Text

Plant Performance Review - Comanche Peak Steam Electric Station
	ML003699046
Person / Time
Site:	Comanche Peak
Issue date:	03/31/2000
From:	Tapia J; NRC/RGN-IV/DRP/RPB-A
To:	Terry C; TXU Electric
References
	Download: ML003699046 (27)
	v • d • e

4 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 76011-8064 years March 31, 2000 Mr. C. L. Terry TXU Electric Senior Vice President & Principal Nuclear Officer ATTN: Regulatory Affairs Department P.O. Box 1002 Glen Rose, Texas 76043

SUBJECT:

PLANT PERFORMANCE REVIEW - COMANCHE PEAK STEAM ELECTRIC STATION

Dear Mr. Terry:

The purpose of this letter is to communicate our assessment of your performance and to inform you of our planned inspections at your facility. On March 2, 2000, we completed a Plant Performance Review (PPR) of Comanche Peak Steam Electric Station. We conduct these reviews to develop an integrated overview of the safety performance of each operating nuclear power plant. We use the results of the PPR in planning and allocating inspection resources and as inputs to our senior management meeting (SMM) process. This PPR evaluated inspection results and safety performance information for the period from January 25, 1999, through February 11, 2000, but emphasized the last 6 months to ensure that our assessment reflected your current performance. Our most recent summary of plant performance at Comanche Peak Steam Electric Station was provided to you in a letter dated September 16, 1999.

The NRC has been developing a revised reactor oversight process that will replace our existing inspection and assessment processes, including the PPR, SMM, and Systematic Assessment of Licensee Performance (SALP). We recently completed a pilot program for the revised reactor oversight process at nine participating sites and are making necessary adjustments based on feedback and lessons learned. We are beginning initial implementation of the revised reactor oversight process industry-wide, including your facility, on April 2, 2000.

This PPR reflects continued process improvements as we make the transition into the revised reactor oversight process. You will notice that the following summary of plant performance is organized differently from our previous performance summaries. Instead of characterizing our assessment results by SALP functional area, we are organizing the results into the strategic arenas embodied in the revised reactor oversight process. Additionally, in assessing your performance we have considered the historical performance indicator data that you submitted in January 2000 in conjunction with the inspection results. The results of this PPR were used to establish the inspection plan in accordance with the new risk-informed inspection program (consisting of baseline and supplemental inspections). Although this letter incorporates some terms and concepts associated with the new oversight process, it does not reflect the much T-eA)-

PL C- 00ý

TXU Electric broader changes in inspection and assessment that will be evident after we have fully implemented our revised reactor oversight process.

During the last 6 months, both units of Comanche Peak Steam Electric Station operated at or near full power until Unit 1 was shut down for refueling. Although the NRC noted some minor performance issues during this assessment period, Comanche Peak Steam Electric Station continues to operate in a safe manner.

We did not identify any significant performance issues in the reactor safety, radiation safety, or safeguards strategic arenas. We did note that you were challenged during the Unit 1 refueling outage by the failure of an electric hoist and subsequent drop of a reactor coolant pump motor.

This was inspected in detail by the resident staff. Based on our assessment, only baseline inspections are planned. contains a historical listing of plant issues, referred to as the Plant Issues Matrix (PIM), that were used during this PPR process to arrive at our integrated view of your performance trends. The PIM for this assessment is grouped by the prior SALP functional areas of operations, maintenance, engineering, and plant support, although the future PIM will be organized along the cornerstones of safety as described in the revised reactor oversight process. The enclosed PIM includes items summarized from inspection reports or other docketed correspondence regarding Comanche Peak Steam Electric Station. We did not document all aspects of licensee programs and performance that may be functioning appropriately. Rather, we only documented issues that we believe warrant management attention or represent noteworthy aspects of performance. In addition, the PPR may also have considered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since our last inspection report was issued but had not yet received full review and consideration. We will make this material publically available as part of the normal issuance of our inspection reports and other correspondence. lists our planned inspections for the period April 2000 through March 2001 at Comanche Peak Steam Electric Station to allow you to resolve scheduling conflicts and personnel availability in advance of our inspector arrival onsite. The inspection schedule for the latter half of the period is more tentative and may be adjusted in the future due to emerging performance issues at Comanche Peak Steam Electric Station or other Region IV facilities.

Routine resident inspections are not listed due to their ongoing and continuous nature.

We will inform you of any changes to the inspection plan. If you have any questions, please contact me at (817) 860-8243.

Sincerely, Josep

. apia, C~

Project Branch A Division of Reactor Projects TXU Electric Docket Nos.: 50-445 50-446 License Nos.: NPF-87 NPF-89

Enclosures:

1. Plant Issues Matrix

2. Inspection Plan cc w/enclosures:

Roger D. Walker TXU Electric Regulatory Affairs Manager P.O. Box 1002 Glen Rose, Texas 76043 Juanita Ellis President - CASE 1426 South Polk Street Dallas, Texas 75224 George L. Edgar, Esq.

Morgan, Lewis & Bockius 1800 M. Street, NW Washington, D.C. 20036 G. R. Bynog, Program Manager/

Chief Inspector Texas Department of Licensing & Regulation Boiler Division P.O. Box 12157, Capitol Station Austin, Texas 78711 County Judge P.O. Box 851 Glen Rose, Texas 76043 Chief, Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin, Texas 78756-3189 John L. Howard, Director Environmental and Natural Resources Policy Office of the Governor P.O. Box 12428 Austin, Texas 78711-3189 TXU Electric Sheriff, Somervell County 1505 Northeast Big Bend Trail Glen Rose, Texas 76043 Mayor of Glen Rose P.O. Box 87 Glen Rose, Texas 76043 The Honorable Don Cleveland County Court Room 7 Granbury, Texas 76048 Mayor of Granbury P.O. Box 969 Granbury, Texas 76048 Federal Emergency Management Agency R. L. Young, Regional Director Region VI, Federal Center 800 North Loop 288 Denton, Texas 76201-3698 Public Utility Commission William B. Travis Bldg.

P.O. Box 13326 1701 North Congress Avenue Austin, Texas 78701-3326 MAR 31I 2000 TXU Electric

-5 bcc to DCD (IE40) bcc electronic distribution from ADAMS by RIV:

Regional Administrator (EWM)

DRP Director (KEB)

DRS Director (ATH)

Senior Resident Inspector (ATG)

Branch Chief, DRP/A (JIT)

Senior Project Engineer, DRP/A (DNG)

Branch Chief, DRPITSS (LAY)

RITS Coordinator (NBH)

B. Henderson, PAO (BWH)

C. A. Hackney, RSLO (CAH)

C. J. Gordon (CJG)

DRS Branch Chiefs (GMG, DAP, JLP)

W. D. Travers, EDO (WDT)

W. M. Dean, Chief, NRR/DIPM/IIPB (WMD)

R. K. Frahm, PPR Program Manager, NRR/ILPB (RKF)

B. A. Boger, Associate Dir. for Inspection and Programs (BAB2)

B. W. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)

G. M. Tracy, Chief, Regional Operations Staff, OEDO (GMT)

S. Richards, NRR Project Director (SAR)

R. Gramm, Chief, Section 1, NRR/DLPM (RAG)

D. H. Jaffe, NRR Project Manager (DHJ) bcc hard copy:

RIV File Room Records Center, INPO DOCUMENT NAME: S:\\PPR 2000-01\\PPR Letters\\CP.wpd To receive copy of document, indicate inbox: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:C:DRP/A A D:DR.

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SignatureA JITapia;df ATH e

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TXU Electric 3 2000 bcc to DCD (IE40) bcc electronic distribution from ADAMS by RIV:

Regional Administrator (EWM)

DRP Director (KEB)

DRS Director (ATH)

Senior Resident Inspector (ATG)

Branch Chief, DRP/A (JIT)

Senior Project Engineer, DRP/A (DNG)

Branch Chief, DRP/TSS (LAY)

RITS Coordinator (NBH)

B. Henderson, PAO (BWH)

C. A. Hackney, RSLO (CAH)

C. J. Gordon (CJG)

DRS Branch Chiefs (GMG, DAP, JLP)

W. D. Travers, EDO (WDT)

W. M. Dean, Chief, NRR/DIPM/IIPB (WMD)

R. K. Frahm, PPR Program Manager, NRR/ILPB (RKF)

B. A. Boger, Associate Dir. for Inspection and Programs (BAB2)

B. W. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)

G. M. Tracy, Chief, Regional Operations Staff, OEDO (GMT)

S. Richards, NRR Project Director (SAR)

R. Gramm, Chief, Section 1, NRR/DLPM (RAG)

D. H. Jaffe, NRR Project Manager (DHJ) bcc hard copy:

RIV File Room Records Center, INPO DOCUMENT NAME: S:\\PPR 2000-01\\PPR Letters\\CP.wpd To receive copy of document, indicate inIox: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:C:DRP/A

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OFFICIAL RECORD COPY

Page:

1 of 19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description 10/02/1999 1999015 Pri: OPS Licensee POS Pri: 1B Good operator performance during a plant transient.

Sec:

Sec: 3B Contract workers erecting scaffolding dropped a scaffold pole on the Unit 1 moisture separator reheater drain tank Dockats Discussed:

alternate drain valve and it failed open. Operators responded well by isolating the failed-open valve and reducing Dockets Domancu e: PTer:

main turbine load.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 09/30/1 999 1999015 Pri: OPS NRC POS Pri: 1B Good operator performance during midloop operations.

