IR 05000382/2011004

IR 05000382-11-004, on 07/01/2011 - 09/30/2011, Waterford Steam Electric Station, Unit 3, NRC Integrated Inspection Report

ML113180605
Person / Time
Site:	Waterford
Issue date:	11/14/2011
From:	Ray Azua NRC/RGN-IV/DRP/RPB-E
To:	Jacobs D Entergy Operations
References
IR-11-004
Download: ML113180605 (57)

Text

UNITED STATES NUCLEAR REGULATO RY COM M I SS I ON R E G I ON I V 612 EAST LAMAR BLVD, SUI TE 400 ARLI NGTON , TEXAS 76011-4125 November 14, 2011 Donna Jacobs, Vice President, Operations Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-0751 Subject: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2011004

Dear Ms. Jacobs:

On September 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3 facility. The enclosed integrated inspection report documents the inspection findings, which were discussed on October 20, 2011, with you and other members of your staff.

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

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

Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements occurred. The NRC has also identified additional findings that were evaluated under the risk significance determination process as having very low safety significance (Green). The NRC determined that six of these findings involved violations of NRC requirements. However, because of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as non-cited violations, consistent with Section 2.3.2 of the NRC Enforcement Policy.

If you contest the violations or the significance of the non-cited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, D.C.

20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV; 612 East Lamar Blvd., Suite 400, Arlington, Texas 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspectors at the Waterford Steam Electric Station, Unit 3 facility. 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 IV, and the NRC inspectors at the Waterford Steam Electric Station, Unit 3 facility.

Entergy Operations, Inc. -2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, and its enclosure, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction.

Sincerely,

/RA/

Ray Azua Acting Chief, Project Branch E Division of Reactor Projects Docket No.: 50-382 License No.: NPF-38

Enclosure:

NRC Inspection Report 05000382/2011004 W/Attachment: Supplemental Information

REGION IV==

Docket No.: 50-382 License No.: NPF-38 Report No.: 05000382/2011004 Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3 Location: Killona, LA Dates: July 1 through September 30, 2011 Inspectors: M. Davis, Senior Resident Inspector D. Overland, Resident Inspector E. Uribe, Reactor Inspector J. Melfi, Project Engineer S. Garchow, Senior Operations Engineer Approved By: Ray Azua Acting Chief, Project Branch E Division of Reactor Projects-1- Enclosure

SUMMARY OF FINDINGS

IR 05000382/2011004; 07/01/2011-09/30/2011; Waterford Steam Electric Station, Unit 3,

Integrated Resident and Regional Report; Maintenance Effectiveness, Refueling and Other Outage Activities, Surveillance Testing, Identification and Resolution of Problems, and Follow-up of Events The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by regional based inspectors. Five NRC-identified and two self-revealing Green non-cited violations were identified. There was also one Green finding identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, Significance Determination Process. The cross-cutting aspect is determined using Inspection Manual Chapter 0310, Components within the Cross Cutting Areas. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstone: Initiating Events

Green.

The inspectors documented a self-revealing non-cited violation of Technical Specification 6.8.1.a because the licensee did not adequately implement Operating Procedure OP-001-003, Reactor Coolant System Drain Down, during the installation of the incore instrumentation flanges. Specifically, the licensee did not establish a reactor coolant system vent path while maintaining reactor coolant level below 26 feet for the assembly of the incore instrumentation flanges as required by OP-001-003. As a result, the licensee experienced a loss of reactor coolant inventory from three unassembled incore instrumentation flanges, which spilled onto the reactor vessel head insulation and filled the upper annulus cavity of the reactor vessel. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2011-3163 and CR-WF3-2011-3636. The immediate corrective actions included opening the pressurizer spray line vent valve (RC-309) to establish a reactor coolant system vent path.

The finding is more than minor because it is associated with the configuration control attribute of the Initiating Events cornerstone and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors performed the initial significance determination for the failure to adequately implement operating procedures using NRC Inspection Manual 0609, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The Initial screening directed the inspectors to use Attachment 1 of Appendix G, Shutdown Operations Significance Determination Process, based on the conditions of the plant at the time of the event. The inspectors evaluated the significance of the finding and determined that it did not require a quantitative assessment because adequate mitigating equipment remained available and the finding did not constitute a loss of control, as defined in Appendix G. Therefore, the inspectors determined that the finding is of very low safety significance (Green). This finding has a cross-cutting aspect in the work control component of the human performance area because the licensee did not appropriately coordinate work activities in incorporating actions to address the impact of the need to keep personnel apprised of work status, the operational impact of work activities, and plant conditions that may affect work activities H.3(b). (Section 1R20.1)

Green.

The inspectors documented a self-revealing non-cited violation of 10 CFR 50.55a, Codes and Standards, because the licensee did not establish and maintain an adequate testing program for a shutdown cooling heat exchanger outlet stop check valve (CS-117A) in accordance with Mandatory Appendix II, Check Valve Condition Monitoring Program, of the American Society of Mechanical Engineers Operation and Maintenance Code 2001 through 2003. Specifically, the licensee did not provide adequate inservice testing to detect degradation of seat leakage on the stop check valve CS-117A. As a result, the operating train of shutdown cooling experienced a flow diversion when the licensee opened the upstream containment spray isolation header valve to fill the containment spray riser. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2011-3350 and CR-WF3-2011-5841. The immediate corrective action included the closure of the upstream isolation valve and the initiation of a work order to address seat leakage on the stop check valve CS-117. The planned corrective action includes the development of an augmented test to determine appropriate seat leakage criteria for the stop check valve.

The finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors performed the initial significance determination using NRC Inspection Manual 0609, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The initial screening directed the inspectors to use Attachment 1 of Appendix G, Shutdown Operations Significance Determination Process, since the degraded stop check valve upsets plant stability and challenge critical safety functions during shutdown conditions. The inspectors evaluated the significance of the finding and determined that it did not require a quantitative assessment because adequate mitigating equipment remained available and the finding did not constitute a loss of control, as defined in Appendix G. Therefore, the inspectors determined that the finding is of very low safety significance (Green). This finding did not have a cross-cutting aspect associated with it because the licensee established the check valve condition monitoring program prior to the past three years. Therefore it is not reflective of current plant performance. (Section 1R20.2)

Green.

The inspectors identified a finding because the licensee did not implement procedure EN-LI-119, Apparent Cause Evaluation Process. Specifically, the licensee did not follow the requirements provided in procedure EN-LI-119,

Section 5.3.3 (k), to complete corrective actions in a timely manner for the intersystem leakage in the gas waste management system. As a result, no corrective action implementation occurred prior to additional equipment failures for the system. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2011-0934. The immediate corrective action included the reevaluation of the causal determination and development of an implementation plan to complete the corrective actions in a timely manner.

The finding is more than minor because it is associated with the protection against external factors attribute of the Initiating Events cornerstone and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.

The intersystem leakage of the gas decay tanks increase the likelihood of a potential explosive mixture and continued to challenge technical specification oxygen concentration limits. The inspectors performed the initial significance determination using NRC Inspection Manual 0609, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The Initial screening directed the inspectors to use Appendix F, Fire Protection Significance Determination Process, because the finding is a contributor to a fire initiation event. The inspectors assigned a degradation rating of low to the finding since the oxygen concentration levels in the gas decay tanks were below the limit of an explosive mixture. The inspectors determined that the finding is of very low safety significance (Green) because the finding minimally impacted the fire protection capabilities of the fire area. This finding has a cross-cutting aspect in the resources component of the human performance area in that the licensee did not minimize long-standing equipment issues and maintenance deferrals H.2(a). (Section 4OA2.3(2))

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of 10 CFR 50.65 (a)(3)because the licensee did not adequately evaluate and take into account, where practical, industry operating experience related to preventive maintenance activities for the dry cooling tower process analog control cards. Specifically, internal and industry-wide operating experience documented previous failures of process analog control cards due to age-related degradation after about 15 years of services. The vendor and industry performed a benchmark in 2003, and noted that the average service life is about 12 to 15 years. The licensee initially provided a preventive maintenance activity to replace the cards on a 20 year interval. However, the licensee deleted the preventive maintenance activities in March of 2009. The licensee determined that the cards were non-critical and had no justification of deleting the preventive maintenance activities. The inspectors noted that after the deletion of the preventive maintenance activities and prior to the 15 year service internal, the licensee experienced additional unplanned failures of several process analog control cards that challenged dry cooling tower reliability. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2011-1356. The immediate corrective action includes the evaluation of the preventive maintenance activity for the dry cooling tower process analog control cards. The planned corrective action includes the reinstatement of the preventive maintenance activity that aligns with industry operating experience.

