IR 05000324/2013010

IR 05000325-13-010, 05000324-13-010; 04/01/2013 - 12/31/2013; Brunswick Steam Electric Plant, Units 1 & 2; Adverse Weather Protection, Follow-up of Events

ML14080A229
Person / Time
Site:	Brunswick
Issue date:	03/21/2014
From:	Hopper G NRC/RGN-II/DRP/RPB4
To:	Hamrick G Duke Energy Progress
References
EA-14-048 IR-13-010
Download: ML14080A229 (34)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION rch 21, 2014

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - NRC INSPECTION REPORT NOS.

05000325/2013010 AND 05000324/2013010

Dear Mr. Hamrick:

This letter refers to the inspection conducted on April 1, 2013, through December 31, 2013, at the Duke Energy Progress Inc., Brunswick Steam Electric Plant. The purpose of the inspection was to review issues related to external flood mitigation onsite. The enclosed report presents the results of this inspection. The inspectors discussed the inspection findings with you and other members of your staff on February 6, February 27, and March 20, 2014.

Based on the results of this inspection, two apparent violations (AVs) associated with site flood mitigation, corrective actions, and reporting of flood impacts to safety-related equipment were identified and are being considered for escalated enforcement action in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. One AV was evaluated using the NRC Reactor Oversight Process (ROP), and one AV was evaluated using the NRC Traditional Enforcement Process.

The NRC identified an AV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, with two examples. The first example involved the failure of the licensee to promptly identify and correct conditions adverse to quality associated with flood protection of multiple safety-related buildings. Specifically, safety-related buildings, contained openings that were not identified and corrected by the licensee and would have adversely impacted their ability to mitigate external flooding of these buildings in the event of a design basis probable maximum hurricane (PMH).

This would have resulted in the potential loss of nine of the ten safety-related service water pumps (SWPs) during the specific PMH flooding event. The second example involved the failure of the licensee to correct a significant condition adverse to quality. Specifically, the licensee failed to implement a corrective action to preclude repetition by not adequately developing an engineering program to mitigate the consequences of external events (flooding, high winds, and seismic) that ensured appropriate equipment classifications, with interfacing programs of maintenance rule (MR) and zero tolerance for equipment failures. This violation does not present an immediate safety concern because the licensee has taken appropriate corrective actions. These issues are discussed in detail in Section 1R01.1 of this report. In accordance with NRC IMC 0609, Significance Determination Process (SDP), we intend to complete our risk evaluations using the best available information and issue our final significance determination within 90 days of the date of this letter. The SDP encourages an open dialogue between the NRC staff and the licensee; however, the dialogue should not impact the timeliness of the staffs final determination.

One of the associated AVs is being considered for escalated enforcement action in accordance with the NRC Traditional Enforcement Policy. Specifically, this issue involved the failure to report a condition prohibited by plant Technical Specification (TS) 3.7.2, Service Water (SW)

System and Ultimate Heat Sink, and an event that could have prevented the fulfillment of a safety function of the residual heat removal system as required by 10 CFR 50.73. This AV is being evaluated using the NRCs enforcement process because it impacted NRCs ability to perform its regulatory function. Additional details regarding this AV are provided in the enclosed inspection report.

Since the NRC has not made a final determination as to the significance of these issues, no Notice of Violation is being issued at this time. Please be advised that the number and characterization of the AVs described in the enclosure may change as a result of further NRC review. You will be advised by separate correspondence of the results of our deliberations on this matter.

Additionally, two NRC-identified findings of very low safety significance (Green) were identified during this inspection. These findings did not involve violations of NRC requirements. If you disagree with the cross-cutting aspect assignment or findings in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II, and the NRC Resident Inspector at the Brunswick Steam Electric Plant.

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, 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 Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely, George T. Hopper, 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, 324/2013010 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62 Report Nos.: 05000325/2013010, 05000324/2013010 Licensee: Duke Energy Progress, Inc.

Facility: Brunswick Steam Electric Plant, Units 1 & 2 Location: 8470 River Road, SE Southport, NC 28461 Dates: April 1, 2013 through December 31, 2013 Inspectors: M. Catts, Senior Resident Inspector M. Schwieg, Resident Inspector Approved by: George T. Hopper, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000325/2013010, 05000324/2013010; 04/01/2013 - 12/31/2013; Brunswick Steam

Electric Plant, Units 1 & 2; Adverse Weather Protection, Follow-up of Events This report covers a nine-month period of inspection by resident inspectors. Two Apparent Violations (AVs) and two Green findings were identified by the inspectors. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, issued June 19, 2012, Significance Determination Process. The cross-cutting aspects were determined using IMC 0310, Components Within the Cross-Cutting Areas, effective January 1, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated January 28, 2013. The NRCs program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision

Cornerstone: Mitigating Systems

• TBD. The NRC identified an AV of 10 CFR Part 50, Appendix B, Criterion XVI,

Corrective Action, with two examples. The first example involved the failure of the licensee to promptly identify and correct conditions adverse to quality associated with flood protection of multiple safety-related buildings. Specifically, the licensee failed to promptly identify or correct safety-related buildings that contained openings that would have adversely impacted their ability to mitigate external flooding of these buildings in the event of a design basis probable maximum hurricane (PMH). The second example involved the failure of the licensee to correct a significant condition adverse to quality.

Specifically, the licensee failed to implement a corrective action to preclude repetition by not adequately developing an engineering program to mitigate the consequences of external events (flooding, high winds, and seismic) that ensured appropriate equipment classifications, with interfacing programs of maintenance rule (MR) and zero tolerance for equipment failures.

This resulted in a violation of technical specification (TS) 3.7.2, Service Water (SW)

System and Ultimate Heat Sink, and TS 3.5.2, Emergency Core Cooling System (ECCS) - Shutdown, since the inoperability of the required number of service water pumps (SWPs) would violate TS 3.7.2, and TS 3.5.2 since SW cools the residual heat removal (RHR) system heat exchangers.

The inspectors determined the failure to identify and correct the missing and degraded flood barriers in multiple safety-related buildings, and the failure to implement a corrective action to preclude repetition by not developing an engineering program to mitigate the consequences of external events that ensured appropriate equipment classifications, with interfacing programs of MR and zero tolerance for equipment failures, was a performance deficiency. The finding was more than minor because it was associated with the protection against external factors attribute (flood hazard) of the

Mitigating Systems Cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, nine of the ten Unit 1 and Unit 2 SWPs would be potentially inoperable and unavailable during specified PMH events. Because the finding involved reactor shutdown operations and conditions, IMC 0609, Appendix G, Shutdown Operations Significance Determination Process (SDP),

Attachment 1, issued May 25, 2004, Phase 1 Operational Checklists for Both pressurized water reactors (PWRs) and boiling water reactors (BWRs), was used. The inspectors used Checklist 5, BWR Hot Shutdown: Time to Boil < 2 Hours, and determined the finding increased the likelihood that a loss of decay heat removal (DHR)will occur due to failure of the system itself or support systems, degraded the licensees ability to cope with a loss of offsite power (LOOP), degraded the licensees ability to add reactor coolant system (RCS) inventory when needed, and degraded the licensees ability to establish an alternate core cooling path if DHR could not be re-established for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Further, the performance deficiency involved external events. Consequently a Phase 2 analysis could not be performed and the issue screened directly to a Phase 3 analysis. The significance of this issue is To Be Determined (TBD) and its final significance will be dispositioned in separate transmittal. The issue is not an immediate safety concern because the licensee has taken appropriate corrective actions. The finding has a cross-cutting aspect in the area of human performance associated with the field presence attribute because deviations from standards and expectations were not corrected promptly, and the licensee did not ensure supervisory and management oversight of work activities, including contractors. Specifically, licensee management failed to ensure degradation associated with flood protection of the safety-related buildings was identified and corrected. [H.2] (Section 1R01.1)

Green.

