IR 05000445/2017001
| ML17129A626 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/09/2017 |
| From: | Haire M S NRC/RGN-IV/DRP/RPB-A |
| To: | Peters K TEX Operations Company |
| MARK HAIRE | |
| References | |
| IR 2017001 | |
| Download: ML17129A626 (38) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511 May 9, 2017 Mr. Ken Peters, Senior Vice President and Chief Nuclear Officer TEX Operations Company LLC P.O. Box 1002 Glen Rose, TX 76043
SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000445/201 7001 and 05000446/
201700 1
Dear Mr. Peters:
On March 31, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Comanche Peak Nuclear Power Plant, Units 1 and 2. On March 27, 2017, the NRC inspectors discussed the results of this inspection with Mr. Tom McCool, Site Vice President, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented four findings of very low safety significance (Green) in this report. All of these findings involved violations of NRC requirements.
Further, inspectors documented two licensee-identified violations which were determined to be of very low safety significance in this report. The NRC is treating these violations as non
-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555
-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555
-0001; and the NRC resident inspector at the Comanche Peak Nuclear Power Plant.. If you disagree with a cross
-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the Comanche Peak Nuclear Power Plant. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC's Public Document Room or the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading
-rm/adams.html. To the extent possible, your response, if any, should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.
Sincerely,/RA/ Mark S. Haire, Chief Project Branch A Division of Reactor Projects Docket Nos. 05000445, 05000446 License Nos. NPF
-87 and NPF
-89
Enclosure:
Inspection Report 05000445/2017001 and 05000446/2017001 w/
Attachment:
Supplemental Information
SUNSI Review By: ADAMS Yes No Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE SRI:DRP/A RI:DRP/A SPE:DRP/A BC:EB1 BC:EB2 BC:OB BC:PSB2 NAME JJosey RKumana RAlexander TFarnholtz GWerner VGaddy HGepford SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ DATE 5/03/17 5/02/17 5/02/17 5/02/17 5/02/17 5/02/17 5/04/17 OFFICE TL-IPAT BC:DRP/A NAME THipschman MHaire SIGNATURE /RA/ /RA/ DATE 5/04/17 5/9/17 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000445, 05000446 License: NPF-87, NPF-89 Report: 05000445/2017001 and 05000446/2017001 Licensee: TEX Operations Company, LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: 6322 N. FM
-56, Glen Rose, Texas Dates: January 1 through March 31, 2017 Inspectors:
J. Josey, Senior Resident Inspector R. Kumana, Resident Inspector J. Braisted, Reactor Inspector C. Smith, Reactor Inspector W. Cullum, Reactor Inspector E. Uribe, Reactor Inspector G. Pick, Senior Reactor Inspector S. Hedger, E mergency P reparednes s Approved By: Mark S. Haire Chief, Project Branch A Division of Reactor Projects
SUMMARY
IR 05000445/2017001 and 05000446/2017001
- 01/01/2017
-3/31/2017; Comanche Peak Nuclear Power Plant
- Equipment Alignment; Heat Sink Performance; Problem Identification and Resolution
The inspection activities described in this report were performed between January 1 and March 31, 2017, by the resident inspectors on site and inspectors from the NRC's Region IV office.
Four findings of very low safety significance (Green) are documented in this report. All of these findings involved violations of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, "Significance Determination Process." Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, "Aspects within the Cross-Cutting Areas." Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG
-1649, "Reactor Oversight Process."
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a non-cited violation of 10 CFR 50.54(hh)(2), "Conditions of License s," involving the licensee's failure to maintain available equipment needed to implement mitigating strategies to provide makeup to steam generators following loss of large areas of the plant due to explosions or fire. Specifically, the licensee failed to maintain available a portable alternate mitigation equipment pump related to the steam generator makeup strategy. As an immediate corrective action the licensee put temporary heaters in place for the alternate mitigation equipment pump to ensure the equipment was stored at temperatures greater than 32 degrees Fahrenheit pending further evaluation. The licensee entered this issue into their corrective action program as Condition Report CR
-2016-010832. The failure to maintain all necessary equipment available to implement mitigating strategies as required by regulations and conditions of the operating license was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix L, "B.5.b Significance Determination Process," dated December 24, 2009, the inspectors determined the finding was of very low safety significance (Green) because it resulted in an unrecoverable unavailability of an individual mitigating strategy but did not result in multiple unavailable mitigating strategies, or loss of all on-site, self-powered, portable pumping capability. The inspectors did no t assign a cross-cutting aspect because the performance deficiency was not reflective of present performance. (Section 1R04)
- Green.
The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to properly evaluate heat loads on the control room air conditioning system. Specifically, the licensee used a non-conservative assumption for the number of persons in the control room envelope when calculating the required capacity of the system. The licensee had assumed there would only be six personnel in the technical support center (which is included in the control room envelope) during a design basis event. However, the emergency plan nominally staffed the technical support center with 25 station personnel, and an additional five NRC personnel.
The licensee implemented immediate corrective actions by entering the issues into the corrective action program for resolution and performed an operability determination for the identified degraded condition.
The licensee entered this issue into their corrective action program as Condition Report CR-2017-000744. The failure to evaluate heat loads to determine the required system capacity was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, "Initial Characterization of Findings," dated October 7, 2016, and Inspection Manual Chapter 0609, Appendix A, "Significance Determination Process for Findings At-Power," Exhibit 2, "Mitigating Systems Screening Questions," the inspectors determined the finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality, (2) did not represent a loss of system and/or function, (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time, and (4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with the licensee's maintenance rule program.
The inspectors determined that no cross-cutting aspect was assigned because the performance deficiency was not reflective of present performance. (Section 1R04)
- Green.
The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," involving the failure to use the design fouling factor for the component cooling water heat exchanger in a design basis calculation evaluating a tornado missile strike of station service water system piping.
The licensee implemented immediate corrective actions by entering the issues into the corrective action program for resolution and performed an operability determination for the identified degraded conditions.
The licensee entered this issue into their corrective action program as Issue Report
IR-2017-001465. The inspectors determined that the failure to use the design fouling factor for the component cooling water heat exchanger in the tornado missile analysis of the station service water system discharge piping was a performance deficiency. This finding was more-than-minor because it was associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the use of a non-conservative heat exchanger fouling factor in a design basis accident analysis resulted in a more restrictive temperature limit (i.e., less than the technical specification allowed value) of the safe shutdown impoundment. In accordance with Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," dated June 19, 2012, Exhibit 2, "Mitigating Systems Screening Questions," the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that (1) did not represent a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of non-technical specification equipment; and (4) did not screen as potentially risk-significant due to seismic, flooding, or severe weather. The inspectors determined that this finding did not have a cross-cutting aspect because the most significant contributor to the performance deficiency did not reflect current licensee performance. Specifically, the licensee performed the calculation in 1988, therefore, the performance deficiency occurred outside of the nominal three-year period for "present performance." (Section 1R07)
- Green.
