ML20198S970
| ML20198S970 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/29/1998 |
| From: | Tapia J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Terry C TEXAS UTILITIES CO. |
| References | |
| NUDOCS 9901120065 | |
| Download: ML20198S970 (19) | |
Text
__
l..
pesay r 'k UNITED STATES
.y yy g
NUCLEAR REGULATORY COMMISSION -
q r,; e -
a f REGION IV 011 RYAiJ PLAZA (,nlVE. SUITE 400
%.'.5. '..
ARUNGTON TEXA5 73011-8064
..a 2 9 8 J
Mr. C. L. Terry TU Electric Senior, Vice President & Principal Nuclear Officer ATTN: Regulatory Affairs Department P.O. Box 1002 Glen Rose, Texas 76043
SUBJECT:
INSPECTION PLANNING REVIEW 1PR)- COMANCHE PEAK STEAM ELECTRIC STATION
- Dear Mr. Terry.
On December 2,1998, the NRC staff completed a unique inspection Planning Review (IPR) of the Comanche Peak Steam Electric Station, Units 1 and 2, reactor facility. The staff normally conducts Semlannual Plant Performance Reviews for all operating nuclear power plants to develop an integrated understanding of safety performance and adjust inspection resources.
However, due to the suspension of the Systematic Assessment of Licensee Performance i
process, we implemented an abbreviated inspection Planning Review for plant issues and to develop inspection plans. The IPR for Comanche Peak Steam Electric Station involved the participation of both the Reactor Projects and the Reactor Safety divisions in evaluating inspection results and safety performance trends for the period April 23 to October 28,1998.
Based upon this review, inspection resources have been prioritized and scheduled. No changes have been made to the inspection resources for your facility. contains an historical listing of plant issues, referred to as the Plant issues Matrix (PIM), that was considered during this IPR process to arrive at an integrated view of licensee performance trends. The PIM includes only items from inspection reports and other
. docketed correspondence between the NRC and TU Electric. The IPR may also have con'sidered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration. is a general description of the PIM table labels. This material will be placed in the
. NRC Public Document Room.
This letter also advises you of our planned inspection effort resulting from the Comanche Peak Steam Electric Station IPR. It is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Enclosure 3 details our inspection plan for Comanche Peak Steam Electnc Station over the next 8 months. The rationale or basis foi each inspection outside the core
~ inspection program is provided so that you are aware of the reason for emphasis in these program areas. Also included in Enclosure 3 are noninspection activities related to licensed 9901120065 981229 i
.ADOCK 0500044!'
O PDR
s TU Electric. operator examinations. Resident inspections are not listed because of their ongoing and continuous nature. We willinform you of any changes to the inspection plan.
if you have any questions, please contact me at (817) 860-8243.
Sincerel k
ph I. Tapia, ief Project Branch A Division of Reactor Projects Docket Nos. 50-445 50-446 License Nos. NPF-87 NPF-89
Enclosures:
- 1. Plant issues Matrix
- 2. General Description of PIM Table Labels
= 3. Inspection Plan oc w/ enclosures:
Mr. Roger D. Walker TU Electric Regulatory Affairs Manager P.O. Box 1002 Glen Rose, Texas 76043
' Juanita Ellis
~ President - CASE
'1426 South Polk Street Dallas, Texas 75224 L
TU Electric l~
3 Metro Center, Suite 810 Bethesda Licensing Bethesda, Maryland 20814 i
j George L. Edgar, Esq.
Morgan, Lewis & Bockius 1800 M. Street, NW Washington,'D.C. 20036
+
k
+
TU Electric
-3 J
G. R. Bynog, Program Manager /
' Chief Inspector Texas Department of Licensing & Regulation Boile~r Division P.O. Box 12157, Capitol Station
- Austin, Texas 78711 County Judge P.O. Box 851 Glen Rose, Texas 76043 Texas Radiation Control Program Director 1100 West 49th Street Austin, Texas 78756 John Howard, Director l Environmental and Natural Resources Policy Office of the Governor P.O. Box 12428 Austin, Texas 78711
4.
TU Electric 7 g._
E Mail report to T. Frye (TJF)
E-Mail report to D. Lange (DJL)
E-Mail report to NRR Event Tracking System (IPAS)
E Mail report to Document Control Desk (DOCDESK)
' E-Mail report to Richard Correia (RPC)
E-Mail report to Frank Talbot (FXT) 1bec to DCD (IE01)' > -
bec distrib. by RIV:
Regional Administrator Resident inspector (2)
DRP Director.
DRS-PSB Branch Chief (DRP/A)
MIS System Project Engineer (DRP/A)
RIV File Branch Chief (DRP/TSS)
Carol Gordon The Chairman (MS: 16-G-15)
Records Center, INPO
' Deputy Regional Administrator C. A. Hackney Commissioner Dieus B. Henderson, PAO Commissioner Diaz B. Murray, DRS/PSB Commissioner McGaffigan SRIs at all RIV sites Commissioner Merrifield W. D. Travers, EDO (MS:.17-G-21)
Associate Dir. for Projects, NRR
' Associate Dir, for insp., and Tech. Assmt, NRR SALP Program Manager, NRR/lLPB (2 copies)-
-J. Hannon, NRR Project Director (MS: 13-H-1)
T. Polich, NRR Project Manager (MS: 13-H-3) 120008 DOCUMENT NAME: G:\\DRPDIR\\lPR\\CP
' 1gelve copy of document, Indicate in boy"C" = Copy without enclosures "E" = Copy with enqlosures "N' = No copy RIV:C:DRP//n
-D:DRh('
DD:DRP
/D:DRP lM JITapia;dfh/kth ATHo%eY KEBrocierGin TPGwynn //
12/19 /98 M \\\\
12/*N/98 1 7 /98 12/$/98
-v y
. OFFICIAL RECORD COPY
____m_
=. -.
