IR 05000298/2013003

IR 05000298-13-003; on 03/24/2013 - 06/22/2013; Cooper Nuclear Station, Integrated Resident and Regional Report; Maintenance Risk Assessment and Emergent Work Control and Operability Evaluations and Functionality Assessments

ML13218B446
Person / Time
Site:	Cooper
Issue date:	08/06/2013
From:	Jessie Quichocho Plant Licensing Branch II
To:	Limpias O Nebraska Public Power District (NPPD)
Quichocho J
References
IR-13-003
Download: ML13218B446 (61)

Text

UNITE D S TATE S NUC LEAR RE GULATOR Y C OMMI S SI ON ust 6, 2013

SUBJECT:

COOPER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000298/2013003

Dear Mr. Limpias:

On June 22, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Cooper Nuclear Station. The enclosed inspection report documents the inspection results which were discussed on July 1, 2013, with Mr. R. Penfield, Director of Nuclear Safety Assurance, and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Two NRC identified findings of very low safety significance (Green) were identified during this inspection.

Both of these findings were determined to involve violations of NRC requirements. Additionally, two licensee-identified violations which were determined to be of very low safety significance are listed in this report. The NRC is treating these violations as non-cited violations (NCVs)

consistent with Section 2.3.2a of the Enforcement Policy.

If you contest these non-cited violations, 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 IV; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector at Cooper Nuclear Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC Resident Inspector at Cooper Nuclear Station. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Jessie Quichocho, Chief (Acting)

Projects Branch C Division of Reactor Projects Docket Nos.: 50-298 License Nos: DRP-46

Enclosure:

Inspection Report 05000298/2013003 w/ Attachment:

1. Supplemental Information 2. Information Request for inspection activities documented in 2RS5, 2RS6, 2RS7, 2RS8, and 4OA7

REGION IV==

Docket: 05000298 License: DRP-46 Report: 05000298/2013003 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: 72676 648A Ave Brownville, NE 68321 Dates: March 24, 2013 through June 22, 2013 Inspectors: J. Josey, Senior Resident Inspector C. Henderson, Resident Inspector B. Baca, Project Engineer, Technical Support Branch L. Carson II, Senior Health Physicist G. Guerra, C.H.P, Emergency Preparedness Inspector L. Ricketson, P.E., Senior Health Physicist Approved Jessie Quichocho, Chief (Acting)

By: Projects Branch C Division of Reactor Projects-1- Enclosure

SUMMARY OF FINDINGS

IR 05000298/2013003; 03/24/2013 - 06/22/2013; COOPER NUCLEAR STATION, Integrated

Resident and Regional Report; Maintenance Risk Assessment and Emergent Work Control and Operability Evaluations and Functionality Assessments.

The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by region-based inspectors. Two Green non-cited violations of significance were identified. The significance of most findings is indicated by their color (Green, White,

Yellow, or Red) using Inspection Manual Chapter 0609, Significance Determination Process.

The cross-cutting aspect is determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting Areas. 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.

Cornerstone: Mitigating Systems

Green.

The inspectors identified two examples of a non-cited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness for Maintenance at Nuclear Power Plants, for the licensees failure to adequately assess risk and implement risk management actions associated with maintenance activities affecting outflow paths that had been credited in the internal flooding analysis for a moderate-energy line break in the service water pump room. The licensees corrective actions included immediately re-evaluating the risk associated with the subject activities, implementing additional risk-management actions, and reconfiguring a drain hose associated with the activity. The licensee entered these deficiencies into their corrective action program for resolution as Condition Reports CR-CNS-2013-03813 and CR-CNS-2013-04347.

The licensees failure to adequately assess the risk and implement required risk-management actions for proposed maintenance activities was a performance deficiency. This performance deficiency was more than minor and was therefore a finding because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the associated objective.

Specifically, by failing to evaluate the risk associated with the maintenance activities, the licensee failed implement risk management actions to restrain staged tools, materials, and equipment to prevent blockage of outflow paths that had been credited in the internal-flooding analysis for a moderate-energy line break in the service water pump room. Because these outflow paths help ensure the availability of systems that respond to initiating events to prevent undesirable consequences, blockage of those paths affected that availability, and thereby affected the cornerstone objective. In accordance with Inspection Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk

Management Significance Determination Process, Flowchart 1, Assessment of Risk Deficit, the inspectors determined the need to calculate the risk deficit to determine the significance of this issue. A senior reactor analyst performed a bounding detailed risk evaluation which determined that the incremental core damage probability associated with this finding was less than 1 X 10-6, so the finding has very low safety significance (Green). The finding has a cross-cutting aspect in the area of human performance associated with the work practices component because the licensee personnel failed to define and effectively communicate expectations regarding procedural compliance and to ensure that personnel followed procedures H.4(b). (Section 1R13)

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to follow Station Procedure 0.5OPS, Operations Review of Condition Reports/Operability Determination, and properly document the basis for operability when a degraded or nonconforming condition was identified. Specifically, the inspectors identified that the licensee failed to consider all relevant information when assessing operability of service water pumps A, B, and D for the design-basis barge impact on the intake structure.

The licensee entered this deficiency into their corrective action program for resolution as Condition Report CR-CNS-2013-03850.

The failure to properly assess and document the basis for operability when a degraded or nonconforming condition was identified was a performance deficiency. This performance deficiency was more than minor and is therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective.

Specifically, the licensees failure to properly document and assess the basis for operability resulted in a condition of unknown operability for a degraded nonconforming system, thereby affecting the associated objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix A, 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 deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program. The finding has a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee did not ensure that the proposed action was safe in order to proceed, rather than unsafe in order to disapprove the action H.1(b).

