IR 05000220/2014003

IR 05000220-14-003, 05000410-14-003; on 4/1/14 - 6/30/14; Nine Mile Point Nuclear Station Units 1 & 2; Operability Determinations & Functionality Assessments, Problem Identification & Resolution, and Follow-Up of Events & Notices of Enforce

ML14223A021
Person / Time
Site:	Nine Mile Point
Issue date:	08/07/2014
From:	Daniel Schroeder Reactor Projects Branch 1
To:	Costanzo C Exelon Generation Co
Schroeder D
References
IR 14-003
Download: ML14223A021 (67)

Text

August 7, 2014

SUBJECT:

NINE MILE POINT NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000220/2014003 AND 05000410/2014003

Dear Mr. Costanzo:

On June 30, 2014, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Nine Mile Point Nuclear Station, LLC (NMPNS), Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on July 21, 2014, with you 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 two NRC-identified non-cited violations (NCVs), one self-revealing NCV, and one self-revealing finding of very low safety significance (Green). However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as NCVs, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspectors at NMPNS. In addition, if you disagree with the cross-cutting aspect assigned to any finding, or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspectors at NMPNS. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access Management 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/

Daniel L. Schroeder, Chief Reactor Projects Branch 1 Division of Reactor Projects

Docket Nos. 50-220 and 50-410 License Nos. DPR-63 and NPF-69

Enclosure:

Inspection Report 05000220/2014003 and 05000410/2014003

w/Attachment: Supplementary Information

REGION I==

Docket Nos.

50-220 and 50-410

License Nos.

DPR-63 and NPF-69

Report Nos.

05000220/2014005 and 05000410/2014005

Licensee:

Exelon Generation (Exelon)

Facility:

Nine Mile Point Nuclear Station, LLC, Units 1 and 2

Location:

Oswego, New York

Dates:

April 1, 2014, through June 30, 2014

Inspectors:

K. Kolaczyk, Senior Resident Inspector

E. Miller, Resident Inspector

G. Stock, Resident Inspector

A. Bolger, Emergency Response Coordinator

E. Burket, Emergency Preparedness Inspector

N. Floyd, Reactor Inspector

J. Furia, Senior Health Physicist

C. Graves, Health Physicist

A. Rosebrook, Senior Project Engineer

Approved by:

Daniel L. Schroeder, Chief Reactor Projects Branch 1 Division of Reactor Projects

Enclosure

SUMMARY

IR 05000220/2014003, 05000410/2014003; 04/01/2014 - 06/30/2014; Nine Mile Point Nuclear

Station, LLC (NMPNS), Units 1 and 2; Operability Determinations and Functionality Assessments, Problem Identification and Resolution, and Follow-Up of Events and Notices of Enforcement Discretion.

This report covered a 3-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified two Green findings, both of which were non-cited violations (NCVs). In addition, one self-revealing NCV and one self-revealing Green Finding were also identified. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Initiating Events

Green.

The inspectors identified an NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, for failure to ensure that corrective actions to preclude repetition for a significant condition adverse to quality were implemented in a timely manner. Specifically, corrective actions to preclude repetition for the April 16, 2013, loss of shutdown cooling event to revise two inadequate Unit 1 procedures had not been completed over a year later. If left uncorrected, the inspectors determined there was the potential for 10 different pumps and breakers to unexpectedly trip upon restoration of a direct current (DC) bus. The loss of several of these pumps and loads would result in an unexpected plant transient or require a manual reactor trip. Exelon wrote condition report (CR)-2014-005693 in response to the inspectors questions and determined that inadequate resources were assigned to this corrective action to preclude repetition.

Procedures N1-OP-47A, 125 [volts direct current] VDC Power System, and N1-SOP-47A.1, Loss of DC, were subsequently revised and issued on June 12, 2014.

This finding is more than minor because it impacted the procedure quality attribute of the Initiating Events cornerstone and adversely affected the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, if left uncorrected, there was the potential for 10 different pumps and breakers to unexpectedly trip upon restoration of a DC bus. Several of these pumps and loads would result in an unexpected plant transient or require a manual reactor trip. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined that this finding is of very low safety significance (Green) because the finding did not involve the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and affected mitigation equipment. This finding has a cross-cutting aspect of in the area of Problem Identification and Resolution, Resolution, because Exelon did not take effective corrective actions to address an issue in a timely manner commensurate with its safety significance. Specifically, Exelon failed to implement corrective actions to prevent recurrence (CA#1 from CR-2013-002926), to revise procedures N1-SOP-47A.1 and N1-OP-47A to contain adequate guidance to ensure recovery from a loss of a DC bus would not result in an unexpected plant transient a year after the event occurred [P.3]. (Section 4OA2)

Green.

A self-revealing Green Finding (FIN) was identified at Unit 2 against procedure CNG-AM-1.01-2000, Scoping and Identification of Critical Components, Revision 00200.

Specifically, Exelon staff performed an inadequate AP-913 evaluation in 2006. This evaluation failed to identify that reactor recirculation pump (RRP) switches S101A and S101B were single-point vulnerable components, so mitigating strategies to ensure proper operation to minimize plant risk were not developed. As a result, on December 2, 2013, both RRPs failed to properly shift from fast to slow speed resulting in a loss of all recirculation flow through the core and requiring operators to insert a manual reactor scram in accordance with plant procedures. Exelon generated CR-2013-009735, performed a root cause analysis (RCA), and developed corrective actions which included revising procedure N2-OP-29, Reactor Recirculation System, Revision 01801, to direct operators to manually start the low frequency motor generator sets, implementing a preventive maintenance activity for these switches, and developing plans to replace the switches during the next refueling outage (RFO).

This finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and adversely impacted the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Additionally, the performance deficiency is similar to Example 4b of IMC 0612, Appendix E, Examples of Minor Issues, in that the error resulted in a plant trip. Specifically, the failure to identify switches S101A and S101B as single-point vulnerabilities and develop appropriate mitigating strategies resulted in the failure of the switches and a manual reactor scram on December 2, 2013. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green); the performance deficiency did not cause both a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition (e.g.; loss of condenser, loss of feedwater).

The inspectors did not assign a cross-cutting aspect to this finding because the performance deficiency was determined to have occurred in 2006, and the guidance in the current revision of CNG-AM-1.01-2000, Appendix A, was sufficient for Exelons root cause team to determine the switches should have been screened in. Therefore, this finding is not indicative of current licensee performance and no cross-cutting issue was assigned.

(Section 4OA3)

Cornerstone: Mitigating Systems

Green.

The inspectors identified a NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, due to Exelon staffs procedures for meeting Unit 2 Technical Specification (TS)

Surveillance Requirement (SR) 3.5.3.4 being inadequate since they did not test all required functions over the pressure range they were required since the start of plant operation.

Specifically, inspectors identified that reactor core isolation cooling (RCIC) was being started with the flow controller in manual during the 165 pounds per square inch gauge (psig)reactor pressure test as opposed to automatic, which is its normal lineup. As a result, the RCIC system has not been adequately tested to develop flow at low reactor pressures to ensure that the surveillance had been met and that the RCIC system met its design basis.

This finding is more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone and its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

This finding is similar to Example 3.d in IMC 0612, Power Reactor Inspection Reports,

Appendix E, Examples of Minor Issues. Specifically, the inadequate testing of the RCIC system with reactor pressure 165 psig has led to uncertainty in the reliability and capability of the system to perform at low reactor pressures.

In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined that this finding is of very low safety significance (Green) because the deficiency affects only the design or qualification of a mitigating SSC; and the design or qualification issue is not currently impacting its operability.

The inspectors did not assign a cross-cutting aspect to this finding because the performance deficiency is not indicative of present performance because Exelons incorrect interpretation for conducting TS SR 3.5.3.4 did not occur within the last 3 years. (Section 1R15)

Cornerstone: Barrier Integrity

Green.

A self-revealing NCV of TS 5.4.1, Procedures, was identified at Unit 2 for Exelons failure to provide procedures to override valve 2SFC*AOV154, filters inlet isolation valve, prior to loss of offsite power (LOOP) testing. Specifically, procedures N2-OSP-EGS-R004,

Operating Cycle Diesel Generator Simulated Loss of Offsite Power With ECCS Division I &

II, Revision 01200, and N2-VLU-01, Valve Lineup and Valve Operations, Revision 00001, did not contain adequate guidance to differentiate between overriding the valve (open position) and repositioning the valve to its non-failure position (closed position). As a result, on March 28, 2014, while implementing N2-OSP-EGS-R004, the spent fuel cooling pump A tripped off and had to be restored. Exelon entered the loss of spent fuel pool (SFP) cooling into the corrective action program (CAP) as CR-2014-002507. Corrective actions included coaching the individuals involved and reinforcing Exelons expectations regarding what information should be discussed during pre-job briefs.

This finding is more than minor because it is associated with the configuration control attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, if N2-OSP-EGS-R004 and Figure 3, Operation of Bettis Actuators, of N2-VLU-01 are not revised, there is the potential for plant operators to incorrectly assume that Section 3.0 of N2-VLU-01 Figure 3 is the valve lineup required by the N2-OSP-EGS-R004, closing 2SFC*AOV154 and causing a subsequent pump trip where the loss of cooling may have more significant consequence leading to an increase in the temperature of the spent fuel cooling pump. In accordance with IMC 0609.04, Initial Characterization of Findings, issued June 19, 2012, the inspectors used IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, because the SFP was still isolated from the reactor core at the time of the finding. Using Appendix A Exhibit 3 - Barrier Integrity Screening Questions Section D, Spent Fuel Pool (SFP), the inspectors determined that this finding is of very low safety significance (Green) because although the performance deficiency adversely affected decay heat removal capabilities from the SFP, the pool temperature did not exceed the maximum analyzed temperature limit specified in the site-specific licensing basis, the performance deficiency did not involve a fuel handling error, did not affect the SFP neutron absorber, and did not result in a loss of SFP water inventory.

This finding has a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because Exelon did not ensure that individuals stopped in the face of uncertain conditions. Specifically, after recognizing that N2-VLU-01 Figure 3 contained multiple sections that were not clearly labeled, plant operators did not stop and consult the senior reactor operator but continued on with an erroneous assumption as to which section to use

[H.11]. (Section 4OA3)

Attachment

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On April 26, 2014, operators reduced reactor power to 73 percent for a rod sequence exchange. Reactor power was returned to 100 percent on April 27. On June 7, operators reduced power to 40 percent to perform scram time testing, 12 circulating water box tube repairs, 13 flow control valve packing replacements, 13 feedwater pump gearbox maintenances, turbine stop valve and control valve testing, and recover 13 RRP. Unit 1 was returned to 100 percent on June 9. On June 11, operators reduced reactor power to 80 percent to perform a rod pattern adjustment and returned Unit 1 to 100 percent power the same day. Unit 1 remained at or near 100 percent power for the remainder of the inspection period.

Unit 2 began the inspection period in a planned RFO. On April 27, 2014, operators took the reactor critical, and the generator was synchronized to the grid on April 28. Unit 2 reached 100 percent power on May 2. On May 19, operators reduced power to 64 percent to isolate the reactor feedwater pump A which developed a leak at the inboard pump seal. On May 23, following maintenance preparation of the standby reactor feedwater pump C, operators began power ascension. Unit 2 reached 100 percent on May 24. On May 28, operators reduced reactor power to 88 percent following a circuit card failure in the control system for the reactor recirculation flow control valve B. Also on May 28, Unit 2 experienced electrohydraulic control system trouble due to a leaking oil bypass valve. On May 29, Unit 2 operators raised reactor power to 96 percent to reduce demand on the electrohydraulic control system while repairs were made to the electrohydraulic control oil bypass valve. Following replacement of the circuit card associated with the reactor recirculation flow control valve B and electrohydraulic control oil bypass valve adjustment on May 30, reactor power was lowered to 85 to perform a rod pattern adjustment. Unit 2 was then returned to 100 percent power the same day. Unit 2 remained at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems

a. Inspection Scope

The inspectors performed a review on May 6 and 7, 2014, of Unit 1 and Unit 2 plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed changes to Exelons procedures affecting these areas and the communication protocols between the transmission system operator and Exelon implemented since the previous samples in 2013. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Exelon established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by reviewing CRs and open work orders (WOs), and walking down portions of the offsite and AC power systems including the 345 kilovolt (kV) and 115 kV switchyards.

