IR 05000220/2005005

IR 05000220-05-005, 05000410-05-005; 10/01/2005 -12/31/2005; Nine Mile Point Nuclear Station, Units 1 and 2; Routine Integrated Report

ML060240297
Person / Time
Site:	Nine Mile Point
Issue date:	01/24/2006
From:	James Trapp Reactor Projects Branch 1
To:	O'Connor T Nine Mile Point
Trapp J RGN-I/DRP/PB1/610-337-5186
References
IR-05-005
Download: ML060240297 (31)

Text

ary 24, 2006

SUBJECT:

NINE MILE POINT NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000220/2005005 and 05000410/2005005

Dear Mr. OConnor:

On December 31, 2005, the US Nuclear Regulatory Commission (NRC) completed an inspection at your Nine Mile Point Nuclear Power Station Unit 1 and Unit 2. The enclosed inspection report documents the inspection results, which were discussed on January 17, 2006, with Mr. Nicola Conicella and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

James M. Trapp, Chief Projects Branch 1 Division of Reactor Projects Docket No.: 50-220, 50-410 License No.: DPR-63, NPF-69 Enclosure: Inspection Report 05000220/2005005 and 05000410/2005005 w/Attachment: Supplemental Information

SUMMARY OF FINDINGS

IR 05000220/2005-005, 05000410/2005-005; 10/01/2005 -12/31/2005; Nine Mile Point Nuclear

Station, Units 1 and 2; Routine Integrated Report.

The report covered a 3-month period of inspection by resident inspectors, and two announced inspections by region-based inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

Licensee-Identified Violations

None.

iii

REPORT DETAILS

Summary of Plant Status

Nine Mile Point (NMP) Unit 1 began the inspection period at 100 percent power and operated at full power for the entire report period with the exception of small power maneuvers for routine online maintenance on recirculation pump motor generators and control rod pattern adjustments.

NMP Unit 2 began the inspection period at 100 percent power and operated at full power for the entire period with the exception of power reductions for reactor feed pump swaps and control rod pattern adjustments.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection (71111.01 - adverse weather preparations - 1 sample)

a. Inspection Scope

The inspectors completed one adverse weather protection sample. The inspectors reviewed the implementation of Unit 1 cold weather preparations. The review included a tour of outdoor facilities, a review of procedures used to test intake water level instrumentation, a walkdown of intake gate equipment, and a verification of items included in the cold weather checklist contained in procedure N1-OP-64, Meteorological Monitoring, Attachment 3, Cold Weather Preparation Checklist. The following areas were examined:

• Unit 1 intake structure and screenhouse; and

• Unit 1 diesel fire pump room.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment (71111.04 - 3 samples,

==71111.04S - 1 sample)

.1 Partial Walkdown

a. Inspection Scope

==

The inspectors performed a partial walkdown of three systems to verify a train was properly restored to service following maintenance or evaluate the operability of one train while the opposite train was inoperable or out-of-service for maintenance and testing. The inspectors compared system lineups to system operating procedures (OPs), system drawings, and the applicable chapters in the Updated Final Safety Analysis Report (UFSAR). The inspectors also verified the operability of critical system components by observing component material condition during the system walkdown and reviewing the maintenance history for each component. Documents reviewed during this inspection are listed in the Attachment. The inspectors performed partial walkdowns of the following systems:

• Unit 1 Division 2 emergency diesel generator (EDG) 103 inspected on November 30, 2005, during on-line maintenance work on the Division 1 EDG 102;

• Unit 1 Division 1 EDG 102 inspected on December 8, 2005 following restoration from maintenance activities to replace generator brushes and DC supply fuses in the field flash circuit; and

• Unit 2 high pressure core spray (HPCS) EDG inspected on November 8, 2005, following restoration from planned maintenance during the week of October 24, 2005.

