ML15320A100
| ML15320A100 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/13/2015 |
| From: | Ruesch E Division of Reactor Safety IV |
| To: | Flores R Luminant Generation Co |
| H. Freeman | |
| References | |
| EA-15-207 IR 2015008 | |
| Download: ML15320A100 (38) | |
See also: IR 05000445/2015008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511
November 13, 2015
Rafael Flores, Senior Vice President
and Chief Nuclear Officer
Attention: Regulatory Affairs
Luminant Generation Company LLC
Comanche Peak Nuclear Power Plant
P.O. Box 1002
Glen Rose, TX 76043
SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT - NRC PROBLEM
IDENTIFICATION AND RESOLUTION INSPECTION REPORT
05000445/2015008 AND 05000446/2015008 AND NOTICE OF VIOLATION
Dear Mr. Flores:
On September 17, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite
portion of a problem identification and resolution biennial inspection at your Comanche Peak
Nuclear Power Plant Units 1 and 2. The inspection team discussed the results of the inspection
with Mr. Ken Peters, Site Vice President, and other members of your staff prior to departing the
site. The team conducted an exit meeting during a telephone conversation with Mr. John
Taylor, Site Engineering Director, and other members of your staff on October 1, 2015. The
inspection team documented the results of this inspection in the enclosed inspection report.
Based on the inspection sample, the inspection team determined that Comanche Peaks
corrective action program and implementation were adequate to support nuclear safety.
However, the team identified some weaknesses in the areas of timely identification and
evaluation of problems. Specifically, the team noted several condition reports that documented
conditions adverse to quality that were either not initiated in a timely manner, not evaluated for
operability, or were not adequately addressed. Licensee personnel initiated condition reports to
address the teams concerns.
In reviewing your corrective action program, the team assessed how well your staff identified
problems at a low threshold, your staffs implementation of the stations process for prioritizing
and evaluating these problems, and the effectiveness of corrective actions taken by the station
to resolve these problems. The team also evaluated other processes your staff used to identify
issues for resolution. These included your use of audits and self-assessments to identify latent
problems and your incorporation of lessons learned from industry operating experience into
station programs, processes, and procedures. The team determined that your stations
performance in each of these areas supported nuclear safety.
R. Flores -2-
Finally, the team determined that your stations management maintains a safety-conscious work
environment in which your employees are willing to raise nuclear safety concerns through at
least one of the several means available.
NRC inspectors documented four findings of very low safety significance (Green) in this report
that involved violations of NRC requirements. The NRC is treating three of these violations as
Non-Cited Violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy
http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. However, one of the
violations did not meet the criteria to be treated as a non-cited violation because the
noncompliance has not been restored within a reasonable period after the violation was
originally identified. Specifically, NRC inspectors identified and documented a noncompliance in
an integrated NRC Inspection Report 05000445/2012003 and 050004462012003 dated July 24,
2012. This finding was a violation of 10 CFR Part 50 Appendix B, Criterion III, for failure to
assure that applicable design bases were correctly translated into procedures associated with
the missile protection analysis of the turbine-driven auxiliary feedwater pump exhaust piping.
As of the end of the onsite portion of this inspection (more than 38 months later), the
noncompliance had still not been restored. The inspectors determined that the licensee did not
provide an adequate justification for the delay.
This violation is cited in the enclosed Notice of Violation (Notice) and the circumstances
surrounding it is described in detail in the enclosed report. You are required to respond to this
letter and should follow the instructions specified in the enclosed Notice when preparing your
response. If you have additional information that you believe the NRC should consider, you
may provide it in your response to the Notice. The NRCs review of your response to the Notice
will also determine whether further enforcement action is necessary to ensure your compliance
with regulatory requirements.
The non-cited violations are described in the subject inspection report. If you wish to contest
these violations or their significance, you should provide a response within 30 days of the date
of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington DC 20555-0001, with a copies to the Regional
Administrator, Region IV, and the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001, and the NRC Resident Inspector at
Comanche Peak. If you disagree with an assigned cross-cutting aspect in this report, provide
your response with the basis for your disagreement, to the Regional Administrator, Region IV;
and to the NRC resident inspector at Comanche Peak.
R. Flores -3-
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your
response will be available electronically for public inspection in the NRCs Public Document
Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide
Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC
Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Eric A. Ruesch, Acting Team Leader
Technical Support Services Team
Division of Reactor Safety
Docket No: 50-445, 50-446
Enclosure: Inspection Report 05000445/2015008
and 05000446/2015008
w/Attachment: Supplemental Information
Electronic Distribution to Comanche Peak
NOTICE OF VIOLATION
Luminant Generation Company LLC Docket No. 50-445, 446
Comanche Peak Nuclear Power Plant License No. NPF-87, NPF-89
During an NRC inspection conducted August 31 through October 1, 2015, a violation of NRC
requirements was identified. In accordance with the NRC Enforcement Policy, the violation is
listed below:
Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in part, Design
control measures shall provide for verifying or checking the adequacy of design, such as
by the performance of design reviews, by the use of alternate or simplified calculational
methods, or by the performance of a suitable testing program.
Contrary to the above, since June 13, 2012, the licensee failed to provide measures for
verifying the adequacy of the design by the use of alternate or simplified calculational
methods. Specifically, the licensee failed to verify the adequacy of design of the turbine
driven auxiliary feedwater pumps steam exhaust piping to withstand impact from a
tornado driven missile hazard, or to evaluate for exemption from missile protection
requirements using an approved methodology.
This violation is associated with a Green Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, Luminant Generation Company LLC is hereby
required to submit a written statement or explanation to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the
Regional Administrator, Region IV, and a copy to the NRC Senior Resident Inspector at the
facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this
Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of
Violation; EA-15-207" and should include for each violation: (1) the reason for the violation, or,
if contested, the basis for disputing the violation or severity level, (2) the corrective steps that
have been taken and the results achieved, (3) the corrective steps that will be taken, and (4) the
date when full compliance will be achieved. Your response may reference or include previous
docketed correspondence if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice, an order or a
Demand for Information may be issued as to why the license should not be modified,
suspended, or revoked, or why such other action as may be proper should not be taken. Where
good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs ADAMS, accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any
personal privacy, proprietary, or safeguards information so that it can be made available to the
public without redaction. If personal privacy or proprietary information is necessary to provide
an acceptable response, then please provide a bracketed copy of your response that identifies
the information that should be protected and a redacted copy of your response that deletes such
information. If you request withholding of such material, you must specifically identify the
portions of your response that you seek to have withheld and provide in detail the bases for your
claim of withholding (e.g., explain why the disclosure of information will create an unwarranted
invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a
request for withholding confidential commercial or financial information). If safeguards
information is necessary to provide an acceptable response, please provide the level of
protection described in 10 CFR 73.21.
Dated this 13th day of November 2015
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket(s): 05000445, 05000446
Report: 05000445/2015008 and 05000446/2015008
Licensee: Luminant Generation Company LLC
Facility: Comanche Peak Nuclear Power Plant
Location: Glen Rose, TX
Dates: August 31 through October 1, 2015
Team Lead: H. Freeman, Senior Reactor Inspector
Inspectors: C. Alldredge, Reactor Inspector
J. Drake, Senior Reactor Inspector
J. Josey, Senior Resident Inspector
Approved By: E. Ruesch, Acting Team Leader
Technical Support Services Team
Division of Reactor Safety
SUMMARY
IR 05000445/2015008 and 05000446/2015008; 08/31/2015 - 10/01/2015; Comanche Peak
Nuclear Power Plant; Problem Identification and Resolution Inspection (Biennial)
The inspection activities described in this report were performed between August 31 and
October 1, 2015, by three inspectors from the NRCs Region IV office and the resident inspector
at Comanche Peak Nuclear Power Plant. The report documents four findings of very low safety
significance (Green). All of these findings involved violations of NRC requirements. The
significance of inspection findings are indicated by their color (i.e., greater than Green, or
Green, White, Yellow, Red) and determined using IMC 0609, Significance Determination
Process dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310,
Components Within the Cross Cutting Areas dated December 10, 2014. All violations of NRC
requirements are dispositioned in accordance with the NRCs Enforcement Policy dated
February 4, 2015. The NRC's program for overseeing the safe operation of commercial nuclear
power reactors is described in NUREG-1649, Reactor Oversight Process revision 5.
Assessment of Problem Identification and Resolution
Based on its inspection sample, the team concluded that the licensee maintained a corrective
action program in which individuals generally identified issues at an appropriately low threshold.
Once entered into the corrective action program, the licensee generally evaluated and
addressed these issues appropriately and timely, commensurate with their safety significance.
The licensees corrective actions were generally effective, addressing the causes and extents of
condition of problems.
However, the team identified some weaknesses in the areas of timely identification and
evaluation of problems. Specifically, the team noted several condition reports that documented
conditions adverse to quality that were either not initiated in a timely manner, not evaluated for
operability, or were not adequately addressed. Licensee personnel initiated condition reports to
address the teams concerns.
The licensee appropriately evaluated industry-operating experience for relevance to the facility
and entered applicable items in the corrective action program. The licensee incorporated
industry and internal operating experience in its root cause and apparent cause evaluations.
The licensee performed effective and self-critical nuclear oversight audits and self-assessments.
The licensee maintained an effective process to ensure significant findings from these audits
and self-assessments were addressed.
The licensee maintained a safety-conscious work environment in which personnel were willing
to raise nuclear safety concerns without fear of retaliation.
