IR 05000298/2011006

IR 05000298-11-006; 6/6/2011 - 6/24/2011; Cooper Nuclear Station, Biennial Baseline Inspection of the Identification and Resolution of Problems

ML112201499
Person / Time
Site:	Cooper
Issue date:	08/08/2011
From:	Powers D Division of Reactor Safety IV
To:	O'Grady B Nebraska Public Power District (NPPD)
References
EA-11-176 IR-11-006
Preceding documents:	ML11265A283 (22 September 2011)
Download: ML112201499 (41)

Text

August 8, 2011 EA-2011-176

Brian J. O'Grady, Vice President-Nuclear and Chief Nuclear Officer Nebraska Public Power District Cooper Nuclear Station 72676 648A Avenue Brownville, NE 68321 SUBJECT: COOPER NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000298/2011006 AND NOTICE OF VIOLATION

Dear Mr. O'Grady:

On June 24, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Cooper Nuclear Station. The enclosed report documents the inspection findings, which were discussed on June 24, 2011, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to identification and resolution of problems, safety and compliance with the Commission's rules and regulations and with the conditions of your operating license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. The inspectors also interviewed a representative sample of personnel regarding the condition of your safety conscious work environment.

The inspectors concluded that Cooper Nuclear Station generally identified, evaluated, and corrected problems according to their safety significance. Cooper Nuclear Station generally analyzed operating experience appropriately, performed effective self-assessments, and maintained an effective safety conscious work environment.

The inspectors identified weaknesses in the areas of operability evaluations, thorough evaluations, and the effectiveness of corrective actions. This was evidenced most notably by repetitive diesel failures in 2009. The inspectors noted that the previous Problem Identification and Resolution inspection, documented in weaknesses in operability evaluations and that some root causes should have been more thorough. Therefore, the inspectors considered the weaknesses in operability evaluations and thorough evaluations to be repetitive weaknesses.

Based on the results of the inspection, the NRC has identified an issue that was evaluated under the risk significance determination process as having very low safety significance (Green). The NRC has also determined that one violation is associated with this issue. The violation is being cited because Cooper Nuclear Station failed to restore compliance with UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV612 EAST LAMAR BLVD, SUITE 400ARLINGTON, TEXAS 76011-4125 Nebraska Public Power District - 2 -

NRC requirements within a reasonable time after a previous violation was identified in NRC Inspection Report 05000298/2010007 (issued December 3, 2010). This is consistent with the NRC Enforcement Policy; Section 2.3.2, which states, in part, that a cited violation will be considered if the licensee fails to restore compliance within a reasonable time after a violation is identified.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

Based on the results of the inspection, the NRC has also identified that two NRC-identified issues that were evaluated under the risk significance determination process as having very low safety significance (Green) and two Severity Level IV violations of NRC requirements occurred. All of these findings were determined to involve violations of NRC requirements. However, because of the very low safety significance of the violations and because they were entered into your corrective action program, the NRC is treating these violations as noncited violations consistent with Section 2.3.2 of the NRC Enforcement Policy.

If you contest these violations or the characterization of the violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 East Lamar Blvd., Suite 400, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Cooper Nuclear Station. 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 IV, and the NRC Resident Inspector at your facility. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web-site at www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Dr. Dale A. Powers, Acting Chief and Senior Technical Analyst Technical Support Branch Division of Reactor Safety Dockets: 50-298 License: DRP-46 Nebraska Public Power District - 3 -

Enclosure 1 - Notice of Violation Enclosure 2 - Inspection Report 05000298/2011006

w/Attachments:

Attachment 1 - Supplemental Information Attachment 2 - Initial Information Request Attachment 3 - Supplemental Information Request

REGION IV Docket: 05000298 License: DRP-46 Report: 05000298/2011006 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: 72676 648A Ave. Brownville, NE 68321 Dates: June 6 through June 24, 2011 Team Leader: B. Tindell, Senior Reactor Inspector Inspectors:

I. Anchondo, Reactor Inspector J. Josey, Senior Resident Inspector N. Okonkwo, Reactor Inspector Approved By: Dr. Dale A. Powers Acting Chief and Senior Technical Analyst Technical Support Branch Division of Reactor Safety

- 2 - Enclosure 2

SUMMARY OF FINDINGS

IR 05000298/2011006; 6/6/2011 - 6/24/2011; Cooper Nuclear Station, Biennial Baseline Inspection of the Identification and Resolution of Problems.

A senior reactor inspector, two reactor inspectors, and a senior resident inspector performed the inspection. In this report, the inspectors documented two noncited violations of very low safety significance (Green), two severity level IV noncited violations, and one cited violation of very low safety significance (Green). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Identification and Resolution of Problems The inspectors reviewed approximately 400 condition reports, work orders, cause evaluations, self-assessments and audits, operating experience evaluations, system health reports, trending reports, metrics, and other supporting documentation to determine if problems were being properly identified, prioritized, evaluated, and resolved.

The inspectors concluded that the licensee generally identified, evaluated, and corrected problems according to their safety significance. The licensee generally analyzed operating experience appropriately, performed effective self-assessments, and maintained an effective safety conscious work environment.

