Text

IR 05000445/2002-003 & 05000446/2002-003, Comanche Peak Steam Electric Station, Inspection on 02/25/2002 Related to Root Causes and Contributing Factors of the White Finding. No Violations Noted
	ML021230646
Person / Time
Site:	Comanche Peak
Issue date:	05/03/2002
From:	Howell A; Division of Reactor Safety IV
To:	Terry C; TXU Generation Co, LP
References
	IR-01-007, IR-02-003
	Download: ML021230646 (13)
	v • d • e

May 3, 2002

EA-01-304

Mr. C. L. Terry

Senior Vice President & Principal Nuclear Officer of

TXU Generation Management Company LCC,

Managing General Partner for

TXU Generation Company LP

ATTN: Regulatory Affairs Department

P.O. Box 1002

Glen Rose, Texas 76043

SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION - NRC SUPPLEMENTAL

INSPECTION REPORT 50-445/02-03; 50-446/02-03

Dear Mr. Terry:

On April 25, 2002, the NRC completed a supplemental inspection at your Comanche Peak

Steam Electric Station. The enclosed report documents the inspection findings which were

discussed with you and other members of your staff at the completion of the inspection.

NRC Inspection Report 50-445/01-07; 50-446/01-07 documented a preliminary White finding

and apparent violation that involved 11 examples in which radiological surveys to detect

radioactivity required by Technical Specification procedures were not adequate. On February

21, 2002, the NRC issued its Final Significance Determination and Notice of Violation for NRC

Inspection Report 50-445/01-07; 50-446/01-07. The significance of the violation was

determined to have low to moderate (White) importance to safety when processed through

public radiation safety significance determination process.

This supplemental inspection was conducted to provide assurance that the root causes and

contributing causes of the White finding were understood, the extent of condition was identified,

and the corrective actions for risk significant performance issues were sufficient to address the

causes and prevent recurrence. To accomplish these objectives, the inspector reviewed your

root cause analysis, evaluation of extent of condition, and proposed corrective actions.

Based on the results of this inspection, the NRC determined that the identification of the root

causes, contributing causes, and corrective actions associated with the White finding were

comprehensive and broad-based. Implementation of the corrective actions should correct the

subject radioactive material control issue.

TXU Generation Company LP -2-

In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter, its

enclosure, and your response will be made available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/ADAMS.html (the Public Electronic Reading Room).

Should you have any questions concerning this inspection, we will be pleased to discuss them

with you.

Sincerely,

/RA/

Arthur T. Howell lll, Director

Division of Reactor Safety

Dockets: 50-445

50-446

Licenses: NPF-87

NPF-89

Enclosure:

NRC Inspection Report

50-445/02-03; 50-446/02-03

cc w/enclosure:

Roger D. Walker

Regulatory Affairs Manager

TXU Generation Company LP

P.O. Box 1002

Glen Rose, Texas 76043

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

TXU Generation Company LP -3-

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

Environmental and Natural

Resources Policy Director

Office of the Governor

P.O. Box 12428

Austin, Texas 78711-3189

Brian Almon

Public Utility Commission

William B. Travis Building

P.O. Box 13326

1701 North Congress Avenue

Austin, Texas 78701-3326

Susan M. Jablonski

Office of Permitting, Remediation and Registration

Texas Natural Resource Conservation Commission

MC-122

P.O. Box 13087

Austin, TX 78711-3087

TXU Generation Company LP -4-

Electronic distribution by RIV:

Regional Administrator (EWM)

DRP Director (KEB)

DRS Director (ATH)

Senior Resident Inspector (DBA)

Branch Chief, DRP/A (DNG)

Senior Project Engineer, DRP/A (CJP)

Staff Chief, DRP/TSS (PHH)

RITS Coordinator (NBH)

Only inspection reports to the following:

Scott Morris (SAM1)

CP Site Secretary (LCA)

