IR 05000445/1999008
| ML20207H388 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/09/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20207H385 | List: |
| References | |
| 50-445-99-08, 50-445-99-8, 50-446-99-08, 50-446-99-8, NUDOCS 9906160197 | |
| Download: ML20207H388 (29) | |
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.U.S. NUCLEAR REGULATORY COMMISSION REGION IV l Docket Nos.: -50-445;50-446 i License Nos.: NPF-87; NPF-89 Report No.: 50-445/99-08; 50-446/99-08 Licensee: TU Electric -
Facility: Comanche Peak Steam Electric Station, Units 1 and 2 Location: FM-56:
Glen Rose, Texas Dates: . May 3-11,1999 Inspector (s): Thomas F. Stetka, Senior' Reactor Engineer, Operations Branch' {
Anthony T. Gody, Senior Resident inspector, Project Branch A j
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Approved By: John L. Pellet, Chief, Operations Branch Division of Reactor Safety 'i
- ATTACHMENT: Supplemental Information
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l 9906160197 990609 PDR ADOCK 05000445 >
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2-EXECUTIVE SUMMARY Comanche Peak Steam Electric Station, Units 1 and 2
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NRC inspection Report No. 50-445/99-08; 50-446/99-08 l p
l .The inspectors performed a routine core inspection of the corrective action program
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implementation at the Comanche Peak Steam Electric Station. An in-office inspection was conducted from April 27-30,1999, which was followed by an on-site inspection that was conducted from May 3-11,1999. The inspection was conducted in accordance with the
. guidance provided by NRC Inspection Procedure 40500,-
The inspectors considered the corrective action program to be effective at identifying, resolving, and preventing issues that degraded the quality of plant operations. It was noted that site personnel and management clearly understood the importance of this program. The inspedors '
j found that some corrective action program procedures either lacked guidance or had l inappropriate guidance. Despite these program weaknesses, the inspectors found that the j licensee conservatively addressed issues.
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l Operations
'* Overall, the corrective action program was effectively identifying, resoI'ving, and preventing problems that could degrade the quality of plant operations (Section 07.1b).
- While the threshold for reporting problems was low, the guidance provided in the corrective action program controlling procedures with respect to identifying adverse issues for enhanced review was inconsistent with the actual process. Overall, the ,
licensee's conservative practices toward problem identification and review were effective
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(Section O7.1b.1).
- One minor maintenance activity deviated from the guidance in the controlling'
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maintenance procedure in that the activity was conducted as a minor maintenance
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activity even though it required entry into a technical specification limiting condition for operation. This failure to follow procedures was considered to be a noncited violation of ,
10 CFR Part 50, Appendix B, Criterion V (Section 07.1b.1). !
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- Corrective action program priorities were appropriate (Section 07.1b.2).
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- Self assessments were thorough and intrusive, and the subsequent corrective actions ;
l identified by the audits were either already corrected or properly tracked for resolution '
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(Section 07.1b.3).
- Program trending methods were appropriate for determining trends and identifying adverse trends. Trends for open corrective actions and number of SmartForms written per month were generally steady with slight increases due to scheduled plant outages (Sechn 07.1b.4).
- Plant personnel had a good understanding of the corrective action program. While all personnel were cognizant of the reporting requirements, some personnel (e.g., ,
I contractor personnel), due to their limited knowledge of the process, used a team
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l- -3-approach for reporting deviations through their supervision. The implementation of the manual SmartForm process allowed personnel to report deviations without use of the computerized system (Section 07.1b.5).
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The process for detecting and correcting repeat problems was effective. However, l repeat problems with electrical breaker failures were not properly initially placed into the L corrective action program, although none resulted in a cited violation because the l licensee had subsequently entered the issues into the program (Section 07.1b.6).
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. Noncited violations were properly entered into the corrective action program and were
! being resolved in a timely and technically adequate manner (Section 07.1b7)
Maintenance I '- The corrective actions, goal setting and monitoring of structures, systems, and
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_ components included in the maintenance rule were appropriate (Section M7).
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Failures of 6.9 kV and 480V circuit breakers were not promptly identified and corrected and were the first and second examples of a noncited viola !on of 10 CFR Part 50, Appendix B, Criterion XVI. Subsequent corrective actions were prioritized properly (Section E7.1).
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Although a large number of work activities were identified for loose or hot fuse clips, an effective thermography surveillance testing program was identifying and correcting fuse L problems before failures occurred. Proper plant configuration was maintained by i effectively controlling failed fuse replacement. However, tracking repeated electrical fuse failures was reduced by the licensee's policy on replacement (Section E7.2).'
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Control of vendor information and industry operating experience was appropriate. Shift management operability and reportability reviews were conducted in a timely manner.
j' Immediate and long-term corrective actions were generally acceptable. A l ' licensee-identified failure to promptly identify and correct a motor-operated valve l
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problem identified by industry update information was a third example of a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI (Section E7.3).
Plant Sucoort
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The radiological department had established an appropriate threshold for initiating ONE .
forms and SmartForms. Corrective actions related to both ONE forms and SmartForms !
were found to be adequate and complete (Section R7). i
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The emergency preparedness program was properly implementing the corrective action program (Section P7).
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Report Details
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Summary of Plant Status Both units of the Comanche Peak Steam Electric Station operated at approximately full power during the entire inspection perio I 1. Operations '
07 Quality Assurance in Operations - 1 l
07.1 Corrective Action Proaram Insoection Scooe (40500)
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This inspection consisted of a review of the licensee's programs that were intended to identify and correct problems discovered at the facility. The review focused on the following seven specific areas: (1) the identification and reporting threshold for adverse conditions, (2) the setting of problem resolution priorities that were commensurate with operability and safety determinations, (3) program monitoring used by the licensee to assure continued program effectiveness, (4) program measurement or trending of adverse conditions, (5) the understanding of the program by alllevels of station ,
personnel, (6) the ability to identify and resolve repeat problems, and (7) resolution of !
