IR 05000305/2012002
| ML12131A422 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 05/10/2012 |
| From: | Kenneth Riemer NRC/RGN-III/DRP/B2 |
| To: | Heacock D Dominion Energy Kewaunee |
| References | |
| IR-12-002 | |
| Download: ML12131A422 (47) | |
Text
May 10, 2012
SUBJECT:
KEWAUNEE POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000305/2012002
Dear Mr. Heacock:
On March 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Kewaunee Power Station. The enclosed inspection report documents the inspection results which were discussed on April 4, 2012, with Mr. A. Jordan and other members of your staff.
The inspection 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.
One Severity Level IV NRC-Identified violation and two NRC-Identified findings of very low safety significance (Green) were identified during this inspection. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest these NCVs, 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 III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector at the Kewaunee Power 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 System (PARS)
component of NRC's document 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/ By N. Shah Acting For/
Kenneth Riemer, Branch Chief Branch 2 Division of Reactor Projects
Docket No. 50-305 License No. DPR-43
Enclosure:
Inspection Report 05000305/2012002 w/ Attachment: Supplemental Information
REGION III==
Docket No:
50-305 License No:
DPR-43 Report No:
05000305/2012002 Licensee:
Dominion Energy Kewaunee, Inc, Facility:
Kewaunee Power Station Location:
Kewaunee, WI Dates:
January 1, 2012, through March 31, 2012 Inspectors:
R. Krsek, Senior Resident Inspector
K. Barclay, Resident Inspector
A. Shaikh, Reactor Inspector
D. McNeil, Senior Operations Engineer
Approved by:
Kenneth Riemer, Branch Chief Branch 2 Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
Inspection Report (IR) 05000305/2012002, 01/01/2012 - 03/31/2012, Kewaunee Power Station (KPS); Post-Maintenance Testing; Surveillance Testing; and Follow-Up of Events and Notices of Enforcement Discretion.
This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. Two Green findings and one Severity Level (SL) IV violation and were identified by the inspectors. The two findings and the SL IV violation were considered non-cited violations (NCVs) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
NRC-Identified
and Self-Revealed Findings
Cornerstone: Barrier Integrity
- Green.
The inspectors identified a finding of very low safety significance and associated NCV of Technical Specification (TS) 5.4.1, Procedures, which required, in part, that written procedures shall be implemented covering the applicable procedures recommended in Regulatory Guide (RG) 1.33, Revision 2, Appendix A. Specifically,
Procedure GNP-08.02.12, Post-Maintenance Testing/Operations Retest, stated, in part, that the post-maintenance tests (PMTs) were performed upon completion of maintenance activities, and demonstrated that the identified deficiency was repaired, and that no new deficiency was created. On July 4, 2011, the licensee replaced the spent fuel pool (SFP) pump motor B, and failed to conduct an adequate PMT, which demonstrated no new deficiency was created. The PMT only tested the replaced motor and failed to include testing of the pump to ensure that no new deficiency was created.
The licensee entered the issue into its corrective action program (CAP) as condition reports (CRs) 464645, 466183, and 466215, and planned to perform an apparent cause evaluation (ACE) and take corrective actions.
The inspectors determined that the finding was more than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," because, if left uncorrected, the failure to perform adequate PMT on motor replacements would have the potential to lead to a more significant safety concern. The inspectors determined that the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 -
Initial Screening and Characterization of Findings, Table 4a, for the Barrier Integrity Cornerstone, dated January 10, 2008. The inspectors answered "No" to the Reactor Coolant System or Fuel Barrier Questions related to Spent Fuel Pool Issues, and screened the finding as having very low safety significance (Green). The inspectors also determined that this finding had a cross-cutting aspect in the area of human performance, resources, because the licensee did not ensure the PMT procedure guidance related to motor replacements was adequate and accurate to assure nuclear safety (H.2(c)). (Section 1R19.1)
- Green.
The inspectors identified a finding of very low safety significance (Green) and an associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to have appropriate procedures to complete TS-required surveillances. Specifically, OSP-CCI-004, Containment Isolation Valve Verification, did not contain adequate steps to complete a TS-required airlock door check and the procedure did not include six manual containment isolation valves (CIVs) that should have been included in the procedure for position verification. The licensee corrected the procedure and entered the issue into its CAP as CRs 464355, 464494, and 467560, and planned to perform an ACE.
The inspectors determined that the finding was more than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," because the finding was associated with the Barrier Integrity Cornerstone attribute of procedure quality and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, inspectors found seven examples in OSP-CCI-004 where either the procedure steps were not adequate or CIVs were missing that should have been included in the procedure for position verification.
The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 -
Initial Screening and Characterization of Findings, Table 4a for the Barrier Integrity Cornerstone, dated January 10, 2008. The inspectors answered No to the Containment Barrier questions and screened the finding as having very low safety significance (Green). This finding has a cross-cutting aspect in the area of human performance, resources, because the licensee did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety was supported. Specifically, OSP-CCI-004 did not get an approval review during the procedure review process and the supervisory review that was conducted did not identify the procedural errors (H.4(c)). (Section 1R22.1)
===Cornerstone:
Other Findings
=
- SL IV. The inspectors identified an SL IV NCV of 10 CFR 50.73(a)(2)(vii) for the failure of the licensee to report an event where a single cause or condition caused two independent trains to become inoperable in a single system designed to control the release of radioactive material. Specifically, the licensee failed to report that both trains of shield building ventilation (SBV) were inoperable due to a single cause, because both trains contained unqualified control card standoffs that were needed to maintain the seismic qualification and operability of the system. The licensee entered this into their CAP as CR429469, planned to perform an ACE, and was drafting an update to Licensee Event Report (LER) 05000305/2011-005.
