IR 05000483/2012004

IR 05000483-12-004; Union Electric Company; 06/27/2012 - 09/25/2012; Callaway Plant, NRC Integrated Inspection Report

ML12311A097
Person / Time
Site:	Callaway
Issue date:	11/05/2012
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-B
To:	Heflin A Union Electric Co
O'Keefe N
References
IR-12-004
Download: ML12311A097 (60)

Text

UNITED STATES ber 5, 2012

SUBJECT:

CALLAWAY PLANT - NRC INTEGRATED INSPECTION REPORT 05000483/2012004

Dear Mr. Heflin:

On September 25, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. The enclosed inspection report documents the inspection results which were discussed on September 27, 2012, with Mr. F. Diya, Vice President Nuclear Operations, and other members of your staff.

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

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

One NRC-identified finding and one self-revealing finding of very low safety significance (Green)

were identified during this inspection. Both of these findings were determined to involve violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you disagree with a cross-cutting aspect assignment in this report, or 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 the Callaway Plant.

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/

Neil O'Keefe, Chief Project Branch B Division of Reactor Projects Docket No.: 50-483 License No: NPF-30 Enclosure: Inspection Report 05000483 w/ Attachment 1: Supplemental Information Attachment 2: Request for Information for Occupational Radiation Safety Inspection cc w/ encl: Electronic Distribution

SUMMARY OF FINDINGS

IR 05000483/2012004; 06/27 - 09/25/2012, Callaway Plant, Integrated Resident and Regional

Report; Operability Evaluations and Functionality Assessments and Radiological Hazard Assessment and Exposure Controls The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by region-based inspectors. Two Green non-cited violations 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 Part 50,

Appendix B, Criterion XVI, "Corrective Action," involving the licensees failure to correct an adverse condition on a safety related system. Specifically, when a low oil condition was identified on an emergency diesel generator governor, the licensee fixed the symptom by adding oil, but failed to correct the condition by stopping the leak. This issue was entered into the licensees corrective action program as Callaway Action Request 201206798.

Failure to correct an adverse condition on a safety related system was a performance deficiency. This finding was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Manual Chapter 0609, Appendix A, Exhibit 2,

Mitigating Systems Screening Questions, the finding was determined to be of very low safety concern because it affected the qualification of a mitigating system, but the affected train was still able to meet its PRA mission time. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution associated with the Corrective Action Program component because the licensee failed to thoroughly evaluate the problem such that the resolutions address causes including properly classifying, prioritizing, and evaluating for operability and reportability conditions adverse to quality P.1(c). (Section 1R15)

Cornerstone: Occupational Radiation Safety

Green.

The inspectors reviewed a self-revealing non-cited violation of Technical Specification 5.4.1.a, because a worker did not follow radiation work permit instructions. Specifically, an individual entered an area with radiation dose rates significantly higher than the areas on which he was briefed. As corrective action, the licensee coached the individual on the radiation work permit instructions and the licensees expected radiation worker behavior. This was documented in the licensees corrective action program as Callaway Action Request 201108483.

The failure to follow radiation work permit instructions is a performance deficiency. The performance deficiency was more than minor because, if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Using the Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding 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 finding had a crosscutting aspect in the human performance area, work practices component, in that the worker failed to use error prevention techniques, such as self-checking H.4(a). (Section 2RS1)

Licensee-Identified Violations

None

REPORT DETAILS

Summary of Plant Status

Callaway operated at 100 percent power for the duration of the inspection period with the exception of planned power reductions for routine surveillance testing.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

Partial Walkdown

a. Inspection Scope

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

• August 11, 2012, high pressure safety injection train A

• August 28, 2012, emergency diesel generator train A

• September 8, 2012, containment spray train B

• September 18, 2012, component cooling water pump B 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, Final 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 Attachment 1.

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

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:

• July 8, 2012, turbine building during fire loop outage, fire area T-2

• July 20, 2012, emergency exhaust equipment rooms trains A and B, fire areas F-6 and F-7

• July 23, 2012, fire pump house during announced fire drill, fire area S-8

• September 1, 2012, south electrical penetration room, fire area A-17

• September 8, 2012, containment spray pump room train B, fire area A-4B The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in Attachment 1, 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 Attachment 1.

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

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 August 14, 2012, 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

• The modeling and performance of the control room simulator

• The quality of post-scenario critiques

• Follow-up actions taken by the licensee for identified discrepancies Specific documents reviewed during this inspection are listed in Attachment 1.

