IR 05000261/2014005
| ML15028A121 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 01/28/2015 |
| From: | Hopper G NRC/RGN-II/DRP/RPB4 |
| To: | Glover R Duke Energy Corp |
| References | |
| IR 2014005 | |
| Download: ML15028A121 (26) | |
Text
UNITED STATES anuary 28, 2015
SUBJECT:
H. B. ROBINSON STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION REPORT 05000261/2014005
Dear Mr. Glover:
On December 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your H. B. Robinson Steam Electric Plant, Unit 2. On January 15, 2015, the NRC inspectors discussed the results of this inspection with members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented one NRC identified finding of very low safety significance (Green).
This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
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 Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II, the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at H. B. Robinson Steam Electric Plant, Unit 2.
In addition, if you disagree with the cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this report, with the basis for your disagreement, to the Regional Administrator, Region II, and the NRC Resident Inspector at H.B. Robinson. In accordance with Title 10 of the Code of Federal Regulations 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publically Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
George T. Hopper, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No.: 50-261 License No.: DPR-23
Enclosure:
IR 05000261/2014005 w/Attachment: Supplemental Information
REGION II==
Docket No: 50-261 License No: DPR-23 Report No: 005000261/2014005 Facility: H. B. Robinson Steam Electric Plant, Unit 2 Location: 3581 West Entrance Road Hartsville, SC 29550 Dates: October 1, 2014 through December 31, 2014 Inspectors: K. Ellis, Senior Resident Inspector C. Scott, Resident Inspector M. Riches, Resident Inspector (Acting)
J. Dodson, Senior Project Engineer, 1R01, 40A2 Approved by: George T. Hopper, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000261/2014005, October 1, 2014 through December 31, 2014; Duke Energy Progress,
Inc., H.B. Robinson Steam Electric Plant, Unit 2, Adverse Weather Protection.
The report covered a 3-month period of inspection by resident inspectors. There was one NRC-identified violation documented in this report. The significance of inspection findings are 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, (SDP)dated June 2, 2011. The 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 January 28, 2013. The NRCs program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green non-cited violation (NCV) of Technical Specification (TS) 5.4.1, for failure to establish procedural guidance to protect diesel driven equipment important to safety from the effects of extreme cold temperatures. Specifically, the licensees cold weather procedures failed to include actions to maintain fuel oil temperatures above the diesel fuel oil cloud point for the dedicated shutdown diesel generator (DSDG) and/or the engine driven fire pump (EDFP). The licensee entered this into the corrective action program (CAP) as AR 715032 and took immediate corrective actions to revise station procedures to protect the diesel driven equipment during periods of extreme low temperatures.
The failure to establish procedural guidance to protect diesel-driven equipment important to safety from the effects of extreme cold temperatures was a performance deficiency. This issue was more than minor because if left uncorrected this finding would have the potential to lead to a more significant safety concern. Specifically, failure to maintain the fuel oil temperatures for the DSDG and/or the EDFP greater than the measured cloud point, may impact the operation of the equipment during extreme low temperature conditions, due to the associated fuel oil transfer system becoming non-functional. A detailed risk assessment was performed by a regional Senior Reactor Analyst in accordance with NRC IMC 0609 Appendices A and F. The latest NRC Robinson SPAR risk model was used to quantify the internal events risk and a calculation was performed to estimate the fire risk. The major analysis assumptions included: both the EDFP and the DSDG were simultaneously considered unavailable without recovery for a 1-day exposure interval, DSDG fire scenarios were considered for the emergency switchgear room (ESWGR), the cable spreading room, and the main control room, where fire could cause a loss of offsite power and the emergency diesel generators (EDGs), compartment total ignition frequency data from the Robinson NFPA 805 project was used and a bounding Conditional Core Damage Probability for the fire scenarios of 1.0. The dominant sequence was a fire in the ESWGR which remained unsuppressed long enough to cause a loss of offsite power and the EDGs requiring use of alternate shutdown which failed due to the performance deficiency impact on the DSDG resulting in station blackout, and core damage due to an unmitigated reactor coolant pump seal loss of cooling accident. The risk was mitigated by the low likelihood of the initiators occurring during the specific cold weather vulnerability periods. The risk due to the performance deficiency was determined to be an increase in core damage frequency of
<1E-6/year, a GREEN finding of very low safety significance. The performance deficiency had a cross-cutting aspect of Evaluation in the area of Problem Identification and Resolution because the licensee failed to thoroughly evaluate the effects of cold weather on the fuel system for diesel driven equipment to ensure that resolutions address the extent of conditions commensurate with their safety significance (P.2).(Section 1R01)
REPORT DETAILS
Summary of Plant Status
The unit began the inspection period at 100 percent power. On October 29, 2014, power was reduced to 84 percent following a heater drain pump trip. The unit returned to 100 percent power on October 30, 2014. On October 31, 2014, power was reduced to 50 percent to perform turbine valve testing. The unit returned to 100 percent power on November 1, 2014, and remained there through the end of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
a. Inspection Scope
.1 Readiness to Cope with External Flooding
The inspectors evaluated the licensees implementation of flood protection procedures and compensatory measures during impending conditions of flooding or heavy rains.
