IR 05000445/1999015

Insp Repts 50-445/99-15 & 50-446/99-15 on 990822-1002. Non-cited Violations.Major Areas Inspected:Operations, Maintenance,Engineering & Plant Support

ML20217M591
Person / Time
Site:	Comanche Peak
Issue date:	10/20/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217M574	List: IR 05000445/1999015 ML20217M571
References
50-445-99-15, 50-446-99-15, NUDOCS 9910270254
Download: ML20217M591 (21)

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ENCLOSURE U.S NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.: 50-445 50-446

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License Nos.: NPF-87 NPF-89 Report No.: 50-445/99-15  !

50-446/99-15 Licensee: TXU Electric '

Facility: Comanche Peak Steam Electric Station, Units 1 and 2 Location: FM-56 Glen Rose, Texas Dates: Au0ust 22 through October 2,1999 Inspectors: Anthony T. Gody, Senior Resident inspector Lcott C. Schwind, Resident inspector Approved By: Joseph I. Tapia, Chief, Branch A Division of Reactor projects l

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ATTACHMENT: Supplemental Information l

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9910270254 991020 PDR ADOCK 05000445 G PDR

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j EXECUTIVE SUMMARY Comanche Peak Steam Electric Station, Units 1 and 2 NRC Inspection Report No. 50-445/99-15; 50-446/99-15 Inspection Period - 08/22 - 10/02/99 Operations

Operators conducted the Unit 1 shutdown in an orderly fashion. A change in plant shutdown procedures allowed operators to trip the reactor at 20 percent power and resulted in a less challenging shutdown for operators (Section 01.2).

Control room operators performed well during the draindown and midloop operations in Unit 1. Reactor coolant system level was monitored on all available instruments which performed as designed. An additional reactor operator was stationed in the control room to monitor the residual heat removal system. This reduced the burden on the reactor operator and allowed him to concentrate on reactor coolant system level indications. Distractions to the operators were kept to a minimum (Section 01.3).

Contract workers erecting scaffolding dropped a scaffold pole on the Unit 1 moisture separator reheater drain tank alternate drain valve and it failed open. Operators responded well by isolating the failed-open valve and reducing main turbine load (Section 01.4).

During a regularly scheduled meeting, the Operations Review Committee provided good oversight and feedback to the licensee regarding plant operations. The committee's recommendations were appropriately incorporated into the licensee's programs and processes (Section 08.1).

Existing plant procedures were adequate for contolling the position of valves in the residual heat removal system and preventing a draindown event such as the on, described in Generic Letter 98-02 (Section 08.2). j l

Maintenance

Housekeeping and material condition remained good. Significant improvements were i noted in the cleanliness of the station service water intake structure. The inspectors I walked down a number of manual containment isolation valvos in Unit 2 and found them to be in the proper position ad in good condition (Section O2.1).

• The performance of maintenance and surveillance was good. Personnel were knowledgeable on the systems being tested or maintained and demonstrated procedure

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adherence as well as good communication with the control room (Section M1.2). i

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Instrument and control technicians demonstrated poor maintenance practices when they inadvertently backfilled pressure transmitter lines with water contaminated with cleaning fluid. This resulted in a high sodium condition in the Unit 2 condensate system. The

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-2-technicians were unaware of the requirements in Procedure INC-3016, "Backfilling Process Sensors and Sensing Line," which would have precluded this event. The licensee's root cause investigation was thorough (Section M1.3).

Enaineerina

- The licensee's safety evaluation for the Unit 1 dual train component cooling water and emergency diesel generator system outages was clear cnd concise. Limits established by the evaluation were properly translated into defense-in-depth contingency plans and monitored by plant personnel (Section E1.1).

• The issue of minimum gap in emergency core cooling system cold leg injection throttle valves was reviewed concurrently with the licensee's ability to perform hot leg recirculation. This issue is discussed in NRC Inspection Reports 50-445;446/99-03 and 50-445;446/99-14 and was closed with weaknesses noted in the licensee's engineering evaluation process. Corrective actions for the hot leg tecirculation issue also encompassed the minimum gap issue and were considered adequate and timely (Section E8.1).

Plant Support

. Several examples of poor radiological control practices were observed by the inspectors and the licensee during the Unit 1 refueling outage. In one example, an individual failed to contact radiation protection technicians when he observed erratic indications on his electronic dosimeter. In two other examples, personnel failed to follow the requirements of Station Administration Manual STA-656," Radiation Work Control," by not complying with the requirements of a radiation work permit and by the use of a tobacco product l inside the radiological control area. Failure to follow this procedure was a violation of Technical Specification 5.4.1. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. These examples are included in the licensee's corrective action program as Smart Forms SMF-1999-2502 and SMF-1999-2530 (Section R1.2).