noncited violation In addition to these seven areas, the corrective action program's ability to identify and resolve issues was determined by selecting four systems for a focused review. These four systems consisted of the ac distribution 6.9 kV, ac distribution 480V, ac distribution 480V motor control centers, and ac distribution inverters. These systems were selected i based upon their system risk importance ranking, a review of the licensee documented system status, and past NRC review activity. Details on this focused review are documented in Section E7 of this repor Observations and Findinas The licensee's corrective action program was primarily implemented by two Procedures, STA-421, " Operations Notification and Evaluation (ONE) Forms / Initiation and Processing of SmartForms," and STA-422, " Processing of ONE Forms / Disposition of SmartForms identifying Potential Adverse Conditions." The licensee was replacing the manually implemented and computer tracked ONE form process with the computer implemented and tracked SmartForm process. A manual SmartForm was included in the new process to assure that personnel that did not have access to a ceinputer or that l
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-S-were lacking in computer skills still had a method to report problems and to provide a backup system if a computer problem was to occur. Since the licensee was in process of phasing out the ONE form process and replacing the process with SmartForms, each of these procedures addressed ONE forms as phase one and the SmartForms as phase two. The licensee planned on having the ONE form process phased out by June 15, 199 The inspectors noted that ONE forms and SmartForms were reviewed by a team consisting of the corrective action program owner (CAPO) and the central organization for reliable plant operation (CORPS). The CAPO/ CORPS review committee typically included a diverse combination of station personnel capable of adequately implementing the corrective action progra (1) Threshold of Reporting The inspectors found that licensee management established the proper threshcid for identification of adverse conditions. In addition, the inspectors found that the philosophy for the new SmartForm process was to have no reporting threshold. Essentially any person can implement a ONE form or SmartForm when a problem is identified. While this threshold was found to be acceptable, the inspectors noted that guidance provided in Procedures STA-421 and STA-422 was not consistent with the corrective action process actually being implemented. The following were some specific examples of these inconsistencie *
Section 6.5.1 of Procedure STA-421 only required the CAPO and the CORPS to review SmartForms that have been coded as "yes" for adverse conditions or for " unsure" conditions. This meant that those SmartForms that were coded as "no" for adverse conditions did not receive the benefit of these team reviews. However, as the result of interviews with plant personnel, the inspectors determined that all SmartForms were reviewed by the CAPO/ CORPS teams. The inspectors considered the review of all SmartForms to be a conservative approach toward problem identification and resolutio *
Section 6.7 of Procedure STA-421 provided the method for changing the SmartForm adverse condition category. It provided the guidance for changing a SmartForm which was coded as "no" for an adverse condition to a "yes" or " unsure" condition. However, the inspectors noted that this guidance was not extended to a condition; whereas, a "yes" or " unsure" was changed to a "no" for the adverse condition. While the inspectors considered the change from a "yes" or " unsure" to a "no" to be less conservative, the procedure did not provide guidance even though such changes were made. The inspectors review of the changes that had been made did not identify any problems with these change =
Attachment 8.A, pages 3 of 4 and 4 of4, of Procedure STA-421 provided guidance for conditions that were not considered to be adverse. The
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-6-inspectors considered this guidance to be lacking in some areas. For g example, foreign material exclusion, routine maintenance (minor j
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maintenance), instrument recalibration and adjustment, and work request tag control were not considered to be adverse. The inspectors determined that this guidance could create the potential that a number of problems would not be considered as an adverse condition and receive the expanded review afforded adverse condition SmartForms. The inspectors reviewed 40 SmartForms that were not considered to be ! '
adverse and interviewed five personnel to determine if this procedure guidance caused problems to be inappropriately classified as not an adverse condition. Based on this review, the inspectors determined that even with this guidance, issues such as foreign material exclusion, were being classified as adverse conditions. The inspectors determined that j the licensee was taking a conservative approach toward classifying l adverse conditions in spite of the procedure guidance. However, this i review also determined that the licensee did misclassify the following I minor maintenance activit Since Procedure STA-421 listed a minor maintenance activity as an issue I that did not require a SmartForm, the inspectors selected 31 out of 431 minor maintenance activities for a detailed review. In addition, the
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i inspectors reviewed Procedure STA-606, " Control of Maintenance and Work Activities," to determine the criteria used by the licensee for concluding whether a maintenance activity was minor maintenance. As the result of this review, the inspectors found one work order 9 (4-98-117140-00 for the hydrogen analyzer) where the activity caused the ]
entry into a limiting condition for operation. Procedure STA-606 !
prohibited any maintenance activity that involved the entry into a technical !
specification limiting condition for operation to be performed as minor j maintenance. The inspectors reviewed this maintenance activity and noted that the performed maintenance activity did not compromise facility ;
operation or safety. This failure to follow Procedure STA-606 was a violation of 10 CFR Part 50, Appendix B, Criterion V, " Instructions, i Procedures, and Drawings," (50-445; 446/9908-01). Because the NRC '
encourages self-identification and correction of conditions adverse to quality and the licensee entered the issue into their corrective action program, this violation is being treated as a noncited violation consistent !
with Appendix C of the NRC Enforcement Policy. This violation was j entered into the licensee's corrective action prograrn as J SmartForm SMF-1999-126 I I
The inspectors also noted that the licensee used a performance enhancement j review committee to review problems that involve potentially significant i personnel errors. The inspectors considered the use of this committee to be an effective tool because the intent of these reviews was to insure that personnel error problems are resolved within 5 working days, thus, minimizing the potential for a repeated human error problem. However, the inspectors noted that Section 6.4 of Procedure STA-421 only requires the performance enhancement review committee to consider human performance errors if the error is
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-7-considered to be significant. Nonetheless, the inspectors' review indicated that, in general, this method of controlling personnel error events was effective as evidenced by the marked reduction in the trend of human performance errors since 199 (2) Priority of Resolution The licensee's priority setting for SmartForms was delineated in Procedures STA-421 and STA-422. These procedures provided four levels of priorities from Priority 1 (Critical) through Priority 4 (Routine /Nonurgent).
Problems that affected plant safety or operation were generally classified as Priority 1 and Priority 2, respectively. The initial setting of a SmartForm priority was usually by the shift managers during their review of the proposed SmartForm. The shift manager's decision was further reviewed during a subsequent 8:30 a.m. manager's meeting and the CAPO/ CORPS team meeting Out of approximately 50 ONE forms and SmartForms reviewed, the inspectors found the shift managers' reviews to be thorough and timely. When needed, operations personnel implemented the appropriate compensatory measures and entered the proper technical specification limiting condition for operation. Any required immediate actions were conservative, and no improper operability or reportability determinations were identified by the inspectors. The licensee's activity determinations, assignment, prioritization, operability and reportability determinations, generic implications, and estimated completion dates were found to be appropriat '
(3) Effectiveness of Program The inspectors reviewed the following selected audits to ascertain the licensee's effectiveness at self-identification and correction of problems. Specifically, the inspectors determined if the licensee's oversight processes adequately monitored the implementation of the corrective action program and if the quality assurance processes were intrusiv NOE-EVAL-98-000071-00-00. "SmartForm Pilot" This nuclear overview evaluation report focused on the newly implemented SmartForm pilot process, communication tools, the conversion of existing ONE forms, the ONE form and SmartForm process and procedures, and personnel perception of the new process and training. The SmartForm pilot was implemented in October 1998 to test the effectiveness of the new SmartForm corrective action program. SmartForm was a computer-based corrective action program that eliminated a significant amount of paperwork, provided better tools for tracking and trending adverse conditions, and facilitated increased management oversight of the corrective action program while placing more rigorous controls on the resolution of adverse conditions. The Nuclear Overview Department team identified six strengths, two issues warranting a SmartForm,
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8-two unresolved items, and nine improvement items. The inspectors determined that most of the Nuclear Overview Department team findings were completed and that the remainder was being appropriately tracked for completio One unre. solved item identified by this audit involved a failure of the SmartForm process to address the conditional release program. The inspectors noted that this item had been closed based on the fact that the necessary changes to the SmartForm process were planned. The conditional release program allowed installation or use of a system, structure, or component prior to approval of the nonconformance disposition. Final Safety Analysis Report, Section 17.2.15, item 5, stated, in part," Conditional releases allow operation of the item pending disposition of the nonconformance provided credit is not taken for TS operability -
of the item." The Nuclear Overview Department unresolved item stated,in part,
" Conditional releases are required to allow items to be installed until resolution of j a nonconformance has been resolved that may affect technical specification i operability of an item or equipment." Section 6.3.8.3 of Procedure STA-422 {
directed the shift manager to review the conditional release for technical j specification operability and issue a technical specification limiting condition for !
