ML081930568
| ML081930568 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/11/2008 |
| From: | Clay Johnson NRC/RGN-IV/DRP/RPB-A |
| To: | Blevins M Luminant Generation Co |
| References | |
| IR-08-009 | |
| Download: ML081930568 (14) | |
See also: IR 05000445/2008009
Text
July 11, 2008
Mike Blevins, Executive Vice President
and Chief Nuclear Officer
Luminant Generation Company LLC
ATTN: Regulatory Affairs
Comanche Peak Steam Electric Station
P.O. Box 1002
Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION - NRC SUPPLEMENTAL
INSPECTION REPORT 05000445/2008009 AND 05000446/2008009
Dear Mr. Blevins:
On June 6, 2008, the U.S. Nuclear Regulatory Commission completed an inspection at your
Comanche Peak Steam Electric Station, Units 1 and 2, facility. The enclosed supplemental
inspection report documents the inspection findings which were discussed at the exit meeting
on June 5, 2008, with Mr. R. Flores and other members of your staff.
The NRC performed this supplemental inspection to assess your evaluation associated with a
White finding in the first quarter of 2008 (failure of Unit 1 Train B Emergency Diesel
Generator 1-02). Detailed observations, assessments, and conclusions of the inspection are
presented in the enclosed inspection report.
The inspection concluded that the root causes of the finding were adequately defined and
understood, and the corrective actions resulting from the evaluations appropriately addressed
the identified causes.
Based on the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRCs 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), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (The Public Electronic Reading Room).
Sincerely,
/RA/
Claude E. Johnson, Chief
Project Branch A
Division of Reactor Projects
UNITED STATES
NUCLEAR REGULATORY COMMISSION
R E GI ON I V
612 EAST LAMAR BLVD, SUITE 400
ARLINGTON, TEXAS 76011-4125
Luminant Generation Company LLC
- 2 -
Dockets: 50-445; 50-446
Enclosure:
NRC Inspection Report 05000445/2008009 and 05000446/2008009
cc w/enclosure:
Mr. Fred W. Madden, Director
Regulatory Affairs
Luminant Generation Company LLC
P.O. Box 1002
Glen Rose, TX 76043
Timothy P. Matthews, Esq.
Morgan Lewis
1111 Pennsylvania Avenue, NW
Washington, DC 20004
County Judge
P.O. Box 851
Glen Rose, TX 76043
Mr. 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
Mr. Brian Almon
Public Utility Commission
William B. Travis Building
P.O. Box 13326
1701 North Congress Avenue
Austin, TX 78701-3326
Ms. Susan M. Jablonski
Office of Permitting, Remediation
and Registration
Texas Commission on
Environmental Quality
MC-122
P.O. Box 13087
Austin, TX 78711-3087
Luminant Generation Company LLC
- 3 -
Anthony Jones
Chief Boiler Inspector
Texas Department of Licensing
And Regulation
Boiler Division
E.O. Thompson State Office Building
P.O. Box 12157
Austin, TX 78711
Luminant Generation Company LLC
- 4 -
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
DRP Director (Dwight.Chamberlain@nrc.gov)
DRP Deputy Director (Anton.Vegel@nrc.gov)
DRS Director (Roy.Caniano@nrc.gov)
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (John. Kramer@nrc.gov)
Branch Chief, DRP/A (Claude.Johnson@nrc.gov
Senior Project Engineer, DRP/A (Thomas.Farnholtz@nrc.gov)
Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Only inspection reports to the following:
J. Adams, OEDO RIV Coordinator (John.Adams@nrc.gov)
P. Lougheed, OEDO RIV Coordinator (Patricia.Lougheed@nrc.gov)
ROPreports
CP Site Secretary (Sue.Sanner@nrc.gov)
SUNSI Review Completed: CEJ ADAMS: Yes
No Initials: CEJ
Publicly Available Non-Publicly Available Sensitive Non-Sensitive
R:\\_REACTORS\\_CPSES\\2008\\CP2008-009 RBC.doc ML 081930568
RIV:RI:DRP/A
C:DRP/A
RBCohen
CEJohnson
/RA electronic/
/RA/
07/09/08
07/11/08
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
- 1 -
Enclosure
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
Dockets:
50-445, 50-446
Licenses:
Report :
05000445/2008009 and 05000446/2008009
Licensee:
Luminant Generation Company LLC
Facility:
Comanche Peak Steam Electric Station, Units 1 and 2
Location:
Dates:
June 2-6, 2008
Inspector:
R. Cohen, Resident Inspector
Approved by:
C. Johnson, Chief, Project Branch A
Division of Reactor Projects
- 2 -
Enclosure
SUMMARY OF FINDINGS
IR 05000445/2008009, 05000446/2008009; 06/02/2008 - 06/06/2008; Comanche Peak Steam
Electric Station, Units 1 and 2, Procedure 95001 Supplemental Inspection.