The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," associated with the licensee's failure to take timely corrective actions for a previously identified condition adverse to quality. Specifically, the licensee failed to verify the adequacy of the design of the Unit 1 120 VAC vital bus inverter 1PC1 with respect to use of alternate AC power to the inverter. The 120 VAC calculation did not properly account for low voltage when the buses are supplied from their alternate source. This issue does not represent an immediate safety concern because, following the inspectors identification, the licensee performed an operability evaluation which established a reasonable expectation of operability.
The licensee implemented immediate corrective actions by entering the issues into the corrective action program for resolution and performed an operability determination for the identified degraded conditions.
The licensee entered this issue into their corrective action program as CR
-2017-001296. The licensee's failure to take timely and adequate corrective actions to correct a condition adverse to quality was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to correct the low voltage susceptibility resulted in delayed restoration of a bus following the failure of the swing inverter to sync. Using Inspection Manual Chapter 0609, Attachment 04, "Initial Characterization of Findings," dated October 7, 2016, and Inspection Manual Chapter 0609, Appendix A, "Significance Determination Process for Findings At-Power," Exhibit 2, "Mitigating Systems Screening Questions," the inspectors determined the finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality, (2) did not represent a loss of system and/or function, (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time, and (4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with the licensee's maintenance rule program. The finding has a human performance cross-cutting aspect associated with resources, in that, the licensee failed to ensure that resources were adequate to support nuclear safety [H.1].
(Section 4 OA2)
Licensee-Identified Violations
Violations of very low safety significance that were identified by the licensee have been reviewed by the inspectors.
Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. These violations and associated corrective action tracking numbers are listed in Section 4OA7 of this report.
PLANT STATUS
Unit 1 began the inspection period at approximately 100 percent power and operated at that power level for the entire inspection period.
Unit 2 began the inspection period at approximately 100 percent power. On March 18, 2017, Unit 2 reduced power to 45% due to a steam generator chemistry issue. Unit 2 returned to full power on March 19, 2017. On March 30, 2017, Unit 2 lowered power to 98.5 percent due to a reactor coolant boron issue, and concurrent ly the unit began coast down and operated at that power level for the remainder of this inspection period.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1 R 01 Adverse Weather Protection (71111.01)
.1 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
On February 27, 2017, the inspectors completed an inspection of the station's readiness for impending adverse weather conditions involving severe thunderstorms in the area. The inspectors reviewed plant design features
, the licensee's procedures to respond to tornado es and high winds, and the licensee's implementation of these procedures.
The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant
.
These activities constitute d one sample of readiness for impending adverse weather condition s , as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1 R 04 Equipment Alignment (71111.04)
.1 Partial Walk
-Down
a. Inspection Scope
The inspectors performed partial system walk
-downs of the following risk
-significant systems: February 8, 2017, Unit 1, train A 118 VAC with inverter 1PC1 out of service February 17, 2017, Unit 1, coolant charging pump 1
-02 while coolant charging pump 1-01 was out of service with a flange leak February 28, 2017, Unit 2, XST2 transformer during XST1A transformer modificati on March 7, 2017, Unit 1 and Unit 2, alternate mitigation equipment The inspectors reviewed the licensee's procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration
.
These activities constitute d four partial system walk
-down samples as defined i n Inspection Procedure 71111.04.
c. Findings
Introduction.
The inspectors identified a Green
, non-cited violation of 10 CFR 50.54(hh)(2), "Conditions of License s," involving the licensee's failure to maintain available equipment needed to implement mitigating strategies to provide makeup to steam generators following loss of large areas of the plant due to explosions or fire. Specifically, the licensee failed to maintain available a portable alternate mitigation equipment pump related to the steam generator makeup strategy.
Description.
During a cold weather walk
-down of the station
's alternate mitigation equipment, the inspectors identified that the alternate mitigation equipment pump was stored in an unheated building. This mitigating strategies equipment is associated with 10 CFR 50.54(hh)(2), which requires the licensee to implement mitigating strategies needed to maintain or restore core, containment, and spent fuel pool cooling capabilities following large fires or explosions (commonly referred to as B.5.b equipment). The inspectors questioned whether the pump was designed to start during cold ambient conditions without block heaters since it was a diesel driven pump.
The licensee reviewed the vendor technical manual and determined that the pump was not rated to start below 32 degrees Fahrenheit without assistance. Based on this, the inspectors determined that the licensee was not able to implement strategy EDMG A.4-4, "Manually Depressurize S/Gs and Use Portable AME Pump for Makeup," under all required conditions.
The licensee entered this issue into the corrective action program as Condition Report CR-2016-010832 for resolution. The licensee also took action to put temporary heaters in place for the alternate mitigation equipment pump to ensure the equipment was stored at temperatures greater than 32 degrees Fahrenheit pending final resolution of this issue.
The inspectors determined that the inadequate pump protection was in place since the original implementation of the mitigation strategies (February 2002) and was not reflective of current performance.
Analysis.
The failure to maintain all necessary equipment available to implement mitigating strategies as required by regulations and conditions of the operating license was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix L, "B.5.b Significance Determination Process," dated December 24, 2009, the inspectors determined the finding was of very low safety significance (Green) because it resulted in an unrecoverable unavailability of an individual mitigating strategy; but did not result in multiple unavailable mitigating strategies, or loss of all on
-site, self
-powered, portable pumping capability. The inspectors did not assign a cross-cutting aspect because the performance deficiency was not reflective of present performance.
Enforcement.
Title 10 CFR 50.54(hh)(2), "Conditions of Licenses," requires, in part, that the licensee develop and implement guidance and strategies intended to maintain or restore core cooling to mitigate fuel damage under the circumstances associated with loss of large areas of the plant due to explosions or fire. Contrary to the above, from February 2002 through March 2017, the licensee failed to implement guidance to maintain or restore core cooling to mitigate fuel damage under the circumstances associated with loss of large areas of the plant due to explosions or fire. Specifically, the licensee failed to maintain available all equipment needed to implement Procedure EDMG A.4-4, "Manually Depressurize S/Gs and Use Portable AME Pump for Makeup." Since this violation was of very low safety significance (Green) and has been entered into the corrective action program as Condition Report CR
-2017-000744, this violation is being treated as a non
-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy. (05000445/2017001
-01; 0500044 6/2017001-01, Failure to Maintain B.5.b Equipment in a State of Readiness to Support Mitigation Strategies)
.2 Complete Walk
-Down
a. Inspection Scope
On February 22, 2017, the inspectors performed a complete system walk-down inspection of the control room air conditioning system. The inspectors reviewed the licensee's procedures and system design information to determine the correct system lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, in
-process design changes, temporary modifications, and other open items tracked by the licensee's operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.
These activities constitute d one complete system walk
-down sample , as defined in Inspection Procedure 71111.04.
b. Findings
Introduction.
The inspectors identified a Green
, non-cited violation of 10 CFR 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to properly evaluate heat loads on the control room air conditioning system. Specifically, the licensee used a non-conservative assumption for the number of persons in the control room envelope when calculating the required capacity of the system.
Description.
