IR 05000220/2007005

IR 05000220-07-005, 05000410-07-005, on 10/01/07 - 12/31/07, Nine Mile Point Nuclear Station, Units 1 and 2; Operability Evaluations and Refueling and Other Outage Activities

ML080390040
Person / Time
Site:	Nine Mile Point
Issue date:	02/08/2008
From:	Glenn Dentel NRC/RGN-III/DRP/RPB1
To:	Polson K Nine Mile Point
Dentel, G RGN-I/DRP/BR1/610-337-5233
References
IR-07-005
Download: ML080390040 (39)

Text

February 7, 2008

SUBJECT:

NINE MILE POINT NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000220/2007005 and 05000410/2007005

Dear Mr. Polson:

On December 31, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Nine Mile Point Nuclear Station, Units 1 and 2. The enclosed integrated inspection report documents the inspection results discussed on January 11, 2008, with Mr. Sam Belcher 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.

This report documents one self-revealing finding and one NRC-identified finding of very low safety significance (Green). Both of these findings were determined to involve violations of NRC requirements. However, because of their very low safety significance and because they were entered into your corrective action program (CAP), the NRC is treating these findings as non-cited violations in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you contest the non-cited violations noted in this report, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, D.C. 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-001; and the NRC Senior Resident Inspector at Nine Mile Point Nuclear Station.

In accordance with 10 CFR Part 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/

Glenn T. Dentel, Chief Projects Branch 1 Division of Reactor Projects

Docket No.:

50-220, 50-410 License No.: DPR-63, NPF-69

Enclosure:

Inspection Report 05000220/2007005 and 05000410/2007005 w/Attachment: Supplemental Information

cc w/encl:

M. Wallace, President, Constellation Generation J. Heffley, Senior Vice President and Chief Nuclear Officer C. Fleming, Esquire, Senior Counsel, Constellation Energy Group, LLC M. Wetterhahn, Esquire, Winston and Strawn T. Syrell, Director, Licensing, Nine Mile Point Nuclear Station P. Tonko, President and CEO, New York State Energy Research and Development Authority J. Spath, Program Director, New York State Energy Research and Development Authority P. D. Eddy, Electric Division, NYS Department of Public Service C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law Supervisor, Town of Scriba T. Judson, Central NY Citizens Awareness Network D. Katz, Citizens Awareness Network

SUMMARY OF FINDINGS

IR 05000220/2007005, 05000410/2007005; 10/01/07 - 12/31/07; Nine Mile Point Nuclear

Station, Units 1 and 2; Operability Evaluations and Refueling and Other Outage Activities.

The report covered a three-month period of inspection by resident inspectors and regional specialist inspectors. Two Green non-cited violations (NCVs) were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review.

The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

An NRC-identified NCV of Unit 2 TS 3.3.6.1, "Primary Containment Isolation Instrumentation," occurred when NMPNS failed to perform Technical Specification (TS) required channel checks of the reactor core isolation cooling (RCIC) room area temperature instruments. This resulted in a failure to detect that the Division 1 instrument was malfunctioning. Immediate corrective actions were to replace the defective temperature instrument and to perform instrument cross-checks as a part of channel checks.

The finding was greater than minor because it resulted in an instrument malfunction not being promptly identified. The finding affected the equipment performance attribute of the Mitigating Systems cornerstone to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The impact of the 2ICS*TE16A malfunction was that it reduced the amount of time that would be available for operators to bypass the RCIC room area high temperature isolation to maintain RCIC operability during a station blackout event. The finding was evaluated in accordance with IMC 0609, Appendix A, and determined to be of very low safety significance (Green) per the SDP Phase one determination because the finding was not a design or qualification deficiency, did not represent a loss of system safety function or safety function of a single train, and did not screen as potentially risk significant due to external events. This finding had a cross-cutting aspect in the area of problem identification and resolution because NMPNS did not identify the inadequate channel checks in a timely manner (P.1.a per IMC 0305). (Section 1R15)

Green.

A self-revealing NCV of Unit 2 TS 5.4, "Procedures," occurred when NMPNS failed to adequately implement procedure GAP-PSH-01, Work Control, while Unit 2 was in the refueling mode. Specifically, an unanticipated loss of shut down cooling (SDC) occurred because operators had not adequately assessed the operational impact of emergent maintenance to test a degraded reactor protection system (RPS)

cable. As a result, establishing the electrical isolation for this maintenance initiated a Division 2 primary containment isolation system (PCIS) Group 5 isolation, which caused the associated isolation valve in the common SDC suction line to close.

Operators promptly recognized the cause and restored shutdown cooling to service.

The finding was greater than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone's objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was evaluated in accordance with IMC 0609, Appendix G, Shutdown Operations Significance Determination Process." The finding was determined to be of very low safety significance (Green) because, although the finding resulted in there being less than one loop of RHR in SDC operation, it did not increase the likelihood of a loss of RCS inventory, degrade the ability to terminate a leak path or add RCS inventory if needed, or degrade the ability to recover decay heat removal.

This finding had a cross-cutting aspect in the area of human performance because NMPNS failed to adequately assess the impact of the emergent work activity on plant operations (H.3.b per IMC 0305). (Section 1R20)

Licensee-Identified Violations

None.

REPORT DETAILS

Summary of Plant Status

Nine Mile Point Unit 1 was operated at full rated thermal power (RTP) throughout the inspection period, with the exception of planned power reductions and recoveries for planned recirculation pump maintenance.