.2 Complete Walkdown

a. Inspection Scope

The inspectors conducted one complete walkdown of the Unit 2 service water (SW)system to identify discrepancies between the existing equipment lineup and the specified lineup. During the walkdown system drawings and OPs were used to verify proper equipment alignment and operational status. The inspectors reviewed the open maintenance work orders (WOs) on the system for any deficiencies that could affect the ability of the system to perform its function. Documentation associated with unresolved design issues such as temporary modifications, operator work-arounds, and items tracked by plant engineering were also reviewed to assess their collective impact on system operation. In addition, the inspectors reviewed the condition report (CR)database to verify that equipment alignment problems were being identified and appropriately resolved. Documents reviewed for this inspection are listed in the

.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

Fire Protection - Tours

a. Inspection Scope

The inspectors toured nine areas important to reactor safety on the NMP site to evaluate NMP Nuclear Station (NMPNS) control of transient combustibles and ignition sources and the material condition, operational status, and operational lineup of fire protection systems including detection, suppression and fire barriers. The inspectors used procedure GAP-INV-02, Control of Material Storage Areas, the fire hazards analysis and pre-fire plans in performing the inspection. The areas inspected included:

• Unit 1 EDG 102 Room;

• Unit 1 EDG 103 Room;

• Unit 1 Powerboard 102 Room;

• Unit 1 Powerboard 103 Room;

• Unit 1 Turbine Building 261 ft elevation;

• Unit 1 Control Room;

• Unit 2 Reactor Building (RB) 175 ft elevation;

• Unit 2 RB 215 ft elevation; and

• Unit 2 RB 261 ft elevation.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures (71111.06 - external flooding - 1 sample)

External Flooding

a. Inspection Scope

The inspectors completed one external flood protection inspection sample. The inspectors reviewed the Individual Plant Examination and UFSAR for Unit 1 and 2 concerning external flooding events at the NMP site. The inspection included a walkdown of accessible areas of the plant perimeter to look for potential susceptibilities to external flooding and verify the assumptions included in the sites external flooding analysis.

b. Findings

No findings of significance were identified.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors completed one annual heat sink performance inspection sample by reviewing containment spray (CS) heat exchanger (HX) performance. This review was performed using the engineering basis for an emergency technical specification (TS)amendment to increase maximum allowed lake water temperature at NMP Unit 1 from 81EF to 83EF. The review also included the most recent CS HX performance tests.

These tests were performed in accordance with NMPNS test procedure N1-TTP-CTNSP-V001A, HTX-80-34 (#111) Heat Removal Capacity Test. The inspectors also discussed the HX performance monitoring program with both the licensing and mechanical design staff.

The methods used by NMPNS to ensure heat removal capabilities for all four CS HX were reviewed and compared to commitments made in response to Generic Letter 89-13, SW System Problems Affecting Safety-Related Equipment. Test methodology and results of HX performance testing were reviewed and verified to be consistent with accepted industry practices and guidance. Also, the inspectors determined that test conditions were consistent with the chosen test method and that acceptance criteria were consistent with design basis values. Additionally, the inspectors reviewed methods for controlling biofouling and monitoring for zebra mussel growth to verify that they were implemented effectively.

The inspectors walked down the Unit 1 CS HXs to assess the general material condition of the selected HXs. Also, the inspectors reviewed a sample of CRs related to the selected HXs. This review was done to ensure that problems related to these components were appropriately identified, characterized, and corrected.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

Biennial Review

a. Inspection Scope

The following inspection activities were performed using NRC NUREG-1021, Rev. 9, Operator Licensing Examination Standards for Power Reactors, Inspection Procedure 71111.11, Licensed Operator Requalification Program, and NRC Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process (SDP), as acceptance criteria. Documents reviewed during this inspection are listed in the Attachment.

The inspectors reviewed Unit 1 and Unit 2 operating examination material for two weeks. Unit 2 written examinations were reviewed for the same two weeks; no written examination was administered at Unit 1 this year. Six scenarios and simulator job performance measures (JPMs) for one operations and one staff crew plus plant JPMs for one operations crew were observed. All observed examinations were on Unit 2.

Corrective action status and adequacy was reviewed for simulator deficiencies identified on both units during the last requalification program inspection. Corrective action for an SDP Green finding concerning inadequate modeling had been adequately completed on Unit 1 (emergency condenser capacity test). Adequacy was determined by review of simulator test Jan 2004 EC Capacity Test Comparison Plant vs. Simulator 4/2004."