While reviewing the alignment of the control room AC system the inspectors noted that the technical support center was located wholly within the control room envelope and that
, during a design basis accident, it would have additional personnel occupying the space. The inspectors asked the licensee what the capacity of the system was with respect to assumed heat loads. The licensee reviewed calculation X-EB-304-1, "Control Room Space Heat Gains and Maximum Space Temperature Limits Unit 1 and 2," Revision 5, and determined that they had assumed only six personnel would be in the technical support center during a design bas i s accident. The inspectors noted that the licensee's emergency plan nominally staffed the technical support center with 25 personnel, with an assumption of an additional 5 NRC personnel.
The inspectors questioned whether the control room air conditioning system was operable with the increased heat load. The control room air conditioning system consists of two trains each capable of supporting both units with 100 percent capacity. Each train consists of two 50 percent capacity units. The licensee's technical specifications allow the licensee to declare a train operable with only one unit provided environmental conditions permit one unit to meet the required safety function for a 30 day mission time. Because the licensee ha d used that allowance to credit operability, the licensee reviewed the system history to determine whether the control room air conditioning system was inoperable.
The licensee determined that the system had sufficient capacity to meet its safety function over the past three years, but that the criteria for determining operability were inadequate.
Addition of the additional required staff resulted in approximately a 2.5 percent margin reduction for the system.
The licensee entered this into their corrective action program as condition report CR
-2017-000744. The inspectors determined that the inadequate calculation was performed in Feburary 1992, and was not reflective of present performance.
Analysis.
The failure to evaluate heat loads to determine the required system capacity was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, "Initial Characterization of Findings," dated October 7, 2016, and Inspection Manual Chapter 0609, Appendix A, "Significance Determination Process for Findings At
-Power," Exhibit 2, "Mitigating Systems Screening Questions," the inspectors determined the finding was of very low safety significance (Green) because the finding:
- (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality,
- (2) did not represent a loss of system and/or function,
- (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out
-of-service for longer than their technical specification allowed outage time, and
- (4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety
-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with the licensee's maintenance rule program.
The inspectors did not assign a cross-cutting aspect because the performance deficiency was not reflective of present performance.
Enforcement.
Title 10 CFR 50, Appendix B, Criterion III, "Design Control" requires, in part, that the design basis "shall be correctly translated into specifications, drawings, procedures, and instructions." Contrary to the above, from Feburary 1992, to March 31, 2017, the licensee failed to ensure that the design basis for the CRAC system was correctly translated into specifications and procedures. The licensee performed an immediate operability evaluation to determine that the CRAC system was operable , pending further review and revision of calculation X-EB-304-1, "Control Room Space Heat Gains and Maximum Space Temperature Limits Unit 1 and 2," Revision 5. Since this violation was of very low safety significance (Green) and has been entered into the corrective action program as Condition Report CR
-2017-000744, this violation is being treated as a non
-cited violation consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000445/2017001
-0 2; 05000445/2017001
-0 2, Failure to Evaluate Heat Loads on Control Room Air Conditioning System)
1 R 05 Fire Protection (71111.05)
.1 Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensee's fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety
- January 5, 2017, Fire zone AA40, Unit 1 and 2, Upper ventilation filter room February 17, 2017, Fire zone 2CA101, Unit 2, Containment refueling cavity area March 27, 2017, Fire area SB2B, Unit 1, Motor driven auxiliary feedwater pump/residual heat removal pump March 29, 2017, Fire area SB2C, Unit 1, Motor driven auxiliary feedwater pump/residual heat removal pump
For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.
These activities constitute d four quarterly inspection sample s , as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1 R 06 Flood Protection Measures (71111.06)
a. Inspection Scope
On March 13, 2017, the inspectors completed an inspection of the station's ability to mitigate flooding due to internal causes. After reviewing the licensee's flooding analysis, the inspectors chose one plant area containing risk
-significant structures, systems, and components that were susceptible to flooding:
Pathway from the circulating water discharge structure via circulating water tunnels to the turbine building and lower level of the electrical and control building The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.
These activities constitute d completion o f one flood protection measures sample
, as defined in Inspection Procedure 71111.06.
b. Findings
No findings were identified.
1 R 07 Heat Sink Performance (71111.07)
a. Inspection Scope
The inspectors reviewed licensee programs to verify heat exchanger performance and operability for the following heat exchangers:
Ultimate Heat Sink Component Cooling Water Heat Exchanger 2
-01 Safety Chilled Water System Centrifugal Chiller 2
-05 The inspectors verified whether testing, inspection, maintenance, and chemistry control programs are adequate to ensure proper heat transfer. The inspectors verified that the periodic testing and monitoring methods, as outlined in commitments to NRC Generic Letter 89-13, utilized proper industry heat exchanger guidance. Additionally, the inspectors verified that the licensee's chemistry program ensured that biological fouling was properly controlled between tests. The inspectors reviewed previous maintenance records of the heat exchangers to verify that the licensee's heat exchanger inspections adequately addressed structural integrity and cleanliness of their tubes. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of three triennial heat sink inspection samples as defined in Inspection Procedure
71111.07 - 05.
b. Findings
Introduction.
The inspectors identified a Green, non
-cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," involving the failure to use the design fouling factor for the component cooling water heat exchanger in a design basis calculation evaluating a tornado missile strike of station service water system piping.
Description.
The licensee used an inaccurate assumption of 0.0003 for the component cooling water heat exchanger fouling factor in attachment 8 of design basis document DBD-ME-229, "Component Cooling Water System," dated December 19, 1988. The licensee used attachment 8 of DBD
-ME-229 to demonstrate the ability to cooldown with a single train of station service water discharge pipe damaged by an impact from a tornado missile following a single failure which removes the other station service water train from service. The station service water discharge piping is currently not protected from tornado missiles at Comanche Peak Nuclear Power Plant, hence, the necessity to prove that the station can cooldown on a single train of station service water. The assumed value of 0.0003 for the component cooling water heat exchanger fouling factor is much less than the 0.000695 actual fouling value obtained from the most recent heat exchanger thermal performance test and the 0.002 design fouling factor found in DBD-ME-229. If the correct 0.002 design fouling factor had been used, the calculation shows that the safe shutdown impoundment temperature would need to be limited to 97 degrees Fahrenheit instead of the technical specification limit of 102 degrees Fahrenheit to ensure that the analysis for a missile strike of the station service water discharge piping is bounded.
Analysis.
The inspectors determined that the failure to use the design fouling factor for the component cooling water heat exchanger in the tornado missile analysis of the station service water system discharge piping was a performance deficiency. This finding was more
-than-minor because it was associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the use of a non
-conservative heat exchanger fouling factor in a design basis accident analysis resulted in the licensee failing to recognize the need for a more restrictive temperature limit (i.e., less than the technical specification allowed value) of the safe shutdown impoundment. In accordance with Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At
-Power," dated June 19, 2012, Exhibit 2, "Mitigating Systems Screening Questions," the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that
- (1) did not represent a loss of operability or functionality;
- (2) did not represent an actual loss of safety function of the system or train;
- (3) did not result in the loss of one or more trains of non-technical specification equipment; and
- (4) did not screen as potentially risk
-significant due to seismic, flooding, or severe weather. The inspectors determined that this finding did not have a cross
-cutting aspect because the most significant contributor to the performance deficiency did not reflect current licensee performance. Specifically, the licensee performed the calculation in 1988, therefore, the performance deficiency occurred outside of the nominal three
-year period for "present performance."
