Semantic search

Jump to navigation Jump to search
 Start dateSiteIdentified byTitleDescription
05000446/FIN-2018011-0130 September 2018 23:59:59Comanche PeakNRC identifiedFailure to Maintain a Quality Record Complete and Accurate in All Material RespectsThe inspectors identified an apparent violation of 10 CFR 50.9, in that the licensee appears to have failed to maintain information required by the Commissions regulations that was complete and accurate in all material respects. Specifically, following equipment manipulation and an unanticipated loss of inventory in a portion of the reactor coolant system, the licensee appears to have failed to maintain complete and accurate information in condition report CR-2017-005788 relative to the cause of the loss of inventory event and the identified condition adverse to quality in the corrective action program. Description: On April 28, 2017, following an attempt to fill the refueling water storage tank (RWST) that resulted in a lowering level in the volume control tank (VCT), a licensed reactor operator (RO) admitted that he provided incomplete or inaccurate information to licensee personnel on a number of occasions. Specifically, the RO stated that after he realized that valve 2-FCV-110B, reactor coolant system makeup to charging pump suction isolation valve,was not aligned properly he did not alert the control room, and when others assumed the valve was leaking by he did not correct them. The RO also admitted that he knowingly submitted a written statement where he indicated that the valve had been closed and reported the same in Condition Report CR-2017-005788 that he drafted, which was not accurate. As a result, the NRC has identified an apparent willful violation of 10 CFR 50.9, Completeness and Accuracy of Information
05000445/FIN-2018003-0130 September 2018 23:59:59Comanche PeakNRC identifiedFailure to Maintain the Ability to Withstand a Station BlackoutThe inspectors identified a Green, non-cited violation of 10 CFR Part 50.63 for the licensees failure to maintain the ability to withstand and recover from a station blackout. Specifically, the licensees approved coping analysis for each unit required the availability of equipment on the non-blacked-out unit, and the licensee failed to maintain the required equipment available.The licensee entered this violation into their corrective action program as condition report CR-2017-011090.
05000445/FIN-2018003-0230 September 2018 23:59:59Comanche PeakNRC identifiedFailure to Establish Adequate Procedural Guidance for Processing Technical Changes Performed by A Vendor on Installed Plant EquipmentThe inspectors identified a Green, NCVof 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to establish an adequate procedure for controlling and processing vendor documents and vendor technical information. This resulted in the licensees failure to properly evaluate changes made by vendors to plant equipment. Specifically, the licensee allowed vendors to make physical changes to a component cooling water pump shaft and main steam isolation valve actuators without evaluating these changes.
05000445/FIN-2018010-0130 September 2018 23:59:59Comanche PeakNRC identifiedFailure to Establish Test Program to Verify Residual Heat Removal Suction Valve CapabilityThe inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for the failure to establish a test program to ensure that residual heat removal suction isolation valves would perform adequately in service.
05000446/FIN-2018011-0230 September 2018 23:59:59Comanche PeakSelf-revealingFailure to Follow a Quality Procedure Associated with the Reactor Makeup and Chemical Control SystemThe inspectors reviewed a self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a for the licensees failure to follow a quality procedure associated with the reactor makeup and chemical control system which resulted in an unanticipated loss of inventory from the volume control tank in the reactor coolant system. Specifically, on April 28, 2017, a reactor operator failed to complete step 5.2.7.G in quality procedure SOP-104B, Reactor Make-up and Chemical Control System, which would isolate the volume control tank from the chemical and volume control system, prior to directing a nuclear equipment operator to complete subsequent steps 5.2.7.K and 5.2.7.L, which opened isolation valves to the refueling water storage tank. These actions resulted in the unanticipated loss of inventory from the volume control tank into the refueling water storage tank.
05000445/FIN-2018010-0230 September 2018 23:59:59Comanche PeakNRC identifiedFailure to Provide Procedural Guidance for the Failure of a Component Cooling Water Surge Tank Makeup ValveThe inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to provide procedural guidance for the failure of a component cooling water surge tank makeup valve.
05000445/FIN-2018002-0330 June 2018 23:59:59Comanche PeakNRC identifiedFailure to Incorporate Design Information Into System Test ProceduresThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Controls, for the licensees failure to ensure that the stations in-service testing program for main steam isolation valves (MSIVs) incorporated the requirements and acceptance limits contained in applicable design documents. Specifically, the licensees in-service procedures did not direct testing of the valves be performed at the minimum required pressure and this resulted in the licensees failure to identify two degraded MSIVs during in-service testing. The licensee entered this issue into the corrective action program as Condition Report CR-2018-003229.
05000445/FIN-2018002-0230 June 2018 23:59:59Comanche PeakNRC identifiedUnacceptable Preconditioning of Main Steam Isolation ValvesThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Controls, for the licensees unacceptable preconditioning of the Unit 1 main steam isolations valves (MSIV) prior to performing as-found in-service stroke time testing. Specifically, the licensee raised accumulator pressure prior to stroke time testing and this potentially masked an issue with MSIV 1-01. The licensee entered this issue into the corrective action program as Condition Report CR-2018-002405.
05000445/FIN-2018002-0130 June 2018 23:59:59Comanche PeakNRC identifiedFailure to Identify and Correct a Condition Adverse to QualityThe inspectors identified a Green,non-cited violation of 10CFR 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensees failure to identify and correct a condition adverse to quality associated with unacceptable main steam isolation valve (MSIV) stroke times. Specifically, during stroke time testing of MSIV 2-02 the valves stroke time was outside of the acceptance limit and the licensee failed to determine why the stroke time was out of specification and correct the issue prior to declaring the valve operable and placing it in service. The licensee entered this issue into the corrective action program as Condition Report CR-2018-002189.
05000445/FIN-2018001-0331 March 2018 23:59:59Comanche PeakNRC identifiedFailure to Provide an Adequate ProcedureThe inspectors identified a Green,non-cited violation of Technical Specification 5.4.1, Procedures, associated with the licensees failure to provide procedures appropriate to the circumstances. Specifically, station procedure INC-2085, Rework and Replacement of I&C Equipment, did not contain adequate instructions for wiring current to pressure (I/P) converters for safety related components which resulted in the steam generator atmospheric relief valve I/P converters being placed in a seismically unqualified configuration. This finding was entered into the licensees corrective action program as Condition Report CR-2017-011922.