The inspectors identified weaknesses in the areas of operability evaluations, thorough evaluations, and the effectiveness of corrective actions. This was evidenced most notably by repetitive diesel failures in 2009 and three recent cited violations. The inspectors noted that the previous Problem Identification and Resolution inspection, documented in NRC Inspection Report 2009007, identified weaknesses in operability evaluations and that some root causes could have been more thorough. Therefore, the inspectors considered the weaknesses in operability evaluations and thorough evaluations to be repetitive weaknesses. In addition, NRC Inspection Report 2011002 documents a repetitive weakness in initiating condition reports evidenced by multiple noncited violations. The inspectors concluded that the licensee needs to be more effective at correcting the observed corrective action program weaknesses in identification, operability evaluations, and thorough evaluations.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," associated with four examples of the licensee's failure to promptly identify and correct conditions adverse to quality. Specifically, the licensee failed to identify and correct excessive setpoint drift of reactor core isolation cooling system pressure switches, the leak of oil from the service water booster pump, a vulnerability that allowed non-quality controlled material to be installed in safety related applications, and the cause of a failure of the high pressure coolant injection steam line high flow instrument. The licensee entered the finding into the corrective action program as Condition Reports 2011-07060, 2011-07105, 2011-07151, and 2011-06653. The performance deficiency was determined to be more than minor because if left uncorrected, the continued failure to promptly identify and correct conditions adverse to quality could result in more risk significant equipment being inoperable, and is therefore a finding. This finding affected the Mitigating Systems Cornerstone. Using Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding was determined to have a crosscutting aspect in the area of problem identification and resolution, associated with the corrective action program component, in that, the licensee failed to implement a corrective action program with a low threshold for identifying issues; issues are identified completely, accurately and in a timely manner commensurate with their safety significance P.1(a) (Section 4OA2.5a).

Green.

The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," for the failure to correct a condition adverse to quality. Specifically, the licensee determined that an interim corrective action to prevent recurrence was ineffective, yet it took no effective corrective action. As a result, the licensee was vulnerable to a repetitive condition adverse to quality. The licensee entered the issue into the corrective action program as Condition Report 2011-07152.

The finding was determined to be more than minor because the performance deficiency could be reasonably viewed as a precursor to an event in that the interim action was not effective as a barrier to prevent recurrence of an event. The finding is associated with the Mitigating Systems Cornerstone. The inspectors performed a Phase 1 screening in accordance with Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," and determined that the finding was of very low safety significance (Green) because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined that this finding had a crosscutting aspect in the area of problem identification and resolution associated with corrective actions because the licensee failed to prioritize and thoroughly evaluate a condition report that documented an inadequate interim corrective action to prevent recurrence P.1(c) (Section 4OA2.5d).

Green.

The inspectors identified a cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to assure that the applicable design basis for applicable structures, systems, and components were correctly translated into specifications, procedures, and instructions. Specifically, the licensee failed to justify through evaluation that the diesel generator fuel oil day tanks would be available following a tornado missile strike on the tank vents. The violation was cited because the licensee failed to restore compliance in a reasonable time following documentation of the issue as a noncited violation in NRC Inspection Report 2010007 (issued December 3, 2010). The licensee entered this issue into the corrective action program as Condition Report 2011-06655.

The performance deficiency was determined to be more than minor because it was associated with the protection against the external factors attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding was determined to have a crosscutting aspect in the area of human performance, associated with the decision making component in that the licensee failed to use conservative assumptions in decision making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate it is unsafe in order to disapprove the action H.1(b) (Section 4OA2.5e).

Cornerstone: Miscellaneous

• Severity Level IV. The inspectors identified a noncited violation of 10 CFR 50.73, "Licensee Event Report System," associated with the licensee's failure to submit a licensee event report within 60 days following discovery of an event meeting the reportability criteria as specified. Specifically, a condition prohibited by technical specifications occurred when a zurn strainer failure rendered the service water system inoperable for longer than the action statement and would have prevented fulfillment of a safety function. The licensee entered the finding into the corrective action program as Condition Report 2011-06778.

The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC's regulatory ability was affected. Specifically, the NRC relies on the licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function; and when this is not done, the regulatory function is impacted. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was a violation determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program. Therefore, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. This finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action component, in that, the licensee failed to appropriately and thoroughly evaluate for reportability aspects all factors associated with the equipment failure P.1(c) (Section 4OA2.5b).

• Severity Level IV. The inspectors identified a noncited violation of 10 CFR 50.59, "Changes, Tests, and Experiments," associated with the failure to adequately evaluate a change in order to ensure that it did not require prior NRC approval. Specifically, the licensee revised a residual heat removal pump motor cable sizing calculation to a smaller sized cable without a change evaluation. The licensee entered the issue into the corrective action program as Condition Report 2011-01730.

The finding was determined to be more than minor because the licensee failed to perform a 10 CFR 50.59 evaluation when required. Specifically, the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done the regulatory function is impacted, and is therefore more than minor. Violations of 10 CFR 50.59 are considered to impede or impact the regulatory process, so they are dispositioned using the traditional enforcement process. The enforcement manual specifies that the severity level is determined in parallel with the Significance Determination Process (SDP). The inspectors performed a Phase 1 screening in accordance with Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," and determined that the finding was of very low safety significance (Green) because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. Therefore, the inspectors categorized the finding as Severity Level IV in accordance with the enforcement manual. The finding was a violation determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program. Therefore, this violation is being treated as a noncited violation consistent with the NRC Enforcement Policy. The inspectors determined the cause of the finding through interviews and document reviews. This finding was determined to have a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program in that the licensee failed to appropriately and thoroughly evaluate all factors associated with the design change P.1(c) (Section 4OA2.5c).

B. Licensee-Identified Violations

None

2

REPORT DETAILS

4OA2 Problem Identification and Resolution

The inspectors based the following conclusions on the sample of corrective action documents that were initiated in the assessment period, which ranged from April 11, 2009, to the end of the on-site portion of this inspection on June 24, 2011.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed documents, interviewed personnel, attended meetings, and walked down plant equipment to determine if problems were being appropriately identified, prioritized, evaluated, and resolved.

The inspectors verified that the licensee entered problems into the condition report system for resolution. The inspectors reviewed the information related to problems to ensure that the evaluations were thorough. The inspectors verified that the licensee considered the extent of cause and extent of condition for problems as appropriate, as well as how the licensee assessed previous occurrences. The inspectors assessed how the licensee prioritized problems so that corrective actions were appropriate and timely. In addition, the inspectors verified the effectiveness of corrective actions, completed or planned, and looked for additional examples of similar problems. The inspectors also expanded their review to the previous five years for age-related problems to determine whether they were being effectively addressed.