Corrective action was still in progress for a Unit 2 discrepancy concerning reactor vessel level transient response. Circumstances were reviewed for unresolved item (URI)2004005-04 concerning use of a software utility rather than plant controls for rod withdrawal for some simulator tests, contrary to American National Standards Institute (ANSI) standard requirements.

The inspectors reviewed a probabilistic risk assessment (PRA) executive summary and significant tasks, and noted that NMPNS was easily able to generate a cross reference of such tasks to training material addressing them. A detailed comparison of facility exam material development guidance to NRC examination standards was performed.

The inspectors reviewed CRs dealing with operator performance for adequacy of evaluation and corrective action.

On December 14, 2005, the inspectors performed an in-office review of NMPNS requalification exam results. For Unit 1, the results are for the operating test only, no written test was administered this year. For Unit 2, results are for the full exam. The inspection assessed whether pass rates were consistent with the guidance of NRC Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process (SDP).

Unit 1

• Crew failure rate on the dynamic simulator was less than 20%.

(Failure rate was 0%.)

• Individual failure rate on the dynamic simulator test was less than or equal to 20%. (Failure rate was 0%.)

• Individual failure rate on the walk-through test JPMs was less than or equal to 20%. (Failure rate was 0%.)

• Individual failure rate on the comprehensive biennial written exam was less than or equal to 20%. (Not applicable, no written exam administered this year)

• More than 75% of the individuals passed all portions of the exam (100% of the individuals passed all portions of the exam).

Unit 2

• Crew failure rate on the dynamic simulator was less than 20%.

(Failure rate was 0%.)

• Individual failure rate on the dynamic simulator test was less than or equal to 20%. (Failure rate was 0%.)

• Individual failure rate on the walk-through test JPMs was less than or equal to 20%. (Failure rate was 0%.)

• Individual failure rate on the comprehensive biennial written exam was less than or equal to 20%. (Failure rate was 0%.)

• More than 75% of the individuals passed all portions of the exam (100% of the individuals passed all portions of the exam).

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed performance-based problems involving the selected in-scope structures, systems, or components (SSCs) to assess the effectiveness of the maintenance program. Reviews focused on: proper maintenance rule (MR) scoping in accordance with 10 CFR 50.65; characterization of reliability issues; changing system and component unavailability; 10 CFR 50.65 (a)(1) and (a)(2) classifications; identifying and addressing common cause failures, trending key parameters, and the appropriateness of performance criteria for SSCs classified (a)(2) as well as the adequacy of goals and corrective actions for SSCs classified (a)(1). The inspectors reviewed system health reports, maintenance backlogs, and MR basis documents. The following four MR samples were reviewed:

• Unit 1 EDG 102 performance related to the voltage regulator failure during monthly surveillance testing on October 24;

• Unit 1 fire protection system performance;

• Unit 1 instrument air system performance; and

• Unit 2 SW system performance.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed risk assessments for ten work weeks during the inspection period. The inspectors verified that risk assessments were performed in accordance with GAP-OPS-117, Integrated Risk Management, that risk of scheduled work was managed through the use of compensatory actions and schedule adherence, and that applicable contingency plans were properly identified in the integrated work schedule.

Documents reviewed for the inspection are listed in the Attachment. The following work weeks were reviewed.

Unit 1

• Week of October 3, 2005, that included uninterruptible power supply (UPS) 172A calibrations while reactor trip bus MG-131 was out of service;

• Week of October 10, 2005, that included EDG 103 out of service

• Week of October 24, 2005, that included an emergent EDG 102 maintenance outage following a monthly surveillance test failure;

• Week of November 7, 2005, that included EDG 103 surveillance testing and reactor trip bus MG-131 troubleshooting and repair;

• Week of November 14, 2005, that included high pressure coolant injection (HPCI) system pump and valve operability testing and emergent 345 kilovolt (kV)switchyard repairs;

• Week of December 5, 2005, that included emergent diesel fire pump troubleshooting and maintenance and planned maintenance on station battery charger 171B; and Unit 2

• Week of October 24, 2005, that included HPCS pump and valve surveillance testing and a HPCS EDG maintenance outage;

• Week of November 7, 2005, that included reactor core isolation cooling (RCIC)system maintenance and testing;

• Week of November 14, 2005, that included reactor feed pump A seal replacement, RB closed loop cooling (RBCLC) pump B planned maintenance, and reactor protection system UPS-3A maintenance; and

• Week of December 5, 2005, that included RB ventilation unit cooler preventive maintenance (PM), station battery charger replacements, C SW planned maintenance and anticipated transient without scram (ATWS) instrumentation functional testing.

b. Findings

No findings of significance were identified.