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 Sec: 3B Control room operators performed well during the draindown and midloop operations in Unit 1. Reactor coolant system level was monitored on all available instruments which performed as designed. An additional reactor Tar:

operator was stationed in the control room to monitor the residual heat removal system. This reduced the burden on the reactor operator and allowed him to concentrate on reactor coolant system level indications. Distractions to the operators were kept to a minimum.

08/21/1999 1999014 Pri: OPS Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 NRC POS Pri: 1B Sec: 38 Ter:

Good performance by control room operators.

Operators conducted themselves in accordance with procedures, training, and licensee management expectations.

Communications were formal, clear, and concise and repeat-backs were observed to be enforced by everyone involved. Operators consistently reviewed alarm reference procedures when unexpected alarms were received.

Operators scanned the control boards at the appropriate frequency and operators demonstrated a questioning attitude for unexpected indications. Operating logs were clear and concise. Entry into Technical Specification Limiting Conditions for Operation were properly documented and the duration was appropriately minimized through effective planning and scheduling.

U0/10/1999 1999012 Pri: OPS Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 NRC NEG Pri: 1A Operators did not enter 4-hour shutdown action statement for feedwater isolation valve.

Sec: 3B Operators were generally attentive to the control boards and demonstrated a questioning approach towards routine plant operations. Control room operators did not enter a 4-hour shutdown action statement for a feedwater isolation Tar:

valve which operated abnormally during a surveillance test. Although the licensee was able to demonstrate operability before the 4-hour allowed outage time would have expired, this demonstrated a departure from the licensee's typically conservative decision making.

06/24/1999 1999301 Pri: OPS Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 NRC POS Pri: 1C Sec:

Ter:

The six applicants for senior operator licenses passed their examinations.

The six applicants for senior operator licenses passed their examinations. Applicants demonstrated effective oversight and adequate communication techniques during the dynamic scenarios.

05/29/1999 1999011 Pri: OPS Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 NRC POS Pri: 1B Control room operators responded well to the loss of the Unit 2, Train A safeguards bus.

Sec:

Control room operators responded well to the loss of the Unit 2, Train A safeguards bus on May 22, The licensee Ter:

was unable to determine the root cause of the event.

Item Type (Compliance,Followup,Other), From 01/25/1999 To 02/11/2000 Sec:

Page: 2of19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description 05/29/1999 1999011 Pri: OPS NRC POS Pri: 1B Operators performed the restart of Unit 2 in accordance with applicable procedures.

Sec:

Sec: 2A During the restart of Unit 2 following the fourth refueling outage, operators performed the return to full power in Dockets Discussed:

T accordance with applicable procedures. Restoration and cleanup following the outage was completed in a timely 05000445 Comanche Peak 1Ter:

manner, with plant equipment in good material condition and properly aligned for normal power operations.

05000446 Comanche Peak 2 05/11/1999 1999008 Pri: OPS NRC POS Pri: 3B Plant personnel had a good understanding of the corrective action program.

Sec:

Plant personnel had a good understanding of the corrective action program. While all personnel were cognizant of Dockets Discussed:

T the reporting requirements, some personnel (e.g., contractor personnel), due to their limited knowledge of the Dockets Doacused: PTer:

process, used a team approach for reporting deviations through their supervision. The implementation of the 05000445 Comanche Peak 1 manual SmartForm process allowed personnel to report deviations without use of the computerized system.

05000446 Comanche Peak 2 05/11/1999 1999008 Pri: OPS NRC POS Pri: 5B Corrective action program priorities were appropriate and self-assessments were thorough.

Sec:

Corrective action program priorities were appropriate. Self assessments were thorough and intrusive, and the Dkts Discussed:

subsequent corrective actions identified by the audits were either already corrected or properly tracked for Dockets Dische Ter:

resolution.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 05/11/1999 1999008 Pri: OPS NRC POS Pri: 5B Nonclted violations were properly entered into the corrective action program.

Sec:

Noncited violations were properly entered into the corrective action program and were being resolved in a timely and Dockets Discussed:

Ter:

technically adequate manner.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 05/11/1999 1999008 Pri: OPS NRC STR Pri: iC Corrective action program was effective and personnel understood the importance of the program.

Sec:

The corrective action program was found to be effective at identifying, resolving and preventing issues that degrade the quality of plant operations. It was noted that both site personnel and management clearly understood the Dockets Discussed:

Ter:

importance of this program. However, there were some examples where the corrective action program controlling 05000445 Comanche Peak 1 procedures were either lacking in guidance or had inappropriate guidance. In spite of these procedure guidance 05000446 Comanche Peak 2 problems, it was found that issues were being conservatively addressed. No issues were identified, that were not already entered into the corrective action program, that was caused by these procedure guidance problems.

04/17/1999 1999007 Pri: OPS NRC POS Pri: 1A Operations response to repeated failures of the SG FRV controls was consistent and minimized transients.

Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 Sec:

Operators responded to repeated failures of the Steam Generator 1-02 feedwater regulating valve control system in a consistent manner that minimized the plant transients. After faulty control cards were replaced, no further failures Ter:

occurred.

Item Type (Compliance,Followup,Other), From 01/25/1999 To 02/11/2000

Page:

3 of 19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description 04/17/1999 1999007 Pri: OPS NRC POS Pri: 1B Shutdown for 4th Unit 2 refueling outage and cooldown of surge line were well controlled.

Sec:

The conduct of operations reflected a conservative decision-making policy. Both units were operated by Dockets Discussed:

Ter:

knowledgeable operators using good self-verification and peer-checking techniques and communications. The shutdown for the fourth Unit 2 refueling outage was well controlled and, in contrast with past shutdowns for refueling 05000445 Comanche Peak 1 outages, did not end in a reactor trip. The Unit 2 solid plant cooldown from 350 0 F to Mode 5 (less than 200 0 F) 05000446 Comanche Peak 2 allowed better control of pressurizer surge line cooldown rates and was conducted without error. This was the first time operators conducted this procedure and the lack of errors was attributed to effective self-and peer-verification and training.

04/17/1999 1999007 Pri: OPS NRC POS Pri: 1B Delay in drain down to mid-loop was conservative and minimized time in reduced inventory.

Sec:

Mid-loop activities were conducted in accordance with procedures and were uneventful. Pre-evolution briefings were comprehensive. Management demonstrated conservative decision-making when the reactor coolant system Dockets Discussed:

Ter:

drain down was delayed until after shift turnover. This minimized the time spent in a reduced inventory condition.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 03/06/1999 1999003 Pri: OPS NRC POS Pri: 1A The operations department has become more demanding of engineering's operability determinations.

Sec:

The operations department has become more demanding of support organizations concerning operability determinations on safety-related equipment. This was demonstrated by their questioning attitude toward failure of Dockets Discussed:

Ter:

Channel 3 of the Unit 1 N-1 6 instrument. This was a noted improvement over past instances of accepting 05000445 Comanche Peak 1 equipment as operable after intermittent failures with no root cause determined.

05000446 Comanche Peak 2 02/12/1999 1999001 Pri: OPS NRC POS Pri: 1C Operators generally performed at high skill and competency levels.

Sec:

Sec: 3B Operators generally performed at high skill and competency levels while exhibiting good implementation of human performance skills including three-part communication, self-verification, peer checking, procedure use, and Dockets Discussed:

Ter:

supervisory oversight. Crew briefings by the unit supervisor occasionally did not meet the expected frequency. This 05000445 Comanche Peak 1 performance was consistent between shift and staff crews.

05000446 Comanche Peak 2 02/12/1999 1999001 Pri: OPS NRC STR Pri: 1A The operations training organization continues to sustain a high level of performance.

Sec:

Sec: 1B The operations training organization continues to sustain a high level of performance in implementing a Systems Approach to Training for the licensed operator requalification program. The recent implementation of the operations Dockets Discussed:

Ter: 3B self-assessment data base for tracking lessons learned from evolution debriefs, was an example of how the 05000445 Comanche Peak 1 program continues to improve.

05000446 Comanche Peak 2 Item Type (ComplianceFollowupOther), From 01/25/1999 To 02/11/2000

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4of 19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description 11/13/1999 1999016-01 Pri: MAINT Licensee NCV Pri: 3A Two errors occurred during fuel handling from a lack of attention-to-detail and poor independent verification Sec:

Sec: 3B The licensee made two separate errors during fuel handling activities: (1) the improper positioning of a thimble plug in the incorrect fuel assembly and (2) a sequence error while reloading the Unit 1 core. Both of these errors were Dockets Discussed:

Ter:

attributed to a lack of attention to detail and ineffective independent verification. In both cases, personnel 05000445 Comanche Peak 1 discovered their own errors, suspended activities, and notified their supervisors. The failure to properly implement the fuel shuffle sequence plan in accordance with plant procedures was a violation of Technical Specification 5.4.1.

This Severity Level IV violation is being treated as a noncited violation, consistent with Section VII.B.1.a of the NRC Enforcement Policy. The incorrect placement of the thimble plug and the core reload sequence error were entered into the licensee's corrective action program as SmartForms SMF-1 999-002717-00 and SMF-1 999-002905-00, respectively.