An NRC-identified Green finding for the failure to meet the requirements of licensee procedure PRO-NGGC-0201, NGG Procedure Writers Guide, was identified with two examples. Specifically, the licensee failed to provide an adequate procedure with appropriate acceptance criteria to inspect flood protection doors for leakage and failed to have an adequate procedure to perform functionality assessments which met the requirements specified in Procedure PRO-NGGC-0201. The licensee entered these issues into the corrective action program (CAP) as nuclear condition reports (NCRs)631303, and 563113 and 580629, respectively.

The inspectors determined that the failure of the licensee to provide an adequate procedure to inspect flood protection doors for leakage and to have an adequate procedure which met the requirements of licensee Procedure PRO-NGGC-0201 to perform functionality assessments was a performance deficiency. The finding is more than minor because it is associated with the protection against external factors (i.e.,

flood hazard) attribute of the Mitigating Systems Cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).

Specifically, the flood protection door and flood penetration seals were missing or degraded which could have resulted in a flood pathway into the high pressure coolant injection (HPCI) system room and service water building (SWB) during a PMH. Using IMC 0609, Appendix A, issued June 9, 2012, The SDP for Findings At-Power, the inspectors determined the finding screened to Green because the individual door and penetration seal degradations did not involve the total loss of any safety function, identified by the licensee through a probabilistic risk assessment (PRA), individual plant examination of external events (IPEEE), or similar analysis, that contributes to external event initiated core damage accident sequences (i.e., initiated by a seismic, flooding, or severe weather event). The finding has a cross-cutting aspect in the area of human performance associated with the documentation attribute because the licensee failed to create and maintain complete, accurate and, up-to-date documentation to inspect flood protection doors and perform functionality assessments. [H.7] (Section 1R01.2)

Green.

An NRC-identified Green finding was identified for the failure of the licensee to follow Procedure OPS-NGGC-1305, Operability Determinations, to perform functionality assessments for degraded or non-conforming flood protection features. Specifically, the licensee failed to perform functionality assessments for flood protection features, including EDG building conduit seals and Unit 2 HPCI sump pump failures. The licensee entered these issues into the CAP as NCRs 613354 and 631442.

The inspectors determined the failure to follow Procedure OPS-NGGC-1305, to perform functionality assessments for degraded or non-conforming flood protection features, was a performance deficiency. The finding is more than minor because it is associated with the protection against external factors (i.e., flood hazard) attribute of the Mitigating Systems Cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to perform functionality assessments for degraded or non-conforming flood protection features could have resulted in a flood pathway into the HPCI room and EDG building during a PMH. Using IMC 0609, Appendix A, issued June 9, 2012, The SDP for Findings At-Power, the inspectors determined the finding screened to Green because the resulting individual functional assessments did not involve the total loss of any safety function, identified by the licensee through a PRA, IPEEE, or similar analysis, that contributes to external event initiated core damage accident sequences (i.e., initiated by a seismic, flooding, or severe weather event). The finding has a cross-cutting aspect in the area of human performance associated with the procedure adherence attribute because the licensee did not follow processes, procedures, and work instructions.

Specifically, the licensee revised Procedure OPS-NGGC-1305 for performing functionality assessments but did not effectively communicate the new procedural requirements to operations personnel such that functionality assessments were performed when required. [H.8] (Section 1R01.3)

• TBD. An NRC-identified AV of 10 CFR 50.73(a)(2)(i)(B) and 10 CFR 50.73(a)(2)(v)(B),

was identified for failure of the licensee to provide a written Licensee Event Report (LER)to the NRC within 60 days of identifying a condition which was prohibited by plant TS 3.7.2, SW System and Ultimate Heat Sink, and an event that could have prevented the fulfillment of a safety function of RHR. The licensees corrective actions included submitting LER 50-325 and 50-324/2013-003-00 on November 14, 2013. The licensee entered this issue into the CAP as NCR 629064.

The inspectors determined the failure of the licensee to provide a written LER to the NRC within 60 days as required by 10 CFR 50.73(a)(2)(i)(B) and 10 CFR 50.73(a)(2)(v)(B) was a performance deficiency. This violation involved a failure to make a required report to the NRC and is considered to impact the regulatory process. Such violations are dispositioned using the traditional enforcement process instead of the SDP. As discussed in the Enforcement Policy, the severity level of a violation involving the failure to make a required report to the NRC will be based upon the significance of and the circumstances surrounding the matter that should have been reported. This issue is being characterized as an AV in accordance with the NRC's Enforcement Policy, and its final significance will be dispositioned in separate future correspondence.

Because this violation involves the traditional enforcement process, a cross-cutting aspect is not assigned to this violation. (Section 4OA3.1)

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

External Flooding (71111.01 - 1 sample)

a. Inspection Scope

The inspectors evaluated the design, material condition, and procedures for coping with the design basis probable maximum flood, which is from the probable maximum hurricane (PMH). 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 flood protection features including building drains, conduit seals, door seals, manholes, sump pumps, and other flood barriers, to determine if the flood protection features were adequate to mitigate the flood, were in place, and were functional. 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 flood barrier. The inspectors also reviewed the abnormal operating procedure for mitigating the design basis flood to ensure it could be implemented as written. Documents reviewed are listed in the Attachment.

.1 Failure to Promptly Identify and Correct Flood Protection Degradation in Safety-Related

Buildings

Introduction.

The NRC identified an Apparent Violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, with two examples. The first example involved the failure of the licensee to promptly identify and correct conditions adverse to quality associated with flood protection of multiple safety-related buildings. Specifically, the licensee failed to identify or correct safety-related buildings that contained openings that would have adversely impacted their ability to mitigate external flooding of these buildings in the event of a design basis PMH. The second example involved the failure of the licensee to correct a significant condition adverse to quality. Specifically, the licensee failed to implement a corrective action to preclude repetition by not developing an engineering program to mitigate the consequences of external events (flooding, high winds, and seismic) that ensured appropriate equipment classifications, with interfacing programs of MR and zero tolerance for equipment failures.

This resulted in a violation of TS 3.7.2, SW System and Ultimate Heat Sink, and TS 3.5.2, ECCS - Shutdown, since the inoperability of the required number of SWPs would violate TS 3.7.2, and TS 3.5.2 since SW cools the RHR heat exchangers.

Description.