The inspectors determined that the failure to report the event in accordance with 10 CFR 50.73 was a performance deficiency. Because violations of 10 CFR 50.73 are considered to be violations that potentially impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the Reactor Oversight Process (ROP) SDP. Because the performance deficiency, a failure to report, was not an ROP finding per IMC 0612, Appendix B, Issue Screening, a cross-cutting aspect was not assigned to this violation. Per the NRC Enforcement Policy, Section 6.0,
Violation Examples, a failure to submit a required LER is categorized as an SL IV violation. (Section 4OA3)
Licensee-Identified Violations
Violations of very low safety significance that were identified by the licensee have been reviewed by inspectors. Corrective actions planned or taken by the licensee have been entered into the licensees CAP. This violation and corrective action tracking number is listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Kewaunee Power Station (KPS) operated at full power for the entire inspection period, except for brief downpowers to conduct planned maintenance and surveillance activities.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness of Offsite and Alternate AC Power Systems
a. Inspection Scope
The inspectors verified that plant features and procedures for operation and continued availability of offsite and alternate alternating current (AC) power systems during adverse weather were appropriate. The inspectors reviewed the licensees procedures affecting these areas and the communications protocols between the transmission system operator (TSO) and the plant to verify that the appropriate information was being exchanged when issues arose that could impact the offsite power system. Examples of aspects considered in the inspectors review included:
- the coordination between the TSO and the plant 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; and,
- the notifications from the TSO to the plant when the offsite power system was returned to normal.
The inspectors also verified that plant procedures addressed measures to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system prior to or during adverse weather conditions. Specifically, the inspectors verified that the procedures addressed the following:
- the actions to be taken when notified by the TSO that the post-trip voltage of the offsite power system at the plant would not be acceptable to assure the continued operation of the safety-related (SR) loads without transferring to the onsite power supply;
- the compensatory actions identified to be performed if it would not be possible to predict the post-trip voltage at the plant for the current grid conditions;
- a re-assessment of plant risk based on maintenance activities which could affect grid reliability, or the ability of the transmission system to provide offsite power; and,
- the communications between the plant and the TSO when changes at the plant could impact the transmission system, or when the capability of the transmission system to provide adequate offsite power was challenged.
Documents reviewed are listed in the Attachment to this report. The inspectors also reviewed CAP items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into the CAP in accordance with station corrective action procedures.
This inspection constituted one readiness of offsite and alternate AC power systems sample as defined in Inspection Procedure (IP) 71111.01-05.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- component cooling water (CCW) train A;
- the SFP system; and,
The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures and system diagrams to determine the appropriate system lineup. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization.
Documents reviewed are listed in the Attachment to this report.
These activities constituted three partial system walkdown samples as defined in IP 71111.04-05.
b. Findings
No findings were identified.
.2 Semi-Annual Complete System Walkdown
a. Inspection Scope
On March 19, the inspectors performed a complete system alignment inspection of the service water (SW) system to verify the functional capability of the system. This system was selected because it was considered both safety significant and risk significant in the licensees probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment lineups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation.
A review of a sample of past and outstanding WOs was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the CAP database to ensure that system equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the to this report.
These activities constituted one complete system walkdown sample as defined in IP 71111.04-05.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Routine Resident Inspector Tours
a. Inspection Scope
The inspectors conducted fire protection (FP) walkdowns, which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant fire zones:
- TU-98, battery room B;
- TU-95A, 480-Volt switchgear bus 1-51 and 1-52 room;
- TU-94, carbon dioxide tank room; and,
- AX-23A, auxiliary building fan floor.
The inspectors reviewed areas to assess if the licensee had implemented an FP program that adequately controlled combustibles within the plant, effectively maintained fire detection and suppression capability, maintained passive FP features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable FP equipment, systems, or features, in accordance with the licensees fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the Attachment to this report, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition.
The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP. Documents reviewed are listed in the Attachment to this report.
These activities constituted four quarterly fire protection inspection samples as defined in IP 71111.05-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
a. Inspection Scope
On February 13, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and that training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of abnormal and emergency procedures;
- control board manipulations; and,
- oversight and direction from supervisors The crews performance in these areas was compared to pre established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11.
b. Findings
No findings were identified.
.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk
On March 16 and March 27, the inspectors observed control room operations during a reactor downpower to 97 percent, and wiring repairs on the N-35 source range test wires coincident with reactor protection train B logic testing, respectively. Both activities required heightened awareness or were related to increased risk. The inspectors evaluated the following areas, as necessary:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms (if applicable);
- correct use and implementation of procedures;
- control board (or equipment) manipulations;
- oversight and direction from supervisors; and,
- ability to identify and implement appropriate TS actions and Emergency Plan (EP) actions and notifications (if applicable).
The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11.
b. Findings
No findings were identified.
.3 Conformance with Operator License Conditions
a. Inspection Scope
The inspector reviewed the licensees corrective actions and documents associated with an improper license application submission. The inspectors reviewed an individual operator license application and the licensed operators medical history to determine the applications accuracy.
b. Findings
The licensee identified a failure to provide the NRC with complete and accurate information regarding the submission of an NRC Form 396, Personnel Qualification Statement, for one of the stations operator license applicants in March 2011.