11/13/1999 1999016-02 Pri: MAINT Licensee NCV Pri: 3A Missed surveillance for power operated relief valve actuation circuits.

Sec:

Sec: 3B On May 10, 1999, the licensee identified that the power-operated relief valve actuation circuits were not properly tested as required by Technical Specification Surveillance Requirements 4.4.4.1 and 4.4.8.3.1. The missed Dockets Discussed:

Ter:

surveillance was reported in accordance with 10 CFR 50.73(a)(2)(B) in Licensee Event Report 05000445 Comanche Peak 1 50-445;446/99-001-00. Surveillance procedures were appropriately modified and the untested contacts tested 05000446 Comanche Peak 2 satisfactorily during the next shutdown. Technical Specification 3.4.8.3 required the power-operated relief valves to be operable in Modes 4, 5, and 6 for low temperature overpressure protection and Technical Specification 3.4.4 required the power-operated relief valves to be operable in Modes 1, 2, and 3 for overpressure protection. Due to the location of the untested contacts, the licensee concluded that the power operated relief valves remained operable for Modes 1, 2 and 3 because the untested contact did not preclude manual operation of the relief valves.

Although the automatic mode of operation was preferred, there was no Technical Specification restriction to rely on manual operation of these valves while in Modes 1, 2 or 3. This Severity Level IV violation is being treated as a noncited violation, consistent with Section VII.B.1.a of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as SmartForm SMF-1999-001289-00.

10/25/1999 1999018 Pri: MAINT Licensee NEG Pri: 2A Failure of electric hoist due to improper maintenance and lack-of-attention to detail resulted in an uncontroll Sec:

Sec: 3A Failure of an electric chain hoist while lifting the Unit 1 Reactor Coolant Pump 1-03 motor resulted in the 40 ton Dockets Discussed:

Ter: 3B motor falling 20 to 30 feet before a chain link randomly lodged between the lower chain block and brass guide bar of the hoist and arrested the fall. Licensee personnel in containment were aggressive in verifying all personnel were 05000445 Comanche Peak 1 clear of the area and that there were no injuries. There were no actual safety consequences as a result of this 05000446 Comanche Peak 2 event. However, had the link not randomly lodged in the hoist, the 40 ton motor would have continued to fall, probably landing on the reactor coolant pump flange and damaging the reactor coolant system piping. Although all the reactor fuel had been moved to the spent fuel pool, a rapid draindown of the refueling cavity could have exposed personnel in containment to high doses of radiation from the exposed core barrel, which was stored in the refueling cavity. The licensee's root cause investigation was thorough, probing, and expedient in determining the root cause of the event. The licensee's investigation team determined that improper maintenance resulted in misalignment between the spindle shaft and the planetary gear assembly in one of the hoist's drive trains. This led to failure of that drive train and, ultimately, failure of the entire hoist. Despite several opportunities, the licensee failed to recognize symptoms of the gear misalignment and correct it prior to this event.

10/02/1999 1999015 Pri: MAINT Self NEG Pri: 3A Maintenance work resulted In secondary chemistry excursion.

Sec:

Sec: 3B Instrument and control technicians demonstrated poor maintenance practices when they inadvertently backfilled pressure transmitter lines with water contaminated with cleaning fluid. This resulted in a high sodium condition in Dockets Discussed:

Ter:

the Unit 2 condensate system. The technicians were unaware of the requirements in Procedure INC-3016, 05000445 Comanche Peak 1 "Backfilling Process Sensors and Sensing Line," which would have precluded this event. The licensee's root cause 05000446 Comanche Peak 2 investigation was thorough, and probed into the root causes of this event.

Item Type (Compliance,Followup,Other), From 01/25/1999 To 02/11/2000

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5 of 19 03/29/2000 16:53:48 IR Report 3 United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Region IV COMANCHE PEAK Functional Template Item Title Date Source Area ID Type Codes Item Description 10/02/1999 1999015 Pri: MAINT NRC POS Pri: 2A Good plant housekeeping and material condition.

Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 Sec:

Housekeeping and material condition remained good. Significant improvements were noted in the cleanliness of the station service water intake structure. The inspectors walked down a number of manual containment isolation Ter:

valves in Unit 2 and found them to be in the proper position and in good condition.

08/21/1999 1999014 Pri: MAINT Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 NRC NEG Pri: 2A Sec: 2B Ter: 3A Plant transient resulted from poor EHC system troubleshooting practices.

Troubleshooting activities on the Unit 1 electrohydraulic control system resulted in a 140 MWe transient on the main turbine. The decision to reinstall a known failed component in an operating plant system for troubleshooting purposes was contrary to sound practices and resulted in the main turbine transient. The transient presented multiple complex challenges to control room operators and was a contributing factor in a failure of Unit 1 Main Feedwater Pump 1 B. In addition, these failures occurred during peak grid loading, which necessitated operating Unit 1 with abnormal equipment conditions for 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> while awaiting for grid conditions to support repair activities.

08/21/1999 1999014 Pri: MAINT Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 08/21/1999 1999014-01 Dockets Discussed:

05000445 Comanche Peak 1 Pri: MAINT Sec:

r4NKU r"JLU r,: 2.A Inadequate configuration control of the EHC system.

Sec: 2B Instrumentation and controls technicians demonstrated a questioning attitude by comparing a new speed sensing card with the old card prior to installation however, a lack of adequate design documentation on the cards and Ter: 3A incorrect drawings led to the installation of an incorrectly configured circuit card. This had no adverse impact on plant operations since the new card did not work.

NRC NCV Pri: 1C Inadequate storage of nonplant equipment.

Sec: 2A A number of examples were identified where nonplant equipment was stored inappropriately. One example involved two carts full of batteries secured to containment radiation monitoring equipment conduits that were in violation of Ter:

Station Administrative Procedures. The licensee immediately corrected the problem and entered the condition in their corrective action program for trending (SmartForm SMF-1 999-002079-00). This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy.

07/10/1999 1999012 Pri: MAINT Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 NRC POS Pri: 1A Sec:

Ter:

Plant material condition and cleanliness continued to be good.

Overall, plant cleanliness and material condition continue to be good. The licensee took prompt and effective steps to correct minor housekeeping issues as they arose.

07/10/1999 1999012 Pri: MAINT Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 NRC POS Pri: 1A Conduct of maintenance and surveillance activities was good.

Sec: 1C The conduct of maintenance and surveillance activities was good. Maintenance and surveillance activities conducted were well planned and safely coordinated. Personnel directing surveillance tests were knowledgeable, Ter:

followed the procedures, and maintained good command and control of the activities. The licensee correctly identified and classified the failure of the Unit 2 charging flow control valve as a maintenance preventable functional failure.

Item Type (ComplianceFollowupOther), From 01/25/1999 To 02/11/2000

Page:

6of 19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description 05/29/1999 1999011 Pri: MAINT NRC POS Pri: 3A The conduct of maintenance and surveillance activities during refueling and startup was good.

Sec:

The conduct of maintenance and surveillance activities was good. Maintenance and surveillance activities Dockets Discussed:

T conducted during the refueling outage and during plant startup were planned and coordinated safely and proficiently.

05000445 Comnchsed a

Ter:

Personnel directing surveillance tests were knowledgeable, followed the procedures, and maintained good 05000445 Comanche Peak 1 command and control of the activities.

05000446 Comanche Peak 2 05/18/1999 1999014-02 Pri: MAINT Licensee NCV Pri: 2B Missed TS surveillance on steam generator gross activity composite sample Sec:

Sec: 3A A licensee event report (LER 50-445;446/99002) was submitted for missing the Technical Specification surveillance requirement for steam generator gross activity composite determination on May 18, 1999. The missed surveillance Dockets Discussed:

Ter:

was caused by chemistry personnel overlooking the directions contained in Chemistry Shift Orders. The following 05000445 Comanche Peak 1 day, the appropriate samples were taken and steam generator gross activity composite was found to be within 05000446 Comanche Peak 2 specification. This condition was entered in the corrective action program (SmartForm SMF-1999-001339-00). The missed Technical Specification surveillance requirement is a Severity Level IV violation of plant Technical Specification 4.7.1.4 which is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy.

05/11/1999 1999008-01 Pri: MAINT NRC NCV Pri: 3A Activity performed as minor maintenance required entry into limiting condition for operation.

Sec:

One minor maintenance activity deviated from the guidance in the controlling maintenance procedure in that the Dockets Discussed:

T activity was conducted as a minor maintenance activity even though it required entry into a technical specification eTer:

limiting condition for operation. This failure to follow procedures is being treated as a non-cited violation of 10 CFR 05000445 Comanche Peak 1 Part 50, Appendix B, Criterion V. Violation was entered into licensee's corrective action program as SmartForm 05000446 Comanche Peak 2 SMF-1999-1261.

04/17/1999 1999007 Pri: MAINT NRC NEG Pri: 3A Minimum throttle valve gap was not verified prior to marking/locking following ECCS flow balance.

Sec:

Although emergency core cooling flow balancing was acceptable, a minor problem involving the licensee not Dockets Discussed:

T verifying the minimum throttle valve gap size prior to ordering the throttle valves locked and marked was identified eTer:

by the inspector. After checking throttle valve gap size, at least one throttle valve had to be unlocked and 05000445 Comanche Peak 1 readjusted. The flow balancing was reperformed with no problems.

