ML20148K285
| ML20148K285 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/11/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20148K264 | List: |
| References | |
| 50-445-97-12, 50-446-97-12, NUDOCS 9706170414 | |
| Download: ML20148K285 (48) | |
See also: IR 05000445/1997012
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ENCLOSURE 2
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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Docket Nos.:
50 445
50-446
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. License Nos.:
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Report No.:
50-445/97-12
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50-446/97 12
Licensee:
TU Electric
Facilityi
Comanche Peak Steam Electric Station, Units 1 and 2
Location:
Glen Rose, Texas
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Dates:
April 21 through May 2,1997
Inspectors:
M. Runyan, Reactor inspector, Engineering Branch
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P. Goldberg, Reactor inspector, Engineering Branch
D. Carter, Resident inspector, Project Branch F
R. Nease, Resident inspector, Project Branch A
Approved By:
C. VanDenburgh, Chief, Engineering Branch
Division of Reactor Safety
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ATTACHMENT:
Supplemental Information
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9706170414 970611
ADOCK 05000445
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TABLE OF CONTENTS
EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . .
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Renort Details . . . . . . . . . . . . . . . . . . .
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1. Operations . . . . . . . . . . . .
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Conduct of Operations . . .
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01.1 Day-to-Day Resolution of Problems by Operations
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01.2 Review of Operator Logs and Records . . . . . . . . . . . . . . .
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O2
Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . 5
02.1 Operator Work-Arounds .
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02.2 Operability and Reportability Determinations
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Operations Procedures and Documentation
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03.1 Licensee Event Report 96-02 . .
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Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . , . . . 8
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Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
07.1 Operations Department Self Assessment . . .
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11. M a i nt e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
M2
Maintenance and Material Condition of Facilities and Equipment
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M 2.1 Corrective Maintenance Orders . . . . . . . . . . , . . . . . . . . . . . , . 10
M2.2 Maintenance Backlog . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
M2.3 Plant Walkdown
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M7
Quality Assurance in Maintenance Activities
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M7.1 Quality Assurance in Maintenance Activities
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111. Engineering
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E2
Enginstdng Support of Facilities and Equipment .
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E2.1
Engineering Support of Operating Experience . . . . . . . . . . . . . . 14
E2.0 Engineering Support in Operability Determinations
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E2.3 Engineering Support of operations, notification, and evaluation
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Forms..........................................
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E2.4 Maintenance Alterations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
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E2.5 Engineering Backlog . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
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E7
Quality Assurance in Engineering Activities . . . . . . . . . . . . . . . . . . . . 23
E7.1
Quality Assurance Audits and Self Assessments
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E7.2 Root-Cause Analysis
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E8
Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
E8.1
(Closed) Inspection Followup Item 445/9601-02: Unit 2
Refueling Water Storage Tank Degradation
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E8.2 (Closed) Inspection Followup item 50-445;-446/9310-07: Use
of Ru n Ef ficie ncy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
E8.3 (Closed) Inspection Followup Item 445,4-46/9505-01:
Therm o-Lag ksu e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
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E8.4 (Closed) Inspection Followup Item 50-445;-446/9710-02:
Temporary Shielding
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V. Management Meetings . . . . . . . . . . . . . . .
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Exit Meeting Summary . .
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ATTACHMENT: Supplemental Information
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EXECUTIVE SUMMARY
Comanche Peak Steam Electric Station, Units 1 and 2
NRC Inspection Report 50-445;-446/97-12
Operations
The safety review committees were effective in analyzing, assessing, and resolving
issues (Section 01.1).
The inspectors identified one occurrence in which an operations, notification, and
evaluation form was not written for the failure of a safety injection system relief
valve as required by their administrative procedures. This was identified as the first
example of a violation of Criterion XVI (Section 01.2).
The licensee failed to provide required information in Licensee Event Report 96-02
related to past occurrences of slow closure of Feedwater Isolation
Valve 1-HV-2135. Although the licensee disagreed with this violation, the
inspectors verified with the program office that the failure to report this information
was a violation of 10 CFR 50.73 (Section 03.1).
Maintenance
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The licensee was maintaining good control over the backlog of maintenance items
(Section M2.2).
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During a walkdown, equipment material control and housekeeping were observed to
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be excellent (Section 2.3).
The licensee failed to initiate a operations, notification, and evaluation form to
document the failure of the diaphragm on the reactor Makeup Water Pump
Discharge Valve 2DD-0019, as required by their administrative procedures. This
was identified as the second example of a violation Criterion XVI (Section M7.1).
The licensee failed to take adequate corrective action for a series of diaphragm
valve f ailures related to improperly installed valve internals, in that, the location of
all the improperly installed diaphragm valves had not been identified and the
licensee had not inspected or evaluated the adequacy of these potential
deficiencies. This was identified as the third example of a violation of Criterion XVI
(Section M7.1).
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The licensee failed to take adequate corrective actions within Plant Incident
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Report 96-055 to determine and correct the administrative and technical problems
that resulted in numerous missed opportunities to earlier identify and correct a slow
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stroking' problem with Feedwater Isolation Valve 1-HV-2135. This was identified as
the fourth example of a violation of Criterion XVI (Section E2.3),
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The licensee failed to initiate a operations, notification, and evaluation form in
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response to an industry notification addressing previously unaccounted errors in a
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motor-operated valve diagnostic system, as required by their administrative
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procedures. This was identified as the fifth example of a violation of Criterion XVI
(Section E2.3),
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An inconsistency existed in the basis for the licensee's establishment of shelf life
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for nitrife elastomer diaphragms (Section E2.3).
The licensee failed to evaluate the safety implications of four design change notices,
each of which involved changes to drawings depicted in the Final Safety Analysis '
Report, in a manner consistent with the requirements established by 10 CFR 50.59.
This discrepancy resulted partially from a licensee guidance document that allowed
" trivial changes" to the facility without performing a safety evaluation. This was
identified as a violation of 10 CFR 50.59. Although the licensee believed that
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previous NRC inspections had accepted this practice, the inspectors concluded that
this was not the case as discussed in the report (Section 2.4).
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The licensee failed to provide adequate instructions for the installation of
temporary lead shielding on safety and nonsafety-related piping systems, in
that it did not discuss the materials to be used as attachment devices or the
methods to secure the temporary shielding. This was identified as a violation
of 10 CFR Part 50, Appendix B, Criterion V (Section 2.5).
The backlog of open engineering issues was well-managed with a declining 2-year
trend (Section E2.6).
System health reports and dedicated teams for each tystem were identified as
strengths in the area of system engineering (Section E7.1).
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Report Details
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Summarv of Plant Status
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Both units were operated at 100 percent power for the duration of the inspection,
l. Operations
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Conduct of Operations
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General Comments 40500
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The objective of this inspection was to evaluate the effectiveness of the Comanche
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Peak Steam Electric Station programmatic controls to identify, resolve and prevent
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problems that degrade plant safety. This review focused on the following areas:
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Safety review committee activities
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Root-cause analysis
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Corrective action
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Self assessment
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Operating experience feedback
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The inspection consisted of an exten;
review of plant documents, attendance at
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various plant meetings, employee interviews, and meetings with licensee personnel
to discuss technical or administrative questions.
The inspectors conducted reviews of ongoing plant operations as it related to the
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corrective rct on process. In general, the plant operations involvement in the
corrective action process was satisfactory.
01.1 Dav-to-Day Resolution of Problems by Operations
a.
Insoection Scope (40500)
The inspectors evaluated the operations staff's efforts to resolve identified problems
by reviewing operations, notification, and evaluation forms, observing the activities
of the operations notification and evaluation committee in developing corrective
actions, and observing the activities of the station operations review committees.
The inspectors held discussions with operational staff personnel to determine how
day-to-day resolution of problems were handled. The inspectors interviewed
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selected operations staff personnel to determine their knowledge of the corrective
action process and procedures at Comanche Peak. The inspectors interviewed nine
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operational staff personnel, which included operations shift manager, unit
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supervisors, reactor operators, and auxiliary equipment operators.
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b.
Observations and Findinos
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The operational staff interviewed by the inspectors were knowledgeable of the
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corrective action process. They indicated that the day-to-day resolution of problems
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(e.g., equipment deficiencies) were handled through the operations, notification, and
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evaluation form process or by use of the control of maintenance and work activities
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process (Procedure STA-606, " Control of Maintenance and Work Activities,"
Revision 24). The control of maintenance and work activities process was used for
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regular maintenance and minor maintenance activities only. Operations,
notification, and evaluation forms were initiated for more significant issues, which
also included human performance and procedural compliance issues.
Upon receipt of a operations, notification, and evaluation form, the shift manager
reviews the operations, notification, and evaluation form for immediate reportability
and operability. All hard copy operations, notification, and evaluation forms were
brought to the shift manager for review and signature. The inspectors observed a
shift manager process Operations, Notification, and Evaluation Form 97-412 that
required the shift manager to request the joint engineering team to ps.iorm a quick
technical evaluation to determine if equipment operability was affected. The quick
technical evaluation was performed within the procedurally recommended 24-hour
period.
The inspectors attended several operations, notification, and evaluation form
meetings between April 22 and 29,1997, a station operations review committee
meeting on April 25,1997, and an industry operating experience report review
meeting on April 29,1997. These groups performed the following functions:
The operations, notification, and evaluation form meeting reviews and
assigns proposed corrective action for each operations, notification, and
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evaluation form. The inspectors observed the operations, notification, and
evaluation form board review, discuss, and assign work control review
processes for each form reviewed.