1R14 Operator Performance During Non-Routine Evolutions and Events (71111.14 - 1

sample)

a. Inspection Scope

The inspectors assessed operator performance during one non-routine evolution as described below. The event was reported in Licensee Event Report (LER)05000220/2005-002-00. During the inspection the inspectors reviewed operator logs and interviewed operators and plant management to determine what occurred, how the operators responded, and if the response was in accordance with plant procedures and management expectations.

• On April 14, 2005, NMPNS began core reload during Unit 1 refueling outage 18.

TS 3.5.3.b specified that during core alterations two source range monitors (SRMs) be operable, one in and one adjacent to any quadrant where fuel was moved. After operations placed the first fuel assembly in the same quadrant as the 12 SRM, the expected count rate did not result on the 12 SRM. Operations halted fuel movement and began troubleshooting. Maintenance determined that the 12 SRM detector cable was not connected to the instrument drawer; therefore, the SRM in the quadrant where fuel was moved was inoperable, resulting in a violation of TS 3.5.3.b. The other three SRMs were operable at the time of this event, and because all control rods were fully inserted and this was the first fuel assembly placed in the quadrant containing SRM 12, there was no potential for an inadvertent criticality. Section 4OA3 contains additional information regarding the closeout of this LER.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed operability determinations to assess the acceptability of the evaluations; the use and control of compensatory measures, when needed; and compliance with TSs. The inspectors review included a verification that the operability determinations were made as specified by procedure S-ODP-OPS-0116, Operability Determinations. The technical adequacy of the determinations was reviewed and compared to the TSs, UFSAR, and associated design basis documents (DBDs). The following seven evaluations were reviewed:

• CR-2-2003-02968 concerning SW check valve back leakage;

• CR-1-2003-02968 concerning SW and emergency service water (ESW) pump operability under high ambient temperature conditions;

• CR-1-2005-3885 concerning 112 chiller/control room emergency ventilation;

• CR-1-2005-4104 concerning both trains of the RB emergency ventilation system (RBEVS) inoperable concurrently;

• CR-2005-4252 concerning EDG 102 failure to reach rated voltage during the monthly surveillance test and subsequent instrumented run;

• CR-2005-4285 concerning the fact that degraded undervoltage relay reset values were higher than post contingency voltage values; and

• CR-2005-4328 concerning the fact that accuracy of the test equipment used for the degraded undervoltage relays for the 4.16 kV emergency busses did not meet calculation accuracy requirements.

b. Findings

No findings of significance were identified.

1R16 Operator Work-Arounds (71111.16 - cumulative assessment - 2 samples, specific

review - 1 sample)

.1 Cumulative Assessment

a. Inspection Scope

The inspectors completed the following two operator work-around inspection samples:

• The inspectors evaluated the cumulative effects of identified operator work-arounds, burdens, and control room deficiencies on the functionality of mitigating systems at Unit 1. The work-arounds were reviewed to determine the effect on the functional capability of affected systems and operator performance during plant transients and accidents. The inspectors verified that all identified problems were captured in the corrective action program (CAP), and also reviewed NMPNS assessment of the cumulative effects of the identified work-arounds at Unit 1 in accordance with NAI-REL-02, Workaround Program.

• The inspectors evaluated the cumulative effects of identified operator work-arounds, burdens, and control room deficiencies on the functionality of mitigating systems at Unit 2. The work-arounds were reviewed to determine the effect on the functional capability of affected systems and operator performance during plant transients and accidents. The inspectors verified that all identified problems were captured in the CAP, and also reviewed NMPNS assessment of the cumulative effects of the identified work-arounds at Unit 2 in accordance with NAI-REL-02, Workaround Program.