Cornerstone: Mitigating Systems
- Green. The team identified a cited violation of 10 CFR Part 50, Appendix B, Criterion III,
Design Control, for the licensees failure to evaluate the lack of missile protection on the
turbine driven auxiliary feedwater pumps steam exhaust piping. Specifically, since June 13,
2012, the licensee failed to verify the adequacy of design of the turbine driven auxiliary
feedwater pumps steam exhaust piping to withstand impact from a tornado driven missile
hazard, or to evaluate for exemption from missile protection requirements using an
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approved methodology. This issue does not represent an immediate safety concern
because the licensee performed an operability evaluation, which established a reasonable
expectation of operability. The licensee entered this issue into the corrective action program
for resolution as Condition Report CR-2015-007869.
The licensees failure to analyze the effects of a tornado missile strike on the turbine driven
auxiliary feedwater pumps steam exhaust piping was a performance deficiency. The
performance deficiency was more than minor because it was associated with the protection
against external events factors attribute of the Mitigating Systems cornerstone and affected
the cornerstone objective to ensure availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences. Specifically, the licensee
failed to evaluate a design nonconformance on the turbine driven auxiliary feedwater pumps
steam exhaust piping for lack of missile protection. Using Inspection Manual Chapter 0609,
Appendix A, The Significance Determination Process (SDP) for Findings At-Power,
Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the team
determined that the finding is of very low safety significance (Green) because (1) the finding
was not a deficiency affecting the design or qualification of a mitigating system; (2) the
finding did not represent a loss of system and/or function; (3) the finding did not represent
an actual loss of function of a single train for greater than its technical specification allowed
outage time; and (4) the finding does not represent an actual loss of function of one or more
non-technical specification trains of equipment designated as high safety-significant in
accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The
finding has a human performance cross-cutting aspect associated with conservative bias
because individuals failed to use decision making practices that emphasize prudent choices
over those that are simply allowable [H.14]. (Section 4OA2.5a)
- Green. The team identified a non-cited violation of 10 CFR 50, Appendix B, Criterion V,
Instructions, Procedures, and Drawings, associated the licensees failure to perform
adequate operability assessments when a degraded or nonconforming condition was
identified associated with the turbine driven auxiliary feedwater pumps steam exhaust
piping not being evaluated for tornado generated missile impacts. Specifically, operators
used probabilistic assumptions and failed to adequately assess and document the basis for
operability when a degraded or nonconforming condition was identified associated with the
turbine driven auxiliary feedwater pumps steam exhaust piping not being evaluated for
tornado generated missile impacts. This issue does not represent an immediate safety
concern because the licensee performed a subsequent operability evaluation, which
established a reasonable expectation of operability. The licensee entered this issue into the
corrective action program for resolution as Condition Report CR-2015-007919.
The licensees failure to properly assess and document the basis for operability when a
degraded or nonconforming condition associated with the turbine driven auxiliary feedwater
pumps steam exhaust piping not being evaluated for tornado generated missile impacts
was identified, was a performance deficiency. The performance deficiency was more than
minor because it was associated with the protection against external events factors attribute
of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure
availability, reliability, and capability of systems that respond to initiating events to prevent
undesirable consequences. Specifically, the licensee failed to evaluate a design
nonconformance on the turbine driven auxiliary feedwater pumps steam exhaust piping for
lack of missile protection. Using Inspection Manual Chapter 0609, Appendix A, The
Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating
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Systems Screening Questions, dated June 19, 2012, the team determined that the finding
is of very low safety significance (Green) because (1) the finding was not a deficiency
affecting the design or qualification of a mitigating system; (2) the finding did not represent a
loss of system and/or function; (3) the finding did not represent an actual loss of function of
a single train for greater than its technical specification allowed outage time; and (4) the
finding does not represent an actual loss of function of one or more non-technical
specification trains of equipment designated as high safety-significant in accordance with
the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The finding has a
human performance cross-cutting aspect associated with conservative bias because
individuals failed to use decision making practices that emphasize prudent choices over
those that are simply allowable [H.14]. (Section 4OA2.5b)
- Green. The team identified a non-cited violation of Technical Specification (TS) 5.4.1,
Procedures, for an inadequate procedure for performing surveillances on the station
service water (SSW) systems in units 1 and 2. Specifically, Procedures OPT-207 A and B,
Service Water System, were modified in September 2010 so that failure of any SSW
vacuum breaker to OPEN was considered a degraded condition and not an inoperable
condition of the associated SSW System train. However, per DBD-ME-233, Station Service
Water, Revision 33, Active Valves, vacuum breakers are required by ASME [Code
Section] III on the inlet and outlet piping to the diesel generator jacket water coolers to
mitigate the effects of water hammer due to water column separation and subsequent
rejoining following a pump trip. This issue does not represent an immediate safety concern
because the licensee confirmed that all of the vacuum breakers in service had passed their
most recent surveillance test. The licensee entered this issue into the corrective action
program for resolution as Condition Report CR-2015-010800.
The finding is more than minor because it is associated with the procedure quality attribute
of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to prevent
undesirable consequences (i.e., core damage). Specifically, the licensee did not ensure the
guidance incorporated into quality related procedures was accurate and consistent with the
design basis analysis for the systems and this conflict resulted in inadequate operability
determinations associated with the SSW System. Using Inspection Manual Chapter 0609,
Appendix A, The Significance Determination Process (SDP) for Findings At-Power,
Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the team
determined that the finding is of very low safety significance (Green) because (1) the finding
was not a deficiency affecting the design or qualification of a mitigating system; (2) the
finding did not represent a loss of system and/or function; (3) the finding did not represent
an actual loss of function of a single train for greater than its technical specification allowed
outage time; and (4) the finding does not represent an actual loss of function of one or more
non-technical specification trains of equipment designated as high safety-significant in
accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This
finding has a human performance cross cutting aspect associated with design margins
because the licensee failed to operate and maintain the SSW system equipment within
design margins. Rather than ensure that margins are carefully guarded and changed only
through a systematic and rigorous process, the licensee failed to re-evaluate SSW system
operability with failed vacuum breaker valves even when additional test information
indicated previous assumptions were incorrect [H.6]. (Section 4OA2.5c)
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- Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B,
Criterion III, Design Control, with two examples associated with the licensees failure to
ensure that design changes were subject to design control measures commensurate with
those applied to the original design and were approved by the designated responsible
organization. Specifically: (1) The licensee instituted an engineering change package to
modify the design and setpoints for the station service water (SSW) system vacuum breaker
valves (CP1/2-SWVAVB-01/02/03/04) and did not consider the allowable tolerance for the
setpoint for all design basis events and operating conditions. The licensee adequately
addressed this issue by reperforming the calculation incorporating the setpoint allowable
tolerance. (2) The licensee failed to account for system design leakage in design
calculation DBD-CS-096, for the safe shutdown impoundment minimum level. The licensee
evaluated the water loss from the impoundment due to evaporation, but failed to account for
losses due to system design leakage. The licensee adequately addressed this issue by
applying the design system leak rate for a 30-day mission time to the available water in the
safe shutdown impoundment.
The licensees failure to evaluate properly the effects of modifying the setpoint including
allowable tolerances for all modes of operation and all sources of water loss from the safe
shutdown impoundment was a performance deficiency. The performance deficiency was
more than minor, and therefore a finding, because it was associated with the configuration
control attribute of the Mitigating Systems Cornerstone, and affected the cornerstone
objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Using Inspection Manual
Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-
Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the team
determined that the finding is of very low safety significance (Green) because (1) the finding
was not a deficiency affecting the design or qualification of a mitigating system; (2) the
finding did not represent a loss of system and/or function; (3) the finding did not represent
an actual loss of function of a single train for greater than its technical specification allowed
outage time; and (4) the finding does not represent an actual loss of function of one or more
non-technical specification trains of equipment designated as high safety-significant in
accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The
inspectors determined that this finding does not have a cross-cutting aspect because the
most significant contributor of this finding occurred more than three years ago and does not
reflect current licensee performance. (Section 4OA2.5d)
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REPORT DETAILS
4. OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution (71152)
The team based the following conclusions on a sample of corrective action documents that were
open during the assessment period, which ranged from November 7, 2013, to the end of the
onsite portion of this inspection on September 17, 2015.
.1 Assessment of the Corrective Action Program Effectiveness
a. Inspection Scope
The team reviewed approximately 120 condition reports (CRs), including associated root
cause analyses and apparent cause evaluations, from approximately 23,500 that the
licensee had initiated or closed between November 2013 and August 2015. The
majority of these (approximately 23,000) were lower-level condition reports that did not
require cause evaluations.
The inspection sample focused on higher-significance condition reports for which the
licensee evaluated and took actions to address the cause of the condition. In performing
its review, the team evaluated whether the licensee had properly identified,
characterized, and entered issues into the corrective action program, and whether the
licensee had appropriately evaluated and resolved the issues in accordance with
established programs, processes, and procedures. The team also reviewed these
programs, processes, and procedures to determine if any issues existed that may impair
their effectiveness.
The team reviewed a sample of performance metrics, system health reports, operability
determinations, self-assessments, trending reports and metrics, and various other
documents related to the licensees corrective action program. The team evaluated the
licensees efforts in determining the scope of problems by reviewing selected logs, work
orders, self-assessment results, audits, system health reports, action plans, and results
from surveillance tests and preventive maintenance tasks. The team reviewed daily
CRs and attended the licensees management review committee (MRC) and station
ownership committee (SOC) meetings to assess the reporting threshold and
prioritization efforts, and to observe the corrective action programs interfaces with the
operability assessment and work control processes. The teams review included an
evaluation of whether the licensee considered the full extent of cause and extent of
condition for problems, as well as a review of how the licensee assessed generic
implications and previous occurrences of issues. The team assessed the timeliness and
effectiveness of corrective actions, completed or planned, and looked for additional
examples of problems similar to those the licensee had previously addressed. The team
conducted interviews with plant personnel to identify other processes that may exist
where problems may be identified and addressed outside the corrective action program.