This report covers a one week period of inspection by a Comanche Peak Steam Electric Station
based resident inspector. No violations were identified. The significance of most findings is
indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609,
Significance Determination Process." Findings for which the significance determination
process does not apply may be Green or be assigned a severity level after NRC managements
review. The NRCs program for overseeing the safe operation of commercial nuclear power
reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated
December 2006.
Cornerstone: Mitigating Systems
The U.S. Nuclear Regulatory Commission performed this supplemental inspection to
assess the licensees evaluation associated with a White finding (failure of Unit 1 Train B
Emergency Diesel Generator 1-02) in the first quarter of 2008. The primary reason for
this finding being characterized as White was based on the results of a Phase 3 analysis
performed by a region-based senior reactor analyst. The failure of Emergency Diesel
Generator 1-02 was attributed to paint being deposited in a location that caused the EDG
to fail to start on demand. During this supplemental inspection, performed in accordance
with Inspection Procedure 95001, the inspector determined that the licensee identified
the most probable cause of the diesel failure to start, adequately determined the
apparent root cause and significant contributing causes, and established appropriate
corrective actions to prevent recurrence. The licensees evaluation identified that the
most probable cause was a drop of paint that adhered to the fuel pump control rack so as
to keep it from operating as designed. The paint came from a maintenance activity
where the Train B emergency diesel generators in both units were being painted to
improve material condition. The root cause analysis determined that, although there was
no documented evidence that a drop of paint was on the fuel rack at the time of the test,
there was evidence that a drop of paint was there at one time.
- 3 -
Enclosure
REPORT DETAILS
01
INSPECTION SCOPE
The U.S. Nuclear Regulatory Commission (NRC) performed this supplemental
inspection to assess the licensees evaluation associated with a White finding (Train B
Emergency Diesel Generator [EDG]) in the first quarter 2008.
Unit 1 Train B EDG 1-02 failed to start on demand. The primary reason for this finding
being characterized as White was based on the results of a Phase 3 analysis performed
by a region-based senior reactor analyst. The failure of EDG 1-02 was attributed to a
drop of paint being deposited in a location that caused the EDG to fail to start on
demand during a monthly surveillance test on November 21, 2007. Following 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />
of troubleshooting, EDG 1-02 was restored to operable status.
The supplemental inspection was focused on the event occurring since the last
successful surveillance test on EDG 1-02 on October 24, 2007, and when the diesel was
returned to operable status, November 22, 2007, whether root causes and contributing
causes were understood, whether extent of conditions and extent of causes were
identified, and whether sufficient corrective actions were taken to prevent recurrence.
02
EVALUATION OF INSPECTION REQUIREMENTS
02.01 Problem Identification
a.
Determination of who (i.e., licensee, self-revealing, or NRC) identified the issue and
under what conditions
Paint that was deposited and adhered to a fuel rack in a location that prevented Unit 1
Train B EDG 1-02 to start on demand during a monthly surveillance test was
self-revealing. EDG 1-02 was declared inoperable on November 21, 2007.
b.
Determination of how long the issue existed and prior opportunities for identification
The issue existed some time between the last successful test on October 24, 2007, and
the monthly surveillance test failure that occurred on November 21, 2007. EDG 1-02
successfully started and loaded during a surveillance performed on October 24, 2007.
The diesel failed to start during a monthly surveillance test on November 21, 2007,
because the fuel rack on at least one fuel injection pump was bound to the extent that
the entire fuel rack assembly was unable to leave the no fuel position. This was
caused by painting activities on and around the diesel. Painting activities to improve the
appearance of EDG 1-02 started on October 15, 2007, and ended on November 21,
2007. The licensee determined that no root cause was identified; however, it is believed
that the most probable cause of EDG 1-02 failure to start was a paint drop that was not
cleaned off of the 6L fuel pump control rack. This paint drop prevented the operation of
the control rack from moving into the fuel pump and at the same time restricted
operation of all other 15 fuel racks on the EDG 1-02. The failure of this component to
respond to the diesel start prevented the engine from receiving sufficient fuel to run.