.2 Specific Review

a. Inspection Scope

• The inspectors performed a detailed review of the NMPNS-identified operator work-around associated with operation of the RBCLC expansion tank level control valve 2CCP-AOV120. The work-around was reviewed to determine its affect on the functional capability of RBCLC and operator performance during plant transients and accidents. The inspector also verified that corrective actions to address the identified work-around were tracked by the corrective action or work management programs.

b. Findings

No findings of significance were identified.

1R17 Permanent Plant Modifications

a. Inspection Scope

The inspectors reviewed one permanent plant modification, replacement of the Unit 2 Division I and II DC power system battery chargers. This modification was performed under equivalency evaluation (EE) 01256 and associated implementing WOs for the two redundant 100 percent capacity battery chargers in each division. The inspectors verified the adequacy of EE 01256, and verified that the design and licensing bases requirements of the system were not degraded during the associated work activities.

The inspectors also verified that post-modification testing adequately demonstrated continued reliability and satisfactory performance of the battery chargers. The inspectors performed a partial system walkdown to verify the modification was implemented as planned.

b. Findings

No findings of significance were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

The inspectors reviewed post maintenance test procedures and associated testing activities for selected risk significant mitigating systems to assess whether the effect of maintenance on plant systems was adequately addressed by control room and engineering personnel. The inspectors verified that test acceptance criteria were clear, demonstrated operational readiness and were consistent with design basis documents; that test instrumentation had current calibrations and the range and accuracy for the application; and that tests were performed, as written, with applicable prerequisites satisfied. Upon completion, the inspectors verified that equipment was returned to the proper alignment necessary to perform its safety function. The adequacy of the identified post-maintenance testing requirements were verified through comparisons with the recommendations of GAP-SAT-02, Pre/Post-Maintenance Test Requirements, and the design basis documentation contained in the TSs, UFSAR and associated design basis documentation. The following eight post maintenance test activities were reviewed:

• EDG 102 failed to achieve rated voltage during the monthly surveillance test.

The cause of the failure was determined to be a failed 53D-X relay in the voltage regulator. The relay microswitches were replaced. The retest was performed by verifying that 102 EDG met the speed and voltage acceptance criteria of N1-ST-M4A, Emergency Diesel Generator 102 and PB 103 Operability Test.

• Planned maintenance was performed on 11 feedwater pump components including check valve 51-42. The retest was performed by verifying that the 11 feedwater pump met the acceptance criteria for check valve reverse flow in Section 8.3 of N1-ST-Q3, High Pressure Coolant Injection Pump and Check Valve Operability Test.

• MG-131 tripped during routine manual scram testing. Trouble shooting determined that time delay relays in the voltage regulator needed adjustment.

The retest was performed by verifying that the motor generator (MG)successfully carried load during N1-ST-W15, Manual Scram Instrument Channel Test.

• Planned maintenance was performed on 102 EDG components including breaker inspections, governor replacement, valve maintenance and relay maintenance. The retest was performed by verifying 102 EDG met the acceptance criteria of procedure N1-ST-V18A, Emergency Diesel Generator 102 Simulated Loss of Power Auto Start and Operability Test.

• Control room ventilation damper 210-08 failed to isolate as required during performance of the monthly surveillance. Fix-it-now personnel replaced a solenoid on the air-operated valve. The retest was performed by verifying the valve operated as required to isolate control room ventilation during performance of N1-ST-M9, Control Room Air Treatment System Operability Test.

• WO 05-15567-00 checked the alignment and re-torqued the foundation bolts on the Unit 2 B RBCLC pump during the week of October 31, 2005. The retest was performed by verifying B RBCLC pump vibration measurements in accordance with procedure N2-IST-VIB-@001, Vibration Measurements. The testing results were unsatisfactory and CR-2005-4448 was written to address the high vibrations.

• WO 04-08997-00 replaced Unit 1 emergency cooling system keep full check valve CKV-39-166 the week of 10/31/2005. The retest was performed in accordance with N1-ST-Q5, Primary Containment Isolation Valve Operability Test.

