IR 05000220/2012004

IR 05000220-12-004, 05000410-12-004; 07/01/2012 - 09/30/2012; Nine Mile Point Nuclear Station, Units 1 and 2, Maintenance Effectiveness, Plant Modifications and Radiation Safety

ML12314A401
Person / Time
Site:	Nine Mile Point
Issue date:	11/09/2012
From:	Glenn Dentel Reactor Projects Branch 1
To:	Langdon K Nine Mile Point
DENTEL, GT
References
IR-12-004
Download: ML12314A401 (60)

Text

UNITED STATES ovember 9, 2012

SUBJECT:

NINE MILE POINT NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000220/2012004 AND 05000410/2012004

Dear Mr. Langdon:

On September 30, 2012, 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 October 12, 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 Commissions 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 four findings of very low safety significance (Green). The findings were determined not to involve violations of NRC requirements. If you contest any findings 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, ATTN.: 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, 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 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 NRCs document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

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 05000220/2012004 and 05000410/2012004 w/Attachment: Supplementary Information

REGION I==

Docket Nos.: 50-220, 50-410 License Nos.: DPR-63, NPF-69 Report No.: 05000220/2012004 and 05000410/2012004 Licensee: Nine Mile Point Nuclear Station, LLC (NMPNS)

Facility: Nine Mile Point, Units 1 and 2 Location: Oswego, NY Dates: July 1 through September 30, 2012 Inspectors: K. Kolaczyk, Senior Resident Inspector D. Dempsey, Resident Inspector E. Miller, Resident Inspector L. Scholl, Senior Reactor Inspector C. Crisden, Emergency Preparedness Specialist B. Dionne, Health Physicist B. Haagensen, Resident Inspector J. Krafty, Resident Inspector T. OHara, Reactor Engineer Approved By: Glenn T. Dentel, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000220/2012004, 05000410/2012004; 07/01/2012 - 09/30/2012; Nine Mile Point Nuclear

Station, Units 1 and 2, Maintenance Effectiveness, Plant Modifications and Radiation Safety.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified four Green findings. 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 the 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.

A self-revealing Green finding (FIN) was identified for NMPNS failure to adequately implement the monitoring activities specified in the operation decision making issues (ODMI)plan for the Unit 1 electronic pressure regulator (EPR) in accordance with procedure CNG-OP-1.01-1001, Operational Decision Making. As a result, when the EPR system began to degrade on June 21, 2012, this condition was not identified by station personnel and corrective action (CA) was not implemented. The EPR subsequently malfunctioned while in service, causing a July 17, 2012, reactor scram. NMPNS removed the EPR from service and entered the issue into its corrective action program as CR-2012-006792.

This finding is more than minor because it adversely affected the human performance attribute of the Initiating Events Cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. The inspectors evaluated the finding using Attachment 0609.04, Initial Characterization of Findings, in Inspection Manual Chapter (IMC) 0609,

Significance Determination Process. The finding was determined to be of low safety significance (Green) because while it caused a reactor scram, it did not result in the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The finding has a cross-cutting aspect in the area of human performance, work practices, because NMPNS did not ensure proper supervisory and management oversight of the ODMI implementation plan. H.4(c) (Section 1R12)

Green.

A self-revealing Green finding (FIN) was identified for NMPNS failure to properly evaluate and implement plant design changes on the Unit 2 turbine gland seal steam supply system. Specifically, incorrect implementation of ECP-11-000977, Turbine Gland Seal and Exhaust System Instrument Changes, in May 2012 caused a reactor scram on July 13, 2012, following a return to full power operations from refueling outage N2RF13. NMPNS immediate corrective actions (CAs) included implementing ECP-12-000629 to revise the initiation setpoints for the emergency seal steam (ESS) system to accommodate higher gland seal operating pressures and properly gagging 2TME-RV135. NMPNS entered this issue into its corrective action program as CR 2012-006615.

This finding is more than minor because it is similar to examples 5.a, 5.b and 5.c of IMC 0612 Appendix E, Examples of Minor Issues. In each example, plant modifications were installed and the system was returned to service without identifying and correcting a problem with the design change. This finding also adversely affects the design control attribute of the Initiating Events Cornerstone and affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors evaluated the finding using Attachment 0609.04, Initial Characterization of Findings, in Inspection Manual Chapter (IMC) 0609, Significance Determination Process. The finding was determined to be of low safety significance (Green) because while it did cause a reactor scram, it did not result in the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The finding has a cross-cutting aspect in the area of human performance in that NMPNS did not ensure that personnel and procedures were available and adequate to assure nuclear safety. Specifically, the procedures that were necessary to implement ECP-11-000977, by gagging relief valve 2TME-RV135, were not adequate to ensure proper installation of the gagging device. H.2(c) (Section 1R18)

Green.

A self-revealing Green finding (FIN) was identified for NMPNS failure to provide adequate instructions for the installation of a control rod blade storage rack in the Unit 1 spent fuel pool. Specifically, certain critical steps were missing from the installation instructions and as a result, the rack was not properly installed, causing it to shift. The rack could have dropped, potentially resulting in damage to the spent fuel bundles stored beneath the rack. NMPNS immediate CAs were to halt further control rod blade moves and install temporary slings to hold up the rack. The rack was then re-leveled and the jacking pad was welded to the spent fuel pool curb. NMPNS entered this issue into its corrective action program as CR 2012-006547.

This finding is more than minor because it would have the potential to lead to a more significant safety concern; e.g. spent fuel bundle damage and a radiological release. The inspectors evaluated the finding using Attachment 0609.04 of Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Exhibit 3, Barrier Integrity Screening Questions, pertaining to spent fuel pools and determined this finding to be of very low safety significance (Green), because the finding did not adversely affect decay heat removal capabilities or pool water inventory, and did not result from fuel handling errors, dropped fuel assembly, dropped storage cask, or crane operations over the spent fuel pool that caused mechanical damage to fuel clad and a detectible release of radionuclides. The finding has a cross-cutting aspect in the area of work practices because NMPNS did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported. Specifically, NMPNS supervision did not ensure that critical assumptions contained in the control rod storage rack design analysis concerning the configuration of the Unit 1 spent fuel pool curb were translated into the installation instructions, and differences between Units 1 and 2 curbs noted during the installation were captured or evaluated by engineering, work control, or the CA process. H.4(c) (Section 1R18)

Cornerstone: Public Radiation Safety and Occupational Radiation Safety

Green.

A self-revealing Green finding (FIN) was identified due to NMPNS having unplanned, unintended occupational collective dose resulting from deficiencies in As Low As Reasonably Achievable (ALARA) planning and work control while performing refueling activities at Unit 2. Specifically, inadequate work planning and control of refueling activities resulted in unplanned, unintended collective exposure that was greater than 50 percent above the intended collective exposure, and greater than five person-rem due to conditions that were reasonably within NMPNSs ability to foresee and correct. These factors resulted in the collective exposure for refueling activities increasing from the original estimate of 31 person-rem to an actual dose of 56 person-rem. NMPNS entered this issue into its corrective action program as CR 2012-005939.

This finding is more than minor because it was associated with the program and process attribute of the Occupational Radiation Safety cornerstone, and affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine reactor operation. This performance deficiency is similar to example 6.i of IMC 0612, Appendix E Examples of Minor Issues in that the actual collective dose exceeded 5 person-rem and exceeded the planned, intended dose by more than 50 percent. The inspectors evaluated the finding using Attachment 0609.04, Initial Characterization of Findings, of Inspection Manual Chapter (IMC) 0609,

Significance Determination Process. The finding was determined to be of very low safety significance (Green) because NMPNS's current three year rolling average collective dose (143 person-rem/reactor year for 2009 to 2011) is less than the criterion of 240 person-rem per boiling water reactor unit. The finding has a cross-cutting aspect in the area of human performance, work control, in that the job site conditions which impacted human performance were not adequately incorporated into the outage plan. Specifically, the ALARA planning and work controls for refueling activities did not avert a significant unplanned and unintended collective occupational dose H.3(a) (Section 2RS2)

Other Findings

None.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On July 17, 2012, the reactor automatically scrammed on high neutron flux due to a pressure transient related to the electronic pressure regulator (EPR). The reactor was restarted on July 20, the main generator was synchronized to the grid, and 100 percent power was achieved on July 21. On September 20, the reactor automatically scrammed when the main turbine tripped due to generator under excitation. The reactor was restarted on September 23, and the turbine was synchronized to the grid on September 24. Full reactor power was reached on September 26. The unit remained at or near 100 percent power for the remainder of the inspection period.