- 4 -
Enclosure
The licensee had prior opportunities to identify this condition. The licensee determined
that although there were daily inspections of the engine performed by painters, paint
supervisors and an operations field support supervisor or operations nuclear equipment
operators, paint could still be found on sensitive components. Not only did these
inspections fail to cause this paint to be removed from the sensitive components, but
they also failed to identify the existence of the paint drop on the 6L fuel pump control
rack. This is supported by photographs taken immediately after the event that showed
that some components had paint on them but should have been free of paint according
to a pre-job briefing notebook that was used by painters. This notebook identified
sensitive components that were not to be painted or have paint on them.
The inspector reviewed the records describing the as-found condition of the diesel,
reviewed the tests and analysis performed on EDG 1-02, and discussed the issue with
the dispositioning manager and the diesel system engineer. As a result of these
activities, the inspector agreed that EDG 1-02 failed to start due to paint being deposited
on the diesel fuel rack linkage during painting activities on and around EDG 1-02
between October 24 and November 21, 2007.
c.
Determination of the plant-specific risk consequences (as applicable) and compliance
concerns associated with the issue
The licensee determined that EDG 1-02 was inoperable for a period of time since the
last successful surveillance on October 24, 2007, and November 21, 2008 when EDG 1-
02 was successfully started. On November 7, 2007, the redundant train EDG 1-01 was
being barred over in preparation for its monthly surveillance test. During this 65 minute
period, two trains of emergency power may not have been operable. To account for the
increased risk of the EDG 1-01 being taken out of service for 65 minutes, EDG 1-02 was
assumed to be unavailable (due to the failure on November 21, 2007). Although the
EDG 1-01 was removed from service for a surveillance test, the EDG 1-01 was
considered to be recoverable during a water roll and available during the run portion of
the surveillance. The configuration risk for the period of unsure operability was found to
be risk significant (total of 9.47E-06). It was noted that even if an exposure time 14 days
(T/2) is used, since the actual time that the EDG 1-02 became unavailable is not known,
the configuration risk value would still be risk significant (4.90E-06). A Phase 3 analysis
performed by a Region IV senior reactor analyst determined that the total change in core
damage frequency was 8.93E-6 which is considered comparable to the licensees
results. The analyst used the SPAR model for CPSES (Comanche Peak Steam Electric
Station) to estimate the change in risk associated with internal initiators that was caused
by the finding.
02.02 Root Cause and Extent of Condition Evaluation
a.
Evaluation of methods(s) used to identify root cause(s) and contributing cause(s)
To evaluate this issue, the licensee used a combination of structured root cause analysis
techniques including barrier analysis, confirm refute matrix, and event and casual factor
chart. The inspector determined that the licensee followed its procedural guidance for
performing root cause analysis. The procedural guidance is contained in
Procedure CPSES Cause Analysis Handbook, Revision 10.
- 5 -
Enclosure
b.
Level of detail of the root cause evaluation
The licensees root cause evaluation was thorough and identified the most probable
cause of the Unit 1 Train B EDG 1-02 failure to start on demand during a monthly
surveillance test. This cause was due to a paint drop being deposited on the diesel fuel
rack linkage during painting activities on and around EDG 1-02. This paint drop was not
cleaned off of the 6L fuel injector control rack after painting activities. This paint drop
prevented the operation of the control rack from moving into the 6L fuel pump and at the
same time restricted operation of the other 15 fuel racks on EDG 1-02. The failure of
this component to respond to the diesel start prevented the engine from receiving
sufficient fuel to run. Painting Procedure MSM-G0-0220, General Plant Painting,
Revision 2, allowed a visual inspection for paint or a manual manipulation of the fuel
rack.
In addition, significant contributing causes were identified which included: (1) work
practices of painters and other groups who performed daily paint clean up inspections
failed to identify paint spatter and drops that needed to be cleaned off sensitive engine
components, (2) painters tools and techniques were not completely effective in
preventing paint spatter and drips, (3) the directions in Control Room Alarm
Procedure ALM-1302A, Revision 5, were not specific and due to differences in
interpretation, the time to discover the problem was extended for approximately
8.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, (4) the fuel control shaft break away force was last performed in 1999 and,
due to aging, the licensee believes that this force may have increased because of wear.
This increased force may have contributed to the force it would have taken to overcome
the adhesion of the paint drop.
c.