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 August 8 and 11, 2012, 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 the evolutions listed below. The inspectors observed the operators performance of the following activities:

• August 8, 2012, high pressure coolant injection system train A valve strokes, reactor coolant system subcooling monitor train A troubleshooting, and alternate emergency power system testing

• August 11, 2012, reactor coolant system dilution and response to loss of interlock annunciator P-9 In addition, the inspectors assessed the operators adherence to plant procedures, including Procedure ODP-ZZ-00001, "Operations Department - Code of Conduct," and other operations department policies.

Specific documents reviewed during this inspection are listed in Attachment 1.

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:

• August 1, 2012, containment ventilation system

• August 9, 2012, review of periodic evaluation per 10 CFR 50.65a(3)

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

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

• Characterizing system reliability issues for performance monitoring

• Charging unavailability for performance monitoring

• 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 Attachment 1.

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

b. Findings

No findings were identified.

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:

• July 16, 2012, 120 volt non-safety inverter PN09 failure and troubleshooting, Job 12003592

• July 17, 2012, work on train B reactor vessel level indication system (protected train work), Job 12003350

• July 23, 2012, Yellow risk during train B pressurizer power operated relief valve block valve breaker maintenance, Job 07507305

• August 13, 2012, 120 volt safety-related inverter NN14 failure and troubleshooting, Job 12003827 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 Attachment 1.

These activities constitute completion of four 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:

• July 11, 2012, turbine-driven auxiliary feedwater pump trip throttle valve seat material qualification issue, Callaway Action Request 201204847

• July 30, 2012, containment normal sump level erratic indication, Callaway Action Request 201205304

• August 6, 2012, containment cooler B inlet temperature instrument failure, Callaway Action Request 201204954

• August 8, 2012, containment spray pump A room door seal leak, Callaway Action Request 201205597

• August 30, 2012, diesel generator A governor oil leak, Callaway Action Request 201201117 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 Final 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 Attachment 1.

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

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," involving the licensees failure to correct an adverse condition on a safety related system. Specifically, when a low oil condition was identified on an emergency diesel generator governor, the licensee fixed the symptom by adding oil, but failed to correct the condition by stopping the leak.

Description.

On February 3, 2012, while performing plant rounds, an operations technician identified a low oil level condition in the governor for emergency diesel generator A. The technician initiated Job 12000746 to add oil to the governor. Later that day, oil was added to the governor. On February 12, 2012, an operations technician again identified a low oil condition in the governor for emergency diesel generator A.

The technician initiated Job 12000905 to add oil to the governor. Upon hearing that the governor needed oil again within the short time frame, the system engineer initiated Callaway Action Request 201201117, performed a walkdown of the governor, and identified an oil leak coming from the drain of the governor. The oil leak was approximately one drop every five minutes. Job 12000924 was initiated to investigate and correct the leak. On February 14, 2012, the drain petcock valve was found to be slightly open. The drain petcock valve was tightened closed and oil was again added to the governor. Subsequent observation noted no additional leakage or oil loss.

A review of the oil leak identified, at the rate of loss with the oil level at the bottom of the sight glass, the diesel generator would operate normally for 3.4 days with an additional 2.9 days of degraded operation. After 6.3 days, the governor would no longer support diesel operation. The mission time for the emergency diesel generator is 7 days.

The inspectors noted that when the licensee first identified the low oil condition, the diesel generator would not have been able to support the full mission time and should have been considered inoperable. Once oil was added, the diesel was able to operate for its designed mission time. However, since the adverse condition was not corrected, the oil level lowered again rendering the diesel generator inoperable a second time.

Analysis.

The inspectors determined that the failure to correct an adverse condition on a safety related component was a performance deficiency. Specifically, when a low oil condition was identified on an emergency diesel generator, the licensee fixed the symptom by adding oil, but failed to correct the condition by stopping the leak. This finding is more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

The inspectors evaluated the finding in accordance with Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined the finding was of very low safety significance (Green) because it affected the qualification of a mitigating system, but the affected train was still able to meet its PRA mission time. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate the problem such that the resolutions address causes and extent of conditions, as necessary including properly classifying, prioritizing, and evaluating for operability and reportability conditions adverse to quality

P.1(c).

Enforcement.

Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to this, on February 3, 2012, the licensee did not correct an adverse condition on a safety related system. Specifically, when a low oil condition was identified on an emergency diesel generator, the licensee fixed the symptom by adding oil, but failed to correct the condition by stopping the leak. This caused the emergency diesel generator to become inoperable again due to inability to support the full mission time. Because this violation was of very low safety significance and was entered into the licensees corrective action program as Callaway Action Request 201206798, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000483/2012004-01, Failure to Correct an Adverse Condition on an Emergency Diesel Generator.

1R18 Plant Modifications

Permanent Modifications

a. Inspection Scope

The inspectors reviewed key parameters associated with, materials, replacement components, timing, equipment protection from hazards, operations, flow paths, pressure boundary, ventilation boundary, process medium properties, licensing basis, and failure modes for the permanent modification identified as MP 12-0019, Install Isolation Valves for the Circulation and Service Hydraulic Pump C, associated with the circulating water isolation valve hydraulic system.

The inspectors verified that modification preparation, staging, and implementation did not impair emergency/abnormal operating procedure actions, key safety functions, or operator response to loss of key safety functions; post modification testing will maintain the plant in a safe configuration during testing by verifying that unintended system interactions will not occur; systems, structures and components performance characteristics still meet the design basis; the modification design assumptions were appropriate; the modification test acceptance criteria will be met; and licensee personnel identified and implemented appropriate corrective actions associated with permanent plant modifications. Specific documents reviewed during this inspection are listed in

1. These activities constitute completion of one sample for plant modifications as defined in

Inspection Procedure 71111.18-05.

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:

• July 11, 2012, safety injection pump train A post-maintenance test, Job 1051509

• August 1, 2012, ultimate heat sink electrical room lighting breaker change, Job 07509139

• August 13, 2012, 120 volt safety-related inverter NN14 logic card replacement, Job 12003827

• August 20, 2012, 120 volt safety-related inverter NN14 component replacement, Job 12004372

• August 24, 2012, reactor vessel level indication system train B, Job 12003350 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:

• 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 Final 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 Attachment 1.

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.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the Final 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

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME Code requirements

• 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.

• July 5, 2012, emergency diesel generator B fast start routine test, Job 12500704

• July 12, 2012, alternate emergency power system diesel routine surveillance test, Job 12506361

• July 17, 2012, emergency exhaust fan A routine surveillance test, Job 12506838

• July 18, 2012, emergency fuel oil pump A routine surveillance test, Job 12504725

• August 20, 2012, 120 volt safety-related inverter NN14 outage test, Job 12004372

• September 24, 2012, shutdown purge system containment isolation verification, Job 12509180 Specific documents reviewed during this inspection are listed in Attachment 1.

These activities constitute completion of a total of six surveillance testing inspection samples, including one containment isolation and five routine surveillances, as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

1EP2 Alert and Notification System Evaluation

a. Inspection Scope

The inspectors discussed with licensee staff the operability of offsite siren emergency warning systems, tone alert radio systems, and backup notification and alerting methods, to determine the adequacy of licensee methods for testing the alert and notification system in accordance with 10 CFR Part 50, Appendix E. The licensee's alert and notification system testing program was compared with criteria in NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1; Federal Emergency Management Agency (FEMA) Report REP-10, "Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants"; and the licensee's current FEMA-approved alert and notification system design report, Callaway Plant Alert and Notification System Design Report, dated April 2011. The specific documents reviewed during this inspection are listed in Attachment 1.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.02-05.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Staffing and Augmentation System

a. Inspection Scope

The inspectors discussed with licensee staff the operability of primary and backup systems for augmenting the on-shift emergency response staff to determine the adequacy of licensee methods for staffing emergency response facilities in accordance with their emergency plan and the requirements of 10 CFR Part 50, Appendix E. The inspectors also reviewed the licensees methods to notify the emergency response organization to staff alternative response facilities as necessary, and licensee training on the primary and backup notification methods. The specific documents reviewed during this inspection are listed in Attachment 1.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.03-05.

b. Findings

No findings were identified.

