IR 05000324/2008004
| ML083050003 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/30/2008 |
| From: | Randy Musser NRC/RGN-II/DRP/RPB4 |
| To: | Waldrep B Carolina Power & Light Co |
| References | |
| IR-08-004 | |
| Download: ML083050003 (36) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 30, 2008
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION REPORT NOS.: 05000325/2008004 AND 05000324/2008004
Dear Mr. Waldrep:
On September 30, 2008, the US Nuclear Regulatory Commission (NRC) completed an inspection at your Brunswick Unit 1 and 2 facilities. The enclosed integrated inspection report documents the inspection findings, which were discussed on October 29, 2008, with you 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.
Based on the results of this inspection, no findings of significance were identified. Four licensee-identified violations which were determined to be of very low safety significance are listed in this report. The NRC is treating these findings as non-cited violations (NCVs), in accordance with Section VI.A.1 of the NRCs 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 II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Brunswick Steam Electric Plant.
CP&L 2 In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs 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/
Randall A. Musser, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62
Enclosure:
Inspection Report 05000325, 324/2008004 w/Attachment: Supplemental Information
REGION II==
Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62 Report Nos.: 05000325/2008004, 05000324/2008004 Licensee: Carolina Power and Light (CP&L)
Facility: Brunswick Steam Electric Plant, Units 1 & 2 Location: 8470 River Road, SE Southport, NC 28461 Dates: July 1, 2008 through September 30, 2008 Inspectors: J. Austin, Senior Resident Inspector P. OBryan, Senior Resident Inspector G. Kolcum, Resident Inspector R. Lewis, Senior Reactor Inspector (1R17)
R. Moore, Senior Reactor Inspector (1R17)
C. Even, Reactor Inspector (1R17)
M. Coursey, Reactor Inspector (1R17)
B. Collins, Reactor Inspector (1R17)
J. Eargle, Reactor Inspector (1R17)
Approved by: Randall A. Musser, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000325/2008004, 0500324/2008004; 07/01/2008 - 09/30/2008; Brunswick Steam Electric
Plant Unit 1 and Unit 2; Routine Baseline Inspection Report.
This report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609,
Significance Determination Process (SDP). The 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-Revealing Findings
None
Licensee Identified Violations
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 corrective actions are listed in Section 4OA7.
REPORT DETAILS
Summary of Plant Status
Unit 1 Unit 1 began the inspection period operating at full power. On August 1, power was reduced to 69 percent for valve testing and returned to 100 percent. On August 3, power was reduced to 88 percent and returned to 100 percent for a control rod improvement. On August 4, power was reduced to 93 percent for a control rod improvement and returned to full power that day and remained there for the duration of the inspection period.
Unit 2 Unit 2 began the inspection period operating at 100 percent power. On July 17, power was reduced to 98 percent for a control rod improvement. The unit was returned to full power that day. On July 31, power was reduced to 98 percent for a control rod improvement. The unit was returned to full power that day. On August 11, power was reduced to 90 percent for a control rod improvement. The unit was returned to full power that day. On August 17, power was reduced to 89 percent for a control rod improvement. The unit was returned to full power that day. On August 24, power was reduced to 89 percent for a control rod improvement. The unit was returned to full power that day. On August 30, the unit scrammed from a power load unbalance trip. The unit commenced startup on Sept 2. Unit 2 maintained power at 75 percent due to the arrival of Tropical Storm Hanna on September 6. Power ascension continued after the passing of Tropical Storm Hanna to 97 percent on September 7. On September 8, power was reduced to 88 percent for a control rod improvement. The unit was returned to full power that day. Again on September 8, power was reduced to 97 percent for a control rod improvement. The unit was returned to full power that day. On September 14, power was reduced to 97 percent for a control rod improvement. The unit was returned to full power that day. Again on September 14, power was reduced to 90 percent due to 1D and 2A circulating water ocean discharge (CWOD) pumps out of service. On September 17, after the repair of 1D CWOD, the unit was returned to full power. On September 21, power was reduced to 95 percent for a control rod improvement and to rinse in 2D condensate deepbed demineralizer.
The unit was returned to full power that day and remained there for the duration of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection
.1 Evaluate Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed actions taken by the licensee in accordance with Procedure AOP-13, Operation During Hurricane, Flood Conditions, Tornado, or Earthquake, prior to the onset of Hurricane Hanna, to ensure that the adverse weather conditions would neither initiate a plant event nor prevent any system, structure, or component from performing its design function. The inspectors also evaluated implementation of the adverse weather preparation procedures and compensatory measures for the affected conditions before the onset of and during adverse weather conditions. Severe weather occurred on:
- September 4 for a Hurricane watch
- September 5 for a Tornado watch
- September 6 for a Tropical Storm warning Documents reviewed are listed in the Attachment to this report. 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.
