ML20217F918
| ML20217F918 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/03/1997 |
| From: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-445-97-15, 50-446-97-15, EA-97-349, TXX-97178, NUDOCS 9710090096 | |
| Download: ML20217F918 (8) | |
Text
_. _ _. _ _ ___... _ _
M-EE Log i TXX-97178
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File # 10130 IR 97-15 U"
nlELECTRIC' October 3, 1997 C. Lance hrry Onmp We l*rrsklee U. S. Nuclear Regulatory Commission i
Attn:
Document Control Desk Washington, D.C. 20555 4
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NG. 50-445 and 50 446 NRC INSPECTION REPORT NUMBERS 50 445/97-15 and 50-446/97-15 RESPONSE TO NOTICE OF VIOLATION
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Gentlemen:
TV Electric has reviewed the NRC's letter EA-349, date.d August 5,1997, concerning the inspections conducted by the NRC Resident Inspectors during the period of June 8 through July 19. 1997. Attached to the report was a Notice of Violation,
-Via Attachment 1. TU Electric hereby responds to the Notice of Violations (50-445(446)/9715-06 and 50-445(446)/9715-03). An extension until October 4
3, 1997, to respond to the violation was di cussed with Mr. J. I. Tapia of your staff.
i With respect to violation 50-445(446)/9715-03, which was based on the
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engineering evaluation provided by TV Electric during July 1997. TU
- j Electric has subsequently performed a confirmatory review of the I-aforementioned evaluation during August and September of 1997.
The
. confirmatory evaluation does not invalidate the conclusions of the x
previous evaluation.
However, it does provide a more current and complete justification that the location of the temperature indicator is adequate, and that the required surveillances are and have been in compliance with
.the Technical Specification.
Based on the confirmatory evaluation TU
. Electric-is denying the 50-445(446)/9715-03 violation.
The confirmatory engineering evaluation is-available on site for review.
4 TV Electric accepts the 50-445(446)/9715-06 violation.
The requested j
information is being provided in the attachment to this letter.
1 9710090096 971003 PDR-ADOCK 05000445 G
PDR-kk l P. C. Box 1002 Glen Rose Teus 76643
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TX,X-97178 Page 2 of 2 Should you have any comments or 'equire additional information, please do not hesitate to contact Obaid Bhatty at (254) 897-5839 to coordinate this effort Sincerely.
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C. L. Terry By:
N7 q
Roger D. Walker Regulatory Affairs Manager 08:ob Attachment cc: Mr. E. W. Merschoff, Region IV Mr. J. I, Tapia, Region IV Resident Inspectors
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-At,tachment to TXX-97178-
-Page 1 of 6 RESPONSE TO THE NOTICE OF VIOLATION RESTATEMENT OF_THE VIOLATION (445(446)/9715 06)
A.
Technical Specification 6.8,1h requires that written procedures covering implementation of the fire protection program be established and implemented, Station Administration Manual Procedure-STA-738, " Fire Protection Systems / Equipment-Impairments," Revision 5. required that any fire protection system / equipment needing to be impaired to support other work activities shall have a Fire Protection Impairment Form STA-738 2 initiated and the necessary compensatory measures established prior to the item being impaired.
Contrtry-to the above, on the following three separate occasions, the licensee failed to establish the necessary com)ensatory actions prior to impairing a fire protection assem)1y by removing a concrete floor plug:
- 1. July 15, 1997, in the Unit 1 Sofeguards Building:
-2,l June 19, 1997, in the Unit-2 Safeguards Building; and 3.-March 13, 1997, in the Fuel Building, RESPONSE TO THE VIOLATION (445: 446/9715 06)
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-TV Electric = accepts the violation, the _ response as requested is provided i
below:
-1. Reason for Violation The reasons for violation for the three events are:
.-The July 16, 1997 event occurred when the Responsible Work Organization (RWO) Supervisor did not adequately review the Fire Protection System / Equipment Impairment Form (STA-738-2),
The RWO Supervi:or did not recognize that section 'III A' of Form STA-738 2 was not complete.
- This section requires-information for a fire watch application when compensatory measures are required for impaired systems / equipment.
. The June 19. 1997 event occurred when a Fire Protection Technician did not review the correct drawing to complete Form STA-738-2.
While reviewing the drawing, the technician concluded that the area being impaired was not within the established fire zone. The technician did not realize that the drawing being used was for CPSES Unit 1, whereas
Attachment to TXX-97178 Page 2 of 6 the impairment was 'n CPSES Unit 2.