The inspectors reviewed the updated final safety analysis report and related flood analysis documents to identify those areas containing safety related equipment that could be affected by external flooding and their design flood levels. The inspectors walked down flood protection barriers, reviewed procedures for coping with external flooding, and reviewed corrective actions for past flooding events. The inspectors verified that the procedures for coping with flooding could reasonably be used to achieve the desired results. For those areas where operator actions are credited, the inspectors assessed whether the flooding event could limit or preclude the required actions.
Documents reviewed are listed in the Attachment.
- The inspectors conducted a walkdown of the site boundary to assess the adequacy of the flood protection measures relied upon to mitigate the effects of external flooding.
.2 Seasonal Extreme Weather Conditions
The inspectors conducted a detailed review of the stations adverse weather procedures written for extreme low temperatures. The inspectors verified that weather-related equipment deficiencies identified during the previous year had been placed into the work control process and/or corrected before the onset of seasonal extremes. The inspectors evaluated the licensees implementation of adverse weather preparation procedures and compensatory measures before the onset of and during seasonal extreme weather conditions. Documents reviewed are listed in the Attachment. The inspectors evaluated the following risk-significant systems:
- Engine Driven Fire Pump
- Dedicated Shutdown Diesel Generator
b. Findings
Introduction:
The inspectors identified a Green non-cited violation (NCV) of Technical Specification (TS) 5.4.1, for failure to establish procedural guidance to protect diesel driven equipment important to safety from the effects of extreme cold temperatures.
Specifically, the licensees cold weather procedures failed to include actions to maintain fuel oil temperatures above the diesel fuel oil cloud point for the dedicated shutdown diesel generator (DSDG) and/or the engine driven fire pump (EDFP).
Description:
Licensee procedure OP-925, Cold Weather Operations, provided instructions for periodic compensatory measures to be taken during cold weather to ensure that important plant equipment is protected from the effects of extreme low temperatures. Procedure OP-925 failed to provide compensatory measures to protect the fuel oil storage tanks, transfer pumps and portions of the fuel lines of the DSDG and EDFP which are located above ground and outside. The cloud point for the associated fuel in these systems is approximately 10 degrees Fahrenheit. Since temperatures on site can be experienced far below the cloud point temperature the licensee determined that compensatory measures were required to ensure the functionality of the DSDG and EDFP during cold weather and initiated EC 97151 to protect the fuel lines. The licensee entered this issue in the CAP as AR 715032.
IR 05000261/2014002 documented an NRC-identified NCV after the licensee failed to ensure that the diesel fuel oil (DFO) temperature remained above the cloud point.
Similarly, the diesel fuel oil (DFO) storage tank, transfer pumps, and portions of the fuel lines to the EDGs were located above ground and outside and it was determined that the operation of the transfer pumps could be adversely affected during periods of cold weather which required the system to be protected. In response to this issue, the licensee failed to thoroughly evaluate the effects of cold weather on the fuel system for all diesel driven equipment, including the EDFP and DSDG, to ensure that the resolution addressed the extent of conditions commensurate with their safety significance.