05000446 Comanche Peak 2 04/17/1999 1999007 Pri: MAINT NRC POS Pri: 3A Safety practices and equipment were used, workers were careful to exclude foreign material from systems.

Sec:

Maintenance activities were conducted in accordance with approved procedures and good work practices. Effective Dockets Discussed:

T communication between work organizations was observed. Personnel protective equipment was used appropriately eTer:

and effective personnel safety practices were observed. Maintenance workers were careful to exclude foreign 05000445 Comanche Peak 1 material from systems. Some minor problems were noted with the storage of non-plant equipment and foreign 05000446 Comanche Peak 2 material exclusion but all were corrected immediately by the licensee.

04/17/1999 1999007 Pri: MAINT NRC POS Pri: 3A Surveillance activities were generally conducted well and self checking was noted.

Sec:

Surveillance activities were generally conducted in accordance with approved procedures and were well coordinated. Good self-checking and peer-verification was noted. Communications between personnel conducting Dockets Discussed:

Ter:

surveillances were clear and included formal repeat backs.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 Item Type (Compliance,Followup,Other), From 01/25/1999 To 02/11/2000

Page:

7 of 19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description 12/25/1999 1999018-01 Pri: ENG NRC NCV Pri: 4B Inadequate abnormal operating procedures for loss of coolant while shutdown Sec:

Sac: 1C The postulated drop of a reactor coolant pump motor onto reactor coolant piping which would result in a reactor coolant leak in Mode 5 with fuel in the reactor would require at least one containment sump for decay heat removal.

Dockets Discussed:

Ter: 313 No procedural controls were developed to maintain at least one sump available while in Mode 5 during heavy load 05000445 Comanche Peak 1 lifts even though abnormal operating procedures directed operators to shift the residual heat removal system 05000446 Comanche Peak 2 suction to the containment sumps following a postulated loss of reactor coolant. The failure to have procedural controls for an available containment sump in Mode 5 during heavy load lifts is a violation of Technical Specification 5.4.1.

This Severity Level IV violation is being treated as a noncited violation, consistent with Section VlI.B.1.a of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as SmartForm 1999-003178-00.

12/25/1999 1999018-02 Pri: ENG Licensee NCV Pri: 4C Failure to translate system requirements into design specifications.

Sec:

Sec: 4B On June 17, 1998, the licensee determined that the hydrogen purge system would not function as described in the Final Safety Analysis Report or the Design Basis Document and appropriately wrote Licensee Event Report Dockets Discussed:

Ter: 3B 98-005-00. The FSAR and DBD state that the system can be operated with containment pressures between 0 and 05000445 Comanche Peak 1 5 psig. However, at containment pressures above 0 psig, the flow rate through the filter elements would exceed the 05000446 Comanche Peak 2 design limits; therefore, the charcoal adsorber residence stay times required by NRC Regulatory Guide 1.140 and ANSI N509-1976 would not be satisfied. The failure to adequately translate the design requirement for maximum flow rates through the hydrogen purge system into design specifications is a violation of 10 CFR Part 50, Appendix B, Criterion III. This Severity Level IV violation is being treated as a noncited violation, consistent with Section VII.B.I.a of the NRC Enforcement Policy. This condition was entered into the licensee's corrective action program as SmartForm SMF-1999-000487-00.

10/02/1999 1999015 Pri: ENG NRC POS Pri: 4B Good safety evaluation for dual train outage.

Sac:

Sec:

The licensee's safety evaluation for the Unit 1 dual train component cooling water and emergency diesel generator system outages was clear and concise. Limits established by the evaluation were properly translated into Dockets Discussed:

Ter:

defense-in-depth contingency plans and monitored by plant personnel.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 08/21/1999 1999014 Pri: ENG NRC NEG Pri: 3B Engineering evaluation of ECCS failed to consider multiple degraded conditions.

Sac:

Sec: 4B The inspectors consulted with the NRC Office of Nuclear Reactor Regulation and concluded that the emergency core cooling system remained operable despite the nonconforming condition associated with throttle valve erosion.

Dockets Discussed:

Ter:

The licensee took adequate and timely corrective actions to address this condition. Although no violation of 05000445 Comanche Peak 1 regulatory requirements was identified, the licensee failed to consider the degraded throttle valve issue in an 05000446 Comanche Peak 2 operability evaluation associated with pressure locking of motor-operated valves. The licensees failure to consider synergistic effects of multiple degraded conditions was a departure from past good performance.

Item Type (ComplianceFollowupOther), From 01/25/1999 To 02/11/2000

United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description flQ/1)414fll, 4nnAA n

i'+-u.

r~ri: ENG Licensee NCV Sec:

Dockets Discussed:

05000446 Comanche Peak 2 08/21/1999 1999014-04 Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 Pri: ENG Sec:

07/10/1999 1999012 Pri: ENG Sac:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 NRC NCV Licensee POS Pan: 3B Poorly implemented design modifications were identified during the Unit 2 outage.

Sac: 4B Several poorly implemented design modifications were identified during the fourth Unit 2 refueling outage. The first Ter:

example involved the installation of expansion joints on steam generator atmospheric relief valves not qualified for the calculated pressure in the design modification. The second involved a nonconforming condition caused by a failure to remove shipping bars prior to the installation of several auxiliary feedwater system check valves. The shipping bar prevented the affected check valves from stroking to their full open position. The third example involved the installation of emergency core cooling throttle valves with the incorrect insert nozzle throat diameter.

Appropriate immediate corrective actions were taken and the specific root causes associated with each issue were identified. Poor documentation of communications between vendors and engineering, inconsistent turnover between lead engineers, and tight vendor schedules were found to contribute to the problems. Inadequate work instructions contributed significantly to the installation of nonconforming auxiliary feedwater check valves in the plant. This condition was entered into the licensee's corrective action program (SmartForm SMF/PIR 1999-001103-01-00). This was a Severity Level IV violation of Technical Specification 6.8.1. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy.

Pri: 3B Design Change did not comply with ANSI/ASME Code N509-1976 requirements.

Sac:

The inspectors identified that the licensee implemented a design change to the control room emergency Ter:

pressurization system that did not conform to the ANSI/ASME Code N509-1976 requirement that the heat generated from radioactive decay and adsorption of iodine be considered when developing these setpoints. The failure to include appropriate design control measures in Design Change 12503, Revision 0, was a Severity Level IV violation of 10 CFR, Part 50, Appendix B,Section III, "Design Control. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. The licensees immediate operability evaluation concluded that the design change error did not affect the radiation dose to operators for a postulated design bases accident. The licensee appropriately placed the issue in their corrective action program (SmartForm SMF-1999-001744-00).

Pri: 4B Thorough evaluation of 6.9kV and 480V setpoints prior to placing in TRM revealed nonconservative values.

Sec: 4C The licensee was thorough in the evaluation of 6.9 kV and 480 volt relay setpoints as these setpoints were transferred from existing Technical Specifications to the Technical Requirements Manual during transition to Ter:

Improved Technical Specifications. The licensee reviewed the basis for the setpoint data, which revealed several nonconservative values, rather than transferring it directly to the Technical Requirements Manual. Immediate corrective actions taken were appropriate and the remaining corrective actions will be tracked in the licensee's corrective action program.

06/18/1999 1999010 Pri: ENG Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 NRC NEG Pri: 4A Sec:

Ter:

CCW design calculations did not account for pump degradation, and IN 97-90 review was inadequate.

The component cooling water heat exchanger monitoring program and resultant surveillance program comprised an effective method of assuring that the equipment was adequate. However, the design calculations did not provide for a pump degradation margin, nor was it accounted for in the IST surveillance procedure. Additionally, the review of the NRC Information Notice 97-90 was inadequate. The team considered this to be an indication of a poor translation of the design basis into plant procedures during initial facility licensing and the subsequent heat exchanger return valve throttling modification.

Item Type (Compliance,Followup,Other), From 01/25/1999 To 02/11/2000 Page: 8of 19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK

Page:

9 of 19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description 06/18/1999 1999010 Pri: ENG NRC NEG Pri: 4A Inability to accurately measure CCW flow to set valve positions was a design deficiency.

Sec:

Sec: 4B The inability to ensure accurately measured component cooling water flow from the residual heat removal and containment spray heat exchangers to set valve control limit switches represented a design deficiency. The team Dockets Discussed:

Ter:

also identified an inability of the licensee's design and safety evaluation programs to identify and address a potential 05000445 Comanche Peak 1 for electronic interference due to the installation of new equipment. The team concluded this was an isolated 05000446 Comanche Peak 2 problem. Overall, the design modification package for replacing the inverter and battery charger was of good quality.

06/18/1999 1999010 Pri: ENG NRC NEG Pri: 4C Lack of rigor, poor safety evaluation and post-modification testing related to modification to cooling water v; Sec:

Sec:

The modification to throttle safety-related heat exchanger cooling water return valves was indicative of a lack of sufficient rigor. The team identified findings that related to poor performance of the safety evaluation and the Dockets Discussed:

Ter:

adequacy of post-modification testing.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 06/18/1999 1999010 Pri: ENG NRC NEG Pri: 4C Significant calculational discrepancies included nonconservative assumptions and failure to update inputs.

