IR 05000255/2016003

NRC Integrated Inspection Report 05000255/2016003

ML16319A056
Person / Time
Site:	Palisades
Issue date:	11/10/2016
From:	Eric Duncan Region 3 Branch 3
To:	Arnone C Entergy Nuclear Operations
References
IR 2016003
Download: ML16319A056 (53)

Text

November 10, 2016

SUBJECT:

PALISADES NUCLEAR PLANTNRC INTEGRATED INSPECTION REPORT 05000255/2016003

Dear Mr. Arnone:

On September 30, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant. On October 19, 2016, the NRC inspectors discussed the results of this inspection with yourself and other members of your staff. The enclosed report documents the results of this inspection.

Based on the results of this inspection, the NRC has identified one issue that was evaluated under the risk significance determination process as having very low safety significance (Green). The NRC has also determined that a violation is associated with this issue. Because a condition report was generated to address the issue, the violation is being treated as a Non-Cited Violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy. The NCV is described in the subject inspection report.

If you contest the violation or significance of the NCV, 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: (1) the Regional Administrator, Region III; (2) the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and (3) the NRC Resident Inspector at the Palisades Nuclear Plant.

In addition, if you disagree with the cross-cutting aspect assigned to any finding 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 Palisades Nuclear Plant. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, 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 NRCs Public Document Room or from the Publicly Available Records System component of the NRC's Agencywide Documents 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/

Eric Duncan, Chief Branch 3 Division of Reactor Projects

Docket No. 50-255 License No. DPR-20

Enclosure:

Inspection Report 05000255/2016003

REGION III==

Docket No:

50-255 License No:

DPR-20 Report No:

05000255/2016003 Licensee:

Entergy Nuclear Operations, Inc.

Facility:

Palisades Nuclear Plant Location:

Covert, MI Dates:

July 1 through September 30, 2016 Inspectors:

A. Nguyen, Senior Resident Inspector

J. Boettcher, Resident Inspector

B. Bartlett, Project Engineer

J. Ellegood, Senior Resident Inspector, D.C. Cook

R. Elliott, Resident Inspector, Dresden Nuclear Station

V. Myers, Senior Health Physicist

D. Sargis, Reactor Engineer

Approved by:

E. Duncan, Chief Branch 3 Division of Reactor Projects

SUMMARY

Inspection Report (IR) 05000255/2016003; 07/01/2016 - 09/30/2016; Palisades Nuclear Plant;

Maintenance Risk Assessments and Emergent Work Control This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. One Green finding was identified by the inspectors.

This finding involved a Non-Cited Violation (NCV) of U.S. Nuclear Regulatory Commission (NRC) requirements. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," dated April 29, 2015.

Cross-cutting aspects are determined using IMC 0310, "Aspects Within the Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6, dated July 2016.

Cornerstone: Mitigating Systems

Green.

A self-revealed finding of very low safety significance and an associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations, Part 50,

Appendix B, Criterion III, Design Control, was identified for the failure to appropriately select and review for suitability of application the control switch and circuit design of the engineered safeguards room cooler fans. Specifically, on July 27, 2016, when the licensee was conducting troubleshooting activities for the tripping of engineered safeguards room cooler fan V-27B, it was revealed that the control switch design was break before make and as the hand switch was transitioned from one position to the next, the supply voltage and the motor became out of phase and caused an overcurrent trip of the breaker. This resulted in an unplanned entry into a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> limiting condition for operation (LCO) for the right train of the emergency core cooling system (ECCS). In the apparent cause evaluation (ACE) for this issue, the licensee determined that the contributing cause had not previously addressed this particular failure mode (i.e. the control switch and circuit design) when similar overcurrent events occurred in the past. Prior corrective actions included adding guidance to system operating procedures to pause between hand switch movements and replacing other components within those systems. These actions were not successful in eliminating this failure mode. The licensee documented the issue in their CAP, planned to revise the control circuit and switch design, and added specific procedural steps on how to operate these fans until the design change was implemented.

The finding was more than minor in accordance with IMC 0612, Appendix B, because it was associated with the Mitigating Systems Cornerstone attribute of Equipment Reliability and adversely impacted the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, as a result of the overcurrent trip of its breaker,

V-27B was declared non-functional and unavailable and the equipment in the room it cooled was declared inoperable, which included the A high pressure safety injection (HPSI) pump and the A containment spray (CS) pump. This led to an unplanned entry into a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO for the right train of ECCS. The finding had a cross-cutting aspect in the area of Problem Identification and Resolution and was related to the cross-cutting component of Evaluation, which required that the licensee thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. As discussed above, in the ACE for this issue the licensee determined that the corrective actions associated with the identified contributing cause following similar overcurrent events that occurred in the past had not addressed or been successful in eliminating this failure mode [PI.2]. (Section 1R13.1)

REPORT DETAILS

Summary of Plant Status

The plant began the assessment period operating at full power. The unit operated at or near full power for the entire inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

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

• A charging system train;

• B auxiliary feedwater (AFW) train; and

• B low pressure safety injection (LPSI) train.