• Three examples of poor radiological practices involved contract employees and ;

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situations which were covered by the licensee's radiation worker training program. This was indicative of weaknesses in the radiation worker training program for contractors (Section 31.2).

• Two examples of poor radiological practices were identified by the licensee's quality assurance organization during routine observations and evaluations, which was .

indicative of a good questioning attitude and their effectiveness in identifying perforraance issues (Section R1.2).

• The licensee improperly released the station service water tunnel from the radiologically controlled area based on inadequate radiation surveys. Although this did not result in any significant unmonitored dose to individuals working in the area, the failure to properly post the tunnel for approximately 8 months was a violation of Technical Specification 5.4.1. This Severity Level IV violation is being treated as a noncited L

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-3-violation, consistent with Appendix C of the NRC Enforcement Policy. This condition was entered into the licensee's corrective action program as Smart Form SMF-1999-1850 (Section R1.3).

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Technical Support Center staff performance during the "Y2K" emergency drill was goo The licensee simulated a partialloss of the plant's telephone system. Personnel responded well and were able to reestablish the required lines of communications. The concept of a "Y2K Center" to deal with year 2000 specificiransition problems was a good initiative (Section P1.1).

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Report Details

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l Summary of Plant Statgji l Unit 1 began the inspection period at 100 percent power but was shut down on September 25, 1999, for its seventh refueling outage and remained in that condition for the remainder of the period. Unit 2 remained at essentially 100 percent power for the entire inspection perio l. Operations

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01 Conduct of Operations i O General Comments (71707)

Using Inspection Procedure 71707, the inspectors conducted frequent observations of plant operations. In general, the conduct of operations was characterized by safety-conscious decisions; noteworthy observations are detailed below. The inspectors concluded that both units were operated by knowledgeable operators using good self-verification techniques and communication O1.2 Unit 1 Shutdown for the Seventh Refuelina Outaco Insoection Scope The inspectors observed portions of the Unit 1 shutdown for the seventh refueling outage and conducted a plant tou Ot,servations and Findinas During a plant tour, the inspectors observed that the Unit 1 heater drain system was not experiencing water hammers as in the past. This would indicate that the heater drain systern modifications were successfu Control room operators were attentive to the control boards and used the Lppropriate procedures. Communications were thorough, formal, and complete. After the reactor was tripped, operators promptly and effectively implemented the reactor trip response procedure. Tripping the reactor at 20 percent power, rather than manually driving rods in and manually shutting down turbine building equipment, eliminated a difficult operational period. This was found to be an improvement over past shutdowns because operator challenges typically increased during low power operation periods which occasionally resulted in unplanned manual trip _C_onclusions Operators conducted the Unit 1 shutdown in an orderly fashion. A change in plant i shutdown procedures allowed operators to trip the reactor at 20 percent power and resulted in a less challenging shutdown for operators.

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-2-01.3 Unit 1 Midloop Operations Inspection Scope (71707)

The inspectors observed controi room operators drain the Unit 1 reactor coolant system to the midloop level to accommodate steam generator nozzle dam installatio Observations and Findinas The licensee initiated a draindown of the Unit 1 reacter coolant system to the midloop level in order to install nozzle dams on all four steam generators. This was done during the first week of the refueling outage, prior to offloading the core. Control room operators demonstrated good team work and three-way communications during this evolution. Multiple diverse levelinstruments were used per plant procedures to monitor reactor coolant system level. The narrow-range, wide-range, and extended wide-range ,

level instruments were continuously monitored, as well as a recently installed Mansell level moniinring system. A conservative draindown rate was established and maintainer. The licensee was appropriately sensitive to the need to establish and !

. maintain a hot leg vent path prior to establishing a cold leg vent path. The licensee I maintained the midloop condition for approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> while the steam generator j nozzle dams were installed and tested. During this period, an additional reactor operator was stationed in the control room to monitor the performance of the residual heat removal system. The inspector observed two shift changes which occurred during this evolution. Each oncoming crew received a thorough brief prior to taking the watc Distractions to the operators were kept at a minimum and management oversight was evident in the control roo Conclusions Control room operators performed well during the draindown and midloop operations in Unit 1. Reactor coolant system level was monitored on all available instruments which performed as designed. An additional reactor operator was stationed in the control room to monitor the residual heat removal system. This reduced the burden on the reactor operator and allowed him tc ., icentrate on reactor coolant system level indications. Distractions to the oper. . ors were kept to a minimum.

