IR 05000348/2011004
| ML113010289 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/28/2011 |
| From: | Jim Hickey NRC/RGN-II/DRP/RPB2 |
| To: | Lynch T Southern Nuclear Operating Co |
| References | |
| IR-11-004 | |
| Download: ML113010289 (24) | |
Text
October 28, 2011
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000348/2011004 AND 05000364/2011004
Dear Mr. Lynch:
On September 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Joseph M. Farley Nuclear Plant, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on October 13, 2011, with 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 NRC reviewed selected procedures and records, observed activities and interviewed personnel.
The report documents one self-revealing finding. This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because the finding was entered into your corrective action program (CAP), the NRC is treating this violation as a non-cited violation (NCV) consistent with the NRC Enforcement Policy. If you contest any NCV, 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 Senior Resident Inspector at the Joseph M. Farley Nuclear Plant. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II, and the NRC Senior Resident Inspector at the Joseph M. Farley Nuclear Plant. The information you provide will be considered in accordance with Inspection Manual Chapter (IMC) 0305.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if any, will be available electronically for public inspection in the NRC public document room or from the publicly available records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the public electronic reading room).
Sincerely,
/RA/
James Hickey, Acting Branch Chief Reactor Projects Branch 2 Division of Reactor Projects
Docket No.: 50-348, 50-364 License No.: NPF-2, NPF-8
Enclosure:
Inspection Report 05000348/2011004 and 05000364/2011004
w/Attachment: Supplemental Information
REGION II==
Docket Nos.:
05000348, 05000364
License Nos.:
Report No.:
05000348/2011004 and 05000364/2011004
Licensee:
Southern Nuclear Operating Company, Inc.
Facility:
Joseph M. Farley Nuclear Plant, Units 1 and 2
Location:
Columbia, AL
Dates:
July 1, 2011 through September 30, 2011
Inspectors:
E. Crowe, Senior Resident Inspector J. Sowa, Resident Inspector
Approved by:
James Hickey, Acting Branch Chief Reactor Projects Branch 2 Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000348/2011004 and 05000364/2011004; July 1, 2011, through September 30, 2011;
Joseph M. Farley Nuclear Plant, Units 1 and 2; Maintenance Rule (MR) Effectiveness.
The report covered a three-month period of inspection by the resident inspectors. One self-revealing NCV with very low safety significance (GREEN) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609,
Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The cross-cutting aspect was determined using IMC 0310, Components Within The Cross-Cutting Areas. 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
Cornerstone: Mitigating Systems (MS)
- Green A self-revealing NCV of Technical Specification (TS) 5.4.1a was identified for the licensees failure to implement procedures recommended in Regulatory Guide (RG) 1.33. Specifically, the licensee did not properly pre-plan maintenance tagout activities on the unit 2 charging system. As a result, the licensee inadvertently overpressurized the 2C high head safety injection (HHSI) pump suction piping, adversely affecting the availability of the safety-related pump. Upon discovery of this condition, the licensee immediately depressurized the pump suction piping and initiated condition report (CR) 343336.
Failure to properly pre-plan maintenance activities is a performance deficiency. This performance deficiency is more than minor because it is associated with the human performance attribute of the mitigating systems (MS) cornerstone, and adversely affected the cornerstone objective to ensure system availability of components responding to initiating events preventing undesirable consequences. The human performance attribute of the MS cornerstone was determined to be adversely affected because: 1) the licensees tagout procedure relied on a check valve as part of the maintenance boundary; 2) the licensees tagout sequence isolated the pump suction valve prior to isolating the pump discharge valve; resulting in overpressurization of the 2C charging pump suction piping, which rendered the 2C charging pump inoperable from August 11, 2011, to September 9, 2011. The significance of this finding was screened using IMC 0609, Significance Determination Process (SDP), Phase 1 worksheets of Attachment 4. The finding screened as Green, because it did not represent an actual loss of safety function of a single train of emergency core cooling system (ECCS) for greater than its TS allowable outage time. The finding was assigned a cross cutting aspect in the resources component of the human performance area (H.2(c)). Specifically, complete, accurate and up-to-date work packages could have prevented overpressurization of the pump. (Section 1R12)
REPORT DETAILS
Summary of Plant Status
Unit 1 started the report period at 100 percent rated thermal power (RTP). The unit remained at or near 100 percent RTP for the remainder of the inspection period.