The operations, notification, and evaluation form meeting reviews each
condition report for significance, determines priority level, and screens each
for potential hazards to nuclear safety.
The station operations review committee reviews all operations, notification,
and evaluation forms that are considered to be a potential hazard to nuclear
safety.
The industry operating experience report review meeting reviews industry
events, NRC information notices, and numerous industry-generated reports
and notifications to ensure lessons learned from industry operating
experience are util zed to improve plant safety.
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The inspectors observed good communications between the various work groups, a
questioning attitude, constructive discussions, comprehensive consideration of
safety significance and root causes, acceptable prioritization of issues, and
appropriate management attendance in every meeting. In general, the meetings
were effective and well conducted.
c.
Conclusions
The inspectors concluded that the day-to-day resolution of problems was handled in
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an effective manner through the operations, notification, and evaluation form
process. Overall, the inspectors concluded that the operations staff handled the
day-to-day resolution of problems in an effective manner. In general, the inspectors
concicded that the safety review committees were effective in analyzing, assessing,
and resolving issues. The committees were also effective in determining safety
significance, pnaritization, and appropriate root-cause determination.
01.2 Review of Operator Loos and Records
a.
Insoection Scone (40500j
The inspectors held discussions with operations personnel and reviewed operations
shift managers logs and operations shift orders to determine if logged items met the
threshold for writing a operations, notification, and evaluation form.
b.
Observations and Findinas
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The inspectors reviewed station operations shift orders for the period between
April 1-29,1997. The shift orders provide operational information for each unit,
status of equipment, operational guidance, and general information pertaining to
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operations department personnel.
The inspectors reviewed the Unit 2 shift managers logs for the period April 20
through May 20,1996. The inspectors reviewed 11 adverse condition log entries,
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These log entries detailed equipment malfunctions and unexpected control room
alarms. Of the 11 log entries, the inspectors verified that 9 log entries had
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operations, notification, and evaluation forms written and one did not meet the
procedural requirement of an adverse condition. One log entry dated May 14,
1996, described isolating the Unit 2, Train A, Safety injection Cross-Tie
Valve 2-8821 A to see if leaking Relief Valve 2-8853A was the cause for a level
decrease in the safety injection accumulators. This log entry requested engineering
to perform a quick technical evaluation to determine operability of the Train A safety
injection system with the relief valve leaking by.
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The licensee performed Technical Evaluation 96-515 on May 15,1996, that
described the relief valve being replaced. The licensee also performed Technical
Evaluation 96-524, dated May 16,1996, to address safety injection system past
operability while relief Valve 2-8853A was leaking by. These technical evaluations
were performed outside of the normal operations, notification, and evaluation form
process. If a operations, notification, and evaluation form had been written, a quick
technical evaluation would have been performed as originally requested by the shift
manager.
The first Technical Evaluation 96 515 was performed within the procedurally
recommended time frame for a quick technical evaluation; however, the second
Technical Evaluation TE96-524 was performed a day later. The licensee missed an
opportunity to take full advantage of the operations, notification, and evaluation
form process to address issues of plant incident resolution, deficiency resolution, or
engineering resolution. These issues were ultimately performed 1 month later on
June 24,1996, when Operations, Notification, and Evaluation Form 96-726 was
written to address over-pressurization of the safety injection pump discharge
header. The licensee became aware of this adverse condition due to
recommendations to monitor system pressure, that were detailed in Technical
Evaluation 96-510, dated May 15,1996.
The inspectors questioned the licensee if a operations, notification, and evaluation
form should have been written to document this problem. The licensee stated that
a operations, notification, and evaluation form was required in this case, but had
not been written.
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," states, " Measures
shall be established to assure that conditions adverse to quality, such as failures,
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malfunctions, deficiencies, deviations, defective material and equipment, and
nonconformances are promptly identified and corrected."
Procedure STA-421, " Operations, Notification and Evaluation (ONE) Form,"
Revision 5, provides a mechanism for plant personnel to report conditions which
potentially threaten the safe operation of the plant. Attachment 8.A of this
procedure includes examples of conditions that should be reported on an operations,
notification, and evaluation form. The aoove example is consistent with these
examples and, therefore, should have been documented on an operations,
notification, and evaluation form.
The failure to initiate a operations, notification, and evaluation form is the first
example of a violation of Criterion XVI (50-445;-446/9712-01).
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c.
Conclusions
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The inspectors concluded that the licensee's threshold to write operations,
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notification, and evaluation forms was adequate. However, one example of the
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. failure to write a operations, notification, and evaluation form resulted in a violation
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of Criterion XVI.
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Operational Status of Facilities and Equipment
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02.1 Operator Work-Arounds
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a.
hsocction Scope (40500)
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The inspectors held discussions with operations personnel and reviewed station
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procedures regarding op3rator work-arounds, defined as items that require operators
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to take compensatory measures beyond the intended design of the plant and that
could distract the operator frc,m required actions during transient conditions.
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b.
Observations and Findinas
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The inspectors reviewed Operations Guideline 36, which described the process for
controlling work-arounds and contained the duties and responsibilities of operations
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personnel with regard to work-arounds. The number of work-arounds had generally
declined over the past year. Currently, both units had seven work-arounds
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identified. The inspectors verified that each operator work around was tracked and
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scheduled for elimination by an maintenance action item.
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The licensee also tracked items termed as operations priority work items, defined as
equipment deficiencies that cannot or have not been corrected through normal
corrective programs and that the operations department feels the need to identify
and track under this program. The number of operations priority work items had
remained relatively constant over the past year,
c.
Conclusions
The inspectors concluded that operator work-arounds were receiving appropriate
management attention and that resolution and closure of work-arounds was being
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performed in a timely manner consistent with licensee priorities.
02.2 Operability and Reportability Determinations
a.
hvoection Scoce (40500)
The inspectors reviewed 22 operations, notification, and evaluation forms handled
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by operations to determine the adequacy of the operability and reportability
determinations.
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b.
Observations and Findinas
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The operations shift manager reviews all operations, notification, and evaluation
forms and documents whether an immediate impact on operability or reportability
exists. If the shift manager has any question on the initial determination of
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operability, Procedure STA-422, " Processing of Operations Notification and
Evaluation (ONE) Forms," Revision 12, requires the initiation of a quick technical
evaluation. Quick technical evaluations by procedure are performed within
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24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inspectors considered the immediate reportability determinations
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made by operations to be satisfactory.
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The inspectors reviewed the operations, notification, and evaluation form opershility
assessments and their bases. Overall, the inspectors found the operability.
assessments and bases to be technically adequate. However, there were some
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instances where the operability determination was not well documented and the
inspectors had to discuss the evaluation with licensee personnel to understand the
basis for concluding that a degraded condition was operable,
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c.
Conclusions
The licensee was adequately handling operability and reportability determinations,
however, some determinations had a less than desirable level of detail to fully
describe the thought process used in the evaluation.
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Operations Procedures and Documentation
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03.1 Licensee Event Reoort 96-02
a.
Insoection Scope (40500)
The inspectors reviewed Licensee Event Report 96-02 as part of a review of a
feedwater isolation valve slow closure event discussed in Section E2.3.
b.
Observations and Findinas
The inspectors questioned the adequacy of Licensee Event Report 96-02, in that it
did not reference previous similar events, in the event, Feedwater Isolation
Valve 1-HV-2135 had stroked closed in greater than the 5-second limit imposed by
the Technical Specifications. At the time that Licensee Event Report 96-02 was
issued, the licensee was aware of numerous previous occurrences where the same
valve had failed to stroke as required. Several of these previous events are
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discussed in Section E2.3 of the inspection report. However, the licensee provided
-the following statement in Licensee Event Report 96-02:
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"There have also been previous similar events related to slow closure
of MFIVs on Unit 2. However, corrective actions taken to resolve the
causes of the previous events would not have prevented this event."
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Although the reference to Unit 2 valves was of uncertain origin, when questioned,
the licensee was able to find a single instance in 1995 when Valve 2-HV-2137 had
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stroked closed in 5.91 seconds in lieu of the 5.0 second requirement. The previous
events of slow closure of Valve 1-HV-2135 were not discussed in any other
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sections of Licensee Event Report 96-02.
Section Ill.B of Licensee Event Report 96-02 states, that a metal fragment in a
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hydraulic solenoid valve was the probable root cause of the failure and concluded
that since the valve was installed in 1993 and that the fragment could not have
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entered the valve during service, that "MFIV 2 (1-HV-2135)is conservatively
considered to have been inoperable from November 1993 until the solenoid valves
were replaced on January 24,1996." The use of the word " conservatively"
suggested a lack of additional objective evidence related to the operability of
this valve. This statement, coupled with the lack of mention of previous slow
closures of the same valve, would leave an impression that the slow closure of
Valve 1-HV-2135 on January 22,1996, was the only known occurrence of this
event.
10 CFR 50.73(b)(5) states, "The Licensee Event Report shall contain: Reference to
any previous similar events at the same plant that are known to the licensee."
During the inspection, the licensee expressed disagreement with the inspectors'
position that a discussion of the previous failures of Valve 1-HV-2135 was required
within Licensee Event F'eport 96-02. This was based on the licensee's
interpretation that the required discussion of previous occurrences was restricted
solely to reported events within previous licensee event reports.