05000445/FIN-2018001-0131 March 2018 23:59:59Comanche PeakNRC identifiedFailure to Follow Commercial Grade Dedication ProcessThe inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to accomplish activities affecting quality in accordance with documented procedures. Specifically, the licensee upgraded the safety classification of Ashcroft series 200 diaphragms to safety related without following the requirements of station procedure ECE-6.02-03, Critical Characteristics Development. The licensee entered this issue into the corrective action program as Condition Reports CR-CR-2016-009733 and CR-2017-007811.
05000445/FIN-2018001-0431 March 2018 23:59:59Comanche PeakNRC identifiedInadequate Maintenance Procedure for Feedwater ValvesThe inspectors reviewed a self-revealed Green,non-cited violation of Technical Specification 5.4.1, Procedures, associated with the licensees failure to prescribe adequate procedures for performing maintenance on the feedwater bypass control valves. Specifically, the licensees procedure failed to specify the correct torque on the handwheel screw locknut, resulting in a loose locknut which led to a control valve failure and a turbine trip. This finding was entered into the licensees corrective action program as Condition Report CR-2017-009139.
05000445/FIN-2018001-0231 March 2018 23:59:59Comanche PeakNRC identifiedFailure to Incorporate Design Information Into System Test ProceduresThe inspectors identified a Green,non-cited violation of 10 CFR 50, Appendix B, Criterion XI, Test Control, for the licensees failure to ensure that station test procedures incorporated all requirements contained in applicable design documents. Specifically, the stations test procedures for the component cooling water system failed to test the safeguards loops supply and return train isolation valves for leakage. Excess leakage from these valves could prevent the performance of a safety function. This finding was entered into the licensees corrective action program as Condition Report CR-2017-012024.
05000445/FIN-2018001-0531 March 2018 23:59:59Comanche PeakNRC identifiedFailure to Correct a Significant Condition Adverse to QualityThe inspectors identified a Green,non-cited violation of 10CFR 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensees failure to take corrective action for the identified cause of a significant condition adverse to quality. Specifically, a feedwater bypass control valve vibrated open resulting in a turbine trip and initiation of auxiliary feedwater. The licensee determined that the cause was an inadequate procedure for performing maintenance on the feedwater bypass control valves, but failed to correct the inadequate procedure after identifying it as the cause of a control valve failure and a turbine trip. This finding was entered into the licensees corrective action program as Condition Report CR-2018-000959.
05000445/FIN-2017003-0230 September 2017 23:59:59Comanche PeakNRC identifiedProgrammatic Failures to Control Transient Combustible Material in Accordance with a Fire Protection ProcedureThe inspectors identified 51 examples of a non- cited violation of Operating Licenses NPF -87 and NPF -89, License Condition 2.G, Fire Protection Program, for the failure to control transient combustibles in accordance with the station s Fire Protection Report . Specifically, Fire Protection Report, Revision 29, identifies areas that require strict control o f transient combustible materials such that they are not introduced into these areas without compensatory measures in place prior to introduction. Contrary to this, the licensee allowed storage of combustible materials in 51 areas without compensatory measures. This issue does not represent an immediate safety concern because the licensee removed the combustible materials when they were identified. The licensee entered this issue into its corrective action program as Condition Report CR -2017- 008728. The failure to control transient combustible material s in accordance with the approved Fire Protection Report is a performance deficiency. The performance deficiency was more than minor and therefore a finding because it was associated with the protection against the external factors attribute of the Mitigating System Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the introduction of transient combustible materials decreased the external event mitigation for fire prevention. Furthermore, the inspectors determined that this was a programmatic issue since multiple departments were responsible for t he inappropriate introduction of combustible materials into the exclusion areas . Using NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, June 19, 2012, the inspectors determined that the finding pertained to a failure to adequately implement fire prevention and administrative controls for transient combustible materials. As a result, the inspectors were directed to Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, Sept ember 20, 2013 , and determined that the finding was of very low safety consequence (Green) because the fire prevention and administrative controls finding would not prevent the reactor from reaching and maintaining a safe shutdown condition because none of the examples impacted both trains of safe shutdown equipment . The finding has a human performance cross -cutting aspect associated with procedure adherence, in that station personnel failed to follow procedure requirements when introducing transient combustible materials into exclusion areas (H.8)
05000446/FIN-2017003-0130 September 2017 23:59:59Comanche PeakNRC identifiedFailure to Promptly Correct a Condition Adverse to QualityThe inspectors identified a non- cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensees failure to take timely corrective actions for a condition adverse to quality. Specifically, the licensee failed to take corrective actions for a leak in the hydraulic snubbers for the Unit 2, loop 3 steam generator, resulting in the level in the hydraulic fluid reservoir going below the minimum level in the sight glass on multiple occasions. This issue does not represent an immediate safety concern because the licensee took action to refill the hydraulic fluid reservoir. The licensee entered this issue into its corrective action program as Condition Report CR -2017- 009071. The licensees 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 protection against the external events 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 leak resulted in the hydraulic fluid reservoir level dropping below the minimum sight glass level , and loss of reasonable assurance of adequate oil in the snubbers to support their operation. 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 4 , External Events Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because: (1) the loss of the equipment by itself during the external initiating event it was intended to mitigate would not cause a plant trip or initiating event, would not de grade two or more train s of a multi -train system or function, and would not degrade one or more trains of a system that supports a risk significant system or function, and (2) the finding did not involve the total loss of any safety function that contributes to external event initiated core damage accident sequences. The finding has a human performance cross -cutting aspect associated with work management , in that, the licensee failed to ensure that the process of planning, controlling, and executing work 3 activities was implemented to ensure nuclear safety was the overriding priority (H.5 )
05000445/FIN-2017008-0130 June 2017 23:59:59Comanche PeakNRC identifiedFailure to Implement and Maintain Adequate Inspection Procedures for Penetration Sealing DevicesGreen. The team identified a non-cited violation of Operating License Condition 2.G related to the licensees failure to maintain adequate procedures for the inspection of required penetration sealing devices as required by the licensees Fire Protection Report, Section IV-2.1.c.1. Specifically, the Fire Protection Report required, in part, that fire-rated assemblies and penetration sealing devices be confirmed operable by visually inspecting the exposed surfaces using a site approved sampling plan every 18 months. Fire Protection Manual Procedure FIR-310, Penetration Seal Inspection, Revision 3, did not appropriately capture all penetration sealing devices for inspection. In 2009, guidance was added to the procedure restricting inspections to equipment accessible from the floor (8 feet or below). Also, the licensees automated random sampling process did not ensure that all penetration seal s would be inspected within the licensees 15-year sampling plan interval. The licensee entered these issues into their corrective action program as Condition Reports CR-2017-007745 and CR-2017-007746 to revise the surveillance procedure and sampling plan to ensure all required penetration seals were included and inspected within the 15-year sampling plan interval. The failure to ensure that fire protection program procedures used to establish inspection criteria for penetration sealing devices appropriately captured all required penetration sealing devices for visual inspection using a site approved sampling plan every 18 months was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the reactor safety Mitigating Systems cornerstone attribute of prot ection against external factors (i.e., fire), and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, dated October 7, 2016, the finding was determined to require additional evaluation under Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, dated September 30, 2013. The finding was screened as a Green finding of very low safety significance in accordance with Task 1.4.3, Fire Confinement, Question B. Based on the analysis performed, the team concluded that the degradation of the fire barrier penetration seals represented a low 3 degradation of the fire confinement element. No inspected barriers were identified as degraded, and all inspected barriers provided at least a 1-hour or greater fire endurance rating. The team did not assign a cross-cutting aspect because the performance deficiency was not reflective of present performance in that the inspection procedure changes occurred in 2009.
