ML20236G932

Notice of Violation from Insp on 980329-0509.Violation Noted:Four Examples Were Identified,Where Licensee Failed to Meet Requirement for Design of ECCS Switchover from Refueling Water Storage Tank to Containment Recirculation

ML20236G932
Person / Time
Site:	Comanche Peak
Issue date:	07/02/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20236G912	List: IR 05000445/1998003 ML20236G910 ML20236G932
References
50-445-98-03, 50-445-98-3, 50-446-98-03, 50-446-98-3, NUDOCS 9807070023
Download: ML20236G932 (5)

Text

- - _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ ____ _____ - . _ _ _ _ _ _ _ _ _ _ _ . ___ _________

ENCLOSURE 1 NOTICE OF VIOLATION TU Electric Docket Nos.: 50-445 Comanche Peak Steam Electric Station 50-446 License Nos.: NPF-87 NPF-89 During an NRC inspection conducted on March 29 through May 9,1998, five violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. 10 CFR Part 50, Appendix B, Criterion lit, " Design Control," requires, in part, that design  !

control measures provide for verifying or checking the adequacy of design, and that design changes be subject to design control measures commensurate with those applied j to the original design. '

Contrary to the above, four examples were identified, where the licensee failed to meet j this requirement for the design of the emergency core cooling system switchover from j the refueling water storage tank to the containment recirculation sumps: 1

1. The licensee changed Emergency Response Guideline Procedures EOS-1.3A, Revision 6, and EOS-1.3B, Revision 1, " Transfer to Cold Leg Recirculation," by adding nine additional steps and failed to revise Calculation 16345-ME(B)-389, "RWST Setpoints, Volume Requirements and Time Depletion Analyses,"

Revision 1, which was based on a sequence of six steps to shift suction from the refueling water storage tank to the containment sumps for the emergency core cooling system pumps. As a result, the licensee did not verify the adequacy of the design when they failed to account for the additional water volume required to complete the switchover added by the additional steps.

2. Westinghouse Letter WPT-3358, dated July 16,1980, and referenced in Calculation 16345-ME(B)-389, provided the outflow requirements during switchover and specified that sufficient volume be provided below the empty alarm to allow sufficient time for operator action to shut off any pump still taking suction from the refueling water storage tank while providing adequate net positive suction head and maintaining sufficient height above the refueling water storage tank outiet nozzle to minimize the possibility of vortex formation.

1 The licensee failed to verify the adequacy of design in that neither l Calculation 16345 ME(B)-320, " Vortex Potential at Charging Pump Outlet in 1 RWST," Revision 0, nor Calculation 16345-ME(B)-389, Revision 1, accounted for I operator response time in determining the empty alarm setpoint.

9807070023 980702 PDR ADOCK 05000445 G PDR ]

i

~ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

I

! 3. Calculation 16345-ME(B)-389, Revision 1, used 60 seconds for accomplishing switchover of the containment spray system from the refueling we.ter storage tank (RWST) to the containment sumps as a design basis to determine the RWST'

' empty level alarm.

l The licensee failed to verify the adequacy of design in that the opening and closing times for the containment spray system valves to the RWST and to the containment sumps was 120 seconds.

4.' in Calculation 16345-ME(B)-389, Revision 2, the licensee reduced the total

, . analyzed instrument uncertainty from 13 inches to 7 inches when determining the L _ RWST volume available to complete switchover to cold leg recirculation based on the erroneous assumption that the total uncertainty was not affected by instrument setpoint drift.'

The licensee failed to verify the adequacy of design in that the reduction in uncertainty was not valid and the resultant calculation did not ensure sufficient

- water between the switchover setpoint and the empty alarm.

This is a Severity Level IV violation (Supplement l} (50-445(446)/9803-04).-

B. 10 CFR 50.59(a)(1), in part, permits the licensee to make changes to the facility and procedures as described in the safety analysis report without prior Commission approval

. provided the change does not involve a change in the technical specifications or an Unreviewed Safety Question (USQ).10 CFR 50.59(a)(2) defines a proposed change as a USQ if a malfunction of a different type than any evaluated previously in the safety analysis report may be created.

10 CFR 50.59(b)(1) requires, in part, that records of changes to the facility must include a written evaluation which provides the bases for the determination that the change does

- not involve an USQ.