Unit 2 started the report period at 100 percent RTP. The unit remained at or near 100 percent until September 27, 2011, when the plant entered into a reactor coolant system (RCS)temperature coast-down period for the upcoming refueling outage (RFO).
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
==1R01 Adverse Weather Protection
a. Inspection Scope
Impending Adverse Conditions:==
The inspectors evaluated implementation of adverse weather preparation procedures and compensatory measures for the following adverse weather condition. The inspectors reviewed station procedures and reviewed trends of containment temperatures. The inspectors also examined temperature-sensitive areas of the plant to ensure proper ventilation was provided. The inspectors verified the applicable portions of procedure FNP-0-AOP-21.0, Severe Weather, were performed.
Documents reviewed are listed in the attachment.
- High ambient temperatures during the week of August 1 through August 8, 2011
b. Findings
No findings were identified.
==1R04 Equipment Alignment
a. Inspection Scope
Partial Walk-Down:==
The inspectors performed partial walk-downs of the following four systems to verify operability of redundant or diverse trains and components when safety equipment was inoperable. The inspectors attempted to identify discrepancies impacting the function of the system and therefore, potentially increasing risk. The walk-downs were performed using the criteria in licensee procedures NMP-OS-007, Conduct of Operations, and FNP-0-SOP-0, General Instructions to Operations Personnel. The walk-downs included reviewing the updated final safety analysis report (UFSAR), plant procedures and drawings, checks of control room and plant valves, switches, components, electrical power, support equipment and instrumentation. Documents reviewed are listed in the attachment.
- Unit 1 service and instrument air system while cross connected with Unit 2 service air system
- Unit 1, A train component cooling water (CCW) system during an equipment outage on the B train CCW pump 1A
- Unit 2, A train chemical and volume control system during an equipment outage on the B train charging pump 2C
- Unit 2, A train CCW during eddy current testing activities associated with B train CCW heat exchanger (HX)
b. Findings
No findings were identified.
==1R05 Fire Protection
a. Inspection Scope
Fire Protection Area Tours:==
The inspectors conducted a tour of the four fire areas listed below to assess material condition and operation status of the fire protection equipment.
The inspectors verified combustibles and ignition sources were controlled in accordance with the licensees administrative procedures; fire detection and suppression equipment was available for use; passive fire barriers were maintained in good material condition and compensatory measures for out-of-service, degraded or inoperable fire protection equipment were implemented in accordance with the requirements of licensee procedures FNP-0-AP-36, Fire Surveillance and Inspection; FNP-0-AP-38, Use of Open Flame; FNP-0-AP-39, Fire Patrols and Watches; and the associated fire zone data sheets. Documents reviewed are listed in the attachment.
- Unit 1, primary chemistry lab, fire zone 4
- Unit 1, motor driven auxiliary feedwater pump (MDAFWP)1A, fire zone 6
- Unit 2, charging pump rooms, fire zone 5
b. Findings
No findings were identified.
==1R07 Heat Sink Performance
a. Inspection Scope
==
The inspectors reviewed the results of performance testing of the 2B diesel generator (DG) jacket water HX. The inspectors verified the licensee utilized the performance monitoring method outlined in Electric Power Research Institute report NP-7552, Heat Exchanger (HX) Performance Monitoring Guidelines. Station procedure FNP-0-ETP-4367, Performance Test for Units 1 & 2 Colt-Pielstick (Large) DG Jacket Water HX, accurately reflected those guidelines. The inspectors evaluated this activity for conditions masking degraded performance, common cause heat sink performance problems increasing risk and heat sink performance problems resulting in initiating events or affecting multiple HXs in MS. The inspectors also reviewed the licensees CR database to verify HX problems were being identified and resolved.
b. Findings
No findings were identified.
==1R11 Licensed Operator Requalification Program
==
.1 Resident Inspector Quarterly Review:
a. Inspection Scope
On July 19, 2011, the inspectors observed portions of the licensed operator training and testing program to verify implementation of procedures FNP-0-AP-45, Farley Nuclear Plant Training Plan; FNP-0-TCP-17.6, Simulator Training Evaluation/Documentation; and FNP-0-TCP-17.3, Licensed Operator Continuing Training Program Administration.