On April 20, 2011, the inspectors identified the emergency diesel generator (EDG) fuel oil tank chamber (FOTC) enclosure contained openings which would adversely impact the ability to mitigate external flooding of the EDG FOTCs in the event of a PMH. This issue was dispositioned as a violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the failure to identify and correct a condition adverse to quality associated with the entrance enclosures for the EDG FOTCs, as discussed in NRC Inspection Report (IR) 05000325/2011012 and 05000324/2011012. On December 27, 2011, the NRC issued the final significance determination of White Finding and Notice of Violation for this issue in NRC IR 05000325/2011014 and 05000324/2011014.

As a result of the EDG FOTC flooding issue, the licensee performed extent of condition walkdowns to inspect safety-related interior walls and ceilings to ensure the wall penetrations were watertight. The licensee inspected the pipes and conduit outer link seals and inner conduit seals, which prevent water intrusion into these safety-related buildings during a flooding event. The licensee identified over 120 work requests (WRs)/work orders (WOs)/NCRs for degraded and/or nonconforming flood protection features, the majority of which were attributed to degraded or nonconforming flood penetration seals.

Example 1 - Failure to Promptly Identify and Correct Conditions Adverse to Quality Associated with Flood Protection of Multiple Safety-Related Buildings During August through September 2012, the licensee performed walkdowns of flood protection features in accordance with Nuclear Energy Institute (NEI) 12-07, Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features, dated May 2012 (Fukushima walkdowns). The licensee identified over 450 WRs/WOs/NCRs for degraded and/or nonconforming flood protection features, the majority of which were again attributed to degraded or nonconforming flood penetration seals. The inspectors determined the licensee did not fully identify all of the degraded flood protection features during the 2011 walkdowns.

The licensee identified additional degradation in the reactor buildings and the EDG building. Specifically, the licensee identified degraded flood penetration seals and a 3-inch gap along the bottom of the Unit 2 reactor building railroad door which would have allowed leakage into the reactor building during a PMH. The inspectors determined that the licensee did not fully evaluate this gap in the railroad door and this 3-inch gap would allow an inleakage of 73 gpm, which exceeds the 30 gpm specified in UFSAR Section 3.4.1.1.1, Protection of Access Openings Below Maximum High Water Elevation. After the inspectors identified the inadequate evaluation of this gap, the licensee performed a calculation and determined that with 73 gpm inflow to the HPCI room sump, and 20 gpm from other water sources, that the HPCI room would flood during the PMH to a depth of 10.3 inches, but that no safety-related equipment would be impacted by that depth. The licensee also identified a number of degraded flood penetration seals, conduit seals, and EDG rollup door that would have allowed water intrusion into the EDG building during the PMH. The inspectors determined the licensee had not performed an aggregate evaluation to determine the impact of the flood protection degradation on the EDG and reactor buildings. The licensee performed an aggregate evaluation of leakage into the EDG building and the reactor buildings during the PMH. The inspectors noted that given the specific storm scenario, there was low margin from the level of water in the basement of the EDG building to the bottom of the potential and current transformers, in the licensees evaluation. The licensee determined that the reactor buildings and the EDG building would not flood to a level that would affect safety-related equipment.

The licensee also identified flood protection feature degradation in the SWB. The licensee identified a potential flood pathway from the SWP intake to the 20 foot elevation of the SWB through unsealed SWP leakoff hub drains. The licensee determined in 1995, that two of the ten hub drains were modified from 2 inches to 4 inches wide. The licensee wrote NCR 559173 to address the design change, since the wider hub drains allowed amounts of water in the SWB that could impact the safety-related SWPs during a PMH. The licensee also took action to install baffle plates over the drain hubs on September 7, 2012. Additionally, the licensee identified a 5-inch unsealed conduit 6BL3/DC, on the 14 foot 6 inch elevation that created a direct flooding pathway from the circulating water pump bay, to the nonsafety-related manhole MH-1SA outside the SWB, into the SWB. The licensee wrote NCR 556861 and took action to seal conduit 6BL3/DC on August 27, 2012. The licensee also identified leaking flood penetration seals that would have allowed water to enter the SWB during a PMH. Finally, the licensee identified the SWPs had shims under the base plates of the pumps which would have allowed water to enter the SWB during a PMH.

UFSAR Section 2.4.5.2, Surge and Seiche Water Levels, stated, In the intake canal, the still water level is expected to reach 22.0 feet [mean sea level (MSL)] [during a PMH].

The nominal plant grade of 20 feet MSL results in two feet of water depth surrounding the plant during maximum surge conditions. All of the safety-related structures are waterproofed to elevation 22 feet MSL. The inspectors determined that with the potential inleakage allowed by the 4-inch drain hubs and the unsealed conduit, the safety-related SWB was not waterproofed to 22 feet, and the numerous flood barrier degradations in the reactor buildings and EDG building rendered them not waterproofed to 22 feet MSL.

On November 20, 2012, the licensee wrote NCR 573930 to evaluate the aggregate impact of flood deficiencies on the flood height in the SWB. In January 2013, the licensee determined that with the 4-inch hub drains and the unsealed conduit, the flood level inside the building would be approximately the same as outside the building and would submerge the SWP discharge valves. These discharge valves contain a start permissive for the motor controls of the 4 kV SWPs. The licensee determined that with the SWP discharge motor operated valves submerged, the control power fuses could fail for these valves. The licensee concluded that the SWPs that were running would have the discharge valves open, and would continue to run because the discharge valves would fail as-is (in the open position). The licensee concluded that the safety function of SW would not be lost with the flooding.

In April 2013, the inspectors reviewed the evaluation in NCR 573930 and determined the evaluation was inadequate and did not address the inoperability of the SWPs with a loss of power. The inspectors identified that submergence of the motor operated discharge valves could have prevented their automatic actuation; therefore the SW valves and pumps would be inoperable and violated TS 3.7.2, Service Water System and Ultimate Heat Sink. This issue would have prevented the fulfillment of the RHR safety function and violated TS 3.5.2, ECCS - Shutdown, since SW would not be sufficient to cool the Units 1 and 2 RHR heat exchangers.

The inspectors also determined that the licensee did not fully evaluate the effects of flooding on the power to the SWP valve actuators if a loss of offsite power (LOOP)occurred. The licensee wrote NCR 603867 to address the inspectors concerns. During a PMH, the licensee would enter Procedure AOP-13, Operation During Hurricane, Flood Conditions, Tornado, and Earthquake, and AI-68, Brunswick Nuclear Plant Response to Severe Weather Warnings. Depending on the time allowed and the projected hurricane, the units would be in hot shutdown or cold shutdown with one or two loops of RHR shutdown cooling (SDC) in operation.

If the PMH flooded the SWB and submerged the SWP discharge valves motor operators, and then a LOOP occurred, the licensee determined that with the limit switch and motor housing flooded, then seven of the ten SWPs would be susceptible to DC grounds, which would prevent the 4kV breakers from closing after a LOOP, resulting in the inoperability and unavailability of seven SWPs. The licensee determined the three remaining SWPs, powered from the same E bus, would be available only if the pumps were running prior to the LOOP event. Since only one pump would normally be running on the E bus prior to the LOOP, only one pump would be available after the LOOP. The inspectors concluded that with one SWP available, this one pump would be insufficient to cool the EDGs and maintain SDC for both reactor units.