Nine Mile Point Unit 2 began the inspection period at full RTP. On October 12, power was reduced to 87 percent due to a mechanical issue that required the B-condensate booster pump to be secured. The problem was corrected and power was returned to 100 percent on October 13.

On November 3, the reactor was shutdown for a planned outage to remove a defective reactor fuel bundle and clear a partial blockage of the 11 reactor recirculation system jet pump. A reactor startup was performed on November 15 and the unit achieved rated RTP on November 18. The unit was operated at full RTP for the remainder of the inspection period, with the exception of several power reductions and recoveries due to moisture separator reheater equipment malfunctions.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

==1R01 Adverse Weather Protection (71111.01 - Two samples)

a. Inspection Scope

==

The inspectors completed two adverse weather protection samples. The inspectors reviewed and verified NMPNS' completion of the cold weather preparation checklists contained in operating procedures (OPs) N1-OP-64, "Meteorological Monitoring," and N2-OP-102, "Meteorological Monitoring," for Units 1 and 2, respectively. Other documents reviewed during this inspection are listed in the Attachment. The inspectors toured selected areas at Unit 1 and Unit 2 to verify cold weather readiness. Additionally, the inspectors assessed the readiness of the following risk significant systems for cold weather:

• Unit 1 service water and circulating water systems;

• Unit 1 reactor and turbine building ventilation heating systems;

• Unit 2 service water system; and

• Unit 2 emergency diesel generator room ventilation systems.

b. Findings

No findings of significance were identified.

==1R04 Equipment Alignment (71111.04Q - Three samples)

a. Inspection Scope

==

The inspectors performed three partial system walkdowns to verify risk-significant systems were properly aligned for operation. The inspectors verified the operability and alignment of these risk-significant systems while their redundant trains or systems were inoperable or out of service for maintenance. The inspectors compared system lineups to system OPs, system drawings, and the applicable chapters in the updated final safety analysis report (UFSAR). The inspectors verified the operability of critical system components by observing component material condition during the system walkdown. Documents reviewed during this inspection are listed in the Attachment. The inspectors performed partial walkdowns of the following systems:

• Unit 1 liquid poison system 11, during maintenance on liquid poison system 12 (October 31, 2007);

• Unit 1 emergency diesel generator (EDG) 103 and power board 103, during maintenance on EDG 102 and power board 102 (November 28, 2007); and

• Unit 2 Division 1 EDG, while the Division 2 EDG was inoperable due to an emergent equipment malfunction (December 4, 2007).

b. Findings

No findings of significance were identified.

1R05 Fire Protection

a. Inspection Scope

The inspectors toured 12 areas important to reactor safety at NMPNS to evaluate the stations control of transient combustibles and ignition sources, and to examine the material condition, operational status, and operational lineup of fire protection systems including detection, suppression, and fire barriers. Documents reviewed for this inspection are listed in the Attachment. The areas inspected included:

• Unit 1 battery rooms 11 and 12, turbine building (TB) 277 foot elevation;

• Unit 1 TB east general floor area, 277 foot elevation;

• Unit 1 reactor building (RB) east general floor area, 298 foot elevation;

• Unit 1 EDG building power board 102 and 103 rooms;

• Unit 1 emergency condenser isolation valve room, RB 298 foot elevation;

• Unit 1 battery board rooms 11 and 12, TB 261 foot elevation;

• Unit 2 Division 1 EDG room;

• Unit 2 Division 2 EDG room;

• Unit 2 RB 306 foot elevation;

• Unit 2 RB 261 foot elevation;

• Unit 2 feedwater heater bays; and

• Unit 2 main control room.

b. Findings

No findings of significance were identified.

==1R11 Licensed Operator Requalification Program

==

.1 Quarterly Review (71111.11Q - Two samples)

a. Inspection Scope

The inspectors completed two licensed operator requalification training (LORT) program inspection samples. The inspectors assessed the clarity and effectiveness of communications, the implementation of appropriate actions in response to alarms, the performance of timely control board operation, and the oversight and direction provided by the shift manager. During the scenario the inspector also compared simulator performance with actual plant performance in the control room. Documents reviewed for this inspection are listed in the Attachment. The following scenarios were observed:

• On November 27, 2007, the inspectors observed Unit 1 LORT to assess operator and instructor performance during a scenario involving loss of a motor-driven feedwater pump, a stuck open emergency relief valve, a high power anticipated transient without scram, a small loss of coolant accident, and loss of power board 12. The inspectors evaluated the performance of risk significant operator actions including the use of emergency operating procedures (EOPs).

• On November 27, 2007, the inspectors observed Unit 2 LORT to assess operator and instructor performance during a scenario involving loss of a low pressure feedwater heater string, a loss of operating instrument air compressors, closure of the main steam isolation valves with a failure to scram, and service water flooding from the B-RHR heat exchanger. The inspectors evaluated the performance of risk significant operator actions including the use of special operating procedures (SOPs) and EOPs.

b. Findings

No findings of significance were identified.

.2 Biennial Review (71111.11B - Three samples)

a. Inspection Scope

The following inspection activities were performed using NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, Inspection Procedure 71111.11, Licensed Operator Requalification Program, and NRC IMC 0609, Appendix I, Operator Requalification Human Performance SDP, as acceptance criteria.

The inspectors reviewed documentation of operating history since the last requalification program inspection. Documents reviewed included NRC inspection reports and Constellation condition reports (CRs) that involved human performance issues.