The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The process analog control card failures challenged the system availability and reliability. The inspectors performed the initial significance determination using NRC Inspection Manual Chapter 0609, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined that the finding is of very low safety significance (Green)because the condition is not a design or qualification deficiency, did not represent the loss of a system safety function, did not represent an actual loss of a single train of equipment for more than its Technical Specification completion time, and did not screen as potentially risk-significant due to an external initiating event. This finding has a cross-cutting aspect in the operating experience component of the problem identification and resolution area in that the licensee did not implement and institutionalizes operating experience through change to station processes, procedures, equipment, and training programs P.2(b). (Section 1R12)

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because the licensee did not promptly identify and correct work order instructions used to perform technical specification surveillance requirements. Specifically, the licensee did not provide adequate work order instructions or acceptance criteria to perform technical specification surveillance requirements associated with safety-related dry cooling tower fans and control room air handling units. The inspectors initially identified the issue of concern with the control room air handling units in December 2010. However, the licensee did not perform an adequate extent of condition review to determine if other work order instructions used to perform technical specification surveillance requirements contained adequate instructions and acceptance criteria. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2010-7223 and CR-WF3-2011-6254. The immediate corrective actions include revisions to the work order instructions in order to provide appropriate quantitative and qualitative acceptance criteria.

The finding is more than minor because it is associated with the procedure quality attribute 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 (i.e., core damage).

Specifically, the inspectors concluded that without appropriate quantitative and qualitative acceptance criteria this would affect the availability, reliability, and capability of the dry cooling tower fans and control room air handling units. The inspectors evaluated this finding using NRC Inspection Manual Chapter 0609,

Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings.

The inspectors determined that the finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train for greater than its technical specification completion time, and did not screen potentially risk significant due to external events. The finding has a cross-cutting aspect in corrective action program component of the problem identification and resolution area because the licensee did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions, as necessary P.1(c). (Section 1R22.1)

Green.

The inspectors identified a non-cited violation of Technical Specification (TS)because the licensee did not enter or comply with the technical specification action requirements. Specifically, the licensee did not enter or comply with Technical Specification Surveillance Requirement 4.0.3 upon discovery of a never performed surveillance related to a safety-related relay contact for the Essential Chilled Water system. The licensee discovered the issue on July 27, 2011. However, the licensee did not enter TS 4.0.3 until August 12, 2011. Subsequently, when the licensee entered TS 4.0.3, the licensee did not perform a risk evaluation within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, as directed by the technical specification surveillance requirement. The licensee, per Technical Specification 4.0.3, has up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform a risk evaluation or enter the applicable technical specification limiting condition for operation immediately.

The inspectors determined that the licensee exceeded the allowed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and then did not enter the limiting condition for operation for Technical Specification 3.0.3 once the requirements for Technical Specification 4.0.3 and other applicable technical specifications had not been met. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2011-5779. The immediate corrective action included the performance of a special test instruction to demonstrate operability of the safety-related relay.

The finding is more than minor because it is associated with the human performance attribute 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 (i.e., core damage).

Specifically, the inspectors concluded that a failure to comply with TS 4.0.3 and 3.0.3 affects the availability and reliability of the Essential Chill Water system. The inspectors evaluated this finding using NRC Inspection Manual Chapter 0609,

Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings.

The inspectors determined that the finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train for greater than its technical specification completion time, and did not screen potentially risk significant due to external events. The finding has a cross-cutting aspect in decision-making component of the human performance area because the licensee did not make a safety-significant or risk-significant decision using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure safety is maintained H.1(a). (Section 1R22.2)

Green.

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

Criterion XVI, Corrective Action, because the licensee did not promptly correct a condition adverse to quality related to repetitive failures of the dry cooling tower fans to start and run in fast speed. Specifically, the licensee did not perform corrective actions to resolve the failure mechanism of the fast speed breaker relay in a timely manner. As a result, additional failures occurred over a period of several years prior to the implementation of corrective action in March 2011. The licensee entered this issue into their corrective action program for resolution as CR-WF3- 2011-2546. The corrective action includes a plan to replace the affected components inside the dry cooling tower fan breakers with a new design.

The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems 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 inspectors concluded that the reoccurrence of the problem challenged the reliability, and capability of the dry cooling tower fans. The inspectors performed the initial significance determination for the failure to start the dry cooling tower fans in fast speed using NRC Inspection Manual Chapter 0609, Attachment 0609.04, Phase 1 -

Initial Screening and Characterization of Findings. The Initial screening directed the inspectors to use Attachment 1 of Appendix G, Shutdown Operations Significance Determination Process, based on fact that the failures of the breaker relay to start in fast speed occurred during refueling outages. The inspectors determined that the finding was of very low safety significance (Green) because it did not require a quantitative assessment since adequate mitigating equipment remained available and it did not constitute a loss of control, as defined in Appendix G. This finding has a cross-cutting aspect in the resource component of the human performance area in that the licensee did not minimize long-standing equipment issues and maintenance deferrals H.2(a). (Section 4OA2.3(1))

• Severity Level IV. The inspectors identified a non-cited violation of 10 CFR 50.73(a)(1) because the licensee did not submit required Licensee Event Reports (LERs) within 60 days after discovery of conditions that required a report.

Specifically, the inspectors identified three instances of untimely LERs submittals for conditions related to an inoperable emergency feedwater pump, a single point vulnerability of spent fuel pool pumps, and a degraded fuel oil supply line for the Train A emergency diesel generator. The licensee submitted the reports at 332,163, and 101 days after discovery of the conditions, respectively. As a result, the licensee exceeded the 60 days for each condition that required a report. The inspectors noted that this is also contrary to the licensees reportability procedure UNT-006-010,

Event Notification and Reporting. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2010-5923. The immediate corrective actions include the performance of a human performance error review.

The inspectors considered this issue to be within the traditional enforcement process because it has the potential to impede or impact the NRC's ability to perform its regulatory function. The inspectors used the NRC Enforcement Policy to evaluate the significance of this violation. The inspectors concluded that the violation is more than minor because it occurred repeatedly within a two year period and the licensee missed opportunities to identify the issue. The NRC relies on the licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done, this impacts the NRCs ability to carry out its statutory mission. The finding has a cross-cutting aspect in the work practices component of the human performance area because the licensee did not define and effectively communicate expectations regarding procedural compliance [H.4.(b)]. (Section 4OA3.4)

Licensee-Identified Violations

None

REPORT DETAILS

Summary of Plant Status

Waterford Steam Electric Station, Unit 3, began the inspection period at 100 percent power and remained at that power level for the duration of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

1R01 Adverse Weather Protection

.1 Summer Readiness for Offsite and Alternate-ac Power

a. Inspection Scope

The inspectors performed a review of preparations for summer weather for selected systems, including conditions that could lead to loss-of-offsite power and conditions that could result from high temperatures. The inspectors reviewed the procedures affecting these areas and the communications protocols between the transmission system operator and the plant to verify that the appropriate information was being exchanged when issues arose that could affect the offsite power system. Examples of aspects considered in the inspectors review included:

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

• The explanations for the events

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

• The notifications from the transmission system operator to the plant when the offsite power system was returned to normal During the inspection, the inspectors focused on plant-specific design features and the procedures used by plant personnel to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the updated final safety analysts report and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant-specific procedures. Specific documents reviewed during this inspection are listed in the attachment. The inspectors also reviewed corrective action program items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their

corrective action program in accordance with station corrective action procedures. The inspectors reviews focused specifically on the following plant systems:

• On July 1 and July 6, 2011, performed partial walkdowns of the switchyard and the startup unit transformers.

These activities constitute completion of one

(1) readiness for summer weather affect on offsite and alternate-ac power sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignments

.1 Partial Walkdown

a. Inspection Scope

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

• On July 6, 2011, 480 volt alternate current distribution system due to a potential degraded condition on the static uninterruptible power supply 3AB

• On July 21, 2011, Train B of the essential chilled water system while train A was inoperable for corrective maintenance The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, updated final safety analysts report, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of two

(2) partial system walkdown samples as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

On August 8, 2011, the inspectors performed a complete system alignment inspection of Train B of the emergency diesel generator to verify the functional capability of the system while train A emergency diesel generator was inoperable for corrective maintenance. The inspectors selected this system because it was considered both safety significant and risk significant in the licensees probabilistic risk assessment. The inspectors inspected the system to review mechanical and electrical equipment line ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. The inspectors reviewed a sample of past and outstanding work orders to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment-alignment problems were being identified and appropriately resolved. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one

(1) complete system walkdown sample as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Fire Inspection Tours

a. Inspection Scope

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

• On July 15, 2011, fuel handling building +46 foot elevation, fire area FHB

• On July 26, 2011, control room heating and ventilation room, fire area RAB-1B

• On September 21, 2011, yard area southeast quadrant, fire area NS-YD-003

• On September 27, 2011, fire water pump house, fire area FWPH-001 The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensees fire plan.

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

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

These activities constitute completion of four

(4) quarterly fire-protection inspection samples as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors reviewed the updated final safety analysts report, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding; reviewed the corrective action program to determine if licensee personnel identified and corrected flooding problems; and verified that operator actions for coping with flooding can reasonably achieve the desired outcomes. The inspectors also inspected the areas listed below to verify the adequacy of equipment seals located below the flood line, floor and wall penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, and control circuits, and temporary or removable flood barriers.

