IR 05000445/1992043

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/92-43 & 50-446/92-43

ML20127P054
Person / Time
Site:	Comanche Peak
Issue date:	01/22/1993
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 9302010173
Download: ML20127P054 (4)

Text

. j@ Clog UNITED STATES -

3, fg NUCLEAR REGULATORY COMMISSION

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REGION IV

1. 611 RYAN PLAZA DRIVE, SUITE 400 ARLINoTON, TEXAS 760118064

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JAN 2 21993 Docket Nos. 50-445 50-446 License No. NPF-87 Construction Permit No. CPPR-127 TV Electric ATTN: W. J. Cahill, Jr., Group Vice President Nuclear Engineering and Operations Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Gentlemen:

SUBJECT: NRC INSPECTION REPORT NO. 50-445/92-43; 50-446/92-43 Thank you for your letter of December 22, 1992, in response to our letter and Notice of Violation dated November 24, 199 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 maintaine

Sincerely,

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A. Bill Beach, Di e to Division of React Pr oj ts cc:

TU Electric ATTN: Roger D. Walker, Manager of Regulatory Affairs for Nuclear Engineering Organization Skyway Tower 400' North Olive Street, L.B. 81 Dallas, Texas 75201 i

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i ETU Electric . 12-Juanita Ellis

President-- ' CASE 14261 South Polk Street Dallas, Texas 75224 GDS-Associates, In . Suite 720

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Marietta,. Georgia 30067-8237 TV Electric Bethesda Licensing-3 Metro Center, Suite 610-Bethesda, Maryland 20814

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Jorden, Schulte, and Burchette

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ATTN: -William;A. Burchette, Es Counsel for Tex-La Electric Cooperative of Texas-1025 Thomas Jefferson St., Washington,- Newman & Holtzinger, ATTN: Jack R. Newman, Es L. Street, Suite-1000 Washington,- D.C. -20036

--Texas Department of Licensing & Regulation G. R. Bynog, Program Manager /_

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Chief. Inspector-Boiler Division-

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P.O. Box 12157, Capitol Station Austin,; Texas-78711i Honorable Dale McPherson County Judge-P.O. Box 851 Glen Rose, Texas-176043 Texas Radiation Control. Program Director fl100: West'49th Street Austin, Tex'as: 78756 Owen L.-Thero,-President Quality Technology Company Lakeview Mobile Home Park,-Lot'35-4793-E.; Loop 820 South

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Log # TXX-92602

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3 File # 10130

1. IR 92-43

- ~ ~. . i 7UELECTRIC Re # 10CFR2.201 December 22, 1992 William J. Cahtll, J Grup Vwe Presidret U. S. Nuclear Regulatory Commission Attn: Document Control Desk Was'nington, DC 20555

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SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNIT 1 DOCKET NO. 50-445 NRC INSPECTION REPORT NOS. 50-445/92-43; 50-446/92-43 RESPONSE TO NOTICE OF VIOLATION REF: 1) TV Electric letter to the NRC dated November 23, 1992 logged TXX-92565 (LER-92-024-00)

Gentlemen:

TV Electric has reviewed the NRC's letter dated November 24, 1992, concerning the inspection conducted by the NRC staff during the period October 19 through October 26, 1992. This inspection covered activities authorized by HRC Operati.1g License NPF-87 and Construction Permit CPPR-127. Attached to the November 24, 1992, letter was a Notice of Violation (NOV).

TV Electric hereby responds to the Notice of Violation (445/9243-01) in the attachment to this lette

Sincerely, edLnpak& William J. Cahill, J By:

Roger D. Walker Manager of Regulatory Affairs for NE0

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08/tg Attachment

l c- Mr. J. L. Milboan, Region IV l Resident Inspectors, CPSES (2)

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i bl Attachment to TXX-92602 Page-1 of 4 NOTICE OF VIOLATION (445/9243-01)

Technical Specification 3.3.3.3 requires that the accident monitoring-instrumentation channels, shown in Table 3.3-6, " Accident ~ Monitoring ,

Instrumentation." be operable. Technical Specification Surveillance .

Requirement 4.3.3.3b, specifies that each accident monitoring instrumentation channel be demonstrated operable at.least once per 18 months by performance of a channel calibratio Technical Specification Surveillance Requirement _4.0.3 specifies, in part, that failuro n perform a surveillance. requirement within the allowed surveillance interval, defined by Technical Specification.4.0.2,-shall- .

constitute noncompliance with the operability requirements-for a limiting--

condition for_ operation. Technical. Specification 4.0.2 requires that each-surveillance requirement.be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent'of the specified surveillance-interva Contrary to the above, on October 21, 1992,- the inspector. determined that the two containment wide range water level instruments, Chann_els 4779 and 4781, were not demonstrated OPERA 8LE within the last 18 months by performance of a channel-calibration. A channel calibration was last

performed for each channel in' October 1989.

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RESPONSE TO NOTICE OF VIOLATION (445/9243-01)-

TV Electric accepts the violation and the requested information follows: Reason for Violation The contain_ ment water level. indicating system. includes an-11' point, dual resistive temperature detector (RTD) sensing array and associated ;

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electronics. _The electronics supply the'4_to 20~ma signal to the y

control' hoard indicators and Emergency Response facility (ERF) computer

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points. The signal changes in incremental steps as a: function of the number of. wetted __ points. There are no alarms or trips associated with these channels. The channels provide indication for-post _ accident

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monitoring as required by Regulatory Guide 1.9 .