(Section 1R15)

Licensee-Identified Violations

Two violations of very low safety significance, which were identified by the licensee, have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and associated corrective action tracking numbers (condition report numbers)are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Cooper Nuclear Station began the inspection period at full power on March 24, 2013. On May 19, 2013, they lowered power to approximately 90 percent to enable repairs to a circulating water pump and then returned to 100 percent power. On June 6, 2013, they lowered power to approximately 20 percent to enable repairs to main feedwater heater 4B. On June 8, 2013, they increased power to 100 percent where it remained for the rest of the reporting period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Summer Readiness for Offsite and Alternate-AC Power Systems

a. Inspection Scope

The inspectors performed a review of preparations for summer weather for selected systems, including conditions that could lead to loss-of-offsite power and conditions that could result from high temperatures. The inspectors reviewed the procedures and communications protocols affecting these areas and verified that they address measures to monitor/maintain availability and reliability of both the offsite and alternate AC power systems. Examples of aspects considered in the inspectors review included:

• The coordination between the transmission system operator and the plants operations personnel during off-normal or emergency events

• The explanations for the events

• The estimates of when the offsite power system would be returned to a normal state

• The notifications from the transmission system operator to the plant when the offsite power system was returned to normal The inspectors performed a walkdown of the switchyard with plant personnel to observe the material condition of offsite power sources. During the inspection, the inspectors focused on plant-specific design features and the procedures used by plant personnel to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant-specific procedures. The inspectors also reviewed corrective action program items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their corrective action program in accordance with station corrective action procedures. The inspectors reviews focused specifically on the following plant systems:

• May 22: Emergency station service transformer and startup transformer These activities constitute completion of one sample to evaluate the readiness of offsite and alternate-ac power for summer weather, as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

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

• May 20: the B train of service water

• June 22: main control room air conditioning units

• June 22: the A train of service water The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected, while considering out of service time, inoperable or degraded conditions, recent system outages, and maintenance, modification, and testing. The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Final Safety Analysis Report, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three partial system walkdown samples, as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

On June 22, 2013, the inspectors performed a complete system alignment inspection of the control room emergency filter system and control room envelope to verify the functional capability of the system. The inspectors selected this system based on risk-informed insights from site-specific risk studies together with other factors, such as engineering analysis and judgment, operating experience, performance history, current plant mode, and/or previous walkdowns. The inspectors reviewed plant procedures, including abnormal and emergency, drawings, the Updated Safety Analysis Report, and vendor manuals to determine the correct lineup. The inspectors also visually inspected the system to review mechanical and electrical equipment line ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, and the operability of support systems. Furthermore, the inspectors ensured that ancillary equipment or debris did not interfere with equipment operation. The inspectors also reviewed a sample of past and outstanding work orders to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment-alignment problems were being identified and appropriately resolved.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one complete system walkdown sample, as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Fire Inspection Tours

a. Inspection Scope

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

• April 4: Control room/cable spreading room interface, Fire Area VIII, Zone 9A and 10B and secondary alarm station

• April 15: Cable expansion room, Fire Area VII, Zone 9B

• May 2: Residual heat removal pump room 1B and 1D, Fire Area I, Zone 1D

• May 2: High pressure coolant injection room, Fire Area I, Zone 1E The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition and verified that adequate compensatory measures were put in place by the licensee for out of service, degraded, or inoperable fire protection equipment systems or features. The inspectors also verified that minor issues identified during the inspection were entered into the licensees corrective action program.

These activities constitute completion of four quarterly fire-protection inspection samples, as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

On May 3, 2013, the inspectors observed a fire brigade activation of a fire in the critical switchgear room. The observation evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies, openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were:

(1) proper wearing of turnout gear and self-contained breathing apparatus;

(2) proper use and layout of fire hoses;

(3) employment of appropriate fire fighting techniques;

(4) sufficient firefighting equipment brought to the scene;

(5) effectiveness of fire brigade leader communications, command, and control;

(6) search for victims and propagation of the fire into other plant areas;

(7) smoke removal operations;

(8) utilization of preplanned strategies;

(9) adherence to the preplanned drill scenario; and

(10) drill objectives.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors reviewed the Updated Final Safety Analysis Report, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding; reviewed the corrective action program to determine if licensee personnel identified and corrected flooding problems; inspected underground bunkers/manholes to verify the adequacy of sump pumps, level alarm circuits, cable splices subject to submergence, and drainage for bunkers/manholes; and verified that operator actions for coping with flooding can reasonably achieve the desired outcomes. The inspectors also inspected the area listed below to verify the adequacy of equipment seals located below the flood line, floor and wall penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, and control circuits, and temporary or removable flood barriers.

Specific documents reviewed during this inspection are listed in the attachment.

• April 17: Cable spreading room, 918 feet These activities constitute completion of one flood protection measures inspection sample, as defined in Inspection Procedure 71111.06-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Quarterly Review of Licensed Operator Requalification Program

a. Inspection Scope

On April 30, 2013, the inspectors observed a crew of licensed operators in the plants simulator during training. The inspectors assessed the following areas:

• Licensed operator performance

• The ability of the licensee to administer the evaluations and the quality of the training provided

• The modeling and performance of the control room simulator

• The quality of post-scenario critiques

• Follow-up actions taken by the licensee for identified discrepancies These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Quarterly Observation of Licensed Operator Performance

a. Inspection Scope

• April 24: 2.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> for high pressure coolant injection operations

• June 6: 1.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> for 70 percent downpower In addition, the inspectors assessed the operators adherence to plant procedures, including the conduct of operations procedure, and other operations department policies.

These activities constitute completion of one quarterly licensed-operator performance sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

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

• May 31: Control room ventilation system valves HV-AO-271 and 272

• June 22: Control room emergency filter system and control room envelope

• June 22: Main control room air conditioning and computer room east and west air conditioning units The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

• Scoping of systems in accordance with 10 CFR 50.65(b)

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

• Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)

• Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were appropriately handled by a screening and identification process and that issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three maintenance effectiveness samples, as defined in Inspection Procedure 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

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

• April 10: Diesel generator 1 limiting condition for operation maintenance window

• April 16: Diesel generator 2 magnetic pick up repair

• April 17: Severe thunderstorm warning

• May 3: Residual heat removal pump B relay replacement

• May 31: Service water valve SW-MO-37MV post-maintenance testing (Yellow risk window)

• June 13: Service water pump D and strainer B maintenance The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of six maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13-05.

b. Findings

Introduction.