The team reviewed corrective action documents that addressed past NRC-identified
violations to evaluate whether corrective actions addressed the issues described in the
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inspection reports. The team reviewed a sample of corrective actions closed to other
corrective action documents to ensure that the ultimate corrective actions remained
appropriate and timely.
The team considered risk insights from both the NRCs and Comanche Peaks risk
models to focus the sample selection and plant tours on risk-significant systems and
components. The team selected the auxiliary feedwater system as a sample to focus a
five-year in-depth review. During the inspection, the team expanded the selection to
include the station service water system based upon the findings identified. The team
conducted walk-downs of these systems and other plant areas to assess whether
licensee personnel identified problems at a low threshold and entered them into the
corrective action program.
b. Assessments
1. Effectiveness of Problem Identification
During the 22-month inspection period, licensee staff generated
approximately 23,500 condition reports. The team determined that most
conditions that required generation of a condition report by STA-421 Initiation of
Condition Reports had been appropriately entered into the corrective action
program.
However, the team also noted several examples where the licensee had failed to
identify conditions in accordance with procedures over the assessment period:
- The licensee failed to perform cause evaluations for two maintenance
preventable functional failures because condition reports were not generated to
perform the evaluation. This constituted a programmatic weakness in the
licensees maintenance rule program and corrective action program and resulted
in MPFFs not being prioritized and evaluated appropriately for corrective action,
which could result in recurring failures. This was previously documented as a
finding in NRC Inspection Report 05000445/2013008 and 05000446/2013008.
- The NRC identified two examples where the licensee failed to provide
adequate acceptance criteria for an activity affecting quality - specifically,
adequate acceptance criteria for bearing oil level in its residual heat
removal pump motors. The finding had a cross-cutting aspect in the corrective
action program component of the problem identification and resolution
cross-cutting area because the licensee had failed to implement a corrective
action program with a low threshold for identifying issues to ensure that an issue
potentially affecting nuclear safety was promptly identified and fully evaluated.
This was previously documented as a non-cited violation in NRC Inspection
Report 05000445/2013008 and 05000446/2013008.
- The NRC identified a Green non-cited violation of 10 CFR 50, Appendix B,
Criterion III, Design Control, for the licensees failure to control deviations from
quality standards. After identifying that maintenance personnel had failed to
ensure that subcomponents of 480-volt switchgear were properly identified and
controlled during refurbishment, the licensee failed to document or evaluate
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where subcomponents of an indeterminate pedigree had been installed in safety-
related applications. The licensee took immediate action to confirm the
operability of the installed trip units and to determine the scope of the
problem. The finding had a cross-cutting aspect in the corrective action
program component of the problem identification and resolution cross-cutting
area because the licensee had failed to implement a corrective action
program with a low threshold for identifying issues to ensure that an issue
potentially affecting nuclear safety was promptly identified and fully evaluated.
This was previously documented as a non-cited violation in NRC Inspection
Report 05000445/2013008 and 05000446/2013008.
The team noted that the licensee initiated fewer condition reports associated with
NRC identified potential findings during this inspection than typical. The team had to
prompt the licensee to initiate a condition report associated with an NRC identified
finding after the onsite inspection ended in order to meet the criteria for issuing a
non-cited violation (Section 4OA2.2.5.c). The team also noted that while the
licensee had initiated condition reports associated with the teams findings (and
thereby meet one of the criteria for issuing a non-cited violation); the descriptions did
not necessarily match the performance deficiency. This mismatch can result in the
licensees failure to address the performance deficiency as evidenced by the cited
violation issued for the licensees failure to address the auxiliary feedwater turbine
exhaust tornado missile protection (Section 4OA2.2.5.a).
Overall, the team concluded that the licensee generally maintained a low threshold
for the formal identification of problems and entry into the corrective action program
for evaluation. Licensee personnel initiated over 1000 CRs per month during the
inspection period. All of the personnel interviewed by the team understood the
requirements for condition report initiation; most expressed a willingness to enter
newly identified issues into the corrective action program at a very low threshold.
2. Effectiveness of Prioritization and Evaluation of Issues
The sample of CRs reviewed by the team focused primarily on issues screened by
the licensee as having higher-level significance, including those that received cause
evaluations, those classified as significant conditions adverse to quality, and those
that required engineering evaluations. The team also reviewed a number of
condition reports that included or should have included immediate operability
determinations to assess the quality, timeliness, and prioritization of these
determinations.
The team has identified a number of condition reports where the licensees cause
evaluation does not appear to address all causes associated with the condition.
Specifically, the licensee appears reluctant to address failures to follow procedures
or to further assess why the individual(s) failed to follow procedures. Specific
examples include: failing to follow procedure in the reassembly of the primary water
filter assembly which led to a plant shutdown; (occurred in 2012); failure to follow
procedures in performing turbine stress evaluator troubleshooting which led to
shorting of the circuit and resulted in a turbine runback; two issues with failure to
follow procedures in performing walkdowns prior to installation of design changes -
one of which led to loss of all offsite power in 2013; and failure to follow procedures
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in performing surveillance testing and led to isolation of residual heat removal
cooling.
While the licensee does identify causes (root or apparent) for these adverse
conditions and generally initiates corrective actions, the licensees reluctance to
calling failure-to-follow procedure as a causal factor can lead to a host of
performance vulnerabilities. Included in this is a general defensive position towards
what the individual(s) did and not acknowledging the licensees own procedure,
which requires individuals to stop, obtain clarification, modify procedures, etc. The
licensee concludes that a lack of management oversight was the cause of the
condition rather than acknowledging that an appropriate barrier was in place at the
time. The cause evaluation does not fully address why the individual failed to follow
procedure and does to assess whether the individual may have made decisions
based upon time pressure. The team sees similarities between two significant
issues associated with Siemens, and CB&I, each one where the licensee concluded
that the occurrence was an isolated example of lack of management oversight.
The team also noted several performance deficiencies within the area of
effectiveness of prioritization and evaluation of issues in this inspection and over the
assessment period. These include:
- The NRC identified a Green, cited violation of 10 CFR Part 50, Appendix B,
Criterion III, Design Control, for the licensees failure to evaluate the lack of
missile protection on the turbine driven auxiliary feedwater pumps steam
exhaust piping. Specifically, since June 13, 2013, the licensee failed to verify the
adequacy of design of the turbine driven auxiliary feedwater pumps steam
exhaust piping to withstand impact from a tornado driven missile hazard, or to
evaluate for exemption from missile protection requirements using an approved
methodology. (Section 4OA2.5a)
- The NRC identified a non-cited violation of 10 CFR 50, Appendix B, Criterion V,
Instructions, Procedures, and Drawings, associated the licensees failure to
perform adequate operability assessments when a degraded or nonconforming
condition was identified associated with the turbine driven auxiliary feedwater
pumps steam exhaust piping not being evaluated for tornado generated missile
impacts. Specifically, operators used probabilistic assumptions and failed to
assess adequately and document the basis for operability when a degraded or
nonconforming condition was identified associated with the turbine driven
auxiliary feedwater pumps steam exhaust piping not being evaluated for tornado
generated missile impacts. (Section 4OA2.5b)
- The NRC identified a non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, for two examples of a
failure to follow procedure for evaluating and correcting significant conditions
adverse to quality. Specifically, the licensee reduced the screening level of two
significant conditions adverse to quality and therefore, failed to perform a root
cause evaluation and identify corrective actions to preclude repetition. This was
previously documented as a non-cited violation in NRC Inspection
Report 05000445/2015001 and 05000446/2015001.
-9-
- The NRC identified that the licensee failed to follow and maintain the
effectiveness of an emergency plan that meets the requirements of planning
standard 50.47(b)(4) which requires that a standard emergency classification and
action level scheme is in use by the licensee. Specifically, several main steam
line monitors were out of service for extended periods of time without apparent
contingency actions in place in order to be able to declare an emergency. This
finding has a problem identification and resolution cross-cutting aspect
associated with evaluation because the licensee failed to evaluate thoroughly the
extent of condition of the inoperable monitors on the emergency plan and
scheme for declaring emergencies. This was previously documented as a non-
cited violation in NRC Inspection Report 05000445/2014003 and
- The NRC identified that the licensee failed to correct exercise performance
weaknesses. Specifically, the licensee failed to identify that a lack of radiological
briefings for plant repair teams and a lack of habitability assessments in the
Operations Support Center were deficiencies requiring corrective action during
an exercise conducted June 10, 2015. The licensee did not assign specific
corrective actions to these performance issues in the site corrective action
program, (05000445/2015002-02; 05000446/2015002-02, Failure to Critique
Weaknesses in Radiation Protection Practices).
The team also identified anecdotal evidence of what appears to be a reluctance to
document potential issues promptly when first identified. For example, during the
safety-conscious work-environment interviews (Section 4OA2.4), individuals advised
that there was an engineering management expectation that all condition reports
initiated by engineers include engineering input to operability and that this sometimes
delays the submittal of the issue until after they had obtained all necessary
information to be able to provide the input.