Consideration of prior occurrences of the problem and knowledge of prior operating
experience
The licensees evaluation included a review to determine if similar problems had
previously been reported with painting activities resulting in inoperability of an EDG. The
review included both internal (Comanche Peak) and external operating experience. An
internal operating experience review determined that no prior experiences were found
associated with mechanical binding of EDG control linkage as a result of painting
activities causing a failure to start of any EDGs. The external operating experience
search returned records where paint was determined to cause the failure to start of
EDGs as a result of gross painting errors (e.g., painting activities causing binding of
control linkages). In several cases, paint was found on fuel metering rods. The licensee
reported that these events differed from the CPSES event because paint was
purposefully applied directly to the control linkages, where at CPSES, the paint was
accidentally splattered or dripped onto the fuel rack. The inspector did not possess any
information to the contrary.
d.
Consideration of potential common cause(s) and extent of condition of the problem
The licensees evaluation considered the potential for common causes and extent of
condition associated with painting activities resulting in inoperability of EDG1-02. The
licensee reported that the extent of condition applied to three other EDGs, but in
particular, the EDG 2-02 which was being painted in a parallel activity at the same time.
The licensees extent of cause evaluation stated that paint can block vent holes, air
pathways, and bind mechanical equipment when it dries. No other vulnerabilities were
- 6 -
Enclosure
identified. The inspector considered the extent of condition and the extent of cause
evaluations to be adequate to address this concern.
02.03 Corrective Actions
a.
Appropriateness of corrective action(s)
After it was identified that EDG 1-02 failed to start on November 21, 2007, the licensee
declared EDG 1-02 inoperable and entered the applicable Technical Specification (TS)
action statement. Troubleshooting and investigating activities were initiated. It was
determined that a paint drop was deposited and remained on at least one fuel rack in a
location that prevented motion required to support the operation of EDG 1-02. The
licensee satisfied the Technical Specification required actions by restoring the EDG to
an operable status on November 22, 2007.
The licensee established corrective actions to prevent recurrence including: (1) develop
and implement procedures to ensure that a maintenance pull test of the fuel rack
mechanisms ensures they are free to operate after painting activities, (2) develop an as
you go inspection and clean up when painting around sensitive components, (3) use
this issue as operational experience in prejob briefing for painters to heighten their
sensitivity to the problems paint drops and spatter can cause for mechanical linkages,
(4) develop a checklist to be used by the painters to perform an inspection of equipment
in applicable areas of the plant, (5) procure paint brushes which can better hold paint
without drips, (6) investigate alternate techniques of painting which would minimize paint
drips and spatter on sensitive engine components, (7) revised diesel failure to start
alarm response procedure that components are free to move by including an action to
manually manipulate the fuel racks, (8) perform a break away force test on a periodic
basis to ensure that the fuel rack operating resistance has not increased to the extent
that could degrade engine response and control, and (9) assess the effectiveness of the
corrective actions to prevent recurrence. The inspector determined that the proposed
corrective actions were appropriate.
b.
Prioritization of corrective actions
The licensees immediate corrective actions restored the EDG 1-02 to operable status
within the Technical Specification allowed outage time. After the EDG was returned to
operable status, the licensee inspected other potentially affected EDGs to assess the
extent of condition. The inspector verified that these inspections did not reveal similar
condition on other diesel generators due to painting activities. The inspector considered
the prioritization of corrective actions to be appropriate.
c.
Establishment of schedule for implementing and completing the corrective actions
The licensee established adequate schedules for completion of the specified corrective
actions. The troubleshooting, investigation, and the return of the EDG 1-02 to operable
status was completed at the earliest opportunity and within the Technical Specification
allowable outage time. The procedure improvements had been completed at the time of
the inspection and incorporated into Procedures MSM-G0-0220, General Plant Painting
Procedure, Revision 2, and ALM-1302A, Alarm Procedure Diesel Generator 1-02
Panel, Revision 5.
- 7 -
Enclosure
d.
Establishment of quantitative or qualitative measures of success for determining the
effectiveness of the corrective actions to prevent recurrence
Smart Form SMF-2008-0000418-00 specified an action to perform an effectiveness
review to determine if corrective actions have corrected the cause of the identified
condition or has created barriers to reduce the frequency and consequences of the
cause of the identified condition to acceptable levels. This action involves performing a
self-assessment to measure the effectiveness of the process changes to ensure future
painting activities around safety-related EDGs do not effect the safety function of the
EDGs. Success criteria are specified in the corrective action plan. This action has a
due date of November 11, 2008. The inspector considered this to be adequate to
determine the effectiveness of the corrective actions to prevent recurrence.
