Text

IR 05000237-12-002, 05000249-12-002; on 01/01/2012 - 03/31/2012; Dresden Nuclear Power Station, Units 2 & 3, Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Program; Follow Up...
	ML12129A233
Person / Time
Site:	Dresden
Issue date:	05/08/2012
From:	Jamnes Cameron; NRC/RGN-III/DRP/B6
To:	Pacilio M; Exelon Generation Co, Exelon Nuclear
References
	IR-12-002
	Download: ML12129A233 (73)
	v • d • e

May 8, 2012

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - NRC INTEGRATED INSPECTION REPORT 05000237/2012002 and 05000249/2012002

Dear Mr. Pacilio:

On March 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Dresden Nuclear Power Station, Units 2 and 3. The enclosed inspection report documents the inspection results which were discussed on April 19, 2012, with Mr. D. Czufin, and other members of your staff.

The inspections 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.

Three self-revealing findings of very low safety significance (Green) were identified during this inspection. Two of these findings were determined to involve violations of NRC requirements.

Additionally, the NRC has determined that two traditional enforcement Severity Level IV violations occurred. Both of these traditional enforcement violations were identified with associated findings. The NRC is treating these violations as non-cited violations (NCVs)

consistent with Section 2.3.2 of the Enforcement Policy.

If you contest these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Dresden Nuclear Power Station. If you disagree with a cross-cutting aspect assignment 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 III, and the NRC Resident Inspector at the Dresden Nuclear Power Station. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agencywide Document Access and 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/

Jamnes L. Cameron, Chief Branch 6 Division of Reactor Projects Docket Nos. 50-237and 50-249 License Nos. DPR-19 and DPR-25

Enclosure:

Inspection Report 05000237/2012-002 and 05000249/2012-002 w/Attachment: Supplemental Information

REGION III==

Docket Nos: 05000237; 05000249 License Nos: DPR-19; DPR-25 Report No: 05000237/2012-002; 05000249/2012-002 Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station, Units 2 and 3 Location: Morris, IL Dates: January 1 through March 31, 2012 Inspectors: C. Phillips, Senior Resident Inspector D. Meléndez-Colón, Resident Inspector J. Beavers, Emergency Preparedness Inspector T. Briley, Reactor Engineer A. Dunlop, Senior Reactor Engineer Z. Falevits, Senior Reactor Inspector T. Go, Health Physicist M. Jones, Reactor Engineer R. Langstaff, Senior Reactor Inspector E. Sanchez Santiago, Reactor Inspector N. Valos, Senior Reactor Analyst Approved by: J. Cameron, Chief Branch 6 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report 05000237/2012-002, 05000249/2012-002; 01/01/2012 - 03/31/2012;

Dresden Nuclear Power Station, Units 2 & 3, Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Program; Follow up of Events, and Notices of Enforcement Discretion.

This report covers a 3-month period of inspection by resident inspectors and region based inspectors. Two (2) Green findings were identified by the inspectors and three (3) Green findings were self-revealing. All of the findings were considered non-cited violations (NCVs) of NRC regulations. The significance of most findings is indicated by their color (Green, White,

Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649,

Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Initiating Events

Green.

A finding of very low safety significance was self-revealed for the failure to have adequate maintenance instructions to install the Unit 2 Control Rod Drive (CRD) Flow Control Valve A/B Selector Valve (2-302-6B) which resulted in the separation of the plastic instrument air tubing and the Unit 2 CRD flow control valves failing closed. The licensee made temporary repairs to 2-302-6B and wrote a work request to make final repairs. The licensee also wrote work requests to inspect the Unit 3 selector switch.

The licensee also wrote a procedure change request to review DOA 0300-01, Control Rod Drive System Failure, to clarify the decision to scram upon flow control valve failure. The licensee generated a corrective action to tie procurement engineering (PE)document 56060 to the new 2-302-6B model number. The licensee planned to prepare an equipment apparent cause evaluation (EACE). Additional corrective actions should result from the EACE.

The finding was determined to be more than minor because the finding was associated with the Initiating Events Cornerstone attribute of equipment performance of the Cornerstone Objectives and Attributes Tables of Manual Chapter 0612, Appendix B, dated January 1, 2010, and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a, for the Initiating Events Cornerstone. The inspectors determined that the finding did not result in both the likelihood of reactor trip and the likelihood that mitigation equipment or functions would not have been available. Therefore, the finding screened as having very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Resources, because the licensee did not have complete, accurate, and up-to-date design documentation. Specifically, the failure to attach PE 56060 to the most current part number necessary to replace 2-302-6B resulted in the failure to include instructions to install plastic piping connectors in the work order that was used to replace 2-302-6B. (H.2(c)) (Section 4OA3.3)

Cornerstone: Barrier Integrity

Severity Level IV. The inspectors identified a Severity Level IV NCV of 10 CFR 50.59,

Changes, Tests, and Experiments, having very low safety significance (Green) for the licensees failure to perform an adequate safety evaluation review for changes made to the facility involving the placement of chemical storage tanks. As part of its corrective action, the licensee entered the issue into its corrective action program as IR 1302573 and performed Engineering Change Evaluations (EC) 38018 and EC 387073 which determined that the control room envelope had been historically operable. The licensee planned to install a completely different design of the chemical addition system that would separate the sodium hypochlorite storage from the hydroxyethylidenediphosphonic acid (HEDP, a strong acid) storage. Completion of the modification is planned for August 2012.

The underlying technical finding was evaluated under the SDP using NRCs IMC 0609,

Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and the inspectors answered Yes to the question in Table 4a; Does the finding represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere? The SDP required a Phase 3 analysis to resolve this type of finding.

However, after consultation with a Region 3 Senior Reactor Analyst it was determined that no SDP methods or tools exist to determine the significance of the finding.

Therefore, the finding was not suitable for evaluation using the SDP, so the risk significance was established in accordance with the qualitative criteria of Appendix M (dated December 22, 2006) of IMC 0609. Specifically, the qualitative decision-making attribute from Table 4.1 of Appendix M, Finding can be bounded using qualitative and/or quantitative information was applicable to this finding. The licensee performed two quantitative engineering evaluations regarding this finding. The first (EC 387018)determined the minimum level of sodium hypochlorite stored in the tanks necessary that if it were to completely interact with the HEPD and completely release all of the contained chlorine would render the control room envelope inoperable. The second (EC 387073) determined that the tanks would not have been affected by wind, seismic, or missile impacts with a level of sodium hypochlorite equal to or greater than the level necessary to make the control room envelope inoperable identified in EC 387018.

Therefore, based upon a qualitative measure of risk determined in accordance with Appendix M, NRC Management concluded that the issue was of very low safety significance (Green). This finding has no cross-cutting aspect because it does not represent current licensee performance. (Section 4OA3.2)

Green.

A finding of very low safety significance and associated non-cited violation of Technical Specification (TS) Section 5.4.1 was self-revealed because the work instructions associated with WO 1450006-01, D2 SA PM 517 RB/TB INTLK DOOR (2-5850-52) ELECTRICAL CHECKS, were inadequate. The use of inadequate work instructions resulted in the temporary failure of the secondary containment boundary between the Unit 2 Reactor Building and the Unit 2 Turbine Building. The licensees corrective actions included disciplining the maintenance planner and having each of the maintenance department heads prepare human performance improvement plans.

The finding was determined to be more than minor because the finding was associated with the Barrier Integrity Cornerstone attribute of configuration control and affected the cornerstone objective of maintaining the functionality of containment. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609,

Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a for the Barrier Cornerstone because the finding affected the secondary containment. The inspectors answered all four questions No which resulted in the finding screening as having very low safety significance (Green). This finding had a cross-cutting aspect in the area of Human Performance,

Work Practices, because the licensee did not ensure that human error techniques such as self and peer checking was used during the creation of the work package. Licensee and management personnel stated that the work planner failed to adequately self-check and get a peer check on the completion of the preparation of the work package. (H.4(c))

(Section 4OA3.4)

Cornerstone: Public Radiation Safety

Green.

A finding of very low safety significance was self-revealed following the licensees failure to appropriately package and transport radioactive material.

This finding also resulted in two associated NCVs of 10 CFR 61.56(a)(3)and 10 CFR 71.5(a). The licensees corrective actions included revising procedures and completing a detailed review through an apparent cause evaluation of the event.

Additionally, the licensee suspended all radioactive material shipments using similar general packagings as a part of their corrective actions.

This finding was assessed using IMC 0609, Attachment D, Public Radiation Safety Significance Determination Process, and determined to be of very low safety significance (Green). The inspectors determined that the finding did not involve the radioactive effluent release program or the radiological environmental monitoring program. The finding did involve the transportation of radioactive material. However, no external radiation levels or surface contamination levels were exceeded, the finding did not involve the certificate of compliance, and there was no failure to make notifications or provide emergency information. The finding did involve a breach of the package during transit and low-level burial ground non-conformance. However, the finding did not involve the loss of package contents or waste classification issues. The inspectors determined that the primary cause of this finding was related to a cross-cutting aspect in the area of Problem Identification and Resolution. (P.2(b)) (Section 2RS8)

Other Findings

Severity Level IV. The inspectors identified a Severity Level IV NCV and associated finding of very low safety significance of 10 CFR 50.72(b)(3)(v)(D), Immediate Notification Requirements for Operating Nuclear Power Reactors, for the failure to report an event to the NRC within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , where an event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident. The licensee had not prepared any corrective actions by the end of the inspection period.

The inspectors determined that a failure to report was an example of a violation that could impact the regulatory process and was subject to Traditional Enforcement. The inspectors determined that the underlying technical issue involved the inability to scram

Unit 3 on flow biased neutron flux-high or fixed neutron flux-high functions within the TS limits prescribed in TS 3.3.1.1, Table 3.3.3.3-1, 2.b and c. The inspectors determined that the issue was more than minor, because if left uncorrected it would have had the potential to lead to a more significant safety concern. Using IMC 0609, Table 4a,

Characterization Worksheet for IE, MS, and BI Cornerstones, the inspectors determined that the finding had very low safety significance because they answered No to all five questions contained in Column 2 of the Table 4a worksheet. The inspectors also determined that the contributing cause that provided the most insight into the performance deficiency affected the cross-cutting area of Problem Identification and Resolution, including properly classifying, prioritizing, and evaluating for operability and reportability conditions adverse to quality. (P.1(c)) (Section 4OA3.5)

Licensee-Identified Violations

No violations were identified.

REPORT DETAILS

Summary of Plant Status

Unit 2 On February 18, 2012 operators reduced power to approximately 57 percent electrical for planned turbine valve testing, 10 percent scram time testing, and sequence exchange.

Operators restored power to 100 percent on February 19, 2012.

The unit operated at or near 100 percent power during the balance of the inspection period, with the exception of operators reducing power routinely for planned control rod pattern adjustments and testing activities.

Unit 3 On March 3, 2012 operators reduced power to approximately 62 percent electrical for a planned sequence exchange, 10 percent scram time testing, and turbine valve testing. Operators returned the unit to full power operation on March 4, 2012.

The unit operated at or near 100 percent power during the balance of the inspection period, with the exception of operators reducing power routinely for planned control rod pattern adjustments and testing activities.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Readiness for Impending Adverse Weather Condition - High Wind Conditions

a. Inspection Scope

Since high winds were identified in the vicinity of the facility for March 6, 2012, the inspectors reviewed the licensees overall preparations/protection for the expected weather conditions. On March 6, 2012, the inspectors walked down the Unit 2 and Unit 3 main and offsite power transformer areas, in addition to the licensees emergency alternating current (AC) power systems, because their safety related functions could be affected or required as a result of high winds or tornado generated missiles or the loss of offsite power. The inspectors evaluated the licensee staffs preparations against the sites procedures and determined that the staffs actions were adequate. During the inspection, the inspectors focused on plant-specific design features and the licensees procedures used to respond to specified adverse weather conditions. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures.