- AR 295107, Oil in storm drain collection basin during Tropical Storm Hanna
- AR 295057, Switchyard fence laid down during Tropical Storm Hanna
b. Findings
No findings of significance were identified.
.2 Evaluate Readiness to Cope with External Flooding
a. Inspection Scope
The inspectors evaluated the design, material condition, and procedures for coping with the design basis probable maximum flood. The evaluation included a review to check for deviations from the descriptions provided in the Updated Final Safety Analysis Report (UFSAR) for features intended to mitigate the potential for flooding from external factors.
As part of this evaluation, the inspectors checked for obstructions that could prevent draining, checked that the roofs did not contain obvious loose items that could clog drains in the event of heavy precipitation, and determined that barriers required to mitigate the flood were in place and operable. Additionally, the inspectors performed a walkdown of the protected area to identify any modification to the site which would inhibit site drainage during a probable maximum precipitation event or allow water ingress past a barrier. The inspectors also reviewed the abnormal operating procedures (AOP) for mitigating the design basis flood to ensure it could be implemented as written.
Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed three partial walkdowns of the below-listed systems to verify that the systems were correctly aligned while the redundant train or system was inoperable or out-of-service (OOS) or, for single train risk significant systems, while the system was available in a standby condition. The inspectors assessed conditions such as equipment alignment (i.e., valve positions, damper positions, and breaker alignment)and system operational readiness (i.e., control power and permissive status) that could affect operability. The inspectors verified that the licensee identified and resolved equipment alignment problems that could cause initiating events or impact mitigating system availability. The inspectors reviewed Administrative Procedure ADM-NGGC-0106, Configuration Management Program Implementation, to verify that available structures, systems or components (SSCs) met the requirements of the configuration control program. Documents reviewed are listed in the Attachment.
- EDG #1, #2, and #3 recirculation dampers while EDG #4 recirculation damper was calibrated on September 10, 2008 To assess the licensees ability to identify and correct problems, the inspectors reviewed the following ARs:
- AR 295847, 2A CSW pump declared inop due to d/p within the alert range
b. Findings
No findings of significance were identified.
.2 Detailed Equipment Walkdown
a. Inspection Scope
The inspectors performed a complete walkdown of the accessible portions of Emergency Diesel Generator #1, #2, #3, and #4 the week of July 21, 2008. The inspectors focused on verifying adequate material condition and correct system alignment. The inspectors reviewed the Technical Specifications (TS), operating procedures, and the Updated Final Safety Analysis Report. The inspectors held discussions with the applicable plant personnel to review system status including a review of open system modifications and temporary modifications. The inspectors reviewed open work requests (WRs) for the system, operator work-arounds, and open adverse conditions or ARs to ensure that the impact on equipment functionality was properly evaluated. The inspectors reviewed the documents listed in the Attachment.
To assess the licensees ability to identify and correct problems, the inspectors reviewed the following ARs:
b. Findings
No findings of significance were identified.
1R05 Fire Protection
.1 Fire Area Walkdowns
a. Inspection Scope
The inspectors reviewed ARs and work orders (WOs) associated with the fire suppression system to confirm that their disposition was in accordance with Administrative Procedure 0AP-033, Fire Protection Program Manual. The inspectors reviewed the status of ongoing surveillance activities to verify that they were current to support the operability of the fire protection system. In addition, the inspectors observed the fire suppression and detection equipment to determine whether any conditions or deficiencies existed which would impair the operability of that equipment. The inspectors toured the following eight areas important to reactor safety and reviewed the associated prefire plans to verify that the requirements for fire protection design features, fire area boundaries, and combustible loading were met. The inspectors reviewed Plant Operating Manual, Volume XIX, Prefire Plan 0PFP-DG, Diesel Generator Building Prefire Plans in preparing for the inspection.