05000445/FIN-2017002-0130 June 2017 23:59:59Comanche PeakNRC identifiedFailure to Control Transient Combustible Material in Accordance with a Fire Protection ProcedureGreen. The inspectors identified a non- cited violation of Operating Licenses NPF -87 and NP F-89, License Condition 2.G, Fire Protection Program, for the failure to control transient combustibles in accordance with the station s fire protection report. Specifically, Fire Protection Report, Revision 29, Section 5.3.8, Fire Area EO Control Room, includes Deviation 3c -1, Control Room Missile Door, which requires, in part, that since the control room missile door in the west wall is not a 3 -hour rated fire door, the area of the turbine deck within 100 feet of the door is to be void of combustibles. Contrary to this, the licensee allowed storage of combustible materials in this area without required compensatory measures. This issue does not represent an immediate safety concern because the licensee removed the combustible materials upon identification. The licensee entered this issue into corrective action program as Condition Report CR -2017 -5564. The failure to control transient combustible material in accordance with the approved fire protection report is a performance deficiency. The performance deficiency was more than minor and therefore a finding because it was associated with the protection against external factors attribute of the Mitigating System Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the introduction of transient combustible materials decreased the external event mitigation for fire prevention. Using NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, June 19, 2012, the inspectors determined that the finding pertained to a failure to adequately implement fire prevention and administrative controls for transient combustible materials. As a result, the inspectors were directed to Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, September 20, 2013. The inspectors evaluated the finding through Appendix F, Attachment 1, Fir e Protection Significance Determination Process Worksheet, September 20, 2013, and determined that the finding was of very low safety consequence (Green) because the Fire Prevention and Administrative Controls finding would not prevent the reactor from re aching and maintaining a safe shutdown condition. The finding has a problem identification and resolution cross -cutting aspect associated with resolution, in that, the licensee failed to take effective corrective actions to address issues in a timely manner. 3 Specifically, the licensee had previously identified this issue in Condition Report CR- 2014010224 but had failed to take corrective actions to address it (P.3)
05000445/FIN-2017008-0230 June 2017 23:59:59Comanche PeakLicensee-identifiedLicensee-Identified ViolationFor Unit 1: As described in the Final Safety Analysis Report through Amendment 78 and as approved in the Safety Evaluation Report (NUREG-0797), and its supplements through Supplemental Safety Evaluation Report 24. 15 For Unit 2: As described in the Final Safety Analysis Report through Amendment 87 and as approved in the Safety Evaluation Report (NUREG-0797), and its supplements through Supplemental Safety Evaluation Report 27. The Fire Protection Report was included as part of the licensees approved fire protection program for both units. The Fire Protection Report was included as part of the licensees Final Safety Evaluation Report for both units, and states, in part, that administrative control of the fire protection program is provided through station procedures to assure that the fire protection equipment/systems are operable and properly maintained. This includes periodic tests and inspections, compensatory measures concerning items which may be inoperable, and quality assurance audits. The program applies to fire protection equipment and systems that protect fire areas which contain safe shutdown equipment. Revision 30, Section IV-2.1.b.1.g of the Fire Protection Report required that at least once per 3 years the fire suppression water system be demonstrated operable by performing a flow test of the system in accordance with Chapter 5, Section 11 of the NFPA Fire Protection Handbook, 14th Edition. This section of the handbook directs the licensee to carefully choose test points and conduct tests in such a way that the available flow and pressure at high value or hazardous areas can be determined readily. Contrary to the above, prior to June 29, 2017, the licensee failed to implement all provisions of the approved fire protection program. Specifically, the licensee identified that Comanche Peak currently performs loop flow testing of the underground Fire Suppression Water System piping per Procedure FIR-PX-3200, Fire Suppression Loop Flow Test, Revision 3, which the licensee identified did not test portions of the underground loop that feed into the main power block buildings, which contain areas housing safety-related and important to safety equipment, and may not be in accordance with the methodology described in Chapter 5, Section 11 of the Fire Protection Handbook, 14th Edition, such that the available flow and pressure at high value or hazardous areas can be determined readily. The performance deficiency was more than minor because it was associated with the protection against external factors (fire) attribute of the Mitigating Systems cornerstone and adversely affected the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was screened in accordance with Inspection Manual Chapter 0609, Appendix F, dated September 20, 2013. The finding was determined to be of very low safety significance (Green) in Task 1.4.7, Fire Water Supply, Question A, because at least 50 percent of required fire water capacity (flow at required pressure) will still be available as evidenced by successful testing of the main transformer suppression systems. The violation was entered into the licensees corrective action program as Condition Report CR-2017-007536.