operations action requirement as necessary. The inspectors noted that the guidance contained within Procedure STA-422 for the shift manager could be misinterpreted such that the installation of a nonconforming item on a system's operability was only based on preliminary engineering judgment. As the result of this concern, the inspectors reviewed all conditional releases issued since January 1996 and interviewed shift management. Interviews with shift management indicated that tight controls were placed on the use of a conditional release. The inspectors also found that the conditional releases that were reviewed, which could affect operability, were all resolved prior to entering the ,
technical specification operating mode for which they were required to be ;
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operable. Therefore, no deviation of licensee commitments documented in the Final Safety Analysis Report was identified. The licensee indicated that it would review its Final Safety Analysis Report commitments and modify Procedure STA-422 as neede A second unresolved item was identified after a review of training documentation and interviews of station personnel revealed a need for training station personnel on the initiation of a SmartForm. This item was closed after conducting a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> training class for all station personnel and some contractors. During interviews, the inspectors found that some station personnel were still not comfortable with the SmartForm process, most craft workers had not yet initiated a SmartForm, and most craft workers relied heavily on teaming with peers and supervision to raise issues. Further information regarding these interviews is discussed in Section 07.2b.5 of this repor NOE-EVAL-98-000074-00-00. " Corrective Action" This nuclear overview evaluation was conducted by the licensee to evaluate their corrective action program. The evaluation reviewed the identification, resolution, and effectiveness of the ONE form and SmartForm process. The inspectors reviewed the evaluation report and re:,ulting corrective actions to ascertain the
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. intrusiveness and impact the Nuclear Overview Department evaluation had on the ,
corrective action progra In the identification area, the Nuclear Overview Department team found that the reportability, operability, and immediate actions associated with corrective actions were conducted in a timely manner and that the shift managers' review was thorough. The inspectors made similar observations during the inspection. Of particular note was the Nuclear Ovewiew Department finding that their survey of 90 people revealed that there was no hesitance to identify adverse conditions or initiate a SmartForm. The Nuclear Overview Department survey also indicated that the electronic SmartForm process was easy to use and would become easier as more users became experience In the resolution area, the Nuclear Overview Department evaluation found some minor administrative errors such as wrong cause codes and some minor examples of a "less than rigorous" disposition of the issue. The inspectors noted that because the sample size was small (37 SmartForms), any conclusions the Nuclear Overview Department team could draw on the overall program implementation would be limite The licensee initiated SmartForm SMF-199919 to address this finding and initiated an additional Nuclear Ovewiew Department evaluation followup item (NOE-EVAL-98-000074). This followup evaluation reviewed over 700 completed activities and found minor problems in over 200. These problems were similar to those identified in the original evaluation and involved cause codes not being referenced on resolutions. generic implications not being identified or addressed, and some instances where corrective actions were not implemented when additional problems were identified during review of the original problem. The inspectors determined that these findings did not represent declining performance in the corrective action program. The inspectors considered these findings to be representative of an improved corrective action program that made the identification of these types of issues easie Assessment of the TU Electric Procurement Proaram at Comanche Peak Steam Electric Station The licensee requested an audit by the Electrical Power Research Institute to evaluate the adequacy and cost effectiveness of their procurement progra While this assessment focused on the commercial grade dedication process, it also evaluated the licensee's procurement program against the current industry practice This assessment was performed November 9-13,1998, and the report was issued on February 28,1999. While the audit team found the licensee's program to be sound, they did identify some minor discrepancies. The inspectors reviewed three of these d;screpancies to determine if the discrepancies were entered into the corrective action program, and if their resolution was timely. As the result of this review, the inspectors found that SmartForms were written for all of these findings and that they were being tracked for resolutio r
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-10-l (4) Program Measurement The licensee's Nuclear Overview Department trended a number of criteria to provide a measure of the corrective action program. Some aspects that were measured by the licensee that were applicable to the corrective action program were the assessment of overall plant performance, the open corrective actions, and the number of SmartForms written per month. The licensee's trending processes were delineated in Procedure NOA 2.11," Trend System." The objective of this system was to identify areas for additional management attention and to monitor system and equipment performanc The inspectors found that a trend of ONE form and SmartForm activities were tracked by a weekly " bubble-up" report that the performance analysis supervisor developed and distributed to the trending staff. This report contained approximately 238 items that were trended over a rolling 18-month time perio .
Based on the supervisor's review of this report, the supervisor selected items that I showed significant trend changes for further staff review. The staff then determined why the significant trend change was occurring. Depending upon this result, the respective plant management personnel were notified of the trending change and a SmartForm was written if the trend char;;a was considerec to be significant. Furthermore, depending upon the nature of the trend, the ,
performance analysis staff would enter the trend into the corrective action l program via the SmartForm for further review and action. The inspectors considered this process effective in providing an early notification to plant management of significant trend change The inspectors also reviewed the " Nuclear Overview Department Assessment of Overall Plant Performance for March 1999." The intent of this monthly report was to provide feedback to plant management regarding emergent trends and patterns in performance and Nuclear Overview Department assessment of the overall plant performance. While the report provided information on diverse plant areas, it focused on personnel errors (human performance) since that quality was considered by the licensee to be the most indicative trend to monito The inspectors reviewed the licensee's trending methods and found them to be appropriate for determining trends and identifying adverse trends. The inspectors considered the use of the weekly Nuclear Overview Department " bubble up" report to be an effective method to assure that changes to trended activities are quickly identified. The inspectors reviewed several trends such as open corrective actions, which showed a slight increase due to the recent outage; number of SmartForms written per month, which had a steady to a slight increase again, due to outages; and the plant performance reports, which showed a measurable declining trend in personnel errors since 1993. The inspectors considered the licensee's trending program to be appropriate and the observed trends to be acceptabl ..
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(5) Program Understanding l The inspectors interviewed 20 site personnel to determine their knowledge of the I
corrective action program and specifically the new SmartForm process. The inspectors noted that management, supervision, and engineers were fami!iar with the SmartForm process. The inspectors also found that all of the craft workers interviewed had not yet initiated a SmartForm but reliad heavily on terimirs with pee s and supervision to raise issues. In every case, either an engineer or a l supervisor initiated the SmartForm. In two cases, the craft worker was not aware l that a manual SmartForm process existed. The inspectors noted that both
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supervisors and engineers who had actually initiated a SmartForm found the electronic SmartForm initiation process easy to use.
l The inspectors also found that contract employees knowledge of the corrective action process was limited. All contract employees interviewed knew to contact l their supervisor if adverse conditions were found. The inspectors determined that l more training for contract employees could be helpful, particularly on the use of j the manual SmartFor (6) Repeat Problems l
! The inspectors noted that repeat problems were generally being identified as long as they were placed in the corrective action program. However, the licensee conducted an independent review of work orders and it identified repeat problems with the 6.9 kV and 480V circuit breakers, which had not been placed in the l corrective action process (discussed in Section E7.1 of this report). The l inspectors also noted that one of the aspects reviewed by the program analysis staff in their weekly " bubble up" report (discussed in Section O7.1b.4 of this report) was to detect repeated problem The inspectors reviewed a sampling of 17 issues that were identified by the performance analysis staff as potential repeated personnel errors. In each of l these issues, a ONE form or SmartForm was written to track and trend the errors l and necessary corrective actions were already in-process or completed. As stated previously in this inspection report, the personnel error trend had a notable decline.
