ML20059K356

Ack Receipt of 900904 Response to Violations Noted in Insp Repts 50-445/90-22 & 50-446/90-22

ML20059K356
Person / Time
Site:	Comanche Peak
Issue date:	09/13/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 9009210266
Download: ML20059K356 (3)

See also: IR 05000445/1990022

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' In Reply Refer To:-

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50 445/90-22

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50-446/90-22

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TU Electric.

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JATTN:

W. Ji Cahill, Jr., Executive

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Vice President, Nuclear

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Skyway Tower

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400 North Dlive Street, L.B. 81

' Dallas. Texas 75201

Gentlemen:

Thank you for your letter of September 4,1990, in response to our letter

and Notice of Violation dated August 3, 1990. We have reviewed your reply end

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find it responsive to the concerns raised in our Notice of Violation. We will

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review the implementation of your corrective actions during a future inspection

to determine that full compliance has been achieved and will be maintained.

Sincerely.

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InIobOSOA

Samel J. Collins, Director

Div!sion of Reactor Projects

cc:

TU Electric

ATTN:

Roger D. Walker, Manager,

. Nuclear Licensing

Skyway Tower

400 North Olive Street, L.B. 81

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Dallas, Texas 75201

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Juanita Ellis

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President:- CASE

1426 South Polk Stniet

'. Dallas, Texas' 75224

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GDS Associates, Inc.

Suite 720

1850 Parkway Place

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Marietta, Georgia 30067-8237

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-Billie Po ner Garde, Esq.

Robinson. Robinson, et. al.

103 East College Avenue

Appleton, Wisconsin 54911

=TV Electric

Bethesda Licensing

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.3 Metro Center, Suite 610.

' Bethesda, Maryland 20814

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Heron, Burchette, Ruckert, & Rothwell

. ATTN: : William A. Burchette,_Esq.

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Counsel for Tex-La Electric -

--Cooperative of Texas

1025 Thomas Jefferson St., N.W.

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Washington, D.C.

20007

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E. F. Ottney

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P.O. Box 1777

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u Glen Rose,' Texas;'76043

~Newman & Holtzinger, P.C.

ATTN:- Jack R.-Newman, Esq.

1615 L. Street, N.W.

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Suite 1000-

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' Washington, D.C. ' 20036

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, Texas' Department of Labor & Standards

ATTN:

.C. R. Bynog, Program Manager /

Chief Inspector.

Boiler Division

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P.O.- Box 12157,' Capitol Station .

Austin, Texas 78711

Honorable George Crump -

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County Judge-

Glen-Rose. Texas 76043

Texas Radiation Control Program Director

1100 West.49th Street.

Austin',_ Texas 78756

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bec d(strib. by RIV:

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R. D. Martin

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Lop # TXX-90315

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IR 90-22

Ref. # 10CFR2.201

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nlELECTRIC

September 4, 1990

Wimsm J. C abm, Jr.

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U. S. Nuclear Regulatory Commission

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Attn: Document Control Desk

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COMANCHEPEAKSTEAMELECTRICSTATION(CPSES)g\\'

SUBJECT:

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DOCKET NOS. 50 445 AND 50 446

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NRC INSPECTION REPORT NOS. 50 445/90 22; 50-446/90 22

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RESPONSE TO NOTICE OF VIOLATION

Gentlemen:

TU Electric has reviewed the NRC's letter dated August 3,1990, concerning the -

inspection conducted by the NRC staff during the period June 6 through July 5,

1990. This inspection covered activities authorized by NRC facility Operating

License NPF-87 and NRC Construction Permit CPPR-127 for CPSES Units 1 and-2.

Attached to the August 3,1990 letter was a Notice of Violation.

TU Electric hereby responds to the Notice of Violation in the attachments to

this letter.

Since, rely,

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William J. Cahill, Jr.

VPC/vid

Attachments

c - Mr. R. D. Martin, Region IV

Resident Inspectors, CPSES (3)

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400 North Olive Street L.B. 81 Dallas, Texas 75201

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Attachment I to TXX-90315

Page 1 of 2

Notice of Violation. Item A

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(445/9022-V-02)

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Technical Specification (TS) 6.8.la requires that written procedures shall

be established, implemented, and maintained covering the activities

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referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February

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1978.