05000445/FIN-2017002-0330 June 2017 23:59:59Comanche PeakNRC identifiedRelays not Environmentally QualifiedGreen. The inspectors identified a non- cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to assure that design changes were subject to design control measures commensurate with those applied to the original design. Specifically, the licensee changed internal components for safety -related, steam generator atmospheric relief valve booster relays but failed to verify that these new components could withstand the environment created during a high energy line break. This issue does not represent an immediate safety concern because the licensee performed an operability determination which established a reasonable expectation for operability, and implemented corrective actions to replace the relays with qualified relays. The licensee 4 entered this issue into the corrective action program for resolution as Condition Report CR- 2017- 006236. The failure to ensure that changes to the facility were subject to design control measures commensurate with those applied to the original design 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 associated 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 hours in accordance with the licensees maintenance rule program. The inspectors did not assign a cross -cutting aspect because the performance deficiency was not reflective of present performance
05000446/FIN-2017002-0230 June 2017 23:59:59Comanche PeakNRC identifiedInadequate Operability Evaluation for Safety - related Pipe SupportsGreen . The inspector s identified a non- cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, that occurred when the licensee failed on two occasions to perform an adequate operability determination associated with multiple safety -related pipe supports. Specifically, the operability determination of multiple carbon steel pipe support clamps exposed to boric acid and a bent sway strut pipe restraint lacked the engineering rigor necessary to provide a high degree of confidence to support the operability of the components. Subsequently, the inspector s concluded that the licensee established reasonable expectation for operability once engineering provided the control room with further analysis on the degraded conditions, and the new information was reviewed and accepted. This issue was entered into the licensees corrective action program as Condition Report CR -2017- 05418. The licensee's failure to perform adequate operability determinations per plant procedures 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 System 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 licensee: (1) failed to perform the required corrosion evaluation for a comparison of material wastage against design dimensions of the pipe support clamps; (2) failed to perform a visual inspection of the material condition of the pipe support clamps as required by the work order; ( 3) used non- seismic design tolerances for the qualification of a seismically qualified strut in the immediate operability determination; and (4) failed to consider that the bent condition of the strut occurred after the previously accepted visual examinations on the same pipe support. All these issues could have resulted in safety -related components failing to perform their specified safety function during accident conditions. 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) it was not a design deficiency; (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 technical specification allowed outage time; (4) and did not result in the loss of a high safety - significant non- technical specification train. This finding had a cross -cutting aspect in the area of problem identification and resolution associated with resolution because the licensee failed to adequately assess the degraded condition of the pipe supports in a complete and accurate manner to support a reasonable expectation of operability (P.1).
05000445/FIN-2017002-0430 June 2017 23:59:59Comanche PeakNRC identifiedFailure to Adequately Assess Risk and Implement Risk Management Actions for Proposed MaintenaneGreen. The inspectors identified a non- cited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the licensees failure to adequately assess risk and implement required risk management actions for a planned maintenance activity. Specifically, the licensee failed to evaluate the risk and implement required risk management actions associated with disabling a hazard barrier and breeching the control room envelope when blocking open door E -40A. This issue did not represent an immediate safety concern because, at the time of identification, the licensee stopped the activity and secured the door. The licensee entered this issue into the corrective action program for resolution as Condition Report CR- 2017- 006019. The failure to adequately assess the risk and implement required risk management actions for proposed maintenance activities was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it was associated with the configuration control attribute o f the Barrier Integrity Cornerstone and affected the associated objective to ensure physical design barriers protect the public from radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, dated May 19, 2005, Flowchart 2, Assessment of Risk Management Actions, the inspectors determined the need to calculate the risk deficit to determine the significance of this issue. A senior reactor analyst determined the finding to have very low safety significance (Green) based on combining the effects of the degradation of the radiological barrier and tornado missile barrier functions. The analyst performed a qualitative review of the screening criteria in Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At -Power, for the degradation of the radiological barrier function for the control room and considered the short exposure time (2.9E -5 years) and the Comanche Peak specific high winds frequency (3.0E -4/year) for the tornado missile barrier function of the control room to determine that the incremental core damage probability deficit and the incremental large early release probability deficit were less than 1E -6 and 1E -7, respectively. The finding has a human performance cross -cutting aspect associated with procedure adherence, in that operations personnel failed to follow procedures when allowing door E -40A to be opened
05000445/FIN-2017002-0530 June 2017 23:59:59Comanche PeakNRC identifiedFailure to Translate Design Requirements Into the As Built FacilityGreen. The inspectors identified a non- cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to assure that applicable regulatory requirements and the design bases, as defined in 10 CFR 50.2 and as specified in the license application, for those structure, systems and components to which this appendix applies, were correctly translated into specifications, drawings, procedures, and instructions. Specifically, from initial construction through March 2017, the licensee failed to fully incorporate applicable moderate energy line break design requirements for fire protection piping located in the vicinity of the station service water pumps, the latter which are needed to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition following a moderate energy line break. This issue does not represent an immediate safety concern because when the lines were identified the licensee took prompt action to isolate and depressurize them, and the licensee has implemented plant modifications. The licensee entered this issue into the corrective action program as Condition Report CR -2016- 008147. The failure to incorporate applicable design requirements into specifications for moderate energy line break protection 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. Specifically, from initial construction through March 2017, the licensee failed to fully incorporate applicable design requirements for components needed to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition following a moderate energy line break. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated July 1, 2012, and Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings At -Power , Exhibit 2, Mitigating Systems Screening Questions, dated 5 October 7, 2016, the inspectors determined the finding required a detailed risk evaluation because the finding involved a deficiency affecting the design and qualification of a mitigating structure, system, or component, and resulted in a loss of operability, and represented an actual loss of function of at least a single train for longer than its allowed outage time. A senior reactor analysts from Region IV performed a detailed risk evaluation and determined that the bounding increase in core damage frequency for this issue was 5.1E -8/year for Unit 1 and 2.9E -10/year for Unit 2, and was therefore of very low safety significance (Green ). The inspectors did not assign a cross -cutting aspect because the performance deficiency was not reflective of present performance