This led to less than adequate compensatory measures in the area (e.g., proper impairment forms). It should be noted that CPSES Unit 1 and Unit 2 are mirror images, however, the fire zones are opposite of each other, CPSES Unit 1 and Unit 2 had a fire watch in thi: area since 1992 awaiting final resolution of the Thermo-Lag issues and other impairments.
Therefore, an existing fire watch was in place.
The March 13, 1997 event occurred similarly to the July 16, 1997 event.
In this event the RWO Supervisor (different from the July 16, 1997 event) received the STA-738-2 Form on March 11, 1997 but did not recognize that section 'III A' needed to be completed, and did not notify the fire protection group to establish a fire watch as a compensatory measure.
Based on several events (prior to this violation) with respect to fire protection systems / equipment impairment procedure implementation anomalies, a programmatic review of the fire 1mpairment/1mplementation of compensatory measures prc ess was requested on Jul," 15, 1997, by CPSES management.
It was determined by this review that these procedure implementation anomalies were attributed to a lack of understanding of the fire protection program requirements over the course of time. As stated earlier, it has been common knowledge among various work organizations that roving fire watches have been in place since 1992, due to the Thermo-Lag issues.
This knowledge that fire watches were already in place contributed to an inadequate review of the Form STA-738-2, and not requesting specific required compensatory measures delineated in the i
station procedures.
Additionally, the aforementioned review identified that there was some confusion among the work groups between the terms
" Fire Impairment" and " Fire Permit," this also may have contributed to the events.
- 2. Corrective Steos Taken and Results Achieved Upon discovery of these items, immediate actions were taken to establish / verify the required compensatory measures and document the events via the ONE Form system to evaluate for further actions.
- 3. Corrective Actions Taken to Preclude Recurrence A review of this recurring issue was performed by the appropriate work group. A ' Fire Protection Issues Awareness' presentation was made to the applicable work groups by the Fire Protection Supervisor.
The preseritation included (in part) the following items:
. Damage to fire protection equipment, its prevention and notification when damage to the equipment is discovered Proper paperwork for impairments transient combustibles permits and fire permits Recognizing the need for an impairment, impairments not being initiated properly and proper review of the impairments During this presentation, improvement to the procedures was solicited from
At.tachment to TXX-97178 Page 3 of 6 the work groups, a review of the improvements / suggestions is currently being performed and will be incorporated in the existing station procedures as applicable.
It was reemphasized that the fire protection program is a collective effort by all individuals at CPSES to assure the effective implementation of the fire protection programmatic requirements.
Additional classroom training is being provided to various work groups responsible for work which may impact fire protection program, TV Electric has adequate confidence that the above stated actions should prevent recurrence.
4.Date of Full Como11ance TU Electric is in full compliance.
If applicable, the procedures will be revised by the end of December 1997, i
-At,tachment to TXX-97178 I
Page 4 of:6 RESTATEMENT OF THE VIOLATION (445(446)/9715 03)_
-B.
Technical Specification 4.7.10. " Area Temperature Monitoring."
requires, in part, that the temperature in each area in the t
safeguJrds building shall be determined to be within its limit at least once per-12 hours.
a Operations Testing Manual Procedures OPT-102A. R1 vision 8 for i-Unit 1. and OPT-102B.. Revision 2 for Unit 2. " Operations Shiftly
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Routine Tests." implemented the surveillance requirements of Technical Specification 4.7.10.
Contrary to the above, the surveillance requirements of Technical t
Specification 4.7;10 were not adequately implemented by 1-Procedures OPT-102A and OPT-102B in that the temperatures of each of the main steam penetration and the feedwater penetration areas:
could not be determined separately by using the specified i
temperature Indicators (1-T!-5624 in Unit 1 and 2-TI-5624 l
in Unit 2).
L RESPONSE TO THE VIOLATION-(445(446)/9715 03)
TV Electric denies the violation.
TV Electric believes that'the surveillance requirements of Technical Specification (TS)'4.7.10 were adequately implemented by Procedures OPT-102A and 0PT-1028 for the j-following reason:
I.
. TECHNICAL SPECIFICATION (TS)
CPSES TS 3.7.10 states that the maximum temperature limit for normal conditions of each area shall not be exceeded for more-i than eight (8) hours, and the maximum temperature limit for abnormal conditions of each area in TS Table 3.7-3 shall not be exceeded.
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' CPSES TS Table 3.7-3 " Area Temperature Monitoring." identifies ohe safeguards-building normal area temperature limit to be 104*F for j
" normal conditions" and 131*F for abnormal conditions" a
I CPSES TS Bases 3/4.7.10 states that the limitations of nominal i-areas ensure that safety related equipment will not be subjected to temperatures that would impact their environmental qualification tempcrature.
