IR 05000445/2014005

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IR 05000445/2014005 & 05000446/2014005, September 27,2014 Through December 31, 2014, Comanche Peak Nuclear Power Plant - Integrated Inspection
ML15035A636
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/03/2015
From: Webb Patricia Walker
NRC/RGN-IV/DRP/RPB-A
To: Flores R
Luminant Generation Co
Walker W
References
IR 2014005
Download: ML15035A636 (59)


Text

UNITED STATES ary 3, 2015

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000445/2014005 and 05000446/2014005

Dear Mr. Flores:

On December 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Comanche Peak Nuclear Power Plant, Units 1 and 2. On January 7, 2015, the NRC inspectors discussed the results of this inspection with Mr. K. Peters, Site Vice President, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

One of these findings involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Comanche Peak Nuclear Power Plant, Units 1 and 2.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the Comanche Peak Nuclear Power Plant, Units 1 and 2.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Wayne C. Walker, Branch Chief Project Branch A Division of Reactor Projects Docket Nos: 50-445 and 50-446 License Nos: NPF-87 and NPF-89

Enclosure:

Inspection Report 05000445/2014005 and 05000446/2014005 w/ Attachment:

1. Supplemental Information 2. Request for Information - Inservice Inspection 3. Request for Information - Radiation Safety Inspection

REGION IV==

Docket: 05000445, 05000446 License: NPF-87, NPF-89 Report: 05000445/2014005 and 05000446/2014005 Licensee: Luminant Generation Company LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: 6322 N. FM-56, Glen Rose, Texas Dates: September 27 through December 31, 2014 Inspectors: J. Kramer, Senior Resident Inspector R. Kumana, Resident Inspector B. Travis, General Engineer B. Tindell, Senior Resident Inspector N. Hernandez, Resident Inspector R. Williams, Senior Reactor Inspector, NRC Region II L. Carson II, Senior Health Physicist C. Alldredge, Health Physicist N. Greene, PhD, Health Physicist P. Hernandez, Health Physicist Approved By: Wayne Walker Chief, Project Branch A Division of Reactor Projects-1- Enclosure

SUMMARY

IR 05000445/2014005, 05000446/2014005; 09/27/2014 - 12/31/2014; Comanche Peak Nuclear

Power Plant, Units 1 and 2; Integrated Inspection Report, Follow-up of Events and Notices of Enforcement Discretion The inspection activities described in this report were performed between September 27, 2014, and December 31, 2014, by the resident inspectors at the Comanche Peak Nuclear Power Plant and inspectors from the NRCs Region IV office and other NRC offices. Two findings of very low safety significance (Green) are documented in this report. One of these findings involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609,

Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects Within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Initiating Events

Green.

The inspectors reviewed a self-revealing finding for the licensees failure to follow the troubleshooting activities procedure while working on the condensate system alarm and control circuit. The troubleshooting activities caused the condensate low pressure heater bypass valve to open resulting in a plant transient. Operators responded to the event by manually initiating a turbine runback and then stabilized the plant. The workers had conducted additional troubleshooting activities without the awareness of operations and an evaluation by engineering, which did not meet the requirements of the troubleshooting procedure. The licensee entered the finding into the corrective action program as Condition Report CR-2014-001268.

The failure to follow the troubleshooting activities procedure was a performance deficiency.

The performance deficiency was more than minor because was associated with the human performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, performing the additional troubleshooting steps without the required evaluation and notification resulted in a plant transient. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 1, Initiating Events Screening Questions, the finding was determined to be of very low safety significance (Green) because the finding did not cause a reactor trip or the loss of mitigation equipment. The finding has a human performance cross-cutting aspect associated with documentation because the licensee failed to ensure that work packages were complete and thorough and that plant activities were governed by high-quality procedures [H.7]. (Section 4OA3.2)

Cornerstone: Mitigating Systems

Green.

The inspectors reviewed a self-revealing non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to follow instructions when performing surveillance testing of the reactor coolant loop cold leg injection boundary valves. The test procedure had a prerequisite for the plant to be in mode or 5. The licensee performed the test in mode 3 which isolated the residual heat removal system flow to loops 3 and 4 and aligned the loop 3 safety injection accumulator to the test line. As a result, both trains of residual heat removal and one safety injection accumulator were inoperable. The licensee revised the procedure for the plant conditions and re-performed the test. The licensee entered the finding into the corrective action program as Condition Report CR-2014-005254.