Documents reviewed for each section of this inspection report are listed in the

.

b. Findings

No findings were identified.

.2 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

During the week of May 19, 2014, the inspectors performed a review of Exelons readiness for the onset of seasonal high temperatures. The review focused on the Unit 1 technical support center ventilation, control room and reactor building (RB) air conditioning systems; and the Unit 2 service water and heating, ventilation, and air conditioning (HVAC) systems. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), TSs, and the CAP to determine what temperatures or other seasonal weather could challenge these systems and to ensure Exelon personnel had adequately prepared for these challenges. The inspectors reviewed station procedures including Exelons seasonal weather readiness procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during hot weather conditions.

b. Findings

No findings were identified.

.3 External Flooding

a. Inspection Scope

During the week of May 19, 2014, the inspectors performed an inspection of the external flood protection measures for NMPNS. The inspectors reviewed AREVA NP Inc.,

Engineering Information Record 51-7012651-000, Constellation Energy Nuclear Group Flood Hazard Reevaluation Report for Nine Mile Point Nuclear Station, which described the approach, methods, and results from the reevaluation of flood hazards at Units 1 and

2. The inspectors conducted a general site walkdown of all external areas of the plant

including Unit 1 and Unit 2 turbine buildings, RBs, and diesel generator enclosures. The inspectors also reviewed EPIP-EPP-26, Natural Hazard Preparation and Recovery, Revision 00400, for mitigating external flooding during severe weather to determine if Exelon planned or established adequate measures to protect against external flooding events.

b. Findings

No findings were identified.

==1R04 Equipment Alignment

Partial System Walkdowns (71111.04Q - 4 samples)

a. Inspection Scope

==

The inspectors performed partial walkdowns of the following systems:

Unit 2 residual heat removal (RHR) system A during Division II electrical bus outage on April 4, 2014

Unit 2 Division I SFP cooling system during refueling operations on April 10, 2014

Unit 1 control room smoke removal system during control room chiller #12 replacement on April 29, 2014

Unit 1 emergency diesel generator (EDG) 102 before EDG 103 was removed from service for surveillance testing on May 5, 2014

The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TSs, WOs, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.

The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

==1R05 Fire Protection

==

.1 Resident Inspector Quarterly Walkdowns

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Exelon controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

Unit 2 drywell (Fire Area (FA) 50) on March 31, 2014

Unit 2 RB steam tunnel (FA 50) on April 1, 2014 Unit 1 main control room (FA 11) on April 8, 2014

Unit 1 screen house (FA 13) on April 8, 2014

Unit 1 diesel fire pump room (FA 14) on April 8, 2014

Unit 2 diesel fire pump room (FA 62) on April 10, 2014

b. Findings

No findings were identified.

.2 Fire Protection - Drill Observation

a. Inspection Scope

The inspectors observed a fire brigade drill scenario conducted on June 24, 2014, that involved a fire on the first floor of the Unit 2 normal switchgear building. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Exelon personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. The inspectors evaluated specific attributes as follows:

Proper wearing of turnout gear and self-contained breathing apparatus (SCBA)

Proper use and layout of extinguishing agents

Employment of appropriate fire-fighting techniques

Sufficient fire-fighting equipment brought to the scene

Effectiveness of command and control

Search for victims and propagation of the fire into other plant areas

Smoke removal operations

Utilization of pre-planned strategies

Adherence to the pre-planned drill scenario

Drill objectives met

The inspectors also evaluated the fire brigades actions to determine whether these actions were in accordance with Exelons fire-fighting strategies.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Annual Review of Cables Located in Underground Bunkers/Manholes

a. Inspection Scope

On May 28, 2014, the inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could affect risk-significant equipment. The inspectors performed walkdowns of risk-significant areas, including Unit 2 manhole MH-1 which contains power cables for the high-pressure coolant spray system pump, to verify that the cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. The inspectors reviewed Exelons corrective actions initiated following a July 22, 2013, discovery that a dewatering system, which had been installed in 2012 to dewater manholes MH-1 and MH-3, had failed to properly operate, and as a result, several feet of water had accumulated in the cable vaults. The performance deficiency surrounding this issue was documented in greater detail in NRC Problem Identification and Resolution Inspection Report 05000410/2013007.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed samples listed below to determine their readiness and availability to perform their safety functions. The inspectors reviewed the design basis for the components and verified Exelon commitments to NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment, issued July 18, 1989. The inspectors reviewed the results of previous inspections of the RHR heat exchangers (HXs). The inspectors discussed the results of the most recent inspection with engineering staff and reviewed pictures of the as-found and as-left conditions. The inspectors verified that Exelon initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the HXs did not exceed the maximum amount allowed.

Unit 2 RHR HX A, 2RHS*E1A, on June 26, 2014

Unit 2 RHR HX B, 2RHS*E1B, on June 26, 2014

b. Findings

No findings were identified.

1R08 Inservice Inspection

a. Inspection Scope

From March 31 to April 4, 2014, the inspectors conducted an inspection and review of Exelons implementation of inservice inspection (ISI) program activities for monitoring degradation of the reactor coolant system (RCS) boundary, risk-significant piping and components, and containment systems during the 14th Unit 2 RFO. The sample selection for this inspection was based on the inspection procedure objectives and risk priority of those pressure-retaining components in systems where degradation would result in a significant increase in risk. The inspectors observed in-process nondestructive examinations (NDEs), reviewed documentation, and interviewed Exelon personnel to verify that the NDE activities performed as part of the third interval, second period, of the ISI program were conducted in accordance with the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 2004 Edition, No Addenda.

NDE and Welding Activities (IMC Section 02.01)

The inspectors performed direct observation of NDE activities in process and reviewed documentation of NDEs listed below. Activities included review of ultrasonic testing (UT), magnetic particle testing, and visual examination.

The inspectors reviewed certifications of the NDE technicians performing the examinations and verified that the inspections were performed in accordance with approved NDE procedures and industry guidance. For UT activities, the inspectors also verified the calibration of equipment used to perform the examinations. The inspectors verified that the test results were reviewed and evaluated by certified Level III NDE personnel and that the parameters used in the test were in accordance with the limitations, precautions, and prerequisites specified in the test procedure.

ASME Code Required Examinations

Documentation review of the manual UT of pipe-to-elbow weld (2ICS-57-07-FW0175), 6-inch diameter, in the RCIC system.

Direct observation of the manual phased array UT of bottom-head meridional welds (2RPV-DA and 2RPV-DB) on the reactor vessel.

Documentation review of the manual phased array UT of the N3C nozzle-to-shell weld (2RPV-KA13) on the reactor vessel.

Documentation review of the magnetic particle testing of the reactor pressure vessel closure head-to-flange weld (2RPV-AG).

The inspectors visually examined the condition of the primary containment liner surfaces on the 269, 288, and 305 elevations. Limited portions of the containment surfaces above and below the listed elevations were accessible for examination.

The inspectors also performed a document review of the containment visual examination records and compared those to the inspector walkdowns.

Other Augmented or Industry-Initiative Examinations

The inspectors sampled the remote enhanced visual examination records of reactor vessel internals as done underwater inside the reactor vessel during in-vessel visual inspection activities. The inspection scope included portions of the feedwater sparger brackets, jet pump wedges, and steam dryers. The inspectors reviewed the applicable parts of the in-vessel visual inspection procedure, observation of a sample of digital video records, the analysis process for the observations, and documentation of indications. The inspectors verified that the activities were performed in accordance with applicable examination procedures and industry guidance.

Repair/Replacement Activities Including Welding Activities

The inspectors performed a record review of the replacement activities associated with the class 3 instrument air valve 2IAS-V181 and associated 1.5 piping to verify that welding and applicable NDE activities were performed in accordance with ASME Section XI code requirements. Specifically, the inspectors observed welding activities for the pre-fabricated portions of piping prior to installation in the plant. The inspectors reviewed the weld procedures and welder qualifications and verified that welding was conducted according to the repair/replacement plan. The replacement work was performed under WO C91898761.

Identification and Resolution of Problems (IMC Section 02.05)

The inspectors reviewed a sample of corrective action reports which identified NDE indications, deficiencies, and other non-conforming conditions since the previous RFO and during the current outage. The inspectors verified that non-conforming conditions were properly identified, characterized, evaluated, and that corrective actions were identified and entered into the CAP for resolution.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Quarterly Review of Licensed Operator Requalification Testing and Training (2 samples)

a. Inspection Scope

The inspectors observed:

Unit 2 licensed operator simulator training which included 2ENS*SWG101 restoration, Division I EDG failure, a single control rod scram, and a stuck-open safety relief valve on May 22, 2014

Unit 1 licensed operator simulator training which included an evaluated job performance measure that involved bypassing the hydrogen/oxygen analyzers following a reactor scram on May 27, 2014

The inspectors evaluated operator performance during the simulated event and verified completion of risk-significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classifications made by the shift manager and the TS action statements entered by the shift technical advisor.

Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

(2 samples)

a. Inspection Scope

The inspectors observed:

Unit 2 control room operations during power ascension activities including preparations for turbine rolling on April 28, 2014

Unit 1 control room operations during control room fire damper maintenance and EDG 103 surveillance testing on May 5, 2014

The inspectors reviewed CNG-OP-1.01-1000, Conduct of Operations, Revision 01000, and verified that procedure use, crew communications, and coordination of plant activities among work groups similarly met established expectations and standards.

Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Exelon staff were reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Exelon staff were identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

Unit 2 auxiliary boilers on May 21, 2014

Unit 2 intermediate range monitors on May 29, 2014

Unit 1 intermediate range monitors on May 29, 2014

Unit 1 feedwater level control system on June 13, 2014

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Exelon performed the appropriate risk assessments prior to removing equipment from service. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Exelon personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Exelon performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Unit 2 planned maintenance on the Division II EDG on April 6, 2014

Unit 1 unplanned maintenance on the feedwater level control system on April 15, 2014

Unit 2 failure of standby gas treatment system (SGTS) fan 2GTS*FN1B to start for primary containment depressurization following integrated leak rate testing on April 23, 2014

Unit 2 planned surveillance testing on the high-pressure core spray (HPCS) system that resulted in an elevated plant risk condition on May 6, 2014

Unit 2 planned surveillance testing on the RCIC system that resulted in an elevated plant risk condition on May 7, 2014

Unit 2 unplanned removal of feedwater pump 2FWS*P1A due to increased inboard pump seal leakage on May 19, 2014

Unit 1 unplanned change in reactor water level due to feedwater level control system malfunction on June 9, 2014

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

Unit 1 technical support center ventilation failure on April 14, 2014

Unit 2 valve 2SWP*MOV50B exceeded its maximum allowable torque on April 23, 2014

Unit 2 time delay relays 62-2ENSX04 and 62-2ENSY04 replacement on April 30, 2014 Unit 2 environmental qualification impact for as-found splice on the SGTS fan motor 2GTS*FN1B-M on May 8, 2014

Unit 2 B control room chiller trip on May 19, 2014

Unit 2 RCIC during 165 psig surveillance testing on May 23, 2014

Unit 2 Division III EDG jacket water leak on May 30, 2014

The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to Exelons evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Exelon. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

Introduction.

The inspectors identified a NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, due to Exelon staffs procedures for meeting Unit 2 TS SR 3.5.3.4 being inadequate since they did not test all required functions over the pressure range they were required since the start of plant operation. Specifically, inspectors identified that RCIC was being started with the flow controller in manual during the 165 psig reactor pressure test as opposed to automatic, which is its normal lineup. As a result, the RCIC system has not been adequately tested to develop flow automatically at low reactor pressures to ensure that the surveillance had been met and that the RCIC system met its design basis.

Description.