This inspection constituted one readiness for impending adverse weather condition sample as defined in Inspection Procedure (IP) 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment (71111.04Q & S)

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

Unit 2 Division II low pressure coolant injection (LPCI) with Division I LPCI minimum flow valve out-of-service (OOS);

3B core spray (CS) during 3A CS OOS; and

2/3 emergency diesel generator (EDG) during Unit 3 EDG OOS.

The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program (CAP) with the appropriate significance characterization.

Documents reviewed are listed in the Attachment to this report.

These activities constituted three partial system walkdown samples as defined in IP 71111.04-05.

b. Findings

No findings were identified.

.2 Semi Annual Complete System Walkdown

Main article: IP 71111.04S

a. Inspection Scope

On January 10, 2012, the inspectors performed a complete system alignment inspection of the Unit 2 core spray system to verify the functional capability of the system. This system was selected because it was considered both safety significant and risk significant in the licensees probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment line ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding WOs was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the CAP database to ensure that system equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the Attachment to this report.

These activities constituted one complete system walkdown sample as defined in IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

Main article: IP 71111.05

.1 Routine Resident Inspector Tours

Main article: IP 71111.05Q

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

Fire Zone 8.2.1A, Unit 2 condensate pumps, elevation 469;

Fire Zone 11.1.3, Unit 3 high pressure coolant injection (HPCI)pump room, elevation 476;

Fire Zone 9.0A, Unit 2 diesel generator, elevation 517; and

Fire Zone 6.1, Unit 3 battery charger room, elevation 538.

The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the Attachment to this report, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP. Documents reviewed are listed in the Attachment to this report.

These activities constituted four quarterly fire protection inspection samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R06 Flooding

Main article: IP 71111.06

.1 Internal Flooding

a. Inspection Scope

The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the UFSAR, engineering calculations, and abnormal operating procedures to identify licensee commitments. The specific documents reviewed are listed in the to this report. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the licensees corrective action documents with respect to past flood related items identified in the CAP to verify the adequacy of the corrective actions. The inspectors verified that the licensee complied with its commitments. The inspectors observed the following activity:

Unit 2 condenser hotwell watertight door surveillance and maintenance.

Specific documents reviewed during this inspection are listed in the Attachment to this report. This inspection constituted one internal flooding sample as defined in IP 71111.06-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

Main article: IP 71111.11Q

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

Main article: IP 71111.11Q

a. Inspection Scope

On March 5, 2012, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification examinations to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

licensed operator performance;

crews clarity and formality of communications;

ability to take timely actions in the conservative direction;

prioritization, interpretation, and verification of annunciator alarms;

correct use and implementation of abnormal and emergency procedures;

control board manipulations;

oversight and direction from supervisors; and

ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.

The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator requalification program sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk

Main article: IP 71111.11Q

a. Inspection Scope

On January 6, 2012, the inspectors observed activities in the control room during the return to service and testing of the Unit 2 emergency diesel generator. This was an activity that required heightened awareness or was related to increased risk. The inspectors evaluated the following areas:

licensed operator performance;

crews clarity and formality of communications;

ability to take timely actions in the conservative direction;

prioritization, interpretation, and verification of annunciator alarms (if applicable);

correct use and implementation of procedures;

control board (or equipment) manipulations;

oversight and direction from supervisors; and

ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications (if applicable).

The performance in these areas was compared to pre established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk-significant systems:

Unit 3 containment cooling service water; and

Unit 3 reactor building closed cooling water.

The inspectors reviewed events such as where ineffective equipment maintenance could result in valid or invalid automatic actuations or transients of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

implementing appropriate work practices;

identifying and addressing common cause failures;

scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

characterizing system reliability issues for performance;

charging unavailability for performance;

trending key parameters for condition monitoring;

ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.

This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

Unit 3 EDG and Unit 2 B core spray OOS;

Operational Risk Activity - construction of scaffold in main control room panels in support of the adjustable speed drive modification;

Unit 2 isolation condenser OOS;

Unit 3 standby liquid control OOS for squib valve replacement; and

Unit 2 HPCI OOS.

These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

These maintenance risk assessments and emergent work control activities constituted five samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Evaluations and Functional Assessments

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed the following issues:

Issue Report (IR) 1287702, Supplemental Information and Issues Relating to IR 1281716;

IR 1309030, NRC Concern for HPCI Venting Time;

IR 1298456, MCC 38-7, Transfer Relay 3-7838-7CR3871 Needs Replacing;

Operability Evaluation (OE)12-002, Dresser Part 21 report for nitrogen relief valve 2(3)-8526 will not pass full rate flow; and

OE 11-006, Rev.000, 4160 V Switchgear MOC Assembly at Buses 23, 23-1, 24, 24-1, 33, 33-1, 34, 34-1.

The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that 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 TS and UFSAR to the licensees 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. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report.

This operability inspection constituted five samples as defined in IP 71111.15-05.

b. Findings

Failure to Report an Unanalyzed Condition that Could Significantly Degrade Plant Safety

Introduction:

The inspectors identified an unresolved item regarding the failure to submit a 10 CFR 50.73(a)(2)(ii)(B) licensee event report (LER) within 60 days following discovery of an unanalyzed condition that could significantly degrade plant safety.

Description:

On January 11, 2012, it was postulated in IR 1312222 that while on shutdown cooling (SDC) in Mode 3 and a loss of coolant accident (LOCA) were to occur, the SDC and LPCI common discharge piping would void resulting in flashing and pipe damage during the 40 seconds it takes for the SDC isolation valves to close on a Group 3 isolation signal. This challenges the ability of both subsystems of LCPI to inject in such a scenario. Both sub-systems of LPCI are required to be operable by technical specifications while in Mode 3. The licensees immediate operability determination was that LPCI remained operable; however, additional analysis was required to determine if the event was plausible and if the plant was bounded by previous analysis. Corrective action assignments were generated to evaluate the condition with Exelon corporate due by January 25, 2013 (over 1 year later). Two other corrective action assignments were written to evaluate the final resolution of a similar scenario at Quad Cities Nuclear Power Station and to evaluate current operations procedures to determine if additional guidance is necessary in this postulated scenario at Dresden. All three corrective actions remained open at the end of the assessment period.

The inspectors questioned the timeliness of licensee corrective actions, in particular with respect to prompt operability and reportability of the potential unanalyzed condition, which was documented in IR 1341563. The licensee justified prompt operability after 60 days based on 1) a GE BWR Owners Group Technical Report Effects of Voiding in emergency core cooling system (ECCS) Drywell Injection Piping, 2) the probability of occurrence of the aforementioned scenario being on the order of 1E-08 and was therefore not a credible event and did not require further analysis, and 3) the fact that preliminary results done at Quad Cities and Duane Arnold Energy Center for similar issues indicated that all operability requirements for piping were met. The licensee justified reportability as no loss of safety function occurred and therefore this issue was not reportable.

The inspectors reviewed the GE technical report and determined that the report does not apply to this scenario as the scope of review was limited to small voids existing prior to an accident or transient - not voids developed as a result of an accident or transient.

Additionally, the GE technical report indicated that flashing as a result of LPCI injection would occur in both the vessel and recirculation lines. In the postulated scenario, LPCI and SDC flashing would occur upstream of the recirculation lines in the LPCI piping that is significantly smaller in diameter than the recirculation piping, 16 inches as opposed to 28 inches, respectively. The licensee indicated that they had an ongoing technical evaluation underway that would show the potential unanalyzed condition would not challenge the ability of LPCI to inject. This analysis was not completed during the 60 day LER reportability timeframe, and at the end of the inspection period the technical evaluation was still in progress. The inspectors considered this issue an unresolved item (URI) pending completion and review of the licensees technical evaluation. (URI 05000237/2012002-01; 05000249/2012002-01, Failure to Report an Unanalyzed Condition that Could Significantly Degrade Plant Safety)

1R18 Plant Modifications

Main article: IP 71111.18

a. Inspection Scope

The inspectors reviewed the following modification(s):

Engineering Change 372521, Unit 2/3 Control Room heating, ventilation, and air conditioning (HVAC) System Train B CREVS RCU [control room emergency ventilation system refrigeration control unit]

The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening against the design basis, the UFSAR, and the TS, as applicable, to verify that the modification did not affect the operability or availability of the affected system. The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modifications were installed as directed and consistent with the design control documents; the modifications operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. Lastly, the inspectors discussed the plant modification with operations, engineering, and training personnel to ensure that the individuals were aware of how the operation with the plant modification in place could impact overall plant performance. Documents reviewed in the course of this inspection are listed in the Attachment to this report.

This inspection constituted one plant modification sample as defined in IP 71111.18-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed the following post-maintenance (PMT) activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

WO 1502188, Unexpected Half Scram on Unit 2 - Will Not Reset;

WO 1307761-09, OP PMT Standby Diesel Generator Inspection;

WO 01412443-02, OP PMT Air Start Regulator on D2 EDG DOS 6600-01;

WO 1107539-01, D2 NDD PM Overhaul CRD B Pump;

WO 748391, D2 8Y PM Disassemble and Inspect Chk Vlv 2-1301-26;

WO 1514515, Re-Wire Bus (23-1/24-1) Loss of Offsite Power Alarm in MCR; and

WO 1188416-09, Ops Perform SBLC Continuity Check 3B Squib Valve.

These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):

the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.

This inspection constituted seven post-maintenance testing samples as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

WO 1489925-01, D2/3 QTR TS D/G CLG WTR PMP Test For IST Program Surveillance (IST);

DOP 2000-180, Drywell Sump Operation with Unit On-Line, Revision 00 (RCS);

WO 1501336-01, D3 45D TS 3C CCSW Alert Range Testing (routine);

WO1475091-01, D3 QTR TS ADS Permissive LPCI and CS PMP Disch Press SW CAL (routine);

WO 1399870-01, EM Annual B5B Portable Generator/Charger Load Test.

(routine); and

WO 1502724-01, D3 QTR HPCI pump OPER Test and IST Surv (routine).

The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

did preconditioning occur;

were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;

were acceptance criteria clearly stated, demonstrated operational readiness, and consistent with the system design basis;

plant equipment calibration was correct, accurate, and properly documented;

as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the UFSAR, procedures, and applicable commitments;

measuring and test equipment calibration was current;

test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;

test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;

test data and results were accurate, complete, within limits, and valid;

test equipment was removed after testing;

where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers (ASMEs) Code, and reference values were consistent with the system design basis;

where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;

where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;

prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

equipment was returned to a position or status required to support the performance of its safety functions; and

all problems identified during the testing were appropriately documented and dispositioned in the CAP.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted four routine surveillance testing samples, one reactor coolant system leak detection inspection sample, and one inservice testing sample, as defined in IP 71111.22, Sections -02 and -05.

b. Findings

One finding and associated non-cited violation was identified which is discussed in Inspection Report (IR) 05000237/2012010; 05000249/2012010.

1EP2 Alert and Notification System Evaluation

Main article: IP 71114.02

a. Inspection Scope

The inspectors held discussions with Emergency Preparedness (EP) staff regarding the operation, maintenance, and periodic testing of the Alert and Notification System (ANS)in the plume pathway Emergency Planning Zone. The inspectors reviewed monthly trend reports and siren test failure records from January 2010 through January 2012.

Main article: IP 71114.06

.1 Training Observation

a. Inspection Scope

The inspector observed a simulator training evolution for licensed operators on March 5, 2012, which required emergency plan implementation by a licensee operations crew. This evolution was planned 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 crew. 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 the licensee evaluators noted the same issues and entered them into the CAP. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the Attachment to this report.

This inspection of the licensees training evolution with EP drill aspects constituted one sample as defined in IP 71114.06-05.

b. Findings

No findings were identified.

RADIATION SAFETY

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

Main article: IP 71124.03

This inspection constituted one complete sample as defined in IP 71124.03-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the plant UFSAR to identify areas of the plant designed as potential airborne radiation areas and any associated ventilation systems or airborne monitoring instrumentation. Instrumentation review included continuous air monitors (continuous air monitors and particulate-iodine-noble-gas-type instruments) used to identify changing airborne radiological conditions such that actions to prevent an overexposure may be taken. The review included an overview of the Respiratory Protection Program and a description of the types of devices used. The inspectors reviewed the UFSAR, TSs, and EP documents to identify location and quantity of respiratory protection devices stored for emergency use.