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

• On September 29, 2011, component cooling water and shutdown cooling heat exchangers These activities constitute completion of one

(1) flood protection measures inspection sample as defined in Inspection Procedure 71111.06-05.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed licensee programs, verified performance against industry standards, and reviewed critical operating parameters and maintenance records on September 1, 2011, for the train A dry cooling towers. The inspectors verified that performance tests were satisfactorily conducted for heat exchangers/heat sinks and reviewed for problems or errors; the licensee utilized the periodic maintenance method outlined in EPRI Report NP 7552, Heat Exchanger Performance Monitoring Guidelines; the licensee properly utilized biofouling controls; the licensees heat exchanger inspections adequately assessed the state of cleanliness of their tubes; and the heat exchanger was correctly categorized under 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one

(1) heat sink inspection sample as defined in Inspection Procedure 71111.07-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Biennial Inspection

a. Inspection Scope

The inspectors:

(1) evaluated examination security measures and procedures for compliance with 10 CFR 55.49;

(2) evaluated the licensees sample plan of the written examinations for compliance with 10 CFR 55.59 and NUREG-1021, as referenced in the facility requalification program procedures;

(3) evaluated the licensed operator's performance on the biennial written examination and the first and second annual operating tests against the Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process, requirements: and (4)reviewed the maintenance of license conditions for compliance with 10 CFR 55.53 by reviewing facility records (medical and administrative), procedures, and tracking systems for licensed operator training, qualification, and watch standing.

Furthermore, the inspectors observed the administration of six dynamic simulator scenarios to two requalification crews; and observed two evaluators administer ten job performance measures, including seven in the control room simulator in a dynamic mode and three in the plant under simulated conditions.

The results of the biennial written examination included 1 individual failure. The operating exams given this year included 1 crew failure out of 11 crews and there were no job performance measure individual failures out of a total of 61 licensed operators.

These results were assessed to determine the licensees appraisal of operator performance and the feedback of performance analysis to the requalification training program. The inspectors discussed the responsiveness of the licensed operator requalification program with several members of the training department and operating crews. The inspectors also observed the examination security maintenance for the operating tests given while the inspectors were onsite July 18 through July 22, 2011.

Additionally, the inspectors assessed the Waterford 3 plant-referenced simulator for compliance with 10 CFR 55.46 using observations performed as part of the operating test inspection and Inspection Procedure 71111.11 (Section 03.11). This assessment included evaluating the adequacy of the licensees simulation facility for use in operator licensing examinations.

b. Findings

No findings were identified.

.2 Quarterly Review

a. Inspection Scope

On August 22, 2011, the inspectors observed a crew of licensed operators in the plants simulator to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• Licensed operator performance

• Crews clarity and formality of communications

• Crews ability to take timely actions in the conservative direction

• Crews prioritization, interpretation, and verification of annunciator alarms

• Crews correct use and implementation of abnormal and emergency procedures

• Control board manipulations

• Oversight and direction from supervisors

• Crews ability to identify and implement appropriate technical specification actions and emergency plan actions and notifications

The inspectors compared the crews performance in these areas to preestablished operator action expectations and successful critical task completion requirements.

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

These activities constitute completion of one

(1) quarterly licensed-operator requalification program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

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

• On August 3, 2011, dry cooling tower process analog control card failures

• On September 1, 2011, shutdown cooling heat exchanger outlet valves The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

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

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

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

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

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

These activities constitute completion of two

(2) quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05.

b. Findings

Introduction.

The inspectors indentified a Green non-cited violation of 10 CFR 50.65 (a)(3) because the licensee did not adequately evaluate and take into account, where practical, industry operating experience related to preventive maintenance activities for the dry cooling tower process analog control (PAC) cards. Specifically, the licensee deleted preventive maintenance activities to replace critical PAC cards and did not take into account where practical, industry operating experience during the evaluation.

Description.

The dry cooling tower (DCT) fans are a part of the component cooling water system, which along with the auxiliary component cooling water system, constitutes the ultimate heat sink at the Waterford Steam Electric Station, Unit 3. The DCTs are essentially large radiators. Each DCT has fifteen fans, in five banks of three.

Each individual fan has a four position handswitch allowing operation in slow speed, fast speed, or auto (off is the fourth position). Auto operation controls fan operation by monitoring component cooling water temperature at the outlet of the component cooling water heat exchanger. When temperature rises to 92 degrees, fan 1 will start in slow speed. If temperature is still above 92 degrees 60 seconds later, then fan 2 starts, and so on, until all fifteen fans are running in slow speed. If more cooling is still needed, the sequence begins again, shifting all fans to fast speed. If the component cooling water system temperature continues to rise to 100 degrees, then all fans (aligned for auto operation) immediately start in fast speed (if not already running in fast speed), and the auxiliary component cooling water system automatically starts to remove heat through the component cooling water heat exchanger. When temperature drops to 88 degrees, the fans begin to sequence off.

The process analog control (PAC) cards control the automatic operation of the DCT fans. These PAC cards perform a variety of control functions in various sequences for the automatic operation. Internal and industry-wide operating experience documented previous failures of process analog control cards due to age-related degradation after about 15 years of services. The vendor and industry performed this benchmark in 2003, and noted that the average service life is about 12 to 15 years. The licensee initially had preventive maintenance activities to replace the cards on a 20 year interval; however the preventive maintenance activities were deleted in March of 2009. Since the deletion of the preventive maintenance activity to replace the PAC cards, the licensee experienced five PAC card failures. Each card was installed in 1985, making them 25 - 26 years old, not counting any shelf-life prior to installation. These failures resulted in unplanned entries into technical specifications and challenged system reliability. In each case,

despite the loss of automatic operation of the affected fans, the PAC card failures would not have prevented the fans from starting and running in manual. The inspectors concluded that the licensee did not adequately evaluate and take into account where practical, industry operating experience related to preventive maintenance activities for the DCT PAC cards. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2011-1356. The immediate corrective action includes the evaluation of the preventive maintenance activity for the DCT PAC cards. The planned corrective action includes the reinstatement of the preventive maintenance activity.

Analysis.

The licensees failure to adequately evaluate and take into account, where practical, industry operating experience associated with preventive maintenance activities for the DCT PAC cards, is a performance deficiency. Specifically, the licensee deleted preventive maintenance activities to replace critical PAC cards and did not take into account, where practical, industry operating experience at least once every refueling cycle. As a result, the licensee experienced additional unplanned failures of several PAC cards. The inspectors determined that this deficiency is reasonable for the licensee to be able to foresee and prevent occurrence. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The PAC card failures challenged the system reliability. The inspectors performed the initial significance determination using NRC Inspection Manual Chapter 0609, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined that the finding is of very low safety significance (Green) because the condition is not a design or qualification deficiency, did not represent the loss of a system safety function, did not represent an actual loss of a single train of equipment for more than its Technical Specification completion time, and did not screen as potentially risk-significant due to an external initiating event. This finding has a cross-cutting aspect in the operating experience component of the problem identification and resolution area in that the licensee did not implement and institutionalize operating experience through change to station processes, procedures, equipment, and training programs P.2(b).

Enforcement.

Title 10 of CFR Part 50.65 (a)(1) requires, in part, that licensees shall monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that these structures, systems, and components, as defined in paragraph

(b) of this section, are capable of fulfilling their intended functions. These goals shall be established commensurate with safety and, where practical, take into account industry wide operating experience. 10 CFR 50.65 (a)(3) requires, in part, that preventive maintenance activities shall be evaluated at least every refueling cycle provided the interval between evaluations does not exceed 24 months and these evaluations shall take into account, where practical, industry-wide operating experience. Contrary to the above, as of March 2009, the licensee did not properly evaluate preventive maintenance activities on the DCT PAC cards and did not take into account, where practical, industry-wide operating experience. Specifically, industry-wide operating experience documented previous failures to PAC cards due to age related degradation, which could be prevented if replaced at a 12 -15 year period. The licensee deleted preventive maintenance tasks associated DCT PAC cards. As a result, the licensee entered

multiple unplanned technical specifications due to degraded or inoperable equipment.

However, because this finding was of very low safety significance (Green) and it was entered into the corrective action program as CR-WF3- 2011-1356. This violation of 10 CFR 50.65 (a)(3), is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy: (NCV 05000382/2011004-01, Failure to Evaluate and Adequately Perform Preventive Maintenance Activities Associated with Dry Cooling Tower Process Analog Control Cards.)

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

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

• On July 20, 2011, emergent maintenance activity to repair essential chilled water valve CHW-786A that rendered train A of the essential chill water system inoperable

• On August 15, 2011, planned maintenance activity on the B2 battery charger while the train B emergency diesel generator B2 air receiver and component cooling water train B were out of service

• On September 12, 2011, planned maintenance activity on train B high pressure safety injection pump while an emergency feedwater flow control valve was out of service

• On September 21, 2011, planned maintenance activity on the switchgear ventilation air handling unit fan 25B while the train A emergency diesel generator A1air receiver was out of service with scheduled maintenance on the AB emergency feedwater pump The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four

(4) maintenance risk assessment and emergent work control inspection samples as defined in Inspection Procedure 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• On July 8, 2011, operability determination for component cooling water train B following discovery of a ladder erected directly above component cooling water pump B

• On July 18, 2011, operability determination for refueling water storage pool recirculation actuation signal when a required surveillance revealed that the refueling water storage pool low level indication voltage was determined to be outside of design specification

• On August 15, 2011, operability determination for the air receiver associated with train A of the emergency diesel generator due to an increase in air leakage

• On September 13, 2011, operability determination for trains A and B dry cooling towers when inspectors discovered that fan start permissive contacts for dry cooling tower inlet isolation valves CC-135 A and B had not been tested The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and updated final safety analysts report to the licensee personnels evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four

(4) operability evaluation inspection samples as defined in Inspection Procedure 71111.15-04

b. Findings

No findings were identified.