1EP5 Maintenance of Emergency Preparedness

a. Inspection Scope

The inspectors reviewed the following documents originated between June 2010 and September 2012:

• The licensee's corrective action program requirements described in Procedure APA-ZZ-00500, Corrective Action Program, Revision 54

• The licensees program requirements for preparing event after-action reports described in Procedure EIP-ZZ-00260, Event Closeout/Plant Recovery, Revision 23

• The licensees program requirements for making changes to the site emergency plan and implementing procedures as described in Procedure KDP-ZZ-00400, RERP Impact Evaluations and Changes, Revision 19

• The licensees program requirements for the protection of onsite workers during hostile actions as described in Procedures OTO-SK-00002 Plant Security Event, Aircraft Threat, Revision 15, and EIP-ZZ-SK001, Response to Security Events, Revision 8

• The licensees program requirements for maintaining emergency preparedness facilities and equipment as described in Procedure KDP-ZZ-00013, Emergency Response Facility and Equipment Evaluation, Revision 9

• Summaries of 164 corrective action program entries assigned to the emergency preparedness department and emergency response organization

• After-action reports for events on April 13, 2010, and September 18, 2011

• Quality Assurance reports, assessments, and audits

• Program assessments

• Drill evaluation reports The inspectors evaluated responses to the corrective action program requests, audits, and assessments, to determine the licensee's ability to identify, evaluate, and correct problems in accordance with the licensee program requirements, planning standard 10 CFR 50.47(b)(14), and 10 CFR Part 50, Appendix E. The inspectors selected 26 corrective action program entries for detailed review against the program requirements.

The inspectors also toured the near-site alternate Technical Support Center and Operations Support Center to determine the licensees compliance with Appendix E to Part 50,Section IV.E(8)(c). The specific documents reviewed during this inspection are listed in Attachment 1.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.05-05.

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 under 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 Attachment 1.

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

b. Findings

Introduction.

The inspectors reviewed a Green, self-revealing non-cited violation of Technical Specification 5.4.1.a because a worker did not follow radiation work permit instructions.

Description.

On October 17, 2011, the licensee was alerted by an electronic dosimeter dose rate alarm to a situation that involved an instrumentation and controls technician installing cameras that would be used during valve work, inside the bioshield. The individual worked in accordance with Radiation Work Permit 191001HRA and was briefed on work area dose rates up to, but not exceeding, the dose rate alarm setpoint of his electronic dosimeter (150 millirem/hour). Without contacting radiation protection personnel as required by the radiation work permit, the instrumentation and controls technician climbed to areas higher than 8 feet above the floor level and entered into an area with a dose rate of 263 millirem/hour, which was significantly greater than that on which the technician was briefed.

The licensee investigated the circumstances that led to the individual receiving the dose rate alarm. They determined the individual had focused on locating the valve on which work was to be done. However, the individual did not perform an adequate two-minute drill to help himself assess the surroundings and recall the requirements of the radiation work permit. The individual was coached on the radiation work permit instructions and the licensees expected behavior.

Analysis.

The failure to follow radiation work permit instructions is a performance deficiency. The performance deficiency was more than minor because, if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Using the Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding 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 finding had a crosscutting aspect in the human performance area, work practices component, in that the worker failed to use error prevention techniques, such as self-checking. H.4(a).

Enforcement.

Technical Specification 5.4.1.a required procedures be established, implemented, and maintained covering activities specified in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 7.e.(1) of the regulatory guide required procedures for access control to radiation areas including a radiation work permit system. Procedure APA-ZZ-01004, Radiological Work Standards, Revision 21, Step, 4.3.1.a.3 required individuals working in the radiological controlled area ensure they adhere to the instructions on radiation work permits. Radiation Work Permit 191001HRA instructed workers to contact radiation protection personnel prior to accessing areas greater than 8 feet above floors or work platforms. Contrary to this, on October 17, 2011, the licensee failed to implement a procedure required by Technical Specification 5.4.1.a and Regulatory Guide 1.33 when a licensee worker did not adhere to the instructions on a radiation work permit. Specifically, an instrumentation and controls technician did not contact radiation protection personnel prior to accessing areas greater than 8 feet above the floor and entering into a dose rate of 263 millirem/hour. As corrective action, the licensee coached the individual on the radiation work permit instructions and the licensees expected radiation worker behavior.

Because this violation is of very low safety significance and has been entered into the licensees corrective action program as Callaway Action Request 201108483, it is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 5000483/2012004-02, "Failure to Follow Radiation Work Permit Instructions."

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 Attachment 1.

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

b. Findings

No findings were identified.