• WO 05-02135-00 performed PM on the HPCS switchgear room unit cooler 2HVC*UC102 supply breaker the week of October 24, 2005. The retest involved cycling the breaker and running the unit in accordance with Attachment 3 of N2-EPM-GEN-V781, Unit Cooler/Air Handling Unit P.M.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors witnessed performance of and/or reviewed test data for six risk-significant surveillance tests (STs) to assess whether the SSCs tested satisfied TS, UFSAR, and NMPNS procedure requirements. The inspectors verified that test acceptance criteria were clear, demonstrated operational readiness and were consistent with the design basis documents; that test instrumentation had current calibrations and the range and accuracy for the application; and that tests were performed, as written, with applicable prerequisites satisfied. Upon ST completion, the inspectors verified that equipment was returned to the status specified to perform its safety function.

Documents reviewed for this inspection are listed in the attachment. The following six STs were reviewed:

• N1-ST-Q1B, CS 121 Pump Valve and Shutdown Cooling System (SDC) Water Seal Check Valve Operability Test;

• N1-ST-Q1A, CS 111 Pump Valve and SDC Water Seal Check Valve Operability Test, with N1-ST-M6, CS Keep Fill System Verification Test;

• N1-ST-Q16A, EDG 102 Quarterly Test;

• N1-ISP-201-022, Drywell Water Detection System Instrument Channel Test;

• N2-OSP-CSH-Q@002, HPCS Pump and Valve Operability and System Integrity Test; and

• N1-ISP-040-001, Core Spray Header Differential Pressure Instrument Channel Test/Calibration.

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications

a. Inspection Scope

The inspectors completed one temporary modification inspection sample. For the Unit 1 temporary change package N1-05-192 regarding the Unit 1 reactor protection system MG-131 overvoltage timing modification, the inspectors assessed the adequacy of the 10 CFR 50.59 evaluations; verified that the change did not adversely affect the systems ability to perform its design functions as described in the UFSAR and TS; that the installation was consistent with the modification documentation; that the drawings and procedures were updated as applicable; and that the post-installation testing was adequate.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety [OS]

2OS1 Access Control to Radiologically Significant Areas (71121.01 - 5 samples)

a. Inspection Scope

The inspectors reviewed NMPNS performance indicators (PIs) for the occupational radiation safety cornerstone.

The inspectors reviewed NMPNS self-assessments, audits, LERs, and special reports related to the access control program since the last inspection and determined that identified problems were entered into the CAP for resolution.

The inspectors reviewed CRs related to access controls. Included in this review were high radiation area radiological incidents in high radiation areas <1R/hr that have occurred since the last inspection in this area.

For repetitive deficiencies or significant individual deficiencies in the CAP, the inspectors determined that NMPNS self-assessment activities were also identifying and addressing these deficiencies.

The inspectors reviewed NMPNS documentation packages for all PI events occurring since the last inspection, and determined that none of these PI events involved dose rates >25 R/hr at 30 centimeters or >500 R/hr at 1 meter. For unintended exposures

>100 mrem total effective dose equivalent (TEDE) (or >5 rem skin dose equivalent (SDE) or >1.5 rem lens dose equivalent (LDE)), the inspectors determined that there were no overexposures or substantial potential for overexposure.

The inspectors reviewed CRs issued since the last inspection that found that the cause of the event was due to radiation worker errors; determined that there was no observable pattern traceable to a similar cause; and determined that this perspective matches the corrective action approach taken by NMPNS to resolve the reported problems. The inspectors verified that there was adequate posting and locking of entrances to high radiation areas and very high radiation areas.

The inspectors reviewed CRs issued since the last inspection that found that the cause of the event was radiation protection (RP) technician error; determined that there was no observable pattern traceable to a similar cause; and determined that this perspective matches the corrective action approach taken by NMPNS to resolve the reported problems.

b. Findings

No findings of significance were identified.

2OS2 ALARA Planning and Controls (71121.02 - 2 samples)

a. Inspection Scope

The inspectors reviewed NMPNS self assessments, audits, and special reports related to the as low as reasonably achievable (ALARA) program since the last inspection and determined that the scope and frequency of NMPNSs audit program for all applicable areas under the occupational radiation safety cornerstone met the requirements of 10 CFR 20.1101.

The inspectors determined that identified problems were entered into the CAP for resolution. The inspectors reviewed dose significant post-job reviews and post-outage ALARA report critiques of exposure performance and determined that identified problems were properly characterized, prioritized, and resolved in an expeditious manner.

b. Findings

No findings of significance were identified.