The inspectors reviewed three weeks of comprehensive biennial written examinations and simulator scenarios, ten additional scenarios, and one week of job performance measures (JPMs) administered to ensure the quality of these examinations met or exceeded the criteria established in the Examination Standards and 10 CFR Part 55.59.

The inspectors observed the administration of operating examinations to two crews. The inspectors observed the administration of three simulator scenarios for one operating crew and two scenarios for a second crew. The inspectors also observed one set of five JPMs administered to one crew. As part of the examination observation, the inspectors assessed the adequacy of Constellations examination security measures.

The inspectors evaluated the use of feedback in the program by review of lesson plans incorporating plant and industry events, discussion with training personnel, and review of self assessments and feedback forms.

Remedial training was assessed through the review of evaluation records for the past two years, to ensure remediation plans were unique to the individual failures, timely, and effective. Remediation plans were reviewed for four annual examination crew failures (two on each unit) and 11 failures of weekly quizzes or cycle simulator evaluations that occurred in this time period.

Conformance with operator license conditions was verified by reviewing the following records:

• Attendance records for the last two-year training cycle,

• Six Unit 2 and four Unit 1 operator medical records to confirm all records were complete, that restrictions noted by the doctor were reflected on the individuals license and that the examinations were given within 24 months, and

• Proficiency watch-standing and reactivation records for two shifts of Unit 2 active operator licenses for two quarters.

The inspectors observed simulator performance during the conduct of the examinations, and reviewed simulator performance tests and discrepancy reports to verify compliance with the requirements of 10 CFR Part 55.46. Nine Mile Point is committed to the ANSI 3.5-1998 standard. The inspectors reviewed simulator configuration control and performance testing through interviews and the review of: facility simulator procedures; open and closed simulator issue reports and maintenance orders; and the review of test results. Tests reviewed are listed in the Attachment. The inspectors verified that:

Unit 1

• Crew pass rate was greater than 80 percent (Pass rate was 83.3 percent).

• No written examination was administered this year.

• Individual pass rate on the walk-through JPMs was greater than 80 percent (Pass rate was 100 percent).

• More than 75 percent of the individuals passed all portions of the examination (93.1 percent of the individuals passed all portions of the examination).

Unit 2

• Crew pass rate was greater than 80 percent (Pass rate was 83.3 percent).

• Individual pass rate on the written examination was greater than 80 percent (Pass rate was 88.8 percent).

• Individual pass rate on the walk-through JPMs was greater than 80 percent (Pass rate was 100 percent).

• More than 75 percent of the individuals passed all portions of the examination (88.8 percent of the individuals passed all portions of the examination).

b. Findings

No findings of significance were identified.

==1R12 Maintenance Effectiveness (71111.12Q - One sample)

a. Inspection Scope

==

The inspectors reviewed performance-based problems and the performance and condition history of the Unit 1 feedwater and extraction steam systems to assess the effectiveness of the maintenance program. The inspectors reviewed the system to ensure that the stations review focused on proper maintenance rule scoping in accordance with 10 CFR Part 50.65, characterization of reliability issues, tracking system and component unavailability, and 10 CFR Part 50.65 (a)(1) and (a)(2) classification. In addition, the inspectors reviewed the sites ability to identify and address common cause failures and to trend key parameters. The inspectors reviewed the system health report, maintenance backlog, and maintenance rule basis documents. Other documents reviewed for the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

==1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - Seven samples)

a.

==

Inspection Scope

The inspectors evaluated the effectiveness of NMPNS maintenance risk assessments required by paragraph (a)(4) of 10 CFR Part 50.65. The inspectors reviewed equipment logs, work schedules, and performed plant tours to gain assurance that actual plant configuration matched the assessed configuration. Additionally, the inspectors verified that risk management actions for both planned and emergent work were consistent with those described in station procedures. Documents reviewed for the inspection are listed in the Attachment.

The inspectors reviewed risk assessments for the activities listed below.

Unit 1

• Week of November 26, 2007, that included planned maintenance on the 102 EDG and 14 reactor recirculation motor-generator, and a Scriba 345 kV switchyard line 8 outage to support grid-related maintenance.

• Emergent repair work on 12 emergency condenser makeup level control valve (LCV)60-18 on November 28-30, 2007.

• Week of December 24, 2007, that included troubleshooting the cause of a 14 reactor recirculation motor-generator trip, surveillance of loop 111 containment spray system, and replacement of control rod drive system timers.

Unit 2

• Week of October 15, 2007, that included automatic depressurization system and A RHR system quarterly surveillance testing, and emergent maintenance to rebuild the actuator for valve 2RHS*FV38A.

• Week of October 22, 2007, that included planned maintenance on the high pressure core spray (HPCS) system, HPCS quarterly surveillance testing, Division 3 EDG monthly surveillance testing, and placing the RHR system into spent fuel pool cooling assist mode.

• Emergent maintenance following failure of a steam supply valve to the A moister separator reheater (MSR) on November 20, 2007, that led to a power reduction to 85 percent and removal of both MSRs from service.

• Week of December 17, 2007, that included low pressure core spray system quarterly surveillance testing, and planned maintenance on the Division 1 EDG, A RHR system, and Division 1 standby liquid control system.

b. Findings

No findings of significance were identified.