In order to accomplish the above, the inspectors reviewed approximately 250 condition reports out of approximately 20,000 that had been issued during the assessment period. The inspectors also reviewed a sample of system health reports, self-assessments, trending reports, metrics, selected logs, audits, operability evaluations, and results from surveillance tests and preventive maintenance tasks. The inspectors reviewed a sample of corrective actions closed to other corrective action documents. The inspectors attended the licensee's Condition Review Group and the Corrective Action Review Board to observe the management of prioritizations, evaluations, and corrective actions. The inspectors interviewed plant personnel to identify other processes that may exist where problems may be identified and addressed outside the corrective action program. The inspectors reviewed corrective action documents that addressed past NRC-identified violations to ensure that the corrective action addressed the issues as described in the inspection reports. The inspectors considered risk insights and selected the DC Distribution System for a detailed work order and condition report review, and a system walkdown.

At the time of the inspection, a potentially greater than green finding was identified in NRC Inspection Report 2010006. In addition, a special inspection was ongoing due to a radiation protection event associated with a shuttle tube, as documented in NRC Inspection Report 2011008. The inspectors excluded these issues from this inspection due to the predecisional nature of the findings.

b. Assessments

1. Assessment - Effectiveness of Problem Identification

The inspectors concluded that the licensee identified conditions adverse to quality and entered them into the corrective action program in accordance with the licensee's corrective action program guidance and NRC requirements.

During the inspection, the inspectors observed that the licensee identified problems at a low threshold. However, NRC Inspection Report 2011002, Section 4OA2, documented a programmatic weakness associated with failure to initiate condition reports. This was evidenced by multiple examples of failure to initiate condition reports over several years with ineffective programmatic corrective actions by the licensee.

2. Assessment - Effectiveness of Prioritization and Evaluation of Issues The inspectors concluded that generally, the licensee effectively evaluated problems. However, the inspectors determined that there were two indications of weak evaluations during this assessment period. Specifically, the inspectors identified five inadequate operability evaluations, and the inspectors identified multiple examples of evaluations that were not thorough. The inspectors noted that the previous Problem Identification and Resolution inspection report, NRC Inspection Report 2009007, also documented weaknesses in operability evaluations and that some root causes that were not thorough. Therefore, the inspectors considered the weaknesses in operability evaluations and thorough evaluations to be repetitive weaknesses that the licensee had not corrected.

Inadequate Operability Evaluations

• In Condition Report 2011-06686, the licensee documented that springs had been installed on both diesel generator fuel racks, which had not been evaluated as a modification. The inspectors identified during the inspection that the licensee had failed to include the moment arm in the calculation of torque on the fuel rack. The licensee updated the operability evaluation and concluded that both diesel generators were operable because the torque applied by the spring was less than allowable.

• In Condition Report 2010-08960, the licensee determined that the control room handswitch for RHR-MOV-27A, residual heat removal loop A injection outboard throttle valve, was experiencing an intermittent failure. However, the station declared the valve operable because the valve had passed troubleshooting and post maintenance testing. The inspectors challenged the licensee's operability determination because the cause evaluation did not match the operability statement in that the cause of the intermittent failure had not been corrected, affecting the reliability of the valve to reposition by manipulating the handswitch. The licensee updated the operability evaluation to include the safety function of the valve, which only included automatic repositioning. The handswitch does not affect the automatic repositioning; therefore, the valve was operable.

• In Condition Report 2009-09486, the licensee documented a water hammer event in the reactor coolant system. The licensee identified that the event was a repeat of an event in 1994. However, the inspectors identified that the licensee had failed to evaluate or act on the operability concern raised in 1994. Specifically, General Electric recommended that the licensee test the low pressure coolant injection check valve to ensure that it was not damaged by the water hammer. The inspectors found that the licensee had restarted the plant following the 2009 water hammer without evaluating or testing the check valve. However, the valve passed an unrelated scheduled surveillance in 2011. Therefore, the valve was operable.

• In Condition Report 2011-04689, operations personnel documented an initial operability determination for a low oil level in a service water booster pump. However, the inspectors identified that the licensee failed to include the level trend and mission time for the pump in the evaluation. The licensee determined that the pump was inoperable on April 27, 2011, after revising the operability determination due to the inspectors' questions.

• In Condition Report 2010-02213, the licensee documented the failure of a service water zurn strainer. However, the inspectors identified that the licensee inappropriately credited manual actions for operability. This resulted in the licensee failing to submit an event report to the NRC, as documented in Section 4OA2.5b of this report.

Evaluations That Were Not Thorough

• The inspectors identified four examples of the licensee's failure to promptly identify and correct conditions adverse to quality that were associated with evaluations that were not thorough. Specifically, the licensee failed to identify and correct excessive setpoint drift of reactor core isolation cooling system pressure switches, determine and correct the leak path of oil from a service water booster pump, failed to identify and correct a vulnerability that allowed non-quality controlled material to be installed in safety related applications, and failed to identify and correct the cause of a malfunction of a high pressure coolant injection steam line high flow instrument. See Section 4OA2.5a of this report for more details.

• The inspectors identified that the licensee revised a residual heat removal pump motor cable sizing calculation to a smaller sized cable without a change evaluation. See Section 4OA2.5c of this report for more details.

• In NRC Inspection Report 2009008, inspectors documented that the licensee incorrectly concluded that a diesel generator lube oil piping failure was caused by four overstress events. However, two independent laboratories concluded that the cause was high cycle fatigue. The licensee's evaluation was not thorough, which resulted in ineffective corrective actions and an additional failure of the diesel generator.

• In NRC Inspection Report 2009005, inspectors documented a self-revealing failure of a diesel generator due to loose fasteners on the mechanical overspeed governor drive flange. The licensee's root cause found that personnel had failed to identify a trend of oil leaks and other loose fasteners as a symptom of generic fastener relaxation on the engines.

3. Assessment - Effectiveness of Corrective Action Program The inspectors concluded that actions to correct problems were generally effective.