2OS3 Radiation Monitoring Instrumentation (71121.03 - 5 samples)

a. Inspection Scope

The inspectors reviewed NMPNS self-assessments, audits, and LERs and focused on radiological incidents that involved personnel contamination monitor alarms due to personnel internal exposures. For internal exposures >50 mrem committed effective dose equivalent (CEDE), the inspectors determined that the affected personnel were properly monitored utilizing calibrated equipment and that the data was analyzed and internal exposures properly assessed in accordance with NMPNS procedures.

The inspectors reviewed CRs related to exposure significant radiological incidents that involved radiation monitoring instrument deficiencies since the last inspection in this area.

For repetitive or significant individual deficiencies in the CAP the inspectors determined that NMPNS self-assessment activities were also identifying and addressing these deficiencies.

Based on the UFSAR, TS and emergency operating procedures requirements, the inspectors reviewed the status and surveillance records of self-contained breathing apparatus (SCBA) staged and ready for use in the plant; inspected NMPNSs capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions; determined that control room operators and other emergency response and RP personnel were trained and qualified in the use of SCBA; and determined that personnel assigned to refill bottles were trained and qualified for that task.

The inspectors reviewed the qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for three SCBA units currently designated as ready for service; ensured that the specified, periodic air cylinder hydrostatic testing was documented and up to date; and verified that the Department of Transportation specified retest air cylinder markings were in place.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

Cornerstone: Occupational Radiation Safety

• Occupational Exposure Control Effectiveness The inspectors reviewed a listing of LERs for the period January 1, 2005, through November 17, 2005, for issues related to the occupational exposure control effectiveness PI that measures non-conformance with high radiation areas greater than 1R/hr and unplanned personnel exposures greater than 100 mrem TEDE, 5 rem SDE, 1.5 rem LDE, or 100 mrem to the unborn child.

The inspectors determined if any of these PI events involved dose rates >25 R/hr at 30 centimeters or >500 R/hr at 1 meter. If so, the inspectors determined what barriers had failed and if there were any barriers left to prevent personnel access. For unintended exposures >100 mrem TEDE (or >5 rem SDE or >1.5 rem LDE), the inspectors determined if there were any overexposures or substantial potential for overexposure.

Cornerstone: Public Radiation Safety

• RETS/ODCM Radiological Effluent Occurrences The inspectors reviewed a listing of licensee event reports for the period January 1, 2005, through November 17, 2005, for issues related to this PI that measures radiological effluent release occurrences per site that exceed 1.5 mrem/qtr whole body or 5 mrem/qtr organ dose for liquid effluents; or 5 mrads/qtr gamma air dose, 10 mrads/qtr beta air dose; or 7.5 mrems/qtr organ doses from I-131, I-133, H-3 and particulates for gaseous effluents.

b. Findings

No significant findings or observations were identified.

4OA2 Identification and Resolution of Problems

.1 Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As specified by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of all items entered into NMPs CAP. The review was accomplished by accessing the computerized database for CRs and attending CR screening meetings. In accordance with the baseline inspection modules, the inspectors also selected 84 CAP items across the initiating events, mitigating systems, barrier integrity and occupational radiation safety cornerstones for additional follow-up and review. The inspectors assessed NMPNSs threshold for problem identification, the adequacy of the cause analyses, extent of condition review, and operability determinations, and the timeliness of the specified corrective actions. The CRs reviewed are noted in the Attachment.

b. Findings

No findings of significance were identified.

.2 Semi-Annual Review to Identify Trends

a. Inspection Scope

As specified by Inspection Procedure 71152, Identification and Resolution of Problems, the inspectors performed a review of the NMPNS CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment and corrective maintenance issues. To perform the review, the inspectors examined CRs prepared from May 1-November 14, 2005, and select licensee reports from quality assurance audits performed during the third and fourth quarters of calendar year 2005. The inspectors review nominally considered the six-month period of June through December 2005, although some examples expanded beyond those dates when the scope of the trend warranted. The inspectors compared and contrasted the results of their review with the results contained in the NMP third quarter integrated quarterly assessment report.

