ML20045A991

LER 93-004-00:on 930514,failure to Satisfy TS Surveillance for Verification of Valve Position Due to Valve Discrepancies Discovered During DBD Review.Valve Cap & Clearance installed.W/930611 Ltr

ML20045A991
Person / Time
Site:	Comanche Peak
Issue date:	06/11/1993
From:	William Cahill, Reimer D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-93-004-01, LER-93-4-1, TXX-93238, NUDOCS 9306160040
Download: ML20045A991 (7)

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Log # TXX-93238 C

._. 3 File # .10020 1UELECTRIC ef. # 0. ( )( )(B) 0 June 11,i1993 wmiam J. Cahm, Jr.

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

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NO. 50-446 A CONDITION PR0HIBITED BY TECHNICAL SPECIFICATIONS LICENSEE EVENT REPORT 93-004-00 Gentlemen:

Enclosed is Licensee Event Report 93-004-00 for Comanche Peak Steam Electric Station Unit 1 " Failure to Satisfy Technical Specification Surveillance Requirement for Verification of Valve Positions".

Sincerely, WAinJ celdL Jo William J. Cahill, Jr.

By: b J.'J. Kelley, Jr.

Vice President of Nuclear Operations OB:tg Enclosure j cc: Mr. J. L. Milhoan, Region IV j Mr. L. A. Yandell, Region IV '

Resident Inspectors, CPSES (2) 150028 9306160040 930611 M ADOCK 05000446 h /

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PDR C .. PM r$1 P.O. Box 1002 Glen Rose, Texas 76043-2002 . l' 0 l l

. Enclosure to TXX-93238 kHC f OHM 3e6 U.S NUCLEAR RE GULA1 DRY COMM:SSON APPRDVED OMB NO. 31504104 EXPRES:4" O 92 ESTIM ATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORM ATOP COLLECTON REQUEST: 50.0 HRS. FORWARD COMMENTS REGARDINC auRDEN ESTIMATE TO THs RECORDS ANo REPORTS MANAGEMEN-LICENSEE EVENT REPORT (LER) BRANCH (P.530), U.S. NUCLE AR REGULAlDR, COMMISSON, WASHINGTON.

DC. 23555, AND TO THE PAPERWORK REDUCTON PRO.!ECT (3150-0104).

OFFICE OF M ANAGEMENT AND BUDGET. WASHINGTON, DC. 20503.

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FAILURE TO SATISFY TECHNICAL SPECIFICATION SURVEILLANCE FOR VERIFICATION OF VALVE POSITION

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On May 14,1993, an operations procedure reviewer discovered that position verification, as required by Technical Specifications (T/S) for some Process Sampling valves, was not incorporated into CPSES Uns 2 procedures. The overall cause of this event was a lack of requirements for reviews by Operations personnel of design changes issued during Unit 2 construction and a lack of attention to detal' concerning the specific design change involved in the event. Corrective actions included veitying valve positions, incorporating the position verification for the valves in appropriate procedures and performing reviews for generic implications.

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DESCRIPTION OF THE REPORTABLE EVENT \

A.

REPORTABLE EVENT CLASSIFICATION _

Technical Specification surveillance was .

requirednot performe B.

PLANT OPERATING CONDITIONS PRIOR TO THE EVEN On May 14,1993, Comanche Peak Steam Electric Station (CPSES percent rated thermal power. Integrated Startup Testing was atwas 29 in progress C. .

INOPERABLE AT THE START OF TO THE EVENT TRIBUTED THE EVEN ERE There event. were no inoperable structures, systems or components that contributed to the D.