Regulatory Guide 1.33, Appendix A, Section 8.b, states that specific

procedures for surveillance tests should be written, including

implementing procedures for each surveillance required by TS.

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Procedure OPT-467A, " Train A Safeguards Slave Relay K609 Actuation Test,"

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was established in accordance with TS 6.8.1.a.

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Contrary to the above, Procedure OPT-467A was inadequate in that it did

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not provide sufficient guidance regarding the solid state protection

system switch-lineup to allow testing of the desired slave relay under the

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existing plant conditions in Mode 5 or to prevent an inadvertent automatic

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start of a motor-driven auxiliary feedwater pump.

Response to Notice of Violation. Item A

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(445/9022-V-02)

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TV Electric accepts the violation and the requested information follows.

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Reason for the Violatiqn

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The cause of the inadvertent automatic start of a motor-driven auxiliary

feedwater pump was attributed to inadequate personnel performance.

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Operations personnel failed to adequately utilize a system operating

procedure (SOP-711A) attachment which verifies correct Solid State

Protection System switch _ alignment. Contributing to this occurrence was

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the fact that the slave relay actuation test procedure (OPT-467A), which

was in progress just prior to the event, did not contain sufficient

prerequisite information to ensure successful test completion. The OPT

did not reference SOP 711A, which requires the operator to verify the

correct position of switches $602 and S604 prior to test performance.

This procedural omission, as well as the event and detailed corrective

actions, were discussed in LER-90-018,

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2.

Corrective Steos Taken and Results Achieved

OPT-467A was changed to provide additional prerequisite information

regarding Solid State Protection System switch lineup during testing and

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normal operation. Action taken which addressed the root cause of the

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event was addressed in LER-90-018.

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Attachment I to -TXX-90315

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Page 2 of 2.

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Corrective Steos Which Will be Taken to Avoid Further Violations

A review of other slave relay test procedures was performes .o identify

similar procedural inadequacies.

Procedures with similar weaknesses were

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changed such that prerequisttes now place the system in a configuration

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which accommodates test performance.

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Date When Full Como11ance Will be Achieved

Full compliance has been achieved.

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Attachment 2 to TXX 90315

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Page 1 of.2

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Notice of Violation. Itga.]

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(446/9022-V-01)

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B.

Criterion V of Appendix B of 10 CFR Part 50 requires, in part, that

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activities affecting quality shall be prescribed by documented

instructions, procedures, or drawings, of a type appropriate to the

circumstances and shall be accomplished in accordance with these

instructions, procedures, or drawings.

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Station Administration Manual Procedure STA 606, ' Work Requests and Work

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Orders," Revision 14, Section 6.6.2.9, requires that work be performed in

accordance with instructions and in the sequence listed,

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Contrary to the above, on June 26, 1990, the work crew opened the Unit 2

reactor coolant pump seal water return filter instead of the correct -

fi' ar when working under Work Order C90-3176 which authorized work on the

Un c 2 reactor coolant filter.

Response to Notice of Violation. Item B

(446/9022 V 01)

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TU Electric accepts the violation and the requested information follows.

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Reason for the Violation

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A Mechanical Maintenance work crew began work on the Unit 2 reactor

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coolant pump seal water return filter but failed to verify that the

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component. tag number matched that of the component identified on the Work-

Order. This resulted in work being performed on the wrong component.

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This occurrence was influenced by a sequence of events which led the work

crew involved in the Unit 2 filter replacement training exercise to

incorrectly presume that the filter worked was correct since the exercise

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was being conducted as training for the replacement of the Unit I reactor

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coolant pcmp seal water return filter.

2.

