IR 05000445/2014004

IR 05000445/2014004, 05000446/2014004; on 06/27/2014 - 09/26/2014; Comanche Peak Units 1 & 2; Maintenance Effectiveness, Surveillance Testing, Maintenance of Emergency Preparedness, and Follow-up of Events and Notices of Enforcement Discret

ML14296A618
Person / Time
Site:	Comanche Peak
Issue date:	10/22/2014
From:	Webb Patricia Walker NRC/RGN-IV/DRP/RPB-A
To:	Flores R Luminant Generation Co
WALKER WAYNE
References
IR 2014004
Download: ML14296A618 (33)

Text

UNITED STATES ber 22, 2014

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000445/2014004 AND 05000446/2014004

Dear Mr. Flores:

On September 26, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Comanche Peak Nuclear Power Plant, Units 1 and 2. On October 1, 2014, 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 four findings of very low safety significance (Green) in this report.

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

If you contest the violations or significance of the NCVs, 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 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 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's Rules of Practice, 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, 50-446 License Nos.: NPF-87, NPF-89

Enclosure:

Inspection Report 05000445/2014004 and 05000446/2014004 w/Attachments:

Supplemental Information

REGION IV==

Docket: 05000445, 05000446 License: NPF-87, NPF-89 Report: 05000445/2014004 and 05000446/2014004 Licensee: Luminant Generation Company LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: 6322 N. FM-56, Glen Rose, Texas Dates: June 27 through September 26, 2014 Inspectors: J. Kramer, Senior Resident Inspector R. Kumana, Resident Inspector G. Guerra, CHP, Emergency Preparedness Inspector J. Melfi, Project Engineer M. Williams, Reactor Inspector Approved By: Wayne Walker Chief, Project Branch A Division of Reactor Projects-1- Enclosure

SUMMARY

IR 05000445/2014004, 05000446/2014004; 06/27/2014 - 09/26/2014; Comanche Peak Nuclear

Power Plant, Units 1 and 2; Maintenance Effectiveness, Surveillance Testing, Maintenance of Emergency Preparedness, and Follow-up of Events and Notices of Enforcement Discretion The inspection activities described in this report were performed between June 27, 2014, and September 26, 2014, by the resident inspectors at the Comanche Peak Nuclear Power Plant and inspectors from the NRCs Region IV office. Four findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations 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 an electrical installation specification and install an insulated bushing on the end of a flexible conduit. As a result, a generator current transformer conductor shorted to ground causing a generator trip and ultimately an automatic reactor trip. The licensee repaired the conductor and returned the unit to service. The licensee entered the finding into the corrective action program as Condition Report CR-2014-000579.

The failure to follow an electrical installation specification and install an insulated bushing on the end of a flexible conduit 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 shutdown as well as power operations. Using Inspection Manual Chapter 0609,

Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 1, Initiating Event Screening Questions, the finding was determined to be of very low safety significance (Green) because although the finding caused a reactor trip, it did not involve the loss of mitigation equipment. The inspectors determined that the finding was not representative of current licensee performance and no cross-cutting aspect was assigned.

(Section 4OA3)

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of 10 CFR 50.65(a)(1) for the failure to establish performance goals and perform monitoring to ensure the uninterruptible power supply air conditioning unit X-01 was capable of performing its intended function.

Specifically, the licensee failed to include unavailability hours that caused the equipment to exceed the performance criteria. The licensee planned to establish goals for the system.

The licensee entered the finding into the corrective action program as Condition Report CR-2014-010188.

The failure to establish goals and monitor the performance of the uninterruptible power supply air conditioning system was a performance deficiency. The performance deficiency was more than minor because it was associated with the equipment 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. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 2, Mitigating System Screening Questions, the finding was determined to be of very low safety significance (Green)because the finding did not represent an actual loss of safety function of a system and did not represent an actual loss of a technical specification train for greater than its allowed outage time. The finding has a human performance cross-cutting aspect associated with procedure adherence because the engineer failed to use human error reduction techniques when following procedure [H.8]. (Section 1R12)

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion XI, Test Control, for the failure to incorporate adequate acceptance limits in a written procedure to demonstrate components will perform satisfactorily. The licensee used acceptance criteria for inservice testing that did not demonstrate successful performance of the test. Specifically, the licensee failed to use appropriate acceptance limits which would have identified a failed check valve when testing auxiliary feedwater discharge check valves.