This could delay NRC licensed reactor operators from making immediate operability
determinations for conditions related to safety-related structures, systems, or
components. The team reinforced with the licensee that NRC expects licensed
operators to make immediate operability determinations based upon reasonable
expectation of operability for those conditions that affect safety-related structures,
systems, or components; prompt operability determinations should be requested
when additional information is required to support or confirm the immediate
determination. Over the course of this inspection, the team noted several condition
reports where the immediate operability determination documented by licensed
reactor operators used essentially the same wording provided by the engineer who
initiated the condition report. The team also identified a minor issue associated with
alarm response procedure 2ALB-2B associated with the safety injection sequencer
that directed operators to request a quick technical evaluation from engineering to
determine operability.
Overall, the team determined that the licensees process for screening and
prioritizing issues that had been entered into the corrective action program generally
supported nuclear safety. However, the team concluded that the operability
determinations was an area that may warrant additional management oversight.
- 10 -
3. Effectiveness of Corrective Actions
In general, the corrective actions identified by the licensee to address adverse
conditions were effective. The team noted a number of instances in which corrective
actions had been untimely or incompletely accomplished:
- The personnel who conducted the design modification walkdowns did not
fully understand their responsibility and the licensees work organization
did not ensure that anyone actually verified the physical details of the
cable route. As a result, the design modification was inadequate and an
incorrect cable was cut which caused a loss of all offsite power to the safety
related 6.9 kV busses on both units. This was previously documented as a
non-cited violation in NRC Inspection Report 05000445/2014007
and 05000446/2014007.
- Maintenance personnel failed to follow work instructions. Specifically,
maintenance personnel failed to follow instructions and cut the wrong cable
during a transformer modification. As a result, one offsite power source to
both units was unavailable during the repair of the damaged cable. This was
previously documented as a non-cited violation in NRC Inspection
Report 05000445/2013005 and 05000446/2013005.
- The NRC identified two examples where the licensee failed to implement
corrective actions in a timely manner for two non-cited violations associated
with the fire protection program. This was previously documented as a cited
violation in NRC Inspection Report 05000445/2014003 and
The team identified that many of the NRC identified performance deficiencies
associated with the station service water system were the result of long standing
performance issues of the vacuum breakers that have been ongoing since 2002.
The team concluded that the licensees corrective actions to address these problems
have not be completely effective.
Overall, the team concluded that the licensee generally identified effective corrective
actions for the problems evaluated in the corrective action program. The licensee
generally implemented these corrective actions in a timely manner, commensurate
with their safety significance, and reviewed the effectiveness of the corrective actions
appropriately.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The team examined the licensees program for reviewing industry operating experience
(OE), including reviewing the governing procedures. The team reviewed a sample of
eight industry OE communications and the associated site evaluations to assess
whether the licensee had appropriately assessed the communications for relevance to
the facility. The team also reviewed assigned actions to determine whether they were
appropriate. Describe any other significant items reviewed.
- 11 -
b. Assessment
Overall, the team determined that the licensees program for evaluating industry OE for
its relevance to the facility was effective. Operating experience information was
incorporated into plant procedures and processes as appropriate. The team did note
that in 2010, the licensee revamped the OE program significantly. As part of that
update, the licensee re-evaluated the effectiveness of their previous responses to all
significant operating experience reports. The licensee placed all OE that was of a lower
tier in their Action Way system so that it is available but did not re-evaluate them. The
inspectors noted that this created a potential vulnerability in that lessons that could have
been learned from low level OE and incorporated into plant processes remained
unevaluated. The team identified an example of this while reviewing the root cause
evaluation of a centrifugal charging pumps failure of the main lubricating pump:
- In August 2014, Centrifugal Charging Pump 2-02s main lubricating oil pump
decoupled from its drive shaft because of improper reassembly of the main
lubricating oil pump to its drive shaft. Maintenance personnel had failed to align the
coupling drive pins with the holes in the drive hub located on the speed increaser
shaft causing the drive pin coupling to be forced back on the driven shaft slightly
which resulted in partial coupling of the charging pump and lube oil pump. The
licensee identified that they had received OE from the South Texas Project in 2010
where their centrifugal charging pump main lube oil pump decoupled for essentially
the same reason. This OE had been screened as a Level 2 and sent to the pump
distribution, but an evaluation was not assigned and no CR was generated. This
was previously documented as a non-cited violation in in NRC Inspection
Report 05000445/2015001 and 05000446/2015001.
The team conclude that the program was currently evaluating industry operating
experience as expected. The team further determined that the licensee appropriately
evaluated industry operating experience when performing root cause analysis and
apparent cause evaluations. The licensee appropriately incorporated both internal and
external operating experience into lessons learned for training and pre-job briefs.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The team reviewed a sample of licensee self-assessments and audits to assess whether
the licensee was regularly identifying performance trends and effectively addressing
them. The team also reviewed audit reports to assess the effectiveness of assessments
in specific areas. The specific self-assessment documents and audits reviewed are
listed in Attachment 1.
b. Assessment
Overall, the team concluded that the licensee had an effective self-assessment and audit
process. The team determined that self-assessments were self-critical and thorough
enough to identify deficiencies.
.4 Assessment of Safety-Conscious Work Environment
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a. Inspection Scope
The team interviewed 46 individuals in six focus groups. The purpose of these
interviews was to (1) evaluate the willingness of staff to raise nuclear safety issues and
whether challenges to the free flow of information in the corrective actions program
exists; (2) evaluate the perceived effectiveness of the corrective action program at
resolving identified problems; and (3) evaluate the licensees employee concerns
program. The focus group participants included personnel from security, operations,
nuclear oversight, engineering, radiation protection, and contract workers. The team
randomly selected personnel to participate in the focus groups from organization charts
provided by the licensee. To supplement these focus group discussions, the team
interviewed the employee concerns program (called the Safe Team) manager to assess
his perception of the site employees willingness to raise nuclear safety concerns. The
team reviewed the case log and select case files. The team also reviewed the minutes
from the licensees most recent safety culture monitoring panel meeting and safety
culture survey.
b. Assessment
The team found that the licensee has established and maintains an environment where
individuals felt free to raise safety concerns to the licensee and to the NRC without fear
of retaliation. Individuals were aware of the corrective action process and knew that they
were able to submit a concern via the condition reporting and other processes. Front-
line individuals typically stated that they were able to raise safety concerns directly to
their supervisor and write condition reports. The team did identify areas that could
impact the effectiveness of the safety-conscious work environment if not adequately
addressed as noted below.
1. Willingness to Raise Nuclear Safety Issues
The team found that all individuals interviewed indicated that they would raise
nuclear safety concerns. All felt that their management was receptive to nuclear
safety concerns and was willing to address them promptly. All of the interviewees
further stated that if they were not satisfied with the response from their immediate
supervisor, they had the ability to escalate the concern to a higher organizational
level. Most expressed positive experiences after raising issues to their supervisors.
All expressed positive experiences documenting most issues in condition reports.
However, during many of the focus groups, some individuals acknowledged that they
had felt schedule pressure (especially during outages); some indicated that it
[schedule pressure] sometime impacts managements decisions in regards to actions
taken or to individuals making mistakes. Some groups stated that they felt free to
stop work at any time they identified a safety concern while others indicated that this
was true except during outages. No one indicated that schedule pressure had
prevented them from raising safety concerns or from stopping work. The licensee
was aware of the perceived schedule pressure and has implemented actions to
address it.
2. Effectiveness of the Corrective Actions Program
- 13 -
The focus group participants generally agreed that the corrective actions program
addressed safety concerns in a timely fashion. On group noted that they sometimes
had to fight for their issues to ensure that the corrective actions and/or prioritization
was appropriate. Some individuals expressed that because of the holding
companys financial situation (bankruptcy), they believed that some concerns may
not be addressed in the future but did not provided any specific concerns where were
not being addressed. Some individuals indicated that they felt that low-level issues
were not being addressed but none of these examples affected the safe operation of
the plant and mostly represented industrial safety issues. These examples were
provided to licensee management.
3. Employee Concerns Program
All interviewees were aware of the employee concerns program (called the Safe
Team). Most explained that they had heard about the program through various
means, such as posters, training, presentations, and discussion by supervisors or
management at meetings. Some of those interviewed did not feel comfortable
raising concerns to the Safe Team because of their perception that an individuals
identity (who had used the program) had been compromised during the investigation.
.5 Findings
a. Failure to Evaluate the Lack of Missile Protection on the Turbine Driven Auxiliary
Feedwater Pumps Steam Exhaust Piping
Introduction. The team identified a Green, cited violation of 10 CFR Part 50,
Appendix B, Criterion III, Design Control, for the licensees failure to evaluate the lack
of missile protection on the turbine driven auxiliary feedwater pumps steam exhaust
piping.
Description. The team reviewed the stations corrective actions taken to address non-
cited violations05000445/2012003-01; 05000446/2012003-02, Failure to Analyze
Tornado Missile Strike on Turbine Driven Auxiliary Feedwater Exhaust Pipe, which was
documented in Condition Report CR-2012-006134. The team noted that the licensees
corrective actions included performing an analysis, CS-CA-0000-5493, Turbine Driven
Auxiliary Feedwater Pump Exhaust Stack Tornado Missile Evaluation, to verify that the
exhaust pipe would not be completely crimped by final safety analysis report design
basis tornado missiles (potentially resulting in a steam environment inside the building).