01.4 Unit 1 Moister Separator Reheater Transient Inspection Scope (71707. 92901)

The inspectors observed the licensee's response to a plant announcement that operators were reducing power because the Moisture Separator . Reheater (MSR)

Separctor Drain Tank 1B alternate drain Valve 1-LV-2713 had failed ope i l

-3- Observations and Findinos The inspector responded to the Unit 1 tv.rbine building and observed plant equipment operators close the manual gate valves to isolate the failed open alternate drain valv Contract employees erecting scaffolding above Valve 1-LV-2713 stated that a scaffold pole had fallen, breaking off the conduit supplying power to the pressure regulating device mounted on Valve 1-LV-2713. With power, and subsequently air pressure, removed from Valve 1-LV-2713, it slowly drifted open as the air pressure on the diaphragm bled off. Unit 1 control room operators responded to the MSR Separator Drain Tank 1B low level alarm and reduced main generator output 25 megawatts-electric (MWe). Main feed pump suction pressure dropped, causing the low suction pressure computer alarm to come on, but the reduced suction pressure caused no problems. The shift manager directed the shift technical advisor to the Unit 1 control board area and the Unit 1 supervisor was overseeing control room operators as they recovered the lost generation. The inspector found operators attentive to the control boards and alarms. Communication was good and distractions were appropriately minimized. Valve 1-LV-2713 was repaired and MSR Separator Drain Tank 1B was restored to normal operatio Conclusions Contract workers erecting scaffol ding dropped a scaffold pole on the Unit 1 MSR drain

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tank alternate drain valve and it failed open. Operators responded well by isolating the failed-open valve and reducing main turbine loa Operational Status of Facilities and Equipment O2.1 Plant Tours and System Walkdowns Lngpection Scoce The inspectors used inspection Procedure 71707 to walk down the following areas of the plant and plant systems:

Unit 1 containment building Units 1 and 2 safeguards buildings Auxiliary Building Units 1 and 2 electrical control buildings Units 1 and 2 turbine buildings Station service water intake structure Unit 2 manual containment isolations valves Observations and Findinas l-

) The inspector made frequent tours of both units during this period to assess general l housekeeping and material condition. The inspectors noted drastic improvements in the

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-4-cleanliness of the station service water intake structure. The licensee's efforts to control insects in this building were effective and the building had received a thorough cleanin Housekeeping in other areas of the plant generally remained goo The inspector performed a walkdown of manual containment isolation valves in the Unit 2 radioactive piping penetration areas. All manual containment isolation valves were closed with locking devices installed and were tagged to indicate the required position and the administrative requirements for repositioning the valve. No signs of leakage were observed on any of these valves. The inspector noted several capped

. vent and drain valves between containment and containment isolation valves which were not tagged, locked, or listed in the monthly containment penetration isolati m verification procedure. The inspector verified that these valves were infrequently operated and were under other administrative controls to assure their proper positio Conclusions l

Housekeeping and material condition remained good. Significant improvements were l noted in the cleanliness of the station service water intake structure. The inspectors ]

walked down a number of manual containment isolation valves in Unit 2 and found them to be in the proper position and in good conditio .1 Operations Review Committee Meetina Insoection Scope (71707)

The inspector observed an Operations Review Committee (ORC) meeting on the assessment of the planned Unit 1 refueling outage and the recently formed quality assurance subcommittee, Observations and Finding;

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The licensee discussed the seventh Unit 1 refueling outage plans with the ORC. The discussion was appropriately focused on the various risk profiles and subsequent defense-in-depth strategies. The ORC asked probing and challenging questions and provided good insights and feedback to the outage manager. Of particular note were the discussions on the risk profiles associated with the front-end and back-end midloop risk periods and the period of time the temporary emergency diesel generator was being tested. Outage planners were well prepared and provided clear answers to all question The licensee and the ORC discussed the recently formed quality assurance subcommittee and the plan to audit subcommittee activities by an outside organizatio Senior plant management had expressed a desire to delay the audit sirm the subcommittee activity would be minimal prior to the scheduled date. The ORC agreed with management's rationale that an audit so soon after formation of the subcommittee would be of limited value to the licensee. The inspectors agreed.

