ML060750831

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Errata for Comanche Peak Steam Electric Station - NRC Integrated Inspection Report 05000445-05-005 & 05000446-05-005
ML060750831
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 03/14/2006
From: Clay Johnson
NRC/RGN-IV/DRP/RPB-A
To: Blevins M
TXU Power
References
IR-05-005
Download: ML060750831 (9)


See also: IR 05000445/2005005

Text

March 14, 2006

Mike Blevins, Senior Vice President

and Chief Nuclear Officer

TXU Power

ATTN: Regulatory Affairs

Comanche Peak Steam Electric Station

P.O. Box 1002

Glen Rose, TX 76043

SUBJECT: ERRATA FOR COMANCHE PEAK STEAM ELECTRIC STATION - NRC

INTEGRATED INSPECTION REPORT 05000445/2005005 AND

05000446/2005005

Dear Mr. Blevins:

Please replace the Summary of Findings and page 11 of the Report Details in NRC Inspection

Report 05000445/2005005 and 05000446/2005005, dated February 13, 2006, with the attached

revised pages. The following changes are necessary to (1) delete the sentence in the

Summary of Findings for the first finding "This finding has a problem identification and

resolution crosscutting aspect because it was caused by lack of effective corrective actions";

(2) delete several phrases and words located in the Summary of Findings (fourth finding, both

paragraphs) and (3) delete several phrases and words in Section 1R08.1, (Description and

Enforcement paragraphs) to clarify the issues.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure 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/

Claude Johnson, Chief

Project Branch A

Division of Reactor Projects

Docket Nos.: 50-445, 50-446

License Nos.: NPF-87, NPF-89

TXU Power

2

-2-

Enclosure:

Errata pages for NRC Inspection Report 05000445/2005005 and 05000446/2005005

cc w/enclosure:

Fred W. Madden, Director

Regulatory Affairs

TXU Power

P.O. Box 1002

Glen Rose, TX 76043

George L. Edgar, Esq.

Morgan Lewis

1111 Pennsylvania Avenue, NW

Washington, DC 20004

Terry Parks, Chief Inspector

Texas Department of Licensing

and Regulation

Boiler Program

P.O. Box 12157

Austin, TX 78711

The Honorable Walter Maynard

Somervell County Judge

P.O. Box 851

Glen Rose, TX 76043

Richard A. Ratliff, Chief

Bureau of Radiation Control

Texas Department of Health

1100 West 49th Street

Austin, TX 78756-3189

Environmental and Natural

Resources Policy Director

Office of the Governor

P.O. Box 12428

Austin, TX 78711-3189

Brian Almon

Public Utility Commission

William B. Travis Building

P.O. Box 13326

Austin, TX 78711-3326

TXU Power

3

-3-

Susan M. Jablonski

Office of Permitting, Remediation and Registration

Texas Commission on Environmental Quality

MC-122

P.O. Box 13087

Austin, TX 78711-3087

Technological Services Branch

Chief

FEMA Region VI

800 North Loop 288

Federal Regional Center

Denton, Texas 76201-3698

TXU Power

4

-4-

Electronic distribution by RIV:

Regional Administrator (BSM1)

DRP Director (ATH)

DRS Director (DDC)

DRS Deputy Director (RJC1)

Senior Resident Inspector (DBA)

Branch Chief, DRP/A (CEJ1)

Senior Project Engineer, DRP/A (TRF)

Team Leader, DRP/TSS (RLN1)

RITS Coordinator (KEG)

Regional State Liaison Officer (WAM)

NSIR/DIPM/EPHP (REK)

Only inspection reports to the following:

DRS STA (DAP)

J. Dixon-Herrity, OEDO RIV Coordinator (JLD)

ROPreports

CP Site Secretary (ESS)

SUNSI Review Completed: __CEJ ADAMS: / Yes

G No Initials: CEJ___

/ Publicly Available G Non-Publicly Available G Sensitive

/ Non-Sensitive

R:\\_REACTORS\\_CPSES\\2005\\CP2005-05 errata.wpd

RIV:C:DRP/A

CEJohnson

/RA/

3/14/06

OFFICIAL RECORD COPY

T=Telephone E=E-mail F=Fax

ENCLOSURE

Revised Pages for NRC Integrated Inspection

Report 05000445/2005005 AND 05000446/2005005

Enclosure

-3-

SUMMARY OF FINDINGS

IR 05000445/2005005, 05000446/2005005; 09/24/2005-12/31/2005; Comanche Peak Steam