l An example of the licensee's hand!ing of repeat problems involved engineered safeguard dieselloading sequencers. During a review of the maintenance rule activities, the inspectors noted a repeated failure of power supplies for the j engineered safeguard dieselloading sequencers. During a review of these power supply failures, the inspectors noted that the existing power supplies were no longer available and that the licensee had to identify replacement supplies and refurbish existing supplies for which parts were still available. In addition, the inspectors were informed that the power supply replacement could only be performed during a plant outage. The inspectors found that the power supplies were replaced during the recent Unit 2 refueling outage and were on the master schedule for the upcoming Unit 1 refueling outage. In addition, the inspectors i
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-12-noted that the power supply vendor recommended the replacement of the electrolytic capacitors every 9 years. The inspectors found that the licensee was replacing these capacitors every 6 years for conservatism even though the capacitor failures were not the cause for the repeated power supply failure l Based upon these obsentations, the inspectors determined that the licensee's process for detecting and correcting repeat problems was effectiv (7) Notice of Violation Followup The licensee had a total of 16 noncited violations from previous NRC inspections that covered the period of January 1998 through April 1999. The inspectors reviewed five of these noncited violations, that were not previously reviewed by ,
the NRC, to determine if the violations were entered into the corrective action l program and if they were resolved or being resolved in a timely manne Noncited Violation 50-445;-446/9809-05 was placed into the corrective action program via ONE Form 981114. The inspectors noted that while the corrective ;
actions were effective, they were not timely. This lack of timeliness was i previously documented in NRC Inspection Report 50-445;-446/98-09 as a violation. The inspector's review of the uncompleted corrective actions indicated I that the licensee wrote a new SmartForm SMF-1999-665 to track and complete the actions on this violation consistent with the demise of the ONE form proces The inspectors determined that the licensee's progress for correcting this violation was acceptabl Noncited Violadons 50-445; 446/9810-02 (addressed by ONE Form 97-200),
9810-04 (addressed by ONE form 97-1138),9811-01 (addressed by ONE Form 98-177), and 9905-01 (addressed by SmartForm SMF-1999-371) were all found to be entered into the corrective action program and resolved in a timely and technically adequate manne c. Conclusionc Overall, the corrective action program was effective for the identification, resolution, and prevention of problems that could degrade the quality of plant operation While the threshold for reporting problems was low, the guidance provided in the corrective action program controlling procedures was found to be inconsistent with the actual process. In spite of the procedure guidance that was inconsistent wiih actual practice, the licensee's conservative actual practices toward problem identification and review were effectiv One minor maintenance activity deviated from the guidance in the controlling
, maintenance procedure in that the activity was conducted as a minor maintenance l activity even though it did require entry into a technical specification limiting condition for operation. This failure to follow procedures was considered to be a noncited violation.
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e-13-The setting of priorities for problem determinations, problem assignment, operability and ;
reportability determinations, and estimated completion dates were appropriat '
The corrective action program was effective at identifying problems through the use of self assessment audits. The audits were found to be intrusive, and the subsequent corrective actions identified by the audits were either already corrected or were properly tracked for resolution, J i
Program trending methods were appropriate for determining trends and identifying l adverse trends. Trends for open corrective actions and number of SmartForms written
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per month were generally steady with slight increases due to scheduled plant outage Plant personnel had a good understanding of the corrective action program. While all 1 personnel were cognizant of the reporting requirements, some personnel (e.g., I contractor personnel), due to their limited knowledge of the process, used a team approach for reporting deviations through their supervision. The implementation of the manual SmartForm process allowed personnel to report deviations without use of the computerized syste The process for detecting and correcting repeat problems was effective when problems
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were placed into the corrective action system. The inspectors noted that trending fuse l failure was problematic and the licensee found numerous examples where 6.9 kV and 480V breaker problems were not placed into the corrective action progra '
Noncited violations were properly entered into the corrective action program and were being resolved in a timely and technically adequate manne II. Maintenance-M7 Quality Assurance in Maintenance M7.1 Maintenance Rule l Inspection Scoce (40500)
l l This inspection reviewed the licensees' monitoring of the structures, systems and components that were within the scope of the maintenance rule. This monitoring was i reviewed to determine if the corrective actions, goals, and monitoring of structures, i systems, and components that were in 10 CFR 50.65(a)(1) were adequat Observations and Findinas The inspectors reviewed the maintenance rule activities by selecting 13 out of 37 maintenance rulo-related ONE forms or SmartForms involving structures, systems, and i
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components that were classified as in Category (a)(1) of 10 CFR 50.65. Of these I selected forms,8 were still open and 5 were closed (i.e., returned to Category (a)(2)
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status). This review was conducted to determine if corrective actions, goals, and monitoring of structures, systems, and components were consistent with regulatory requirement For each of the selected items, the inspectors found that the corrective actions were adequate and that the goal setting and monitoring were consistent with regulatory requirements. The inspectors noted that whenever a performance measure was not met ,
such that a structure, system, and component was placed in Category (a)(1) status, a l ONE form or SmartForm was written. This action placed the issue into the corrective l action program for disposition. Following entry into the corrective action program, the I system engineers determined the appropriate goal and submitted their recommended l goal to the expert panel for review, in addition, the inspectors noted that a table entitled, i
"What systems are currently in (a)(1) and what are their goals?" was issued in a monthly
" Management Performance Indica' ors Package." This package assured that l
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management was informed of the systems that were not meeting their performance measures and that the goal setting was adequate for proper resolutio The inspectors noted that the licensee's maintenance rule coordinator set a goal of approximately 90 days as the period from the time that a structure, system, and component went into Category (a)(1) to the time that the goal was set for returning the structure, system, and component back into Category (a)(2). However, when the inspectors compared the data for the period of January 1998 to May 1999, it was noted that 3 out of 17 structures, systems, and components did not have their goals set within the 90 days. The goal setting for the safety chilled water system was not accomplished un'il 343 days had elapsed, the goal setting for the radiation monitoring system was not set until 156 days had elapsed, and the goal setting for the containment isolation was not set until 103 days had elapse This observation was discussed with the maintenance rule coordinator and the applicable system engineers. As the result of these discussions, the inspectors determined that the delayed goal setting for the radiation monitoring and the containment isolation were appropriate. However, the inspectors determined that goal setting for the safety chilled water was not appropriat The inspectors further reviewed tMs issue and noted that a failure of the safety chilled water system to meet performance goals placed the system back into (a)(1) on May 20,
- 1998. However, SmartForm SMF-1999-543, which addressed this change in
! performance goals, was not issued until March 12,1999. The inspectors found that the system engineer did not issue a SmartForm when the performance goal was not me While Section 6.4.7 of Procedure STA-744, " Maintenance Effectiveness Monitoring Program," required that a SmartForm be issued if a performance measure was not met, such that a structure, system, and component was placed in Category (a)(1) status, it did not specify when the SmartForm should be issued. Further review of this issue by the L
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-15-inspectors indicated that the failure to issue the SmartForm was due to a system engineer error. Even though the system engineer was delinquent in issuing a SmartForm, the inspectors found that all necessary actions (e.g., placing the structure, system, and component in Category (a)(1) and implementing increased monitoring)
were accomplished. Based on the result of their review, the inspectors considered this issue to be an isolated occurrence in an otherwise effective progra Conclusions The licensee's corrective actions, goal setting, and monitoring of the structures, systems, and components included in the maintenance rule were found to be appropriat Ill. Enaineerina E7 Quality Assurance in Engineering Activities E7.1 System Reviews Insoection Scope (40500)