05000445/FIN-2017002-0630 June 2017 23:59:59Comanche PeakNRC identifiedUnanalyzed Condition Involving Potential Moderate Energy Line BreakInspection Scope On September 13, 2016, based on initial observations by NRC inspectors, the licensee determined that pressurized fire protection piping in the service water intake structure was not properly shielded for moderate energy line break protection of service water components which resulted in inoperability of one train of service water for both Unit 1 and Unit 2. During extent of condition walk downs conducted on October 6, 2016, October 10, 2016, November 17, 2016, December 5, 2016, and December 22, 2016, additional piping in the Unit 1 and Unit 2 safeguards and auxiliary buildings was found to not be shielded correctly as well, resulting in inoperability of one train of various safety related equipment for both units. The licensee determined the most likely cause of this event was that the methodology used to conduct the initial moderate energy line break walk downs was flawed and allowed some threats to be missed. The licensees corrective actions include shielding the affected piping, performing a 100 percent walk down of rooms containing moderate energy line break piping identified for shielding, and revising the systems interaction program maintenance procedure. These activities constituted completion of one event follow -up sample, as defined in Inspection Procedure 71153. b. Findings Introduction. The inspectors identified a non- cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to assure that applicable regulatory requirements and the design bases, as defined in 10 CFR 50.2 and as specified in the license application, for those structure, systems and components to which this appendix applies, were correctly translated into specifications, drawings, procedures, and instructions. Specifically, from initial construction through March 2017, the licensee failed to fully incorporate applicable design requirements for components needed to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition following a moderate energy line break. Description. On September 13, 2016, inspectors performed walkdowns in the service water intake structure and identified a vertical run of unshielded, pressurized fire protection piping that appeared to pose a moderate energy line break threat to the service water pumps. Inspectors determined that in the event of a moderate energy line break crack along any portion of the unshielded piping, the resultant spray had the potential to impact the function of any one of the four service water pumps. However, only one train would have been affected during the event due to the physical configuration/separation relative to the source line and target pumps and/or associated motor control centers that support pump operation. Inspectors informed the licensee of their concern. Engineering personnel performed a subsequent walkdown of the intake structure and determined that the identified piping was not correctly shielded and operability of the service water pumps was in question. The licensee took immediate action to isolate and depressurize the fire protection line in question which addressed the operability concern. The licensee entered this issue into the station corrective action program as Condition Report CR -2016 -008147 for resolution. Part of the licensees actions was to perform extent of condition walkdowns for unshielded moderate energy piping in the safeguards building for Unit 1 and 2. During the extent of condition walk downs conducted on October 6, 2016, October 10, 2016, November 17, 2016, December 5, 2016, and December 22, 2016, additional piping in the Unit 1 and Unit 2 safeguards and auxiliary buildings was found to not be appropriately shielded against a moderate energy line break, resulting in the inoperability of various safety related equipment for both units. Unit 2 Train B 480 VAC motor control center 2EB2- 1 (Unit 2 Train B emergency core cooling, battery charger, containment spray, and containment isolation valve equipment) Unit 1 Train B 480V MCC 1EB4- 2, and Unit 1 Train B Distribution Panel 1ED2- 2 (Unit 1 Train B safety -related pumps, panels, sequencer, and transformers) Unit 1 Train B 480V MCC 1 EB4- 1 (Unit 1 Train B safety -related pumps, valves, fans, battery chargers, and transformers) Unit 2 Train B 480V MCC 2E134- 1 (Unit 2 Train B safety -related pumps, valves, fans, battery chargers, and transformer) Unit 1, Train B 480V MCC 1E84- 1 (Unit 1 Train B safety -related pumps, valves, fans, battery chargers, and transformers) In each of these instances the licensee took prompt action to isolate and depressurize the identified moderate energy piping pending modification. The licensee subsequently determined that the most probable cause of the issue was the use of a flawed methodology during the initial moderate energy piping walkdowns conducted in 1989. The licensee reported this issue to NRC in Event Report 52239, and Licensee Event Report 16 -002- 00. Analyses. The failure to incorporate applicable design requirements into specifications for moderate energy line break protection 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. Specifically, from initial construction through March 2017, the licensee failed to fully incorporate applicable design requirements for components needed to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition following a moderate energy line break. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated July 1, 2012, and Inspection Manual Chapter 0609, Appendix A , Significance Determination Process for Findings At -Power , Exhibit 2, Mitigating Systems Screening Questions, dated October 7, 2016, the inspectors determined the finding required a detailed risk evaluation because the finding involved a deficiency affecting the design and qualification of a mitigating structure, system, or component, and resulted in a loss of operability, and represented an actual loss of function of at least a single train for longer than its allowed out age time. A senior reactor analysts from Region IV performed a detailed risk evaluation and determined that the bounding increase in core damage frequency for this issue was 5.1E -8/year for Unit 1 and 2.9E -10/year for Unit 2 , and was therefore of very low safety significance (Green). Additional information is included in the detailed risk evaluation in Attachment 3 of this report. The inspectors did not assign a cross -cutting aspect because the performance deficiency was not reflective of present performance. Enforcement. Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in part, that, measures shall be established to assure that applicable regulatory requirements and the design bases, as defined in 10 CFR 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, measures established by the licensee did not assure that applicable regulatory requirements and the design bases, as defined in 10 CFR 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies, were correctly translated into specifications, drawings, procedures, and instructions. Specifically, from initial construction through March 2017, the licensee failed to fully incorporate applicable design requirements for components needed to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition following a moderate energy line break. This issue does not represent an immediate safety concern because when the lines were identified the licensee took prompt action to isolate and depressurize them, and the licensee has implemented plant modifications. Since this violation was of very low safety significance (Green) and has been entered into the corrective action program as Condition Report CR- 2016- 008147, this violation is being treated as a non -cited violation consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000445/2017002 -05; 05000446/2017002- 05, Failure to Translate Design Requirements Into the As Built Facility)
05000445/FIN-2017001-0131 March 2017 23:59:59Comanche PeakNRC identifiedFailure to Maintain B.5.b Equipment in a State of Readiness to Support Mitigation StrategiesGreen. The inspectors identified a non-cited violation of 10 CFR 50.54(hh)(2), Conditions of Licenses, involving the licensees 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 not assign a cross-cutting aspect because the performance deficiency was not reflective of present performance.
05000446/FIN-2017001-0631 March 2017 23:59:59Comanche PeakLicensee-identifiedLicensee-Identified ViolationComanche 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 stations 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 licensees corrective action program as Condition Report CR-2016-009888.
05000445/FIN-2017001-0231 March 2017 23:59:59Comanche PeakNRC identifiedFailure to Evaluate Heat Loads on Control Room Air Conditioning SystemGreen. The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees 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 hours in accordance with the licensees maintenance rule program. The inspectors determined that no cross-cutting aspect was assigned because the performance deficiency was not reflective of present performance.
05000445/FIN-2017001-0331 March 2017 23:59:59Comanche PeakNRC identifiedUse of Non-Design Fouling Factor for Component Cooling Water Heat Exchanger in Station Service Water Tornado Missile CalculationGreen. 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.
05000445/FIN-2017001-0431 March 2017 23:59:59Comanche PeakNRC identifiedFailure to Promptly Correct a Condition Adverse to QualityGreen. The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensees 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 licensees 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 hours in accordance with the licensees 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).
05000445/FIN-2017001-0531 March 2017 23:59:59Comanche PeakLicensee-identifiedLicensee-Identified ViolationTitle 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 licensees 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 licensees corporate security office removed 32 members of the ERO from the licensees 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 licensees corrective action program as CR-2017-001524.