- Unit 1 and Unit 2 Reactor Building East 50 elevation (2 areas)
- Unit 1 and Unit 2 Reactor Building West 50 elevation (2 areas)
- Unit 1 and Unit 2 Reactor Building North 20 elevation (2 areas)
- Unit 1 and Unit 2 Reactor Building South 20 elevation (2 areas)
To assess the licensees ability to identify and correct problems, the inspectors reviewed the following ARs:
- AR 286392, U1 turbine building exhaust fan room door blocked
- AR 290506, Offsite fire in vicinity of transmission lines
- AR 290609, Cracking issues on red angus fire hose
- AR 292935, Open holes found in diesel generator building fire barrier
- AR 293942, Fire brigade drill failure
- AR 296866, Diesel fire pump out of service > 48 hrs
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures
.1 Internal Flooding
a. Inspection Scope
The inspectors performed a walkdown of the U1 and U2 Core Spray rooms to verify that internal flood protection features were consistent with the licensees internal flooding analysis as described in UFSAR Section 3.4.2, Protection From Internal Flooding. The inspectors reviewed the effects of postulated piping failures for the area to verify that analysis assumptions and conclusions were based on the current plant configuration.
The internal flooding design features and equipment for coping with internal flooding were also inspected. The walkdown included sources of flooding and drainage, sump pumps, level switches, watertight doors, curbs, pedestals and equipment mounting. The inspectors reviewed the procedures for coping with internal flooding.
To assess the licensees ability to identify and correct problems, the inspectors reviewed the following ARs and WRs:
- AR 296021, 2C CSW pump strainer leakage
- AR 297816, Safety system outage delay
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification
.1 Quarterly Review
a. Inspection Scope
The inspectors observed licensed operator performance and reviewed the associated training documents during simulator-evaluated scenarios for training cycle 2008-03. The simulator observations and review included evaluations of emergency operating procedure and abnormal operating procedure utilization. The inspectors reviewed Procedure 0TPP-200, Licensed Operator Continuing Training Program, to verify that the program ensures safe power plant operation. On August 12, 2008, simulator sessions were observed on anticipated and unanticipated plant transients during seismic event, nitrogen leak, steam leak, high radiation alarm, reactor scram, and a drywell high range radiation monitor alarm. The scenarios tested the operators ability to respond to failures. The inspectors reviewed operator activities to verify consistent clarity and formality of communication, conservative decision-making by the crew, appropriate use of procedures, and proper alarm response. Group dynamics and supervisory oversight, including the ability to properly identify and implement appropriate TS actions, regulatory reports, and notifications, were observed. The inspectors observed instructor critiques and preliminary grading of the operating crews and assessed whether appropriate feedback was planned to be provided to the licensed operators.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
For the two equipment issues described in the ARs listed below, the inspectors reviewed the licensees implementation of the Maintenance Rule (10 CFR 50.65) with respect to the characterization of failures, the appropriateness of the associated Maintenance Rule a(1) or a(2) classification, and the appropriateness of the associated a(1) goals and corrective actions. The inspectors reviewed the work controls and work practices associated with the degraded performance or condition to verify that they were appropriate and did not contribute to the issue. The inspectors also reviewed operations logs and licensee event reports to verify unavailability times of components and systems, if applicable. Licensee performance was evaluated against the requirements of Procedure ADM-NGGC-0101, Maintenance Rule Program.
- AR 288267, Cable spread room damper solenoid failed shortly after replacement To assess the licensees ability to identify and correct problems, the inspectors reviewed the following ARs:
- AR 292192, 2-CAC-TY-4426-2 Suppression pool temperature monitoring system failed
- AR 296146, 1D CWOD pump discharge head liner missing bolts
- AR 287851, 10 VDC reading out of tech spec during 0MST-IRM24R on IRM H
- AR 289850, 1A CSW pump inop
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensees implementation of 10 CFR 50.65 (a)(4)requirements during scheduled and emergent maintenance activities, using Procedure 0AP-025, BNP Integrated Scheduling and Technical Requirements Manual 5.5.13, Configuration Risk Management Program. The inspectors reviewed the effectiveness of risk assessments performed due to changes in plant configuration for maintenance activities (planned and emergent). The review was conducted to verify that, upon unforeseen situations, the licensee had taken the necessary steps to plan and control the resultant emergent work activities. The inspectors reviewed the applicable plant risk profiles, work week schedules, and maintenance WOs for the following four conditions:
- Unit 2 entered Yellow risk condition for performing 0MST-RHR-26Q, RHR and Core Spray low reactor pressure functions during week of July 7, 2008
- WO 1386051 for Unit 1 RCIC when U1 HPCI OOS on July 18, 2008 for main pump seal failure (emergent)
- WO 1398802 Unit 2 RCIC while HPCI was OOS for scheduled maintenance on August 13, 2008
- EDG #1, #3, and #4 while EDG #2 was OOS for scheduled maintenance on September 30, 2008 To assess the licensees ability to identify and correct problems, the inspectors reviewed the following ARs:
- AR 294746, Adverse trend seen in U2 control rod performance due to double notching
- AR 295008, U2 main stop valve #3 indication
- AR 286221, 1A reactor recirculation pump seal #2 pressure
- AR 292706, Unplanned LCO entry for suppression pool level indicator 2-CAC-LI-3342
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the operability evaluations associated with the five issues documented in the ARs listed below, which affected risk significant systems or components, to assess, as appropriate: 1) the technical adequacy of the evaluations; 2) the justification of continued system operability; 3) any existing degraded conditions used as compensatory measures; 4) the adequacy of any compensatory measures in place, including their intended use and control; and 5) where continued operability was considered unjustified, the impact on any TS limiting condition for operation and the risk significance. In addition to the reviews, discussions were conducted with the applicable system engineer regarding the ability of the system to perform its intended safety function.