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5- Conclusions During a regularly scheduled meeting, the Operations Review Committee provided good oversight and feedback to the licensee regarding plant operations. The committee's recommendations were appropriately incorporated into the licensee's programs and processe .2 [ Closed) Temporarv instruction (TI) 2515/142. "Draindown Durino Shutdown and Common-Mode Failure" The inspectors conducted a review of the licensee's response to Generic Letter 98-02,

" Loss of Reactor Coolant inventory and Associated Potential for Loss of Emergency j Mitigation Functions While in a Shutdown Condition," using Tl 2515/142, "Draindown '

During Shutdown and Common-Mode Failure."

The residual heat removal system at both units of Comanche Peak Steam Electric j Station is identical to the system discussed in the generic letter. The residual heat !

removal pump discharge to the refueling water storage tank isolation valve, 1/2-8717, I could provide a flow path for high temperature water to the refueling water storage tank and cause reactor coolant system draindown if misaligne The inspector verified that the licensee had effectively implemented administrative controls, configuration management, and operating procodures to preclude an inadvertent draindown event as described in the generic letter. Valve 1.T-0717 was j locked closed in accordance with System Operating Procedure (SOP) 102A/B l

" Residual Heat Removal System." The configuration management of valve position and l locked component status was maintained by ODA-403," Operations Department Locked Component Control," and OWi-103," Locked Component Listings and Deviation Control." The inspector reviewed both of these procedures and found them to be adequate for controlling the position of Valve 1/2-8717. The licensee made no specific changes to its procedure or programs as a result of Generic Letter 98-02. The inspector concluded that this was appropriat No specific corrective actions were taken by the licensee for human factor contributors to the initiation of the type of event described in the generic letter. Operator training on this event was conducted by the licensee through their required reading and lessons leamed program; however, no other specific training was conducted. No further human performance enhancements were made to the labeling of Valve 1/2-8717. However, in addition to the locking device, the valves are labeled with a red tag that states to contact the shift manager prior to removing the lock or operating the valve. This was required by owl-103. The inspector concluded that this was sufficient.

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4-6-II. Maintenance M1 Conduct of Maintenance M1.1 General Comments (61726,62707)

Using Inspection Procedures 61726 and 62707, the inspectors conducted reviews of ongoing maintenance and surveillance activities. In general, the conduct of maintenance and surveillance activities reflected a policy of procedure adherence and quality; noteworthy observations are detailed in the sections belo . M1.2 Maintenance and Surveillance Observations Insoection Scope (61726. 62707)

The inspectors observed all, or portions of, the following maintenance and surveillance activities:

• ' ' Unit 2 Instrument Air Compressor 2-01 troubleshooting

• Unit 1 main steam safety valve testing

• Unit 1 fuel receipt

• ' Unit 1 core alterations

• Unit 2 K601 slave relay test (OPT 4638)

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Unit 1 safety injection accumulator dump test

• Unit 1 main steam atmospheric relief valve actuator modification

• Unit 1 Train A diesel generator 10-year overhaul Observations and Findinas The inspectors observed the receipt inspection and movement of new fuel for the Unit 1 refueling outage. The crews demonstrated propei aafety precautions and good teamwork while inspecting anu ransferring new fuel to the dry storage racks. Good foreign material exclusion practices were observed while transferring the fuel from the dry racks to the Unit 1 spent fuel pool. A reactor engineer was present during both of these activities and provided good support to operations and maintenance personnel performing the wor The inspector observed the main steam safety valve testing in Unit 1. Control room operators were appropriately briefed on the expected plant response and required action in the event that one of the safety valves should stick open. Operators were attentive to

. j the main steam system during the testing and maintained good communications with personnelin the field. Personnelin the field were knowledgeable on the use of the pneumatic safety valve actuator and were able to install it on the safety valves safely and proficiently. Emergency egress paths were maintained during the test, in the event a valve stuck ope l

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7-l Conclusions {

The performance of maintenance and surveillance was good. Personnel were 3 knowledgeable on the systems being tested or maintained and demonstrated procedure adherence as well as good communication with the control roo i A11.3 Inadvertent Sodium Contamination of the Unit 2 Condensate System Insoection Scope .