05000445/FIN-2016201-0131 December 2016 23:59:59Comanche PeakNRC identifiedSecurity
05000445/FIN-2016004-0131 December 2016 23:59:59Comanche PeakNRC identifiedFailure to Evaluate Inservice Testing Results of Power Operated Relief ValveGreen. The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XI, Test Control, for the licensees failure to evaluate inservice testing results of a power operated relief valve (PORV). Specifically, the licensee restored a unit 1 PORV to service that did not meet its specified opening time, which resulted in the inoperability of the low temperature overpressure protection (LTOP) system. Following maintenance on PORV 1-PCV-455A during October 2014, the licensee performed stroke time testing on the valve, but failed to recognize that the valve exceeded its test acceptance criteria until it failed again in May 2016. The licensee entered this issue into the corrective action program as CR-2016-003920. The failure to evaluate test results to ensure they met test requirements is a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the Reactor Coolant System Equipment and Barrier Performance attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated October 7, 2016, Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, dated May 9, 2014, and Appendix G Attachment 1, Phase 1 Initial Screening and Characterization of Findings, Exhibit 4, Barrier Integrity Screening Questions, the inspectors determined the finding affected the Barrier Integrity cornerstone and required a detailed risk evaluation because the finding involved the unavailability of a PORV during LTOP operations. Using the assumption that the slow opening time prevents the PORV from fulfilling its LTOP system function, a senior reactor analyst performed a bounding qualitative assessment, using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process. The influential assumptions used by the senior reactor analyst included an exposure time of approximately 9 hours and that the licensee maintained the availability of a single additional relief valve with capability sufficient to mitigate an LTOP event as described in the final safety analysis report. Using these assumptions, the senior reactor analyst determined that a bounding increase in core damage frequency for this issue was 1.45E-8 per year and was therefore, of very low safety significance (Green). The finding has a human performance cross-cutting aspect associated with work management, in that, the licensee failed to ensure that the work process includes the need for coordination with different groups or job activities (H.5).
05000445/FIN-2016201-0231 December 2016 23:59:59Comanche PeakNRC identifiedSecurity
05000445/FIN-2016004-0231 December 2016 23:59:59Comanche PeakNRC identifiedFailure to Scope the Containment Ventilation System in the Maintenance Rule ProgramGreen. The inspectors identified a non-cited violation of 10 CFR 50.65(b)(2) associated with the licensees failure to scope the containment ventilation system into the maintenance rule program. Specifically, the containment ventilation system, a non-safety related system that is relied upon to mitigate accidents or transients and used in emergency operating procedures, was not included in the scope of the monitoring program specified in 10 CFR 50.65(a)(1). In response to this issue the licensee scoped the system in the plants maintenance rule monitoring program, and placed the equipment under 10 CFR 50.65(a)(1) monitoring requirements pending further review. The licensee entered this issue into the corrective action program as CR-2016-008491. The failure to monitor the performance and condition of a system that meets the maintenance rule scoping criteria of 10 CFR 50.65(b)(2) is the 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. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated July 1, 2012, and Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated October 7, 2016, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding affected the Mitigating Systems cornerstone and was of very low safety significance (Green), because the finding did not represent a loss of system function and the system was not designated as high safety-significant in accordance with the licensees maintenance rule program. The finding has a human performance cross-cutting aspect associated with avoiding complacency, in that, the licensee failed to ensure that individuals recognized and planned for the possibility of mistakes and latent issues when re-evaluating the basis for excluding the system (H.12).
05000445/FIN-2016004-0431 December 2016 23:59:59Comanche PeakLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 50 Appendix B, Criterion V, requires, in part, that licensees shall perform activities affecting quality in accordance with instructions appropriate to the circumstances. Contrary to the above, on May 10, 2016, the licensee failed to perform safety chiller maintenance, a quality related activity, in accordance with the approved instructions. Specifically, licensee personnel failed to torque electrical connections on overload relays on the unit 1 train A safety chiller as required by the licensees work instructions. The inadequate torque was present until June 9, 2016, when the licensee performed thermography on the chiller electrical connections. The licensee discovered elevated temperatures, shut down the chiller, and replaced and torqued the affected components. The licensee determined that the chiller was inoperable from May 28, 2016, when it was required to be in service due to the unit entering Mode 4, until the chiller was restored on June 9. The violation is more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone and impacted 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 A, The Significance Determination Process for Findings At-Power, the inspectors determined that the violation required a detailed risk evaluation (DRE) because the finding represented a loss of function of a single train for greater than its technical specification allowed outage time. A senior reactor analyst from Region IV performed the risk evaluation. The licensee provided an analysis demonstrating that the chiller would be able to perform its safety function for at least 24 hours. Based on that demonstration, the analyst was able to determine that the risk was of very low safety significance (Green). The violation was entered into the licensees corrective action program as CR-2016-005798.
05000445/FIN-2016004-0331 December 2016 23:59:59Comanche PeakLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 50.65(a)(2), requires, in part, that monitoring of system performance under 10 CFR 50.65(a)(1) is not required where it has been demonstrated that performance of the system is being effectively controlled through appropriate preventive maintenance. Contrary to the above, from June 2014 to May 2016, the licensee failed to demonstrate that performance of the 480 Volt AC system, a system not being monitored under 10 CFR 50.65(a)(1), was being effectively controlled by preventive maintenance. Specifically, the 480 Volt AC system exceeded the established performance criteria in June 2014, and the licensee failed to evaluate its performance. The licensee discovered in May 2016 through an engineering review that the system had exceeded its criteria in 2014 and should have been placed in (a)(1) monitoring status. The licensee evaluated the system performance and ensured appropriate corrective action had been taken. The violation is more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone and impacted 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 A, The Significance Determination Process for Findings At-Power, the inspectors determined that the violation is of very low safety significance (Green) because the finding did not represent a loss of system or function, and did not represent a loss of function of a single train for greater than its technical specification allowed outage time. The violation was entered into the licensees corrective action program as CR-2016-009963.
05000445/FIN-2016007-0130 September 2016 23:59:59Comanche PeakNRC identifiedFailure to Update Final Safety Analysis Report Section 8.3.1.1.11The inspectors identified a Severity Level IV violation of 10 CFR 50.71(e) which states, in part, that the licensee shall update periodically the final safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. The submittal shall include the effects of all changes made in the facility or procedures as described in the final safety analysis report, or all safety analyses and evaluation performed by the licensee either in support of approved license amendments or in support of conclusions that changes did not require a license amendment in accordance with 10 CFR 50.59 (c)(2). Specifically, from October 9, 2012, to September 29, 2016, the licensee did not include the effects of changes to the K300 voltage relay setpoint or the safety evaluation in submittals to the Final Safety Analysis Report, Section 8.3.1.1.11, that supported the conclusion that the changes did not require a license amendment. In response to this issue, the licensee planned a corrective action to initiate a licensing document change request to update the final safety analysis report. This finding was entered into the licensees corrective action program as Condition Report CR-2016-008177. The inspectors determined that the licensees failure to initiate a Licensing Document Change Request, in accordance with Procedure STA-116, Maintenance of CPNPP Licensing Basis Documents, Operating License conditions and Technical Specifications, Revision 14, Instruction 6.1, to update the Final Safety Analysis Report, Section 8.3.1.1.11, for the setpoint revision of the K300 voltage relays was a performance deficiency. In accordance with Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, this was determined to be a minor performance deficiency. This violation was evaluated using the traditional enforcement process because it had the potential for impacting the NRCs ability to perform its regulatory oversight function. The reactor oversight processs significance determination process does not consider violations that impact the NRCs regulatory oversight function. This violation was determined to be a Severity Level IV violation, consistent with the example in paragraph 6.1.d.3 of the NRC Enforcement Policy, dated August 1, 2016. Specifically, the licensee failed to update the final safety analysis report as required by 10 CFR 50.71(e), but the lack of up-to-date information has not resulted in any unacceptable change to the facility or procedures. The inspectors determined that this violation did not have a cross-cutting aspect because traditional enforcement violations are not assessed for cross-cutting aspects.