2RS3 In-plant Airborne Radioactivity Control and Mitigation

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 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, performed walkdowns of various portions of the plant, and reviewed the following items:

• The licensees use, when applicable, of ventilation systems as part of its engineering controls

• The licensees respiratory protection program for use, storage, maintenance, and quality assurance of National Institute for Occupational Safety and Health certified equipment, qualification and training of personnel, and user performance

• The licensees capability for refilling and transporting self-contained breathing apparatus air bottles to and from the control room and operations support center during emergency conditions, status of self-contained breathing apparatus staged and ready for use in the plant and associated surveillance records, and personnel qualification and training

• Audits, self-assessments, and corrective action documents related to in-plant airborne radioactivity control and mitigation since the last inspection Specific documents reviewed during this inspection are listed in Attachment 1.

These activities constitute completion of one sample as defined in Inspection Procedure 71124.03-05.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

a. Inspection Scope

This area was inspected to:

(1) determine the accuracy and operability of personal monitoring equipment;

(2) determine the accuracy and effectiveness of the licensees methods for determining total effective dose equivalent; and

(3) ensure occupational dose is appropriately monitored. 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, performed walkdowns of various portions of the plant, and reviewed the following items:

• External dosimetry accreditation, storage, issue, use, and processing of active and passive dosimeters

• The technical competency and adequacy of the licensees internal dosimetry program

• Adequacy of the dosimetry program for special dosimetry situations such as declared pregnant workers, multiple dosimetry placement, and neutron dose assessment

• Audits, self-assessments, and corrective action documents related to dose assessment since the last inspection Specific documents reviewed during this inspection are listed in Attachment 1.

These activities constitute completion of one required sample as defined in Inspection Procedure 71124.04-05.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Occupational Radiation Safety, Public 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 second 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 for the period from the third quarter 2011 through the second quarter 2012. To determine the accuracy of the performance indicator 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 reviewed the licensees operator narrative logs, issue reports, event reports, and NRC integrated inspection reports for the period of July 2011 through June 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

1. 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 for the period from third quarter 2011 through the second 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 July 2011 through June 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 Attachment 1.

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 third quarter 2011 through the second 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 July 2011 through June 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 Attachment 1.

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 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspectors sampled licensee submittals for the Drill and Exercise Performance, performance indicator for the period April 2011 through June 2012. The performance indicator definitions and guidance in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used determine the accuracy of the reported performance indicator data. The inspectors reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance and site Procedure KDP-ZZ-02000, NRC Performance Indicator Data Collection, Revision 14. The inspectors reviewed licensee records of performance indicator opportunities during predesignated control room simulator training sessions, the 2011 biennial exercise, and other drills. The specific documents reviewed are described in Attachment 1.

These activities constitute completion of one drill/exercise performance sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.6 Emergency Response Organization Drill Participation (EP02)

a. Inspection Scope

The inspectors sampled licensee submittals for the Drill and Exercise Performance, performance indicator for the period April 2011 through June 2012. The performance indicator definitions and guidance in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used determine the accuracy of the reported performance indicator data. The inspectors reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance and site Procedure KDP-ZZ-02000, NRC Performance Indicator Data Collection, Revision 14. The inspectors reviewed licensee records of drill and exercise participation opportunities for key emergency response organization personnel, organization rosters, and exercise participation records. The specific documents reviewed are described in Attachment 1.

These activities constitute completion of one emergency response organization drill participation sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.7 Alert and Notification System (EP03)

a. Inspection Scope

The inspectors sampled licensee submittals for the Drill and Exercise Performance, performance indicator for the period April 2011 through June 2012. The performance indicator definitions and guidance in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used determine the accuracy of the reported performance indicator data. The inspectors reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance and site Procedure KDP-ZZ-02000, NRC Performance Indicator Data Collection, Revision 14. Specifically, the inspectors reviewed licensee records and processes, including procedural guidance for assessing opportunities for the performance indicator, and the results of periodic alert notification system operability tests. The specific documents reviewed are described in

1. These activities constitute completion of one alert and notification system sample as

defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.8 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

The inspectors reviewed performance indicator data for the fourth quarter 2011 through the second quarter 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 one occupational exposure control effectiveness sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.9 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual

Radiological Effluent Occurrences (PR01)

a. Inspection Scope

The inspectors reviewed performance indicator data for the fourth quarter 2011 through the second quarter 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 one 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. Minor issues entered into the licensees corrective action program because of the inspectors observations are included in the list of documents reviewed in

1. These routine reviews for the identification and resolution of problems did not constitute

any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

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

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

b. Findings

No findings were identified.