NUREG 1022, " Event Reporting Guidelines 10 CFR 50.72 and 50.73," Revision 1,
Second Draft, Section 5.2.1.(5), page 116, states:
. . . previous occurrences should include previous events or
conditions that involved the same underlying concern or reason
as this event, such as the same root cause, failure, or
sequence of events. For infrequent events such as fires, a
rather broad interpretation should be used (e.g., all fires and,
certainly all fires in the same building should be considered
previous occurrences. For more frequent events such as ESF
actuations, a narrower definition may be used (e.g., only those
scrams with the same root cause). The intent of the rule is to
identify generic or recurring problems.
NUREG 1022, " Licensee Event Reporting System," Supplement No.1, Question and
Answer 12.9, page 20, provides essentially the same guidance. Therefore, whether
defining the feedwater isolation valve problem as a frequent or infrequent event, the
guidance of NUREG 1022 clearly indicates that the same valve failing because of
the same cause is within the scope of the 10 CFR 50.73 definition of similar events.
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The f ailure to report previous occurrences of f ailure of Valve 1-HV-2135 in Licensee
Event Report 96-02 is a violation of 10 CFR 50.73 (50-445/9712-02).
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Conclusions
The inspectors concluded that the licensee had failed to provide reqc: red
information concerning previous failures of Valve 1-HV-2135 in Licensee Event
Report 96-02. This was identified as a violation of 10 CFR 50.73.
04
Operator Knowledge and Performance
04.1 Operator Involvement in the Corrective Action Process
a.
Inspection Scope (40500)
The inspectors interviewed operations personnel to determine their knowledge and
involvement in the corrective action process,
b.
Observations and Findinos
Operations staff management personnel were present and actively participated in
the operations notification and evaluation committee, station operations review
committee, and operations review committee meetings. All operations, notification,
and evaluation forms were reviewed and approved by the control room shift
manager.
Operational staff personnel were encouraged by management to write operations,
notification, and evaluation forms. Ope;ators interviewed by the inspectors stated
that they were not reluctant to write operations, notification, and evaluation forms,
and felt that if there was a doubt about an equipment issue, they could write a
operations, notification, and evaluation form to ensure that the matter would be
corrected,
c.
Conclusions
The inspectors concluded that operations involvement in the corrective action
process was satisfactory.
07
Quality Assurance in Operations
07.1 Operations Denartment Self Assessment
a.
Inspection Scooe (40500)
The inspectors reviewed two operations self assessments and four nuclear overview
department evaluation reports. The review covered a wide variety of operations
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concerns (i.e., conduct of operations, plant status, procedures, f acilities and
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equipment, and operator knowledge and performance.)
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b.
Observations and Findinas
The inspectors reviewed the last two operations self assessments for completeness
of reviews and trends. The inspectors interviewed the operations department head
and questioned him on concerns mentioned in tne last operations self assessment.
The operations manager was aware of the status of most issues. However, when
questioned on an issue that was a carryover item in the last two operations self
assessments (i.e., the timely access to the hot tool room for auxiliary operators),
the manager was not sure of the status of the issue. Upon further review with his
staff, the manager was able to detail the corrective actions taken to correct the
issue.
The inspectors reviewed four nuclear overview department evaluation reports.
Report NOE-EVAL-96-000134, dated July 15,1996, documented an unresolved
item which referenced a 1995 Nuclear Overview Department evaluation that
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identified an improvement area regarding docurnentation of operability
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determinations associated with operations, notification, and evaluation forms and
quick technical evaluations. Report NOE-EVAL-000200, dated February 20,1997,
addressed this unresolved item and described corrective actions taken by the
operations shift manager to correct this issue. However, the unresolved item
remained open pending further response from the shift operations manager
following his assessment of the documentation of operability determinations on
quick technical evaluations.
o 'ight of this licensee-identified problem area, the inspectors reviewed 20
mrations, notification, and evaluation form operability assessments and
determined, in general, that operability determinations were adequately performed.
One operations, notification, and evaluation form requested an operability
determination; however, a quick technical evaluation had not been performed it
was not clear until the inspectors held discussions with plant staff that the
operability issue had been adequately addressed, in a second instance, the shift
managers log requested that a quick technical evaluation be performed to determine
whether operability had been effected on a safety-related system due to a leaking
relief valve. A operations, notification, and evaluation form was not written;
however, a technical evaluation was performed the next day, which determined that
the system had remained operable. This f ailure to write a operations, notification,
and evaluation form is described in detail in Section 01.2 of this report.
c.
Conclusions
Operations assessments were effective in identifying strengths and areas of
concern. In general, actions were taken to correct recurring deficiencies. However,
additional management at*.ention is required in the area of assessment of the
documentation of operability determinations and quick technical evaluations.
Operations management was generally aware of strengths and concerns mentioned
in operations self assessments.
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11. Maintenance
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M2 -
Maintenance and Material Condition of Facilities and Equipment
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M2.1. Corrective Maintenance' Orders
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a.
Insoection Scone (40500)
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The inspectors reviewed 27 corrective maintenance orders to determine if repetitive
problems existed and to determine if they were being used to improperly modify the
plant design. In addition, the inspectors reviewed corrective maintenance work
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orders to determine if identified problems were being properly documented on
operations, notification, and evaluation forms. The inspectors discussed several of
the maintenance work orders with applicable licensee personnel.
b.
Observations and Findinas
The inspectors found that the corrective maintenance work orders were used
appropriately for repair and replacement of plant equipment. The inspectors found
no examples where the maintenance orders were improperly used to modify the
plant design. . In addition, no examples of repetitive maintenance were identified.
The inspectors determined that the licensee had performed appropriate corrective
actions for the corrective rr
'tenance orders reviewed.
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For the 27 corrective maintenance work orders reviewed, the licensee used
operations, notification, and evaluation forms where required to document
discrepant conditions,
c.
Conclusions
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The inspectors concluded that corrective maintenance work orders were
appropriately used for repair and replacement of plant equipment.
M2.2 Maintenance Backloa
a.
Inspection Scope (40500)
,
The inspectors reviewed the maintenance backlog of corrective maintenance work
orders to determine the backlog size, the trend (i.e., increasing, decreasing or
steady), how the backlog was tracked and managed, and how priorities were
determined. The inspectors also discussed the backlog with applicable maintenance
personnel.
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b.
Observations and Findinos
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The licensee's corrective maintenance safety-related work order backlog from April
1995 to April 1997 indicated a generally decreasing trend. In April 1995, the
corrective maintenance backlog consisted of 278 open work orders. By April 1997,
the backlog had decreased to 44 open items.
c.
C_qnclusions
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The inspectors concluded that the licensee's corrective maintenance backlog of
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work orders had decreased significantly over a 2-year period and was being
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effectively managed.
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M2.3 Plant Walkdown
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a.
Inspection Scoce (40500)
The inspectors conducted walkdowns of various plant areas to deterrrine equipment
operability and material condition. In addition, the inspectors conducted walkdowns
to determine general plant housekeeping and plant material condition.
b.
Observations and Findinas
.
t
During the plant walkdowns, the inspectors noted that excellent plant housekeeping
was being maintained as evidenced by an absence of leaks, debris. material storage
problems, and indications of corrosion on equipment. The team found a few minor
inconsistencies which were reported to the licensee. Specifically, the team found
two safety chains on a platform which were too short to be connected in the Unit 2
turbine driven auxiliary feedwater room. In addition, two more safety chains that
were too short to be connected in the turbine building. Also, the inspectors found
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some trash between the pump and the shielding over the pump in the Unit 2 Train A
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residual heat removal pump room. The licensee responded promptly to correct
these deficiencies.
c.
Conclusions
Overall, the inspectors concluded that both equipment material condition and plant
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housekeeping were excellent.
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M7
Quality Assurance in Maintenance Activities
M 7.1 Quality Assurance in Maintenance Activities
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a.
Inspection Scope (40500)
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The inspectors reviewed "1996 Maintenance Functional Self Assessment," which
a
was performed during the period of July 8-12,1996. The inspectors discussed the
findings with licensee personnel to determine if the corrective actions and
recommendations that resulted from the self assessment were adequate and had
been completed in a timely manner.
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b.
Observations and Findinas
The inspectors found that the licensee's self assessment was thorough and critical
of maintenance department processes. Some of the areas covered by the self
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assessment included the material condition of the plant, work control, preventive
maintenance, and maintenance procedures and documentation. The inspectors
sampled some of the recommendations from the self assessment and determined
that the licensee had resolved the items adequately.
The self-assessment team reviewed operations, notification, and evaluation forms
for a 2-year period to determine if actions taken as a result of the occurrences were
I
effective at identifying the causes and preventing recurrence. One problematic
issue identified by the self-assessment team was eight separate occurrences of ITT
Grinnell diaphragm valve failures over the 2-year period. Seven of the valves had
f ailed because of incorrectly installed finger plates (i.e., finger plate installed upside
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down), which resulted in tearing of the diaphragm when the valve was opened.
The eighth failure resulted from misalignment of the compressor prior to reassembly.
The inspectors reviewed the six operations, notification, and evaluation forms and
one work order that were generated to correct problems with the incorrectly
installed finger plates. Operations, Notification, and Evaluation Form 94-902, dated
July 6,1994, identified that a finger plate had been installed upside down.
However, since the licensee determined that no previous work had been performed
on the valve by maintenance, the licensee determined this was an isolated
manufacturer-related problem and that no further action was required. As the
failures continued to occur, the licensee determined that the valve procedure
associated with th':, failed valves lacked clear guidance as to the proper orientation
of the finger plate during installation. Based on the self assessment's
recommendation that all procedures relative to diaphragm valve assembly be revised
to include appropriate instructions to preclude additional diaphragm valve failures,
the licensee revised all of the dir.phragm valve procedures.
