IR 05000445/1998004
| ML20238F035 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/16/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20238F031 | List: |
| References | |
| 50-445-98-04, 50-445-98-4, 50-446-98-04, 50-446-98-4, NUDOCS 9809030065 | |
| Download: ML20238F035 (13) | |
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ENCLOSURE U.S. NUCLEAR RECULATORY COMMISSION
REGION IV
Docket Nos.:
50-445 50-446 License Nos.:
NPF-87 NPF-89 Report No.:
50-445/98-04 50-446/98-04 Licensee:
TU Electric Facility:
Comanche Peak Steam Electric Station, Units 1 and 2 Location:
May 10 through June 20,1998 Inspector (s):
Anthony T. Gody, Jr., Senior Resident inspector Harry A. Freeman, Resident inspector Approved By:
Joseph I. Tapia, Chief, Project Branch A Division of Reactor Projects Attachment:
Supplemental Information j
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9809030065 980716 W
PDR ADOCK 05000445 i
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EXECUTIVE SUMMARY Comanche Peak Steam Electric Station, Units 1 and 2 NRC Inspection Report 50-445/9804; 50-446/9804 The resident inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 6 week period of resident inspection.
j Operations
Operations continued to be characterized by conservative plant operation.
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Operations personnel actively pursued a temporary modification to a condensate pump motor to increase secondary plant reliability and thereby reduce the potential consequences of a plant transient. Operators consistently used self-verification and peer-checking as circumstances warranted and were attentive to the control boards (Section 01.1).
Maintenance Plant material condition continued to be excellent. This was evident during plant
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walkdowns, a review of equipment reliability, and during ongoing reviews of the licensee's problem identification process. Few valve packing and equipment oil leaks were noted. Very few temporary hoses and drip-catch containment assemblies were needed. The licensee actively identified and corrected material condition deficiencies in a timely manner (Section M2).
The installation of the temporary modification to provide attemate cooling to
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Condensate Pump Motor 1-02 lower bearing was in accordance with the temporary modification instructions. Material installation was of high quality and used techniques similar to permanent changes to the facility. All components were secured to structural components and did not interfere with permanently installed
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components (Section E2.1).
Cable spreading room deluge valves were demonstrated operable by knowledgeable
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technicians. Some minor discrepancies were noted with the procedures and with the implementation of the tests.' These discrepancies did not invalidate the tests and were considered to be minor (Section M3.1).
Enaineerina
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'1 The temporary modification package to provide attemate cooling to Condensate
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Pump Motor 1-02 lower bearing was thorough and detailed. Specific componenta, installation, and testing instructions were included in the package. The technical screen and impact reviews were appropriate (Section E2.1).
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Report Details
Summary of Plant Status Units 1 and 2 operated throughout the inspection period at essentially 100 percent power.
1. Operations i
- O1 Conduct of Operations 01.1 Observations of Ooerator Performance a.
- Inspection Scoce (71707)
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J The inspectors conducte_d reviews of ongoing plant operation by touring the plant and walking down control boards and safety systems. The inspectors routinely observed activities in the control room. Several operating crews were observed for
^ continuous periods ranging from 1 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and the inspectors also observed a number of shift turnovers.
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Observations and Findinas The licensee demonstrated a safety-conscious approach towards plant operations.
This was particularly evident in the decision associated with the Condensate Pump Motor.1-02 lower bearing cooling problems. A loss of one condensate pump while at 100 percent power would likely have caused an automatic reactor trip. The licensee closely monitored the pump motor parameters and installed an effective temporary
modification to provide alternate cooling to the lower bearing. The inspector noted that the individual operator turnover briefings were thorough and of sufficient detail to understand both ongoing and planned activities Oncoming crew briefs were
' thorough and comprehensive with each member of the crew providing a complete status of activities and equipment for their areas.
Operators consistently demonstrated effective communications. Communications were clear and unambiguous. Unit supervisors ensured that management expectations for three-leg communications were met. Communications outside the control room were generally formal.
The inspector noted that licensed reactor operators routinely exhibited good self-checking and peer-checking when manipulating controis and operating components.
Control room staffing met procedural and Technical Specification requirements and supervisory oversight of operators was appropriate. Control room access was limited by the unit supervisors and distractions to operators were appropriately minimized.