Unit 2 began the inspection period at 91 percent power in the extended power uprate (EPU)power ascension test plan period of plant operation. On July 12, 2012, the reactor was scrammed from 85 percent power due to high offgas system inlet pressure and degrading condenser vacuum. On July 14, the reactor was restarted and the turbine was synchronized to the grid on July 16. Later on July 16, the moisture separator reheaters (MSRs) isolated on high drain tank level. On July 17, reactor power was reduced from 80 percent to 65 percent to recover the MSRs and to perform a rod pattern adjustment. Power ascension in accordance with the EPU test plan was resumed and 100 percent rated power was achieved on July 21. On August 11, reactor power was reduced to 65 percent to change reactor feedwater pumps.

Reactor power was restored to 100 percent later that day and the unit operated at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

Partial System Walkdown (71111.04Q - Four samples)

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

Unit 1 control room emergency ventilation system on July 24, 2012 Unit 1 reactor building (RB) emergency ventilation system (both trains) while the 12 RB exhaust fan was out-of-service on August 28, 2012 Unit 2 high pressure core spray (HPCS) system on August 15, 2012 Unit 2 reactor core isolation cooling system on August 17, 2012 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 updated final safety analysis report (UFSAR), technical specifications (TSs), work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions 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 deficiencies. The inspectors also reviewed whether NMPNS staff had properly identified equipment issues and entered them into the corrective action program (CAP)for resolution with the appropriate significance characterization. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Resident Inspector Quarterly Walkdowns (71111.05Q - Six 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.

Unit 1 diesel generator 102 room, 261 foot elevation (fire area 20) on August 6, 2012 Unit 1 diesel generator 103 room, 261 foot elevation (fire area 22) on August 6, 2012 Unit 1 power board 102 room, 261 foot elevation (fire area 23) on August 6, 2012 Unit 1 power board 103 room, 261 foot elevation (fire area 19) on August 6, 2012 Unit 2 Division I diesel generator room, 261 foot elevation (fire area 28) on August 7, 2012 Unit 2 Division I diesel generator room, 261 foot elevation (fire area 29) on August 7, 2012

b. Findings

No findings were identified.

.2 Fire Protection - Drill Observation (71111.05A - One sample)

a. Inspection Scope

The inspectors observed a fire brigade drill scenario conducted on August 21, 2012, that involved a fire in the Unit 2 turbine building (TB) 277 foot elevation normal switchgear room west. The inspectors evaluated the readiness of the plant fire brigade to fight fires.

The inspectors verified that NMPNS personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate CAs as required. The inspectors evaluated specific attributes as follows:

Proper wearing of turnout gear and self-contained breathing apparatus Proper use and layout of fire hoses Employment of appropriate fire-fighting techniques Sufficient fire-fighting equipment brought to the scene Effectiveness of command and control Smoke removal operations Utilization of pre-planned strategies Adherence to the pre-planned drill scenario Drill objectives met The inspectors also evaluated the fire brigades actions to determine whether these actions were in accordance with NMPNS fire-fighting strategies.

b. Findings

No findings were identified.

1R06 Flood Protection Measures (71111.06 - Two samples)

.1 Internal Flooding Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if NMPNS identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors focused on the Unit 2 service water bays to verify the adequacy of equipment seals located below the flood line, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.

b. Findings

No findings were identified.

.2 Annual Review of Cables Located in Underground Bunkers/Manholes

a. Inspection Scope

The inspectors conducted an inspection of underground bunkers/manholes (MHs)subject to flooding that contain cables whose failure could disable risk-significant equipment. The inspectors performed walkdowns of risk-significant areas, including man-holes MH-1 and MH-3 containing power cables for the HPCS system, to verify that cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program (71111.11 - Four samples)

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed Unit 1 licensed operator simulator training on August 7, 2012, which included a loss of reactor vessel level indication, a leak in the instrument air system, loss of offsite power and a failure of a diesel generator to start. The inspectors observed Unit 2 licensed operator simulator training on August 7, 2012, which included a loss of offsite power and failure of emergency core cooling systems. 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 (EOPs). 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 classifications made by the shift manager and the TS action statements entered by the shift technical advisor.

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 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed operations during planned breaker maintenance on the 12 RB emergency ventilation system and scaffold construction around main control room panels at Unit 1 on September 6, and planned surveillance tests of the main generator and standby liquid control system at Unit 2 on September 23, 2012. The inspectors reviewed CNG-OP-1.01-1000, Conduct of Operations Revision 00800 and verified that procedure use, crew communications, and coordination of plant activities among work groups similarly met established expectations and standards.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness (71111.12 - Four samples)

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule basis documents to ensure that NMPNS was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR Part 50.65 and verified that the (a)(2) performance criteria established by NMPNS staff was reasonable.

As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and CAs to return these SSCs to (a)(2). Additionally, the inspectors ensured that NMPNS staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

Unit 1 EPR on July 17, 2012 Unit 1 emergency diesel generator (EDG) lube oil pump on August 6, 2012 Unit 2 RB ventilation on August 7, 2012 Unit 2 screen house cooling on August 9, 2012

b. Findings

Introduction.

A self-revealing Green finding (FIN) was identified for NMPNS failure to adequately implement the monitoring activities specified in the operational decision making issues (ODMI) plan for the Unit 1 electronic pressure regulator (EPR) in accordance with procedure CNG-OP-1.01-1001, Operational Decision Making, Revision 00500. As a result, when the EPR system began to degrade on June 21, 2012, this condition was not identified by station personnel and CA was not implemented. The EPR subsequently malfunctioned while in service, causing a July 17, 2012, reactor scram.

Description.

The EPR is part of a control system that regulates reactor pressure by controlling the movement of the turbine control valves. The control system also includes the mechanical pressure regulator (MPR), which is normally a backup to the EPR. The MPR is designed, in part, to take control of the turbine control valves should the EPR fail and thereby minimize the potential for a reactor plant transient.

The EPR started exhibiting problems a year before the July 17, 2012, reactor scram. On June 30, 2011, the EPR failed, resulting in a half scram and rod block. A failed capacitor was replaced, and the EPR was returned to service on August 2, 2011. On December 6, 2011, the EPR momentary failed, which resulted in a reactor pressure increase, neutron flux spike, and a 5 to 6 percent increase in reactor power. In response to that event, NMPNS placed the MPR into service and commenced troubleshooting the EPR.

Although the cause could not be repeated, NMPNS determined the most probable cause for the transient was a bound precision control valve (part of the EPR control system)due to foreign material. This valve was replaced and NMPNS personnel commenced monitoring the EPR using the data acquisition system (DAS) while the MPR was in service. While monitoring the EPR, an engineering review of DAS data identified that differential transformer DT-1 output was drifting. The power supply for DT-1 was replaced and the drifting stopped. Additionally, the EPR and MPR servo indications were adjusted within eight percent of each other to minimize the scram potential when the EPR was placed in service.

The EPR was placed into service on February 15, 2012, and performance was monitored as required by an ODMI. On February 24, 2012, the EPR was removed from service due to potential performance issues identified during a plant startup from a forced outage. On February 25, 2012, the signal from DT-1 changed unexpectedly. The next day, the EPR servo indicator jumped over 10 percent twice and was turned off. The demodulator card for DT-1 was replaced.

The February ODMI was revised on April 10, 2012. The ODMI stated that a definitive cause for the EPR malfunction had not been identified. The ODMI implementation plan required maintaining the MPR servo indication within 8-10 percent of the EPR servo indication and the EPR/MPR paddle gap to be between 1/8 and 1/4'. Following a fleet challenge board held on June 20, 2012, the EPR was reenergized.

On June 21, 2012, DT-1 output spiked. However, this condition was not noticed.

Between June 21 and June 26, 2012, there was no evidence that the EPR monitoring data was reviewed by NMPNS engineering personnel. The EPR was placed back in service on June 26, 2012. The same day, the alert criteria for the paddle gap and the MPR to EPR servo position difference was exceeded. The paddle gap was adjusted to the desired range, and the next day, CR 2012-006227 was written by operations department personnel to document that the servo position difference was out of the desired band. The CR disposition indicated the out of specification condition was not a functionality concern and the issue was classified as a low priority 4 item, which could be further investigated during a future quarterly system schedule maintenance period.

From June 27 through July 5, 2012, although the MPR to EPR servo position was outside of the range established in the ODMI, no additional CRs were initiated to document this discrepancy and this condition was not communicated to engineering personnel for evaluation.

On July 17, 2012, DT-1 failed causing the turbine control valves to close by 11.5 percent. In part because the MPR to EPR servo position was outside of the range established in the ODMI, a reactor pressure spike occurred, resulting in a reactor scram on high neutron flux.

NMPNS immediate CAs included removing the EPR from service and using the MPR to control reactor pressure when the plant was restarted following the scram. Additional CAs are outlined in CR 2012-006792.

Analysis.