The team reviewed Calculation CS-CA-0000-5493 and noted that the calculation:
1) stated that the licensing basis did not require the piping to be qualified for tornado
missile impact; 2) did not evaluate all of the licensing basis tornado generated missiles;
3) did not evaluate all licensing basis tornado missile trajectories, specifically vertical
missiles were dismissed based on probabilistic assumptions; and 4) assumed that as
long as the auxiliary feed function was maintained (crediting the motor driven pumps) the
exhaust stacks were not required to be protected.
The team noted that the stations Final Safety Analysis Report (FSAR) contained the
following information:
- 14 -
- FSAR Appendix 1A(B) identifies that the station is committed to Regulatory
Guide 1.117, Tornado Design Classification, and states, in part, structures,
systems, and components are designed to withstand the effects of a design basis
tornado, including tornado missiles, in conformance with Revision 1 (4/78) of this
regulatory guide. The auxiliary feedwater system is identified in this regulatory
guide.
- FSAR Chapter 3
o Section 3.1.1.2 identifies that stations compliance with General Design
Criteria GDC-2, and requires that the systems and components needed for
accident mitigation remain fully functional before, during, and after a tornado
event.
o Section 3.2.1.1.2 identifies the auxiliary feedwater system as a Class I
system.
o Section 3.3.2, states in part, because of the potential switchyard damage, a
trip of the turbine-generators and loss of offsite power are assumed to result
from the design basis tornado.
o Table 3.5-8 specifies the licensing bases tornado generated missiles that
must be considered, and identifies that vertical missiles are part of the current
licensing basis.
- FSAR Chapter 10, Section 10.4.9.3 states, in part, that in the event of loss of
offsite power, the backup turbine driven auxiliary feedwater pump operates.
As such, the team determined that Calculation CS-CA-0000-5493 did not provide an
adequate design analysis that would assure that the exhaust stacks would be functional
during a postulated tornado event under all design bases missile scenarios.
Furthermore, the team noted that previously in NCV 05000445/2015007-04, Failure to
Evaluate Changes to Ensure They Did Not Require Prior NRC Approval, inspectors had
determined that Calculation CS-CA-0000-5493 did not demonstrate that the exhaust
stacks would be functional following a tornado event. The team determined that the
licensee had not entered this issue into the stations corrective action program for
resolution.
Based on this, the team determined that the licensee had failed to restore compliance for
NCVs05000445/2012003-01; 05000446/2012003-02, within a reasonable amount of
time.
Analysis. The licensees failure to analyze the effects of a tornado missile strike on the
turbine driven auxiliary feedwater pumps steam exhaust piping was a performance
deficiency. The performance deficiency was more than minor because it was associated
with the protection against external events factors attribute of the Mitigating Systems
cornerstone and affected the cornerstone objective to ensure availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable
- 15 -
consequences. Specifically, the licensee failed to evaluate a design nonconformance on
the turbine driven auxiliary feedwater pumps steam exhaust piping for lack of missile
protection. Using Inspection Manual Chapter 0609, Appendix A, The Significance
Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems
Screening Questions, dated June 19, 2012, the team determined that the finding is of
very low safety significance (Green) because (1) the finding was not a deficiency
affecting the design or qualification of a mitigating system; (2) the finding did not
represent a loss of system and/or function; (3) the finding did not represent an actual
loss of function of a single train for greater than its technical specification allowed outage
time; and (4) the finding does not represent an actual loss of function of one or more
non-technical specification trains of equipment designated as high safety-significant in
accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The finding has a human performance cross-cutting aspect associated with conservative
bias because individuals failed to use decision making practices that emphasize prudent
choices over those that are simply allowable [H.14].
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in
part, Design control measures shall provide for verifying or checking the adequacy of
design, such as by the performance of design reviews, by the use of alternate or
simplified calculational methods, or by the performance of a suitable testing program.
Contrary to the above, since June 13, 2012, the licensee failed to provide measures for
verifying the adequacy of the design by the use of alternate or simplified calculational
methods. Specifically, the licensee failed to verify the adequacy of design of the turbine
driven auxiliary feedwater pumps steam exhaust piping to withstand impact from a
tornado driven missile hazard, or to evaluate for exemption from missile protection
requirements using an approved methodology. This issue does not represent an
immediate safety concern because, following the teams identification, the licensee
performed an operability evaluation which established a reasonable expectation of
operability. This performance deficiency had been previously identified by the NRC and
had been documented as non-cited violation NCVs05000445/2012003-01;
05000446/2012003-02. In accordance with Section 2.3.2.a of the NRC Enforcement
Policy, this finding is being cited because the licensee failed to restore compliance within
a reasonable amount of time after the violation was initially identified. This finding
was entered into the licensees corrective action program as Condition
Report CR-2015-007869, (VIO 05000445/2015008-01; 05000446/2015008-01, Failure
to Evaluate the Lack of Missile Protection on the Turbine Driven Auxiliary Feedwater
Pumps Steam Exhaust Piping)
b. Failure to Properly Assess and Document the Basis for Operability associated with the
Turbine Driven Auxiliary Feedwater Pumps Steam Exhaust Piping not being Evaluated
for Tornado Generated Missile Impacts
Introduction. The inspectors identified a Green non-cited violation of 10 CFR 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated the
licensees failure to perform adequate operability assessments when a degraded or
nonconforming condition was identified associated with the turbine driven auxiliary
feedwater pumps steam exhaust piping not being evaluated for tornado generated
missile impacts.
- 16 -
Description. While reviewing station Calculation CS-CA-0000-5493, Turbine Driven
Auxiliary Feedwater Pump Exhaust Stack Tornado Missile Evaluation, the team
determined that this analysis did not provide an adequate design analysis that would
assure that the exhaust stacks would be functional during a postulated tornado event
under all design bases missile scenarios (VIO 05000445/2015008-01;
05000446/2015008-01, Failure to Evaluate the Lack of Missile Protection on the Turbine
Driven Auxiliary Feedwater Pumps Steam Exhaust Piping). The team informed the
licensee of their concerns, and the licensee initiated Condition Report 2015-007869 to;
capture the issue in the stations corrective action program, and document an operability
evaluation for the identified degraded condition.
The team reviewed the operability evaluation documented in Condition
Report 2015-007869. During their review, the team noted that the licensee did not
evaluate all licensing basis tornado missile trajectories as part of the operability
determination. Specifically, the licensee dismissed vertical missiles based on
probabilistic assumptions of them being highly unlikely. The team reviewed Station
Procedure STI-442.01, Operability Determination and Functionality Assessment
Program, and noted that step 6.1, required, in part, that when a potential degraded or
nonconforming condition is identified, the shift manager should ensure the operability
determination process is initiated to determine the operability of the structure, system or
component.
The team determined that the operability evaluation documented in Condition
Report 2015-007869 did not establish a reasonable expectation of the turbine driven
auxiliary feedwater pumps steam exhaust piping ability to remain functional in the event
of a tornado missile impact. Therefore, the team determined that this evaluation was not
an appropriate basis for operability for the turbine driven auxiliary feedwater pumps
steam exhaust piping. The team informed the licensee of their concern and the licensee
initiated Condition Report CR-2015-007919 to capture this issue in the stations
corrective action program.
Analysis. The licensees failure to properly assess and document the basis for
operability when a degraded or nonconforming condition was identified associated with
the turbine driven auxiliary feedwater pumps steam exhaust piping not being evaluated
for tornado generated missile impacts, was a performance deficiency. The performance
deficiency was more than minor because it was associated with the protection against
external events factors attribute of the Mitigating Systems cornerstone and affected the
cornerstone objective to ensure availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences. Specifically, the
licensee failed to evaluate a design nonconformance on the turbine driven auxiliary
feedwater pumps steam exhaust piping for lack of missile protection. Using Inspection
Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for
Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19,
2012, the team determined that the finding is of very low safety significance (Green)
because (1) the finding was not a deficiency affecting the design or qualification of a
mitigating system; (2) the finding did not represent a loss of system and/or function;
(3) the finding did not represent an actual loss of function of a single train for greater
than its technical specification allowed outage time; and (4) the finding does not
represent an actual loss of function of one or more non-technical specification trains of
equipment designated as high safety-significant in accordance with the licensees
- 17 -
maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The finding has a human
performance cross-cutting aspect associated with conservative bias because individuals
failed to use decision making practices that emphasize prudent choices over those that
are simply allowable [H.14].
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,
and Drawings, requires, in part, that activities affecting quality shall be accomplished in
accordance with documented instructions, procedures, or drawings, of a type
appropriate to the circumstances. Procedure STI-442.01, Operability Determination
and Functionality Assessment Program, Revision 3, a procedure that is appropriate to
the circumstances of evaluating the operability of safety-related components, step 6.1,
requires, in part, that when a potential degraded or nonconforming condition is identified,
the shift manager should ensure the operability determination process is initiated to
determine the operability of the structure, system or component. Contrary to the above,
on September 1, 2015, an activity affecting quality was not accomplished in accordance
with a procedure that was appropriate to the circumstances. Specifically, operators
failed to adequately assess and document the basis for operability when a degraded or
nonconforming condition was identified associated with the turbine driven auxiliary
feedwater pumps steam exhaust piping not being evaluated for tornado generated
missile impacts. This issue does not represent an immediate safety concern because
the licensee performed a subsequent operability evaluation that established a
reasonable expectation of operability. Since this violation was of very low safety
significance (Green) and has been entered into the corrective action program as
Condition Report CR-2015-007919, this violation is being treated as a non-cited violation
consistent with Section 2.3.2.a of the NRC Enforcement Policy.