Analysis:
The failure to establish procedural guidance to protect diesel-driven equipment important to safety from the effects of extreme cold temperatures was a performance deficiency. This issue was more than minor because if left uncorrected this finding would have the potential to lead to a more significant safety concern.
Specifically, failure to maintain the fuel oil temperatures for the DSDG and/or the EDFP greater than the measured cloud point, may impact the operation of the equipment during extreme low temperature conditions, due to the associated fuel oil transfer system becoming non-functional.
The EDFP and the DSDG each performed multiple safety functions all of which impacted the Mitigating Systems Cornerstone. The fire suppression function of the EDFP screened to GREEN per NRC IMC 0609 Appendix F phase 1 because the motor driven fire pump was available during the periods where temperature was less than the fuel oil cloud point. The remaining functions which consisted of: the external events fire safe shutdown (SSD) function for the DSDG and the internal events functions; SBO mitigation for the DSDG, charging pump backup cooling and auxiliary feedwater pump backup suction supply for the EDFP, were evaluated with a detailed risk assessment as the performance deficiency did not represent low degradation per NRC IMC 0609 Appendix F attachment 2 as it impacted a component required for SSD and affected the ability to reach and maintain stable conditions within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a potential fire event. A detailed risk assessment was performed by a regional Senior Reactor Analyst in accordance with NRC IMC 0609 Appendices A and F. The latest NRC Robinson SPAR risk model was used to quantify the internal events risk and a calculation was performed to estimate the fire risk. The major analysis assumptions included: both the EDFP and the DSDG were simultaneously considered unavailable without recovery for a 1 day exposure interval, DSDG fire scenarios were considered for the emergency switchgear room (ESWGR), the cable spreading room, and the main control room, where fire could cause a loss of offsite power and the emergency diesel generators (EDGs),compartment total ignition frequency data from the Robinson NFPA 805 project was used and a bounding Conditional Core Damage Probability for the fire scenarios of 1.0.
The dominant sequence was a fire in the ESWGR which remained unsuppressed long enough to cause a loss of offsite power and the EDGs requiring use of alternate shutdown which failed due to the performance deficiency impact on the DSDG resulting in station blackout, and core damage due to an unmitigated reactor coolant pump seal loss of cooling accident. The risk was mitigated by the low likelihood of the initiators occurring during the specific cold weather vulnerability periods. The risk due to the performance deficiency was determined to be an increase in core damage frequency of
<1E-6/year, a GREEN finding of very low safety significance.
The performance deficiency had a cross-cutting aspect of Evaluation in the area of Problem Identification and Resolution because the licensee failed to thoroughly evaluate the effects of cold weather on the fuel system for diesel driven equipment to ensure that resolutions address the extent of conditions commensurate with their safety significance (P.2).
Enforcement:
TS 5.4.1.a requires, in part, that written procedures be established, implemented, and maintained covering the activities specified in Appendix A, Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors, of Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements (Operations), Revision 2, dated February 1978. RG 1.33, Appendix A, Section 6, Procedures for Combating Emergencies and Other Significant Events, required procedures for acts of nature, including extreme low temperatures. The licensee relies upon OP-925, Cold Weather Operation, to protect plant equipment from extreme low temperatures.
Contrary to the above, prior to December 31, 2014, the licensee failed to establish a written procedure containing guidance to ensure that diesel driven equipment was protected against the effects of extreme low temperatures. Specifically, station procedures failed to include compensatory actions to keep fuel oil temperatures for the DSDG and/or the EDFP above the diesel fuel oil cloud point. The licensee took immediate corrective actions to revise station procedures to protect the diesel driven equipment during periods of extreme low temperatures. Because this violation was of very low safety significance (Green) and was entered into the corrective action program as AR 715032, this violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000261/2014005-01 Failure to Protect Diesel Driven Equipment from Effects of Extreme Cold Temperatures)
1R04 Equipment Alignment
a. Inspection Scope
Partial Walkdown The inspectors verified that critical portions of the selected systems were correctly aligned by performing partial walkdowns. The inspectors selected systems for assessment because they were a redundant or backup system or train, were important for mitigating risk for the current plant conditions, had been recently realigned, or were a single-train system. The inspectors determined the correct system lineup by reviewing plant procedures and drawings. Documents reviewed are listed in the Attachment.