The inspectors determined that NMPNS failure to adequately implement the EPR ODMI monitoring plan, as required by procedure CNG-OP-1.01-1001, Operational Decision Making, is a performance deficiency that was within NMPNS ability to foresee and correct and should have been prevented. Specifically, contrary to CNG-OP-1.01-1001, NMPNS did not review the monitored data between June 21 and June 26, 2012, as required by the ODMI and therefore missed an opportunity to identify the malfunctioning EPR as evidenced by the DT-1 spike. As a result, the EPR was placed in service on June 26, 2012, and subsequently failed on July 17, 2012, causing a reactor scram. This finding is more than minor because it adversely affected the human performance attribute of the Initiating Events Cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. The inspectors evaluated the finding using Attachment 0609.04, Initial Characterization of Findings, in IMC 0609, Significance Determination Process. The finding was determined to be of low safety significance (Green) because while it caused a reactor scram, it did not result in the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The inspectors determined that this finding had a cross-cutting aspect in the area of human performance, work practices, because NMPNS did not ensure proper supervisory and management oversight of the ODMI implementation plan. H.4(c)

Enforcement.

Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory requirement. Specifically, the primary components involved in this event, the EPR and MPR, are not safety related. As such, the applicable maintenance and surveillance procedures are not governed by the requirements of Unit 1 TS 6.4 Procedures. This issue was entered into the NMPNS CAP as CR 2012-006792. Because this finding does not involve a violation of regulatory requirements and has very low safety significance, it is identified as a finding. (FIN 05000220/2012004-01, Inadequate Implementation of ODMI Monitoring Plan for EPR Results in Reactor Scram)

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - Five 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 Title 10 of the Code of Federal Regulations (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 stations 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 applicable requirements were met.

Unit 1 planned work activities on control rod drive pump 12 and the area cooler for the electric feedwater pumps on July 9, 2012 Unit 1 planned maintenance on the power supply to offsite power line 4 by the local electrical distribution operator on July 13, 2012 Unit 1 unplanned replacement of 11 liquid poison train relief valve PSV-42-37 on September 18, 2012 Unit 2 planned preventive maintenance on the Division I EDG on September 18 through 22, 2012 Unit 2 unplanned maintenance on the diesel driven fire pump battery during the week of September 24, 2012

b. Findings

No findings were identified.

1R15 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:

Unit 1, concerning the failure to install safety-related charcoal filter in the RB emergency ventilation system on May 30, 2012 Unit 1, concerning the impact of removal of boraflex coupons from the spent fuel pool for over a year and their ability to represent the condition of the remaining boraflex racks on August 31, 2012 Unit 1, high channel control rod friction on control rods 02-31 and 26-51 on September 22, 2012 Unit 2, concerning a failed load test of the Division III station battery on July 26, 2012 Unit 2, concerning high thrust bearing temperature on reactor feedwater pump A on August 21, 2012 Unit 2, concerning a steam leak from reactor water cleanup system check valve 2WCS-V47 in the main steam tunnel on August 31, 2012 Unit 2, concerning failure to adequately test all contacts associated with reactor protection system relay K14J-2RPSA01 on September 20, 2012 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

No findings were identified.

1R18 Plant Modifications (71111.18 - Four samples)

Permanent Modifications

a. Inspection Scope

The inspectors evaluated the permanent modifications listed below. The inspectors verified that the design bases, licensing bases, and performance capabilities of the affected systems were not degraded by the modifications. In addition, the inspectors reviewed modification documents associated with the upgrades and design changes.

The inspectors also reviewed revisions to the operating and control room alarm response procedures and interviewed engineering and operations personnel to ensure the procedures could be reasonably performed.

DCR N2-01-164 - Revise setpoint of 2TME-PC122 ECP 11-000727 - Install manhole MH-1 & MH-3 sump pumps ECP 11-000730 - Design and install alternate control rod blade racks ECP 11-000977 - Turbine gland seal and exhaust system instrument changes

.1 Inadequate Evaluation and Implementation of Design Modifications to the Turbine Gland

Seal Supply System

Introduction.

A self-revealing Green finding (FIN) was identified for NMPNS failure to properly evaluate and implement plant design changes on the Unit 2 turbine gland seal steam supply system. Specifically, incorrect implementation of ECP-11-000977, Turbine Gland Seal and Exhaust System Instrument Changes, in May 2012 caused a reactor scram on July 13, 2012, following a return to full power operations from refueling outage N2RF13.

Description.

On July 13, 2012, Unit 2 was manually scrammed from 85 percent power because of a loss of condenser vacuum caused by excessive air leakage through the turbine gland seals. The loss of adequate turbine gland seal steam pressure caused increased air flow into the main condenser. This event occurred because NMPNS did not adequately control the consequences of two design changes made to the gland seal system in 2008 and 2012.

In 2008, NMPNS implemented design change DCP N2-01-164 Modify Controls for 2TME-PV122, in preparation for the EPU in 2012. The design change modified the pressure control system for the emergency seal steam (ESS) system and reduced the ESS supply header automatic initiation pressure from 4.0 to 2.8 psig. At the time, the design change team recognized that the reduction in ESS pressure could potentially cause insufficient gland seal steam supply if the normal gland seal steam pressure was elevated to counteract condenser air leakage. However, the design change package concluded that operator action could be taken should this backup system initiate with condenser in-leakage unusually high. The design change team also recommended changing the off-normal procedure N2-OP-25, Auxiliary Steam and Auxiliary Condensate and Gland Seal section H.3.0 to provide direction for increasing the ESS initiation pressure in the event gland seal supply pressure increased as high as 7.5 psig. This recommendation was not adopted. NMPNS procedure NIP-CON-01, Design and Configuration Control Process, Revision 02302 requires a critical characteristics assessment of the design change. NMPNS concluded that the emergency steam seal supply system would initiate when required and provide sufficient steam sealing flow (45,000 pounds per hour) with margin. Contrary to the requirements of NIP-CON-01, the design change did not provide adequate controls to ensure sufficient ESS pressure and flow during a loss of the clean reboilers if gland seal pressure had been elevated to 6.5 psig. Reliance on operator action to increase ESS pressure could not be completed in time to prevent a reactor scram.

The loss of the clean reboiler steam supply was triggered by inadequate implementation of design change ECP-11-000977. In May 2012, NMPNS did not adequately translate directions from the design change package into detailed work instructions in the field under WO C91758555 to gag relief valve 2TME-RV135. The increased gland seal steam supply pressure challenged the lift set point for 2TME-RV135, which was providing over pressure protection for a steam supply line that was no longer in service.

Maintenance personnel used a lock nut to secure the gagging device, but the work package directions did not specify how the lock nut was to be installed. The workers installed the lock nut such that it physically interfered with the gagging device by causing an offset between the end of the gagging device and the relief valve actuator spindle.

Maintenance relied on the skill of the trade to install the relief valve gagging device and lock nut, which proved to be inadequate. This offset allowed the relief valve to chatter and partially lift when gland seal supply pressure was increased, starving the condensate supply and resulting in a trip of the clean reboiler. Furthermore, NMPNS did not conduct an adequate post-maintenance test (PMT) to verify that the gagging device on relief valve 2TME-RV135 had been properly installed and the valve was not leaking by. The post scram evaluation indicated that 2TME-RV135 had begun to leak by on July 4, 2012, and finally lifted on July 12, 2012. NMPNS also did not require additional verification or hold point inspection to ensure the gagging device installation was proper.

NMPNS relied entirely on the workers skill to install the gagging device correctly without verification of success. NIP-CON-01 requires the specification of the scope of post-modification testing to adequately address failure mechanisms. This includes validation of performance claims through testing and demonstration. Contrary to this requirement, NMPNS did not verify that the relief gagging device had been properly installed and was effective.

NMPNS immediate CAs included implementing ECP-12-000629 to revise the initiation setpoints for the ESS system to accommodate higher gland seal operating pressures and properly gagging 2TME-RV135. Additional CAs are outlined in CR 2012-006615.

Analysis.

The inspectors determined that NMPNS failure to adequately evaluate and implement these design changes as required by NIP-CON-01, Design and Configuration Control Process, was a performance deficiency that was reasonably within NMPNS ability to foresee and should have been prevented. This finding is more than minor because it is similar to example 5.b of IMC 0612 Appendix E, Examples of Minor Issues. In this example, a plant modification was installed and the system was returned to service without identifying and correcting a problem with the design change.