The inspectors observed an annual licensed operator re-qualification examination conducted in the licensees simulator. The scenario included a steam generator (SG)tube leak with a Notice of Unusual Event (NOUE) classification, a failure of the reactor trip feature with an Alert classification and a loss of heat sink due to the failure of the auxiliary feedwater system (AFWS), with a site area emergency classification. The inspectors observed high-risk operator actions, overall crew performance, self-critiques, training feedback and management oversight to verify operator performance was evaluated against the performance standards of the licensees scenario. Documents reviewed are listed in the attachment.
b. Findings
No findings were identified.
==1R12 Maintenance Rule (MR) Effectiveness
==
.1 Resident Inspector Quarterly Inspection Samples
a. Inspection Scope
The inspectors reviewed the following three activities for
- (1) appropriate work practices;
- (2) identifying and addressing common cause failures;
- (3) scoping in accordance with 10 CFR 50.65(b) of the MR;
- (4) characterizing reliability issues for performance;
- (5) trending key parameters for condition monitoring;
- (6) charging unavailability time;
- (7) classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); and (8)appropriateness of performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified as (a)(1). In addition, the NRC specifically reviewed events where ineffective equipment maintenance resulted in invalid automatic actuations of engineered safeguards systems affecting the operating units.
Documents reviewed are listed in the attachment.
- CR 2010103897, Unit 2, 2B MDAFWP failure to start
- CR 344011, Unit 1 emergency diesel generator (EDG) 1B failed motor operated potentiometer
- CR 343336, Unit 2, 2C charging pump suction piping overpressurized
b. Findings
Introduction:
A self-revealing NCV of Technical Specification (TS) 5.4.1a was identified for the licensees failure to implement procedures recommended in Regulatory Guide (RG) 1.33. Specifically, the licensee did not properly pre-plan maintenance tagout activities on the Unit 2 charging system. As a result, the licensee inadvertently overpressurized the 2C high head safety injection (HHSI) pump suction piping, adversely affecting the availability and operability of the safety-related pump. Upon discovery of this condition, the licensee immediately depressurized the pump suction piping and initiated condition report (CR) 343336.
Description:
On August 11, 2011, the licensee prepared and implemented a tagout to support repair of the 2C charging pump (this pump also serves as the 2C high head safety injection pump) discharge valve. To complete the repair a freeze seal had to be installed downstream of the 2C charging pump discharge valve. Based on the NRC inspectors review of the tagout and interviews with station personnel, the licensee attempted to accomplish the tagout of the 2C charging pump by closing the recirculation valve for the pump, then closing the suction isolation valve for the pump. Before the licensee could complete the tagout by closing the 2C charging pump discharge valve, the discharge check valve upstream of the discharge isolation valve leaked by, causing the suction piping of the pump to be exposed to a maximum pressure of 2750 psig (pounds per square inch). The licensees pipe listing specification document indicates the 2C charging pump suction piping is rated for 150 psig.
The overpressurization condition was discovered when control room operators noticed an unplanned decrease in the volume control tank (VCT) level. System operators were dispatched to the 2C charging pump room and discovered a packing leak. The licensee stopped the tagout evolution and manipulated valves in order to stop the leak. The leak rate was calculated to be
.34 gallons per minute by correlating the leak rate on the pump
suction valve to the reduction in VCT.
The overpressurization resulted in the licensee declaring the 2C charging pump inoperable an unavailable beginning August 11, 2011. Following nondestructive examination (NDE) testing and engineering evaluation, the pump status changed to inoperable but available status on September 9, 2011.
Analysis:
Failure to properly pre-plan maintenance activities is a performance deficiency. This performance deficiency is more than minor because it is associated with the human performance attribute of the MS cornerstone, and adversely affected the cornerstone objective to ensure system availability of components responding to initiating events preventing undesirable consequences. The human performance attribute of the MS cornerstone was determined to be adversely affected because: 1)the licensees tagout procedure relied on a check valve as part of the maintenance boundary; 2) the licensees tagout sequence isolated the pump suction valve prior to isolating the pump discharge valve; resulting in overpressurization of the 2C charging pump suction piping, which rendered the 2C charging pump inoperable from August 11, 2011 to September 9, 2011. The significance of this finding was screened using IMC 0609, Significance Determination Process (SDP), Phase 1 worksheets of Attachment 4.