The RCIC system is designed to initiate and discharge flow to the reactor vessel over a pressure range of 165 to 1,215 psig. RCIC is initiated on a low-low reactor vessel water level signal (108.8 inches) and is used to maintain adequate reactor coolant inventory and core cooling during a station blackout. RCIC is also used to provide make-up water to the reactor vessel upon a loss of normal feedwater during a LOOP. Per the design analysis for loss of normal feedwater in NEDC-33351P, Safety Analysis Report for Nine Mile Point Nuclear Station Unit 2 Constant Pressure Power Uprate, Revision 0, HPCS was conservatively assumed to be unavailable, and RCIC is expected to inject within 68 seconds from the start of the event to ensure adequate core coverage and preclude automatic depressurization and low-pressure emergency core cooling system (ECCS) initiation.

The inspectors noted that procedure N2-OSP-ICS-R002, RCIC System Flow Test, Revision 00302, which was used to conduct the surveillance test, had operators start the pump with the flow controller in manual, and upon reaching 600 gallons per minute (gpm), switch the flow controller to automatic, and maintain it at 600 gpm for about 10 minutes. SR 3.5.3.4 specifically states that operators verify, with reactor pressure 165 psig, the RCIC pump can develop a flow rate 600 gpm against a system head corresponding to reactor pressure once every 24 months prior to reactor pressure exceeding 165 psig, normally during power ascension from each RFO.

Previous operating experience from Susquehanna Generating Station Integrated Inspection Reports 05000387/2011005, 05000388/2011005, 05000387/2012005, and

===05000388/2012005 documented a similar concern where operators were testing the RCIC system by starting the pump with the flow controller in manual vice automatic. It was noted in the inspection reports that by not testing RCIC with the flow controller in automatic, the ramp generator signal converter was bypassed. The inspectors also documented information from General Electric Service Information Letter (GE SIL) 336, Surveillance Testing Recommendations for HPCI and RCIC Systems, Revision 1, which was developed after GE observed inconsistencies and inadequacies in high-pressure coolant injection (HPCI) and RCIC surveillance testing. It stated, in part:

An operability demonstration of the HPCI and RCIC systems should include not only steady state pump flow and pressure data, but also quick-start control capability and proper valve sequencing. The objective of surveillance testing should be to simulate closely the actual startup sequence of the system following an auto-initiation signalThe system flow controller is frequently placed in manual and its output reduced to a minimum speed demand signal. The speed signal is manually increased after system startup. This practice does not test the dynamic response of the control systemthe following quick-start is recommended for surveillance testing of the systems(2) Confirm that the system flow controller is in automatic and set for design flow rate.

The NRCs Office of Nuclear Reactor Regulation was also asked to provide information on how the RCIC system should be tested. Following a conference call with the Office of Nuclear Reactor Regulation and the inspectors on October 11, 2012, it was determined that the licensee did not establish the conditions assumed in the accident analysis in their implementing procedure.

Based on the operating experience from Susquehanna Generating Station, the inspectors asked Exelon if RCIC was being tested properly. Exelon staff polled both fleet and non-fleet boiling water reactors to determine how their RCIC system was being tested for TS SR 3.5.3.4. Based on this feedback from industry peers, Exelon staff determined that NMPNS had not been testing RCIC properly. It was believed that the GE SIL 336 was interpreted and NMPNS chose to combine post-maintenance testing and surveillance testing in the same run. Exelon plans to update procedure N2-OSP-ICS-R002 to include testing with the flow controller in automatic during the next performance of TS SR 3.5.3.4.

The inspectors also questioned operability given that Exelon had not properly tested all necessary attendant instrumentation and controls required for RCIC to perform its specified function during SR 3.5.3.4 for the entire operational period of Unit 2.

Specifically, the ramp generator signal converter was bypassed by being in manual and, therefore, has not been tested to demonstrate the ability to automatically raise RCIC flow to 600 gpm while at low reactor pressures. Exelon evaluated operability and determined that RCIC was currently operable based on the following:

The most recent performance of N2-OSP-ICS-R002 demonstrated adequate flow once 600 gpm had been reached and the flow controller was switched to automatic

Successful performance of N2-OSP-ICS-Q@002, RCIC Pump and Valve Operability Test and System Integrity Test and ASME XI Functional Test, Revision 01000, for SR 3.5.3.3, which is an automatic start at a reactor pressure of 1,035 psig on April 29, 2014

Given the RCIC system has not been tested with the flow controller in automatic for SR 3.5.3.4 to ensure proper response of RCIC at low reactor pressures; Exelon verified that operators have an emergency operating procedure for level control which refers operators to N2-OP-35, Reactor Core Isolation Cooling System, Revision 01202, Section F.3, which directs operators to perform manual injection using RCIC. This ensures that operators would be able to control and inject using RCIC in the event that the automatic flow controller does not function properly during low reactor pressures.

Exelon has entered this issue into their CAP as CR-2014-004314 and CR-2014-005654.

Analysis.

The inspectors determined that Exelons inadequate testing of the RCIC system with reactor pressure 165 psig, as required by TS SR 3.5.3.4, was a performance deficiency that was reasonably within Exelons ability to foresee and correct and should have been prevented. This finding is more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone and the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This finding is also similar to Example 3.d in IMC 0612,Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues, issued August 11, 2009. Specifically, the inadequate testing of the RCIC system with reactor pressure 165 psig led to uncertainty in the reliability and capability of the system to perform at low reactor pressures.

In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the deficiency affects only the design or qualification of a mitigating SSC; and the design or qualification issue is not currently impacting its operability.

The inspectors did not assign a cross-cutting aspect to this finding because the performance deficiency was not indicative of present performance because NMPNS determination for how SR 3.5.3.4 was performed was completed in the early 1990s and did not occur within the last 3 years.

Enforcement.

10 CFR Part 50, Appendix B, Criterion XI, Test Controls, requires, in part, that a test program shall be established to assure that all testing required to demonstrate that SSCs will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. TS SR 3.5.3.4 requires operators to verify, with reactor pressure 165 psig, the RCIC pump can develop a flow rate 600 gpm against a system head corresponding to reactor pressure once every 24 months prior to reactor pressure exceeding 165 psig. GE SIL 336, Surveillance and Testing Recommendations for HPCI and RCIC Systems, Revision 1 states that in order to verify proper dynamic response of the RCIC system, the flow controller must be in automatic and set for design flow. Contrary to the above, Exelons test procedure did not adequately demonstrate that the RCIC system would perform satisfactorily in service under all required design conditions and pressures as required by TS SR 3.5.3.4.

Specifically, the inspectors determined that procedure N2-OSP-ICS-R002, RCIC System Flow Test, Revision 00302, does not verify the operability of the RCIC system and its ramp generator signal converter response at reactor pressure 165 psig due to the flow controller being directed to be set in manual. This resulted in Exelon developing an operability determination to support current operability and a procedure change for N2-OSP-ICS-R002 to ensure proper future testing during power ascension. Because this violation was of very low safety significance and was entered into Exelons CAP (CR-2014-004314 and CR-2014-005654), this violation is being treated as an NCV consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000410/2014003-01, Inadequate Surveillance Testing of Reactor Core Isolation Cooling during 165 psig Reactor Pressure Test for Surveillance Requirement 3.5.3.4)

1R18 Plant Modifications

.1 Temporary Modification

a. Inspection Scope

The inspectors evaluated a temporary modification performed under engineering change package (ECP) 14-000235, Relay R10 Removal, Revision 0, on June 2, 2014, which removed relay R10 from the air start system for the Unit 1 diesel-driven fire pump. As a result, the diesel air start system lost the capability to automatically receive air from the standby air receiver. The inspectors verified that the design bases, licensing bases, and performance capability of the affected system was not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the change, conducted a walkdown of the temporary modification in the field, and reviewed the diesel fire pump operating procedure.

b. Findings

No findings were identified.

.2 Permanent Modification

a. Inspection Scope

The inspectors evaluated ECP 13-001026, Cut Out and Remove Valve 2IAS*V181, Revision 2, which is located in the drywell portion of the Unit 2 instrument air system.

The inspectors verified that the design bases, licensing bases, and performance capability of the affected system was not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the upgrade and design change including the post-installation test procedure, the 10 CFR 50.59 screening form, the operational impact assessment form, and the fire hazards assessment analysis.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities 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 the 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.

Unit 2 time delay relay 2C-2ENSX04 associated with RHR pump 2RHS*P1A following replacement on April 10, 2014

Unit 2 main steam isolation valve 2MSS*AOV6B following valve re-packing on April 11, 2014

Unit 2 primary containment isolation valve 2CPS*AOV106 following seat rebuild on April 25, 2014

Unit 2 uninterruptible power supply 2VBB*UPS3B following J4 card and backplane replacement on April 29, 2014

Unit 2 Division III electrical manhole MH-1 sump following switch replacement on May 29, 2014

Unit 1 control room envelope following block valve BV-210-27B repairs on May 30, 2014

Unit 1 replacement of diesel generator 102 turbocharger lubricating oil pump on June 25, 2014

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

The inspectors reviewed the stations work schedule and outage risk plan for the Unit 2 maintenance and RFO (N2R14), which was conducted March 23 through May 2, 2014.

The inspectors reviewed Exelons development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities:

Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable TSs when taking equipment out of service Implementation of clearance activities and confirmation that tags were properly hung and that equipment was appropriately configured to safely support the associated work or testing

Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting

Status and configuration of electrical systems and switchyard activities to ensure that TSs were met

Monitoring of decay heat removal operations

Impact of outage work on the ability of the operators to operate the SFP cooling system

Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss

Activities that could affect reactivity

Maintenance of secondary containment as required by TSs

Refueling activities, including fuel handling and fuel receipt inspections

Fatigue management

Tracking of startup prerequisites, walkdown of the drywell and suppression chamber to verify that debris had not been left which could block the ECCS suction strainers, and startup and ascension to full power operation

Identification and resolution of problems related to RFO activities

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and Exelon procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

Unit 2, N2-OSP-EGS-R001, Diesel Generator ECCS Start Division II on April 6, 2014

Unit 2, N2-CSP-RCS-W102, Dose Equivalent Iodine-131 on April 8, 2014 (RCS Leak Rate Sample)

Unit 2, N1-ST-Q8A, Liquid Poison Pump 11 and Check Valve Operability Test on April 14, 2014 (IST Sample)

Unit 2, N2-TSP-CNT-@001, Reactor Containment Building Integrated Leak Rate Test on April 20, 2014

Unit 2, N2-OSP-ICS-Q@002, RCIC Pump and Valve Operability Test and System Integrity Test and ASME Xl Functional Test on April 28, 2014 (IST Sample)

Unit 2, N2-OSP-ICS-R002, RCIC System Flow Test on April 29, 2014

Unit 1, N1-ST-Q9, Control Room HVAC Operability Test on May 28, 2014 (IST Sample)

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

Exelon implemented various changes to NMPNS emergency action levels (EALs),emergency plan, and implementing procedures. In accordance with 10 CFR 50.54(q)(3),

Exelon had determined that any change made to the EALs, emergency plan, and its lower-tier implementing procedures had not resulted in any reduction in effectiveness of the plan and that the revised plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR 50 Appendix E.

The inspectors performed an in-office review of all EAL and emergency plan changes submitted by Exelon as required by 10 CFR 50.54(q)(5), including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential reductions in effectiveness of the emergency plan. This review by the inspectors was not documented in an NRC safety evaluation report and does not constitute formal NRC approval of changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed an emergency response drill for Unit 1 on June 10, 2014, which required emergency plan implementation by Exelons emergency response organization.

Exelon planned for this evolution to be evaluated and included in performance indicator (PI) data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the emergency response organization. The inspectors also attended the post-evolution critique for the scenario.

The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that Exelon evaluators noted the same issues and entered them into the CAP.

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

During the period April 7 - 10, 2014, the inspectors reviewed and assessed Exelons performance in assessing the radiological hazards and exposure control in the workplace. The inspectors used the requirements in 10 CFR Part 20, Standards For Protection Against Radiation, and guidance in Regulatory Guide (RG) 8.38, Control of Access to High and Very High Radiation Areas of Nuclear Plants, Revision 1, TSs, and procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the 2013 PIs for the occupational exposure cornerstone, radiation protection program audits, and any reports of operational occurrences related to occupational radiation safety since the last inspection.