The inspectors selected the following three systems or trains to inspect:
- Steam-driven Auxiliary Feedwater (AFW) Pump with the C AFW Pump Out of Service
- EDFP after extended maintenance outage
b. Findings
No findings were identified.
1R05 Fire Protection
a. Inspection Scope
Quarterly Inspection The inspectors evaluated the adequacy of selected fire plans by comparing the fire plans to the defined hazards and defense-in-depth features specified in the fire protection program. In evaluating the fire plans, the inspectors assessed the following items:
- control of transient combustibles and ignition sources
- fire detection systems
- water-based fire suppression systems
- gaseous fire suppression systems
- manual firefighting equipment and capability
- passive fire protection features
- compensatory measures and fire watches
- issues related to fire protection contained in the licensees CAP The inspectors toured the following four fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the
.
- Component Cooling Pump Room, fire zone 5
- Emergency Switchgear (E-1/E-2) Room, fire zone 20
- A Emergency Diesel Generator Room, fire zone 2
- Charging Pump Room, fire zone 4
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
.1 Internal Flooding
The inspectors reviewed related flood analysis documents and walked down the area listed below containing risk-significant structures, systems, and components susceptible to flooding. The inspectors verified that plant design features and plant procedures for flood mitigation were consistent with design requirements and internal flooding analysis assumptions. The inspectors also assessed the condition of flood protection barriers and drain systems. In addition, the inspectors verified the licensee was identifying and properly addressing issues using the corrective action program. Documents reviewed are listed in the Attachment.
- Emergency Switchgear (E-1/E-2) Room
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
a. Inspection Scope
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
The inspectors observed an evaluated simulator scenario administered to an operating crew conducted in accordance with the licensees accredited requalification training program. The scenario evaluated the operators ability to respond to a tube leak on the C steam generator, turbine trip due to a sudden break in the electric hydraulic control system and a faulted steam generator followed by a tube rupture.
The inspectors assessed the following:
- licensed operator performance
- the ability of the licensee to administer the scenario and evaluate the operators
- the quality of the post-scenario critique
- simulator performance Documents reviewed are listed in the Attachment.
.2 Resident Inspector Quarterly Review of Licensed Operator Performance
The inspectors observed licensed operator performance in the main control room during an emergent reduction in power to 84 percent following a heater drain pump trip. The inspectors also observed licensed operator performance in the main control room during a planned reduction in power to 50 percent for turbine valve testing.
The inspectors assessed the following:
- use of plant procedures
- control board manipulations
- communications between crew members
- use and interpretation of instruments, indications, and alarms
- use of human error prevention techniques
- documentation of activities
- management and supervision Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors assessed the licensees treatment of the two issues listed below to verify the licensee appropriately addressed equipment problems within the scope of the maintenance rule (10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants). The inspectors reviewed procedures and records to evaluate the licensees identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. The inspectors also interviewed system engineers and the maintenance rule coordinator to assess the accuracy of performance deficiencies and extent of condition.
Documents reviewed are listed in the Attachment.
- LT-108A Boric Acid Storage Tank (BAST) failed to 94 percent with corresponding level alarm
- C AFW Diesel Generator Tripped on Pump Start
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the three maintenance activities listed below to verify that the licensee assessed and managed plant risk as required by 10 CFR 50.65(a)(4) and licensee procedures. The inspectors assessed the adequacy of the licensees risk assessments and implementation of risk management actions. The inspectors also verified that the licensee was identifying and resolving problems with assessing and managing maintenance-related risk using the corrective action program. Additionally, for maintenance resulting from unforeseen situations, the inspectors assessed the effectiveness of the licensees planning and control of emergent work activities.
Documents reviewed are listed in the attachment.
