IR 05000458/2013002

IR 05000458-13-002; Entergy Operations, Inc; 01/01/2013 - 03/30/2013; River Bend Station, NRC Integrated Inspection Report

ML13128A427
Person / Time
Site:	River Bend
Issue date:	05/08/2013
From:	David Proulx NRC/RGN-IV/DRP/RPB-C
To:	Olson E Entergy Operations
WALKER W
References
IR-13-002
Download: ML13128A427 (63)

Text

U N IT E D S TA TE S N U C LE AR R E GU LA TOR Y C OM MI S S I ON May 8, 2013

SUBJECT:

RIVER BEND STATION - NRC INTEGRATED INSPECTION REPORT 05000458/2013002

Dear Mr. Olson:

On March 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your River Bend Station. The enclosed inspection report documents the inspection results which were discussed on April 4, 2013, with you and other members of your staff.

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

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

One NRC-identified finding and three self-revealing findings of very low safety significance (Green) were identified during this inspection.

Three of these findings were determined to involve violations of NRC requirements. The NRC is treating these violations as non-cited violations consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest these non-cited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at River Bend Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC Resident Inspector at River Bend Station.

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

Sincerely,

/RA/

David L. Proulx, Acting Branch Chief Project Branch C Division of Reactor Projects Docket Nos.: 50-458 License Nos: NPF-47 Enclosure: Inspection Report 05000458/2013002 w/ Attachments:

1. Supplemental Information 2. Information Request for Inspection Activities Documented in 2RS1, 2RS2, and 4OA1 3. Information Request for Inspection Activities Documented in 1R08 cc w/ encl: Electronic Distribution

SUMMARY OF FINDINGS

IR 05000458/2013002; 01/01/2013 - 03/30/2013; RIVER BEND STATION; Integrated Resident and Regional Report; Maintenance Effectiveness; Radiological Hazard Assessment and Exposure Controls; Occupational ALARA Planning and Controls The report covered a 3-month period of inspection by resident inspectors, two announced baseline inspections by region-based inspectors, and one announced baseline inspection by a headquarters-based inspector. Three Green non-cited violations and one Green finding of significance were identified. The significance of most findings is indicated by their color (Green,

White, Yellow, or Red) using Inspection Manual Chapter 0609, Significance Determination Process. The cross-cutting aspect is determined using Inspection Manual Chapter 0310,

Components Within the Cross-Cutting Areas. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of 10 CFR 50.65(a)(1)associated with the licensees failure monitor the floor and equipment drains system against licensee-established goals. The licensee failed to properly classify two maintenance preventable functional failures for this system, and as a result, inappropriately left the system in maintenance rule a(2) status. In response, the licensee properly classified the subject failures and classified the affected system into maintenance rule (a)(1) status. The licensee entered this issue into their corrective action program as Condition Report CR-RBS-2013-00295.

The failure to adequately monitor the performance of the floor and equipment drains system is a performance deficiency. The performance deficiency was more-than-minor and was therefore a finding because if left uncorrected, the failure to adequately monitor the performance of the floor and equipment drains system could lead to a more significant safety concern. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process For Findings At-Power, the inspectors determined that the finding is of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than its technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety significance in accordance with the licensees maintenance rule program. No cross-cutting aspect was assigned because the finding does not represent current performance (Section 1R12).

Cornerstone: Occupational Radiation Safety

Green.

The inspectors reviewed two examples of a self-revealing, non-cited violation of Technical Specification 5.7.1 that resulted because individuals failed to request briefings of the dose rates in high-radiation areas before entry. In response, the licensee coached the involved individuals involved about the acceptable radiation work practice. The licensee entered this issue into their corrective action program as Condition Reports 2012-07643 and 2013-01275.

The failure to request briefings of the dose rates in high-radiation areas before entry was a performance deficiency. The significance of the performance deficiency was more-than-minor because it was associated with the Occupational Radiation Safety Cornerstone attribute of program and process (exposure control) and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation because the failure exposed workers to higher than anticipated radiation dose rates. The Occupational Radiation Safety Cornerstone was affected; therefore, the inspectors used Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, to determine the significance of the violation. The violation had very low safety significance because: (1) it was not an as low as is reasonably achievable finding, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. This violation had a cross-cutting aspect in the human performance area, associated with the work practices component, because licensee personnel failed to use human error prevention techniques, such as self- and peer-checking, commensurate with the risk of the assigned task such that work activities were performed safely H.4(a)

(Section 2RS1).

Green.

The inspectors reviewed a self-revealing, non-cited violation of Technical Specification 5.7.1 that resulted because a radiation protection technician failed to provide adequate job coverage. In response, the licensee coached the involved individuals involved about the acceptable radiation work practice. The licensee entered this issue into their corrective action program as Condition Report 2013-00479.

The failure to provide adequate radiation protection job coverage was a performance deficiency. The requirement not met was Technical Specification 5.7.1. The significance of the performance deficiency was more-than-minor because it was associated with the Occupational Radiation Safety Cornerstone attribute of program and process (exposure control) and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation because the failure exposed workers to higher than anticipated radiation dose rates. The Occupational Radiation Safety Cornerstone was affected; therefore, the inspectors used Manual Chapter 0609,

Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, to determine the significance of the violation.

The violation had very low safety significance because: (1) it was not an as low as is reasonably achievable finding, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. This violation had a cross-cutting aspect in the human performance area, associated with the decision making component, because licensee personnel did not make a risk-significant decision using a systematic process when faced with uncertain or unexpected plant conditions

H.1(a) (Section 2RS1).

Green.

The inspectors reviewed a self-revealing finding associated with the licensees failure to provide adequate instructions for installing a new seal cartridge in the reactor water cleanup A pump. The licensee entered this issue into their corrective action program as Condition Report CR-RBS-2011-09015. In that condition report, the licensee developed a corrective action to revise all reactor water cleanup procedures and model work orders to verify proper installation of the pump seal.