Enforcement.
The inspectors identified a Green, non
-cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," which states, in part, "Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions." Contrary to the above, from December 19, 1988, to January 31, 2017, the licensee did not establish measures to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee used 0.0003 as the component cooling water heat exchanger fouling factor instead of the design value of 0.002 when evaluating tornado missile protection for the station service water system discharge piping. In response to this issue, the licensee performed immediate and prompt operability evaluations and determined that the station can perform the required shutdown and cooldown (given a postulated tornado missile strike of the exposed station service water system piping) as long as the safe shutdown impoundment temperature is less than 97 degrees Fahrenheit. In addition, the licensee created Standing Order TX 0023 to track the safe shutdown impoundment temperature to ensure it is below 97 degrees Fahrenheit until further analysis is performed. This finding was entered into the licensee's corrective action program as Issue Report IR
-2017-001465. Because this finding was of very low safety significance and has been entered into the licensee's corrective action program, this violation is being treated as a non
-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000445/2017001
-03; 05000446/2017001
-03, Use of Non-Design Fouling Factor for Component Cooling Water Heat Exchanger in Station Service Water Tornado Missile Calculation)1 R 11 Licensed Operator Requalification Program and Licensed Operator Performance (71111.11)
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On March 28, 2017, the inspectors observed simulator training for an operating crew
.
The inspectors assessed the performance of the operators and the evaluators' critique of their performance.
These activities constitute d completion of one quarterly licensed operator requalification program sample , as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.2 Review of Licensed Operator Performance
a. Inspection Scope
Inspectors observed the performance of on
-shift licensed operators in the plant's main control room.
At the time of the observations, the plant was in a period of heightened activity or risk due to modifications being performed on the electrical distribution system
. The inspectors observed the operators' performance of the following activities:
February 26, 2017, Surveillance Testing in preparation for XST1A alternate transformer modification February 27, 2017, Control room operations during XST1A alternate transformer cable cutting operations
In addition, the inspectors assessed the operators' adherence to plant procedures, including conduct of operations procedure and other operations department policies.
These activities constitute d completion of one quarterly licensed operator performance sample , a s defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
1 R 12 Maintenance Effectiveness (71111.12)
.1 Routine Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed one instance of degraded performance or condition of safety-significant structures, systems, and components (SSCs):
February 28, 2017, Unit 1 and Unit 2, XST2/XST1 transformer relays The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensee's corrective actions. The inspectors reviewed the licensee's work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensee's characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.
These activities constituted completion of one maintenance effectiveness sample, as defined in Inspection Procedure 71111.12.
b. Findings
No findings were identified.
.2 Quality Control
a. Inspection Scope
On February 17, 2017, the inspectors reviewed the licensee's quality control activities through a review of the licensee's control of quality parts during maintenance associated with emergency diesel generator reactive power (KVAR) meter replacement
.
These activities constituted completion of one quality control sample, as defined in Inspection Procedure 71111.12.
b. Findings
No findings were identified.
1 R 13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a. Inspection Scope
The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:
February 15, 2017, Unit 1 and Unit 2, Connection of alternate transformer XST1A to the station electrical distribution system March 6, 2017, Unit 1 and Unit 2, Service water unit cross connect surveillance testing The inspectors verified that these risk assessment were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensee's risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments. Additionally, on March 7, 2017, the inspectors observed portions of an emergent work activity for emergency diesel generator 1
-01 that had the potential to affect the functional capability of mitigating systems.
The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs.
These activities constitute d completion of three maintenance risk assessments and emergent work control inspection samples , as defined in Inspection Procedure 71111.13.
b. Findings
No findings were identified.
1 R 15 Operability Determinations and Functionality Assessments (71111.15)
a. Inspection Scope
The inspectors reviewed five operability determinations that the licensee performed for degraded or nonconforming SSCs:
January 31, 2017, Unit 1, CR
-2017-000789 centrifugal charging pump 1
-01 piping over pressurization February 24, 2017 , Unit 1, CR
-2017-000597 118VAC with swing inverter synchronization issue March 14, 2017, Unit 1 and 2, CR
-2017-003131, XST1 transformer with loss of forced coolin g
March 24, 2017, Unit 2, IR
-2017-002867 nonfunctioning thermistor strips inside containment March 29, 2017, Unit 1, IR
-2017-003936, Wrong lubricant added to safety chilled water recirculation pumps The inspectors reviewed the timeliness and technical adequacy of the licensee's evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensee's compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded condition s on the operability or functionality of the degraded SSC
. These activities constitute d completion of five operability and functionality review samples , as defined in Inspection Procedure 71111.15.
b. Findings
No findings were identified.
1 R 18 Plant Modifications (71111.18)
a. Inspection Scope
On March 8, 2017, the inspectors reviewed a permanent plant modification to connect alternate transformer XST1A with the station electrical distribution system.
The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors verified that post-modification testing was adequate to establish the operability of the SSC as modified.
These activities constitute d completion of one sample of permanent modifications , a s defined in Inspection Procedure 71111.18.
b. Findings
No findings were identified.
1 R 19 Post-Maintenance Testing (71111.19)
a. Inspection Scope
The inspectors reviewed four post-maintenance testing activities that affected risk
-significant SSCs:
February 23, 2017, Unit 1 and Unit 2, Spent fuel pool cooling pump X
-02 following mechanical seal replacement, WO5257546 March 13, 2017, Unit 1, Emergency diesel generator 1
-01 following emergent maintenance March 14, 2017, Unit 1 and Unit 2, XST1 transformer modification March 27, 2017, Unit 2, Motor drive auxiliary feedwater pump 2
-02 following regulator 2
-PV-2454A replacement The inspectors reviewed licensing- and design
-basis documents for the SSCs and the maintenance and post-maintenance test procedures.
The inspectors observed the performance of the post
-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.
These activities constitute d completion of four post-maintenance testing inspection samples , as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1 R 22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors observed four risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components (SSCs) were capable of performing their safety functions:
In-service test s: January 26, 2017
, Unit 1, Turbine driven auxiliary feedwater pump
Containment isolation valve surveillance tests:
March 6, 2017, Unit 2, OPT
-218B containment integrity verification for main steam line 2
-01 penetration
Other surveillance tests:
February 10, 2017
, Unit 1 and Unit 2, OPT
-207A service water cross connect valve stroke February 27, 2017, Unit 2, OPT
-414B Train A safety injection and blackout sequencer logic test The inspectors verified that these test s met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.