Radiological Hazard Assessment

The inspectors determined there have been no changes to plant operations since the last inspection that may result in a significant new radiological hazard for onsite workers or members of the public.

The inspectors reviewed the last radiological surveys for four areas and evaluated whether the thoroughness and frequency of the surveys were appropriate for the given radiological hazard.

The inspectors conducted walkdowns and independent radiation measurements in the facility including radioactive waste processing, storage, and handling areas to evaluate material and radiological conditions.

The inspectors selected various work activities that involved exposure to radiation and evaluated the pre-work surveys and the adequacy of established protective measures.

The inspectors observed work in potential airborne radioactivity areas and evaluated whether the air samples were representative of the breathing air zone and were properly evaluated. The inspectors evaluated whether continuous air monitors were representative of actual work areas. The inspectors evaluated Exelons program for monitoring levels of loose surface contamination in areas of the plant.

Instructions to Workers

The inspectors selected three containers of radioactive materials and assessed whether the containers were labeled and controlled in accordance with 10 CFR Part 20 requirements.

The inspectors reviewed various radiation work permits (RWPs) used to access high radiation areas and evaluated if the work controls and control barriers were consistent with TS requirements.

The inspectors assessed whether permissible dose for work under each RWP were clearly identified. The inspectors evaluated whether electronic personal dosimeter alarm set points were in conformance with survey indications and plant procedural requirements.

The inspectors reviewed two occurrences where a workers electronic personal dosimeter malfunctioned or alarmed and evaluated whether workers responded appropriately. The inspectors assessed whether the issue was included in the CAP and whether compensatory dose evaluations were conducted as appropriate.

For work activities that could suddenly increase radiological hazards, the inspectors assessed Exelons means to inform the workers.

Contamination and Radioactive Material Control

The inspectors observed Unit 2s access control point where Exelon monitors material leaving the radiological control area and inspected the methods used for control, survey, and release of these materials from the control point. The inspectors observed the performance of personnel surveying and releasing material for unrestricted use and evaluated whether the work was performed in accordance with plant procedures. The inspectors evaluated whether any recent transactions involving nationally tracked sources were reported in accordance with 10 CFR Part 20 requirements.

Radiological Hazards Control and Work Coverage

The inspectors evaluated radiological conditions and performed independent radiation measurements during walkdowns and assessed whether the conditions were consistent with postings, surveys, RWPs, and worker briefings.

The inspectors evaluated the adequacy of radiological controls, surveys, radiation protection job coverage, and evaluated Exelons use of electronic personal dosimeters in high noise areas.

The inspectors reviewed the application of dosimetry to monitor exposure to personnel in high radiation work areas with significant dose rate gradients.

The inspectors reviewed two RWPs for work within airborne radioactivity areas and evaluated airborne radioactive controls, monitoring containment barrier integrity, and the operation of temporary high-efficiency particulate air ventilation systems.

The inspectors examined the posting and physical controls for selected high and very high radiation areas to verify conformance with the occupational PI.

Risk-Significant High and Very High Radiation Area Controls

The inspectors discussed with the radiation protection manager the controls and procedures for high and very high radiation areas and assessed whether any changes to Exelons procedures reduce the effectiveness of worker protection.

The inspectors discussed with first-line health physics supervisors the controls in place for special areas that have the potential to become very high radiation areas during certain plant operations and ensured that an individual was not able to gain unauthorized access to these areas.

Radiation Worker Performance

The inspectors observed the performance of radiation workers with respect to radiation protection requirements and assessed whether workers were aware of the radiological conditions in their workplace and the RWP controls/limits in place.

The inspectors reviewed radiological problem reports since the last inspection that attributed the cause of the event-to-human performance errors and evaluated whether there was an observable pattern traceable to a similar cause and whether this perspective matched the corrective action approach taken by Exelon to resolve the reported problems.

Radiation Protection Technician Proficiency

The inspectors observed the performance of the radiation protection technicians with respect to controlling radiation work. The inspectors evaluated whether technicians were aware of the radiological conditions in their workplace and the RWP controls/limits and whether their performances were consistent with their training and qualifications.

The inspectors reviewed radiological problem reports since the last inspection that attributed the cause of the event to technician error and evaluated whether there was an observable pattern traceable to a similar cause and assessed whether this perspective matched the corrective action approach taken by Exelon to resolve the reported problems.

Problem Identification and Resolution

The inspectors evaluated whether problems associated with radiation monitoring and exposure control were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in the CAP. The inspectors assessed Exelons process for applying operating experience to their plant.

b. Findings

No findings were identified.

2RS2 Occupational ALARA Planning and Controls

a. Inspection Scope

During the period April 7 - 10, 2014, the inspectors assessed performance with respect to maintaining occupational individual and collective radiation exposures as low as reasonably achievable (ALARA). The inspectors used the requirements in 10 CFR Part 20, RG 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will be As Low As Is Reasonably Achievable, Revision 3, RG 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposure As Low As Is Reasonably Achievable, Revision 1-R, TSs, and Exelon procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed pertinent information regarding Unit 2 collective dose history, current exposure trends, and ongoing or planned activities in order to assess current performance and exposure challenges during the RFO.

The inspectors compared the site-specific trends in collective exposures against the industry average values and those values from similar vintage reactors. In addition, the inspectors reviewed any changes in the radioactive source term by reviewing the trend in average contact dose rates with recirculation piping measured on April 5, 2014.

The inspectors reviewed site-specific procedures associated with maintaining occupational exposures ALARA which included a review of processes used to estimate and track exposures from specific work activities.

Radiological Work Planning

The inspectors selected the following work activities that had the highest exposure:

Drywell snubbers

Drywell ISI examinations

Under-vessel work control rod drive and local power range monitor replacement

Drywell safety relief valve exchange

Reactor disassembly/reassembly and cavity decontamination

Refuel floor underwater activities

The inspectors reviewed the ALARA work activity evaluations, exposure estimates, and exposure reduction requirements. The inspectors reviewed the grouping of radiological work into work activities based on historical precedence, industry norms, and/or special circumstances.

The inspectors assessed whether Exelons planning identified appropriate dose reduction techniques and estimated reasonable dose goals and evaluated Exelons ALARA assessment of the use of respiratory protective equipment. The inspectors determined whether Exelons work planning considered the use of remote technologies and the use of dose reduction insights from industry operating experience and plant-specific lessons learned. The inspectors assessed the integration of ALARA requirements into work procedure and RWP documents.

The inspectors compared the dose results achieved with the intended dose established in Exelons ALARA planning documents for these work activities. The inspectors compared the person-hour estimates provided by maintenance planning and other groups to the radiation protection group actual person-hours for the work activity and evaluated the accuracy of these time estimates. The inspectors assessed the reasons for any inconsistencies between intended and actual work activity doses.

Verification of Dose Estimates and Exposure Tracking Systems

The inspectors reviewed the assumptions and basis for the current annual collective dose estimate for accuracy and reviewed applicable procedures to determine the methodology for estimating exposures from specific work activities and for department and station collective dose goals.

The inspectors evaluated whether Exelon had established measures to track, trend, and reduce occupational doses for ongoing work activities and assessed whether dose threshold criteria were established for work in-progress reviews. The inspectors evaluated the method used for adjusting exposure estimates or re-planning work when unexpected changes in scope or emergent work were encountered.

Source Term Reduction and Control

The inspectors reviewed Exelon records to determine the historical trends and current status of plant source term and assessed whether Exelon had developed contingency plans for expected changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary chemistry.

Radiation Worker Performance

The inspectors observed radiation worker and radiation protection technician performance during work activities being performed in radiation areas, airborne radioactivity areas, and high radiation areas and evaluated whether workers demonstrated the ALARA philosophy in practice and whether there were any procedural compliance issues.

Problem Identification and Resolution

The inspectors evaluated whether problems associated with ALARA planning and controls were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in the CAP. The inspectors assessed Exelons process for applying operating experience to their plant.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

a. Inspection Scope

During the period April 7 - 10, 2014, the inspectors verified in-plant airborne concentrations were being controlled consistent with ALARA principles and the use of respiratory protection devices on-site did not pose an undue risk to the wearer. The inspectors used the requirements in 10 CFR Part 20, the guidance in RG 8.15, Acceptable Programs for Respiratory Protection, Revision 1, RG 8.25, Air Sampling in the Workplace, Revision 1, NUREG-0041, Manual of Respiratory Protection Against Airborne Radioactive Material, TSs, and procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the UFSAR to identify areas of the plant designed as potential airborne radiation areas and any associated ventilation systems or airborne monitoring instrumentation. The review included a review of the respiratory protection program and a description of the types of protective devices used. The inspectors reviewed the location and quantity of respiratory protection devices stored for emergency use. The inspectors reviewed the procedures for maintenance, inspection, and use of respiratory protection equipment including SCBA as well as procedures for air quality maintenance.

The inspectors reviewed reported PIs to identify any related to unintended dose resulting from intakes of radioactive material.

Engineering Controls

The inspectors reviewed Exelons use of permanent and temporary ventilation to determine whether Exelon used these systems as part of its engineering controls to control airborne radioactivity. The inspectors reviewed procedural guidance for use of installed plant systems to reduce dose and assessed whether the systems were used during high-risk activities.

The inspectors selected two temporary ventilation system setups used to support work in contaminated areas and assessed whether the use of these systems were consistent with procedural guidance and the principles of ALARA.

Use of Respiratory Protection Devices

The inspectors selected two work activities where respiratory protection devices were used to limit the intake of radioactive materials and assessed whether Exelon performed an evaluation concluding that further engineering controls were not practical and that the use of respirators was ALARA. The inspectors assessed whether respiratory protection devices used to limit the intake of radioactive materials were certified by the National Institute for Occupational Safety and Health/Mine Safety and Health Administration or have been approved by the NRC.

The inspectors reviewed records of air testing for supplied air devices and SCBA bottles to determine whether the air used in these devices meets or exceeds Grade D quality and reviewed plant breathing air supply systems to determine whether they meet the minimum pressure and airflow requirements for the devices in use.

The inspectors selected three individuals qualified to use respiratory protection devices and assessed whether they were qualified to use the devices by successfully passing an annual medical examination, respirator fit test, and relevant respiratory protection training. The inspectors observed the donning, doffing, and functionally checking the device. Through interviews with these individuals, the inspectors evaluated whether they knew how to safely use the devices and how to properly respond to any device malfunction or unusual occurrence (loss of power, loss of air, etc.).

Problem Identification and Resolution

The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in the CAP. The inspectors determined whether the corrective actions were appropriate for a selected sample of problems involving airborne radioactivity and were appropriately documented by Exelon.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

a. Inspection Scope

The inspectors verified that occupational dose was appropriately monitored, assessed, and reported by Exelon. The inspectors used the requirements in 10 CFR Part 20, the guidance in RG 8.13, Instruction Concerning Prenatal Radiation Exposures, Revision 3, RG 8.36, Radiation Dose to the Embryo/Fetus, RG 8.40, Methods for Measuring Effective Dose Equivalent from External Exposure, TSs, and Exelons procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the results of radiation protection program audits related to internal and external dosimetry. The inspectors reviewed the most recent National Voluntary Laboratory Accreditation Program (NVLAP) report on the principal dosimetry used to establish dose of legal record. A review was conducted of Exelon procedures associated with dosimetry operations including issuance/use of external dosimetry and assessments of external and internal dose for radiological incidents. The inspectors evaluated whether Exelon had established procedural requirements for determining when external dosimetry and internal dose assessments were required.

External Dosimetry

The inspectors evaluated whether Exelons dosimetry vendor was NVLAP accredited and if the approved irradiation test categories for each type of personnel dosimeter used were consistent with the radiation present and the use of the dosimetry. The inspectors evaluated the onsite storage of dosimeters before issuance, during use, and before processing/reading and reviewed the guidance provided to radiation workers with respect to care and storage of dosimeters.