Sec:

The licensee had a comprehensive process in place for control of calculations. The calculation for the heat Dockets Discussed:

T exchanger fouling was an example of the pro-active engineering actions. However, a number of significant eTer:

calculational discrepancies included use of nonconservative assumptions and the failure to update design inputs in 05000445 Comanche Peak I all of the calculations affected by system modifications.

05000446 Comanche Peak 2 06/18/1999 1999010 Pri: ENG NRC POS Pri: 4B Engineering became more effective In the control of work and closure of backlog task items.

Sec:

Associated with the 1996 reorganization, the engineering organization apparently became more effective in the Dockets Discussed:

Ter:

control of work and the closure of backlog task items, despite a reduced staff.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 06/18/1999 1999010 Pri: ENG NRC POS Pri: 5C Corrective action program for CCW was effective, licensee was very aggressive in identifying prematurely cl Sec:

Sec:

Implementation of the corrective action program relative to the CCW system, including evaluations, technical reviews, and corrective actions, was effective. The change in philosophical approach from ONE Forms to Dockets Discussed:

Ter:

SmartForms regarding closure of corrective action documents was an administrative enhancement, which reduced 05000445 Comanche Peak 1 the potential for not completing identified corrective actions. Upon discovery of a failure to implement corrective 05000446 Comanche Peak 2 actions after a ONE Form had been prematurely closed, licensee personnel were very aggressive in identifying similar conditions.

06/18/1999 1999010-01 Pri: ENG NRC NCV Pri: 4A Failure to Correctly Implement a Modification onthe CCW System Sec:

Sec:

The failure to correctly implement facility design modification process elements related to conservatism in calculations, validation of uncertainties, instrument loop uncertainties, post-modification testing, and the potential for Dockets Discussed:

Ter:

inducing degradation due to a modification, was a noncited violation of Criterion III of Appendix B to 10 CFR Part 50.

05000445 Comanche Peak 1 The licensee addressed these issues in SmartForms 1999-1326, 1999-1377, 1999-1396, and 1999-1397.

05000446 Comanche Peak 2 Item Type (ComplianceFollowupOther), From 01/25/1999 To 02/11/2000

Page:

10 of 19 03129/2000 16:53:48 IR Report 3 Region IV United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Sec:

Ter:

Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 Although a large number of work activities were identified for loose or hot fuse clips, an effective thermography surveillance testing program was identifying and correcting fuse problems before failures occurred. Proper plant configuration was maintained by effectively controlling failed fuse replacement. However, tracking repeated electrical fuse failures was reduced by the licensee's policy on replacement.

05/11/1999 1999008-02 Pri: ENG Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 Licensee NCV Pri: 4B Failure to Identify and correct 6.9kV and 480V circuit breakers and motor operators problems was an NCV.

Sec:

Failures of 6.9 kV and 480V circuit breakers were not promptly identified and corrected and were the first and second examples of a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI.

A licensee-identified failure Ter:

to promptly identify and correct a motor-operated valve problem identified by industry update information was a third example of a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI. Subsequent corrective actions were prioritized properly. This violation was entered into the licensee's corrective action program as SmartForms SMF-1999-268, SMF-1999-1259, and SMF-1999-1291.

04/17/1999 1999007 Pri: ENG Sec:

NRC POS Pri: 4C Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 Item Type (Compliance,Followup,Other), From 01/25/1999 To 02/11/2000 Licensee review of AFW was performed with adequate degree of confidence The licensee review of the Auxiliary Feedwater System was performed in such a way that an adequate degree of confidence existed that deficient surveillance procedures for testing of system safety-related logic circuits had been properly identified and the surveillance procedures had been adequately revised.

Functional Template Item Title Date Source Area ID Type Codes Item Description 06/18/1999 1999010-02 Pri: ENG NRC NCV Pri: 2B Failure to Perform Required Surveillance Testing of Station Battery Sec:

Sec:

The missed surveillance service test for Unit 1 Battery BT1 ED2 was a noncited violation of Technical Specification 4.8.2.1.d. However, the surveillance tests conducted were adequate to ensure plant operation under normal, Dockets Discussed:

Ter:

abnormal, and emergency conditions. Enforcement discretion was granted by the Office of Nuclear Reactor 05000445 Comanche Peak 1 Regulation for the inspection team-identified missed BT1ED2 battery surveillance and a plant shutdown was not required (EA 99-197). The attention to detail in scheduling, conducting, and reviewing battery surveillance testing needed improvement to achieve adequate surveillance testing.

06/18/1999 1999010-03 Pri: ENG NRC NCV Pri: 4C Failure to Perform Temporary Modification Evaluations and Required Walkdowns Sec:

Sec:

Generally, temporary modifications were controlled in accordance with the governing procedures. There was one identified instance in which licensee personnel failed to document authorization and implementation of a change to Dockets Discussed:

Ter:

a temporary modification. The team observed that the temporary modification extension and justification process 05000445 Comanche Peak 1 appeared to be ineffective, in that, the review failed to recognize that the changes to the temporary modification 05000446 Comanche Peak 2 itself occurred, which might have impacted the original evaluation. In addition, the team identified a failure by licensee personnel to perform walkdowns at the specified frequency to verify that temporary modifications were correctly installed. Both of these conditions were examples of a noncited violation of Criterion V of Appendix B to 10 CFR Part 50. The licensee initiated SmartForms 1999-1321 and 1999-1384 to address these issues.

05/29/1999 1999011 Pri: ENG NRC POS Pri: 4B System engineering provided good support by promptly evaluating an Accumulator 2-04 leak.

Sec:

Safety Injection Accumulator 2-04 developed a small intersystem leak. System engineering provided good support to safe plant operation by promptly evaluating the impact of the leakage and identifying the source. The Dockets Discussed:

Ter:

troubleshooting plan was thorough and appropriately documented per plant procedures.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 05/11/1999 1999008 Pri: ENG NRC NEG Pri: 4C Tracking repeated fuse failures was hampered by licensee's policy on fuse replacement.

Ter:

Page:

11 of 19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description 04/17/1999 1999007 Pri: ENG NRC POS Pri: 4C Industry Operating Experience Report program adequately addressed Generic Letter 96-01 issues.

Sec:

Based on a sample of Generic Letter 96-01 deficiencies identified by other licensees, the licensee's Industry Dockets Discussed:

Ter:

Operating Experience Report Review Program adequately addressed these deficiencies.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 03/06/1999 1999003 Pri: ENG NRC NEG Pri: 4C Previously Identified degraded conditions were not considered in current operability determinations.

Sec:

The licensee failed to include important information about degraded emergency core cooling system performance in Dockets Discussed:

Ter:

their motor-operated valve pressure locking issue operability review. As a result, engineers improperly concluded 05000445 Comanche Peak 1 that the emergency core cooling system hot-leg injection mode was still operational following a design basis loss-of-coolant accident. The licensee had no formal process for ensuring that existing degraded conditions 05000446 Comanche Peak 2 identified in the past were considered in current operability evaluations.

03/06/1999 1999003 Pri: ENG NRC NEG Pri: 4C Justification for continued operation was based partially on unsupported engineering judgement.

Sec:

The licensee's justification for continued plant operation, which addressed an adverse condition associated with Dockets Discussed:

Ter:

emergency core cooling throttle valve erosion, partially relied on a Westinghouse topical submittal which had been 05o00445 Doiancused:

Tk 1withdrawn from the NRC in October 1998. The submittal, which proposed the elimination of the emergency core 05000445 Comanche Peak 1 cooling system hot-leg recirculation mode following a loss-of-coolant accident, had been withdrawn because it was 05000446 Comanche Peak 2 technically incorrect in assuming that the core barrel-to-vessel gap was sufficient to allow flow under all conditions.

As a result, the licensee's justification for continued operation was based partially on unsupported engineering judgement 02/18/1999 1998009 Pri: ENG NRC NEG Pri: 4A A generator load relection occurred which shnuld hauve hbeen b,

t h

&..;11....

Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 c,**apa ty lO sustain operation.

Sec:

On January 3, 1999, a significant main generator load rejection occurred which should have been beyond the capability of Unit 2 to remain in operation. This was attributed to the large capacity of the steam dumps which also Ter:

caused reactor coolant system overcooling following reactor trips. The propensity for reactor coolant system overcooling has sensitized operators toward rapidly securing the turbine-driven auxiliary feedwater pump following a reactor trip to prevent an inadvertent safety injection from occurring. Modifications to the steam dumps were being considered.

01/21/2000 2000002 Pri: PLTSUP NRC WK Pri: 1C Design Weakness In Security System.

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 Sec: 4A A weakness in the design of the security system allowed an individual security officer to grant unescorted access to individuals without the knowledge of any other security officer or plant employee. This weakness was corrected Ter:

during the inspection.

01/21/2000 2000002-01 Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 Pri: PLTSUP Licensee Sec:

NCV Pri: 1C Sec: 3B Ter:

Unescorted Access Authorization Granted Prior to Completion of Required Plant Access Training and Testin A violation of the security plan and a security procedure was identified for granting an employee unescorted protected area access prior to the employee successfully completing plant access and fitness-for-duty training and testing. This Severity Level IV violation is being treated as a noncited violation, consistent with Section VII.B.1.a of the NRC Enforcement Policy. This violation was entered into the licensees corrective action program as Smart Form SMF-1999-000698-00.