- AR 295999, 2C CSW discharge strainer sheer pin failure
- AR 291455, Unexpected Rx Bldg ventilation isolation and auto start of 2A Standby Gas Treatment system
b. Findings
No findings of significance were identified.
1R17 Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications
a. Inspection Scope
The inspectors reviewed selected samples of evaluations to confirm that the licensee had appropriately considered the conditions under which changes to the facility, Updated Final Safety Analysis Report (UFSAR), or procedures may be made, and tests conducted, without prior NRC approval. The inspectors reviewed evaluations for eleven changes and additional information, such as drawings, calculations, supporting analyses, the UFSAR, and Technical Specifications (TS) to confirm that the licensee had appropriately concluded that the changes could be accomplished without obtaining a license amendment. The nine evaluations reviewed are listed in the List of Documents Reviewed.
The inspectors reviewed samples of changes for which the licensee had determined that evaluations were not required, to confirm that the licensees conclusions to screen out these changes were correct and consistent with 10 CFR 50.59. The 19 screened out changes reviewed are listed in the List of Documents Reviewed.
The inspectors evaluated engineering design change packages for eleven material and design based modifications to evaluate the modifications for adverse effects on system availability, reliability, and functional capability. The eleven modifications and the associated attributes reviewed are as follows:
EC 58110, Allow Use of Improved Bonnet/Gland Design for 10 ADV DDGV Applicable to E41-F001/2/3, Rev. 2 (Mitigating Systems)
- Materials Replacement Components
- Operations
- Licensing Basis
- Post Modification Testing EC 51218, Enhance Valve Stem Anti-Rotation Arm for Valves 1(2)-E51-F022, Rev. 0 (Mitigating Systems)
- Materials Replacement Components
- Operations
- Licensing Basis
- Post Modification Testing EC 66710, Replacement of CST Level Switches for HPCI/RCIC Suction, Rev. 3 (Mitigating Systems)
- Materials Replacement Components
- Operations
- Licensing Basis
- Post Modification Testing
- Energy Needs
- Control signals EC 63126, Replace DG Excitation Potential Transformers, Rev. 2 (Mitigating Systems)
- Energy Needs
- Materials/Replacement Components
- Licensing Basis EC 66593, DG Shutdown Circuit Logic Change, Rev. 1 (Mitigating Systems)
- Timing
- Control Signals
- Licensing Basis EC 62707, EDG Jacket Water Cooler Expansion Joint, Rev 1 (Mitigating Systems)
- Materials/Replacement Components
- Process Medium
- Pressure Boundary EC 64711, Modification to Replace Aging and Obsolete Shutdown Interlock Valves on Diesel Generators, Rev. 3 (Mitigating Systems)
- Energy Needs
- Materials/Replacement Components
- Timing
- Heat Removal
- Control Signals
- Equipment Protection
- Flowpaths
- Structural
- Process Medium
- Licensing Basis
- Failure Modes EC 65981, Specification 21A9206 Material Reconciliation, Rev. 000 (Barrier Integrity)
- Materials/Replacement Components
- Pressure Boundary EC 50913, MOVs 1/2-E11-F007A/B Operator Motor Gear Ratio Changes (Mitigating Systems)
- Timing
- Control Signals
- Process Medium EC 59437, Diesel Starting Air Inventory Requirements (Mitigating Systems)
- Energy Needs
- Timing
- Flowpaths
- Process Medium EC 63274, Replace Obsolete Reactor Building RR (209 and 210) Lock Components (Barrier Integrity)
- Materials/Replacement Components
- Structural Documents reviewed included procedures, engineering calculations, modification design and implementation packages, work orders, site drawings, corrective action documents, applicable sections of the UFSAR, supporting analyses, Technical Specifications, and design basis information. The inspectors additionally reviewed test documentation to ensure adequacy in scope and conclusion. The inspectors review was also intended to verify that all details were incorporated in licensing and design basis documents and associated plant procedures.