!~
l-TU Electric
-4 DEC 2 9 1998 E-Mail report to T. Frye (TJF)
E-Mail report to D. Lange (DJL)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
E Mail report to Richard Correia (RPC)
E-Mail report to Frank Talbot (FXT) bec to DCD (IE01) bec distrib. by RIV:
Regional Administrator Resident inspector (2)
DRP Director DRS-PSB Branch Chief (DRP/A)
MIS System Project Engineer (DRP/A)
RIV File Branch Chief (DRP/TSS) '
Carol Gordon The Chairman (MS: 16-G-15)
Records Center, INPO j
Deputy Regional Administrator C. A. Hackney Commissioner Dieus B. Henderson, PAO Commissioner Diaz B. Murray, DRS/PSB Commissioner McGaffigan SRis at all RIV sites Commissioner Merrifield.
W. D. Travers, EDO (MS: 17-G-21)
I Associate Dir. for Projects, NRR Associate Dir, for Insp., and Tech. Assmt, NRR SALP Program Manager, NRR/lLPB (2 copies)
J. Hannon, NRR Project Director (MS: 13-H-1)
T. Polich, NRR Project Manager (MS: 13-H-3)
I DOCUMENT NAME: G:\\DRPDIR\\lPR\\CP To receive copy of document, Indicate in bop *C' is Copy w6thout enclosures *E" = Copy with enqlosures "N" - No copy lRIV:C:DRP//n D:DRb[
DD:DRP
/D:DRP
/) -
l lJITapia:dfbdM ATHo%eV KEBrocknf5In TPGwynn W l
l1203 /98 N P 12/fQ98 1 7 /98 12f26/98 V
\\
OFFICIAL RECORD COPY
)
PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM DESCRIPTION CODE 09/12/98 NEG IR 98-06 LIC OPS 1A The licensee identified that excavation work was being conducted in the switchyard while simultaneously performing emergency diesel generator maintenance.
09/12/98 STR 1R 98-06 NRC OPS 1A 3A 3C Control room operators used good self-venfication techniques, were attentive to the control boards, 18 and effectively identified adverse trends through a review of operating logs, computer data, and strip chart traces. Operators responded weu to a leaking in-core thimble tube.
08/01/98 STR 1R 98-05 NRC OPS 1A 3C Operators continued to use self-verification and peer-checking as circumstances warranted and were attentive to the control boards. Operators dernonstrated a clear knowledge of limitations and immediate actions and demonstrated elevated awareness during increased main turbine blade vibration.
08/01/98 STR IR 98-05 NRC OPS 3C Operations continued to be characterized by conservative plant operation. This was demonstrated by the licensee decision to reduce Unit 2 generation when main turbine blade vibration increased but was stin below the administrative limit.
C3/26/98 POS IR 98-301 NRC OPS 3B 3A AII nine (six reactor operators and three senior operators) license applicants passed their license examinations. The applicants exhibited good oversight, peur checking and effective communications.
06/26/98 NEG IR 98-301 NRC OPS 3B The administrative topics and control room systems and facility walk-through test materials were inadequate for licensing examination administration as submitted.
06/20/98 STR 1R 98-04 NRC OPS 1A Operations continued to be characterized by conservative plant operation. For example, the licensee actively pursued a temporary modification to a condensate pump motor to increase secondary plant reliability and thereby reduce the potential consequences of a plant transient.
Operators consistently used self-verification and peer-checking as circumstances warranted and were attentive to the control boards.
05!09/98 NCV 1R 98-03 LIC OPS 1C 4B An inadequate procedure revision in conjunction with poor coordination resulted in a partialloss of reactor coolant system level indication while in reduced inventory. Temporary pressure gages were inadequately vented and placed in service at an inappropriate time. In the revision safety screen, the licensee incorrectly assumed that the change was administrative and that a safety evaluation was not necessary. The inadequate procedure was a violation of Technical Specification 6.8.1.
This is a non-cited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy.
05/09/98 POS IR 98-03 NRC OPS 3A 3B 3C During reduced inventory operations, operators were knowledgeable of system pump vortex and cavitation limits and criticallimits such as time to boil. Unit supervisors routinely quizzed reactor operators on these limits. Operators carefully monitored the reactor coolant system drain rate, frequently checking the redundant reactor vessel level indications for deviations.
05/09/98 NEG IR 98-03 NRC OPS 2A SC Licensee corrective actions have not been completely successful in resoMng level indication problems encountered during vacuum fill of the reactor coolant system. This has resulted in reduced operator confidence in midloop level instruments.
October 28,1998 1
COMANCHE PEAK
PLANT ISSUES MATRIX ENCLOSUREI DATE TYPE SOURCE ID SFA TEMPLATE ITEM DESCRIPTION CODE 05/09/98 POS IR 98-03 NRC OPS 3A Control room operators used good self-verihcation techniques, were attentive to the control boards, consistently used good communications with one exception, and used operator aids as appropriate.
03/28/98 POS IR 98-02 NRC OPS 3B The conduct of operations continued to be characterized by excellent operator performance during evolutions and transients. The recent plant shutdcwn using a new process was well implemented.
Inspectors observed close monitoring by the reactor operators and effective management by shift supervision.
02/02/98 VIO IR 98-01 NRC OPS 3C The licensee failed to document the heat related degradation of a safeguards sequencer, a St [y condition adverse to quality, on an operations notification and evaluation form, which is a violation of 10 CFR 50, Appendix B, Cnterion XVL 01/16/98 NCV IR 98-01 llc OPS 3A The licensee exceeded Technical Specification surveillance 4.3.1.1. interval when a licensed LER LER 2 98-001 operator neglected to perform the calorimetric for the nuclear instrument and nitrogen-16 detectors. The calorimetric was immediately performed and detectors were found within tolerance.