This inspection reviewed the corrective action processes as they related to several selected plant systems. These systems included the 6.9kV switchgear,480V switchgear, 480V motor-control centers, and electrical control inverters. For the electrical control inverters, the review was limited to completed ONE forms and SmartForms written since January 1,1998. The 6.9kV switchgear review was limited to only the 6.9kV circuit breakers and involved a review of ONE forms, SmartForms, the 6.9kV breaker refurbishment program, internal audits, and individual work documents. The 480V switchgear and motor-control center review was limited to ONE forms, SmartForms, and work orders for all the breakers on two switchgear units (1EB1 and 1EB3) and two motor-control centers (1 EB1-2 and 1EB3-2). Observations and Findinas Overall, the inspectors found that the corrective action processes for prioritization, trending, and disposition of corrective actions for these systems to be appropriate. Some problems were identified with the licensee's ability to trend issues, which also involved some isolated problems associated with the threshold of initiation of ONE forms and SmartForms. These issues are discussed belo .9 kV Switchaear l After reviewing work orders associated with the 6.9kV switchgear, the inspectors noted l that a number of corrective action related work orders did not reference a ONE form or SmartForm. The inspectors discussed this with the SMART Team 3 manager, whose team was primarily responsible for maintenance and surveillance of this equipment. As the result of these discussions, the inspectors were informed that SMART Team 3 had written a SmartForm to address a ONE form and SmartForm threshold issue that they had discovered in February 1999. SmartForm SMF-1999-268 dated February 10,1999, identified 12 corrective maintenance items for which ONE forms or SmartForms had not b
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-16-been written since 1992. The inspectors reviewed 6 of these work orders and found that corrective actions directed by the work order were timely and appropriate in each cas No evidence of a failure to consider equipment operability was identified. Nevertheless, because each of these issues had not been placed into the licensee's corrective action process, the identification of generic issues and the evaluation of preventive maintenance activities could not be effectively implemented. The licensee's review of the corrective maintenance work orders resulted in a reevaluation of the 6.9kV circuit breaker refurbishment program and improved focus on troubleshooting circuit breaker issue The inspectors evaluated the licensee's review of this issue and found that the licensee interpreted the subject work orders in an appropriate manner and applied a conservative ONE form or SmartForm threshold. For example, the inspectors found that a work order that was written to correct an indicating light failure because of dirty contacts, which had no effect on circuit breaker operation, was identified by the licensee as a failure to write a ONE form. The licensee retrained SMART Team 3 personnel on the procedural requirements for initiating a ONE form or SmartForm. Interviews with SMART Team 3 personnel indicated that the retraining efforts were successful. Procedure STA-421 stated, "an individual discovering a potential adverse condition shall document the condition on an Electronic SmartForm, Manual SmartForm, or a ONE form in a timely manner or ensure that another individual does so in a timely manner." Because of the broad and comprehensive nature of the licensee's corrective actions, the inspectors concluded that they were adequat After implementing the corrective actions, SMART Team 3 initiated 79 SmartForms during the most recent refueling outage with 29 of these SmartForms related to circuit breaker issues. This reflected a significant increase from the previous outage where 37 ONE forms were initiated by SMART Team 3,8 of which were related to circuit breaker issues. The inspectors considered this data to be indicative that there was a lowered threshold for writing SmartForm The identification by the licensee of a failure to promptly identify and correct conditions l ajverse to quality of the 6.9 kV circuit breaker failures is considered to be an example of 1 a Severity Level IV violation of 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," (50-445; 446/9908-02). Because the NRC encourages self identification and correction of conditions adverse to quality and the licensee's immediate and long-term corrective actions were effective, this violation is being treated as a noncited violation consistent with Appendix C of the NRC Enforcement Policy. This violation was entered into the licensee's corrective action program as SmartForm SMF-1999-26 After reviewing a sample of ONE forms and SmartForms, the inspectors noted a potential limitation of the ONE form database. The ONE form database only allowed the selection of one system effected by the subject of the ONE form, e.g., while the operation of particular circuit breakers could affect more than one system, the database would only identify a single system. This resulted in the licensee having to conduct word or phrase searches of the database to identify trends for system interfacing components such as circuit breakers. Specifically, after reviewing the ONE forms or SmartForms for the component cooling water system for the period from January 1,1998, to April 14,1999, the inspectors found three ONE forms cr SmartForms associated with 6.9kV circuit !
breakers that were listed under the component cooling water system but not listed in the l
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-17-6.9kV switchgear system. This made it difficult for the licensee to identify trends in circuit breaker performance. This limitation did not appear to be a restriction with the new SmartForm process. The inspectors determined that fullimplementation of the SmartForm should correct this limitatio V Switchaear and Motor-Control Centers in order to assess if the SmartForm initiation threshold issue was limited to only 6.9kV circuit breakers, the inspectors requested that the licensee provide work order, ONE form ,
and SmartForm data on all 480V circuit breakers associated with 1EB1 and 1EB3 switchgear ano 1EB1-2 and 1EB3-2 motor-control centers. This review showed similar results in that, of 13 work orders reviewed,10 should have had a ONE form or ,
SmartForm written, but only 4 had been written. The inspectors selected a sample of the l work orders reviewed by the licensee and found that the licensee's review was conservativ As was the case for the 6.9 kV circuit breakers, the inspectors concluded that because of the broad and comprehensive nature of the licensee's corrective actions associated with SmartForm 1999-268, these actions were sufficient to address these ONE form and SmartForm threshold issue The identification by the licensee of a failure to promptly identify and correct conditions adverse to quality for the 480V circuit breaker failures was considered to be the second example of a Severity Level IV violation of 10 CFR Part 50, Appendix B, Criterion XV Because the NRC encourages self identification and correction of conditions adverse to quality and the licensee's immediate and long-term corrective actions were effective, this violation is being treated as a noncited violation consistent with Appendix C of the NRC Enforcement Polic Durinr, tha licensee's process of gathering information on the 480V circuit breakers, the SMART Team 3 manager directed the SMART Team staff to write a SmartForm on the repeated failures of Westinghouse Type W-2 cell switches. However, when the staff e attempted to write the SmartForm, they discovered that SmartForm SMF-1999-1259 was already written. This SmartForm placed the finding into the licensee's corrective action progra SmartForm SMF-1999-1259 was wriden by the licensee 1 Nuclear Overview Department because they had observed a Westinghouse W-2-Type cell switch replacement during the Spring 1999 refueling outage. Subsequent followup of the Nuclear Overview Department observations revealed that NRC Information Notice 87-61, " Failure of Westinghouse W-2-Type Circuit Breaker Cell Switches," and its supplement had been previously evaluated by the licensee. The licensee's internal response to the NRC information notice and its supplement indicated that the licensee had evaluated the safety significance of the W-2 cell switch deficiency by analysis of the specific applications and functions of the W-2 cell switches and concluded that if any of the cell switches were to fail, it would not adversely affect the safe p! ant operations. Corrective actions associated with the W-2 cell switch failures included conducting inspections of the cell switch every 5 years. A review of work order history revealed that, since the implementation of these corrective actions, the licensee had numerous failures of the
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-18-W-2 cell switch on both units. The licensee also reviewed a recent industry operating i experience report from ar other nuclear plant involving the failure to close of an emergency diesel generator output breaker during a loss of off-site power event, due to this same type of cell switch failure. Based on this information, the licensee determined a need to reevaluate their response to NRC Information Notice 87-61 and its supplement ,
to determine if any additional actions were needed to reduce or eliminate future W-2 cell i switch failures. In addition, the Nuclear Overview Department recommended that a review be conducted to determine why this trend had not been previously discovere The inspectors reviewed work order information on cell switches and noted that since j 1996, W-2 cell switch failures were as follows: 1996 - 1 failure,1997 - no failures, i 1998 - 4 failures,1999 - 8 failures as of April. This was clearly a recent adverse trend in Westinghouse W-2 cell switch failures. The inspector determined that the licensee ,
appropriately identified this adverse trend. Since no corrective actions had been !
implemented at the end of this inspection other than placing the issue in the corrective action process, the inspectors could not evaluate the effectiveness of this corrective actio Electrical Control Inverters 1 The inspectors reviewed 36 closed ONE forms and SmartForms associated with the new electrical control inverters since January 1998. The inspectors noted that the majority of the issues described in the ONE forms and SmartForms could be grouped into two categories. The first category involved vendor quality issues (loose wires, broken components, insulation damage, or incorrect wiring), which were all discovered during preinstallation inspections or post-installation testing. The second category involved unanticipated frequency instability issues. The inspectors found that all significant issues were classified as operational mode limiting during the refueling outage and were corrected prior to declaring the inverters operable. In each case, the corrective actions were simple and adequat c. Conclusions The inspectors considered that the corrective action program was properly implemented for the 6.9 kV circuit breakers, the 480V circuit breakers, and the circuit breaker W-2 cell switches. The inspectors found that the licensee-identified threshold and trending issues were confined to the ONE form process that was being phased out. Its replacement, the new SmartForm process, was designed to allow an improved identification threshold and trending. An aggressive Nuclear Overview Department review appropriately identified an adverse trend in Westinghouse W 2 cell switch failure rate The inspectors did not identify any failures to address the effect of these circuit breaker failures on system operability.