APPROXIMATE TIMESNARRATIVE

SUMMARY

OF THE EVENT, least once per 31 days, CONTAINMENT .

ar at at rated by verifying that INTEGR l

l all manual valves outside containment, needed toe.isolate a penet ,

I On February 26,1992, and on June 25,1992, Design Change Author ons (DCAs)

Containment isolation manual valves ng (Ells: (ISV)(K rawings. The i DCAs failed to document on these drawings that the valves were to be l

and capped. Because these drawings were used ockedto closed prepare the proc verify closure of containment isolation valves per T/S 4.6.1.1a, Proces 2PS-0030,2PS-0510,2PS-0511, and 2PS-0512 no (drain valves adjace containment penetrations) were not incorporated into these procedures .

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1. DESCRIPTION OF THE REPORTABLE EVENT A. REPORTABLE EVENT CLASSIFICATION Any operation or condition prohibited by the Technical Specifications. A required  ;

Technical Specification surveillance was not performed.

B. PLANT OPERATING CONDITIONS PRIOR TO THE EVENT On May 14,1993, Comanche Peak Steam Electric Station (CPSES) Unit 2 was at 29 percent rated thermal power. Integrated Startup Testing was in progress.

C. STATUS OF STRUCTURES, SYSTEMS, OR COMPONENTS THAT WERE INOPERABLE AT THE START OF THE EVENT AND THAT CONTRIBUTED TO THE EVENT There were no inoperable structures, systems or components that contributed to the event.  :

D. NARRATIVE

SUMMARY

OF THE EVENT, INCLUDING DATES AND '

APPROXIMATE TIMES ,

t Technical Specification Surveillance Requirement 4.6.1.1a requires in part that at least once per 31 days, CONTAINMENT INTEGRITY be demonstrated by verifying that '

all manual valves outside containment, needed to isolate a penetration, are closed.

On February 26,1992, and on June 25,1992, Design Change Authorizations (DCAs) were initiated by CPSES Unit 2 Engineering to incorporate Process Sampling Containment isolation manual valves (Ells: (ISV)(KN)) into vital station drawings. The DCAs failed to document on these drawings that the valves were to be locked closed ,

and capped. Because these drawings were used to prepare the procedures to verify closure of containment isolation valves per T/S 4.6.1.1a, Process Sampling valves 2PS-0030,2PS-0510,2PS-0511, and 2PS-0512 (drain valves adjacent to  ;

containment penetrations) were not incorporated into these procedures.

Enclosure to TXX-93238 NHC FOHM St0A u.5. N4d.As hHah. ATOAt C,OMM255.ON APPROVED OWB NO. 31MW EXPIRES:4/3n2 .

ESTIM ATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORM ATch

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0 0 0 3 w 0 6 i.%. u-,,- -- +c w .m o a E. THE METHOD OF DISCOVERY OF EACH COMPONENT OR SYSTEM FAILURE, OR PROCEDURAL OR PERSONNEL ERROR On May 14,1993, an Operations procedure reviewer (utility, licensed) performed a review of a draft revision to Design Basis Document (DBD)-ME-013 " Containment isolation System." During this review, the procedure reviewer discovered that the Primary Sampling Valves were not properly identified as Containment Penetration Non-Automatic Isolation Valves on the flow diagram, in the DBD or in Operations and j Chemistry procedures.  ;

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11. COMPONENT OR SYSTEM FAILURES A. FAILURE MODE, MECHANISM, AND EFFECT OF EACH FAILED COMPONENT j

l Not applicable - there were no component failures associated with this event.

B. DURATION OF SAFETY SYSTEM TRAIN INOPERABILITY Not applicable - there was no safety related equipment rendered inoperable during or i as a result of the event.

C. SAFETY CONSEQUENCES AND IMPLICATIONS OF THE EVENT The field conditions and programs for Containment Isolation consist of: 1) use of double isolation barriers,2) periodic testing,3) administrative control of manual isolation valves, and 4) surveillance of automatic isolation valves. These activities meet requirements and ensure the Containment isolation System performs its intended function. Incorrect positioning of a manualisolation valve on these penetrations would have been detected via normal plant activities. Under postulated accident conditions the Containment isolation System would have satisfactorily performed its intended safety function.