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The inspector reviewed the licensee's root cause investigation and corrective actions for j an inadvertent addition of contaminants to the Unit 2 condensate system, which resulted l in high sodium levels in the condensat Observations and Findinas ,

l On June 28,1999, the control room received indications of high sodium in the Unit 2 j Condenser Hotwell A. Operators initially concluded that there was a condenser tube )

leak and took act!ons to reduce reactor power to approximately 85 percent and isolate {

Condenser Waterbox A. After this was completed, sodium levels in the hotwell did not j continue to increase as would have been expected due to a condenser tube lea i Further investigation revealed that instrument and control technicians had calibrated two auxiliary condenser vacuum pressure transmitters earlier that day. This required the technicians to backfill the transmitter lines with demineralized water after the calibration was completed. The technicians obtained a chemical sprayer from the shop which was routinely used to transport demineralized water into the plant. However, contrary to Procedure INC-3016,"Backfilling Process Sensors and Sensing Line," the technicians 1'

did not empty and flush the sprayer prior to refilling it with demineralized water. It was later determined that the sprayer tank contained an unspecified amount of cleaning flu'd which was introduced into the transmitter lines and eventually made its way into the main condenser. This demonstrated poor maintenance practices by the technician The licensee entered this condition into their corrective action program as Smart Form 1 SMF/PIR-1999-001645-01-0 Conclusions Instrument and control technicians demonstrated poor maintenance practices when they inadvertently backfilled pressure transmitter lines with water contaminated with cleaning fluid. This resulted in a high sodium condition in the Unit 2 condensate sysicm. The ,

technicians were unaware of the requirements in Procedure INC-3016,"Backfilling l Process Sensors and Sensing Line," which would have precluded this event. The l licensee's root cause investigation was thorough.'

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E1 Conduct of Engineering 1 E1.1 Safety Evaluation (SE) Review

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Inspection Scope (37551)

' The inspectors reviewed SE 99-000037-00-00, which was used as the basis for a dual train outage on both trains of the Unit 1 Component Cooling Water (CCW) and Emergency Diesel Generator (EDG) systems during the seventh refueling outage. The {

inspectors also reviewed defense-in-depth (DID) contingency plans associated with the l dual train CCW and EDG system outage ) Observations and Findinas The inspectors found the DID contingency plans and their implementation sufficient to 1 i

assure equipment reliability. Critical equipment was roped off, and signs were placed to limit access and work in the are l The licensee's evaluation, conta,aed in SE 99-000037-00-00, properly considered the !

plant's design and licensing bases and provided adequate justification for the dual train I CCW and EDG outages on Unit 1. The spent fuel pool cooling system was aligned such that Unit 2 provided the CCW to the Train B spent fuel pool heat exchanger which :

directly cooled the Unit 1 spent fuel pool. Both spent fuel pools were mixed with the Train A spent fuel pool cooling loop. This arrangement was described in the Updated Final Safety Analysis Report and included initial spent fuel pool temperaten limitations of 150 F and initial service water temperature of 102 F. The inspectors verified that control room operators were monitoring both of these temperatures. The DID contingency plans clearly estab!ished these limits, including a 10*F margin (140 F) on the Unit 1 spent fuel poo Spent Fuel Pool Coolina Durina a Postulated Unit 2 Loss-of-Coolant-Accident With CCW cooling being supplied to the spent fuel pools from Unit 2, the licensee performed a calculation which t,oncluded that there was no adverse thermal impact on the Unit 2 CCW system during a postulated loss-of-coolant-accident in Unit 2. One assumption in the calculation was that 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> had elapsed after the Unit 1 shutdown prior to the postulated loss-of-coolant-accident. The 200-hour delay allowed the offloaded fuel decay heat to decrease. The inspectors reviewed the planned schedule for the Unit 1 outage and found that the dual train CCW outage was more than 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> following the Unit 1 shutdow Station Blackout Analysis with Dual Train CCW and EDG System Outaaes in SE 99-000037-00-00, the licensee evaluated the effects of a postulated station blackout with a dual train CCW and EDG outage on Unit 1. The licensee's evaluation L

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l I identified several critical parameters such as: (1) the Unit 1 spent fuel pool should not j begin to boil before the 4-hour coping period was over, (2) initial Unit 1 spent fuel pool l temperature was 140*F or below, and (3) initial Unit 2 uninterruptible power supply room temperature was 80*F or below. As long as the critical parameters were met, the l licensee concluded that they would still be able to cope with a 4-hour station blackout.

The inspectors verified that the DID contingency plans adequately established these limits and operators were monitoring the appropriate parameters.

t c. - Conclusions l

The licensee's safety evaluation for the Unit 1 dual train component cooling water and l emergency diesel generator system outages was clear and concise. Limits established

, by the evaluation were properly translated into DID contingency plans and monitored by l plant personne E8 Miscellaneous Engineering lasues l E (Closed) Licensee Event Report (LER) 50 445/97008: LER 50-445/97008-01: minimum aao for cold lea iniection emeraency core coolina system throttle valves not in accordance with desian.