==1R15 Operability Evaluations (71111.15 - Five samples)

a. Inspection Scope

==

The inspectors evaluated the acceptability of the operability evaluations, the use and control of compensatory measures, and the compliance with TSs. The evaluations were reviewed using criteria specified in NRC Regulatory Issue Summary 2005-20, Revision to Guidance Formerly Contained in NRC Generic Letter 91-18, Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability, and Inspection Manual Part 9900, Operability Determinations and Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety. The inspectors review included verification that the operability determinations were made as specified by Procedure CNG-OP-1.01-1002, Conduct of Operability Determinations / Functionality Assessments.

The technical adequacy of the determinations was reviewed and compared to the TSs, UFSAR, and associated design basis documents (DBDs). Documents reviewed for the inspection are listed in the Attachment. The following five evaluations were reviewed:

• CR-2007-6629 concerning Unit 1 EDG 103 output voltage phase differences during monthly testing;

• CR-2007-1277 concerning inadequate qualification basis for 5 kV Okonite T-95 tape splices on Unit 1 core spray and containment spray pump motors;

• CR-2007-6631 concerning Unit 2 reactor protection system cables exposed to excessive heat due to missing main steam line insulation;

• CR-2007-6096 concerning past operability of the Unit 2 Division 1 EDG when one of the cylinder test valves was found open after it had been replaced several weeks earlier; and

• CR-2007-7482 concerning a Unit 2 RCIC room temperature instrument that was indicating higher than the actual room temperature.

b. Findings

Introduction.

An NRC-identified Green NCV of Unit 2 TS 3.3.6.1, "Primary Containment Isolation Instrumentation," occurred when NMPNS failed to perform TS required channel checks of the RCIC room area temperature instruments. This resulted in a failure to detect that the Division 1 instrument was malfunctioning.

Description.

While performing strip chart recorder maintenance on December 8, 2007, I&C technicians noted that the point for the Division 1 RCIC room area temperature, 2ICS*TE16A, was indicating higher than expected at approximately 100º F. The equivalent Division 2 instrument, 2ICS*TE16B, was indicating 77º F. These instruments provide the temperature input to the reactor coolant leak detection system (LDS), to provide automatic isolation of the RCIC steam supply line on high (131.5º F) RCIC room temperature. RCIC room temperature was checked with a pyrometer and verified to be 77º F. 2ICS*TE16A was declared inoperable and the defective temperature switch was replaced later the same day. The issue was entered into the CAP as CR 2007-7482.

TS 3.3.6.1, "Primary Containment Isolation Instrumentation," specifies that a channel check be performed on 2ICS*TE16A and B every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This was being accomplished by recording the indications during shiftly operator rounds. TS 1.1, "Definitions," states that a channel check shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter. However, as of December 8, 2007, such instrument channel cross-checks were not being performed on 2ICS*TE16A and B. The readings were recorded on separate pages of the operator rounds log, and therefore did not lend themselves to formal or informal cross-checks. Review of previous operator rounds logs identified that the 2ICS*TE16A malfunction had occurred more than two months earlier.

The inspectors questioned why the TS-required instrument cross-checks of 2ICS*TE16A and B were not being performed as part of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> channel checks. NMPNS indicated that, at the beginning of licensed operation, they had made a determination that performing instrument cross-checks for area temperature instruments was not practical.

This was based on the possibility that the location of the temperature detectors could be widely separated in the area; this, along with different combinations of ventilation fans and operating equipment would make the instruments indicate inconsistently different, thereby rendering a cross-check meaningless.

However, NMPNS had applied this as a general interpretation for all area temperature instrument channel checks. The inspectors noted that 2ICS*TE16A and B are located adjacent to each other, making a cross-check possible, and therefore, required. The inspectors concluded that NMPNS was not performing channel checks of 2ICS*TE16A and B in accordance with TS requirements. This issue was entered into the CAP as CR 2007-7809. NMPNS implemented instrument cross-checks as a part of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> channel checks of 2ICS*TE16A and B on December 20, 2007.

The performance deficiency associated with this finding was that NMPNS was not performing instrument cross checks as a part of TS required channel checks of 2ICS*TE16A and B.

Analysis.

The finding was greater than minor because it was similar to IMC 0612, Appendix E, example 4.l, in that failure to perform channel checks in accordance with TS requirements resulted in an actual instrument malfunction not being promptly identified.

The finding affected the equipment performance attribute of the Mitigating Systems cornerstone to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The impact of the 2ICS*TE16A malfunction was that it reduced the amount of time that would be available for operators to bypass the RCIC room area high temperature isolation to maintain RCIC operability during a station blackout event. The finding was evaluated in accordance with IMC 0609, Appendix A, and determined to be of very low safety significance (Green) per the SDP Phase one determination because the finding was not a design or qualification deficiency, did not represent a loss of system safety function or safety function of a single train, and did not screen as potentially risk significant due to external events.

This finding had a cross-cutting aspect in the area of problem identification and resolution because NMPNS did not identify the inadequate channel checks in a timely manner (P.1.a per IMC 0305).

Enforcement.

TS 3.3.6.1 and TS Table 3.3.6.1-1, "Primary Containment Isolation Instrumentation," require that a channel check be performed on the RCIC equipment room area temperature instruments every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. TS 1.1, "Definitions," states, in part, that a channel check, "... shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter." Contrary to the above, prior to December 20, 2007, the channel check of RCIC equipment room area temperature instrument 2ICS*TE16A did not include comparison of the channel indication and status to the independent instrument channel measuring the same parameter, 2ICS*TE16B. Because this deficiency is of very low safety significance and has been entered into the CAP (CR 2007-7809), this violation is being treated as an NCV, consistent with Section VI.A of the NRC Enforcement Policy:

NCV 05000410/2007005-01, Inadequate RCIC Room Temperature Channel Checks.