These activities constitute d completion of four surveillance testing inspection samples , as defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
Cornerstone:
Emergency Preparedness 1 EP 4 Emergency Action Level and Emergency Plan Changes (71114.04)
a. Inspection Scope
The inspector performed an in
-office review of Comanche Peak Nuclear Power Plant Emergency Plan, Unit 1 and Unit 2, Revision 41. This revision:
revise d the evacuation time estimate analysis summary, add ed a description of the alternate facility site required for response to a hostile action event, and revise d the emergency action level (EAL) scheme description to reflect the recently NRC-approved EAL revision based on NEI 99
-01, Revision 6.
This revision was compared to its previous revision, to the criteria of NUREG
-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, to Nuclear Energy Institute Report 99
-01, "Emergency Action Level Methodology," Revision 6, and to the standards in 10 CFR 50.47(b) to determine if the revision adequately implemented the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that the revisions did not decrease the effectiveness of the emergency plan. This review was not documented in a safety evaluation report and did not constitute approval of licensee
-generated changes; therefore, this revision is subject to future inspection.
These activities constitute completion of one emergency action level and emergency plan changes sample as defined in Inspection Procedure 71114.04.
b. Findings
No findings were identified.
1 EP 6 Drill Evaluation (71114.06)
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors observed emergency preparedness drill s on January 11, and February 15, 2017, to verify the adequacy and capability of the licensee's assessment of drill performance. The inspectors reviewed the drill scenario s, observed the drill s fro m the emergency operations facility and simulator, and attended the post
-drill critique s. The inspectors verified that the licensee's emergency classifications, off
-site notifications, and protective action recommendations were appropriate and timely.
Th e inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post
-drill critique s and entered into the corrective action program for resolution.
These activities constitute d completion of two emergency preparedness drill observation sample s, as defined in Inspection Procedure 71114.06.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security 4OA 1 Performance Indicator Verification (71151)
.1 Unplanned Scrams per 7000 Critical Hours (IE01)
a. Inspection Scope
The inspectors reviewed licensee event reports (LERs) for the period of January 2016, through December 2016 to determine the number of scrams that occurred. The inspectors compared the number of scrams reported in these LERs to the number reported for the performance indicator. Additionally, the inspectors reviewed monthly operating logs to verify the number of critical hours during the period.
The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the data reported.
These activities constituted verification of the unplanned scrams per 7000 critical hours performance indicator for Unit s 1 and 2 , as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Unplanned Power Changes per 7000 Critical Hours (IE03)
a. Inspection Scope
The inspectors reviewed operating logs, corrective action program records, and operating reports for the period of January 2016, through December 2016 to determine the number of unplanned power changes that occurred. The inspectors compared the number of unplanned power changes documented to the number reported for the performance indicator. Additionally, the inspectors reviewed monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the data reported.
These activities constituted verification of the unplanned power outages per 7000 critical hours performance indicator for Unit s 1 and 2, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.3 Unplanned Scrams with Complications (IE04)
a. Inspection Scope
The inspectors reviewed the licensee's basis for including or excluding in this performance indicator each scram that occurred between January 2016, and December 2016. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the data reported.
These activities constitute d verification of the unplanned scrams with complications performance indicator for Units 1 and 2 , as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA 2 Problem Identification and Resolution (71152)
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensee's corrective action program and periodically attended the licensee's condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified.
The inspectors also reviewed the licensee's problem identification and resolution activities during the performance of the other inspection activities documented in this report.
b. Findings
No findings were identified.
.2 Semi annual Trend Review
a. Inspection Scope
The inspectors reviewed the licensee's corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors focused on the stations corrective action program and maintenance backlogs. The inspectors reviewed documents, and planned work schedules and interviewed personnel to determine if the licensee completely and accurately identified problems in a timely manner commensurate with its significance, evaluated and dispositioned operability issues, considered the extent of condition, prioritized problems commensurate with their safety significance, identified appropriate corrective actions, and completed corrective actions in a timely manner commensurate with the safety significance of the issue.
The inspectors verified that the licensee was taking corrective actions to address identified adverse trends.
These activities constitute d completion of one semiannual trend review sample , a s defined in Inspection Procedure 71152.
b. Findings
No findings were identified.
.3 Annual Follow
-up of Selected Issues
a. Inspection Scope
The inspectors selected two issues for an in
-depth follow
-up: From October 3 to October 17, 2016, and January 23 to February 8, 2017, during in-office inspection, the inspectors reviewed the NRC
-identified and licensee
-identified issues documented in Inspection Report 05000445; 05000446/2014406 for an in-depth follow
-up. The inspectors reviewed procedures, digital asset listings, and corrective action documents associated with the licensee's cyber security program. The inspectors interviewed personnel involved in implementing the corrective actions.
The inspectors assessed the licensee's cause analyses, extent of condition reviews, and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were appropriate.
The inspectors reviewed the licensee's corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused on an issue with safety
-related inverter 1PC1 documented in Condition Report CR
-2017-000597. The inspectors assessed the licensee's problem identification threshold, cause analyses, and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.
These activities constitute d completion of two annual follow
-up sample s as defined i n Inspection Procedure 71152.
b. Findings
Introduction.
The inspectors identified a non
-cited violation of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," associated with the licensee's failure to take timely corrective actions for a previously identified condition adverse to quality.
Description.
On January 15, 2017, the Unit 1 120 VAC vital bus inverter that supplies 1PC1 output voltage dropped causing an alarm due to low voltage during periodic equipment rotation. The licensee determined that the inverter was inoperable due to the inability to maintain voltage while powered from the station batteries. The licensee also had an issue with the swing inverter not syncing
, so operators entered electrical power system Technical Specification 3.8.9.B, a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> shutdown limiting condition of operation. Subsequently, the licensee exceeded the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limiting condition of operation time limit and was in the process of making plans to shut the unit down when they were able to place the swing inverter in service and exit Technical Specification 3.8.9.B (at approximately 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />).
The inspectors reviewed the licensee's actions and questioned why the licensee was not crediting the availability of alternate AC power to the inverter, as allowed by the technical specifications. Inspectors noted that this would have allowed entry into Technica l Specification 3.8.9.A, a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limiting condition of operation, instead of Technical Specification 3.8.9.B. The licensee responded that the alternate AC power source could not be credited because of a previous NRC identified issue.
Inspectors subsequently determined that this issue had been identified by an NRC Component Design Basis Inspection team and documented in Inspection Report2013007 as non-cited violation (NCV)05000445; 05000446/2013007
-02; "Inadequate Voltage Calculations for the 125 VDC and 120 VAC Buses.
" During the 2013 inspection, the team had determined that the 480/120V transformer d id not have automatic voltage regulation capability, so when connected to the transformer source the 120 VAC distribution panel voltage will fluctuate with fluctuations on the upstream 480 V AC motor control center source. However, Branch Technical Position PSB-1, to which the licensee is committed, requires that the setpoints for the degraded voltage relays be determined from an analysis of the voltage requirements of the Class 1E loads at all onsite system distribution levels. The 2013 inspection team reviewed voltage calculation EE
-1E-1EB4-1, which determined voltage for the 480/120V transformer. The 2013 inspection team determined that the calculation used an available voltage at the motor control center considerably higher (444.96 V AC) than the voltage afforded by the degraded voltage relays (433 V AC) under accident loading conditions. In response to the 2013 inspection team's inquiries, the license e had initiated Condition Report CR
-2013-006396.