The finding screened as Green, because it did not represent an actual loss of safety function of a single train of ECCS greater than its TS allowable outage time.
The inspectors reviewed this performance deficiency for cross-cutting aspects and determined the licensee failed to implement work practices commensurate with the risk associated with the tagout procedure leading to unplanned unavailability of the 2C charging pump. The finding was assigned a cross cutting aspect in the resources component of the human performance area. Specifically, complete, accurate and up-to-date work packages could have prevented overpressurization of the pump. This is reflective of cross-cutting aspect H.2(c).
Enforcement:
TS 5.4.1a, requires, in part, that written procedures shall be established, implemented and maintained covering the following activities: The applicable procedures recommended in RG 1.33. RG 1.33 Appendix A, Section 9, states maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions or drawings appropriate to the circumstances. Contrary to the above, the licensee failed to properly pre-plan maintenance activities associated with the tagout of the 2C charging pump. Specifically, the licensee improperly prepared and implemented a tagout on August 11, 2011, that led to the overpressurization of the 2C charging pump suction line and subsequent unavailability of the safety-related 2C charging pump. The overpressurization condition was discovered approximately two hours later and the inadequate tagout was corrected, which was resolved the overpressurization condition.
The licensee wrote a CR to evaluate the overpressurization effects on the 2C charging pump suction piping and associated components. Because this violation was of very low safety significance and entered into the licensees CAP as CR 343336, this violation is being treated as a NCV, consistent with the Enforcement Policy. NCV 05000364/2011004-01, Failure to properly pre-plan maintenance activities while conducting tagout operations on the 2C charging pump.
==1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
==
The inspectors reviewed the following four activities to verify appropriate risk assessments were performed prior to taking equipment out of service (OOS) for maintenance. The inspectors verified risk assessments were performed as required by 10 CFR 50.65(a)(4), and were accurate and complete. When emergent work was performed, the inspectors verified appropriate use of the licensees risk assessment and risk categories in accordance with requirements in licensee procedures FNP-0-ACP-52.3, Mode 1, 2, & 3 Risk Assessment; FNP-0-UOP-4.0, General Outage Operations Guidance; NMP-GM-006, Work Management; and NMP-OS-007, Conduct of Operations.
- July 14, 2011, YELLOW risk condition concurrent with A train service water (SW)direct current (DC) system breaker replacement
- July 26, 2011, Unit 1, YELLOW risk condition concurrent with B train MDAFWP equipment outage
- July 28, 2011, Unit 2, YELLOW risk condition concurrent with B train MDAFWP equipment outage
- August 30, 2011, Unit 2, YELLOW risk condition concurrent with B train MDAFWP equipment outage
b. Findings
No findings were identified.
==1R15 Operability Evaluations
a. Inspection Scope
==
The inspectors reviewed the following five operability evaluations to verify the requirements of licensee procedures NMP-OS-007, Conduct of Operations, and NMP-AD-012, Operability Determinations (ODs) and Functionality Assessments, were met.
The scope of this inspection also included a review of the technical adequacy of the evaluations, the adequacy of compensatory measures and the impact on continued plant operation.
- CR 334648, loose tube fitting identified on the 1-2A EDG air start system shuttle valve
- CR 337192, 2B EDG secured during surveillance run due to a high jacket water temperature condition
- CR 340659, 1-2A EDG electrical load variations during surveillance run
- CR 341491, 2A containment spray pump did not develop expected discharge flow during surveillance run
- CR 343336, 2C charging pump after over-pressurization of 2C charging pump suction piping and suction isolation valve
b. Findings
No findings were identified.
==1R18 Plant Modifications
a. Inspection Scope
==
The inspectors reviewed the following temporary plant modification to ensure the safety functions of important safety systems were unaffected. The inspectors also verified design bases, licensing bases and performance capability of risk-significant SSCs had not been degraded through modifications. The inspectors verified any modification performed during risk-significant configuration did not place the plant in an unsafe condition. The inspectors evaluated system operability, availability, configuration control, post-installation test activities, documentation updates and operator awareness of the modification. Documents reviewed are listed in the Attachment.
