IR 05000220/2011005

IR 05000220-11-005 and 05000410-11-005. Nine Mile Point Nuclear Station - NRC Integrated Inspection Report

ML12027A220
Person / Time
Site:	Nine Mile Point
Issue date:	01/27/2012
From:	Glenn Dentel Reactor Projects Branch 1
To:	Langdon K Nine Mile Point
Dentel G
References
IR-11-005
Download: ML12027A220 (35)

Text

SUBJECT:

NINE MILE POINT NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000220/2011005 AND 05000410/2011005

Dear Mr. Langdon:

On December 31, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Nine Mile Point Nuclear Station Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on January 13, 2012, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

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

This report documents two NRC-identified and one self-revealing findings of very low safety significance (Green). One of the findings was determined to involve a violation of NRC requirements. However, because of the very low safety significance, and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCV noted in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, AnN,:

Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Nine Mile Point Nuclear Station. In addition, jf 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 I, and the NRC Resident Inspector at Nine Mile Point Nuclear Station.

In accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).

Sincerely,

~1:Jd Glenn T. Dentel, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-220,50-410 License Nos.: DPR-63, NPF-69

Enclosure:

Inspection Report 05000220/2011005 and 05000410/2011005 w/Attachment: Supplementary Information

REGION I==

50-220,50-410 DPR-63, NPF-69 05000220/2011005; 05000410/2011005 Nine Mile Point Nuclear Station, LLC (NMPNS)

Nine Mile Point, Units 1 and ~~

Oswego, NY October 1 through December 31,2011 K. Kolaczyk, Senior Resident Inspector D. Dempsey, Resident Inspector T. Fish, Senior Operations Engineer N. Perry, Senior Project Engineer J. Brand, Reactor Engineer B. Fuller, Operations Engineer B. Keighley, Project Engineer T. Ziev, Reactor Engineer Glenn T. Dentel, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000220/2011005, 05000410/2011005; 10101/2011 - 12/31/2011; Nine Mile Point Nuclear

Station, Units 1 and 2; Operability Determinations and Functionality Assessments, Problem Identification and Resolution, Follow-up of Events and Notices of Enforcement Discretion.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Thre~:; Green findings, one of which was a non cited violation (NCV), were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). The cross-cutting aspects for th~9 findings were determined using IMC 0310, "Components Within Cross-Cutting Areas." Findings for which the SDP 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 identified a Green finding for the failure of NMPNS to meet the fleet standard for establishing and implementing preventive maintenance (PM) templates.

Specifically, in 2009, NMPNS failed to implement PM templates for critical non-safety related molded case circuit breakers in accordance with the guidance in the new fleet standard.

NMPNS entered this issue into their corrective action program as CR-2011-011 000 and CR 2011-011045 to evaluate corrective actions needed to address this issue.

The inspectors determined that the finding was more than minor because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, continued failure to perform the "clean and inspect" PM on critical NSR MCCBs could lead to a failure that could cause a plant transient. The inspectors determined that the finding was of very low safety significance (Green) since the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions will not be available. This finding had a cross-cutting aspect in the human performance area, work practices component, in that I\\JIVIPI\\IS did not implement procedures for conducing preventive maintenance on electrical breakers [H.4.(b)]. (Section 40A2)

Green.

A Green self-revealing NCV of technical specification (TS) 5.4.1, "Procedures," was identified for NMPNS' failure to properly implement S-MMP-GEN-201, "Site Valve Packing Procedure," Revision 00600 when maintenance personnel repacked recirculation pump discharge isolation valve 2RCS*MOV18A in AU~lust 2011. As a result, on December 9, 2011, the packing for valve 2RCS*MOV18A failed and unidentified reactor coolant system (RCS) leakage increased above the TS limit of a 2 gpm increase per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> forcing a plant shutdown. NMPNS' immediate corrective actions were to repair the valve stem and install a live loaded packing system on the recirculation discharge isolation valves.

This finding is more than minor because it reasonably could be viewed as a precursor to a more significant event and adversely impacted the Initiating Events Cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. This finding challenged ttle availability and reliability of a mechanical RCS pressure boundary. This finding was evaluated using IMC 0609,

"Significance Determination Process," Attachment 04, "PhasH 1-lnitial Screening and Characterization of Findings," Table 4a, and determined to require further evaluation because the as-found leakage exceeded a TS RCS leakage limit. Based on Region I Senior Reactor Analyst (SRA) review, the finding was determined to be of very low safety significance (Green) since the maximum possible leak rate t~lrough the valve packing would be compensated by normal operation of the control rod drive system and the condensate/feedwater system. This finding has a cross-cutting aspect in the area of human performance, work control because NMPNS did not define and effectively communicate expectations regarding procedural compliance and personnel did not follow procedures during their inspection of the valve stem [HA.(b)]. (Section 40A3)

Cornerstone: Barrier Integrity

Green.

The inspectors identified a Green findinu for the failure of NrvlPNS to follow the technical specifications (TS) bases associated with limiting condition for operation (LCO)3.0.2. Specifically on October 24, 2011, on three separate occasions, NMPNS entered TS 3.3.6.1 Condition B for operational convenience to conduct troubleshooting of a reactor water cleanup (RWCU) system differential flow high channel. The inspectors determined this action was contrary to the bases of TS LCO 3.0.2 which states, in part, intentional entry into actions should not be made for operational convenience and must not compromise safety. NMPNS immediate corrective actions included coaching the control room personnel involved in the troubleshooting process and entered the issue into the corrective action program as CR 2011-009767.