05000446/FIN-2016002-0130 June 2016 23:59:59Comanche PeakNRC identifiedFailure to Correct Conditions Adverse to QualityThe inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensees failure to correct a condition adverse to quality in safety-related equipment. Specifically, following an in-service testing failure of auxiliary feedwater check valve 2FW-091 in November 2012, the licensee performed an operability evaluation of the auxiliary feedwater system. However, the inspectors identified that the licensee failed to take corrective action to address the condition adverse to quality that resulted in the valve failing to seat properly. Consequently, the same valve failed a subsequent inservice test in November 2015. Following discovery of this issue, the licensee performed an operability determination that established a reasonable expectation of operability pending implementation of corrective actions. The licensee entered this issue into corrective action program as CR-2015-10961. The licensees failure 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 licensee failed to correct auxiliary feedwater check valve 2FW-0191 failure to seat in November 2012 resulting in an additional failure in November 2015. Using Inspection Manual Chapter (IMC) 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, inspectors determined that this finding was of very low safety significance (Green) because the finding (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality, (2) did not represent a loss of system and/or function, (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time, and (4) did 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 hours in accordance with the licensees maintenance rule program. The finding has a problem identification and resolution cross-cutting aspect associated with evaluation, in that, the licensee failed to thoroughly evaluate issues to ensure that resolutions address extent of conditions. Specifically, the licensee failed to appropriately classify the issue of the check valve not seating and recognize this as a degraded condition (P.2).
05000445/FIN-2016002-0330 June 2016 23:59:59Comanche PeakLicensee-identifiedLicensee-Identified ViolationComanche Peak Unit 1, Operating License NPF-87, 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 78 and as approved in the Safety Evaluation Report and its supplements through Supplement 24. 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 stations approved fire protection program includes Fire Protection Report, Revision 29, Section 5.3.8, Fire Area EO Control Room, includes Deviation 3c-1, Control Room Missile Door, which requires, in part, that since the control room missile door in the west wall is not a three hour rated fire door, the area of the turbine deck within 100 feet of the door is to be void of combustibles. Contrary to the above, on May 5, 2016, the licensee stored combustible materials within 100 feet of the control room missile door in the west wall. Specifically, licensee personnel identified that contractors had stored combustibles within the combustible free zone, and that no compensatory measures had been implemented for the deviation from the Fire Protection Report. The licensee implemented a periodic roving fire watch to compensate for the reduction in fire protection. The violation is more than minor because if left uncorrected, it could lead to a more significant safety concern. 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 licensees corrective action program as CR-2016-004167.
05000445/FIN-2016404-0130 June 2016 23:59:59Comanche PeakNRC identifiedSecurity
05000446/FIN-2016002-0430 June 2016 23:59:59Comanche PeakLicensee-identifiedLicensee-Identified ViolationTechnical Specification 5.4.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Section 9.a., identifies procedures for maintenance as required procedures. Work order 4831032 is a procedure established by the licensee for performing maintenance on diesel generator 2-02. The work order provided instructions for installation of the magnetic speed pickup sensor cable. Contrary to the above, from October 1996 through March 2, 2016, the licensee failed to install the unit 2 diesel generator 2-02 magnetic speed pickup sensor cable in accordance with the approved instructions. Specifically, the speed sensor cable conduit was not fully threaded onto the cable plug. This inadequate installation was present until 2016, when the conduit threaded connection was physically impacted at an undetermined time. The impact caused the conduit connection to break and the conduit to separate from the plug, leaving the cable leads exposed but intact. A licensee technician identified the broken connection during a system walk down on March 2, 2016. The licensee declared the diesel generator inoperable and restored the cable to its design configuration. The licensee analyzed the apparent thread engagement, and determined that, prior to the break in the conduit connection, the cable would have maintained its function in a seismic event, but after the break, the cable function could not be assured. The licensee determined that a failure of the cable would result in the diesel generator exceeding its allowed frequency, but would not result in a diesel generator failure to run. Because the time that the break occurred could not be determined, the diesel generator was assumed to be inoperable at the time of discovery. The violation is more than minor because it affected the configuration control attribute of the Mitigating Systems cornerstone and impacted 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 A, The Significance Determination Process for Findings At-Power, the inspector determined that the violation is of very low safety significance (Green) because the finding did not represent a loss of system or function, and did not represent a loss of function of a single train for greater than its technical specification allowed outage time. The violation was entered into the licensees corrective action program as CR-2016-001941.
05000445/FIN-2016002-0230 June 2016 23:59:59Comanche PeakSelf-revealingFailure to Determine Dose Rates Prior to Allowing Entry into a High Radiation AreaThe inspectors reviewed a self-revealed non-cited violation of Technical Specification 5.7.1.e associated with the licensee allowing a worker access into the 2-077-B penetration valve room, a high radiation area, without an adequate knowledge of the radiological conditions. Specifically, the licensee briefed the worker on the conditions with outdated radiation survey information even though the 2-077-B penetration valve room was subject to changing radiological conditions. As a result, an individual entered areas with general area dose rates of 210 mrem per hour rather than the briefed dose rates of less than 50 mrem per hour. This issue was entered into the licensees corrective action program as Condition Report CR-2015-010211. Corrective actions included performing follow-up radiation surveys and implementing improvements to the high radiation area access control program. The inspectors determined that allowing a worker access into a high radiation without an adequate knowledge of the radiological conditions was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it affected the program and process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation. Specifically, entry into a high radiation area without adequate knowledge of the radiological conditions placed the individual at risk for unnecessary exposure. The finding was assessed using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, issued August 19, 2008, and was determined to be of very low safety significance (Green) because the performance deficiency was not an ALARA planning issue, there was not an overexposure nor substantial potential for an overexposure, and the licensees ability to assess dose was not compromised. The finding has a human performance cross-cutting aspect associated with work management, because the organization failed to implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority (H.5).