The licensee revised the inadequate test procedure. The licensee entered the finding into the corrective action program as Condition Report CR-2014-010082.

The licensees failure to incorporate adequate acceptance limits in a written procedure to demonstrate components perform satisfactorily was a performance deficiency. The finding was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. 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 be of very low safety significance (Green) because although the finding was a deficiency affecting the design or qualification of a mitigating system, the system maintained its operability and functionality. The inspectors determined that the finding was not representative of current licensee performance and no cross-cutting aspect was assigned. (Section 1R22)

Cornerstone: Emergency Preparedness

Green.

The inspectors identified a non-cited violation of 10 CFR 50.54(q)(2) for the failure to follow and maintain the effectiveness of an emergency plan that meets the requirements of planning standard 50.47(b)(4), which requires that a standard emergency classification and action level scheme is in use by the licensee. Specifically, several main steam line monitors were out of service for extended periods of time without apparent contingency actions in place in order to be able to declare an emergency. The licensee entered the finding into the corrective action program as Condition Report CR-2014-005874.

The failure to maintain a standard emergency classification and action level scheme for the initiating condition requiring the main steam line monitors was a performance deficiency.

The performance deficiency was more than minor because it affected the licensees ability to implement adequate measures to protect the health and safety of the public. Using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance

Determination Process, and Table 5.4-1, Significance Examples 50.47(b)(4), the finding was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements and was not a degraded risk significant planning standard function. The planning standard function was not degraded because of other emergency action levels; an appropriate declaration could be made in an accurate and timely manner.

This finding has a problem identification and resolution cross-cutting aspect associated with evaluation because the licensee failed to thoroughly evaluate the extent of condition of the inoperable monitors on the emergency plan and scheme for declaring emergencies [P.2].

(Section 1EP5)

PLANT STATUS

Unit 1 began the inspection period at approximately 100 percent power and operated at that power level for the entire inspection period.

Unit 2 began the inspection period at approximately 100 percent power. On July 25, 2014, the operators reduced power to approximately 94 percent power for feedwater heater maintenance.

The unit returned to approximately 100 percent power on 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, Barrier Integrity

1R01 Adverse Weather Protection

.1 Summer Readiness for Offsite and Alternate Power Systems

a. Inspection Scope

The inspectors completed an inspection of the stations off-site and alternate-ac power systems. The inspectors observed the material condition of these systems, including transformers and other switchyard equipment to verify that plant features and procedures were appropriate for operation and continued availability of off-site and alternate-ac power systems. The inspectors reviewed work orders and condition reports for these systems. The inspectors performed a walkdown of the switchyard to observe the material condition of equipment providing off-site power sources. The inspectors assessed corrective actions for identified degraded conditions and verified that the licensee had considered the degraded conditions in its risk evaluations and had established appropriate compensatory measures. The inspectors verified that the licensees procedures included appropriate measures to monitor and maintain availability and reliability of the offsite and alternate power systems.

These activities constituted one summer readiness of offsite and alternate power systems sample as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.2 Readiness to Cope with External Flooding

a. Inspection Scope

On September 16, 2014, the inspectors completed an inspection of the stations readiness to cope with external flooding. The inspectors performed a system walkdown of the Units 1 and 2, and common area building roofs. The inspectors reviewed the licensees design drawings and supporting calculations, and the periodic maintenance and inspection reports, to verify the systems were constructed and perform as designed.

The inspectors verified that roof systems provide adequate drainage to prevent overloading of the roof structures during the probable maximum precipitation event.