The licensee identified a licensed operator that had been prescribed, and was using a CPAP (Continuous Positive Airway Pressure) device - a device used to treat sleep apnea. The licensed operators condition was not included on the operator license application as a needed license restriction.
The inspectors review of this issue was considered to be a part of the original inspection effort, and as such did not constitute any additional inspection samples.
(See Section 4OA7 for Licensee-Identified Violations for details).
1R12 Maintenance Effectiveness
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the Technical Support Center (TSC) diesel generator (DG) voltage regulator and also reviewed the licensees most recent 10 CFR 50.65(a)(3) Periodic Evaluation.
The inspectors verified the licensee's actions to address system performance or condition problems in terms of the following areas, as necessary:
- implementing appropriate work practices;
- identifying and addressing common cause failures;
- scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;
- characterizing system reliability issues for performance;
- charging unavailability for performance;
- trending key parameters for condition monitoring;
- ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and,
- verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
.1 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and SR equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:
- SW to turbine-driven auxiliary feedwater (TDAFW) pump bundled maintenance on January 26;
- turbine building fan coil unit (TBFCU) maintenance with the cross connect damper closed on February 13;
- emergent work on auxiliary building mezzanine fan coil unit (FCU) 1A on March 8;
- auxiliary feedwater (AFW) pump testing on March 16; and,
These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4), and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Documents reviewed are listed in the Attachment to this report.
These maintenance risk assessments and emergent work control activities constituted six samples as defined in IP 71111.13-05.
b. Findings
- (1) Incorrectly Modeled Ventilation Damper Changes Daily Risk Color
Introduction:
The inspectors identified an unresolved item (URI) concerning the incorrect modeling of an SR ventilation damper in the licensees daily risk assessment tool.
Description:
During the daily review of CRs, inspectors reviewed CR464332, which documented that cross connect damper TAV-82, which connected two trains of turbine building ventilation, was modeled in the licensees probabilistic risk assessment (PRA)tool as open, when the actual position of the damper was closed. When the licensees PRA tool was updated with the correct damper position, the daily risk calculated to comply with 10 CFR 50.65(a)(4) increased from green to orange on train B, and from green to red on train A. The licensee reevaluated the model taking credit for a nonsafety-related (NSR) general turbine building ventilation system that also provided air flow to the two rooms in question and the risk was reduced. The updated model for the removal of a TBFCU from service maintained green risk for train B and only increased train A to yellow risk.
At the conclusion of the inspection period the inspectors needed additional information to determine if an error in the original inputs to the base PRA tool, versus an error in the daily application of the PRA tool, was a violation of 10 CFR 50.65(a)(4). As a result, this item was considered unresolved (URI 05000305/2012002-01, Incorrectly Modeled Ventilation Damper Changes Daily Risk Color).
- (2) Potential Mobile Crane Heavy Load Risk Modeling Error
Introduction:
The inspectors identified a URI concerning the use of dropped load probabilities for mobile cranes in the licensees daily risk assessment tool.
Description:
During plant tours, the inspectors observed the licensees preparations for a heavy lift of circulating water pump motor B from the SW screen house through the screen house roof hatch to a motor stand outside. The inspectors had previously identified during daily plant status activities that EDG train A was tagged out for maintenance; and during discussions with the maintenance personnel performing the motor lift, found that the load path for the 44,000 lb motor went over both buried cables for the SW pumps train B, which were a needed support system for EDG train B.
The inspectors questioned the licensee about the load path and found that the licensee had not recognized the location of the underground cables during the planning phase of the load lift, and had not evaluated a load drop over the cables and what affect the drop would have on the cables. The licensee suspended the lift until the next day, when EDG train A was operable and the licensee had an opportunity to perform a risk assessment for the heavy load travelling over the SW cables. The inspectors reviewed the risk assessment for the heavy lift and questioned whether the probability used for a load drop was conservative.
At the conclusion of the inspection period, the inspectors needed additional information to determine if a performance deficiency occurred. As a result, this item was considered unresolved (URI 05000305/2012002-02, Potential Mobile Crane Heavy Load Risk Modeling Error).
1R15 Operability Determinations and Functional Assessments
.1 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues:
- CR460536, Calc for Control Room Console Temperature Did Not Include Uncertainty;
- RAS 200, for spent fuel heat exchanger loads.
The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and USAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee had identified and corrected any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report.
This operability inspection constituted six samples as defined in IP 71111.15-05.
b. Findings
The inspectors documented one licensee-identified violation in Section 4OA7.
1R18 Plant Modifications
.1 Plant Modifications
a. Inspection Scope
The inspectors reviewed the following modifications:
- DC-10-01101, EDG ventilation air supply modification (permanent); and,
- commercial grade dedication of TBFCU motors (permanent).
The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening against the design basis, the USAR, and the TSs, as applicable, to verify that the modification did not affect the operability or availability of the affected systems. The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modifications were installed as directed and consistent with the design control documents; the modifications operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. For commercial grade dedications, the inspectors also reviewed the appropriateness of the critical characteristics selected for the dedication process and verified that the licensees testing or acceptance method for the critical characteristics was appropriate. Documents reviewed are listed in the to this report.
This inspection constituted two permanent plant modification samples as defined in IP 71111.18-05.
b. Findings
Potential Inadequate Commercial Grade Dedication
Introduction:
The inspectors identified a URI concerning the adequacy of the commercial grade dedication for the SR TBFCU motors.