The inspectors assessed the use of electronic personal dosimeters to determine if Exelon used a correction factor to address the response of the dosimeters as compared to the dosimeter of legal record for situations when the electronic personal dosimeter was used to assign dose.

The inspectors reviewed three dosimetry occurrence reports or CAP documents for adverse trends related to electronic personal dosimeters and assessed whether Exelon had identified any adverse trends and implemented appropriate corrective actions.

Internal Dosimetry Routine Bioassay (In Vivo)

The inspectors reviewed procedures used to assess the dose from internally deposit radionuclides using whole body count (WBC) equipment and evaluated whether the procedures addressed methods for differentiating between internal and external contamination, the release of contaminated individuals, determining the route of intake, and the assignment of dose.

The inspectors reviewed the WBC process to determine if the frequency of measurements were consistent with the biological half-life of the radionuclides available for intake.

The inspectors reviewed Exelons evaluation for use of its portal radiation monitors as a passive monitoring system and assessed if instrument minimum detectable activities were adequate to determine the potential for internally deposited radionuclides sufficient to prompt an investigation.

The inspectors selected five WBCs and evaluated whether the counting system used had sufficient counting sensitivity for the potential radionuclides of interest. The inspectors evaluated how Exelon accounts for hard-to-detect radionuclides in their internal dose assessments.

Special Bioassay (In Vitro)

There was no internal dose assessments obtained using in-vitro results for the inspectors to review. The inspectors reviewed the vendor laboratory quality assurance program and assessed whether the laboratory participated in an industry-recognized cross-check program.

Internal Dose Assessment - Airborne Monitoring

Exelon had not performed any internal dose assessments using airborne/derived air concentration monitoring during the period reviewed.

Internal Dose Assessment - WBC Analyses

The inspectors determined Exelon has not documented any internal dose assessments using WBC results during the period reviewed.

Special Dosimetry Situations Declared Pregnant Workers

The inspectors assessed whether Exelon informed workers of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for (voluntarily) declaring a pregnancy. The inspectors reviewed the records for two individuals who had declared pregnancy during the current assessment period and evaluated the radiological monitoring program (internal and external) for these declared pregnant workers and the dose to the embryo/fetus. The inspectors reviewed exposure results and monitoring controls that were implemented.

Dosimeter Placement and Assessment of Effective Dose Equivalent for External Exposures

The inspectors reviewed the methodology for monitoring external dose where large dose gradients existed and evaluated the criteria for determining when the use of multi-badging was implemented. The inspectors reviewed selected dose assessments performed using multi-badging to evaluate whether the assessment was performed consistent with procedures and industry standards.

Neutron Dose Assessment

The inspectors evaluated the neutron dosimetry program including dosimeter types and/or radiation survey instrumentation. The inspectors reviewed neutron exposure occurrences for independent spent fuel storage installations work and assessed whether dosimetry and/or instrumentation was appropriate for the expected neutron spectra, there was sufficient sensitivity for low dose and/or dose rate measurement, and that neutron dosimetry and/or neutron detection instruments were properly calibrated.

Problem Identification and Resolution

The inspectors assessed whether problems associated with occupational dose assessment were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in the CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by Exelon involving occupation dose assessment.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and

Transportation (71124.08)

a. Inspection Scope

During the period of June 23 - 27, 2014, the inspectors verified the effectiveness of Exelons programs for processing, handling, storage, and transportation of radioactive material. The inspectors used the requirements of 10 CFR Part 20, Part 61,Licensing Requirements For Land Disposal of Radioactive Waste, and Part 71, Packing and Transportation of Radioactive Material, and 10 CFR Part 50, Appendix A, Criterion 63, Monitoring Fuel and Waste Storage, and Exelon procedures required by the TSs/Process Control Program (PCP) as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the solid radioactive waste system description in the UFSAR, the PCP, and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste disposed.

The inspectors reviewed the scope, the results, and the adequacy of Exelons corrective actions of quality assurance audits performed since the last inspection.

Radioactive Material Storage

The inspectors inspected areas where containers of radioactive waste were stored.

The inspectors verified that the radioactive materials storage areas were controlled and posted as appropriate.

The inspectors verified that Exelon had established a process for monitoring the impact of long-term storage (e.g., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water). The inspectors verified that there were no signs of swelling, leakage, or deformation.

Radioactive Waste System Walkdown

The inspectors walked down accessible portions of liquid and solid radioactive waste processing systems to verify and assess that the current system configuration and operation agree with the descriptions in the UFSAR, offsite dose calculation manual, and PCP.

The inspectors identified radioactive waste processing equipment that was not operational and/or was abandoned in place and verified that Exelon had established administrative and/or physical controls for the protection of personnel from unnecessary personnel exposure.

The inspectors reviewed the adequacy of any changes made to the radioactive waste processing systems since the last inspection. The inspectors verified that changes from what was described in the UFSAR were reviewed and documented.

The inspectors identified processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers. The inspectors verified that the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the PCP and provided representative samples of the waste product for the purposes of waste classification.

For those systems that provide tank recirculation, the inspectors verified that the tank recirculation procedure provided sufficient mixing. The inspectors verified that Exelons PCP correctly described the current methods and procedures for dewatering waste.

Waste Characterization and Classification

The inspectors identified radioactive waste streams and verified that Exelons radiochemical sample analysis results were sufficient to support radioactive waste characterization. The inspectors verified that Exelons use of scaling factors and calculations to account for difficult-to-measure radionuclides was technically sound and based on current analyses.

The inspectors verified that changes to plant operational parameters were taken into account to maintain the validity of the waste stream composition data between the annual or biennial sample analysis update and verified that waste shipments continued to meet applicable requirements.

The inspectors verified that Exelon had established and maintained an adequate quality assurance program to ensure compliance with applicable waste classification and characterization requirements.

Shipment Preparation

The inspectors reviewed the records of shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and Exelons verification of shipment readiness. The inspectors verified that the requirements of any applicable transport cask certificate of compliance had been met. The inspectors verified that the receiving licensee was authorized to receive the shipment packages.

The inspectors determined that the shippers were knowledgeable of the shipping regulations and that shipping personnel demonstrated adequate skills to accomplish the package preparation requirements for public transport. The inspectors verified that Exelons training program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities.

Shipping Records

The inspectors identified non-excepted package shipment records and verified that the shipping documents indicated the proper shipper name, emergency response information and a 24-hour contact telephone number, accurate curie content and volume of material, and appropriate waste classification, transport index, and international shipping identification number. The inspectors verified that the shipment placarding was consistent with the information in the shipping documentation.

Identification and Resolution of Problems

The inspectors verified that problems associated with radioactive waste processing, handling, storage, and transportation were being identified by Exelon at an appropriate threshold, were properly characterized, and verified the appropriateness of the corrective actions for a selected sample of problems. Exelon generated six CRs to document material condition deficiencies identified during this inspection.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 RCS Specific Activity and RCS Leak Rate (4 samples)

a. Inspection Scope

The inspectors reviewed Exelons submittal for the RCS specific activity (BI01) and RCS leak rate (BI02) PIs for Unit 1 and Unit 2 for the period of January 1 through December 31, 2013. To determine the accuracy of the PI data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements of RCS leakage and compared that information to the data reported by the PI. Additionally, the inspectors observed surveillance activities to verify that the chemistry personnel taking and analyzing an RCS sample followed procedures and processes.

b. Findings

No findings were identified.

.2 Occupational Exposure Control Effectiveness (2 samples)

a. Inspection Scope

From April 7 - 10, 2014, the inspectors sampled Exelon submittals for the occupational exposure control effectiveness (OR01) PI for Unit 1 and Unit 2 for the period of January 1 through December 31, 2013. To determine the accuracy of the PI data reported during those periods, the inspectors used definitions and guidance contained in NEI 99-02, Revision 7.

To assess the adequacy of Exelons PI data collection and analyses, the inspectors discussed with radiation protection staff the scope and breadth of its data review and the results of those reviews. The inspectors independently reviewed electronic personal dosimetry accumulated dose alarms, dose reports, and dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized PI occurrences. The inspectors also conducted walkdowns of numerous locked high and very high radiation area entrances to determine the adequacy of the controls in place for these areas.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Exelon entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended CR screening meetings.

b. Findings

No findings were identified.

.2 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a semi-annual review of site issues as required by Inspection Procedure 71152 to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely related issues that may have been documented by Exelon outside of the CAP such as trend reports, PIs, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or CAP backlogs. The inspectors also reviewed Exelons CAP database for the first and second quarters of 2014 to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed Exelons quarterly trend reports for the fourth quarter of 2013 and the first quarter of 2014 conducted under CNG-QL-1.01-1008, Periodic QPA Performance Reporting Process, Revision 00500, to verify that Exelon personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.

b. Findings and Observations

No findings were identified.

In the fourth quarter of 2013, the inspectors identified a growing trend in the area of human performance which included improper tagging, plant transients, and configuration control including mispositioning events. Despite increased awareness provided by station management and corrective actions directed at correcting this ongoing issue, during the first and second quarters of 2014, Unit 2 operations department, in particular, continued to experience the majority of the challenges in this area. Specifically, the following issues occurred at Unit 2:

CR-2013-009846, bottom head valve mispositioned on December 4, 2013

CR-2014-001466, carbon dioxide valves incorrectly repositioned on February 20, 2014

CR-2014-001689, valve found mispositioned on March 1, 2014

CR-2014-001963, bumping results in reactor scram on March 10, 2014

CR-2014-002507, SFP pump trip while hanging tags on March 26, 2014

CR-2014-002589, tagging controls insufficient for maintenance work on March 27, 2014

CR-2014-002844, jet pump switch mispositioned on March 31, 2014

CR-2014-002983, tagging results in backup scram signal on April 3, 2014

CR-2014-003126, Division II EDG valve found mispositioned on April 6, 2014

CR-2014-003301, main steam isolation valve tag stated closed and found open on April 8, 2014

CR-2014-003392, bundle incorrectly oriented in SFP on April 10, 2014

CR-2014-003404, bundle incorrectly oriented in reactor core on April 11, 2014

CR-2014-003815, primary component cooling valve found mispositioned on May 8, 2014

CR-2014-001963 and CR-2014-003301 were caused by maintenance and instrument and control departments, respectively. However, the operations department had the opportunity to prevent both issues.

On April 4, 2014, Exelon staff generated CR-2014-003047 to elevate and reevaluate this ongoing trend in the operations department. At the time the CR was written, the first eight events were identified. Since that time, five more events occurred. Exelons assessment concluded that previous corrective actions to address these behaviors have not been robust or timely enough. Additional corrective actions have been developed and are currently being administered to address this trend. Corrective actions included leadership training and mentorship programs for shift managers as well as developing team building exercises for shift crews. The improved shift manager training will emphasize strengthening relationships between Unit 1 and Unit 2 supervisors and provide a forum for shift managers to reinforce leadership expectations. Additionally, future resource loading will be reviewed to facilitate above-normal base load work. The inspectors review determined that corrective actions appeared reasonable to improve operator performance. The inspectors will continue to assess open corrective actions related to operations performance through daily review of the CAP.

.3 Annual Sample:

Corrective Actions for Unit 1 Loss of Shutdown Cooling Event

a. Inspection Scope

The inspectors performed an in-depth review of Exelons evaluations and effectiveness of corrective actions associated with Unit 1 loss of shutdown cooling event which occurred on April 16, 2013. The inspectors assessed Exelons problem identification threshold, associated analyses and evaluations, and prioritization and timeliness of corrective actions pertaining to loss of shutdown cooling event and issues identified during Exelons and the NRCs evaluation of the event. The inspectors performed this review to determine whether Exelon personnel were appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned and completed corrective actions were appropriate. The inspectors reviewed CRs, a RCA, and an apparent cause evaluation, as well as conducted interviews with various Exelon staff to assess the adequacy, effectiveness, and timeliness of implemented corrective actions.