L-l The issue of minimum gap in emergency core cooling system cold leg injection throttle valves was reviewed concurrently with the licensee's ability to perform hot leg recirculation. This issue was discussed in NRC Inspection Reports 50-445;446/99-03 and 50-445;446/99-14 and was closed with weaknesses noted in the licensee's engineering evaluation process. Corrective actions for the hot leg recirculation issue l also encompassed the minimum gap issue and were considered adequate and timely.

I-IV. Plant Support l

.R1 Radiological Protection and Chemistry Controls R General Comments The inspectors conducted frequent tours of the radiologically controlled area during this inspection period, which included a portion of the Unit 1 refueling outage, and observed radiological practices of plant personnel. In general, personnel adhered to good radiological practices and As-Low-As-Reasonably-Achievable (ALARA) concept However, there were several notable exceptions which are detailed below.

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. R1.2 Unit 1 Refuelina Outaae Radioloaical Prauices

Inspection Scope 171750)

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The inspectors used inspection Procedure 71750 to conduct observations of radiological

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control practices by plant personnel and contractors during the Unit 1 refueling outag Observations were made during a diverse range of jobs throughout the plan Observations and Findinas The inspector was in the Unit 1 main steam penetration room, which is inside the radiologically controlled area (RCA), discussing an ongoing modification with personnel in the area. During this discussion, an individual's electronic dosimeter began alarming on high dose rate. He informed the inspector that it haa Jone this several times already and he believed it was due to a cellular telephone which he had clipped to his belt next to the dosimeter. In addition, the dosimeter was reading a total dose of 3 millirem, which was unusual since this area was a low dose area and the individual had not been in any other part of the RCA except in transit. No other dosimeters in the area were alarming or indicating any dose. Contrary to the licensee's radiation worker training program, the individual did not contact radiation protection technicians when his dosimeter began alarming. The inspector exited the RCA and informed radiation protection technicians of the situation who, in turn, verified that the dose rate alarms were false and reset the dosimeter. This condition was entered into the licensee's corrective action progra During a Nuclear Overview Department evaluation of refueling outage work, licensee personnel observed a contract employee using smokeless tobacco products inside the RCA. This practice'was contrary to station administration manual STA-656, " Radiation Work Control," Section 6.1.1, which states, " Eating, smoking, chewing, or loitering, in an RCA is prohibited." The individual corrected the contract employee's conduct and documented this occurrence in the licensee's corrective action program as Smart Form SMF-1999-250 The licensee observed contracted personnel inside a contamination area in the Unit 1 containment erecting scaffolding without proper anticontamination clothing. Individuals were bare-handed in two cases and, on one occasion, an individual unzipped his protective clothing to remove a watch. The licensee took immediate actions to correct this situation ~. STA-656, Section 5.4.1, requires that radiation workers read and follow the appropriate radiation work permit. Radiation Work Permit 99-1215 required that workers wear gloves. Contrary to this requirement, these individuals were erecting scaffolding in an area covered by the radiation work permit and they f ailed to wear gloves as required. This was documented in the licensee's corrective action program as Smart Form SMF-1999-253 Technical Specification 5.4.1 requires, in part, that procedures and instructions be implemented in accordance with NRC Regulatory Guide 1.33, " Quality Assurance Program Requirements." Regulatory Guide 1.33, Appendix A, Section 7, requires procedures for radiation protection. Station administration manual STA-656," Radiation l

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-11-Work Control," prohibits " dipping or chewing" in the RCA and requires radiation workers to read and follow the appropriate radiation work permit. Contrary to these requirements, an individual was observed using tobacco products in the RCA, and personnel erected scaffolding in a contamination area without using gloves as specified by their radiation work permit. This was a violation (50-445;50-446/9915-01) of Technical Specification 5.4.1. This Severity Level IV violation is being treated as a noncited violation, consistent with Appuidix C of the NRC Enforcement Polic Conclusions Several examples of poor radiological control practices were observed by the inspectors and the licensee during the Unit 1 refueling outage. In one example, an individual failed to contact radiation protection technicians when he observed erratic indications on his electronic dosimeter. In two other instances, personnel failed to follow the requirements of Station Administration Manual STA-656, " Radiation Work Control." Failure to follow this procedure was a violation of Technical Specification 5.4.1. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is included in the licensee's corrective action program as Smart Forms SMF-1999-2502 and SMF-1999-253 Three examples of poor radiological practices involved contract employees and i situations which were covered by the licensee's radiation worker training program. This I was indicative of weaknesses in the radiation worker training program for contractor Two examples of poor radiological practices were identified by the licensee's quality I assurance organization during routine observations and evaluations, which was l indicative of a good questioning attitude and their effectiveness in identifying l performance issue R1.3 Radioloaical Surveys and Postinas of the Station Service Water Tunnel Inspection Scope (71750)