Inspectors reviewed the licensees procedures for maintenance, inspection, and use of respiratory protection equipment including self-contained breathing apparatus, as well as procedures for air quality maintenance.

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

b. Findings

No findings were identified.

.2 Engineering Controls (02.02)

a. Inspection Scope

The inspectors reviewed the licensees use of permanent and temporary ventilation to determine whether the licensee uses ventilation systems as part of its engineering controls (in lieu of respiratory protection devices) to control airborne radioactivity. The inspectors reviewed procedural guidance for use of installed plant systems, such as containment purge, spent fuel pool ventilation, and auxiliary building ventilation, and assessed whether the systems are used, to the extent practicable, during high-risk activities (e.g., using containment purge during cavity flood-up).

The inspectors selected installed ventilation systems used to mitigate the potential for airborne radioactivity, and evaluated whether the ventilation airflow capacity, flow path (including the alignment of the suction and discharges), and filter/charcoal unit efficiencies, as appropriate, were consistent with maintaining concentrations of airborne radioactivity in work areas below the concentrations of an airborne area to the extent practicable.

The inspectors selected temporary ventilation system setups (high-efficiency particulate air/charcoal negative pressure units, down draft tables, tents, metal Kelly buildings, and other enclosures) used to support work in contaminated areas. The inspectors assessed whether the use of these systems is consistent with licensee procedural guidance and as-low-as-is-reasonably-achievable concept.

The inspectors reviewed airborne monitoring protocols by selecting installed systems used to monitor and warn of changing airborne concentrations in the plant and evaluating whether the alarms and setpoints are sufficient to prompt licensee/worker action to ensure that doses are maintained within the limits of 10 CFR Part 20 and the as-low-as-is-reasonably-achievable concept.

The inspectors assessed whether the licensee had established trigger points (e.g., the Electric Power Research Institutes Alpha Monitoring Guidelines for Operating Nuclear Power Stations) for evaluating levels of airborne beta-emitting (e.g., plutonium-241) and alpha-emitting radionuclides.

b. Findings

No findings were identified.

.3 Use of Respiratory Protection Devices (02.03)

a. Inspection Scope

For those situations where it is impractical to employ engineering controls to minimize airborne radioactivity, the inspectors assessed whether the licensee provided respiratory protective devices such that occupational doses are as-low-as-is-reasonably-achievable.

The inspectors selected work activities where respiratory protection devices were used to limit the intake of radioactive materials, and assessed whether the licensee performed an evaluation concluding that further engineering controls were not practical and that the use of respirators is as-low-as-is-reasonably-achievable. The inspectors also evaluated whether the licensee had established means (such as routine bioassay) to determine if the level of protection (protection factor) provided by the respiratory protection devices during use was at least as good as that assumed in the licensees work controls and dose assessment.

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 per 10 CFR 20.1703(b). The inspectors selected work activities where respiratory protection devices were used. The inspectors evaluated whether the devices were used consistent with their National Institute for Occupational Safety and Health/Mine Safety and Health Administration certification or any conditions of their NRC approval.

The inspectors reviewed records of air testing for supplied-air devices and self-contained breathing apparatus bottles to assess whether the air used in these devices meets or exceeds Grade D quality. The inspectors 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 several individuals qualified to use respiratory protection devices, and assessed whether they have been deemed fit to use the devices by a physician.

The inspectors selected several individuals assigned to wear a respiratory protection device and observed them donning, doffing, and functionally checking the device as appropriate. Through interviews with these individuals, the inspectors evaluated whether they knew how to safely use the device and how to properly respond to any device malfunction or unusual occurrence (loss of power, loss of air, etc.).

The inspectors chose multiple respiratory protection devices staged and ready for use in the plant or stocked for issuance for use. The inspectors assessed the physical condition of the device components (mask or hood, harnesses, air lines, regulators, air bottles, etc.) and reviewed records of routine inspection for each. The inspectors selected several of the devices and reviewed records of maintenance on the vital components (e.g., pressure regulators, inhalation/exhalation valves, hose couplings).

b. Findings

No findings were identified.

.4 Self-Contained Breathing Apparatus for Emergency Use (02.04)

a. Inspection Scope

Based on the UFSAR, TSs, and emergency operating procedure requirements, the inspectors reviewed the status and surveillance records of self-contained breathing apparatuses staged in-plant for use during emergencies. The inspectors reviewed the licensees capability for refilling and transporting self-contained breathing apparatus air bottles to and from the control room and operations support center during emergency conditions.

The inspectors selected several individuals on control room shift crews and from designated departments currently assigned emergency duties (e.g., onsite search and rescue duties) to assess whether control room operators and other emergency response and radiation protection personnel (assigned in-plant search and rescue duties or as required by emergency operating procedures or the emergency plan) were trained and qualified in the use of self-contained breathing apparatuses (including personal bottle changeout). The inspectors evaluated whether personnel assigned to refill bottles were trained and qualified for that task.

The inspectors determined whether appropriate mask sizes and types are available for use (i.e., in-field mask size and type match what was used in fit-testing). The inspectors determined whether on-shift operators had no facial hair that would interfere with the sealing of the mask to the face and whether vision correction (e.g., glasses inserts or corrected lenses) was available as appropriate.

The inspectors reviewed the past 2 years of maintenance records for select self contained breathing apparatus units used to support operator activities during accident conditions and designated as ready for service to assess whether any maintenance or repairs on any self-contained breathing apparatus units vital components were performed by an individual, or individuals, certified by the manufacturer of the device to perform the work. The vital components typically are the pressure-demand air regulator and the low-pressure alarm. The inspectors reviewed the onsite maintenance procedures governing vital component work to determine any inconsistencies with the self-contained breathing apparatus manufacturers recommended practices. For those self-contained breathing apparatuses designated as ready for service, the inspectors determined whether the required, periodic air cylinder hydrostatic testing was documented and up to date, and the retest air cylinder markings required by the U.S. Department of Transportation (DOT) were in place.

b. Findings

No findings were identified.

.5 Problem Identification and Resolution (02.05)

a. Inspection Scope

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

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

Main article: IP 71124.04

This inspection constituted one complete sample as defined in IP 71124.04-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the results of radiation protection program audits related to internal and external dosimetry (e.g., licensees quality assurance audits, self-assessments, or other independent audits) to gain insights into overall licensee performance in the area of dose assessment and focus the inspection activities consistent with the principle of smart sampling.

The inspectors reviewed the most recent National Voluntary Laboratory Accreditation Program accreditation report on the vendors most recent results to determine the status of the contractors accreditation.

A review was conducted of the licensee procedures associated with dosimetry operations, including issuance/use of external dosimetry (routine, multibadging, extremity, neutron, etc.), assessment of internal dose (operation of whole body counter, assignment of dose based on derived air concentration-hours, urinalysis, etc.), and evaluation of and dose assessment for radiological incidents (distributed contamination, hot particles, loss of dosimetry, etc.).

The inspectors evaluated whether the licensee had established procedural requirements for determining when external and internal dosimetry is required.

b. Findings

No findings were identified.

.2 External Dosimetry (02.02)

a. Inspection Scope

The inspectors evaluated whether the licensees dosimetry vendor is National Voluntary Laboratory Accreditation Program accredited and if the approved irradiation test categories for each type of personnel dosimeter used are consistent with the types and energies of the radiation present and the way the dosimeter is being used (e.g., to measure deep dose equivalent, shallow dose equivalent, or lens dose equivalent).

The inspectors evaluated the onsite storage of dosimeters before their issuance, during use, and before processing/reading. The inspectors also reviewed the guidance provided to rad-workers with respect to care and storage of dosimeters.

The licensee does not use non-National Voluntary Laboratory Accreditation Program accredited passive dosimeters.

The inspectors assessed the use of active dosimeters (electronic personal dosimeters)to determine if the licensee uses a correction factor to address the response of the electronic personal dosimeter as compared to the passive dosimeter for situations when the electronic personal dosimeter must be used to assign dose and whether the correction factor is based on sound technical principles.

The inspectors reviewed dosimetry occurrence reports or CAP documents for adverse trends related to electronic personal dosimeters, such as interference from electromagnetic frequency, dropping or bumping, failure to hear alarms, etc. The inspectors assessed whether the licensee had identified any trends and implemented appropriate corrective actions.

b. Findings

No findings were identified.

.3 Internal Dosimetry (02.03)

Routine Bioassay (In Vivo)

a. Inspection Scope

The inspectors reviewed procedures used to assess the dose from internally deposited nuclides using whole body counting equipment. The inspectors evaluated whether the procedures addressed methods for differentiating between internal and external contamination, the release of contaminated individuals, the route of intake and the assignment of dose.

The inspectors reviewed the whole body count process to determine if the frequency of measurements was consistent with the biological half-life of the nuclides available for intake.

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

The inspectors selected several whole body counts and evaluated whether the counting system used had sufficient counting time/low background to ensure appropriate sensitivity for the potential radionuclides of interest. The inspectors reviewed the radionuclide library used for the count system to determine its appropriateness. The inspectors evaluated whether any anomalous count peaks/nuclides indicated in each output spectra received appropriate disposition. The inspector's reviewed the licensee's 10 CFR Part 61 data analyses to determine whether the nuclide libraries included appropriate gamma-emitting nuclides. The inspectors evaluated how the licensee accounts for hard-to-detect nuclides in the dose assessment.

b. Findings

No findings were identified.

Special Bioassay (In Vitro)

a. Inspection Scope

There were no internal dose assessments obtained using in vitro monitoring for the inspectors to review. The inspectors reviewed procedures and assessed the adequacy of the licensees program for in vitro monitoring (i.e., urinalysis and fecal analysis) of radionuclides (tritium, fission products, and activation products), including collection and storage of samples.

The inspectors performed a limited review on the vendor laboratory program and assessed whether the laboratory participated in an industry recognized cross-check program including whether out-of-tolerance results were resolved appropriately.

b. Findings

No findings were identified.

Internal Dose Assessment - Airborne Monitoring

a. Inspection Scope

The inspectors reviewed the licensee's program for airborne radioactivity assessment and dose assessment, as applicable, based on airborne monitoring and calculations of derived air concentration. The licensee had not performed dose assessments using airborne/derived air concentration monitoring since the last inspection.

b. Findings

No findings were identified.

Internal Dose Assessment - Whole Body Count Analyses

a. Inspection Scope

The inspectors reviewed several dose assessments performed by the licensee using the results of whole body count analyses. The inspectors determined whether affected personnel were properly monitored with calibrated equipment and that internal exposures were assessed consistent with the licensee's procedures.

b. Findings

No findings were identified.

.4 Special Dosimetric Situations (02.04)

Declared Pregnant Workers

b. Findings

No findings were identified.

.5 Problem Identification and Resolution (02.05)

a. Inspection Scope

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

b. Findings

No findings were identified.

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

Transportation Program (71124.08) These inspection activities constitute a partial sample as defined in IP 71124.08-05.

.1 Waste Characterization and Classification (02.04)

a. Inspection Scope

The inspectors reviewed shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness. The inspectors assessed whether the requirements of applicable package compliance had been met. The inspectors evaluated whether the receiving licensee was authorized to receive the shipment packages. The inspectors evaluated whether the licensees procedures for soft-sided engineered packages were consistent with the vendors current approved procedures.

b. Findings

Introduction:

A finding of very low safety significance was self-revealed following the licensees failure to appropriately package and transport radioactive material. This finding also resulted in two associated Non-Citied Violations (NCVs) of 10 CFR 61.56(a)(3) and 10 CFR 71.5(a).

Description:

On November 10, 2011, three exclusive use shipments were shipped from the licensees facility to a disposal facility at Clive, Utah. Each shipment contained approximately 140,000 lbs of low pressure turbine casings and was shipped in soft-sided packages. The soft-sided shipping packages were then covered with tarps and secured to the truck bed with straps and tie-downs (chains).