Specifically, the inadequate implementation of ECP-11-000977 to gag relief valve 2TME-RV135 led to an unintended loss of gland seal steam. An earlier modification, N2-01-164:

(1) did not assess the operational impact of the reduction of ESS gland seal steam pressure;

(2) did not specify a maximum differential pressure between the normal gland seal steam supply from the reboilers and the ESS auto-initiation pressure, and

(3) did not provide an adequate post modification test of the system at reduced initiation pressure. This combination of design change errors caused the July 13, 2012, reactor scram. This finding also adversely affects the design control attribute of the Initiating Events Cornerstone and affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. In this case, the failure to properly gag relief valve 2TME-RV135 triggered the loss of the normal gland seal steam supply, while the latent failure to evaluate the effect of raising gland seal steam pressure on the auto-initiation pressure of the backup steam supply caused a reactor scram. The inspectors evaluated the finding using Attachment 0609.04, Initial Characterization of Findings, in IMC 0609, Significance Determination Process. The finding was determined to be of low safety significance (Green) because while it caused a reactor scram, it did not result in the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding has a cross-cutting aspect in the area of human performance in that NMPNS did not ensure that personnel and procedures were available and adequate to assure nuclear safety. Specifically, the procedures that were necessary to implement ECP-11-000977, by gagging relief valve 2TME-RV135, were not adequate to ensure proper installation of the gagging device. H.2(c)

Enforcement.

Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory requirement. Specifically, the primary components involved in this event, the ESS system and clean steam reboilers, are not safety related. As such, the applicable maintenance and surveillance procedures are not governed by the requirements of Unit 2 TS 5.4. Procedures or the design control requirements of 10 CFR Part 50, Appendix B. This issue was entered into NMPNS CAP as CR 2012-006615. Because this finding does not involve a violation of regulatory requirements and has very low safety significance, it is identified as a finding. (FIN 05000410/2012004-02, Inadequate Evaluation and Implementation of Design Modifications to the Turbine Gland Seal Supply System)

.2 Inadequate Installation Instructions for Control Rod Blade Storage Rack

Introduction.

A self-revealing Green finding (FIN) was identified for NMPNS failure to provide adequate instructions for the installation of a control rod blade storage rack in the Unit 1 spent fuel pool. Specifically, certain critical steps were missing from the installation instructions and as a result, the rack was not properly installed, which caused it to shift. The rack could have dropped, potentially resulting in damage to the spent fuel bundles stored beneath the rack.

Description.

The nonsafety-related control rod blade storage racks at NMPNS are designed to mount to the side of the spent fuel pool and are secured by a jacking bolt and pad against the pool curb. Each rack holds 14 control rod blades. The rack was installed at Unit 1 in June 2012 using vendor-supplied instructions that had also been used successfully at Unit 2. On July 10, 2012, while loading the tenth control rod blade into the rack, the jackscrew pad slipped upward, but remained partially seated on the pool curb, resulting in the rack dropping slightly toward the spent fuel bundles stored beneath.

The inspectors determined the rack shifted because the rack installation instructions did not take into account important differences in the construction of Units 1 and 2 spent fuel pool curbs or critical assumptions contained in the design analysis. Specifically, the Unit 2 curb is a vertical 4-inch surface that provided sufficient surface area for clamping, while the curb at Unit 1 is shorter and its outer surface is not completely vertical. Also at Unit 1, a short outer steel plate installed during original construction slightly tapers the outer curb face, resulting in an angle that adversely affected the clamping force of the jackscrew. In addition, the stainless steel plate on the Unit 1 curb is painted, while the rack design calculation for the jackscrew bolt assumed a coefficient of friction based on stainless steel against stainless steel. Finally, the base of the curb at Unit 1 retained residual grout left over from construction, which created uneven flooring at the base of the curb, adversely affecting the jackscrew pad contact area. Some of the differences were noted by the installers at Unit 1, but no actions were taken by supervision to capture or evaluate these differences by formal engineering or CA processes.

NMPNS immediate CAs were to halt further control rod blade moves and install temporary slings to hold up the rack. The rack was then re-leveled and the jacking pad welded to the spent fuel pool curb. Additional CAs are outlined in CR 2012-006547.

Analysis.

The failure to ensure in June 2012 that the control rod blade storage rack design change package contained adequate instructions for installation, as required by CNG-FES-010, Engineering Change Package Installation and Testing Instructions, Revision 0001, is a performance deficiency that was within NMPNS ability to foresee and correct, and should have been prevented. This finding is more than minor because it would have the potential to lead to a more significant safety concern; e.g. spent fuel bundle damage and a radiological release. The inspectors evaluated the finding using 0609.04, Initial Characterization of Findings, in IMC 0609, Significance Determination Process, Appendix A, Exhibit 3, Barrier Integrity Screening Questions, pertaining to spent fuel pools and determined this finding to be of very low safety significance (Green), because the finding did not adversely affect decay heat removal capabilities or pool water inventory, and did not result from fuel handling errors, a dropped fuel assembly, a dropped storage cask, or crane operations over the spent fuel pool that caused mechanical damage to fuel cladding and a detectible release of radionuclides.

This finding has a cross-cutting aspect in the area of work practices because NMPNS did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported. Specifically, NMPNS supervision did not ensure that critical assumptions contained in the control rod storage rack design analysis concerning the configuration of the Unit 1 spent fuel pool curb were translated into the installation instructions, and differences between Units 1 and 2 curbs noted during the installation were captured or evaluated by engineering, work control, or the CA process. H.4(c)

Enforcement.

Enforcement action does not apply because this performance deficiency did not involve a violation of a regulatory requirement. Specifically, the control rod blade storage racks installed in the NMPNS spent fuel pools are nonsafety-related. As such, the applicable design package and installation instructions related with the storage racks are not governed by the requirements of Unit 1 TS 6.4, Procedures, or the design control requirements of 10 CFR Part 50, Appendix B. This issue was entered into NMPNS CAP as CR 2012-006547. Because this finding does not involve a violation of regulatory requirements and has very low safety significance, it is identified as a finding.

(FIN 05000220/2012004-03, Inadequate Installation Instructions for Control Rod Blade Storage Rack)

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

a. Inspection Scope

The inspectors reviewed the 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 basis 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 diesel generator raw water pump 102 bearing replacement on August 24, 2012 Unit 2 main turbine emergency gland seal pressure regulator setpoint adjustment on July 16, 2012 Unit 2 reactor protection system (RPS) B channel scram response time testing following relay K14J-2RPSB06 replacement on September 12, 2012

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities (71111.20 - Three samples)

a. Inspection Scope

The inspectors reviewed the stations work schedules and outage risk plans for Unit 1 forced outages 1F1202 and 1F1203, which were conducted July 17 through July 21, 2012, and September 20 through September 24, 2012, respectively, and Unit 2 forced outage 2F1201 which was conducted July 12 through July 21, 2012. The inspectors reviewed NMPNS development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outages, the inspectors observed portions of the shutdown and cooldown processes, and monitored controls associated with the following outage activities:

Drywell entry to inspect for potential leakage 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 Identification and resolution of problems related to refueling outage activities Power ascension activities

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22 - Four samples)

a. Inspection Scope

The inspectors observed performance of the following surveillance tests (STs) and/or reviewed test data of risk-significant SSCs 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, tests were 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 STs:

N1-ST-Q8B, Liquid Poison Pump 12 and Check Valve Operability Test, completed on July 31, 2012 (Inservice Testing)

N1-ST-Q26, Feedwater and Main Steam Line Power Operated Isolation Valves Partial Exercise Test and Associated Functional Testing of Reactor Protection System Trip Logic, completed on September 27, 2012 N2-OSP-GTS-R@001, Standby Gas Treatment System Functional Test, completed on August 3, 2012 N2-ISP-DER-M001, Monthly Functional Test of Primary Containment Drywell Floor and Equipment Drain Leak Rate Instrument Channels, completed on September 10, 2012 (Leak Detection Surveillance)

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP2 Alert and Notification System Evaluation (71114.02 - One sample)

a. Inspection Scope

An onsite review was conducted to assess the maintenance and testing of the alert and notification system (ANS). During this inspection, the inspector conducted a review of the ANS testing and maintenance programs. The inspector reviewed the associated ANS procedures and the Federal Emergency Management Agency-approved ANS design report to ensure compliance with design report commitments for system maintenance and testing. The inspection was conducted in accordance with NRC Inspection Procedure (IP) 71114, Attachment 2. 10 CFR Part 50.47(b)(5) and the related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Staffing and Augmentation System (71114.03 - One sample)

a. Inspection Scope

The inspector conducted a review of the NMPNS emergency response organization (ERO) augmentation staffing requirements and the process for notifying and augmenting the ERO. The review was performed to verify the readiness of key NMPNS staff to respond to an emergency event and to verify NMPNS ability to activate its emergency response facilities (ERF) in a timely manner. The inspector reviewed the NMPNS emergency plan for ERF activation and ERO staffing requirements, the ERO duty roster, applicable station procedures, pager test reports, the most recent drive-in drill report, and CRs related to this inspection area. The inspector also reviewed a sample of ERO responder training records to verify training and qualifications were up to date. The inspection was conducted in accordance with NRC IP 71114, Attachment 3. Title 10 CFR Part 50.47(b)(2) and related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.

b. Findings

No findings were identified.