On May 16, 2013, the NRC Problem Identification and Resolution inspection team identified a violation involving the failure to correct a leaking pipe seal in the SWB for over nine years. The leaking pipe seal was identified in 2003 in WR 91804 on the Unit 1 conventional service water pump (CSWP) pipe header. This leaking seal was not corrected until the penetration was injected with a sealant under WO 02034121-19 on May 1, 2012. The inspection team opened unresolved item (URI) 05000324, 325/2013009-02, Failure to Correct a Leaking Service Water Building Pipe Penetration Seal, to determine if this long term corrective action issue was more than minor. The inspectors concluded that this long term degradation of a penetration seal was another example of the licensees failure to promptly identify and correct degraded and nonconforming flood protection features.

The inspectors determined that the licensee failed to promptly identify and correct long term flood protection deficiencies. The licensee did not fully identify and correct degraded and nonconforming flood protection features during the 2011 White finding extent of condition walkdowns, daily walkdowns of safety-related areas by operations personnel, or walkdowns of safety-related areas by engineering personnel, prior to the Fukushima walkdowns. This resulted in flooding pathways into the SWB, EDG building, and reactor buildings, and the potential inoperability of most of the SWPs, during a PMH.

Example 2 - Failure to Correct a Significant Condition Adverse to Quality - to Preclude Repetition The licensees corrective action to preclude repetition of the NRC-identified White finding from 2011 was to develop an engineering program in accordance with licensee procedure EGR-NGGC-0008, Engineering Programs, to mitigate the consequences of external events (flooding, high winds, and seismic). This program, or programs, must ensure appropriate equipment classifications, with interfacing programs of maintenance rule and zero tolerance for equipment failures. The program must ensure performance of necessary operation, maintenance, testing, and inspection activities in accordance with the work management process to maintain needed design features. The inspectors determined the licensee did not adequately develop this engineering program including scoping credited flood protection features into the MR program.

In June 2013, during the NRC Flood Audit, the inspectors identified that check valves in the safety-related building sump pump discharge lines, were not identified as flood protection features in 0BNP-TR-019, External Event Protection Features, and that no preventive maintenance (PM) activities were being performed on these check valves.

These check valves are credited for flood protection in the licensees flood protection Engineering Change (EC) document 80408. The inspectors also identified that the EDG drain backflow preventer, which prevents external flood waters from entering the EDG building and EDG FOTC building during a PMH, had no scheduled PM. The inspectors also determined these flood protection features were not scoped into the MR program.

The licensee entered this issue into the CAP as NCR 612979-28 and NCR 614443.

In September 2013, during the NRC Component Design Basis Inspection, the inspectors identified that no PM activities had been created or performed on the sump pumps in the SWB, reactor buildings, EDG building, and EDG FOTC building, that were credited for flood protection in EC 80408. The inspectors determined these flood protection features were also not scoped into the MR program. The licensee entered this issue into the CAP as NCR 631304. The licensee plans to inspect and test the flood protection features before June 1, 2014, prior to the onset of hurricane season. The inspectors also identified that the SWP hub drains should also be incorporated into the MR program since the degradation of the hub drains could result in water intrusion into the SWB during a PMH. The licensee created MR scoping documents and performance criteria for the flood protection features in the reactor buildings, EDG building, SW building, and augmented offgas building on November 21, 2013, and the licensee approved the MR scoping documents on January 23, 2014.

The inspectors determined that if the licensee had adequately developed an engineering program that ensured appropriate equipment classifications, with interfacing programs of MR and zero tolerance for equipment failures, they would have scoped these flood protection features into the MR program, as a result of the White finding corrective actions to preclude repetition. This would have required that the flood protection features have appropriate PM and performance monitoring.

Analysis.

The inspectors determined the failure to identify and correct the missing and degraded flood barriers in multiple safety-related buildings, and the failure to implement a corrective action to preclude repetition by not developing an engineering program to mitigate the consequences of external events that ensured appropriate equipment classifications, with interfacing programs of MR and zero tolerance for equipment failures, was a performance deficiency. The finding was more than minor because it was associated with the protection against external factors attribute (flood hazard) of the Mitigating Systems Cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, nine of the ten Unit 1 and Unit 2 SWPs would be potentially inoperable and unavailable during specified PMH events. Because the finding involved reactor shutdown operations and conditions, IMC 0609, Appendix G, Shutdown Operations SDP, Attachment 1, issued May 25, 2004, Phase 1 Operational Checklists for Both pressurized water reactors (PWRs) and boiling water reactors (BWRs), was used. The inspectors used Checklist 5, BWR Hot Shutdown: Time to Boil

< 2 Hours, and determined the finding increased the likelihood that a loss of decay heat removal (DHR) will occur due to failure of the system itself or support systems, degraded the licensees ability to cope with a loss of offsite power (LOOP), degraded the licensees ability to add reactor coolant system (RCS) inventory when needed, and degraded the licensees ability to establish an alternate core cooling path if DHR could not be re-established for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Further, the performance deficiency involved external events. Consequently a Phase 2 analysis could not be performed and the issue screened directly to a Phase 3 analysis. The significance of this issue is To Be Determined (TBD) and its final significance will be dispositioned in separate transmittal.

The issue is not an immediate safety concern because the licensee has taken appropriate corrective actions. The finding has a cross-cutting aspect in the area of human performance associated with the field presence attribute because deviations from standards and expectations were not corrected promptly, and the licensee did not ensure supervisory and management oversight of work activities, including contractors.

Specifically, licensee management failed to ensure degradation associated with flood protection of the safety-related buildings was identified and corrected. [H.2]

Enforcement.

Appendix B to 10 CFR Part 50, Criterion XVI, Corrective Action, states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure the cause of the condition is determined and corrective action taken to preclude repetition. Contrary to the above, from 1995 to January 24, 2014, the licensee failed to promptly identify and correct flood protection deficiencies, such as degraded and nonconforming flood penetration seals and openings in multiple safety-related buildings, and failed to implement a corrective action to preclude repetition by not adequately developing an engineering program to mitigate the consequences of external events (flooding, high winds, and seismic) that ensured appropriate equipment classifications, with interfacing programs of MR and zero tolerance for equipment failures, prior to the Fukushima walkdowns.

This resulted in a violation of TS 3.7.2, Service Water System and Ultimate Heat Sink, and TS 3.5.2, ECCS - Shutdown, since the licensee failed to have the required number of SWPs per TS 3.7.2, and with the inoperability of the required number SWPs, the licensee failed to have the required number of ECCS per TS 3.5.2 since SW cools the RHR heat exchangers.

The licensee corrected the flooding deficiencies, which included sealing penetrations susceptible to flooding, in the safety-related buildings. The licensee also scoped the flood protection features into the MR program. The licensee entered this issue into the CAP as NCRs 573930, 588742, and 600850. This violation is being treated as an AV, consistent with the NRCs Enforcement Policy and is identified as AV 05000325/2013010-01 and 05000324/2013010-01, Failure to Promptly Identify and Correct Flood Protection Degradation in Safety-Related Buildings.