The inspectors identified two examples of a Green, non-cited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the failure to adequately assess risk associated with service water pump D refurbishment and implement risk management actions for service water Division II strainer maintenance.

Description.

On May 21, 2013, the inspectors observed service water pump D refurbishment activities being conducted under Work Order 4882599. The inspectors noted several untethered items in the service water pump room that could block outflow paths that are credited in the stations internal flooding analysis for mitigating a moderate energy line break (MELB). The inspectors reviewed the risk assessment and barrier permit for the work order, and determined that the licensee had not completed a qualitative risk assessment as required by Station Procedure 0.49, Schedule Risk Assessment, Revision 33, for the potential impact on the service water pump rooms internal flooding analysis for the MELB. Additionally, Barrier Control Permit 2013-069 required by Station Procedure 0-Barrier, Barrier Control Process, Revision 3, did not address the storage of materials in the credited outflow paths for mitigating a MELB.

The licensee initiated Condition Report CR-CNS-2013-03813 to capture this issue in the stations corrective action program. The licensee also immediately removed all material staged in the service water pump room that could float or relocate to block credited outflow paths. Furthermore, the licensee conducted a qualitative risk assessment that included the potential impact on the internal flooding analysis for the service water pump room. Through that assessment, the licensee determined that additional risk-management actions were required, and revised Barrier Control Permit 2013-069 to include specific requirements to restrain staged tools, material, and equipment to prevent potential blockage of credited outflow paths.

On June 11, 2013, the inspectors observed service water Division II strainer maintenance being conducted under Work Order 4882595, which included Barrier Control Permit 2013-041. The inspectors saw that a hose was located physically within the easternmost floor drain of the service water pump room. (In the stations internal flooding analysis, this floor drain is a credited outflow path for mitigating a MELB in the service water pump room.) The inspectors noted that to manage the risks associated with the maintenance activity, Barrier Control Permit 2013-041 required that all staged tools, material, and equipment must be attended to or restrained to prevent potential blockage of credited outflow paths. In particular, it did not allow physically locating a hose within the eastern floor drain. The inspectors thus determined that locating a hose within the eastern floor drain was contrary to the risk-management actions described in the barrier control permit. The licensee initiated Condition Report CR-CNS-2013-04347 to capture this issue in the stations corrective action program. The licensee also immediately removed the subject hose and controlled it in accordance with Barrier Control Permit 2013-041. Furthermore, the licensee evaluated the operability of safety related equipment contained within the service water pump room, and determined that even with a blocked floor drain, the minimum flood heights resulting from a MELB would not impact safety related equipment.

The inspectors determined that the apparent cause of this finding was that the licensee had failed to follow Station Procedure 0.49 and Station Procedure 0-Barrier to evaluate the impact of maintenance on the service water pump rooms internal flooding analysis and to follow the requirements of a barrier control permit.

Analysis.

The licensees failure to adequately assess the risk and implement required risk management actions for proposed maintenance activities are two performance deficiencies. Each performance deficiency is more than minor, and is therefore a finding, because each is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective. Specifically,

• For the May 23, 2013 work activities, the licensees failure to evaluate the risk associated with internal flooding from a MELB resulted in developing a Barrier Control Permit that did not address the storage of materials in the credited outflow paths for mitigating a MELB, which in turn allowed workers to store materials in those outflow paths, which degraded the capability of the outflow paths.

• For the June 11, 2013, work activities, the licensees failure to restrain staged tools, materials, and equipment to prevent blockage of credited outflow paths for mitigating a MELB, resulted in workers positioning a hose within a floor drain that was credited as an outflow path, which in turn which degraded the capability of that path.

Using Inspection Manual 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, Flowchart 1, Assessment of Risk Deficit, the inspectors determined the need to calculate the risk deficit to determine the significance of this issue. Therefore, a senior reactor analyst performed a bounding detailed risk evaluation. The result was the incremental core damage probability was determined to be less than 1 X 10-6, so the finding was determined to be of very low safety significance (Green). The finding has a cross-cutting aspect in the area of human performance associated with the work practices component because the licensee personnel failed to define and effectively communicate expectations regarding procedural compliance and to ensure that personnel followed procedures H.4(b).

Enforcement.

Title 10 CFR 50.65(a)(4) states, in part, that before performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Contrary to the above, the licensee failed to properly assess and manage the increase in risk that resulted from proposed maintenance activities. Specifically,

• On May 21, 2013, the licensee failed to assess risk and implement risk management actions for the impact of refurbishing service water pump D on the service water pump rooms internal flooding analysis;

• On June 11, 2013, the licensee failed to implement required risk management actions to manage the increase in on-line risk associated with service water Division II strainer maintenance.

This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensees correction action program as Condition Reports CR-CNS-2013-03813 and CR-CNS-2013 04347.

(NCV 05000298/2013003-01, Failure to Adequately Assess Risk and Implement Risk Management Actions for Proposed Maintenance)

1R15 Operability Evaluations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed the following assessments:

• April 4: Damage to essential ventilation ducting between control room and vital switchgear room

• April 17: Diesel generator 2 magnetic pick-up failure

• April 30: High pressure coolant injection relief valve compensatory measure with clogged drain

• May 3: Diesel generator keeper seal Part 21

• May 3: Mechanical problems with the pump associated with the Z2 sump

• May 23: Service water pump A, B, and D barge impact The inspectors selected these operability and functionality assessments based on the risk significance of the associated components and systems along with other factors, such as engineering analysis and judgement, operating experience, and performance history. The inspectors evaluated the technical adequacy of the evaluations to ensure technical specification operability was properly justified and to verify the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and Updated Final Safety Analysis Report to the licensees evaluations to determine whether the components or systems were operable.

Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of six operability evaluations inspection samples, as defined in Inspection Procedure 71111.15-05.

b. Findings

Introduction.

The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to perform an adequate operability determination in accordance with Station Procedure 0.5OPS, Operations Review of Condition Reports/Operability Determination.

Description.

