansed operator failed to clcse Valve 2-8812A per Step 8.8.
2.
On August'7. 1997, during the ptrformance c' Procedure-0PT-2148.- a. licensed operator did not immediately load Emergency Diesel-Generator 2-01 per Step 8.1.V.
13, On August 21. 1997, while securing flow through the cation
-bed demineralizer, an auxiliary operator failed to close the inlet and outlet valves of chemical and volume control system cation bed Demineralizer 1-01 per Step 5.3.10, of
-1 Procedure-SOP-103A.
RESPONSE TO THE VIOLATION (445(446)/9717 01)-
TU Electric accepts the violation the response as requested is provided
.below:
~1. Reason for Violation-
.The reasons for violation for the three events are:
(
Attachment to TXX-97220 i
Page 2 of 5 On May 7. 1997, while performing OPT-457B. " Train A Safeguards Slave Relay K740 and K741 Actuation Test." Revision 2. a licensea operator failed to perferm a step in the procedure. Tha c.)erator inadvertently missed Step 8.8 which required Valve 2-8812A to be closed and as a result, the surveillance test failed to meet its acceptance criteria.
The test failure resulted from improperly positioning a valve prior to test actuation.
The surveillance test faile1 and was subsequently retested and the surveillance results were sati factory, however, the system was still capable of performing its safety function.
The cause of this was attributed to attention to detail.
On August 7, 1997, during the post maintenance testing of Emergency Diesel Generator (EDG) 2-01 an operator missed the opportunity to immediately load the EDG as required by Procedure OPT-214B. " Diesel Generator Operability Test." Revision 4 Step 8.1.V and the EDG tripped on reverse power.
"7ce the EDG was already inoperable as a result of maintenance, no operational safety significance issues were identified.
Tne cause of this was attributed to less than adequate self verification.
On August 21. 1997, operations personnel identified that the Unit 1 chemical and volume control system cation hed was not properly secured in accordance with Procedure SOP-103. " Chemical and Volume Control System." Revision 10.
The cation bed was placed in service for lithium controi.
An auxiliary operator opened the bypass valve but inadvertently missed step 5.3.10 of SOP-103, which addressed the closure of the inlet and outlet valves to the cation bed.
Indicated flow through the bed was zero and a subsequent chemistry analysis identified a slight decrease in lithium of approximately 0.02 ppm.
Reactor coolant chemistry remained within desired limits.
Based on the aforementioned it was concluded that this event was of minor safety significance.
The cause of this was attributed to less than adequate self verification.
These events were collectively reviewed to determine a common root cause. TU Electric believes that the cause for the first example stated above was due to attention to detail, which is an error of omission.
The other two examples were deemed to be caused by less than adequate self verification which are errors of commis ion.
No generic implications with respect to operat.r inattentiveness were noted during this review.
- 2. Corrective Steos Taken and Results Achieved Upon discovery of these items, im" 3diate actions were taken to establish the required plant configuration.
These events were shared with the cognizant individuals, and managements expectation with respect to adequate self verification was reemphasized.
- 3. Corrective Actions Taken to Preclude Recurrence Managements expectation with respect to self verification and attention to detail has been reemphasized.
Additionally, as a separate matter, a
l l
Attachment to TXX-97220 l
l Page 3 of 5 human performance evaluation with respect to operator errors is being performed.
The results/ recommendations of this evaluation will be promulgated among operation personnel.
4.Date of Full Comoliance TV Electric is in tull compliance.
If applicable. TU Electric will supplement this response with the corrective actions taken as result of the human performance evaluation stated above in section 3.
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~A,ttachment to TXX-97220 Page-4 of-5 RESTATEMENT OF THE VIOLATION (445(446)/9717 04)
B..
Technical-Specification 4.6.3.1 states, "The containment isolation talves shall be demonstrated OPERABLE prior to returnir'1 the valve to service after maintenance, repair or l
replaceJnt work-is performed on the valve or its associated-actuator, control or power circuit by performance of a cycling test, and verification of isolation time."
Contrary to the above, on July 8.-1997, the licensee failed to test Valve 1-HV-4175. Unit 1 containment isolation accumulator-sample valve, after performing maintenance on the valve actuator.
RESPONSE-TO-THE VIOLATION (445(446)/9717 04)
TU Electric accepts the violation, the response as requested is provided below:
- 1. Reason for Violation During a post work review of the work order. System Engineering testing-personnel and a Senior Reactor Operator evaluated the maintenance activity and determined-incorrectly that this activity would not affect valve performance.
This incorrect decision was based in part on the incorrect belief that the work did not involve replacement-of the o-rings between the stem bushing and the valve stem. Additionally, the personnel involved with the work activity did not recognize that as, a containment isolation valve a post work testing (e.g., stroke-time test) may-have been required as delineated in the CPSES Technical Specifications (TS).
- 2. Corrective Steos Taken and Results Achieved Upon discovery.- immediate corrective action was taken to test the valve-in'accordance with TS requirements.
No indication of degradation was identified, and the valve was declared operable.
A review of other work orders for this type of valve did not indicate a generic implication concern.
.3. Corrective Actions Taken to Prer.lude Recurrence To prevent recurrence, addit nal guidance has been provided to responsible work organizations concerning the testing requirements of the subject valves.
Attachment to TXX-97220 Page 5 of 5 4.Date of Full Como11ance TU Electric is in full compliance.
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