These activities constituted one readiness to cope with external flooding sample as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment

a. Inspection Scope

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

• July 24, 2014, Unit 1, safety chiller 1-06, residual heat removal pump 1-02, safety injection pump 1-02, and containment spray pump 1-02 when safety chiller 1-05 was unavailable due to maintenance

• August 13, 2014, Unit 1, auxiliary feedwater pumps 1-01 and 1-02 when the turbine driven auxiliary feedwater pump was unavailable due to maintenance

• August 28, 2014, Unit 1, turbine driven auxiliary feedwater pump and motor driven auxiliary feedwater pump 1-01 when motor driven auxiliary feedwater pump 1-02 was unavailable for maintenance 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 three partial system walkdown samples 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:

• August 28, 2014, Unit 1, fire zone 1SB15, containment access corridor

• August 28, 2014, Unit 2, fire zone 2SB15, containment access corridor

• September 9, 2014, Unit 1, fire area 1SK, main steam and feedwater penetration

• September 9, 2014, Unit 2, fire area 2SK, main steam and feedwater penetration

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 four quarterly fire protection samples as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed licensee programs to verify heat exchanger performance and operability for the following heat exchangers:

• Residual heat removal heat exchanger 1-01

• Containment spray heat exchanger 2-02

• Centrifugal charging pump lube oil coolers 2-01 and 2-02

• Spent fuel pool heat exchanger X-01 The inspectors verified whether testing, inspection, maintenance, and chemistry control programs are adequate to ensure proper heat transfer. The inspectors verified that the periodic testing and monitoring methods, as outlined in commitments to NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment, utilized proper industry heat exchanger guidance. Additionally, the inspectors verified that the licensees chemistry program ensured that biological fouling was properly controlled between tests. The inspectors reviewed previous maintenance records of the heat exchangers to verify that the licensees heat exchanger inspections adequately addressed structural integrity and cleanliness of their tubes. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four triennial heat sink performance samples as defined in Inspection Procedure 71111.07.

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 August 25, 2014, the inspectors observed a simulator scenario performed by 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 scenario.

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. The inspectors observed the operators performance of the following activities:

• July 25, 2014, Unit 2, 75 megawatt electric power reduction for secondary valve maintenance

• July 25, 2014, Unit 1, swapping the running component cooling water pumps and centrifugal charging pumps In addition, the inspectors assessed the operators adherence to plant procedures, including the conduct of operations procedure and other operations department policies.

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.

• Units 1 and 2 uninterruptible power supply air conditioning unit X-01

• Unit 1 component cooling water

• Unit 2 component cooling water 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.

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

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR 50.65(a)(1)for the licensees failure to establish performance goals and perform monitoring to ensure the uninterruptible power supply air conditioning unit X-01 was capable of performing its intended function. Specifically, the licensee failed to include unavailability hours that caused the equipment to exceed the performance criteria.

Description.

On June 25, 2014, the inspectors reviewed the unavailability hours for the uninterruptible power supply air conditioning unit X-01. The technical aspects and associated finding relative to the failure of the uninterruptible power supply air conditioning unit X-01 were described in the previous quarterly integrated inspection report Section 4OA2.2 (05000445/2014003; 05000446/2014003 - ADAMS Accession No. ML14218A072). In this inspection period, the inspectors identified that the licensee did not include approximately 230 hours0.00266 days <br />0.0639 hours <br />3.80291e-4 weeks <br />8.7515e-5 months <br /> for periods of unavailability in the months of March and April 2013. The inspectors informed the system engineer of the observation.

The system engineer acknowledged that the unavailability hours were not documented for the component and the performance criteria for unavailability were exceeded.

The inspectors discussed the cause of the event with the licensee. The inspectors determined that the engineer failed to properly link events in accordance with Procedure STA-744, Maintenance Effectiveness Monitoring Program, Revision 6, Attachment 8.8, Maintenance Effectiveness Monitoring Guide, step 2.3.3, Event Linking, and therefore did not include 230 hours0.00266 days <br />0.0639 hours <br />3.80291e-4 weeks <br />8.7515e-5 months <br /> of unavailability time. The inspectors determined that the engineer did not use proper human error reduction techniques when entering the unavailability time.

Analysis.

The failure to establish goals and monitor the performance of the uninterruptible power supply air conditioning system was a performance deficiency. The performance deficiency was more than minor because it was associated with the equipment 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. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 2, Mitigating System Screening Questions, the finding was

determined to be of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; did not represent an actual loss of a technical specification train for greater than its allowed outage time; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The finding has a human performance cross-cutting aspect associated with procedure adherence because the engineer failed to use human error reduction techniques when following procedure [H.8].

Enforcement.

