ML20043A613

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LER 90-008-00:on 900416,Train a Diesel Generator Rendered Inoperable Due to Failure to Complete post-work Operability Testing on Starting Air Receiver Check Valve 01. Caused by Inadequate Review.Procedure revised.W/900516 Ltr
ML20043A613
Person / Time
Site: Comanche Peak Luminant icon.png
Issue date: 05/16/1990
From: William Cahill, Hood D
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-90-008, LER-90-8, TXX-90160, NUDOCS 9005220311
Download: ML20043A613 (9)


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I Lo'g. #'TXX-90160-. ,

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' File # 10200- l

'909.52 ,

C C Ref. # '50.73 -.

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M1 ELECTRIC 50.73(a)(2)(i). >

w.J.com . -

krcutive %ce President -

I U. S. Nuclear Regulatory Commission

-Attni Document Control Desk

. Washington, D.-C. 20555 ,

SUBJECT:

. COMANCHE PEAK: STEAM ELECTRIC STATION DOCKET NO.'50 445 CONDITION PR0HIBITED BY THE PLANT'S TECHNICAL SPECIFICATIONS' LICENSEE EVENT? REPORT 90-008 "

Gentlemen:

Enclosed is Licensee Event Report 90-008-00 for Comanche Peak Steam Electric

. Station Unit 1, " Train A Diesel Generator Inoperable."'

Sincerely,.-

y a$

William J. Cahill, Jr.

.RJB/daj -

Enclosure c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)

I 9005220311 900516 -

PDR ADOCK 05000443 -7 S PDC .

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4tJO North Olive Street LB 81 Dallas. Te.tas 73201 '

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l- Enclosure to TXX-90160 )

NRC FORM 366 - U.S. NUCLEAR HEGULAYORY COWW$$10N APPROVED OWB NO. 31640104 EXPIRE 8:4/3ME )

ESTIM ATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION 1 COLLECTON REQUEST: 60DHRS. FORWARD COMMENTS REGARDING f auRoEN E8tiuATE TO THE RECORo8 ANo REPORTS MANAGEuENT ,

LICENSEE EVENT REPORT (LER) GRANCH (P.630). U.8. NUCLEAR REOULATORY COMMISSION. WASHINGTON,  !

3C. 20656. AND 10 THE PAPERWORK REDUCTON PROJECT (3150 0104) l OFFICE OF MANAGEMENT AND BUDOET. WASHINGTON. DC. 20603. ]

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COMANCHE PEAK - UNIT 1 0151010l'Ol41415 1 I or 10i8  !

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TRAIN A DIESEL GENERATOR INOPERABLE  :

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{ower Other (Scoo#y b Anstram below and in Text.

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70 40$ulf HM 50 73(almM) 60.73(a)2(v) l Licensee Contars For This LER (121 lL __

Telephone Nurrber Name ,

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I Area Coue l D. NORMAN HOOD SUPERVISOR COMPLIANCE 8l117 819I 7 l- l 5 I 8 I 8 I 9 '

Compinto One Line For Each Componert Faauro Described in This Rooort (13)

Cause System CA,., .ert Manufacture' Cause System .C-. J' Manufactueer T T R - "-

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! Ab , (two u00 . to., ano, imate,y mieen .n paos we en i.e.) o6>

Train A Diesel Generator (DG) was rendered inoperable on April 11,1990 at 0230 CST due to the failure to complete post work operability testing on Starting Air Receiver 01 check valves prior to initiating maintenance activities on the redundant Starting Air Receiver 02 check valves. The DG was discovered to be inoperable on April 16,1990 at 1102 CST by a Unit 2 ,

Supervisor who was reviewing post work test packages for closure. Both Starting Air Systems of Train A DG had undergone maintenance on air receiver inlet check valves without -

performing the required post work operability testing. Train A DG was declared inoperable at ,

1102 CST since one Starting Air Syctem is required to be available and operable, Post work operability testing was satisfactorily completed on the Starting Air Receiver 01 check -

- valves and the Train A DG was declared operable on April 16,1990 at 1335 CST. -

The root cause of the event was inadequate review of the work package on Starting Air Receiver 01 check valves prior to initiating work activities on Starting Air Receiver 02 check 4 valves. Corrective actions include procedure savisions and counselling of personno!.