The sensor arrays are unique in that they use a-heatt:r element which is thermally connected to the RTDs-which are used to detect a dry or wet'

condition in' containment'from the 808 foot 3 inch level-to'the-817-foot- '

6 inch level in 6 to 12 inch increments. When level reaches.one of the sensor points, the heated RTD cools as the thermal energy is dissipated

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Attachment to TXX-92602 Page 2 of 4 in the water, lowering the temperature of the heated or active RT This results in a decreasing resistance value approaching the_ resistance-of the reference RTD. .Both RTDs comprise half of a bridge circuit which-converts the resistance into a voltage output which is: processed by-the signal processor cards located in the Control Room. The signal is summed and converted to a 4 to 20 ma signal which is read on the control board to give indication of water-leve The vendor manual describes two methods of testing the level sensor 11-point array. The first method employs the use of calibration cups, which are placed over the RTO sensor points and filled with water to provide an actual wetted-condition. The second method uses shorting adapters, which are plugged into the signal processing cards in the control room to simuldte-a wetted condition by simulating sensor actio The shorting adapters do not-check the actual sensing elements but merely allow a check of the electronics. The vendor manual specifically states that-the test using the shorting adapters will give_ essentially the same information as using the calibration caps, but without the necessity of entering containmen The first method was not included in calibration procedures because of the undesirability of entering containment during-power operations. The second method was included in all revisions of the Unit 1 and Unit 2 containment water level instrumentation surveillance procedures. third method was developed on site after discussion with the vendor and

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i incorporated in revision 2 of the Unit 1 procedure as a. functional test

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of the sensors following the shorting adapter calibration. This third methodology checked-the sensor without having to enter containment and_ !

satisfied the requirement of. Technical Specification _section 4.3.3.3b, Table 3.3-6, Item 8, and section 1.5, which requires that.."the channel calibration.shall encompass the entire channel including the sensors...."

On June 22, 1990, Revision 3 to the Unit 1 calibration procedure was prepared as part of.the biennial procedure review process and to-update the procedure format to meet current administrative guidelines. During that revision, the third method of testing the sensors was deleted from-the procedure. Revision 3 of the Unit 1 procedure was approved on July 24, 1990, and on March 25, 1991, the procedure was performed to satisfy the requirements of the associated Technical Specification surveillance activity. Because the sensor check had been deleted from the procedure, the Technical Specification requirement was not satisfie As stated above, the equipment vendor manual states'that the use of shorting adapters will give essentially the same information without the necessity of entering containment. This information was understood b the preparer of revision 3 as justification for. deletion of the alternate testing metho . . - _ . - , , . . - . .

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t Attachment to TXX-92602 Page 3 of 4 The individual performing the technical review on revision number 3 noted that the sensor was not checked and questioned how the procedure satisfied the surveillance requirement. He directed that comment to the interdiscipline reviewer of revision number 2 who responded that the use of calibration cups was not require That individual was not aware that the alternate method (method 3) had been deleted from the test procedure in revision number The technical justification for including the third method of checking the sensor added in revision 2 of the Unit 1 procedure was not _

documented and save This third method was added in revision 2 following discussions with the vendor, but this information was not documented for later reference. The preparer of revision 3 did not find this third method anywhere in the vendor documentation as an acceptable method, and subsequently deleted it. The technical reviewer of revision 3 was also unaware that this method had existe The procedure revision process contains a provision for description of the changes resulting from a procedure revision. The description of the changes resulting from revision 3 stated, " major revision due to format change," but did not mention deletion of the third method of checking sensors. Omission of this information reduced the opportunities for other reviewers to recognize the impact of the deletion, in 1991, the Unit 2 containment level indicating system calibration procedure was prepared using the Unit 1 procedure as a mode During the technical review process, the question of sensor calibration was raised, but the issue was not adequately resolved, because the procedure writer believed that the vendor manual was correc . Corrective Steos Taken and Results Achieved A ONE Form was issued to document the conditio CPSES Unit I was in MODE 1 preparing for shutdown to perform its second refueling outage. A limiting condition for operation was initiated by the shift superviso The affected Unit 1 and Unit 2 procedures were corrected to restore method three of performing the required sensor check The required surveillance activities were performed using the revised procedures. Point 8 of the 11 points on the sensor array was found failed in the open circuit condition, and was reworked. The surveillance activities were successfully performed on Unit 1 containment post accident water level indicating instrumentatio Finally, Licensee Event Report (LER)-92-024-00 (Reference 1) was issued pursuant to the requirements of 10CFR50.7 . Corrective Actions Taken to Preclude Recurrence A review of similar Unit 1 surveillance procedures was initiated to ensure that satisfactory sensor checks are performe Following

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Attachment to TXX-92602 Page 4 of 4 completion of the review, any affected Unit 2 procedures will be corrected, as require The related vendor manual will be amended to include justification for the third method of checking the level sensors. An instructional memorandum will be distributed to personnel within the affected organizations reviewing the event and stressing the importance of thorough reviews and effective communicatio The administrative procedure controlling the procedure revision process is being revised to require a more thorough description of the changes resulting from a procedure revision if change hars are not used to identify change _

4 Date When Full Compliance Will Be Achieved Full compliance has been achieved. The activities described in section 3 above will be completed by February 28, 1992.