This finding is more than minor because it impacted the configuration control aspect of the Barrier Integrity Cornerstone and adversely affected the Cornerstone objective to maintain functionality of containment. Specifically, as part of a planned troubleshooting activity, a protective isolation feature was removed from service on multiple occasions that collectively exceeded the allowed LCO time for the system. The inspectors determined that the finding was of very low safety significance (Green) since the finding did not represent an actual open pathway in the physical integrity of the reactor containment. This finding has a cross cutting aspect in the area of human performancE3 in that NMPNS did not use conservative assumptions in decision making when performing multiple entries into TS [H.1.(b)]. (Section

'IR15)

Other Findings

None.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On October 29, reactor power was lowered to approximately 71 percent to conduct planned maintenance and surveillance activities including a rod sequence exchange. The reactor was returned to 100 percent power on October 30. On December 17, reactor power was rE~duced to 95 percent to remove the 15 recirculation pump from service for planned maintenance. Power was returned to 100 percent later that day and remained at 100 percent for the rE~mainder of the report period.

Unit 2 began the inspection period at 100 percent power. On November 19, reactor power was lowered to 65 percent to conduct a planned control rod sequencH exchange and to perform turbine valve testing. The reactor was returned to 100 percent power later the same day. On December 9, the reactor was shut down as required by technical speCifications (TSs) due to an increase in unidentified RCS leakage. On December 15, the reactor was taken critical and the turbine was synchronized to the grid on December 16. The plant was restored to 100 percent power on December 19. On December 28, reactor power was lowered to 97 percent due to main feedwater heater level control system problems. On December 29, following repairs, the reactor was returned to 100 percent power. The unit remained at 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Seasonal Extreme Weather Conditions (Two samples)

a. Inspection Scope

The inspectors performed a review of NMPNS' readiness for the onset of seasonal low temperatures for Units 1 and 2. The review focused on the Unit 1 intake structure and service water (SW) pump area, the Unit 1 diesel fire pump room, and the Unit 2 SW pump bays and Emergency Diesel Generator (EDG) rooms. The inspectors reviewed the updated final safety analysis report (UFSAR), TSs, control room logs, and the corrective action program (CAP) to determine what temperatures or other seasonal weather could challenge the systems, and to ensure NMPNS personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including NMPNS procedure NAI-PSH-11, "Seasonal Readiness Program," Revision 06. The inspectors verified completion of the operations department cold weather preparation checklists contained in procedures N1-0P-64 and N2-0P-102, "Meteorological Monitoring," Revisions 00500 and 01000. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

1

R04 Equipment Alignment

Partial Walkdown (71111.04Q - Three samples)a.

. Inspection Scope The inspectors performed partial walkdowns of the following systems:

• High pressure coolant injection subsystem 11 while the 13. feedwater booster pump was out of service for planned maintenance on October 3, 2011

• Technical support center ventilation system prior to pE3rformance of an emergency drill on October 12,2011

• Division I of the control room air conditioning system (CRACS) system when the Division II CRACS was out of service for planned maintenance on November 3, 2011 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TSs, work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify condi1ions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiE3ncies. The inspectors also reviewed whether NIVIPNS staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

1

R05 Fire Protection

Quarterly Inspection (71111.05Q - Five samples)

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that NMPNS controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

.1 *

Unit 1 turbine building (TB) east battery room 277 foot elevation (fire zone TB277-07)on October 27, 2011

• Unit 1 TB west battery room 277 foot elevation (fire zone TB277-08) on October 27, 2011

• Unit 1 control room complex, control room 277 foot elevation (fire zone CC277 -01 )

on October 28, 2011

• Unit 2 HPCS cable routing area 244 foot elevation (fir,e area 21) on November 8, 2011

• Unit 2 diesel fire pump room 261 foot elevation (fire area 62) on November 10, 2011

b. Findings

No findings were identified.

1R11 Licensed Operator Regualification Program

Quarterly Review of Licensed Operator Requalification Testing and Training (71111.11 Q

- Two samples)

a. Inspection Scope

The inspectors observed a Unit 1 licensed operator simulator training on October 18, 2011, which included failure of the mechanical hydraulic control system, a leak in the reactor water cleanup (RWCU) system, and a failure of a RWCU system isolation valve.

On October 25, 2011, the inspectors observed a licensed operator simulator graded examination for Unit 2. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

. 2 Annual Review (71111.11A - One Sample)

a. Inspection Scope

On December 21, 2011, an NRC region-based inspector conducted an in-office review of results of Nine Mile Point-administered annual Unit 1 operating tests and comprehensive written exams. The inspection assessed whether pass rates were consistent with the guidance of NRC Inspection Manual Chapter (lMC) 0609, Appendix I, and "Operator Requalification Human Performance Significance Determination Process (SDP)." The inspector verified that:

• Crew pass rates were greater than 80 percent (pass rate was 100 percent)

• Individual pass rates on the dynamic simulator test wore greater than 80 percent (pass rate was 100 percent)

• Individual pass rates on the job performance measures (JPMs) of the operating exam were greater than 80 percent (pass rate was 100 percent)

• More than 75 percent of the individuals passed all portions of the exam (100 percent of the individuals passed all portions of the examination)

Unit 1 comprehensive written exams were previously administered in November and December 2010.

b. Findings

No findings were identified.

. 3 Biennial Review (71111.11 B - One sample)

The following inspection activities were performed using I\\lUREG-1 021, "Operator Licensing Examination Standards for Power Reactors," R.evision 9, Supplement 1, Inspection Procedure Attachment 71111.11, "Licensed Operator Requalification Program," Appendix A, "Checklist for Evaluating Facility Testing Material" and Appendix B, "Suggested Interview Topics."

A review was conducted of recent operating history documentation found in inspection reports, licensee event reports (LERs), NMPNS' CAP, and the most recent NRC plant issues matrix. The inspectors also reviewed specific events from NMPNS' CAP which indicated possible training deficiencies, to ve-rify that they had been appropriately addressed. The resident staff was also consulted for insights regarding licensed operators' performance. These reviews did not detect any operational events that were indicative o*f possible training deficiencies.