1EP5 Maintenance of Emergency Preparedness (71114.05 - One sample)

a. Inspection Scope

The inspector reviewed a number of activities to evaluate the efficacy of NMPNS efforts to maintain the NMP emergency preparedness (EP) program. The inspector reviewed:

Letters of Agreement and/or Memoranda of Understanding with offsite agencies; the 10 CFR Part 50.54(q) emergency plan change process and practice; NMPNS maintenance of equipment important to EP; and records of evacuation time estimate population evaluation. A walk-down of the control room was conducted to inspect equipment important to EP, which included interviews with control room staff on the process for identifying and managing that out-of-service equipment. The inspector also verified NMPNS compliance at NMP with new NRC EP regulations regarding:

emergency action levels for hostile action events; the emergency operations facility performance-based approach; ERO augmentation at alternate ERFs; event declaration within 15 minutes; and protective actions for on-site personnel during events.

The inspector further evaluated NMPNS ability to maintain its EP program through their identification and correction of EP weaknesses, by reviewing a sample of drill reports, actual event reports, self-assessments, 10 CFR Part 50.54(t) audits, and EP-related CRs. The inspector reviewed a sample of EP-related CRs initiated at NMPNS between July 2010 and July 2012. The inspection was conducted in accordance with NRC IP 71114.05. Title 10 CFR Part 50.47(b) and the related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS2 Occupational ALARA Planning and Controls (71124.02 - One sample)

This area was inspected during the week of July 23 through 27, 2012, to assess performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspector used the requirements in 10 CFR Part 20, Regulatory Guide (RG) 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Plants will be As Low As Reasonably Achievable, RG 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposure As Low as Reasonably Achievable, TSs, and the NMPNS procedures required by TSs as criteria for determining compliance.

.1 Inspection Planning

a. Inspection Scope

The inspector reviewed pertinent information regarding NMPNS collective dose history, current exposure trends, and ongoing or planned activities in order to assess current performance and exposure challenges. The inspector reviewed the plants three year rolling average collective exposure.

The inspector reviewed site-specific procedures associated with maintaining occupational exposures ALARA, which included a review of processes used to estimate and track exposures from specific work activities.

b. Findings

No findings were identified.

.2 Radiological Work Planning

a. Inspection Scope

The inspector compared the results achieved (dose rate reductions, person-rem used)with the intended dose established in NMPNS ALARA planning for these work activities.

The inspector compared the person-hour estimates provided by maintenance planning and other departments to the radiation protection (RP) departments actual person-hours for the work activity time requirements, and evaluated the accuracy of these time estimates. The inspector assessed the reasons for any inconsistencies between intended and actual work activity doses.

ALARA review (AR) 212890, refuel floor activities AR #212830, NMP-2 chemical decontamination AR #212891, N2R13 EPU steam dryer modification AR #212802, drywell 249 foot and 261 foot under-vessel work AR #212810, drywell scaffold The inspector determined whether post-job reviews were conducted to identify lessons learned. If problems were identified, the inspector verified that worker suggestions for improving dose/contamination reduction techniques were entered into NMPNS corrective action program.

b. Findings

Failure to Maintain Radiation Exposure ALARA During Refueling Activities

Introduction:

A self-revealing Green finding (FIN) was identified due to NMPNS having unplanned, unintended occupational collective dose resulting from deficiencies in ALARA planning and work control while performing refueling activities at Unit 2 during N2RF13. Specifically, inadequate work planning and control of refueling activities resulted in unplanned, unintended collective exposure that was greater than 50 percent above the intended collective exposure and greater than five person-rem due to conditions that were reasonably within NMPNS ability to foresee and correct. These factors resulted in the collective exposure for refueling activities increasing from the original estimate of 31 person-rem to an actual dose of 56 person-rem.

Description:

Unintended collective exposure that was greater than 50 percent above the intended collective exposure and greater than five person-rem occurred during N2RF13 as a result of multiple factors, most notably: 1) problems with the stud tensioner hoists during stud de-tensioning resulted in unplanned dose associated with de-tensioning of the reactor vessel head, 2) repeated equipment reliability issues with the reactor building polar and refueling bridge cranes resulted in frequent crane failures and unplanned dose to repair this equipment, 3) flooding-up the refueling cavity while refueling water activity remained four times higher than the ALARA target concentration resulted in unintended dose, 4) postponing cavity decontamination using strippable paint until after de-tensioning resulted in unintended dose for the stud tensioning work activity, 5) improper positioning of one reactor vessel head stud washer interfered with the correct placement of the tensioning tool and resulted in unintended dose, and 6) a defective torque tool resulted in additional dose due to re-torqueing 20 bolts on the reactor vessel head insulation package.

During reactor disassembly, additional time in the cavity was required to repair a broken tensioning hoist on the carousel. Instead of using four hoists as originally planned, detensioning was performed with only two hoists. In addition, as a result of inadequate preventive maintenance, failures in the operation of both the refueling bridge crane and the reactor building polar crane persisted throughout the outage. This resulted in an added collective dose of 0.893 person-rem that was not planned in the original estimate (CNG-CA-1.01-1005, Tier 1 Apparent Cause Evaluation for CR-2012-003783). On April 13, 2012, the Site ALARA Committee (SAC) held the first on-going review for Refueling Activities. An additional dose of 1.364 person-rem resulted from these unplanned factors.

The pre-outage ALARA plan set a reactor water clean up target for Cobalt 60 concentration level of <4.00E-4 uCi/ml. This would achieve a dose rate of <1 mRem/hr at 30cm from the water surface. However, NMPNS decided to flood the cavity with water having a Co-60 concentration well above the ALARA target level, which resulted in dose rates of approximately 2.5 mRem/hr at 30 cm from the waters surface. On April 15, 2012, a SAC meeting was held to review and approve the dose impact of the higher Co-60 concentrations levels than what was planned. An additional dose of 1.329 person-rem resulted from these unintended elevated dose rates.

On May 12, 2012, a SAC meeting was held to review and approve additional dose estimates for future work. Additional ALARA controls to reduce dose during reactor reassembly were added to the ALARA Plan. As a result of unanticipated delays, additional unintended dose of 3.148 person-rem, due to postponing the decontamination of the cavity using strippable coating, resulted from the above and other unplanned factors.

On May 18, 2012, RPV head tensioning began. Reactor reassembly was interrupted when it was identified that a washer associated with a reactor vessel head bolt assembly had slipped out of place. The improper positioning of the washer interfered with the correct placement of the tensioning tool. On May 19, 2012, another SAC meeting was held to approve the 1.855 person-rem of additional dose as a result of this unintended activity.

On May 20, 2012, tensioning of bolts associated with the reactor vessel head insulation package was being performed when a worker inadvertently kicked the tool being used for tensioning. The tool then displayed erratic readings and was removed from the area.

Following testing, the tool was found to be defective. Since the calibration of the tool could not be verified during use, twenty bolts that had been tensioned using this torque tool had to be replaced and re-torqued. On May 21, 2012, another SAC meeting was held to approve 1.938 person-rem of additional dose as a result of this unplanned activity.

Overall, the total collective dose for the refueling activities increased from the original estimate of 31 person-rem to an actual dose of 56 person-rem. NMPNS immediate CAs included entering this issue into its corrective action program as CR 2012-005939.

Analysis:

The inspectors determined that NMPNS failure to appropriately plan and control refueling activities, together with the inability to perform effective reactor water cleanup and cavity decontamination, was a performance deficiency that was within NMPNS's ability to foresee and correct and should have been prevented. This finding is more than minor because it was associated with the program and process attribute of the Occupational Radiation Safety cornerstone and affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine reactor operation. This performance deficiency is similar to example 6.i of IMC 0612, Appendix E, Examples of Minor Issues in that the actual collective dose exceeded 5 person-rem and exceeded the planned, intended dose by more than 50 percent. The inspectors evaluated the finding using 0609.04, Initial Characterization of Findings, of IMC 0609, Significance Determination Process. The finding was determined to be of very low safety significance (Green) because NMPNS's current three year rolling average collective dose (143 person-rem/reactor year for 2009 to 2011) is less than the criterion of 240 person-rem per BWR unit. The finding has a cross-cutting aspect in the area of human performance, work control, in that the job site conditions which impacted human performance were not adequately incorporated into the outage plan. Specifically, the ALARA planning and work controls for refueling activities did not avert a significant unplanned and unintended collective occupational dose H.3(a)

Enforcement:

Enforcement action does not apply because this performance deficiency did not involve a violation of a regulatory requirement. Specifically, the Statements of Consideration of the ALARA rule, 10 CFR Part 20.1101(b), indicate that compliance with the ALARA requirement will be judged on whether NMPNS has incorporated measures to track and, if necessary, to reduce exposures, and not whether exposures and doses represent an absolute minimum, or whether NMPNS has used all possible methods to reduce exposures. The overall exposure performance of a nuclear power plant is used to determine its compliance with the ALARA rule. This issue was entered into NMPNS corrective action program as CR 2012-005939. Since NMPNS is below a three year rolling average of 240 person-rem per unit and has an established ALARA program to reduce exposure consistent with the 10 CFR Part 20.1101 Statements of Consideration, no violation of 10 CFR Part 20.1101(b) exists. Because this finding does not involve a violation of regulatory requirements and has very low safety significance, it is identified as a finding. (FIN 05000410/2012004-04, Failure to Maintain Radiation Exposure ALARA During Refueling Activities)

.3 Verification of Dose Estimates and Exposure Tracking Systems

a. Inspection Scope

The inspector assessed whether dose threshold criteria were established to prompt additional reviews and/or additional ALARA planning and controls. The inspector evaluated NMPNS methods of adjusting exposure estimates or re-planning work when unexpected changes in scope or emergent work were encountered. The inspector assessed whether adjustments to exposure estimates were based on sound RP and ALARA principles or whether they were adjusted to account for failures to plan/control the work.

b. Findings

No findings were identified.