The failure to provide adequate instructions for properly installing reactor water cleanup pump seal cartridges was a performance deficiency. The performance deficiency was more-than-minor because it was associated with the Occupational Radiation Safety Cornerstone attribute of program and process (exposure control) and affected the cornerstone objective in that it caused increased collective radiation dose for occupational workers. Additionally, the finding was similar to example 6(i) in Appendix E to Manual Chapter 0612, Power Reactor Inspection Reports - Examples of Minor Issues. Using Manual Chapter 0609,

Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, the inspectors determined the finding had very low safety significance because, although the finding involved ALARA planning and work controls, the licensees latest three-year rolling average collective dose was less than 240 person-rem. This finding had a cross-cutting aspect in the human performance area, associated with the resources component, because the licensee failed to use complete, accurate and up-to-date procedures and work orders to perform the seal installation, which resulted in unnecessary dose

H.2(c) (Section 2RS2).

Licensee-Identified Violations

None

REPORT DETAILS

Summary of Plant Status

River Bend Station began the inspection period at 100 percent reactor power. It departed from full power as follows:

On January 4, operators reduced reactor power to 75 percent for a control rod adjustment and returned to 100 percent power on the same day.

On January 5, operators reduced reactor power to 87 percent to repack the feedwater regulating valve B after a steam leak developed. Operators returned the plant to 100 percent power on January 6.

On January 23, operators reduced reactor power to 64 percent for a control rod sequence exchange and returned to 100 percent power on January 24.

On February 8, the plant reduced power to 89 percent to perform a control rod adjustment and returned to 100 percent power on February 9.

On February 16, the operators took the plant offline to begin refuel outage 17. The plant started up in power from refuel outage 17 on March 15. On March 26, after arranging two intermediate control rod patterns, operators established their final 100 percent control rod pattern.

The plant remained at 100 percent reactor power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

Since thunderstorms with potential tornados and high winds were forecast in the vicinity of the facility for February 25, the inspectors reviewed the plant personnels overall preparations/protection for the expected weather conditions. On that day, the inspectors walked down the primary containment structure equipment hatch, which was open at the time due to refueling outage 17, and the condensate storage tank because their safety-related functions could be affected as a result of high winds or tornado-generated missiles or the loss of offsite power. The inspectors evaluated the plant staffs preparations against the sites procedures and determined that the staffs actions were adequate. During the inspection, the inspectors focused on plant-specific design features and the licensees procedures used to respond to specified adverse weather conditions. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. Additionally, the inspectors reviewed the Updated Safety Analysis Report and performance requirements for the systems selected for inspection and verified that operator actions were appropriate as specified by plant-specific procedures. The inspectors also reviewed a sample of corrective action program items to verify that the licensee identified adverse weather issues at an appropriate threshold and dispositioned them through the corrective action program in accordance with station corrective action procedures. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one readiness for impending adverse weather condition sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Partial Walkdown

a. Inspection Scope

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

Residual heat removal B in shutdown cooling with suppression pool cooling B in alternate decay heat removal and residual heat removal A out of service, completed on February 19 (during refueling outage 17)

Division 1 emergency diesel generator, completed on February 21 Residual heat removal pump A in shutdown cooling with residual heat removal B out of service, completed on March 6 (during refueling outage 17)

Spent fuel pool cooling A, completed on March 12 The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Safety Analysis Report, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four partial system walkdown samples as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Fire Inspection Tours

a. Inspection Scope

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

January 9: fire zone ET-1, B tunnel east smoke detectors - deluge initiated January 9: fire zone ET-2, B tunnel west smoke detectors - deluge initiated February 7: auxiliary building, 78-foot, 98-foot, 114-foot, and 141-foot elevations February 11: reactor building, 162-foot and 186-foot elevations February 13: control building, 98-foot and 116-foot elevations March 15 (during refueling outage 17): drywell March 19: auxiliary building, 78-foot, 98-foot, and 141-foot elevations The inspectors reviewed these areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensees fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees corrective action program. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of seven quarterly fire-protection inspection samples as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

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

These activities constitute completion of one heat sink inspection sample as defined in Inspection Procedure 71111.07-05.

b. Findings

No findings were identified.

1R08 Inservice Inspection Activities

Completion of Sections

.1 and .5, below, constitutes completion of one sample as

defined in Inspection Procedure 71111.08-05.

.1 Inspection Activities Other Than Steam Generator Tube Inspection, Pressurized Water

Reactor Vessel Upper Head Penetration Inspections, and Boric Acid Corrosion Control (71111.08-02.01)

a. Inspection Scope

The inspectors observed nine nondestructive examination activity and reviewed 21 nondestructive examination activities that included four types of examinations. The licensee did not identify any relevant indications accepted for continued service during the nondestructive examinations.

The inspectors directly observed the following nondestructive examination:

SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor Water WCS-005A-FW007 Ultrasonic Cleanup Jet Pump Beam BB-1 Ultrasonic (IVVI)

Jet Pump Beam BB-2 Ultrasonic(IVVI)

Jet Pump Beam BB-3 Ultrasonic(IVVI)

Core Spray Sparger A S2a Enhanced VT-1 (IVVI)

Core spray Sparger C S2c Enhanced VT-1 (IVVI)

Core Spray Piping P3a(L) 59 º Enhanced VT-1 (IVVI)

Core Spray Piping P2a(R) 93 º Enhanced VT-1 (IVVI)

Core Spray Piping P3b(R) 119 º Enhanced VT-1 (IVVI)

The inspectors reviewed records for the following nondestructive examinations:

SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor B33-PC001A-WJ-3 Liquid Penetrant Recirculation Pump Residual Heat RHS-014A-FW010 Magnetic Particle Removal Main Steam MSS-008A-FW029 Magnetic Particle Feedwater FWS-062A-FW012 Magnetic Particle Feedwater FWS-037A-FW012AA/AD Magnetic Particle Feedwater FWS-037A-FW008AA/DD Magnetic Particle SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor Water WCS-006B2-XI-SW004 Ultrasonic Cleanup Standby Liquid SLS-037D-FW004 Ultrasonic Control Residual Heat RHS-034B-FW003 Ultrasonic Removal Reactor Coolant RCS-800CX-SW018B Ultrasonic Main Steam MSS-900A3-FWD05 Ultrasonic Reactor Core ICS-001B-FW004 Ultrasonic Isolation Cooling Feedwater FWS-038A-SW012 Ultrasonic Core Spray-Low CSL-043B-FW001 Ultrasonic Core Spray-High CSH-041A-FW005 Ultrasonic Feedwater FWS-037A-SW019 Ultrasonic Main Steam MSS-900A2-FWD04 Ultrasonic Reactor Coolant RCS-800CX-SW018A Ultrasonic Residual Heat RHS-034B-FW002 Ultrasonic Removal Standby Liquid SLS-037D-FW003A Ultrasonic Control Reactor Water WCS-006B2-XI-FW011 Ultrasonic Cleanup During the review and observation of each examination, the inspectors verified that activities were performed in accordance with the ASME Code requirements and applicable procedures. The inspectors also verified the qualifications of all nondestructive examination technicians performing the inspections were current.

The inspectors reviewed three welds on pressure retaining risk significant systems.

The inspectors reviewed records for the following welding activities:

SYSTEM WELD IDENTIFICATION WELD TYPE Leakage Control LSV-SP1B Gas Tungsten Arc Penetration Valve Standby Diesel EGS-EG1A Gas Tungsten Arc Generator Leakage Control LSV-LS28B Single Metal Arc Penetration Valve The inspectors verified that the welding procedure specifications and the welders had been properly qualified in accordance with ASME Code,Section IX, requirements. The inspectors also verified that essential variables were identified, recorded in the procedure qualification record, and formed the bases for qualification of the welding procedure specifications. Specific documents reviewed during this inspection are listed in the attachment.

These actions constitute completion of the requirements for Section 02.01.

b. Findings

No findings were identified.

.5 Identification and Resolution of Problems (71111.08-02.05)

a. Inspection scope

The inspectors reviewed 13 condition reports associated with inservice inspection activities, and determined that the corrective actions taken were appropriate. The inspectors concluded that the licensee has an appropriate threshold for entering inservice inspection issues into the corrective action program, and has procedures that direct a root cause evaluation when necessary. The licensee also has an effective program for applying inservice inspection industry operating experience. Specific documents reviewed during this inspection are listed in the attachment.

These actions constitute completion of the requirements of Section 02.05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Quarterly Review of Licensed Operator Requalification Program

a. Inspection Scope

On January 22, the inspectors observed a crew of licensed operators in the plants simulator during requalification testing. The inspectors assessed the following areas:

Licensed operator performance The ability of the licensee to administer the evaluations and the quality of the training provided The modeling and performance of the control room simulator The quality of post-scenario critiques These activities constitute completion of one quarterly licensed operator requalification program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Quarterly Observation of Licensed Operator Performance

a. Inspection Scope

On February 22, the inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity due to shutdown for refueling outage 17 and fuel movement.

In addition, the inspectors assessed the operators adherence to plant procedures, including EN-OP-115, Conduct of Operations, Revision 013 and other operations department policies.

These activities constitute completion of one quarterly licensed-operator performance sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

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

System 512 - control room panels System 552 - containment atmosphere monitoring The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

Implementing appropriate work practices Identifying and addressing common cause failures Scoping of systems in accordance with 10 CFR 50.65(b)

Characterizing system reliability issues for performance Charging unavailability for performance Trending key parameters for condition monitoring Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)

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

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

These activities constitute completion of two quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05.

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR 50.65(a)(1)

(maintenance rule) associated with the failure to monitor the performance of the floor and equipment drains system against licensee-established goals.

Description.

Inside the drywell, leakage from the reactor coolant system pressure boundary is detected by independently monitored variables, such as sump level changes, drywell gaseous levels, and particulate radioactivity levels. The primary means of quantifying leakage in the drywell involves a leakage process computer, DER-KC174, which monitors the drywell floor and pedestal drain sump. The computer calculates drywell leakage and starts/stops sump pumps in the drywell to control sump level. It also will activate an alarm if it detects an abnormal condition. The inspectors challenged two of the licensees functional failure assessments associated with the Leakage Process Computer. Specifically:

Condition Report CR-RBS-2010-05306 documented that the reactor floor drain pump would not automatically stop at the required level set point. The maintenance rule function was lost because the process computer could not automatically control pedestal sump pump operation.

Condition Report CR-RBS-2009-05361 documented that during a surveillance test, the drywell floor drain, DFR-DNF1101, failed to achieve the specified drain rate due to blockages caused by foreign material in the drain piping. The maintenance rule function was lost because drain flow rate prevented the Leakage Process Computer from determining an accurate and timely reactor coolant unidentified leak rate.

After reviewing the inspectors challenges, the licensee initiated CR-RBS-2013-00295, corrected the maintenance rule functional failure classifications for these two condition reports and placed the floor and equipment drains system in maintenance rule (a)(1)status. The licensee identified that the computer had failed to perform its functions twice within an 18-month interval. As a result, the floor and equipment drains system had exceeded its performance criteria of one functional failure in an 18-month period, and should have been in maintenance rule a(1) status from October 12, 2009, to approximately April 12, 2011.

Analysis.