DOCUMENT NAME: R:\DRS\REPORTS\CP2002-03RP-MPS.WPD

RIV:DRS/PSB PEER REVIEW C:PSB C:DRP/A D:DRS

MPShannon GMGood WDJohnson AHowell

/RA/ /RA/ /RA/ /RA/ /RA/

4/ 29 /02 4/29 /02 5/01 /02 5/02 /02 5/03/02

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No(s).: 50-445; 50-446

License No(s).: NPF-87; NPF-89

Report No: 2002-03

Licensee: TXU

Facility: Comanche Peak

Location: Glen Rose, Texas

Dates: April 23-25, 2002

Inspector: Michael P. Shannon, Senior Health Physicist

Gail M. Good, Chief, Plant Support Branch

Division of Reactor Safety

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SUMMARY OF FINDINGS

Comanche Peak

NRC Inspection Report No. 50- 445-02-03; 50-446-02-03

IR 05000445-02-03; IR 05000446-02-03; on 04/23-25/2002; TXU Energy; Comanche Peak

Steam Electric Station; Units 1 and 2. Regional Report.

The inspection was conducted by a regional office inspector. The inspection identified no

findings of significance. The significance of issues is indicated by their color (Green, White,

Yellow, or Red) and was determined by the Significance Determination Process in Inspection

Manual Chapter 0609. The NRCs program for overseeing the safe operation of commercial

nuclear power reactors is described at its Reactor Oversight Process website at

http://www.nrc.gov/NRR/OVERSIGHT/index.html.

Cornerstone: Public Radiation Safety

This supplemental inspection was performed by the NRC to assess the licensees

evaluation of the control of radioactive material. A finding previously characterized as

having low to moderate safety significance (White) was documented in the Final

Significance Determination for NRC Inspection Report 50-445/01-07; 50-446/01-07.

During this supplemental inspection performed in accordance with Inspection Procedure

95001, the inspector determined that the licensee performed a thorough, broad-based

evaluation of the causes of the radioactive material control issue and correctly identified

the extent of the conditions that led to the control problems. The licensees evaluation

identified 17 root causes. Corrective actions included: (1) conducting a pre-outage

stand-down with all station work groups to discuss the past associated problems and the

importance for control of radioactive material; (2) procedural revisions that clarified

radioactive material control expectations and identification programs; (3) improved

Radiation Worker Training lesson plans that stressed the need for and the controls in-

place for handling radioactive material; and, (4) increased staffing for monitoring and

controlling the release of radioactive material during outages. An effectiveness

evaluation of radiation protection activities, to include the control of radioactive material,

will be documented in Nuclear Oversight Department Evaluation 2002-015, at the

completion of refueling outage 2RFO6.

Because of the licensees acceptable performance in addressing the control of

radioactive material, the White finding associated with this issue will only be considered

in assessing plant performance for a total of four quarters, in accordance with the

guidance in IMC 0305, Operating Reactor Assessment Program.

Report Details

01 Inspection Scope

This supplemental inspection was performed to assess the licensees evaluation of the

root causes, contributing causes, and corrective actions associated with the White

radioactive material control finding. This performance issue was previously

characterized as White in NRC Inspection Report 50-445/01-07; 50-446/01-07 and is

related to the public radiation safety cornerstone in the radiation safety strategic

performance area.

The inspector interviewed radiation workers and reviewed the following documents:

Smart Form 2001-2621 and the associated root cause evaluation which

documented the control of radioactive material issue identified in NRC inspection

report 50-445/01-07; 50-446/01-07,

Nuclear Overview Department Draft Evaluation 2002-015; Station Procedure

STA-652, Radioactive Material Control, Revision 11; Nuclear Procurement

Services Procedure NPS-4.13, Control of Tools in the Radiologically Controlled

Area, Revision 3; Radiation Protection Instructions RPI-213, Survey and

Release of Material and Personnel, Revision 8; RPI-602, Radiological

Surveillance and Posting, Revision 20; and RPI-802, Performance of Source

Checks, Revision 6; Radiation Protection Guideline 2-1, RMC Activities,

Revision 0; Security Instruction 3.3, Vehicle/Material Delivery Access Control,

Revision 10, and

Radiation Worker Training lesson plans dated March 11, 2002.

02 Evaluation of Inspection Requirements

02.01 Problem Identification

a. Determine that the evaluation identifies who (i.e. licensee, self revealing, or

NRC), and under what conditions the issue was identified.