Upon arrival at the burial site, burial facility personnel identified tears on two of three of the soft-sided shipping packages (DW-11-053 and DW-11-055). Disposal facility personnel did not identify any degradation on the third shipping package (DW-11-054).

These package degradations created the potential for loss of radioactive contamination control during the shipments. However, no radioactive contamination was identified outside of the shipping package as a result of this event.

The burial site personnel also identified free-standing liquid of greater than three percent in two of the three shipping packages (DW-11-053 and DW-11-054). One of these soft-sided packages was compromised during transport and exposed to adverse weather conditions at the licensees site prior to transport. Consequently, the water intrusion into the package could have occurred either at the licensees facility or during transport. The other shipping package was not compromised during transit, so most likely, the water intrusion to this package occurred at the licensees facility when it was exposed to adverse environmental conditions. Burial sites require licensees to ensure that Class-A radioactive waste arrive ready for disposal with less than one percent liquid by volume.

A licensee apparent cause evaluation determined that the licensee failed to prepare and store the radioactive shipment appropriately for transport. The evaluation also determined that the turbine casings were partially prepared and packaged for transport inside the licensees facility. Then while awaiting shipment, the partially prepared packages were stored outside at the licensees facility without proper protection from the environment and were subjected to rainfall. This left the soft-sided shipping packages susceptible to water intrusion while in interim storage. In addition, the licensee noted pooling of water on top of the shipping packages. The soft-sided shipping packages were covered with tarps just prior to shipment. However, the licensee did not verify the packages and contents as being compliant with federal transportation requirements after outside storage and prior to shipment.

The use of the soft-sided package was not appropriate for transporting the package contents in that the soft-sided package was water resistant and not water tight. The package as designed allowed an access point for water to enter the package through the seams which were vulnerable to in-leakage. Secondly, the soft sided package was made of a ply of woven cloth material coated in polyethylene and felt like material that could be degraded under excessive stress and strain during conditions other than normal transportation.

During transportation of the exclusive use shipment, the drivers added tie-downs and made adjustments to the original straps. The effectiveness of the packages was substantially reduced by the addition and adjustments of straps and tie-downs. These adjustments effectively modified the shipping package design characteristics. Making field adjustments to the straps and tie-downs could facilitate or induce tears to the tarps and/or the soft-sided packaging. The drivers carrying these shipments were trained in accordance with 49 CFR on the basic knowledge of controlling shipments in transit.

However, the licensee failed to specifically instruct the drivers on the need to maintain the structural integrity of the soft-sided packages.

The investigation also pointed out after passing the inclement weather, during a stop, the drivers identified tears on the outer tarps and reported these conditions to the licensee.

The damage to the tarps was deemed insignificant by the licensee and the drivers were approved to proceed to the disposal facility. The licensee failed to question the full extent of the damage in order to assess the impact of degradation to the soft-sided shipping packages and package contents underneath the tarps. Thus, the degradation in shipping package integrity left the package susceptible to the loss of radioactive contamination control and to water intrusion into the packages.

As a part of their corrective action program, the licensee completed a detailed review of all radioactive material shipments and performed immediate/ interim corrective actions that included:

(1) fleet review of the event and fleet applicability;

(2) suspending the use of soft sided engineered shipping packages within the fleet;

(3) initiated and performed an apparent cause evaluation of the event;

(4) intercepted and inspected Dresdens turbine rotor elements on rail cars that were being shipped to Clive; and

(5) all large bulk item shipments to be peer checked prior to shipment.

Analysis:

The failure to appropriately package and transport radioactive material was a performance deficiency as defined in IMC 0612 Appendix B, Issue Screening. The inspectors reviewed the guidance in IMC 0612, Appendix E, Examples of Minor Issues, but did not identify any examples similar to the performance deficiency. However, the inspectors determined that the finding was more than minor because it affected the Public Radiation Safety Cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain.

Specifically, the loss of soft-side package integrity and the introduction of free-standing liquid inside the packaging(s) could lead to unnecessary radioactive contamination in the public domain and adversely impact the handling of the packages at the disposal site.

This failure was within the licensees ability to foresee and correct, and should have been prevented; specifically, a similar event of minor safety significance occurred on a shipment to Clive Burial Site in 2011 from a sister plant (Quad Cities IR No. 01228709).

The finding was not subject to traditional enforcement since the incident did not have a significant safety consequence, did not impact the NRCs ability to perform its regulatory function, and was not willful.

This finding was assessed using IMC 0609, Attachment D for the Public Radiation Safety Significance Determination Process (SDP) and determined to be of very low-safety significance (Green). The inspectors determined that the finding did not involve the radioactive effluent release program or the radiological environmental monitoring program. The finding did involve the transportation of radioactive material.

However, no external radiation levels or surface contamination levels were exceeded, the finding did not involve the certificate of compliance, and there was no failure to make notifications or provide emergency information. The finding did involve a breach of the package during transit. However, there was no loss of package contents. Specifically, disposal facility personnel performed radiological surveys and determined that there was no spread of radiological contamination as a result of compromised transport packages during the transit to the burial site. The finding did involve a low-level burial ground non-conformance. However, there was no issue with waste classification.

The inspector reviewed IMC 0612, Appendix F, example of cross-cutting aspects, and determined that this finding had a cross-cutting aspect in the area of Problem Identification and Resolution (P.2(b)). The licensee did not effectively implement industry operating experience to ensure the effective use of soft-sided packaging(s).

Enforcement.

Two violations of regulatory requirements were associated with this event.

Specifically, 10 CFR 71.5(a) states, in part, each licensee who transports licensed material outside the site of usage, as specified in the NRC license, or where transport is on public highways, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the DOT regulations in 49 CFR Parts 107, 171 through 180, and 390 through 397, appropriate to the mode of transport.

Specifically, 49 CFR 173.24(b)(2), states, in part, each package used for the shipment of hazardous materials under this subchapter shall be designed, constructed, maintained, filled, its contents so limited, and closed, so that under conditions normally incident to transportation the effectiveness of the package will not be substantially reduced Contrary to the above, on November 16, 2011, the licensee failed to ensure the effectiveness of the packages as required by DOT regulations 49 CFR Part 173 that resulted in the loss of containment of general design packages. Because this violation was of very low safety significance and it was entered into the licensees corrective action program, this violation is being treated as an NCV, in accordance with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000237/2012002-02; 05000249/2012002-02; Failure to Ensure the Effectiveness of Packages as required by DOT Regulations)

Title 10 CFR 61.56(a)(3) states, in part, the following requirements are minimum requirements for all classes of waste and are intended to facilitate handling at the disposal site and provide protection of health and safety of personnel at the disposal site; in that solid waste containing liquid shall contain as little free standing and noncorrosive liquid as is reasonably achievable, but in no case shall the liquid exceed 1 percent of the volume.

Contrary to the above, on November 16, 2011, the licensee failed to ensure that packages containing solid waste that were offered for transportation contained as little free standing and noncorrosive liquid as reasonably achievable, but in no case the liquid exceed 1 percent of the volume. Specifically, the packages with the identification numbers DW-11-053 and DW-11-054 were found to have 7.3 cubic feet of unexpected liquid in each package, which was approximately 3.2 percent of the waste volume.

Because this violation was of very low safety significance and it was entered into the licensees corrective action program as IR 1291418, Turbine Retrofit Lower Casing Shipment, this violation is being treated as an NCV, in accordance with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000237/2012002-03; 05000249/2012002-03; Failure to Ensure Packages Containing Solid Waste Contain as Little Free Standing and Noncorrosive Liquid as Reasonably Achievable)

.2 Shipping Records (02.06)

a. Inspection Scope

The inspectors evaluated whether 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 UN number for the following radioactive shipments:

DW-11-053 - Turbine Lower Casing;

DW-11-054 - Turbine Lower Casing; and

DW-11-055 - Turbine Lower Casing.

Additionally, the inspectors assessed whether the shipment placarding was consistent with the information in the shipping documentation.

a. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

4OA1 Performance Indicator Verification

Main article: IP 71151

.1 Unplanned Scrams per 7000 Critical Hours

4OA2 Identification and Resolution of Problems

Main article: IP 71152

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.

Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

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 licensees CAP. This review was accomplished through inspection of the stations daily condition report packages.

These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Selected Issue Follow up Inspection: Control of Scaffolding

a. Inspection Scope

The inspectors reviewed the effectiveness of the licensee scaffolding program. In particular, the inspectors focused on the licensees ability to monitor, track, and evaluate temporary scaffolds installed in the plant. A selection of IRs concerning scaffolds were reviewed to ensure that the full extent of the conditions were identified, appropriate evaluations were performed, and appropriate corrective actions were specified, prioritized, and completed. The inspectors interviewed the scaffolding coordinator, reviewed licensee scaffold procedural requirements, and performed various plant walkdowns. This inspection effort represented one sample. The documents reviewed are listed in the Attachment to this report.

b. Observations The inspectors noted several programmatic weaknesses in the licensees control of temporary scaffolding. In particular, that the licensee and contractors have two separate scaffold tracking databases in which the contractors scaffolds were not readily shared with or reviewed by the licensee; the licensees maintenance scaffold log has no readily apparent notification of temporary scaffolds approaching the 90-day limit without having a 10 CFR 50.59, Changes, Tests, and Experiments, evaluation performed; and no formal scaffold training is provided to the scaffold coordinator. These weaknesses have routinely inhibited the ability of the licensee to track and monitor temporary scaffolds built in the plant. This has led to numerous scaffolds being identified by the licensee as installed over 90 days without a 50.59 evaluation. Upon identification, these scaffolds were quickly removed or had a 50.59 evaluation performed. None of the temporary scaffolds over 90 days old that were reviewed by the inspectors impacted any safety related equipment.

The inspectors identified one scaffold in the licensees database that had been installed on the Unit 3 torus catwalk near Bay 2 in 2010. No required 50.59 evaluation had been performed. Further licensee investigation revealed that the scaffold was actually a work platform that was no longer in the plant. The associated work order task to remove the scaffold was never closed and the actual removal date was unknown. IR 1331002, Scaffold Installed Longer than 90 Days without 50.59, was written to address the issue.

The licensee has taken various corrective actions including, but not limited to, selecting a new scaffold coordinator, performing monthly maintenance scaffold log reviews as opposed to every 90 days, and requesting licensee contractors to readily share their scaffolding database and incorporating that information into the licensees maintenance scaffold log. At the end of the assessment period, these corrective actions have not yet proven fully effective. In particular, the inspectors identified a teletower scaffold in the Unit 2 SBO diesel room that both straddled and was in contact with the Unit 2 SBO diesel generator jacket cooling water pipes. Additionally, no labeling was present on the scaffold. IR 1346496, NRC ID: Teletower in U2 SBO Diesel Room Touching Piping was written to address the issue. The inspectors will continue to monitor the licensees scaffolding program as corrective actions are implemented.

c. Findings

No findings of significance were identified.

4OA3 Followup of Events and Notices of Enforcement Discretion

Main article: IP 71153

.1 (Closed) Unresolved Item 05000237/2011002-01; 05000249/2011002-01; Satisfactory

Performance of a Surveillance Test Procedure That Was Later Demonstrated to be Not Capable of Being Performed The inspectors reviewed WO 902046-01, D2/3 Annual PM Control Room HVAC System Smoke Detector Test, performed on November 25, 2008. This work order was to perform surveillance test DFPS 4183-14, Unit 2/3 Control Room Heating, Ventilation, and Air Conditioning Smoke Detector Annual Surveillance Procedure, Revision 9. The test results identified that Alarm 2/3 2223-89-C1, Control Room/East Turbine Building Smoke Detector Trouble, would not alarm when the following detectors were sprayed with test gas:

2/3-8941-017, located in the control room main return duct;

2/3-8941-018, located in the control room HVAC equipment room train B exhaust duct; and

2/3-8941-013, located on the main control room HVAC outside air supply duct.