The licensees failure to follow procedure for performing surveillance testing of the reactor coolant loop cold leg injection boundary valves was a performance deficiency. Specifically, personnel failed to ensure prerequisites were met in accordance with the procedure. The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. The performance deficiency resulted in both trains of the residual heat removal system and one safety injection accumulator being inoperable.

Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to require a detailed risk evaluation because the finding represented a loss of function for the residual heat removal system. A senior reactor analyst performed a bounding detailed risk evaluation and determined the finding to be of very low safety significance (Green). The finding has a human performance cross-cutting aspect associated with challenging the unknown because the licensee failed to stop when faced with uncertain conditions and evaluate risks before proceeding [H.11]. (Section 4OA3.1)

PLANT STATUS

Unit 1 began the inspection period at approximately 100 percent power. On October 4, 2014, the operators shut down Unit 1 to begin a scheduled refueling outage. On November 27, 2014, the outage ended when the main generator output breakers were closed and Unit 1 was placed on the grid. On November 30, 2014, the unit returned to approximately 100 percent power and operated at that power level for the remainder of the inspection period.

Unit 2 began the inspection period at approximately 100 percent power. On December 2, 2014, operators reduced reactor power to approximately 70 percent power for turbine valve testing.

The unit returned to approximately 100 percent power the same day and operated at that power level for the remainder of the inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On November 13, 2014, the inspectors completed an inspection of the stations readiness for seasonal extreme weather conditions. The inspectors reviewed the licensees adverse weather procedures for cold weather and evaluated the licensees implementation of these procedures. The inspectors verified that, prior to the onset of extreme low temperatures, the licensee had corrected weather-related equipment deficiencies identified during the previous cold weather season.

The inspectors selected three risk-significant systems that were required to be protected from cold weather:

  • Diesel generators
  • 480 volt AC power
  • Condensate storage tank The inspectors reviewed the licensees procedures and design information to ensure the systems or components would remain functional when challenged by adverse weather.

The inspectors verified that operator actions described in the licensees procedures were adequate to maintain readiness of these systems. The inspectors performed a walkdown of portions of these systems to verify the physical condition of the adverse weather protection features.

These activities constituted one sample of readiness for seasonal adverse weather as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

  • December 31, 2014, Unit 2, diesel generator 2-02 and safety-related train B 6.9 kV bus when diesel generator 2-01 was unavailable The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. The inspectors verified that critical portions of the systems were correctly aligned for the existing plant configuration.

These activities constitute completion of two partial system walkdown samples as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

On December 20, 2014, the inspectors performed a complete system walkdown of the Unit 2 containment spray system. The inspectors reviewed the licensees procedures and system design information to determine the correct system lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, in-process design changes, temporary modifications, and other open items tracked by the licensees operations and engineering departments. The inspectors verified that the system was correctly aligned for the existing plant configuration.

These activities constituted one complete system walkdown sample as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on the following plant areas important to safety:

  • October 22, 2014, Units 1 and 2, fire water pump house
  • October 29, 2014, Units 1 and 2, fire zone AA21f, auxiliary building 790 foot elevation
  • October 29, 2014, Units 1 and 2, fire zone AA21d, auxiliary building 830 foot elevation
  • October 30, 2014, Units 1 and 2, fire zone EA43, electrical and control building 778 foot elevation
  • October 30, 2014, Unit 1, fire zone 1SB5, auxiliary feedwater pump 1-01 room For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constitute completion of five quarterly fire protection samples as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

On November 13, 2014, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose two plant areas containing risk-significant structures, systems, and components that were susceptible to flooding:

  • Unit 2 cable spreading room
  • Unit 2 train B switchgear room The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors performed a walkdown of the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers.

The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.

These activities constitute completion of one flood protection measures sample as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R08 Inservice Inspection Activities

The activities described in subsections

.1 through .4 below constitute completion of one

inservice inspection activities sample as defined in Inspection Procedure 71111.08.

.1 Nondestructive Examination Activities and Welding Activities

a. Inspection Scope

The inspectors directly observed the following nondestructive examinations:

SYSTEM COMPONENT IDENTIFICATION EXAMINATION TYPE Reactor Coolant 12.75-inch Pipe to elbow weld area Ultrasonic Test System TBX-1-4101-MRP Reactor Coolant ASME Class 1 attachment welds TBX-1-4102-H3 Dye Penetrant System Test Reactor Coolant Reactor Vessel Closure Head Penetrations Visual Test System (General Visual)

Containment Containment Liner in Elevator Shaft Visual Test (General Visual)

Containment Containment Moisture Barrier-Seismic Gap Visual Test Material (General Visual)

The inspectors reviewed records for the following nondestructive examinations:

SYSTEM COMPONENT IDENTIFICATION EXAMINATION TYPE Reactor Coolant 6.625-inch Elbow to pipe weld TBX-2-2402-23 Ultrasonic Test System Reactor Coolant 6.625-inch Pipe to elbow weld TBX-2-2402-24 Ultrasonic Test System Reactor Coolant 6.625-inch Elbow to pipe weld TBX-2-2402-25 Ultrasonic Test System Reactor Coolant 18-inch Reducing elbow to pipe weld TBX-2- Ultrasonic Test System 2401-2NW

SYSTEM COMPONENT IDENTIFICATION EXAMINATION TYPE Reactor Coolant ASME Class 2 attachment welds TBX-2-2401-H2 Magnetic Particle System Test Reactor Coolant ASME Class 2 attachment welds TBX-2-2401-H6 Magnetic Particle System Test Chemical 3-inch Pipe to valve weld TUX 21-1 Radiograph Test Volume Control Chemical 3-inch Pipe to valve weld TUX 22-1 Radiograph Test Volume Control Chemical 3-inch Pipe to valve weld TUX 23-1 Radiograph Test Volume Control Reactor Coolant Reactor Vessel Lower Head Bottom Mounted Visual Test System Instrument Penetrations (General Visual)

During the review and observation of each examination, the inspectors observed whether activities were performed in accordance with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code requirements and applicable procedures. The inspectors also reviewed the qualifications of all nondestructive examination technicians performing the inspections to determine whether they were current.

The inspectors observed a portion of the following welding activities:

SYSTEM WELD IDENTIFICATION WELD TYPE Auxiliary Feed System tie-in for AFW primary FLEX connection Gas Tungsten/

Water System valve 1-0272 Shield Metal Arc Welding Auxiliary Feed System tie-in for AFW primary FLEX connection Gas Tungsten/

Water System valve 1-0273 Shield Metal Arc Welding The inspectors reviewed records for the following welding activities:

SYSTEM WELD IDENTIFICATION WELD TYPE Safety Injection Safety Injection Pump 1-01 Lube Oil Cooler Gas Tungsten Arc System Basket Strainer Welding Reactor Coolant MOV 1-HV-8402A Gas Tungsten Arc System Welding The inspectors reviewed whether the welding procedure specifications and the welders had been properly qualified in accordance with ASME Code,Section IX requirements.

The inspectors also determined whether that essential variables were identified,

recorded in the procedure qualification record, and formed the bases for qualification of the welding procedure specifications.

b. Findings

No findings identified.

.2 Vessel Upper Head Penetration Inspection Activities

a. Inspection Scope

The licensee performed a visual inspection per procedure, Reactor Vessel Closure Head Visual Examination Plan, Revision 4. During refueling outages when a bare metal visual inspection is not required per ASME Code Case N-729-1, a less detailed general visual assessment is performed. The inspectors reviewed the results of the licensees visual assessment and verified that there was no evidence of boric acid challenging the structural integrity of the reactor vessel upper head components and attachments.

b. Findings

No findings were identified.

.3 Boric Acid Corrosion Control Inspection Activities

a. Inspection Scope

The inspectors reviewed the licensees implementation of its boric acid corrosion control program for monitoring degradation of those systems that could be adversely affected by boric acid corrosion. The inspectors reviewed the documentation associated with the licensees boric acid corrosion control walkdown as specified in procedure STA-737, Boric Acid Detection and Evaluation, Revision 8. The inspectors reviewed whether the visual inspections emphasized locations where boric acid leaks could cause degradation of safety significant components, and whether engineering evaluation used corrosion rates applicable to the affected components and properly assessed the effects of corrosion induced wastage on structural or pressure boundary integrity. The inspectors observed whether corrective actions taken were consistent with the ASME Code, and 10 CFR 50, Appendix B requirements.

b. Findings

No findings were identified.

.4 Steam Generator Tube Inspection Activities

a. Inspection Scope

The licensee did not perform steam generator tube inspection activities during Refueling Outage 1R17. The next steam generator tube inspection will take place during Refueling Outage 1R19.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On December 1, 2014, the inspectors observed simulator training for an operating crew.

The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the training activity.