Electric Station, Units 1 and 2; Inservice Inspection Activities, Event Follow-up, and Other

Activities

This report covered a 3-month period of inspection by two resident inspectors, two reactor

inspectors, one operations engineer, one emergency preparedness inspector, one regional

project engineer, and one consultant. Four Green noncited violations were identified. The

significance of most findings is indicated by their color (Green, White, Yellow, Red) using

Inspection Manual Chapter 0609, Significance Determination Process (SDP). Findings for

which the SDP does not apply may be Green or may be assigned a severity level after NRC

management review. The NRC's program for overseeing the safe operation of commercial

nuclear power reactors is described in NUREG-1649, ?Reactor Oversight Process, Revision 3,

dated July 2000.

A.

NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

C

Green. A Green self-revealing noncited violation of Technical Specification 5.4.1.a was identified for failure to implement the maintenance procedure to

properly install a check valve in the Emergency Diesel Generator 1-01 lubrication

system. On October 20, 2005, the diesel generator shutdown for lack of lube oil

to the turbo-chargers after 60 seconds during a post maintenance test. The lube

oil strainer check valve had been installed backwards during the previous

refueling outage but the opposite strainer had been in service for the ensuing 18

months. The check valve was reinstalled properly, the flow direction of similar

check valves verified, and the damaged turbo-chargers replaced.

The violation was more than minor because one of two lube oil strainers for the

turbo-chargers was incapable of flow, thus affecting the reliability of the diesel

generator. The finding has a human performance crosscutting aspect because

the failure to follow the procedure caused the diesel generator failure. However,

the error was committed in April 2004. The violation is of very low safety

significance because CPSES operating experience indicated that the lube oil

strainers had never been swapped outside of an outage, and then only to

balance run time on the equipment. The significance determination process

screened this out as Green because it only affected the mitigating systems

cornerstone and it did not cause an actual loss of safety function of a single train

nor a loss of safety function that contributed to external event initiated core

damage sequences. This event was entered into the corrective action program

as Smart Form 2005-004233 (Section 4OA3.1).

Enclosure

-4-

C

Green. A Green self-revealing noncited violation of Appendix B, Criterion XVI

was identified for failure to implement effective corrective actions for a significant

condition adverse to quality. Specifically, station service water Pump 1-01 was

returned to service on October 20, 2005, and after two hours of operation tripped

on an electrical fault on Phase C of the motor leads. The degraded electrical

condition of the motor lead had been identified during restoration from the pump

maintenance, but the actions taken to ensure the pump was reliable failed.

Phase C of the motor leads was replaced prior to returning the pump to service.

The failure to take effective corrective actions was the performance deficiency.

The violation was more than minor because the pump was returned to service

with a degraded motor lead. At the time of the event, Unit 1 was defueled and

did not require an operable station service water pump. However, Unit 2 was

required by Technical Specifications 3.7.8 to have at least one operable station

service water pump from the opposite unit. With Unit 2 at 100 percent power, a

significance determination was performed using Appendix A of Manual

Chapter 0609. The finding was determined to be of very low safety significance

(Green) because it did not represent a loss of system safety function, was not an

actual loss of safety function for a single Unit 2 train, did not involve equipment

or function specifically designed to mitigate a seismic, flooding, or severe

weather initiating event, and did not involve the total loss of any safety function

that contributed to external event initiated sequences. The cause of this finding

is related to the crosscutting aspects of problem identification and resolution.

The event was entered into the corrective action program as Smart

Form 2005-004220 (Section 4OA3.2).

Green. A Green self-revealing noncited violation of Technical Specification 3.8.1

was identified, after both the alternate and emergency power supplies to a

6.9 kV safeguards bus failed to provide power to the bus within the time

assumed in the accident analysis. On October 19, 2004, an unplanned loss of

the preferred offsite power caused the Unit 2, Train B, 6.9 kV safeguards bus to

de-energize. A degraded Agastat relay delayed the normal power supply

breaker from opening for 30 seconds, which delayed powering the bus from the

alternate offsite AC power supply or the emergency diesel generator. This issue

had crosscutting aspects in the area of problem identification and resolution

because the licensee previously identified that aged Agastat relays were

unreliable and should be replaced if they were in service greater than 12 years.