However, the inspectors identified multiple examples of ineffective corrective actions, as seen below. In addition, the inspectors noted that the NRC had documented three cited violations due to ineffective or untimely corrective actions associated with NRC documented findings within the past two years, including the cited violation in this report. Therefore, the inspectors considered that the licensee had a weakness in ensuring effective corrective actions.

• Condition Report 2010-05972 was initiated August 19, 2010, because maintenance personnel had blocked open the steam exclusion barrier door for the emergency diesel generators without taking the appropriate compensatory measures. The licensee determined that this issue represented a significant condition adverse to quality, and had developed and implemented actions to prevent recurrence of this issue. Subsequently, the inspectors identified that maintenance personnel had again disabled a hazard barrier, the steam exclusion barrier doors for the control room, without taking the appropriate compensatory measures, as documented in Condition Report 2010-09639, and Condition Report 2011-00684. The inspectors determined that this was a recurrence of a significant condition adverse to quality because of ineffective corrective actions.

• The inspectors identified that the licensee revised a residual heat removal pump motor cable sizing calculation to a smaller sized cable in response to an NRC finding documented in NRC Inspection Report 2010007. However, the licensee failed to perform a change evaluation for the calculation change. Therefore, while the licensee's actions corrected the compliance issue, the corrective actions were not fully effective.

See Section 4OA2.5c of this report for more details.

• The inspectors identified that the licensee took no effective corrective action after determining that an interim corrective action to prevent recurrence was ineffective. Specifically, after the licensee identified that the craft lacked sufficient knowledge on the Risk Release for Maintenance process in a root cause evaluation, the licensee provided training as corrective action to prevent recurrence. However, the licensee identified that the training was ineffective and took no other interim effective corrective action. See Section 4OA2.5d of this report for more details.

• The inspectors identified that the licensee failed to justify that the diesel generator fuel oil day tanks would be available following a tornado missile strike on the tank vents. The violation was cited because the licensee failed to restore compliance in a reasonable time following documentation of the issue as a noncited violation in NRC Inspection Report 2010007. See Section 4OA2.5e of this report for more details.

• In NRC Inspection Report 2010004, inspectors documented a self-revealing finding for a breaker fire due to ineffective corrective actions. The same breaker had a fire the previous year, but the licensee failed to implement measurable and reasonable corrective actions.

• In NRC Inspection Report 2010007, inspectors documented a failure to correct conditions adverse to quality involving three examples of inadequate installation and testing of safety-related batteries.

• In NRC Inspection Report 2011002, inspectors documented a cited violation for the repetitive failure to correctly assess and manage the risk to offsite power equipment during nearby work with heavy equipment as required by 10 CFR 50.65(a)(4).

• In NRC Inspection Report 2010005, inspectors documented a cited violation for the failure to promptly correct a licensee identified violation involving inappropriately extending protective action recommendations when the wind changed direction.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors examined the licensee's program for reviewing industry operating experience, including reviewing the governing procedure and self-assessments. The inspectors reviewed a sample of industry operating experience evaluations to assess whether the licensee had appropriately evaluated the notifications for relevance to the facility. The inspectors also reviewed assigned actions to address the applicable operating experience to ensure they were appropriate. The inspectors reviewed a sample of root and apparent cause evaluations to ensure that the licensee had appropriately included industry operating experience.

b. Assessment The inspectors concluded that the licensee adequately evaluated industry operating experience for relevance to the facility and appropriately entered applicable operating experience, including causal evaluations, into the corrective action program.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of licensee self-assessments and audits to assess whether the licensee was regularly identifying performance trends and effectively addressing them. The inspectors sampled self-assessments and audits in several different areas of the licensee's organization.

b. Assessment The inspectors concluded that the licensee's self-assessment process was effective. The licensee had recently taken action to revise the self-assessment process to achieve better results. In addition, appropriate management attention was given to self-assessments and audits. Self-assessments and audits included personnel from outside organizations. Self-assessments and audits were determined to be critical.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The inspectors conducted individual interviews with twenty individuals. The interviewees represented various functional organizations and included contractor, staff, and supervisor levels. The inspectors conducted these interviews to assess whether conditions existed that would challenge the establishment of a safety conscious work environment.

b. Assessment The inspectors concluded that the licensee maintained a safety conscious work environment. The individuals interviewed were aware of, and indicated that they were willing to use the various ways to bring problems to management's attention without fear of retaliation.

.5 Specific Issues Identified During This Inspection

a. Failure to Promptly Identify and Correct Conditions Adverse to Quality

Introduction.

The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," associated with four examples of the licensee's failure to promptly identify and correct conditions adverse to quality. Specifically, the licensee failed to identify and correct excessive setpoint drift of reactor core isolation cooling system pressure switches, the leak of oil from the service water booster pump, a vulnerability that allowed non-quality controlled material to be installed in safety related applications, and the cause of a failure of the high pressure coolant injection steam line high flow instrument.

Description.

The inspectors identified four examples of a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," associated with the licensee's failure to promptly identify and correct conditions adverse to quality.

Example 1) The inspectors reviewed Condition Report 2009-01756, which had been initiated on March 5, 2009, to document that pressure switch RCIC-PS-87D was found out of technical specification allowed tolerance while the licensee was performing a surveillance test of the steam supply pressure monitors for the reactor core isolation cooling system. The licensee performed an apparent cause evaluation to determine why the switch had gone outside of its allowed tolerance band. Through this evaluation, the licensee determined that the mechanistic cause was set point drift. The licensee identified the apparent cause as inadequate set point monitoring during quarterly functional testing which allowed the set point to drift beyond the technical specification limit. The licensee replaced the switch and calibrated the replacement switch in accordance with the set point calculation.

The inspectors questioned the identified apparent cause. Specifically, the inspectors noted that the calculation that had established the set point for the switch also accounted for worse case drift. In doing this, the licensee incorporated a margin to ensure that the switch would not be outside of the technical specification limit. As such, the inspectors determined that the identified mechanistic cause was correct, but the identified apparent cause was incorrect. Therefore, the corrective actions were inadequate and subsequently, switch RCIC-PS-87D was found outside of its technical specification allowed tolerance during another surveillance test on December 7, 2009.