The inspectors also reviewed selected ARs and the licensees recent self-assessment associated with modifications and screening/evaluation issues to confirm that problems were identified at an appropriate threshold and were entered into the corrective action process, and appropriate corrective actions had been initiated and tracked to completion.
b. Findings
No findings of significance were identified.
1R18 Plant Modifications
.1 Temporary Modifications
a. Inspection Scope
The inspectors reviewed Plant Operating Manual 0PLP-22, Temporary Changes, to assess the need for implementation of a temporary modification to route the water from the north core spray sump to the residual heat removal (RHR) sump during a maintenance activity (which was supported by the engineering change listed below) to replace the Unit 1 North core spray sump liner. The inspectors also assessed drawings and procedures for appropriate updating and post-modification testing.
- Engineering Change (EC) 69995, Unit 1 North core spray sump liner degradation
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
For the five maintenance activities listed below, the inspectors reviewed the post-maintenance test procedure and witnessed the testing and/or reviewed test records to confirm that the scope of testing adequately verified that the work performed was correctly completed. The inspectors verified that the test demonstrated that the affected equipment was capable of performing its intended function and was operable in accordance with TS requirements. The inspectors reviewed the licensees actions against the requirements in Procedure 0PLP-20, Post Maintenance Testing Program.
- WO 1383024, Emergency Diesel Generator (EDG) #2 oscillations
- WO 1414604, 1A Nuclear Service Water (NSW) pump inop due to not being able to rack breaker in
- WO 1407370, Control Rod Drive (CRD) flow controller replacement and PMT
- WO 1386051, High Pressure Coolant Injection (HPCI) main pump seal failure
- WO 1398802, HPCI seal plate bushing measurements
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
.1 Routine Surveillance Testing
a. Inspection Scope
The inspectors either observed surveillance tests or reviewed test data for the seven risk significant SSC surveillances listed below to verify the tests met TS surveillance requirements, UFSAR commitments, inservice testing (IST) requirements, and licensee procedural requirements. The inspectors assessed the effectiveness of the tests in demonstrating that the SSCs were operationally capable of performing their intended safety functions.
- Unit 2, 0PT- 40.2.12 Main Turbine Bypass Valves Operability Test Revision 8 on August 10, 2008
- Unit 2, 0PT-07.1.8 Core Spray System Component Test Revision 24 on August 27, 2008
- Unit 1, 0PT-02.3.1B Suppression Pool to Drywell Vacuum Breaker Position Check Revision 9 on August 29, 2008
- Unit 2, 0PT-14.1A Control Rod Coupling Check and CRD Testing Revision 38 on September 3, 2008
- Unit 2, 0PT-24.0.-2 Service Water System Valve Lineup Revision 12 on September 26, 2008 To assess the licensees ability to identify and correct problems, the inspectors reviewed:
- AR 290930, U2 main turbine bypass valve failures
- AR 294914, Unexpected inoperability U2 main turbine bypass system
b. Findings
No findings of significance were identified.
.2 In-service Surveillance Testing
a. Inspection Scope
The inspectors reviewed the performance of Periodic Test 0PT-16.1, CAD system Component Test, Revision 24, performed on August 2, 2008. The inspectors evaluated the effectiveness of the licensees American Society of Mechanical Engineers (ASME)
Section XI testing program to determine equipment availability and reliability. The inspectors evaluated selected portions of the following areas: 1) testing procedures; 2)acceptance criteria; 3) testing methods; 4) compliance with the licensees IST program, TS, selected licensee commitments, and code requirements; 5) range and accuracy of test instruments; and 6) required corrective actions. The inspectors also assessed any applicable corrective actions taken.
b. Findings
No findings of significance were identified.
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors observed one site emergency preparedness training drill and two simulator scenarios conducted on July 22, 2008, July 29, 2008 and August 13, 2008.