(NCV 05000445/2015008-02; 05000446/2015008-02, Failure to Evaluate Operability for
a Degraded Condition)
c. Inadequate Procedure for Surveillance on Safety-Related Service Water Systems
Introduction. The team reviewed a self-revealing, non-cited violation of Technical
Specification 5.4.1.a for the licensees failure to establish, implement and maintain a
procedure required by Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Specifically, the licensee failed to maintain an adequate surveillance test procedure for
the station service water system. Sections 8.2R and 8.3R of procedure OPT-207 A
and B, Service Water System, Revision 15, were modified to state that failure of the
vacuum breaker check valve is a degraded condition but does not render the train
inoperable. This procedure change was based on an operability determination that
assumed the vacuum breakers were not needed to prevent column separation water
hammer events from occurring in the system. This assumption is in direct conflict with
Calcuation15454-NP(B)-F034, Revision 0, Service Water System Calculation, REI-701,
Revision 0, SSW Water Hammer Test, DBD-ME-233, Revision 33, Station Service
Water, and ME-CA-0233-5494, Revision 1, Hydraulic Transient Analyses of the Station
Service Water System.
Description. Over the past 5 years, the licensee has experienced recurring failures of
the safety-related vacuum breaker valves in the SSW systems for both units. As a part
of the corrective actions for this recurring deficiency, the licensee modified
Procedure OPT-207 A and B, Service Water System, Revision 15, sections 8.2R and
8.3R to indicate that failure of the vacuum breaker valves to operate was a degraded
- 18 -
condition but did not render the affected train of SSW inoperable. This procedure
change was based on an operability determination that assumed the vacuum breakers
were not needed to prevent column separation water hammer events from occurring in
the system. This assumption lacked adequate engineering evaluation and was in direct
conflict with multiple design bases documents, Calculation 15454-NP(B)-F034,
Revision 0, Service Water System Calculation, REI-701, Revision 0, SSW Water
Hammer Test, DBD-ME-233, Revision 33, Station Service Water, and
ME-CA-0233-5494, Revision 1, Hydraulic Transient Analyses of the Station Service
Water System.
Per DBD-ME-233, Station Service Water Revision 33, Active Valves, states that
vacuum breakers are required by ASME [Code Section] III on the inlet and outlet piping
to the emergency diesel generator jacket water coolers to mitigate the effects of water
hammer due to water column separation and subsequent rejoining following a pump trip.
Additionally, per ME-CA-0233-5494, revision 1, Hydraulic Transient Analyses of the
Station Service Water System, accepted on July 28, 2014, the pump trip case without
the breakers is shown to have severe pressure surges due to liquid column separation
and rejoining. It was concluded that the 2-inch vacuum breakers installed in the SSW
system were critically important for mitigating the pressure transients. When this new
information was received, the licensee failed to incorporate the information into the
procedures.
Analysis. The licensees failure to ensure that changes to quality-related procedures
were based on proper engineering evaluation and were supported by the design bases
calculations and associated design documents was a performance deficiency. This
performance deficiency was more than minor, and therefore a finding, because it was
associated with the procedure attribute of the Mitigating Systems Cornerstone and
affected the associated objective to ensure availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences.
Specifically, the licensee failed to properly evaluate and consider design calculations
and other design bases documents when procedure OPT-207 A and B, Service Water
System, Revision 15, were modified in steps 8.2.R and 8.3.R to state that failure of the
vacuum breaker valves to operate is a degraded condition but does not render the
service water train inoperable. This procedure change was based on an operability
determination that assumed the vacuum breakers were not needed to prevent column
separation water hammer events from occurring in the system, even though multiple
design documents indicated the vacuum breakers were needed for system operability
per ASME Code.
The licensee entered this deficiency into their corrective action program as
CR 2015-010800. Using Inspection Manual Chapter (IMC) 0609, Appendix A, The
Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012,
inspectors determined that this finding was of very low safety significance (Green)
because the finding: (1) was not a deficiency affecting the design and qualification of a
mitigating structure, system, or component, and did not result in a loss of operability or
functionality; (2) did not represent a loss of system and/or function; (3) did not represent
an actual loss of function of at least a single train for longer than its allowed outage time,
or two separate safety systems out-of-service for longer than their technical specification
allowed outage time; and (4) does not represent an actual loss of function of one or
more non-technical specification trains of equipment designated as high safety-
- 19 -
significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with the licensees maintenance rule
program. The inspectors determined that this finding does not have a cross-cutting
aspect because the most significant contributor of this finding occurred more than three
years ago.
Enforcement. Technical Specification 5.4.1.a states, in part, that written procedures
shall be established, implemented, and maintained covering the applicable procedures
recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Regulatory Guide 1.33, Appendix A, Section 8.b., identifies procedures for surveillance
tests as required procedures. Procedure OPT-207 A and B, Service Water System, is
a procedure established by the licensee for performing surveillances on the service
water systems. Contrary to the above, from May 13, 2010, until September, 2015, the
licensee failed to adequately maintain Procedures OPT-207 A and B, Service Water
System, Revision 15, which direct operator actions for performing surveillances on the
SSW systems in Units 1 and 2. Specifically, the licensee failed to maintain an adequate
surveillance test procedure for the station service water system. Procedures OPT-207 A
and B, Service Water System, Revision 15, section 8.2R and 8.3R were modified to
state that failure of the vacuum breaker check valves is degraded condition but does not
render the train inoperable. This procedure change was based on an operability
determination that assumed the vacuum breakers were not needed to prevent column
separation water hammer events from occurring in the system. This assumption is in
direct conflict with Calcuation15454-NP(B)-F034, Revision 0, Service Water System
Calculation, REI-701, Revision 0, SSW Water Hammer Test, DBD-ME-233,
Revision 33, Station Service Water, and ME-CA-0233-5494, Revision 1, Hydraulic
Transient Analyses of the Station Service Water System. Because this finding is
determined to be of very low safety significance and has been entered into the licensees
corrective action program, this violation is being treated as a non-cited violation
consistent with Section 2.3.2.a of the NRC Enforcement Policy.
(NCV 05000445/2015008-03 and 05000446/2015-03, Inadequate procedure for
surveillance on safety-related service water systems.)
d. Failure to Maintain Adequate Controls for Design Calculations
Introduction. The inspectors identified a non-cited violation of 10 CFR Part 50,
Appendix B, Criterion III, Design Control, associated with the licensees failure to
ensure that design changes were subject to design control measures commensurate
with those applied to the original design and were approved by the designated
responsible organization.
Description. Example 1: The team identified that the licensee had failed to properly
evaluate the impact on the system of a change to the setpoint for the vacuum breakers.
Specifically, the licensee instituted an engineering change package to modify the design
and setpoints for the SSW system vacuum breaker valves
(CP1/2-SWVAVB-01/02/03/04) and did not consider the allowable tolerance for the
setpoint for all design basis events and operating conditions. The inspectors discussed
this issue with the station engineering staff and determined that the setpoint was
changed in Final Design Authorization 2007-000728, dated May 5, 2010. The inspectors
reviewed the design change and noted that it directed a setpoint change from 0.2 psid
to 1.0 + 0.5 psid, but it did not evaluate this new setpoint with allowable tolerance as was
done in the original design analysis, it simply evaluated that 1.0 psid was acceptable
- 20 -
based on a review of the original design analysis. Therefore, the team determined that
the licensee had failed to ensure that this design change was subject to design control
measures commensurate with those applied to the original design and approved by the
designated responsible organization. The licensee adequately addressed this issue by
reperforming the calculation incorporating the setpoint allowable tolerance. The licensee
entered this deficiency into their corrective action program as CR 2015-008353.
Example 2: The team identified that the licensee had failed to evaluate properly all the
sources of water loss from the safe shutdown impoundment. Per DBD-ME-233, Station
Service Water Revision 33, the Safe Shutdown Impoundment (SSI) serves as the
ultimate heat sink, and supplies water needed to safety operate, shut down, and cool
down the plant. The SSI is required to dissipate safely the heat from an accident in one
unit, and to permit the concurrent safe shutdown and cool down of the second unit. This
capability is required to be maintained for a minimum of 30 days without makeup water.
However, design calculation DBD-CS-096 only took into consideration the losses due to
evaporation when the minimum level in the SSI was determined. The inspectors
informed the licensee of their concern. Failure to account for the loss due to design
system leak rate was non-conservative; however, when the licensee did take the SSW
design leak rates into consideration, they determined that sufficient margin was available
in the SSI to meet the 30-day mission time. The licensee initiated Condition Report
CR 2015-008589 to capture this issue in their corrective action program.
Analysis. The licensees failure to ensure that changes to the facility were subject to
design control measures commensurate with those applied to the original design and
approved by the designated responsible organization was a performance deficiency.
This performance deficiency was more than minor, and therefore a finding, because it
was associated with the equipment performance attribute of the Mitigating Systems
Cornerstone and affected the associated objective to ensure availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable
consequences. Specifically, the licensee instituted an engineering change package to
modify the design and setpoints for the SSW system vacuum breaker valves
(CP1/2-SWVAVB-01/02/03/04) and did not consider the allowable tolerance for the
setpoint for all design basis events and operating conditions. The licensee adequately
addressed this issue by reperforming the calculation incorporating the setpoint allowable
tolerance. In addition, the licensee failed to consider the water inventory loss due to
design leak rates for the SSW system when calculating the minimum level in the SSI for
its 30-day mission time. Although the licensee failed to consider the system leakage,
when the calculation was adjusted to account for it, there system remained operable, but
with significantly less margin. The licensee entered these deficiencies into their
corrective action program as CR 2015-008353 and CR 2015-008589. Using Inspection
Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for
Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19,
2012, the team determined that the finding is of very low safety significance (Green)
because (1) the finding was not a deficiency affecting the design or qualification of a
mitigating system; (2) the finding did not represent a loss of system and/or function; (3)
the finding did not represent an actual loss of function of a single train for greater than its
technical specification allowed outage time; and (4) the finding does not represent an
actual loss of function of one or more non-technical specification trains of equipment
designated as high safety-significant in accordance with the licensees maintenance rule
- 21 -
program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inspectors determined that this finding does not
have a cross-cutting aspect because the most significant contributor of this finding
occurred more than three years ago.