.3 Selected Issue Follow-up Inspection

a. Inspection Scope

During a review of items entered in the licensees corrective action program, the inspectors recognized a corrective action item documenting:

• alternate emergency power system diesel generator 1 inadvertent isolation, Callaway Action Request 201205208

• conflicting guidance in the procedures directing the response to an abnormal condition of the safety-related 120 volt inverters, Callaway Action Request 201205681 These activities constitute completion of two in-depth problem identification and resolution samples as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

.4 In-depth Review of Operator Workarounds

a. Inspection Scope

The inspectors evaluated the licensees implementation of their process used to identify, document, track, and resolve operational challenges. Inspection activities included, but were not limited to, a review of the cumulative effects of the operator workarounds on system availability and the potential for improper operation of the system, for potential impacts on multiple systems, and on the ability of operators to respond to plant transients or accidents.

The inspectors performed a review of the cumulative effects of operator workarounds.

The documents listed in Attachment 1 were reviewed to accomplish the objectives of the inspection procedure. The inspectors reviewed both current and historical operational challenge records to determine whether the licensee was identifying operator challenges at an appropriate threshold, had entered them into their corrective action program, and proposed or implemented appropriate and timely corrective actions that addressed each issue. Reviews were conducted to determine if any operator challenge could increase the possibility of an initiating event, if the challenge was contrary to training, required a change from long-standing operational practices, or created the potential for inappropriate compensatory actions. Additionally, all temporary modifications were reviewed to identify any potential effect on the functionality of mitigating systems, impaired access to equipment, or required equipment uses for which the equipment was not designed. Daily plant and equipment status logs, degraded instrument logs, and operator aids or tools being used to compensate for material deficiencies were also assessed to identify any potential sources of unidentified operator workarounds.

This activity constitutes completion of one operator workaround inspection sample as part of the annual in-depth problem identification and resolution samples defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

Inverter NN14 Notice of Enforcement Discretion

Introduction.

On August 19, 2012, safety-related inverter NN14 failed. After determining the cause of the failure, the length of time to repair, test, and return to service; the licensee requested enforcement discretion since activities would extend beyond the allowed outage time specified in technical specifications. An unresolved item was identified to assess whether the cause for the noncompliance, for which a Notice of Enforcement Discretion was granted, involved a violation.

Description.

On July 27 and August 13, 2012, safety related inverter NN14 auto-transferred to the backup source. The licensee entered Technical Specification 3.8.7, Action A.1, which required returning the inverter to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or place the plant in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Troubleshooting efforts concluded that the most likely cause for the inadvertent auto-transfer was a degraded card associated with the automatic static transfer switch. This card was replaced along with successful completion of post-maintenance testing.

On August 19, 2012, inverter NN14 failed again. The licensee entered Technical Specification 3.8.7, Action A.1. Troubleshooting revealed that the constant-voltage transformer phase B secondary windings were shorted to ground. The most probable cause of the short was determined to be degradation of the transformer windings/insulation.

In consultation with the vendor, the licensee determined that following replacement of the transformer, post-maintenance testing and temperature/voltage stabilization would exceed the time allowed by technical specifications. Therefore, the licensee contacted the NRC on August 20, 2012, to request enforcement discretion to extend the allowed outage time of Technical Specification 3.8.7, Action A.1, for an additional 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (a total of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />). The NRC staff evaluated the information provided by the licensee and granted Notice of Enforcement Discretion 12-4-002 (ADAMS ML12237A010).

An unresolved item was identified to assess whether the cause for the noncompliance, for which a Notice of Enforcement Discretion was granted, involved a violation URI 05000483/2012004-03, "Review Cause of the Failure of Inverter NN14."

4OA5 Other Activities

(Closed) Temporary Instruction 2515/185, Follow-up on the Industrys Ground Water Protection Initiative

a. Inspection Scope

An NRC follow-up assessment of the licensees ground water protection program was performed the week of August 27, 2012. This review was to determine whether the licensee had implemented program elements that were identified as incomplete during the NRCs inspection of Temporary Instruction on Groundwater Protection, TI-2515/173, Industry Groundwater Protection Initiative, on June 22, 2009. Inspectors interviewed personnel, performed walkdowns of selected areas, and reviewed the implementation of the program elements listed below.

b. Findings

The following elements had been implemented since the previous review:

• Element 1.1a - Perform hydrogeologic studies to determine predominant ground water flow characteristics and gradients.