The 2/3-2223-89-C1, Control Room/East Turbine Building Smoke Detector Trouble, alarms at Panel 2/3-2223-89 in the Unit 2 switchgear room if a detector loses power. Other alarms at Panel 2/3-2223-89 and in the Control Room alarmed when the detectors were sprayed with test gas. The licensee wrote IR 849580, Problems Encountered during Performance of DFPS 4183-14, to document the issue.

The problem with the test procedure, in this case, was that per DFPS 4183-14 the 2/3 2223-89-C1 alarm was expected to annunciate when the detector was sprayed with test gas. The 2/3-2223-89-C1 alarm was not designed to annunciate when sprayed with test gas but only when the detector lost power. This was not recognized by the licensee at the time even though the 2/3-2223-89-C1 alarm had not annunciated during the performance of DFPS 4183-14 since the first performance of the surveillance test in 2006.

The licensee generated WO 1191692-01, Problems Encountered During Performance of DFPS 4183-14, to troubleshoot the failure of 2/3-2223-89-C1 to alarm when sprayed with test gas. The result of this work order was that all three smoke detectors needed to be replaced. This was documented in IR 957560, Three Smoke Detectors Require Replacement. IR 957560 stated that the scope of work requested was to touch jumper between terminal 9 and 10 of each detector to determine if annunciator 2/3-2223-89-C1 alarmed. The author of the IR stated that annunciator 2/3-2223-89-C1 alarmed for each smoke detector and, therefore, the detectors were bad and needed to be replaced. In this case, the troubleshooting procedure did not identify that the cause of the failure of the 2/3-2223-89-C1 alarm to annunciate was a design issue and not an equipment issue. This was not recognized by the licensee at the time.

However, surveillance test DFPS 4183-14 was performed again, per WO 1191661-01, D2/3 Annual PM Control Room HVAC System Smoke Detector Test, on February 3, 2010, this time with no issues regarding annunciator 2/3-2223-89-C1. The inspectors questioned how this could happen since the detectors, identified as bad in IR 957560 had yet not been replaced and no work had been performed on any of the smoke detectors in question. The licensee performed fact finding based on the inspectors questions why this surveillance test passed when it should not have. The inspectors discussed the fact finding results with the licensee manager that performed the fact finding on April 6, 2011. The licensee found no explanation why the test passed.

The individual that performed the test stated that the performance of that specific test could not be recalled.

The inspectors reviewed the circumstances surrounding the performance of WO 1191661-01, D2/3 Annual PM Control Room HVAC System Smoke Detector Test, on February 3, 2010. The inspectors were unable to determine why the test passed with no issues on February 3, 2010. The inspectors determined that surveillance test procedure DFPS 4183-14, Unit 2/3 Control Room HVAC Smoke Detector Annual Surveillance Procedure, Revision 9, was inadequate as written. The inspectors concluded that the finding was minor since the outcome of the surveillance test regarding the availability or reliability of the smoke detectors was not impacted by this specific procedural inadequacy. The satisfactory performance of DFPS 4183-14 on February 3, 2010, was unexplained. This URI is closed.

.2 (Closed) Unresolved Item 05000237/2011004-05; 05000249/2011004-05; Alert

Declared Due to Chemical Spill Inadequate Basis in 10 CFR 50.59 Evaluation for Installation of Hypochlorite System and Failure to Document a 10 CFR 50.59 Evaluation for Changes Made to the Facility

Introduction:

The inspectors identified a Severity Level IV NCV of 10 CFR 50.59, Changes, Tests, and Experiments having very low safety significance (Green) for the licensees failure to perform an adequate safety evaluation review for changes made to the facility.

Description:

At some point in the past the licensee installed tanks containing sodium hypochlorite and HEDP, (a strong acid) in close proximity to one another. The licensee was unable to retrieve documentation of the existing hypochlorite chemical treatment system. The licensee estimated this change to the facility occurred in 1998 based on drawing change dates. When these chemicals mix, they would produce an on-site release of chlorine gas, as occurred during the Alert referenced in the URI, which could potentially overcome the control room operators. This accident scenario had not been previously considered in the UFSAR and was not bounded by the evaluation of chlorine gas released from off-site sources. Therefore, the licensee failed to provide an adequate basis as to why the installation with a sodium hypochlorite tank in close proximity to HEDP did not create conditions for an accident of a different type than any previously evaluated in the UFSAR.

Dresden Station was committed to Regulatory Guide (RG) 1.78, Assumptions for Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release, Revision 0, in UFSAR, Section 1.8. This RG identified a detailed list and quantity of chemicals considered hazardous to control room habitability, which included chlorine gas. This RG required a detailed analysis of the effects of a hazardous substance released (such as chlorine gas) on the habitability of the control room.

Specifically, Appendix B of RG 1.78 required a detailed diffusion analysis for release of hazardous chemicals (e.g., chlorine) to assess the impact on control room habitability.

Further, step C.3 of RG 1.78 stated any hazardous chemicals stored on-site should be accompanied by instrumentation that will detect its escape, set off an alarm, and provide a readout in the control room. Step C.12 of RG 1.78 required that concurrent chemical release of container contents during an earthquake, tornado or flood should be considered for chemical container facilities that are not designed to withstand these natural events. The inspectors could not assess if the above requirements of RG 1.78 were met because of the lack of documentation.

Without automatic alarm systems, the inspectors concluded, in the event of an on-site generation of chlorine gas, the control room operators may not have sufficient notification to preclude chlorine intrusion into the control room. The inspectors could not determine the consequences of this postulated event because the licensee had not completed a detailed diffusion analysis for the potential chlorine gas generated as discussed in Appendix B of RG 1.78. Therefore, the inspectors concluded that the storage of bulk HEPD in proximity to the sodium hypochlorite tank created conditions for a different type of accident than any previously considered in the UFSAR.

On December 14, 2011, the inspectors questioned the Shift Manager if the station had evaluated the potential for damage to the tanks from earthquake or missile strikes and whether an operability evaluation for the control room envelope had been performed.

The Shift Manager stated that he did not know and wrote IR 1302573, NRC Senior Resident Inspector Question on Chemical Tanks and CREVS [control room emergency ventilation system]. The licensees preliminary operability evaluation determined that none of the tanks were tall enough to tip over during a design basis earthquake and that the height of the fluid was not a concern. In addition, the licensee determined that the coefficient of friction between the concrete and the tanks would prevent the tanks from sliding. The licensee also determined that the probability of a missile strike was on the order of E10-7 or less. The licensee planned to perform a more detailed operability evaluation. On December 15, 2011, the licensee drained the sodium hypochlorite tanks to a tanker truck until a more permanent solution could be found.

The licensee performed Engineering Technical Evaluation (EC) 387018, Control Room Habitability Evaluation for Chlorine Gas Release at the Crib House, Revision 1. The technical evaluation determined that the control room envelope was safe from a worst case toxic exposure to chlorine gas as long as Sodium Hypochlorite volume remained less than 45 percent of total (2 tank) volume (7,197 gallons). The licensee also performed EC 387073 to determine the historic operability of the sodium hypochlorite tanks to include seismic, wind, and missile considerations. The licensee determined in EC 387073 that the tanks would not have been affected by wind, seismic, or missile impacts with a level of sodium hypochlorite equal to or greater than the level necessary to make the control room envelope inoperable identified in EC 387018.

Analysis:

The inspectors determined that the failure to provide an adequate basis for changes made to the facility in accordance with 10 CFR 50.59 was a performance deficiency warranting a significance evaluation. Specifically, the licensee failed to provide an adequate basis as to why changes made, i.e. installing the two chemical tanks in close proximity to one another, did not create conditions for a different type of accident than any previously considered in the UFSAR.

In accordance with the NRC Enforcement Policy section 6.1.d.2, this finding was categorized as Severity Level IV violation because it was an example where the licensee failed to provide a safety evaluation for a plant design change and the underlying technical issue was evaluated under the SDP as having a very low safety significance.

Because violations of 10 CFR 50.59 are considered to be violations that potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the SDP. However, if possible, the underlying technical issue is evaluated under the SDP to determine the severity of the violation. In this case, the underlying technical issue affected the Barrier Integrity Cornerstone. The finding was evaluated under the SDP using NRCs IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and the inspectors answered yes to the question in Table 4a; Does the finding represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere? The SDP required a phase 3 analysis to resolve this type of finding. However, after consultation with a Region 3 Senior Reactor Analyst it became apparent that no SDP methods or tools exist to determine the significance of the finding. Therefore, the finding was not suitable for evaluation using the SDP. As a result, the risk significance was established in accordance with the qualitative criteria of Appendix M (dated December 22, 2006) of IMC 0609. Specifically, the qualitative decision-making attribute from Table 4.1 of Appendix M, Finding can be bounded using qualitative and/or quantitative information?,

was applicable to this finding. The licensee performed two quantitative engineering evaluations regarding this finding. The first (EC 387018) determined the minimum level of sodium hypochlorite stored in the tanks necessary that, if it were to completely interact with the HEPD and completely release all of the contained chlorine, would render the control room envelope inoperable. The second (EC 387073) determined that the tanks would not have been affected by wind, seismic, or missile impacts with a level of sodium hypochlorite equal to or greater than the level necessary to make the control room envelope inoperable identified in EC 387018. Therefore, based upon a qualitative measure of risk determined in accordance with Appendix M, NRC management concluded that the issue was of very low safety significance (Green).

This finding has no cross-cutting aspect because it does not represent current licensee performance.

Enforcement:

Title 10 CFR 50.59(b)(1) (1997, 1998) stated, in part, that the licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section, to the extent that these changes constitute changes in the facility as described in the safety analysis report or to the extent that they constitute changes in procedures as described in the safety analysis report. These records must include a written safety evaluation which provides the bases for the determination that the change, test, or experiment does not involve an unreviewed safety question.

Title 10 CFR 50.59 (a)(2)(ii) (1997, 1998) stated, in part, that a proposed change, test, or experiment shall be deemed to involve an unreviewed safety question if a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created.

Contrary to the above, from approximately 1998, through December 15, 2011, the licensee failed to maintain records of a change to the facility when it installed HEPD tanks in proximity to a sodium hypochlorite tank. The licensee did not maintain records of a written safety evaluation which provided the basis for the determination that the change did not involve an unreviewed safety question. Specifically, the accident scenario involving an on-site release of chlorine gas overcoming the control room operators had not been previously evaluated in the UFSAR and was not bounded by the UFSAR evaluation of chlorine released from off-site sources.

In accordance with the Enforcement Policy, this violation of the requirements of 10 CFR 50.59 was classified as a Severity Level IV Violation because the underlying technical issue was of very low safety significance. Because this non-willful violation was non-repetitive, and was captured in the licensees CAP (IR 1302573), it is considered a NCV consistent Section 2.3.2 of the Enforcement Policy.

(NCV 05000237/2012002-04; 05000249/2012002-04, Inadequate Basis in 10 CFR 50.59 Evaluation for Installation of Hypochlorite System)

The finding is evaluated separately from the traditional enforcement violation and, therefore, is being assigned a separate tracking number (FIN 05000237/2012002-05; 05000249/2012002-05, Failure to Document a 10 CFR 50.59 Evaluation for Changes Made to The Facility). As part of its corrective action, the licensee entered the issue into its corrective action program (IR 1302573)and performed EC evaluations EC 38018 and EC 387073 which resulted in the draining of the sodium hypochlorite tanks to a volume of less than 45 percent for both tanks until the historical operability of the system could be determined.

URI 05000237/2011004-05; 05000249/2011004-05, Alert Declared Due to Chemical Spill is closed.

.3 Unit 2 Control Rod Drive Flow Control Valve Failed Closed Due to Inadequate Work

Order Instructions

Introduction:

A finding of very low safety significance was self-revealed for the failure to properly install instrument air tubing that affected the operation of both of the Unit 2 Control Rod Drive (CRD) Flow Control Valves (FCV).