The inspector reviewed the licensee's investigation into improperly releasing the station service water tunnel from the RCA. In addition, the inspector reviewed the licensee's dose estimates for personnel that worked in the tunnel during that time, Observations and Findinas During a routine survey of the station service water tunnel, the licensee discovered a previously unidentified radioactive waste process line approximately 18 feet above the tunnel floor. At the time of discovery, exposure rates at one meter from the line were approximately 2 millirem per hour. Of particular concern was the fact tnat the licensee had released the tunnel from the radiologically controlled area for 8 months during 1998 and 1999, in order to facilitate personnel access during a refurbishment projec Exposure rates in the tunnel during this time period were unknown as they vary widely depending on the status of the liquid waste processing system. The licensee entered L

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-12-this condition into their corrective action program and initiated a technical evaluation to determine the extent of exposure received by maintenance personnel working in the tunnel while it was released from the RC The process line was used to transport contaminated water from high integrity containers in the fuel storage buildings to a waste holdup tank in a batch proces Therefore, the line was empty most of the time. On August 4,1999, the licensee -

performed a detailed survey of the tunnel while the line was in use and found exposure rates 9 feet above the tunnel floor to be approximately 0.3 millirem per hour. The licensee believed that this would be the worst case radiological conditions in the tunne Maintenance personnel were working on scaffolding at various elevations in the tunnel, l- including near the ceiling and on the tunnel floor. Although personnel were interviewed by the licensee, no one could recall exactly where they were working in the tunnel and for what duration, therefore, the licensee used the 0.3 millirem per hour as the average exposure rate since this reading was taken in the middle of the tunnel. The licensee also determined that during the 8-month refurbishment project the tunnel had been i

occupied a total of 4 days while the process line was in use. The licensee conservatively assigned an average exposure rate of 0.4 millirem per hour to personnel working in the tunnel during those 4 day As a result of the licensee's evaluation, a total of 70 people were assigned additional doses,11 of whom received exposures greater then 10 millirem. The most significant case was an individual who was estimated to have received 103 millirem during the 8 month period. No dose limits were exceeded as a result of this even Technical Specification 5.4.1 requires, in part, that procedures and instructions be implemented in accordance with NRC Regulatory Guide 1.33," Quality Assurance Program Requirements." Regulatory Guide 1.33, Appendix A, Section 7, requires procedures for radiation protection. The licensee's radiation protection manual, Instruction Number RPI-602," Radiological Surveillance and Posting," Attachment 1, requires areas outside the primary RCA to be posted as radiation areas if the dose rates to the major portion of the whole body exceed 2 millirem in any one hour. Contrary to this requirement, the service water tunnel met this criteria but was not posted as a radiation area between June 29,1998, and March 5,1999. This was a violation (50-445;50-446/9915-02) of Technical Specification 5.4.1. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This issue was documented in the licensee's corrective action program as Smart Form SMF-1999-185 Conclusions The licensee improperly released the station service water tunnel from the RCA based on inadequate radiation surveys. Although this did not result in any significant unmonitored dose to individuals working in the area, the failure to properly post the tunnel for approximately 8 months was a violation of Technical Specification 5.4.1. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This ccndition was entered into the licensee's corrective action program as Smart Form SMF-1999-1850.