- 10/27-11/02, B Train Work Week - Engine Driven Fire Pump OOS, Switchyard maintenance C AFW Pumps OOS
- 10/03/14, Critical Activity Plan - 14W40-44 Dry Cask Fuel Transfer/Storage
- Complex Activity Plan challenges associated with the EDFP Extended Outage
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors selected the two operability determinations or functionality evaluations listed below for review based on the risk-significance of the associated components and systems. The inspectors reviewed the technical adequacy of the determinations to ensure that technical specification operability was properly justified and the components or systems remained capable of performing their design functions. To verify whether components or systems were operable, the inspectors compared the operability and design criteria in the appropriate sections of the technical specification and updated final safety analysis report to the licensees evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with operability evaluations.
Documents reviewed are listed in the attachment.
- Part 21 Report Defect in C&D Technologies Inc LCR-25 Standby Batteries, AR715731
- Revision to OST-020, Shiftly Surveillances, Resulted in Missed Surveillance of R-11, Containment and Plant Vent Air Particulate Monitor, AR 723261
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
The inspectors verified that the plant modification listed below did not affect the safety functions of important safety systems. The inspectors confirmed the modifications did not degrade the design bases, licensing bases, and performance capability of risk significant structures, systems and components. The inspectors also verified modifications performed during plant configurations involving increased risk did not place the plant in an unsafe condition. Additionally, the inspectors evaluated whether system operability and availability, configuration control, post-installation test activities, and changes to documents, such as drawings, procedures, and operator training materials, complied with licensee standards and NRC requirements. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with modifications. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors either observed post-maintenance testing or reviewed the test results for the three maintenance activities listed below to verify the work performed was completed correctly and the test activities were adequate to verify system operability and functional capability.
- WO # 2288491, Replace Diesel Driven Fire Pump Engine for EC 91633, November 27, 2014
- WO #13423763, Dedicated Shutdown Diesel - Replace Motor-operated Potentiometer
- WO#13379554, Containment Spray Pump A - Disassemble, Inspect, Repair and Reassemble The inspectors evaluated these activities for the following:
- Acceptance criteria were clear and demonstrated operational readiness.
- Effects of testing on the plant were adequately addressed.
- Test instrumentation was appropriate.
- Tests were performed in accordance with approved procedures.
- Equipment was returned to its operational status following testing.
- Test documentation was properly evaluated.
Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with post-maintenance testing. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the four surveillance tests listed below and either observed the test or reviewed test results to verify testing adequately demonstrated equipment operability and met technical specification and licensee procedural requirements. The inspectors evaluated the test activities to assess for preconditioning of equipment, procedure adherence, and equipment alignment following completion of the surveillance.
Additionally, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with surveillance testing. Documents reviewed are listed in the Attachment.
Routine Surveillance Tests
- EST-003, Incore/Excore Detector Calibration (Quarterly Interval), Rev. 15
- MST-014, Steam Generator Pressure Protection Channel Testing, Rev. 38
- OST-101-3, Chemical Volume Control System (CVCS) Component Test Charging Pump C, Rev. 50
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors observed the emergency preparedness drill conducted on October 1, 2014. The inspectors observed licensee activities in the simulator, technical support center and the emergency operations facility to evaluate implementation of the emergency plan, including event classification, notification, and protective action recommendations. The inspectors evaluated the licensees performance against criteria established in the licensees procedures. Additionally, the inspectors attended the post-exercise critique to assess the licensees effectiveness in identifying emergency preparedness weaknesses and verified the identified weaknesses were entered in the corrective action program. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
a. Inspection Scope
The inspectors reviewed a sample of the performance indicator (PI) data, submitted by the licensee, for the Unit 2 PIs listed below. The inspectors reviewed plant records compiled between October 2013 and September 2014 to verify the accuracy and completeness of the data reported for the station. The inspectors verified that the PI data complied with guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Performance Indicator Guideline, and licensee procedures. The inspectors verified the accuracy of reported data that were used to calculate the value of each PI.
In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with PI data.