A review of computer data found detectors had been within tolerance since the last surveillance.
The operator was counseled. Human error and inattention to detail. The LER was issued on 02/13/98. This is a non-cited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy.
01/03/98 POS IR 97-23 NRC OPS 1A Operations was characterized by good command, control, and communications as observed in the reactor coolant system drain down and vacuum fill, the reactor startup from refueling, and the response to the failure of a nitrogen-16 detector channel 01/03/98 NCV IR 97-23 LlO OPS 1A A non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy, of Technical Specification 6.8.3 was identified when the alarm indicating that the south wide range gas monitor sample pump had stopped was acknowledged without compensatory actions being taken.
11/10/97 VIO IR 97-20 LIC OPS 1A Weak procedural guidance, poor communications, and a lack of understanding of the operation of SLIV LER 2 97-005 the personnel airlock doors resulted in a violation of Technical Specifcation 3.9.4, concerning the LER capability to ensure containment integrity during core alterations.
11/08/97 NCV IR 97-20 LIC OPS 1A 3B 5A A non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy, of Technical LER LER 2 97-003 Specification 3.9.5 was identified by the licensee when operators performed core a!!erations prior to establishing direct communications with the control room. The fuel handling supervisor directed personnel in the area to position lights in the vessel for core off load. It was determined that placing the light in the vessel was a core afteration and not a!! of the TS requic wents were in place. Self checking was determined to be less than adequate.
10/27/97 POS 1R 97-20 SELF OPS 18 2A Operations personnel response to the Unit 1 and Unit 2 trips were prompt, appropriate, and LER LER 2 97-002 characterized by excellent three-way communications and good command and control.
October 28,1998 2
COMANCHE PEAK
PLANTISSUES MATRIX ENCLOSUREI DATE TYPE SOURCE.
ID SFA TEMPLATE -
ITEM DESCRIPTION CODE.
10/25/97 VIO 1R 97-20 SELF OPS 18 in violation of 10 CFR Part 50 Appendix B, Criterion V, inadequate procedural guidance, SL IV complicated by the senior reactor operator's lack of understanding of the system's operation, led to inadvertent actuation of the low-temperature overpressure protection system during the Unit 2 cooldown.
10/11/97 POS IR 97-18 NRC OPS SA 4C The licensee identified and took prompt, conservative actions on two issues where the design assumptions had not been fuDy implemented. These issues indicate that the licensee continues to perform thorough reviews of plant systems and procedures as expected by their response to 10 CFR 50.54(f).
10/11/97 POS IR 97-18 NRC OPS SA 4C The licensee continued to pay close attention to the material condition of the plant. This was especiaHy significant ccuG&.y the increasing level of activity in preparation for the Unit 2 refueling outage. The licensee and took prompt corrective actions on two issues, outside the control room, which could have led to a reactor trip had the condition been left uncorrected.
10/11/97 POS IR 97-18 NRC OPS 1A 3A Overall, conduct of operations continued to be very good. The plant was operated in a safety
' conscious manner with appropriate supervisory and management oversight. With the exception of the BTRS leakage, good performance by operators was noted for severalissues.
10/02/97 NEG IR 97-18 SELF OPS 1C 3C 3B A vague procedure combined with an operating crew that did not fully review equipment status, lead to the contaminaton of several areas while flushing the boron thermal regeneration system. The event indicated a weakness in attention-to-detail and an over reliance on the procedure.
October 28,1998 3
COMANCHE PEAK
PLANT ISSUES MATRIX ENCLOSUREI DATE TYPE SOURCE ID SFA TEMPLATE ITEM DESCRIPTION CODE 09/12/98 POS IR 98-06 NRC MAINT 2A Plant materiai condition continued to be excellent. Few packing leaks were detected, with all leakage properly controlled by drip containments constructed in accordance with procedures and properly tracked.
09/12/98 POS IR 98-06 NRC MAINT 3A In-core thimble tube maintenance was planned and implemented well The licensee developed and successfully implemented plans to maintain dose ALARA. Clear and effective communications were observed.
09/12/98 POS IR 98-06 NRC MAINT 2A 28 3A Maintenance personnel adhered to proceoues, work orders, radiation work permits, and used good safety practices. Increased ownership of procedures and a re-emphasis of procedure adherence expectations were observed.
09/12/98 POS IR 98-06 NRC MAINT 2B The corrective maintenance backlog on the Unit 2 residual heat removal systems and the Unit 1 safety injection systems decreased notably since January 1998.
09/12/98 POS IR 98-06 NRC MAINT 2A The licensee's decision to replace the Unit 2 Train A hydrogen recombiner power supply as a whole, rather than conduct troubleshooting in place, was a good use of spare parts to minimize equipment unavailability.
08/01/98 POS IR 98-05 NRC MAINT 3A Maintenance activities were well conducted and in accordance with the work orders and instructbn procedures. Technicians were knowledgeable, demonstrated ownership, and were conscientious to leave work areas clean following the maintenance activity.
08/01/98 POS IR 98-05 NRC MAINT 2A 3A Plant material condition was particularty noteworthy. Equipment preservation was effective. Little exterior corrosion was noted, even on systems exposed to severe service and outside weather conditions. Pump oilers were clean and always maintained full, motor air filters were exceptionally clean, mechanical pump seals leaked the prescribed amount, valve packing teaks were minimal, and valve packing followers were assembled with care to not impact valve stema.