The operating tests for the week of December 5, 2011, were reviewed for quality and performance.

On December 21, 2011, the results of the Unit 2 requalification exam for year 2011 were reviewed in office to determine if pass fail rates were consistent with the guidance of NUREG-1021, "Operator Licensing Examination Standards for Power Reactors,"

Revision 9, Supplement 1, and NRC Manual Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance Determination Process (SDP)."

• Crew pass rates were greater than 80 percent (pass rate was 85.7 percent)

• Individual pass rates on the dynamic simulator test wsre greater than 80 percent (pass rate was 91.8 percent)

• Individual pass rates on the written exam were greater than 80 percent (pass rate was 93.7 percent)

• Individual pass rates on the ~IPMs of the operating exam were greater than 80 percent (pass rate was 97.9 percent).

• More than 75 percent of the individuals passed all portions of the exam (85.4 percent of the individuals passed all portions of tile examination)

Observations were made of the dynamic simulator exams and JPMs administered during the week of December 5, 2011. These observations included facility evaluations of crew and individual performance during the dynamic simulator exams and individual performance of five JPMs.

The remediation plans for an individual's and one crew's 'failure were reviewed to assess the effectiveness of the remedial training.

Five license reactivation records were reviewed to ensure that 10 CFR Part 55.53 license conditions and applicable program requirements were met.

Operators, instructors, and training/operation's management were interviewed for feedback on their training program and the quality of training received.

Simulator performance and fidelity were reviewed for conformance to the reference plant control room.

A sample of records for requalification training attendance, program feedback, reporting, and medical examinations were reviewed for compliance with license conditions, including NRC regulations.

b. Findings

No findings were identified.

1 R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - Six samples)

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that NMPNS performed the appropriate risk assessments prior to removing equipment for work. 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 NMPNS personnel performed risk assessments as required by 10 CFR Part 50.65(a)(4) and that the assessments were accurate and complete. When NMPNS performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. ThE~ inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applica.ble requirements were met.

• Week of October 31,2011, WO C91695643, emergent work to backseat second stage reheater stop check valve CVK-08-30

• Week of November 1, 2011, planned maintenance on 115 kilovolt (kV) offsite power line 4,345 kV line 8 and the number 12 liquid poison pump which placed in the plant in an elevated (yellow) risk condition

• Week of November 2,2011, WO C91698942, emergemt work to repair 12 TB exhaust fan

• Week of December 19.2011. in which planned maintE~nance was conducted on the 12 condensate pump. condensate booster pump and containment spray loop 111 which placed in the plant in an elevated (yellow) risk condition

• November 7 and '8,2011, emergent work. to replace trip unit E31A-N619B which had failed isolating the reactor core isolation cooling (RCIC) and RWCU systems

• Week of December 19, 2011, in which planned maintenance was conducted on the Division 1 EDG that placed in the plant an elevated (yellow) risk condition

b. Findings

No findings were identified.

1 R15 Operability Determinations and Functionality Assessments (71111.15 - Seven samples)

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non conforming conditions:

• CR 2011-007548. concerning 10 CFR Part 21, "Failure to Include Seismic Input in Reactor Control Blade Customer Guidance," submitted by GE Hitachi on August 28, 2011

• CR 2011-010440, concerning degradation of a main steam isolation valve closure scram limit switch on November 21,2011

• CR 2011-009027. concerning cracking that was discovered on the cover of Division II battery cell 13 on October 7,2011

• CR 2011*009767, concerning the unexpected failure of a RWCU instrument channel on October 23, 2011

• CR 2011-010179, concerning the unexp!3cted trip of HVC*ACU2B during a post maintenance surveillance test (ST) that was performed on November 10, 2011

• CR 2011-008733, concerning water in 1:3 condensate pump upper motor bearing oil, on November 29,2011

• CR 2011-007525, concerning unexpected dryweilleakage detection alarm H2-4-7 on Unit 1. The condition was corrected on December 1, 2011 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to NMPNS 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 by NMPNS. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

Introduction.

The inspectors identified a Green finding for the failure of NMPNS to follow the TS bases associated with limiting condition for operation (LCO) 3.0.2. Specifically on October 24, 2011, NIVIPNS entered TS 3.3.6.1 Condition B on three occasions for operational convenience.

Description.

On October 23, 2011, at 0915, Unit 2 operators declared the Division I RWCU system differential flow high channel inoperable when it failed a periodic channel check. As a result of the failure, operators entered LCO Condition A for TS 3.3.6.1, "Primary Containment Isolation Instrumentation," which required placing the channel in trip within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. To investigate the failure, a troubleshooting plan was subsequently developed. While implementing the troubleshooting plan on October 24, 2011, on three separate occasions at 01 :52, 02:58 and 05:19, both Divisions I and II RWCU differential flow timers were placed in bypass and LCO Condition B for TS 3.3.6.1 was entered for one or more automatic functions with isolation capability not maintained. LCO Condition B for TS 3.3.6.1 allows both channels of an automatic isolation function to be inoperable for one hour. If this time limit is not met, LCO Condition F= of TS 3.3.6.1 is entered which requires the affected penetration to be isolated within one hour. In each of the three instances, one channel of the RWCU system differential flow high channels was returned to service within the one hour time limit allowed in LCO Condition B of TS 3.3.6.1. Both channels were bypassed for a total of 151 minutes. The troubleshooting did not identify the cause of the initial instrument failure, and as a result on October 24, 2011, at 0807, operators entered Condition F of TS 3.3.6.1 and isolated the RWeU system penetration that was affected by the failed instrument channel.

The RWCU system high flow channel isolation is designed to isolate the RWCU system in the event a flow imbalance occurs in the RWeU system which could indicate a RWeU system pipe leak has occurred. When reviewing this event, the inspectors were informed by NMPNS personnel that the short duration entries into and out of LCO Condition B for TS 3.3.6.1 while conducting troubleshootiing operations were accomplished to avoid having to remove the RWCU systlsm from service, which could adversely impact reactor coolant chemistry and increase radiation exposure to personnel.