==1R19 Post Maintenance Testing (71111.19 - Eight samples)

a. Inspection Scope

==

The inspectors reviewed the post maintenance tests listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data, to verify that the test results adequately demonstrated restoration of the affected safety functions.

Documents reviewed for this inspection are listed in the Attachment.

• Unit 1, work order (WO) 06-12365-00 that performed preventive maintenance on the 12 liquid poison pump. The retest was performed in accordance with N1-ST-Q8B, Liquid Poison Pump 12 and Check Valve Operability Test.

• Unit 1, Action Request 07-06133 that corrected a problem with EDG 103 output voltage indication. The retest was performed in accordance with N1-ST-M4B, Emergency Diesel Generator 103 and PB 103 Operability Test.

• Unit 1, WO 06-20711-00 that involved performance of biennial preventive maintenance on 102 EDG. The retest was performed in accordance with N1-OP-45, Emergency Diesel Generators, and N1-MPM-GEN-852, Emergency Diesel Generator Engine and Associated Equipment Inspection (ENG-DG102 and ENG-DG103).

• Unit 1, WO 07-14752-00 that repaired leaking emergency condenser level control valve LCV 60-18. The retest was performed in accordance with N1-ST-M2, Emergency Condenser System Makeup Tank Level Control Valves Exercising Test, and also included a universal diagnostic system test.

• Unit 2, WO 07-11886-00 that performed corrective maintenance to rebuild the actuator for valve 2RHS*FV38A. The retest was performed in accordance with N2-OSP-RHS-Q@001, RHR System Loop A Valve and Partial ASME XI Pressure Test.

• Unit 2, WO 07-10867-00 that performed corrective maintenance to rebuild the actuator for valve 2ICS*AOV130. The retest was performed in accordance with N2-OSP-ICS-R003, RCIC Valve Position Indicator Operability Test.

• Unit 2, surveillance test (ST) N2-OSP-RPV-@003, Reactor Pressure Vessel and All Class I Systems Leakage Test with the RPV Solid, performed as retest for reactor vessel reassembly and maintenance on various other reactor coolant system pressure boundary components during planned outage 2P702.

• Unit 2, ST N2-OSP-RMC-@001, Control Rod Drive Scram Insertion Time Testing, for control rods 14-31, 26-31, 22-11, 06-47, and 18-19, performed as retest for maintenance on their associated hydraulic power units during 2P702.

b. Findings

No findings of significance were identified.

==1R20 Refueling and Other Outage Activities (71111.20 - One sample)

==

.1 Unit 2 Mid-Cycle Outage

a. Inspection Scope

The inspectors observed and reviewed the following activities during the Unit 2 mid-cycle outage, 2P702, from November 3 through November 15. Documents reviewed for this inspection are listed in the Attachment.

The inspectors observed portions of the plant shutdown and cooldown and verified that the TS cooldown rate limits were satisfied. The inspectors reviewed outage schedules and procedures and verified that TS-specified safety system availability was maintained, shutdown risk was considered, and that contingency plans existed to restore key safety functions such as electrical power and containment integrity.

The inspectors performed a walkdown of the drywell to identify evidence of reactor coolant system leakage, and verify the condition of drywell coatings, structures, valves, piping, supports, and other equipment. The inspectors also verified that no debris was left in the drywell that could affect the performance of the emergency core cooling system suction strainers.

The inspectors observed portions of the reactor startup following the outage, and verified through plant walkdowns, control room observations, and ST reviews that safety-related equipment specified for mode change was operable.

b. Findings

Introduction.

A self-revealing Green NCV of Unit 2 TS 5.4, "Procedures," occurred when NMPNS failed to implement procedure GAP-PSH-01, Work Control, and correctly assess plant impact of emergent maintenance performed during 2P702. This resulted in an unanticipated loss of shutdown cooling (SDC).

Description.

During the mid-cycle outage, NMPNS identified a section of main steam system piping that did not have insulation installed. As a result, the electrical insulation on several adjacent cables had been damaged by heat (see section 1R15 for operability evaluation). To evaluate the impact of the insulation damage, one of the cables was selected for electrical testing. An activity to megger and continuity test this cable, 2RPSBYX649, was added to the outage maintenance scope as a high priority item.

During maintenance isolation clearance section (tagout) preparation, two licensed reactor operators (ROs) did not identify that this electrical isolation would impact shutdown cooling. An independent review did not identify the impact to the system. It was concluded that the isolation of circuit breaker 2VBS*PNLB103-14 would have no impact on plant operations in the refueling mode, and the package was released for work.

However, breaker 2VBS*PNLB103-14 supplies multiple loads, one of which is portions of the Division 2 reactor coolant LDS. When the breaker was opened to apply the tagout, the Division 2 LDS produced a Group 5 (shutdown cooling) isolation signal. This caused the inboard isolation valve for the common shutdown cooling suction line, 2RHS*MOV112, to close. This, in turn, caused RHR pump (A), which was operating in the shutdown cooling mode, to trip on interlock. Operators promptly identified the cause of the loss of shutdown cooling and reclosed circuit breaker 2VBS*PNLB103-14. Shutdown cooling was restored 11 minutes after it was lost. Minimal RCS heatup occurred, due to the short period of time that SDC was lost, and because the reactor cavity was flooded.