1R18 Plant Modifications

.1 Temporary Modifications

a. Inspection Scope

To verify that the safety functions of important safety systems were not degraded, on July 29, 2011, the inspectors reviewed the temporary modification to install jumpers in three of the four qualified safety parameter display system channels to address a deficiency in the existing power supply wiring harnesses.

The inspectors reviewed the temporary modification and the associated safety-evaluation screening against the system design bases documentation, including the updated final safety analysts report and the technical specifications, and verified that the modification did not adversely affect the system operability/availability. The inspectors also verified that the installation and restoration were consistent with the modification documents and that configuration control was adequate. Additionally, the inspectors verified that the temporary modification was identified on control room drawings, appropriate tags were placed on the affected equipment, and licensee personnel evaluated the combined effects on mitigating systems and the integrity of radiological barriers.

These activities constitute completion of one

(1) sample for temporary plant modifications as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

1R19 Postmaintenance Testing

a. Inspection Scope

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

• On July 21, 2011, corrective maintenance repairs to essential chilled water valve, CHW-786A

• On July 26, 2011, corrective maintenance repairs on emergency feedwater flow control valve, FW-223B

• On August 1, 2011, scheduled maintenance activity to replace filters for shield building ventilation

• On September 28, 2011, emergent corrective maintenance on the train B essential chilled water pump The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following (as applicable):

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

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

These activities constitute completion of four

(4) postmaintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

The inspectors completed a review of an unresolved item in addition to an event follow-up associated with the Waterford Steam Electric Station, Unit 3 refueling outage, conducted on April 6, 2011 - May 11, 2011. During the refueling outage, the inspectors observed portions of the shutdown and cool-down processes and monitored licensee controls over the outage activities as described in previous NRC Integrated Inspection Report 05000382/2011003.

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

These activities provide closure to an unresolved item previously opened. Therefore, these inspection activities do not constitute another refueling outage inspection sample as defined in Inspection Procedure 71111.20-05.

.1 Failure to Adequately Implement a Reactor Coolant System Drain Down Procedure

Introduction.

The inspectors documented a self-revealing Green non-cited violation of Technical Specification 6.8.1.a because the licensee did not adequately implement Operating Procedure OP-001-003, Reactor Coolant System Drain Down, during the installation of the incore instrumentation flanges. Specifically, the licensee did not establish a reactor coolant system vent path while maintaining reactor coolant level below 26 feet for the assembly of the incore instrumentation flanges as required by OP-001-003.

Description.

On April 29, 2011, while installing the incore instrumentation flanges, members of the Refueling Team observed reactor coolant inventory coming from three unassembled incore instrumentation flanges. The loss of reactor coolant from the incore instrumentation flanges occurred twice within a two hour span because Operators were unaware that the pressurizer spray vent valve (RC-309) had been restored to its normal operating configuration of locked closed prior to assembly of the incore instrumentation flanges. The inspectors noted that the plant conditions at the time of the event required valve RC-309 to be open to provide a reactor coolant system vent path. Specifically, Section 6.4.6.1.2 of OP-001-003 requires either valve RC-309 to be open or the pressurizer manway to be removed while Operators maintain reactor coolant system level below 26 feet to assemble the incore instrumentation flanges.

The inspectors reviewed the logs and noted that operations personnel installed the pressurizer manway on dayshift due to other maintenance activities being completed.

However, the operations personnel did not know that valve RC-309 had also been restored to a close position prior to starting the installation of the incore instrumentation flanges. The restoration of the vent valve occurred because the Work Management Center cleared a tagout when maintenance personnel completed work on the pressurizer vessel. The inspectors concluded that with no reactor coolant system vent path established, that this caused a loss of reactor coolant inventory from three unassembled incore instrumentation flanges. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2011-3163 and CR-WF3-2011-3636. The immediate corrective action restored valve RC-309 to an open position to establish a proper vent path for the reactor coolant system.

Analysis.

The failure by the licensee to adequately implement Operating Procedure OP-001-003 is a performance deficiency. Specifically, the licensee did not establish and verify a pressurizer vent path while maintaining reactor coolant system level as required by Section 6.4.6.1.2 of OP-001-003, during the installation of the incore instrumentation flanges. It is reasonable for the licensee to be able to foresee and prevent the occurrence of this performance deficiency. The finding is more than minor because it is associated with the configuration control attribute of the Initiating Events cornerstone

and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors performed the initial significance determination for the failure to adequately implement operating procedures using NRC Inspection Manual 0609, 0609.04, Phase 1 - Initial Screening and Characterization of Findings.

The Initial screening directed the inspectors to use Attachment 1 of Appendix G, Shutdown Operations Significance Determination Process, based on the conditions of the plant at the time of the event. The inspectors evaluated the significance of the finding and determined that it did not require a quantitative assessment because adequate mitigating equipment remained available and the finding did not constitute a loss of control, as defined in Appendix G. Therefore, the inspectors determined that the finding is of very low safety significance (Green). This finding has a cross-cutting aspect in the work control component of the human performance area because the licensee did not appropriately coordinate work activities in incorporating actions to address the impact of the need to keep personnel apprised of work status, the operational impact of work activities, and plant conditions that may affect work activities H.3(b).

Enforcement.

Technical Specification 6.8.1.a requires, in part, that written procedures shall be established, implemented, and maintained for activities described in Appendix A of the Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Specifically, Section 3 of Regulatory Guide 1.33, Appendix A states, in part, instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared and implemented, as appropriate for the Reactor Coolant System.

Contrary to the above, on April 29, 2011, the licensee did not implement written procedures for the reactor coolant system during the installation of incore instrumentation flanges. Specifically, the licensee did not establish and verify a pressurizer vent path as required by Section 6.4.6.1.2 of OP-001-003 while maintaining reactor coolant system level. However, because this finding was very low safety significance and it was entered into the corrective action program as CR-WF3-2011-3163 and CR-WF3-2011-3636, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000382/2011004-02: Failure to Adequately Implement a Reactor Coolant System Drain Down Procedure).

.2 Failure to Provide Adequate Testing for a Shutdown Cooling Heat Exchanger Outlet

Stop Check Valve

Introduction.

The inspectors documented a self-revealing Green non-cited violation of 10 CFR 50.55a, Codes and Standards, because the licensee did not establish and maintain an adequate testing program for a shutdown cooling heat exchanger outlet stop check valve CS-117A in accordance with Mandatory Appendix II, Check Valve Condition Monitoring Program, of the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code 2001 through 2003. Specifically, the licensee did not provide adequate inservice testing to detect degradation of seat leakage on the stop check valve CS-117A. As a result, the operating train of shutdown cooling experienced a flow diversion when the licensee opened the upstream containment spray isolation header valve to fill the containment spray riser.

Description:

On May 6, 2011, at 2:07 a.m., the licensee met the conditions of an Unusual Event due to identified leakage of reactor coolant system inventory being greater than 25 gallons per minute. The loss of reactor coolant system inventory was due to a flow diversion from the operating Train A of the shutdown cooling system. Train A of the shutdown cooling system experienced this flow diversion because of seat leakage past a shutdown cooling heat exchanger outlet stop check valve CS-117A. This 10 inch stop check valve CS-117A has a manual closed safety function to prevent a diversion of the shutdown cooling flow to the containment spray ring header and into containment if the isolation valve upstream is open during shutdown cooling operation.

The initiation of the event occurred when the licensee opened the upstream containment spray header isolation valve CS-125A to fill the containment riser. The licensee entered this condition into their corrective action program for resolution as CR-WF3-2011-3350 and conducted an apparent cause evaluation. The licensee also initiated a higher level human performance error review to gather and evaluate the facts surrounding the event.

The licensee determined that excessive seat leakage on valve CS-117A impacted reactor coolant inventory control. The licensee also determined that the component monitoring associated with this issue does not detect increase seat leakage because it had no leakage limits specified in the design.

The inspectors performed a review of the event timeline, apparent cause evaluation, corresponding tests, and maintenance history for valve CS-117A. A review of the valves maintenance history identified other instances of excessive leakage. Based on this discovery, the inspectors requested a copy of the valves condition monitoring justification since valve CS-117A is a part of the licensees check valve condition monitoring program. The licensee implemented this program prior to May of 2011 in accordance with the Mandatory Appendix II, Check Valve Condition-Monitoring Program of ASME Code 2001 through 2003. The purpose of this program is both to improve valve performance and to optimize testing, examination, and preventive maintenance activities in order to maintain the continued acceptable performance of check valves as stated in Section ISTC-5222 of the ASME OM Code. However, the licensee did not provide any corresponding tests or maintenance activities to detect seat leakage degradation of valve CS-117A. In addition, the inspectors noted that valve CS-117A has two safety-related functions:

(1) an open function to allow containment spray flow; and

(2) a manual close function to prevent a flow diversion when shutdown cooling is in operation. The inspectors concluded that the licensee did not adequately test the manual close safety-related function of valve CS-117A. The inspectors determined that the licensee did not establish and maintain adequate testing for the shutdown cooling heat exchanger outlet stop check valve.