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E7.2 Component Reviews Inspection Scoce (40500)
This inspection was conducted to determine the effectiveness of the corrective action program as it applied to electrical fuses and transmitters by conducting a review of licensee procedures, trending programs, work documents, corrective action documents, and Nuclear Overview Department evaluation Observations and Findinas l
Electrical Fuses The inspectors reviewed a list of work orders and found that of the approximate 163 work orders related to fuse failures since April 14,1997,19 involved failed fuses, and 74 involved loose or hot fuse clips. As such, the inspectors focused on the licensee's corrective actions associated with failed fuses and hot / loose fuse clip issue Additionally, the inspectors evaluated the licensee's control of fuse In NRC Inspection Reports 50-445;-446/96-16 and 50-445;-446/98-05, inspectors !
discussed a generic issue involving electrical contact degradation between fuses and
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their associated Buchanan, Model 361, fuse clips. Contact degradation could cause j inadvertent actuation of safety-related equipment, prevent the operation of safety-related '
equipment, or could cause a plant transient. The licensee's investigation revealed that after a fuse had been removed and reinstalled into a Buchanan, Model 361 fuse clip 50 times, the force necessary to remove the fuse dropped by approximately 9 percen After 100 times, the force dropped by approximately 32 percent. The licensee developed a design change to replace the Buchanan, Model 361 fuse clip with a different type of clip and, in the interim, implemented a thermography surveillance activity to monitor the fuse clips every 6 months. A design change authorized the replacement of the Buchanan, Model 361 fuse clips with fuse clips manufactured by the Bussman corporation, which were constructed out of a sturdier alloy. The sturdier alloy (approximately 90 percent copper) would reduce the amount of relaxation during installation and removal of the fuses. Testing conducted by the licensee revealed that while there was some relaxation over time, the force necessary to remove the fuse fiom the Bossman clip after 1000_ cycles was still greater than the force necessary to remove the fuse from the Buchanan clip after the first remova After reviewing a summary of ONE forms and SmartForms associated with fuses, the inspectors concluded that there was a significant decrease in the number of fuse clip related failures. No significant fuse clip failures were identified on a SmartForm or ONE form since thermography surveillance activities began. In addition, the inspectors noted that when a hot fuse clip was identified during the thermography surveillance, a work order was promptly written to replace the fuse holder. The inspectors concluded that the thermography surveillance was effective in identifying and corrective actions were effective in replacing loose fuse clips before failur The inspectors evaluated the effectiveness of the licensee control of fuses installed in the plant by walking down the process described in Procedure CDA-401, " Control of
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-20 Annunciators, Instruments, and Protsetive. Relays," with an operator. This was accomplished by randomly selecting four panels having the operator open them and randomly selecting two or three fuses in each panel. Once the fuse location and installed fuse type were noted, the operator demonstrated to the inspectors how they verified that the proper fuse was installed by reviewing controlled station drawings. This was the same process described in Procedure ODA-401 for replacing a failed fuse. All of the fuses inspected were installed properly, looked to be in good condition, and were of the proper typ The inspectors noted that Step 6.3.5 of Procedure ODA-401 stated, " Replacing a blown fuse should only be attempted once. If a fuse blows after being replaced, initiate a work request." Procedure ODA-401 further stated,"The equipment affected by the blown fuse and corrective action should be logged in the Unit log." After questioning licensee personnel, the inspectors concluded that no other actions were required to track a single fuse failure other than those described in Procedure ODA-401. The inspectors also interviewed plant operators to ascertain how frequently blown fuses were replace Almost every operator interviewed indicated that they seldom replaced fuses. All operators interviewed indicated that they had not replaced a failed fuse for some time, and none remembered documenting a fuse replacement in the Unit lo The inspectors then selected five work orders related to failed fuses and requested the licensee to demonstrate how they tracked equipment availability. Each example was found to either not affect the functionality of the system or that the unavailability time was properly tracke Based on this review, the inspectors determined that while the licensee exhibited good fuse controls, its fuse replacement practices resulted in a minor reduction in the licensee's ability to identify fuse failure trend Transmitters The inspectors reviewed a list of ONE forms and SmartForms since April 14,1997, and selected two ONE forms and three SmartForms for a detailed review. Each of the examples selected were found to be addressed appropriately and in accordance with the licensee's procedures. A review of Procedure ICA 101, "I&C Work Control," revealed that the guidance providcd to instrumentation and control technicians adequately specified the threshold for writing a ONE form and SmartForm when transmitter surveillance test results were outside the allowable range. The inspectors found that the transmitter trending program was adequate and that failures and subsequent technical evaluations were easily audited and traceabl c. Conclusions Although a large number of work activities were identified for loose or hot fuse clips, the inspectors found that an effective thermography surveillance testing program identified and corrected problems before failur The licensee maintained the pro rr plant configuration by effectively controlling fuse replacements and transmitter f6ibre r e
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E7.3 Vendor Information and Industry Ooeratina Experience l Inspection Scope (40500)
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This inspection reviewed the licensee's disposition of 45 ONE forms or SmartForms associated with vendor information, and 26 ONE forms or SmartForms associated with industry operating experience issues resolved between January 1998 and April 1999, l Observations and Findinas The inspectors found that shift management, operability, and reportability reviews were conducted in a timely manner. Immediate and long-term corrective actions were generally appropriate. As the result of these reviews, the following items were identified:
Potential Compensator Sprina Hvdraulic Lockina on SMB-1 Motor-Operated Valve I Actuators (ONE Form 97-1291)
On November 4,1997, the licensee wrote ONE Form 97-1291 to address a motor-operated valve actuator Limitorque (the vendor) Maintenance Update 89-1, which recommended that the Zerk grease fitting on Type SB-1 compensator housings be replaced with plugs to prevent inadvertent greasing. The concern was that,if grease was ;
added to the Type SB-1 actuator, the grease would not be allowed to migrate out of the compensator housing. This could result in a buildup of grease in the area of the Belleville type washer springs. If the Belleville springs became packed with grease, its ability to compress would decline and the actuator would experience unacceptably high inertial loadin The inspectors noted that the engineering resolution did not discuss the impact potential that higher inertialloading could have on the subject valve in its disposition of the ONE form. Higher inertial loading could result in damage to the valve or increase the unseating torque requirements to unacceptable values. The licensee concluded in its ONE form disposition document that the problem did not have an impact on the operability of the valves. The conclusion was based on the supposition that motor-operated valve testing would identify grease in the compensator springs, and no problems had been noted at the time the ONE form was written. In addition, the valves were relatively new, and the potential for grease accumulation was small. The inspectors reviewed a sample of the test data on the subject motor-operated valves and concluded that the actuator test data indicated that none of the actuators were adversely affected by the greas The inspectors noted that the corrective actions listed on the ONE form disposition did not include an inspection if grease was present when the Zerk fitting was replaced. The ONE form disposition did note that Work Orders 4-97-113783-00 and 4-97-113784-00 nre developed to replace the Zerk grease fitting with a plug in all the affected actuator A review of the actual work orders revealed that they did, indeed, require an inspection for grease, but only one of the work orders documented that the inspection had taken plac ~
