IR 05000445/1998008
| ML20198N536 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/30/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20198N520 | List: |
| References | |
| 50-445-98-08, 50-445-98-8, 50-446-98-08, 50-446-98-8, NUDOCS 9901060152 | |
| Download: ML20198N536 (15) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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Docket Nos.:
50-445'
i 50-446 i
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License Nos.:
NPF-87 NPF-89
Report No.:
50-445/98-08 50-446/98-08 i
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Licensee:
TU Electric
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Facility:
Comanche Peak Steam Electric Station, Units 1 and 2 l
' Location:
FM-56 -
Glen Rose, Texas-l
Dates:
October 25 through December 5,1998
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l Inspector (s):
Anthony T. Gody, Jr., Senior Resident inspector j
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Scott C. Schwind, Resident inspector Donald B. Allen, Project Engineer i
Paul C. Gage, Regional Inspector j'-
Approved By:
Joseph I. Tapia, Chief, Project Branch A l.
Division of Reactor Projects
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Supplemental Information p:
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9901060152 981230 PDR ADOCM 05000445
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EXECUTIVE SUMMARY Comanche Peak Steam Electric Station, Units 1 and 2 NRC inspection Report 50-445/98-08; 50-446/98-08 Operations Operators consistently used clear three-way communications. Self-and peer-checking
was evident during routine operations. Operator response to alarms was prompt and I
appropriate (Section 01.1).
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Spent fuel movement from Spent Fuel Pool (SFP) 1 to SFP 2 was conducted in a
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deliberate and well controlled manner. Modifications to the fuel handling crane, procedures, and use of a fuel guide were effective in preventing fuel handling issues previously encountered (Section O1.2).
i Equipment operability, material condition, and housekeeping was acceptable in all
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cases. Systems were in their proper standby condition (Section O2.1).
Field support supervisors were knowledgeable of plant conditions and planned activities.
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Communications were effective. The licensee's practice of periodically assigning the j
field support supervisor watchstation to unit supervisors helped maintain the unit supervisors knowledge of the plant (Section O4.1).
Maintenance Pre-and postjob briefs were effective. Maintenance personnel used good work
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practices such as three-way communications and verbatim procedure adherence. Work planning reflected good coordination and timing of activities to minimize abnormal plant configurations and maximize safety equipment availability (Section M1.1).
Enoineerino A focused review of the licensee's corrective action program revealed that the licensee
l had established the proper threshold for engaging the corrective action process. This was attributable to adequate training, awareness campaigns, immediate feedback from supervision, and effective management (Section E2.1).
Immediate corrective actions for significant adverse conditions were found to be
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appropriate and conservative. Nevertheless, two examples were noted where safety l
systems were declared operable after successfully completing the Technical Specification surveillance procedure following a failure when the immediate corrective actions had not actually corrected the problem (Section E2.1).
Plant Support
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The licensee's emergency response organization effectively implemented the
emergency plan during a planned emergency preparedness drill. Operators appropriately focused on core cooling and containment integrity. Initial classification of
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2-the event and notification of offsite parties were timely. Status boards were used effectively and communications were consistently clear and accurate. Protective action recommendations were appropriate and timely. Measures implemented to reduce the simulated radiation release were resourceful and effective (Section P1.1).
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Report Details Summary of Plant Status Both units operated at approximately 100 percent power for the entire report period.
l. Operations
Conduct of Operations 01.1 General Comments (71707)
Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing plant operations. In general, the conduct of operations was professional and safety-conscious; specific events and noteworthy observations are detailed in the sections below. Through daily observations of control room activities, the inspectors concluded that both units were operated by knowledgeable operators using good self-verification techniques and communications. Operators consistently used three-way communications and self-and peer-checking, and operator responses to alarms were observed to be prompt and appropriate to the circumstances.
The Unit 2 operators used Procedure SOP-104B, " Reactor Makeup and Chemical
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Control System," to perform routine dilutions of the reactor coolant system. The reactor operators demonstrated good knowledge and awareness of plant conditions when j
questioned by the inspectors.
j 01.2 Movement of Soent Fuel a.