Corrective Steos Taken and Results Achieved

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ONE form, FX-90 1798, was initieted to document the failure to follow Work

Order instructions. Mechanical Mainicr.=cc ;::.sonnel involved in the Unit

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2 reactor coolant pump seal water return filter work were reminded of ohe

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importance of Work Order compliance and the need for attention to detail

in performance of assigned tasks,

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Attachment 2 to TXX 90315

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Page 2 of 2

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Cartective Steos Which Will be Taken to Avoid Furthtr Violations

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The Maintenance Manager issued a memorandum to shos super'eisors to

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reemphasize the importance of procedure and/or wort instruction

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compliance.- This memorandus directed the shop supervisors to discuss ONE

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Form FX 90-1798 with their maintenance work crews and reiterate the need

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for attention to detail.

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In addition, the Maintenance Department requested an " Attention to Detail'

training course be developed by the Training Department and provided to

maintenance' personnel as part of the Maintenance Department ongoing cycle

Training Program. .Thereafter, ' Attention to Detail' training will be

repeated on a periodic basis.

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pate When Full Comoliance Will be Achieved

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The actions required by the Maintenance Manager's memorandum anC

development of Atter. tion to Detail training will be completed by

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September 24, 1990.

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Attachment 3 to TXI 90315

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Page 1 of 2

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Notice of Violation. Item C

(445/9022-V 03)

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Criterion XVI of Appendix B of 10 CFR Part 50 and the licensee's quality

assurance program as described in Section 17.2.16 of the facility Safety

. Analysis Report (FSAR) requires, in part, that measures shall be established

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to assure that conditions adverse to quality, such as failure, malfunctions,

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deficiencies, deviations, defective material and equipment, and

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nonconformances are promptly identified and corrected.

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Contrary to the above, a deficiency was not promptly identified and corrected

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in that the technical disposition of operations notification and evaluation

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(ONE) Form FX-90 Il0 failed to adequately quantify the reported flange

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misalignment.

This resulted in an indeterminate residual stress condition in

the flow orifice flanged joint immediately upstream of Auxiliary Feedwater

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Check Valve IAF-093.

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Specifically, the technical disposition which allowed the acceptance of the

reported misalignment was inadequate in that it failed to properly consider

the actual displacement of the flange which was physically restrained by the

presence of several flange fasteners left in place in the flanged joint.

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Resnonse to Notice of Violation. I,Otgl

(445/9022-V-03)

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TU Electric accepts the violatson and the requested information follows.

1.

Reason for the Violation

A site deficiency document (ONE Form) was utilized to document the

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existence of a flange misalignment problem noted during performance of a

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maintenance activity on the Auxiliary Feedwater (AFW) System. The ONE

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Form described the misalignment as approximately 1/4 inch.

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dispositioning the ONE Form, engineering personnel did not to visually

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. examine the nonconformance to precisely quantify the extent of

misalignment. The approximately 1/4 inch misalignment originally observed

was with flange fasteners still loosely installed. Subsequent removal of

the fasteners permitted the full misalignment to be precisely determined.-

Contributing to this occurrence was the fact that the governing

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maintenance procedure.did not clearly specify that misalignment be

measured with the flange loose but fasteners installed, and then again

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when the fasteners were completely removed. This lack of clarity in the

maintenance procedure was partly a reflection of a lack of specific detail

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in the governing specification.

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Attachment 3-to TXX-90315

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Page 2 of 2

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Corrective Steos Taken and Results Achieved

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After complete removal of fasteners from the subject flange, additional

measurements were taken of the misaligt.nent and the lack of face

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parallelism, and documented on a separate ONE Form.

Engineering performed

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a computer analysis of this condition and detemined that the stresses due

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to the misalignment were well below allowable limits.

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Corrective Steos Which Will be Taken to Avoid Further Violations

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A letter was issued to Design Engineering Organization personnel

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emphasizing the need for personal inspections of discrepant conditions

prior to dispositioning DNE Forms, and stressing that rigorous evaluations

of nonconfoming conditions are essential.

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The lack of clarity in the maintenance procedure and governing

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specification was documented on an additional ONE Form. The engineering

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specification has been revised to provide specific guidance for flange

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alignment with the fasteners removed and with the fasteners loosely

installed. Appropriate revisions to the mechanical maintenance procedure

are in progress.

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Date When Full Comoliance Will be Achieved

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The p scedure change described above will be issued by September 30, 1990.

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