The failure to adequately monitor the performance of the floor and equipment drains system was a performance deficiency. This performance deficiency was more than minor and is therefore a finding because if left uncorrected, the failure to adequately monitor the performance of the floor and equipment drains system would have the potential to lead to a more significant safety concern. Specifically, the failure to adequately monitor the performance of that system could lead to an undetected and therefore unresolved degradation in system availability. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process For Findings At-Power, the inspectors determined that the finding is of very low safety significance (Green) because the finding:

(1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality;

(2) did not represent a loss of system and/or function; (3)did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than its technical specification allowed outage time; and

(4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety significance in accordance with the licensees maintenance rule program. No cross-cutting aspect was assigned because the finding does not represent current performance.

Enforcement.

10 CFR 50.65(a)(1) requires, in part, that holders of an operating license shall monitor the performance or condition of systems, structures, and components within the scope of the rule against licensee-established goals in a manner sufficient to provide reasonable assurance that such systems, structures, and components are capable of fulfilling their intended safety functions. 10 CFR 50.65(a)(2) requires, in part, that monitoring specified in paragraph (a)(1) is not required where it has been demonstrated the performance or condition of a system, structure, and component is being effectively controlled through appropriate preventive maintenance, such that the system, structure, and component remains capable of performing its intended function.

Contrary to the above, from October 12, 2009, to April 12, 2011, the licensee failed to demonstrate that the performance or condition of the floor and equipment drains system had been effectively controlled through the performance of appropriate preventive maintenance and did not monitor the system against licensee-established goals.

Specifically, the licensee failed to identify two maintenance preventable functional failures of the floor and equipment drains system, which demonstrated that the performance or condition of this system was not was not being effectively controlled through the performance of appropriate preventative maintenance and, as a result, that goal setting and monitoring was required. This violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensees corrective action program as Condition Report CR-RBS-2013-00295 (NCV 05000458/2013002-01, Failure to Monitor the Performance of the Floor and Equipment Drains System).

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

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

Emergent work in Fancy Point switchyard to investigate opened generator output breaker, January 17 Risk due to fire water out of service in tunnels and radwaste building, January 18 Planned maintenance on the station blackout diesel and surveillance testing on the Division 3 emergency diesel generator, January 28 Planned maintenance on the Division 1 battery charger while moving scaffold material in the main transformer yard, February 6 Emergent work to troubleshoot reactor core isolation cooling minimum flow valve cycling with residual heat removal Division 1 out of service for quarterly surveillance, February 7 Risk due to severe weather and yellow outage risk condition, February 25 The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of six maintenance risk assessments and emergent work control inspection samples as defined in Inspection Procedure 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Evaluations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed the following assessments:

CR-RBS-2012-07027, pressure control valve, SWP-PVY32A, damaged seat, reviewed on January 23 CR-RBS-2012-04063, residual heat removal pump minimum flow valve tripped when valve opened, reviewed on January 24 CR-RBS-2013-00560, Division 3 emergency diesel generator fuel oil foreign material exclusion, reviewed on February 1 CR-RBS-2013-01661, refuel platform main hoist emergency brake engaged (refueling outage 17), reviewed on February 27 CR-RBS-2013-02182, refuel platform main hoist emergency brake slow to operate (refueling outage 17), reviewed on March 6 CR-RBS-2013-02569, control rod 48-17 failed to settle at target position, reviewed on March 26 The inspectors selected these operability and functionality assessments based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure technical specification operability was properly justified and to verify the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and Updated Safety Analysis Report to the licensees 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. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations.

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

These activities constitute completion of six operability evaluations inspection samples as defined in Inspection Procedure 71111.15-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

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

WO-00321421, "HVY-PV32A Rebuild and Installation, reviewed on February 20 WO-00313939, "HVK-TV17B Slow to Operate / Gagged Full Open, reviewed on March 7 WO-00339910, "SWP-P2D Packing was Found Hot During Run, reviewed on March 13 WO-00323591, "E51-SOV005 Remove and Replace the Solenoid Operated Valve," reviewed on March 25 WO-00343651, "HVK-CHL-1D Control building Ciller Water Chiller 1D Motor Didn't Start," reviewed on March 26 The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following (as applicable):

The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate The inspectors evaluated the activities against the technical specifications, the Updated Safety Analysis Report, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five post-maintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

The inspectors reviewed the outage safety plan and contingency plans for refueling outage 17, conducted February 16 to March 21, to confirm that licensee personnel had appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense in depth.

During the refueling outage, the inspectors observed portions of the shutdown and cooldown processes and monitored licensee controls over the outage activities listed below.

Configuration management, including maintenance of defense in depth, is commensurate with the outage safety plan for key safety functions and compliance with the applicable technical specifications when taking equipment out of service.

Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication, accounting for instrument error.

Status and configuration of electrical systems to ensure that technical specifications and outage safety-plan requirements were met, and controls over switchyard activities.

Monitoring of decay heat removal processes, systems, and components.

Verification that outage work was not impacting the ability of the operators to operate the spent fuel pool cooling system.

Reactor water inventory controls, including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss.

Controls over activities that could affect reactivity.

Maintenance of primary containment as required by the technical specifications.

Refueling activities, including fuel handling and sipping to detect fuel assembly leakage.

Startup and ascension to full power operation, tracking of startup prerequisites, walkdown of the drywell (primary containment) to verify that debris had not been left which could block emergency core cooling system suction strainers, and reactor physics testing.

Licensee identification and resolution of problems related to refueling outage activities.