Item Type (Compliance,Followup,Other), From 01/25/1999 To 02/11/2000 See:

Page:

12 of 19 03/29/2000 16:53:48 IR Report 3 United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Region IV COMANCHE PEAK Functional Template Item Title Date Source Area ID Type Codes Item Description 10/02/1999 1999015 Pri: PLTSUP Licensee NEG Pri: 3B Weaknesses in contractor radiation worker training program.

Sec:

Three examples of poor radiological practices involved contract employees and situations which were covered by the licensee's radiation worker training program. This was indicative of weaknesses in the radiation worker training Dockets Discussed:

Ter:

program for contractors.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 10/02/1999 1999015 Pri: PLTSUP NRC POS Pri: 1C Licensee exercised Y2K contingency plan.

Sec:

Technical Support Center staff performance during the "Y2K" emergency drill was good. The licensee simulated a Dockets Discussed:

T partial loss of the plant's telephone system. Personnel responded well and were able to reestablish the required Dockets Doacused: PTer:

lines of communications. The concept of a "Y2K Center" to deal with year 2000 specific transition problems was a 05000445 Comanche Peak 1 good initiative.

05000446 Comanche Peak 2 10/02/1999 1999015 Pri: PLTSUP NRC P0s Pri: 5A Quality assurance department effective in identifying performance trends.

Sec:

Two examples of poor radiological practices were identified by the licensee's quality assurance organization during routine observations and evaluations, which was indicative of a good questioning attitude and their effectiveness in Dockets Discussed:

Ter:

identifying performance issues.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 10/02/1999 1999015-01 Pri: PLTSUP Licensee NCV Pri: 3A Radiological Controls Practices Not in Accordance with Plant Procedures Sec:

Sec: 3B Several examples of poor radiological control practices were observed by the inspectors and the licensee during the Unit 1 refueling outage. In one example, an individual failed to contact radiation protection technicians when he Dockets Discussed:

Ter:

observed erratic indications on his electronic dosimeter. In two other instances, personnel failed to follow the 05000445 Comanche Peak 1 requirements of Station Administration Manual STA-656, "Radiation Work Control." Failure to follow this procedure 05000446 Comanche Peak 2 was a violation of Technical Specification 5.4.1. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. These examples are included in the licensee's corrective action program as Smart Forms SMF-1999-2502 and SMF-1999-2530.

10/02/1999 1999015-02 Pri: PLTSUP Licensee NCV Pri: 3A Failure to Post the Station Service Water Tunnel as a Radiation Area Sec:

Sec:

The licensee improperly released the station service water tunnel from the radiologically controlled area based on Dockets Discussed:

T inadequate radiation surveys. Although this did not result in any significant unmonitored dose to individuals working 05000445 Comanche Peak 1Ter:

in the area nor did it exceed the posting requirements of 10 CFR 20.1902, the failure to properly post the tunnel in accordance with licensee procedures for approximately 8 months was a violation of Technical Specification 5.4.1.

05000446 Comanche Peak 2 This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This condition was entered into the licensee's corrective action program as Smart Form SMF-1999-1850.

07/23/1999 1999013 Pri: PLTSUP NRC NEG Pri: 1C Implementing procedure not consistent with emergency plan for minimum EOF staffing.

Sec:

A licensee emergency plan implementing procedure concerning the activation and operation of the emergency Dockets Discussed:

T operations facility was not consistent with the emergency plan in that it stated that the facility could be considered 05000445 Comanche Peak 1Ter:

activated with only three key personnel present while the plan required six.

05000446 Comanche Peak 2 Item Type (ComplianceFollowupOther), From 01/25/1999 To 02/11/2000

Page:

13 of 19 03/29/2000 16:53:48 IR Report 3 United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Region IV COMANCHE PEAK Functional Template Item Title Date Source Area ID Type Codes Item Description 07/23/1999 1999013 Pri: PLTSUP NRC STR Pri: IC Overall emergency response performance was good and TSC engineering support was noteworthy.

Sec:

Sec: 3A Overall, performance was good. The control room, technical support center, operations support center, and Dockets Discussed:

T emergency operations facility successfully implemented key emergency plan functions including emergency DdTer:

classifications, notifications, protective action recommendations, and dose assessment. Engineering analysis and 05000445 Comanche Peak 1 support from the technical support center was noteworthy.

05000446 Comanche Peak 2 07/21/1999 1999013 Pri: PLTSUP Licensee NEG Pri: 1C One EOF notification with updated PARs was unnecessarily delayed due to facility briefing and concurrence Sec:

Sec:

One notification from the emergency operations facility, which contained updated protective action recommendations, was unnecessarily delayed due to a facility briefing and obtaining the Texas Bureau of Radiation Dockets Discussed:

Ter:

Controls concurrence prior to the notification.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 07/21/1999 1999013 Pri: PLTSUP NRC NEG Pri: 1C Control room post-exercise critique did not include normal conduct of operations or basic operator knowled Sec:

Sec: 5A The licensee's post-exercise facility debriefs and the management critique were generally thorough, open, and self critical. However, in the control room simulator, the licensee did not discuss issues concerning normal conduct of Dockets Discussed:

Ter:

operations or basic operator knowledge even though these areas could affect emergency response efforts.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 07/10/1999 1999012 Pri: PLTSUP NRC NEG Pri: 3B Radiation workers lack of knowledge of PM-7 portal monitor operation.

Sec:

Radiation workers demonstrated a lack of knowledge on the operation of the PM-7 portal monitor. As a direct result, approximately 20 radiation workers did not recognize an actual alarming condition when an individual who recently Dockets Discussed:

Ter:

had a radio-chemical treatment for medical reasons caused all the PM-7 portal monitors to alarm as out of service, 05000445 Comanche Peak 1 an expected alarm condition for high radiation background.

05000446 Comanche Peak 2 07/10/1999 1999012 Pri: PLTSUP NRC POS Pri: IC Transfer of resin to high-integrity container performed by knowledgeable personnel.

Sec:

Personnel involved in the transfer of spent resin to a high-integrity container for shipment offsite were knowledgeable of the procedure and the expected dose rates during the process. Radiation protection technicians Dockets Discussed:

Ter:

were effective in maintaining the dose ALARA during the evolution.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 Item Type (ComplianceFollowupOther), From 01/25/1999 To 02/11/2000

Page:

14 of 19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description 06/18/1999 1999010-04 Pri: PLTSUP Licensee NCV Pri: 1C Failure to Assure Safe Shutdown Capability Sec:

Sec:

A design basis fire in the cable spreading room had the potential to cause the spurious opening of the RHR system Dockets Discussed:

r hot-leg isolation valves and the licensee's alternative shutdown capability for the cable spreading room was not 05000445 Comanche Peak 1Ter:

capable of mitigating the resulting transient. Therefore, the licensee was not in compliance with its fire protection program because the ability to safely shut down the plant was challenged in the event a design basis fire occurred in the cable spreading room. Operating License Section 2.G requires the licensee to implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report and this occurrence was considered a violation of Operating License, Section 2.G. However, discretion is being exercised after consultation with the Office of Enforcement pursuant to Section VII.B.6 of the Enforcement Policy and a violation is not being cited on the basis of the licensee's timely and effective corrective action pursuant to the guidance in Enforcement Guidance Memorandum 98-02, Revision 1 (EA 99-203). The licensee had identified the necessary corrective actions in SmartForm 1998-2203, which was being closed. This closed LER 50-445/98007-00 and -01.

04/23/1999 1999009 Pri: PLTSUP NRC POS Pri: 2B Effective In-place filter maintenance and testing program was implemented.

Sec:

An effective maintenance and testing program was implemented for the in-place filter and laboratory charcoal Dockets Discussed:

Ter:

testing of the engineered-safety-feature ventilation filter systems.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 04/23/1999 1999009 Pri: PLTSUP NRC POS Pri: 21 Liquid and gaseous effluent rad monitors were operable and maintained.

Sec:

The liquid and gaseous effluent radiation monitors were operable and propedy maintained, tested, and calibrated in accordance with Offsite Dose Calculation Manual requirements. Effluent radiation monitor alarm set points were Dockets Discussed:

Ter:

properly calculated and installed.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 04/23/1999 1999009 Pri: PLTSUP NRC POS Pri: 3B Training and qualification programs for the chemistry, radiation protection, and radwaste staff were proper.

Sec:

Training and qualification programs for the chemistry technical staff, radiation protection technical support staff, and radwaste plant equipment operators were properly implemented. The chemistry, radiation protection, and radwaste Dockets Discussed:

Ter:

operations departments maintained well trained, qualified, and experienced staffs for conducting sampling, 05000445 Comanche Peak 1 analyses, processing, and release operations for radioactive waste effluents.

05000446 Comanche Peak 2 04/23/1999 1999009 Pri: PLTSUP NRC POS Pri: 5A Licensee's assessment program for radwaste effluent program was good.

Sec:

Sec: 5C The licensee's assessment program of the radioactive waste effluent program was good. The auditors assigned to Dockets Discussed:

T perform the assessment of the radioactive waste effluent program were well qualified to perform the radioactive Dockets Coacused:

eTer:

waste effluent program evaluations. The annual nuclear overview evaluations provided management with a good 05000445 Comanche Peak 1 perspective to assess the radioactive waste effluent program. The contractor laboratories used to perform 05000446 Comanche Peak 2 surveillance testing of the engineered-safety-related ventilation filter systems and the radioactive waste effluent samples were properly evaluated.