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, the Updated Final Safety Analysis Report (UFSAR), Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports (CRs), 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 Inspection procedure (IP) 71111.04-05.

b. Findings

No findings were identified.

.2 Semi-Annual Complete System Walkdown

a. Inspection Scope

On July 11 through 13, 2016, the inspectors performed a complete system alignment inspection of the service water system to verify the functional capability of that 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 lineups; electrical power availability; system pressure and temperature indications, as appropriate; component labeling; component lubrication; component and equipment cooling; hangers and supports; support system operability; 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 systems functions. 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

.1 Routine Resident Inspector Tours

a. Inspection Scope

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

• Fire Areas 1 & 33: control room and technical support center, elevation 625';

• Fire Areas 29, 30, and 31: mechanical equipment rooms, elevations 629 & 639;

• Fire Areas 21 and 26: electrical equipment room and southwest cable penetration room, elevation 607;

• Fire hose stations in the turbine and auxiliary buildings;

• Fire protection post-indicator valves inside and outside plant buildings; and

• Fire Area 13B: charging pump rooms, elevation 590.

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 issues identified during the inspection were entered into the licensees CAP.

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

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

On September 8, 2016, and September 15, 2016, the inspectors observed a fire brigade activation drill for a fire in a switchyard transformer. Based on these observations, the inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies, openly discussed them in a self-critical manner, and took appropriate corrective actions. Specific attributes evaluated included the following:

• proper wearing of turnout gear and self-contained breathing apparatus;

• proper use and layout of fire hoses;

• employment of appropriate firefighting techniques;

• sufficient firefighting equipment brought to the scene;

• effectiveness of fire brigade leader communications, command, and control;

• search for victims and propagation of the fire into other plant areas;

• smoke removal operations; and

• utilization of pre-planned strategies.

Documents reviewed are listed in the Attachment to this report.

These activities constituted one annual fire protection inspection sample as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R06 Flooding

.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 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 performed a walkdown of the following plant areas to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:

• east and west engineered safeguards rooms (zones 1 and 2).

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.

In addition, the inspectors did not identify a history of cable degradation or failure due to submergence at the site. As a result and as provided for in IP 71111.06-05, an underground vaults inspection sample was not performed.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

On September 30, 2016, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training. The inspectors verified that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and that training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• licensed operator performance;

• the 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

• the crews 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 simulator sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Observation During Periods of Heightened Activity or Risk

(71111.11Q)

a. Inspection Scope

On August 16, 2016, the inspectors observed activities in the main control room during a downpower and AFW pump testing. This was an activity that required heightened awareness and was related to increased risk. The inspectors evaluated the following areas:

• licensed operator performance;

• the 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 procedures;

• control board manipulations; and

• oversight and direction from supervisors.

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

.1 Routine Quarterly Evaluations

a. Inspection Scope

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

• diesel driven fire pump, P-41.

The inspectors reviewed events including those where ineffective equipment maintenance had resulted in valid or invalid automatic actuations 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 Title 10 of the Code of Federal Regulations (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 one quarterly maintenance effectiveness sample as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 Maintenance Risk Assessments and Emergent Work Control

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:

• emergent work on V-24A and V-24B, 1-1 diesel generator (DG) ventilation fans, temperature switches concurrent with intermittent 2400V ground alarm troubleshooting;

• troubleshooting for slow start time of 1-2 DG B air start motor concurrent with failure of the right train DG load sequencer design basis accident (DBA)/normal shutdown (NSD) processor in the control room;

• unplanned inoperability of A high pressure safety injection (HPSI) and A containment spray (CS) pumps due to the east engineered safeguards room cooler, V-27B, breaker tripping;

• emergent, risk significant troubleshooting for CV-0780, B steam generator atmospheric steam dump valve, leakage; and

• planned risk-significant work to perform preventive maintenance on the 1-2 DG, conduct the quarterly surveillance test of the C service water pump, perform a high risk diving evolution, and conduct ISFSI dry runs on September 19-20, 2016.

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 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. Documents reviewed during this inspection are listed in the Attachment to this report.