The current inspectors reviewed CR
-2013-006396 and noted that this condition report had been closed to actions to submit a license amendment. However, the license amendment was canceled and the issue was not resolved. Based on this, inspectors determined that the licensee had failed to take timely and adequate corrective actions to correct the identified condition adverse to quality associated with inadequate voltage calculations for the 120 VAC bus. Inspectors informed the licensee of their observations and the licensee initiated Condition Report CR
-2017-001296 to capture this issue in the station's corrective action program. The licensee also performed an operability determination that established a reasonable expectation of operability pending implementation of corrective actions.
Analyses. The licensee's failure to take timely and adequate corrective actions to correct a condition adverse to quality was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to correct the low voltage susceptibility resulted in delayed restoration of a bus following the failure of the swing inverter to sync. Using Inspection Manual Chapter 0609, Attachment 04, "Initial Characterization of Findings," dated October 7, 2016, and Inspection Manual Chapter 0609, Appendix A, "Significance Determination Process for Findings At
-Power," Exhibit 2, "Mitigating Systems Screening Questions," the inspectors determined the finding was of very low safety significance (Green) because the finding:
- (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality,
- (2) did not represent a loss of system and/or function,
- (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out
-of-service for longer than their technical specification allowed outage time, and
- (4) does not represent an actual loss of function of one or more non
-technical specification trains of equipment designated as high safety
-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with the licensee's maintenance rule program. The finding has a human performance cross
-cutting aspect associated with resources, in that, the licensee failed to ensure that resources were adequate to support nuclear safety [H.1].
Enforcement.
10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, from June 2013 through January 26, 2017, for quality related components associated with the safety related electrical distribution system, to which 10 CFR Part 50, Appendix B applies, the licensee failed to assure that conditions adverse to quality were promptly identified and corrected.
In response to this issue, the licensee also performed an operability determination which established a reasonable expectation of operability pending implementation of corrective actions. Since this violation was of very low safety significance (Green) and has been entered into the corrective action program as Condition Report CR
-2017-001296, this violation is being treated as a non
-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000446/201 7 00 1-04, Failure to Promptly Correct a Condition Adverse to Quality)4OA 5 Other Activities
.1 Temporary Instruction 2515/192, "Inspection of the Licensee's Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems."
a. Inspection Scope
The objective of this performance based Temporary Instruction was to verify implementation of interim compensatory measures associated with an open phase condition design vulnerability in electric power system s for operating reactors. The inspector conducted an inspection to determine if Comanche Peak had implemented the following interim compensatory measures.
These compensatory measures are to remain in place until permanent automatic detection and protection schemes are installed and declared operable for open phase condition design vulnerability. The inspector verified the following:
Comanche Peak identified and discussed with plant staff the lessons
-learned from the open phase condition events at the US operating plants including the Byron Station open phase condition event and its consequences. This included conducting operator training for promptly diagnosing, recognizing consequences, and responding to an open phase condition event.
Comanche Peak updated plant operating procedures to help operators promptly diagnose and respond to open phase condition events on off-site power sources credited for safe shutdown of the plant.
Comanche Peak established and implement ed periodic walk
-down activities to inspect switchyard equipment such as insulators, disconnect switches, and transmission line and transformer connections associated with the offsite power circuits to detect a visible open phase condition.
Comanche Peak ensured that routine maintenance and testing activities on switchyard components have been implemented and maintained.
As part of the maintenance and testing activities, the licensee assessed and managed plant risk in accordance with 10 CFR 50.65(a)
- (4) requirements.
b. Findings
No findings were identified.
4OA 6 Meetings, Including Exit
Exit Meeting Summary
On January 12, 2017, the inspector presented the final Temporary Instruction 2515/192 inspection results to Mr. T. Hope, Regulatory Affairs Manager, and other members of your staff. The licensee acknowledged the results presented. No proprietary information was identified.
On February 2, 2017, the inspectors presented the final inspection results for the triennial heat sink performance inspection to Mr. T. McCool, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
On February 8, 2017, the inspectors presented the inspection results for the in
-office inspection of corrective actions related to the cyber security program to Mr. T. Hope, Manager, Regulatory Affairs, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors destroyed the proprietary information reviewed during this inspection.
On March 22, 2017, the inspector conducted a telephonic exit meeting to present the results of the in-office inspection of changes to the licensee's emergency plan to Mr. J. Hull, Manager, Nuclear Emergency Planning. The licensee acknowledged the issues presented. On March 27, 2017, the inspectors presented the inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
4OA 7 Licensee-Identified Violations The following licensee
-identified violations of NRC requirements were determined to be of very low safety significance and meet the NRC Enforcement Policy criteria for being dispositioned as Non-Cited Violations:
Title 10 CFR 50.54(q)(2) requires, in part, that licensees shall follow and maintain the effectiveness of an emergency plan that meets the planning standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(2) requires, in part, that timely augmentation of response capabilities be available. The licensee's emergency plan provides for the ability to augment response capabilities by use of a system to callout additional personnel to fill their emergency response organization (ERO) staffing requirements for declared emergencies. Contrary to the above, from January 5, 2017 until January 17, 2017, the licensee failed to ensure timely augmentation of response capabilities was available.
Specifically, on January 5, 2017, the licensee's corporate security office removed 32 members of the ERO from the licensee's callout system, including eight personnel assigned to minimum staffing positions.
The licensee identified the issue when, following an inadvertent actuation of the callout system on January 16, 2017, they discovered that multiple personnel were not called. The licensee restored all required personnel to the callout system on January 17, 2017.
The violation is more than minor because it affected the ERO readiness attribute of the Emergency Preparedness cornerstone and impacted the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Using Inspection Manual Chapter 0609, Attachment 04, "Initial Characterization of Findings," and Inspection Manual Chapter 0609, Appendix B, "Emergency Preparedness Significance Determination Process," the inspector determined that the violation is of very low safety significance (Green) because the finding represented a failure to comply with planning standard (b)(2), and, using table 5.2
-1, was screened as a Green finding because the deficiency did not cause more than one required ERO functional area to not be filled. The violation was entered into the licensee's corrective action program as CR
-2017-001524.