The performance deficiency associated with this finding was NMPNS failed to adequately implement administrative procedure GAP-PSH-01, Work Control. Specifically, operators failed to identify that opening circuit breaker 2VBS*PNLB103-14 would affect operation of shutdown cooling.

Analysis.

The finding was greater than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone's objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was evaluated in accordance with IMC 0609, Appendix G, Shutdown Operations Significance Determination Process." Per the Phase 1 SDP, Checklist 7, BWR Refueling Operation with RCS Level > 23 feet, the finding was determined to be of very low safety significance (Green) because, although the finding resulted in there being less than one loop of RHR in SDC operation, it did not increase the likelihood of a loss of RCS inventory, degrade the ability to terminate a leak path or add RCS inventory if needed, or degrade the ability to recover decay heat removal.

This finding had a cross-cutting aspect in the area of human performance because NMPNS failed to adequately assess the impact of the emergent work activity on plant operations (H.3.b per IMC 0305).

Enforcement.

TS 5.4, "Procedures," 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 includes procedures associated with equipment control (e.g.,

locking and tagging). NMPNS Administrative Procedure GAP-PSH-01, "Work Control,"

Revision 41, Section 3.4, "Work Order Preparation and Planning," states, in part, "Operations planning personnel shall ensure that the plant impact of the work activity is identified and recorded." Contrary to the above, on November 8, 2007, NMPNS Administrative Procedure GAP-PSH-01 was not adequately implemented, in that, the plant impact of opening circuit breaker 2VBS*PNLB103-14 was not correctly identified, which resulted in an unanticipated loss of shutdown cooling. Because this procedural deficiency is of very low safety significance and has been entered into the CAP (CR 2007-6769), this violation is being treated as an NCV, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000410/2007005-02, Loss of Shutdown Cooling due to Inadequate Maintenance Planning.

.2 Review of Operating Experience Smart Sample (OpESS) FY2007-03, Crane and Heavy

Lift Inspection, Supplemental Guidance for IP-71111.20, Revision 1

a. Inspection Scope

The inspectors reviewed the design and licensing basis of the RB polar crane, surveillance and preventive maintenance procedures, and responses to NRC guidance documents to verify an acceptable safety basis for performing reactor vessel head and other heavy load lifts at Unit 2. Documents reviewed for this inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

==1R22 Surveillance Testing (71111.22 - Four samples)

a. Inspection Scope

==

The inspectors witnessed performance of and/or reviewed test data for four risk-significant STs to assess whether the components and systems tested satisfied design and licensing basis requirements. The inspectors verified that test acceptance criteria were clear, demonstrated operational readiness and were consistent with the DBDs; 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 test 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

. The following STs were reviewed:

• N1-ST-Q16A, Emergency Diesel Generator 102 Quarterly Test;

• N1-ST-Q6B, Containment Spray System Loop 121 Quarterly Operability Test;

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

• N2-OSP-MSS-CS001, Main Steam Isolation Valve Operability Test.

b. Findings

No findings of significance were identified.

==1R23 Temporary Plant Modifications (71111.23 - Two samples)

a. Inspection Scope

==

The inspectors verified that systems were maintained within the design basis and system established criteria. The inspectors reviewed the associated 10 CFR Part 50.59 evaluations against the system design bases information, including the UFSAR and TS.

The inspectors verified that the modifications did not affect the operators response to abnormal or emergency conditions. The inspectors verified that post-installation testing was adequate. In addition, the inspectors verified that NMPNS controlled the modifications in accordance with their station procedures and all drawings and procedures were updated as applicable. The following temporary modifications were reviewed:

• ECR 07-05153, Backup Hydrogen Supply and Pressure Regulating Skid Inside the Protected Area; and

• Temporary Alteration 07-06434, "Control Rod 46-35 Position Indication Interim Compensatory Action."

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety (OS)

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

a. Inspection Scope

The inspectors reviewed Constellations self assessments, CRs, audits, licensee event reports (LER) and special reports related to the access control program since the last inspection. The inspectors determined if identified problems were entered into the CAP for resolution. Included in this review were high radiation area radiological incidents (high radiation areas <1R/hr) that have occurred since the last inspection in this area.

Furthermore, for repetitive deficiencies or significant individual deficiencies in problem identification and resolution identified above, the inspectors determined if Constellations self-assessment activities were also identifying and addressing these deficiencies.

The inspectors reviewed Constellations documentation packages for all performance indicator (PI) events occurring since the last inspection. 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.

The inspectors reviewed radiological problem reports attributed to radiation worker errors.

The inspectors determined if there was an observable pattern traceable to a similar cause.

The inspectors determined if this perspective matched the corrective action approach taken by Constellation to resolve the reported problems. The inspectors discussed with the radiation protection manager any problems with the correction actions planned or taken. The inspectors verified adequate posting and locking of entrances to high dose rate high radiation areas, and very high radiation areas.

The inspectors reviewed radiological problem reports attributed to radiation protection technician error. The inspectors determined if there was an observable pattern traceable to a similar cause. The inspectors determined if this perspective matched the corrective action approach taken by Constellation to resolve the reported problems.

The inspectors reviewed work activities in the drywell, refueling floor and balance of plant at Unit 2 associated with mid-cycle maintenance outage 2F702. Specific activities observed included those associated with preparations for fuel sipping and valve inspection/rebuild on 2RCS*MOV18A and 2RSC*MOV18B.

b. Findings

No findings of significance were identified.