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

b. Findings

Introduction:

A self-revealed finding of very low safety significance (Green) and an associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion III, Design Control, was identified for the failure to appropriately select and review for suitability of application the control switch and circuit design of the engineered safeguards room cooler fans. Specifically, on July 27, 2016, when the licensee was conducting troubleshooting activities for V-27B, engineered safeguards room cooler fan, tripping, it was revealed that the control switch design was break before make and as the hand switch was transitioned from one position to the next, the supply voltage and the motor became out of phase, and caused an overcurrent trip of the breaker. This resulted in an unplanned entry into a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> limiting condition for operation (LCO) for the right train of the emergency core cooling system (ECCS).

Description:

On July 27, 2016, operators were attempting to secure the motor for V-27B, the engineered safeguards room cooler fan, by moving the hand switch from the auto position to the push to lock position. Per the guidance in the system operating procedure, the operator paused in between each hand position while moving the hand switch. While transitioning through these positions, the operator noticed that the indicating lights were not lit on the hand switch and the breaker was later found to be tripped. This resulted in V-27B being declared non-functional and unavailable and the equipment in the room it cooled being declared inoperable, which included the A HPSI pump and the A CS pump.

Troubleshooting revealed the supply breaker for V-27B tripped on overcurrent with no other issues identified after inspecting the breaker. Plant internal operating experience suggested a potential issue with the control switch for the fan motor, so the engineers then conducted troubleshooting on a spare, identical model control switch from the warehouse. This troubleshooting revealed that the control switch design was break before make, which meant that as the hand switch was moved through the various switch positions, the circuit was designed to break one connection before making up another connection. If the control circuit was signaling the fan to run in both positions, the voltage to the motor will transition from on, to off, and back to on again. Normally, the supply voltage and the motor position are in phase. As the hand switch is transitioned from one position to the next, the supply voltage and the motor can become out of phase and if that deviation is large enough, a current transient can occur.

After validating no physical issues with the fan, motor, or breaker, the licensee restarted the fan and it operated appropriately. The licensee determined this issue to be a repeat maintenance rule functional failure; the same control switch design issue caused maintenance rule functional failures of 1-1 and 1-2 DG ventilation fans earlier in 2016 and in 2014. The licensee conducted an ACE which determined the cause to be the design of the control switch being break before make, leading to the supply voltage and motor voltage being out of phase, and causing the overcurrent condition. A contributing cause identified to be associated with this issue was that this particular failure mode, the control switch and circuit design, had not been previously addressed when similar overcurrent events occurred on this and other fans with the same switch design in the past. Prior corrective actions included adding guidance to system operating procedures to pause between hand switch movements and replacing other components within those systems. These actions were not successful in eliminating this failure mode. New planned corrective actions included remediation of the control circuit and switch design and the addition of specific, procedural steps on how to operate these fans until the design change was implemented.

Analysis:

The inspectors determined that the failure to appropriately select and review for suitability of application the control switch and circuit design of the engineered safeguards room cooler fans was a performance deficiency that warranted a significance determination.

The inspectors determined that the finding was more than minor in accordance with Inspection Manual Chapter (IMC) 0612, "Power Reactor Inspection Reports,"

Appendix B, "Issue Screening," dated September 7, 2012, because it affected the Mitigating Systems Cornerstone attribute of Equipment Reliability and adversely impacted the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, as a result of the overcurrent trip of its breaker, V-27B was declared non-functional and unavailable and the equipment in the room it cooled was declared inoperable, which included the A HPSI pump and the A CS pump. This led to an unplanned entry into a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO for the right train of ECCS. Utilizing IMC 0609, Appendix A, Exhibit 2, effective July 1, 2012, the finding screened as Green by answering No to the Mitigating SSCs and Functionality questions related to the finding representing an actual loss of function of at least a single train for greater than its TS allowed outage time or an actual loss of function of one or more non-TS, maintenance rule high safety-significant trains for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The finding had a cross-cutting aspect in the area of Problem Identification and Resolution related to the cross-cutting component of Evaluation, which required that the licensee thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. In the apparent cause evaluation for this issue, the licensee determined that the contributing cause had not previously addressed this particular failure mode (i.e. the control switch and circuit design) when similar overcurrent events occurred in the past. Prior corrective actions included adding guidance to system operating procedures to pause between hand switch movements and replacing other components within those systems. These actions were not successful in eliminating this failure mode [PI.2].

Enforcement:

10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of structures, systems, and components.

Contrary to the above, on July 27, 2016, it was discovered that the licensee failed to select and review for suitability the control switch for the safeguards room cooler fan V-27B as required by 10 CFR 50, Appendix B, Criterion III, Design Control.