Description:
On January 21, the licensee discovered elevated noise on TBFCU motor 1B. Subsequent vibration data indicated that the outboard bearing was in imminent failure. The licensee declared the FCU inoperable, replaced the motor, and returned the FCU to a functional status at 7:41 a.m. on January 22. A failure analysis of the motor and bearing determined that the apparent cause of the motor failure was incorrect assembly of the motor after installation of sealed bearings at a local vendor.
The licensee also considered an undetected original manufacturing defect of the motor that resulted in excessive thrust load on the bearing was also a potential apparent cause because it could not be ruled out. The motor was procured as NSR; the original bearings were replaced at a local vendor for double shielded bearings; and then the motor was commercially dedicated. Since the opposite train motor was procured at the same time using the same process, the licensee replaced that the motor and also sent it off for analysis. The inspectors were concerned that the incorrect assembly error was not discovered during the commercial dedication process and inspected the commercial dedication package for the motor. The inspectors found that the critical characteristics for the dedication process may have been inadequate to identify the incorrect assembly at the vendor; however, the licensee informed the inspectors near the end of the inspection period that the failure analysis for the second motor may have had different conclusions than the first.
The inspectors were unable to evaluate the second failure analysis prior to the end of the inspection period, and needed additional time to determine if a performance deficiency existed. As a result, this item was considered to be unresolved pending a review of the second failure analysis (URI 05000305/2012002-03, Potential Inadequate Commercial Grade Dedication).
1R19 Post-Maintenance Testing
.1 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance (PM) activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
- TBFCU B work conducted on January 22;
- safeguard logic test following ESF relay replacement on February 10;
- retest of TBFCU A following motor replacement on February 13; and,
These activities were selected based upon the SSCs ability to impact risk.
The inspectors evaluated these activities for the following (as applicable): the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and, test documentation was properly evaluated. The inspectors evaluated the activities against documents such as TSs, USAR, 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 (PMTs) to determine whether the licensee identified problems and entered them into the CAP, and that the problems were corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.
This inspection constituted six post-maintenance testing samples as defined in IP 71111.19-05.
b. Findings
Inadequate Post-Maintenance Test of Motor Replacements
Introduction:
The inspectors identified a finding of very low safety significance (Green)and an associated NCV of TS 5.4.1, Procedures, which required, in part, that written procedures shall be implemented covering the applicable procedures recommended in RG 1.33, Revision 2, Appendix A. Specifically, GNP-08.02.12, Post-Maintenance Testing/Operations Retest, stated, in part, that the PMTs were performed upon completion of maintenance activities and demonstrated that the identified deficiency was repaired and that no new deficiency was created. On July 4, 2011, the licensee replaced SFP pump motor B and failed to conduct an adequate PMT, which demonstrated no new deficiency was created. The PMT only tested the replaced motor, and failed to include testing of the pump to ensure that no new deficiency was created.
Description:
The inspectors reviewed the PMT associated with the replacement of TBFCU motor 1B conducted on January 22, 2012, under work order (WO)
KW100863379. The inspectors initially noted that the PMT for the motor only specified acceptable vibration readings of the motor and verification that the motor amperage readings were consistent with the name plate rating. Since the motor provided the power to rotate a fan, the inspectors questioned why the fan flow was not specified as a PMT to ensure that no new deficiency was created that affected FCU 1B overall, as required by procedure. The licensee initiated CR464645 to document this deficiency.
The inspectors later determined that mechanics did verify fan speed, an indication of fan flow, as part of a procedure, even though it was not required by the PMT.
The inspectors noted that GNP-08.02.12, Post-Maintenance Testing/Operations Retest, required that the PMT demonstrate the identified deficiency was repaired, and no new deficiency was created. The inspector also noted that the procedure did not provide adequate guidance for process flow testing of the equipment a motor was attached to, following a motor replacement. The inspectors identified that nuclear industry guidance available to the licensee in a PMT Guide, specified that in order to demonstrate a replaced motor was capable of performing its intended function, that verification of the correct process flow should be evaluated.
While researching the recent PMT of small motors onsite, the inspectors noted that in March 2012, SFP pump B performance flow exhibited a 13 percent drop in total flow since the pumps performance was last tested. While flow was still acceptable to perform the intended safety function, the licensee initiated CR466183 to document the measured decrease in flow. The inspectors reviewed WO KW100388379 for the replacement of SFP pump motor 1B, which occurred on July 4, 2011, because the existing motor had failed. The inspectors again noted that the PMT for this small motor replacement only specified acceptable vibration readings of the motor, and that verification that the motor amperage readings were consistent with the name plate rating. The inspectors concluded that verification of the replaced motor properties did demonstrate that the identified deficiency was repaired; however, it did not demonstrate that no new deficiency was created in the SFP train B system. The inspectors also noted that while the operations retest notes did specify verification of the pump discharge pressure, this was not performed or included as part of the PMT.
Analysis:
The inspectors determined the failure to have adequate PMT of the SFP was a performance deficiency and a finding.
The inspectors determined that the finding was more than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening,"
because, if left uncorrected, the failure to perform adequate PMT on motor replacements would have the potential to lead to a more significant safety concern. The inspectors determined that the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a, for the Barriers Integrity Cornerstone, dated January 10, 2008. The inspectors answered "No" to the Reactor Coolant System or Fuel Barrier Questions related to Spent Fuel Pool Issues, and screened the finding as having very low safety significance (Green).
Therefore, the finding is considered to be of very low safety significance (Green).