Description:

On January 31, 2012, both Unit 2 CRD flow control valves failed closed when an instrument air line leading into the Unit 2 CRD Flow Control Valve A/B Selector Valve (2-302-6B) separated removing control air to both valves. This condition was identified when the 902-5 F-3 Rod Drive Temperature High alarm was received in the control room. The separated line was made of plastic. An operator, with instrument maintenance department assistance, reconnected the line within 31 minutes from the time the alarm was received. The licensee wrote IR 1321011, Unit 2 CRD FCV Failed Closed, and performed a prompt investigation.

The inspectors reviewed the licensee prompt investigation. The licensees investigation stated that the operators entered DOA 0300-01, Control Rod Drive System Failure, Revision 21, but did not state whether the procedure had been performed correctly. The inspectors reviewed DOA 0300-01 and interviewed the nuclear station operator at the time of the event. The inspectors concluded that DOA 0300-01 was entered and performed correctly.

The licensee also wrote IR 1323295, Improper Installation of U2 CRD FCV Selector Switch Tubing, and IR 1324945, NOS ID - Issue with Tech Justification for Plastic Air Line. These documents identified that the failed Unit 2 CRD Flow Control Valve A/B Selector Valve (2-302-6B) had been replaced on December 1, 2011, via WO 1487301-01. The equipment installed under this work order was neither safety-related nor augmented quality. However, plant design specification K-4080 Section 1502.1.b7 stated, neither plastic tubing nor plastic piping are acceptable for instrument and control piping except where specified. The newly replaced 2-302-6B had plastic tubing. Procurement Evaluation (PE) 56060 was previously prepared which specified that the new tubing was plastic and Attachment 4 of PE 56060 required the tubing to be installed using a barbed plastic connector to hold the connection in place where 5/32 inch tubing connected with 1/4 inch tubing. However, PE 56060 was prepared for a previous model number of the part used for 2-302-6B. When 2-302-6B was replaced in December 2011, a new model number was used which did not have the PE 56060 attached to it. The work planner did not have access to PE 56060 when WO 1487301 was prepared. The new model number still required the barbed connector.

The WO 1487301-01 instructions did not specify the use of this barbed connector and it was not installed. The point at which the barbed connector was not installed was the point at which the tubing failed.

Analysis:

The inspectors determined that the failure to have adequate maintenance instructions to install 2-302-6B with plastic tubing connectors was contrary to PE 56060 and was a performance deficiency.

The finding was determined to be more than minor because the finding was associated with the Initiating Events Cornerstone attribute of equipment performance of the Cornerstone Objectives and Attributes Tables of Manual Chapter 0612, Appendix B, dated January 1, 2010, and affected the cornerstone objective of to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to install the plastic piping connectors resulted in the separation of the plastic instrument air tubing resulting in the Unit 2 CRD FCVs to fail closed. In addition, DOA 0300-01, Step D.9.d, stated, in part, that if CRD flow control is lost and cannot be regained then reduce load and manually scram the reactor. The inspectors concluded, after interviewing the control room operator at the time of the valve failure, that the reason for the valve failure was identified and corrected in a timely manner. However, if the non-licensed operator in the field had not been able to quickly identify the source of the problem and resolve it there would have been no choice but to scram the reactor.

The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 -

Initial Screening and Characterization of Findings, Table 4a, for the Initiating Events Cornerstone. The inspectors determined that the finding did not result in both the likelihood of reactor trip and the likelihood that mitigation equipment or functions would not have been available. Therefore, the finding screened as having very low safety significance (Green).

This finding has a cross-cutting aspect in the area of Human Performance, Resources, because the licensee did not have complete, accurate, and up-to-date design documentation. Specifically, the failure to attach PE 56060 to the most current part number necessary to replace 2-302-6B resulted in the failure to include instructions to install the plastic piping connectors in the work order that was used to replace 2-302-6B.

This resulted in the separation of the plastic instrument air tubing and the Unit 2 CRD FCVs failing closed. (H.2(c))

Enforcement:

No violation of regulatory requirements occurred.

(FIN 05000237/2012002-06; 05000249/2012002-06, Unit 2 Control Rod Drive Flow Control Valve Failed Closed Due to Inadequate Work Order Instructions)

The licensee entered this into the corrective action program as IR 1323295, Improper Installation of U2 CRD FCV Selector Switch Tubing. The licensee made temporary repairs to the 2-302-6B switch and wrote a work request to make final repairs. The licensee also wrote work requests to inspect the Unit 3 selector switch. The licensee also wrote a procedure change request to review DOA 0300-01, Control Rod Drive System Failure, to clarify the decision to scram upon flow control valve failure. The licensee generated a corrective action to tie PE 56060 to the new 2-302-6B model number. The licensee planned to prepare an equipment apparent cause evaluation (EACE). Additional corrective actions should result from the EACE.

.4 Inadequate Work Instructions Leads to Failure of Secondary Containment Interlock

Introduction:

A finding of very low safety significance and associated non-cited violation of TS Section 5.4.1 was self-revealed because the work instructions associated with WO 1450006-01, D2 SA PM 517 RB/TB INTLK DOOR (2-5850-52) ELECTRICAL CHECKS, were inadequate.

Description:

On December 21, 2011, the licensee performed WO 1450006-01, D2 SA PM 517 RB/TB INTLK DOOR (2-5850-52) ELECTRICAL CHECKS, to ensure the reactor building interlock doors were functioning properly. During the performance of this work, connection point A19 was lifted to measure the in-line current of the door magnet for reactor building interlock door 52 (EPN 2-5850-52).

By lifting connection A19, turbine building interlock door 16 (EPN 2-5850-16) lost power to its locking magnets. This loss of power caused both doors of the Unit 2 interlock to be open (door 52 was being held open and did not lose power due to this). This caused alarm 902-4 E-19, RX/TURB 517 INTLK DOORS INOP/BYP, to occur. This condition existed for nine seconds. The licensee entered into TS 3.6.4.1, Condition A, Secondary Containment Inoperable in Mode 1, 2, or 3, and resulted in a subsequent event notification report, Event Number 47540. The licensee subsequently determined that the differential pressure between the reactor building and the turbine building never exceeded the TS limit of -.25 in Hg and retracted the event notification. The inspectors concurred with the licensees retraction.

The licensee performed a root cause investigation and determined that the instructions for WO 1450006 were inadequate because the instructions required the lifting of an electrical connection at the wrong point. The licensees root cause evaluation determined that the work planner copied the instructions for the Unit 2 task from the Unit 3 work instructions and did not ensure that all the instructions unique to Unit 2 were correct.

Analysis:

The inspectors determined that the failure to use adequate work instructions for an activity affecting quality was contrary to TS 5.4.1 and was a performance deficiency.

The finding was determined to be more than minor because the finding was associated with the Barrier Integrity Cornerstone attribute of configuration control and affected the cornerstone objective of maintaining the functionality of containment. Specifically, the use of inadequate work instructions resulted in the temporary failure of the secondary containment boundary between the Unit 2 Reactor Building and the Unit 2 Turbine Building.

The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 -

Initial Screening and Characterization of Findings, Table 4a for the Barrier Cornerstone because the finding affected the secondary containment. The inspectors answered all four questions No which resulted in the finding screening as having very low safety significance (Green).

This finding has a cross-cutting aspect in the area of Human Performance, Work Practices, because the licensee did not ensure that human error techniques such as self and peer checking was used during the creation of the work package. Specifically, the licensees root cause report stated that the root cause of the problem was the lack of rigor in the application of technical human performance fundamentals by a work planner.

The inspectors questioned what the was the specific requirement not followed by the work planner licensee and management personnel stated that the work planner failed to adequately self-check and get a peer check on the completion of the preparation of the work package. (H.4(c))

Enforcement:

TS Section 5.4.1 states, in part, that written procedures shall be established, implemented, and maintained covering applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, issued February 1978.

Paragraph 9 of this Regulatory Guide states, in part, that procedures for performing maintenance on safety-related equipment should be properly prepared and activities shall be performed in accordance with these procedures. The licensee established WO 1450006-01, D2 SA PM 517 RB/TB INTLK DOOR (2-5850-52) ELECTRICAL CHECKS, as the implementing procedure for performing surveillance testing of the Unit 2 secondary containment door interlocks.

Contrary to the above, on December 21, 2011, maintenance procedure WO 1450006-01, D2 SA PM 517 RB/TB INTLK DOOR (2-5850-52) ELECTRICAL CHECKS, was inadequate. Specifically, the procedure did not contain the correct designation for a lead that was lifted while performing the surveillance test. The licensees corrective actions included disciplining the maintenance planner and having each of the maintenance department heads prepare human performance improvement plans. Because this violation was of very low safety significance and it was entered into the licensees corrective action program as IR 1305358 this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.

(NCV 05000237/2012002-07; 05000249/2012002-07, Inadequate Work Instructions Leads to Failure of Secondary Containment Interlock)

.5 Failure to Make a Required 8 Hour Event Report Per 10 CFR 50.72(b)(3)(v)(D) and

APRMs 4, 5, and 6, Not Within The Technical Specification limits Prescribed In Technical Specification 3.3.1.1 Table 3.3.3.3-1, 2.b and c

Introduction:

The inspectors identified a Severity Level IV NCV and associated finding of very low safety significance of 10 CFR 50.72(b)(3)(v)(D), Immediate Notification Requirements for Operating Nuclear Power Reactors, for the failure to report an event to the NRC within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months where an event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident.

Description:

On February 19, 2012, the licensee entered TS 3.3.1.1 because the flow biased neutron flux-high and the fixed neutron flux-high functions for average power range monitor (APRMs) channels 4, 5, and 6 were inoperable simultaneously. The APRMs 4, 5, and 6 impacted all of Trip System B of the reactor protection system. With APRMs 4, 5, and 6, all inoperable at the same time the reactor would not scram on flow biased neutron flux-high or fixed neutron flux-high within the TS limits.

The licensee performed a down power to perform a rod pattern adjustment. The licensee failed to respond in a timely manner to a computer alarm warning that the APRM Gain Adjustment Factor (AGAF) settings were not within limits. The Nuclear Station Operator, the Unit Supervisor, the Reactivity Manager, and the Qualified Nuclear Engineer were all aware that the alarm had sounded but no action was taken to verify the extent of or correct the problem until after the next shift took over. When the problem was identified the oncoming shift verified that the time period where APRMs 4, 5, and 6 exceeded the TS 3.3.1.1 limit did not exceed the TS Limiting Condition for Operation time limit.

Analysis:

The inspectors determined that the failure to report within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months an event where an event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident, as required by 10 CFR 50.72(b)(3)(v)(D), was a performance deficiency.

The inspectors reviewed this issue in accordance with IMC 0612, Appendix B, and the discussion for Block 7, Figure 2, paragraph 2.a.v., and determined that a failure to report was an example of a violation that could impact the regulatory process and was subject to Traditional

Enforcement.

The inspectors determined that the underlying technical issue involved the inability to scram Unit 2 on flow biased neutron flux-high or fixed neutron flux-high functions within the TS limits prescribed in TS 3.3.1.1 Table 3.3.3.3-1, 2.b and c. Although the licensee identified the issue before the TS Limiting Condition for Operation expired a more timely identification and resolution of the problem might have prevented entering the TS at all.

The inspectors determined that the issue was more than minor, because if left uncorrected it would have had the potential to lead to a more significant safety concern.

Using IMC 0609, Table 4a, Characterization Worksheet for IE, MS, and BI Cornerstones, the inspectors determined that the finding had very low safety significance because they answered No to all five questions contained in Column 2 of the Table 4a worksheet. As a result, the inspectors determined that the finding had very low safety significance (Green). The inspectors then asked Does the finding represent a loss of system safety function? The inspectors concluded through discussions with a Region III Senior Reactor Analyst that this question referred to a loss of the entire reactor protection system which was not the case. Only the flow biased neutron flux-high and fixed neutron flux-high safety functions were impacted.

In accordance with the NRC Enforcement Policy, this violation was categorized as Severity Level IV because it was an example where the licensee failed to make a report required by 10 CFR 50.72. Specifically, it represented a failure to identify a loss of safety function. The inspectors evaluated the underlying technical issue utilizing the SDP and determined the finding to be of very low safety significance.