The licensee initiated Condition Report 2011-07060 to capture this issue in the corrective action program.

The inspectors noted that the licensee has since replaced this style pressure switch in the reactor core isolation cooling system with a switch of a different design.

Example 2) The inspectors reviewed Condition Report 2009-03602, which had been initiated because on May 7, 2009, the licensee identified that the B service water booster pump's inboard bearing oil level was below the level required for it to be considered operable. The licensee classified this condition report as a Category C, "broke-fix" issue, and assigned it to the operations department to address the issue of operators failing to recognize that the level in the bearing was below the operability limit. This classification required operations to do a fix evaluation. Based on their evaluation, operations determined that the cause of the issue was a lack of operations personnel knowledge on the required oil level.

Operations personnel documented that the oil had been drained and refilled one week prior to being discovered below the operability limit (2 3/4 of an inch below the reference mark). Prior to a post maintenance pump run, oil level was a "bubble" below the maximum startup level (2 3/16 of an inch below the reference mark). Operations personnel had noted that the oil level eventually leveled off near the minimum startup oil level (2 3/8 of an inch below the reference mark) following the pump run and cool down period. Subsequently, on May 7, 2009, the oil level was below the operability limit. The inspectors determined that the operations department evaluation sufficiently addressed the personnel knowledge issue, however, the cause of the oil level lowering was not identified or corrected.

The licensee initiated Condition Report 2011-07105 to capture this issue in the corrective action program.

Example 3) The inspectors reviewed Condition Report 2010-02123, which had been initiated because on March 23, 2010, when planning a safety related engineering package, the planner noted that one of the items specified for use, electrical lugs, were not safety related. Further investigation revealed that these lugs were listed as non-essential in the material control program; however, they were listed as safety related in the engineering package list of materials. Through subsequent reviews of previous packages to determine if these lugs had been installed in the plant, the planner determined that these same lugs had been incorrectly installed in the plant in safety related applications. Specifically, they had been installed in three service water booster pump closing circuitries. The licensee classified this condition report as a Category C, "broke-fix" issue, and assigned it to the work control group. This classification required the work control group to do a fix evaluation. Based on their evaluation, the work control group determined that two actions needed to be taken; 1) replace the non-safety related materials installed in the service water booster pumps, and 2) remove the non-safety related material from the warehouse.

During the inspectors' review of this fix evaluation they noted that while the licensee had taken action to ensure that the material could not be installed in the plant again, they had not taken action to determine how non-safety related material had been designated for use in a safety related application in four safety related work orders. Therefore, the inspectors determined that the licensee had failed to promptly identify and correct a condition adverse to quality. The inspectors also noted that subsequently, the licensee had identified more instances where non-safety related materials had been designated for use in safety related applications through safety related work orders.

The licensee initiated Condition Report 2011-07151 to capture this issue in the corrective action program.

Example 4) The inspectors reviewed Condition Report 2010-07390, which had been initiated because on October 6, 2010, during the licensee's performance of surveillance testing of the high pressure coolant injection steam line high flow pressure instrument, HPCI-DPIS-77, it was found to be out of its technical specification allowed tolerance. The licensee performed an apparent cause evaluation to determine why the switch had gone outside of its allowed tolerance band. Based on their evaluation, the licensee determined that the apparent cause of this issue was the unavailability of spare parts necessitated an in-field repair.

The inspectors questioned the identified apparent cause. Specifically, during their review the inspectors noted that one month prior to the failure, HPCI-DPIS-77 had been taken out of service to replace two internal switch assemblies. This was done as part of the extent of condition actions resulting from the failure of a similar instrument. During the replacement of the switches, technicians broke a mounting post for the micro switches. Due to the unavailability of a complete spare instrument, the licensee had determined that the only option was to perform an in-field repair (i.e., replacing internal parts to fix the broken mounting post). An in-field repair required the technicians to perform a full disassembly and removal of the internal mechanism of the switch. During the alignment and calibration per station procedure, the technicians had difficulty adjusting the switches to the correct calibration tolerance, but after several hours of alignment and adjustment technicians were able to get the switches calibrated to the tolerance specified in the procedure.

The inspectors determined that the licensee considered an in-field repair acceptable, and that if done correctly, it would have corrected the condition. The inspectors determined that the inadequate in-field repair caused the misalignment of the mechanical components in the switch, which caused the failure to meet the surveillance requirement. Therefore, the inspectors determined that the licensee's conclusion in the apparent cause was incorrect.

The licensee initiated Condition Report 2011-06653 to capture this issue in the corrective action program.

These examples demonstrate the licensee's failure to have a low threshold for documenting additional issues in the corrective action program when evaluating existing conditions.

Analysis.

The failure to promptly identify and correct conditions adverse to quality was a performance deficiency. The performance deficiency was determined to be more than minor because if left uncorrected, the licensee's continued failure to promptly identify and correct conditions adverse to quality could result in more risk significant equipment being inoperable, and is therefore a finding. This finding affected the Mitigating Systems Cornerstone. Using Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," the finding was determined to have very low safety significance because the finding:

(1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality;

(2) did not represent an actual loss of safety function of the system or train;

(3) did not result in the loss of one or more trains of nontechnical specification equipment; and

(4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined the cause of the finding through interviews and document reviews. The finding was determined to have a crosscutting aspect in the area of problem identification and resolution, associated with the corrective action program component, in that, the licensee failed to implement a corrective action program with a low threshold for identifying issues; issues are identified completely, accurately and in a timely manner commensurate with their safety significance P.1(a).

Enforcement.

Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that "Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected." Contrary to the above, between March 5, 2009, and October 6, 2010, the licensee failed to promptly identify and correct conditions adverse to quality. Because this finding is of very low safety significance and has been entered into the corrective action program as Condition Reports 2011-07060, 2011-06653, 2011-07105, and 2011-07151, this violation is being treated as a noncited violation consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000298/2011006-01, "Failure to Promptly Identify and Correct Conditions Adverse to Quality." b. Failure to Report Conditions Prohibited by Technical Specifications and Safety System Functional Failures

Introduction.

The inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73, "Licensee Event Report System," associated with the licensee's failure to submit a licensee event report within 60 days following discovery of an event meeting the reportability criteria as specified. Specifically, a condition prohibited by technical specifications occurred when a zurn strainer failure rendered the service water system inoperable for longer than the action statement and would have prevented fulfillment of a safety function.

Description.

On May 14, 2010, the licensee completed a root cause evaluation of a component failure associated with the train A service water zurn strainer wiper arm motor-to-gear box coupling, which had occurred on March 27, 2010, and was documented in Condition Report 2010-02213. This failure resulted in the strainer motor not being able to perform its function of rotating the wiper arm for backwash, an essential function required for Technical Specification 3.7.2, Service Water System and Ultimate Heat Sink. The licensee's evaluation concluded that the failure was due to an inadequate design of the reduction gear to motor shaft. Through review of previous maintenance documents and condition reports, the licensee determined that this issue had existed since initial installation of the system.

The inspectors noted that the licensee had performed an operability evaluation at the time of the failure and determined the equipment was operable because manual actions could be taken to rotate the strainer for backwash functions. As such, the inspectors noted that when licensing personnel reviewed this issue for potential reportability they noted that this event was not reportable because the equipment was operable.

The inspectors questioned the operability position taken by the licensee. Specifically, while the strainer essential function could be performed by way of manual actions, this did not meet the station technical specification definition of operable:

"A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s), and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s)."

The identified condition appeared to meet the definition of operable with compensatory measures required, as defined by station procedure EN-OP-104:

"OPERABLE-COM MEAS is a PCRS Flag for Continued Operability/Functionality based on an evaluation following an initial screening of Operable/Functional-Judgment or Inoperable. It is a category of identifying and tracking degraded or nonconforming conditions that represent a challenge to the Operability/Functionality of an SSC such that additional measures have to be taken to maintain or assure Operability/Functionality. Additional measures may involve compensatory measures, operational restraints (i.e., startup restraints, time limits, MODE change restrictions, and weather changes), further analysis, or a change to the licensing bases (i.e., CLB change)."

As such, the inspectors concluded that the strainer had in fact been inoperable prior to this event, and the licensee had operated the service water system in a condition prohibited by technical specifications. Furthermore, through reviews and discussions with licensee personnel, the inspectors determined that prior maintenance activities conducted by the licensee had allowed the B train of service water to be taken out of service while the affected A train of service water was credited as operable. The inspectors determined that these activities resulted in a condition that prevented the service water system from performing its safety function. The licensee initiated Condition Report 2011-06778 to capture this issue in the station's corrective action program.

The inspectors determined that the licensee failed to appropriately and thoroughly evaluate for reportability aspects all factors associated with the equipment failure.

Analysis.

The failure to submit a required licensee event report within 60 days after discovery of an event or condition requiring a report to the NRC was a performance deficiency. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC's regulatory ability was affected. Specifically, the NRC relies on the licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function; and when this is not done, the regulatory function is impacted. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was a violation determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program. Therefore, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. The inspectors determined the cause of the finding through interviews and document reviews. This finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action component, in that, the licensee failed to appropriately and thoroughly evaluate for reportability aspects all factors associated with the equipment failure P.1(c).

Enforcement.

Title 10 CFR 50.73(a)(1) requires, in part, that licensees shall submit a licensee event report for any event of the type described in this paragraph within 60 days after the discovery of the event. Title 10 CFR 50.73(a)(2)(i)(B) requires, in part, that the licensee report any operation or condition prohibited by the plant's technical specification, and Title 10 CFR 50.73(a)(2)(v) requires, in part, that the licensee report any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to

• Shutdown the reactor and maintain it in a safe condition

• Remove residual heat

• Control the release of radioactive material

• Mitigate the consequences of an accident Contrary to the above, it was determined that the service water system had been operated in a condition prohibited by technical specifications due to a design inadequacy, and the licensee failed to correctly report this inadequacy that could have prevented the fulfillment of its safety function during past maintenance activities. This finding was determined to be applicable to traditional enforcement because the failure to report conditions or events meeting the criteria specified in regulations affects the NRC's regulatory ability. The finding was evaluated in accordance with the NRC's Enforcement Policy. The finding was a violation of very low safety significance, was not repetitive or willful, and was entered into the corrective action program. This violation is being treated as a Severity Level IV noncited violation, consistent with the NRC Enforcement Policy: 05000298/2011006-02, "Failure to Report Conditions Prohibited by Technical Specifications and Safety System Functional Failures."

c. Failure to Perform 10 CFR 50.59 Evaluation for Design Change

Introduction.

The inspectors identified a Severity Level IV noncited violation of 10 CFR 50.59, "Changes, Tests, and Experiments," associated with the failure to adequately evaluate a change in order to ensure that it did not require prior NRC approval. Specifically, the licensee revised a residual heat removal pump motor cable sizing calculation to a smaller sized cable without a change evaluation.

Description.

During an NRC component design basis inspection, inspectors identified that the licensee had changed residual heat removal pump motor cables from 4/0 to 2/0 power cables without adequate technical justification in the design basis calculations. The inspection finding was documented in NRC Inspection Report 2010007 and the licensee documented the concern in Condition Report 2010-05522. In order to resolve the problem, the licensee performed a calculation documented in NEDC-10-075 to justify the design change. In processing the corrective action and calculation change, the licensee did not perform an evaluation in accordance with 10 CFR 50.59 to ensure that the change did not require prior NRC approval. The inspectors determined that it was not immediately clear if it would have required prior NRC approval. The licensee entered the issue in the corrective action program as Condition Report 2011-07130.