The inspectors also determined that this finding had a cross-cutting aspect in the area of human performance, resources, because the licensee did not ensure the PMT procedure guidance related to motor replacements were adequate and accurate to assure nuclear safety (H.2(c)).
Enforcement:
The TS 5.4.1, Procedures, requires, in part, that written procedures shall be implemented covering the applicable procedures recommended in RG 1.33, Revision 2, Appendix A, February 1978. The RG 1.33, Section 9.3.e, Procedures for Performing Maintenance, states, in part, that general procedures for the control of maintenance, repair and replacement be prepared, as appropriate.
Procedure GNP-08.02.12, Post-Maintenance Testing/Operations Retest, stated, in part, that PMTs were performed upon completion of maintenance activities and demonstrated that the identified deficiency was repaired, and that no new deficiency was created.
Contrary to this, on July 4, 2011, the licensee implemented WO KW100388379 to replace SFP pump motor 1B, which specified PMT of satisfactory motor vibration readings and verification of motor amperage readings consistent with the motor name plate rating, and verification of pump discharge pressure. The PMT performed did not include verification of pump discharge pressure or pump flow, even though the motor for the pump was replaced. Therefore, the PMT performed only demonstrated that the identified motor deficiency was repaired; but the test failed to demonstrate that no new deficiency was created as part of the maintenance for the SFP train B pump and motor system. Because this violation was of very low safety significance, and because it was entered into the licensees CAP, as CRs 464645, 466183, and 466215, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.
(NCV 05000305/2012002-04, Inadequate Post-Maintenance Test of Motor Replacements)
At the end of the inspection period, the licensee was performing an ACE to determine the causes of the event, and developing corrective actions.
1R22 Surveillance Testing
.1 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function, and to verify testing was conducted in accordance with applicable procedural and TS requirements:
- OSP-54-063, turbine trip mechanism test on February 13 (routine);
- OSP-CCI-004, CIV on February 5 (CIV);
- SP-47-62B, reactor protection system train B on March 27 (routine);
- OSP-AFW-003B, motor driven AFW pump B testing on March 16 (inservice testing (IST));
- OSP-CC-002A, component cooling pump and valve test train A on March 8 (IST);and,
- OSP-RCS-001, reactor coolant system (RCS) leakrate surveillances on February 8 and February 9 (RCS).
The inspectors considered the following test attributes, if applicable, while they observed in-plant activities and reviewed procedures and associated records:
- did preconditioning occur;
- were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;
- were acceptance criteria clearly stated, demonstrated operational readiness, and consistent with the system design basis;
- plant equipment calibration was correct, accurate, and properly documented;
- as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the USAR, procedures, and applicable commitments;
- measuring and test equipment calibration was current;
- test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;
- test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;
- test data and results were accurate, complete, within limits, and valid;
- test equipment was removed after testing;
- where applicable for IST activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers (ASME) code, and reference values were consistent with the system design basis;
- where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;
- where applicable for SR instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;
- where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;
- prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;
- equipment was returned to a position or status required to support the performance of its safety functions; and,
- all problems identified during the testing were appropriately documented and dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted two routine surveillance testing samples, two IST samples, one CIV sample, and one RCS leak detection inspection sample, as defined in IP 71111.22, Sections -02 and -05.
b. Findings
Inadequate Procedure For Technical Specification Surveillance
Introduction:
A finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors for the failure to have adequate procedures to complete TS-required surveillances. Specifically, OSP-CCI-004, Containment Isolation Valve Verification, did not contain adequate steps to complete a TS-required airlock door check and the procedure did not include six manual CIVs that should have been included in the procedure for position verification.
Description:
During the inspection for the closure of URI 05000305/2011004-02, Failure to Perform Maintenance Rule Evaluations for Risk Significant Fire Door Failures, the inspectors identified that the licensee may not have been properly controlling airlock doors that were credited for maintaining the integrity of the shield building. The SBV system filters potential radioactive leakage coming from the containment liner into the shield building during a design basis accident.
While collecting information to answer the inspectors question related to the control of the shield building airlock doors, the licensee found that OSP-CCI-004 was not worded adequately, and operators were checking the wrong air lock doors during completion of the surveillance requirement. The TS SR 3.6.8.1 stated, Verify one shield building access door in each access opening is closed. Procedure OSP-CCI-004, Step 5.2.2, which accomplished TS SR 3.6.8.1, stated, ENSURE one door for each of the following openings is closed: [- Personnel Air Lock, -Emergency Air Lock]. Because the procedure did not clarify which air lock to check, the operators were checking the containment air locks closed instead of the shield building air locks. The inspectors performed a review of OSP-CCI-004, and also identified six additional manual valves that appeared in the CIV table in the USAR, but were not included in the procedure.
The inspectors gave their observation to the licensee, and the licensee concluded that the six manual valves missing from the procedure should have been included.
Analysis:
The inspectors determined that the failure to have appropriate procedures was contrary to 10 CFR Part 50, Appendix B, Criterion V, and was a performance deficiency.
The finding was determined to be more than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," because the finding was associated with the Barrier Integrity Cornerstone attribute of procedure quality, and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, inspectors found seven examples in OSP-CCI-004 where either the procedure steps were not adequate or CIVs were missing that should have been included in the procedure for position verification. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a for the Barrier Integrity Cornerstone, dated January 10, 2008. The inspectors answered No to the Containment Barrier questions and screened the finding as having very low safety significance (Green).