This sample primarily focused on the evaluations associated with the event and the development and implementation of corrective actions. The event itself was documented in NRC Integrated Inspection Report 05000220/2013003 and 05000440/2013003 (ML13225A471), dated August 13, 2013; the NRCs Preliminary Choice Letter (ML13266A237), dated September 23, 2013; and the NRCs Final Significance Determination of Green Finding Letter (NRC Inspection Report 05000220/2013010, ML13344A989), dated December 10, 2013. Two Green NCVs were documented in NRC Inspection Report 05000220/2013010.

b. Observations

One finding was identified which is discussed in Section 4OA2.3.c below.

As discussed in the Final Significance Determination Letter, the inspectors conducted a focused problem identification and resolution sample to review the development and implementation of Exelons corrective actions associated with the loss of shutdown cooling event that occurred at Unit 1 on April 16, 2013, and Exelons actions to address the lessons learned from this event at a fleet level.

The inspectors reviewed Exelon staffs RCAs (CR-2013-002926 and CR-2013-002916)and additional CRs written for the event. As discussed in the NRC inspection reports and letters reviewing this event, there were two separate and distinct performance deficiencies identifieda loss of equipment configuration control which resulted in an unplanned loss of DC Bus 21 and an inadequate procedural guidance which resulted in the unplanned loss of all shutdown cooling during restoration from the loss of DC Bus 21. Additionally, there was a significant complicating factor identifiedthe planning and scheduling of the LOOP/loss-of-coolant accident (LOCA) testing, which although permitted by TSs, significantly impacted the plant risk presented by this event.

While Exelon did not have a single evaluation which encompassed the entire event, the inspectors concluded that Exelon staff did evaluate and develop corrective actions for each of the major aspects discussed in NRC Inspection Report 05000220/2013010. The inspectors determined that the corrective actions were reasonable and appeared appropriate to address the issues identified in the report. Effectiveness reviews of the corrective actions were scheduled where appropriate.

However, the inspectors made several observations. First, the RCA associated with CR-2013-002926 included a corrective action to prevent recurrence which was to revise Unit 1 procedures N1-SOP-47A.1, Loss of DC Power, Revision 00101, and N1-OP-47A, 125 VDC Power System, Revision 02600, to include sufficient detail to allow for restoration of the DC bus without unexpected responses from connected loads and to address any and all interlocks. These were the inadequate procedures cited in NRC Inspection Report 05000220/2013010 which documented NCV 05000220/2013010-01, Improper Bus Restoration Results in Loss of Shutdown Cooling. Accordingly, this corrective action was necessary in order to fully restore compliance for this NCV. The original due date to revise the procedures was July 2013. On April 16, 2014, the inspectors confirmed that this corrective action was not completed. All other corrective actions involving procedure changes were completed. This observation is discussed further in section 4OA2.3.c below.

Second, the inspectors identified two missed opportunities to develop corrective actions following the April 2013 loss of cooling event which were not specifically discussed in Exelons evaluations. The first missed opportunity was prior to the Unit 1 RFO when a focused area self-assessment (SA-2013-00013 dated March 8, 2013) was conducted to review outage readiness. This self-assessment included a focus area of outage shutdown risk management. This review did not result in any findings, deficiencies, or enhancements, and did not challenge the scheduling of the LOOP/LOCA testing concurrent with reactor vessel head removal, reduced inventory condition, and resultant short time to reach core boiling. This was a missed opportunity for Exelon to implement compensatory actions that could have reduced the significance of the event.

The second missed opportunity identified by inspectors was that Exelon did not identify procedure N1-OP-47A, Revision 2500, Section H-14, Transfer of DC Control Power for PB 16 to Support Maintenance, and Section H-15, Transfer of DC Control Power for PB 17 to Support Maintenance, contained guidance which could have precluded the loss of shutdown cooling event if it would have been directed to be entered via another procedure. Both sections contained caution statements which stated failure to properly align [control rod drive] CRD, SFP cooling, and shutdown cooling may result in pumps tripping when DC control power is transferred. Sections H-14.4/H-14.7 and H-15.4/H-15.7 of N1-OP-47A discussed removing/reinstalling trip fuses for the running SFP pumps if the pump was required to remain in service. Had Exelon identified this, the appropriate procedures could have been updated to reference N1-OP-47A and provide a second layer of defense to preclude a potential loss of shutdown cooling and other equipment important to reactor safety.

c. Findings

Introduction.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for failure to ensure that corrective actions to preclude repetition for a significant condition adverse to quality were implemented in a timely manner. Specifically, corrective actions to preclude repetition for the April 16, 2013, loss of shutdown cooling event to revise two inadequate Unit 1 procedures had not been completed over a year after the initial event. This corrective action was developed to fully restore compliance with NCV 05000220/2013010-01. If left uncorrected, the inspectors determined there was the potential for 10 different pumps and breakers at Unit 1 to unexpectedly trip upon restoration of a DC bus. The loss of several of these pumps and loads would result in an unexpected plant transient or require a manual reactor trip.

Description.

NRC Inspection Report 05000220/2013010 documented NCV 05000220/2013010-01, Improper Bus Restoration Results in a Loss of Shutdown Cooling. This was an NCV of Unit 1 TS 6.4.1, Procedures, because NMPNS did not establish adequate procedures for the onsite DC system to include a loss of electrical power. Specifically, on April 16, 2013, following the loss of vital DC Bus 12, operators attempted to restore power to the bus using procedures N1-OP-47A and N1-SOP-47A.1.

While those procedures indicated tripping circuits and tripping actions may be carried out when power is reestablished, the procedures did not specify all of the affected components including shutdown cooling pumps. As a result, when operators attempted to reestablish power, Unit 1 temporarily lost all shutdown cooling capability.

Exelons RCA, described in CR-2013-002926, developed one corrective action to preclude repetition for the loss of shutdown cooling event. This RCA was approved on June 3, 2013, and required the following:

CAPR#1: Revise the DC procedures N1-OP-47A and N1-SOP-47A.1 to include a restoration section for loss of the battery board.

This is to include sufficient detail to allow for restoration of the bus without unexpected responses from connected loads and to address any interlocks. Due date July 31, 2013.

During the week of April 14, 2014, NRC inspectors conducting a follow-up problem identification and resolution sample to review the corrective actions implemented following the April 16, 2013, loss of shutdown cooling event. During the review, the inspectors identified that procedures N1-OP-47A and N1-SOP-47A.1 had not been revised. Further, the inspectors identified that although the due date for this corrective action had been properly extended from July 31 until September 30, 2013, the corrective action was extended a second time from September 30, 2013, to March 29, 2014, on the basis that this was a long-term corrective action which required multiple cycles of operator training to implement. However, this extension was not signed by the management review committee chairperson. The corrective action was extended a third time from March 29, 2014, to June 20, 2014, since neither the procedure change nor the training had been completed. The justification and safety evaluation for the extensions did not address the increase in plant risk that would occur during restoration of a DC bus at power, and the fact that the loss of a DC bus puts the plant in a 2-hour shutdown action statement, adds time pressure and increases the likelihood for human error without adequate procedural guidance.

Exelon wrote CR-2014-005693 in response to the inspectors questions and determined that inadequate resources were assigned to this corrective action to preclude repetition.

The corrective action was assigned to a single senior reactor operator (SRO) as a collateral duty; although Exelon determined these actions required 600 to 700 man hours of work to research and develop the new procedures. Exelon management had three opportunities to address this problem during the management review committee reviews for the corrective action to preclude repetition extensions discussed above since the lack of resources was the reason the extensions were required.

The inspectors also identified that Revision 02600 to N1-OP-47A which was issued on July 10, 2013, was an opportunity for the procedural guidance to be updated.

Considering that all other recommended corrective actions and enhancements involving procedure changes had been implemented, the inspectors determined that Exelons failure to revise procedures N1-OP-47A and N1-SOP-47A.1 a year after the initial event constituted untimely corrective action.

The inspectors compared the procedures for Unit 1 and Unit 2 regarding DC system operation and identified that Unit 2s procedures contained more specific guidance for operators regarding which loads would be adversely affected during a loss of DC power and what loads could de-energize during the restoration of a DC bus. The inspectors noted that NMPNS identified in CR-2013-002926 a list of Unit 1 components which were susceptible to tripping upon bus restoration. However, the inspectors could not find any guidance or standing orders directing operators to refer to that list if another loss of DC power occurred.

The list of control circuits with pumps susceptible to trip conditions when re-energized included the RRPs, reactor feedwater pumps 11 and 12, reactor water cleanup pumps, mechanical vacuum pumps, condensate spray pump, control rod drive water pumps, SFP cooling pumps, shutdown cooling pumps, core spray topping pump, and the EDG output breaker. Since the loss of several of these pumps at power would result in a significant power excursion or require a manual reactor trip, the failure to update this procedure in a timely manner would increase the potential for an unexpected plant transient. Since the inspectors review, the corrective actions were completed and the procedures issued on June 12, 2014.

Analysis.

The failure of Exelon staff to complete a corrective action to preclude recurrence, to revise procedures N1-OP-47A and N1-SOP-47A.1, in a timely manner was a performance deficiency that was reasonably within Exelons ability to foresee and correct and should have been prevented. This finding is more than minor because it impacted the procedure quality attribute of the Initiating Events cornerstone and adversely affected the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, if left uncorrected, there was the potential for 10 different pumps and breakers to unexpectedly trip upon restoration of a DC bus. Several of these pumps and loads would result in an unexpected plant transient or require a manual reactor trip.

In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the finding did not involve the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and affected mitigation equipment.

This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Resolution, because Exelon did not take effective corrective actions to address an issue in a timely manner commensurate with its safety significance.

Specifically, Exelon failed to implement corrective actions to prevent recurrence, CA#1 from CR-2013-002926, to revise procedures N1-SOP-47A.1 and N1-OP-47A to contain adequate guidance to ensure recovery from a loss of a DC bus would not result in an unexpected plant transient a year after the event occurred [P.3].

Enforcement.

10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, states:

Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.

Contrary to the above, from September 30, 2013, until June 14, 2014, Exelon failed to promptly correct a significant condition adverse to quality and report the status of the approved corrective actions to Exelon management. Specifically, NMPNS did not complete corrective actions to preclude repetition CA#1 for CR-2013-002926 to revise two inadequate DC procedures which were the subject of a previous NCV, NCV 05000220/2013010-01, Improper Bus Restoration Results in a Loss of Shutdown Cooling, and failed to inform Exelon management that additional resources were required to complete the corrective actions to preclude repetition in a timely manner.

Because this violation is of very low safety significance (Green) and Exelon entered this issue into its CAP (CR-2014-005693), this violation is being treated as an NCV consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000220/2014003-02, Failure to Correct a Significant Condition Adverse to Quality in a Timely Manner)

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

.1 Plant Event (1 sample)

a. Inspection Scope

For the plant event listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant event to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, issued October 28, 2011, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Exelon made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Exelons follow-up actions related to the event to assure that Exelon implemented appropriate corrective actions commensurate with their safety significance.

Unit 2 loss of SFP cooling on March 26, 2014

b. Findings

Introduction.

A self-revealing Green NCV of TS 5.4.1, Procedures, was identified at Unit 2 for Exelons failure to provide adequate procedures to override valve 2SFC*AOV154, filters inlet isolation valve, prior to performing LOOP testing.

Specifically, procedures N2-OSP-EGS-R004, Operating Cycle Diesel Generator Simulated Loss of Offsite Power With ECCS Division I & II, Revision 01200, and N2-VLU-01, Valve Lineup and Valve Operations, Revision 00001, did not contain adequate guidance on how to align valve 2SFC*AOV154 so it would not reposition to its fail-safe closed position when power was lost to the actuator. As a result, on March 28, 2014, operators did not correctly align the valve while implementing N2-VLU-01 resulting in 2SFC*AOV154 failing closed and a subsequent partial loss of SFP cooling.

Description.

On March 26, 2014, Unit 2 was shutdown for a RFO in Mode 5 with the reactor vessel head removed and the refuel cavity flooded up to support refueling activities. The refueling gates between the cavity and the SFP were still installed.