Title 10 CFR 50.65(a)(1) requires, in part, that licensee shall monitor the performance of systems within the scope of the rule against licensee-established goals in a manner sufficient to provide reasonable assurance that such systems are capable of fulfilling their intended safety functions. Contrary to the above, on June 25, 2014, the licensee failed to monitor the performance of systems within the scope of the rule against licensee-established goals in a manner sufficient to provide reasonable assurance that systems are capable of fulfilling their intended safety functions. Specifically, the licensee failed to demonstrate that the performance of the uninterruptible power supply air conditioning system had been effectively controlled through the performance of appropriate preventive maintenance and did not monitor the system against licensee-established goals. As part of corrective actions, the licensee planned to establish goals for the system. Since the violation was of very low safety significance and was documented in the licensees corrective action program as Condition Report CR-2014-010188, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000445/2014004-01; 05000446/2014004-01, Failure to Establish Goals and Monitor the Performance of the Uninterruptible Power Supply Air Conditioning System.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensees evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed when removing equipment for work:

• June 30, 2014, Unit 2, service water pump 2-02 maintenance

• July 24, 2014, Unit 1, safety chill water pump 1-05 corrective maintenance

• August 13, 2014, Unit 1, emergent work on steam supply valve to the turbine driven auxiliary feedwater pump valve HV-2452-1

• September 25, 2014, Unit 1, outage risk assessment and management of orange risk operations 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 four 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-2014-002543, Unit 1, failure of digital rod position indication for control rod E13

• Condition Report CR-2014-006510, Unit 1, diesel generator 1-02 turbo charger gasket leak

• Condition Report CR-2014-008903, Units 1 and 2, technical support center doors out of position

• Condition Report CR-2014-009517, Unit 1, turbine driven auxiliary feedwater pump trip and throttle valve 1-HV-2452 tappet engagement

• Condition Report CR-2014-010278, Unit 1, safety injection pump 1-01 low service water flow 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 a permanent plant modification associated with the post-Fukushima spent fuel pool level instrumentation. The inspectors reviewed the design and implementation of the modification and specifically final design

authorization 13-008-25. The inspectors verified that the activities involved in implementing the modification 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 plant modifications sample 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:

• June 30, 2014, Unit 2, testing of station service water pump 2-02 discharge header cross-connect valve XSW-0029 following valve repair

• August 13, 2014, Unit 1, accumulator testing following repair of pressure regulator for main steam line 1-04 supply valve to turbine driven auxiliary feedwater pump 1-01

• September 4, 2014, Unit 1, residual heat removal pump 1-01 testing following breaker and pump maintenance

• September 11, 2014, Unit 1, turbine driven auxiliary feedwater pump 1-01 discharge to steam generator 1-01 isolation valve 2491A testing following breaker maintenance 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.

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

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:

Pump or Valve Inservice Test

• August 28, 2014, Unit 1, inservice test of auxiliary feedwater pump 1-02 in accordance with Procedure OPT-206A, AFW System, Revision 29 Other Surveillance Testing

• February 27, 2014, Unit 2, auxiliary feedwater pump 2-01 discharge check valve testing in accordance with Procedure OPT-206B, AFW System, Revision 21

• August 20, 2014, Unit 1, diesel generator 1-02 testing in accordance with Procedure OPT-214A, Diesel Generator Operability Test, Revision 22

• September 8, 2014, Units 1 and 2, acceptable movement of fuel and final spent fuel pool storage configuration in accordance with: Procedure NUC-211, SFP Storage Limitations for Reactivity Control, Revision 6; license amendment 162; Technical Specification 3.7.17, Spent Fuel Assembly Storage; and confirmatory action letter 4-12-004 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 (one pump or valve inservice testing sample, and three other surveillance testing samples) as defined in Inspection Procedure 71111.22.

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for the licensees failure to incorporate adequate acceptance limits in a written procedure to demonstrate components will perform satisfactorily. The licensee used acceptance criteria for inservice testing that did not demonstrate successful performance of the test.

Description.

The inspectors observed licensee performance of inservice testing of the motor driven auxiliary feedwater pump 2-01 discharge check valve 2AF-0065. The licensee performed this test by connecting a test rig from the demineralized water header to a point downstream of the check valve and connected a vent hose to the pump casing upstream of the check valve. The licensee measured the differential pressure across the valve by reading the pressure from a test gauge attached to the rig and determined whether the valve was closed by ensuring a sufficiently high differential

pressure existed. This is an acceptable method for performing the test in accordance with American Society of Mechanical Engineers code.