This finding has a cross-cutting aspect in the area of human performance, resources, because the licensee did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety was supported. Specifically, OSP-CCI-004 did not get an approval review during the procedure review process and the supervisory review that was conducted did not identify the procedural errors (H.4(c)).
Enforcement:
Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, from February 12, 2011, through March 23, 2012, the licensee failed to prescribe procedures appropriate to the circumstances for activities affecting quality. Specifically, OSP-CCI-004 did not contain appropriate steps to complete a TS-required airlock door check, and the procedure did not include six manual CIVs that should have been included in the procedure for position verification. Because this violation was of very low safety significance and it was entered into the licensees CAP as CRs 464355, 464494, and 467560, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000305/2012002-5, Inadequate Procedure For Technical Specification Surveillance).
The licensee corrected the procedure and planned to perform an ACE at the end of the inspection period.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness
4OA2 Identification and Resolution of Problems
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection
.1 Routine Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.
Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.
These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.
b. Findings
No findings were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily condition report packages.
These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.
b. Findings
No findings were identified.
.3 Selected Issue Follow-Up Inspection:
ACE 18964: Engineered Safety Feature Relay Failure During Testing
a. Inspection Scope
During a review of items entered in the licensees CAP, the inspectors recognized a corrective action item documenting the failure of an ESF relay during routine testing.
The inspectors reviewed the licensees ACE, previous occurrences, and the licensees planned remedial corrective actions, as well as long term corrective actions to address the issue. Documents reviewed are listed in the Attachment to this report.
This review constituted one in-depth problem identification and resolution sample as defined in IP 71152-05.
b. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
.1 Retraction of Event Notification (EN) 47476:
4160-Volt Alternating Current Busses Declared Inoperable
a. Inspection Scope
The inspectors reviewed the plants January 18 retraction of a November 24, 2011, event in which the licensed operators declared both 4160-Volt AC busses inoperable due to voltages being high outside of the procedurally directed band. While the control board indications for SR busses 5 and 6 indicated less than 4400 Volts, a laptop installed as part of temporary modification (TMOD) TMOD-2011-05 that more accurately measured voltage at the back of the meter indicated values that were out of the specified range prescribed in OSP-MISC-002, Attachment D. As a result, at 3:15 a.m., the operators declared busses 5 and 6 inoperable per TS 3.8.9; declared offsite power sources as inoperable per TS 3.8.1; and entered the requirements of TS 3.0.3, which required action to commence a unit shutdown within one hour if operability could not be restored. At 4:10 a.m., the load tap changers for the supply transformers to busses 5 and 6 were adjusted to reduce the emergency bus voltages to within their procedurally required operating bands, and the aforementioned TSs were exited.
The licensee reviewed the events and determined that the ranges prescribed in OSP-MISC-002, Attachment D, contained unnecessary conservatisms in the development of voltage values for the laptop installed as part of TMOD-2011-05.
A review of the actual voltages present on November 24, 2011, with the correct procedure values revealed that voltages did not exceed the required values to support bus operability.
As part of the review, the inspectors reviewed control room logs and available indications; interviewed engineering and operations staff; and reviewed operations procedures and engineering technical evaluations. Documents reviewed are listed in the to this report.
The inspectors concluded that with the new values, the busses remained operable on November 24, 2011, and this condition did not meet the reportability criteria.
This event follow-up review constituted one sample as defined in IP 71153-05.
b. Findings
No findings were identified.
.2 (Closed) Licensee Event Report (LER) 05000305/2011-005-00:
Shield Building Ventilation Train Inoperable for Longer Period Than Allowed by Technical Specifications
a. Inspection Scope
On January 26, 2011, the licensee found a control card, for train A of the SBV system, hanging down partially by its control cables. The licensee determined the cause to be insufficient quality and design of the standoff material resulting in improper adhesion between the metal stud and the neoprene. The standoffs were used to support the control cards at four points and were needed to maintain the seismic qualification of the card. The licensees initial assessment of this event failed to recognize the past operability implications, as well as, how the unqualified standoffs were installed in the system to begin with. The inspectors documented two violations related to this event in NRC Integrated Inspection Report (IR) 05000305/2011003. One additional violation of 10 CFR 50.73 was identified during the review of this LER for the failure to report any event where a single cause or condition caused two independent trains to become inoperable in a single system designed to control the release of radioactive material.
Specifically, the licensees failed to report or update their previous LER after the vendor communicated that the standoffs were the wrong design if they needed to support the control cards during a seismic event. Documents reviewed are listed in the Attachment to this report. This LER is closed.
This event follow-up review constituted one sample as defined in IP 71153-05.
b. Findings
Failure to Submit Licensee Event Report per 10 CFR 50.73
Introduction:
The inspectors identified an SL IV NCV of 10 CFR 50.73(a)(2)(vii) for the failure of the licensee to report an event where a single cause or condition caused two independent trains to become inoperable in a single system designed to control the release of radioactive material. Specifically, the licensee failed to report that both trains of SBV were inoperable due to a single cause, because both trains contained unqualified control card standoffs that were needed to maintain the seismic qualification and operability of the system.