The inspectors determined that the licensee failed to thoroughly evaluate the factors associated with the design change.

Analysis.

The inspectors determined that the failure to perform a 10 CFR 50.59 evaluation for design change calculation NEDC-10-075 was a performance deficiency. The finding was determined to be more than minor because the licensee failed to perform a 10 CFR 50.59 evaluation when required. Specifically, the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done the regulatory function is impacted, and is therefore more than minor. Violations of 10 CFR 50.59 are considered to impede or impact the regulatory process, so they are dispositioned using the traditional enforcement process. The enforcement manual specifies that the severity level is determined in parallel with the Significance Determination Process (SDP). The inspectors performed a Phase 1 screening in accordance with Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," and determined that the finding was of very low safety significance (Green) because the finding:

(1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality;

(2) did not represent an actual loss of safety function of the system or train;

(3) did not result in the loss of one or more trains of nontechnical specification equipment; and

(4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. Therefore, the inspectors categorized the finding as Severity Level IV in accordance with the enforcement manual. The finding was a violation determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program. Therefore, this violation is being treated as a noncited violation consistent with the NRC Enforcement Policy. The inspectors determined the cause of the finding through interviews and document reviews. This finding was determined to have a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program in that the licensee failed to appropriately and thoroughly evaluate all factors associated with the design change P.1(c).

Enforcement.

Title 10 CFR 50.59, "Changes, Tests, and Experiments," Section (c)(1)(i) states, in part, that a licensee may make changes in the facility as described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to 10 CFR 50.90 only if the change, test, or experiment does not meet any of the criteria in paragraph (c)(2). Paragraph (c)(2) states, in part, "a licensee shall obtain a license amendment pursuant to Section 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would:

• Result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the final safety analysis report (as updated);

• Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the final safety analysis report (as updated);

• Result in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report (as updated);

• Result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated);

• Create a possibility for an accident of a different type than any previously evaluated in the final safety analysis report (as updated);

• Create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated);

• Result in a design basis limit for a fission product barrier as described in the FSAR (as updated) being exceeded or altered; or

• Result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses."

Contrary to the above, on December 27, 2010, the licensee failed to perform an evaluation that provided a bases for the determination that changing the design of RHR cable did not require a license amendment. Specifically, the licensee failed to perform a 10 CFR 50.59 evaluation for the calculation to justify the change of residual heat removal pump 1B and 1C motor power cable from 4/0 to 2/0. Because this finding is of very low safety significance and has been entered into the licensee's corrective action program as Condition Report 2011-01730, this violation is being treated as a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy: 05000289/2011006-03; "Failure to Perform 10 CFR 50.59 Evaluation for Design Change."

d. Failure to Take Action for an Ineffective Corrective Action

Introduction.

The inspectors identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the failure to correct a condition adverse to quality. Specifically, the licensee determined that an interim corrective action to prevent recurrence was ineffective, which placed the licensee in a vulnerable condition until the additional corrective actions were in place.

Description.

During root cause investigation, "Movement of the Reactor Building Crane Outside Its Operability Evaluation," documented in Condition Report 2009-03203, the licensee identified that the reactor building crane had been moved outside the allowance of station processes, causing a potential concern for equipment located under the crane. The personnel had incorrectly used the Risk Release for Maintenance process to move the crane. The licensee identified, as a root cause, that supervisory oversight and craft knowledge of the Risk Release for Maintenance process was lacking. The root cause evaluation implemented an interim corrective action to prevent recurrence in an effort to correct the lack of knowledge in the short term, as well as other long term corrective actions.

The licensee conducted a tailgate session that included a review of Procedure 3.4, "Configuration Change Control," Revision 48, with an emphasis on Risk Release for Maintenance. Subsequently, the licensee also revised training material, SKL0610102, "Project Management Training," from classroom instruction to a required qualification card to ensure procedural competency.

The licensee completed a corrective action effectiveness review for the above corrective actions. The reviewer initiated Condition Report 2009-06814 to document the continuing lack of knowledge on the Risk Release for Maintenance process. The reviewer stated that this was a result of ineffective tailgate training, which manifested in continued violations of the process. The Condition Report Group administratively closed this condition report with the comment that not enough time had elapsed to perform an effectiveness review. Subsequently, a new action was assigned to perform a new corrective action effectiveness review three to six months later.

The licensee performed a second corrective action effectiveness review, documented in LO-CNSLO-2009-00004, CA-25, which also concluded that the training was ineffective. However, by this time multiple violations of the Risk Release for Maintenance process had already occurred. In addition to other less significant violations, a root cause evaluation for a digital electrical hydraulic fluid leak concluded that the Risk Release for Maintenance process was violated again. The root cause evaluation assigned additional training.

The inspectors concluded that the licensee had failed to correct the lack of knowledge of the Risk Release for Maintenance process, which allowed other violations to occur.

The licensee entered the finding into the corrective action program as Condition Report 2011-07152.

The inspectors determined that the licensee had failed to properly prioritize the condition report written for the ineffective interim corrective action to prevent recurrence, which resulted in no evaluation or corrective actions taken.

Analysis.

The licensee's failure to take action for an ineffective interim corrective action to prevent recurrence was a performance deficiency, which resulted in a vulnerability to a repetitive condition adverse to quality. The finding was determined to be more than minor because the performance deficiency could be reasonably viewed as a precursor to an event in that the interim action was not effective as a barrier to prevent recurrence of a significant event until other corrective actions were in place. The finding was associated with the Mitigating Systems Cornerstone. The inspectors performed a Phase 1 screening in accordance with Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," and determined that the finding was of very low safety significance (Green) because the finding:

(1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality;

(2) did not represent an actual loss of safety function of the system or train;

(3) did not result in the loss of one or more trains of nontechnical specification equipment; and

(4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.