Exelon was preparing to implement N2-OSP-EGS-R004 to test Division II EDGs ability to restore power to safety-related loads following a simulated LOOP and ECCS initiation signal. At 5:30 p.m., during shift turnover, the oncoming night shift was informed that they would need to perform Step 8.1.16 of N2-OSP-EGS-R004, which directed the operators to override open valve 2SFC*AOV154 per Figure 3 of N2-VLU-01, Operation of Bettis Actuators. Overriding the fail-safe mode of 2SFC*AOV154 was necessary to prevent a loss of spent fuel cooling during performance of the test since the valve is designed to fail closed on a loss of power which would result in a trip of spent fuel cooling pump A.

At 7:30 p.m., the operators assigned to realign 2SFC*AOV154 received a brief from a reactor operator and a SRO. The brief included the need to coordinate the valve alignment with other plant activities, a job hazard analysis, a discussion regarding the procedure to be used to override the valve to the non-failure position per N2-VLU-01 Figure 3, operationally focused questions, the importance of work on protected decay heat removal equipment, and the need for SRO oversight. The SRO designated to provide oversight during the activity did not attend the brief, but had been informed of the reason for the alignment. Prior to beginning the work, the assigned plant operators reviewed Figure 3 of N2-VLU-01. Figure 3 contained one section with general information on Bettis actuators and three sections for operating Bettis actuators. These sections are labeled under Figure 3 as: 1.0 General Information, 2.0 To Override a Valve With Air Supplied to the Valve, 3.0 To Reposition a Valve to its Non-Failure Position, and 4.0 To Operate ETS Style Actuators. After reviewing the procedure, the plant operators chose to implement Section 3.0, based on its title, To Reposition a Valve to its Non-Failure Position. However, the plant operators should have implemented Section 2.0, To Override a Valve With Air Supplied to the Valve.

At 9:47 p.m., while implementing the steps in N2-VLU-01, Figure 3, Section 3.0, operators isolated air to 2SFC*AOV154 which caused the valve to fail closed. As a result, pump 2SFC*P1A tripped as designed due to low flow which caused a loss of spent fuel cooling. Upon hearing 2SFC*P1A trip, the plant operators who isolated air to 2SFC*AOV154 contacted the control room to inform them of their actions. In response to the loss of pump 2SFC*P1A control room operators entered procedure N2-SOP-38, Spent Fuel Pool Cooling and Cleanup System, Revision 01900, Section E, Startup, 2.0, Starting Pump 1A in Cooling Only Mode [SOP]. Pump 2SFC*P1A was restarted and spent fuel cooling pump was restored after 16 minutes. During the loss of 2SFC*P1A, RHR pump B provided cooling for the reactor vessel and SFP, and the temperature and level of the SFP did not change. Exelon entered the loss of SFP cooling into the CAP as CR-2014-002507. Initial corrective actions included coaching the individuals involved and reinforcing Exelons expectations regarding what information should be discussed during pre-job briefs.

Analysis.

The inspectors determined that the failure of procedure N2-OSP-EGS-R004 to provide operators with a specific section of Figure 3 in procedure N2-VLU-01 to use when aligning valve 2SFC*AOV154 was a performance deficiency that was reasonably within Exelons ability to foresee and correct and should have been prevented. This finding is more than minor because it is associated with the configuration control attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the failure to provide adequate procedural guidance in N2-OSP-EGS-R004 and N2-VLU-01 resulted in an unplanned loss of SFP cooling.

In accordance with IMC 0609.04, Initial Characterization of Findings, issued June 19, 2012, the inspectors used IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, because the SFP was still isolated from the reactor core at the time of the finding. Using Appendix A, Exhibit 3 - Barrier Integrity Screening Questions Section D, Spent Fuel Pool (SFP), the inspectors determined that this finding is of very low safety significance (Green) because although the performance deficiency adversely affected decay heat removal capabilities from the SFP, the pool temperature did not exceed the maximum analyzed temperature limit specified in the site-specific licensing basis, the performance deficiency did not involve a fuel handling error, did not affect the SFP neutron absorber, and did not result in a loss of SFP water inventory.

This finding has a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because Exelon did not ensure that individuals stopped in the face of uncertain conditions. Specifically, after recognizing that N2-VLU-01 Figure 3 contained multiple sections that were not clearly labeled, plant operators did not stop and consult supervision for guidance but continued on with an erroneous assumption as to which section to use [H.11].

Enforcement.

TS 5.4.1, Procedures, requires written procedures to be established, implemented, and maintained covering the applicable procedures recommended in RG 1.33, Quality Assurance Program Requirements (Operation), Appendix A, Revision 2, dated February 1978. Procedure N2-OSP-EGS-R004, Operating Cycle Diesel Generator Simulated Loss of Offsite Power with ECCS Division I & II, is a procedure recommended by Section 8 of RG 1.33, Appendix A. Contrary to the above, procedure N2-OSP-EGS-R004 was not adequately maintained. Specifically, Step 8.1.16 of procedure N2-OSP-EGS-R004 did not contain adequate instructions to ensure that the appropriate section in Figure 3 of N2-VLU-01 was used and resulted in loss of SFP cooling. Because this violation is of very low safety significance (Green) and Exelon entered this issue into their CAP (CR-2014-002507), this finding is being treated as an NCV consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000410/2014003-03, Loss of Spent Fuel Cooling Pump due to Inadequate Procedures)

.2 (Closed) Licensee Event Report (LER) 05000220/2014-001-00:

Reportable Conditions

Not Reported During the Previous 3 Years Involving Power Range Monitors Inoperability

On February 12, 2014, Exelon staff discovered that Unit 1 had not reported two conditions when the average power range monitor (APRM) was inoperable in accordance with the administrative guidance in NUREG-1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, Revision 3. Both of the events represented a condition that could have prevented the fulfillment of the safety function of a structure or system needed to shut down the reactor and maintain it in a safe condition. In both events, the APRMs were declared inoperable as a result of RRP trips resulting in the flow biased control rod block and scram functions being non-conservative at lower power conditions. LER 05000220/2014-001-00 was generated to acknowledge that NMPNS failed to provide an LER for the two events described below:

The first reportable condition occurred on March 20, 2011, at 3:48 p.m. Prior to this event, the plant was operating at 89 percent power with five recirculation pumps in operation. When personnel attempted to remove RRP 14 discharge and discharge bypass valves from their back-seated positions per an operations department special order, RRP 14 tripped. Operations entered N1-SOP-1.3, Recirc Pump Trip at Power, Revision 01, for the recirculation pump trip. N1-SOP-1.5, Unplanned Reactor Power Change, Revision 04, was performed for the unplanned power change. The plant subsequently commenced a shutdown to start a planned RFO.

The second reportable condition occurred on January 3, 2012; at 9:30 p.m. while the plant was operating at 100 percent rated thermal power with four recirculation pumps in operation. During this event, operators inappropriately removed a potential transformer drawer to verify the transformers were properly racked in which resulted in tripping RRP 13. N1-SOP-1.3 and N1-SOP-1.5 were entered as required and reactor power was reduced to 85 percent power. The plant returned to rated thermal power on January 4.

The inspectors reviewed this issue and questioned whether this was applicable to loss of flow events at Unit 2 such as the one that occurred on December 2, 2013. Unit 2 has Oscillation Power Range Monitors to provide redundant protection under loss of flow conditions; thus, the safety function was not lost for Unit 2.

The inspectors reviewed both Unit 1 events for significance using IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined that in both cases, the operators recognized the conditions, entered the appropriate TS action statements, and took timely actions to adjust APRM protective limit set points within 15 minutes to correct the non-conservative conditions and restore the safety function. As a result, the issues were determined to be of minor risk significance.

With respect to the failure to report the conditions under 10 CFR 50.72(b)(3)(v)(A) and 50.73(a)(2)(v)(A) in a timely manner, the inspectors determined that Exelon staff did have the information available to them at the time to make the appropriate required reports and failed to do so. However, since Exelon staff identified the error and corrected the public record by generating this late report, this would be considered an untimely report vice failure to make a required report. In accordance with the NRC Enforcement Policy examples an untimely report would be considered a minor violation as long as basis of any regulatory decisions would not have be changed had the report been made in a timely manner. Had both events been reported as safety system functional failures, the associated PI would have remained below the Green to White threshold of no greater than six safety system functional failures in a 12-month period.

Thus, this violation was determined to be minor. This LER is closed.

.3 (Closed) LER 05000410/2013-004-00:

Manual Reactor Protection System Actuation due to Loss of Reactor Recirculation Flow

On December 2, 2013, at 9:03 a.m., Unit 2 was lowering reactor power level to remove the main turbine from service to support maintenance. During the power reduction, the low frequency motor generators did not start automatically. Attempts to manually start the recirculation system pumps in slow speed were unsuccessful and a manual reactor scram was inserted due to the sudden reduction in core flow. This event was reportable in accordance with 10 CFR 50.73(a)(2)(iv)(A) as a condition that resulted in manual or automatic actuation of any of the systems listed in 10 CFR 50.73(a)(2)(iv)(B).

The root cause of this event is a failure to identify that the switches in the auto transfer circuits for the RRPs to shift from high speed to low speed were single-point vulnerable components because they were exempted from the AP-913 classification process.

Since the switches were not classified as single-point vulnerable components, no mitigation strategies were developed. Corrective actions include revision of the operating procedures to manually start the low frequency motor generator sets and not rely on the auto transfer circuitry. The enforcement aspects of this issue are discussed below. This LER is closed.

b. Findings

Introduction:

The inspectors identified a self-revealing Green Finding (FIN) against procedure CNG-AM-1.01-2000, Scoping and Identification of Critical Components, Revision 00200. Specifically, Exelon staff performed an inadequate AP-913 evaluation in 2006. This evaluation failed to identify that RRP switches S101A and S101B were single-point vulnerable components, so mitigating strategies to ensure proper operation to minimize plant risk were not developed. As a result, on December 2, 2013, both RRPs failed to properly shift from fast to slow speed resulting in a loss of all recirculation flow through the core and requiring operators to insert a manual reactor scram in accordance with plant procedures.

Description.

On December 2, 2013, at 9:03 a.m., Unit 2 operators were lowering reactor power level to remove the main turbine from service to support maintenance on a 5th point feedwater heater level control valve. With reactor power at 41 percent, operators attempted to shift both RRPs from fast to slow speed in accordance with plant procedure N2-OP-29, Reactor Recirculation System, Revision 01801, Section G, Shutdown, Step 1.6. During the shift, the pump high-speed circuit breakers CB5A and CB5B tripped as designed; however, both low frequency motor generator sets did not automatically start. This caused a loss of reactor recirculation flow through the core and a reduction of power to 25.5 percent. Operators immediately recognized that the recirculation pumps failed to properly shift to slow speed and manually started both low frequency motor generator sets by closing their supply breakers CB1A and CB1B in accordance with CNG-OP-1.01-1000, Conduct of Operations, Revision 01000.

Although both motor generators started, recirculation pump speeds had slowed below the value which would permit a pump start. As a result, operators entered N2-SOP-29, Sudden Reduction in Core Flow, Revision 01301, and manually inserted a reactor scram as directed by the procedure. All safety systems responded to the manual scram as expected, and there were no complications.

Exelon staff conducted a post-trip review and initiated CR-2013-009735 to determine the cause of the recirculation pumps failing to start in slow speed as designed. The direct cause was determined to be high-resistance connections in the auto transfer circuits associated with switches S101A and S101B. This caused the auto transfer relays K121A and K121B to not actuate during the pump transfer and initiate the starting of the low frequency motor generator sets as designed. Corrective actions included revising procedure N2-OP-29 to direct operators to manually start the low frequency motor generator sets, implementing a preventive maintenance activity for these switches, and developing plans to replace the switches during the next RFO.