The inspectors reviewed the drill scenario narrative to identify the timing and location of classifications, notifications, and protective action recommendations development activities. The inspectors evaluated the drill conduct from the control room simulator, technical support center, and the emergency operations facility. During the drill, the inspectors assessed the adequacy of event classification and notification activities. The inspectors observed portions of the licensees post-drill critiques at the technical support center and emergency operating facility. The inspectors verified that the licensee properly evaluated the drills performance with respect to performance indicators and assessed drill performance with respect to drill objectives.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
The inspectors sampled licensee data for the performance indicator (PI) listed below.
To verify the accuracy of the PI data reported during the period reviewed, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, and Rev. 5 was used to verify the basis for each data element.
Reactor Safety Cornerstone The inspectors sampled licensee submittals for the Units 1 and 2 PIs listed below for the period September 2007 through June 2008.
- Mitigating Systems Performance Index, Residual Heat removal system
- Reactor coolant system specific activity
- Reactor coolant system leakage
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Routine Review of ARs
To aid in the identification of repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed frequent screenings of items entered into the licensees CAP. The review was accomplished by reviewing daily ARs.
.2 Annual Sample Review
a. Inspection Scope
The inspectors performed an in-depth annual sample review of selected ARs to determine whether conditions adverse to quality were addressed in a manner that was commensurate with the safety significance of the issue. The inspectors reviewed the actions taken to verify that the licensee had adequately addressed the following attributes:
- Complete, accurate, and timely identification of the problem
- Evaluation and disposition of operability and reportability issues
- Consideration of previous failures, extent of condition, generic or common cause implications
- Prioritization and resolution of the issue commensurate with the safety significance
- Identification of the root cause and contributing causes of the problem
- Identification and implementation of corrective actions commensurate with the safety significance of the issue The inspectors reviewed the following issues:
b. Findings
No findings of significance were identified.
4OA3 Event Follow-up
.1 Personnel Performance During Plant Evolutions
a. Inspection Scope
The inspectors reviewed the operator response to an unplanned scram which occurred on August 30, 2008. To assess operator performance during the transient, the inspectors reviewed operator logs, plant computer data, associated operator actions and Emergency Operating Procedure 2EOP-01-RSP, Reactor Scram Procedure. The inspectors monitored and reviewed the Scram Investigation Team and the post-trip review. Unit 2 entered Mode 3 (Hot shutdown) following the scram on August 30. Mode 2 (startup) was entered on September 2 and Mode 1 (Power Operation) was entered on September 3. Documents reviewed are listed in the Attachment. The following specific areas were reviewed during the inspection period:
Outage Plan. The inspectors reviewed the outage plan to verify that the licensee has considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense-in-depth.
Licensee Control of Outage Activities. The inspectors observed and reviewed activities and plant conditions to verify that the licensee maintained defense-in-depth commensurate with the outage risk control plan. The inspectors reviewed the electric power systems to ensure emergency power was available.
Monitoring of Startup Activities. The inspectors verified on a sampling basis, that TS, license conditions, and other requirements, commitments, and administrative procedure prerequisites for mode changes were met prior to changing modes or plant configurations. The inspectors observed and monitored the startup of Unit 2 including the approach to criticality, parallel to the grid, and power ascension.
Identification and Resolution of Problems. The inspectors reviewed ARs to verify that the licensee was identifying problems related to outage activities at an appropriate threshold and entering them in the corrective action program. The inspectors reviewed the following issues identified during the outage to verify that the appropriate corrective actions were implemented or planned:
- AR 294333, Scram discharge volume level switch reset time excessive for Unit 2 scram
- AR 294505, Common cause implementation of engineering changes
b. Findings
No findings of significance were identified.
.2 (Closed) LER 05000325/2006-007 and Supplement 1: Operations Prohibited by
Technical Specifications Due to Inoperable Emergency Diesel Generator 1. On November 1, 2006, Emergency Diesel Generator (EDG) tripped on low lube oil pressure while running unloaded in response to a loss of the Unit 2 start-up transformer. NRC Inspection Report 05000325, 324/2006004 identified the event as an unresolved issue (URI 05000325, 324/2006004-01). NRC Inspection Report 05000325, 324/2007008 closed the URI to a preliminary White apparent violation of TS 3.8.1, AC Sources -
Operating (AV 05000324/2007008-01). Final significance of the event was determined to be White (i.e. an issue of low to moderate safety significance) in NRC Inspection Report 05000325, 324/2007009 and the issue was documented as a violation of TS 3.8.1, AC Sources-Operating (VIO 05000324/2007009-01). This LER is closed.