The inspectors observed that the licensees test procedure used a value of 40 pounds per square inch on the test gauge as the acceptance criteria for the test. The procedure also stated that flow from the vent was acceptable because the test was not required to demonstrate that the valve did not leak. The inspectors observed that the pressure on the gauge was 130 pounds per square inch, corresponding to the nominal pressure of the demineralized water system, and questioned why a pressure as low as 40 pounds per square inch was acceptable.

The licensee was unable to provide an adequate technical basis for the 40 pounds per square inch test acceptance criteria. The licensee performed calculations to determine the indicated pressure on the gauge with a failed open valve or missing check valve.

The licensee determined that, if the valve had failed open with a demineralized water header pressure of 130 pounds per square inch, the pressure would indicate approximately 80 pounds per square inch on the test gauge. The inspectors determined that the test acceptance criteria were invalid because the physical test configuration ensured successful results even if the check valve failed fully open. The valve could also pass the test if the check valve disc had detached, a condition that is described in NRC Information Notice 2000-21, Detached Check Valve Disc Not Detected by Use of Acoustic and Magnetic Nonintrusive Test Techniques.

The inspectors reviewed past performances of the test. The inspectors determined that the historical test data was sufficient to demonstrate that the discharge check valves were still intact. The inspectors also determined that the test had been performed using the inadequate acceptance limits since September 2005.

Analysis.

The licensees failure to incorporate adequate acceptance limits in a written procedure to demonstrate components perform satisfactorily was a performance deficiency. The finding was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. 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 be of very low safety significance (Green) because although the finding is a deficiency affecting the design or qualification of a mitigating system, the system maintained its operability and functionality. The inspectors determined that the finding was not representative of current licensee performance and no cross-cutting aspect was assigned.

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires, in part, that a test program shall be established to assure that all testing required to demonstrate components will perform satisfactorily in service is identified and performed in accordance with written procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Contrary to the above, from September 2005, to August 28, 2014, the licensee failed to incorporate adequate acceptance limits in a quality-related written procedure that demonstrates components will perform satisfactorily. Specifically, the licensee failed to use appropriate acceptance limits when testing auxiliary feedwater discharge check valves. The licensee revised the

inadequate test procedure. Since the violation was of very low safety significance and was documented in the licensees corrective action program as Condition Report CR-2014-010082, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000445/2014004-02; 05000446/2014004-02, Inadequate Acceptance Criteria for Inservice Testing of Auxiliary Feedwater Discharge Check Valves.

1EP5 Maintenance of Emergency Preparedness

a. Inspection Scope

The inspectors reviewed licensee-provided information regarding Unresolved Item 05000445/2014003-03; 05000446/2014003-03, Maintenance of a Standard Action Level Scheme for Main Steam Line Monitors, to determine if the licensee had adequately implemented planning standard 10 CFR 50.47(b)(4) and if the emergency action level initiating condition was rendered ineffective such that any general emergency would not be declared for a particular off-normal event in an accurate and timely manner or in a degraded manner. This unresolved item is closed.

These activities do not constitute completion of any additional maintenance of emergency preparedness samples as defined in Inspection Procedure 71114.05.

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR 50.54(q)(2)for the licensees failure to follow and maintain the effectiveness of an emergency plan that meets the requirements of planning standard 50.47(b)(4), which requires that a standard emergency classification and action level scheme is in use by the licensee.

Specifically, several main steam line monitors were out of service for extended periods of time without apparent contingency actions in place in order to be able to declare an emergency.

Description.

On November 20, 2013, the licensee initiated Condition Report CR-2013-011914 identifying that the main steam line radiation monitors had a trend of being out-of-service for significant time periods. Monitor 1-RE-2328 was out of service for 110 and 210 days on two separate occasions; Monitor 1-RE-2326 was out of service for 77 and 157 days on two separate occasions; and Monitor 1-RE-2325 was out of service for 61 days. Four other monitors from the two units had been out of service, some more than once, for periods of five days or less. There are four online main steam line monitors for each unit. The licensee addressed the trend by trouble-shooting, repairing, and replacing detectors.