The RCA associated with CR-2013-009735 subsequently determined that switches S101A and S101B were a single-point vulnerable. In 2006, Exelon staff conducted an Institute of Nuclear Power Operations AP-913 evaluation in accordance with procedure CNG-AM-1.01-2000, Scoping and Identification of Critical Components, Revision 00202. The purpose of the AP-913 evaluation was to identify critical components and single-point vulnerable components. Single-point vulnerability is defined as a single component or portion of a system whose failure as a minimum will result in a reactor trip or potential lost generation of greater than 20 percent. For identified single-point vulnerabilities, mitigation strategies were required to be developed to eliminate the vulnerability or reduce the plant risk.

During this evaluation, switches S101A and S101B were inappropriately determined to be exempt from the AP-913 review. While hand switches are listed in CNG-AM-1.01-2000, Attachment 1, EXEMPT Components Port, the guidance states:

If a reduction in supplied voltage level due to high fuse component resistance has the potential to create a new or different failure mode, then fuse failure should be evaluated separately from the supplied component evaluation. In some cases, PMs that include periodic inspections and cleanings can be used to reduce or mitigate the likelihood of these failure modes.

While hand switches are not specifically discussed in that guidance, Exelon determined that these hand switches should have been screened into the review since a high-resistance connection can introduce a new failure mechanism for the system. Since this failure results in a manual reactor trip, it would also be a single-point vulnerability. As a result, a mitigating strategy such as the vendor recommended periodic cleaning and inspection of these switches should have been implemented for switches S101A and S101B. As a result of being screened out, S101A and S101B had no preventive maintenance activities and eventually failed to operate.

The inspectors reviewed Exelons prompt investigation, post-trip review, CR-2013-009735, and LER 05000410/2013-004-00 and determined Exelons evaluation and determination of the cause was reasonable and appropriate corrective actions were developed and scheduled to be implemented in a timely manner. Since this performance deficiency resulted in a manual reactor scram, this finding is considered to be self-revealing.

Analysis.

Exelons failure to conduct an effective AP-913 evaluation in accordance with Exelon procedure CNG-AM-1.01-2000 and to identify single-point vulnerabilities and develop mitigating strategies for S101A and S101B is a performance deficiency that was within Exelons ability to foresee and correct and should have been prevented. This finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and adversely impacted the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.

Additionally, the performance deficiency is similar to Example 4b of IMC 0612, Appendix E, Examples of Minor Issues, issued August 11, 2009, in that the error resulted in a plant trip. Specifically, the failure to identify switches S101A and S101B as single-point vulnerabilities and develop appropriate mitigating strategies resulted in the failure of the switches and a manual reactor scram on December 2, 2013.

In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012; the inspectors determined that this finding is of very low safety significance (Green). The performance deficiency did not cause both a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition (e.g.; loss of condenser, loss of feedwater).

The inspectors did not assign a cross-cutting aspect to this finding because the performance deficiency was determined to have occurred in 2006, and the guidance in the current revision of CNG-AM-1.01-2000, Appendix A, was sufficient for Exelons root cause team to determine the switches should have been screened in. Therefore, this finding is not indicative of current licensee performance and no cross-cutting issue was assigned.

Enforcement.

This finding is against procedure CNG-AM-1.01-2000, Scoping and Identification of Critical Components, Revision 00202, for Exelons failure to identify that switches S101A and S101B were single-point vulnerabilities and develop appropriate mitigating strategies resulting in a plant scram. Procedure CNG-AM-1.01-2000 is not a procedure required by RG 1.33, Quality Assurance Program Requirements (Operation), Revision 2, and the work being performed was not on a safety-related system. Therefore, this finding does not involve enforcement action because no violation of a regulatory requirement was identified. The issue was entered into Exelons CAP as CR-2013-009735. Because this finding does not involve a violation and is of very low safety or security significance, it is identified as a FIN. (FIN 05000410/2014003-04, Failure to Identify Single-Point Vulnerabilities Results in a Manual Reactor Scram)

.4 (Closed) LER 05000410/2013-005-00:

Secondary Containment Inoperabilities Due to Differential Pressure Not Meeting Technical Specification Surveillance Requirement 3.6.4.1.1===

(Closed) LER 05000410/2014-005-00: Secondary Containment Inoperable Due to

Sustained High Winds (1 sample)

(Closed) LER 05000410/2014-007-00: Secondary Containment Inoperable Due to

Simultaneous Opening of Airlock Doors (1 sample)

LER 05000410/2013-005-00 reported that on December 11, 2013, NMPNS discovered secondary containment was rendered inoperable at Unit 2 and had not been reported to the NRC in accordance with the guidance contained in NUREG-1022, Revision 3, 10 CFR 50.72(b)(3)(v)(C), and 10 CFR 50.73(a)(2)(v)(C) as a condition that could have prevented the fulfillment of the safety function of a structure or system needed to control the release of radioactive material. This condition had occurred numerous times within the past 3 years when secondary containment was declared inoperable as a result of the differential pressure (DP) dropping below the TS SR 3.6.4.1.1 minimum value of vacuum water gauge. The direct causes of the secondary containment DP dropping below the SR minimum value were attributed to changes in outdoor environmental conditions (changing wind direction and velocity), valve lineup changes, or equipment failures associated with the normal non-safety-related RB ventilation system. In each case, operators entered the applicable limiting condition for operation (LCO) for TS 3.6.4.1, Secondary Containment, and subsequently exited the LCO once the secondary containment DP was restored. In all cases, secondary containment was restored to an operable status before the TS required completion time was exceeded. This was entered into Exelons CAP as CR-2013-010111.

LER 05000410/2014-005-00 reported that on March 12, 2014, Unit 2 operators declared secondary containment inoperable due to secondary containment DP dropping below the SR 3.6.4.1.1 minimum value of vacuum water gauge due to sustained high winds during winter storm Vulcan. In response to the event, operators isolated the RB normal ventilation, entered the LCO for TS 3.6.4.1, and subsequently exited the LCO once secondary containment DP was restored. The LCO action required completion time was not exceeded. This event was entered into Exelons CAP as CR-2014-002028.

LER 05000410/2014-007-00 reported that on April 2, 2014, Unit 2 operators declared secondary containment inoperable when workers inadvertently, momentarily, simultaneously opened RB airlock doors R261-1 and R261-2 while an activity which had the potential for draining the reactor vessel was in progress. Since the requirements of SR 3.6.4.1.3, which requires one secondary containment access door to be closed, was not met, operators entered and exited TS 3.6.4.1 once the airlock doors were verified to be properly closed (approximately 4 to 5 seconds). Accordingly, the LCO completion time was met. This event was entered into Exelons CAP as CR-2014-002881.

For the three events described above, corrective actions taken included writing the CRs referenced above, initiating the required reports to the NRC, and training SROs on the guidance in NUREG-1022, Revision 3, associated with 10 CFR 50.72(b)(3)(v)(C) and 10 CFR 50.73(a)(2)(v)(C) reporting requirements relative to secondary containment inoperability. Regarding the April 2 event, additional compensatory actions included stationing a door monitor at the airlock doors to ensure the airlock doors were operated correctly during the RFO, training operations and maintenance personnel on proper airlock access, and installing signs on the airlock doors that reinforced proper airlock operation.

For each of these events, a violation of plant TSs did not occur since the required TS action statements were entered and compensatory actions completed before the action time limit was exceeded. Further, the inspectors determined that during the events, secondary containment remained capable of performing its design basis function as described in the Unit 2 UFSAR Section 6.2.3.1. Specifically, the design of the secondary containment, as described in the Unit 2 UFSAR, is to enclose the primary containment and in conjunction with the SGTS and portions of the RB heating and ventilation return system, provide a means of controlling and minimizing leakage from primary containment to the outside atmosphere during a LOCA and from the refueling facilities (including the SFP) during a postulated refueling accident. Secondary containment utilizes the heating and ventilation return system during normal operation, and the SGTS during emergency operation to maintain a pressure of at least 0.25 of vacuum water gauge with respect to the outside atmosphere. This ensures that while the systems are operating, all leakage into the RB atmosphere is discharged through the filtration units of the SGTS or through a monitored release point.

To ensure air-in leakage is within the air-removal capability of the heating and ventilation return system and the SGTS, Unit 2 TS SR 3.6.4.1.1 ensures that air-in leakage is not greater than the capacity of the heating and ventilation return system (normally 2,670 cubic feet per minute). However, the safety-related SGTS which is credited during a design basis event has a capacity of 4,000 cubic feet per minute per train. As shown on March 12 for high wind conditions once the RB was isolated (as it would automatically be during a design basis accident), air-in leakage was within the capacity of the SGTS, and secondary containment remained capable of performing its design function.

Regarding the April 4 event while both airlock doors were opened simultaneously for 4 to 5 seconds, secondary containment vacuum was verified to stay above 0.25 inches of water during the event (thus air-in leakage was within the capacity of the SGTS which was in service during the event and administrative control of the doors was maintained as evidenced by workers closing the doors within seconds of identifying the condition.

Thus, secondary containment remained functional due to the brief amount of time both doors were open.

The inspectors reviewed the LERs for accuracy, the adequacy of proposed and completed corrective actions, and the appropriateness of the extent-of-condition review.

As discussed above, the underlying technical issue does not represent a violation of NRC requirements. However, for LER 05000410/2013-005-00, a performance deficiency was identified because NMPNS personnel failed to report secondary containment inoperable as required by 10 CFR 50.72(b)(3)(v)(C) and 10 CFR 50.73(a)(2)(v)(C) which was reasonably within Exelons ability to foresee and correct.

Since Exelon identified the missed report, properly made a late notification (LER 05000410/2013-005-00), and the late report would not have changed the basis of any NRC regulatory decisions, this is considered to be an untimely report vice the failure to make a required report. In accordance with the Section 2.2.1.c in the NRC Enforcement Policy, an untimely report would be considered to be a minor violation.

These LERs are closed.

4OA6 Meetings, Including Exit

On July 21, 2014, the inspectors presented the inspection results to Mr. Christopher Costanzo, Site Vice President, and other members of the NMPNS staff. The inspectors verified that no propriety information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

C. Costanzo, Vice President

P. Orphanos, Plant General Manger

J. Stanley, Plant General Manager

W. Trafton, Director, Operations

M. Busch, Director, Operations

K. Clark, Director, Security

J. Dean, Supervisor, Quality Assurance

S. Dhar, Design Engineering

J. Holton, Supervisor, Systems Engineering

S. Homoki, System Engineer

M. Kunzwiler, Security Supervisor

J. Leonard, Supervisor Design Engineering

E. Perkins, Director, Licensing

M. Shanbhag, Licensing Engineer

J. Snyder, Maintenance Rule Coordinator

T. Tanguay, Unit 2 General Supervisor, Operations

J. Thompson, General Supervisor, Mechanical Maintenance

J Tsardakas, Unit 1 General Supervisor, Operations

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000410/2014003-01

NCV

Inadequate Surveillance Testing of Reactor Core Isolation Cooling during 165 psig Reactor Pressure Test for Surveillance Requirement 3.5.3.4 (Section 1R15)

05000220/2014003-02

NCV

Failure to Correct a Significant Condition

Adverse to Quality in a Timely Manner (Section 4OA2)

05000410/2014003-03

NCV

Loss of Spent Fuel Cooling Pump due to

Inadequate Procedures (Section 4OA3)

05000410/2014003-04

FIN

Failure to Identify Single-Point Vulnerabilities

Results in a Manual Reactor Scram

(Section 4OA3)

Closed

05000220/2014-001-00

LER

Reportable Conditions Not Reported

During the Previous 3 Years Involving

Average Power Range Monitors

Inoperability (Section 4OA3)

05000410/2013-004-00

LER

Manual Reactor Protection System

Actuation due to Loss of Reactor

Recirculation Flow (Section 4OA3)

05000410/2013-005-00

LER

Secondary Containment Inoperabilities due

to Differential Pressure Not Meeting

Technical Specification Surveillance

Requirement 3.6.4.1.1 (Section 4OA3)

05000410/2014-005-00

LER

Secondary Containment Inoperable due to

Sustained High Winds (Section 4OA3)

05000410/2014-007-00

LER

Secondary Containment Inoperable due to

Simultaneous Opening of Airlock Doors

(Section 4OA3)