Insoection Scope (71707)
The inspectors observed the transfer of spent fuel assemblies from SFP 1 to SFP 2.
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Observations and Findinas The licensee moved 193 spent fuel assemblies from SFP 1 to SFP 2 in order to allow for
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a full core off-load to SFP 1 dring the next outage. SFP 1 rontained low density fuel racks while SFP 2 contained high density racks, making it easier to perform a full core off load to SFP 1. This was the first fuel movement since the fuel handling crane was modified to allow better speed control of the hoist motor it was also the first fuel movement using a fuel guide to facilitate fuel movement in the high density racks since a new fuel assembly was damaged in 1997 while using the same guide. Fuel movements were deliberately cautious and well controlled. The inspectors observed
- good work practices and radiological precautions by operators performing this task.
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Conclusions l
The inspectors observed the transfer of spent fuel assemblies from SFP 1 to SFP 2.
Modifications to the fuel handling crane and training on the use of the fuel guide proved to be effective as evidenced by the lack of events during this evolution. Fuel
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2 movements were deliberately cautious and well controlled. The inspectors observed good work practices and radiological precautions by operators performing this task.
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Operwtional Status of Facilities and Equipment l
02.1 Plant Tours and Enaineered Safetv Features Walkdowns a.
Insoection Scooe (71707)
q l-The inspectors used inspection Procedure 71707 to walk down accessible portions of l
the following engineered safety features systems:
l Unit 2 containment airlock
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Unit 1 turbine-driven auxiliary feedwater system
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_ Units 1 and 2 Class 1 E 6.9kV electrical distribution system i;
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Unit 2 Train B motor-driven auxiliary feedwater pump
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L Unit 2 containment building
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Observations and Findinas j
Overall, equipment operability, material condition, and housekeeping were acceptable in all cases. Systems were found in their proper standby conditions. Plant material
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The inspectors observed good material condition and cleanliness during plant tours and walkdowns. Engineered safety features systems were in proper standby condition. The j
Unit 2 Train B moto -driven auxiliary feedwater pump walkdown was performed following i
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the restoration lineup from a quarterly surveillance test.- The inspectors toured all L
accessible areas of the Unit 2 containment building during a routine entry and observed good housekeeping and no active leaks.
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Conclusions The inspector concluded that these observations demonstrated effective maintenance and configuration management. Several minor discrepancies were brought to the
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licensee's attention and were all corrected satisfactorily.
Operator Knowledge and Performance
' 04.1 Field Suocort Supervisor Performance (71707)
The inspectors conducted a number of extended tours with several field support supervisors. The inspector found the field support supervisors to be knowledgeable of plant conditions and planned activities. Communication between plant equipment operators and the control room was effective. The inspector noted that the licensee l
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routinely assigned qualified unit supervisors to the field support supervisor position and I
found that this practice would help maintain the unit supervisors knowledge of plant conditions.
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II. Maintenance
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M1 Conduct of Maintenance M1.1 Maintenance and Surveillance Observations a.
Insoection Scope (61726. 62707)
The inspectors reviewed and/or observed the conduct of both 9 it surveillance and
maintenance during the report period. The inspectors observed all or portions of the following activities:
l Unit 1, turbine-driven auxiliary feedwater pump containment isolation valve
testing and operability testing Unit 2, containment air-lock inner door seal replacement and postmaintenance a
localleak rate test Service water intake structt.e personnel screen removal, cleaning, and
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installation Unit 2, Train B motor-driven auxiliary feedwater pump
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l Unit 1, Solid State Protection System K631 slave relay actuation test
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Motor Control Center XEB1-2 cleaning and inspection
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Observations and Findinos The inspector observed good prejob briefs and work practices associated with the above work activities. Personnel used good three-pari communications and proper procedure adhererice. Specific observations are as follows:
l Operators were know;edgeable of the procedure and performed well during the Unit 2 Train B motor-driven auxiliary feed pump test. The briefing was thorough and there were no performance issues resulting from the test. In addition, the inspectors l
performed a system walkdown after completion of the test end found it to be properly aligned for standby operation.