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The inspectors reviewed Work Order 3-95-322110-01, dated March 1996, which
stated that the finger plate on Diaphragm Valve 2DD-0019 (Reactor Makeup Water
Pump 2-01 discharge valve) had been installed upside down causing the diaphragm
to tear. The inspectors determined that the licensee had not written a operations,
notification, and evaluation form for this adverse condition.
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," states, " Measures
shall be established to assure that conditions adverse to quality, such as failures,
malfunctions, deficiencies, deviations, defective material and eouipment, and
,
nonconformances are promptly identified and corrected."
Procedure STA-421, " Operations, Notification and Evaluation (ONE) Form,"
Revision 5, provides a mechanism for plant personnel to report conditions which
potentially threaten the safe operation of the plant. Attachment 8.A of this
procedure includes examples of conditions that should be reported on a operations,
notification, and evaluation form. The above example is consistent with these
examples and, therefore, should have been documented on an operatir>ns,
notification, and evaluation form.
The failure to identify this condition adverse to quality in accordance with
Administrative Procedure STA-421 was considered to be the second example of a
violation of Criterion XVI (50-445;-446/9712-01).
The inspectors also discussed with the licensee the six operations, notification, and
evaluation forms and one work order that were initiated for incorrect finger plate
installations and the resultant torn diaphragms. The inspectors asked the licensee
what actions had been taken to ensure that other similar valves, both safety and
nonsafety, installed in the plant were not affected by improper installation of the
finger plates. The licensee stated that they had not completely reviewed the
generic implications associated with incorrect installation of the finger plates.
Based on this concern, the licensee initiated Operations, Notification, and Evaluation
Form 97-435, during the inspection on May 2,1997. The form reviewed the
generic implications of the finger plates and also attached a listing of approximately
500 diaphragm valves, in both safety-related and nonsafety-related systems, where
the potential existed for incorrect installation of the finger plates. The licensee
performed an operability review and determined that the valves were operable based
on the fact that there had not been a failure of a diaphragm valve for over a year
and that some of the valves had been opened and had not failed. The inspectors
considered the operability review to be justified pending the additional actions the
licensee intended to take to fully assess the situation.
The licensee's failure to take adequate corrective action to review the generic
implications of the diaphragm failures was the third example of a violation of
Criterion XVI (50-446;-446/9712-03)
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c.
Conclusions
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The inspectors concluded that the 1996 Maintenance Functional Self Assessment
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was thorough, critical, and effective. In addition, the inspectors concluded that the
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licensee had initiated appropriate responses to the recommendations in the report.
However, the inspectors identified two violations that had not been identified by the
self assessment. Specifically, the licensee had failed to initiate a operations,
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notification, and evaluation form for the incorrect installation of the finger plate on
Diaphragm Valve 2DD-0019 (Reactor Makeup Water Pump 2-01 discharge valve).
In addition, the licensee failed to evaluate the generic aspects of the diaphragm
failures until prompted by the NRC inspectors. These examples were identified as
violations of 10 CFR Part 50, Appendix B, Criterion XVI.
Ill, Enaineerina
E2
Engineering Support of Facilities and Equipment
E2.1
Enaineerina Support of Operatina Exoerience
a.
Insoection Scons (40500)
The inspectors r3 viewed the licensee's response to the information notices and
10 CFR Part 21 reports identified in the attachment to this inspection report.
,
b.
Observations md Findinas
,
The inspectors observed that the licensee appropriately addressed each technical
i
issue discussed in the listed reports. The licensee implemented corrective actions
as necessary to disposition the resulting technical findings.
c.
Conclusions
The inspectors concluded that the licensee had satisfactorily addressed the
technical issues discussed in the listed reports.
E2.2 Enaineerina Sucoort in Ooerability Determinations
1
a.
Scoce (40500)
The inspectors reviewed six quick turnaround evaluations performed by engineering,
as listed in the attachment to this inspection report. The quick turnaround
evaluation process provides a 24-hour Merability evaluation for conditions that
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cannot be independently assessed by operations personnel,
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Observations and Findinas
The inspectors did not identify any concerns related to the analyses performed by
engineering to determine the operability of degraded equipment as described in the
quick turnaround evaluations reports.
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c.
Conclusions
The inspectors concluded that engineering performed an acceptable assessment of
operability within each quick turnaround evaluation reviewed.
E2.3 Enaineerina Sucoort of ooerations, notification, and evaluation Forms
a.
Insoection Scoce (40500)
The inspectors selected a sample of operations, notification, and evaluation forms
that were assigned to engineering for resolution. These are included in a list of
operations, notification, and evaluation forms in the attachment to this inspection
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report. The inspectors reviewed the reports and arranged meetings with licensee
engineers to discuss questions that arose during the reviews.
b.
Observations and Findinas
b.1
General Assessment
The inspectors reviewed 47 operations, notification, and evaluation forms that were
principally dispositioned by engineering. These reports were of high quality,
including complete descriptions of the problem, well-conceived root-cause
,
evaluations, and appropriate application of corrective actions. Of particular note
i
was the consistent consideration of the generic consequences of the identified
problem. The operations, notification, and evaluation form prompted the reviewer
to document an evaluation of the potential for the identified problem to be present
in other applications. The inspectors identified this as a strength.
The inspectors identified issues specific to several of the reviewed operationt,
notification, and evaluation forms, as discussed below.
b.2 Feedwater Isolation Valve Slow Closure - The inspectors reviewed Plant incident
Report 96-055, which described the licensee's investigation into the events
following a Unit 1 trip on January 22,1996. A plant incident report functions
similarly to a operations, notification, and evaluation form, but is reserved for
more significant events. During the event, a loss of power to Panel 1EC1 resulted
in a close signal being sent to all four feedwater isolation valves. However, one
of these valves (1-HV-2135) was noted by the operators to be in a mid position.
This valve closed in 38 seconds, but is required by Technical Specification 4.7.1.6
to close within 5 seconds.
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Upon investigation the licensee discovered a small metal fragment between the
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fluid filter screens and valve internals of the Train A Hydraulic Solenoid
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Valve 1-HV-2135-SV1. The licensee concluded that the fragment, in restricting
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the free flow of hydraulic fluid, was the root cause of the valve's failure to close in
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the required time.
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This event was reviewed by a task team during the post-recovery period as
documented in NRC Inspection Reports 50-445;-446/96-02 and
50-445;-446/96-06. During this time, the licensee determined that the
post-maintenance test methods used on Valve 1-HV-2135 following various
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troubleshooting efforts were inadequate. Specifically, the test procedure energized
both the Trains A and B solenoids in order to verify closure of the valve within the
required time. Since one train was capable of closing the valve within its required
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time limit, the proper functioning of one train could mask any deficiencies in the
train on which maintenance was performed. The licensee identified that the correct
post-maintenance test for operability should have been the train specific response
time test in accordance with Surveillance Procedure PPT-S1-9404B, "Feedwater
Isolation Valve Response Time Test, Train B," Revision 1. The failure to specify
the correct post-maintenance test was identified as a noncited violation in NRC
inspection Report 50-445:-446/96-06,
i
During this inspection, the inspectors noted that Plant incide,nt Report 96-055
discussed several past events where Valve 1-HV-2135 had stroked closed in greater
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than the Technical Specification time limit. However, the plant incident report did
not evaluate why the corrective action process had failed to identify the root cause
and correct the inoperable condition. The following is a timeline of several of the
events leading up to the January 22,1996, event.
On March 4,1995, Valve 1-HV-2135 stoked closed in greater than
25 seconds during the performance of Surveillance Test OPT-511 A.
Operations, Notification, and Evaluation Form 95-181 was written to
investigate. However, the forra was written in such a way that the root
cause of the test failure was presumed to be a limit switch problem. After
checking the limit switches, the valve tested satisfactorily. The licensee
missed an opportunity to correct the problem at this time because of a
presumptive approach to the troubleshooting effort combined with a lack of
sensitivity to the potential for an intermittent failure mechraism.
On November 19,1995, Valve 1-HV-2135 stoked closee
+1
approximately 88 to 112 seconds following a Unit 1 trip. . < licensee
informed the inspectors that the operators noted the slow closure. The valve
was retested satisfactorily and returned to service. An operations,
notification, and evaluation form was not written to investigate the failure.
Later, in the process of investigating the January 22 event on January 30,
,
1996, Operations, Notification, and Evaluation Form 96-0080 was written
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following a review of plant computer data that confirmed the slow closure.
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On January 17,1996, the operators again noted that Valve 1-HV-2135 was
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in a mid-position following a Unit 1 trip. Again, an operations, notification,
and evaluation form was not processed and less than adequate action was
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taken to troubleshoot the valve failure. As a result, the inoperable condition
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of Valve 1-HV-2135 was not identified, and the unit was restarted. Had the
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event of January 22,1996, not occurreci, the inoperable condition of
Valve 1-HV-2135 would most likely not have been discovered for an
extended period of time.
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The inspectors observed that Plant incident Report 96-055 reported, but did not
evaluate the consequences of the above events and several others that occurred
during the approximate 3-year period during which Valve 1-HV-2135 was
intermittently inoperable. As a result, corrective actions were not taken addressing
the deficiencies that permitted this safety significant condition to go uncorrected for
an extended period of time.
