IR 05000280/2010002

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IR 05000280-10-002 & 05000281-10-002 on 01/01/2010 - 03/31/2010 for Surry, Units 1 and 2, Post Maintenance Testing
ML101200347
Person / Time
Site: Surry  Dominion icon.png
Issue date: 04/30/2010
From: Gerald Mccoy
NRC/RGN-II/DRP/RPB5
To: Heacock D
Virginia Electric & Power Co (VEPCO)
References
IR-10-002
Download: ML101200347 (30)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION April 30, 2010

SUBJECT:

SURRY POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000280/2010002 and 05000281/2010002

Dear Mr. Heacock:

On March 31, 2010, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Surry Power Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on April 20, 2010, with Mr. Bischoff and other members of your staff.

The inspection examined activities conducted under your licenses as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents one NRC identified finding of very low safety significance (Green) which was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because the finding was entered into your corrective action program, the NRC is treating the finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any 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 the Surry Power Station.

In addition, if you disagree with the characterization of 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 II; and the NRC Resident Inspector at the Surry Power Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

VEPCO 2 In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the 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/

Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37

Enclosure:

Inspection Report 05000280/2010002 and 05000281/2010002 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37 Report No: 05000280/2010002 and 05000281/2010002 Licensee: Virginia Electric and Power Company (VEPCO)

Facility: Surry Power Station, Units 1 and 2 Location: 5850 Hog Island Road Surry, VA 23883 Dates: January 1, 2010 through March 31, 2010 Inspectors: C. Welch, Senior Resident Inspector J. Nadel, Resident Inspector T. Lighty, Project Engineer J. Hamman, Reactor Inspector (Section 1R17)

W. Lewis, Reactor Inspector (Section 1R17)

R. Patterson, Reactor Inspector (Section 1R17)

A. Sengupta, Reactor Inspector (Section 1R17)

C. Smith-Stansberry, Reactor Inspector (Section 1R17)

R. Fanner, Reactor Inspector (Section 1R17)

Approved by: Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000280/2010-002 and 05000281/2010-002; 01/01/2010 - 03/31/2010; Surry Power

Station, Units 1 and 2, Post Maintenance Testing.

The report covered a 3 month period of inspection by resident inspectors and an announced inspection by regional engineering inspectors. One Green finding, which was a non-cited violation (NCV), was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspect was determined using IMC 0310,

Components Within The Cross-Cutting Areas. Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI,

Corrective Action for failure to identify that a non-conservative error had been introduced into the Unit 1 A main station battery quarterly technical specification surveillance procedure (CR 366388). The licensee modified the procedure to eliminate the non-conservative error.

The inspectors determined the failure to identify a non-conservative error which was introduced into the TS quarterly surveillance procedure following the replacement of individual battery cells, was a condition adverse to quality and a performance deficiency which was reasonably within the licensees ability to foresee and correct, and should have been prevented. The finding was more than minor because if left uncorrected the non-conservative error in 1-EPT-0103-01 would have the potential to lead to a more significant safety concern. Specifically, this is because the error was large enough to mask cell degradation and an inoperable cell. The finding was associated with the equipment performance attribute of the reactor safety mitigating systems cornerstone, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of the safety related 125 VDC station batteries that provide class 1E backup power to risk significant components needed to prevent undesirable consequences during a loss of offsite power event. The finding was evaluated using MC-0609, Attachment 4,

Phase 1 - Initial Screening and Characterization of Findings, and determined to be of very low safety significance (Green) because operability of the Unit 1 A battery was not lost and the error was removed prior to the next quarterly surveillance. This finding had a cross cutting aspect in the area of problem identification and resolution because the licensee did not evaluate and communicate relevant external OE, including vendor recommendations, to affected internal stakeholders in a timely manner (P.2(a)). Specifically, the caveat to have cells on a float charge for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> was not fully evaluated when the battery cells were replaced. (Section 1R19)

Licensee Identified Violations

None

REPORT DETAILS

Summary of Plant Status

Both Unit 1 and 2 operated at or near full rated thermal power (RTP) throughout the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

The inspectors reviewed the licensees preparations for extreme cold weather predicted for January 4 - 8, 2010. Inspection focused on verification of design features and the licensees implementation of their cold weather procedures to protect mitigating systems from adverse weather effects. The inspectors reviewed station procedures 0-OSP-ZZ-001, Cold Weather Preparations; OC - 21, Severe Weather Checklist; and 0-ECM-1205-01, EDG Room Temperature Monitoring and Compensatory Measures for Extreme Low Room Temperatures; and walked down areas vulnerable to cold weather.