.4 Source Term Reduction and Control

a. Inspection Scope

During the refueling outage, NMPNS performed a chemical decontamination to remove radioactive material that had built up on the reactor recirculation system piping, reactor water cleanup system and residual heat removal system. The inspector reviewed the results of the pre- and post-decontamination surveys that indicated dose rate reductions by factors of two to ten.

b. Findings

No findings were identified.

.5 Problem Identification and Resolution

a. Inspection Scope

The inspector evaluated whether problems associated with ALARA planning and controls are being identified by NMPNS at an appropriate threshold and were properly addressed for resolution in NMPNS corrective action program.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03 - One sample)

a. Inspection Scope

This area was inspected to verify in-plant airborne concentrations are being controlled consistent with ALARA principles, and the use of respiratory protection devices on-site does not pose an undue risk to the wearer. The inspector used the requirements in 10 CFR Part 20, the guidance in RG 8.15, Acceptable Programs for Respiratory Protection, RG 8.25, Air Sampling in the Workplace, NUREG-0041, Manual of Respiratory Protection Against Airborne Radioactive Material, the TSs, and NMPNS procedures required by TSs as criteria for determining compliance.

.1 Inspection Planning

a. Inspection Scope

Inspector reviewed NMPNS procedures for maintenance, inspection, and use of respiratory protection equipment, including self-contained breathing apparatus (SCBA),as well as procedures for air quality maintenance. The inspector reviewed reported performance indicators to identify any related to unintended dose resulting from intakes of radioactive material.

b. Findings

No findings were identified.

.2 Engineering Controls

a. Inspection Scope

The inspector selected the Unit 2 control room and standby gas treatment system ventilation systems used to mitigate the potential for airborne radioactivity. The inspector evaluated whether the ventilation systems operating parameters were consistent with maintaining concentrations of airborne radioactivity in these areas below the concentrations of an airborne radioactive material area.

b. Findings

No findings were identified.

.3 Use of Respiratory Protection Devices

a. Inspection Scope

The inspector assessed whether respiratory protection devices used to limit the intake of radioactive materials were certified by the National Institute for Occupational Safety and Health/Mine Safety and Health Administration. The inspector evaluated whether the devices were used consistent with their National Institute for Occupational Safety and Health/Mine Safety and Health Administration certification or NRC approval.

The inspector selected five individuals qualified to use respiratory protection devices, and assessed whether they were deemed qualified to use the devices by successfully passing an annual medical examination, respirator fit-test, and relevant respiratory protection training.

The inspector reviewed training curricula for users of respiratory protection devices or requested a demonstration of device use (donning, doffing, functional checks, and device malfunction) from selected individuals.

The inspector chose ten respiratory protection devices staged and ready for use in the plant. The inspector assessed the physical condition of the device components and reviewed records of equipment inspection for each type of equipment. The inspector selected several of the devices and reviewed records of maintenance on the vital components. The inspector verified that onsite personnel assigned to repair respiratory protection equipment have received vendor-provided training.

b. Findings

No findings were identified.

.4 Self Contained Breathing Apparatus (SCBA) for Emergency Use

a. Inspection Scope

The inspector reviewed the status and surveillance records of selected SCBAs staged in-plant for use during emergencies. The inspector reviewed NMPNS capability to refill and transport SCBA air bottles to and from the control room and the operations support center during emergency conditions.

The inspector reviewed the past two years of maintenance records for three SCBA units to assess whether any maintenance and repairs on any self-contained breathing apparatus units were performed by an individual, or individuals, certified by the manufacturer of the device to perform the work. For those self-contained breathing apparatuses that were ready for use the inspector verified the required, periodic air cylinder hydrostatic testing was documented and up to date.

b. Findings

No findings were identified.

.5 Problem Identification and Resolution

a. Inspection Scope

The inspector evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by NMPNS at an appropriate threshold and were properly addressed for resolution in the NMPNS corrective action program. The inspector assessed whether the corrective actions were appropriate for a selected sample of problems involving airborne radioactivity and were appropriately documented by NMPNS.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment (71124.04 - One sample)

This area was inspected to ensure occupational dose at NMPNS is appropriately monitored and assessed. The inspector used the requirements in 10 CFR Part 20, the guidance in RG 8.13, Instructions Concerning Prenatal Radiation Exposures, RG 8.36, Radiation Dose to Embryo Fetus, RG 8.40, Methods for Measuring Effective Dose Equivalent from External Exposure, TSs, and NMPNS procedures required by TSs as criteria for determining compliance.

.1 Inspection Planning

a. Inspection Scope

The inspector reviewed the results of RP program audits related to internal and external dosimetry.

b. Findings

No findings were identified.

.2 External Dosimetry

a. Inspection Scope

The inspector assessed the use of electronic person dosimeters (EPDs) to determine if NMPNS uses a correction factor to address the response of the EPD as compared to the dosimeter of legal record for situations when the EPD is used to assign dose and whether the correction factor is based on sound technical principles.

b. Findings

No findings were identified.

Routine Bioassay (In Vivo)

The inspector reviewed the whole body count (WBC) process to determine if the frequency of measurements was consistent with the biological half-life of the radionuclides available for intake. The inspector selected three WBCs and evaluated whether the counting system used had sufficient counting time/low background to ensure appropriate sensitivity for the potential radionuclides of interest. The inspector reviewed the radionuclide library used for the count system to determine if it included the gamma-emitting radionuclides that exist at the site. The inspector evaluated how NMPNS accounts for hard-to-detect radionuclides in its internal dose assessments, as applicable.

Special Bioassay (In Vitro)

The inspector selected one internal dose assessment obtained using WBC. The inspector reviewed and assessed the adequacy of NMPNS program for urinalysis and fecal analysis of radionuclides including collection and storage of samples. The inspector reviewed the internal dose assessments obtained using urinalysis sample results.

The inspector reviewed the vendor laboratory quality assurance program and assessed whether the laboratory participated in an industry recognized cross-check program including whether out-of-tolerance results were reviewed, evaluated and resolved appropriately.

Internal Dose Assessment - Airborne Monitoring NMPNS had not performed any internal dose assessments using airborne/derived air concentration monitoring during the period reviewed.

Internal Dose Assessment - WBC Analyses The inspector reviewed several dose assessments performed by NMPNS using the results of WBC analyses. The inspector determined whether affected personnel were properly monitored with calibrated equipment and that internal exposures were assessed consistent with the NMPNS procedures.

.4 Special Dosimetric Situations

Declared Pregnant Workers

a. Inspection Scope

The inspector assessed whether NMPNS informs workers, as appropriate, of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for (voluntarily) declaring a pregnancy.

The inspector reviewed documentation for one individual who had declared pregnancy during the current assessment period and evaluated whether NMPNS radiological monitoring program (internal and external) for declared pregnant workers is technically adequate to assess the dose to the embryo/fetus. The inspector also reviewed exposure results and monitoring controls that NMPNS implemented.

b. Findings

No findings were identified.

.5 Problem Identification and Resolution

a. Inspection Scope

The inspector assessed whether problems associated with occupational dose assessment are being identified by NMPNS at an appropriate threshold and are properly addressed for resolution in the NMPNS corrective action program. The inspector assessed the appropriateness of the corrective actions for a selected sample of problems documented by NMPNS involving occupational dose assessment.

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation

This area was inspected during the week of September 24 through 27, 2012, to verify NMPNS is assuring the accuracy and operability of radiation monitoring instruments that are used to protect occupational workers and to protect the public from nuclear power plant operations. The inspector used the requirements in 10 CFR Part 20, 10 CFR Part 50 Appendix A, Criterion 60, Control of Release of Radioactivity to the Environment and Criterion 64, Monitoring Radioactive Releases, 10 CFR 50 Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water - Cooled Nuclear Power Reactor Effluents, 40 CFR Part 190 - Environmental Radiation Protection Standards for Nuclear Power Operations, NUREG 0737 - Clarification of Three Mile Island Corrective Action Requirements, the TSs/offsite dose calculation manual (ODCM),applicable industry standards, and NMPNS procedures required by TSs as criteria for determining compliance.