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

These activities constitute completion of one refueling outage and other outage inspection sample as defined in Inspection Procedure 71111.20-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

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

Preconditioning Evaluation of testing impact on the plant Acceptance criteria Test equipment Procedures Jumper/lifted lead controls Test data Testing frequency and method demonstrated technical specification operability Test equipment removal Restoration of plant systems Fulfillment of ASME Code requirements Updating of performance indicator data Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct Reference setting data Annunciators and alarms setpoints The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

STP-209-6310, Revision 38, RCIC Quarterly Pump and Valve Operability Test, performed on January 18 (inservice test)

STP-053-3001, Revision 20, Jet Pump Operability Test, performed on January 18 (routine)

STP-403-0603, Revision 7, Division 1 Standby Gas Treatment System Functional Test, performed on January 18 (routine)

STP-256-6305, Revision 96, Division 1 Standby Service Water Quarterly Valve Operability Test, performed on February 6 (inservice test)

STP-309-0601, Revision 43, Division 1 ECCS Test, performed on February 27 (routine)

TSP-0021, Revision 6, Containment Monitoring System Leak Test, performed on March 6 (routine)

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

These activities constitute completion of six surveillance testing inspection samples as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP4 Emergency Action Level and Emergency Plan Changes (IP 71114.04)

a. Inspection Scope

The NSIR headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures (EPIPs) and the Emergency Plan located under ADAMS accession numbers ML12354A521 and ML13014A041 as listed in the attachment.

The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.04-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on January 22, 2013, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the postevolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

This area was inspected to:

(1) review and assess licensees performance in assessing the radiological hazards in the workplace associated with licensed activities and the implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures,

(2) verify the licensee is properly identifying and reporting Occupational Radiation Safety Cornerstone performance indicators, and

(3) identify those performance deficiencies that were reportable as a performance indicator and which may have represented a substantial potential for overexposure of the worker.

The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensees procedures required by technical specifications as criteria for determining compliance. During the inspection, the inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspectors performed walkdowns of various portions of the plant, performed independent radiation dose rate measurements and reviewed the following items:

Performance indicator events and associated documentation reported by the licensee in the Occupational Radiation Safety Cornerstone The hazard assessment program, including a review of the licensees evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity, and surface contamination levels Instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability Radiological hazards control and work coverage, including the adequacy of surveys, radiation protection job coverage, and contamination controls; the use of electronic dosimeters in high noise areas; dosimetry placement; airborne radioactivity monitoring; controls for highly activated or contaminated materials (non-fuel) stored within spent fuel and other storage pools; and posting and physical controls for high-radiation areas and very high-radiation areas Radiation worker and radiation protection technician performance with respect to radiation protection work requirements Audits, self-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.01-05.

.1 Failure to Request Briefings of the Dose Rates in High-Radiation Areas Before Entry

Introduction.

The inspectors reviewed two examples a self-revealing green, non-cited violation of Technical Specification 5.7.1 that resulted because individuals failed to request briefings of the dose rates in high-radiation areas before entry. The violation had very low safety significance.

Description.

On December 12, 2012, one of three instruments and controls technicians received an unanticipated electronic dosimeter dose rate alarm when he/she entered a high-radiation area on the 114-foot elevation of the reactor building while performing a scram discharge volume water level channel functional test. The individual entered a dose rate of 211 millirems per hour, but had not been briefed on the dose rates in the area. The individual worked in accordance with Radiation Work Permit 20121004, Task 1, which did not allow work in high-radiation areas. A high-radiation area is an area with dose rates greater than 100 millirems per hour at 30 centimeters from the source of the radiation. The occurrence was documented in Condition Report 2012-07643. Licensee personnel reviewed the occurrence and determined job site reviews and peer checking of the work area failed to note the high-radiation area enclosing the work area. Neither the workers or the radiation protection personnel questioned the use of Task 1. As corrective action, licensee personnel enhanced the training for new nuclear workers and revised the surveillance procedure used by the instruments and controls technicians for this particular functional test to add a precaution that this level switch was in a high-radiation area.

On February 21, a worker received an unanticipated electronic dosimeter dose rate alarm on the 141-foot elevation of the drywell. The individual entered a dose rate of 453 millirems per hour, but had only been briefed for a dose rate of 40 millirems per hour on the 95-foot elevation of the drywell, according to licensee personnel. The individual worked in accordance with Radiation Work Permit 20131932, Task 1. The dose rate setpoint was 300 millirems per hour. The occurrence was documented in Condition Report 2013-01275. The workers access to the radiological controlled area was restricted and the worker was coached on the proper practice. Licensee personnel investigated the occurrence and found that the worker was redirected by his/her supervisor to another location and the worker did not self-check and request another briefing. The worker and supervisor were coached on acceptable radiation work practices.

Analysis.

The failure to request briefings of the dose rates in high-radiation areas before entry is a performance deficiency. The requirement not met was Technical Specification 5.7.1. The significance of the performance deficiency was more-than-minor because it was associated with the Occupational Radiation Safety Cornerstone attribute of program and process (exposure control) and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation because the failure exposed workers to higher than anticipated radiation dose rates. The Occupational Radiation Safety Cornerstone was affected; therefore, the inspectors used Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, to determine the significance of the violation. The violation had very low safety significance because:

(1) it was not an as low as is reasonably achievable finding,

(2) there was no overexposure,

(3) there was no substantial potential for an overexposure, and

(4) the ability to assess dose was not compromised. This violation had a cross-cutting aspect in the human performance area, associated with the work practices component, because licensee personnel failed to use human error prevention techniques, such as self- and peer-checking, commensurate with the risk of the assigned task such that work activities were performed safely H.4(a).

Enforcement.

Technical Specification 5.7.1 requires individuals entering an area with radiation dose rates greater than 100 millirems per hour be aware of the dose rates prior to entry. Contrary to the above, licensee personnel entered areas with radiation dose rates greater than 100 millirems per hour without being aware of the dose rates.