The inspectors, on a sampling basis, verified action items from the cold weather procedures were complete; which included verifying the proper position of roll-up doors, ventilation louvers, thermostat settings, and that piping insulation and heat tracing was installed and operable in areas susceptible to a cold environment. The areas walked down include: the auxiliary and safeguards buildings, the turbine building, the AFW systems in the main steam valve houses, EDG rooms, refueling water storage tank level instrumentation, and the low level intake structure. The inspectors verified weather related problems were being identified, entered into the corrective action program, and properly addressed.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed a partial walkdown of the four risk-significant systems identified below to verify the redundant or diverse train for equipment removed from service was operable and/or that the system was properly aligned to perform its designated safety function following an extended outage. During the walkdown, the inspectors verified the positions of critical valves, breakers, and control switches by in-field observation and/or review of the main control board. To determine the correct configuration to support system operation, the inspectors reviewed applicable operating procedures, station drawings, the Updated Final Safety Analysis Report, and the Technical Specifications. The inspectors attempted to identify any discrepancies that could impact the function of the system, and, therefore, potentially increase risk.

  • Unit 1 B battery and inverter on January 14 during replacement of battery cells in the A battery bank
  • Unit 1 auxiliary feedwater system on March 2 following testing of the A motor driven AFW pump and motor operated valves

b. Findings

No findings of significance were identified.

.2 Complete System Walkdown

a. Inspection Scope

The inspectors performed a full system walkdown of the Unit 1 and Unit 2 DC Power systems to verify the systems were properly aligned and capable of performing their safety function, and to assess their material condition. During the walkdown, the inspectors verified breaker positions were in the proper alignment, component labeling was accurate, hangers and supports were functional, and local indications were accurate. The plant health report, system drawings, condition reports, the UFSAR, and Technical Specifications were reviewed and outstanding deficiencies were verified to be properly classified and not affect system operability and capability to perform its safety function. The inspectors reviewed the corrective action program to verify equipment alignment issues were being identified and resolved.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Quarterly Fire Protection Reviews

a. Inspection Scope

The inspectors conducted a defense-in-depth (DID) review for the seven fire areas listed below by walkdown and review of licensee documents. The reviews were performed to evaluate the fire protection program operational status and material condition and the adequacy of:

(1) control of transient combustibles and ignition sources;
(2) fire detection and suppression capability;
(3) passive fire protection features;
(4) compensatory measures established for out-of-service, degraded or inoperable fire protection equipment, systems, or features; and
(5) procedures, equipment, fire barriers, and systems so that post-fire capability to safely shutdown the plant is ensured. The inspectors reviewed the corrective action program to verify fire protection deficiencies were being identified and properly resolved.
  • Fire zone 1, Unit 1 cable vault
  • Fire zone 3, Unit 1 emergency switchgear room
  • Fire zone 2, Unit 2 cable vault
  • Fire zone 4, Unit 2 emergency switchgear room
  • Fire zone 5, main control room

b. Findings

No findings of significance were identified.