Item Type (ComplianceFollowupOther), From 01/25/1999 To 02/11/2000

Page:

15 of 19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description 04/23/1999 1999009 Pri: PLTSUP NRC STR Pri: 1C An excellent liquid and gaseous radwaste management program was implemented.

Sec:

An excellent liquid and gaseous radioactive waste effluent management program was implemented. The Dockets Discussed:

processing, sampling, and analyses of radioactive liquid and gaseous waste effluents and the approval and eTer:

performance of waste discharges were conducted in accordance with Offsite Dose Calculation Manual 05000445 Comanche Peak 1 requirements. Excellent performance was noted in the reduction of liquid effluent volume, gamma radionuclide 05000446 Comanche Peak 2 curies released, and offsite dose. Since 1993, the volume of liquid radioactive waste discharged was reduced approximately 80 percent, and the curie amount of radioactive liquid effluent mixed fission and activation products released showed a 74 percent reduction resulting in a dose reduction of approximately 99.6 percent. Since 1994, the gaseous effluent activity released decreased approximately 99.4 percent.

04/17/1999 1999007 Pri: PLTSUP NRC POS Pri: 1A Management conservative decisions minimized radiation worker dose.

Sec:

Sac:

Licensee management demonstrated conservative decision-making when they pre-approved various radiation worker limitations and temporary shielding that increased the duration of the outage but minimized radiation worker Dockets Discussed:

Ter:

dose. Overall, radiation protection personnel conducted effective radiation and contamination surveys. The 05000445 Comanche Peak 1 planned dose for the Unit 2 refueling outage was 190 person-rem. Actual dose received was 101.7 person-rem 05000446 Comanche Peak 2 which was approximately 40 person-rem less than the last Unit 2 refueling outage.

04/09/1999 1999006-02 Pri: PLTSUP NRC NCV Pri: 3A Failure to perform complete radiological evaluations on temporary shielding packages.

Sec:

Sec: 3C A violation of Technical Specification 6.8.1 was identified for failure to perform complete radiological exposure evaluations on three separate temporary shielding packages as required by a radiation protection program Dockets Discussed:

Ter:

procedure. This Severity Level IV violation is being treated as a non-cited violation, consistent with Appendix C of 05000445 Comanche Peak 1 the NRC Enforcement Policy. This violation was placed in the licensee's corrective action program as SMART Form 05000446 Comanche Peak 2 SMF-1999-000813-00.

04/02/1999 1999006 Pri: PLTSUP NRC NEG Pri: 3A RP failed to evaluate rad levels and post hot spots in accordance with expectations.

Sec:

Sec: 3C Radiation protection personnel failed to evaluate radiation levels and post hot spots in accordance with Dockets Discussed:

Ter:

expectations.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 04/02/1999 1999006 Pri: PLTSUP NRC NEG Pri: 3B Rad workers did not respond to continuous air monitor alarms.

Sec:

On two occasions, radiation workers, in a high traffic area of containment, did not respond to continuous air monitor Dockets Discussed:

Ter:

audible and visual alert/fault alarms in accordance with management expectations.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 04/02/1999 1999006 Pri: PLTSUP NRC POS Pri: 1C ALARA program was acceptably implemented.

Sec:

The ALARA program was acceptably implemented. ALARA considerations were properly incorporated into the Dockets Discussed:

T outage schedule and were generally well implemented. Radiological work packages were effectively planned, and eTer:

ALARA personnel were involved during the implementation stage. Lessons learned from past similar work were 05000445 Comanche Peak 1 incorporated into the radiological work packages. Station and task activity doses were tracked and trended by the 05000446 Comanche Peak 2 ALARA staff. The Unit 2 refueling outage dose as of March 31, 1999, was approximately 36 person-rem. Effective chemistry shutdown plans and controls were implemented. Appropriate radiation protection instrumentation, protective clothing, and consumable supplies were available to support radiological work.

Item Type (ComplianceFollowupOther), From 01/25/1999 To 02/11/2000

Page:

16 of 19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description 04/02/1999 1999006 Pri: PLTSUP NRC POS Pri: 3B Contract RP technician trn

'i-.-,..

Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 04/02/1999 1999006-01 Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 Pri: PLTSUP NRC Sec:

Sec:

The contract radiation protection technician training program was effectively implemented. Radiation protection management was involved in the development of the contract radiation protection technician training program and Ter:

qualification task topics. Qualification tasks included all the tasks assigned to contract senior radiation protection technicians. Contract senior radiation protection technicians met the technical experience requirement of Technical Specification 6.3.1.b and the training requirements delineated in station procedures.

NCV Pri: 3A Failure to perform radiological surveys.

Sec: 3C A violation of 10 CFR 20.1501 (a) was identified for failure to evaluate the airborne concentrations and potential radiological hazards that could be present in the spent fuel pool work area on the 860-foot elevation of the fuel Ter:

building. This is the first example of a Severity Level IV violation that is being treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy. A second violation of 10 CFR 20.1501(a) was identified for failure to ensure the radioactive airborne quality from Steam Generators 1 and 4 portable ventilation units. These violations were placed in the licensee's corrective action program as SMART Form SMF-1 999-000808-00. A third violation of 10 CFR 20.1501(a) was identified for failure to evaluate the airborne concentrations and potential radiological hazards that could be present inside Steam Generator 3. This violation was placed in the licensee's corrective action program as SMART Form SMF-1999-000818-00.

03/06/1999 1999003 Pri: PLTSUP Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 03/06/1999 1999003 Pri: PLTSUP NRC Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 NRC POS Pri: 1A Sec:

Ter:

POS Pri: 1C Sec: 38 Ter:

Plant cleanliness remains very good, despite extensive work In the Unit 2 turbine building.

Plant cleanliness remains very good, despite extensive work in the Unit 2 turbine building and outage preparations in all areas of Unit 2. Extensive scaffolding was erected in support of the outage but was not observed to interfere with safety-related equipment.

The Inspectors observed good radiological practices being implemented by plant personnel.

The inspectors observed good radiological practices being implemented by plant personnel. Workers were familiar with their radiological work permit requirements. The inspectors accompanied licensee personnel into the Unit 2 containment during power operations and observed good contamination controls and ALARA practices.

03/06/1999 1999003 Pri: PLTSUP NRC POS Pri: 1C Security drills conducted were appropriately monitored and controlled. The scenarios were challenging.

Sec:

Sec: 3B The inspector found that the security drills conducted were appropriately monitored and controlled. The scenarios Dockets Discussed:

Ter:

were challenging and maximized the opportunity to identify weaknesses.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 03/06/1999 1999003 Pri: PLTSUP Sec:

Dockets Discussed:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 NRC POS Pri: 1C Sec: 3B Ter:

Plant personnel were quick to respond to a report of a grass fire on plant property.

Plant personnel were quick to respond to a report of a grass fire on plant property. Although no structures or safety-related equipment were threatened by the fire, high winds and dry conditions aggravated the situation. The plant fire brigade performed well in extinguishing the fire.

Item Type (Compliance, FollowupOther), From 01/25/1 999 To 02/11/2000 S........

""'"tip av~uaumwase Cnu iv ely nmplementeo.

Page:

17 of 19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description 02/26/1999 1999005 Pri: PLTSUP NRC NEG Pri: 4C Licensee failed to request renewal of its QA program within 30 days of expiration.

Sec:

Due to tracking system errors, the licensee failed to request renewal of its quality assurance program within 30 days of expiration. The NRC expedited its quality assurance program renewal so the licensee could continue radioactive Dockets Discussed:

Ter:

shipping activities.

05000445 Comanche Peak 1 05000446 Comanche Peak 2 02/26/1999 1999005 Pri: PLTSUP NRC POS Pri: 2A Housekeeping throughout the radiological controlled areas was very good.

Sec:

Housekeeping throughout the radiological controlled areas was very good.

Dockets Discussed:

Ter:

05000445 Comanche Peak 1 05000446 Comanche Peak 2 02/26/1999 1999005 Pri: PLTSUP NRC POS Pri: 5A Comprehensive audits and corrective actions were effective for the solid radwaste program.

Sec:

Sec: 5B Comprehensive audits performed by qualified personnel effectively evaluated the solid radioactive waste Dockets Discussed:

T management and radioactive waste/material transportation programs. The corrective action process was effectively 05000445 Comanche Peak 1Ter:

used to identify problems, perform evaluations and assessments, and implement prompt corrective actions.

05000446 Comanche Peak 2 02/26/1999 1999005 Pri: PLTSUP NRC STR Pri: 1A Solid radwaste management and transportation programs implemented well.

Sec:

Sec: IC The solid radioactive waste management and radioactive waste/material transportation programs were implemented well, Waste stream sampling and analysis met regulatory requirements. Solid radioactive waste was properly Dockets Discussed:

Ter:

classified and characterized for shipment and disposal. Shipping papers contained the required information, and 05000445 Comanche Peak 1 packages were properly surveyed and labeled. The process of preparing for shipment a high integrity container with 05000446 Comanche Peak 2 exposure rates up to 23 rem/hr was conducted very proficiently keeping radiation exposures ALARA.