The failed relay had been in service for 16 years.

The violation was more than minor because it impacted the Mitigating Systems

Cornerstone objective of availability, reliability, and capability of systems that

respond to initiating events. Using Inspection Manual Chapter 0609,

Appendix AProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix A" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Determining the Significance of Reactor Inspection Findings for

At-Power Situations, the finding was determined to be of very low safety

significance because the likelihood of a medium or large break loss of coolant

accident coincident with a loss of offsite power, which are the only conditions

where the deficiency would cause a non-negligible change in the baseline risk

Enclosure

-5-

profile, is less than or equal to 1E-6 per year. Therefore the change in core

damage frequency will be less than 1E-6 per year. The licensee captured the

issue in their corrective action program as Smart Form SMF-2004-003528

(Section 4OA5.2).

Cornerstone: Barrier Integrity

Green. A Green noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI

(Corrective Action) was identified, in that licensee personnel failed to take

effective corrective action for a condition adverse to quality. Specifically,

licensee welders repaired a body-to-bonnet leak on Valve 1-8702B, Residual

Heat Removal Pump 1-02 hot-leg recirculation isolation valve, in April 2004 by

installing a seal weld. The valve required additional repair in October 2005 for a

body-to-bonnet leak.

The failure to take effective corrective action for a body-to-bonnet leak on

Valve 1-8702 B was a performance deficiency. This finding is greater than minor

because it is similar to Example 3.g. of Appendix E of Manual Chapter 0612

because the leakage reoccurred. The inspectors found this finding screened out

of the Phase 1 process as Green. The inspectors considered this finding to be

of very low safety significance because the event was leakage and not a line

break. The cause of this finding is related to the crosscutting aspects of problem

identification and resolution. (Section 1R08.1)

B.

Licensee Identified Violations

None.

Enclosure

-11-

because of evidence of boron leakage since 1995. The valves were 2-8378B, Reactor

Coolant System Loop 2-04 charging upstream check valve; 2-8379A, and 2-8379B,

Reactor Coolant System Loop 2-01 charging system downstream check valves.

Licensee personnel found all of these welds to subsequently leak within a year in 1996.

In 2005, licensee welders also repaired two valve body-to-bonnet flanged connections

because of evidence of leakage. These valves were numbered 2-8818B and 2-8818C,

residual heat removal loop check valves. In summary, this repair has been done six

times and failed four times. Two of the six times this repair has been done are unknown

at this time in respect to leakage because a refueling outage has not occurred. The

inspectors considered the evidence of boron leakage in these body-to-bonnet flanged

connections to be a condition adverse to quality.

Analysis. The inspectors found this finding to be greater than minor because it is similar

to Example 3.g. of Appendix E of Manual Chapter 0612 because the leakage reccurred.

The inspectors considered this finding as of very low safety significance because the

event was leakage and not a line break. The inspectors found this finding screened out

of the Phase 1 process as Green. The licensee issued a Smart Form (SMF)

SMF-2005-004209 regarding this finding.

Enforcement. Criterion XVI, Corrective Actions, of Appendix B to 10 CFR Part 50

states, in part, that measures shall be established to assure that conditions adverse to

quality are promptly identified and corrected. Contrary to the above, corrective actions

were inadequate in that leakage of the body-to-bonnet flanged connections on

Valve 1-8702B after previous repair in 2004, and on Valves 2-8378B,

2-8379A/B in 1995, were recurrent. The inspectors identified this finding as an NCV

because of its very low safety significance and because the licensee has entered this

finding in its corrective action program. This is consistent with Section VI.A. of the NRC

Enforcement Policy: NCV 05000445/2005005-01, Inadequate Corrective Actions for a

Leaking Valve with a Seal Weld which Subsequently Leaked.

.2

Pressurizer Water Reactor Vessel Upper Head Penetration Inspection Activities

(Section 02.02)

a. Inspection Scope

The inspection procedure requires observation or review of upper head inspections after

the completion of Temporary Instruction 2515/150. The procedure requires samples

similar in number to the preceding section.

The licensee plans to replace this head, and thus close the Temporary

Instruction 2515/150. The licensee did not perform upper head inspections other than

visual during this outage. The visual inspection activities are documented in

Section 1R20 of this report.