.2 Annual Fire Drills

a. Inspection Scope

The inspectors observed a fire brigade drill held on March 4, 2010, to evaluate the readiness of the licensees personnel to fight fires. Aspects considered in the evaluation include: the control room operators response, including identification of the fire location, dispatch of the fire brigade, and sounding of alarms; the number of individuals assigned to the fire brigade; response timeliness; use of protective clothing and self-contained breathing apparatus; the brigade team leaders command and control, use of pre-fire plan strategies, briefs, and delegation of assignments; fire hose deployment and reach; approach into the fire area; effectiveness of communications among brigade members and between the brigade and the control room; search for victims, smoke evacuation, and the drills objective and acceptance criteria. The inspectors observed the post drill critique and verified noted deficiencies or areas for improvement were captured.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

.1 Internal Flooding

a. Inspection Scope

The inspectors reviewed the Updated Final Safety Analysis Report and Individual Plant Examination of Non-Seismic External Events and Fires to identify those areas that can be affected by external and internal flooding. Based on the reviews, the inspectors walked down the Unit 1 and 2 turbine building basements, the emergency switchgear rooms, and mechanical equipment rooms 3, 4, and 5. The inspectors observed and assessed the condition and availability of temporary or removable flooding barriers, flooding dikes, floor drain backflow preventers, the sealing of holes and penetrations between flood areas, the adequacy of water tight doors, and the operability of flooding alarms and installed sump pumps. The inspectors verified on a sampling basis that completed surveillance tests of the turbine building flood detectors and circulating water (CW) system motor operated isolation valves were satisfactory, and the flood shields were properly installed over the CW system flexible piping connections. The inspectors reviewed the corrective action program and verified internal flooding related problems were being identified and properly addressed.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review

a. Inspection Scope

The inspectors observed a licensed operator simulator exam given on January 13 and 14, 2010. The exam, administered using scenarios RQ-10.1-SE-9 (Rev. 0) and RQ-10.1-SE-10 (Rev. 0), involved both operational transients and design basis events. The inspector verified that simulator conditions were consistent with the scenario and reflected the actual plant configuration (i.e., simulator fidelity). The inspector observed the crews performance to determine whether the crew met the scenario objectives; accomplished the critical tasks; demonstrated the ability to take timely action in a safe direction and to prioritize, interpret, and verify alarms; demonstrated proper use of alarm response, abnormal, and emergency operating procedures; demonstrated proper command and control; communicated effectively; and appropriately classified events per the emergency plan. The inspector observed the evaluators post scenario critiques and confirmed items for improvement were identified and would be discussed with the operators to further enhance performance.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

For the equipment issue described in the condition report listed below, the inspectors evaluated the effectiveness of the corresponding licensee's preventive and corrective maintenance. The inspectors performed a detailed review of the problem history and associated circumstances, evaluated the extent of condition reviews, as required, and reviewed the generic implications of the equipment and/or work practice problem.

Inspectors performed walkdowns of the accessible portions of the system, performed in-office reviews of procedures and evaluations, and held discussions with system engineers. The inspectors compared the licensees actions with the requirements of the Maintenance Rule (10 CFR 50.65), VPAP 0815, Maintenance Rule Program, and the Surry Maintenance Rule Scoping and Performance Matrix.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors evaluated, as appropriate, for the five work activities listed below:

(1) the effectiveness of the risk assessments performed before maintenance activities were conducted;
(2) the management of risk;
(3) that, upon identification of an unforeseen situation, necessary steps were taken to plan and control the resulting emergent work activities; and,
(4) that maintenance risk assessments and emergent work problems were adequately identified and resolved. The inspectors verified that the licensee was complying with the requirements of 10 CFR 50.65(a)(4) and the data output from the licensees safety monitor associated with the risk profile of Units 1 and 2. The inspectors reviewed the corrective action program to verify deficiencies in risk assessments were being identified and properly resolved.
  • On-line green risk condition for Units 1 and 2 during replacement of battery cells in the Unit 1 A battery and removal of the emergency switchgear room flood barrier on January 14
  • On-line green risk condition for Units 1 and 2 during sustained freezing conditions January 4 - 8
  • On-line green risk condition for Units 1 and 2 during severe cold weather coincident with a declared high wind advisory for Surry County on February 10
  • On-line green risk condition for Units 1 and 2 during replacement of emergency switchgear room, cable tunnel and MER #3 backflow preventers on February 7
  • On-line green risk condition for Units 1 and 2 during planned maintenance on the intake canal low canal level indication circuitry on March 23

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the five operability evaluations, listed below, affecting risk-significant mitigating systems, to assess, as appropriate:

(1) the technical adequacy of the evaluations;
(2) whether continued system operability was warranted;
(3) whether other existing degraded conditions were considered;
(4) if compensatory measures were involved, whether the compensatory measures were in place, would work as intended, and were appropriately controlled; and
(5) where continued operability was considered unjustified, the impact on TS Limiting Conditions for Operation and the risk significance.