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in
part, that, design changes shall be subject to design control measures commensurate
with those applied to the original design and be approved by the organization that
performed the original design unless the applicant designates another responsible
organization. Contrary to the above, on May 5, 2010, the licensee failed to ensure that
a design change was subject to design control measures commensurate with those
applied to the original design and approved by the organization that performed the
original design. Specifically, the licensee instituted an engineering change package to
modify the design and setpoints for the SSW system vacuum breaker valves
(CP1/2-SWVAVB-01/02/03/04) and did not consider the allowable tolerance for the
setpoint for all design basis events and operating conditions. Additionally, the licensee
failed to consider system design leakage when determining the minimum design level in
the safe shutdown impoundment. The licensee entered these deficiencies into their
corrective action program as CR 2015-008520. This violation is being treated as a non-
cited violation, consistent with Section 2.3.2.a of the Enforcement Policy. The violation
was entered into the licensees corrective action program as Condition Reports
CR 2015-008353 and CR 2015-008589. (NCV 05000445/2015008-04;
05000446/2015008-04, Failure to Maintain Adequate Controls for Design Calculations.)
e. Failure to Perform Adequate Operability Assessments associated with Failures of
Service Water System Vacuum Breaker during Surveillance Tests (multiple failures)
Introduction. The team identified an unresolved issue associated with the failures of the
vacuum service water breakers that remained in service. During these failures, the
licensee had documented the surveillance failures as degraded conditions and
concluded that they did not have an impact on the operability of the service water
system.
Description. The team reviewed the licensees operability assessments associated with
surveillance tests where at least one of the service water system vacuum breakers failed
to meet acceptance standards. During these failures, maintenance personnel
mechanically agitated the vacuum breakers in order to get them to operate but did not
replace the vacuum breakers until a future date. The inspectors noted that design basis
calculations indicate that the larger of the two vacuum breakers (check valve) was
required in order to protect the EDG jacket service water coolers and concluded that the
licensee did not have appropriate justification to conclude that the service water system
remained operable with a failed vacuum breaker if it was the larger breaker. During the
inspection period the team was not able to determine which vacuum breakers were
found in a degraded condition, therefore more information is required to determine if a
non-compliance exists. Specifically, since September 2010, the licensee issued twenty-
six operability evaluations associated with failed surveillance test on vacuum breakers in
the service water system where operators used incorrect information when assessing
operability, which failed to establish a reasonable expectation of operability. This issue
does not represent an immediate safety concern because at the time of discovery, there
were no failed vacuum breakers in service. The licensee entered the finding into
corrective action program as Condition Report CR-2015-008334.
- 22 -
This issue will remain unresolved until the NRC is provided sufficient information
regarding the particulars associated with the check valve/vacuum breaker failures in
order to determine if a non-compliance exists. Specifically, the team requires
information associated with the specific valve(s) that failed, the length of time that the
failed valve remained in service prior to replacement; whether the opposite train diesel
generator was ever inoperable during the period the failed valve remained in service.
(URI 05000445/2015008-05; 05000446/2015008-05, Failure to Perform Adequate
Operability Assessments associated with Failures of Service Water System Vacuum
Breaker during Surveillance Tests)
4OA6 Meetings, Including Exit
Exit Meeting Summary
On September 17, 2015, the inspectors presented the inspection results to Mr. Ken Peters, Site
Vice President, and other members of the licensee staff. The licensee advised that they had
additional information they would provide that they wished the NRC that would considered in
characterizing one of the findings. After considering that information, the team conducted a
follow up telephonic exit on October 1, 2015, with Mr. John Taylor, Site Engineering Director and
other members of the licensee staff where the final characterizations of the inspection were
presented. The licensee acknowledged the issues presented. The licensee confirmed that any
proprietary information reviewed by the inspectors had been returned or destroyed.
4OA7 Licensee-Identified Violations
None.
ATTACHMENTS:
1. Supplemental Information
2. Information Request
- 23 -
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
J. Boyer System Engineering Manager
S. Bradley Interim Training Director
J. Dreyfuss Plant Manager
D. Farnsworth Performance Improvement Director
T. Gibbs Safe Team/Employee Concerns Program Manager
D. Goodwin Director, Work Management
S.E. Harvey Outage Manager
T.A. Hope Regulatory Affairs Manager
K. Kettering Corrective Action Program Supervisor
D. Klooster DEA Manager
E. Lessmann Engineering Smart Team Manager
A. Marzloff Shift Operations Manager
T.P. McCool Engineering & Support Vice President
D.W. Mcgaughey Director Nuclear Operations
G.L. Merka Regulatory Affairs
L.M. Neuburger Engineering Corrective Action Program Coordinator
J.L. Patton Quality Assurance Manager
K. Peters Site Vice president
J. Rasmussen Operations Supt. Manager
K. Robertson Continuous Improvement / HP Manager
L. Slaughter Corrective Action Program
S. Sewell Director, Organizational Effectiveness
J.A. Taylor Director, Site Engineering
B. Thomas Engineering Smart Team Manager
C.K. Tran Engineering Programs Manager
D.S. Volkening NOS Audit Manager
L. Windham Corrective Action Program Manager
NRC Personnel
J. Clark Deputy Director, Division of Reactor Safety
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
05000445/2015008-02; NCV Failure to Properly Assess and Document the Basis for
05000446/2015008-02 Operability associated with the Turbine Driven Auxiliary
Feedwater Pumps Steam Exhaust Piping not being Evaluated
for Tornado Generated Missile Impacts05000445/2015008-03; NCV Inadequate Procedure for Surveillance on Safety-Related
05000446/2015008-03 Service Water Systems05000445/2015008-04; NCV Failure to Maintain Adequate Controls for Design Calculations05000446/2015008-04
A1-1 Attachment 1
Opened
05000445/2015008-01; VIO Failure to Evaluate the Lack of Missile Protection on the
05000446/2015008-01 Turbine Driven Auxiliary Feedwater Pumps Steam Exhaust
Piping
05000445/2015008-05; URI Failure to Perform Adequate Operability Assessments05000446/2015008-05 associated with Failures of Service Water System Vacuum
Breaker during Surveillance Tests
LIST OF DOCUMENTS REVIEWED
Condition Reports
2002-000937 2002-001194 2002-003366 2002-003370
2002-003545 2007-000937 2007-000946 2008-001110
2008-001380 2008-003247 2008-003249 2008-003345
2009-005880 2010-004111 2010-008411 2011-004858
2011-005495 2011-005987 2011-007598 2011-007644
2011-010546 2011-011159 2012-005825 2012-005846
2012-008620 2012-009711 2012-010253 2012-012871
2012-013488 2013-000264 2013-000564 2013-002804
2013-003398 2013-004029 2013-005278 2013-006118
2013-006240 2013-006453 2013-006709 2013-006748
2013-008181 2013-008182 2013-008183 2013-008203
2013-010064 2013-010449 2013-010455 2013-010505
2013-010523 2013-010956 2013-012081 2013-012143
2013-012287 2013-012621 2013-012990 2013-015278
2014-000443 2014-001017 2014-001268 2014-001848
2014-004284 2014-004693 2014-005001 2014-005254
2014-005604 2014-005874 2014-005961 2014-007431
2014-007316 2014-007979 2014-008651 2014-008716
2014-007798 2014-009952 2014-010068 2014-010608
2014008815 2013-010268 2013-004781 2014-006750
2014-009586 2014-011561 2014-012587 2015-000124
2014-010985 2015-002385 2015-003848 2015-004659
2015-000933 2015-005121 2015-005273 2015-005276
2015-004662 2015-005496 2015-007814 2015-007869
2015-005374 2015-007919* 2015-007930* 2015-007960*
2015-007895* 2015-007869* 2015-008275* 2015-008288*
2015-007976 2015-008334* 2015-008353* 2015-008402
2015-008311* 2013-008696 2013-007329 2014-012105
2015-010800* 2015-007997*
A1-2
- Issued because of inspection activities.