These activities constitute completion of one quarterly licensed operator requalification program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity or risk. In addition, the inspectors assessed the operators adherence to plant procedures, including the conduct of operations procedure and other operations department policies. The inspectors observed the operators performance of the following activities:

  • October 4, 2014, Unit 1, manual reactor trip and emergency response guideline usage at the start of refueling outage 1RF17
  • November 25, 2014, Unit 1, reactor startup from refueling outage 1RF17 These activities constitute completion of one quarterly licensed operator performance sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated the degraded performance or condition of the following risk-significant structures, systems, or components:

  • Unit 2 diesel generators
  • Service water cross-connect valves The inspectors reviewed the extent of condition of possible common cause structure, system, or component failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the structures, systems, or components. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

The inspectors reviewed Operating Experience Smart Sample (OpESS) FY 2010-01 Recent Inspection Experience for Components Installed Beyond Vendor Recommended Service Life for the review of the service water cross-connect valves.

These activities constituted completion of four maintenance effectiveness samples as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the following risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

  • October 9, 2014, both units, risk management of alternate spent fuel pool cooling alignment
  • October 28, 2014, Unit 1, outage risk management and management of orange risk during mid-loop operations
  • December 13, 2014, Unit 1, remote shutdown panel testing associated with diesel generator 1-02 and the train B 6.9 kV switchgear supply breakers The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant

procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

These activities constitute completion of three maintenance risk assessments and emergent work control inspection samples as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed the following operability determinations and functionality assessments that the licensee performed for degraded or nonconforming structures, systems, or components:

  • Condition Report CR-2014-007235, Unit 2, supplying component cooling water to spent fuel pool heat exchanger X-01 from Unit 2
  • Condition Report CR-2014-011528, Unit 1, automatic start of diesel fire pump X-06
  • Condition Report CR-2014-012526, Unit 1, air leak from diesel generator 1-02 lower plenum
  • Condition Report CR-2014-013003, Unit 2, leakage past pressurizer spray valve 1-PCV-455C The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded structures, systems, or components to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded structures, systems, or components.

These activities constitute completion of five operability determination and functionality assessment inspection samples as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

The inspectors reviewed the permanent plant modification that affected risk-significant structures, systems, and components associated with the Unit 1 diverse and flexible mitigation capability (FLEX) equipment. The inspectors reviewed Final Design Authorization FDA-2013-000008-05-02. The inspectors performed a walkdown of the modifications. The inspectors verified that work activities involved in implementing the modifications did not adversely impact operator actions that may be required in response to an emergency or other unplanned event.

These activities constitute completion of one sample of permanent modifications inspection samples as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities that affected risk-significant structures, systems, or components:

  • October 5, 2014, Unit 1, containment polar crane testing following relay panel replacement prior to reactor vessel head and reactor coolant pump motor lifts
  • October 10, 2014, Unit 1, centrifugal charging pump 1-01 testing following maintenance
  • October 30, 2014, Unit 1, diesel generator 1-02 testing following outage maintenance and replacement of governor drive coupling element
  • November 1, 2014, Unit 1, alternate power diesel generator testing to confirm functionality of the diesel generators and components following installation
  • November 7, 2014, Unit 1, digital rod position indication testing following replacement of a digital rod position indication coil
  • November 7, 2014, Unit 1, turbine driven auxiliary feedwater pump over-speed testing following maintenance
  • December 15, 2014, Unit 1, remote shutdown panel testing following replacement of a power supply The inspectors reviewed licensing and design basis documents for the structures, systems, or components and the maintenance and post-maintenance test procedures.

The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the

established acceptance criteria, and restored the operability of the affected structures, systems, or components.

The inspectors reviewed Operating Experience Smart Sample (OpESS) FY2008-01, Negative Trend and Recurring Events Involving Emergency Diesel Generators in the review of diesel generator testing.

These activities constitute completion of seven post-maintenance testing samples as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

During the stations refueling outage that concluded on November 27, 2014, the inspectors evaluated the licensees outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions. This verification included the following:

  • Review of the licensees outage plan prior to the outage
  • Monitoring of shut-down and cool-down activities
  • Verification that the licensee maintained defense-in-depth during outage activities
  • Observation and review of reduced-inventory and mid-loop activities
  • Observation and review of fuel handling activities
  • Monitoring of heat-up and startup activities These activities constitute completion of one refueling outage sample as defined in Inspection Procedure 71111.20.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed the following risk-significant surveillance tests and reviewed test results to verify that the tests adequately demonstrated that the structures, systems, and components were capable of performing their safety functions:

  • April 21, 2014, Unit 2, power operated relief valve testing in accordance with Procedure OPT-606B, PORV N2 Accumulator Check Valve Leak Test, Revision 7
  • October 24, 2014, Unit 1, surveillances required for entry into Mode 6 in accordance with technical specifications and Procedure RFO-102, Refueling Operation, Revision 13
  • November 18, 2014, Unit 2, reactor coolant pump component cooling water check valve testing in accordance with Procedure OPT-501B, CCW Valves, Revision 10.