- 2A FW regulating valve extender card installation for data-gathering of potential causes of electronic spikes on the valves controlling channel for greater than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
b. Findings
No findings were identified.
==1R19 Post-Maintenance Testing
a. Inspection Scope
==
The inspectors reviewed the criteria contained in licensee procedures FNP-0-PMT-0.0, Post-Maintenance Test Program, to verify post-maintenance test procedures and test activities for the following five systems/components were adequate to verify system operability and functional capability. The inspectors also witnessed the test or reviewed the test data to verify test results adequately demonstrated restoration of the affected safety functions. Documents reviewed are listed in the Attachment.
- FNP-0-STP-80.1, DG 1-2A Operability Test, following replacement of inverter in 1-2A DG local control panel
- FNP-2-STP-33.0B, Solid State Protection System (SSPS) Train B Operability Test, following troubleshooting of test indication.
- FNP-0-STP-24.17, DG SW Valves Remote Position Indication Inservice Test (IST)following handswitch (Q1P16HS5017A) repair to the SW to 1B EDG motor operated valves.
- FNP-2-STP-21.3, Turbine Driven Auxiliary Feedwater Pump (TDAFWP) Steam Supply Valves Valve IST following replacement of solenoid control for TDAFWP steam header warmup isolation valve Q2N12HV3234B
- FNP-2-STP-73.1, Verification of TDAFWP Steam Admission Valve Operation From The Hot Shutdown Panel, Appendix O following TDAFWP overspeed
b. Findings
No findings were identified.
==1R22 Surveillance Testing
a. Inspection Scope
==
The inspectors reviewed the following five surveillance tests and either observed the test or reviewed test results to verify testing adequately demonstrated equipment operability and met TS requirements. The inspectors reviewed the activities to assess for preconditioning of equipment, procedure adherence and valve alignment following completion of the surveillance. The inspectors reviewed licensee procedures FNP-0-AP-24, Test Control; FNP-0-M-050, Master List of Surveillance Requirements; and NMP-OS-007, Conduct of Operations, and attended selected briefings to determine if procedure requirements were met. Documents reviewed are listed in the Attachment.
Surveillance Tests
- FNP-2-STP-33.2B, Reactor Trip Breaker Train B Operability Test
- FNP-2-STP-22.2, 2B AFWP Quarterly IST
- FNP-2-STP-16.1, 2A Containment Spray Pump Quarterly IST
- FNP-2-STP-16.2, 2B Containment Spray Pump Quarterly IST
In-Service Test (IST)
- FNP-1-STP-22.2, 1B AFWP Quarterly IST
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness (EP)
1EP6 Drill Evaluation
a. Inspection Scope
The NRC evaluated the conduct of a licensee annual emergency preparedness (EP) drill on the following date to identify any weaknesses and deficiencies in classification, notification and protection action recommendation (PAR) development activities. The NRC observed emergency response operation in the simulated control room to verify event classification and notifications were performed in accordance with FNP-0-EIP-9.0, Emergency Classification and Actions. The NRC used procedure FNP-0-EIP-15.0, Emergency Drills, as the inspection criteria. The NRC also evaluated the licensee drill critique to compare any inspector-observed weaknesses with those identified by the licensee in order to verify whether the licensee was properly identifying issues.
- August 24, 2011-general emergency due to radiation levels in containment greater than 200 millirems (mrems) per hour due to a large break loss of coolant accident (LOCA) coincident with a fuel element failure and a loss of containment barrier.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
The inspectors sampled licensee data for the PIs listed below to verify the accuracy of the PI data reported during the period listed. Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline, Rev. 6, was used to verify the basis in reporting for each data element. Documents reviewed are listed in the Attachment.