Specifically, while conducting troubleshooting activities for V-27B, engineered safeguards room cooler fan, tripping, it was revealed that the control switch design was break before make and as the hand switch was transitioned from one position to the next, the supply voltage and the motor became out of phase, and caused an overcurrent trip of the breaker. This resulted in V-27B being declared non-functional and the equipment in the room it cooled being declared inoperable, which included the A HPSI pump and the A CS pump, which resulted in an unplanned entry into a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO for the right train of the ECCS.

The licensee documented this issue in condition report CR-PLP-2016-03456, Unavailability of V-27B East Engineered Safeguards Room Cooling Fan Resulting in an LCO Action Statement Entry, and performed an equipment apparent cause evaluation. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very low safety significance and was entered into the licensees CAP. Corrective actions included remediation of the control circuit and switch design and specific, procedural steps on how to operate these fans until the design change was implemented. (NCV 05000255/2016003-01, Failure to Appropriately Select and Review for Suitability of Application the Control Switch and Circuit Design of the Engineered Safeguards Room Cooler Fans)

1R15 Operability Determinations and Functional Assessments

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• elevated seal temperature for control rod drive 13;

• cracks identified on the lids of the safety-related, main station batteries;

• past operability evaluation for issues identified on the left train control room heating and ventilation system (CRHVAC);

• loose bolts identified on both DG exhaust hangers; and

• continued service life of the 1-2 DG jacket water cooler after tube plugging.

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 TSs 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 sample 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

No findings were identified.

.2 Review of Operator Workarounds

a. Inspection Scope

Operator workarounds are operator actions taken to compensate for degraded or non-conforming conditions. Operator workarounds that cannot be implemented effectively can contribute to an increase in overall plant risk. The inspectors verified that the licensee was identifying operator workarounds at an appropriate threshold, entering them into their CAP, and had planned or taken appropriate corrective actions. As part of their review, the inspectors considered all existing plant conditions and the cumulative impact of all operator workarounds.

The inspectors evaluated the licensee's operator workarounds to determine if any mitigating system functions were adversely impacted. Additionally, the inspectors assessed whether the operator workarounds had adversely impacted the operators ability to implement abnormal or emergency operating procedures. The inspectors placed particular emphasis on any operator workarounds that had not been evaluated by the licensee; that had been formalized or proceduralized as the long-term corrective actions for a degraded or nonconforming condition; and that may have increased the potential for human error, such as operator workarounds that:

• required operations that were not consistent with current training and system knowledge;

• required a change from long-standing operational practices;

• required operation of a system or component in a manner that was inconsistent with similar systems or components;

• created the potential for the compensatory action to be performed on equipment or under conditions for which it was not appropriate;

• impaired access to required indications, increased dependence on verbal communications, or impacted the timeliness of time-critical event mitigating actions under adverse environmental conditions;

• required the use of equipment and interfaces that had not been designed with consideration of the task being performed;

• required the licensee to assess and manage an increase in risk; or

• required a license amendment in accordance with 10 CFR 50.59, but were implemented without an approved amendment.

Documents reviewed are listed in the Attachment to this report.

These activities by the inspectors constituted a single operator workarounds review inspection sample as required by IP 71111.15, Section 02.01(a).

b. Findings

No findings were identified.

1R18 Plant Modifications

.1 Plant Modifications

a. Inspection Scope

The inspectors reviewed the following modification:

• temporary shielding on charging pump piping and components.

The inspectors reviewed the configuration changes and associated 10 CFR 50.59 and 72.48 safety evaluation screenings against the design basis, the UFSAR, and the TSs, as applicable, to verify that the modification did not affect the operability or availability of the affected systems. The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modification was installed as directed and consistent with the design control documents; the modification operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modification 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 are listed in the Attachment to this report.

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

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

.1 Post-Maintenance Testing

a. Inspection Scope

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

• system operating test of P-55C, C charging pump, following preventative maintenance activities;

• surveillance test of C-2B, B instrument air compressor, following valve and relay replacements;

• diagnostic testing and stroke timing of CV-3025, shutdown cooling heat exchanger discharge valve, after valve operator replacement;

• partial safety injection actuation system surveillance test after replacement of the right channel DG load sequencer DBA/NSD processor;

• system operating test and non-destructive examination of new welds on P-55B, B charging pump, discharge manifold flush line; and

• surveillance testing of 1-2 DG following air system and jacket water cooler maintenance.

These activities were selected based upon the SSCs 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 six post-maintenance testing samples as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

.1 Surveillance Testing

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:

• RI-3C, 'C' channel pressurizer pressure calibration (routine);

• QO-21B, B AFW pump surveillance test (inservice test);

• MO-7A-2, 1-2 DG surveillance test (routine);

• QI-5, containment high pressure test (routine); and

• primary coolant system leakrate surveillance (reactor coolant system leak detection).