.2 Inadequate Procedures for Inspecting Flood Protection Doors and Performing

Functionality Assessments

Introduction.

An NRC-identified Green finding for the failure to meet the requirements of licensee procedure PRO-NGGC-0201, NGG Procedure Writers Guide, was identified with two examples. Specifically, the licensee failed to provide an adequate procedure with appropriate acceptance criteria to inspect flood protection doors for leakage and failed to have an adequate procedure to perform functionality assessments which met the requirements specified in Procedure PRO-NGGC-0201.

Description.

The inspectors identified two examples of failure to have an adequate procedure which met the requirements of licensee procedure PRO-NGGC-0201.

Example 1 - Failure to Have an Adequate Procedure to Inspect Flood Protection Doors On October 8, 2012, the licensee identified a 3-inch gap in the weather stripping along the bottom of the Unit 2 railroad door, 2-RB-DR-EL020-210. The licensee entered this issue into the CAP as NCR 565786. The licensee determined that with the 3-inch weather stripping missing, that the door was functional and within the allowable in leakage limits such that the leakage could be handled by the floor drain system which drains to the HPCI sump.

The inspectors reviewed NCR 565786 and determined that the evaluation was not adequate due to the size of the gap along the bottom of the door. The inspectors determined a 3-inch gap could allow flood waters to exceed the 30 gallons per minute (gpm) in leakage limit specified in Specification 024-001, Special Doors,Section II(D)(4)(d)(1), which stated, In leakage limits for doors shall be in accordance with the following maximum values: Exterior Reactor Building Railroad Airlock doors, 30 gpm.

The licensee performed a calculation to determine the impact of the 3-inch gap along the bottom of the Unit 2 railroad door and concluded that the gap would allow an in leakage of 73 gpm. With a 73 gpm flow rate, the Unit 2 railroad door should have been declared nonfunctional for its flood protection function.

Procedure PRO-NGGC-0201, Section 4.5.1.2, required acceptance criteria for testing procedures. Testing Procedure 0PT-34.2.1.1, Step 7.5.1, stated the following acceptance criterion for flood control doors, With more than minimal gaps, the door may not conform to design requirements for flood protection as stated in UFSAR 3.4.1, 3.4.2, and Specification 024-001. The licensee had used this acceptance criterion to conclude that a minimal gap existed on the Unit 2 railroad door. Since the door leakage would have exceeded the 30 gpm limit with a 3-inch gap, the inspectors determined this acceptance criterion was not adequate to ensure these flood protection doors could provide their flood protection function during a PMH.

The licensee wrote NCR 631303 and Procedure Revision Request 632125 to revise the procedure to change the acceptance criteria. The licensee revised the procedure on November 18, 2013, to state, Allowable gap sizes for flood control doors are specified in Specification 024-001. Specification 024-001 was revised to state that for the reactor building railroad doors, the allowable gap size to limit leakage to 30 gpm is 0.61 square inches.

Example 2 - Failure to Have an Adequate Procedure to Perform Functionality Assessments In August through September 2012, the licensee performed walkdowns of flood protection features in accordance with NEI 12-07, Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features, Revision 0, dated May 2012. During the walkdowns of the SWB, the licensee identified eight flood penetration seals in the SWB were degraded. The license wrote NCRs 556860 through 556867 for each of these flood penetration seals. The licensee marked these NCRs as not requiring a functionality assessment in accordance with Procedure OPS-NGGC-1305, Operability Determinations.

The inspectors reviewed Procedure OPS-NGGC-1305, which defined, in part, functional/functionality as the ability of non-TS SSCs to perform their specified functions that have necessary support functions. Also, a non-TS SSC with a necessary support function is one that has been determined by the plant to be a Maintenance Rule - high risk significant SSC per 10 CFR 50.65(a)(4).

The inspectors questioned this definition of functionality as being too restrictive since licensee Procedure PRO-NGGC-0201, NGG Procedure Writers Guide, Step 4.5.11(3)stated, Definitions of items or phrases NOT unique to the procedure should be consistent with definitions provided in referenced procedures, TSs or the Quality Assurance Program Manual. Procedure OPS-NGGC-1305, references NRC Regulatory Issue Summary (RIS) 2005-20, Rev 1: Revision to NRC Inspection Manual Part 9900 Technical Guidance, Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety.

NRC Inspection Manual Part 9900 Technical Guidance, Section 3.5, defines functional/functionality as an attribute of SSCs that is not controlled by TSs. An SSC is functional or has functionality when it is capable of performing its specified function, as set forth in the current licensing basis. Functionality does not apply to specified safety functions, but does apply to the ability of non-TS SSCs to perform other specified functions that have a necessary support function. RIS 2005-20 did not limit functionality assessments to necessary support functions that are determined by the plant to be a Maintenance Rule - high risk significant SSC per 10 CFR 50.65(a)(4). The licensee wrote Procedure Revision Request 563077 and NCR 563113, and revised Procedure OPS-NGGC-1305 to remove this additional criterion.

Analysis.

The inspectors determined that the failure of the licensee to provide an adequate procedure to inspect flood protection doors for leakage and to have an adequate procedure which met the requirements of licensee Procedure PRO-NGGC-0201 to perform functionality assessments was a performance deficiency. The finding is more than minor because it is associated with the protection against external factors (i.e., flood hazard) attribute of the Mitigating Systems Cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the flood protection door and flood penetration seals were missing or degraded which could have resulted in a flood pathway into the HPCI room and SWB during a PMH.

Using IMC 0609, Appendix A, issued June 9, 2012, The SDP for Findings At-Power, the inspectors determined the finding screened to Green because the individual door and penetration seal degradations did not involve the total loss of any safety function, identified by the licensee through a PRA, IPEEE, or similar analysis, that contributes to external event initiated core damage accident sequences (i.e., initiated by a seismic, flooding, or severe weather event). The finding has a cross-cutting aspect in the area of human performance associated with the documentation attribute because the licensee failed to create and maintain complete, accurate and, up-to-date documentation to inspect flood protection doors and perform functionality assessments. [H.7]

Enforcement.

This finding does not involve enforcement action because there was no violation of a regulatory requirement. The licensee entered these issues into the CAP as NCRs 631303, and 563113 and 580629, respectively. Because this finding does not involve a violation and is of very low safety significance, it is identified as FIN 05000325/2013010-02 and 05000324/2013010-02, Inadequate Procedures for Inspecting Flood Protection Doors and Performing Functionality Assessments.

.3 Failure to Perform Functionality Assessments for Flood Protection Features

Introduction.

An NRC-identified Green finding was identified for the failure of the licensee to follow Procedure OPS-NGGC-1305, Operability Determinations, to perform functionality assessments for degraded or non-conforming flood protection features.

Specifically, the licensee failed to perform functionality assessments for flood protection features, including EDG building conduit seals and Unit 2 HPCI sump pump failures.