The main steam line radiation monitors are important to emergency preparedness because they are inputs into the emergency action level scheme for defining the initiating conditions related to abnormal radiation releases/radiation effluent emergency declarations. The emergency action level scheme has initiating conditions for unusual event through general emergency. Procedure EPP-201, EAL Technical Bases, Revision 0, implements the licensees emergency classification scheme.

The inspectors determined that the licensee had taken appropriate action to initiate corrective action and repair. The licensee also tracked the out-of-service time of the monitors as operational focus items and in the station tactical equipment issues list. All eight main steam line monitors are currently in service with zero out of service days in 2014. However, there was no evidence that contingency actions were implemented to maintain the approved emergency action level scheme when the monitors were out of service.

The action level scheme was impacted because several main steam line monitors were out of service for extended periods of time without apparent contingency actions in place. However, because of other emergency action levels, an appropriate emergency declaration could still be made in an accurate and timely manner. The inspectors determined that the licensee failed to thoroughly evaluate the extent of condition of the inoperable monitors on the emergency plan and emergency action level scheme for declaring emergencies.

Analysis.

The failure to maintain a standard emergency classification and action level scheme for the initiating condition requiring the main steam line monitors was a performance deficiency. The performance deficiency was more than minor because it affected the licensees ability to implement adequate measures to protect the health and safety of the public. Using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, and Table 5.4-1, Significance Examples 50.47(b)(4), the finding was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements and was not a degraded risk significant planning standard function. The planning standard function was not degraded because of other emergency action levels; an appropriate declaration could be made in an accurate and timely manner. This finding has a problem identification and resolution cross-cutting aspect associated with evaluation because the licensee failed to thoroughly evaluate the extent of condition of the inoperable monitors on the emergency plan and scheme for declaring emergencies [P.2].

Enforcement.

Title 10 CFR 50.54(q)(2) requires licensees to follow and maintain the effectiveness of an emergency plan that meets the requirements of the planning standards of 50.47(b). Planning standard 50.47(b)(4), requires, in part, that a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the licensee. Contrary to the above, between April 2011 and December 2013, the licensee failed to maintain the effectiveness of its emergency plan when inoperable main steam line monitors rendered ineffective the emergency action level initiating condition. Specifically, several main steam line monitors were out of service for lengthy periods without contingency actions in place. Since the violation was of very low safety significance and was documented in the licensees corrective action program as Condition Report CR-2014-005874, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000445/2014004-03; 05000446/2014004-03, Maintenance of a Standard Action Level Scheme for Main Steam Line Monitors.

1EP6 Drill Evaluation

a. Inspection Scope

On August 6, 2014, the inspectors observed an emergency preparedness drill to verify the adequacy and capability of the licensees assessment of drill performance. The inspectors reviewed the drill scenario, observed the drill from the simulator and emergency operations facility, and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.

These activities constitute completion of one drill/training evolution observation sample as defined in Inspection Procedure 71114.06.

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: Emergency AC Power Systems (MS06)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of July 2013 through June 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 emergency ac power systems performance indicator samples, one per unit, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index: High Pressure Injection Systems (MS07)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of July 2013 through June 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 high pressure injection systems performance indicator samples, one per unit, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Mitigating Systems Performance Index: Heat Removal Systems (MS08)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of July 2013 through June 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 heat removal 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 Annual Follow-up of Selected Issues

a. Inspection Scope

On September 6, 2014, the inspectors performed an in-depth follow-up of the Unit 1 cumulative effects of operator workarounds and burdens to determine the reliability, availability, and potential for incorrect operation of systems or components. The inspectors verified the ability of operators to respond in a correct and timely manner to plant transients and accidents, and if the licensee had identified and implemented appropriate corrective actions associated with operator workarounds.

These activities constitute completion of one annual operator work-around sample as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

.3 Semiannual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees gas intrusion program. Specifically, the inspectors reviewed condition reports, drawings, and supporting calculations associated with the program. The inspectors discussed the program with engineering.

The inspectors verified that the licensee was maintaining adequate program actions to prevent negative impact of gas voids on systems important to safety at the plant.