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," states, " Measures
'
shall be established to assure that conditions adverse to quality, such as failures,
malfunctions, deficiencies, deviations, defective material and equipment, and
nonconformances are promptly identified and corrected. In the case of significant
conditions adverse to quality, the measures shall assure that the cause of the
condition is determined and corrective action taken to preclude repetition."
The licensee's f ailure, on numerous previous occasions, to properly assess the root
cause of the failure of Feedwater Isolation Valve 1-HV-2135 to stroke closed within
design parameters resulted in this valve being inoperable for an extended period of
time. Because the timely closure of this valve is assurned within the t afety analysis
of the plant to prevent overcooling of the reactor or to isolate a faulted steam
generator, the failure to earlier identify and correct this condition represented a
significant condition adverse to quality. Although Plant incident Report 96-055
identified this significant condition adverse to quality, it failed to determine the
cause of the condition or to take corrective action to preclude repetition.
This issue was identified as the fourth example of a violation of 10 CFR Part 50,
Appendix B, Criterion XVI (50-445;-446/9712-03).
b.3 Ellis and Watts Coolina Coil Fan Motors durina Tornado - NRC Inspection
Report 99901308/96-01 documented a vendor audit of Ellis and Watts, Division of
Dynamics Corporation of America. This inspection report documented a concern
regarding the cooling coil fan motors purchased by Comanche Peak, in that, the
fans had not undergone a proper commercial-grade dedication by the vendor.
Specifically, the dedication plans did not address verification of a critical
characteristic of the fan motors involving their capability to operate during tornado
conditions at a reduced pressure of 11.7 psia.
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The licensee issued Operations, Notification, and Evaluation Form 96-1541 to
iddress this issue and performed Calculation ME-CA-0000-4098, Revision 0, to
perform the tornado analysis. Using a computer model, the calculation assumed
that the pressure would decrease rapidly from 14.7 to 11.7 psia, hold at 11.7 psia
for approximately 10 seconds, and then rapidly recover. The maximum pressure
drop across the coolers during the transient was calculated to be 0.0209 psi, which
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is approximately 60 percent of the pressure drop at which the unit filters are
recommended for replacement. Based on these facts, the licensee concluded that
!
the fan cooler units would continue to operate during and after a tornado.
The inspectors reviewed Calculation ME-CA-0000-4098 and considered that the
analysis adequately oddressed the procurement discrepancy discussed in NRC
Inspection Report 99901308/96-01.
b.4
MOVATS MUTN 96-02 - The licensee initiated Operations, Notification, and
Evaluation Form 96-1487 to address a maintenance update (MUTN 96-02) received
from MOVATS addressing previously unaccounted errors in the MOVATS 3500
strain module. The inspectors inquired as to the licensee's response to
Supplement 1 of MUTN 96-02. The licensee stated that, because of administrative
changes the supplement was misrouted and was not processed as a operations,
notification, and evaluation form. However, a faxed copy of ths supplement was
)
received by the licensee's motor-operated valve group. The licensee had
investigated some of the technical details of the notice, but a operations,
notification, and evaluation form had not been initiated.
In response to the inspectors' questioning of this issue, the licensee initiated
Operations, Notification, and Evaluation Form 97-405, to address the immediate
operability and reportability questions related to the supplement. The inspectors
considered the form to have satisfactorily addressed the immediate operability
consequences.
1
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," states, " Measures
shall be established to assure that conditions adverse to quality, such as failures,
malfunctions, deficiencies, deviations, defective material and equipment, and
nonconformances are promptly identified and corrected."
Procedure STA-421, " Operations, Notification and Evaluation (ONE) Form,"
Revision 5, provides a mechanism for plant personnel to report conditions which
potentially threaten the safe operation of the plant. Attachment 8.A of this
procedure includes examples of conditions that should be reported on a operations,
notification, and evaluation form. The above example is consistent with these
examples and, therefore, should have been documented on an operations,
notification, and evaluation form.
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The failure to identify a condition adverse to quality in response to receipt of the
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adverse vendor information is considered the fifth example of a violation of
Criterion XVI (50-445;-446/9712-01).
b.5 Shelf Life of Diaphraams -The inspectors reviewed Operations, Notification, and
.
Evaluation Forms97-409 and 97-420, dated April 25 and 29,1997, respectively,
.
which concerned various actuator diaphragms stored in the warehouse that had
developed cracks. The majority of the diaphragms had been purchased from Fisher
Controls and Copes Vulcan. The inspectors also reviewed Procedure ECE 6.08,
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" Determination of Shelf Life," Revision 0, which identified that nitrile elastomer
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diaphragms had a shelf life of 14 years based on an Electric Power Research
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institute guideline. However, the inspectors noted that the manufacturer had
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recommended a shelf life of 2 years for the diaphragms, which could be extended to
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6 years if certain conditions were met. The licensee was currently reviewing the
>
)
issue to determine whether a revision to the shelf life of the diaphragms was
needed. This issue was identified as an inspection followup item
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(50-445;-446/9712-04).
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c.
Conclusions
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Generally, the licensee's performance in the dispositioning of operations,
notification, and evaluation forms was good in particular, the treatment of generic
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concerns was comprehensive. Some exceptions were noted, including a violation
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for failure to take adequate corrective actions and for failing to initiate a necessary
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operm;ons, notification, and evaluation form.
E2.4 Maintenance Alterations
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a.
Insoection Scoce (40500)
The inspectors selected a sample of maintenance alterations that were assigned to
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engineering for resolutior, as listed in the attachmcnt to this inspection report. The
%pecto reviewed the maintenance alterations and arranged meetings with
,
licensee personnel to discuss questions that arose during the reviews.
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b.
Observations and Findinas
The inspectors reviewed Procedure ECE 5.01-07, " Maintenance Alteration
Evaluations," Revision 2, which provided the method and criteria for determining if
,
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the change was a maintenance alteration or a modification to the plant. According
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to the licensee, the maintenance alteration process met at least the minimum
requirements of 10 CFR Part 50, Appendix B, Criterion lit, " Design Control."
However, the level of detail from an administrative and budgetary perspective was
less than that used in the design modification process.
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The inspectors noted that a maintenance alteration allowed some configuration
changes to systems, structures, and components. The procedure defined a
maintenance alteration as a configuration change thct did not change the existing
licensing or design basis. The inspectors determined that the criteria defining which
,
changes met the definition of a maintenance alteration were vague, leaving much of
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the decision-making to the responsible engineer. However, one definite stipulation
"
was that any change requiring a 10 CFR 50.59 safety evaluation could not be
processed as a maintenance alteration.
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The inspectors reviewed Administrative Procedure STA-707, "10 CFR 50.59
Reviews," Revision 13, which established and maintained the licensee's safety
evaluation program. The inspectors found that this procedure referenced another
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procedure titled "10 CFR 50.59 Review Guide," Revision 4, for guidance for
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performing safety evaluations. The inspectors noted that the review guide defined
,
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" trivial changes" as being modifications that did not constitute changes to the
facility as described in the Safety Analysis Report. The review guide stated that
trivial changes did not require a 10 CFR 50.59 safety evaluation and instructed
licensee personnel to answer "NO" to the relevant 10 CFR 50.59 screening
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questions. Within the review guide, the licensee defined seven categories of " trivial
changes" as follows.
Editorial changes
,
Clarifications
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Relocation of information to a more appropriate section
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Revisions to make supporting sections of the licensing basis document
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consistent
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Organizational changes
Deletion of existing information which was believed to be below the level of
detail required to be included in the Final Safety Analysis Report
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Minor changes, which had no potential safety impact
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The inspectors consulted with the Office of Nuclear Reactor Regulation and
concluded that the last two categories of the licensee's definition allowed changes
were potentially beyond the scope of trivial changes as discussed in NRC guidance
documents. The NRC definition of " trivial changes" [ discussed, in part, in
Inspection and Enforcement Manual Chapter, Part 9800, "CFR Discussions,
Changes to Facilities, Procedures and Tests (or Experiments)," Section D.7.d, dated
,
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January 1,1984) included editorial, organizational, and typographical changes, but
did not extend to changes involving physical changes to the plant configuration that
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resulted in a revision to plant drawings included in the Final Safety Analysis Report.
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The inspectors reviewed a sample of maintenance alterations and identified four
examples where the licensee had made a trivial change without performing a safety
evaluation as requi.ed by 10 CFR 50.59. These are listed below.
Maintenance Alteration Design Change Notice 10490, Revision 0, involved
changing the valve lineup to bypass a flow transmitter by opening a bypass
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line for the reactor coolant post accident sampling system sample cooler.
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This change was not trivial because it involved a revision to
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Drawing M1-0228-01, which was included in the Final Safety Analysis
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Report.
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Maintenance Alteration Design Change Notice 10714, Revision 0, involved
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deleting two feedwater drain valves. This change was not trivial because it
involved a revision to Drawing M2-0203-01 A, which was included in the
i
Final Safety Analysis Report.
Maintenance Alteration Design Change Notice 10445, Revision 0, involved
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removing the internals of a instrument air check valw on the discharge side
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of an instrument air compressor. This change was not trivial because it
involved a revision to Drawing M1-0216, which was included in the Final
Safety Analysis Report.
Maintenance Alteration Design Change Notice 9013, Revision 1, involved a
generic replacement of globe and hermetically sealed valves in nonprocess
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a iplications with ball valves. This change was applicable for both safety and
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nonsafety applications. The activity screening stated that specific
applications would be indicated on the flow diagrams by means of an
optional valve symbol as reflected or the flow diagram Legend M1-200.