The inspectors also determined that the contributing cause that provided the most insight into the performance deficiency affected the cross-cutting area of Problem Identification and Resolution, including properly classifying, prioritizing, and evaluating for operability and reportability, conditions adverse to quality. (P.1(c))

Enforcement:

Title 10 CFR 50.72(b)(3)(v)(D), Immediate Notification Requirements for Operating Nuclear Power Reactors, requires, in part, that the licensee shall report within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months an event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident.

Contrary to the above, on February 19, 2012, the licensee entered TS 3.3.1.1 because the flow biased neutron flux-high and the fixed neutron flux-high functions for APRMs 4, 5, and 6 were inoperable simultaneously and did not report this condition within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The APRMs 4, 5, and 6 impacted all of Trip System B of the reactor protection system.

With APRMs 4, 5, and 6, all inoperable at the same time the reactor would not scram on flow biased neutron flux-high or fixed neutron flux-high within the TS limits prescribed in TS 3.3.1.1 Table 3.3.3.3-1, 2.b and c. This was an event that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident. The licensee had not prepared any corrective actions by the end of the inspection period.

In accordance with Section 6.9.d.9 of the Enforcement Policy, the violation was classified as Severity Level IV because it was an example where the licensee failed to make a report required by 10 CFR 50.72; and the underlying technical issue was evaluated by the SDP and determined to be of very low safety significance. Because this violation was of very low safety significance, was not repetitive or willful, and was entered into the licensee's corrective action program as IRs 1328879, 1341456, and 1344970, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000237/2012002-08; Failure to Make a Required 8 Hour Event Report Per 10 CFR 50.72(b)(3)(v)(D))

This finding was evaluated separately from the Traditional Enforcement violation; therefore, the finding was assigned a separate tracking number.

(FIN 05000237/2012002-09; APRMs 4, 5, and 6, Not Within The TS limits Prescribed In TS 3.3.1.1 Table 3.3.3.3-1, 2.b and c)

.6 (Closed)Licensee Event Report 05000237;05000249/2011-004-00, Personnel Error

Results in Control Room Emergency Ventilation Air Conditioning System Inoperability The inspectors reviewed the subject LER to evaluate the accuracy, appropriateness of corrective actions, any violations of requirements, and potential generic issues.

On October 24, 2011, during Unit 2 refueling activities, two electrical maintenance technicians performing a clearance boundary safety verification opened a Bus 23 potential transformer (POT) fuse drawer causing an undervoltage load shed signal that resulted in the inoperability of the CREV air conditioning system. The Bus 23 POT fuse drawer was subsequently closed and plant systems returned to their original configuration.

Following the event, the licensee determined the cause was personnel error. Corrective actions taken included an electrical maintenance department clock reset and stand down to discuss the event and consequences of taking actions in the plant without proper guidance. Further licensee corrective actions involved performing an evaluation of the implementation of robust barriers for bus pot fuse compartments.

A self-revealed finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was previously documented as NCV 05000237/2011005-01 for failure to follow clearance order instructions and operating plant equipment without a procedure.

Documents reviewed in this inspection are listed in the Attachment to this report. This LER is closed.

This event follow up review by the inspectors constituted a single inspection sample as defined in IP 71153-05.

4OA5 Other Activities

.1 (Closed) NRC Temporary Instruction 2515/177, Managing Gas Accumulation in

Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (NRC Generic Letter 2008-01)

a. Inspection Scope

The inspectors verified that the onsite documentation, system hardware, and licensee actions were consistent with the information provided in the licensees response to NRC Generic Letter (GL) 2008-01, Managing Gas Accumulation in ECCS, Decay Heat Removal (DHR), and CS Systems. Specifically, the inspectors verified that the licensee has implemented or was in the process of implementing the commitments, modifications, and programmatically controlled actions described in the licensees response to GL 2008-01. The inspection was conducted in accordance with Temporary Instruction (TI)2515/177, Managing Gas Accumulation in ECCS, DHR, and CS Systems (NRC GL 2008-01), and considered the site-specific supplemental information provided by Office of Nuclear Reactor Regulations (NRR) to the inspectors. The inspectors focused their review on the HPCI and core spray systems.

The documents reviewed are listed in the Attachment to this report.

b. Inspection Documentation The selected TI areas of inspection were licensing basis, design, testing, and corrective actions. The documentation of the inspection effort and any resulting observations are below.

(1) Licensing Basis: The inspectors reviewed selected portions of licensing basis documents to verify that they were consistent with the NRR assessment report and that they were processed by the licensee. The licensing basis verification included the verification of selected portions of TS, TS basis, UFSAR, and Technical Requirements Manual (TRM). The inspectors noted that the licensee had not updated the UFSAR to reflect the analysis performed in response to GL 2008-01 to demonstrate the capability of the subject systems to shut down the reactor, maintain it in a safe shutdown condition, and prevent or mitigate the consequences of an accident with respect to potential gas accumulation. This issue had been previously identified by the licensee during their Functional Area Self-Assessment (FASA) in preparation for this inspection and was being tracked by the licensee in the CAP per IR1316097.

The inspectors also verified that applicable documents that described the plant and plant operation, such as calculations, piping and instrumentation diagrams (P&IDs),procedures, and CAP documents, addressed the areas of concern and were changed if needed following plant changes. The inspectors also confirmed that the frequency of selected surveillance procedures were at least as frequent as required by TSs. In addition, the inspectors confirmed the licensee had implemented a periodic monitoring program to monitor other gas susceptible locations via ultrasonic testing (UT) as part of their resolution to GL 2008-01. The licensees basis for the UT periodicity was, in part, the results of the examinations performed up to the timeframe of this inspection. Finally, the inspectors also confirmed that the licensees CAP captured the commitment to support the industry Technical Specification Task Force Traveler (TSTF) and NEI Gas Accumulation Management Team activities regarding resolution of generic TS issues, evaluate the resolution of the TSTF, and submit a license amendment request, if deemed necessary based on this evaluation, within 180 days following NRC approval of the TSTF. This commitment was tracked in the CAP per IR 831868.

(2) Design: The inspectors reviewed selected design documents, performed system walkdowns, and interviewed plant personnel to verify that the design and operating characteristics were addressed by the licensee. Specifically:

(a) The inspectors assessed the licensees efforts for identifying the gas intrusion mechanisms that apply to the licensees plant and noted one example where the licensee did not initially recognize a potential gas intrusion mechanism.

Specifically, the SDC system design and operation may not preclude the formation of steam voids during Mode 3 if a loss-of-coolant event occurred.

Since the SDC system discharges into the LPCI discharge piping it could potentially cause a water hammer in the piping if the hot water flashed to steam during the switchover from SDC to LPCI. The licensee identified this concern during the FASA based on a review of industry operating experience and was tracking the evaluation in the CAP per IR 1312222.

(b) The inspectors assessed whether the licensees void acceptance criteria was consistent with NRRs void acceptance criteria. If NRRs acceptance criterion was not met, then the inspectors verified that the licensee had justified the deviations. The inspectors also confirmed that

(1) the licensee addressed the effect of pressure changes during system startup and operation since such changes could significantly affect the void fraction from the initial value; and

(2) the range of flow conditions evaluated by the licensee was consistent with the full range of design basis and expected flow rates for various break sizes and locations.

(c) The inspectors reviewed selected documents, including calculations, engineering evaluations, and vendor technical manuals, with respect to gas accumulation in the subject systems. Specifically, the inspectors verified these documents addressed venting requirements, keep-full systems, void control during system realignments, and the effect of debris on strainers in the torus causing accumulation of gas under the upper elevation of strainers and the impact on net positive suction head requirements.

The licensee identified a void in the discharge flow path of the Unit 2 HPCI system caused by seat leakage through motor operated valve (MOV) 2-2301-8 and its associated check valve 2-2301-7, which was identified during testing in November 2011. The leakage was documented and analyzed in IR 01287893 and IR 01311205. The licensee could not measure the void size by UT due to radiological conditions in the area. The licensee initiated an Adverse Conditioning Monitoring Program (ACMP) 1287893-02, as an alternate method, to assess the size of the void at power until the next available work window that would allow valve rework to address the leak-by issues. The inspectors reviewed the ACMP for Unit 2 and the associated RELAP5 model generated to assess the licensees ability to determine the void size based on piping temperatures. The RELAP5 model was based on a separate independent model that had been generated using actual plant data gathered during a previous water hammer event in 2001, where representative pressures and loads seen during the event were determined. Therefore, the inspectors concluded that, absent actual void measurement, the model produced a reasonable estimation of void size in the discharge line of the HPCI system based on valve leakage and pipe temperatures. Using the current leakage rate, pipe temperatures and pressures, and constant environmental conditions, the licensee determined that the maximum void size would not result in a transient that would exceed design piping loads. The licensee determined that a similar void may exist in the Unit 3 HPCI discharge piping due to similar piping configuration and recent operating experience, where a small amount of gas was vented from the high point as documented in IR 01314936. The licensee initiated ACMP 1314936-06 similar to Unit 2 utilizing RELAP5 results for Unit 3 HPCI discharge injection piping upstream of MOV 3-2301-8. The licensees actions to monitor and/or minimize the void size, which was recently revised in January 2012, included establishing a sufficient length of venting time, trending vent times, temperature/pressure monitoring, and increasing the venting frequency, to ensure the voids were below the maximum void size assumed in the RELAP5 model until additional corrective actions can be taken to resolve the leakage issue. The inspectors, in consultation with NRC Headquarters staff, concluded the licensees approach provided reasonable assurance the void volumes would remain acceptable from an operability standpoint. The licensee continued to explore additional methods to monitor these susceptible void locations while at power.

(d) The inspectors conducted a walkdown of selected regions of HPCI and core spray in sufficient detail to assess the licensees walkdowns. The inspectors also verified that the information obtained during the licensees walkdown was consistent with the items identified during the inspectors independent walkdown.

The inspectors also assessed if the P&IDs accurately described the subject systems and were up-to-date with respect to recent hardware changes. In addition, the inspectors assessed if the licensee had isometric drawings that describe the configurations of the GL 2008-01 scoped systems and had confirmed the accuracy of the drawings.

(e) The licensee indicated the isometric drawings were not maintained up-to-date; therefore, were not relied upon for the gas management program. The licensee stated the current, as built configurations are documented in the P&IDs and inservice inspection (ISI) drawings. While reviewing the modification documents for installing the core spray vent lines, the inspectors identified the installation process did not require the ISI drawings to be updated. The inspectors noted the drawings had been updated after the licensee completed another modification -

the installation of additional vent path piping. However, the inspectors noted the licensee did not capture this discrepancy in the corrective action program. The licensee initiated IR 1324322 to address the concern with not updating the drawings when vent valves were initially installed and for not following the CAP process.

The inspectors also conducted a similar walkdown of the normally inaccessible portions of the core spray and HPCI systems in earlier inspection periods.

These additional activities counted towards the completion of this TI and were documented in IR 05000237/2009005; 05000249/2009005 and IR 05000237/2010002; 05000249/2010002.

(f) The inspectors verified that licensees walkdowns have been completed. In addition, the inspectors selectively verified that information obtained during the licensees walkdowns were addressed in procedures, the CAP, and training documents.

During the FASA, the licensee identified the engineering groups had not received training on GL 2008-01, which was documented in IR 1315483. The inspectors noted that in their October 29, 2009, response to a Request for Additional Information, the licensee had indicated that training modules were being developed for engineering, maintenance, and operation personnel and the modules would be evaluated for implementation at the station. Although no commitment was made to implement the training, the licensee had not established any tracking mechanism to conduct this evaluation stated in their response to the NRC. The inspectors further identified the mechanical maintenance and operations personnel also did not receive the training on GL 2008-01. The licensee initiated IR 324819 to address this issue.

(3) Testing: The inspectors reviewed selected surveillance, post-modification test, and post-maintenance test procedures and results to assess if the licensee approved and was using procedures that were adequate to address the issue of gas accumulation and/or intrusion in the subject systems. Specifically:

(a) The inspectors reviewed procedures used for conducting void periodic monitoring and determination of void volumes to ensure the void criteria was satisfied and will be reasonably ensured to be satisfied until the next scheduled void surveillance.