The inspectors selected Condition Report CR-CNS-2012-05937 for review based on its risk significance and previously identified issues with out-of-tolerance conditions and vendor repairs associated with the refurbishment of service water pump bowl assemblies. Specifically, the condition report documented issues associated with controlling the flange thicknesses on service water pumps A, B, and D during vendor refurbishment. It also assessed the effect of out-of-tolerance flange thicknesses on the operability of those pumps.

During their review of the operability determination, the inspectors noted that the flange thickness varied from the analyzed thickness tolerances for the associated service water pumps. The inspectors determined that the licensee had evaluated operability with respect to acceleration due to a design-basis earthquake, but they did not evaluate operability with respect to the acceleration of a design basis barge impact on the structure that houses the service water pumps. Inspectors noted that the stations design basis documented an acceleration of 0.2g due to a design-basis earthquake, and an acceleration of 3g due to a design basis barge impact. Because the acceleration due to an impact of a river barge is more limiting than the acceleration due to an earthquake, the inspectors determined that the licensees operability evaluation was not adequate to fully establish pump operability. To capture this concern in the stations corrective action program, the licensee initiated Condition Report CR-CNS-2013-03850. Also, as an immediate corrective action, the licensee completed an operability evaluation that considered the acceleration due to an impact of a river barge, and determined that the weight changes due to the out-of-tolerance flange thicknesses for the service water pumps would not appreciably change the calculated stresses.

The inspectors determined that the apparent cause of this finding was that the licensee had failed to use conservative assumptions and had failed to conduct effectiveness reviews to validate the most limiting horizontal acceleration.

Analysis.

The failure to properly assess and document the basis for operability when a nonconforming condition was identified was a performance deficiency. This performance deficiency is more than minor and therefore is a finding because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective. Specifically, the licensees failure to properly document and assess the basis for operability of a system with a nonconforming component resulted in a condition of unknown operability, which affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix A, 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 deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality;

(2) did not represent a loss of system and/or function;

(3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and

(4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program. The finding has a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee did not use conservative assumptions in decision-making and did not conduct effectiveness reviews to verify the validity of underlying assumptions.

H.1(b).

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V requires, in part, that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings, of a type appropriate to the circumstances.

Station Procedure 0.5OPS, Operations Review of Condition Reports/Operability Determination, a procedure that is appropriate to the circumstances of evaluating the operability of safety-related components, required the licensee to properly assess and document the basis for operability when a degraded or nonconforming condition is identified. Contrary to the above, an activity affecting quality was not accomplished in accordance with a procedure that was appropriate to the circumstances. Specifically, on or about September 10, 2012, when the licensee evaluated the operability of service water pumps on which the flange thicknesses were out-of-tolerance, the licensee did not properly assess and document the basis for operability, in that in their seismic evaluation, they did not consider the horizontal acceleration of those pumps due to a barge impact on the structure that houses the pumps. This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensees correction action program as Condition Report CR-CNS-2013-03850. (NCV 05000298/2013003-02, Failure to Follow Operability Procedure)

1R18 Plant Modifications

Permanent Modifications

a. Inspection Scope

The inspectors reviewed key affected parameters associated with energy needs, materials, replacement components, timing, heat removal, control signals, equipment protection from hazards, operations, flow paths, pressure boundary, ventilation boundary, structural, process medium properties, licensing basis, and failure modes for the permanent modifications listed below.

• April 8: Bolt replacement for lube oil header to diesel generator 2 turbo support bracket mounting

• June 22: Removal of heater bay steam leak detection switches for Group 1 primary containment isolation system The inspectors verified that modification preparation, staging, and implementation did not impair emergency/abnormal operating procedure actions, key safety functions, or operator response to loss of key safety functions; postmodification testing will maintain the plant in a safe configuration during testing by verifying that unintended system interactions will not occur; systems, structures and components performance characteristics still meet the design basis; the modification design assumptions were appropriate; the modification test acceptance criteria will be met; and licensee personnel identified and implemented appropriate corrective actions associated with permanent plant modifications. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of two samples for permanent plant modifications, as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

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

• April 15: Diesel generator 1 limiting condition for operation maintenance window

• April 18: Diesel generator 2 magnetic pick up repair

• April 30: Modification to service water valves SW-MO-651MV and REC-MO-714MV associated with 10 CFR 50, Appendix R

• May 3: Residual heat removal pump B auxillary relay replacement

• May 24: Modification to service water valves SW-MOV-37MV associated with 10 CFR 50, Appendix R

• May 29: Refurbishment of control room ventilation valve HV-AO-271AV The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following (as applicable):

• The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed

• Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate The inspectors evaluated the activities against the technical specifications, the Updated Final Safety Analysis Report, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of six post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors selected risk-significant surveillance activities based on risk information and reviewed the Updated Final Safety Analysis Report, procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME Code requirements

• Updating of performance indicator data

• Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct

• Reference setting data

• Annunciators and alarms setpoints The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

• April 4: Reactor coolant system leak detection

• April 24: Division II core spray and residual heat removal pump discharge permissive channel functional test

• April 30: Reactor equipment cooling motor-operated valves SW-MO-651MV and REC-MO-714MV in-service testing

• May 3: Reactor core isolation cooling inservice test and quarterly surveillance

• June 12: Reactor coolant system specific activity sample

• June 22: Core spray pump A inservice testing Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of six surveillance testing inspection samples, as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on May 7, 2013, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the control room and the emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package.

These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

.2 Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on May 1, 2013, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the postevolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package.

These activities constitute completion of one training observation sample, as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

This area was inspected to verify the licensee is assuring the accuracy and operability of radiation monitoring instruments that are used to:

(1) monitor areas, materials, and workers to ensure a radiologically safe work environment; and

(2) detect and quantify radioactive process streams and effluent releases. The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensees procedures required by technical specifications as criteria for determining compliance.