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-22-With respect to timeliness of corrective actions, the inspectors noted that ONE Form 97-1291 involved a 1989 Limitorque Maintenance Update. The ONE form was initiated in November 1997, and the simple and effective corrective actions were completed by June 1998. This failure to promptly identify and correct conditions adverse to quality for the Limitorque motor actuators was considered to be the third example of a i Severity Level IV violation of 10 CFR Part 50, Appendix B, Criterion XVI 50-445; 446/9908-02). Because the NRC encourages self-identification and correction of conditions adverse to quality, and the licensee's immediate and long-term corrective actions were effective, this violation is being treated as a noncited violation consistent with Appendix C of the NRC Enforcement Policy. The licensee entered this violation into l its corrective action program as ONE Form 97-129 j Enthalov Transport Model Variability Problem (ONE form 97-1700)
On December 24,1997, the licensee documented that the Siemens Power Corporation l identified a variability problem with the enthalpy transport model contained within the RELAP4 code (a model used to determine thermohydraulic phenomena in the reactor core) in a letter dated December 18,1997. This model was used in the licensee's analysis for a large break loss-of-coolant accident. The licensee's nuclear engineering department conducted a sensitivity analysis on the effect of the enthalpy transport model and concluded that it had a negligible effect on peak centerline temperature of the fuel during the accident and concluded that operability was unaffecte The inspectors were concerned about the nuclear engineering department's conclusion that the variability problem had no adverse effect because it was based on a computer run for one point in the analysis. The results of the licensee's analysis indicated that when the enthalpy transport model was turned off, fuel peak centerline temperature for the single point increased by 5 degrees Fahrenheit. The inspectors agreed with the licensee that a 5 degree Fahrenheit change in peak fuel temperature was minor, but also noted that the evaluation was not rigorous. After discussing this observation with the licensee, the licensee's nuclear engineering conducted additional reviews which demonstrated a -30 to +5 degree Fahrenheit variability in the analysis conclusions. The licensee, again, concluded that the enthalpy transport model variability problem was negligible for the Comanche Peak Steam Electric Station model which used a 5-node core model rather than the typical 3-node core model. The inspectors agreed with the licensee's conclusio c. Conclusions s
Control of vendor information and industry operating experience was appropriate. Shift management operability and reportability reviews were conducted in a timely manne Immediate and long-term corrective actions were generally acceptabl The inspectors found one example where the licensee's corrective actions for a 1989 Limitorque Maintenance Update was not timely. This failure was considered to be a r.3ncited violatio p l
-23-IV. Plant Support l R7 Quality Assurance in Radiation Protection and Chemistry Controls a. Insoection Scope (40500)
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This inspection involved a review of selected ONE forms and SmartForms that were written in the radiation protection area. In addition, to the ONE form and SmartForm l
review, several months of radiation protection logs, which encompassed a refueling outage, and a selection of notable log entries were reviewed to determine if issues were properly entered into the corrective action program and if the subsequent corrective actions were appropriat b. Observations and Findinas The review of approximately 16 ONE forms and SmartForms indicated that issues were entered into the corrective action program for resolution. The inspectors found that problems identified in these selected ONE forms and SmartForms were being or had been properly tracked and resolve During the review of radiation protection logs, the inspectors selected several personnel contamination events for review. Each event was found to be minor in nature (less than 10,000 ncpm) and did not involve a ONE form or SmartForm. The inspectors noted that Section 6.1.7 of Procedure RPI 402, " Personnel Decontamination," instructed the user to
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generate a ONE Form in accordance with Procedure STA-421 if the cause of the contamination event was caused by poor radiological work practices. The inspectors found that the licensee interpreted the term " poor radiological practice" broadly by including issues requiring a ONE form such as contaminated spills of reactor coolant, airborne events, and multiple personnel contamination events. Based on these log reviews, the inspectors considered the licensee's thresholds for initiating ONE forms or SmartForms to be appropriate, c. Conclusions The inspectors concluded that the radiological department had established an appropriate threshold for initiating ONE forms and SmartForms. Corrective actions related to both ONE forms and SmartForms were found to be adequate and complet P7 Quality Assurance in Emergency Preparedness Activities a. inspection Scope (40500)
This inspection involved a review of 21 selected ONE forms and SmartForms that were l written to identify problems in the area of emergency preparedness.
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-24- l b. Observations and Findinas The inspectors selected 21 out of 40 ONE forms and SmartForms to determine if the corrective actions identified in these forms were adequate and either complete or on i track for completion. As the result of these reviews, the following issues were identifie I'
The inspectors noted that the public warning siren failure rate was a higher rate than that preferred by the licensee. Following discussions with licensee personnel, the inspectors determined that the licensee was properly tracking and correcting these failures and had maintained a functional system. Furthermore, the inspectors noted that the licensee's !'
siren availability was about 95 percent which was better than the Federal Emergency Management Administration required availability rate of 90 percent or greate The inspectors noted that SmartForm SMF-1998-2281 identified the improper installation of a siren U.D.I. module. The licensee's investigation of this finding indicated that the improperly installed module was caused by human error, however, the SmartForm also stated that no conclusion could be determined. Further review by the licensee determined that the improperly installed module was a manufacturing error and that no human error was involved. The inspectors considered the licensee's actions for this SmartForm to be appropriat In addition, the inspectors noted that SmartForm SMF 1998-2121 identified that Post-accident Sampling System Valve 1PS-0050 was found to be mispositione Because no definite cause for the mispositioning could be determined, the SmartForm corrective actions did not include any human error corrective actions. The inspectors considered the licensee's actions to be appropriate in this case and noted that their actions were consistent the requirements of Procedure STA-42 c. Conclusions The inspectors concluded that the corrective action program in emergency preparedness was being properly implemente V. Manaaement Meetinas X1 Exit Meeting Summary ,
I The inspectors presented the inspection results to members of licensee management at l the conclusion of the onsite inspection on May 11,1999. The licensee's representatives acknowledged the findings presente :
At this meeting, the licensee stated that it was not in agreement with the inspectors'
findings regarding the threshold for a performance enhancement review committee ;
meeting and review of personnel error events (Section 07.1b.1of this report). Licensee j representatives considered the threshold to be appropriate and to be effective toward )
l reducing the number of personnel errors.
I 1 The inspectors asked the licensee staff and management whether any materials i examined during the inspection should be considered proprietary. No proprietary information was identifie p .
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ATTACHMENT l^
SUPPLEMENTAL INFORMATION
. PARTIAL LIST OF PERSONS CONTACTED Licensee A. Carver, Nuclear Overview Department h. Clark, Operations Support i D. Barham, Senior Nuclear Specialist l M. Cox, Central Organization for Reliable Plant Systems Team Manager D. Depierro, Smart Team 3 System Supervisor J. Gallman, Performance Analysis Supervisor .
E. Gastinel, System Engineering R. Green, Senior Engineer ' 1 H. Haby, Technical Support J. Henderson, System Engineering .
D. Hood, Emergency Planning Manager .i R. Kidwell, Emergency Preparedness Planning j D. Lowery, Senior Engineer, Central Organization for Reliable Plant Systems Team i S. Patel, System Engineering ;
B. Poole, Technical Support l W. Reppa, System Engineering i
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T. Robbins, System Engineering W. Sly, Materials Condition Manager S. Smith, Smart Team No. 3, Manager i C. Terry, Senior Vice President and Principal Nuclear Officer T. Tigner, Program Supervisor Central Organization for Reliable Plant Systems Team R. Walker, Regulatory Affairs Manager NBQ J. Pellet, Chief, Operations Branch INSPECTION PROCEDURE USED 40500 Effectiveness of Licensee Process to identify, Resolve, and Prevent Problems l ITEMS OPENED AND CLOSED I Opened and Closed 50-445; 446/9908-01 NCV Failure to follow minor maintenance procedure i 50-445; 446/9908-02 NCV Failures of circuit breakers and motor operators were not promptly i identified and corrected ;
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PARTIAL LIST OF DOCUMENTS REVIEWED .