The licensee entered this issue into their corrective action program for resolution as CR-WF3-2011-3350 and CR-WF3-2011-5841. The immediate corrective actions include the closure of the upstream isolation valve and the initiation of a work order to address seat leakage on valve CS-117A. The planned corrective action includes the development of an augmented test to determine appropriate seat leakage criteria for the stop check valve.

Analysis.

The licensee did not establish and maintain adequate testing for the shutdown cooling heat exchanger outlet stop check valve CS-117A in accordance with Mandatory

Appendix II, Check Valve Condition Monitoring Program, of the ASME OM Code 2001 through 2003 is a performance deficiency. Specifically, the licensee did not perform adequate testing to detect degradation of seat leakage on a 10-inch stop check valve.

As a result, the operating train of shutdown cooling experienced a flow diversion when the licensee opened the upstream containment spray isolation header valve to fill the containment spray riser. This deficiency is reasonable for the licensee to be able to foresee and prevent occurrence. The finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors performed the initial significance determination using NRC Inspection Manual Chapter 0609, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The initial screening directed the inspectors to use 1 of Appendix G, Shutdown Operations Significance Determination Process, since the degraded stop check valve upsets plant stability and challenge critical safety functions during shutdown conditions. The inspectors evaluated the significance of the finding and determined that it did not require a quantitative assessment because adequate mitigating equipment remained available and the finding did not constitute a loss of control, as defined in Appendix G. Therefore, the inspectors determined that the finding is of very low safety significance (Green). This finding did not have a cross-cutting aspect associated with it because the licensee established the check valve condition monitoring program prior to the past three years. Therefore it is not reflective of current performance.

Enforcement.

Title 10 of the Code of Federal Regulations, Part 50.55a requires, in part, that testing of valves meet the requirements of the ASME OM Code. The Mandatory Appendix II, Check Valve Condition Monitoring Program of the ASME OM Code, states, in part, that this Appendix establishes the requirements for implementing and maintaining a check valve condition monitoring program as discussed in Section ISTC-5222. Section ISTC-5222 of the ASME OM Code, states, in part that the purpose of the Check Valve Condition Monitoring Program is both to improve valve performance and to optimize testing, examination, and preventive maintenance activities in order to maintain the continued acceptable performance of check valves. Contrary to the above, prior to May 6, 2011, the licensee did not establish and maintain adequate testing for the shutdown cooling heat exchanger outlet stop check valve (CS-117A) in accordance with Mandatory Appendix II, Check Valve Condition Monitoring Program, of the ASME OM Code 2001 through 2003. Specifically, the licensee did not perform adequate testing to detect degradation of seat leakage on a 10-inch stop check valve. However, because this finding is of very low safety significance (Green) and it is entered into the corrective action program as CR-WF3-2011- 3350 and CR-WF3-2011-3636, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000382/2011004-03: Failure to Provide Adequate Testing for a Shutdown Cooling Heat Exchanger Outlet Stop Check Valve).

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the updated final safety analysts report, procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME Code requirements

• Updating of performance indicator data

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

• Reference setting data

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

• On July 11, 2011, scheduled surveillance to verify operability of emergency diesel generator A

• On July 16, 2011,scheduled surveillance to verify operability of shield building ventilation train B

• On July 22, 2011, scheduled inservice test to verify operability of essential chiller AB aligned to essential chilled water train A

• On August 28, 2011, emergent surveillance test to verify operability of essential chiller A, B, and AB safety injection actuation system bypass relay contact function Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four

(4) surveillance testing inspection samples, as defined in Inspection Procedure 71111.22-05.

.1 Failure to provide adequate work order instructions for technical specification

surveillance procedures

Introduction.

The inspectors identified Green finding associated with a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because the licensee did not promptly identify and correct work order instructions used to perform Technical Specification Surveillance Requirements. Specifically, the licensee did not provide adequate work order instructions or acceptance criteria to perform surveillance requirements associated with safety-related dry cooling tower fans and control room air handling units.

Description.

During a review of the control room air handling units (AHUs) and dry cooling tower (DCT) fans, the inspectors identified an issue of concern related to the work order instructions used to perform the Technical Specification Surveillance Requirements 4.7.6.3 and 4.7.4.b, respectively. Specifically, the work orders instructions used to demonstrate operability of the control room AHUs and DCT fans did not have specified acceptance criteria or adequate instructions to determine if the surveillance test would accomplish the task satisfactorily. The inspectors also identified that the control room AHU test results were not documented as a part of the work order instructions. The inspectors initially identified the issue of concern with the AHU fans in December 2010. The inspectors noted that the licensee treated the test results as a paperless task and did not include any instructions on how to start the AHUs. The licensee captured the results of the test in the operator logs and not in the work order.

The inspectors performed a review of the operator logs and identified inconsistent entries on how operators completed the surveillance test.

The licensee conducted an extent of condition review and determined that no other issues existed with the work orders instructions that are used to perform technical specification surveillance requirements. However, the inspectors identified a similar issue with the DCT fan technical specification surveillance work order instructions. The

DCT fans work order instructions did not provide instructions on starting the fans in fast speed, which is the credited design function. The inspectors observed that there were no instructions on how to perform the test and that the licensee relied on operator knowledge to start the DCT fans in fast speed. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2010-7223 and CR-WF3-2011-6254, respectively. The immediate corrective actions include a revision to the work order instructions to provide adequate instructions and acceptance criteria for both the control room AHUs and DCT fan surveillance tasks.

Analysis.

The performance deficiency is that the licensee did not promptly identify and correct work order instructions used to perform Technical Specification Surveillance Requirements. Specifically, the licensee did not provide adequate work order instructions or acceptance criteria to perform surveillance requirements associated with safety-related dry cooling tower fans and control room air handling units. The inspectors determined that this deficiency is reasonable for the licensee to be able to foresee and prevent occurrence. The finding is more than minor because it is associated with the procedure quality attribute 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 (i.e., core damage).

Specifically, the inspectors concluded that without appropriate quantitative and qualitative acceptance criteria this would affect the availability, reliability, and capability of the DCT fans and control room AHUs. The inspectors evaluated this finding using NRC Inspection Manual Chapter 0609, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined that the finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train for greater than its technical specification completion time, and did not screen potentially risk significant due to external events. The finding has a cross-cutting aspect in corrective action program component of the problem identification and resolution area because the licensee did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions, as necessary P.1(c).

Enforcement.

Title 10 of CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that conditions adverse to quality are promptly identified and corrected.

Contrary to the above, prior to September 6, 2011, did not promptly identify and correct work order instructions used to perform technical specification surveillance requirements. Specifically, the licensee did not provide adequate work order instructions or acceptance criteria to perform technical specification surveillance requirements associated with safety-related dry cooling tower fans and control room air handling units.

However, because this finding was of very low safety significance (Green) and it was entered into the corrective action program as CR-WF3-2011-6254, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000382/2011004-04: Failure to Promptly Identified and Correct Work Order Instructions used for Technical Specification Surveillance Requirements).

.2 Failure to comply with Technical Specifications Surveillance Requirement 4.0.3 and the

Limiting Condition for Operations for Technical Specification 3.0.3.

Introduction.

The inspectors identified a Green finding associated with a non-cited violation of Technical Specification because the licensee did not enter or comply with a technical specification action requirement. Specifically, the licensee did not enter TS 4.0.3 or comply with the requirements to perform a risk evaluation within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, as directed by the technical specification, once the licensee discovered that a surveillance test for a safety-related relay contact for the Essential Chilled Water system had never been performed.

Description.

On July 27, 2011, the licensee initiated a condition report to document a concern with a safety-related relay bypass contact relay contained in the starting circuit of all three essential chillers of the Essential Chilled Water system. The concern was that the Safety Injection Actuation Signal bypass contact, K7 relay, had never been tested. The licensee performed an operability assessment and documented the situation as being operable with an evaluation based on informal engineering input. The licensee requested engineering to provide a more formal operability evaluation within seven days. On August 4, 2011, the licensee determined that the concern identified on July 27, 2011 constituted a missed surveillance and a failure to comply with NRC Generic Letter 96-01, Testing of Safety-Related Logic Circuits. However, the licensee did not enter Technical Specification Surveillance Requirement 4.0.3 until August 12, 2011. The inspectors noted that this was sixteen days after the condition existed and therefore did not comply with Technical Specification 4.0.3 requirements. The licensee had up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform a risk evaluation or enter the applicable limiting condition for operation immediately as required by the technical specification. Additionally, Technical Specification 4.0.3 requires a risk evaluation for any surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and that the risk impact shall be managed. The inspectors noted that even after the delayed entry into Technical Specification 4.0.3 on August 12, 2011, the licensee did not perform a risk evaluation until August 19, 2011. The inspectors determined that the licensee exceeded the allowed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to comply with the requirements in Technical Specification 4.0.3 and did not enter the limiting condition for operation for Technical Specification 3.0.3 immediately since the never performed surveillance test, affected both safety Trains of the Essential Chilled Water system. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2011-5779. The immediate corrective action included the performance of a special test instruction to demonstrate operability of the safety-related relay.