The Unit 1 Slave Relay K631 actuation test was performed as a postmaintenance test for work performed on Valve 2-HS-5556 (postaccident sample system containment air
- sample return valve) which had failed to close during Slave Relay K631 relay testing
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2 weeks earlier. Troubleshooting indicated a bad limit switch was preventing the valve
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from operating properly. The switch was replaced and the valve tested as satisfactory.
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Conclusions Maintenance and surveillance activities were performed well during this inspection
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period, consistent with previously documented observations. Good coordination and planning minimized the time spent in abnormal plant cunfigurations and maximized
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safety equipment availability during online maintenance.
M8 Miscellaneous Maintenance issues (92700,92902)
M8.1 -(Closed) Violation 50-445(446)/9810-01: failure to include 13 structures and the reactor rod control and indication function in the scope of their program implementing the requirements of the maintenance rule,10 CFR 50.65," Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Licensee document," Structural Monitoring inspections," Revision 0, failed to identify all the structures that support system functions which were within the scope of the maintenance rule. The licensee implemented Revision 1 of the structural monitoring document to include the service water and circulating water discharge structures, two main transformer pads for each unit, two auxiliary transforrner pads for each unit, the 345 kV and 138 kV switchyard relay houses, and the startup transformer pad. The inspectors reviewed the walkdown inspections and confirmed that the appropriate structures had been added to the scope of the maintenance rule program and that each structure had been properly inspected.
The inspectors reviewed the maintenance effectiveness monitoring program and the third quarter's system health report to determine that the digital rod position indication system had been added to the maintenance rule program scope and that adequate performance measures were established to monitor the effectiveness of maintenance.
The incpectors concluded that the licensee's corrective actions were appropriate to address the issues.
MP.2 (Closed) Violation 50-445(446)/9810-03: failure to establish condition monitoring criteria for systems with zero functional failures for their reliability performance measure. The licensee revised Procedure STA-744 " Maintenance Effectiveness Monitoring Program,"
Revision 1, to incorporate guidance for systems with zero functional failures as their reliability performance measure. The inspectors noted the licensea's maintenance rule program utilized a color-coded system status rating guide to evaluate individual system's health st9us and performanc e. The inspectors reviewed the guidance delineated in Procedw STA-744 and confirmed that, if a system with an established reliability criteria of zero functional failures degraded to a " red" status condition, the system engineer would determine if the affected system should be subjected to increased monitoring and corrective actions as required by Category (a)(1) of the maintenance rule. The inspectors concluded that the licensee's corrective actions were appropriate to address j
the issue.
l M8.3 (Closed) Licensee Event Report (LER) 50-445/98006-00: inadequate Technical Specification surveillance procedure for the hydrogen recombiner system. The I
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50-445(446)/9806. The LER and subsequent corrective actions identified by the l
licensee provided no information which would change the inspectors' original conclusion that the licensee's corrective actions were timely and effective. Therefore, this licensee-identified and corrected violation of Technical Specification 3.6.4.2 is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-445/9808-01).
.ill. Enaineerina E2 Engineering Support of Fac811 ties and Equipment E2.1 Corrective Action Proaram Review a.
Insocction Scoce (37551)
i in NRC Inspection Reports FO-445(446)/98-02 and 50-445(446)/98-03 several violations were cited for failure to take adequate corrective actions. The inspectors were directed by the NRC Region IV office to focus some inspection on the licensee's implementation of corrective actions following the identification of an adverse condition. Using NRC Inspection Procedure 37551, the inspectors reviewed the immediate corrective actions of all licensee-identified significant adverse conditions and both the long-and short-term corrective actions of a sample of less significant adverse conditions identified by the licensee. Below are some of the results of this ongoing review.
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Observations and Findinos The inspectors reviewed all issues that were placed in the licensee's corrective action system on a daily basis. The purpose of this review was to: (1) maintain cognizance of the plant material condition and the adequacy of the implementation of quality related programs, (2) identify significant adverse conditions and appropriately plan inspection resources to ensure public health and safety was being considered, and (3) identify selected issues to review for adequacy of corrective actions.