• Element 1.1 b - Review existing hydrogeologic and geologic studies, historical environmental studies and permit or license-related reports.

• Element 1.1 c - Identify potential pathways for ground water migration from on-site locations to off-site locations through ground water.

• Element 1.1d - Establish the frequency for periodic reviews of site hydrogeologic studies.

• Element 1.2.c - Identify potential enhancements to leak detection systems or programs. These may include additional or increased frequency of rounds or walkdowns or inspections, or integrity testing.

• Element 1.2d - Identify potential enhancements to prevent spills or leaks from reaching ground water.

• Element 1.2f - Establish long-term programs to perform preventative maintenance or surveillance activities to minimize the potential for inadvertent releases of licensed materials due to equipment failure.

• Element 1.2g - Establish the frequency for periodic reviews of systems, structures, and components and work practices.

• Element 1.3.b - Consider, as appropriate, placing sentinel wells closer to structures, systems, and components that have the highest potential for inadvertent releases that could reach ground water or structures, systems, and components where leak detection capability is limited.

• Element 1.3d - Establish a formal, written program for long-term ground water monitoring. For those ground water monitoring locations that are included in the REMP, revise the sites Offsite Dose Calculation Manual.

• Element 1.3f - Establish a long-term program for preventative maintenance of ground water wells.

• Element 1.4a - Establish written procedures outlining the decision making process for remediation of leaks and spills or other instances of inadvertent releases.

• Element 1.4b - Evaluate the potential for detectible levels of licensed material resulting from planned releases of liquids and/or airborne materials.

• Element 1.4c - Evaluate and document, as appropriate, decommissioning impacts resulting from remediation activities or the absence thereof.

All elements were verified as complete. No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On August 30, 2012, the inspectors presented the results of the radiation safety inspections to Mr. L. Graessle, Director of Plant Support, 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.

On September 14, 2012, the inspector presented the results of the onsite inspection of the licensees emergency preparedness program to Mr. C. Reasoner, Vice President, Engineering, and other members of the licensees 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.

On September 27, 2012, the inspectors presented the inspection results to Mr. F. Diya, Vice President Nuclear Operations, and other members of the licensee staff. On October 9, 2012, the inspectors conducted a follow-up exit and presented updated inspection results to Mr. S.

Maglio, Regulatory Affairs Manager. 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 retained.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

F. Bianco, Assistant Operations Manager, Support

K. Blair, Engineer, Engineering Technical Support and Programs

L. Bodenschatz, Engineer, Maintenance Rule

B. Cox, Manager, Planning/Scheduling/Outages

W. Cravens, Medical Review Officer

L. Eitel, Supervising Engineer Systems, Balance of Plant

T. Elwood, Supervising Engineer, Licensing/Regulatory Affairs

G. Gary, Consulting Chemist, Ameren

K. Gilliam, ALARA Supervisor, Radiation Protection

L. Graessle, Director, Operations Support

C. Graham, Health Physicist, Radiation Protection

A. Heflin, Senior Vice President and Chief Nuclear Officer

G. Hurla, Supervisor, Radiation Protection

A. King, Senior Health Physicist, Radiation Protection

J. Little, Supervising Engineer Systems, Reactor/Safety Analysis

S. Maglio, Manager, Regulatory Affairs

P. McKenna, Manager, Emergency Preparedness

D. Neterer, Plant Director

H. Osborn, Regulatory Affairs Specialist

T. Pettus, Supervisor of Major Projects, Engineering

S. Petzel, Engineer, Regulatory Affairs

C. Reasoner, Vice President Engineering

C. Smith, Manager, Radiation Protection

F. Stuckey, Senior Health Physicist, Radiation Protection

D. Thompson, Senior Health Physicist, Radiation Protection

LIST OF ITEMS

OPENED AND CLOSED

Opened

Review the Cause of the Failure of Inverter NN14

05000483/2012004-03 URI (Section 4OA3)

Opened and Closed

05000483/2012004-01 NCV Failure to Correct an Adverse Condition on an Emergency Diesel Generator (Section 1R15)

05000483/2012004-02 NCV Failure to Follow Radiation Work Permit Instructions (Section 2RS1)

Attachment 1