02/26/1999 1999005-01 Pri: PLTSUP NRC NCV Pri: 3B Failure to perform required training for two radwaste quality control inspectors.

Sec:

A violation of 49 CFR 172.704 was identified involving the failure of two radwaste quality control inspectors to receive function specific training every three years. This violation is in the licensee's corrective action program as Dockets Discussed:

Ter:

SMART Form 1999-000371. This Severity Level IV Violation is being treated as a Non-Cited Violation, consistent 05000445 Comanche Peak 1 with Appendix C of the NRC Enforcement Policy.

01/29/1999 1999004 Pri: PLTSUP NRC POS PrH: 1A Comprehensive audits effectively evaluated the radiological environmental monitoring program.

Sec:

Sec: 5A Comprehensive audits, performed by qualified personnel, effectively evaluated the radiological environmental Dockets Discussed:

T monitoring program. The corrective action process was effectively used to identify problems, perform evaluations 05000445 Comanche Peak 1Ter:

and assessments, and implement prompt corrective actions.

05000446 Comanche Peak 2 Item Type (ComplianceFollowupOther), From 01/25/1999 To 02/11/2000

Page:

18 of 19 03/29/2000 16:53:48 IR Report 3 Region IV COMANCHE PEAK United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date Source Area ID Type Codes Item Description 01/29/1999 1999004 Pri: PLTSUP NRC STR Pri: 1A An excellent radiological environmental monitoring program was implemented.

Sec:

Sec: 1C An excellent radiological environmental monitoring program was implemented in accordance with the Technical Dockets Discussed:

T Specifications and the Offsite Dose Calculation Manual requirements. A well trained, experienced, and qualified 05000445 Comanche Peak 1Ter:

staff were responsible for implementing the radiological environmental monitoring program. In 1997, no environmental air samples were missed indicating that the air sampling program was effectively implemented.

05000446 Comanche Peak 2 Sample collection, shipment, and analyses report records were meticulously maintained. An effective meteorological monitoring program was in place. The meteorological towers were properly maintained with all instrumentation calibrated at the proper frequencies. Data recovery was greater than 90 percent in 1997 and 1998.

Item Type (Compliance,Followup,Other), From 01/25/1999 To 02/11/2000

Page:

19 of 19 0312912000 16:53:48 IR Report 3 United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Legend Template Codes:

Functional Areas:

ID Codes:

NRC NRC Self Self-Revealed Licensee Licensee EEls are apparent violations of NRC Requirements that are being considered for escalated enforcement action in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action" (Enforcement Policy), NUREG-1 600. However, the NRC has not reached its final enforcement decision on the issues identified by the EEls and the PIM entries may be modified when the final decisions are made.

URIs are unresolved items about which more information is required to determine whether the issue in question is an acceptable item, a deviation, a nonconformance, or a violation, A URI may also be a potential violation that is not likely to be considered for escalated enforcement action. However, the NRC has not reached its final conclusions on the issues, and the PIM entries may be modified when the final conclusions are made.

Item Type (ComplianceFollowupOther), From 01/25/1999 To 02/11/2000 Type Codes:

BU Bulletin CDR Construction DEV Deviation EEl Escalated Enforcement Item IFI Inspector follow-up item LER Licensee Event Report LIC Licensing Issue MISC Miscellaneous MV Minor Violation NCV NonCited Violation NEG Negative NOED Notice of Enforcement Discretion NON Notice of Non-Conformance OTHR Other P21 Part 21 POS Positive SGI Safeguard Event Report STR Strength URI Unresolved item VIO Violation WK Weakness OPS Operations MAINT Maintenance ENG Engineering PLTSUP Plant Support OTHER Other 1A Normal Operations 1B Operations During Transients 1C Programs and Processes 2A Equipment Condition 2B Programs and Processes 3A Work Performance 3B KSA 3C Work Environment 4A Design 4B Engineering Support 4C Programs and Processes 5A Identification 5B Analysis 5C Resolution

Page 1 of 2 03/30/2000 16:16:16 SU-nits illnsDection Activitv l[

Title COMANCHE PEAK Inspection / Activity Plan 04/02/2000 - 03/31/2001 No. of Staffi No. assigned Planned Dates Inspection S1 onsite to Procedure Start End Type 1,2 1,2 1,2 1,2 1,2 1,2 1,2 1,2 1,2 1,2 1,2 1,2 1,2 1,2 1,2 1,2 1,2 1,2 1,2 1,2 2

RPBA17

- DRILL, EXERCISE AND EVENT EVALUATION IP 7111406 Drill Evaluation RPBA13

- TEMPORARY PLANT MODIFICATIONS IP 7111123 Temporary Plant Modifications EMB

- 50.59 IP 7111102 Evaluation of Changes, Tests, or Experiments PSB-RP1

- EFFLUENTS IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems PBA-TI

- TI-144, PI DATA REVIEW IP 2515/144 Performance Indicator Data Collecting and Reporting Process Review PSB-RP7

- ENVIRONMENTAL MONITORING IP 7112203 Radiological Environmental Monitoring Program PSB-RP2

- RAD MATERIAL PROCESSING/SHIPPING IP 7112202 Radioactive Material Processing and Transportation PSB-RP3

- RAD MONITORING INSTR IP 7112103 Radiation Monitoring Instrumentation RPBA21

- EQUIPMENT ALIGNMENTS IP 7111104 Equipment Alignment PSB-EP1

- A&N, ERO, PI&R, EAL/EP, PIV IP 7111402 Alert and Notification System Testing I P 7111403 Emergency Response Organization Augmentation Testing IP 7111404 Emergency Action Level and Emergency Plan Changes IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies IP 71151 Performance Indicator Verification OB-PIR

- PIR INSPECT IP 71152 Identification and Resolution of Problems EMB

- MAINT RULE IMPLEMENTATION IP 7111112B Maintenance Rule Implementation PSB-RP4

- ALARA PLANNING/CONTROL 1 IP 7112102 ALARA Planning and Controls EMB

- ISI IP 7111108 Inservice Inspection Activities EMB

- SSD&PC BAGMAN IP 7111121 Safety System Design and Performance Capability RPBA25

- ADVERSE WEATHER IP 7111101 Adverse Weather Protection This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

5 1

1 1

1 2

07/08/2000 Baseline Inspections 04/02/2000 04/02/2000 04/24/2000 05/01/2000 05/14/2000 05/15/2000 06/26/2000 06/26/2000 07/09/2000 07/17/2000 07/17/2000 07/17/2000 07/17/2000 07/17/2000 07/31/2000 08/28/2000 09/25/2000 10/02/2000 10/02/2000 10/08/2000 03/31/2001 04/27/2000 05/05/2000 08/05/2000 05/19/2000 06/30/2000 06/30/2000 08/19/2000 07/21/2000 07/21/2000 07/21/2000 07/21/2000 07/21/2000 08/04/2000 09/01/2000 09/29/2000 10/06/2000 10/06/2000 01/13/2001 Baseline Inspections Baseline Inspections Baseline Inspections Safety Issues Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections

COMANCHE PEAK Inspection / Activity Plan 04/02/2000 - 03/31/2001 IU-n-i-s llnspection Activity 11 Title Il No. of Staff No. assigned 1 Planned Dates I Inspection on Site to Procedure Start End Type 1

1 10/09/2000 10/13/2000 Baseline Inspections 1

10/09/2000 10/13/2000 Baseline Inspections 1

1 10/23/2000 1

10/23/2000 1

10/23/2000 10/27/2000 10/27/2000 10/27/2000 10/27/2000 Baseline Inspections Baseline Inspections Baseline Inspections Baseline Inspections PSB-RP5

- ACCESS TO RAD SIGN AREAS AND PIV 1,2 1P 7112101 Access Control to Radiologically Significant Areas 1,2 IP 71151 Performance Indicator Verification PSB-S1

- ACCESS AUTH/CONTROL, SEC PLAN, AND PIV 1,2 IP 7113001 Access Authorization Program (Behavior Observation Only) 1,2 IP 7113002 Access Control (Search of Personnel, Packages, and Vehicles: Identification ar 1,2 IP 7113004 Security Plan Changes 1,2 IP 71151 Performance Indicator Verification EMB

- SSD&PC 1,2 IP 7111121 Safety System Design and Performance Capability PSB-RP6

- ALARA PLANNING/CONTROL 2 1,2 IP 7112102 ALARA Planning and Controls RPBA22

- EQUIPMENT ALIGNMENTS 1,2 IP 7111104 Equipment Alignment RPBA20

- DRILL, EXERCISE AND EVENT EVALUATION 1,2 IP 7111406 Drill Evaluation OB-RQ

- REQUAL INSP 1,2 IP 7111111B Licensed Operator Requalification EMB

- HEAT SINK PERF 1,2 IP 7111107B Heat Sink Performance 2

2 2

3 4

10/30/2000 11/17/2000 Baseline Inspections 2

12/18/2000 12/22/2000 Baseline Inspections 2

01/14/2001 02/24/2001 Baseline Inspections 2

01/14/2001 03/31/2001 Baseline Inspections 2

02/12/2001 02/16/2001 Baseline Inspections 1

03/26/2001 03/30/2001 Baseline Inspections 1

This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 2 03/30/2000 16:16:16 I

7

ML003699046

Contents

Text

SUBJECT:

Dear Mr. Terry:

Enclosures:

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