05000445/FIN-2016404-0230 June 2016 23:59:59Comanche PeakLicensee-identifiedLicensee-Identified Violation
05000445/FIN-2016403-0131 March 2016 23:59:59Comanche PeakNRC identifiedSecurity
05000445/FIN-2016403-0231 March 2016 23:59:59Comanche PeakLicensee-identifiedLicensee-Identified Violation
05000445/FIN-2016001-0131 March 2016 23:59:59Comanche PeakNRC identifiedFailure to Adequately Evaluate Operability for a Degraded ConditionThe inspectors identified seven examples of a non-cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to perform adequate operability assessments for a degraded or nonconforming condition. Specifically, when vacuum breakers installed in the service water system failed to actuate during surveillance testing, the licensee completed an operability evaluation that relied on judgement, and was contrary to the station design analysis. In particular, the licensee concluded that the vacuum breakers were not required to support operability of the service water system. Following questions from inspectors, the licensee determined that this judgement was not correct and performed a new evaluation to establish operational parameters necessary to ensure operability of the service water system with a failed vacuum breaker. The licensee entered this issue into corrective action program as Condition Report CR-2015-008334. The failure to properly assess and document the basis for operability for a degraded or nonconforming condition 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, service water vacuum breakers failing to open resulted in a condition where structures, systems, and components necessary to mitigate the effects of a column separation event may not have functioned as required. Using Inspection Manual Chapter (IMC) 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, inspectors determined that this finding was of very low safety significance (Green) because the finding (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality, (2) did not represent a loss of system and/or function, (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time, and (4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours in accordance with the licensees maintenance rule program. The inspectors determined that this finding does not have a cross-cutting aspect because the most significant contributor of this finding occurred more than three years ago, and is not indicative of current licensee performance.
05000445/FIN-2015408-0131 December 2015 23:59:59Comanche PeakNRC identifiedSecurity
05000445/FIN-2015005-0131 December 2015 23:59:59Comanche PeakNRC identifiedIncorrect Visual Resolution Requirements in Augmented Dissimilar Metal Weld Visual Examination ProceduresThe inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion IX, Control of Special Processes, because the licensee failed to assure that visual examination activities for the reactor vessel dissimilar metal nozzle welds and bottommounted instrumentation nozzles were accomplished in accordance with the visual acuity requirements of ASME Code Case N-722-1. In response to the issue, for Unit 2, the licensee scheduled reexamination of the welds prior to the end of the outage, and, for Unit 1, performed a reasonable degradation evaluation to determine that reexamination of the welds could be delayed to the next outage. This finding was entered into the corrective action program as Condition Report 2015-009586. The inspectors determined that the failure to assure visual examination activities were accomplished in accordance with the visual acuity requirements of ASME Code Case N-722-1 was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, routinely performing examinations with incorrect visual acuity requirements of N-722-1 has the potential to lead to missed opportunities to identify and correct relevant indications in reactor coolant system pressure boundaries. In accordance with Inspection Manual Chapter MC 0609, Attachment 4, Significance Determination Process Initial Characterization, the inspectors determined that this finding affected the Initiating Events cornerstone as a primary system LOCA initiator contributor. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 1, Initiating Events Screening Questions, the finding screened as having very low safety significance (Green) because after a reasonable assessment of degradation, the finding did not result in exceeding the RCS leak rate for a small LOCA and did not affect other systems used to mitigate a LOCA. The finding does not have a crosscutting aspect because the most significant contributor is not reflective of current licensee performance.
05000445/FIN-2015005-0431 December 2015 23:59:59Comanche PeakNRC identifiedFailure to Identify Conditions Adverse to QualityThe inspectors identified two examples of a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to identify conditions adverse to quality. Specifically, in two separate instances involving extent of condition reviews for grease on 6.9 kV breaker stabs and degraded piping in the Unit 1 service water system, the licensee failed to identify conditions adverse to quality that were reasonably within their ability to identify. As a result, the licensee failed to; 1) identify 24 additional breakers that were in a degraded condition due to grease on secondary stabs, and 2) identify a section of service water piping that was below the ASME minimum wall thickness. 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 these issues into the corrective action program as Condition Reports CR-2015-009992 and CR-2015-010120. The licensees failure to identify conditions adverse to quality for quality related systems was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it affected the equipment performance 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. Specifically, the failure to identify degraded conditions could affect the reliability or availability of multiple safety related systems. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1, Initiating Events Screening Questions, dated June 19, 2012, the finding was determined to be of very low safety significance (Green) because the finding is a deficiency affecting the design or qualification of a mitigating SSC, but the SSC maintained its operability. The finding has a problem identification and resolution cross-cutting aspect associated with evaluation, in that, the licensee failed to thoroughly evaluate issues to ensure that resolutions address extent of conditions. Specifically, the licensee failed to adequately consider the extent of the degraded conditions on similar safety related components (P.2).
05000445/FIN-2015005-0231 December 2015 23:59:59Comanche PeakNRC identifiedFailure to Take Appropriate Maintenance Rule Corrective Actions for the 6.9 kV AC SystemThe inspectors identified a non-cited violation of 10 CFR Part 50.65(a)(1), for the failure to establish goals that provide reasonable assurance that the 6.9 kV electrical distribution system is capable of fulfilling its intended functions. Specifically, the 6.9 kV electrical distribution system had been in maintenance rule (a)(1) status since 2009 due to the failure of breakers to close on demand. Subsequently, in 2013 and 2015 there were additional breaker failures, which exceeded the established performance criteria, and were due to causes not previously evaluated. These additional failures were determined to be due to inadequate maintenance, but the licensee did not re-evaluate the established goals and revise the corrective actions to address these additional failures. The licensee implemented corrective actions to re-evaluate the goals and corrective actions for the 6.9 kV AC system. The licensee entered this issue into the corrective action program as Condition Report CR-2015-009077. The licensees failure to evaluate existing goals and corrective actions for a system that did not meet established performance goals was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it affected the equipment performance 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. Specifically, the failure to take appropriate corrective actions adversely affected the reliability of a system scoped in the plant's maintenance rule program. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the finding was determined to be 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 hours in accordance with the licensees maintenance rule program. The finding has a human performance cross-cutting aspect associated with procedure adherence, in that, the licensee failed to follow maintenance rule implementing procedures. (H.8).