Description:
As part of the inspection for LER 05000305/2011-005, the inspectors reviewed information related to the vendors failure analysis of the SBV circuit card standoffs that were found failed in train A on January 26, 2011. The inspectors found that the licensee received communications from the vendor that the standoffs failed because they were embrittled, most likely from over-processing during the freezing and tumbling portion of the manufacturing process. While none of the train B standoffs failed until the licensee was removing them from the system, the licensee was not able to determine the extent of the embrittlement of the standoffs in train B, and whether they would have been able to survive a seismic event. Additionally, the licensee found out on November 17, 2011, during further communications with the vendor, that the standoff design specifications were not appropriate for the application and would not survive a seismic event. The licensee installed the standoffs on train A on December 3, 2010, and removed them on January 26, 2011. The licensee installed the train B standoffs on January 6, 2011, and removed them on February 3, 2011. The inspectors concluded that since the inadequate standoffs were installed on both trains from January 6 to January 26, 2011, and they were needed to maintain the seismic qualification of the independent trains, the licensee should have reported this issue as a single cause or condition that caused two independent trains to become inoperable in a single system designed to control the release of radioactive material.
Analysis:
The inspectors determined that the failure to report the condition in accordance with 10 CFR 50.73 was a performance deficiency. Because violations of 10 CFR 50.73 are considered to be violations that potentially impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the ROP SDP. Because the performance deficiency, a failure to report, was not an ROP finding per IMC 0612, Appendix B, Issue Screening, a cross-cutting aspect was not assigned to this violation. Per the NRC Enforcement Policy, Section 6.0, Violation Examples, a failure to submit a required LER is categorized as an SL IV violation.
Enforcement:
Title 10 CFR 50.73(a)(2)(vii) requires, in part, that licensees report any event where a single cause or condition caused two independent trains to become inoperable in a single system designed to control the release of radioactive material.
Contrary to these requirements, on February 7, 2012, the licensee failed to report that both SBV trains A and B were inoperable from January 6, 2011, through January 26, 2011, from a single cause of unqualified parts. Because this violation was not repetitive or willful, and was entered into the licensees CAP as CR429469, this violation is being treated as an SL IV NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000305/2012002-06, Failure to Submit LER Per 10 CFR 50.73).
The licensee entered this into their CAP, planned to perform an ACE, and is drafting an update to Licensee Event Report (LER) 05000305/2011-005.
4OA5 Other Activities
.1 Temporary Instructions (TI) -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, the 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 of the review described above, Phase I of TI-2515/182 was completed.
b.
Observations The licensees buried piping and underground piping and tanks program was inspected in accordance with Paragraphs 03.01.a through 03.01.c of TI-2515/182, and was found to meet all applicable aspects of NEI 09-14, Revision 1, as set forth in Table 1 of the TI.
c. Findings
No findings were identified.
.2 (Closed) URI 05000305/2011004-02:
Failure to Perform Maintenance Rule Evaluations for Risk Significant Fire Door Failures
a. Inspection Scope
During a 2011 FP inspection sample, the inspectors identified that the licensee was not performing maintenance rule evaluations for risk significant fire doors as required by its maintenance rule program. The licensee entered this into their CAP and at the conclusion of the inspection period, was performing a historical review of door failures to determine if the maintenance rule doors system should be monitored in accordance with 10 CFR 50.65a(1). The inspectors reviewed the additional door failures indentified in the licensees review and did not identify a violation of 10 CFR 50.65a(1). This URI is closed.
b. Findings
During the closure of this URI, the inspectors identified a violation 10 CFR Part 50, Appendix B, Criterion V, Procedures, which is documented in Section 1R22.
Additionally, the inspectors documented a licensee-identified violation in Section 4OA7.
4OA6 Management Meetings
Exit Meeting Summary
On April 4, 2012, the inspectors presented the inspection results to Mr. A. Jordan, and other members of the licensee staff. The licensee acknowledged the issues presented.
The inspectors confirmed that none of the potential report input discussed was considered proprietary.
Interim Exit Meetings
- The Review of TI-2515/182, Industry Initiative to Control Degradation of Underground Piping and Tanks, with Site Vice-President, Mr. A. Jordan, and other members of the licensee staff on February 1, 2012. The licensee confirmed that none of the potential report input discussed was considered proprietary.
- Notification to the station of the licensee-identified violation with Mr. A. Fahrenkrug, Supervisor, Licensed Operator Requalification Training, via telephone on March 27, 2012.
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 Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as NCVs.
.1 Calculation Error Leads to Inadequate Post-Maintenance Test Procedure
Title 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances.
Contrary to this, on November 28, 2011 and December 5, 2011, procedure ER-KW-STP-DGM-002A and -002B, Post-Tie-in Testing for DC KW-10-01101, Train A and Post-Tie-in Testing for DC KW-10-01101, Train B which were one time use special test procedures, were not appropriate to the circumstances. Specifically, the procedures determined the leak rate for the SR backup air supply for the EDG ventilation dampers and because of a calculation error, the procedure only required a test duration of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> instead of a test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee corrected the operations version of the procedure and, during the quarterly test of train A on February 19, 2012, found the leakage to be greater than expected, and determined the installed bottles would not have enough air to support operation of the dampers for 7 days without manual operator action. The licensee repaired the leaking components and entered this into the CAP as CRs 460168 and 463265. The air bottles contained enough air to operate the dampers for approximately 3.5 days, which exceeded the 24-hour PRA mission time of the EDG, and therefore, the inspectors screened this finding as having very low safety significance (Green).
.2 Appendix R Fire Door Pinned Open and Unattended
License condition 2.C(3) required the licensee to implement and maintain, in effect, all provisions of the approved FP program as described in the licensees fire plan, and as referenced in the USAR, and as approved through Safety Evaluation Reports dated November 25, 1977, and December 12, 1978, and supplement dated February 13, 1981.
