TXX-9027, Responds to NRC Re Violations Noted in Insp Repts 50-445/90-19 & 50-446/90-19.Corrective Action:Specific Activity within Tech Spec Limits.No Further Corrective Action Required

Responds to NRC Re Violations Noted in Insp Repts 50-445/90-19 & 50-446/90-19.Corrective Action:Specific Activity within Tech Spec Limits.No Further Corrective Action Required

ML20058L153
Person / Time
Site:	Comanche Peak
Issue date:	07/30/1990
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-90271, NUDOCS 9008070016
Download: ML20058L153 (6)

Text

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,E E log # TXX 90271

=,. _- File # 10130

= r IR 90 19 nlELECTRIC g,g, p 1nclgjn, Ju'./ 30, 1990 ElDN[/N",$,

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC 51 AT10N (CPSES)

DOCKET N05, 50 445 AND 50 446 NRC INSPECTION REPORT NOS. 50 445/90-19; 50 446/90 19 RESPONSE TO NOTICE OF VIOLATION Gentlemen:

TV Electric has reviewed the NRC's letter dated June 29, 1990, concerning the inspection conducted by the NRC staff during the period Nay 3 through June 5, 1990. This inspection covered activities authorized by NRC Facility Operating License HPF-87 and NRC Construction Permit CPPR-127 for CPSES Units 1 and 2. Attached to the June 29, 1990, letter was a Notice of Violation.

I r hereby responds to the Notice of Violation in the attachment to Sincerely, a

William J. Cahill. Jr.

CBC/daj Attachment c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3) 003 9008070016 900730 ,

PDR ADOCK 0500044'5 O PDC 400 North Olive Street LB. 81 Dallas, Texas 75201 ,

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Attachment to TXX-90271 Page 1 of 5 NOTICE OF VIOLATION. ITEM A (445/9019 V 02)

Technical Specification Surveillance Requirement 4.4.7 requires that the specific activity of the reactor coo 16nt shall be determined to be within the limits by performance of the sampling and analysis program of Table 4.4.1.

Table 4.4.1 requires, in part, that an isotopic analysis for iodine be performed between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following a thermal power change exceeding 15 percent of the rated thermal power within a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period.

Centrary to the above, on May 20, 1990, at 3:35 a.m. (CDT) 4:55 a.m. (CDT),

6:19 a.m. (CDT), and 3:25 p.m. (CDT), Unit 1 experienced power changes that exceeded 15 percent of rated thermal power, but no isotopic analysis for iodine was performed within the specified time interval.

EISPONSE TO NOTICE OF V10.L61101. ITEM A (445/9019 V 02)

TV Electric accepts the violation and the requested information follows.

1. Eggion for the Violation As a result of the Steam Dump Valve testing conducted on May 20 and 21, reactor power changed in excess of 15 percent of rated thermal power (RTP) within one hour on eight separate occasions. Review of reactor power history revealed that the isotopic analyses required by Technical Specification (TS) 4.4.7 had been performed for only four of these eight power changes. The missed surveillances should have been performed by 0935, 1055, 1219 and 2125 on May 20.

The root cause of the missed surveillances was a deficiency in the steam dump capacity test procedure. The procedure stated that steam dump flow would increase reactor power by 10 1 2 percent for each bank of valves opened with generator output fixed. However, the changes in reactor power observed were greater than 15 percent during the testing and the procedure did not'contain information to " trigger" the special condition surveillance.

Two other factors contributed to the violation. The Unit Supervisor involved in portions of the testing was aware of the changes in reactor power but did not associate those power changes with the need to perform reactor coolant analyses for iodine. Additionally, a misunderstood verbal communication contributed to the surveillance missed at 2125 on May 20 for the change greater than 15 percent of RTP that occurred 1

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, l Attachment to TXX 90271 Page 2 of 5 between 1455 and 1525 on May 20. A Unit Supervisor informed Chemistry at 1910 on May 20 that a change greater than 15 percent of RTP within one hour occurred at 1504 A sample, taken at 1720 as part of a special four hour frequency sampling program, was thought by the Chemistry Technician involved to satisfy the time requirements imposed by the TS. However, the time provided by the Unit Supervisor was the onset, not the conclusion, of the power change. .The conclusion of the power change surveillance actually occurred at 1525. Therefore, an additional sample should have been taken after 1725 and prior to 2125,

2. Corrective _Steos Taken and Results Achiey34 Results of samples taken on May 20 and 21, subsequent to the four missed v l

on May 20, indicated that the specific activity was within TS limits. ,

Therefore, no further corrective action is required.

3. Corrective Steps Which Will be Taken to Avoid Further Violations The on shift licensed operaters were informed by Operations staff of the missed special condition surveillances and were reminded to remain cognizant of power changes and the need to perform reactor coolant analysis for lodine to meet TS requirements. The Unit Supervisor involved in thit event has been counselled on the importance of remaining cognizant of power changes and the need to perform reactor coolant analyses for lodine to meet TS requirements.

Additionally, placards have been placed on the main control boards above the Control Rod in Hold-Out switch and below the generator demand panel.

The placards caution the Operator to notify Chemistry of changes in excess of 15 percent of RTP within a one hour period.

,' The test procedure on steam dump valves capacity will be revised to l include a " trigger" to the special condition surveillance to ensure inclusion in Unit 2 testing, it will also include a requirement for Operations personnel to inform Chemistry personnel of the time period the reactor coolant sample is to be taken to meet TS 4.4.7 surveillance requirements.