The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected structures, systems, and components following testing.

These activities constitute completion of four surveillance testing inspection samples as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the radiation monitoring equipment used by the licensee

(1) to monitor areas, materials, and workers to ensure a radiologically safe work environment, and
(2) to detect and quantify radioactive process streams and effluent releases. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:
  • Selected plant configurations and alignments of process, postaccident, and effluent monitors with descriptions in the Final Safety Analysis Report and the offsite dose calculation manual
  • Selected instrumentation, including effluent monitoring instrument, portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks
  • Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, postaccident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors
  • Audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation since the last inspection These activities constitute completion of one sample of radiation monitoring instrumentation as defined in Inspection Procedure 71124.05.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

The inspectors evaluated whether the licensee maintained gaseous and liquid effluent processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the licensees quality control program ensured radioactive effluent sampling and analysis adequately quantified and evaluated discharges of radioactive materials. The inspectors verified the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors interviewed licensee personnel and reviewed or observed the following items:

  • Radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection
  • Effluent program implementing procedures, including sampling, monitor setpoint determinations and dose calculations
  • Equipment configuration and flow paths of selected gaseous and liquid discharge system components, filtered ventilation system material condition, and significant changes to their effluent release points, if any, and associated 10 CFR 50.59 reviews
  • Selected portions of the routine processing and discharge of radioactive gaseous and liquid effluents including sample collection and analysis
  • Controls used to ensure representative sampling and appropriate compensatory sampling
  • Results of the inter-laboratory comparison program
  • Effluent stack flow rates
  • Surveillance test results of technical specification-required ventilation effluent discharge systems since the previous inspection
  • Significant changes in reported dose values
  • A selection of radioactive liquid and gaseous waste discharge permits
  • Part 61 analyses and methods used to determine which isotopes are included in the source term
  • Meteorological dispersion and deposition factors
  • Latest land use census
  • Records of abnormal gaseous or liquid tank discharges
  • Groundwater monitoring results
  • Changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater
  • Identified leakage or spill events and entries made into 10 CFR 50.75(g) records, if any, and associated evaluations of the extent of the contamination and the radiological source term
  • Offsite notifications and reports of events associated with spills, leaks, and groundwater monitoring results
  • Audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment since the last inspection These activities constitute completion of one sample of radioactive gaseous and liquid effluent treatment, as defined in Inspection Procedure 71124.06.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

a. Inspection Scope

The inspectors evaluated whether the licensees radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program. The inspectors verified that the radiological environmental monitoring program

was implemented consistent with the licensees technical specifications and offsite dose calculation manual, and that the radioactive effluent release program met the design objective in Appendix I to 10 CFR Part 50. The inspectors verified that the licensees radiological environmental monitoring program monitored non-effluent exposure pathways, was based on sound principles and assumptions, and validated that doses to members of the public were within regulatory dose limits. The inspectors reviewed or observed the following items:

  • Selected air sampling and dosimeter monitoring stations
  • Collection and preparation of environmental samples
  • Operability, calibration, and maintenance of meteorological instruments
  • Selected events documented in the annual environmental monitoring report which involved a missed sample, inoperable sampler, lost dosimeter, or anomalous measurement
  • Selected structures, systems, or components that may contain licensed material and has a credible mechanism for licensed material to reach ground water
  • Significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census or sampler station modifications since the last inspection
  • Calibration and maintenance records for selected air samplers, composite water samplers, and environmental sample radiation measurement instrumentation
  • Inter-laboratory comparison program results
  • Audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection These activities constitute completion of one sample of radiological environmental monitoring program as defined in Inspection Procedure 71124.07.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

The inspectors evaluated the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed licensee personnel and reviewed the following items:

  • The solid radioactive waste system description, process control program, and the scope of the licensees audit program
  • Control of radioactive waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition
  • Changes to the liquid and solid waste processing system configuration including a review of waste processing equipment that is not operational or abandoned in place
  • Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides
  • Processes for waste classification including use of scaling factors and 10 CFR Part 61 analyses
  • Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest
  • Audits, self-assessments, reports, and corrective action reports radioactive solid waste processing, and radioactive material handling, storage, and transportation performed since the last inspection These activities constitute completion of one sample of radioactive solid waste processing and radioactive material handling, storage, and transportation as defined in Inspection Procedure 71124.08.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, and Occupational Radiation Safety

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance Index: Residual Heat Removal Systems (MS09)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of October 2013 through September 2014 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted completion of two mitigating system performance index for residual heat removal systems performance indicator samples, one per unit, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index: Cooling Water Support Systems (MS10)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of October 2013 through September 2014 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted completion of two mitigating system performance index for cooling water support systems performance indicator samples, one per unit, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

The inspectors performed a trend review of work instruction quality. The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, external audits, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends.