Cornerstone: Mitigating Systems
- high pressure injection system
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review
The inspectors screened items entered into the licensees corrective action program in order to identify repetitive equipment failures or specific human performance issues for follow-up. The inspectors reviewed condition reports, attended screening meetings, or accessed the licensees computerized corrective action database.
.2 Semi-Annual Trend Review
a. Inspection Scope
The inspectors reviewed issues entered in the licensees corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on repetitive equipment issues and human performance trends but also considered the results of inspector daily condition report screenings, licensee trending efforts, and licensee human performance results. The review nominally considered the 6-month period of July 2014 through December 2014, although some examples extended beyond those dates when the scope of the trend warranted. The inspectors compared their results with the licensees analysis of trends. Additionally, the inspectors reviewed the adequacy of corrective actions associated with a sample of the issues identified in the licensees trend reports.
The inspectors also reviewed corrective action documents that were processed by the licensee to identify potential adverse trends in the condition of structures, systems, and/or components as evidenced by acceptance of long-standing non-conforming or degraded conditions. Documents reviewed are listed in the Attachment.
b. Findings and Observations
No findings were identified.
.3 Annual Follow-up of Selected Issues
a. Inspection Scope
The inspectors conducted a detailed review of condition report AR 645333, Requirements of OP-925 for Construction of Equipment Enclosures and Verification of Acceptable Freeze Protection System Performance.
The inspectors evaluated the following attributes of the licensees actions:
- complete and accurate identification of the problem in a timely manner
- evaluation and disposition of operability and reportability issues
- consideration of extent of condition, generic implications, common cause, and previous occurrences
- classification and prioritization of the problem
- identification of root and contributing causes of the problem
- identification of any additional condition reports
- completion of corrective actions in a timely manner Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
4OA5 Other Activities
.1 Operation of an Independent Spent Fuel Storage Installation (ISFSI) (60855.1)
a. Inspection Scope
The inspectors monitored the activities associated with the dry fuel storage campaign completed on October 10, 2014, including fuel loading into a dry shielded canister (DSC)and transfer of the DSC from the spent fuel pool to the cask preparation area, as well as transportation of the DSC to the horizontal storage module. The inspectors reviewed changes made to the onsite ISFSI programs and procedures, including associated 10 CFR 72.48, Changes, Tests, and Experiments, screens and evaluations to verify that changes made were consistent with the license or certificate of compliance. The inspectors observed the loading activities to verify that the licensee recorded and maintained the location of each fuel assembly placed in the ISFSI. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
.2 Temporary Instruction 2515/190 - Inspection of the Proposed Interim Actions Associated
with Near-Term Task Force Recommendation 2.1 Flooding Hazard Evaluations The inspectors independently verified that the licensees proposed interim actions would perform their intended function for flooding mitigation. Specifically the inspectors performed the following items:
- Visual inspection of the flood protection features if the flood protection feature was relevant. External visual inspection for indications of degradation that would prevent its credited function from being performed.
- Reasonable simulation
- Flood protection feature functionality assessment using either visual observation or by review of other documents.
The inspectors verified that issues identified were entered into the licensees corrective action program.
4OA6 Meetings, Including Exit
On January 15, 2015, the resident inspectors presented the inspection results to Mr. Glover and other members of the licensees staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection period.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- T. Cosgrove, Plant General Manager
- S. Connelly, Licensing
- H. Curry, Training Manager
- M. Glover, Vice President
- R. Hightower, Licensing/Reg. Programs Supervisor
- D. Hoffman, Nuclear Oversight Manager
- K. Holbrook, Operations Manager
- J. Kammer, Engineering Director
- M. Pastva, Jr., Nuclear Regulatory Affairs
- T. Pilo, Emergency Preparedness Supervisor
- C. Sherman, Radiation Protection Superintendent
- K. Moser, Outage & Scheduling Manager
NRC personnel
- G. Hopper, Chief, Reactor Projects Branch 4
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened &
Closed
- 05000261/2014005-01 NCV Failure to Protect Diesel Driven Equipment from Effects of Extreme Cold Temperatures (Section 1R01)