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' Enclosyre to TXX 90160 l NRC FORM 366A U.S. NUCLE AR REGULA TORY COMMISSION APPMD OMB E St80 0108 ESTIMATED BURDEN PER RE E COMPLY WITH THl8 INFORMATION LlOENSEE EVENT REPORT (LER).  %,'","jM8';1 y'7","'g,y,^*,g,8 ,%L*g, TEXT CONTINUATION l

f","i7g,u s NmAR g Ry r aAToRyn CoMMesa e, nw w7 OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON OC.20601 Fachy Nam. (1) Duchet Number (2) LER Nunter t8) Page (3) v- e 9:3= mi r?m COMANCHE PEAK - UNIT 1 015101010l414l5 910 -

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1. DESCRIPTION OF WHAT OCCURRED ,

A. PLANT OPERATING CONDITIONS BEFORE THE EVENT ,

( On April 16,1990, Comanche Peak Steam Electric Station (CPSES) Unit 1 was in .l Mode 2, Startup, at approximately 2 percent power.

B. REPORTABLE EVENT DESCRIPTION (INCLUDING BATES AND APPROXIMATE TIMES OF MAJOR OCCURRENCES)

Event Classification  : Any operation or condition prohibited by the plant's ~ '

l Technical Specifications.

l L

On March 27,'1990, two work requests were initiated to replace gaskets (Ells:(SEAL)(LC)) on the Train A Diesel Generator (DG) Starting Air Receiver check valves (Ells:(V)(LC)) which separate the safety grade portion of the DG Starting Air-System (Ells:(LC)) from the non safety portion. Work requests were submitted to j Mechanical Maintenance Planning for preparation of the work order package. The .

l prepared work order packages, including a clearance requ_est for isolation of ,

components during work performance and a Post-Work Test Report (PTR) which identified required operability testing, were forwarded to the Site Work Control Center (S'WCC) to be reviewed by the SWCC Operations reviewer (utility licensed) l for plant impact. - The SWCC Operations reviewer (utility-licensed) added the l comment to the work package associated with Starting Air Receiver 01 check valves I

to " ensure the 02 compressor and air receiver are in service" during work ,

i performance. A similar note was added to the work package associated with ,

l Starting Air Receiver 02 check valves. '

1 Clearance for work associated with Starting Air Receiver 01 check valves was authorized and clearance tags were attached to the appropriate equipment on April 7,1990 at 2150 CST. The clearance was accepted on April 8,1990 at 0312 and . ,

work was authorized to start on April 9,1990.

Enclosure to TXX 90160 NRC FORM 366A U.S. NUCLE AR fisOULA10RY COMMIS$10N APPRO B NO B 0104 ESTIMATE 0 8URDEN PER RESDONSE TO COMPLY WITH TH$ 1NFORMA.EW LICENSEE EVENT REPORT (LER) $%El,% "Eg8'; gl"gg,g,"*,M8gfg^

TEXT CONTINUATION 82%"ggyf,"fy,W&"u*cEREcE""0E [

OFFICE OF MANAGEMENT AND BUDGET. WASHINGTON. DC. 20603.

Doce6et hunte, p) LER Nunter (6) Page (3p Faomy Name (1)

- w: w.y w m COMANCHE PEAK , UNIT 1 0l510101014l415 910 0l0l8 -

0IO Ol3 OF 018 w=. - . - on. -i C am.a 6A. m l The DG (Ells:(DG)(EK)) is designed to operate with one of the two redundant 100 ,

percent capacity Starting Air Systems. When work was authorized to begin on Starting Air Receiver 01 check valves, a Tracking Limiting Condition for Operations Action Requirement (LCOAR) was initiated on April 9,1990 at 1310 CST. The LCOAR was initiated as a precautionary measure and not required by procedure.

Plant procedures require either active or tracking LCOARs when a Technical-Specification (TS) Action Statement is entered. Active LCOARs apply to the present plant mode and tracking LCOARs apply only to a mode change restraint. The two requirements for terminating the tracking LCOAR for work on Starting Air Receiver 01- .

check valves were (1) complete work order and (2), associated clearance released.