.
These changes were not trivial because Drawings M1-0242, M1-0269,
M1-031 ' M2-0210, M2-0215, M1-0200, M1-0210, M1-0215, and
M1-024
ocluded within the Final Safety Analysis Report were revised.
The licensee c
Jdered each of the four examples to meet the definition of a
" trivial change" U.e., minor changes which had no potential safety impact). In each
case, the 10 CFR 50.59 screening question asking whether the change resulted in a
change to the facility, as described in the Final Safety Analysis Report, was marked
"NO." However, the inspectors concluded that the four examples did not represent
trivial plant configuration changes because they involved revisions to the drawings
in the Final Safety Analysis Report. Because the licensee had, in f act, changed the
f acility as described in the Final Safety Analysis Report, a safety evaluation was
required by 10 CFR 50.59 to determine whether an unreviewed safety question
existed.
!
10 CFR 50.59(a)(1) states, " . . . the holder of a license authorizing operation of a
production utilization f acility may (i) make changes in the f acility as described in the
safety analysis report . . . unless the proposed change . . . involves . . . an
unreviewed safety question."
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10 CFR 50.59(b)(1) states that, " . . . the licensee shall maintain records of changes
.in the facility . .'. to the extent that these changes constitute changes in the facility
as described in the safety analysis report . . . These records must include a written
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safety evaluation which provides the basis for the determination that the change
. . . does not involve an unreviewed safety question."
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The failure to perform and document a safety evaluation for the four design change
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notices was identified as a violation (50-445;-446/9712-05).
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During the inspection and at the exit meeting, the licensee disagreed with the
proposed violation because this practice had been accepted in previous NRC
inspections. With regard to this discussion, the licensee indicated the following:
)
(1)
There had been previous NRC inspections of the licensee's 10 CFR 50.59
procedures and guidelines, and that all of these inspections had come to
]
positive conclusions with respect to the licensee's implementation of
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(2)
Inspection Report 50-445;-446/93-32, Section 2.2.2, describing the review
1
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of Temporary Modification 92-1-05, constituted a review and acceptance of
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the licensee's definition of a " trivial change."
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With regard to example (1), the inspectors noted that NRC acceptance of a position
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is not conferred by the lack of reference to an issue within a report. As such,
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licensees should not conclude that every undocumented element of a reviewed
program has been accepted by the NRC.
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With regard to example (2), the inspectors noted that the discussion in
Section 2.2.2 of the inspection report did not review and approve the licensee's
design change program with respect to " trivial changes". The inspection
l
documented that a safety evaluation had not been performed for a temporary
!
modification to the reactor vessel level instrumentation, which involved a clear-
!
change to the facility as described in the licensing basis documents. The inspectors
noted that the change should have been implemented as a " trivial" type change
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because the change had no potential safety impact. The inspectors were concerned
I
about the need to carefully follow administrativo procedures to ensure that changes
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to the facility were properly evaluated. The inspectors also were concerned that the
change had been accomplished as a temporary modification vice a permanent
'
change to the facility; however, they concluded that this error was isolated and of
minor safety significance. Nevertheless, these views and concerns cannot be
j
reasonably construed to be NRC approval of the licensee's program for use of
'
" trivial changes". The example represented an isolated instance, which was not
reviewed by the Office of Nuclear Reactor Regulation. Therefore, the inspectors
concluded that this current violation is appropriate.
,
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4
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c.
Conclusions
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The inspectors concluded that the procedure used for maintenance alterations was
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weak, in that, it did not clearly specify the criteria for determining when a
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maintenance alteration could be performed instead of a modification. In addition,
the inspectors concluded that the licensee's 10 CFR 50.59 Review Guide incorrectly
defined " trivial changes". As such, the inspectors identified four examples of the
failure to perform safety evaluations required by 10 CFR 50.59.
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E2.5 Enaineerina Backloa
a.
Insoection Scoce (40500)
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The inspectors reviewed the licensee's engineering backlog to determino the
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backlog size, how +he backlog was tracked and managed, and how priorities were
determined. In addition, the inspectors reviewed the backlog to determine the
backlog trend (i.e., increasing, decreasing, or steady).
b.
Observations and Findinas
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The inspectors reviewed the backlog and found that as of April 1997 there were a
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total of 2586 open action items. Based on a graph that plotted open action items
from April 1995 through April 1997, a slight decreasing trend existed over the
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2-year period. In April of 1995 there had been a total of approximately 3400 open
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action items. Out of the current open 2586 action items,1202 of the items were
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safety related. These open items included 419 operations, notification, and
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evaluation forms, 53 maintenance alterations, 283 design change notices,
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99 technical evaluations, and other items.
c.
Conclusions
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The inspectors concluded that the licensee was controlling the backlog at an
acceptable level with a declining trend over the past 2 years.
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-E7
. Quality Assurance in Engineering Activities
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E7.1 - Quality Assurance Audits and Self Assessments
a.
Insoection Scope (40500)
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To evaluate the effectiveness of the licensee's controls in identifying and resolving
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plant problems, the inspectors selected and reviewed the licensee's corrective
'
actions for nine observations from the licensee's self-assessment report, "1995
Engineering Self-Assessment Report," dated September 1996.
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b.
Observations and Findinos
The inspectors reviewed the licensee's responses to nine observations generated
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from the 1996 engineering self assessment and discussed them with the applicable
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engineering personnel to determine the adequacy of the action item response. The
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inspectors reviewed the licensee's action plan for the 1995 engineering self
assessment and found that each finding from the self assessment had been
addressed.
Two of the recommendations concerned developing a restoration plan for each of
!
the active temporary modifications and developing and implementing a priority
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scheme that complemented the site-wide priority scheme and prioritized work. The
licensee stated that they had created a system health report, which was issued
>
quarterly. The inspectors reviewed the fourth quarter 1996 report and found that it
,
was a very good tool for system engineers and management to focus attention and
'
resources on the systems that failed to meet performance goals.
The inspectors noted that each plant system was rated using four assessment
- colors. To rate the systems, each system engineer met quarterly with dedicated
- personnel from maintenance, operations, and modification engineering to discuss
the system and determine its rating and trend. The inspectors found that each
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system report contained a justification for the system rating, short-term corrective
l
actions or recommendations for improvement, long-term corrective actions, and
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temporary modifications installed. The report also contained information on system
I
unavailability, reliability, and listed operational concerns.
The inspectors found'that the licensee had adequately dispositioned the action
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items and had resolved the issues. The inspectors concluded that the system
'
health reports and the dedicated teams assigned to each system were a strength.
c.
Conclusions
The inspectors concluded that the licensee had adequately dispositioned nine
observations selected from the 1995 engineering self assessment. The inspectors
also concluded that the system health reports and the dedicated teams for each
system were a strength.
E7.2 Root-Cause Analysis
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a.
Insnection Scope (40500)
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Within the condition reports listed in the attachment, the inspectors reviewed
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root-cause analyses performed by the licensee.
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b.
Observations and Findinas
in general, the licensee's root cause analyses were comprehensive and broad
scoped. The identified root causes appeared to be consistent with the reported
facts. One exception was Pla'nt incident Report 96-055, where the root cause
process failed to consider previous failures to identify a safety significant deficiency
(see Section E2.3).
c. Conclusions
The licensee had implemented a good root cause analysis process. Only one root
!
cause reviewed during the inspection was observed to be deficient.
E8
Miscellaneous Engineering issues (92903)
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E8.1
(Closed) Inspection Followuo item 445/9601-02: Unit 2 Refuelina Water Storage
Tank Deoradation
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Backaround - This item involved a possible leak from the Unit 2 refueling water
storage tank. White deposits had been found on the surface of the tank. All
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questions had been resolved except for two: (1) the potential for an unmonitored
release path and (2) the potential for long-term degradation of the tank rebar from
l
boric acid corrosion.
'
Inspector Followuo - The inspectors reviewed Calculation CS-CA-0000-5013,
Revision 0, which evaluated the potential degradation of the reinforcing steelin the
refueling water storage tank concrete structure. The calculation indicated that a
minimum design margin of 29 percent was available for the criticalload case, but
also concluded that some corrosion of rebar may be occurring based on the
presence of iron oxide in the precipitate. The licensee concluded that the extent of
existing and future corrosion would not threaten the available margin. Upon
observations of the exterior of the tank, the inspectors did not detect any
indicatiens of active leaks. The pressure grouting applied by the licensee was
evident in the lower sections of the tank and appeared to be holding well.
The inspectors concluded that the issue was adequately resolved for the current
time. Ongoing examinations of the tank conducted during routine plant walkdowns
~
should be sufficient to detect future leaks. If necessary, the issue could be
reopened at that time.
E8.2 (Closed) Inspection Followuo item 50-445:-446/9310-07: Use of Run Efficiency
Backaround - This item identified the practice by the licensee of using run efficiency
in the equation for predicting the unseating capability of some of its motor-operated
valves. The actuator vendor, Limitorque, had not endorsed the use of run efficiency
for the opening direction, instead recommending use of a lower pullout efficiency
for this application,
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Inspector Followuo - During this inspection, the inspectors discussed this issue with
a licensee motor-operated valve expert. For certain applications, Comanche Peak
was still using run efficiency for the open analysis. However, the following two
f actors, not typically considered, were also included in the calculation of pullout
capability: (1) a factor accounting for torque losses due to a stem-thrust effect of
approximate magnitude to account for the difference between run and pullout
efficiency, and (2) the use of a 0.9 application factor in lieu of.the 1.0 application
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factor endorsed by Limitorque for instances where the limiting voltage is less than
90 percent rated. In recognition of these facts and the extensive testing the
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licensee performed to justify their methodology, the inspectors considered the issue
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to be resolved at Comanche Peak. However, this does not confer a generic NRC
endorsement to use run efficiency for motor-operated valve open capability
analyses.