Corrective Action initiation Threshold The inspectors noted that the licensee had procedurally established the proper threshold for engaging the corrective action process. A review of the type and number of issues placed in the corrective action program combined with the implementation of the core resident inspection program revealed that the licensee had properly trained personnel on when to initiate corrective actions. This success was attributed to adequato training, awareness campaigns, immediate feedback from iicensee supervision, and effective management of the corrective action proces.
I g-6-Immediate Corrective Actions immediate corrective actions were generally found by the inspectors to be appropriate and conservative. However, the inspectors noted two examples where systems were declared operable after successfully completing the 'l echnical Specification surveillance procedure following the identification of an adverse condition when immediate corrective actions had not actually fixed the problem. Each example where this occurred was technically complex and the problem involved incomplete communications regarding tne certainty of cotrective actions between the personnel conducting the troubleshooting and the operations personnel responsible for determining equipmut operability.
The first example involved several inadequate repairs to th9 Train A control room emergency filtration / pressurization system following failures in July and August 1998.
The Train A control room emergency filtration / pressurization system problem was ultimately identified and repaired on September 4, more than 50 days beyond the 7-day Technical Specification allowed outage time. LER 50-445(446)/98008-00 was submitted to the NRC on September 18. The regulatory aspects of this issue are still under review by NRC management and the results of that review will be documented in the closure of LER 50-445(446)/98008-00.
The second example involved a Unit 1 rod control system failure which occurred on November 30, during a monthly Technical Specification surveillance procedure. When the rod control cabinet was opened for troubleshooting, the technicians and system engineer heard a relay click and the symptoms disappeared. Believ!ng the problem was a sticking mercury wetted relay which self-corrected, the rod control selector switch was cycled several times and proper system response was verified. After verifying proper rod control system operation and restoring rods to their correct position, the rod control system Technical Specification surveillance test was satisfactorily completed. The rod control system was then declared operable on December 1. After reviewing the licensee's immediate corrective actions, the inspectors questioned the thoroughness of troubleshooting and adequacy of the repair. At the same time the inspectors were discussing their concerns with the shift operations manager, the system engineer identified that the symptoms and problem resolution didn't match and immediately initiated further troubleshooting that same day. The additional troubleshooting revealed loose connections in the rod control multiplexing circuit which could have caused the symptoms. These loose connections were tightened and rod control system operability was reverified. The licensee inspected all the rod control cabinets for loose connections and found other examples of loose connections, none of which could have affected actual rod control. The inspector concluded that the licensee effectively corrected the Unit 1 rod control system problems within the 48-hour Technical Specification allowed outage time and that no violation of NRC requirements occurred.
Lona-Term Corrective Actions Many of the long-term corrective actions for the issues selected by the inspectors were still being implemented by the licensee and therefore are still under review by the inspectors. Overall conclusions on the effectiveness of long-term corrective actions will be made following this review.
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d-7-Control of Oraanic Matter in the Station Service Water System (ONE Forms 98-1135.
98-1234. and 98-1276)
i ONE Forms 98-1135 and 98-1276 were written to document the repetitive clogging of service water strainers on safety-related equipment with moss and algae while ONE j
Form 98-1234 documented problems controlling chlorination /bromination of the service water system. These ONE forms were closed before actually fixing the problem, but the j
is.sces were captured in the third quarter system status review for service water along i
with proposed modifications to correct them. The inspector concluded that adequate
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management attention to corrective actions will be provided through the system status review process, c.
Conclusions The licensee demonstrated that they had established the proper threshold for initiating corrective actions for adverse conditions. Immediate corrective actions for significant adverse conditions were typically timely and appropriate. Two examples where systems were declared operable before actually fixing the problem were identified and may reflect isolated examples where communications between maintenance, engineering, q
and operations needed improvement.