During the inspection, the inspectors interviewed licensee personnel, performed walkdowns of various portions of the plant, and reviewed the following items:

• Selected plant configurations and alignments of process, postaccident, and effluent monitors with descriptions in the Final Safety Analysis Report and the offsite dose calculation manual

• Select instrumentation, including effluent monitoring instrument, portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks

• Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, postaccident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, continuous air monitors

• Audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.05-05.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

This area was inspected to:

(1) ensure the gaseous and liquid effluent processing systems are maintained so radiological discharges are properly mitigated, monitored, and evaluated with respect to public exposure;

(2) ensure abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, are controlled in accordance with the applicable regulatory requirements and licensee procedures;

(3) verify the licensees quality control program ensures the radioactive effluent sampling and analysis requirements are satisfied so discharges of radioactive materials are adequately quantified and evaluated; and

(4) verify the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors used the requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190, the Offsite Dose Calculation Manual, and licensee procedures required by the Technical Specifications as criteria for determining compliance. The inspectors interviewed licensee personnel and reviewed and/or observed the following items:

• Radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection, if any

• Effluent program implementing procedures, including sampling, monitor setpoint determinations and dose calculations

• Equipment configuration and flow paths of selected gaseous and liquid discharge system components, filtered ventilation system material condition, and significant changes to their effluent release points, if any, and associated 10 CFR 50.59 reviews

• Selected portions of the routine processing and discharge of radioactive gaseous and liquid effluents (including sample collection and analysis)

• Controls used to ensure representative sampling and appropriate compensatory sampling

• Results of the inter-laboratory comparison program

• Effluent stack flow rates

• Surveillance test results of technical specification-required ventilation effluent discharge systems since the previous inspection

• Significant changes in reported dose values, if any

• A selection of radioactive liquid and gaseous waste discharge permits

• Part 61 analyses and methods used to determine which isotopes are included in the source term

• Offsite dose calculation manual changes, if any

• Meteorological dispersion and deposition factors

• Latest land use census

• Records of abnormal gaseous or liquid tank discharges, if any

• Groundwater monitoring results

• Changes to the licensees written program for indentifying and controlling contaminated spills/leaks to groundwater, if any

• Identified leakage or spill events and entries made into 10 CFR 50.75(g) records, if any, and associated evaluations of the extent of the contamination and the radiological source term

• Offsite notifications and reports of events associated with spills, leaks, or groundwater monitoring results, if any

• Audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample, as defined in Inspection Procedure 71124.06-05.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

a. Inspection Scope

This area was inspected to:

(1) ensure that the radiological environmental monitoring program verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program;

(2) verify that the radiological environmental monitoring program is implemented consistent with the licensees technical specifications and/or offsite dose calculation manual, and to validate that the radioactive effluent release program meets the design objective contained in Appendix I to 10 CFR Part 50; and

(3) ensure that the radiological environmental monitoring program monitors non-effluent exposure pathways, is based on sound principles and assumptions, and validates that doses to members of the public are within the dose limits of 10 CFR Part 20 and 40 CFR Part 190, as applicable. The inspectors reviewed and/or observed the following items:

• Annual environmental monitoring reports and offsite dose calculation manual

• Selected air sampling and thermoluminescence dosimeter monitoring stations

• Collection and preparation of environmental samples

• Operability, calibration, and maintenance of meteorological instruments

• Selected events documented in the annual environmental monitoring report which involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement

• Selected structures, systems, or components that may contain licensed material and has a credible mechanism for licensed material to reach ground water

• Records required by 10 CFR 50.75(g)

• Significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census or sampler station modifications since the last inspection

• Calibration and maintenance records for selected air samplers and environmental sample radiation measurement instrumentation

• Inter-laboratory comparison program results

• Audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.07-05.

b. Findings

No findings were identified.

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

and Transportation (71124.08)

a. Inspection Scope

This area was inspected to verify the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors used the requirements of 10 CFR Parts 20, 61, and 71 and Department of Transportation regulations contained in 49 CFR Parts 171-180 for determining compliance. The inspectors interviewed licensee personnel and reviewed the following items:

• The solid radioactive waste system description, process control program, and the scope of the licensees audit program

• Control of radioactive waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition

• Changes to the liquid and solid waste processing system configuration including a review of waste processing equipment that is not operational or abandoned in place

• Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides

• Processes for waste classification including use of scaling factors and 10 CFR Part 61 analysis

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest

• Audits, self-assessments, reports, and corrective action reports radioactive solid waste processing, and radioactive material handling, storage, and transportation performed since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.08-05.

b. Findings

No findings were identified.

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the licensee for the first quarter 2013 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, Performance Indicator Program.

b. Findings

No finding identified.

.2 Safety System Functional Failures (MS05)

a. Inspection Scope

The inspectors sampled licensee submittals for the safety system functional failures performance indicator for the period from the third quarter 2012 through the second quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73." The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and NRC integrated inspection reports for the period of July 2012 through June 2013, to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.

These activities constitute completion of one safety system functional failures sample,as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.3 Reactor Coolant System Specific Activity (BI01)

a. Inspection Scope

The inspectors sampled licensee submittals for the reactor coolant system specific activity performance indicator for the period from the third quarter 2012 through the second quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors reviewed the licensees reactor coolant system chemistry samples, technical specification requirements, issue reports, event reports, and NRC integrated inspection reports for the period of July 2012 through June 2013, to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. In addition to record reviews, the inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample.

These activities constitute completion of one reactor coolant system specific activity sample, as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.4 Reactor Coolant System Leakage (BI02)

a. Inspection Scope

The inspectors sampled licensee submittals for the reactor coolant system leakage performance indicator for the period from the third quarter 2011 through the second quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6.

The inspectors reviewed the licensees operator logs, reactor coolant system leakage tracking data, issue reports, event reports, and NRC integrated inspection reports for the period of July 2012 through June 2013, to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.

These activities constitute completion of one reactor coolant system leakage sample, as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensees corrective action program because of the inspectors observations are included in the attached list of documents reviewed.

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

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow up, the inspectors performed a daily screening of items entered into the licensees corrective action program. The inspectors accomplished this through review of the stations daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on repetitive equipment issues, but also considered the results of daily corrective action item screening discussed in Section 4OA2.2, above, licensee trending efforts, and licensee human performance results. The inspectors nominally considered the 6-month period of January 2013 through June 2013 although some examples expanded beyond those dates where the scope of the trend warranted.