.1 Inspection Planning

a. Inspection Scope

The inspector reviewed the UFSAR to identify radiation instruments associated with monitoring area radiation, airborne radioactivity, process streams, effluents, materials/articles, and workers. Additionally, the inspector reviewed the associated TS requirements for post-accident monitoring instrumentation. The inspector reviewed a listing of in-service survey instrumentation, including air samplers and small article monitors (SAM), along with radiation monitoring instruments used to detect and analyze contamination and external dose rates. Additionally, the inspector reviewed personnel contamination monitors and portal monitors, including whole-body counters to detect workers surface and internal contamination. The inspector assessed whether an adequate number and type of instruments were available to support operations.

The inspector reviewed NMPNS and third-party evaluation reports of the radiation monitoring program since the last inspection including evaluations of offsite calibration facilities or services.

The inspector reviewed procedures that govern instrument source checks and calibrations, focusing on instruments used for monitoring transient high-risk radiological conditions, including instruments used for underwater surveys. The inspector reviewed the calibration and source check procedures for adequacy. The inspector reviewed the area radiation monitor (ARM) alarm setpoint values and bases as provided in the TSs and the UFSAR. The inspector reviewed effluent monitor alarm setpoint bases and the calculation methods provided in the ODCM.

b. Findings

No findings were identified.

.2 Walkdowns and Observations

a. Inspection Scope

The inspector walked down five effluent radiation monitoring systems including: Unit 1 Stack Radiation Monitor, Unit 1 Service Water Discharge Monitor, Unit 2 Wide Range Stack Gas Monitoring System, Unit 2 Reactor and Radwaste Building Wide Range Gas Monitoring System and the Unit 2 Service Water Discharge Monitor. The focus was placed on flow measurement devices and all accessible point-of-discharge liquid and gaseous effluent monitors. The inspector assessed whether the effluent/process monitor configurations align with what is described in the UFSAR and ODCM.

The inspector selected five portable survey instruments in use or available for issuance and assessed calibration and source check stickers for currency as well as instrument material condition and operability.

The inspector observed NMPNS staff performance as the staff demonstrated source checks for the Eberline RO-2A Ion Chamber, the Eberline RM-14 Scaler with HP 201 GM Probe, and the MGP Telepole portable survey instruments. The inspector assessed whether high-range instruments are source checked on all appropriate scales.

The inspector walked down five ARMs and five continuous air monitors (CAMs) to determine whether they are appropriately positioned relative to the radiation sources or areas they were intended to monitor. Selectively, the inspector compared monitor response (via local readout or remote control room indications) with actual area radiological conditions for consistency.

The inspector selected six personnel contamination monitors, six portal monitors, and three SAMs and evaluated whether the periodic source checks were performed in accordance with the manufacturers recommendations and NMPNS procedures.

b. Findings

No findings were identified.

Process and Effluent Monitors

The inspector selected five process and effluent monitor instruments and evaluated whether channel calibration and functional tests were performed consistent with TSs/ODCM. The inspector assessed whether:

(1) NMPNS calibrated its monitors with National Institute of Standards and Technology traceable sources;

(2) the primary calibrations adequately represented the plant nuclide mix;

(3) when secondary calibration sources were used, the sources were verified by comparison with the primary calibration source; and

(4) NMPNS channel calibrations encompassed the instruments alarm set-points.

The inspector assessed whether the effluent monitor alarm setpoints are established as provided in the ODCM and station procedures. For changes to effluent monitor setpoints, the inspector evaluated the basis for changes to ensure that an adequate justification existed.

Whole Body Counter (WBC)

The inspector reviewed the methods and sources used to perform functional checks on the WBC before daily use and assessed whether check sources were appropriate and align with the plants radionuclide mix.

The inspector reviewed calibration records for the whole body counter since the last inspection and evaluated whether calibration sources were representative of the plant radionuclide mix and that appropriate calibration phantom(s) were used. The inspector looked for anomalous results or other indications of instrument performance problems.

Post-Accident Monitoring Instrumentation Inspector reviewed the calibration documentation for the Unit 1 and Unit 2 drywell high-range monitors. The inspector assessed whether an electronic calibration was completed for all ranges and were also calibrated using an appropriate radiation source.

The inspector assessed whether calibration acceptance criteria were reasonable, considering the large measurement range and the intended use of the instrument.

The inspector selected two effluent/process monitors that are relied on by NMPNS in its emergency operating procedures as a basis for triggering emergency action levels and subsequent emergency classifications, or to make protective action recommendations during an accident. The inspector evaluated the calibration and availability of these instruments.

As available, the inspector observed electronic and radiation calibration of those instruments associated with the post accident effluent sampling to verify conformity with NMPNS calibration and test protocols.

Portal Monitors, Personnel Contamination Monitors, and SAMs The inspector selected at least two of each type of these instruments and verified that the alarm setpoint values were reasonable under the circumstances to ensure that licensed material is not released from the site.

The inspector reviewed the calibration documentation for each selected instrument and reviewed the calibration methods to determine consistency with the manufacturers recommendations.

Portable Survey Instruments, ARMs, Electronic Dosimetry, and Air Samplers/CAMs The inspector reviewed calibration documentation for at least one of each type of portable instrument. For portable survey instruments and ARMs, the inspector reviewed detector measurement geometry and calibration methods and reviewed the use of its instrument calibrator as applicable.

As available, the inspector selected one portable survey instruments that did not meet acceptance criteria during calibration or source checks to assess whether NMPNS had taken appropriate corrective action for instruments found significantly out of calibration (greater than 50 percent). The inspector evaluated whether NMPNS had evaluated the possible consequences associated with the use of an instrument that is out-of calibration since the last successful calibration or source check.

Instrument Calibrator The inspector reviewed the current radiation output values for NMPNS portable survey and ARM instrument calibrator unit. The inspector assessed whether NMPNS periodically verifies calibrator output over the range of the exposure rates/dose rates using an ion chamber/electrometer.

The inspector assessed whether the precision measurement devices had been calibrated by a facility using National Institute of Science and Technology traceable radioactive sources, and whether decay corrective factors for these measurement devices were properly applied by NMPNS in its output verification.

Calibration and Check Sources The inspector reviewed NMPNS source term or waste stream characterization per 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, to assess whether calibration sources used were representative of the types and energies of radiation encountered in the plant.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance Index (Ten samples)

a. Inspection Scope

The inspectors reviewed NMPNS submittal of the Mitigating Systems Performance Index for the following systems for the period of July 1, 2011 through June 30, 2012:

Units 1 and 2 emergency alternating current power system Units 1 and 2 high pressure injection system Units 1 and 2 heat removal system Units 1 and 2 residual heat removal system Units 1 and 2 cooling water system To determine the accuracy of the performance indicator (PI) data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors also reviewed NMPNS operator narrative logs, CRs, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

.

b. Findings

No findings were identified.

.2 Emergency Planning Performance Indicators (Three samples)

a. Inspection Scope

The inspector reviewed data for the three EP PIs, which are:

(1) drill and exercise performance;

(2) ERO drill participation; and

(3) ANS reliability. The last NRC EP inspection at NMPNS was conducted in the fourth calendar quarter of 2011. Therefore, the inspector reviewed supporting documentation from EP drills and equipment tests from the fourth calendar quarter of 2011 through the second calendar quarter of 2012 to verify the accuracy of the reported PI data. The review of the PIs was conducted in accordance with NRC IP 71151. The acceptance criteria documented in NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 6, was used as reference criteria.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution (71152 - Three samples)

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by NRC IP 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 the CAP at an appropriate threshold, gave adequate attention to timely CAs, 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 Samples: Review of the Unit 1 and 2 Operator Workaround Program

a. Inspection Scope

The inspectors reviewed the cumulative effects of the existing Units 1 and 2 operator workarounds, operator burdens, existing operator aids and disabled alarms, and open main control room deficiencies to identify any effect on EOP operator actions, and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed operator workarounds as specified in NMPNS procedure S-ODP-OPS-0124, Control of Operator Workarounds and Burdens.

The inspectors reviewed NMPNS process to identify, prioritize and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these operator workarounds and reviewed the most recent operator workarounds and burdens program aggregate impact review. The inspectors also toured the control rooms and discussed the current operator workarounds with the operators to ensure the items were being addressed on a schedule consistent with their relative safety significance.

b. Findings and Observations

No findings were identified.

The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement the abnormal operating procedures or the EOPs. The inspectors also determined that NMPNS entered operator workarounds and burdens into the CAP, and planned or implemented CAs commensurate with their safety significance.