Specifically, on December 12, 2012, an individual entered an area with a dose rate of 211 millirems per hour on the 114-foot elevation of the reactor building without being briefed on dose rates in the area. On February 21, an individual entered an area on the 141-foot elevation of the drywell with a dose rate of 453 millirems per hour, but had only been briefed for a dose rate of 40 millirems per hour on the 95-foot elevation of the drywell. The workers were coached on the acceptable radiation protection practice and training content was enhanced as determined appropriate by the licensee. This violation was being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy.

The violation was entered into the licensees corrective action program as Condition Reports CR-RBS-2012-07643 and CR-RBS-2013-01275. (NCV 05000458/2013002-02, Failure to Request Briefings of the Dose Rates in High-Radiation Areas Before Entry)

.2 Failure of a Radiation Protection Technician to Provide Adequate Job Coverage

Introduction.

The inspectors reviewed a self-revealing, non-cited green, violation of Technical Specification 5.7.1 that resulted because a radiation protection technician failed to provide adequate job coverage. The violation had very low safety significance.

Description.

On January 25, an operator and a radiation protection technician entered the offgas recombiner room on the 123-foot elevation of the turbine building. The area was controlled as a locked high-radiation area, an area with dose rates greater than 1000 millirems per hour at 30 centimeters from the source of the radiation. The radiation protection technicians responsibility was to perform radiation surveys, determine dose rates in the area, and inform the operator before the operator entered the area, as required by Technical Specification 5.7.1.b and to provide positive control over activities within the area, as required by Technical Specification 5.7.1.c. However, the radiation protection technician did not provide positive control until he/she determined the dose rates in the area, and both the individuals entered the offgas combiner room and received unanticipated electronic dosimeter alarms. The radiation protection technicians dosimeter indicated a maximum dose rate of 1,190 millirems per hour and the operators dosimeter indicated a maximum dose rate of 1,350 millirems per hour.

Licensee personnel documented the occurrence in Condition Report 2013-00479 and performed an investigation. They determined the radiation protection technician did not extend the extendable radiation survey instrument because he/she did not expect to see dose rates as high as were encountered. The radiation protection technician did not instruct the operator to stay at the entryway until dose rates were determined. Licensee representatives concluded the radiation protection technician was overconfident regarding the coverage and did not expect to see dose rates higher than 500 millirems per hour. Also, the radiation protection technician did not communicate to the operator to ensure the operator waited until the dose rates were determined before entering.

Analysis.

The failure to provide adequate radiation protection job coverage was a performance deficiency. The requirement not met was Technical Specification 5.7.1.

The significance of the performance deficiency was more-than-minor because it was associated with the Occupational Radiation Safety Cornerstone attribute of program and process (exposure control) and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation because the failure exposed workers to higher than anticipated radiation dose rates. The Occupational Radiation Safety Cornerstone was affected; therefore, the inspectors used Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, August 19, 2008, to determine the significance of the violation.

The violation had very low safety significance because:

(1) it was not an as low as is reasonably achievable finding,

(2) there was no overexposure,

(3) there was no substantial potential for an overexposure, and

(4) the ability to assess dose was not compromised. This violation had a cross-cutting aspect in the human performance area, associated with the decision making component, because licensee personnel did not make a risk-significant decision using a systematic process when faced with uncertain or unexpected plant conditions H.1(a).

Enforcement.

Technical Specification 5.7.1 requires individuals entering an area with radiation dose rates greater than 100 millirems per hour enter into such areas after the personnel are aware of the dose rates. Contrary to the above, licensee personnel entered an area with radiation dose rates greater than 100 millirems per hour without being aware of the dose rates. Specifically, on January 25, an operator and a radiation protection technician entered the offgas recombiner room on the 123-foot elevation of the turbine building, an area with dose rates of 1190 to 1350 millirems per hour, without being aware of the dose rates in the area. This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy, because it was of very low safety significance and was entered into the licensees corrective action program as Condition Report CR-RBS-2013-00479 to address recurrence (NCV 05000458/2013002-03, Failure of a Radiation Protection Technician to Provide Adequate Job Coverage).

2RS2 Occupational ALARA Planning and Controls

a. Inspection Scope

This area was inspected to assess performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensees procedures required by technical specifications as criteria for determining compliance. During the inspection, the inspectors interviewed licensee personnel and reviewed the following items:

Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site-specific trends in collective exposures, and source-term measurements ALARA work activity evaluations/postjob reviews, exposure estimates, and exposure mitigation requirements The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies Records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high-radiation areas Audits, self-assessments, and corrective action documents related to ALARA planning and controls since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.02-05.

b. Findings

Introduction.

The inspectors reviewed a self-revealing, Green finding associated with the licensees failure to provide adequate procedures for installing a seal on reactor water cleanup (RWCU) A pump. The finding had very low safety significance.

Description.

On December 4, 2011, while adding oil to the RWCU A pump (G33-PC001A), licensee personnel identified seal leakage at a rate of approximately one quart per minute. Several days later, the licensee identified a rise in the leak rate to about 0.5 gallons per minute. On January 3, 2012, the licensee initiated another work order request and properly replaced the pump seal with vendor oversight.

To install the new seal, mechanics followed the installation procedure provided to them in work order 180842. That work order directed the workers to install the seal into a blind gland after the impeller nut was installed and fully torqued. However, it did not require the workers to ensure that the seal was fully inserted prior to torquing the impeller nut, and installing the impeller and impeller nut prior to ensuring that the seal was fully inserted allowed the seal cartridge to rotate during the torquing steps which mispositioned the anti-rotation pin in relation to the pin guide. This rotation ultimately bent the anti-rotation pin and dislodged the pin from the machined guide. Once the pin was deformed, it caused the mating surfaces of the sealing faces to shift, resulting in a gap that allowed the seal to leak. That leak prompted licensee personnel to rework the seal replacement on January 3, 2012 with vendor oversight.