08/01/93 NCV 1R 98-05 LIC MAINT 3A While the unit was in Mode 4, a contract technician racked out the Train A source range detector IR 98-02 during a time when the Train B detector was out of service in violation of Technical Specifcations 6.8.1. This violation was determined to be non-cited consistent with Section Vll.B.1 of the NRC Enforcement Policy. This NCV closed unresolved item URI 50-445/9802-03, dated 3/21/98.
07/15/98 STR 1R 98-10 NRC MAINT 1C The licensee's program for assessing safety for removing equipment from service for maintenance was very good. The process ensured that combinations of equipment removed from service were either pre-analyzed or received a cafety evaluation from a risk expert prior to the start of the maintenance activity. The licensee had a strong program to monitor risk during planned outages, and had comprehensive procedures to e sure equipment needed to mitigate events were available.
07/15/98 NEG IR 98-10 NRC MAINT 3A The Maintenance Rule review panel made determinations of structure, system, or component function safety significance with a probabilistic risk analysis that had not been updated since 1992.
As a result, recent plant modifications that potentially impacted risk that were not modeled in the probabilistic risk assessment included new high temperature reactor coolant pump seals, a common instrument air compressor, and a swing inverter.
October 28,1998 4
COMANCHE PEAK
PLANT ISSUES MATRIX ENCLOSUREI DATE TYPE SOURCE ID SFA TEMPLATE ITEM DESCRIPTION CODE 07/15/98 NEG 1R 98-10 NRC MAINT SC The licensee's second periodic assessment regarding Maintenance Rule effectiveness had not been issued in a timely manner. Specifically, the report had not been approved and issued since completion of the assessment 5-1/2 months ago. Despite the lack of timeliness, the licensee had initiated appropriate corrective actions in response to identified issues.
07/15/98 VIO IR 98-10 NRC MAINT 3B The hcensee's program scoping, in general, was adequate ard met the intent of the Maintenance SL IV Rule. However, examples of failure to include in the program scope 13 applicable structures and the reactor rod control and indication function were identified as a violation of 10 CFR 50.65(b).
07/15/98 NEG IR 98-10 NRC MAINT 3A Licensee actions, in two instances, were untimely regarding historical assessment performance, which resulted in delayed placement of systems into Category (a)(1). After revising Component Cooling Water Function 01 on July 10,1997, and establishing Containment Isolation Function 04 on July 16,1997, the licensee performed a historical assessment and identified that the performance criteria had been exceeded. ONE forms were initiated on December 15,1997, and February 16, 1998, respectively, and the containment isolation and component cooling water systems were placed in Category (a)(1) on March 19 and March 20,1998, respectively.
07/15/98 VIO 1R 98-10 NRC MAINT 3B A violation of 10 CFR 50.65(a)(2) involved the licensee's inappropriate reliability performance SLIV criteria for certain functions (i.e., less than one functional failure) without establishing condition monitoring performance criteria for those functions.
07/15/98 POS IR 98-10 NRC MAINT 4C The licensee established conservative action level criteria for reliability and unavailabihty to allow corrective actions to be implemented prior to exceeding the established performance enteria. The team considered this approach, although not required by the haintenance Rule, to be indicative of an aggressive overall program to identify and correct plant problems at a very low threshold even for non-risk significant systems.
07/15/98 NCV IR 98-10 LlO MAINT 38 Pursuant to Section Vil.B.1 of the NRC Enforcement Policy, a non-cited violation of 10 CFR 50.65(a)(2) was identified regarding the failure to monitor unavailability hours from July 10,1996, to the third quarter 1997 for Feedwater System Functions 02 and 07; to the fourth quarter 1997 for Auxiliary Feedwater System Function 16 and Instrument Air System Function 01; and to the second quarter 1998 for Solid State Protection System Functions 06 and 07.
07/15/98 WK IR 98-10 NRC MAINT 4C A program weakness involved the licensee's use of plant level performance criteria for some functions to monitor equipment performance in lower operating modes. Plant level performance monitoring criteria would not be triggered by functional failures in these lower operating modes.
07/15/98 STR 1R 98-10 NRC MAINT SA The team concluded that the licensee's Maintenance Rule self-assessment process was comprehensive in nature and that it was effective in identifying areas for improvement. The team also determined that issues identified during this process were effectively prioritized and tracked to resolution.
07/15/98 POS IR 98-10 NRC MAINT 2A The team generally found that the visible external material condition of the structures, electrical equipment, and mechanical systems reviewed was very good.
October 28,1998 5
COMANCHE PEAK
PLANT ISSUES MATRIX ENCLOSUREI DATE TYPE SOURCE ID SFA TEMPLATE ITEM DESCRIPTION CODE 07/15/98 POS IR 98-10 NRC MAINT 3B With one exception, the Maintenance Rule review panel had property categonzed the safety significance of SSCs. The team found that, from a defense-in-depth perspective, the review panoi had inappropriately categorized the containment structure as non-risk significant.
07/15/98 NCV IR 98-10 LIC MAINT 3B Pursuant to Section Vll.B.1 of the NRC Enforcement Policy, a non-cited violation of 10 CFR 50.65(b) was identified fo-failure to include 23 functions associated with 18 systems in the program scope.
07/15/98 STR 1R 98-10 NRC MAINT 3C The licensee had developed an overall strong Maintenance Rule program that was attributed to very good management focus and attention.
06/20/98 STR IR 98-04 NRC MAINT 2A Plant material condition continued to be excellent. This was evident during plant walkdowns, a review of equipment reliability, and during ongoing reviews of the licensee's problem identification process. Few valve packing and equipment oilleaks were noted. Very few temporary hoses and drip-catch containment assemblies were needed. The Icensee actively identified and corrected material condition deficiencies in a timely manner.