The inspectors review included verification that determinations of operability followed procedural requirements of OP-AA-102, Operability Determination. The inspectors reviewed the corrective action program to verify deficiencies in operability determinations were being identified and corrected.

  • CR 365150, discovery of Unit 2 B battery positive terminal cable found exceeding minimum specified bend radius
  • CR 366388, Unit 1 A battery identified with high electrolyte level in six cells after cell replacement
  • CR 364602, Unit 1 containment particulate and gaseous radiation monitors exhibiting flow oscillations after return to service following maintenance
  • CR 371403, emergency service water pump 1-SW-P-1C high motor vibes on non-IST points

b. Findings

No findings of significance were identified.

1R17 Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications

a. Inspection Scope

The inspectors reviewed selected samples of evaluations to confirm that the licensee had appropriately considered the conditions under which changes to the facility, Updated Final Safety Analysis Report (UFSAR), or procedures may be made, and tests conducted, without prior NRC approval. The inspectors reviewed evaluations for seven changes and additional information, such as drawings, calculations, supporting analyses, the UFSAR, and Technical Specifications (TS) to confirm that the licensee had appropriately concluded that the changes could be accomplished without obtaining a license amendment. The seven evaluations reviewed are listed in the List of Documents Reviewed.

The inspectors reviewed samples of changes for which the licensee had determined that evaluations were not required, to confirm that the licensees conclusions to screen out these changes were correct and consistent with 10CFR50.59. The 21 screened out changes reviewed are listed in the List of Documents Reviewed.

The inspectors evaluated engineering design change packages for 13 material, component, and design based modifications to evaluate the modifications for adverse effects on system availability, reliability, and functional capability. The 13 modifications and the associated attributes reviewed are as follows:

  • LSM 2-07-013, SI Flow Transmitter 2940 Replacement
  • DCP 06-041, RWST Level ESFAS Function to Support GSI-191 Containment Sump Modifications
  • DCP 07-048, Replacement of 1-SW-262/268 and 2-SW-442/445 with a Swing Check Valve
  • DCP 07-031, Install New AFW Isolation MOV Auto Open Signal Configuration
  • DCP 04-064, EDG Combustion Air Inlet Filter Bank Vendor Recommended Modifications
  • CGD 10000001580, MCR Chiller Control Panels - SWR Reset
  • EE 10000002835, 125 VDC Switchboard 50 Amp Circuit Breaker
  • DCP 07-032, Delete HPHD Pump Autostart Signal
  • DCP SU-09-0029, RC Taylor Math Unit Fuse Installations Documents reviewed included procedures, engineering calculations, modification design and implementation packages, work orders, site drawings, corrective action documents, applicable sections of the living UFSAR, supporting analyses, Technical Specifications, and design basis information. The inspectors additionally reviewed test documentation to ensure adequacy in scope and conclusion. The inspectors review was also intended to verify that all details were incorporated in licensing and design basis documents and associated plant procedures.

The inspectors also reviewed selected CRs and the licensees recent self-assessment associated with modifications and screening/evaluation issues to confirm that problems were identified at an appropriate threshold, were entered into the corrective action process, and appropriate corrective actions had been initiated and tracked to completion.

b. Findings

No findings of significance were identified.