Throughout the inspection' period, the inspectors noted that control room operators were attentive to their watch stations. The inspectors observed operators implement
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i conduct of operation procedures and guidance by scanning the control boards and l
l by performing board walkdowns at the appropriate intervals.
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Operators followed the appropriate procedures when they responded to alarms and during routine plant evolutions. Operators were generally aware of the status of (
annunciators and knowledgeable of out-of-service annunciators and their compensatory measures.
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Operational Status of Facilities and Equipment l
02.1 Enaineered Safety Feature System Walkdown a.
Inspection Scope (71707)
The inspector performed a walkdown of the accessible portions of the Unit 2 residual heat removal system. The inspector reviewed the Final Safety Analysis Report, Technical Specifications and their bases, design basis documents, plant drawings, I
and standard operating procedures for the system.
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Observations and Findinos The inspector found that equipment was operable, and that material condition and I
housekeeping were good. The residual heat removal system was maintained in a condition as described in the Final Safety Analysis Report and was tested in i
accordance with Technical Specification requirements. Containment isolation valves were in their required position and found locked when appropriate.
Miscellaneous Operations issues (92901,92700)
j 08.1 (Closed) Violation 50-446/9720-01: inadequate procedure resulted in both power-operated relief valves opening when pressure was allowed to remain above the low-temperature overpressure protection system limit. The inspector verified that the corrective actions described in the licensee's response letter, dated March 15, j
1998, were reasonable and complete. Changes to the operating procedures were
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designed to prevent recurrence.
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08.2 (Closed) Violation 50-446/9720-02 and LER 50-446/97005-00: conducting core alterations with the personnel airlock doors incapable of being closed. The inspector verified that the corrective actions described in the licensee's response letter, dated March 15,1998, were reasonable and complete. Changes to the operating procedures were designed to prevent recurrence.
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08.3 (Closed) LER 50-446/98002-00: automatic reactor trip subsequent to a turbine trip due to loss of turbine plant cooling water. This issue was discussed in Inspection l
Report 50-445(446)/9802. No new issues were revealed by the LER.
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-5-08.4 (Closed) Violation 50-446/9801-01: failure to document the heat related degradation of the solid state safeguards sequencer on a ONE form was a violation of Technical Specification 6.8.1. The inspector verified that the corrective actions described in the licensee's response letter, dated April 24,1998, were reasonable and complete.
08.5 (Closed) Inspection Followuo item 50-445/9803-02: minimum residual heat removal (RHR) system flow requirements during reduced inventory operations. In NRC inspection Report 445(446)/9803, the inspector noted that operators closed the RHR heat exchanger inlet valve and then bypassed the heat exchanger in accordance with Procedure IPO-010A, " Reactor Coolant System Reduced Inventory Operations,"
to accomplish the reactor coolant system heatup prior to performing the reactor coolant system vacuum fill. The inspector questioned whether it was appropriate to throttle RHR system flow prior to bypassing the heat exchanger as directed in Procedure IPO-010A. Reducing RHR flow through the core to only the leakage of the RHR heat exchanger inlet valve could adversely affect both reactor temperature indications and boron mixing. The inspector reviewed the licensee's response to NRC Generic Letter 88-17, " Loss of Decay Heat Removal," in Letter TXX 89041 dated February 10,1989, and found that the licensee had stated, " reduced inventory operating procedures were being prepared that would address required minimum RHR flow for decay heat removal." The inspector also found that IPO-010A specified the minimum RHR flow to be 1000 gallons per minute.
The inspector questioned the licensee on this apparent procedure inconsistency and found that the licensee had not considered how the steps in IPO-010A, which directed operators to close the RHR heat exchanger inlet valve, affected reactor coolant system temperature indications or boron mixing. In assessing the significance of the observations, the inspector noted several facts: (1) the RHR heat exchanger inlet valve leaked significantly (approximately 600 gallons per minute), (2)
RHR flow was decreased to below 1000 gallons per minute after a refueling outage and, as a result, only a small amount of decay heat was present, and (3) the RHR heat exchanger bypass valve was opened quickly, restoring RHR flow. The inspector concluded that the brief period that RHR flow less than the minimum of 1000 gallons per minute was not significant.