The inspectors also included issues documented outside the normal corrective action program in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and Maintenance Rule assessments.

The inspectors compared and contrasted their results with the results contained in the licensees corrective action program trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.

These activities constitute completion of one single semi-annual trend inspection sample, as defined in Inspection Procedure 71152-05.

b. Findings and Observations

No findings were identified.

.4 Substantive Cross-Cutting Issues Trend Review

(1) Cross-Cutting Theme in Decision Making H.1(b)

The H.1(b) cross-cutting theme was first identified in the mid-cycle assessment letter dated September 1, 2009. Corrective actions were implemented for training to correct knowledge deficiencies and inadequate documentation to address the five non-conservative decision making events. These non-conservative assumptions were associated with flooding calculations, inadequate evaluation of emergency diesel generator electrical connections, incorrect cause evaluations of emergency diesel generator lube oil piping cracks, lack of vibration criterion for emergency diesel generator Amphenol connection vibration monitoring, and inadequate evaluation of design changes for emergency diesel generator Amphenol connections. At the time, the NRC did not identify a substantive cross-cutting issue because the licensee appropriately recognized this theme and implemented a range of corrective actions to address it.

The 2009 end-of-cycle letter dated March 1, 2010, continued this theme but still did not identify a substantive cross-cutting issue, primarily because no findings with this common theme had been identified since the full implementation of the licensee corrective actions in mid-2009. However, these corrective actions were subsequently determined to be inadequate as demonstrated by six findings related to the use of conservative assumptions in decision making which occurred during the 2010 assessment period, all occurring following full implementation of the 2009 corrective actions. These findings occurred in the Initiating Events and Mitigating Systems Cornerstones. Examples included errors which led to an ice deflector pontoon barge being stored in the service water discharge canal, failing to monitor the performance of Agastat relays to ensure appropriate corrective actions were implemented, failing to ensure an adverse condition associated with safety-related station batteries was promptly corrected, and failing to properly assess and manage the risk associated with maintenance in the switchyard. This theme was recognized by the licensee but the apparent cause evaluation determined there was no common cause for these non-conservative decisions and no corrective actions were required. The inspectors discussed this with the licensee who stated the evaluation would be reopened to determine corrective actions to correct this adverse non-conservative decision making theme.

During the 2010 end of cycle assessment period, the NRC determined that the H.1(b)theme included six findings from two cornerstones. In addition, the NRC determined that twice during the last half of the 2010 assessment period the licensee initiated corrective action documents that acknowledged the decision making theme. However, neither of those corrective action documents resulted in implementation of adequate corrective actions to mitigate the theme. The lack of action prompted an NRC concern with the licensees scope of effort and progress in addressing the cross-cutting theme. Due to the continued cross-cutting theme associated with the use of conservative assumptions in decision making and NRC concerns with the licensees scope of effort and progress in addressing the common theme, the February 3, 2011, end-of-cycle performance review opened a substantive cross-cutting issue in the human performance area associated with the decision making component related to the use of conservative assumptions in decision making H.1(b).

On October 25, 2011, the licensee notified the NRC of their readiness for inspection of this substantive cross-cutting issue, and the NRC completed that inspection on December 2, 2011. The NRC found that:

• During the current assessment period, six findings had been identified with cross-cutting aspects in H.1(b). The findings included requalification issues, errors in reactor building internal flooding analyses, errors in tornado wind effects on diesel generator fuel oil storage vent, and unplanned exposure to radiation workers.

• Five of these findings had been identified during the first two quarters of 2011, prior to full implementation of the licensees corrective actions in August 2011.

• In August 2011, full implementation of the licensees corrective actions included emphasizing the nuclear principles of decision-making reflects safety first, a questioning attitude is cultivated, and improving monitoring and oversight of performance related to decision making and assumptions. In addition, the licensee implemented actions to monitor lower-level decision-making indicators and case-study training with involved departments. The licensee also established measurable objectives to monitor the effectiveness of that training.

• In a public meeting held on October 27, 2011, the licensee provided assurance that their corrective actions to address human performance would be sustained.

With respect to the stated criteria for closing this substantive cross-cutting issue, the NRC considered that these results, demonstrate sustainable performance improvements that are evidenced by effective implementation of an appropriate corrective action plan that resulted in no safety-significant inspection findings and a notable reduction in the overall number of inspection findings with the same common theme. Therefore, because the licensee had satisfied the criteria stated in the 2010 end of cycle assessment letter, the substantive cross-cutting issue in H.1(b) was closed in the 2011 end of cycle assessment letter.

The licensee noted that the station had seven findings associated with H.1(b) and initiated Condition Report CR-CNS-2012-04267 (NRC Findings with a CCA of H.1(b) -

Conservative Assumptions) on June 25, 2012. The licensees investigation determined that current station performance confirms that there exists a number of individuals within departments that lack specific attributes and behaviors that support conservative decision making. The licensee determined that a corrective action that would determine whether these incidents are specific to individuals or a site weakness would be through oral board examinations for the Engineering, Operations, Maintenance, and Radiation Protection supervision.

In the 2012 mid-cycle assessment letter, dated September 4, 2012, the NRC opened a substantive cross-cutting issue in the decision making component of the human performance area involving the use of conservative decision making H.1(b). During the assessment period, the NRC had identified eight findings associated with issues related to the use of conservative decision making. The NRC determined that a substantive cross-cutting issue existed because:

(1) there was a concern with the licensees scope of effort and progress in addressing this cross-cutting theme, and

(2) this theme repeats a theme that had previously been identified in the 2009 mid-cycle and end-of-cycle assessment letters, declared a substantive cross-cutting issue in the 2010 end-of-cycle letter, reviewed in the 2011 mid-cycle letter, and closed in the 2011 end-of-cycle letter.

The licensee acknowledged this theme and initiated CR-CNS-2012-05981 (NRC IR 2012-006 Identified Substantive Cross-Cutting Issue (SCCI)) on September 9, 2012.)