TS 3.0.2 states, in part, that "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall bE, met.... " The bases of TS 3.0.2 states, "Entering ACTIONS must be.done in a manner that does not compromise safety.

Intentional entries into ACTIONS should not be done for operational convenience." The inspectors determined that the multiple entries into and out of LeO Condition B for TS 3.3.6.1 when troubleshooting the RWCU system high flow channel isolation were for operational convenience, and as such were not consistent with the bases of TS 3.0.2.

.1 The failure to properly implement TS 3.0.2 was documented in CR 2011-009767, "Bases

Behind TS 3.0.2 Was Not Correctly Applied During RWCU Priority One Issue." NMPNS' immediate corrective actions included coaching the control room personnel involved in the troubleshooting process. This issue has a cross-cutting aspect in the area of human performance in that NMPNS did not use conservative assumptions in decision making.

Analysis.

The performance deficiency associated with this finding is that contrary to the bases for TS LCO 3.0.2 on October 24, 2011, NMPNS performed multiple short duration entries into LCO Condition B of TS 3.3.6.1 for operational convenience. These multiple entries delayed removal of the RWCU system from service. This action is contrary to the bases of TS LCO 3.0.2 which states, "Entering ACTIONS must be done in a manner that does not compromise safety. Intentional entries into ACTIONS should not be done for operational convenience." NMPNS troubleshooting activities compromised safety since a protective isolation feature was removed from service on multiple occasions, as part of a planned troubleshooting activity that collectively exceeded the allowed LCO time for the system. This finding is more than minor because it impacted the configuration control aspect of the Barrier Integrity Cornerstone and adversely affected the Cornerstone objective to maintain functionality of containment. The inspectors determined that the finding was of very low safety significance (Green) through performance of a Phase 1 SOP in accordance with IMC 0609.04, Table 4a Characterization Worksheet for Initiating Events, Mitigating Systems and Barrier Integrity Cornerstones. Specifically, the finding did not represent an actual open pathway in the physical integrity of the reactor containment. This finding has a cross-cutting aspect in the area of human performance, decision making, in that NIVIPNS did not use conservative assumptions in decision making when performing multiple entries into TS 3.3.6.1 [H

.1. (b)].

Enforcement.

Enforcement action does not apply because this performance deficiency did not involve a violation of a regulatory requirement. Specifically the bases of TS 3.0.2 are not part Appendix A of the plant TS. This issue was entered into NMPNS CAP as CR-2011-009767. Because this finding does not involve a violation and has very low safety significance, it is identified as a finding. (FIN 050004'10/2011005-01, Troubleshooting Approach Not Consistent With Technical Specification Bases)1 R18 Plant Modifications (71111.1B)

Temporary Modifications (One sample)

a. Inspection Scope

The inspectors reviewed the temporary modification described in engineering change package ECP-OB-0033, "Revise High Operating or Alarm Limits from 135 degrees Fahrenheit (OF) to 160 of for Service Water Pump 'D' Bearing Temperature," to determine whether the modification affected the safety functions of systems that are important to safety. The inspectors reviewed 10 CFR 50.59 documentation and post modification testing results, and conducted field walkdowns of the modification to verify that the temporary modification did not degrade the design bases, licensing bases, and performance capability of the affected system.

b. Findings

No findings were identified.

. 2 Permanent Modifications (One sample)

a. Inspection Scope

The inspectors evaluated a modification to the Unit 2 reactor recirculation pump isolation valves implemented by engineering change package ECP-11-000982, "Install Live Loaded Packing on Unit 2 Recirculation Blocking Valves 2RCS*MOV18N18B and 2RCS*MOV10NB." The inspectors verified that the design bases, licensing bases, and performance capability of the affected valves were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the design change, including installation of the packing gland follower piece, and gland stud assembly and Belleville washers.

b. Findings

No findings were identified.

1 R19 Post-Maintenance Testing (71111.19 -- Eight samples)

a. Inspection Scope

The inspectors reviewed the post-maintenance tests (PMTs) for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedures to verify that the procedures adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria In the procedures were consistent with the information in the applicable licensing bases and/or design basis documents, and that the procedures had been properly reviewed and approved. The inspectors also witnessed the tests or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

• Unit 1 WO C91103878 to upgrade the capacity of the 11 liquid poison pump. The PMT was to verify expected flow rate using N1-ST-Q8A, "Liquid Poison Pump 11 and Check Valve Operability Test," Revision 00400, and to verify motor voltage and running current on October 26, 2011

• Unit 1 WO C91698942 to replace 12 TB exhaust fan drive motor MOT-203-06. The PMT was to verify correct rotation and acceptable vibration readings on November 4, 2011

• Unit 1 WO C91695610 to repair 11 TB exhaust fan FN-203-05. The PMT was to conduct vibration and noise checks at full fan speed using N1-MPM-GEN-558, "Reactor and Turbine Building Supply and Exhaust Fans," Revision 00701 on November 17,2011

• Unit 1 WO C91706330 to replace a 5 volt direct current power supply to the rod position indication system, The PMT was to energize the replacement power supply and verify output voltage was within vendor recommended values on November 19, 2011

• Unit 1 WO C91 031713 that disassembled and flushed the SW radiation monitor piping. The PMT was to leak test the SW piping that had been disassembled and verify the monitor was receiving adequate SW flow per N1-CTP-V203, "Service Water Radiation Monitor Flow Adjustment/Pump Switch/Air Purge/Pump Startup/Shutdown," Revision 02 on November 29, 201 1

• Unit 1 WOs C91389912 and C90921883 that performed aging management inspections of the 102 EDG cooling water heat exchangers and preventive maintenance (PM) of the raw water pump breaker. The PMT was to verify leak tightness and proper cooling system operation using N1-ST-M4A, "EDG 102 and PB 102 Operability Test," Revision 00500 on December 2, 2011

• Unit 2 WO C91704355, to replace reactor building spent fuel heat exchanger room

'B' air temperature switch. The PI\\IIT was to verify proper operation of the switch using N2-ISP-LDS-R108, "Reactor Building Pipe Chase Temperature Instrument Channel Calibration," Revision 01000 on November 10, 2011

• Unit 2 WO C91717796 that installed test equipment in the Division III EDG air start system. The PMT was to start and run the machine using N2-0SP-EGS-M@002, "Diesel Generator and Diesel Air Start Valve Operability Test - Division til," Revision 00900 on December 1, 2011

b. Findings

No findings were identified.