05/09/98 POS IR 98-03 NRC MAINT 3A Overall, maintenance personnel adhered to procedures, work orders, and radiation work permits.
Good foreign material control was observed and equipment cleanliness was maintained.
Maintenance personnel used good safety practices.
05/09/98 POS IR 98-03 NRC MAINT SA SC The licensee's investigation and corrective actions following a reactor inp breaker's failure to close during testing were appropriate.
05/09/98 NEG IR 98-03 NRC MAINT 1A 2B 3B Overall, the Unit 1 refueling outage was well coordinated. However, several coordination problems were notable. An error associated with the tensioning of reactor vessel studs resulted in an additional 1.8 rem to the stud tensioning crew. A partialloss of reactor vessel level indcation occurred while the reactor coolant system was in reduced inventory, partially because of poor coordination and configuration management. Poor coordination of reactor coolant pump maintenance resulted in a spill of reactor coolant. And poor coordination of containment closeout activities resulted in a sentor reactor operator cleaning the containment sumps following repairs.
03/28/98 POS 1R 98-02 NRC MAINT 38 The licensee thoroughly addressed the fuel handling errors during the previous outage. Corrective actions included: defining each position's responsibilities, improving communications, and improving fuel handiing equipment performance.
03/21/98 VIO IR 98-02 SELF MAINT 2B The administrative procedure for the control of switchyard activities was not adequate to prevent the SLIV inadvertent actuation of safety systems during a normal shutdown for refueling and resulted in an inadvertent boration. This was a 10 CFR Part 50, Appendix B, Criterion V violation.
03/21/98 NCV IR 98-02 LIC MAINT 3A While performing reactor trip breaker response time testing, technicians failed to follow procedure in that the wrong logic selector switch was repositioned during the test and the breaker failed to trip when tested. The licensee stopped the test and corrected the mistake. This was a Technical Specificatioq 6.8.1 violation and determined to be a non-cited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy.
October 28,1998 6
COMANCHE PEAK
PLANT ISSUES MATRIX ENCLOSUREI DATE TYPE SOURCE ID SFA TEMPLATE ITEM DESCRIPTION CODE 02/17/98 VIO IR 98-02 LIC MAINT 3C The licensee exceeded the procedural limit for hoist pretension during new fuel receipt. The SLIV licensee's investigation revealed that this problem involved long standing work control problems; however, the closed defciency resolution did not reflect any of the identif ed issues. This was a Technical Specifcation 6.8.1 violation for failure to follow procedures.
02/14/98 POS 1R 98-01 NRC MA!NT 3A The licensee's performance of surveillances, preventive maintenance, and repairs was characterized by conservative decision-making and professicoafism. Inspectors observed the performance of surveillances, preventive maintenance and repair work orders.
01/15/98 NCV IR 98-01 LIC MAINT 3A Maintenance workers found a motor pinion key in the residual heat removal pump suction valve had not been staked, contrary to procedure requirements, in violation of Technical Specification 6.8.1.
This condition had existed since the valve was last refurbished in March of 1996. Because the pinion key was in place, tne valve was considered operable. The licensee staked the pinion key before retuming the valve to service. This failure to follow procedure was determined to be a non-cited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy.
01/10/98 NEG IR 98-01 NRC MAINT SC After identifying that feedwater isolation valves tend to develop a nitrogen leak following stroking, LER LER 198-001 the system engineer requested a note be placed in the standard surveillance work order to require operators to monitor nitrogen pressure after stroking feedwater isolation vatves. The licensee failed to revise the planned and printed surveillance work order to include this requirement, and was forced to enter Technical Specification 3.0.3 when two feedwater isolation valves were declared inoperable due to inadequate nitrogen pressure after stroking. Failure to incorporate guidance to address a known potential vulnerability.
01/03/98 POS IR 97-23 NRC MAINT SC The licensee's troubleshooting efforts regarding the failure of the Unit 1 safety injection sequencer were well-controlled, and included thorough management involvement.
01/03/98 POS IR 97-23 NRC MAINT 2A Material condition continued to be excell;rit. and the licensee actively identified and corrected material condition deficiencies in a timely manner.
11/22/97 POS 1R 97-20 NRC MAINT 1B The licensee's retrieva! of the damaged fuel assembly was performed in a deliberate and professional manner, the prejob briefing was thorough, and good radiological. foreign material and personnel safety practices were observed.
11/22/97 NCV 1R 97-20 LIC MAINT 4A A non-cited violation consistent with Section Vll.B.1 of the NRC Enforcement Pohey, of Techncal IR 97-17 Specification 6.8.1 was identified when maintenance workers modified bushings in as many as 79 valve actuators without review and documentation as required by procedure. This closed unresolved item 50-445;446/9717-03.
11/22/97 POS IR 97-20 NRC MAINT 3A The licensee's performance of observed surveillances was well-controlled and professional, prejob briefings were thorough, and communications were excellent.
11/22/97 VIO IR 97-20 LIC MAINT SC in violation of 10 CFR 50, Appendix B, Criterion XVI, the licensee failed to repair all the structural SL IV LER 2 97-004 gaps in the Unit 2 emergency core cooling sumps that had been identified in 1994.
LER October 28,1998 7
COMANCHE PEAK
PLANT ISSUES MATRIX ENCLOSURES DATE TYPE SOURCE ID SFA TEMPLATE ITEM DESCRIPTION CODE
-11/17/97 NEG IR 98-01 NRC MAINT 3C During a pre-job briehng a maintenance supervisor added to the scope of work without revising the work order instructions as required by procedure. Although this work was on non-safety equipment, a quahty-related procefure was used to perform this work. Weak procedure in that it permitted broad interpretatens of the definition of secpe change.