1R18 Plant Modifications

a. Inspection Scope

The inspectors reviewed the three identified temporary plant modifications listed below to verify:

(1) that the design and licensing bases, and performance capability of risk-significant systems, structures, and components (SSCs) were not degraded through modification;
(2) that modifications performed during increased risk-significant configurations do not place the plant in an unsafe condition; and,
(3) that the modification did not affect system operability or availability as described by the TS and UFSAR. The inspectors reviewed applicable procedures, engineering calculations, the modification design and implementation package, work orders, drawings, corrective action documents, the UFSAR and TS, supporting analyses, and design basis information. Inspectors witnessed aspects of the modification implementation and observed/reviewed aspects of the post-modification testing.
  • Temporary plant modification S1-09-142, Jumper out cell #21 to restore operability of 1-EPD-B-1A main station battery
  • Temporary plant modification S1-10-143, Jumper out cell #11 to restore operability of 1-EPD-B-1A main station battery
  • Temporary plant modification S1-10-144, Install piping to add oil to the top of main feedwater pump 1A (1-FW-P-1A) slinger ring to reduce bearing temperature

b. Findings

No findings of significance were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

For the eight risk-significant maintenance activities listed below, the inspectors reviewed the associated post maintenance testing (PMT) procedures and either witnessed the testing and/or reviewed completed records to assess whether:

(1) the effect of testing on the plant had been adequately addressed by control room and/or engineering personnel;
(2) testing was adequate for the maintenance performed;
(3) test acceptance criteria were clear and adequately demonstrated operational readiness consistent with design and licensing basis documents;
(4) test instrumentation had current calibrations, range, and accuracy consistent with the application;
(5) test were performed as written with applicable prerequisites satisfied;
(6) jumpers installed or leads lifted were properly controlled;
(7) test equipment was removed following testing; and
(8) equipment was returned to the status required to perform its safety function. The inspectors reviewed the corrective action program to verify PMT deficiencies were being identified and corrected. Documents reviewed are listed in the Attachment to this report.
  • Preventive maintenance on 2-SI-MOV-2862B and quick look testing, W.O.

38102347276

  • Corrective maintenance on containment particulate radiation monitor, 1-RM-RMS-159, due to a filter tear indication, W.O. 38102721741
  • Corrective maintenance to replace cells 3, 21, and 22 in the unit 1 battery 1-EPD-1A, due to degradation from cracking, W.O. 38102588642
  • Preventative maintenance and eddy current exam on control room chiller 1-VS-E-4A, W.O.38102586240
  • Corrective maintenance to replace valve 2-SW-TCV-208A, W.O. 38102743736
  • Preventive maintenance for #3 EDG relay replacement; W.O. 38102241043
  • Preventive maintenance for #3 EDG 18 month overhaul; W.O. 38102455624
  • Preventive maintenance for #3 EDG air motor replacement; W.O. 38102613991

b. Findings

Introduction:

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action; for failure to identify that a non-conservative error had been introduced into the Unit 1 A main station battery quarterly technical specification surveillance procedure (CR 366388). The licensee modified the procedure to eliminate the non-conservative error.

Description:

On January 14, 2010, the licensee replaced six cells in the 60 cell Unit 1 A battery which were degraded due to cracks in the plastic lids. Post maintenance testing required performance of the quarterly TS surveillance test procedure, 1-EPT-0103-01; which requires the electrolyte specific gravity, temperature, and level be recorded for each cell and compared to specific acceptance criteria. There are acceptance criteria for both the individual cell readings and the average values for the entire battery. The licensee performed the test immediately after re-terminating the battery following installation of the six replacement cells. The inspectors noted the vendor manual recommends waiting a minimum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before taking specific gravity readings while on a float charge. Additionally, 1-EPT-0103-01 includes a precaution that cells should be on a float charge for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to performing the procedure. However, several one-time-only changes were made to the procedure to allow taking some data immediately after re-terminating the battery and neither the vendor recommendation nor the precaution was fully evaluated. The licensee noted no abnormalities during the test and all results were within the acceptance criteria.

Eleven days after the battery replacement, the inspectors walked down the A battery and identified electrolyte level in all six replaced cells had risen above the high level mark, and one cells level was greater than 1/4 inch above the high level mark, placing the cell into an alert condition. The electrolyte level of all cells is maintained at the midpoint between the high and low level marks and all replacement cells were recorded at the midpoint when the battery was returned to service on January 14, 2010. The quarterly surveillance procedure incorporates correction factors for temperature and level which are then applied to the measured values for individual cell specific gravity. These corrected values are used in the comparison to the acceptance criteria to determine both individual cell and collective battery operability. In this case however, the level increase was caused by natural changes within the battery electrolyte that were a direct result of the installation process and the disruption of the float charge on the installed cells.