Nevertheless, the licensee acknowledged the inspectors observations and appropriately changed Procedure IPO-010A to prevent the possibility of isolating RHR flow to the core when raising reactor coolant system tempemture. The inspector concluded that the licensee was responsive to the inspector's concems.
This item is closed.
II. Maintenance M1 Conduct of Maintenance M1.1 Maintenance Observations
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Inspection Scope (62707. 61726)
The inspectors obsented all or portions of the following maintenance and surveillance activities, reviewed the Technical Specification requirements, and verified compliance with station procedures:
Emergency Diesel Fire Pump X-06 Maintenance
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Unit 1 Station Service Water System Surveillance Test Unit 2 Cable Spreading Room Deluge System Surveillance Test b.
Observations and Findinos The inspectors found that maintenance and maintenance surveillance were performed in accordance with station procedures. Work packages were properly maintained and the appropriate approvals were obtained prior to the initiation of work. The inspectors observed maintenance personnel follow appropriate personnel safety practices. Foreign material exclusion boundaries were properly established and materials entering the areas were properly controlled. The inspectors also observed maintenance personnel use appropriate radiological work practices. In general, the inspectors concluded that maintenance was performed in a safe manner.
M2 Maintenance and Material Condition of Facilities and Equipment (71707)
M2.1 General a.
Insoection Scope (71707)
During periodic tours and surveillance observations throughout the facility, the inspectors observed the plant material condition. During daily observations, the inspectors reviewed equipment out-of-service logs, the condition of running equipment, and the licensee's problem identification process.
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Observations and Findinas The material condition of the facility continued to be excellent. Few packing leaks were detected. The small amount of radioactive leakage present was properly controlled by drip containments and hoses properly routed to radioactive drains. The emergency diesel generators were clean and without any notable oilleaks. All observed safety-related equipment had visible oilindication in their sight glasses.
The licensee continued to stress the removal or securing of non-plant equipment -
assure that the equipment would not prevent safety-related equipment operation during an accident or seismic event.
M3 Maintenance Procedures and Documentation
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-7-I M3.1 Cable Spreadina Room Deluae Valve Surveillance Test i
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Inspection Scope (61726)
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l The inspector observe.J portions of Procedure PPT-P2-3119, " Deluge I
Valves 2-HV-4101A (2FP-0410) and 2-HV-4104B (2FP-0412) for Unit 2 Cable
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Spreading Room 134 - Preaction," conducted in accordance with Work Order 3-97-302297-01. This surveillance test is performed once per fuel cycle to demonstrate the operability of the fire suppression system for those rooms. The inspector reviewed the work order, the procedure, and the clearance to determine that the work was authorized, that the prerequisites had been met, and that the test was performed in accordance with the procedures.
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Observation, and Findinas
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The inspector found that the deluge system was tested by knowledgeable i
technicians. The work order and the surveillance test procedure were not well l
integrated. Specifically, Work Order Steps 3 and 7 directed that pancake blinds be
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installed in the flanges down stream of the deluge valves. Procedure PPT-P2-3119 Steps 8.4 and 8.13 also directed the installation of the blinds. However, the work order did not direct the performance of the deluge valve test in accordance with PPT-P2-3119 until Work Order Step 8. As a result, Procedure Step 8.4 was performed prior to Steps 8.2, and 8.3 for Valve 2HV-4104A, and Step 8.13 was performed prior to Steps 8.11, and 8.12 for Valve 2HV-4104B.
The inspector noted a minor discrepancy in the test performance. Step 8.6 opened the fire main supply valve to the deluge valve two turns. When the deluge valve was actuated in Step 8.7, fire main pressure was applied to the space between the deluge valve and the blind flange. Step 8.8 verified that the deluge valve actuated by observing that a water flow alarm actuated at a remote alarm panel. Step 8.9 shut the fire main supply valve opened in Step 8.6. Since the drain valve was open, fire main water would spray out of the drain when the deluge valve was actuated. In an effort to minimize the amount of water sprayed onto the surrounding floor and equipment, technicians shut the supply valve as soon as they heard flow through the deluge valve and saw water spray out of the drain, but before they had a verbal confirmation from the remote alarm panel.