Description.

On September 25, 2012, the inspectors identified licensee Procedure OPS-NGGC-1305, was inadequate since the procedure only required functionality assessments in accordance with the following: non-TS SSC with a necessary support function is one that has been determined by the plant to be a Maintenance Rule - high risk significant SSC per 10 CFR 50.65(a)(4). The licensee wrote Procedure Revision Request 563077 and NCR 563113, and revised Procedure OPS-NGGC-1305 to remove this additional criterion. The licensee also implemented a major revision of Procedure OPS-NGGC-1305 to provide guidance on how to address functionality assessments by providing definitions, basic screening instructions for functionality assessments, and documentation requirements. This new version of licensee Procedure OPS-NGGC-1305, Revision 5, went into effect November 12, 2012. The finding associated with the inadequate Procedure OPS-NGGC-1305 is dispositioned in Section 1R01.2 of this report.

The inspectors determined that the licensee had not performed functionality assessments on flood protection features as required by Procedure OPS-NGGC-1305 after the new procedure went into effect November 12, 2012. The inspectors identified three examples where functionality assessments were not performed. On December 12, 2012, the licensee identified a duct bank in the EDG building where three of the conduits had openings in the flood protection interior conduit seals. The licensee wrote NCR 577807 and determined the equipment was operable. With holes in these conduit seals, the seals should have been declared nonfunctional for flood protection, and the licensee should have performed an operability determination for the EDGs. In addition, on December 16, 2012, and January 8, 2013, the licensee identified the Unit 2 HPCI sump pump tripped on magnetics. The licensee wrote NCRs 578464 and 581434 to address these issues. The licensee did not perform functionality assessments even though the HPCI sump pump is credited for internal and external flooding events to protect the HPCI system, and the RHR pumps, since the rooms are connected by ventilation ducts. The licensee should have declared the HPCI sump pump nonfunctional and performed an operability determination for the HPCI and RHR pumps.

In all three examples, after discussions with the inspectors, the licensee determined that these flood protection features were nonfunctional for flooding, but that the failure of these flood protection features would not have resulted in the inoperability of any safety-related equipment.

The inspectors identified that although licensee Procedure OPS-NGGC-1305 had been revised to provide additional guidance for functionality assessments, operations personnel had not been fully trained on the procedure revision. The licensee provided interim guidance in a standing order to operations personnel and has provided additional training to operations personnel on performing functionality assessments.

Analysis.

The inspectors determined the failure to follow Procedure OPS-NGGC-1305, to perform functionality assessments for degraded or non-conforming flood protection features, was a performance deficiency. The finding is more than minor because it is associated with the protection against external factors (i.e., flood hazard) attribute of the Mitigating Systems Cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to perform functionality assessments for degraded or non-conforming flood protection features could have resulted in a flood pathway into the HPCI room and EDG building during a PMH.

Using IMC 0609, Appendix A, issued June 9, 2012, The SDP for Findings At-Power, the inspectors determined the finding screened to Green because the resulting individual functional assessments did not involve the total loss of any safety function, identified by the licensee through a PRA, IPEEE, or similar analysis, that contributes to external event initiated core damage accident sequences (i.e., initiated by a seismic, flooding, or severe weather event). The finding has a cross-cutting aspect in the area of human performance associated with the procedure adherence attribute because the licensee did not follow processes, procedures, and work instructions. Specifically, the licensee revised Procedure OPS-NGGC-1305 for performing functionality assessments but did not effectively communicate the new procedural requirements to operations personnel such that functionality assessments were performed when required. [H.8]

Enforcement.

This finding does not involve enforcement action because there was no violation of a regulatory requirement. The licensee entered this issue into the CAP as NCRs 613354 and 631442. Because this finding does not involve a violation and is of very low safety significance, it is identified as FIN 05000325/2013010-03 and 05000324/2013010-03, Failure to Perform Functionality Assessments for Flood Protection Features.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following systems:

• Active flood protection barriers (i.e. sump pumps, check valves)

• Passive flood protection barriers (i.e. hub drains, conduit and penetration seals)

The inspectors reviewed events where ineffective equipment maintenance may have resulted in equipment failure or invalid automatic actuations of Engineered Safeguards Systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

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

• 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 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.

b. Findings

The enforcement aspects related to the issues identified are discussed in Section

4OA2 Identification and Resolution of Problems

.1 Selected Issue Follow-up Inspection

a. Inspection Scope

The inspectors selected NCR 573930, Fukushima Near Term Task Force 2.3 Flooding; Past Service Water Building In-Leakage Evaluation, for detailed review. This NCR was associated with evaluating the aggregate effect of in-leakage into the SWB from degraded flood barriers identified during the Fukushima walkdowns.

The inspectors reviewed this evaluation to verify that the licensee identified the full extent of the issue, performed an appropriate evaluation, and specified and prioritized appropriate corrective actions. The inspectors evaluated the report against the requirements of the licensees CAP as delineated in corporate procedure CAP-NGGC-0200, Condition Identification and Screening Process, and 10 CFR Part 50, Appendix B.

Documents reviewed are listed in the Attachment.

b. Findings

The enforcement aspects of the NRC-identified corrective action issue are documented in Section 1R01.1 of this report.

.2 (Closed) URI 5000325, 324/2013009-01, Extent of Condition Review for NCR 490292

a. Inspection Scope

The inspectors completed an evaluation of URI 05000325; 324/2013009-01, opened for an extent of condition review associated with an NRC-identified flooding concern with the four day EDG FOTC. In May 2011, inspectors identified holes, gaps, and other degradations in the four-day EDG FOTC. The licensee performed a root cause for this issue under NCR 490292. This root cause resulted in an extent of condition walkdown in October 2011 to identify other flood protection feature degradation. Assignment 53 to NCR 490292 was created to correct the deficiencies identified during the October 2011 extent of condition walkdowns. This URI was opened to 1) verify deficiencies identified in the walkdown reports were identified in NCR 490292 assignment 53; 2) verify that adequate corrective actions were taken for issues from NCR 490292 assignment 53 and were appropriately documented in the CAP; and 3) review of the results of

(1) and

(2) to determine if a performance deficiency exists.

The inspectors performed a review of the licensees Review of Flood Protection Vulnerability Walkdown 2011 Report, completed on September 23, 2013. The inspectors also reviewed the corrective actions associated with NCR 490292, assignment 53. The inspectors discussed this issue with licensee personnel to understand the corrective actions taken to address the flooding extent of condition.

Documents reviewed are listed in the Attachment.

b. Findings

The inspectors evaluated the adequacy of the licensees corrective actions and determined that the deficiencies identified in the walkdown reports were documented in NCR 490292. The inspectors determined that the corrective actions taken for issues identified in NCR 490292 assignment 53 were appropriately documented in the CAP.

However, the inspectors determined that during the 2011 walkdowns, the licensee did not fully identify and correct all degraded or non-conforming flood protection features.

The enforcement aspects of the NRC-identified corrective action issue are documented in Section 1R01.1 of this report. This URI is closed.