Since the mass of liquid in the new cells did not change when the level increased, the level correction factor required by 1-EPT-0103-01 became a non-conservative error affecting the corrected specific gravity of the replaced cells. When this error was identified the magnitude was greater than the alert band of the acceptance criteria, meaning that an inoperable cell could meet the acceptance criteria and be recorded as fully operable, masking battery cell degradation.

Analysis:

The inspectors determined the failure to identify a non-conservative error which was introduced into the TS quarterly surveillance procedure following the replacement of individual battery cells, was a condition adverse to quality and a performance deficiency which was reasonably within the licensees ability to foresee and correct, and should have been prevented.

The finding was more than minor because if left uncorrected the non-conservative error in 1-EPT-0103-01 would have the potential to lead to a more significant safety concern.

Specifically, this is because the error was large enough to mask cell degradation and an inoperable cell. The finding was associated with the equipment performance attribute of the reactor safety mitigating systems cornerstone, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of the safety related 125 VDC station batteries that provide class 1E backup power to risk significant components needed to prevent undesirable consequences during a loss of offsite power event. The finding was evaluated using MC-0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and determined to be of very low safety significance (Green) because operability of the Unit 1 A battery was not lost and the error was removed prior to the next quarterly surveillance.

This finding had a cross cutting aspect in the area of problem identification and resolution because the licensee did not evaluate and communicate relevant external OE, including vendor recommendations, to affected internal stakeholders in a timely manner (P.2(a)). Specifically, the caveat to have cells on a float charge for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> was not fully evaluated when the battery cells were replaced.

Enforcement:

10 CFR 50, Appendix B, Criterion XVI, Corrective Action requires, in part, that conditions adverse to quality be promptly identified and corrected. Contrary to the above, the licensee failed to identify the non-conservative impact on technical specification surveillance acceptance criteria caused by battery cell replacement activities. Because this finding is of very low safety significance, has been entered into the licensees corrective action program as CR 367879, and has been corrected; this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. NCV 05000280/2010002-01: Failure to identify a non-conservative error in the quarterly TS surveillance for the Unit 1 A battery.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors witnessed and/or reviewed test records for the seven risk-significant surveillance tests listed below, to determine whether the SSCs selected meet Technical Specifications (TS), the Updated Final Safety Analysis Report (UFSAR), and licensees procedure requirements and demonstrate that the SSCs are capable of performing their intended safety functions (under conditions as close as practical to accident conditions or as required by TS) and their operational readiness.

In-Service Testing:

  • 2-OPT-CS-006, Rev. 12, Unit 2 RWST, Chemical Injection Tank, and Containment Spray System MOV Stroke Test Surveillance Testing:
  • 0-OSP-AAC-003, Rev. 3; Automatic Start Test of AAC Diesel Generator
  • 1-EPT-0103-01, Rev. 12; Main Station Battery 1A Quarterly Check RCS Leakage:
  • 1-OPT-RC-10.0, Rev. 30, Unit 1 Reactor Coolant Leakage - Computer Calculated
  • 2-OPT-RC-10.0, Rev. 29, Unit 2 Reactor Coolant Leakage - Computer Calculated

b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed the emergency response training drill conducted on February 9, 2010, to assess licensee performance in event classification per the emergency plan, protective action recommendations, and off-site notifications. The drill required emergency plan response actions be taken by personnel located in the simulator control room, the technical support center (TSC), and local emergency operating facility (LEOF).

The inspectors observed conduct of the drill from the TSC and the subsequent critique performance. This drill is included in the Emergency Response Performance Indicator Statistics.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors sampled licensee data for the Performance Indicators (PIs) listed below.