PROCEDURES STA-421- Operations Notification and Evaluation (ONE) Forms / Initiation and
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Processing of SmartForms, Revision 7.
l STA-422 Processing of ONE Forms / Disposition of SmartForms identifying Potential
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Adverse Conditions, Revision 1 I STA-606 Control of Maintenance and Work Activities, Revision 2 NQA 2.11 Trend System, Revision 7.
! - NQA 1.08 Development and Control of Evaluation Plans, Revision 2.
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NQA 3.01 Evaluation Program, Revision 3.
l NOA 3.09 - 9.05 Performance of Quality Control Surveillances, Revision ODA-401 Control of Annunciators, instruments, and Protective Relays, Revision '
TSP-523 Rosemount Transmitter Monitoring Program, Revision 2.
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INC-2088 - Testing Rosemount Transmitter Response to Process Changes, )
Revision j lCA-101 ~ l&C (Instrument and Controls) Work Control, Revision RPl-110 Radiation Protection Shift Activities, Revision 6.-
RPl-402 Personnel Decontamination, Revision 1 STA-744 Maintenance Effectiveness Monitoring Program, Revision ODA-308 LCO (Limiting Condition for Operation) Tracking Program, Revision 7.
i ONE FORMS
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- ONE NUMBER SUBJECT DATE ONE 98-00114 Bussman Type KTK and KTN-R Fuse Failures 1/1/98 ONE 97-1601- Fuse Clip Failures 12/3/97 ONE 98-0737 ES 06 (Engineering Safeguards Loading Sequencer) 5/6/98 Unavailability Criteria Exceeded for Train B t i
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ONE 98-0624 CB-02 (Containment Airlocks) Functional Failure 4/10/98 Criteria Exceeded ONE 98-0980 VD-10 (Vents and Drains) Functional Failure Criteria 7/9/98 Exceeded ,
l ONE 98-0176 Failed to Meet FW-02 (Feedwater isolation Valve) 2/12/98 i Performance Criteria Goals '
ONE 98-0098 Failed to Meet CHS-02 (Safety Chilled Water) Reliability 1/27/98 I Performance Criteria ONE 96-0055 ECl-01 (Electrical Inverters) Unavailability Exceeded for 1/22/96 Train A ONE 97-0253 (Electrical Inverter) Maintenance Preventable Functional 3/13/97 Failure (MPFF) and Failure to Meet Previously Established '
Goal ONE 98-0096 MS-02 (Main Steam) Functional Failure Criteria Exceeded 1/26/98 ONE 98-0138 During Performance of ETP-908 (Test Procedure), 2/3/98 Audibility in the 138 kV Switchyard was inadequate ONE 98-0143 Eight Persons Assigned to the Emergency Response 2/5/98 i Organization do not have Unescorted Access i ONE 98-0188 Personnel Not Being Properly Requalified for their 2/13/98 Emergency Response Organization Positions ONE 98-0205 Emergency Operations Facility Dosemeters not set to 2/17/98 the Autonomous Mode ONE 98-0240 Paging System Lost due to Lightening Strikes 2/26/98 ONE 98-0906 Failure to Report Post-Accident lodine and Particu! ate 6/16/98 Samples to the Control Room ONE 98-1017 Updated Softwear and Firmwear Not included in Plant 7/6/98 Documentation ONE 98-1085 Failure of the Containment Air Post Accident Sampling 7/29/98 System Leakage Test ONE 98-1223 Several Operators Failed to Take Requalification 8/27/98 Training For Respirator Usage ONE 98-1114 Inoperable Train A Control Room Emergency Filtration / 8/3/98 Pressurization System
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-4 ONE 98-0177 Inadequate Search for Explosives / Incendiary Devices 2/12/98 ONE 97-1138 Failure to Monitor Unavailability Hours 10/21/97 ONE 97-0200 Failure to include 23 Functions associated with 18 2/27/97 Systems in the Maintenance Rule Program Scope SMARTFORMS SMF NUMBER SUBJECT DATE SMF 98 2253 Repeat MPFFs (Maintenance Preventable Functional 11/23/98 Failure) for RM-03 SMF-99-0543 Safety Chilled Water Failed to Meet Reliability Criteria 5/20/98 SMF-98-2121 Vent Valve 1PS-0050 Found Out of Position During 10/29/98 Testing
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SMF 98-2120 Failure of Personnel to Sign-in on a Work Clearance 10/29/98 SMF-98-2239 - Emergency Light Failed to Energize 11/19/98 SMF-98-2281 Emergency Siren UDI Module Installed Incorrectly 12/1/98 SMF-99-0060 EOF (Emergency Operations Facility) Not Implemented in 1/13/99 ,
Accordance with the Emergency Plan !
SMF-99-0093 Personnel Contamination Monitor Removed from Service 1/19/99 Due to Failed Source Check SMF 99 0157 Emergency Sirens do not Respond to Feedback Polls 1/28/99 SMF-99-0158 Emergency Sirens do not Respond to Feedback Polls 1/28/99 l SMF-99-0159 Emergency Sirens do not Respond to Feedback Polls 1/28/99 SMF-99-0171 Emergency Sirens do not Respond to Feedback PoHs 2/1/99 SMF-99-0285 Emergency Notification Form Program and ORCAS will 2/12/99 Not Print Out in the Control Room
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SMF-99-0434 Emergency Siren Failed the Monthly Test 3/2/99 SMF-99-0435 Emergency Siren Failed the Monthly Test 3/2/99 SMF-98-2266 Numerous Emergency Lighting Battery Packs From 11/25/98 Discharged in Containment
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SMF-99-0192 Plant Paging System (Galtronics) Inaudible or Not 2/3/99 I Understandable in Certain Plant Areas SMF 99-0982 Three Emergency Lights Failed to Energize During Fire 4/10/99 !
Inspections !
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SMF-99-0497 - EOF Ventilation System will not Attain 0.05 3/9/99-l (Inchee water gauge) Positive Pressure in the Emergency Mode l
SMF 99-0371 - Failure to Perform Required Training 2/25/99 '!
SELF-ASSESSMENTS l
NUMBER TITLE DATE
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..N/A Assessment of the TU Electric Procurement Program at 2/28/99 l Comanche Peak Steam Electric Station l NOE-EVAL-98-000071-00-00 SmartForm Pilot 11/30/98 :
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f. - NOE-EVAL 98-000074-00-00 Corrective Action 1/19/99 i i
NOE-EVAL-97-000028-00-00 Fuse Clip Failures 2/14/97 i
~N/A Nuclear Overview Department Assessment of Overall Plant Performance for the Month of March 1999 ]
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' MISCELLANEOUS DOCUMENTS ~ l j
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Engineering Document Change Notice, EDCN-02," Procurement Engineering Review of j Procurement Documents," dated March 4,1997 j Manager's Performance Indicator Package, March 1999 )
Performance Enhancement Program for CPSES - White Paper dated 4/7/93
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Operators Guideline No.18, Operable / Operability dated 7/8/98 l i l Work Order 4-98-117140-00, Appears there is a D/A (Digital / Analog) converter proble i
- Repair / replace required circuit boards, dated 3/28/98 I_ Weekly " bubble-up" Report for the week of 3/5/99
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