These activities constitute completion of one semiannual trend review 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 one follow-up of events and notices of enforcement discretion sample as defined in Inspection Procedure 71153.

(Closed) Licensee Event Report 05000445/2014-001-00, Unit 1 Automatic Reactor Trip Due to Generator Lockout Relay Trip

a. Inspection Scope

The inspectors performed a review of a licensee event report documenting the Unit 1 automatic reactor trip that occurred on January 18, 2014. The inspectors examined associated procedures, work orders, condition reports, and the licensees apparent cause analysis of the event.

b. Findings

Introduction.

The inspectors reviewed a Green self-revealing finding for the licensees failure to follow an electrical installation specification and install an insulated bushing on the end of a flexible conduit. As a result, a generator current transformer conductor shorted to ground causing a generator trip and ultimately an automatic reactor trip.

Description.

On January 18, 2014, as a result of vibration of the conduit and current transformer wire, the current transformer phase A wire shorted through the insulation causing a generator trip and subsequent turbine trip and automatic reactor trip. The licensee determined that the configuration of the conduit and wire was unique, in that, a flexible conduit was used and was not secured due to the configuration of the area. In addition, the area experienced high vibration and high air flow. The method of installation of the wire in combination of the vibrational environment resulted in the failure of the insulation on the wire.

In October 2002, the licensee performed a maintenance activity on the main generator to shorten a current transformer flexible conduit and wire. Although the maintenance work instruction did not specify to include an insulated bushing on the end of a flexible conduit, an electrical specification required the bushing. Specification 2323-ES-100, Electrical Installation, Revision 33, step 3.3.5.12, provides the requirements on when to install an insulated bushing. The licensee determined that the specification was not followed, in that, the flexible conduit was not securely attached at its end point and no insulated bushing was installed.

Analysis.

The licensees failure to follow an electrical installation specification and install an insulated bushing on the end of a flexible conduit 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 shutdown as well as power operations. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 1, Initiating Event Screening Questions, the finding was determined to be of very low safety significance (Green) because although the finding caused a reactor trip, it did not involve the loss of mitigation equipment. The inspectors determined that the finding was not representative of current licensee performance and no cross-cutting aspect was assigned.

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-2014-000579. The issue is being characterized as finding, FIN 05000445/2014004-04; Failure to Install an Insulated Bushing on a Generator Current Transformer Circuit Results in an Automatic Reactor Trip.

4OA5 Other Activities

a. Inspection Scope

The inspectors evaluated the impact of financial conditions on continued safe performance at Comanche Peak. In that 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

Exit Meeting Summary

On July 10, 2014, the inspectors presented results of the triennial heat sink performance inspection to Mr. T. McCool, Vice President, Engineering and Support, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On July 31, 2014, the inspectors presented the results of the inspection of the emergency preparedness program 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 October 1, 2014, 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. 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, Performance Improvement

B. Moore, Director, Nuclear Training

K. Nickerson, Director, Engineering Support

B. Patrick, Director, Maintenance

J. Patton, Manager, Nuclear Oversight

K. Peters, Site Vice President

B. Reppa, Director, Site Engineering

S. Sewell, Plant Manager

M. Smith, Director, Nuclear Operations

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000445/2014004-01 NCV Failure to Establish Goals and Monitor the Performance of

05000446/2014004-01 the Uninterruptible Power Supply Air Conditioning System (Section 1R12)

05000445/2014004-02 NCV Inadequate Acceptance Criteria for Inservice Testing of

05000446/2014004-02 Auxiliary Feedwater Discharge Check Valves (Section1R22)

05000445/2014004-03 NCV Maintenance of a Standard Action Level Scheme for Main

05000446/2014004-03 Steam Line Monitors (Section 1EP5)

05000445/2014004-04 FIN Failure to Install an Insulated Bushing on a Generator Current Transformer Circuit Results in an Automatic Reactor Trip (Section 4OA3)

Closed

05000445/2014003-03 URI Maintenance of a Standard Action Level Scheme for Main

05000446/2014003-03 Steam Line Monitors (Section 1EP5)

05000445/2014-001-00 LER Unit 1 Automatic Reactor Trip Due to Generator Lockout Relay Trip (Section 4OA3)

Attachment