These activities constitute completion of one semiannual trend review sample as defined in Inspection Procedure 71152.

b. Observations and Assessments The inspectors noted several recent examples of issues where work instruction quality was a contributing factor. The inspectors also observed examples from baseline inspection samples where work instruction quality did not meet licensee standards. The inspectors determined that the licensee had programs and actions in place to address these issues. The inspectors shared these observations with licensee management.

Specific examples are:

  • Condition Report CR-2014-003017, work orders for adjusting the position indicators on containment emergency airlock doors
  • Condition Report CR-2015-000135, work orders for replacement of secondary stabs on safety-related circuit breakers

adequate work instructions for modifications to the 138kV startup transformer XST1

  • Condition Report CR-2014-001268, Finding FIN 05000446/2014005-02 documented a failure to follow procedure with a contributing factor of inadequate work instructions for troubleshooting a condensate system alarm (Section 4OA3.1)

c. Findings

No findings were identified.

.3 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors performed an in-depth follow-up of the containment emergency airlock doors. On March 18, 2014, the inspectors identified that the exterior position indicator for handwheel number 1 of the Unit 1 emergency airlock did not indicate closed. The licensee verified that the door was closed and the indicator had been misaligned. On April 14, 2014, the inspectors identified that the Unit 2 emergency airlock interior door was open. At the time, the unit was shutdown. The licensee closed the airlock door.

The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews, and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.

These activities constitute completion of one annual follow-up of selected issues sample as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

The following activities constitute completion of two follow-up of events and notices of enforcement discretion samples as defined in Inspection Procedure 71153.

.1 (Closed) Licensee Event Report 05000446/2014-002-00, Both Trains of Residual Heat

Removal Inoperable During Testing in Mode 3

a. Inspection Scope

The inspectors reviewed a licensee event report documenting a condition that occurred on April 25, 2014, where both trains of residual heat removal were inoperable in mode 3.

The inspectors examined associated procedures, work orders, condition reports, and the licensees root cause analysis of the event.

b. Findings

Introduction.

The inspectors reviewed a Green self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to follow instructions when performing surveillance testing of the reactor coolant loop cold leg injection boundary valves. The test procedure had a prerequisite for the plant to be in mode 4 or 5. The licensee performed the test in mode 3 which isolated the residual heat removal system flow to loops 3 and 4 and aligned the loop 3 safety injection accumulator to the test line. As a result, both trains of residual heat removal and one safety injection accumulator were inoperable. The licensee revised the procedure for the plant conditions and re-performed the test.

Description.

On April 22, 2014, the licensee performed a leak test of the reactor coolant loop cold leg injection check valves in Unit 2. The licensee used four procedures, one for each loop, that each tested four individual check valves. The valves were not required to be operable until the reactor was in mode 2. Each procedure had a note stating that the testing of the residual heat removal to cold leg injection check valve and the safety injection accumulator downstream injection check valve cannot be performed in mode 3 due to the required test lineup. Each procedure also stated in the prerequisites that the plant was required to be in mode 4 or 5 when testing those two valves.

With the plant in mode 4, the licensee successfully performed testing of the four check valves in reactor coolant loops 1 and 2. During the performance of Procedure OPT-615B, RCS Pressure Boundary Leakage Test for Loop 3 CL Injection Valves, Revision 2, the licensee determined that the test of the safety injection accumulator downstream injection check valve could not be performed at the current system pressure due to higher than normal seat leakage. The licensee decided to postpone testing until it could be performed at a higher pressure. Testing was allowed to be performed at a higher pressure as long as the plant remained in mode 4.

On April 25, 2014, the licensee entered mode 3 and increased pressure to approximately 1800 pounds. The licensee attempted to perform the remaining testing with the prerequisites no longer being met. The licensee closed the residual heat removal to cold leg 3 and 4 injection isolation valve in accordance with step 8.4.3. With this valve closed, both trains of residual heat removal were inoperable. The licensee then opened the residual heat removal to cold leg 2-03 test valve in accordance with step 8.4.5. Opening this valve provided a path from the accumulator to the safety injection test line which began draining the accumulator because the unit was in mode 3 and the safety injection accumulators were lined up to discharge to the reactor coolant loops. The control room received the accumulator 3 low level alarm and took action to stop the accumulator discharge. The licensee restored the systems to their normal lineup and refilled the accumulator. The licensee determined that safety injection accumulator 3 was inoperable for 56 minutes and both trains of residual heat removal were inoperable for 31 minutes.