Comanche Peak Unit 2, Operating License NPF
-89, Condition 2.G, "Fire Protection," requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 87
, and as approved in the Safety Evaluation Report and its supplements through Supplement 27. The station's approved fire protection program includes Fire Protection Report, Revision 29, Section 3.1 which requires, in part, that when fire detection equipment located inside of the containment building is inoperable then hourly monitoring of air temperature is performed as a compensatory measure. Contrary to the above, on November 22, 2016, licensee personnel identified that compensatory measures implemented for a failed detection system in the Unit 2 containment had not been implemented. The licensee had implemented a compensatory measure on December 3, 2015, to monitor containment temperature in the Unit 2 containment hourly due to a failed thermistor strip. On November 17, 2016, the licensee stopped monitoring temperature after restoring a different component to service. The licensee subsequently realized that the compensatory measure was still required and reinstated it on November 22, 2016. The violation is more than minor because it affected the protection against external events attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, "Initial Characterization of Findings," and Inspection Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process," the inspector determined that the violation is of very low safety significance (Green) because the finding did not affect the ability of either unit to achieve safe shutdown. The violation was entered into the licensee's corrective action program as Condition Report CR
-2016-009888.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- K. Peters, Senior Vice President and Chief Nuclear Officer
- T. McCool, Site Vice President
- S. Sewell, Senior Director, Engineering and Regulatory Affairs
- J. Dreyfuss, Plant Manager
- D. Goodwin, Director, Work Management
- B. St. Louis, Director, Operations
- M. Stakes, Director, Maintenance
- J. Taylor, Director, Site Engineering
- D. Farnsworth, Director, Nuclear Oversight
- H. Winn, Director, Performance Improvement
- D. Christiansen, Director, Nuclear Training
- T. Hope, Manager, Regulatory Affairs
- J. Lloyd, Manager, Operations Support
- C. Tran, Manager, Engineering Programs
- J. Gumnick, Manager, Radiation Protection
- J. Hull, Manager, Nuclear Emergency Preparedness
- M. McNally, Manager, Nuclear Security
- G. Merka, Consulting Nuclear Technologist, Regulatory Affairs
- J. Barnette, Consulting Nuclear Technologist, Regulatory Affairs
- J. Hicks, Consulting Nuclear Engineer, Regulatory Affairs
- S. Porter, Engineer
- G. Williams, Senior Nuclear Technologist
- R. Green, Senior Programs Engineer
- S. Clark, Engineer
- B. Loose, Program Manager, Cyber Security
- B. Martin, Project Lead, Cyber Security Project Lead
- D. Woodard, Project Engineer, Cyber Security
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
-01
-01 NCV Failure to Maintain B.5.b Equipment in a State of Readiness to Support Mitigation Strategies
-0 2
-0 2 NCV Failure to Evaluate Heat Loads on Control Room Air Conditioning System
-03
-03 NCV Use of Non
-Design Fouling Factor for Component Cooling Water Heat Exchanger in Station Service Water Tornado Missile Calculation
-04 NCV Failure to Promptly Correct a Condition Adverse to Quality
Discussed 2515/192 TI Inspection of the Licensee's Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems
(Section 4OA5)
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Procedures
- Number Title Revision / Date
- ABN-907
- Acts of Nature
- ODA-308 LCO Tracking Program
Section 1R04: Equipment Alignment
Procedures
- Number Title Revision / Date
- SOP-802 Control Room Ventilation System
Condition Reports
- CR-2016-010027
- CR-2017-000744
- CR-2016-010697
- CR-2017-000164 CR-2016-009421
Section 1R05: Fire Protection
Procedures
- Number Title Revision /
- Date
- FPI-411 Auxiliary Building Train A Primary Plant Exhaust Filter Room Elevation 886'
-6" 5
- FPI-201B Unit 2 Containment Building Elevation 808'
-0" 2
- FPI-102A Unit 1 Safeguards Building Elevation 790'
-0" 3
Condition Reports
- CR-2016-009888
Miscellaneous Documents
- Number Title Revision / Date
- FPI-409 Auxiliary Building Chiller and Train B Primary Plant Exhaust Filter Room Elevation 886'
-6" 5 NEC0203 Purchase Order Oil, Fuel, Diesel, ASTM D975 Grade No. 2D; Non-Safety 2 NEC00752017
- Purchase Order Oil, Fuel, Diesel, ASTM D975 Grade No. 2D; Commercial Grade
Section 1R06: Flood Protection Measures
Drawings
- Number Title Revision 2323-S-1102
- Circulating Water Intake Structure Sects. & Dets
-Sh. 1 6 2323-S-1103 Circulating Water Intake Structure Sects. & Dets
-Sh. 2 5 2323-S-1106 Circulating Water Discharge Structure Sheet 1
- 2323-S-1115 Circulating Water Discharge Structure Sheet 2
Miscellaneous Documents
- Number Title Revision / Date
- DBD-CS-071
- Probable Maximum Flood (PMF)
Section 1R07: Heat Sink Performance
Procedures
- Number Title Revision
- ABN-501 Station Service Water System Malfunction
- ABN-907 Acts of Nature
- CHM-140 Water Treatment
- COP-501 Station Service Water
- ECA-0.0A Loss of All AC Power
Procedures
- Number Title Revision
- ENV-318 SSI Biological Monitoring and Management
- OWI-103 Locked Component Listings and Deviation Control 16
- PPT-SX-7517 Safe Shutdown Impoundment Inspection
- STA-502A Component Cooling Water System Operating Manual
- STA-677 Preventive Maintenance Program
- STA-730 Corrosion Monitoring Program
- STA-734 Service Water System Fouling Monitoring Program 5
- TDM-901A Systems Data Throttled Valves/Flow Rates
Calculations
- Number Title Revision 1561600-F019 Service Water train B Fluid Transient Analysis for Pump Trip
- 15616-NP(B)-F04 Waterhammer Analysis of the Residual Heat Removal System due to RV 2
-8708A/B Discharge
- 2-ME-0265 Component Cooling Water Heat Exchanger Tube Plugging Analysis 0
- ME-CA-0000-3264 Safe Shutdown Impoundment Hydrothermal Analysis
- ME-CA-0229-2188 Component Cooling Water Heat Exchanger Fouling Factor Analysis 8
- ME-CA-0229-5129 CCW Parameters for Fouling Monitoring
- ME-CA-0233-5017 SSI Heat Load Summary
- RXE-LA-CPX/0-020 RHR Cooldown Calculations
Miscellaneous
- Number Title Date
- CPNPP System Status
- Service Water [CLS & SW]