1 R20 Refueling and Other Outage Activities (71111.20 - One sample)

a. Inspection Scope

During the emergent December 2011 outage at Unit 2, the inspectors observed and/or reviewed the following activities to verify that operability requirements were met and that risk, industry experience, and previous site-specific problems were considered.

• Following the plant shutdown due to excessive RCS leakage, the inspectors toured drywell elevations 249 foot, 261 foot, and 306 foot to verify that components located in the general area of 2RCS*MOV18A were not damaged by water and steam that emanated from the packing on that valv~

• The inspectors attended several outage meetings where risk management activities were discussed. The inspectors also toured plant areas to verify risk management actions had been properly implemented

• The inspectors observed portions of the December 15, 2011, reactor plant startup and initial power ascension and plant heatup activities

• The inspectors observed NMPNS repair activities, and attended several outage meetings including a post scram plant operations review committee meeting

• The inspectors observed configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable TSs when taking equipment out of service

• The inspectors observed the status and configuration of electrical systems and switchyard activities to ensure that TSs were met

• The inspectors observed activities that could affect reactivity

b. Findings

No findings were identified.

1 R22 Surveillance Testing (71111.22 - One sample)

a. Inspection Scope

The inspectors observed performance of the following ST and/or reviewed test data of selected risk-significant structures, systems, and components to assess whether test results satisfied TSs, the UFSAR, and NMPNS procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, the test was performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following ST:

• N1-ST-W15, "Manual Scram Instrument Channel Test," Revision 00401 completed on November 21, 2011

b. Findings

No findings were identified.

OTHER ACTIVITIES

40A1 Performance Indicator Verification (71151 - Two samples) Safety System Functional Failures

a. Inspection Scope

The inspectors sampled NMPNS' submittals for the Safety System Functional Failures performance indicator for both Units 1 and 2 for the period of October 1, 2010, through September 30, 2011. To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, "Regula1tory Assessment Performance Indicator Guideline," Revision 6, and NUREG-1022, "Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." The inspectors reviewed NMPNS' operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, condition reports, event reports and NRC integrated inspl~ction reports to validate the accuracy of the submittals.

.1 b.*

Findings No findings were identified.

40A2 Problem Identification and Resolution (71152 - Three samples)

Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, "Problem Identification and Resolution," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that NMPNS entered issues into tile CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. 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 CAP.

b. Findings

No findings were identified.

. 2 Annual Samgle: Effectiveness of Corrective Actions for Unit 2, Historical Reactor Water Clean-up Pumps Seal Failures (One sample)

a. Inspection Scope

This inspection was conducted to assess the effectiveness of NMPNS' planned and implemented corrective actions to address historical Unit 2 RWCU pump seal failures.

Specifically, RWCU pump mechanical seal failures at Unit 2 have been occurring since original plant startup in 1987. Approximately twenty three seal failures have occurred, and some failures have been very premature; e.g. within a few days of seal repair or replacement (CR-1998-03286 and 2010-001649). Dose rates in the area are high and seal repairs cause significant radiation exposure to workers. RWCU pump mechanical seal failure is a known General Electric boiling water reactor (BWR) industry problem in the United States.

The Unit 2 RWCU system consists of two 50 percent (%) capacity pumps and four filters.

The system is designed to maintain high reactor water quality by removing corrosion products and impurities from the reactor. The system is also used to remove water to control reactor pressure vessel level during plant shutdown and startup evolutions while at low power levels. Portions of the RWCU system are part of the reactor coolant pressure boundary, and therefore perform a safety function to detect a break or leak in the RWCU system and to isolate the leak to prevent exceeding off5ite dose limits.

The inspectors reviewed the associated root cause and related assessments to determine the effectiveness of the corrective actions. The inspectors reviewed NMPNS' UFSAR, the applicable TS, the associated maintenance rule scope, system health reports, and Unit 2 RWCU pump Vendor Specification N2U05500PUMP004, to determine the design requirements and overall performance of the RWCU pumps, the mechanical seals, and associated components. The inspectors also interviewed engineers, plant operators, licensing and management personnel, and performed a visual video camera inspection of the pumps and seals. In addition, the inspectors reviewed ST procedures to ensure that testing was being performed in accordance with the current licensing basis.

b. Findings and Observations

No findings were identified.

A number of root cause analyses and evaluations have been performed due to RWCU pump seal failures. In 2010, NMPNS recognized that several minor system/pump design changes and various maintenance and system operating improvements have been implemented over the years without a significant improvement in the life of the mechanical seal. The corrective actions takEm to date have typically been symptom based and have not entirely addressed the causes of the seal failures. A Category I, root cause evaluation was performed by NMPNS under CR-2010-010023, to fully understand this long standing issue.