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, demonstrate operational readiness, and consistent with the system design basis;

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

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

• was measuring and test equipment calibration current;

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

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

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

• was test equipment removed after testing;

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

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

• where applicable for safety-related instrument control surveillance tests, were reference setting data accurately incorporated in the test procedure;

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

• had prior procedure changes provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

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

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

Documents reviewed are listed in the Attachment to this report.

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

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

.1 Engineering Controls

a. Inspection Scope

The inspectors reviewed procedural guidance for use of ventilation systems, and assessed whether the systems were used, to the extent practicable, during high-risk activities to control airborne radioactivity and minimize the use of respiratory protection. The inspectors assessed whether installed ventilation airflow capacity, flow path, and filter/charcoal unit efficiencies for selected systems were consistent with maintaining concentrations of airborne radioactivity in work areas below the concentrations of an airborne area to the extent practicable. The inspectors also evaluated whether selected temporary ventilation systems used to support work in contaminated areas were consistent with licensee procedural guidance and as-low-as-reasonably-achievable (ALARA).

The inspectors reviewed select airborne monitoring protocols to assess whether alarms and set points were sufficient to prompt worker action. The inspectors assessed whether the licensee established trigger points for evaluating levels of airborne beta-emitting and alpha-emitting radionuclides.

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

b. Findings

No findings were identified.

.2 Use of Respiratory Protection Devices

a. Inspection Scope

The inspectors assessed whether the licensee provided respiratory protection devices for those situations where it was impractical to employ engineering controls such that occupational doses were ALARA. For select instances where respiratory protection devices were used, the inspectors assessed whether the licensee concluded that further engineering controls were not practical. The inspectors also assessed whether the licensee had established a means to verify that the level of protection provided by the respiratory protection devices was at least as good as that assumed in the work controls and dose assessment.

The inspectors assessed whether the 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 (NIOSH/MSHA) or had been approved by the NRC. The inspectors evaluated whether the devices were used consistent with their NIOSH/MSHA certification or any conditions of their NRC approval.

The inspectors reviewed records of air testing for supplied-air devices and self-contained breathing apparatus (SCBA) bottles to assess whether the air used met or exceeded Grade D quality. The inspectors evaluated whether plant breathing air supply systems satisfied the minimum pressure and airflow requirements for the devices.

The inspectors evaluated whether selected individuals qualified to use respiratory protection devices had been deemed fit to use the devices by a physician.

The inspectors reviewed training curricula for use of respiratory protection devices to assess whether individuals are adequately trained on donning, doffing, function checks, and how to respond to a malfunction.

The inspectors observed the physical condition of respiratory protection devices ready for issuance and reviewed records of routine inspection for selected devices. The inspectors reviewed records of maintenance on the vital components for selected devices and assessed whether on-site personnel assigned to repair vital components received vendor-provided training.

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

b. Findings

No findings were identified.

.3 Self-Contained Breathing Apparatus for Emergency Use

a. Inspection Scope

The inspectors reviewed the status and surveillance records for select SCBAs.

The inspectors evaluated the licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions.

The inspectors assessed whether control room operators and other emergency response and radiation protection personnel were trained and qualified in the use of SCBAs and evaluated whether personnel assigned to refill bottles were trained and qualified for that task.

The inspectors assessed whether appropriate mask sizes and types were available for use. The inspectors evaluated whether on-shift operators had no facial hair that would interfere with the sealing of the mask and that appropriate vision correction was available.

The inspectors reviewed the past two years of maintenance records for selected in-service SCBA units used to support operator activities during accident conditions.

The inspectors assessed whether maintenance or repairs on an SCBA units vital components were performed by an individual certified by the manufacturer of the device to perform the work. The inspectors evaluated the on-site maintenance procedures governing vital component work to determine whether there was any inconsistencies with the SCBA manufacturers recommended practices. The inspectors evaluated whether SCBA cylinders satisfied the hydrostatic testing required by the U.S. Department of Transportation.

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

b. Findings

No findings were identified.

.4 Problem Identification and Resolution

a. Inspection Scope

The inspectors assessed 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. Additionally, the inspectors evaluated the appropriateness of the corrective actions for selected problems involving airborne radioactivity documented by the licensee.

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

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

.1 Source Term Characterization

a. Inspection Scope

The inspectors evaluated whether the licensee had characterized the radiation types and energies being monitored and that the characterization included gamma, beta, hard-to-detects, and neutron radiation.