Field work was completed on the Starting Air Receiver 01 check valves and the associated clearance was released with tags removed on April 10,.1990 at 2019 CST Post work / pretest review of the PTR was then performed and the work package was statused for post work testing.  !

Cloarance for work associated with Starting Air Receiver 02 check valves was l authorized on April 10,1990 at 1626 CST and clearance tags attached on April 11, -

1990 at 0230 CST The clearance was accepted by Operations on April 11,1990 at - -

0405 CST. The Sbbt Supervisor (utility-licensed) reviewed outstanding clearances L

and ensured that DG Starting Air System 01 was in service with the Starting Air  !

Receiver 01 tank (Ells:(TK)(LC)) pressurized prior to the clearance tags' being attached. However, the LCOAR logs were not reviewed and a tracking LCOAR was not initiated. Work was authorized to start on Starting Air Receiver 02 check valves on April 11,1990. F! eld work was completed on April 11,1990 and post work / pretest review of the PTR was performed on April 12,1990. The associated clearance was released on April 13,1990 at 0225 CST and the work package was statused for post .

work testing.

l On April 12,1990, the work packages for Starting Air Receiver check valves were forwarded separately to the Control Room for the performance of post work operability testing. On April-16,1990 at 1102 CST, while reviewing post work testing -

L packages for closure, a Unit 2 Supervisor (utility-licensed) discovered that both L Starting Air Systems fcr Train A DG had undergone maintenance on air receiver inlet l check valves without performing the required post work operability testing. Upon discovery, the Train A DG was immediately declared inoperable and an active LCOAR was initiated. Technical Specification 3.8.1.1 Action Statements were met.

Post work operability testing was satisfactorily completed on April 16,1990 at 1333

l Enclospre to TXX-90160 j NRC FORM 366A ' . U.S. NUCLE AR REGULATORY COMMISSON APPROVED OMB NO. 31640104., 1 EXPIRE 8:4/3Mie . -) '

ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THl$ INFORMATON LICENSEE EVENT REPORT (LER) g'ol,'M,Ty; 1 l"gg,y, , gy, ff'g,'" ,

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TEXT CONTINUATION u 8"^ g 7 gyp,Ngrngyn%9 RR g ngc S

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OFFICE OF MANAGEMENT AND BUDGET.WASHNOTON DC.20601 LE R Nueer (6) P.gm (3) i F acany Name (1) Dook.t Nue.r (2) v- m te a mam  !

COMANCHE PEAK - UNIT 1 0151010101414 l 5 910 -

0IOl8 -

010 014 OF 018 >

i v <-. . muen --Ru- mA e> <,n CST on Starting Air Receiver 01 check valves. Train A DG was declared operable on April 16,1990 at 1335 CST and the active LCOAR was terminated. Post work operability testing on Starting Air Receiver 02 check valves was satisfactorily

completed at 1434 CST.

For Modes 1 through 4, the DG being inoperable due'to both Starting Air Systems inoperable would require entry into TS Action Statements. The failure to identify that the DG was inoperable resulted in not completing the appropriate actions specified '

as well as exceeding the time frame allowed by the Action Statement for DG inoperability.

a C. STATUS OF STRUCTURES. SYSTEMS. OR COMPONENTS THAT WERE INOPERABLE AT THE START OF THE EVENT AND THAT CONTRIBUTED TO THE EVENT Not applicable - no structures, systems, or components were inoperable at the start of the event that have been determined to have contributed to the event.

D. CAUSE OF EACH COMPONENT OR SYSTEM FAILURE. IF KNOWN Not applicable - no component or system failures have been identified.

E. FAILURE MODE. MECH ANISM. AND EFFECT OF EACH FAILED COMPONENT Not applicable - no failed components have been identified. -

F. FOR FAILURES OF COMPONENTS WITH MULTIPLE E FUNCTIONS. LIST OF SYSTEMS OR SECONDARY  ;

! FUNCTIONS THAT WERE ALSO AFFECTED l

Not applicable -no component failures have been Identified. 5

Enclosure to TXX-90160 NFCFORM386A U.S. NVOLE AR HEGULA10RY COMMu$lON APPROWD OMB NO. 3150104 ESTIMATED BURDEN PER RL8 8 COMPLY WITH THIS INFORMATION LICENSEE EVENT REPORT (LER) $";5l,'%,",5y8';

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1 , " ^7 , L C "," R o7gc Q Q OFFICE OF MANAGEMENT AND BUDGET, WA$HINGTON. DC. 20603.