11/07/91 POS IR 97-22 NRC MAINT 3B Performance of inservice inspection examinations were contracted out, but were performed by nondestructive examination examiners whose certifications were reviewed and approved by the licensee. Inservice inspection supervisor and site-Level lll examiner exhibited high degree of competence and knowledge of commitments.
11/07/97 POS IR 97-22 NRC MAINT 28 3C Inservice inspection procedures contained adequate detail and instructions to perform the applicable nondestructive examinations, and were consistent with the requirements of the American Society of Mechanical Engineers Code.
11/07/97 POS 1R 97-22 NRC MAINT 3A 33 3C Nondestructive examinations involving the safety injection system were performed in a thorough manner. Examiners were knowledgeable of their assigned tasks.
11/07/97 POS IR 97-22 NRC MAINT 28 3A inservice inspection activities were performed in a well organized and controlled manner, with appropriate supporting documentation.
10/27/97 NEG IR 97-20 SELF MAINT 2B 3C Poor control of work activities in the switchyard arid personnel error resulted in an automatic trip of LER LER 197-009 Unit 1 reactor from 100 percent power.
10/11/97 VIO IR 97-18 NRC MAINT 4C While the standardization of sensors conducted prior to the surveillance testing of the hydrogen SLIV recombiner did not constitute preconditioning, the activity was not irkluded in the procedures and was a violation of 10 CFR 50, Appendix B, Criterion V for procedure adequacy. This lack of procedural direction lead to inconsistent performance.
October 28,1998 8
COMANCHE PEAK
PLANT ISSUES MATRIX ENCLOSUREI DATE TYPE SOURCE ID SFA TEMPLATE ITEM DESCRIPTION CODE 09/12/98 STR IR 98-06 NRC ENG 4B 4C The system health process was objective and rigorous and was considered a program strength.
09/12/98 POS 1R 98-06 NRC ENG SB A thorough and intrusive independent Safety Evaluation Group review of an NRC event notifcation LER LER 2-98-006 resulted in the identifcation of an ambiguous hydrogen recombiner surveillance procedure step.
Following a more thorough review of past surveillance test results, the licensee declared the Units 1 and 2, Train A hydrogen recombiners inoperable.
09/12/98 NCV IR 98-06 LIC ENG 4B 5A The hcensee's NRC Genere Letter 96-01 review was extensive and thorough and identifgx1 over POS 1R 98-01 SC 500 safety-related contacts that had either not been tested or were not tested adequately. These LER LER 1-97-004 failures to test were violations of approximately 10 different Technical Specifications. Inadequate lockout relay testing issues were identified in September 1995 but were not reported until March 1998 as part of the licensee's NRC Generic Letter 96-01 review. Corrective actions for the Unit 2 lockout relay testing issue did not meet the licensees commitment to complete their review and corrsctive actions by the end of the Unit 1 refueling outage in the Spring of 1998. This is a non-cited violation consistent with Section Vil.B.1 of the NRC Enforcement Policy.
09/12/98 POS IR 98-06 NRC ENG 4B System engineering support was evident in most aspects of plant operation and maintenance.
Engineering products were of high quality and demonstrated a questioning attitude.
08/01/98 POS IR 98-05 NRC ENG 4B System engineering was proactive in developing and communicating conservative recommendations to support operating Unit 2 with increased main turbine blade vibration.
C3/20/98 POS IR 98-04 NRC ENG 4B A temporary modification package to provide attemate cooling the a condensate pump motor lower bearing was thorough and detailed. Specific components, in:tallation, and testing instructions were included in the package. The technical screen and impact reviews were appropnate.
05/09/98 VIO IR 98-03 NRC ENG 4A 48 A violation of 10 CFR 50.59 was identified for changes to a facility operating procedure as described SLIV IR 96-16 in the Final Safety Analysis Report which were found to involve an unreviewed safety question. The unreviewed safety question was introduced by adding steps to the procedure and reducing the time assumed to perform the steps. These changes increased the probabihty of occurrence of a malfunction of equipment important to safety, namely the increased probability of gas binding emergency core cooling system pumps, due to the increased time required to complete switchover.
The licensee inappropriately concluded in a safety evaluation performed to evaluate the changes that no unreviewed safety question existed. This closed unresolved item 50-445;446/9616-06.
05/09/98 NEG IR 98-03 LIC ENG 4B The joint engineering team inappropriately used a maintenance troubleshooting procedure intended NCV for electronic equipment to install temporary pressure gages for attemate reactor vessel level indication. In addition, an engineering supervisor approved the maintenance troubleshooting plan contrary to the procedure recommendations. The licensee failed to adequately evaluate the deleterious affect these temporary pressure gages could have on reactor vessel level instrumentation. This contributed to a partialloss of levelinstrumentation while the reactor coolant system was in reduced invento y. This failure to implement Maintenance Department Administrative Procedure MDA-111 was a violation of Technical Specification 6.8.1. This is a non-cited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy.
October 28,1998 9
COMANCHE PEAK
PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM CESCRIPTION CODE 05/09/98 POS IR 98-03 NRC ENG 4A Design modifications were clear and straight forward. Safety evaluations were complete and the engineering review was consistent with the plant design and licensing bases.
05/09/98 NCV IR 98-03 LIC ENG SA A non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy, was identified, POS LER 196-009 reported in a licensee event report, and corrected by the licensee associated with switchgear LER breaker cubicles being placed in a seismica!!y unanalyzed condition by placing breakers in the
" remove" position.