The inspectors determined the cause of the finding through interviews and document reviews. The inspectors determined that this finding had a crosscutting aspect in the area of problem identification and resolution associated with corrective actions because the licensee failed to prioritize and thoroughly evaluate a condition report that documented an inadequate interim corrective action to prevent recurrence P.1(c).

Enforcement.

Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that "Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformance's are promptly identified and corrected." Contrary to the above, on September 14, 2009, the licensee failed to assure that a condition adverse to quality was promptly corrected. Specifically, the licensee failed to promptly correct an ineffective interim corrective action to prevent recurrence associated with lack of knowledge of the Risk Release for Maintenance process. Since this violation was of very low safety significance and was documented in the licensee's corrective action program as Condition Report 2011-07152, it is being treated as a noncited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000298/2011006-04, "Failure to Take Action for an Ineffective Corrective Action." e. Failure to Correctly Translate Design Requirements into Installed Plant Configuration

Introduction.

The inspectors identified a Green cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to assure that the applicable design basis for applicable structures, systems, and components were correctly translated into specifications, procedures, and instructions. Specifically, the licensee failed to justify through evaluation that the diesel generator fuel oil day tanks would be available following a tornado missile strike on the tank vents. The violation is cited because the licensee failed to restore compliance in a reasonable time following documentation of the issue as a noncited violation in NRC Inspection Report 2010007 (issued December 3, 2010).

Description.

During an NRC component design basis inspection in July 2009, an issue was identified associated with the emergency diesel generator day tank vent lines. Specifically, the inspectors determined that the licensee did not have a design basis calculation to show that the fuel oil day tanks would be available following a tornado or high wind impact event on the day tank vent lines. The licensee entered this issue into their corrective action program as Condition Report 2010-05350. This issue was documented as a noncited violation,05000298/2010007-04, for the licensee's failure to demonstrate that the design basis requirements were being met.

As a result of this condition report, corrective action 2 was generated which directed the station to perform a formal analysis of the diesel generator day tank vent lines pertaining to missile protection, and generate additional corrective actions if required. Station calculation NEDC 10-070, "Emergency Diesel Day Tank Vent Survival Subsequent to a Tornado Strike Sealing the Vents," Revision 0 dated November 30, 2010, was generated in response to this corrective action. With this, corrective action 2 was closed on December 14, 2010, and Condition Report 2010-05350 was closed on December 28, 2010.

On June 9, 2011, the inspectors reviewed the licensee's corrective actions from the previous noncited violation. During this review, the inspectors noted that station calculation NEDC 10-070 contained several assumptions that appeared to be non-conservative and could have an effect on the outcome of the calculation. The inspectors informed the licensee of this concern, and the licensee entered this issue into the corrective action program as Condition Report 2011-06655.

During subsequent re-analysis of NEDC 10-070, the licensee determined that it could not validate the assumptions that had been used without extensive engineering analysis. The licensee initiated Condition Report 2011-07064 to capture this issue. The licensee documented a reasonable justification of continued operation using engineering judgment, pending further analysis to validate their assumptions and establish a design basis for the emergency diesel generator fuel oil day tank vent lines relative to tornado and high wind impacts.

As such, the inspectors determined that the licensee had failed to restore compliance within a reasonable time after the previous noncited violation was identified on December 3, 2010.

Analysis.

The inspectors determined that the licensee's failure to ensure that design requirements were correctly translated into installed plant equipment was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the protection against the external factors attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," the finding was determined to have very low safety significance because the finding:

(1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality;

(2) did not represent an actual loss of safety function of the system or train;

(3) did not result in the loss of one or more trains of nontechnical specification equipment; and

(4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined the cause of the finding through interviews and document reviews. The finding was determined to have a crosscutting aspect in the area of human performance, associated with the decision making component in that the licensee failed to use conservative assumptions in decision making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate it is unsafe in order to disapprove the action H.1(b).

Enforcement.

Title 10 CFR 50, Appendix B, Criterion III, "Design Control," requires, in part, measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2 and as specified in the license application, for those components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, since December 3, 2010, the licensee failed to assure that applicable regulatory requirements and the design basis were correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to correctly translate regulatory and design basis requirements, associated with tornado and high wind generated missiles, into design information necessary to protect the emergency diesel generator fuel oil day tank vent line components. This performance deficiency was previously identified by the NRC and was documented as noncited violation 05000298/2010007-04. The inspectors determined that the licensee had failed to restore compliance within a reasonable time following issuance of this noncited violation. Therefore, this violation is being cited, consistent with the NRC Enforcement Policy, Section 2.3.2, which states, in part, that a cited violation will be considered if the licensee fails to restore compliance within a reasonable time after a violation is identified: VIO 05000298/2011006-05, "Failure to Correctly Translate Design Requirements into Installed Plant Configuration."

4OA6 Meetings

Exit Meeting Summary

On June 24, 2011, the inspectors presented the inspection results to B. O'Grady, and other members of the licensee staff. The licensee's management initially questioned the characterization of several findings presented. After further telephonic discussions, the licensee's management acknowledged the issues presented. The inspector asked the licensee's management whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

/Enclosure 2

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

L. Dewhirst, Manager, Corrective Action and Assessments

J. Flaherty, Licensing Engineer

A. Zaremba, Director of Nuclear Safety Assurance

NRC Personnel

D. Powers, Acting Chief, Technical Support Branch

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened

05000298/2011006-05

VIO Failure to Correctly Translate Design Requirements into Installed Plant Configuration (Section 4OA2.5e)

Opened and Closed

05000298/2011006-01

NCV Failure to Promptly Identify and Correct Conditions

Adverse to Quality (Section 4OA2.5a)

05000298/2011006-02

NCV Failure to Report Conditions Prohibited by Technical Specifications and Safety System Functional Failures (Section 4OA2.5b)

05000298/2011006-03

NCV Failure to Perform 10 CFR 50.59 Evaluation for Design Change (Section 4OA2.5c)

05000298/2011006-04

NCV Failure to Take Action for an Ineffective Corrective Action (Section 4OA2.5d)

1/Enclosure 2