Analysis.

The performance deficiency is that the licensee did not comply with the limiting condition for operation for Technical Specification 3.0.3 and Technical Specification Surveillance Requirement 4.0.3. Specifically, the licensee did not perform a risk evaluation or enter the limiting condition for operation for Technical Specification 3.0.3 after a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, once the licensee discovered that surveillance, on a safety-related relay contact for the Essential Chilled Water system had never been performed.

The inspectors determined that this deficiency is reasonable for the licensee to be able to foresee and prevent occurrence. The finding is more than minor because it is associated with the human performance attribute 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 (i.e.,

core damage). Specifically, the inspectors concluded that a failure to comply with TS 4.0.3 and 3.0.3 affects the availability and reliability of the Essential Chill Water system.

The inspectors evaluated this finding using NRC Inspection Manual Chapter 0609, 0609.04, Phase 1 - Initial Screening and Characterization of Findings.

The inspectors determined that the finding was of very low safety significance (Green)because the finding was not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train for greater than its technical specification completion time, and did not screen potentially risk significant due to external events. The finding has a cross-cutting aspect in decision-making component of the human performance area because the licensee did not make a safety-significant or risk-significant decision using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure safety is maintained H.1(a).

Enforcement.

Technical Specification Surveillance Requirement 4.0.3 requires, in part that if it is discovered that the Surveillance was not performed within its specified interval, then compliance with the requirement to declare the limiting condition for operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever greater. A risk evaluation shall be performed for any surveillance delay greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed. IF the Surveillance is not performed within the delay period, the limiting condition for operation must immediately be declared not met, and the applicable ACTION(s) must be entered.

Technical Specification 3.0.3 requires, in part, that when a limiting condition for operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable, in at least HOT STANDBY within the next six hours, at least in HOT SHUTDOWN within the following six hours, and at least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Contrary to the above, between July 27, 2011 and August 19, 2011, while in MODE 1, the licensee did not comply with the limiting condition for operation for Technical Specifications 3.0.3 and 4.0.3. Specifically, the licensee did not performed a risk evaluation or enter the limiting condition for operation for Technical Specification 3.0.3 after a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, once the licensee discovered that a surveillance on a safety-related relay contact had not been performed. The licensee discovered the issue on July 27, 2011. However, the licensee did not enter Technical Specification 4.0.3 until August 12, 2011 and did not perform a risk evaluation until August 19, 2011. The inspectors determined that the licensee exceeded the allowed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to comply with requirements in Technical Specification 4.0.3 and did not enter the limiting condition for operation for Technical Specification 3.0.3 immediately since the never performed surveillance affected both Trains of the Essential Chilled Water system. However, because this finding was a Severity Level IV and it was entered into the corrective action program as CR-WF3-2011-5779, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy.

(NCV 05000382/2011004-05: Failure to Comply with Technical Specifications Surveillance Requirement 4.0.3 and the Limiting Conditions for Operation for Technical Specifications 3.0.3).

1EP6 Drill Evaluation

.1 Training Observations

a. Inspection Scope

The inspectors observed a simulator based exercise for licensed operators on August 22, 2011, that required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the postevolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the attachment.

These activities constitute completion of one

(1) sample as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the licensee for the second Quarter 2011 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, Performance Indicator Program.

This review was performed as part of the inspectors normal plant status activities and, as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

.2 Safety Systems Functional Failures (MS05)

a. Inspection Scope

The inspectors sampled licensee submittals for the safety system functional failures performance indicator for the period from the second quarter 2010 through the second quarter 2011 to determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73." The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and NRC integrated inspection reports for the period from the second quarter 2010 through the second quarter 2011 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one

(1) safety system functional failures sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.3 Mitigating Systems Performance Index - Heat Removal System (MS08)

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance index - heat removal system performance indicator for the period from the second quarter 2010 through the second quarter 2011 to determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator narrative logs, issue reports, event reports, mitigating systems performance index derivation reports, and NRC integrated inspection reports from the second quarter 2010 through the second quarter 2011 to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one

(1) mitigating systems performance index -

heat removal system sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.4 Mitigating Systems Performance Index - Residual Heat Removal System (MS09)

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance index - residual heat removal system performance indicator for the period from the second quarter 2010 through the second quarter 2011 to determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator narrative logs, issue reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports for the period from the second quarter 2010 through the second quarter 2011 to validate the accuracy of the submittals.

The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one

(1) mitigating systems performance index -

residual heat removal system sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

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

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees

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

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

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

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

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

b. Findings

No findings were identified.

.3 Selected Issue Follow-up Inspection

a. Inspection Scope

The inspectors performed an in-depth review of the licensees evaluation and corrective actions related to repetitive failures of the dry cooling tower fan fast speed solenoids and intersystem leakage in the waste gas management system. The inspectors reviewed the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluation identified likely causes for the issues and identified appropriate corrective actions to address the identified causes. The inspectors also conducted a review of the corrective actions to verify that appropriate measures were in place to prevent

reoccurrence of the issue. In addition, the inspectors assessed whether the licensee's evaluation considered extent of condition, generic implications, common cause, and previous occurrences. The inspectors reviewed the potential impact on nuclear safety and risk to verify that the licensee had taken corrective actions commensurate with the significance of the issue. The inspectors evaluated these actions against the requirements of the licensee's corrective actions program and performance attributes contained in IP 71152, Section 03.06.

These activities constitute completion of two

(2) in-depth problem identification and resolution samples as defined in Inspection Procedure 71152-05.

b. Findings

(1) Untimely Actions to Correct Repetitive Dry Cooling Tower Fan Failures

Introduction.

The inspectors identified a Green finding associated with a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, because the licensee did not promptly correct a condition adverse to quality. The adverse condition was the repetitive failure of the dry cooling tower fans to start and run in fast speed.

Corrective actions to resolve the adverse condition were not consistent with the failure mechanism, and were not taken in a timely manner.

Description.

The dry cooling tower (DCT) fans are a part of the component cooling water system, which along with the auxiliary component cooling water system, constitutes the ultimate heat sink at the site. The component cooling water system is a two train system, each with a 100 percent capacity pump and a swing pump that can be aligned to either train. Train heat rejection is through a heat exchanger (cooled by auxiliary component cooling water) and a DCT. The DCTs are essentially large radiators. Each DCT has fifteen fans, in five banks of three. Each individual fan has a four position handswitch allowing operation in slow speed, fast speed, or auto (off is the fourth position). The breaker for each fan contains two starting solenoids, a three-pole solenoid for slow speed fan operation and a five-pole solenoid for fast speed fan operation.

Failure of the DCT fan breakers began in October 2000. Since then, the site has experienced eleven failures, in total. After the sixth failure in 2007, the licensee identified the repeating failures as a condition adverse to quality and performed an apparent cause evaluation. The cause was determined to be overstress to the five-pole solenoid, however the corrective actions addressed an aging mechanism, rather than a degradation mechanism and its source. The actions created preventative maintenance tasks to replace the solenoids. Despite the incorrect alignment of cause and action, if implemented in a timely manner, the actions could have prevented reoccurrence of the breaker failures.

Between March 29, 2011 and April 25, 2011, the site experienced four additional failures of this long-standing issue, preventing DCT fans from starting in fast speed on demand.

Each of the four failures prevented a DCT fan from starting in auto or manual, resulting

in the fan being inoperable. Only one of the four failures occurred during a required mode of operation, with the other three occurring during shutdown operations.

In all four cases, the fault was a shorted winding in the five-pole fast speed solenoid. A root cause determination concluded that the most likely cause was failure of the fast speed coil due to repetitive exposure to an elevated voltage condition (which is consistent with the overstress conclusion in 2007). Each breaker is rated for 120Vac

+/- 10 percent. During outage conditions, the coils see voltage that is toward the high end or slightly above specification. The licensee concluded that this degradation mechanism shortened the life of the coils and led to eventual failure. No manufacturer recommendations for life expectancy are provided.

Between 2007 and 2011, the licensee identified (on multiple occasions) that the corrective actions to address the solenoid failures were not being implemented in a timely fashion (CR-WF3-2009-3322, CR-WF3-2010-1957, CR-WF3-2011-0034, CR-WF3-2011-0566, and CR-WF3-2011-1839). Additionally, some of the preventive maintenance tasks created in response to the apparent cause evaluation in 2007 were later retired with no alternative maintenance strategy.

Immediate corrective actions have been to replace the failed solenoids. Additional corrective actions include a design change to replace the solenoids with a newer design and develop a preventive maintenance strategy to maintain system health.

Analysis.

The failure to take timely corrective actions to resolve a condition adverse to quality is a performance deficiency. The inspectors determined that this deficiency is reasonable for the licensee to be able to foresee and prevent occurrence. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems 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 inspectors concluded that the reoccurrence of the problem challenged the reliability, and capability of the DCT fans.