The licensee used Radiation Work Permit (RWP) 2011-1096 and RWP 2012-1096 to perform this work. The original dose estimate was 3.871 person-rem. However, because of the re-work, a total of 6.343 person-rem was accrued for both seal installations in December 2011 and January 2012.

The licensees apparent-cause evaluation of this incident is documented in condition report CR-RBS-2011-09015, which determined that the work instructions had inappropriately delayed verification of the seal installation until after the impeller and impeller nut was installed and fully torque. In that condition report, the licensee developed corrective actions to Revise all RWCU procedures and model work orders to verify seal engagement prior to torquing the impeller nut.

The inspector therefore determined that the increased collective dose was due to the licensees failure to provide adequate work instructions for installing RWCU pump seals.

That failure was inconsistent with licensee expectations described in maintenance Procedure EN-MA-101, Fundamentals of Maintenance, Revision 13, which states, in part, that maintenance personnel are expected to accomplish assigned work with the highest quality, striving to do it right the first time.

Analysis.

The failure to provide adequate work instructions for installing RWCU pump seals is a performance deficiency with respect to the licensees expectations described in Procedure EN-MA-101. The performance deficiency was more-than-minor because it was associated with the Occupational Radiation Safety Cornerstone attribute of program and process (exposure control) and affected the cornerstone objective, in that it caused increased collective radiation dose for occupational workers. Additionally, the finding was similar to example 6(i) in Appendix E to Manual Chapter 0612, Power Reactor Inspection Reports - Examples of Minor Issues. This example states that an issue is more-than-minor if it results in a collective dose greater than 5 person-rem, and the actual dose exceeds the estimated dose by greater than 50 percent. Using Manual Chapter 0609, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, the inspectors determined the finding had very low safety significance because, although the finding involved ALARA planning and work controls, the licensees latest three-year rolling average collective dose was less than 240 person-rem. This finding had a cross-cutting aspect in the human performance area, associated with the resources component, because the licensee failed to use complete, accurate, and up-to-date procedures and work orders to perform the seal installation, which resulted in unnecessary dose H.2(c).

Enforcement.

This finding does not involve enforcement action because no violation of a regulatory requirement was identified. Because this finding does not involve a violation and is of very low safety significance, it is identified as a finding (FIN 05000458/2013002-04, Failure to Provide Adequate Work Instructions for Installing Reactor Water Cleanup Pump Seals).

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the licensee for the fourth quarter 2012 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, Performance Indicator Program.

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

b. Findings

No findings were identified.

.2 Unplanned Scrams per 7000 Critical Hours (IE01)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical hours performance indicator for the period from the first quarter 2012 through the fourth quarter 2012. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator narrative logs, issue reports, event reports, and NRC integrated inspection reports for the period of January 2012 through December 2012 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one unplanned scrams per 7000 critical hours sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.3 Unplanned Power Changes per 7000 Critical Hours (IE03)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned power changes per 7000 critical hours performance indicator for the period from the first quarter 2012 through the fourth quarter 2012. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator narrative logs, issue reports, maintenance rule records, event reports, and NRC integrated inspection reports for the period of January 2012 through December 2012 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one unplanned power changes per 7000 critical hours sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.4 Unplanned Scrams with Complications (IE04)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned scrams with complications performance indicator for the period from the first quarter 2012 through the fourth quarter 2012. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator narrative logs, issue reports, event reports, and NRC integrated inspection reports for the period of January 2012 through December 2012 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one unplanned scrams with complications sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.5 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

The inspectors reviewed performance indicator data for the second quarter of 2012 through the fourth quarter of 2012. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods. The inspectors used the definitions and clarifying notes contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for determining whether the licensee was in compliance.

The inspectors reviewed corrective action program records associated with high-radiation area (greater than 1 rem/hr) and very high-radiation area non-conformances.

The inspectors reviewed radiological, controlled area exit transactions greater than 100 mrem. The inspectors also conducted walkdowns of high-radiation areas (greater than 1 rem/hr) and very high-radiation area entrances to determine the adequacy of the controls of these areas.

These activities constitute completion of the occupational exposure control effectiveness sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.6 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual

Radiological Effluent Occurrences (PR01)

a. Inspection Scope

The inspectors reviewed performance indicator data for the second quarter of 2012 through the fourth quarter of 2012. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods. The inspectors used the definitions and clarifying notes contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for determining whether the licensee was in compliance.

The inspectors reviewed the licensees corrective action program records and selected individual annual or special reports to identify potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose.

These activities constitute completion of the radiological effluent technical specifications/offsite dose calculation manual radiological effluent occurrences sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions.

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

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

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

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

b. Findings

No findings were identified.

4OA5 Other Activities

.1 (Closed) Temporary Instruction (TI) 2515/187, Inspection of Near-Term Task Force

Recommendation 2.3 Flooding Walkdowns

a. Inspection Scope

The inspectors verified that licensees walkdown package WP-1, Auxiliary Building South Wall Below Elevation 96 00 and Applicable Portions of D-Tunnel, contained the elements as specified in NEI 12-07 Walkdown Guidance document.

The inspectors accompanied the licensee on October 23, 2012 on their walkdown of the Auxiliary Building, 70 foot elevation, south wall and verified that the licensee confirmed the following flood protection features:

Visual inspection of the flood protection feature was performed if the flood protection feature was relevant. External visual inspection for indications of degradation that would prevent its credited function from being performed was performed.

Critical structures, systems, and components dimensions were measured Available physical margin, where applicable, was determined Flood protection feature functionality was determined using either visual observation or by review of other documents The inspectors independently performed their walkdown of the Control Building south wall below elevation 96 foot elevation and verified that the following flood protection features were in place:

Visual inspection of the flood protection feature was performed if the flood protection feature was relevant. External visual inspection for indications of degradation that would prevent its credited function from being performed was performed.