The inspectors assessed whether the licensee had developed scaling factors for including hard-to-detect nuclide activity in internal dose assessments.

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

b. Findings

No findings were identified.

.2 External Dosimetry

a. Inspection Scope

The inspectors evaluated whether the licensees dosimetry vendor was National Voluntary Laboratory Accreditation Program accredited and if the approved irradiation test categories for each type of personnel dosimeter used were consistent with the types and energies of the radiation present and the way the dosimeter was being used.

The inspectors evaluated the on-site storage of dosimeters before their issuance, during use, and before processing/reading. For personal dosimeters stored on-site during the monitoring period, the inspectors evaluated whether they were stored in low dose areas with control dosimeters. For personal dosimeters that were taken off-site during the monitoring period, the inspectors evaluated the guidance provided to individuals with respect to the care and storage of the dosimeter.

The inspectors evaluated the calibration of active dosimeters. The inspectors assessed the bias of the active dosimeters compared to passive dosimeters and the correction factor used. The inspectors also assessed the licensees program for comparing active and passive dosimeter results, investigations for substantial differences, and recording of dose. The inspectors assessed whether there were adverse trends for active dosimeters.

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

b. Findings

No findings were identified.

.3 Internal Dosimetry

a. Inspection Scope

The inspectors reviewed procedures used to assess internal dose using whole body counting equipment to evaluate 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 assessed whether 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 portal radiation monitors as a passive monitoring system to determine if instrument minimum detectable activities were adequate to detect internally deposited radionuclides sufficient to prompt additional investigation. The inspectors reviewed whole body counts and evaluated the equipment sensitivity, nuclide library, review of results, and incorporation of hard-to-detect radionuclides.

The inspectors reviewed procedures used to determine internal dose using in-vitro analysis to assess the adequacy of sample collection, determination of entry route and assignment of dose.

The inspectors reviewed the licensee's program for dose assessment based on air sampling, as applicable, and calculations of derived air concentration. The inspectors determined whether flow rates and collection times for air sampling equipment were adequate to allow lower limits of detection to be obtained. The inspectors also reviewed the adequacy of procedural guidance to assess internal dose if respiratory protection was used.

The inspectors reviewed select internal dose assessments and evaluated the monitoring protocols, equipment, and data analysis.

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

b. Findings

No findings were identified.

.4 Special Dosimetric Situations

a. Inspection Scope

The inspectors assessed whether the licensee informs workers of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for declaring a pregnancy. The inspectors selected individuals who had declared a pregnancy during the current assessment period and evaluated whether the monitoring program for declared pregnant workers was technically adequate to assess the dose to the embryo/fetus. The inspectors assessed results and/or monitoring controls for compliance with regulatory requirements.

The inspectors reviewed the licensee's methodology for monitoring external dose in non-uniform radiation fields or where large dose gradients exist. The inspectors evaluated the licensee's criteria for determining when alternate monitoring was to be implemented. The inspectors reviewed dose assessments performed using multi-badging to evaluate whether the assessment was performed consistently with licensee procedures and dosimetric standards.

The inspectors evaluated the licensees methods for calculating shallow dose equivalent from distributed skin contamination or discrete radioactive particles. The inspectors reviewed select shallow dose equivalent dose assessments for adequacy.

The inspectors evaluated the licensees program for neutron dosimetry, including dosimeter types and/or survey instrumentation. The inspectors reviewed select neutron exposure situations and assessed whether dosimetry and/or instrumentation was appropriate for the expected neutron spectra, there was sufficient sensitivity, and neutron dosimetry was properly calibrated. The inspectors also assessed whether interference by gamma radiation had been accounted for in the calibration and whether time and motion evaluations were representative of actual neutron exposure events.

For the special dosimetric situations reviewed in this section, the inspectors assessed how the licensee assigns dose of record. This included an assessment of external and internal monitoring results, supplementary information on individual exposures, and radiation surveys and/or air monitoring results when dosimetry was based on these techniques.

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

b. Findings

No findings were identified.

.5 Problem Identification and Resolution

a. Inspection Scope

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

These inspection activities constituted one complete sample as defined in I P 71124.04-05.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance IndexHigh Pressure Injection Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI) - High Pressure Injection Systems (MS07) Performance Indicator (PI) for the period from the third quarter 2015 through the second quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, CRs, MSPI derivation reports, event reports and NRC Integrated Inspection Reports (IRs) for the period of July 1, 2015, through June 30, 2016, to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, whether the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees CR database to determine if any problems had been identified with the PI data collected or transmitted for this indicator. Documents reviewed are listed in the to this report.

