COMANCHE PEAK NUCLEAR POWER PLANT – NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT - December 24, 2013

by Bob Meyer

This inspection report lists 5 violations, two of which are self-identified. One violation is of particular interest because it deals with safety related oil levels. This is great OE to brief the crew on and solicite feedback from equipment operators to ensure understanding.

Violation #1: A Green finding for a failure to follow procedures that required the licensee to perform cause evaluations for maintenance preventable functional failures (MPFFs). Two MPFFs were not evaluated for their causes because a condition report was not generated to perform the evaluation. After identification of this performance deficiency, the licensee generated condition reports to evaluate the two MPFFs for causes.

The licensee’s failure to ensure that cause evaluations were performed for MPFFs as required by procedure was a performance deficiency. This constituted a programmatic weakness in the licensee’s maintenance rule program and corrective action program and resulted in MPFFs not being prioritized and evaluated appropriately for corrective action, which could result in recurring failures.

The finding has a human performance cross-cutting aspect associated with work practices in that licensee supervision failed to define expectations regarding compliance with the maintenance rule and corrective action program procedures (H.4(b)).

Violation #2: A Green NC violation of 10 CFR 50, Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” for the licensee’s failure to provide adequate acceptance criteria for bearing oil level in its residual heat removal pump motors. The team identified two examples of this violation, one of which resulted in pump bearing oil being lowout-of-specification. After identification of this performance deficiency, operations management issued an Operations Shift Order to ensure equipment operators appropriately verified bearing oil levels.

The failure to provide adequate acceptance criteria for an activity affecting quality was a performance deficiency. The performance deficiency was more than minor because it adversely affected the human performance attribute of the mitigating systems cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events.

The finding had a cross-cutting aspect in the corrective action program component of the problem identification and resolution crosscutting area because the licensee had failed to implement a corrective action program with a low threshold for identifying issues to ensure that an issue potentially affecting nuclear safety was promptly identified and fully evaluated (P.1(a)).

Violation #3: A Green NC violation of 10 CFR 50, Appendix B, Criterion III, “Design Control,” for the licensee’s failure to control deviations from quality standards. After identifying that maintenance personnel had failed to ensure that subcomponents of 480-volt switchgear were properly identified and controlled during refurbishment, the licensee failed to document or evaluate where subcomponents of an indeterminate pedigree had been installed in safety-related applications. The licensee took immediate action to confirm the operability of the installed trip units and to determine the scope of the problem.

The finding had a cross-cutting aspect in the corrective action program component of the problem identification and resolution cross-cutting area because the licensee had failed to implement a corrective action program with a low threshold for identifying issues to ensure that an issue potentially affecting nuclear safety was promptly identified and fully evaluated (P.1(a)).

Licensee-Identified Violations

• Title 10 CFR 50, Appendix B, Criterion XVI, “Corrective Action,” requires that measures shall be established to ensure that conditions adverse to quality are promptly identified and corrected. Contrary to this requirement, the licensee failed to promptly identify and correct the continued unreliability of its service water vacuum breakers. The licensee initially identified and documented this violation in CR-2011-007644 and CR-2011-08500. This violation was of very low safety significance because it did not result in the loss of operability or functionality of any system or train.

• Title 10 CFR 50, Appendix B, Criterion VII, “Identification and Control of Materials, Parts, and Components,” requires that measures shall be established for the identification and control of materials, parts, and components.” Contrary to this requirement, the licensee failed to establish measures to identify and control safety-related Amptector trip units. The licensee identified and documented this violation in CR-2009-001000. This violation was of very low safety significance because it did not result in the loss of operability or functionality of any system or train.

Licensee Personnel

D. Ambrose, Corrective Action Program Manager

J. Bain, Equipment Reliability Supervisor

T. Gibbs, Safeteam Manager

T. Hope, Nuclear Licensing Manager

B. Mays, Vice President, Engineering

G. Merka, Regulatory Affairs

B. St. Louis, Manager, Operations Support

B. Thompson, Corrective Action Program Supervisor

H. Winn, Corrective Action Program Manager

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