05/09/98 VIO 1R 98-03 NRC ENG 4A 4B Four examples of a violation of 10 CFR, Part 50, Appendix B, Criterion lit were identif ed during the SLIV LER 197-002 LIC resolution of an unresolved item conceming discrepancies between the design bases and LER 1R 96-16 emergency procedure for switchover of the emergency core cooling system pumps from injection to rectreulation. This closed unresolved item 50-445:446/9616-06.
03/28/98 VIO IR 98-02 NRC ENG 4B The licensee failed to consider the effect significantly increased starting frequencies of the safety SLIV injection pumps had on their equipment qualification design bases in their corrective actions. The equipment qualificatic,n design bases for the pumps assumed two start cycles per month (960 total) over the 40 year life of the plant. The inspectors estimated that during Unit 1 Cycle 6, each SI pump was started about 560 times. This was a 10 CFR, Part 50, Appendix B, Criterion XVI violation for inadequate corrective actions.
01/0T98 NCV IR 97-23 LIC ENG 3A A non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy, of Technical Specification 6.8.1 occurred when the licensee closed Operations Notification and Evaluation Form 97-787, documenting the Unit 1 Component Cooling Water Pump 1-02 failure, without fully implementing the corrective actions as required by procedure.
01/03/98 POS IR 97-23 NRC ENG 4B Engineering provided good t:upport in the startup of the Unit 2 feedwater heater drain tank pumps, and was active in addressing equipment and system reliability issues.
11/22/97 NEG 1R 97-20 NRC ENG SB The inspectors found that the licensee's evaluation of an issue concerning control room pressurization surveillance testing was weak in that it failed to encompass all potential vulnerabilities.
10/02/97 POS IR 97-18 LIC ENG 4A SA SB The licensee identified that two throttle valves in ea:h unit may have minimum gap openings which LER LER 197-008 are smaller than the mesh on the emergency core cooling system sumps. The licer see had previously evaluated the industry information concerning the throttle valves but the original evaluation did not consider the disk guide rings and failed to recognize that the minimum gap between the guide rings and the valve body could be sma!!er than the disk to seat gap.
October 28,1998 10 COMANCHE PEAK
_P_LANT ISSUES MATRIX ENCLOSUREI DATE TYPE SOURCE ID SFA TFMPLATE ITEM DESCRIPTION CODE 08/01/98 STR IR 98 05 NRC PS 3C Security, radiation protection, and chemistry continued their high level of performance. Security personnel were knowledgeable, alert, and attentive to their posts, and responded appropriately to issues. The plant continued to be very clean radiologically, and was found to be appropriately surveyed and posted. Radiation work permit requirements were known by workers. The Chemistry department continued to aggressively pursue and restore plant chemistry to very high standards.
06/19/98 STR 1R 98-13 NRC PS 1C Performance in the physical security and access authorization areas was excellent. The alarm stations were redundant and well protected. A good radio and telephone communication systems were maintained. Assessment aids provided a high quality and complete assessment of the perimeter detection zones. Changes to security plans were properly implemented in accordance with 10 CFR 50.54(p). A very good securly event reporting program was in place. Background investigation screening files were complete and thorough. Senior management support for the secunty organization was very good as demonstrated by ongoing support for improved equipment and facilities. Audits of the security, access authorization, and fitness-for-duty programs were effective, thorough, intrusive, and performance based.
05/09/98 STR 1R 98-03 NRC PS 2A 1C The licensee continued to minimize the amount of temporary, radiological drip containments.
Excellent radiological support of maintenance activities in the containmen' building during the planned Unit 1 refueling outage was noted. The licensee continued to closely control water chemistry and take aggressive actions to correct any readings that were outside the prescribed guidelines.
04/13/98 VIO IR 98-03 NRC PS SA SC The licensee failed to identify and correct conditions adverse to quality involving the Unit 1 SLIV uninterruptible power supp!y rooms fire doors in that the ability of the door to close wr 3 impaired from March 1997 to April 1998 and that the licensee failed to identify that the inability of the fires doors to remain open impaired the operation of the tomado doors. This was a violation of 10 CFR 50, Appendix B, Criterion XVI.
03/27/98 POS IR 98-11 NRC PS 3A Excellent performance was noted in the areas of alarm stations, communications, protected area detection aids, security event logs, assessment aids, vehicle access control, and the security organization.
03/06/98 VIO IR 98-02 NRC PS 1C The licensee's removal of locks from the containment personnel airlock doors was a violation of SLIV Technical Specification 6.12.2. Upon notification, the locks were immediately replaced. The locks were absent for 3 days.
02/27/98 NEG IR t'l-02 NRC PS 4A Unsecured bookshelves could have blocked the access hallway to the technical support center during a seismic event and was a winerabihty which the licensee had not identified.
02/12/98 NCV IR 98-11 LIC PS 3A A non-cited violation, consistent with Section VII.B.1 of the NRC Enforcement Policy, was identified LER LER 198-002 for failing to adequately search personnel for explosives and incendiary devices. This was a violation of the licensee's Physical Security Plan.
October 28,1998 11 COMANCHE PEAK
PLANT ISSUES MATRIX-ENCLOSUREI-DATE
' TYPE SOURCE ID SFA TEMPLATE ITEM DESCRIPTION CODE 01/03/98 POS IR 97-23 NRC PS 3A Radiation protection technicians were responsive to inspector's concerns regarding fixed contamination, were knowledgeable of the radiological requirements, and took prompt and appropriate actions.
11/08/97 NCV IR 97-20 LIC PS 1C A non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy, of Technical Specification 6.12.2 was ider,tified when a radiation protection technician failed to maintain constant physical control of the radiation area key.
10/31/97 POS IR 97-21 NRC PS 1C Ughting system along perimeter barrier and associated isolation zones were effective in ensuring visualinspection of the protected area.