This inspection constituted one MSPI - High Pressure Injection System sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance IndexResidual Heat Removal System

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - Residual Heat Removal System (MS09) PI for the period from the third quarter 2015 through the second quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, CRs, MSPI derivation reports, event reports and NRC IRs for the period of July 1, 2015, to June 30, 2016, to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, whether the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees CR database to determine if any problems had been identified with the PI data collected or transmitted for this indicator. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one MSPI - Residual Heat Removal System sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Reactor Coolant System Leakage

a. Inspection Scope

The inspectors sampled licensee submittals for the reactor coolant system leakage PI for the period from the third quarter 2015 through the second quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator logs, reactor coolant system leakage tracking data, CRs, event reports and NRC IRs for the period of July 1, 2015 to June 30, 2016 to validate the accuracy of the submittals. The inspectors also reviewed the licensees CR database to determine if any problems had been identified with the PI data collected or transmitted for this indicator.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted one reactor coolant system leakage sample as defined in IP 71151-05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.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 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 Annual Follow-up of Selected Issues:

Inadequate Documentation and Controls for Measuring and Test Equipment

a. Inspection Scope

During a review of items entered in the licensees CAP, the inspectors reviewed a corrective action item documenting a quality assurance finding identified by the licensees Nuclear Independent Oversight (NIOS) group. The licensee identified that they had not adequately implemented controls to ensure that the measuring and test equipment (M&TE) program met the requirements for calibration, storage, and traceability. Specifically, it was identified that environmental conditions were not monitored, or in some cases controlled, in M&TE storage and calibration areas.

Additionally, it was identified that documentation of M&TE deviations from calibration standards and the review and approval of vendor-calibrated equipment did not meet the requirements of procedure EN-MA-105, Control of M&TE.

The inspectors reviewed CAP documents to verify the complete, accurate, and timely documentation of the identified problem. The inspectors reviewed the apparent cause evaluation (ACE) for identification of the apparent cause of the problem and corrective actions that were appropriately focused to correct the problem. The licensee determined that the apparent cause was that the guidance given in procedure EN-MA-105 was not clear. Corrective actions included purchasing monitoring equipment for M&TE calibration and storage locations and implementation of a monitoring process for each of the M&TE locations. The licensee was also evaluating changes to EN-MA-105 to clarify requirements. The inspectors concluded, based on the ACE and interviews with licensee staff, that the corrective actions associated with the above issues were timely and appropriately focused to correct the problem.

Documents reviewed are listed in the Attachment to this report.

This review constituted one in-depth problem identification and resolution sample as defined in IP 71152-05.

b. Findings

No findings were identified.

.4 Annual Follow-up of Selected Issues:

Fire Tours

a. Inspection Scope

On May 24 and 25, 2016, while the inspectors were observing a maintenance activity on a service water pump in the screenhouse, they noted that hourly fire tours were not being conducted consistently by security personnel. Plant room badging records and the paper hourly fire tour daily log sheets were requested from the licensee for the fire tours completed. The inspectors identified that some areas on the fire tour log sheets were annotated as complete, yet there were no corresponding badge records for these areas. A small extent of condition review was conducted by the inspectors and the identified discrepancies were discussed with the licensee.

The licensee entered this issue into the CAP as CR-PLP-2016-2650, A Review of Fire Tours Reported as Completed by Security Personnel has Found Discrepancies in What was Reported. The licensee promptly began an extent of condition review of the applicable records. The condition report was appropriately characterized as significance level A, which included conducting a root cause evaluation and and formulating corrective actions to prevent recurrence. The inspectors reviewed the licensees immediate interim corrective actions to ensure the issue did not occur while the evaluation was being conducted and determined they were appropriate until further, permanent corrective actions could be implemented.

Documents reviewed are listed in the Attachment to this report.

This review constituted one in-depth problem identification and resolution sample as defined in IP 71152-05.

b. Findings

(Open) Unresolved Item: Hourly Fire Tour Discrepancies

Introduction:

The inspectors identified an unresolved item (URI) related to discrepancies found during fire tour daily log sheet and corresponding badge record reviews.

Specifically, the NRC is in the process of reviewing the licensees evaluation of the root and contributing causes of the issue, as well as the corrective actions to prevent recurrence. Also, the NRC will verify that the licensees actions taken to address the issue are sustainable.

Description:

On May 24 and 25, 2016, while the inspectors were observing a maintenance activity on a service water pump in the screenhouse, they noted that hourly fire tours were not being conducted consistently by security personnel. The inspectors requested plant room badging records and copies of the hourly fire tour daily log sheets from the licensee for hourly fire tours completed on May 24 and 25, 2016. The inspectors identified that some areas on the fire tour log sheets were annotated as complete, yet there were no corresponding badge records for these areas. The inspectors requested additional fire tour daily log sheets and badge records for May 31 and June 1, 2016 for an extent of condition review. Additional issues were identified with the fire tour log sheets not corresponding with badge records for certain plant areas required to be covered by the hourly fire tours.