The inspectors performed the initial significance determination for the failure to start the DCT fans in fast speed using NRC Inspection Manual Chapter 0609, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The Initial screening directed the inspectors to use Attachment 1 of Appendix G, Shutdown Operations Significance Determination Process, based on fact that the failures of the breaker relay to start in fast speed occurred during refueling outages. The inspectors determined that the finding was of very low safety significance (Green) because it did not require a quantitative assessment since adequate mitigating equipment remained available and it did not constitute a loss of control, as defined in Appendix G. This finding has a cross-cutting aspect in the resource component of the human performance area in that the licensee did not minimize long-standing equipment issues and maintenance deferrals H.2(a).

Enforcement.

Title 10 of CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that conditions adverse to quality are promptly identified and corrected.

Contrary to the above, between March 2007 and March 2011, the licensee failed to assure that the corrective actions taken to address the adverse condition identified in

2007 were implemented in a timely manner. As a result, additional failures challenged system operability. However, because this finding was of very low safety significance (Green) and it was entered into the corrective action program as CR-WF3-2011-2546, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000382/2011004-06: Untimely Actions to Correct Repetitive Dry Cooling Tower Fan Failures)

(2) Failure to Follow Apparent Cause Evaluation Process Procedure

Introduction.

The inspectors identified a finding because the licensee did not implement procedure EN-LI-119, Apparent Cause Evaluation Process. Specifically, the licensee did not follow the requirements provided in procedure EN-LI-119, Section 5.3.3 (k), to complete corrective actions in a timely manner for the intersystem leakage in the gas waste management system.

Description.

The gas waste management (GWM) system consists of two waste gas compressors and three gas decay tanks (GDTs). Gas concentrations in the decay tanks are governed by technical specifications, to ensure that hydrogen and oxygen concentrations do not result in an explosive mixture in any of the three decay tanks.

Intersystem leakage in the GWM system is documented back as far as 2006. Beginning in 2008, multiple technical specification limiting condition for operation entries has been required as a result of the GDT hydrogen and oxygen concentrations. These prohibited concentrations were the result of intersystem leakage. In 2008, the GWM intersystem leakage was identified as a condition adverse to quality and an apparent cause evaluation (ACE) was completed for this long-standing equipment issue. The ACE concluded that the leakage was the result of corrosion particles from the carbon steel system piping marring the isolation valve seating surfaces, resulting in leakage past the closed seat. The ACE also concluded that since the GWM system was classified as a run-to-fail system, no preventive maintenance tasks were in place to maintain GWM system health. Corrective actions included replacing the carbon steel piping between the compressors and the GDTs with stainless steel piping and scheduled work to fix leakage past GDT isolation valves (this could only be done during a refueling outage).

Additionally, work to repair a leaking GDT nitrogen isolation valve NG-230A was scheduled for refueling outage RF-16.

In 2010 and 2011, additional technical specification limiting condition for operation entries occurred, as a result of prohibited gas concentrations in the GDTs. On February 14, 2011, TS 3.11.2.5 action statement was entered, and the licensee was unable to comply with the required action to reduce tank hydrogen concentration to an acceptable level within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, necessitating a licensee event report submittal. Intersystem leakage past the NG-230 valves (which had not yet been repaired) caused the three GDTs to essentially behave as a single tank. This condition was once again categorized as a condition adverse to quality and an ACE was completed. The ACE reached the same conclusion as the ACE in 2008; corrosion particles from the carbon steel components were marring isolation valve seating surfaces. The only difference in these subsequent events was the source of the carbon steel corrosion particles. The corrective actions from 2008 only replaced the carbon steel piping on the discharge of

the compressors. The carbon steel GDTs and other carbon steel system piping were not addressed in corrective actions from 2008, and therefore continued to provide a source for corrosion particles to be created. Limited scope during the extent of condition completed in 2008 did not consider these other potential corrosion sources as a problem. Additionally, the work to repair NG-230A during RF-16 was cancelled and this corrective action from 2008 had not been completed prior to multiple additional failures, resulting in the subsequent technical specification limiting condition for operation entries.

The inspectors reviewed NUREG/CR-2726, Light Water Reactor Hydrogen Manual, Revision 3, and determined that although outside technical specification limits, the actual gas concentrations on February 14, 2011 remained below acceptable limits and therefore did not pose an actual explosion hazard. Immediate actions were to return gas concentrations to TS acceptable levels. Additional corrective actions were to repair the leaking isolation valves and to evaluate additional preventive maintenance tasks to maintain system health.

The inspectors also identified that the licensee failed to assess the run to failure classification of the GWM system following the ACE completed in 2008, which stated, Each run to failure system has been evaluated to determine if the consequences of failure are considered acceptable. In the case of the GWM system, it appears that the consequences of failure are greater than previously considered. System and component classification is done according to corporate procedure EN-DC-153, Preventive Maintenance Component Classification. The revision in effect when the 2008 ACE was completed was revision 1. According to this procedure, the WGM system should have been classified as a critical system, rather than a run to fail system (two classifications lower). A critical system would have preventive maintenance tasks designed to maintain system reliability, where a run to fail system has no preventive maintenance tasks. Despite the 2008 ACE conclusion that the run to fail classification of the GWM system underestimates the failure consequences, no corrective actions were created to evaluate the appropriateness of the classification.

Ultimately, no changes were made to the system classification, even though procedure EN-DC-153 would have required a different classification.

Analysis.

The failure to follow a safety-related procedure is a performance deficiency.

This performance deficiency led to untimely corrective actions to resolve a condition adverse to quality. The inspectors determined that it is reasonable for the licensee to be able to foresee and prevent the occurrence of this deficiency. The finding is more than minor because it is associated with the protection against external factors attribute of the Initiating Events cornerstone and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The intersystem leakage of the GDTs, increase the likelihood of a potential explosive mixture and continued to challenge technical specification oxygen concentration limits. The inspectors performed the initial significance determination using NRC Inspection Manual Chapter 0609, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The Initial screening directed the inspectors to use Appendix F, Fire Protection Significance Determination Process, because the finding is a contributor to a fire initiation event.

The inspectors assigned a degradation rating of low to the finding since the oxygen

concentration levels in the GDTs were below the limit of an explosive mixture. The inspectors determined that the finding is of very low safety significance (Green) because the finding minimally impacted the fire protection capabilities of the fire area. This finding has a cross-cutting aspect in the resources component of the human performance area in that the licensee did not minimize long-standing equipment issues and maintenance deferrals H.2(a).

Enforcement.

Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory requirement. This finding was of very low safety significance and entered into the licensees corrective action program as CR-WF3-2011-0934. (FIN 05000382/2011004-07: Failure to Follow Apparent Cause Evaluation Process Procedure).

4OA3 Event Follow-up

.1 (Closed) Licensee Event Report (LER) 05000382/2009-003-00: Multiple Tyco Relay

Failures.

This LER was updated and supplemented in LER 05000382/2009-003-01. Therefore, LER 05000382/2009-003-00 is being administratively closed and the issues will be reviewed under the supplemental LER.

.2 (Closed) Licensee Event Report (LER) 05000382/2009-003-01: Multiple Tyco Relay

Failures.

The inspector performed an in-office evaluation of documentation submitted by licensee personnel.

On July 8, 2009, the licensee identified that a higher than expected failure rate existed for normally energized Tyco Relay Model E7024PB electro-pneumatic time delay relays produced since 2007. On July 24, 2009, the NRC completed the on-site portion of a special inspection at the facility. The special inspection focused on circumstances surrounding six failures of safety-related relays in a ten-month period from September 2008 through June 2009. The inspector reviewed the event captured in LER 2009-003 and Condition Report CR-WF3-2009-03448, including the associated Root Cause

Analysis.

On February 22, 2010, the licensee identified a failed Tyco Relay Model Type E7024PB during a scheduled surveillance test. On February 27, 2010, the licensee identified a second failed Tyco Relay Model Type E7024PB during a scheduled surveillance test.

The licensee sent the two relays to the vendor for failure analysis. The vendor informed the licensee that the problems with the relays were not significant and concluded that the issues did not constitute a defect requiring notification per 10 CFR Part 21.

However, the licensee concluded that it was appropriate to issue a Part 21 notification, and did so on April 21, 2010, for the Tyco Relay Model Type E7024PB.

The licensee determined that replacing the relays would be the most effective corrective action and implemented a schedule to replace all Tyco Relay Model Type E7024PB with

a specified date code. The resident inspectors completed a thorough review of the two latest failures and issued the licensee a violation for untimely corrective actions. This violation is documented as non-cited violation 05000382/2010003-01, Failure to Conduct Timely Corrective Actions to Replace Faulty Relays. The inspector determined that Licensee Event Report 2009-003-01 contained no new issues that had not been addressed in inspection reports 05000382/2009010 and 05000382/2010003.

Therefore, this licensee event report is closed.

.3 (Closed) Licensee Event Report (LER) 05000382/2011-001-00: Waste Gas System

Oxygen Exceeded Technical Specification Allowed Duration.