.3 (Closed) URI 5000325, 324/2013009-02, Failure to Correct a Leaking Service Water

Building Pipe Penetration Seal

a. Inspection Scope

The inspectors completed an evaluation of URI 05000325; 324/2013009-02, opened due to a performance deficiency involving the failure to correct a leaking pipe seal in the SWB for over nine years. In WR 91804, written on April 8, 2003, the licensee identified water leaking past a link seal on 30-inch SW pipe 1-SW-100-30-157 in the SWB. The WR directed repair or replacement of the link seal. The WR was not worked until May 1, 2012, when the penetration was injected with a sealant under WO 2034121-10.

This URI was opened to determine if the performance deficiency involving the failure to correct this condition for over 9 years is more than minor. The inspectors performed a walkdown of the link seal. The inspectors reviewed the licensees corrective actions for this link seal. The inspectors discussed this issue with licensee personnel to understand the timeliness of the corrective actions taken to address this issue. Documents reviewed are listed in the Attachment.

b. Findings

The inspectors evaluated the adequacy of the licensees corrective actions and determined that the leaking seal was a condition adverse to quality and that the failure to correct this condition for nine years was a performance deficiency. The inspectors determined the link seal was not safety-related, but was necessary to protect the safety-related SWPs during the PMH. The enforcement aspects of the NRC-identified corrective action issue are documented in Section 1R01.1 of this report. This URI is closed.

4OA3 Follow-up of Events

.1 Failure to Submit a Timely LER for Service Water System Inoperability

a. Inspection Scope

The inspectors performed independent walkdowns to ensure the licensee identified degraded or missing flood protection features in the SWB, reactor building, and EDG building. The inspectors reviewed NCR 573930, in response to the aggregate evaluation of these flood deficiencies in the SWB, to determine the operability and functionality of the SW valves and pumps when power was lost to the SWP discharge valves. The inspectors also reviewed this evaluation to verify that the licensee identified the full extent of the issue, performed an appropriate evaluation, and specified and prioritized appropriate corrective actions. The inspectors evaluated the report against the requirements of 10 CFR 50.73, and reviewed the guidance in NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73, Revision 3. The licensee entered this issue into the CAP as NCR 629064. The inspectors reviewed the cause evaluation, walked down safety-related buildings, reviewed the corrective actions, and interviewed operations and engineering personnel. Documents reviewed are listed in the Attachment.

b. Findings

Introduction.

An NRC-identified AV of 10 CFR 50.73(a)(2)(i)(B) and 10 CFR 50.73(a)(2)(v)(B), was identified for failure of the licensee to provide a written Licensee Event Report (LER) to the NRC within 60 days of identifying a condition which was prohibited by plant TS 3.7.2, Service Water System and Ultimate Heat Sink, and an event that could have prevented the fulfillment of a safety function of RHR.

Description.

In August through September 2012, the licensee, performed walkdowns of flood protection features in accordance with NEI 12-07, Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features, Revision 0, dated May 2012.

During the walkdowns of the SWB, the licensee identified a potential flood pathway from the SWP intake to the 20 foot elevation of the building through unsealed hub drains.

The licensee reviewed design documentation for these hub drains, and identified the hub drains were 2 inches wide to limit the flow of water into the building per UFSAR Section 3.4.1.1.1.4. The licensee identified during the Fukushima walkdowns that in 1995, per revision 16 of drawing F-04024, two of the ten hub drains were modified to four inches wide, in accordance with plant modification documents 82-220L and 82-221L. The licensee wrote NCR 559173 to address the inadequate design change that widened two of the hub drains, since the wider hub drains could potentially flood the SWB during a PMH. The licensee also took action to install baffle plates over the drain hubs per WOs 2134095-01 and 2134125-01, completed on September 7, 2012. Since the issue occurred in 1995, the licensee could not determine the cause.

The licensee identified 5-inch unsealed conduit 6BL3/DC, on the 14 foot 6 inch elevation of the building that created a potential flood pathway into the SWB. This unsealed conduit created a direct flooding pathway from the SWB to a nonsafety-related manhole outside the SWB, which communicated directly with the circulating water pump bay. The licensee wrote NCR 556861 and took action to seal conduit 6BL3/DC on August 27, 2012.

On November 20, 2012, the licensee wrote NCR 573930 to evaluate the aggregate impact of flood deficiencies on the flood height in the SWB. The licensee completed the evaluation on January 4, 2013, and determined with the hub drains and the unsealed conduit, the flood level inside the building would be approximately the same as outside the building and would submerge the SWP discharge valves. These discharge valves contain a start permissive for the motor controls of the 4kV SWPs. The licensee determined with the SWP discharge motor operated valves submerged, the control power fuses could fail for these valves. The licensee concluded that the SWPs that were running would have the discharge valves open, and would continue to run, because the discharge valves would fail as is (in the open position). The licensee concluded that the safety function of SW would not be lost with the flooding.

The inspectors reviewed the evaluation in NCR 573930 and determined with the power lost to the SW discharge valves, the SW valves and pumps would be inoperable. The inspectors reviewed TSs, Section 1.1 Definitions, Operable - Operability, which stated, in part, that a system, subsystem, division, component, or device shall be operable or have operability when it is capable of performing its specified safety function(s) and when all necessary normal or emergency electrical power that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

On September 17, 2013, after questions from the NRC inspectors, engineering personnel again concluded that the aggregate effect of the conditions could have resulted in submergence of the motor-operated discharge valves for the ten Unit 1 and Unit 2 SWPs (i.e., each unit has two NSWPs and three CSWPs), potentially causing inoperability of the SW systems. Surveillance Requirement 3.7.2.5 of TS 3.7.2, verifies that each required SW system automatic component actuates on an actual or simulated initiation signal. Due to the above condition, Units 1 and 2 would have exceeded Completion Times associated with TS 3.7.2. Therefore, this condition is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as operation prohibited by the plants TSs because submergence of the motor-operated discharge valves could have prevented their automatic actuation. Further, in accordance with the guidance of NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73, Revision 3, TS inoperability of a SSC with no redundant equipment in the same system operable constitutes an event that could have prevented the fulfillment of a safety function. This event is also reportable as an event that could have prevented fulfillment of the RHR safety function in accordance with 10 CFR 50.73(a)(2)(v)(B), since SW cools the RHR heat exchangers.

The licensee submitted LER 50-325 and 50-324/2013-003-00 to address these issues on November 14, 2013.

The inspectors concluded that the licensee failed to provide a written LER to the NRC within 60 days of January 4, 2013, as required by 10 CFR 50.73(a)(2)(i)(B) and 10 CFR 50.73(a)(2)(v)(B).

Analysis.

The inspectors determined the failure of the licensee to provide a written LER to the NRC within 60 days as required by 10 CFR 50.73(a)(2)(i)(B) and 10 CFR 50.73(a)(2)(v)(B) was a performance deficiency. This violation involved a failure to make a required report to the NRC and is considered to impact the regulatory process. Such violations are dispositioned using the traditional enforcement process instead of the SDP. As discussed in the Enforcement Policy, the severity level of a violation involving the failure to make a required report to the NRC will be based upon the significance of and the circumstances surrounding the matter that should have been reported. This issue is being characterized as an AV in accordance with the NRC's Enforcement Policy, and its final significance will be dispositioned in separate future correspondence.