Inspectors noted the licensee revised procedure ER-DR-200-101, Periodic Monitoring for Gas Accumulation in ECCS Systems, on July 29, 2010, to clarify the evaluation equation used to determine void volumes in both sloped and horizontal piping. The inspectors identified that although the licensee had identified and corrected the equation, no review was performed to evaluate whether void sizes determined using the previous methodology were still bounded by the licensees acceptance criteria. The licensee initiated IR 1317850, IR 1318782, IR 1325027 to address historical voids and verified as-left voids were still bounded by the void acceptance criteria.

(b) The inspectors reviewed selected procedures used for void control, such as filling and venting, following conditions which may have introduced voids into the subject systems, to verify that the procedures addressed testing for such voids and provided processes for their reduction or elimination.

(4) Corrective Actions: The inspectors reviewed selected licensees assessment reports and CAP documents to assess the effectiveness of the licensees CAP when addressing the issues associated with GL 2008-01. In addition, the inspectors verified that selected corrective actions identified in the licensees 9-month and supplemental reports were documented. The inspectors also verified that commitments were included in the CAP.

Based on this review, the inspectors concluded that there is reasonable assurance that the licensee will complete all outstanding items and incorporate this information into the design basis and operational practices. Therefore, this TI is considered closed

c. Findings

No findings of significance were identified.

.2 Temporary Instruction 2515/182, Review of the Industry Initiative to Control Degradation

of Underground Piping and Tanks

a. Inspection Scope

Leakage from buried and underground pipes has resulted in ground water contamination incidents with associated heightened NRC and public interest. The industry issued a guidance document, NEI 09-14, Guideline for the Management of Buried Piping Integrity, (ADAMS Accession No. ML1030901420), to describe the goals and required actions (commitments made by the licensee) resulting from this underground piping and tank initiative. On December 31, 2010, NEI issued Revision 1 to NEI 09-14, Guidance for the Management of Underground Piping and Tank Integrity, (ADAMS Accession No.

ML110700122), with an expanded scope of components, which included underground piping that was not in direct contact with the soil and underground tanks. On November 17, 2011, the NRC issued TI-2515/182, Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks, to gather information related to the industrys implementation of this initiative.

The inspectors reviewed the licensees programs for buried pipe, underground piping and tanks in accordance with TI-2515/182 to determine if the program attributes and completion dates identified in Sections 3.3 A and 3.3 B of NEI 09-14 Revision 1 were contained in the licensees program and implementing procedures. For the buried pipe and underground piping program attributes with completion dates that had passed, the inspectors reviewed records to determine if the attribute was in fact complete and to determine if the attribute was accomplished in a manner which reflected good or poor practices in program management.

Based upon the scope of the review described above, Phase I of TI-2515/182 was completed.

b. Observations The licensees buried piping and underground piping and tanks program was inspected in accordance with Paragraphs 03.01.a through 03.01.c of TI-2515/182 and was found to meet all applicable aspects of NEI 09-14 Revision 1, as set forth in Table 1 of the TI.

c. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On April 19, 2012, the inspectors presented the inspection results to Mr. D. Czufin, and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee.

.2 Interim Exit Meetings

Interim exit meetings were conducted for:

The review of the Industry Initiative to Control Degradation of Underground Piping and Tanks (TI -2515/182) with Site Vice President, Mr. D. Czufin, and other members of the licensee staff on January 19, 2012.

The inspection results for the areas of in-plant airborne radioactivity control and mitigation; occupational dose assessment; and RCS specific activity performance indicator verification with Mr. D. Czufin, Site Vice President, on January 27, 2012.

Public radiation safety for the radioactive solid waste processing and radioactive material handling, storage, and transportation program with Mr. D. Czufin, Site Vice President on January 27, 2012.

The results of the Emergency Preparedness program inspection were discussed with Mr. D. Czufin on February 03, 2012.

On February 10, 2012, the inspectors presented the Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (NRC Generic Letter 2008-01) (TI-2515/177)inspection results to Mr. S. Marik, and other members of the licensee staff.

The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D. Czufin, Site Vice President

S. Marik, Station Plant Manager

D. Anthony, NDES Manager

J. Biegelson, Engineering

H. Bush, Radiation Protection Manager

J. Cady, Radiation Protection Manager

P. Chambers, Dresden Licensed Operator Requalification Training Lead

P. DiSalvo, GL 89-13 Program Owner

H. Do, Corporate ISI Manager

D. Doggett, Emergency Preparedness Coordinator

J. Fox, Design Engineer

J. Freeman, Corporate Engineering

G. Gates, Operations

D. Glick, Radioactive Material Shipping Specialist

G. Graff, Nuclear Oversight Manager

M. Hosain, Site EQ Engineer

R. Johnson, Chemistry

L. Jordan, Training Director

B. Kapellas, Operations Director

D. Ketchledge, Engineering

J. Knight, Director, Site Engineering

M. Knott, Instrument Maintenance Manager

J. Kish, Site ISI

S. Kvasnicka, NDE Level III

D. Leggett, Regulatory Assurance Manager / Chemistry Manager

G. Lupia, Corporate Buried Pipe Engineer

T. Mohr, Supervisor, Engineering Programs

P. Mankoo, Chemistry Manager

G. Morrow, Operations

M. McDonald, Maintenance Director

T. Mohr, Engineering Program Manager

P. OBrien, Regulatory Assurance - NRC Coordinator

D. OFlanagan, Security Manager

M. Otten, Operations Training Manager

M. Pavey, RP Specialist

P. Quealy, Emergency Preparedness Manager

R. Ruffin, Licensing Engineer

D. Schiavoni, Engineering

J. Sipek, Work Control Director

R. Stachniak, Engineering

R. Sisk, Buried Pipe Program Owner

L. Torres, Engineering

Attachment

Nuclear Regulatory Commission

S. West, Director, Division of Reactor Projects

J. Cameron, Chief, Division of Reactor Projects, Branch 6

IEMA

R. Schulz, Illinois Emergency Management Agency

R. Zuffa, Illinois Emergency Management Agency

Attachment

ITEMS OPENED, CLOSED AND DISCUSSED

Opened

05000237/2012002-01 URI Failure to Report an Unanalyzed Condition that Could

05000249/2012002-01 Significantly Degrade Plant Safety (1R15)05000237/2012002-02 NCV Failure to Ensure the Effectiveness of Packages as05000249/2012002-02 required by DOT Regulations (Section 2RS8)05000237/2012002-03 NCV Failure to Ensure Packages Containing Solid Waste

05000249/2012002-03 Contain as Little Free Standing and Noncorrosive Liquid

as Reasonably Achievable (2RS8)05000237/2012002-04; NCV Inadequate Basis in 10 CFR 50.59 Evaluation for

05000249/2012002-04 Installation of Hypochlorite System (4OA3.2)05000237/2012002-05; FIN Failure to Document a 10 CFR 50.59 Evaluation for

05000249/2012002-05 Changes Made to the Facility (4OA3.2)05000237/2012002-06; FIN Unit 2 Control Rod Drive Flow Control Valve Failed Closed

05000249/2012002-06 Due to Inadequate Work Order Instructions (4OA3.3)05000237/2012002-07; NCV Inadequate Work instruction Leads to Failure of

05000249/2012002-07 Secondary Containment Interlock (4OA3.4)05000237/2012002-08 NCV Failure to Make a Required 8 Hour Event Report Per

CFR 50.72(b)(3)(v)(D) (4OA3.5)05000237/2012002-09 FIN APRMs 4, 5, and 6, Not Within The TS limits Prescribed In

TS 3.3.1.1 Table 3.3.3.3-1, 2.b and c (4OA3.5)

Closed

05000237/2012002-02 NCV Failure to Ensure the Effectiveness of Packages as05000249/2012002-02 required by DOT Regulations (Section 2RS8)05000237/2012002-03 NCV Failure to Ensure Packages Containing Solid Waste

05000249/2012002-03 Contain as Little Free Standing and Noncorrosive Liquid

as Reasonably Achievable (2RS8)05000237/2011002-01; URI Satisfactory Performance of a Surveillance Test

05000249/2011002-01 Procedure That Was Later Demonstrated to be Not

Capable of Being Performed (4OA3.1)05000237/2011004-05; URI Alert Declared Due to Chemical Spill (4OA3.2)05000249/2011004-05

05000237/2012002-04; NCV Inadequate Basis in 10 CFR 50.59 Evaluation for

05000249/2012002-04 Installation of Hypochlorite System (4OA3.2)05000237/2012002-05; FIN Failure to Document a 10 CFR 50.59 Evaluation for

05000249/2012002-05 Changes Made to the Facility (4OA3.2)05000237/2012002-06; FIN Unit 2 Control Rod Drive Flow Control Valve Failed Closed

05000249/2012002-06 Due to Inadequate Work Order Instructions (4OA3.3)05000237/2012002-07; NCV Inadequate Work instruction Leads to Failure of

05000249/2012002-07 Secondary Containment Interlock (4OA3.4)05000237/2012002-08 NCV Failure to Make a Required 8 Hour Event Report Per

CFR 50.72(b)(3)(v)(D) (4OA3.5)05000237/2012002-09 FIN APRMs 4, 5, and 6, Not Within The TS limits Prescribed In

TS 3.3.1.1 Table 3.3.3.3-1, 2.b and c (4OA3.5)

05000237/2011-004-00; LER Personnel Error Results in Control Room Emergency

05000249/2011-004-00 Ventilation Air Conditioning System Inoperability (4OA3.6)

NRC Temporary TI Managing Gas Accumulation in Emergency Core Cooling,

Attachment

Instruction 2515/177 Decay Heat Removal, and Containment Spray Systems

(NRC GL 2008-01) (4OA5.1)

Discussed

05000237/2012010-01 NCV Failure of the 125 Vdc Generator Rectifier Set (1R22)05000249/2012010-01

05000237/2011005-01 NCV Bus 23 Pot Fuse Drawer Resulting in the Inoperability of

the Control Room Emergency Ventilation Air Conditioning

System (Section 4OA3.6)

NRC Temporary TI Review of the Industry Initiative to Control Degradation of

Instruction 2515/182 Underground Piping and Tanks (4OA5.2)

Attachment

LIST OF DOCUMENTS REVIEWED

IR 05000237/2012002

Text

SUBJECT:

Dear Mr. Pacilio:

Enclosure:

SUMMARY OF FINDINGS

NRC-Identified

Cornerstone: Initiating Events

Cornerstone: Barrier Integrity

Cornerstone: Public Radiation Safety

Other Findings

Licensee-Identified Violations

REPORT DETAILS

Summary of Plant Status

REACTOR SAFETY

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Condition - High Wind Conditions

a. Inspection Scope

b. Findings

1R04 Equipment Alignment (71111.04Q & S)

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

b. Findings

.2 Semi Annual Complete System Walkdown

a. Inspection Scope

b. Findings

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

b. Findings

1R06 Flooding

.1 Internal Flooding

a. Inspection Scope

b. Findings

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

b. Findings

.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk

a. Inspection Scope

b. Findings

1R12 Maintenance Effectiveness

a. Inspection Scope

b. Findings

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

b. Findings

1R15 Operability Evaluations and Functional Assessments

a. Inspection Scope

b. Findings

Introduction:

Description:

1R18 Plant Modifications

a. Inspection Scope

b. Findings

1R19 Post-Maintenance Testing

a. Inspection Scope

b. Findings

1R22 Surveillance Testing

a. Inspection Scope

b. Findings

1EP2 Alert and Notification System Evaluation

a. Inspection Scope

b. Findings

1EP3 Emergency Response Organization Augmentation Testing

a. Inspection Scope

b. Findings

1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies

a. Inspection Scope

b. Findings

1EP6 Drill Evaluation

.1 Training Observation

a. Inspection Scope

b. Findings

RADIATION SAFETY

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

.1 Inspection Planning (02.01)

a. Inspection Scope

b. Findings

.2 Engineering Controls (02.02)