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E8.3 (Closed) Insoection Followup Item 445.446/9505-01: Thermo-Lao issues
Backaround - This item involved issues related to the use of Thermo-Lag fire barriers
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at Comanche Peak. One of these concerns involved the use of TU Electric Test
Scheme 15-2, in which a localized heat affected zone was observed on a single
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cable. The other issue involved a number of Thermo-Lag discrepancies in Unit 2
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that were documented in TU Engineering Report ER-ME-100, " Evaluation of Unit 2
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Thermo-Lag Fire Barrier Discrepancies," Revision 0, dated February 15,1995.
During a previous inspection, this report had been in draf t.
Insoector Followuo - During the current inspection, the inspectors verified that in a
letter dated May 22,1996, the NRC accepted Scheme 15-2, except for cables
smaller than 750 KcMil [MCM). In a Letter TXX-97047, dated February 28,1997,
the licensee stated that TU Electric Test Scheme 15-2 is not used to certify
configurations that are less than 750 MCM cable.
The inspectors also reviewed the completed report and discussed this issue with the
-
site Thermo-Lag licensing contact. Based on this, the inspectors concluded that the
licensee had, in their detailed review of 10 percent of these discrepancies,
.
established a reasonable basis for discontinuing the fire watches initiated in
response to these discrepancies. However, the licensee, for other reasons, had
i
retained the fire watches throughout this time period to the present.
Although certain issues related to Thermo-Lag at Comanche Peak remain open, the
inspectors concluded that this inspection followup item could be closed. Remaining
issues are being resolved under an ongoing dialogue between the licensee and the
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Office of Nuclear Reactor Regulation.
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E8.4 (Closed) Inspection Followup Item 50-445:-446/9710-02: Temocrary Shieldina
1
Backaround - During a routine plant tour, the inspectors observed temporary lead
shielding in the plant that was secured with the use of plastic tie wrap. Based on
the concern that the temporary shielding could detach and damage surrounding
equipment, the inspectors questioned the engineering analysis that had been
performed for this method of installation.
Inspector Followuo - The licensee stated that eight temporary shielding installations
1
existed in the radiation controlled area of both units, some for greater than 2 years.
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The inspectors observed temporary shielding installed in several of these areas, and
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noted that it was within the vicinity of other safety-related piping and components.
The temporary shielding was secured with white, plastic tie wraps.
The inspectors reviewed Calculation ECE-PSE-139, dated August 21,1990, that
allowed the installation of temporary shielding within the guidelines described in
Procedure RPI-608, " Quality-Related Control of Temporary Shielding," Revision 5,
dated May 26,1994, and found that an analysis of the securing mechanism (i.e.,
plastic tie wraps) for temporary shielding had not been provided. The calculation
did address the additional piping loads generated by the shielding, but did not
evaluate the capability of the plastic tie wrap to keep the shielding in place during
seismic or other events. The lack of consideration of the tie wrap strength for these
installations was considered a weakness in the calculation method employed for this
application.
In response to the inspectors' concerns, the licensee issued Operations,
Notification, and Evaluation Form 97-429 and attached a technical evaluation of the
acceptability of the tie wrap attachments. The evaluation concluded that for three
of the eight existing installations, the loads generated by a seismic event would
exceed the vendor's recommended loading, but would not exceed the loop tensile
strength. For one of the eight existing temporary shielding installations, the
calculation stated that the installation was unacceptable; however, the licensee
found no seismic Catego.y ll/l concerns in the area where this shielding was
installed. Therefore, for this installation, falling shielding would not cause an
operability concern.
On May 2,1997, the licensee issued Shift Order 97-05, which stated, " Temporary
shielding in the plant which is secured using plastic tie wraps must be inspected if a
seismic event or plant transient has occurred." The inspectors considered the
technical evaluation in combination with Shift Order 97-05 to have satisfactorily
addressed the immediate operability concerns related to this issue.
The inspectors noted that there were both white and blue, plastic tie wraps securing
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shielding in various locations in the radiation controlled area; however, only blue tie
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wraps were available in the tool room. However, licensee personnel provided
'
conflicting answers concerning which tie wraps should be used to secure temporary
shielding. For example, a radiation protection technician told the inspectors that
white, plastic tie wraps were to be used in radiation areas. A joint engineering team
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supervisor told the inspectc s that blue, plastic tie wraps should be used in radiation
areas (and had, in fact, tested blue tie wraps for tensile strength in response to this
issue). Personnel in the tool room stated that blue, plastic tie wraps were issued for
installing shielding in the radiation controlled area. Finally, the acting radiation
protection manager stated that the only distinction between blue and white tie
wraps were for foreign material exclusion control in containment where only blue tie
wraps were to be used.
Procedure RPI-608, " Quality-Related Control of Temporary Shielding," Revision 5,
dated May 26,1994, allowed for the installation of lead shielding on both safety
>
and nonsafety-related systems. Attachment 2 to Procedure RPI-608, " Shielding
Installation Guidelines," stated that plastic tie wraps were acceptable as securing
devices. - However, the attachment failed to specify the type or size of the tie-wraps
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to use and failed to provide guidelines on how to correctly secure the temporary
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shielding, such as the maximum spacing between the attachrnents. The inspectors
concluded that Procedure RPI-608 was inadequate to control the installation of
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temporary shielding and ensure that the temporary shielding did not adversely affect
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safety-related components.
10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"
requires, in part, that activities affecting quality shall be prescribed by documented '
procedures and instructions appropriate to the circumstances.
(
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The failure of Procedure RPI-608 to provide adequate installation instructions for the
!
installation of temporary shielding was identified as a violation of 10 CFR 50,
Appendix B, Criterion V (50-445;-446/9712-06).
V. Manaaement Meetinas
X1
Exit Meeting Summary
>
The inspectors presented the inspection results to members of "censee management
at the conclucion of the inspection on May 2,1997. The licensee acknowledged
the findings presented. The licensee disagreed with two of the proposed violations
,
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involving the failure (1) to provide information regarding previous f ailures of a valve
discussed in Licensee Event Report 96-02; and (2) to perform a safety evaluation
for several plant changes which the licensee classified as " trivial changes". As
'
discussed in Sections 03.1 and E2.4 of the inspection report, we have concluded
that (1) the information omitted from the Licensee Event Report was clearly within
the scope of the intent of the existing regulations, and (2) our previous inspections
did not approve the licensee's method of implementing " trivial changes".
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The inspectors asked the licensee whether any materials examined during the
!
inspection should be considered proprietary. No proprietary information was
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identified.