Because this violation involves the traditional enforcement process, a cross-cutting aspect is not assigned to this violation.

Enforcement.

10 CFR 50.73(a)(2)(i)(B) and 10 CFR 50.73(a)(2)(v)(B) require licensees to submit an LER to the NRC within 60 days of identifying a condition which was prohibited by plant TS 3.7.2, and an event that could have prevented the fulfillment of the RHR safety function. Contrary to the above, on January 4, 2013, the licensee completed an evaluation that determined that during a PMH, due to the failure to maintain the SWB water tight, flood waters could have reached a flood level inside the SWB to submerge the service water pump (SWP) discharge valves, resulting in control power being lost to the valves. The inspectors determined that with control power lost to the discharge valves, that the ten Unit 1 and Unit 2 SWPs would be inoperable.

Subsequent to the inspectors questioning, the licensee concluded that the condition met the criteria for reporting under 10 CFR 50.73(a)(2)(i)(B) and 10 CFR 50.73(a)(2)(v)(B),and that a 60-day report was required to be submitted to the NRC. The licensees corrective actions included submitting LER 50-325 and 50-324/2013-003-00 on November 14, 2013. The licensee entered this issue into the CAP as NCR 629064.

This is being characterized as an AV in accordance with the NRCs Enforcement Policy, and its final significance will be dispositioned in separate future correspondence: AV 05000325/2013010-04 and 05000324/2013010-04, Failure to Submit a Timely LER for Service Water System Inoperability.

.2 (Closed) LER 05000325;324/2013-003-00, Operation Prohibited by Technical

Specifications - Service Water System Inoperability

a. Inspection Scope

In August through September, 2012, the licensee, performed walkdowns of flood protection features in accordance with NEI 12-07, Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features, Revision 0, dated May 2012. Two of the conditions identified and corrected as a result of the walkdowns included: 1) an unsealed 5-inch conduit that created a potential flood pathway from the circulating water pump bay to the SWB, and 2) ten drain hubs in the SWB that communicated directly with the SWP bays. The licensee performed an aggregate evaluation of these flood deficiencies in the SWB, and found that during a PMH, the SWP discharge valves would have been submerged resulting in the potential inoperability of the SWPs. The root cause of this issue is the historical lack of external flooding program. As a result, flood protection deficiencies were not appropriately identified and corrected. The licensees corrective actions to preclude repetition include developing an engineering program to mitigate the consequences of external flooding, and develop a topical design basis for internal and external flooding. The licensee entered this issue into the CAP as NCRs 603867 and 629064. The inspectors reviewed LER 05000325;324/2013-003-00 and the associated NCRs. The inspectors reviewed the cause evaluation, walked down the service water building, reviewed the corrective actions, and interviewed operations and engineering personnel. Documents reviewed are listed in the Attachment.

b. Findings

The enforcement aspects of the NRC-identified failure to submit a timely LER issue are documented in Section 4OA3.1 of this report. No additional findings were identified during the review of this LER. This LER is closed.

4OA5 Other Activities

(Closed) URI 05000325/2013002-02 and 05000324/2013002-02, Flood Impacts due to Degraded Flood Protection Measures

a. Inspection Scope

From August through October 2012, the licensee performed walkdowns of flood protection features in accordance with NEI 12-07 Walkdown Guidance. The licensee and inspectors identified degraded or missing flood protection features in the SWB, reactor building, and EDG building. The inspectors completed an evaluation of URI 05000325; 324/2013002-02, opened to determine if a performance deficiency exists due to the flood protection feature degradation with the potential for flood intrusion into safety-related buildings during a PMH.

The inspectors performed a walkdown of the degraded flood protection features and the repairs to those features. The inspectors reviewed the licensees corrective actions for the degraded flood protection features. The inspectors discussed this issue with licensee personnel to understand the aggregate impact of degraded flood protection features on safety-related equipment during the PMH.

b. Findings

The inspectors reviewed the licensees aggregate evaluation of degraded flood protection features on safety-related equipment. The inspectors evaluated the adequacy of the licensees corrective actions and determined that the corrective actions were adequate to repair or replace the degraded flood barriers. The inspectors determined that the aggregate impact of degraded flood protection features on the safety-related SWPs could have impacted the ability of the SWPs to perform their design basis function during a PMH. The enforcement aspects of the NRC-identified corrective action issue are documented in Section 1R01.1 of this report. This URI is closed.

4OA6 Management Meetings

Exit Meeting Summary

On February 6, February 27, and March 20, 2014, the inspectors presented the inspection results to Mr. George Hamrick, and other members of the licensee staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

K. Allen, Manager - Design Engineering

Y. Anagostopoulos, Manager - Major Projects

A. Brittain, Manager - Security

K. Crocker, Supervisor - Emergency Preparedness

P. Dubrouillet, Manager - Nuclear Systems Engineering

S. Gordy, Manager - Maintenance

L. Grzeck, Supervisor - Licensing

K. Hamm, Superintendent - Mechanical Maintenance

G. Hamrick, Site Vice President

B. Houston, Manager - Environmental and Radiological Controls

J. Kalamaja, Manager - Operations

G. Kilpatrick, Manager - Training

J. Krakuszeski, Plant General Manager

W. Murray, Licensing Specialist

J. Nolin, Director - Engineering

A. Padleckas, Manager - Shift Operations

F. Payne, Manager - Outage and Scheduling

D. Petrusic, Superintendent - Environmental and Chemistry

A. Pope, Manager - Nuclear Support Services

B. Raper, Supervisor - U1 Outage Manager

T. Sherrill, Licensing Specialist

M. Turkal, Licensing Specialist

E. Willis, Director - Site Operations

O. Wrisbon, Superintendent - Electrical, Instrumentation and Controls Maintenance

NRC Personnel

G. Hopper, Chief, Reactor Projects Branch 4

J. Dodson, Senior Project Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000325,324/2013010-01 AV Failure to Identify and Correct Flood Protection Degradation in Safety-Related Buildings (Section 1R01.1)

05000325,324/2013010-04 AV Failure to Submit a Timely LER for Service Water System Inoperability (Section 4OA3.1)

Opened and Closed

05000325,324/2013010-02 FIN Inadequate Procedures for Inspecting Flood Protection Doors and Performing Functionality Assessments (Section 1R01.2)

05000325,324/2013010-03 FIN Failure to Perform Functionality Assessments for Flood Protection Features (Section 1R01.3)

Closed

05000325,324/2013009-01 URI Extent of Condition Review for NCR 490292 (Section 4OA2.2)

05000325,324/2013009-02 URI Failure to Correct a Leaking Service Water Building Pipe Penetration Seal (Section 4OA2.3)

05000325;324/2013-003-00 LER Operation Prohibited by Technical Specifications -

Service Water System Inoperability (Section 4OA3.2)

05000325,324/2013002-02 URI Flood Impacts due to Degraded Flood Protection Measures (Section 4OA5)