Condition Report CR-CNS-2012-05981 was subsequently closed to Condition Report CR-CNS-2012-06111 (Long Term Trend-Human Performance SCCIs) dated September 13, 2012. The licensees investigation determined that the primary cause was that the station has not effectively applied knowledge and monitoring tools to proactively address the Human Performance area of Safety Culture cross-cutting themes, and contributing causes were:

(1) the station has failed to effectively and consistently use trending to preclude the emergence of NRC cross-cutting themes or substantive cross-cutting issues, and

(2) when a cross-cutting aspect trend is identified, the associated condition report significance level typically assigned does not prompt evaluation and corrective action to preclude escalation of the issue.

The end-of-cycle performance assessment letter, dated March 12, 2013, maintained this substantive cross-cutting issue open. Specifically, the NRC noted that there had not been sustainable improvement in the cross-cutting area as evidenced by the identification of 13 findings during the assessment period in the decision making component related to the use of conservative assumptions in decision making H.1(b).

The licensee acknowledged this theme and initiated Condition Report CR-CNS-2013-01740 (2012 NRC Annual Assessment Letter Identified [Three]

Substantive Cross-Cutting Issues) on March 4, 2013. The licensees investigation determined that the root causes were:

(1) The stations standards related to the resolution of apparently low significance regulatory issues are low and do not meet Entergy fleet or industry expectations. This manifests in a lack of urgency to fully understand and resolve substantive cross-cutting issues and NRC findings of low significance (Green); and

(2) The stations Engineering and Operations departments are not adequately proficient in the application of the licensing and design basis of the plant.

Weak design basis knowledge together with limited experience related to the application of the design basis, particularly in engineering, result in the reduced levels of proficiency.

The station is in the process of implementing corrective actions for the identified causes.

The full implementation of the stations corrective actions is scheduled for later this year.

This baseline inspection semi-annual trend continues to monitor for sustainable performance improvements as evidenced by effective implementation of an appropriate corrective action plan that results in no safety significant inspection findings and a notable reduction in the overall number of inspection findings with the same common theme. The licensee has developed actions to focus on conservative decision making and addressing cross-cutting trends before they escalate to a theme.

To date, the NRC has identified 12 findings with the cross-cutting aspect of H.1(b) and this continues to comprise a cross-cutting theme. The licensee has implemented corrective actions to address this theme and the inspectors will continue to monitor for sustained improvement.

(2) Cross-Cutting Theme in Problem Evaluation P.1(c)

In the 2011 mid-cycle assessment letter, dated September 1, 2011, the NRC staff identified that a cross-cutting theme existed in the corrective action program component of the problem identification and resolution area P.1(c). At the time, the NRC did not identify a substantive cross-cutting issue due to the licensees scope of effort in addressing the theme, and it being an emergent performance trend. The licensee acknowledged this theme and initiated CR-CNS-2011-08284 (NRC Findings with a CCA of P.1(c)) on July 28, 2011. The investigation performed by CR-CNS-2011-08284 concluded that licensees failure to use internal operating experience to review recurring legacy problems was the common factor for most of the findings. The licensees corrective actions for this theme were:

(1) establish qualifications for individuals performing apparent-cause evaluations, and

(2) programmatic changes to require operating-experience reviews along with independent checks.

The end-of-cycle performance assessment letter, dated March 5, 2012, opened a substantive cross-cutting issue in the corrective action program component of the problem identification and resolution area P.1(c). Specifically, the NRC noted that the licensee did not develop corrective actions to address identified concerns involving the utilization of resources to perform problem evaluations. The licensee acknowledged this theme and initiated CR-CNS-2012-01522 (NRC IR 2012-001 Identified Substantive Cross-Cutting Issue) on March 5, 2012. The licensees investigation determined that the primary cause was management expectation error due to inadequate or inconsistent standards, secondary causes were:

(1) inadequate management oversight and follow-up of the noted issues, and

(2) organizational interface breakdowns as a result of inadequate organization to organization performance in addressing the noted issues.

The mid-cycle performance assessment letter, dated September 4, 2012, maintained this substantive cross-cutting issue open. Specifically, the NRC noted that there had not been sustainable improvement in the cross-cutting area as evidenced by the identification of eight findings during the assessment period in the corrective action program component of the problem identification and resolution area P.1(c). The licensee acknowledged this theme and initiated Condition Report CR-CNS-2012-05980 (NRC IR 2012-006 Identified Substantive Cross-Cutting Issue) on September 6, 2012.

The licensees investigation determined that actions to address the issues identified in the previous apparent cause evaluation documented in Condition Report CR-CNS-2012-01522 (NRC IR 2012-001 Identified Substantive Cross-Cutting Issue)were completed from April 18, 2012 through June 12, 2012, and based on the current understanding of the substantive cross-cutting issue, the actions implemented under Condition Report CR-CNS-2012-01522 would have the desirable impact of sustained improved performance over a period of time.

The end-of-cycle performance assessment letter, dated March 12, 2013, maintained this substantive cross-cutting issue open. Specifically, the NRC noted that there had not been sustainable improvement in the cross-cutting area as evidenced by the identification of four findings during the assessment period in the corrective action program component of the problem identification and resolution area P.1(c). The licensee acknowledged this theme and initiated Condition Report CR-CNS-2013-01740 (2012 NRC Annual Assessment Letter Identified 3 Substantive Cross-Cutting Issues) on March 4, 2013. The licensees investigation determined that the root causes where:

(1) The stations standards related to the resolution of apparently low significance regulatory issues are low and do not meet Entergy fleet or industry expectations. This manifests in a lack of urgency to fully understand and resolve substantive cross-cutting issues and NRC findings of low significance (Green);

(2) The stations Engineering and Operations departments are not adequately proficient in the application of the licensing design basis of the plant. Weak design basis knowledge together with limited experience related to the application of the design basis, particularly in engineering, result in the reduced levels of proficiency. The station is in the process of implementing corrective actions for the identified causes. The full implementation of the stations corrective actions is scheduled for later this year.