The inspectors noted the root cause analysis in CR-2010-010023 was detailed and adequately recognized the chronic problems with Unit 2 RWCU pump seal leakage. The inspectors verified that mechanical maintenance technicians have taken critical dimensional checks to verify critical clearances and pump condition. Also, independent vendors experienced in mechanical seal failure analysis were procured to help determine the cause of the seal failures and to develop recommendations and corrective actions to minimize recurrence. The engineering evaluation included historical reviews, interviews with maintenance, operations and engineering personnel, and vendor representatives. The evaluation included an extent of condition review which concluded that Unit 1 RWCU pumps do not experience similar mechanical seal problems primarily because they operate in milder conditions (lower suction temperature and suction pressure) than Unit 2 pumps. In addition, unlike the Unit 2 RWCU configuration, the Unit 1 RWCU pumps are located downstream of the filters which reduces the likelihood of small particles lodging between seal faces. The root cause was determined to be a less than adequate original design of the Unit 2, RWCU pumps and system configuration.

Contributing factors included; 1) inadequate management decision making; 2)inadequate procedures; and 3) inadequate maintenance practices. The evaluation determined that major plant modifications such as pump replacements or system pipe modifications had been necessary at almost all of the US BWR plants to resolve chronic RWCU pump seal failures.

Corrective actions performed at NMPNS thus far include the following:

• Replaced the 'A' RWCU pump with an improved design to achieve longer operation (greater than three years versus less than six months) without mechanical seal leakage

• Implemented operating and maintenance procedure improvements to enhance pump re-assembly, pump warm-up and system filling and venting

• Initiated a long term solution to replace the 'A" RWCU pump with a new 100%

capacity seal-less pump design to align with industry standards, and to achieve longer operating periods without repairs (target life of six years). This design will allow operation with one pump, using the second pump as an on-line spare The inspectors concluded that although RWCU pump seal leakage has resulted in increased radiation exposure to workers and chemistry control issues since original start-up in 1987, there were no performance deficiencies. This is because safety related components have not been directly impacted, and over the years a number of root cause analyses and evaluations have been performed and multiple corrective actions have been implemented. Specifically, the new seal and pump combination that has already been installed on the 'N RWCU pump (and planned, scheduled and budgeted for the 'B' RWCU pump) has improved reliability (life of the mechanical seals) in that failures have gone from less than every six months to approximately every three years. In addition, I\\JMPNS has a high priority, Category I CR and associated long term corrective actions to replace the seals on one of the two RWCU pumps with a new seal-less 100%

capacity pump which is expected to eliminate seal leakage and improve system reliability.

. 3 Semi-Annual Trend Review (One sample)

a. Inspection Scope

The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, "Problem Identification and Resolution," to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by NMPNS outside of the CAP, such as trend reports, Pis, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or corrective action program backlogs. The inspectors also reviewed NMPNS' CAP database for the third and portions of the fourth quarters of 2011 to assess condition reports written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 40A2.1). The inspectors reviewed NMPNS' quarterly trend report for the first quarter of 2011, conducted under CNG-CA-1.01-1 007, "Performance Improvement Program Trending and Analysis," to verify that NMPNS personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.

b. Findings and Observations

No findings were identified. No trends were noted by the inspectors that indicated a potential safety significant issue. The inspectors verified that NMPNS appropriately identified trends and captured them in the CAP, performance monitoring program, system health reports, and quality assurance assessments. Examples of trends identified by NMPNS were trends in the areelS of procedure use and adherence, and radiation monitor and control rod drive system performance.

Annual Sample: Unresolved Item (URI) 05000220. 05000410/2011008-01:

Inconsistencies Between Non-Safety Related Breaker Preventive Maintenance Templates and Station Practices (One sample)

.4 a.

Inspection Scope This URI was opened in inspection report 05000220/410/2011008 pending inspector determination if the difference between the PM templates and actual station practices was a performance deficiency and if this issue was more than minor. The characterization of this issue as a finding and its risk significance are discussed below.

This URI is closed.

b. Findings

Introduction.

The inspectors identified a Green Finding for NMPNS' failure to meet the Constellation fleet standard for establishing and implementing PM templates.

Specifically, in 2009, NMPNS failed to implement PM templates for non-safety related (NSR) molded case circuit breakers (MCCB) in accordance with the guidance in the new fleet standard.

Description.

In 2005. NMPNS transitioned to a new work management system and transferred existing PM templates into this system. In 2006. NMPNS undertook an effort to classify components as critical. significant. economic, or run-to-failure. At this time, PMs for NSR MCCBs were removed from the work schedule. to be re-added after the classification was completed. Later in 2006 through 2007, NMPNS conducted an analysis to reconcile existing PM templates with new fleet templates. For NSR MCCBs, this analysis concluded that the existing PM templates met the requirements in the fleet template. and no changes to the template were required. In 2008. NMPNS identified that the PM templates for NSR MCCBs had not been re-added to the work schedule.

NMPNS drafted PM change requests to re-establish these PMs; however. the change requests were never processed.

In 2009, fleet engineering standard CNG-FES-039. "Preventive Maintenance Template Development, Review, Analysis and Application," was issued. This standard required that, "All PM Tasks or maintenance strategies that are outlined in the PM template for a particular component shall be reviewed and applied in accordance with the PM template to the extent achievable. Where a PM template task or maintenance strategy is not appropriate for application, a technical deviation is required if the PM template is not applied as written." However. NMNPS did not perform PM template required maintenance on NSR MCCBs. and did not provide a technical deviation in the PM basis.

This standard also stated that "PM template deviations for critical components should be rarely applied and should only be reserved for severelhardship situations." for non conservative deviations. Contrary to this guidance, NMPNS did not meet this guidance for critical NSR MCCBs. The PM templates for NSR MCCBs required a "clean and inspect" PM to be performed on a 10 year frequency, but that activity was not performed on 35 critical NSR MCCBs on Unit 1 and 391 on Unit 2 (this activity was only performed on 123 critical MCCBs total). Failure of a critical NSR MCCB could result in issues such as a plant transient On June 25. 2011. there was a fire in a non-critical NSR MCCB. and NMNPS declared an Unusual Event. The apparent cause evaluation for this event identified failure to perform a "clean and inspect" PM as the cause of the fire. As a corrective action for this event, NMPNS evaluated the PM templates for NSR MCCBs to determine if "clean and inspect" PMs should be added to the PM templates. During this review, NMPNS determined that the "clean and inspect" PM should be implemented for all critical and some significant NSR MCCBs. However, NMPNS failed to identify that PM templates for NSR MCCBs were not implemented in accordance with the guidance in CNG-FES-039.

