TXX-6070, Suppls Response to NRC Re Violation & Deviation Noted in Insp Repts 50-445/86-01 & 50-446/86-01.Corrective Actions:Test Procedures & Data Reviewed & Evaluated to Ensure Adequacy of Auxiliary Feedwater Sys
| ML20213F231 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/04/1986 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| TXX-6070, NUDOCS 8611140090 | |
| Download: ML20213F231 (2) | |
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Log # TXX-6070 2
File # 10130 IR 86-01 TEXAS UTILITIES GENERATING COMPANY IR 86-01 SKYWAY TOWER = 40s NORTH OLIVE NTREET. E.B. 88. DALLAS. TEXAS 75203 November 4, 1986 r
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l k JLU Mr. Eric H. Johnson, Director Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 SUPPLEMENTAL RESPONSE TO NRC NOTICE OF VIOLATION AND NOTICE OF DEVIATION INSPECTION REPORT NOS. 50-445/86-01 AND 50-446/86-01
Dear Mr. Johnson:
We responded to Inspection Report Nos. 50-445/86-01 and 50-446/86-01 on October 13, 1986 (TXX-5048).
In the response to Notice of Deviation, Item A (445/8601-D-04), we stated that CPSES Engineering is still evaluating the Notice of Deviation and the tests and requirements for the Auxiliary Feedwater Pumps.
In addition, we committed to provide a complete response by November 3, 1986.
NOTICE OF DEVIATION ITEM A (445/8601-D-04)
A.
FSAR Section 10.4.9.1 states that the Auxiliary Feedwater (AFW) System is capable of supplying the minimum required flow to at least two steam generators against a back pressure equivalent to the accumulation pressure of the lowest set main steam safety valve plus the system frictional and static losses.
FSAR Table 14.2-2, Sheet 51, Test Method No. 3 commits the applicant to verify through preoperational testing that the hydraulic performance of each AFW pump meets design requirements and is within limits assumed in the appropriate accident analysis.
In deviation from the above, preoperational tests ICP-PT-37-01, " Auxiliary Feedwater System (Motor Driven Pumps)," and ICP-PT-37-03, " Auxiliary Feedwater System (Turbine Driven Pumps)," failed to test the AFW pumps against a back pressure determined using main steam safety valve accumulation pressure, but instead incorrectly used the safety valve set pressure. This amounts to a less conservative 36 psi reduction in the back pressure during this test. Consequently, the pump capacity data recorded in the above completed test packages are incorrect for the maximum back pressure test.
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.TXX-6070 November 4, 1986 Page 2 of 2 RESPONSE TO ITEM A 1.
Reason for Deviation The acceptance criteria in the test procedures deviated from the design limits described in FSAR Section 10.4.9.1 due to incomplete documentation of the accident analysis assumptions. The acceptance criteria for the test procedures were based on the acceptance criteria in FSAR Table 14.2-2 and Section 15.2 neither of which documented the 3% accumulation.
2.
Corrective Action Taken To ensure the adequacy of the Auxiliary Feedwater System, the test procedures and data are being reviewed and evaluated.
The evaluation includes a review of the test objectives, acceptance criteria, test niethodology, and data. The results of this evaluation will be attached to the Unit 1 test procedures and test data packages. The 4
Unit 2 test procedures will be revised to incorporate the evaluation findings prior to the Unit 2 tests.
FSAR Table 14.2-2 and Chapter 15 will be revised to document the appropriate acceptance criteria.
3.
Action to Prevent Recurrence The design limits assumed in each accident analysis will be reviewed against the FSAR Chapter 15 documentation and the FSAR corrected as required. Any resulting FSAR changes will be reviewed against the affected test procedures / test data packages and corrective action documented as discussed above for the Auxiliary Feedwater System.
4.
Date of Full Compliance TUGC0 will be in full compliance prior to fuel load or we will submit a specific request to load fuel with this deficiency outstanding.
Very truly yours, l'Nd W. G. Counsil RSB/amb i
c - Region IV (Original + 1 copy)
Director, Inspection and Enforcement (15 copies)
V. S. Nuclear Regulatory Commission Washington, D. C.
20555 Mr. V. S. Noonan Mr. D. L. Kelley i
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