.3 Annual Sample: Potential Adverse Impact to GE Magne-Blast Breakers due to Parts

Deficiency Identified in GEH SC 11-06

a. Inspection Scope

In October 2011 GEH identified the potential for some shoulder bolts and lock washers within prop spring kits that were supplied to NMPNS for refurbishment of GE Magne-Blast circuit breakers may be technically deficient. GEH provided this information in SC 11-06, in accordance with 10 CFR Part 21.21(d) as a Transfer of Information to allow NMPNS to determine if any of the 40 prop spring kits supplied to them contained any potentially deficient parts, and if they existed in any safety-related GE Magne-Blast circuit breakers. NMPNS initiated CR 2011-011225 and conducted a barrier analysis to ensure that potentially defective shoulder bolts and lock washers were not installed in any safety-related GE Magne Blast circuit breakers. NMPNS developed corrective actions CA 2012-000044 and CA 2012-000048 to enhance preventive maintenance procedures to perform a bolt tightness check and issue a purchase order for new prop spring kits.

The inspectors reviewed documents associated with the CAs, operating experience, SC 11-06, and performed walkdowns of accessible circuit breakers. The inspectors also reviewed applicable procedures associated with preventive maintenance of circuit breakers, and any associated procedure changes that were intended to verify the adequacy of bolts and washers in the circuit breaker.

b. Findings and Observations

No findings were identified.

NMPNS determined that this issue was not applicable to NMPNS because no in-service failures had occurred, no deviations had been detected by GEH breaker technicians during periodic breaker refurbishment, which included cycling the breakers a minimum of 75 times at rated voltage prior to shipment to NMPNS, and no issues had been identified during receipt inspection, preventive maintenance, or surveillance tests performed by NMPNS maintenance personnel. However, as an additional conservative measure, NMPNS generated several procedure change requests (PCRs) that would ensure that the subject bolts and washers were properly tightened during preventive maintenance.

The inspectors identified a performance deficiency associated with implementation of the CAs. Specifically, CA 2012-000044 was generated to implement procedure change requests PCR-12-00569 and PCR-12-00587 to update N1-EPM-GEN-150, 4.16KV Breaker Inspection PM, and N2-EPM-GEN-550, GE 4.16KV Magne-Blast Breaker PM, respectively. The PCRs were to add a step to each procedure to verify the prop spring bolt and washer were properly tightened. The inspectors identified that although each PCR had been generated and the associated CA had been closed out, the procedures had not been appropriately updated.

This issue was determined to be a minor violation of NMPNS procedure CNG-PR-1.01-1000, Fleet Procedure Process, Revision 00801 because it was related to equipment qualification, and no equipment operability or functionality was significantly affected. In accordance with NRC IMC 0612, Power Reactor Inspection Reports, the above issue constituted a violation of minor significance that is not subject to enforcement action in accordance with the Enforcement Policy. NMPNS entered the inspectors observations into its corrective action program as CR 2012-009162.

NMPNS overall response to the issue was commensurate with the safety significance, was timely, and included appropriate CAs. The inspectors determined that the actions taken were reasonable to resolve the issue.

4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153 - Four samples)

.1 Plant Events

a. Inspection Scope

For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that NMPNS made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors responded to the control room and observed NMPNS immediate responses to the events. The inspectors reviewed NMPNS follow-up actions related to the events to assure that NMPNS implemented appropriate corrective actions commensurate with their safety significance.

Unit 2 manual reactor scram due to loss of gland sealing steam and low vacuum on July 12, 2012 Unit 1 automatic reactor scram due to EPR malfunction, resulting in high neutron flux scram on July 17, 2012 Unit 1 automatic reactor scram due to a main generator trip and subsequent turbine trip on September 20, 2012.

b. Findings

No findings were identified.

.2 (Closed) Licensee Event Report (LER) 05000410/2012-004-00: Manual Reactor Scram

due to a Loss of Main Turbine Gland Sealing Steam Resulting in Lowering Condenser Vacuum On July 12, 2012, NMPNS Unit 2 was manually scrammed from approximately 85 percent of rated power due to lowering condenser vacuum and indications of rising offgas system inlet pressure. These conditions occurred due to loss of the in-service clean steam reboiler and failure of the backup gland sealing steam supply to provide adequate steam pressure to the main turbine gland seals. The enforcement aspects of this issue are discussed in Section 1R18. The inspectors did not identify any new issues during the review of the LER. This LER is closed.

4OA5 Other Activities

.1 Power Uprate (71004 - One sample)

a. Inspection Scope

On May 27, 2009, NMPNS submitted an EPU license amendment request for NMPNS Unit 2, requesting an increase in reactor power from 3467 megawatts thermal (MWt) to 3988 MWt. The inspector performed portions of NRC procedure 71004, Power Uprate, to verify that equipment performance, procedures, and processes are adequate to support operations at an increased power level.

Erosion-Corrosion/Flow Accelerated-Corrosion Program Review The inspector verified that NMPNS had taken the required actions to detect adverse effects (wall thinning) on systems and components as a result of operating changes related to EPU, such as increased flow in affected primary and secondary systems, including their interfacing systems. The inspector followed the guidance of procedure 49001, Inspection of Erosion-Corrosion/Flow Accelerated-Corrosion Monitoring Programs, to verify program adequacy.

Flow Induced Vibration Monitoring Review The inspector reviewed NMPNS actions to monitor plant components for the effects of flow induced vibration during EPU operating conditions. NMPNS installed strain gages on all main steam lines to monitor potential vibration and the potential effect on the steam dryer structural integrity. NMPNS also installed accelerometers on several main steam line locations, several steam relief valves, several feedwater line locations, several feedwater heater drain lines and on several locations in the condensate system.

Power Uprate Ascension Plan The inspector reviewed NMPNS completed power ascension procedure performed during the power ascension to the increased power level. NMPNS completed the procedure in a controlled manner, stopping at appropriate power levels to record and assess system and component vibration levels prior to re-commencing the power ascension. Changes and variations in the procedure performance were entered into the CA process and the reported conditions were evaluated and dispositioned.

b. Findings

No findings were identified.

.2 Temporary Instruction 2515/187 - Inspection of Near-Term Task Force

Recommendation 2.3 - Flooding Walkdowns

a. Inspection Scope

On August 28, 2012, the inspectors commenced activities to independently verify that NMPNS conducted external flood protection walkdown activities using an NRC-endorsed walkdown methodology. These flooding walkdowns are being performed at all sites in response to Enclosure 4 of a letter from the NRC to licensees entitled, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 (ADAMS Accession No.

ML12053A340). The results of this temporary instruction will be documented in a future inspection report.

b. Findings

No findings were identified.

.3 Temporary Instruction 2515/188 - Inspection of Near-Term Task Force

Recommendation 2.3 - Seismic Walkdowns

a. Inspection Scope

On June 24, 2012, the inspectors commenced activities to independently verify that NMPNS conducted seismic walkdown activities using an NRC-endorsed seismic walkdown methodology. These seismic walkdowns are being performed at all sites in response to Enclosure 3 of a letter from the NRC to licensees entitled, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 (ADAMS Accession No.

ML12053A340). When complete, the results of this temporary instruction will be documented in a future inspection report.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On October 12, 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.

ATTACHMENT:

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 Manager

S. Dhar, Design Engineering

J. Dosa, Director, Licensing

J. Gillard, Emergency Preparedness Analyst

J. Holton, Supervisor, Systems Engineering

G. Inch, Principle Engineer, EPU Project Manager

M. Kunzwiler, Security Supervisor

J. Leonard, Supervisor Design Engineering

C. McClay, Senior Engineer

R. Meyers, Director, Emergency Preparedness

F. Payne, Manager, Operations

J. Reid, Design Engineer

M. Shanbhag, Licensing Engineer

T. Syrell, Manager, Nuclear Safety and Security

LIST OF ITEMS OPENED, CLOSED, DISCUSSED AND UPDATED

Opened

None

Opened and Closed

05000220/2012004-01 FIN Inadequate Implementation of Operational Decision Making Issues Monitoring Plan for EPR Results in Reactor Scram (Section 1R12)

05000410/2012004-02 FIN Inadequate Evaluation and Implementation of Design Modifications to the Turbine Gland Seal Supply System (Section 1R18)

05000220/2012004-03 FIN Inadequate Installation Instructions for Control Rod Blade Storage Rack (Section 1R18)

05000410/2012004-04 FIN Failure to Maintain Radiation Exposure ALARA During Refueling Activities (Section 2RS2)

Closed

05000410/2012-004-00 LER Manual Reactor Scram due to a Loss of Main Turbine Gland Sealing Steam Resulting in Lowering Condenser Vacuum

Discussed

05000220/410/2515/187 TI Inspection of Near-Term Task Force Recommendation 2.3 -

Flooding Walkdowns (Section 4OA5)

05000220/410/2515/188 TI Inspection of Near-Term Task Force Recommendation 2.3 -

Seismic Walkdowns (Section 4OA5)