E8 Miscellaneous Engineering issues (92700,92903)
E8.1 (Closed) Inspection Followup item (IFI) 50-445(446)/9612-04: maintenance planners indicated a lack of confidence in the master equipment list because of past problems.
In NRC Inspection Report 50-445(446)/96-12, the inspectors documented that planners had specified the wrong setpoint for a new component cooling water system relief valve which was to be installed in the plant. This error was identified by the mechanics before the incorrect relief valve was installed, and the proper relief valve was installed in the plant. After interviewing several maintenance planners who demonstrated a lack of confidence in the master equipment list, the inspector decided to follow planned master equipment list improvements. Over 2 years, these improvements included software changes which would allow better tracking of equipment changes, additional personnel to review the accuracy of the data contained in the master equipment list, and the add; tion of several different types of document cross-references. The inspector monitored the rate at which deficiencies were identified over the past 2 years, reviewed a number of corrective action documents, and concluded that the licensee adequately maintained the master equipment list. Therefore, this item is closed.
E8.2 (Closed) LER 50-446/970.1-00: diaphragm failures. In response to a diaphragm failure at th9 Bruce Nuclear Station in Canada, the vendor, Fisher Controls Corporation, changed production of Type 657, Size 80, molded nitrile rubber diaphragms by
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increasing the thickness. Following several diaphragm failures, the vendor conducted tests and found that the newer / thicker diaphragms tended to delaminate and pull out of l
the diaphragm casing during normal use. The licensee attributed the diaphragm failures j
to inadequate design. All newer / thicker diaphragms were immediately replaced with the
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8-older / thinner design by the licensee. Seven contributing factors were also identified by the licensee. These included diaphragm alignment, case warpage, applied air pressur6, case finish, torque requirements, storage, and aging. The storage and aging aspects were reviewed by the ms' ectors in NRC Inspection Report 50-445(446)/98-05. The p
corrective actions associated with the remaining centributing causes were reviewed by the inspectors and were found to address the specific issues identified. Therefore, this item is closed. The LER also satisfied the 10 CFR Part 21 reporting requirements associated with the diaphragm design problem.
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IV. Plant Support R1 Radiological Protection and Chemistry Controls R1.1 General Comments '71750j Radiological protection personnel were observed to maintain the appropriate controls over high radiation areas, and plant areas toured were properly posted. Maintenance and surveillance activities observed within radiologically controlled areas were found to be conducted in accordance with the appropriate radiation worker practices. The inspectors verified that effluent and environmental radiation monitors and meteorological tower indications either remained operable or that appropriate compensatory actions were taken for those which were out of service. The inspectors routinely reviewed secondary water activity analyses and primary plant chemistry analyses and verified that these parameteia remained within Technical Specifications and procedural limits or that appropriate actions were being taken for those which did not.
P1 Conduct of Emergency Planning Activities P1.1 1998 Green Team Fall Trainina Drill a.
Inspection Scope (71750)
The inspectors participated in the licensee's drill conducted on November 10,1998. The inspectors also observed the licensee's performance in the control room simulator and the technical support center (TSC), includir.g the postdri!! facility critiques.
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Observati.oas and Findinas This drill was intended to exercise the green emergency response team's ability to respond to an event at the site leading to a general emergency. All emergency response facilities were activated during the driil. The inspectors simulated their event response, conducted observations in the control room simulator and TSC, and conducted a walkdown of the relocating process for the emergency operations facility to
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Simulator
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All control room responses to the drill were carried out in the control room simulator.
Operators effectively implemented the emergency operating procedures and gave appropriate consideration to core cooling and containment integrity. Initial classification and notifications of the event were made by the control room staff in a timely manner.
The inspectors noted that the shift manager was particularly effective in utilizing his staff during the scenario. A facility critique was held immediately following the drill which was thorough and self-criticcl. No weaknesses were identified but several areas were noted for improvement.
TSC Status boards were used effectively to communicate the current status of events. The staffing board was maintained up-to-date as individuals arrived and left the TSC. Major activities and priorities were displayed on a status board which was routinely updated.