The inspectors reviewed a condition where intersystem leakage in the waste gas management system caused the licensee to violate hydrogen and oxygen gas concentration limits described in technical specification 3.11.2.5. The inspectors identified a non-cited violation that is documented as NCV 05000382/2011004-07 and is described in Section 4OA2 of this report. Therefore, this licensee event report is closed.

.4 Failure to submit a LER within 60 days after discovery of an event

Introduction.

The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.73(a)(1) because the licensee did not submit required Licensee Event Reports (LERs) within 60 days after discovery of conditions that required a report. Specifically, the inspectors identified three instances of untimely LERs submittals for conditions related to an inoperable emergency feedwater pump, a single point vulnerability of spent fuel pool pumps, and a degraded fuel oil supply line for the Train A emergency diesel generator. The licensee submitted the reports at 332,163, and 101 days after discovery of the conditions, respectively.

Description:

During the review and closure of several Licensee Event Reports (LERs),the inspectors identified three instances within a two year period of the licensees failure to submit a required LER within 60 days after discovery of conditions that required a report. Specifically, the inspectors identified three instances of untimely LERs submittals for conditions related to an inoperable emergency feedwater pump, a single point vulnerability of spent fuel pool pumps, and a degraded fuel oil supply line for the Train A emergency diesel generator. The licensee submitted the reports at 332,163, and 101 days after discovery of the conditions, respectively. As a result, the licensee exceeded the 60 days for each condition that required a report. In the instance that involved the inoperable emergency feedwater pump, the licensee did not adequately evaluate the condition initially as a part of their reportability review. The licensee discovered the inadequate evaluation nine months after the event. Subsequently, the licensee requested an additional extension to complete the reportability review. The extension was due to other emergent regulatory issues as stated in the justification. The inspectors noted that 332 days passed prior to the submittal on April 27, 2009.

In the other two instances, the licensee was aware of the condition that existed but requested extensions to perform and complete the reportability review. The licensee extended the reportability review because of work priorities and other administrative

tasks as stated in the justification of the extensions. The inspectors noted that this did not meet the requirements as described in procedure UNT-006-010, Event Notification and Reporting. Section 5.5.4 of Procedure UNT-006-010 requires, in part, that in cases where a potentially reportable condition may need additional information to determine the reportability, the due date should be limited to 30 days from the date initiation unless there is reasonable assurance that the condition will ultimately be determined non-reportable. The inspectors determined that the extensions did not meet the intent of the licensees event notification and reporting procedure. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2009-4908, CR-WF3-2010-0889 and CR-WF3-2010-5923. The immediate corrective actions included the performance of a human performance error review.

Analysis.

The performance deficiency is that the licensee did not submit required Licensee Event Reports within 60 days after discovery of conditions that required a report. Specifically, the inspectors identified three instances of untimely LERs for conditions related to an inoperable emergency feedwater pump, a single point vulnerability of spent fuel pool pumps, and a degraded fuel oil supply line for the Train A emergency diesel generator. The inspectors determined that this deficiency is reasonable for the licensee to be able to foresee and prevent occurrence. The inspectors considered this issue to be within the traditional enforcement process because it has the potential to impede or impact the NRC's ability to perform its regulatory function. The inspectors used the NRC Enforcement Policy to evaluate the significance of this violation. The inspectors concluded that the violation is more than minor because it occurred repeatedly within a two year period. The NRC relies on the licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not met, this impacts the NRCs ability to carry out its statutory mission. The finding has a cross-cutting aspect in the work practices component of the human performance area because the licensee did not define and effectively communicate expectations regarding procedural compliance H.4(b).

Enforcement.

Title 10 of CFR 50.73(a)(1) states, in part, that the holder of an operating license under this part shall submit a Licensee Event Report (LER) for any event of the type described in this paragraph within 60 days after discovery of the event or condition.

Contrary to the above, between April 27, 2009 and May 20, 2010, the licensee did not submit required Licensee Event Reports within 60 days after discovery of conditions that required a report. Specifically, the inspectors identified three instances of untimely LERs for conditions related to an inoperable emergency feedwater pump, a single point vulnerability of spent fuel pool pumps, and a degraded fuel oil supply line for the Train A emergency diesel generator. The licensee submitted the reports at 332,163, and 101 days after discovery. As a result, the licensee did not promptly submit LERs within 60 days for each condition that required a report. However, because this finding was a Severity Level IV and it was entered into the corrective action program as CR-WF3-2010-1330, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000382/2011004-08: Failure to submit a LER within 60 days after discovery of an event).

4OA5 Other Activities

(Closed) URI 05000382/2011003-05 Loss of Reactor Coolant Inventory during the Assembly of Incore Instrumentation Flanges The inspectors opened an unresolved item in NRC Inspection Report 05000382/2011003 to review a loss of reactor coolant inventory resulting from an error during a tagging restoration.

The inspectors concluded that a self-revealing non-cited violation occurred. This item is documented as NCV 05000382/2011004-02 and is discussed in Section 1R20 of this report.

4OA6 Meetings

Exit Meeting Summary

On October 20, 2011, the inspectors presented the inspection results to Ms. Donna Jacobs, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. The inspectors returned the proprietary information used during the inspection prior to the end of the inspection period.

On September 14, 2011, the inspectors presented the results of the review of LER 2009-003-00 and LER 2009-003-01 to Mr. W. Steelman, Manager, Licensing and Regulatory Affairs. The licensee acknowledged the issues presented. No proprietary information was reviewed.

On July 22, 2011, the inspectors presented the preliminary results of the onsite inspection to licensee staff, who acknowledged the insights provided. The inspectors confirmed that proprietary information was returned to licensee staff prior to leaving the site. The final results of the inspection were provided via telephonic exit by Steve Garchow to John Signorelli, Simulator Training Superintendent, on September 8, 2011.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Entergy Personnel

D. Jacobs, Vice President, Operations

K. Cook, General Manager, Plant Operations

E. Begley, Senior Engineer, Programs and Components

B. Briner, Technical Specialist IV, Programs and Components

A. Buford, Engineer II, System Engineering

J. Jarrell, Manager, Operations

G. Fey, Manager, Emergency Planning

C. Fugate, Assistant Manager, Operations

J. Hashim, Senior Engineer, Programs and Components

M. Haydel, Supervisor, Programs and Components

J. Hornsby, Manager, Chemistry

J. Houghtaling, Senior Project Manager

C. Hunsaker, Code Programs Engineer

J. Labry, Senior Operations Training Instructor

H. Landeche, Jr., Senior Technician, Instruments and Controls

B. Lanka, Manager, System Engineering

B. Lindsey, Manager, Maintenance

M. Mason, Senior Licensing Specialist, Licensing

W. McKinney, Manager, Corrective Action and Assessments

D. Miller, Supervisor, Radwaste and Radioactive Material Control

D. Moor, Fleet Manager, Radiation Protection

K. Nichols, Director, Engineering

R. Perry, Senior Emergency Planner

J. Pollack, Senior Licensing Specialist, Licensing

C. Pramono, Engineer, Systems Engineering

T. Qualantone, Manager, Plant Security

W. Steelman, Manager, Licensing and Regulatory Affairs

D. Vince, Operations Training Superintendent

J. Williams, Senior Licensing Specialist, Licensing

NRC Personnel

M. Davis, Senior Resident Inspector

D. Overland, Resident Inspector

Attachment

LIST OF ITEMS

OPENED AND CLOSED

Opened and Closed

05000382/2011004-01 NCV Failure to Evaluate and Adequately Perform Preventive Maintenance Activities Associated with Dry Cooling Tower Process Analog Control Cards (Section 1R12)

05000382/2011004-02 NCV Failure to Adequately Implement a Reactor Coolant System Drain Down Procedure (Section 1R20.1)

05000382/2011004-03 NCV Failure to Provide Adequate Testing for a Shutdown Cooling Heat Exchanger Outlet Stop Check Valve (Section 1R20.2)

05000382/2011004-04 NCV Failure to Promptly Identified and Correct Work Order Instructions used for Technical Specification Surveillance Requirements (Section 1R22.1)

05000382/2011004-05 NCV Failure to Comply with Technical Specifications Surveillance Requirement 4.0.3 and the Limiting Conditions for Operation for Technical Specifications 3.0.3 (Section 1R22.2)

05000382/2011004-06 NCV Untimely Actions to Correct Repetitive Dry Cooling Tower Fan Failures (Section 4OA2.3(1))

05000382/2011004-07 FIN Failure to Follow Apparent Cause Evaluation Process Procedure (Section 4OA2.3(2))

05000382/2011004-08 NCV Failure to Submit a LER within 60 days after Discovery of an Event (Section 4OA3.4)

Closed

05000382/2009003-00 LER Multiple Tyco Relay Failures (Section 4OA3.1)

05000382/2009003-01 LER Multiple Tyco Relay Failures (Section 4OA3.2)

05000382/2011001-00 LER Waste Gas System Oxygen Exceeded Technical Specification Allowed Duration (Section 4OA3.3)

05000382/2011003-05 URI Loss of Reactor Coolant Inventory during the Assembly of Incore Instrumentation Flanges (Section 4OA5)

Attachment