During investigation into this issue, NMPNS identified that when CNG-FES-039 was issued in 2009 it was not disseminated to all appropriate E:lngineering personnel, or implemented.

The inspectors determined that the finding has a cross-cutting aspect in the human performance area, work practices component, in that NMPNS did not implement procedures. NMPNS entered the failure to meet CNG-FES-039 into their corrective action program as CR-2011-011 000 and CR*2011-011 045 to evaluate corrective actions needed to ensure PM templates for NSR MCCBs are implemented in accordance with the guidance in the standard. NIVlPNS also intends to evaluate the extent of condition for PM templates on other components.

Analysis.

The inspectors determined that failure to ensure that PM templates for NSR MCCBs were implemented in accordance with fleet engineering standards was a

.

performance deficiency within NMPNS's ability to foresee and correct, and should have been prevented. The inspectors determined that the finding was more than minor because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, continued failure to perform the "clean and inspect" PM on critical NSR MCCBs could lead to a failure that could cause a plant transient. This was demonstrated by the internal operating experience at NMPNS and NRC Information Notice 2008-18, "Loss of a Safety-Related Motor Control Center Caused by a Bus Fault," that documented failures at other sites.

The inspectors evaluated the finding using IMC 0609.04, Phase 1 -Initial Screening and Characterization of Findings, Table 4a, "Characterization Worksheet for Initiating Events, Mitigating Systems and Barrier Integrity Cornerstones." The inspectors determined the finding to be of very low safety significance (Green) because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions will not be available. The inspectors determined that the finding has a cross-cutting aspect in the human performance area, work practices component, in that NMPNS did not implement procedures. Specifically, NMPNS failed to ensure that CNG-FES-039 was implemented after it was issued in 2009 [HA.(b)].

Enforcement.

This finding does not involve enforcement action because no regulatory requirement violation was identified. Because this findin~~ does not involve a violation and has very low safety significance, it is identified as a finding. (FIN 05000220, 05000410/2011005*02, Failure to Meet Fleet Standards for Preventive Maintenance Templates)40A3 Followup of Events and Notices of Enforcement Discretion (71153 - Three samples)

(Closed) Licensee Event Report 05000410/2011-002-00: Reactor Shutdown Due to Reactor Coolant System Unidentified Leakage Above Technical Specification Limits On August 6, 2011, NMPNS shut down Unit 2 after identifying that unidentified ReS leakage into the drywell had exceeded the TS limits. Following a drywell entry, the

.1 source of the leakage was found to be stem packing failure on recirculation pump

discharge isolation valve 2RCS*MOV18A. Other aspects of this event are discussed in Section 40A3.4 of NRC Integrated Inspection Report 05000220/2011004 and 05000410/2011004 in which no performance deficiencies were found. The inspectors did not identify any new issues during review of the LER. This LER is closed,

,2 (Closed) Licensee Event Report 05000410/2011-003-00: Reactor Shutdown Due to an Unisolatable Leak on a Feedwater Pump Minimum Flow Line On August 10, 2011, during power ascension from an outage, with the reactor at approximately 15 percent of rated thermal power, NMPNS identified a leak from a vent pipe connected to the 'A' feedwater pump minimum flow line, The leak resulted from fatigue failure of a socket weld. A self*revealing finding concerning this issue is discussed in Section 40A3.5 of NRC Integrated Inspection Report 05000220/2011-004 and 05000410/2011004. The inspectors did not identify any new issues during the review of the LER. This LER is closed.

. 3 Technical Specification-Required Shutdown Due To An Increase in Unidentified Reactor Coolant System Leakage

a. Inspection Scope

On December 9, 2011, at 10:46 a.m., NMPNS Unit 2 commenced a TS-required shutdown due to an increase in unidentified RCS (drywell) leakage of greater than two gallons per minute (gpm) within the previous 24-hour period, At 9:03 a.m, operators had identified and commenced monitoring of increasing dryweilleakage, Unidentified leakage reached a maximum of 3.7 gpm. In accordance with procedures, operators completed a controlled reactor shutdown and reached the hot shutdown condition at 11:17 p,m. The plant was taken to cold shutdown on December 10 at 6:13 p.m. Drywell leakage decreased as expected as RCS pressure decreased. Following a drywell entry, the cause of the rise in leakage was determined to be from the 'A' recirculation pump discharge isolation valve packing.

The inspectors responded to the control roorn and observed operators' responses to the event. Operators responded in accordance with the TSs and normal operating procedures. The inspectors verified that NMPNS appropriately characterized the event in accordance with its emergency plan procedures and notified the NRC and state government authorities in a timely manner.

The inspectors reviewed the circumstances surrounding the event. The inspectors monitored startup preparation activities and corrective actions through plant walkdowns, attendance at outage update meetings, discussions with plant personnel, and review of records.

b. Findings

Introduction, A Green self-revealing NCV of TS 5.4.1, "Procedures," was identified for NMPNS' failure to properly implement S-MMP-GEN-201, "Site Valve Packing Procedure," Revision 00600 when maintenance personnel repacked recirculation pump discharge isolation valve 2RCS*MOV18A in August 2011. As a result, on December 9, 2011, the packing for valve 2RCS*MOV18A failed and unidentified RCS leakage increased above the TS limit of a two gpm inGrease per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> forcing a plant shutdown.

Description.