This baseline inspection semi-annual trend continues to monitor for sustainable performance improvements as evidenced by effective implementation of an appropriate corrective action plan that results in no safety significant inspection findings and a notable reduction in the overall number of inspection findings with the same common theme.

.4 Selected Issue Follow-up Inspection

a. Inspection Scope

During a review of items entered in the licensees corrective action program, the inspectors recognized a corrective action item documenting:

• April 18: Service water strainer A cotter pin

• April 30: Service water booster pump room fan coil unit and essential ventilation During a review of items entered in the licensees corrective action program, the inspectors recognized a corrective action item dealing with the service water system and service water booster pumps. The inspectors considered the following, as applicable, during the review of the licensees actions:

(1) complete and accurate identification of the problem in a timely manner;

(2) evaluation and disposition of operability/reportability issues;

(3) consideration of extent of condition, generic implications, common cause, and previous occurrences;

(4) classification and prioritization of the resolution of the problem;

(5) identification of root and contributing causes of the problem;

(6) identification of corrective actions; and

(7) completion of corrective action in a timely manner.

These activities constitute completion of two in-depth problem identification and resolution samples, as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

4OA5 Other Activities

Temporary Instruction 2515/182 - Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks

a. Inspection Scope

Leakage from buried and underground pipes has resulted in ground water contamination incidents with associated heightened NRC and public interest. The industry issued a guidance document, Nuclear Energy Institute (NEI) 09-14, Guideline for the Management of Buried Piping Integrity (ADAMS Accession No. ML1030901420) to describe the goals and required actions (commitments made by the licensee) resulting from this underground piping and tank initiative. On December 31, 2010, NEI issued Revision 1 to NEI 09-14, Guidance for the Management of Underground Piping and Tank Integrity, (ADAMS Accession No. ML110700122), with an expanded scope of components which included underground piping that was not in direct contact with the soil and underground tanks. On November 17, 2011, the NRC issued TI-2515/182 Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks to gather information related to the industrys implementation of this initiative.

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

Based upon the scope described above, Phase I was found to meet all applicable aspects of NEI 09-14, Revision 1, as set forth in Table 1 of TI-2515/182.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On May 2, 2013, the inspectors presented the results of the radiation safety inspections to Mr. D. Buman (Director, Engineering) and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On July 1, 2013, the inspectors presented the inspection results to Mr. Rod Penfield (Director Nuclear Safety Assurance) and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by the licensee and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy, for being dispositioned as non-cited violations.

.1 Technical Specification 5.5.4 requires the radioactive effluent controls program be contained

in the offsite dose assessment manual and include limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation. Cooper Nuclear Station Offsite Dose Assessment Manual, Appendix D, Section D 3.3.2(a) requires the gaseous radiation monitoring instrumentation channels shown in Table D3.3.2-1 be operable with the minimum operable channels in service. The effluent process flow element associated with the elevated release point monitoring system is shown in Table D3.3.2-1 and the minimum number of operable channels is one. Under Condition B, the licensee is required to restore inoperable channels to operable status within 31 days. Contrary to this requirement, the licensee did not restore at least one channel of the elevated release point process flow monitor operable within 31 days. The 31-day period expired September 7, 2012, and at the time of the inspection, the process flow monitor was still not operable. As an interim corrective action to ensure the elevated release point gaseous effluent radiation monitor functioned in the absence of a flow rate signal, licensee representatives provided an electrical signal to simulate the signal provided by the process flow monitor. Licensee personnel said the signal provided was a conservative value, in that, it simulated a higher-than-actual flow rate, which would cause the radiation monitor alert setpoint to be reached at a lower concentration than required. The violation had very low safety significance because, although it involved an effluent program violation, it did not result in a substantial failure to implement the effluent program and it did not result in public doses exceeding either 10 CFR Part 50, Appendix I, values or 10 CFR 20.1301(e) values. The details were documented in Condition Report CR-CNS-2012-06010.

.2 Title 10 CFR Part 50, Appendix B, Criterion V states, in part, that activities affecting quality

shall be accomplished in accordance with procedures of a type appropriate to the circumstances. Contrary to the above, an activitity affecting quality was not accomplished in accordance with procedures of a type appropriate to the circumstances. Specificially, from November 2011 to April 2013, the licensee failed to properly assess and document the basis for operability of essential ventilation duct work between the vital switchgear room and control room in accordance with Station Procedure 0.5OPS, Operations Review of Condition Reports/Operability Determinaton. This performance deficiency was more than minor and therefore is a finding because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone. Specifically, the licensees failure to properly document and assess the basis for operability resulted in a condition of unknown operability for a degraded nonconforming system, thereby affecting the associated objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix A, 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 deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality;

(2) did not represent a loss of system and/or function;

(3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and

(4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Anderson, Radiological Operations Supervisor, Radiation Protection

J. Bebb, Staff Health Physicist, Radiation Protection

J. Bednar,Technical Supervisor, Radiation Protection

R. Beilke, Manager, Radiation Protection

D. Buman, Director, Engineering

B. Duncan, Environmental Specialist, Chemistry

K. Fike, Plant Chemist, Chemistry

S. Freiling, Staff Health Physicist, Radiation Protection

G. Kahnk, System Engineer, Engineering

L. Maine, Technician, Chemistry

E. McCutchen, Senior Engineer, Licensing

R. Penfield, Director, Nuclear Safety Assurance

C. Stipp, Corporate Environmental Coordinator

K. Tanner, Supervisor, Radiation Protection

J. Teten, Supervisor, Chemistry

D. Van Der Kamp, Manager, Licensing

B. Voss, Manager, Refueling Services/Refuel Floor

A. Walters, Manager, Chemistry

W. Williams, Specialist, Radiation Protection

J. White, Specialist, Radiation Protection

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

Failure to Adequately Assess Risk and Implement Risk

05000298/2013003-01 NCV Management Actions for Proposed Maintenance (Section 1R13)

05000298/2013003-02 NCV Failure to Follow Operability Procedure (Section 1R15)

Attachment 1