Exposure to temperatures in excess of the maximum temperature for normal conditions for " extended" periods of time could-reduce the qualified life or design life of L
that equipment.
Exposure to temperatures in excess of the maximum abnormal temperature could degrade the Operability of i
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.a
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/At,tachmenttoTXX-97178 Page 5 of 6-that' equipment.
II.
IMPLEMENTATION The Ma.in Steam /Feedwater penetration area is considered as a
' Normal Area *. The temperature monitoring requirements of TS are implemented in accordance with Operations Testing Manual Procedure (OPT)-102A at-Temperature Indicator 1-TI-5624 for Unit 1: and OPT-102B at 2-TI-5624 for Unit 2 at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
- III, LOCATION OF THE TEMPERATURE INDICATORS 15 4.7.10 requires that the temperature in each of the areas shown in Table 3.7-3 be determined to be within its limit at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, Table 3.7-3 lists the maximum temperature limit of normal safeguards building areas under normal conditions to be 104'F. The main steam penetration /
feedwater penetration area is considered a normal safeguards building area-(please refer to NRC inspection reports 50 445/91-70 S 4.1 and 50-446/92-03 5 5.5), and is therefore subject to the 104* F maximum temperature limitation. Operations Testing Manual Procedures OPT-102A. Revision 8. (Unit 1) and OPT-1028.. Revision-2,-(Unit:2).." Operations Shiftly Routine Tests," implemented TS Surveillance Requirement 4.7.10. Procedures OPT-102A and OPT-1028 require that temperature indicators (TI) 1-TI-5624-(Unit 1) and-2-TI-5624_(Unit 2) be recorded to determine that the area temperatures are within their limit.
The engineering evaluation of the location of the tis has concluded that the location of
~these tis 1s-adequate to_ measure bulk. area temperatures (which is an accepted industry practice). As:a result of this evaluation, it was also deemed that area temperatures in-excess of the limit would be-identified.~ Based on this it-can be concluded that surveillance requirements of TS 4.7.10 are being met.
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= JUSTIFICATION The temperature is recorded via a calibrated temperature indicator (TI), -The TI is calibrated on an eighteen month cycle.
A review of.the calibration / history records di6 not reveal any-i matters of concern, it was concluded that the tis are reliable.
-TI-5624 measures the temperature of the air that exits through -
-the common exhaust of the main. steam /feedwater penetration area.
The HVAC system for the area.is a closed system, i.e., the supply into'these areas is through a single header from the cooling
-units. The return air intake for this area is through a common exhaust header that exhausts the air to the atmosphere.
As such
'the supply and exhaust for this area do not communicate with other area-HVAC system. The main steam penetration area and the
-feedwater penetration areas are subdivided into separate compartments with a supply in each compartment from the single header._and a return intake which feeds into the single return air header:where the TI is located.
Additicaally, there is an area of communication between the main steam /feedwater
Attachment to TXX-97D8 Page 6 of 6 penetration area at the containment wall.
Based on these factors, the main steam /feedwater penetration area is considered as a single normal area.
In order to validate this conclusion, temperatures from each compartment as well as the TI were recorded twice a day (morning and evening) over a seven (7) day time period.
This data was then evaluated, and it was determined that the measured temperatures at the TI was consistent (within i 1.5'F) with the average area temperature of the main steam penetration area and the feedwater penetration area.
- Moreover, the measured temperature at the TI was within i 1.1*F of the bulk area temperature of the combined main steam /feedwater penetration area.
The maximum calculated temperature for the main steam /feedwater penetration area is s 104*F.
As such, considering the main steam /feedwater penetration as a single normal area is acceptable.
The bases for monitoring temperature is to assure that the maximum temperature for normal conditions is not exceeded for extended periods.
The equipment qualification program assumes that the equipment experiences the maximum normal temperature 365 days a year.
This is a conservative assumption which is used to account for times of temperature excursion in local areas.
The evaluation of the main steam /feedwater penetration area shows the bulk area temperature to be 104*F with certain cubicle (s) to be greater during peak summer temperatures.
This evaluation is based on a worst case scenario, however, the assumption of 365 days at 104*F bounds the situation if some locations within this area are greater than 104*F for short periods of times.
As such applying the " Normal Area" limit on this area is acceptable.
V.
CONCLUSION Based on the above TV Electric has concluded that the requirements of TS 4.7.10 are being met under the auspices of OPT-102 (A&B),
Hence TU Electric believes that a violation of CPSES Technical Specification or a violation of 10 CFR 50.
Appendix B Criterion V does not exist.
Nonetheless, as a separate matter and to provide greater margin to the TS limit TU Electric is evaluating the need to perform periodic maintenance of the filters and the dampers to optimize the air flow in these areas.