Due to leakage identified in August 2011, the packing of valve 2RCS*MOV18A was removed and replaced. In accordance with Attachment 1 step 1.2.1 of procedure S-MMP-GEN-201, the stem and stuffing box were inspected for scratches, nicks, gouges, and pitting and documented in work order C91530786 as satisfactory for new packing installation. However, when the stem and stuffing box were inspected on December 9, 2011, following a plant shutdown, NMPNS identified scoring marks and a 10 mil burr on the valve stem. NMPNS determined that following the August 2011 valve repack, during valve stroking for packing consolidation, the burr scored the inner diameter of a carbon packing bushing and damaged the packing resulting in leakage that led to the December 2011 plant shutdown.

The failure to properly implement S-MMP-GEN-201 during the August 2011 valve repack activity was documented in CR 2011-0109091. NMPNS' immediate corrective actions were to repair the valve stem and install a live loaded packing system on valves 2RCS*MOV 18A and 2RCS*MOV18B. This finding has a cross-cutting aspect in the area of human performance, work control, because NMPINS did not define and effectively communicate expectations regarding procedural compliance and personnel did not follow procedures.

Analysis.

The failure to have properly performed a repacking of the recirculation pump discharge isolation valve in August 2011 is a performancl;l deficiency. Specifically, inadequate work practices led to damage of the valve stem and stuffing box that directly contributed to leakage from the valve packin;J on Decemt)er 9, 2011, that exceeded the TS limit of greater than a two gpm increase in less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This finding is more than minor because it reasonably could be viewed as a precursor to a more significant event and adversely impacted the Initiating Events Cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. This finding challenged the availability and reliability of a mechanical RCS pressure boundary.

This finding was evaluated using IMC 0609, "Significance Determination Process,"

04, "Phase 1-lnitial Screening and Characterization of Findings," Table 4a, and determined to require further evaluation because the as-found leakage exceeded a TS RCS leakage limit. A Region I Senior Reactor Analyst (SRA) conducted a qualitative risk assessment to characterize the potential increase in core damage frequency as a result of the identified RCS leakage rate and pathway. Based upon NMPNS' estimate of 4 gpm maximum leakage, this amount of ReS leakage is less than half the lower bounds of the "very small loss of coolant accidenUleak rate" cate~Jory (10 to 100 gpm ra nge).

Leak rates in the "very small" category are typically compensated for by routine operation of the control rod drive system anel significantly minimized by the high volume operation of the condensate/feedwater system. Accordingly, the increase in core damage frequency as a result of this identified RCS leak rate and pathway is inconsequential. This finding is of very low safety significance (Green). This finding has a cross-cutting aspect in the area of human performance, work control because NMPNS did not define and effectively communicate expectations regarding procedural compliance and personnel did not follow procedures during their inspection of the valve stem [H.4.(b)].

Enforcement.

TS 5.4.1 requires that written procedures shall be established, implemented, and maintained covering activities as recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Regulatory Guide 1.33, Appendix A, section 9 requires that maintenance that can affect the performance of safety-related equipment should be pre-planned and performed in accordance with written procedures appropriate to the circumstances. Step 1.2.1 of Attachment 1 of S-MMP-GEN-201, "Site Valve Packing Procedure," Revision 00600 requires inspection of a valve stem and packing stuffing box for scratches, nicks, gouges, and pitting. Contrary to the above, on August 9, 2011, NMPNS did not perform an inspection adequate to identify significant scoring and a burr on the stem of valve 2RCS*MOV18A. As a result, on December 9, 2011, the valve packing failed in service. NMPNS' immediate corrective actions were to repair the valve stem and install a live loaded packing system on valves 2RCS*MOV 18A and 2RCS*MOV18B. Because this finding is of very low safety significance and NMPNS has entered it into its CAP as CR-2011-010906, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000410/2011005*03, Failure to Follow Valve Packing Procedure)40A6 Meetings, Including Exit On January 13, 2012, the inspectors presented the inspection results to Mr. Kenneth Langdon, Site Vice President, and other members of the NMPNS staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

AITACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

NMPNS Personnel

K. Langdon, Vice President

M. Philippon, Plant General Manager

P. Bartolini, Supervisor, Design Engineering

J. Dean, Supervisor, Quality Assurance

R. Dean, Training lVIanager

S. Dhar, Design Engineering

K. Dellinger, Component Engineering

J. Dosa, Director, Licensing

T. Fioenza, General Supervisor Program Engineering

J. Holton, Supervisor, Systems Engineering

G. Inch, Principle Engineer, EPU Project Manager

J. Kaminski, Director, Emergency Preparedness

M. Kunzwiler, Security Supervisor and Fatigue Rule Program Coordinator

J. Leonard, Supervisor Design Engineering

C. McClay, Senior Engineer

F. Payne, Manager, Operations

J. Reid, Design Engineer

M. Shanbhag, Licensing Engineer

P. Swift, Engineering Manager

T. Syrell, Manager, Nuclear Safety and Security

J. Thompson, Unit 2 General Supervisor Operations

LIST OF ITEMS OPENED, CLOSED, DISCUSSED AND UPDATED

Opened

None

Opened and Closed

05000410/2011005-01 FIN Troubleshooting Approach Not Consistent With Technical Specification Bases

05000220,

05000410/2011005

FIN Failure to Meet Fleet Standards for Preventive Maintenance Templates

05000410/2011005-03 NCV Failure to Follow Valve Packing Procedure

Closed

05000410/2011002-00 LER Reactor Shutdown Due to Reactor Coolant System Unidentified Leakage Above Technical Specification Limits

05000410/2011003-00 LER Reactor Shutdown Due to an Unisolatable Leak on a Feedwater Pump Minimum Flow Line

05000220,

05000410/2011008-01

Discussed

URI I nconsistencies Between Non-

Safety Related Breaker Preventive Maintenance Templates and Station Practices None