Fachy Name (1)

  • Dodet Numtier (2) LER Nunter (6) Papa (3) i v- 4 w wm COMANCHE PEAK - UNIT 1 015l010101414l5 910 -

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010 015 OF 0g i u. . ... . . w.cF - = 4.n m G. FOR FAILURES THAT RENDERED A TRAIN OF A SAFETY SYSTEM INOPERABLE. AN ESTIMATE OF THE ELAPSED TIME FROM THE DISCOVERY OF INOPERABILITY UNTIL THE TRAIN WAS RETURNED TO SERVICE Train A DG was discovered to be inoperable on April 16,1990 at 1102 CST and was returned to operability at 1335 CST for a total elapsed time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 33 minutes.

The Train A DG was rendered inoperable on April 11,1990 at 0230 CST when tho )

- clearance tags for work on Starting Air Receiver 02 check valves were attached.- <

l

. Train A DG was Inoperable for 5 days,8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and.32 minutes prior to discovery. l

- H.- THE METHOD OF DISCOVERY OF EACH COMPONENT OR SYSTEM FAILURE OR PROCEDURAL ERROR I

While reviewing the post work testing packages for closure, a Unit 2 Supervisor (utility-licensed) discovered that redundant Starting Air Systems for Train A DG had q undergone maintenance on air receiver inlet check valves without comp!eting the l required post work operability testing identified in the work packages.

l

1. CAUSE OF THE EVENT I i

Root Cause j q

The root cause of Train A DG being inoperable without entering appropriate TS Action Statements within required time frames was inadequate review by the Operations reviewer (utility-licensed) of the work package on Starting Air System 01 check valves. Personnel ensured that Starting Air System 01 was in service  :

prior to authorizing work on Starting Air System 02 check valves but did not identify i that post work operability testing was required. Therefore, the Operations reviewer did not identify that the DG was rendered inoperable. This is considered a personnel error contrary to an approved procedure.

_ . _ - _ _ - - _ _ . - - _ - - - . _ _ _ e-,- .e.,- +-n- ,, , _e _. + . , , . ,, , , , , , ,

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Enclosure to TXX 90160 t- NRC FORM 366A U.S. NUCLEAR hEGULATORY COMM4SION #PROWD OM8 E 320W ESTIMATED BURDEN PER RES NS COMPI,Y WITH THIS INFORMATON E H ARD S RE LICENSEE EVENT REPORT (LER) RolyT,",E3, ST , ,, wN NT

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TEXT CONTINUATlON OC. 20555, AND TO THE PAPERWORK REDUCTON PROJECT (31S>0104).

OFFCE OF MANAGEMENT AND BUDGET, WASHINGTON. DC 20603.

F acey Nam. (i) Dochee Noeer (2) LER (6) Pag. (3)

COMANCHE PEAK - UNIT 1 01510101014l4l5 910 -

0IOI8 -

Ol0 0l6 OF 0l8 u ic.iw mo . . . e .. -M NRcF.,m a66A.3(ir) i l

Contributina Factor Procedures were less than adequate. Plant procedures did not require tracking LCOARs to be issued when one of two redundant trains are removed from service .

when the component is not rendered inoperable. As such, when the clearance was approved for work on Starting Air Receiver 02 check valves, the LCOAR log was not -

reviewed.

J. SAFETY SYSTEM RESPONSES THAT OCCURRED Not applicable - there were no safety system responses and none were required.

K. FAILED COMPONENT INFORM ATION Not applicable - no failed components were involved.

l II. ASSESSMENT OF THE SAFETY CONSEQUENCES AND IMPLICATIONS OF THIS EVENT CPSES Unit 1 is designed with two independent DGs sized so that each set is capable of carrying the required load in the event of a loss of offsite power, safety injection signal or manual initiation. Each DG is designed with two 100 percent capacity Starting Air Systems, each capable of starting the DG and consists of a non-safety air compressor (Ells:(CMP)(LC)) and air dryer (Ells:(DRY)(LC)) and safety related air receiver tank and air start manifold (Ells:(BAF)(LC)). The check valves separate the . safety grade portion of the Starting Air System from the non-safety related portion and are identified as American L Society for Mechanical Engineers Boiler and Pressure Vessel Code Section XI valves.