.3 (Closed) Licensee Event Report (LER) 05000324/2007003 and Supplement 1: As-Found
Values for Safety/Relief Valve Lift Setpoints Outside Technical Specification Allowed Tolerance. This LER reported that as-found testing for four of the eleven safety/relief valves removed from Unit 2 during the Spring 2007 outage (i.e., B218R1) were outside the Technical Specification allowed setpoint tolerance. The cause of the failure of the valves was due to maintenance practices. The licensee has instituted corrective actions to preclude recurrence, including replacing all of the affected valves and revising maintenance procedures. The failure of these four safety/relief valves to lift within the allowed setpoint limits constituted a condition prohibited by TS 3.4.3. This finding is similar to example 2a of Manual Chapter 0612 appendix E in that the equipment exceeded technical specification limits and the finding is therefore greater than minor.
However, an evaluation of the as-found condition of the safety/relief valves was compared to the current overpressure analysis. The analysis concluded that the overpressure analysis remained bounding. Since the valves degradation would have had a minimal impact on design basis events, this finding has very low safety significance (Green). The enforcement aspects of this finding are discussed in Section 4OA7 of this report. This LER is closed.
.4 (Closed) Unresolved Item (URI) 05000325,324/2008002-01: Review Adequacy of
Suppression Pool Temperature Monitoring System Calibration. In NRC Inspection Report 05000325,324/2008002, dated April 25, 2008, the Resident Inspectors identified an unresolved item (URI 05000325,324/2008002-01) to further review the adequacy of suppression pool temperature monitoring system calibration relative to Technical Specification SR 3.3.3.1.3. The inspectors reviewed the licensees investigation (AR 267562) and concluded that there have been multiple instances of non-gross failures (e.g. drift high or low without reaching the automatic gross failure limit), within the temperature loops. However, a review of licensee actions taken to address the failures did not identify any specific deficiencies with the requirements of SR 3.3.3.1.3. No violations of regulatory requirements were identified. This URI is closed.
4OA5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status review and inspection activities.
b. Findings
No findings of significance were identified.
.2 (Open) Temporary Instruction (TI) 2515/176, Emergency Diesel Generator Technical
Specification Surveillance Requirements Regarding Endurance and Margin Testing.
a. Inspection Scope
The objective of this TI was to gather information to assess the adequacy of nuclear power plant emergency diesel generator (EDG) endurance and margin testing as prescribed by plant-specific technical specifications (TS). The inspector interfaced with the appropriate station staff to obtain the information specified in Attachment 1 of the TI, Worksheet. The TI applies to all operating nuclear power reactor licensees that use EDGs as the onsite standby power supply. The inspector verified the accuracy of the information by review of TS, EDG Design Basis Event (DBE) loading calculations, EDG endurance run test procedures, test data from the last three endurance tests performed on each EDG, EDG ratings, and EDG operating history. The information gathered will be forwarded to the office of Nuclear Reactor Regulation/Division of Engineering/Electrical Engineering Branch (NRR/DE/EEEB) for further review to assess the adequacy and consistency of EDG testing at nuclear stations.
b. Findings and Observations
The TI is presently scheduled to be open until August 31, 2009, pending completion of the NRR/DE/EEEB review.
4OA6 Meetings, Including Exit
On October 29, 2008, the resident inspectors presented the inspection results to Mr. Ben Waldrep and other members of his staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
4OA7 Licensee-Identified Violations
The following violations of very low safety significance (Green) were identified by the licensee and are a violation of NRC requirements which meet the criteria of Section VI.A.1 of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as NCVs.
.1 Technical Specification 5.4.1, Administrative Control (Procedures), requires that written
procedures shall be established, implemented, and maintained covering applicable procedures recommended in Regulatory Guide 1.33, Appendix A, November 1972.
Regulatory Guide 1.33, Section D
- (7) states, in part, that instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared, as appropriate for the Emergency Core Cooling System. Contrary to the above, the licensees procedure OP-19, HPCI System Operating Procedure, Revision 112, was inadequate because it contained unclear actions which resulted in a main pump seal failure from an inadequate fill and vent of the Unit 1 HPCI system cross-around piping after a complete drain and refill during outage B117R1. On April 29, 2008, as a result of inadequate venting of the HPCI pump, the inboard seal failed. This issue is more than minor because it affects the Mitigating Systems Cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent core damage and is associated with the cornerstone attribute of equipment performance. This finding is of very low safety significance because the HPCI pump did not exceed its allowed TS outage time. This issue has been entered into the CAP as AR 277188.
.2 Technical Specification 5.4.1, Administrative Control (Procedures), requires that written
procedures shall be established, implemented, and maintained covering applicable procedures recommended in Regulatory Guide 1.33, Appendix A, November 1972.