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

a. Inspection Scope

Utilizing Constellations records, the inspectors determined the historical trends and current status of tracked plant source terms. The inspectors determined if Constellation was making allowances or developing contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry.

The inspectors evaluated the radiation protection group shielding requests with respect to dose rate reduction problem definition and assigning value. The inspectors evaluated engineering shielding responses and actions taken.

The inspectors determined if work activity planning included consideration of the benefits of dose rate reduction activities such as shielding provided by water filled components/piping, job scheduling, and shielding and scaffolding installation and removal activities.

The inspectors determined if Constellation had developed an understanding of the plant source-term, including knowledge of input mechanisms to reduce the source term. The inspectors determined whether Constellation had a source-term control strategy in place.

The inspectors determined if specific sources have been identified by Constellation for exposure reduction actions and what priorities Constellation had established for implementation of these actions. The inspectors determined what results have been achieved against these priorities since the last refueling cycle. During the current 12-month assessment period, the inspectors determined whether source reduction evaluations have been made and actions have been taken to reduce the overall source-term compared to the previous year.

The inspectors determined if identified problems were entered into the CAP for resolution.

The inspectors reviewed dose significant post-job (work activity) reviews and post-outage as low as is reasonably achievable (ALARA) report critiques of exposure performance.

The inspectors determined if identified problems were properly characterized, prioritized, and resolved in an expeditious manner.

The inspectors reviewed corrective action reports related to the ALARA program. The inspectors interviewed staff and review documents to determine if the follow-up activities were being conducted in an effective and timely manner commensurate with their importance to safety and risk.

b. Findings

No findings of significance were identified.

2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03 - Four samples)

a. Inspection Scope

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

For repetitive deficiencies or significant individual deficiencies in problem identification and resolution identified above, the inspectors determined if Constellations self-assessment activities were also identifying and addressing these deficiencies.

Based on UFSAR, TSs 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. The inspectors reviewed Constellations capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions. The inspectors determined if 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. For the same three units, the inspectors ensured that the required, periodic air cylinder hydrostatic testing was documented and up to date, and the Department of Transportation-required retest air cylinder markings were in place.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

a. Inspection Scope

The inspectors sampled NMPNS submittals for the PIs listed below. To verify the accuracy of the PI data reported during that period, the PI definition guidance contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Indicator Guideline,"

Revision 5, was used to verify the basis in reporting for each data element.

Cornerstone: Initiating Events

The inspectors reviewed LERs and operator logs to determine whether NMPNS accurately reported the number of unplanned power changes greater than 20 percent at Unit 1 and Unit 2 from April 2006 to September 2007.

• Unit 1 and Unit 2 unplanned power changes per 7000 critical hours

Cornerstone: Mitigating Systems

The inspectors completed a review of Mitigating Systems Performance Index (MSPI) data including a review of NMPNS' train/system unavailability data, monitored component demands, and demand failure data. The inspectors also reviewed out-of-service logs, operating logs, and maintenance rule information to determine the accuracy and completeness of the reported unavailability data. Operating data from July 2006 to July 2007 were reviewed to complete this inspection. The MSPIs reviewed were:

• Unit 1 and Unit 2 heat removal system;

• Unit 1 and Unit 2 RHR system;

• Unit 1 and Unit 2 support cooling water system;

• Unit 2 emergency AC power system; and

• Unit 2 high pressure injection system.

Unit 1 and Unit 2 LERs issued between the end of the third quarter 2006 and the end of the third quarter 2007 were reviewed for safety system functional failures.

• Unit 1 and Unit 2 safety system functional failures

Cornerstone: Barrier Integrity

The inspectors reviewed operator logs, plant computer data, and daily sampling and surveillance procedure results to verify the accuracy of NMPNS' reported reactor coolant system performance indicators from April 2006 to June 2007.

• Unit 1 and Unit 2 reactor coolant system leak rate

• Unit 2 reactor coolant system specific activity

Cornerstone: Occupational Radiation Safety

The inspectors reviewed Constellations PIs for the Occupational Exposure Cornerstone for follow-up. The inspectors reviewed a listing of Constellations CRs for the period January 1, 2007 through November 4, 2007 for issues related to the occupational radiation safety PI, which measures non-conformances with high radiation areas greater than 1R/hr and unplanned personnel exposures greater than 100 mrem total effective dose equivalent (TEDE), 5 rem skin dose equivalent (SDE), 1.5 rem lens dose equivalent (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: Physical Protection

The inspectors reviewed Constellations PI data for gathering, processing, evaluating, and submitting data for the Fitness-for-Duty, Personnel Screening, and Protected Area Security Equipment Performance Indicators (PIs) for the period July 2006 through June 2007. The inspectors verified that the PIs had been properly reported as specified in NEI 99-02. The review included Constellations tracking and trending reports, personnel interviews, and security event reports for the PI data collected since the last security baseline inspection. The inspectors noted from Constellations submittal that there were no reported failures to properly implement the requirements of 10 CFR 73 and 10 CFR 26 during the reporting period.

Security PIs were inspected during the annual security baseline inspection and the documentation was inadvertently omitted from the security baseline inspection report issued previously in 2007.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems (71152 - Four samples)

.1 Review of Items Entered into the CAP

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 items entered into Nine Mile Points CAP. In accordance with the baseline inspection modules, the inspectors also identified selected CAP items across the initiating events, mitigating systems, and barrier integrity cornerstones for additional follow-up and review. The inspectors assessed Constellations threshold for problem identification, the adequacy of the cause analyses, extent of condition review, operability determinations, and the timeliness of the specified corrective actions.