The licensee entered this issue into their corrective action program as CR-2014-005254 and performed a root cause evaluation. The licensee determined that operators had concerns about the test lineup, but those concerns were not addressed before proceeding with the test. The inspectors reviewed the event logs, procedures, and the

licensees evaluation. The inspectors determined that the evaluation identified the cause and appropriate corrective actions.

Analysis.

The licensees failure to follow procedure for performing surveillance testing of the reactor coolant loop cold leg injection boundary valves was a performance deficiency. Specifically, personnel failed to ensure prerequisites were met in accordance with the procedure. The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. The performance deficiency resulted in both trains of the residual heat removal system and one safety injection accumulator being inoperable. Using Inspection Manual Chapter 0609, 04, Initial Characterization of Findings, and Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to require a detailed risk evaluation because the finding represented a loss of function for the residual heat removal system.

A senior reactor analyst performed a bounding detailed risk evaluation. The dominant sequence was a medium-break loss-of-coolant-accident, with an exposure time of approximately one hour, resulting in an incremental conditional core damage probability of 7.75 x 10-8. Because the incremental conditional core damage probability was determined to be less than 1 x 10-6, the risk was of very low significance (Green).

The finding has a human performance cross-cutting aspect associated with challenging the unknown, in that, the licensee failed to stop when faced with uncertain conditions, and evaluate risks before proceeding [H.11].

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions. Contrary to the above, on April 25, 2014, the licensee performed an activity affecting quality and failed to accomplish the activity in accordance with documented instructions. Specifically, personnel failed to establish prerequisites for testing in accordance with licensee procedure OPT-615B, RCS Pressure Boundary Leakage Test for Loop 3 CL Injection Valves, Revision 2, step 6.3. The licensee took immediate action to restore the affected systems. Since the violation was of very low safety significance and was documented in the licensees corrective action program as Condition Report CR-2014-005254, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy:

NCV 05000446/2014005-01, Failure to Follow Procedure for Boundary Valve Leakage Testing.

.2 Failure to Follow the Troubleshooting Activities Procedure Results in a Plant Transient

a. Inspection Scope

On February 4, 2014, operators initiated a manual runback of the turbine to 900 MW due to the low pressure heater bypass valve 2-PV-2286 opening while at full power.

Licensee personnel had been troubleshooting intermittent alarms associated with the valve. During troubleshooting, technicians were removing a tool from a terminal when it created a short and caused the valve to open. The inspectors examined associated

procedures, work orders, condition reports, and the licensees root cause analysis of the event.

b. Findings

Introduction.

The inspectors reviewed a Green self-revealing finding for the licensees failure to follow the troubleshooting activities procedure while working on the condensate system alarm and control circuit. The troubleshooting activities caused the condensate low pressure heater bypass valve to open resulting in a plant transient. Operators responded to the event by manually initiating a turbine runback and then stabilized the plant. The workers had conducted additional troubleshooting activities without the awareness of operations and an evaluation by engineering, which did not meet the requirements of the troubleshooting procedure.

Description.

In January 2014, the condensate low pressure heater bypass trouble alarm began intermittently actuating and clearing. The licensee determined that the alarms were not valid and began efforts to troubleshoot the alarm circuit. On January 31, 2014, maintenance personnel connected electrical test equipment to the alarm circuit. This equipment remained in place for several days and was removed on February 3, 2014, after the licensee determined the problem was not in the alarm circuit. On February 4, 2014, maintenance personnel performed troubleshooting of the low pressure heater bypass alarm pressure switches.

The workers identified a problem with one of the switches and decided to continue troubleshooting on the switch. The workers initially planned to lift leads, but after examining the switch, attempted to test voltages within the switch using another tool.

Upon removing the tool, the workers inadvertently shorted the control circuitry, resulting in a blown control power fuse. This caused the low pressure heater bypass valve to fail open. In response to the valve opening, operators initiated a manual runback of the turbine from 100 percent power to approximately 70 percent power and stabilized the plant.