Corrective actions associated with a sample of the issues identified in the quarterly assessment report were reviewed for adequacy.

b. Assessment and Observations The inspectors did not identify any adverse performance trends that were not already documented in the NMPNS CAP. One of these trends, an adverse trend in resolving equipment and performance deficiencies in the fire protection program area, has been an ongoing issue at NMP. NMP personnel have developed new corrective actions in an effort to improve performance in this area.

.3 Annual Sample - Configuration Control Issues During Unit 1 Refueling Outage 18 (1 -

PI&R sample)

a. Inspection Scope

Numerous equipment configuration control issues challenged plant operations during the 2005 Unit 1 refueling outage (RFO18). NMPNS selected nine of these events for in-depth evaluation under CR-2005-1643, to identify commonalities and develop corrective actions. The inspectors reviewed this CR, as well as the original CRs associated with the individual events.

b. Assessment and Observations No findings of significance were identified. NMPNS determined through a detailed cause analysis that the root cause of the increased incidence of configuration control issues during RFO18 was that management was not effective in reinforcing an appropriate balance between quality and production. Despite managements communication of NMPNS policy, workers perceived that managements true expectations were biased in favor of production over quality. This led to less than adequate use of human performance error prevention tools by workers and a resultant increase in configuration control errors.

NMPNSs corrective action to address the root cause was to conduct training for managers, general supervisors, and front-line supervisors in the area of human performance. The training covered how to effectively communicate expectations to workers in the field and emphasized that outage implementation must be consistent with expressed expectations regarding the use of human performance tools. The inspectors determined based on CR documentation that there were no plans to reinforce the management/supervisor training regarding human performance expectations and effective communication of those expectations to the worker in the field prior to the Unit 2 refueling outage in March 2006. NMPNS initiated CR-2005-5220 to evaluate that issue.

4OA3 Event Followup

1. (Closed) LER 05000220/2005-002-00, Fuel Moved with an Inoperable SRM Due to

Human Error Resulting in a TS Violation.

The event detailed in this LER is discussed in Section 1R14 of this inspection report.

The inspectors reviewed this LER and no findings of significance were identified. The cause of the event was that maintenance personnel failed to follow work instructions to reconnect the lifted leads for the 12 SRM. Reviews of work documentation prior to reload did not identify the discrepancy. The failure to comply with TS 3.5.3.b constituted a violation of minor significance that is not subject to enforcement action in accordance with Section IV of the NRCs Enforcement Policy. This event was entered into the CAP as CR-2005-1692. This LER is closed.

4OA5 Other Activities

(Closed) URI 05000410/2004005-04. NMP Unit 2 Simulator Demonstration of Expected Plant Response to Operator Input and Normal Evolutions Using Only Operator Actions Normal to the Reference Unit.

This item was opened due to the facility use of software utility rather than console controls to pull control rods in order to save time during some simulator testing. This practice did not demonstrate the ability of the simulator to perform these evolutions using only the simulated controls of the reference plant. The facility has discontinued this practice, and the inspectors reviewed a satisfactory startup test performed on the simulator without it. No simulator inadequacies were discovered due to use of the software utility. This issue is therefore closed.

4OA6 Meetings, Including Exit

The inspectors presented the inspection results to Mr. Nicola Conicella and other members of NMPNS management on January 17, 2006. NMPNS acknowledged that no proprietary information was involved.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

NMPNS personnel

J. Gerber, ALARA Supervisor

R. Godley, Manager, Operations

B. Holston, Manager, Engineering Services

J. Hutton, Director of Licensing

A. Julka, CEG, Director, Q&PA

T. Kulczycky, Reliability Engineering

T. Mogren, GS, Design Engineering

T. OConnor, Plant General Manager

G. Perkins, General Supervisor, Engineering Programs

J. Spina, Site Vice President

T. Syrell, Nuclear Regulatory Matters

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed

05000220/2005-002-00 LER Fuel Moved with an Inoperable SRM Due to Human Error Resulting in a TS Violation (4OA3)

05000410/2004005-04 URI NMP Unit 2 Simulator Demonstration of Expected Plant Response to Operator Input and to Normal Conditions Using Only Operator Actions Normal to the Reference Unit (4OA5)