A review was conducted for the adequacy of " triggers" currently in place for special condition surveillances and procedures revised as necessary.

Administrative procedures were revised to require Operations personnel to

! include time requirements as necessary when requesting support from other departments. Operation and test procedures were reviewed and revised as l necessary to include a " trigger" to the special condition surveillance if L the potential exists for a change in excess of 15 percent of RTP within one hour exists.

4 Attachment to TXX+90271 Page 3 of 5 To provide additional awareness of the special condition surveillance and-the need for clear communication, the Licensee Event Report associated with this event (LER 90-015 00).will be reviewed by on shift licensed operators.

L 4. ' Date When Full' Compliance Will be Achieved The Unit 2 test procedure revision on steam dump valves capacity will be issued prior to entering Mode 1 for Unit 2.

The LER review will be completed by August 20. 1990.

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Attachment to TXX-90271 Page 4 of 5 NOTICE OF VIOLATION. ITEM Q (445/9019 V 03) l B. Criterion V of Appendix B of 10 CFR Part 50 requires that activities i affecting quality shall be prescribed by documented instructions, i i

procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, I h or drawings. It also requires that instructions, procedures, or drawings i shall include appropriate quantitative or qualitative acceptance criteria I for determining that important activities have been satisfactorily l accomplished. l l

Contrary to the above, Testing Manual Procedure EGT 327A, Revision 0, J

" Steam Generator Atmospheric Relief Valve Capacity Test," specified review criteria of 2.5 1 1 percent total rated steam flow for the acceptable capacity of each atmospheric relief valve ( ARV). This corresponds to a l steam flow rate capacity of approximately 227,100 pounds mass per hour I (Ibm /hr.) to 529,900 lbm /hr. The actual acceptable capacity of the ARVs )

as specified by Revision 3 of Design Basis Document (DBD) ME-202 is 1 779,000 lbm./hr. to 968,000 lbm /hr. I RESPONSE TO NOTICE OF VIOLATION. ITEM B (445/9019 V 03)

TU Electric accepts the violation and the requested information follows:

1. Reason for Violation At the time test procedure EGT 327A, Revision 0, was written, the applicable Design Basis Document (DBD ME-202) supported use of 2.5 i 1 percent of rated steam flow as an acceptable value for the capacity of an Atmospheric Relief Valve (ARV). Subsequently, engineering personnel began l

preparation of a Design Change Authorizatien toCA) to the DBD which provided a value equivalent to approv.imately 5.1 percent of rated steam

• flow as the required ARV capacity. At the same time that the DCA was being prepared, the Test Review Group (TRG) was reviewing the test procedure.

The engineering member of the TRG, who was responsible for ensuring that the test procedure was consistent with the DBD, belonged to a dif ferent engineering organization than that which was preparing the DCA.

Consequently, the TRG engineering representative was not aware of the planned change to the DBD and approved the test procedure as written. The DCA was issued five days later. Subsequent to issuance of the DCA, the test procedure was formally approved by the TRG and issued. Since the DCA had already been issued,- the established mechanisms for identifying changes to test procedure references (such as the DBD) which are issued after the test procedure has been approved, did not identify the DCA as affecting the test procedure, i

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1 Attachment to TXX-90271 i

Page 5 of 5 l l l 1 In, summary TV Electric considers that the engineering review and approval )

process for the test procedure allowed a unique sequence of events to  !

result in an issued test procedure which was inconsistent with the DBD. l l

L. Corrective Sigos Taken and Results Achieved t

l When the test procedure was performed, discrepancies were noted between ,

I the criteria in the test procedure and the ARV flow rates derived from the i test data, investigation of these discrepancies identified the procedure i problem described above and problems in setting the ARV stroke length.

I The stroke length problems are described in Licensee Event Report (LER) 1 90 016-00 transmitted by TV Electric letter TXX 90192, dated  ;

June 22, 1990. The stroke length problems were resolved as stated in the j LER and the test procedure was revised to provide criteria for ARV flow  ;

rates that were consistent with the D00. The ARY capacity was determined to be within the revised test procedure criteria, and met the DBD l requirements.

A review of other test procedures was conducted to determine if similar differences between test criteria and the applicable DBO's existed. A i

sample of 10% of the power ascension tests was used, biasing the sample to l those tests performed to verify design numbers such as capacities. No  ;

discrepancies were found during this review. This same sample of test procedures was then reviewed by the cognizant organization for accident analyses. This review was conducted to determine if the test criteria were consistent with assumptions used in the applicable accident analyses.

l No discrepancies were identified.

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3. Corrective Steps Which Will Be Taken To Avoid Further Violations )

1 Subsequent to issuance of the test procedure, but prior to identification of the test procedure discrepancy, the Unit 1 engineering organization was restructured such that the TRG engineering review of test procedures is performed by Project Engineering system engineers. Project Engineering system engineers either originate or review proposed changes to DBDs involving their assigned system. Thus, they are aware of any planned DBD l changes during their review of test procedures. .

The Unit 2 engineering organization is aligned in a manner similar to l Unit 1 in that the system engineers will originate or review proposed j l changes to DBD's involving their assigned system as well as conduct the '

engineering review of Test Procedures. Thus the organizational structure I does not allow for a separate group without system design responsibility to provide engineering review of test procedures.

I 4. Date When Full Compliance Will Be Achieved Full compliance has been achieved.