Appendix B of the KPS Fire Protection Program Plan lists the 1975 edition of NFPA-80, Fire Doors and Windows, as an applicable NFPA code. NFPA-80 states, in part, that a fire door shall be closed and latched at the time of fire.
Contrary to the above, on May 15, 2010, the licensee failed to implement and maintain, in effect, all provisions of the approved FP program as described in the licensees Fire Plan. Specifically, the licensee found fire door 265 unattended and propped open with the doors bottom bolt engaged in the floor. The licensee closed fire door 265 and entered this into their CAP as CR381342. The inspectors walked down both sides of the fire door using guidance from IMC 0609, Appendix F, Fire Protection Significance Determination Process, and concluded that no creditable fire scenario existed that would allow fire to pass from either the alternate fire area to the dedicated fire area or from the dedicated fire area to the alternate fire area. The inspectors screened this finding as having very low safety significance (Green).
.3 Failure of Licensed Operator to Report a Medical Condition
On December 21, 2005, a KPS employee was diagnosed with sleep apnea and was prescribed a CPAP [Continuous Positive Airway Pressure] device to aid in correcting sleep patterns. The employee was subsequently enrolled in the KPS initial operator license training to obtain an NRC operators license. The employee did not report the use of the CPAP device to the site nurse when she was preparing the applicants medical certification in conjunction with his application to the NRC to become a licensed operator. This prescribed device was used to treat sleep apnea and was a condition requiring notification of the NRC. The employee was unaware of the requirement to report the use of CPAP devices.
The employee was issued an NRC operating license on March 2, 2011, without a requirement to use therapeutic devices as directed. The NRC issued the operators license without knowledge of the operators medical condition. If the NRC had been informed of this medical condition, the NRC would have required a medical restriction be included in the operators license. This was a potential violation of 10 CFR 50.9, Completeness and Accuracy of Information.
On July 6, 2011, the operator notified the site nurse of his prescription for a CPAP device. On August 1, 2011, the licensee notified the NRC of the need to add this condition to the operators license. On October 24, 2011, the NRC amended the operators license to include the license condition, must use therapeutic devices as prescribed to maintain medical qualifications. Since the license had previously been submitted without the license condition, and the NRC doctor determined that the license needed to be revised; the original license submittal was incomplete/inaccurate. As such, this was a violation of 10 CFR 50.9.
Because this issue impacted the ability of the NRC to perform its regulatory oversight function, the regulatory significance was determined using the traditional enforcement process. The inspectors determined that the operators medical condition did not adversely affect the operators ability to safely operate the facility even though the operators license was incorrect. The operators performance was monitored and evaluated as satisfactory during periodic testing and requalification testing. As such, the NRC determined this to be an SL IV violation, which may be dispositioned as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.
Corrective actions included a resubmitted NRC Form 396 for the operator, documenting the issue in CR435966, and performing an ACE. Additionally, the licensee conducts annual training regarding operator license restrictions, including the use of prescribed medication, therapeutic devices, and reporting of medical conditions.
The inspectors review of this issue was considered to be a part of the original inspection effort, and as such did not constitute any additional inspection samples.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- S. Jordan, Site Vice President
- S. Yuen, Director of Engineering
- V. Armentrout, Dominion Fleet Buried Pipe Program Owner
- J. Rusch, Site Buried Piping Program Owner
- T. Breene, Licensing Manager
- M. J. Haese, Licensing
- J. Gadzala, Licensing
- R. Repshas, Licensing
- J. Kudick, Engineering
- J. Stafford, Director, Safety & Licensing
- R. Simmons, Plant Manager
- J. Grau, Maintenance Manager
- D. Lawrence, Operations Manager
- D. Asbel, Planning & Scheduling Manager
- J. Madden, System Engineering Manager
- R. Schaefer, Supply Chain
- R. Adams, Radiation Protection
- M. Aulik, Design Engineering Manager
- A. Fahrenkrug, Licensed Operator Requalification Training Program Supervisor
Nuclear Regulatory Commission
- K. Riemer, Chief, Division of Reactor Projects, Branch 2
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000305/2012002-01 URI Incorrectly Modeled Ventilation Damper Changes Daily Risk Color (Section 1R13.1(1))
- 05000305/2012002-02 URI Potential Mobile Crane Heavy Load Risk Modeling Error (Section 1R13.1 (2))
- 05000305/2012002-03 URI Potential Inadequate Commercial Grade Dedication (Section 1R18.1)
- 05000305/2012002-04 NCV Inadequate Post-Maintenance Test of Motor Replacements (Section 1R19.1)
- 05000305/2012002-05 NCV Inadequate Procedure For Technical Specification Surveillance (Section 1R22.1)
- 05000305/2012002-06 NCV Failure to Submit LER Per 10 CFR 50.73 (Section 4OA3.2)
Closed
- 05000305/2012002-04 NCV Inadequate Post-Maintenance Test of Motor Replacements (Section 1R19.1)
- 05000305/2012002-05 NCV Inadequate Procedure For Technical Specification Surveillance (Section 1R22.1)
- 05000305/2011-005-00 LER Shield Building Ventilation Train Inoperable for Longer Period Than Allowed by Technical Specifications (Section 4OA3.2)
- 05000305/2012002-06 NCV Failure to Submit LER Per 10 CFR 50.73 (Section 4OA3.2)
- 05000305/2011004-02 URI Failure to Perform Maintenance Rule Evaluations for Risk Significant Fire Door Failures (Section 4OA5.2)