The inspector noted that the work order stated that " quality independent verification" hold points were applicable in accordance with MSM-G0-0203 for the installation of the pancake blinds. The inspector did not observe the licensee performing any quality independent verification during these steps. The licensee concluded that these were probably generic statements included in any work order step that required flange assembly. The inspector concluded that the verification step was not essential to the testing of the valve.
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Conclusions The deluge valves were demonstrated to be operable by knowledgeable technicians.
Some minor discrepancies were noted with the procedures and with the implementation of the tests. These discrepancies did not invalidate the tests and were considered to be of minor significance.
l M8 Miscellaneous Maintenance issues (92902,92700)-
M8.1 (Closed) Violation 50-445/9717-04 and LER 50-445/97007-00: failure to perform stroke time testing of containment isolation valve following actuator maintenance. To
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prevent recurrence, the licensee added additional guidance _concerning the testing
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requirements of containment isolation valves. No similar problems were identified.
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No new issues were revealed by the LER.
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l M8.2 (Closed) LER 50-445/97005-00: five main steam safety valves fail Technical Specification surveillance testing. The safety valves failed the testing on October 4 and 5,1996, but the need to submit an LER pursuant to the requirements of 10 CFR 50.73(a)(2)(vii) was not recognized until August 15,1997, following the review of industry information. The LER was submitted on September 15,1997.
The licensee initiated a ONE form to review and document the untimely reporting of the safety valve failures. The. licensee had previously reported safety valve test'
failures in LERs 50-445/91024-00 and 50-446/94013-00..This failure constitutes a violation of mir'or significance and is not subject to formal enforcement action. There have been no additional main steam safety valve surveillance test failures and no
l other failure to submit an LER in accordance with 10 CFR 50.73 was identified.
Ill. Enaineerina E1
' Conduct of Engineering in general, the inspectors observed good engineering support to plant operation.
System engineers were involved in emergent troubleshooting activities and typically
provided timely and correct engineering support for both operations and l
maintenance E2 Engineering Support of Facilities and Equipment E2.1' Temocrary Modification to Unit 1 Condensate Pumo a.
-Inspection Scope (37551. 62707. 71707)
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-9 The inspector reviewed Temporary Modification 1-98-000005 which provided an alternate cooling source to the lower motor bearing of Condensato Pump 1-02 in order to alleviate a high temperature problem. The inspector walked down the installation and questioned the operations department on the implementation of the modification.
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Observations and Findinas
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The inspector found that the temporary modification package was thorough and
detailed. Specific components, installation, and testing instructions were included in
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the package. The technical screen and impact reviews were appropriate. The installation of the temporary modification was in accordance with the modification package. All components were secured to structural components and did not interfere with permanently installed components. The inspector observed the shift
manager perform a critical inspection of the installation and of the implementing
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procedure. All observed activities involved with this temporary modification were
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performed well.
E8 Miscellaneous Engineering Issues (92903,92700)
E8.1 (Closed) Inspection Followup Item 50-445(446)/9717-02: comparison of control room emergency pressurization unit testing to national standards. This item was left open to review the licensee's justification for the differences between their testing procedures and the national standards to which the licensee had committed.
After the inspector informed the system engineering manager that Plant incident Evaluation ONE-PIR-97-934 did not address all the issues identified in Inspection Report 50-445(446)/9717 concerning control room emergency pressurization unit testing, the licensee initiated ONE Form 97-1243 to address these issues. The inspector reviewed the resolution of these issues.
The inspector found that the licensee thoroughly addressed the control room pressurization unit testing procedure differences. The licensee changed the
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procedure to ensure that the sampling method was consistent with national standards. Additionally, the licensee's formula used to calculate air flow was equivalent to the national standards formula but added an additional factor to increase the accuracy. The inspector concluded that the differences did not render the licensee's procedure invalid.
l E8.2 (Closed) LER 50-445/97003-00: Unit 1 and 2 floor drains missing backwater check valves which were assumed to exist in the environmental analyses for high and moderate energy line breaks. The inspector determined that the licensee's
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corrective actions were adequate.
IV. Plant Support
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-10-R1 Radiological Protection and Chemistry Controls R1.1 General (71707. 71750)
During periodic plant tours, the inspectors noted that radiation workers adhered to radiation work permits and followed appropriate radiation work practices. Radiation workers were observed utilizing radiation protection staff expertise to determine the specific hazards that they could encounter during their assigned activities. The inspectors observed that radiological hazards were properly posted and controlled in a manner that kept dose as low as reasonably achievable.