On June 8, 2016, the inspectors discussed these discrepancies with the licensee. The licensee entered this issue into the CAP and promptly began an extent of condition review of the fire tour daily log sheets and plant room badging records for the period of March 1, 2016 through June 8, 2016. The condition report included actions to conduct a root cause evaluation to determine the root and contributing causes of the discrepancies identified in the fire tour and badging records and formulating corrective actions to prevent recurrence. The licensees immediate interim corrective actions included direct supervisor observation of all hourly fire tours being conducted, newly formatted fire tour log sheets with additional detail added, and re-training of personnel conducting the tours on the requirements and expectations for completion of the activity. Pending NRC review of the licensees evaluation of the issue, subsequent corrective actions to prevent recurrence, and verification that the actions are sustainable, this issue is unresolved.

(URI 050000255/2016003-02, Hourly Fire Tour Discrepancies)

4OA5 Other Activities

.1 Spent Fuel Pool Safety at Operating Reactors

a. Inspection Scope

The inspectors evaluated spent fuel pool safety to verify the design, operation and administrative measures in place assured safety of the spent fuel pool during normal and accident conditions. The inspection evaluated the following areas:

• spent fuel pool inventory control for

- normal inventory control;

- emergency make up;

- spent fuel pool leaks;

- level monitoring; and

- cooling system walk down.

• criticality controls

- criticality analysis of record;

- spent fuel pool loading per technical specifications; and

- fixed poison monitoring.

• chemistry and cleanliness

- chemistry results; and

- water clarity.

• control of heavy loads

- spent fuel pool crane maintenance records;

- spent fuel pool crane daily checks; and

- walkdown of the spent fuel pool crane.

During the conduct of the inspections, the inspectors performed walkdowns of the spent fuel pool floor and spent fuel pool heat exchanger room, reviewed records as listed in the attachment, and conducted interviews with plant personnel.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted the completion of one spent fuel pool safety at operating reactors inspection as defined in IP 60715.

b. Findings

No findings were identified.

4OA6 Management Meetings

Exit Meeting Summary

On October 19, 2016, the inspectors presented the inspection results to Mr. C. Arnone, Site Vice President, 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.

.2 Interim Exit Meetings

Interim exits were conducted for:

• The inspection results for the Radiation Safety Program review with Mr. D. Nestle, Radiation Protection Manager, and other members of the licensee staff on August 19, 2016.

• The inspection results for the Spent Fuel Pool Safety at Operating Reactors inspection procedure with Mr. A. Williams, General Manager of Plant Operations, and other members of the licensee staff on September 15, 2016.

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

C. Arnone, Site Vice President

A. Williams, General Manager Plant Operations

T. Mulford, Operations Manager

B. Baker, Operations Manager - Shift

J. Borah, Engineering Manager, Systems and Components

R. Craven, Production Manager

T. Davis, Regulatory Assurance

B. Dotson, Regulatory Assurance

J. Erickson, Regulatory Assurance

O. Gustafson, Director of Regulatory and Performance Improvement

J. Hardy, Regulatory Assurance Manager

J. Haumersen, Site Projects and Maintenance Services Manager

G. Heisterman, Maintenance Manager

M. Lee, Operations Manager - Support

D. Lucy, Outage Manager

D. Malone, Emergency Planning Manager

W. Nelson, Training Manager

D. Nestle, Radiation Protection Manager

K. OConnor, Engineering Manager, Design and Programs

C. Plachta, Nuclear Independent Oversight Manager

P. Russell, Site Engineering Director

M. Schultheis, Performance Improvement Manager

M. Soja, Chemistry Manager

J. Tharp, Security Manager

U.S. Nuclear Regulatory Commission

E. Duncan, Chief, Reactor Projects, Branch 3

LIST OF ITEMS

Opened

05000255/2016003-01 NCV Failure to Appropriately Select and Review for Suitability of Application the Control Switch and Circuit Design of the Engineered Safeguards Room Cooler Fans (Section 1R13.1)

05000255/2016003-02 URI Hourly Fire Tour Discrepancies (Section 4OA2.4)

Closed

05000255/2016003-01 NCV Failure to Appropriately Select and Review for Suitability of Application the Control Switch and Circuit Design of the Engineered Safeguards Room Cooler Fans (Section 1R13.1)

Discussed

None