There were 11 events associated with the White finding. The details of the 11 events

are documented in NRC Inspection Report 50-445/01-07; 50-446/01-07. The licensee

documented all the events; however, two of these events were self revealing (Protected

area egress radiation portal monitors alarmed.) The other nine events were identified by

the licensee.

b. Determine that the evaluation documents how long the issue existed, and prior

opportunities for identification.

The evaluation documented that the licensee identified issues with the control of

radioactive material as early as January 2000. Corrective actions implemented during

this time period included discontinued use of launderable glove liners and the phasing-

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out of modesty garments with pockets. These actions were taken to help eliminate

contaminated glove liners from being removed from the radiologically controlled area.

c. Determine that the evaluation documents the plant specific risk consequences

(as applicable) and compliance concerns associated with the issue.

A plant specific probabilistic risk assessment is not applicable to this control of

radioactive material finding. However, the evaluation did identify that the continued

failure to properly control radioactive material may result in a loss of public confidence

with the safe operation of Comanche Peak Steam Electric Station.

02.02 Root Cause and Extent of Condition Evaluations

a. Determine that the problems were evaluated using a systematic method(s) to

identify root cause(s) and contributing cause(s).

The inspector concluded that the root cause analysis was performed in a systematic

manner which correctly and completely determined the root causes and contributing

factors. The evaluation team performed the root cause analysis using an industry

accepted methodology which employed the following techniques: records review,

personnel interviews, barrier analysis, and change analysis. The inspector determined

that the above root cause evaluation was performed in accordance with Station

Procedure STA-422, Processing Smart Forms, Revision 18. The licensee employed a

six-person root cause evaluation team led by a trained member of the licensee's staff.

b. Determine that the root cause evaluation was conducted to a level of detail

commensurate with the significance of the problem.

The licensees root cause evaluation identified 17 root causes. Recommended actions

fell into four general categories:

Release of radioactive material to areas outside the protected and satellite

radiologically controlled areas.

Plant wide communication to reinforce positive tool control practices.

Improvement of the radiologically controlled area tool control and identification

programs.

Facility changes to reduce the requirements for releasing large amounts of

material from the radiologically controlled area.

The inspector determined that each root cause evaluation focused on the overall events

and was conducted to the appropriate level of detail commensurate with the significance

of the problem. When combined, the evaluations were thorough, broad-based, and

conducted to a sufficient level of detail to enhance the program for the control of

radioactive material.

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c. Determine that the root cause evaluation included a consideration of prior

occurrences of the problem and knowledge of prior operating experience.

The inspector concluded that the root cause evaluation considered similar events

associated with the problem of maintaining control of radioactive material for the past

two years. From discussions with the licensees staff, the inspector determined that

industry experience was reviewed to help improve their program.

d. Determine that the root cause evaluation included consideration of potential

common cause(s) and extent of condition of the problem.

The licensees evaluation considered the potential common causes and the extent of the

conditions associated with the control of radioactive material. Common causes included

procedure deficiencies and lack of ownership for the control of radioactive materials on

the part of radiation workers.

02.03 Corrective Actions

a. Determine that appropriate corrective action(s) are specified for each

root/contributing cause or that there is an evaluation that no actions are

necessary.

The inspector concluded that the corrective actions appropriately addressed the

associated root causes. The inspector found that licensee representatives had

identified specific corrective actions to address each of the documented 17 root causes.

Corrective actions included: (1) holding a pre-outage stand-down with all station work

groups to discuss the importance for the control of radioactive material and the past

associated problems; (2) procedural revisions that clarified radioactive material control

expectations and identification programs; (3) improved Radiation Worker Training

lesson plans that stressed the need for and the controls in-place for handling radioactive

material; and, (4) increased staffing for monitoring and controlling the release of

radioactive material during outages.

The inspector determined that the corrective actions appeared to be appropriate to

prevent similar occurrences.

b. Determine that the corrective actions have been prioritized with consideration of

the risk significance and regulatory compliance.

The inspector concluded that the corrective actions were properly prioritized. A

completion date and priority were assigned for each corrective action.

c. Determine that a schedule has been established for implementing and

completing the corrective actions.