To assess the accuracy and completeness of the submitted PI data and whether the PIs were properly calculated during the period reviewed, PI definitions and guidance contained in NEI 99-02, ARegulatory Assessment Indicator Guideline,@ Rev. 4, were used to verify the basis for each data element.

Initiating Event Cornerstone The following Unit 1 and 2 PIs were reviewed from the fourth quarter 2008 through the fourth quarter 2009. Documents reviewed included NRC inspection reports, licensee event reports, operator logs and station performance indicators.

  • Unplanned Scrams per 7000 Critical Hours.
  • Unplanned Scrams With Complications

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Daily Reviews of items Entered into the Corrective Action Program:

As required by NRC Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished by reviewing daily CR report summaries and periodically attending daily CR Review Team meetings.

.2 Annual Follow-up of Selected PI&R Issues

CR 364061 Minimum Shift Manning Requirements Not Met

a. Inspection Scope

The inspectors selected CR 364061 and its associated root cause evaluation (RCE -

000999) for follow-up based on the potential adverse impact on the licensees ability to meet the emergency plans minimum staffing requirements. The inspectors reviewed the CR and RCE against the applicable performance attributes contained in NRC inspection procedure 71152, Problem Identification and Resolution.

b. Findings

Introduction:

An unresolved item (URI) was identified by the inspectors relating to maintenance of the required minimum onsite manning in accordance with the licensees Emergency Plan.

Description:

On January 4, 2010, the licensee identified issues relating to the Emergency Plan minimum manning requirements for maintenance personnel. They subsequently initiated CR364061 in their CAP and the respective root cause evaluation, RCE000999, for appropriate corrective actions. The inspectors reviewed RCE000999 and require additional information from the licensee to appropriately characterize a performance deficiency which may be greater than minor. This issue is identified as URI 05000280, 281/2010002-02, Emergency Plan Minimum Staffing.

4OA3 Event Follow-up

1. Licensee Event Report (LER) 05000281/2009-001-00

a. Inspection Scope

The inspectors reviewed LER 05000281/2009-001-00, Manual Reactor Trip Initiated to replace a Rod Control Data Logging Card and related documents to assess the LERs accuracy, appropriateness of the corrective actions, potential violation of NRC requirements, and generic issues. The LER documents the November 29, 2009, manual reactor trip inserted during physics startup testing following failure of the A114 Supervisory Data Logging Card which caused a loss of rod position step counter indications for shutdown bank B and control banks B and D.

b. Findings

No findings of significance were identified and no violation of NRC requirements occurred.

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with the licensee security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

An interim exit with licensee management and staff was conducted on January 28, 2010, to discuss the results of the DRS engineering inspection. Proprietary information reviewed by the team as part of routine inspection activities was returned to the licensee in accordance with prescribed controls.

On April 20, 2010, the inspection results were presented to Mr. Bischoff and other members of his staff, who acknowledged the findings. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.

ATTACHMENT: SUPPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Adams, Director, Station Engineering
G. Bischof, Site Vice President
B. Garber, Supervisor, Licensing
K. Grover, Manager, Operations
A. Harrow, Supervisor, Electrical Systems
R. Johnson, Manager, Outage and Planning
R. Manrique, Supervisor, Primary Systems
C. Olsen, Manager, Site Engineering
L. Ragland, Supervisor, Health Physics Operations
K. Sloane, Plant Manager (Nuclear)
B. Stanley, Director, Station Safety and Licensing
M. Wilda, Supervisor, Auxiliary Systems
J. Eggart, Manager, Radiation Protection & Chemistry
B. Hilt, Supervisor, HP Technical Services
D. White, Supervisor, ALARA
D. Godwin, Supervisor, Nuclear Engineering

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened

05000280, 281/2010002-02 URI Emergency Plan Minimum Staffing (Section 40A2.2)

Opened and Closed

05000280, 281/2010002-01 NCV Failure to identify a non-conservative error in the quarterly TS surveillance for the Unit A battery (Section IR19)

Closed

05000281/2009-001-00 LER Manual Reactor Trip Initiated to replace a Rod Control Data Logging Card (Section 40A3)

LIST OF DOCUMENTS REVIEWED

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