Regulatory Guide 1.33,Section I
- (1) states that maintenance that can affect the performance of safety-related equipment should be properly preplanned, and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to the above, the licensees procedure 0CM-PHM504, Pacific Pumps, Model RHCH, HPCI main pump maintenance, Revision 7, was inadequate because the pump was reassembled with an improper clearance between the seal sleeve and seal plate bushing. On July 18, 2008, the main pump inboard seal failed due to excessive heating at the shaft sleeve due to contact between the seal plate bushing and the shaft sleeve such that the shaft sleeve set screw force applied to the shaft was relieved, and the pump internal pressure forced the seal sleeve out 1/8 inch.
This 1/8 inch extension caused excessive force to be applied on the seal faces which resulted in premature failure due to seal face overheating followed by a quench. This issue is more than minor because it affects the Mitigating Systems Cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent core damage and is associated with the cornerstone attribute of equipment performance. This finding is of very low safety significance because the HPCI pump did not exceed its allowed TS outage time. This issue has been entered into the CAP as AR 287869.
.3 Technical Specification Limiting Condition for Operation 3.4.3, Safety/Relief Valves,
requires 10 safety/relief valves to be operable while in Mode 1 with their lift setpoints within a specified range. Contrary to this, during surveillance testing on safety/relief valves removed from Unit 2 during the Spring 2007 refueling outage (B218R1), four of the eleven valves actuated at pressures outside the technical specification limits. This finding is of very low safety significance because the as-found lift setpoint conditions of the Unit 2 safety/relief valves were analyzed and determined to meet the design basis criteria for an over-pressurization event. This issue has been entered into the CAP as AR 287535.
.4 10 CFR 50.65(a)(4) states, in part, that before performing maintenance activities, the
licensee shall assess and manage the risk that may result from the proposed maintenance activities. Contrary to the above, the licensee did not perform an adequate risk assessment of switchyard activities which involved operating a test device in the generator terminal current sensing circuitry in the switchyard relay house. Unit 2 automatically scrammed due to a spurious power load unbalance (PLU) turbine trip signal while the unit was in operation at 100% rated thermal power. This spurious signal was determined to be generated from the maintenance activities in the switchyard. The licensee determined that procedure 0AP-025 BNP Integrated Scheduling, which was used to implement Engineering Change, 68642, Digital Fault Recorder Replacement (Switchyard), did not adequately evaluate the post modification testing to be performed on the PLU circuit, and therefore did not characterize the maintenance as a contributor to the risk of a plant transient or reactor scram. The finding is of very low safety significance because the incremental core damage probability deficit is less than 1E-6 and the incremental large early release probability deficit is less than 1E-7. This issue has been entered into the CAP as AR 294164.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- M. Annacone, Director Site Operations
- G. Atkinson, Supervisor - Emergency Preparedness, Licensing/Regulatory Programs
- L. Beller, Superintendent, Operations Training
- A. Brittain, Manager - Security
- B. Davis, Manager - Engineering
- J. Fergusen, Manager - ER&C
- M. Grantham, Superintendent of Design Engineering
- D. Griffith, Manager - Training Manager
- S. Howard, Manager - Operations
- R. Ivey, Manager - Site Support Services
- J. Johnson, Chemistry Manager
- M. Millinor, Environmental
- W. Murray, Licensing Specialist
- T. Pearson, Supervisor - Operations Training
- A. Pope, Manager - Maintenance
- E. Rochelle, RC Supervisor
- T. Sherrill, Engineer - Technical Support
- J. Titrington, Manger - Nuclear Assessment Services
- J. Vincelli, RC Manager
- B. Waldrep, Site Vice President
- M. Williams, Manager - Operations Support
- E. Wills, Plant General Manager
NRC Personnel
Randall
- A. Musser, Chief, Reactor Projects Branch 4, Division of Reactor Projects Region II
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
None
Closed
- 05000325/2006-007 and LER Operations Prohibited by Technical Specifications Due Supplement 1 to Inoperable Emergency Diesel Generator (4OA3)
- 05000324/2007-003 and LER As-Found Values for Safety/Relief Valve Lift Setpoints Supplement 1 Outside Technical Specification Allowed Tolerance.
(4OA3)
- 05000325,324/2008002-01 URI Review Adequacy of Suppression Pool Temperature Monitoring System Calibration (4OA3)
Opened
2515/176 TI Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and Margin Testing (4OA5)