Critical structures, systems, and components dimensions were measured Available physical margin, where applicable, was determined Flood protection feature functionality was determined using either visual observation or by review of other documents The inspectors verified that noncompliances with current licensing requirements, and issues identified in accordance with the 10 CFR 50.54(f) letter, Item 2.g of Enclosure 4, were entered into the licensee's corrective action program. In addition, issues identified in response to Item 2.g that could challenge risk significant equipment and the licensees ability to mitigate the consequences will be subject to additional NRC evaluation.

b. Findings

No findings were identified.

.2 (Closed) Temporary Instruction (TI) 2515/188, Inspection of Near-Term Task Force

Recommendation 2.3 Seismic Walkdowns

a. Inspection Scope

The inspectors accompanied the licensee on their seismic and area walkdowns of the standby switchgear room motor control center EHS-MCC8B in the control building 98 elevation on October 10th and 11th, 2012. The inspectors verified that the licensee confirmed that the following seismic features associated with motor control center EHS-MCC8B were free of potential adverse seismic conditions:

Anchorage was free of bent, broken, missing or loose hardware.

Anchorage was free of corrosion that is more than mild surface oxidation.

Anchorage was free of visible cracks in the concrete near the anchors.

Anchorage configuration was consistent with plant documentation.

SSCs will not be damaged from impact by nearby equipment or structures.

Overhead equipment, distribution systems, ceiling tiles and lighting, and masonry block walls are secure and not likely to collapse onto the equipment.

Attached lines have adequate flexibility to avoid damage.

The area appears to be free of potentially adverse seismic interactions that could cause flooding or spray in the area.

The area appears to be free of potentially adverse seismic interactions that could cause a fire in the area.

The area appears to be free of potentially adverse seismic interactions associated with housekeeping practices, storage of portable equipment, and temporary installations (e.g., scaffolding, lead shielding).

On November 30, 2012, the inspectors independently performed walkdowns and verified all of seismic features as specified in the EPRI guidance document for the licensees inspection of the following equipment:

ENB-PNL02A, 125V DC Panel, Control Building 136 elevation SWP-AOV599, SCT Station Blackout SWP return valve, G tunnel 67 elevation ENB-MCC1, Motor Control Center, Aux Building 95 elevation ENB-INV01B, Vital Bus B Inverter, Control building 98 elevation Observations made during the walkdown that could not be determined to be acceptable were entered into the licensees corrective action program for evaluation. Additionally, inspectors verified that items that could allow the spent fuel pool to drain down rapidly were added to the SWEL and these items were walked down by the licensee.

b. Findings

No NRC-identified or self-revealing findings were identified.

.3 Temporary Instruction (TI) 2515/182, Review of the Implementation of the Industry

Initiative to Control Degradation of Underground Piping and Tanks

a. Inspection Scope

The licensees buried piping and underground piping and tanks program was inspected in accordance with paragraphs 03.01.a through 03.01.c of the TI and was found to meet all applicable aspects of NEI 09-14, Revision 1, as set forth in Table 1 of the TI.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On March 1, the inspectors presented the results of the radiation safety inspections to Mr. Eric Olson, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified. The inspectors conducted subsequent discussions with licensee personnel concerning changes in the characterization of a finding, concluding with a telephone conversation with Ms. K. Huffstatler, Senior Licensing Specialist, on April 3.

On March 19, the inspector presented the inspection results of the review of inservice inspection activities to Mr. J. Roberts, Director, Nuclear Safety Assurance, and other members of the licensee staff. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On April 4, the inspectors presented the integrated inspection results to Mr. Eric Olson, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Barkowski, Quality Assurance

J. Boulanger, Manager, Maintenance

M. Briley, Engineering

D. Burnett, Manager, Emergency Preparedness

G. Bush, Manager, Material, Procurement, and Contracts

M. Chase, Manager, Training

J. Clark, Manager, Licensing

C. Coleman, Manager, Engineering Programs & Components

F. Corley, Manager, Design Engineering

R. Creel, Superintendent, Plant Security

T. Evans, Manager, Operations

M. Feltner, Manager, Production

A. Fredieu, Manager, Outage

R. Gadbois, General Manager, Plant Operations

T. Gates, Assistant Operations Manager - Shift

K. Hallaran, Manager, Chemistry

D. Hebert, Engineering

K. Huffstatler, Senior Licensing Specialist

B. Kienlen, Engineering

G. Krause, Assistant Operations Manager - Training

P. Lucky, Manager, Corrective Actions and Assessments

J. Maher, Manager, System Engineering

W. Mashburn, Director, Engineering

D. Moore, Corporate Manager, Radiation Protection

E. Neal, Superintendent, Radiation Protection

E. Olson, Site Vice President

J. Roberts, Director, Nuclear Safety Assurance

T. Santy, Manager, Security

T. Shenk, Assistant Operations Manager - Support

J. Vukovics, Supervisor, Reactor Engineering

J. Wieging, Manager, Planning and Scheduling, Outages

L. Woods, Manager, Quality Assurance

Attachment 1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

Review of the Implementation of the Industry Initiative to 2515/182 TI Control Degradation of Underground Piping and Tanks

Opened and Closed

Failure to Monitor the Performance of the Floor and

05000458/2013002-01 NCV Equipment Drains System (Section 1R12)

Failure to Request Briefings of the Dose Rates in High-

05000458/2013002-02 NCV Radiation Areas Before Entry (Section 2RS1)

Failure of a Radiation Protection Technician to Provide

05000458/2013002-03 NCV Adequate Job Coverage

05000458/2013002-04 FIN Failure to Properly Perform a Maintenance Activity (2RS2)

Closed

Inspection of Near-Term Task Force Recommendation 2.3 2515/187 TI Flooding Walkdowns Inspection of Near-Term Task Force Recommendation 2.3 2515/188 TI Seismic Walkdowns