10/31/97 POS IR 97-21 NRC PS 3B 1C Control of vehicles, personnel, and packages was effective and eff~cient.
10/31/97 NCV IR 97-21 LlO PS SA 1C A non-cited violation, consistent with Section Vll B.1 of the NRC Enforcement Poicy, was identified involving the failure to temporarily deactivate access authorization of personnel with only occasional access to the plant if they are not on site to be immediately tested. Cause of violation was problems with the computer commands for deactivation of access authorization. Corrective actions were in place and no recurrences of this nature were identified after June 1997.
10/31/97 NCV IR 97-21 LIC PS 3C A non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy, was identified involving the failure to inspect all vital area doors every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Location of vital doors 227 and 527 were such that passage through two other vital areas within the power block were required.
Corrective actions included training and briefing of security officers.
10/31/97 NCV IR 97-21 LIC PS 1C 3B A non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy, was identified involving the failure to property requalify security officers on the semiautomatic pistol. Appendix D, Stage 2, requires each officer to fire 3 rounds from a kneeling, strong-hand supported position.
Cause of violation was the assumption by the range sergeant of an option to fire three rounds from a standing position. Immediate corrective action was requalifying of security officers.
October 28,1998 12 COMANCHE PEAK
ENCt.OSURE 2 GENERAL DESCRIPTION OF PIM TABLE LABELS Actual date of an event or significant issue for those items that have a clear date of occurrence, the date the source of the information was issued (such as the LER date), or, for inspection reports, the last date of the inspection period.
Type The categorization of the issue - see the Type Item Code table.
SFA SALP Functional Area Codes: OPS for Operations; MAINT for Maintenance; ENG for Engineering; and PS for Plant Support.
Sorrres The document that contains the issue information: IR for NRC Inspection Report or LER for Licensee Event Report.
ID Identification of who disemered issue: N for NRC; L for Licensee; or S for Self Identifying (events).
Issue Description Details of the issue from the LER text or from the IR Executive Summaries.
Codes Template Codes - see table.
TEMPLATE CODES TVPE ITEM CODES 1
Operational Performance: A - Normal Operations; B - Operations During Transients; EA Enforcement Action Letter with Civil Penalty and C - Programs and Processes ED Enforcement Discretion - No Civil Penalty 2
Material Condition: A - Equipment Condition or B - Programs and Processes STR Strength - Overall Strong Licensee Performance 3
Human Performance: A - Work Performance; B - Knowledge, Skills, and Abilities /
WK Weakness - Overall Weak Licensee Performance Training; C - Work Environment EEI*
Escalated Enforcement Item-Waiting Final NRC Action 4
Engineering / Design: A - Design; B - Engineering Support: C - Programs and Processes VIO Violation Level I, II, III, or IV 5
Problem Identification and Resolution: A - Identification; B - Analysis; and C -
NCV Non-Cited VioPation Resolution DEV Deiiation Irom Licensee Commitment to NRC
'O M POS Positive - Individual Good Inspection Finding Eels are apparent siolations of NRC requirements that are being considered for escalated enforcement action in accordance with the " General Statement of Policy and NEG Negative - Indisidual Poor Inspection Finding Procedure for NRC Enforcement Action"(Enforcement Policy), NUREG-1600.
LER Licensee Event Report to the NRC Ilowever, the NRC has not reached its final enforcement decision on the issues identified by the Eels and the PIM entries may be nodified when the final decisions are made.
URI "
Unresolsed Item from inspection Report Before the NRC makes its enforcement decision, the licensee will be provided uith an opportunity to either (1) respond to the apparent violation or (2) request a predecisional Licensing Licensing Issue from NRR enforcement conference.
MISC Miscellantaus - Emergency Preparedness Findirg (EP),
Declared Emergency, Nonconformance Issue, etc.
URIs are unresolved items about which more information is required to determine w hether the issue in question is an acceptable item, a destation, a nonconformance, or a violation. Ilowever, the NRC has not reached its final conclusions on the issues, and the PIM entries may be modified when the final conclusions are made.
ENCLOSURE 3 COMANCHE PEAK STEAM ELECTRIC STATION INSPECTION PLAN IP - Inspection Procedure T1 - Temporary Instruction Cora inspection - Minimum NRC Inspection Program (mandatory all plants)
RI-Additionalinspection resources related to potential problems identified d ring perfc9 nance assessments NI-Noninspection activity INSPECTION TITLE /
NtJMBER OF DATES TYPE OF INSPECTION / COMMENTS PROGRAM AREA INSFECTORS,
IP 82701 Operatiorial Status of the EP Procram 1
01/18-22/99 Core Inspection IP 84750 Enviremental Monitoring 1
01/25-29/99 Core inspection IP 84750 Radioactive Waste Treatment 1
02/08-12/99 Core inspection i
IP 71001 Licensed Operator Requalification 2
72/08-12/99 Core inspection Program Evaluation i
IP 86750 Solid Rad. Waste Management &
1 02/22-26/99 Core inspection Transportation of Rad. Material IP 40500 Effectiveness of Licensee Controls in 3
03'29/99-04/02/99 Core inspection Identifying. Resolving, and Preventing Problems IP 83750 Occupational Radiation Exposure 1
04/0549/99 Core inspection IP 37001 10 CFR 50.59 Safety Eval. Program 6
05/10-28/99 Core inspection IP 64704 Fire Protection Program IP 93809 Safety System Engineering inspection IP 81700 Physical Security Program 1
05/24-28/99 Operational Safeguards Response Evaluation NI Examination Preparation 1
05/31/99-06/04/99 NA N1 Initial Examinations 2
06/21-25/99 NA IP 82301 Evaluation of Exercise 4
07/19-23/99 Core inspection
-