Frequent briefings were conducted and announcements were made to the TSC staff as significant changes in plant status occurred. Protective action recommendations were appropriate and timely and measures implemented to reduce the simulated radiation release were resourceful and effective. In general, gooo communications were observed throughout the drill. Tne post-drill critique was effective and self-critical, with all p"sonnel given an opportunity to present observations.
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Conclusions The licensee's emergency response organization effectively implemented the emergency plan during a planned emergency preparedness drill. Operators appropriately focused on core cooling and containment integrity. Initial classification of the event and notification of offsite parties were timely. Status boards were used effectively and communications were consistently clear and accurate. Protective action recommendations were appropriate and timely. Measures implemented to reduce the simulated radiation release were resourceful and effective.
S1 Conduct of Security and Safeguards Activities S1.1 General Comments (71750)
Inspection of the licensee's security program during the inspection period included a e
verification of the integrity of selected protected area barriers, maintenance of isolation zones, and protected area personnel access measures. The inspectors found the security personnel to be knowledgeable of their assigned stations. Security officers touring the plant were attentive and often identified issues to plant management.
Material condition of security equipment continued to be excellen.
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F8 Miscellaneous Fire Protection issues (92904)
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I F8.1 (Closed) Violation 50-445/9803-07: failure to correct the problem of the fire doors not
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shutting fully and failure to identify or correct the impaired tornado doors. The inspector verified the corrective actions described in the licensee's response letter, TXX-98176, to be reasonable and complete. No similar problems were noted.
V. Manaaement Meetinas X1 Exit Meeting Summary t
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The inspector presented the results of the inspection to members of licensee management on December 10,1998. The licensee acknowledged the findings presented. No proprietary information was identified.
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l i-ATTACHMENT SUPPLEMENTAL INFORMATION t
PARTIAL LIST OF PERSONS CONTACTED Licensee C. L. Terry, Senior Vice President & Principal Nuclear Officer D. R. Moore, Operations Manager
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T. A. Hope, Regulatory Compliance Manager -
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' W. G. Guldemond, Shift Operations Manager
~ J. M. Ayres, Plant Support Overview Manager R. D. Bird, Jr., Plant Support Manager 1NSPECTION PROCEDURES USED
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IP 37551 Onsite Engineering j
IP 61726 Surveillance Observations IP 62707 Maintenance Observations IP 7170'7 Plant Operations
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IP 71750 Plant Support Activities IP 92700 Onsite Followup of Written Reports of Non-routine Events at Power Reactor Facilities IP 92902 Followup - Maintenance
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IP 92903 Followup - Engineering IP 92904 Followup - Plant Support ITEMS OPENED. CLOSED. AND DISCUSSED Opened 50-445/9808-01 NCV Inadequate Technical Specification surveillance procedure for the hydrogen recombiner system. (Section M8.3)
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-2-Closed 50-445(446)9810-01 VIO Failure to include 13 structures and the reactor rod control and indication function in the scope of their program implementing the requirements of the maintenance rule, 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."
(Section M8.1)
50-445(446)9810-03 VIO Failure to establish condition monitoring criteria for systems with zero functional failures for their reliability performance measure. (Section M8.2)
50-445/98006-00 LER inadequate Technical Specification surveillance procedure for the hydrogen recombiner system. (Section M8.3)
50-445/9808-Oi NCV Inadequate Technical Specification surveillance procedure for the hydrogen recombiner system. (Section M8.3)
50-445(446)9612-04 IFl Maintenance planners indicated a lack of confidence in the master equipment list because of past problems.
(Section E8.1)
50-446/9701-00 LER Diaphragm failures. (Section E8.2)
50-445/9803-07 VIO Failure to correct the problem of the fire doors not shutting fully and failure to identify or correct the impaired tornado doors. (Section F3.1)
Discussed 50-445(446)/98008-00 LER Failure to repair the Train A control room emergency filtration / pressurization system. (Section E2.1)
LIST OF ACRONYMS USED IFl inspection followup item
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SFP spent fuel pool LER license event report NRC Nuclear Regulatory Commission TSC technical support center l
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