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S1 Conduct of Security and Safeguards Activities S2.1 Protected and Vital Area Access Control a.
Inspection Scope (71750)
The inspectors evaluated protected and vital area access control throughout the report period by direct observations and discussions with security personnel.
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Observations and Findinas The inspectors frequently toured the plant and discussed compensatory security measures with posted security personnel and ccncluded that compensatory measures were appropriate for the affected protected and vital area boundaries.
Security personnel were knowledgeable of the purpose of their assignments and of the poter.tial threats caused by the degraded barriers. The inspectors concluded that access control was implemented in accordance with station procedures and that security personnel were attentive and knowledgeable of their posted positions.
F1 Control of Fire Protection Activities l
F1.1 Fire impairments. and Control of Fire Hazards
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Inspection Scope (71750)
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The inspector observed the licensee implement their hre protection program during l
routine maintenance activities.
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Observations and Findinas
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-11-The licensee used fire watches appropriately. Impaired doors had fire impairment reviews and were tagged and tracked in accordance with procedures. The inspector questioned control of contaminated mop heads stored in 55-gallon metal drums
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which were locked in the volume control tank rooms of both units. After contacting i
fire protection personnel, the radiation protection technician touring with the inspector determined that the program did require transient combustible permits and corrected
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the deficiency. This failure was of minor significance. Overall, the fire protection j
program was wellimplemented during normal maintenance activities.
F8 Miscellaneous Fire Protection issues (92904)
F8.1 (Closed) Violation 50-445(446)/9715-06: failure to establish compensatory measures prior to impairing a fire protection assembly. The inspector verified that the corrective actions described in the licensee's response letter, dated October 3,1997, were reasonable and complete.
I V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the results of the inspection to members oflicensee management on June 25,1998. The licensee acknowledged the findings presented. No proprietary information was identified.
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ATTACHMENT i
SUPPLEMENTAL INFORMATION j
PARTIAL LIST OF PERSONS CONTACTED bcensee
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Bird, R. D., Jr., Nuclear Planning Manager l
Blevins, M. R., Vice President of Nuclear Operations
Davis, D. L., Nuclear Overview Manager Kelley, J. J., Vice President, Nuclear Engineering and Support Walker, R. D., Regulatory Affairs Manager
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INSPECTION PROCEDURES USED IP 37551:
Onsite Engineering IP 61726:
Surveillance Observations IP 62707:
Maintenance Observations IP 71707:
Plant Operations IP 71750:
Plant Support Activities IP 92700:
Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901:
Followup - Plant Operations l
lP 92902:
Followup - Maintenance IP 92903:
Followup - Engineering IP 92904:
Followup - Plant Support ITEMS CLOSED 50-445(446)/9715-06 VIO Failure to establish compensatory measures prior to impairing a fire protection assembly (Section F8.1).
50-445(446)/9717-02 IFl-Comparison of control room emergency pressurization unit testing to national standards (Section E8.1).
50-445/9717-04 VIO Failure to perform stroke time testing of containment isolation 50-445/97007-00 LER valve following actuator maintenance (Section M8.1).
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-2-50-446/9720-01 VIO Inadequate procedure resulted in both power-operated relief valves opening when pressure was allowed to remain above the low-temperature overpressure protection system limit (Section 08.1).
50-446/9720-02 VIO Conducting core alterations with the personnel airlock doors 50-446/97005-00 LER incapable of being closed (Section 08.2).
50446/9801-01 VIO Failure to document the heat related degradation of the solid state safeguards sequencer on a ONE form was a violation of Technical Specification 6.8.1 (Section 08.4).
50-445/9803-02 IFl Minimum decay heat removal flow during reduced inventory operations (Section 08.5).
50-445/97003-00 LER Floor drains missing backwater check valves (Section E8.2).
50-445/97005-00 LER Five main steam safety valves fail Technical Specification surveillance testing (Section M8.2).
50-446/98002-00 LER Automatic reactor trip subsequent to a turbine trip due to loss of turbine plant cooling water (Section 08.3).
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