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a
ATTACHMENT
SUPPLEMENTAL INFORMATION
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee
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J. Barker, Engineering Overview Manager
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O. Bhatty, Senior Regulatory Compliance Specialist
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R. Bird, Nuclear Planning Manager
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M. Blevins, Plant Manager
D. Buschbaum, Technical Compliance Manager
R. Byrd, Smart Team 2 Manager
R. Calder, Executive Assistant
J. Curtis, Radiation Protection Manager
R. Cutlip, Maintenance Support
D. Deperro, Smart Team 3 System Supervisor
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S. Ellis, Smart Team 1 Manager
J. Finneran, Smart Team DW:n Load
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R. Flores, System Engineering Manager
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W. Grace, Safety Services Manager
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W. Guldemond, Shift Operations Manager
T. Hope, Regulatory Compliance Manager
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T. Jenkins, Smart Team 3 Manager
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J. Kelly, Vice President, Nuclear Engineering and Support
M. Killgore, Nuclear Engineering Manager
D. Kross, Work Control Manager
B. Lancaster, Plant Support Manager
H. Lancaster, Operations
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F. Madden, Technical Support Manager
D. McAfee, Programs Overview Manager
G. Merka, Regulatory Affairs
M. Sunseri, Nuclear Training Manager
C. Terry, Group Vice President, Nuclear Production
R. Walker, Regulatory Affairs Manager
D. Weyardt, Smart Team 2 Support
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NRC
V, Ordaz, Resident inspector
T. Polich, Project Manager
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INSPECTION PROCEDURES USED
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Effectiveness of Licensee Controls in identifying, Resolving, and
Preventing Problems
Followup - Engineering
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-445;-446/9712-01
Failure to Initiate Operations, Notification, and
Evaluation Form
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50-445/9712-02
Inadequate Licensee Event Report
50-445;-446/9712-03
Inadequate Corrective Actions
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50-445;-446/9712-04
IFl
Diaphragm Shcif Liie
50-445;-446/9712-05
Inadequate 10 CFR 50.59 Evaluation
50-445;-446/9712-06
Inadequate Temporary Shielding Installation Procedure
Closed
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50-445;-446/9310-07
IFl
Run Efficiency for Motor-Operated Valve Opening
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Analysis
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50-445;-446/9505-01
IFl
Thermo-lag issues
50-445;-446/9601-02
IFl
Unit 2 Refueling Water Storage Tank Degradation
50-445:-446/9710-02
IFl
Inadequate Temporary Shielding
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LIST OF DOCUMENTS REVIEWED
1
PROCEDURES
STA-421
Operations Notification and Evaluation (ONE) Form, Revision 5
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STA-422
Processing of Operations Notification and Evaluation (ONE) Forms,
Revision 12
STA-504
Technical Evaluation, Revision 11
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ODA-102
Conduct of Operations, Revision 16
NOA-2.30
Industry Operating Experience Report Review Program
ECE 6.08
Determination of Shelf Life
ECE 5.01-07 Maintenance Alteration Evaluations
STA-707
10 CFR 50.59 Reviews
N/A
10 CFR 50.59 Review Guide, Revision 4
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ONE FORMS
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Ooerations95-790
Spurious containment ventilation isolation signal
95-985
Leaking S/G blowdown containment isolation valve
95-1001
Two valves in boric acid flowpath found out of position
96-100
Operator mistakenly started CCP instead of BAMUP
96-410
Auxiliary Operator closed wrong valve removing RHR from service
96-460
Improper fuse installed in fuse block
96-572
Noisy source range channels causes swapover of CP suction to RWST
96-579
MSIV hydraulic oil pump failed to maintain required pressure
96-601
l&C inadequately restored MFP turbine control computers causing turbine trip
96-634
Unit unable to reach full power due to MSR drain line size
96-723
Inadvertent boration while filling & venting BTRS96-726
Overpressurization of SI discharge piping
96-736
Penetration seal breach without LCOAR tracking
96-830
Rod control power supply failure
96-1102
Reactor vessellevel fluctuation during draindown
96-1145
Chiller tripped due to combination of things
96-1182
Breaker failed to open de-energizing bus causing Rx trip
96-1359
Fire door /RCA boundary found open
96-1455
Excessive load increase causing letdown to isolate
Maintenance
96-0166
Erosion of ECCS Throttle Valves
96-0088
Valves Fail Leak Test
95-1144
Valve 'Nould Not Open Manually
95-OE64
10 CFR Part 21 Cylinder Liners
96-1064
MOV Testing Deficiency
95-0007
DCN Closed Before Grinding Work was Performed
95-0030
Camshaft Cover Bolts Discrepancies
95-0720
TD-AFW Pump Alignment Out-of Balance
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Enaineerina
96-0080
FWlV Slow Closure
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96-0308
MOV Failed to Open
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96-0352
MOV Fails to Fully Close
96-0408
Safety Injection Pump Exceeds Max Head Limits
96-0429
MOV Failed Closed
96-0862
MOV Unseating Problem
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96-0781
Starting Air Block Valve
96-0910
EDG Generator Frequency Unstable
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96-1487
10 CFR Part 21 MOVATS 3500 Strain Module
95-0018
Failure to Perform impact Reviews on Minor Modification
!
95-0022
Circuit Breaker Failed Testing
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95-0048
Filtration Unit Airflow out of Specification
96-0951
CCP Lubricating Oil Problem
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96-0022
No Design Change Initiated to Remove Components95-949
Data bases differ on the classification of therrnocouples
95-1013
Incorrect torque used on bonnet fasteners
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95-1049
Water discovered in left bank air intake manifold of EDG
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96-121
Safety injection relief valve lifted and ruptured its bellows
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96-299
Relief valve failed set pressure and seat leakage tests
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95-816
Safety injection relief valve found relieving to the floor
9elief valve failed set pressure test
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95 1027
Found scaling calculation revised for a modification not implemented
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95-1102
Flow diagrams and MEL are inconsistent in the classification of valves
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95-1152
Process sample line was found closed and capped but stillleaking
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95-1013
Torque wrench used to torque fasteners outside of its range
95-756
ONE form disposition was changed from repair to use-as-is
95 1094
On start of TDAFWP handswitch indicator for valve failed
During EDG test,3 of 6 bolts on the fuel oil pump were loose
95-930
Poppet was found installed backwards on the EDG fuel oil pump valve
Valves were found stuck open due to dirty system
95-031
Replacement nozzle for relief valve was wrong size
96-1217
Two pressurizer safety valves failed as-found tests95-949
Conflict between MEL and PRISM for status of thermocouples
95-1104
Carbon steel valve replaced with stainless valve
95-723
Increased oxygen concentration found in condensate storage tank
AFW pump shaft found binding
95-738
Guide bushing land was damaged
95 833
Piping to outboard seal was cracked
95-799
CCW surge tank low alarm
95-850
Accumulator check valve leak rates97-435
Generic implications of diaphragm valve finger plates
Finger plate found upside down on diaphragm valve
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95-839
Finger plate installed improperly in diaphragm valve
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96-602
Diaphragm finger plate found installed upside down
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96-38
Finger plate was installed upside down
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Finger plate was installed upside down
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96-419
Finger plate was found upside ~ down
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Corrective Maintenance Work Orders
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NUMBER
DESCRIPTION
+
92-028462
Bolt missing in component shelf
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96-104945
Water found inside motor cavity
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96-102519
Valve exceeds alert limit stroke time
96-100954
Replace valve
95-086259
Leaking through packing
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95-089356
O-ring broken in operator
96-100644
Remove dielectric kits
96-105877-
Problem with low oil pressure
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95-084650
Isolation valve for pressure indicator is frozen open
96-101667
Diaphragm leaking air
96-104036
Replace lube oil pump low speed shaft
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95-091729
Boron crystals buildup on sealleakoff drain
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95-094513
Remove and replace 4 cylinder liners for inspection
95-089444
Wires possibly rolled at AC distribution box
95-084212
Replace existing solenoid valves
95-092829
Backleakage through check valve is responsible for accumulator level
96-102268
Minor oil leak at handwheel shaft to casting
96-105889
Troubleshoot problem with flow control valve
96-104040
Rework and replace swing arm / disc assembly as required
96-101080
Valve leaking by seat
96-102617
Valve sprayed from the diaphragm when closed from full open
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97-108132
Small diaphragm leak
95-081016
Atmospheric relief valve leaks past seat
95-090815
Spent fuel pool isolation valve has stripped spindle
96-102163
Rebuild relief valve and determine cause for failure
96-102955
Realign station service water pump
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96-104477
Stud broken off on primary plant ventilation exhaust filter unit
95-322110
Finger plate on diaphragm valve installed upside down
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Maintenance Alterations
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DCN NUMBER
DESCRIPTION
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10804
Replace 3/4-inch valves with 2-inch valves
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10234
Relocate personnel air lock door limit switch
10666
Revise purnps by adding retrofit kit
1
10701
Machine replacement shaft for valve for proper fit
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10702
Used an eccentric bushing in check valve swing arm to correct
condition
10787
Permanent addition of thermometer to replace temporary one
10657
Used jack bolts as an . alternative configuration to position axial
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alignment key on feedwater pump
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10949
Machine relief groove on the feedwater pump turbine rotor
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10863
Install foam deflector shield panels to the top of the clarifier surge
tank
9637
Replace 2 inch and smaller Edwards Univalves with commercial globe
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valves
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10738
Provide guidance for maintenance of components which experience
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service induced material defects
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10659
Reduce projection on 4 wall anchor bolts in pressurizer compartment
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9813
Replace existing outboard bearing on the SF cooling pump motors
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with insulated bearings
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10147
Substitute one type of fuse for another
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10790
Relocate valve and associated flanges due to flow induced vibration
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9876
Modify 2 sections of insulation on the reactor vessel
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11074
Install 2 tubing runs between containment penetrations to support
ILRT testing
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10631
Replace valve and section of nearby piping
10485
Determine inoperable motor space heater for containment HVAC fan
motor
10720
Remove the check valve and the strainer for the safety chillers and
reinstall them as shown
10721
Remove the check valve and the strainer for the safety chillers and
reinstall them as shown
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10142
Modify RHR pump motor upper and lower cover plates
10922
Modify pump interlock
10797
Install drain valves in radiation waste system
10174
Remove 2 feedwater valves since they are not needed
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10445
Remove internals of instrument air check valve
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10490
Valve out CCW flow transmitter and open bypass line
9013
Generically replace gate valves with ball valves
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Assessments and Audits
NUMBER
DESCRIPTION
1995
Engineering Self Assessment Report, September 1995
1996
Maintenance Function Self-Assessment
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10 CFR Part 21 Reports
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MKW Power Systems, " Voltage Adjust Potentiometers," dated May 14,1996
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Cooper Energy Services, " Starting Air Admission Valves (block and vent valves)," dated
July 9,1996
Consolidated Power Supply, " Indeterminate Material Shipped," dated June 20,1996
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Rosemount Nuclear instruments, " Conduit Seals Exhibit Short Conditions," dated
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September 20,1996
MOVATS, "3500 System Strain Module and Aux Contact Module Time Delay Testing,"
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dated September 26,1996
INFORMATION NOTICES
96-48 MOV Performance issues
96-61 Failure of a Main Steam Safety Valve to Reseat Caused by an improperly installed
Release Nut
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96-24 Preconditioning of Molded-Case Circuit Breakers Before Surveillance Testing
Operability Reviews
ONE-QTE-96112 Diesel Generator KVAR and load swings
ONE-QTE-97-272 RWST Suction Isolation Calculation Error
ONE-QTE-96-495 Abnormal discharge pressure of Containment Spray Pump
ONE-QTE-96-226 CCW Discharge Crosstie Velve i.eaks 4 PPM
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ONE-QTE-97-256 Slight Interference Torque Arm to Packing Gland
ONE-QTE-95-442 As-Left Seat Leak Test not Performed
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