Contrary to the above,

1. On January 3,1997, the licensee made a change to procedures as described in

~

the safety analysis report which involved an USQ. Final Safety Analysis Report (FSAR) Table 6.3-7 listed six manual operator steps required to switchover the emergency core cooling system from injection. FSAR Table 6.3-11 stated that 90,166 gallons were required to complete the switchover and that this was based on 30 seconds of operator response time for each. step. Section 6.3.2.8 stated that 94,179 gallons were available for switchover.10 CFR 50.59 Evaluation 97-001, Revision 0, was generated to evaluate the impact of going from six manual operator steps to the 15 steps listed in Emergency Response Guidelines Procedures EOS-1.3A, Revision 6, and EOS-1.3B, Revision 1, " Transfer to Cold Leg Recirculation," The results of the evaluation disclosed that the additional e water volume required by the nine additional steps was not available. The I

m licensee shortened the assumed operator response time from 30 seconds to less than 15 seconds in order to provide the required volume. This change increased the probability of occurrence of a malfunction of equipment important to safety, and therefore, did invo've a USQ which was not approved by the Commission.

2. As of December 19,1996, Emergency Response Guidelines Procedure EOS-1.3,

" Transfer to Cold Leg Recirculation" had been revised to include additional steps to perform the manual actions required to switchover the emergency core cooling system pumps from injection to recirculation. This revision changed the facility as described in FSAR Table 6.3-7 and no written safety evaluation was prepared to provide the bases for the determination that the changes did not constitute a USQ. As a result, Table 6.3-11 was not accurate in that it underestimated the water volume required to complete the manual switchover.

This is a Severity Level IV violation (Supplement 1) (50-445(446)/9803-05).

C. Technical Specification 6.8.1 states, in part, that written procedures be established, implemented, and maintained as recommended by Appendix A of Regulatory Guide 1.33, Revision 2. Regulatory Guide 1.33 specifies that procedures for operating safety-related pressurized water reactor systems, such as the reactor coolant system, include instructions for filling, venting, and draining.

Contrary to the above, on April 18,1998, Integrated Plant Operating Procedure IPO-010A, " Reactor Coolant System Reduced Inventory Operations," was used to install temporary reactor coolant level instrumentation during reduced inventory operations but did not include instructions for filling, venting or operating the temporary instrumentation attached to the reactor coolant system and, as a result, a partial loss of reactor coolant system level indication occurred.

This is a Severity Level IV violation (Supplement I)(50-445/9803-01)

D. Technical Specification 6.8.1 states, in part, that written procedures be established, implemented, and maintained as recommended by Appendix A of Regulatory Guide 1.33, Revision 2. Regulatory Guide 1.33 specifies, in part, that procedures be developed for planning and performing maintenance that can affect the performance of safety-related equipment.

Accordingly, Maintenance Department Administrative Procedure MDA-111

" Troubleshooting Activities," Section 6.3.5 stated, in part, that test equipment and test leads be listed as pre-approved for use or, that their use be evaluated using a technical evaluation.

Contrary to the above, the pressure sensing devices, which were test equipment used for troubleshooting, were not pre-approved for use and no technical evaluation was performed by engineering prior to their use on April 18,1998.

[< _

l ., n L

l This is a Severity Level IV violation (Supplement 1)(50-445/9803-03) >

L E. 10 CFR Part 50, Appendix B, Criterion XVl', " Corrective Action," requires, in part, that conditions adverse to_ quality, such as deficiencies 'and nonconformances, be promptly i identified and corrected. ~

L ,

'. Contrary to the ' abo 0e, the licensee failed to identify and correct conditions adverse to L quality involving fire doors for the Unit 1 uninterruptible power supply rooms in that, from~

March 1997 to April 1998,' the licensee failed to identify that the inability of the fire doors

- to remain open on the fusible links. impaired the ability of the doors to properly function

'during a tornado.

r l s This is a Severity Level IV violation (Supplement 1) (50-445/9803-07).

Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control

, Desk, Washington,' D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at

the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: ~ (1) the reason for the violation, or, if contested,

' the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further L . violations, and (4) the date when full compliance will be achieved. Your response may reference i or include previous docketed correspondence, if the correspondence adequately addresses the l,> required response, if an adequate reply is not received within the time specified in this Notice, L an order or a Demand for Information may be issued as to why the license should not be l-

modified, suspendedi or revoked, or why such other action as may be proper should not be L . taken.1 Where good cause is shown, consideration'will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

u s Because your response will be placed in the NRC Public Document Room (PDR), to the extent

$ possible, it should not include any' personal privacy, proprietary, or safeguards information so f that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your

response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you_must specifically identify the portions of your response that you seek to have withheld and provide in

( detail the bases for your claim of withholding (e.g., explain why the disclosure of information will l

i

< l t

5-l- crea' en unwarranted invasion of personal privacy or provide the information required by 10 . 790(b) to support a request for withholding confidential commercial or financial inforn.auon); if safeguards inforrnation is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Arlington, Texas this 2 day of July 1998 :

I l

l 1

1 i

- _ - - - - - - - - _ - - - - - - - - _ - _ _ _ - - - - - - - - - - - -