The licensee entered the issue into the corrective action program as Condition Report CR-2014-001268 and performed a root cause evaluation for this event. Procedure MDA-111, Maintenance Department Troubleshooting Activities, Revision 4, section 6.6 contains specific requirements for extended troubleshooting. These requirements include a formal troubleshooting plan and review and approval by an engineer. In addition, Procedure MDA-111, section 6.5 contains requirements for complex troubleshooting. These requirements also include a formal plan and additional approval and evaluation of the plan. The continued troubleshooting past the initial shift on January 31, 2014, constituted extended troubleshooting, and the decision to continue work and troubleshoot the relay in the switch constituted complex troubleshooting. The licensee determined that the workers did not contact the supervisor when the troubleshooting fell outside the definition of simple troubleshooting, and did not perform complex and extended troubleshooting with an approved plan. The licensee also identified that the work order did not include all the requirements for extended and complex troubleshooting. If the troubleshooting plan had been approved and evaluated, the risk to plant operation could have been controlled.

The inspectors reviewed the work orders, procedures, and the root cause evaluation.

The inspectors determined that the troubleshooting screening guidance was not clear in

its guidance for determining the category of troubleshooting. In addition, the inspectors determined that the work order did not contain specific information about what troubleshooting efforts were authorized for simple troubleshooting.

Analysis.

The failure to follow the troubleshooting activities procedure was a performance deficiency. The performance deficiency was more than minor because it was associated with the human performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, performing the additional troubleshooting steps without the required evaluation and notification resulted in a plant transient. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 1, Initiating Events Screening Questions, the finding was determined to be of very low safety significance (Green) because the finding did not cause a reactor trip or the loss of mitigation equipment. The finding has a human performance cross-cutting aspect associated with documentation because the licensee failed to ensure that work packages were complete and thorough and that plant activities were governed by high-quality procedures [H.7].

Enforcement.

This finding does not involve enforcement action because no violation of a regulatory requirement was identified. The licensee entered the finding into the corrective action program as Condition Report CR-2014-001268. The issue is being characterized as finding, FIN 05000446/2014005-02, Failure to Follow the Troubleshooting Activities Procedure Results in a Plant Transient.

4OA5 Other Activities

a. Inspection Scope

The inspectors evaluated the impact of financial conditions on continued safe performance at Comanche Peak. Because the licensees parent company, Energy Future Holdings, was under bankruptcy protection/reorganization during the inspection period, NRC Region IV conducted special reviews of processes at Comanche Peak.

The inspectors evaluated several aspects of the licensees operations to determine whether the financial condition of the station impacted plant safety. The factors reviewed included:

(1) impact on staffing,
(2) corrective maintenance backlog,
(3) changes to the planned maintenance schedule,
(4) corrective action program implementation, and (5)reduction in outage scope, including risk-significant modifications. In particular, the inspectors verified that licensee personnel continued to identify problems at an appropriate threshold and enter these problems into the corrective action program for resolution. The inspectors also verified that the licensee continued to develop and implement corrective actions commensurate with the significance of the problems identified.

The special review of processes at Comanche Peak included continuous reviews by the Resident Inspectors, as well as the specialist-led baseline inspections completed during the inspection period which are documented previously in this report.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On October 16, 2014, the inspectors presented the inservice inspection activities inspection results to Mr. T. McCool, Vice President, Engineering and Support, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On December 11, 2014, the inspectors presented the radiation safety inspection results to Mr. F. Madden, Director, External Affairs, and other members of the licensee staff.

The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed On January 7, 2015, the inspectors presented the resident inspection results to Mr. K. Peters, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors acknowledged review of proprietary material during the inspection. No proprietary information was documented in the report.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Flores, Senior Vice President and Chief Nuclear Officer
S. Bradley, Manager, Radiation Protection
D. Farnsworth, Director, Performance Improvement
D. Goodwin, Director, Work Management
T. Hope, Manager, Regulatory Affairs
J. Hull, Manager, Emergency Preparedness
F. Madden, Director, External Affairs
B. Mays, Assistant Chief Nuclear Officer
T. McCool, Vice President, Engineering and Support
D. McGaughey, Director, Operations
P. Passaligo, Engineering Program Manager
J. Patton, Manager, Nuclear Oversight
K. Peters, Site Vice President
B. St. Louis, Director, Nuclear Training
S. Sewell, Plant Manager
M. Stakes, Director, Maintenance
J. Taylor, Director, Site Engineering

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000446/2014005-01 NCV Failure to Follow Procedure for Boundary Valve Leakage Testing (Section 4OA3)
05000446/2014005-02 FIN Failure to Follow the Troubleshooting Activities Procedure Results in a Plant Transient (Section 4OA3)

Closed

05000446/2014-002-00 LER Both Trains of Residual Heat Removal Inoperable During Testing in Mode 3 (Section 4OA3)

Attachment 1

LIST OF DOCUMENTS REVIEWED