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 reviewed NMPNS's CAP and associated documents to identify trends that could indicate significant safety issues. The inspectors' review focused on repetitive equipment and corrective maintenance issues but also considered the results of daily inspector CAP item screening. The review included issues documented outside the normal CAP in system health reports, quality assurance performance assessment reports, maintenance rule status reports, department quarterly review reports, and the 2007 top ten material condition list. The inspectors' review considered the six month period of June 2007 through November 2007. Documents reviewed for this inspection are listed in the

.

b.

Assessment and Observations

No findings or observations of significance were identified.

.3 Annual Sample - Unit 1 Operator Workarounds

a. Inspection Scope

The inspectors reviewed Unit 1 operator workarounds to verify the NMPNS was identifying operator workaround problems at an appropriate threshold and entering them into the CAP. The inspectors evaluated the potential for cumulative effects of identified operator workarounds, burdens, and control room deficiencies on the functionality of mitigating systems.

b.

Assessment and Observations

No findings or observations of significance were identified.

.4 Annual Sample - Unit 2 Operator Workarounds

a. Inspection Scope

The inspectors reviewed Unit 2 operator workarounds to verify the NMPNS was identifying operator workaround problems at an appropriate threshold and entering them into the CAP. The inspectors evaluated the potential for cumulative effects of identified operator workarounds, burdens, and control room deficiencies on the functionality of mitigating systems.

b.

Assessment and Observations

No findings or observations of significance were identified.

.5 Annual Sample - Review of Corrective Actions for NRC-Identified Green NCV Regarding

Improper RCIC Alignment During Maintenance Activities

a. Inspection Scope

The inspectors selected NCV 05000410/2006003-01, RCIC Alignment During Maintenance Not Consistent With Design Bases, for detailed review. This NRC-identified Green NCV was documented in section 1R15 of NRC Integrated Inspection Report 05000220/2006003 and 05000410/2006003. NMPNS entered this issue into the CAP as CR 2006-0545. NMPNS also reported the issue to the NRC in LER 05000410/2006002 on July 25, 2006. The NCV involved operators isolating a RCIC system turbine exhaust vacuum breaker line to the torus while maintaining RCIC aligned for automatic initiation.

This configuration prevented the vacuum breakers from mitigating a water hammer event that could occur following RCIC shutdown. The water hammer could produce stresses in the RCIC steam exhaust line that exceed ASME code-allowable values during certain scenarios. The inspectors reviewed NMPNS corrective actions to address this Green NCV. The inspectors also interviewed NMPNS staff.

b.

Assessment and Observations

No findings of significance were identified. The inspectors determined that NMPNS performed a thorough review of the issue and implemented timely and appropriate corrective actions to prevent recurrence. The corrective actions were aligned with a root cause analysis and included procedure and maintenance work order revisions, improved training to operators and engineering personnel on water hammer mechanisms, and operating experience program improvements. NMPNS also reviewed all systems at NMP Unit 1 and Unit 2 to identify other potential system configuration and procedure issues that could jeopardize design features intended to eliminate water hammer. NMPNS identified an additional issue regarding the design basis for timing of the closure of the RCIC vacuum breaker isolation line from a primary containment isolation signal. NMPNS entered this issue into the CAP as CR 2006-3145 for resolution.

40A5 Other Activities

(Closed) URI 05000220&410/2004005-03, Acceptability or Suitability of Nine Mile Point Unit 1and Unit 2 Simulator Scenario Based Tests for Meeting ANSI/ANS-3.5-1998 Performance Testing Criteria.

This unresolved item was opened due to a lack of clarity in the regulatory requirements concerning the level of detail required for documenting scenario based simulator testing.

The inspectors noted that the facility now includes a more detailed plant response description for each scenario malfunction. Based on the licensees corrective actions and the absence of specific NRC performance criteria, the inspectors concluded that the unresolved item is closed with no identified performance deficiency.

4OA6 Meetings, including Exit

Exit Meeting Summary

The inspectors presented the inspection results to Mr. Sam Belcher and other members of NMPNS management on January 11, 2008. NMPNS acknowledged that no proprietary information was involved.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

K. Polson, Vice President

S. Belcher, Plant Manager

P. Bartolini, Design Engineer

N. Conicella, Manager, Operations

R. Dean, Director, Quality and Performance Assessment

J. Kaminski, Manager, Emergency Preparedness

M. Shanbhag, Licensing Engineer

T. Shortell, Manager, Training

T. Syrell, Director, Licensing

A. Verno, Manager, Nuclear Security

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000410/2007005-01

NCV

Inadequate RCIC Room Temperature Channel Checks (Section 1R15)

05000410/2007005-02

NCV

Loss of Shutdown Cooling due to Inadequate Maintenance Planning (Section 1R20)

Closed

05000220&410/2004005-03 URI

Acceptability or Suitability of Nine Mile Point Unit 1and Unit 2 Simulator Scenario-Based-

Tests (SBTs) For Meeting ANSI/ANS-3.5-

1998Property "ANSI code" (as page type) with input value "ANSI/ANS-3.5-</br></br>1998" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. Performance Testing Criteria (Section 4OA5)

Discussed

None.