Miscellaneous Documents
Number Title Revision/Date
CPNPP Cause Analysis Handbook 16
15454-NP (B)-F06 SSW water hammers 2
15454-NP (B)-F34 Vacuum breaker set points 0
CP-0575-001 Solid State Safeguards System Sequencer 9
DCN 45351 Centrifugal Charging Pump Speed Increaser Lube Oil 3
Coupling Modification Procedure
EVAL 2015-006 Security Site Access Authorization/Fitness for
Duty/PADS
EVAL-2013-012 Management of Documents and Records January 15, 2014
EVAL-2013-014 Equipment Reliability Process and Maintenance Rule June 10, 2014
EVAL-2013-564 Core Performance Engineering and Fuel Management August 7, 2013
EVAL-2014-001 Emergency Preparedness
EVAL-2014-007 Operations Program March 26, 2014
EVAL-2014-011 Training Programs August 25, 2014
EVAL-2015-001 Emergency Preparedness
EVAL-2015-002 Work Management/Radiation Protection
M2-0233 Flow Diagram Station Service Water System
M2-0234 Flow Diagram Station Service Water System
ME-CA-0233-5494 Hydraulic Transient Analysis of the Station Service 1
Water System
QTE- 2002-003545 Operability of Service Water System with Vacuum 0
Breaker valve Failure
Procedure
Number Title Revision
CAP 101 Performing Apparent Cause Evaluations 7
CAP-102 Performing Common Cause Analyses 1
CAP-103 Performing Root Cause Analyses 0/3
CAP-104 Performing Effectiveness Reviews 2/3
CAP-105 Corrective Actions Program Oversight 0
ECE-5.01-08 Electronic Design Change Process 19/20
OPT-207B Service Water System 13/14
STA-421 Initiation of Condition Reports 19
STA-422 Processing Condition Reports 31/32
STA-424 Self-Assessment and Benchmarking Process 9
STA-428 Station Issue/Event Trending 3
STA-426 Industry Operating Experience Program 7
A1-3
Number Title Revision
STA-753 Management of Contracts 8
STI-124.01 Cable Deletions and Mid Span Cuts 0
STI-422.01 Operability Determination and Functionality Assessment Program 1/3
STI-422.02 Compensatory Actions & Transient Equipment Placements 1
STI-426.01 Processing and Maintaining Significant OE IER Levels 1 & 2 & 1
SOERS
STI-426.02 Processing Important OE, IERL3 & IERL4, INs & OPESS 0
Reports
STI-426.03 Processing Noteworthy OE (NOE) 0
STI-716.01 Project Management Of Design Modifications And Projects 4
STI-716.02 Site Facilities Activities 1
STI-716.03 Modification Team Guidelines (Mtg) Design Modification 0
Development Process Guidelines For Managing The Modification
Process The Right Mods At The Right Time
STI-716.04 Modification Oversight 0
Work Orders
4794262 4660504 4756056 12048420 4705071
459324 4485217
A1-4
Information Request
June 22, 2015
Biennial Problem Identification and Resolution Inspection -
August 31 - September 18, 2015
Comanche Peak Nuclear Power Plant
Inspection Report Number 05000445/2015008 and 05000446/2015008
This inspection will cover the period from November 8, 2013, through the end of the
inspection on September 18, 2015. All requested information should be limited to this
period or to the date of the request unless otherwise specified. To the extent possible,
provide the requested information electronically in Adobe PDF (preferred) or Microsoft
Office format. Provide paper copies of any sensitive information during the teams first
week on site; do not provide sensitive or proprietary information electronically.
Lists of documents (summary lists) should be provided in Microsoft Excel or a similar
sortable format. Please ensure that the fields (especially condition report descriptions)
are not size limited so that complete descriptions are provided. Please provide the
information on a compact disc (one for each team member), if possible. This information
may also be uploaded on the Certrec IMS website if so desired.
Please provide the following no later than August 3, 2015:
1. Document Lists
Note: For these summary lists, please include the document/reference number, the
document title or description of the issue, the priority, initiation date, status, and long text
descriptions of the issues.
a. Summary list of all corrective action documents related to significant conditions
adverse to quality that were opened, closed, or evaluated during the period
b. Summary list of all corrective action documents related to conditions adverse to
quality that were opened or closed during the period
c. Summary lists of all corrective action documents which were upgraded or
downgraded in priority/significance during the period
d. Summary list of all corrective action documents that subsume or roll up one or
more smaller issues for the period, or that identify a trend
e. Summary lists of operator workarounds, operator burdens, temporary
modifications, and control room and safety system deficiencies currently opened
or that were evaluated and/or closed during the period
f. Summary list of safety system deficiencies that required prompt operability
determinations (or other engineering evaluations) and ODMIs to provide
reasonable assurance of operability
A2-1 Attachment 2
g. Summary list of plant safety issues raised or addressed by the Employee
Concerns Program (or equivalent)
h. Summary list of all Apparent Cause Evaluations completed during the period
i. Summary list of all Root Cause Evaluations planned or in progress but not
complete at the end of the period
2. Full Documents with Attachments
a. Root Cause Evaluations completed during the period
b. Quality assurance audits performed during the period
c. All audits/surveillances performed during the period of the Corrective Action
Program, of individual corrective actions, and of cause evaluations
d. Corrective action activity reports, functional area self-assessments, and non-
NRC third party assessments completed during the period (do not include INPO
assessments)
e. Corrective action documents generated during the period for the following:
i. All Cited and Non-Cited Violations
ii. All Licensee Event Reports
f. Corrective action documents generated for the following, if they were determined
to be applicable (for those that were evaluated but determined not to be
applicable, provide a summary list):
i. NRC Information Notices, Bulletins, and Generic Letters issued or
evaluated during the period
ii. Part 21 reports issued or evaluated during the period
iii. Vendor safety information letters (or equivalent) issued or evaluated
during the period
iv. Other external events and/or Operating Experience evaluated for
applicability during the period
g. Corrective action documents generated for the following:
i. Emergency planning drills and tabletop exercises performed during the
period
ii. Maintenance preventable functional failures which occurred or were
evaluated during the period
iii. Adverse trends in equipment, processes, procedures, or programs which
were evaluated during the period
iv. Action items generated or addressed by plant safety review committees
during the period
A2-2
3. Logs and Reports
a. Corrective action performance trending/tracking information generated during the
period and broken down by functional organization
b. Corrective action effectiveness review reports generated during the period
c. Current system health reports or similar information
d. Radiation protection event logs during the period
e. Security event logs and security incidents during the period (sensitive information
can be provided by hard copy during first week on site)
f. Employee Concern Program (or equivalent) logs (sensitive information can be
provided by hard copy during first week on site)
g. List of Training deficiencies, requests for training improvements, and simulator
deficiencies for the period
4. Procedures
a. Corrective action program procedures (initiation, evaluation, classification, and
disposition of conditions adverse to quality. Include operability determination
procedures, root and apparent cause evaluation procedures and any other
procedures that implement the corrective action program;
b. Maintenance rule program and implementing procedures;
c. Operating experience program;
d. Employee concerns program;
e. Self-assessment program;
f. Degraded/non-conforming condition process (e.g., RIS 2005-20);
g. System Health process or equivalent equipment reliability improvement
programs;
h. Operational Decision Making (ODMI) process.
5. Other Items
a. Scheduled date/time/location of all meetings associated with implementation of
the corrective action program, such as screening meetings, corrective action
review board meetings, etc.
A2-3
b. Organization charts for plant staff and long-term/permanent contractors
c. Electronic copies of UFSAR (or equivalent), technical specifications and bases, if
available
d. All copy of assessments or evaluations (internal or external) regarding station or
department safety-culture.
e. A list of maintenance preventable functional failures (MPFFs) of risk-significant
systems (include actions completed and current status). A list of current
Maintenance Rule a(1) systems and a list of those systems that entered a(1)
within the last two years, but which were returned to a(2) status. Include a copy
of the current system health report for those systems now in a(1).
f. Copy of the latest corrective action program statistics such as the number
initiated by department, human performance errors by department, backlog,
corrective action timeliness and others as may be available.
g. A listing of the top 10 risk-significant systems, components, and/or operator
manual actions as appropriate.
Please provided on CDs and/or DVDs sent via overnight carrier to:
U.S. NRC Region IV
1600 E. Lamar Blvd.
Arlington, TX 76011-4511
Attention: Harry Freeman
Please note that the NRC is not currently able to accept electronic documents on thumb drives
or other similar digital media.
A2-4
SUNSI Review ADAMS Yes Non-Sensitive Publicly Available Keyword
By: HAF No Sensitive Non-Publicly Available NRC-002
OFFICE DRS/TSS/SRI DRS/TSS/RI DRS/PSB2/SRI DRP/PBA/SRI ORA/ACES DRP/PBA/C DRS/TSS/TL
NAME HFreeman CAlldredge JDrake JJosey JKramer RSmith ERuesch/RA/
SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ T. Farnholtz for
DATE 11/12/15 11/12/15 11/12/15 11/12/15 11/10/15 11/12/15 11/13/15
Letter to Rafael Flores from Eric A. Ruesch dated, November 13, 2015
SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT - NRC PROBLEM
IDENTIFICATION AND RESOLUTION INSPECTION REPORT
05000445/2015008 AND 05000446/2015008 AND NOTICE OF VIOLATION
Electronic distribution:
Regional Administrator (Marc.Dapas@nrc.gov)
Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)
DRP Director (Troy.Pruett@nrc.gov)
DRP Deputy Director (Ryan.Lantz@nrc.gov)
DRS Director (Anton.Vegel@nrc.gov)
DRS Deputy Director (Jeff.Clark@nrc.gov)
Senior Resident Inspector (Jeffrey.Josey@nrc.gov)
Resident Inspector (Rayomand.Kumana@nrc.gov)
Administrative Assistant (Rhonda.Smith@nrc.gov)
Acting Branch Chief, DRP/A (Rich.Smith@nrc.gov)
Senior Project Engineer, DRP/A (Ryan.Alexander@nrc.gov)
Project Engineer, DRP/A (Thomas.Sullivan@nrc.gov)
Project Engineer, DRP/A (Mathew.Kirk@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Project Manager (Balwant.Singal@nrc.gov)
Acting Team Leader, DRS/TSS (Eric.Ruesch@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Technical Support Assistant (Loretta.Williams@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)
RIV/ETA: OEDO (Cindy.Rosales-Cooper@nrc.gov)
ROPreports