Cornerstone: Barrier Integrity
- RCS activity
- RCS leakage
Cornerstone: Mitigating Systems
- Heat removal system
The inspectors reviewed samples of raw PI data, licensee event reports (LERs), and monthly operating reports for the period covering July 1, 2010, to July 31, 2011. The data reviewed was compared to graphical representations from the most recent PI report. The inspectors also examined a sampling of operations logs and procedures to verify PI data was appropriately captured for inclusion into the PI report, as well as ensuring the individual PIs were calculated correctly.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Daily Condition Report (CR) Reviews
As required by Inspection Procedure (IP) 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the NRC performed a daily screening of items entered into the licensees CAP. This review was accomplished by reviewing hard copies of CRs, attending daily screening meetings and accessing the licensees computerized database.
.2 Selected Issue Follow-up Inspection
a. Inspection Scope
In addition to the routine review, the inspectors selected the issue listed below for a more in-depth review. The inspectors considered the following during the review of the licensees actions:
- (1) complete and accurate identification of the problem in a timely manner;
- (2) evaluation and disposition of operability/reportability issues; (3)consideration of extent of condition, generic implications, common cause, and previous occurrences;
- (4) classification and prioritization of the resolution of the problem; (5)identification of root and contributing causes of the problem;
- (6) identification of CRs; and
- (7) completion of corrective actions in a timely manner.
b.
Observations:
DG 2B single circuit emergency start test surveillance was accomplished on a 558 day required frequency to ensure the diesels automatic circuitry functioned properly. The licensee utilized station procedure FNP-2-IMP-226.4 to accomplish the surveillance.
Step 7.2.4.6 of the procedure tested the 140 second response time of the emergency stop time delay drop-out relay (relay 5E). During the performance of this step on August 23, 2011, station personnel identified contact terminal points three and five were spared by a permanent plant modification installed in June 2009. The surveillance procedure directed station craft to install leads at these locations as part of the response time monitoring. The inspectors reviewed the design change package (DCP) for this modification, and reached the same conclusion as the licensee. The impact review performed prior to implementation of the modification failed to identify the need to revise the above station procedure. Additionally, the surveillance was previously accomplished on February 11, 2010, with the same revision of FNP-2-IMP-226.4. The inspectors interviewed station personnel and observed the licensees efforts to ascertain how surveillance was successfully accomplished. Station personnel did not recall how surveillance was accomplished, but their collected data was similar to data from the most recent surveillance. The inspectors determined the licensee failed to properly perform the surveillance in accordance with station guidance on February 11, 2010, but the issue was minor because the correctly performed procedure on August 23, 2011, did not identify any operability concerns with station equipment.
The inspectors also reviewed additional station documents to evaluate the extent of the condition. Previously performed surveillances of the 1-2A EDG and 1B EDG were performed with accurate procedures, reflecting the similar permanent plant modifications implemented on these EDGs. The inspectors reviewed station drawings for the starting circuitry from these EDGs, and discovered the 1B EDG controlled drawing (D-172778, Revision 20.0), had not been updated to reflect modification to this diesel. As a second verification, the NRC inspectors requested a hard copy of DCP 1959891501 and associated WO 1959891502, which indicated the modification had been completed on February 9, 2008. The NRC inspectors determined the issue was minor because the inaccurate drawing had not been relied upon or caused any operability concerns with station equipment.
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 were identified.
4OA6 Meetings, Including Exit
On October 13, 2011, the NRC presented the inspection results to you and members of your staff who acknowledged the results. The NRC confirmed proprietary information was not provided or examined during the inspection.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- D. Gilbert, EP Assistant
- B. Griner, Engineering Director
- J. Horn, Site Support Manager
- F. Hundley, Fleet Oversight Supervisor
- J. Jerkins, Corrective Action Program Supervisor
- R. Martin, Engineering Programs Manager
- S. Odom, Emergency Preparedness (EP) Supervisor Emergency Preparedness
- W. Oldfield, Licensing Engineer
- T. Pelham, Performance Improvement Supervisor
- R. Roberson, Fleet Oversight
- D. Simmons, EP Specialist
- L. Smith, Maintenance Manager
- S. Varnum, Chemistry Manager
- C. Westberry, Engineering Systems Manager
- T. Youngblood, Plant Manager
NRC personnel
James Hickey, Acting Branch Chief, Branch 2, Division of Reactor Projects
LIST OF REPORT ITEMS
Opened and Closed
Failure to properly pre-plan maintenance activities while conducting tagout operations on the 2C charging pump
Closed
None
Discussed
None