ML20212B633
| ML20212B633 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/24/1997 |
| From: | Tapia J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| 50-445-97-17, 50-446-97-17, NUDOCS 9710280157 | |
| Download: ML20212B633 (4) | |
See also: IR 05000445/1997017
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UNITE o STATES
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NUCLEAR REGULATORY COMMISSIOf)
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REGloN IV
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611 RYAN PLAZA drive, Sul1E 400
ARLINGTON, TEXAS 760119064
OCT 2 41997
Mr. C. L. Terry
TU Electric
Group Vice President, Nuclear
ATTN: Regulatory Affairs Department
P.O. Box 1002
Glen Rose, Texas 76043
SUBJECT:
NRC INSPECTION REPORT 50-445/97-1-';50-446/97-17
Dear Mr. Terry:
Thank you for your letter of October 20,1997, in response to our letter and Notice
of Violation dated September 19,1997. We have reviewed your reply and find it
responsive to the concerns raised in our Notice of Violation. We will review the
implementation of your corrective actions during a future inspection to determine that full
compliance has been achieved and will be maintained.
Sincerely,
J
6seph I. Tapia, Chief
Project Branch A
Division of Reactor Projects
Docket Nos.: 50-445
50446
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License Nos.: NPF-87
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cc w/ enclosure:
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Mr. Roger D. Walker
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TU Electric
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Regulatory Affairs Manager
P.O. Box 1002
Glen Rose, Texas 76043
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Juanita Ellis
President CASE
1426 South Polk Street
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TU Electric -
Bethesda Licensing
3 Metro Center, Suite 610
Bethesda, Maryland 20814
George L. Edgar, Esq.
Morgan, Lewis & Bocklus
1800 M. Street, NW
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Washingtc,n, D.C. 20036
G. R. Bynog, Program Manager /
Chief Inspector
Texas Department of Licensing & Regulation
Boiler Division
P.O. Box 12? 37, Capitol Station
Honorable Dale McPherson
County Judge
P.O. Box 851
- Glen Rose,' Texas 76043
-Texas Radiation Control Program Director
1100 West 49th Street
- John Howard, Director
Environmental and Natural Resources Policy
- Office of the Governor
P.O. Box 12428
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October 20,,1997
C. Lance Terry z
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U.4S; Nuclear Regulatory Commission:
- Attn: L Document Centrol Desk
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Washington, D.C. 20555
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SUBJECT: (,0MANCHE PEAK' STEAM ELECTRIC STATION (CPSES)
DOCKET NO. 50 445 and 50 446
NRC INSPECTION REPORT NUMBERS 50-445/97-17 and 50-446/97-17
RESPONSE TO NOTICE-0F VIOLATION
REF.;
TV Electric logged TXX-97217 to-the NRC dated October 17 1997
Gentlemen:
Tu~ Electric has reviewed the.NRC's letter dated September 19, 1997,
concerning the inspections conducted by the NRC Resident Inspectors during
the period of July 20 through August 30. 1997. Attached to,the report was
Via' Attachment 1, TU Electric hereby responds to the V1'olations 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, oleese do
not besttate to contact Obaid Bhatty at (254) 897 5839 to coordinate this
e f fort.
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Sincerely,
s. S. %
C. L. Terry
By:
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Roge'r D. Walker
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Regulatory' Affairs Manager
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Attachment-to TXX 97220
Page 1 of 5
RESPONSE TO THE NOTICE OF VIOLATION
RESTATEHENT OF THE VIOLATION
(445(446)/9717 01)
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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.
Revis1on 2. February 1978.
Appendix A requires general plant
operating procedures for power operation, startup, shutdown of
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safety-related systems and for conducting maintenance.
Procedure OPT-457B " 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 4 Step 8.1 V. required that the emergency diesel
generator be immediately loaded.
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Procedure 50P-103A. " Chemical and Volume Control System."
Revision 10 Step 5.3.10. required that the inlet and outlet
valves of the cation bed demineralizer be clerod.
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Contrary to the above:
1.
On May 7. 1997, while perforning Procedure OPT-457B, a
licensed operator failed to close Valve 2-8812A per Step
8.8.
2.
On August 7. 1997, during the performance of Procedure OPT-
2148, a licensed operator did not immediately load
Emergency Diesel Generator 2-01 per Step 8.1.V.
3.
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
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:
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Attachment to TXX 97220
Page ? of 5
On May 7.1997.-while performing OPT-457B. " Train A Safeguards -
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Slave Relay K740 and K?41 Actuation Test." Revision 2. a licensed
operator f ailed to perform a step in the procedure. The operator
- 1nadvertently 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 failed and was subsequently retested and the surveillance
result 3 were satisfactory, however.' the system was still capable
of per'orming its safety function.
The cause of this was
attributed to attention to detail.
On August 7,1997, during the post maintenance testing of
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Emergency Diesel Generator (EDG) 2-01. an operator missed the
opportunity to immediately load the EDG as required by Procedure
OPT 2148. "Diesal Generator Operability Test." Revision 4
Since the EDG
Step 8.1.V and the EDG tripped on reverse
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was already inoperable as a result of mainto . ace, no operational
safety significance 1ssues were 1dentified.
The cause of this
was attributed to less than adequate self verification.
On August 21. 1997, operations personnel identified that the Unit
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1 chemical and volume control system cation bed was not properly
secured in accordance with Procedure 50P-103, " Chemical and
Volume Control System." Revision 10.
The cation bed was placed
in service far lithium control.
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 ctilectively reviewed to determine a common root
cause. TV Electric believes that the cause for the first example stated
above was due to attention to detail, which is an error of emission.
The other two examples were deemed to be caused by less than adequate
self verification which are errors of comm1ssion.
No generic
implications with respect to operator inattentiveness were noted during
this review.
2. Corrective SteoLJten and Results Achieved
Upon discovery of these items
1mmediate 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 v2rification was reemphas12ed.
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
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Attachment to TXX-97220
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 Como11ance
TV Electric is in full compliance.
If applicable. TV 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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Attachment to TXX-97220
LPage 4-of 5- -
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RESTATEMENT OF THE VIOLATION
-(445(446)/9717 04)
B.
Technical Specification 4.6.3.1 states
"The containment
. isolation valves.shall be demonstrated OPERABLE prior to
returning the valve to service after maintenance, repair or-
replacement 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 isol? tion accumulator
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sampie valve, after performing maintenance on the valve actuator.
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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
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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 ir the CPSES Technical
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Specifications (TS).
2. Corrective Steos Taken and Results Achievert
-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 Preclude Recurrence
To prevent recurrence, additional guidance has been provided to
responsible work organizations concerning the testing requirements of
the. subject valves.
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'Attachinent to TXX-97220
Page 5 of 5
4.Qate of Full Como11ance
TU Electric is in full compliance.