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i.m.m. - .r - - ~acso,m m ypn III. CAUSE OF THE EVENT The following causes contributed to this event. A review of the design change process i used during the construction phase indicated that procedures did not require that changes affecting a DBD be included in the design change document being prepared. Rather, the DBD was to be reviewed to roll up all affected changes as the Unit 2 work scope neared completion. The valve discrepancies were discovered during the DBD review to roll up all design changes.

The procedures also did not require an Interdisciplinary Review (IDR) by Systems ,

Engineering or a review by Operations personnel for impact on Operations programs and i procedures unless the system had been turned over to Operations.

More attention to detail by the design change engineers during origination, review and approval may have precluded the event. Neither the originator nor reviewers identified the need for locked closed valves (similar to Unit 1), the need for a DBD change, or the need to change Operations procedures.

IV. CORRECTIVE ACTION l i

A. IMMEDIATE Upon discovery, Operations personnel were dispatched to verify the valve positions.

The as-found condition of the valves (May 14,1993) were:

2PS-0030 - CLOSED, uncapped.

2PS-0510 - CLOSED, capped.

2PS-0511 - CLOSED, capped.

2PS-0512 - CLOSED, capped.

Immediate corrective actions included installing the valve cap and hanging a clearance to administratively maintain the valves closed.

A review of Unit 1 drawings and procedures indicated that the valves were listed and designated correctly on Unit 1 documents.

. En, closure to TXX-93238 tec FOHM MA LLb. NJCLEAR niCmAATORY COMut5hiON APPROVED OMB NO. 31504104 [

EXPIRES:4'3Mt2  ;

ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATIOk i ME Tl N R@EST: SM HRS. FORWARD COMMNS REGARDING LICENSEE EVENT REPORT (LER) BURDEN ESTIMATE TO THE RECORDS AND REPORTS MANAGEMEN' i-

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B. ACTIONS TO PREVENT RECURRENCE j Applicable design documents and operations procedures will be updated to reflect the position and status of the valves discussed in this report. The appropriate surveillances will be performed. 7 Operations performed a review of other Unit 2 Containment penetrations as depicted j on vital station mechanical drawings. This review compared the valves associated i with each penetration to the valves listed ;n surveillance procedures. Additionally, the results of the comparison were reviewed against the DBD-ME-013 listing of these ,

valves. This review determined that the drawings, surveillance procedures and the t DBD contained the required valves and were consistent with each other.

Engineering reviewed the Design Change Notice in question and a sampling of other Design Change Notices prepared by Unit 2 Engineering (construction phase) personnel that affected DBDs. A design drawing and FSAR figure were identified to  !

be incorrect. These discrepancies did not affect operability and applicable documents will be corrected. [

The Unit 2 construction program is no longer in effect. Design activities are being f performed under Unit 1/ Unit 2 procedures. Under these procedures, Engineering personnel perform IDR on plant changes. In addition, Design Modifications or Minor Modifications receive Operations impact Assessments. This process assesses the impact of a design change on Nuclear Operations programs and procedures. The two unit program has not produced errors similar to the one described in this event.  ;

V. PREVIOUS SIMILAR EVENTS  ;

CPSES Units 1 and 2 have submitted a number of Licensee Event Reports (LER) concerning missed surveillances. This report identifies the causes of this event to be a lack of requirements for operational reviews of design changes during Unit 2 construction and inattention to detail during the design change process. None of the previous LERs associated with missed surveillances identified the cause(s) as inadequate design control.

Although some of the LERs discussed personnel error or inattention to detail, none were related to the design change process. LER 50-445/92-015-00 " Personnel Error Leading to Potential Inoperability of Blackout Sequencer" (which did not discuss a missed l

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Test (11 f cre spum a tmaurea. <me a20numm N c Form 3t4A sp (17) l surveillance) identified the root cause and contributing factors to be related to inadequate ,

design controls; however, the causes and contributing factors were different from those described in this event. The corrective actions taken for LER-92-015-00 would not have l precluded this event.

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