rd Qtr FY16
- Service Water Visual Inspection Form October 14, 2015
- Service Water Visual Inspection Form May 9, 2016
- Service Water Visual Inspection Form May 3, 2016
- Service Water Phosphates and MS Corrosion Rate January 4, 2010 - April 4, 2016
- Dam Safety Inspection Report for the Nuclear Regulatory Commission (NRC)
- April 11, 2013
- Volumetric and Sedimentation Survey of Squaw Creek Reservoir August 2008
- Component (2SW003
-P009) Evaluation Report January 30, 2012
- Component (2SW962
-P001) Evaluation Report January 30, 2012
- Component (2SW960
-P001) Evaluation Report January 30, 2012
- EV-CR-2014-004722-1 2014 SOER 07
-2 Three-Year Review
- EV-CR-2015-004321-20 INPO 15-003, Section 4.1.14 Gap Analysis
- SW Reliability Program
-445 and 50
-446 NRC Generic Letter 89-13 Service Water Systems Affecting Safety
-Related Equipment January 26, 1990
-90031 from Mr. W.J. Cahill, Jr. to USNRC dated January 26, 1990
- May 21, 1990
-90186 from W. J. Cahill, Jr. to USNRC dated May 21, 1990
- September 21, 1990
-90347 from W. J. Cahill , Jr. to USNRC dated September 21, 1990
- January 7, 1991
-01 November 16, 2016
Miscellaneous
- Number Title Date
-01 September 12, 2016
- DBD-CS-096 Safe Shutdown Impoundment/Dam
- DBD-ME-229 Component Cooling Water System
- DBD-ME-233 Station Service Water System
- AH-RS-681 Residual Heat Exchanger
- J12226ARS York Document MN
-2049 January 5, 1987
- Final Design Authorizations
- FDA-2015-000135-01-00
- FDA-2016-000053-01-01
- FDA-2014-000175-01-00
Condition Reports
(Reviewed)
- CR-2014-000192
- CR-2014-000429
- CR-2014-000443
- CR-2014-001812
- CR-2014-001968
- CR-2014-002122
- CR-2014-002272
- CR-2014-002593
- CR-2014-002911
- CR-2014-004461
- CR-2014-004749
- CR-2014-005955
- CR-2014-005903
- CR-2014-006051
- CR-2014-006201
- CR-2014-006283
- CR-2014-006399
- CR-2014-007161
- CR-2014-007431
- CR-2014-007767
- CR-2014-007829
- CR-2014-008212
- CR-2014-008449
- CR-2014-009667
- CR-2014-010608
- CR-2014-013208
- CR-2014-013245
- CR-2014-013615
- CR-2015-000046
- CR-2015-000602
- CR-2015-001525
- CR-2015-001569
- CR-2015-001676
- CR-2015-002091
- CR-2015-002835
- CR-2015-004357
- CR-2015-004461
- CR-2015-005121
- CR-2015-006902
- CR-2015-006914
- CR-2015-008334
- CR-2015-009945
- CR-2015-009957
- CR-2015-010233
- CR-2015-010384
- CR-2015-011497
- CR-2015-011663
- CR-2015-012075
- CR-2016-000164
- CR-2016-001605
- CR-2016-001864
- CR-2016-002485
- CR-2016-002880
- CR-2016-003537
- CR-2016-004366
- CR-2016-004552
- CR-2016-004688
- CR-2016-004868
- CR-2016-005650
- CR-2016-006553
- CR-2016-007639
- CR-2016-007912
- CR-2016-009417
- CR-2016-009972
- TR-2016-006602
- TR-2016-009730
- CR-2014-013613
- CR-2015-001578
- CR-2015-001933
- CR-2015-004159
- CR-2015-006765
- CR-2015-008276
- CR-2015-009824
- CR-2015-009839
- CR-2015-012118
- CR-2016-000344
- CR-2016-000418
- CR-2016-001084
- CR-2016-001219
- CR-2016-003337
- CR-2016-003808
- CR-2016-003957
- CR-2016-004024
- CR-2016-004786
- CR-2016-006524
- CR-2016-006740
- CR-2016-006845
- CR-2016-006966
- CR-2016-008147
- TR-2015-002284
Condition Reports
(Reviewed)
- TR-2016-002235
- TR-2016-000765
- TR-2016-006227
- TR-2016-008751
- CR-2010-008411
- CR-2012-012426
- IR-2017-001398
- IR-2017-001465
- IR-2017-001552
- IR-2017-001561
- IR-2017-001569
Work Orders
- 4494256
- 3812384
- 3779730
- 4590645
- 4812980
- 4874033
- 5082658
- 4297555
- 4955479 5213587
Section 1R12: Maintenance Effectiveness
Condition Reports
- CR-2016-008993
Miscellaneous Documents
- Number Title Revision/ Date
- EVAL-2005-001345-001
Work Orders
- 5059724
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
Procedures
- Number Title Revision Date
- STA-629
- Switchyard Control and Transmission Grid Interface
Condition Reports
- TR-2017-001018
- TR-2017-000901
- CR-2013-000085
Drawings
- Number Title Revision 09-500-76001 Diesel Engine Control Panel Schematic
Miscellaneous Documents
- Number Title Revision / Date DID
- XST1-01 Loss of Offsite Power and Station Blackout During XST1 Maintenance
Work Orders
- 5403331 5403401
Section 1R15: Operability Determinations and Functionality Assessments
Calculations
- Number Title Revision EE(B)-074 XST1 and XST2 Start
-up Transformers Load Study
Condition Reports
- CR-2017-000789
- CR-2017-000597 CR-2017-003131
Section 1R18: Plant Modifications
Procedures
- Number Title Revision / Date
- ECE-5.01 Design Control Program
- ECE-5.01-08 Electronic Design Change Process
Condition Reports
- CR-2013-012287
- CR-2014-005538
- Final Design Authorizations
- FDA-2012-000073-01-14
- FDA-2012-000073-02-04
- FDA-2012-000073-03-0 1
- FDA-2012-000073-0 7-05
- FDA-2012-000073-0 8-01
- FDA-2012-000073-1 1-00
Section 1R19:
- Post
-Maintenance Testing
Procedures
- Number Title Revision / Date
- SOP-609A Diesel Generator System
Work Orders
- 257546
Section 1R22: Surveillance Testing
Procedures
- Number Title Revision / Date
- OPT-206A AFW System
- OPT-207A Service Water System
- OPT-414B
- OPT-218B
Work Orders
- 5377445
Section 1EP4: Emergency Action Level and Emergency Plan Changes
Miscellaneous
- Number Title Revision/
- Date
- Comanche Peak Nuclear Power Plant Emergency Plan Unit 1 and Unit 2
- CP-201500668,
- TXX-15101 Comanche Peak Nuclear Power Plant Docket Nos. 50
-445 and 50-446, License Amendment Request 15
-003 for Revision to Unit 1 and Unit 2 Emergency Action Levels June 30, 2015
Section 1EP6: Drill Evaluation
Miscellaneous Documents
- Number Title Revision / Date
- Exercise Report
- Green Team
- January 11, 2017
- February 7, 2017
Section 4OA2: Problem Identification and Resolution
Procedures
- Number Title Revision / Date
- CSI-101 Cyber Security Defensive Strategy
Condition Reports
- CR-2013-012287
- CR-2014-005538
- CR-2013-007383
- CR-2013-010991
- CR-2014-002240
- CR-2014-002284
- CR-2014-002286
- CR-2014-002316
- CR-2016-009192
Miscellaneous Documents
- Number Title Revision / Date
- Cyber Security Directorate Analysis Of The Keyboard, Video, Mouse Switch Installation at Comanche Peak November 18, 2016
- FDA-2013-000142-2 Upgrade the Plant Computer System and Plant Information Isolation Hardware and Software to Support New Cyber Security Controls March 10, 2015 NEI0809R6ITSECLAN950SA0V-001 Schematic Architecture Overview for LAN950 and Interconnections
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