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" P1 Conduct of Ernergency Planning Activities P1.1 Emergency Preparedness Drill Insoection Scope (71750)

The inspectors observed the licensee's performance during an emergency preparedness drill conducted on August 24,1999. Observations included activities in the Technical Support Center (TSC) and the "Y2K Center." Observations and Findinas Scenario The drill commenced at 7:30 a.m. on August 24,1999. However, the licensee simulated the time of occurrence to be 11:30 p.m., December 31,1999, in order to include year 2000 transition scenarios in the drill. The scenario started with Unit 1 at 100 percent power. Operators in the control room simulator identified a reactor coolant system leak in excess of 10 gallons per minute which led to the declaratio'n of a Notification of Unusual Event. This was followed by a fire in the Unit.1, Train A, diesel generator which burned for longer than 15 minutes, leading to an Alert declaration. The drill culminated in an offsite release and the declaration of a Site Area Emergency and, finally, a 4 General Emergency. The scenario was complicated by failures in the plant computer, l the PC-11 Radiation Monitoring System, one of three public branch exchanges (PBX) I serving the plant, and a partialloss of communication with county and state officials due J to year 2000 transition problem Observations The TSC was staffed and operational at the beginning of the drill scenario as part of the

"Y2K Continency Plan." The TSC manager and utaff performance was good during the !

drill; however, the inspector noted that communications protocols were not predefined in '

the event that normal communications were lost. When the PBX failed as part of the drill scenario, some telephones in the TSC workeo while others did not, and it appeared that the TSC staff resorted to trial and error until full communications were reestablished using the remaining operational telephones. In addition, the TSC manager had a cell phone with him; however, he was unsure if the cell phone would work in the TSC or even if he should attempt to use it, considering the close proximity of sensitive electronic equipmen The "Y2K Center" was established during this drill to deal with problems specific to the year 2000 transition and was staffed with members of the system engineering computer team, a regulatory affairs liaison, and an operations department liaison. This concept was still under development; therefore, the drill was conducted as a walkthrough. The i licensee intended to use this team to evaluate and resolve problems with digital systems as they occur as well as analyze advance information as it is received f rom facilities in l

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time zones east of Comanche Peak. The inspector noted that several of the "Y2K Center" staff members were not members of the licensee's emergency response organization and were unfamiliar with the requirements of the emergency plan for I

control of activities in the plant during an emergency. This included requirements such as personnel accountability and dosimetry. Despite this, the inspector observed no specific example where personnel violated emergency procedure c. Conclusions TSC staff performance during the "Y2K" emergency drill was good. The licensee ;

I simulated a partialloss of the plant's telephone system. Personnel responded well and were able to reestablish the required lines of communications. The concept of a "Y2K Center" to deal with year 2000 specific transition problems was a good initiativ V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the results of the inspection to members of the licensee management on October 7,1999. The licensee acknowledged the findings presente No proprietary information was identifie I i

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee C. L. Terry, Senior Vice President and Principal Nuclear Officer J. Kelley, Vice President, Nuclear Engineering and Support M. Lucas, Maintenance Manager D. Moore, Vice President, Nuclear Operations M. Sunseri, Operations Manager J. R. Curtis, Radiation Protection Manager R. Flores, System Engineering Manager D. L. Walling, Plant Modification Manager D. Kross, Outage Manager D. L. Davis, Nuclear Overview Manager INSPECTION PROCEDURES USED

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IP 37551 Onsite Engineering

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IP 61726 Surveillance Observations IP 62707 Maintenance Observations IP 71707 Plant Operations IP 71750 Plant Support Activities IP 90712 Inoffice Review of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92700 Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92903 Followup - Engineering Ti 2515/142 Draindown During Shutdown and Common-Mode Failure t

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l 2-ITEMS OPENED. CLOSED. AND DISCUSSED I

Ooened 50-445;446/9915-01 NCV- Radiological controls practices not in accordance with plant procedures (Section R1.2)

50-445;446/9915-02 NCV Failure to post the station service water tunnel as a radiation area (Section R1.3)

Closed 50-445;446/9915-01 NCV Radiological controls practices not in accordance with plant ;

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procedures (Section R1.2)

50-445;446/9915-02 -NCV Failure to post the station service water tunnel as a radiation i

I area (Section R1.3)

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(' 50-445/97008-00 LER Minimum gap for cold leg injection eccs throttle valves not in accordance with design (Section E8.1)

50-445/97008-01 LER Minimum gap for cold leg injection eccs throttle valves not in accordance with design (Section E8.1)

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3-LIST OF ACRONYMS USED ALAR as-low-as-reasonably-achievable CCW component cooling water DID . defense-in-depth

.EDG: emergency diesel generator-

-IP inspection procedure LER licensee MSR moisture separator reheater 4 i

MWe megawatt electric NCV noncited violation ORC Operations Review Committee -

PBX public branch exchanges PIR Plant incident Report .

RCA radiologically controlled area SE safety evaluation SMF Smart Form SO ' station operating procedure STA, station administrative procedure TI Temporary instruction TSC Technical Support Center L