From a review of the root cause evaluation, the inspector determined that a schedule

had been developed for the completion of each corrective action. As of April 19, 2002,

all corrective actions were completed.

-4-

d. Determine that quantitative or qualitative measures of success have been

developed for determining the effectiveness of the corrective actions to prevent

recurrence.

From a review of Draft Nuclear Oversight Department (NOD) Evaluation 2002-015 and

discussions with members of the NOD, the inspector concluded that NOD performed

observations of radiation protection activities during refueling outage 2RFO6. An

effectiveness evaluation of radiation protection activities, including the control of

radioactive material, will be documented, at the completion of refueling outage 2RFO6.

4. OTHER ACTIVITIES

4OA3 Event Followup

(Closed) Violation (VIO) 50-445/0107-01; 50-446/0107-01(EA-01-304)

The Final Significance Determination for NRC Inspection Report 50-445/01-07;

50-446/01-07, documented a violation that involved 11 examples in which radiological

surveys to detect radioactivity required by Technical Specification procedures were not

adequate. The inspector reviewed the licensees root cause determination and

associated corrective action document (Smart Form 2001-2621) pertaining to the

Technical Specification 5.4.1.a violation. The licensees evaluation identified corrective

actions that fell into four general categories: (1) Release of radioactive material to areas

outside the protected and satellite radiologically controlled areas, (2) Plant wide

communication to reinforce positive tool control practices, (3) Improvement of the

radiologically controlled area tool control and identification programs, and (4) Facility

changes to reduce the requirements for releasing large amounts of material from the

radiologically controlled area.

The inspector concluded that the licensees corrective actions adequately addressed the

root causes.

4OA6 Management Meetings

Exit Meeting Summary

The inspector presented the inspection results to Mr. L. Terry, Senior Vice-President

and Principal Nuclear Officer, and other members of licensee staff at the conclusion of

the inspection on April 25, 2002. The licensee acknowledged the findings presented.

This meeting constituted the regulatory performance meeting specified in the Inspection

Manual Chapter 0305 action matrix.

The inspector asked the licensee whether any materials examined during the inspection

should be considered proprietary. No proprietary information was identified.

Attachment 1

PARTIAL LIST OF PERSONS CONTACTED

Licensee

S. Bradley, Supervisor, Radiation Protection

J. Curtis, Manager, Radiation Protection

T. Hope, Manager, Regulatory Compliance

D. Kay, Supervisor, Radiation Protection

J. Kelly, Vice-President Engineering

M. Lucas, Manager, Nuclear Oversight Department

R. McGaughy, Engineer, Nuclear Oversight Department

C. Terry, Senior Vice-President and Principal Nuclear Officer

R. Walker, Manager, Regulatory Affairs

D. Wilder, Manager, Radiation and Industrial Safety

C. Wilkerson, Senior Engineer, Regulatory Affairs

NRC

G. Good, Chief, Plant Support Branch

ITEMS OPENED, CLOSED, AND DISCUSSED

Closed During this Inspection

50-445;446/0107-01 VIO Failure to survey (EA-01-304)

SUMMARY OF FINDINGS

Comanche Peak

NRC Inspection Report No. 50- 445; 50-446

INSPECTION PERIOD APRIL 23-25, 2002

IR 05000445-02-03; IR 05000446-02-03; on 04/23-25/2002; TXU Electric; Comanche Peak

Steam Electric Station; Units 1 and 2. Regional Report.

The inspection was conducted by a regional office inspector. The inspection identified no

findings of significance. The significance of issues is indicated by their color (Green, White,

Yellow, or Red) and was determined by the Significance Determination Process in Inspection

Manual Chapter 0609. The NRCs program for overseeing the safe operation of commercial

nuclear power reactors is described at its Reactor Oversight Process website at

http://www.nrc.gov/NRR/OVERSIGHT/index.html.

M. Shannon (4640)

Cornerstone: Public Radiation Safety

PIM NRC FIN PS April 25, 2002 95001

Supplemental inspection results

A supplemental inspection was performed by the NRC to assess the licensees