1 Although Train A DG was rendered inoperable in Mode 2 without initiating the appropriate TS Action Statements within the specified time limits, the event did not adversely affect the safe operation of CPSES Unit 1 or the health and safety of the public based on the following discussion.

?

Enclospre to TXX-90160 NF0 FORM 366A U.S. NUCLEAR REQULATORY COMMSSON APPROVED OMB NO. 31940104 EXPIRES:4'3092 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTTH THIS INFORMATON LICENSEE EVENT REPORT (LER) g,C, ",1,'M*T; y' l","*ggy,'", g,"'8ffo",Z, TEXT CONTINUATION ""^""7>**""^""E"*^'" " " * * " " " " *  :

DC. 20556. AND TO THE PAPERWORK REDUCTION PROJECT (31540104). e OFFCE OF MANAGEMENT AND SUDOET. WASHfHOTON, DC.20603.

Fcotsy Name (t) Docket Nurreer (2) LER hunter (6) Pa0* (3)

  • v- a w a p_s COMANCHE PEAK - UNIT 1 0151010l0l4l4l5 910 -

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1) Train B DG was operable and available during the time period Train A DG was -

Inoperable and would have responded to an emergency or manual start signal. The - .

i monthly surveillance test to ensure Train B DG operability had been successfully completed on April 5,1990.  :

2)- Both Starting Air Systems on Train A DG successfully met post work operability testing requirements.

3)'

During the time period Train A DG was rendered inoperable on April 11; 1990, a -  ;

Starting Air System was in service at all times although post work operability testing had not been conducted.

  • lll. CORRECTIVE ACTIONS L Root Cause '

Inadequate post work order review on Starting Air Receiver 01 check valves prior to i l Initiating work on the redundant Starting Air Receiver 02 check valves.

Corrective Action Personnelinvolved with this event have been counselled. To provide additional  !

l awareness on the importance of performance of work order review,' this Licensee Event '

Report will be reviewed by on shift licensed operators. The post work closure process will be reviewed and identified enhancements will be incorporated.

Contributina Factor [

, Procedures did not cover the situation of initiating tracking LCOARs when one of two-L trains are removed from service when the component is not rendered inoperable.

4 Enclosure to TXX 90160

'NRC FbRU se6A . U.S. NUCLEJ.R REOULATORY COMM4 SON APPROVED OM8 NO.31640104 EXPIRES:4M ESTIMATED BURDEN PER RESPON8E TO COMPLY WITH THIS INFORMATION C LLECTON RE UEST E0 HRS. FORWMD COMMENTS REGARDM i LICENSEE EVENT REPORT (LER) OURDEN ESitMATE TO THE RECORD 8 AND REPORTS MANAGEMENT  !

BRAN H (PM M NU LEAR REOaATORY COMMISSim WASHMTON.

TEXT CONTINUATION Z. 20555. AND TO THE PAPEHWORK REDUCTON PROJECT (31600104).

OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON. OC. 20603.

Facday Name (1) Docmat Nunter (2) LER Nuntier {6) Page (3)

Year Qf "y^^jy a G-S :

COMANCHE PEAK , UNIT 01510IOIOl414I5 910 -

0l0l8 -

010 0l8 OF 0l8 iai e me - . -ixm NRC F- 21A.m i) t Corrective Actions L A shift order was issued April 16,1990 instructing that tracking LCOARs be initiated when f one of two redundant trains are removed from service although the component is not rendered Inoperable. This requirement will be incorporated into the plant procedures.

The procedure revision willincrease the scope of tracking LCOARs to include present a plant mode components also.

IV. PREVIOUS SIMILAR EVENTS L There have been no previous similar events reported pursuant to 10CFR50.73.

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