03
MANAGEMENT MEETINGS
Exit Meeting Summary
On June 5, 2008, the inspector presented the inspection results to Mr. R. Flores, Site
Vice President, and members of his staff who acknowledged the findings. The inspector
confirmed that proprietary information was provided or examined during the inspection
and the inspector destroyed this information at the conclusion of the inspection.
ATTACHMENT: SUPPLEMENTAL INFORMATION
- 1 -
Attachment
LIST OF DOCUMENTS REVIEWED
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
M. Blevins, Executive Vice President and Chief Nuclear Officer
M. Bozeman, Supervisor, Emergency Planning
G. Casperson, Interim Manager, Training
H. Davenport, System Engineer
R. Flores, Site Vice President
D. Goodwin, Director, Operations
A. Heap, System Engineer
T. Hope, Manager, Regulatory Performance
R. Kidwell, Licensing Analyst
D. Kross, Plant Manager
F. Madden, Director, Regulatory Affairs
M. McCutchen, System Engineer
E. Meaders, Manager, Outage
J. Mercer, Maintenance Rule Coordinator
G. Merka, Licensing Analyst
J. Meyer, Manager, Nuclear Technical Support
W. Morrison, Interim Director, Nuclear Maintenance
W. Reppa, Manager, System Engineering
J. Skelton, System Engineer
K. Strickland, Supervisor, Nuclear Maintenance
P. Torres, Supervisor, Nuclear Maintenance
C. Tran, Engineering Programs Manager
D. Wilder, Manager, Security, Emergency Planning, and Environmental
H. Winn, System Engineer
NRC
C. Johnson, Chief, Project Branch A, DRP
D. Allen, Senior Resident Inspector, CPSES
B. Tindell, Resident Inspector, CPSES
LIST OF ITEMS, OPENED, CLOSED, AND DISCUSSED
Opened and Closed
None
LIST OF DOCUMENTS REVIEWED
Smartforms/Evaluations
Eval-2007-003253-00
SMF-2004-001177-00
SMF-2004-001884-00
SMF-2006-003157-00
SMF-2007-002401-00
SMF-2007-003035-00
SMF-2008-001905-00
SMF-2008-001906-00
SMF-2008-001908-00
- 2 -
Attachment
SMF-2004-002972-00
SMF-2005-000395-00
SMF-2006-001656-00
SMF-2007-003302-00
SMF-2007-003426-00
SMF-2008-001898-00
SMF-2008-001910-00
SMF-2008-001980-00
Licensee Event Reports
LER 2007-01-00, EDG Failed Surveillance Test Due to Paint on Fuel Injector Control Linkage,
Comanche Peak Unit 1
Procedures
NUMBER
TITLE
REVISION
MSM-GO-0220
General Plant Painting
2
ALM-1302A
Diesel Generator 1-02 Panel
5
MSM-P0-3374
EDG Monthly Run Related Inspections
3
MSM-GO-0216
Protective Coatings
23
OPT-214A
Emergency Diesel Operability Test
19
OWI-104-28
Plant Equipment Operator Diesel Generator 1-02
Operating Log;
11
MSM-GO-0220
Diesel Generator Painting Pre-Job Work Aid
0
STA-202
Nuclear Generation Procedure Change Process
32
OPT 214A
EDG Operability Test
19
ES Cause Analysis Handbook
10
Work Orders
3439601
3439604
4-07-176543
4-07-176545
4-07-276544
5-07-502391
Drawings
Fuel Control Shaft Break Away Force Study dated October 8, 1999
Other
CPSES Operations Logs, dated November 21-22, 2007
Root Cause Analysis, Eval-2007-003253-02-02
TU Electric Office Memorandum; CPSES-9800371; Expectations For Procedure Compliance;
dated February 2, 1998
OE 26026, Unit 1 B-Train EDG Failed to Start at Comanche Peak
- 3 -
Attachment
Information Notices
IN 93-76, Inadequate Control of Paint and Cleaners for Safety-Related Equipment
IN 91-46, Degradation of EDG Fuel Oil Delivery Systems
NRC Inspection Documents
Manual Chapter 0612 Appendix C; Guidance For Supplemental Inspections; June 20, 2003
NRC Inspection Plan - Comanche Peak 95001; INSPECTION FOR ONE OR TWO WHITE
INPUTS IN A STRATEGIC PERFORMANCE AREA; dated May 29, 2008
Inspection Report Numbers 05000445/2008009 and 05000446/2008009
Inspection Procedure 95001, Inspection For One Or Two White Inputs In A Strategic
Performance Area, dated October 16, 2006
NRC Inspection Report