IR 05000498/2010006

IR 05000498-10-006; 05000499-10-006; 08/30/10 - 09/16/10; South Texas Project Units 1 and 2: Identification and Resolution of Problems

ML103010543
Person / Time
Site:	South Texas
Issue date:	10/28/2010
From:	Hay M Division of Reactor Safety IV
To:	Halpin E South Texas
References
IR-10-006
Download: ML103010543 (31)

Text

UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N ber 28, 2010

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION -

NRC IDENTIFICATION AND RESOLUTION OF PROBLEMS INSPECTION REPORT 05000498/2010006 AND 05000499/2010006

Dear Mr. Halpin:

On September 16, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of a team inspection at your South Texas Project Electric Generating Station. The enclosed inspection report documents the inspection findings, which were discussed on September 16, 2010, with Mr. D. Rencurrel and members of your staff.

This inspection reviewed activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel. The team also interviewed a representative sample of personnel regarding the condition of your safety conscious work environment at the South Texas Project.

On the basis of the samples selected for review, there were no findings of significance identified during this inspection. The team concluded that the South Texas Project has a comprehensive and effective corrective action program. Problems are being identified at an appropriately low threshold, assessed, and ultimately corrected. The team determined that the procedures and program controls that implement the various aspects of the corrective action program were well established. However, the team indentified weaknesses in the implementation of operability determinations and samples of corrective actions that were limited in scope and not always documented properly.

A licensee-identified violation which was determined to be of very low safety significance is listed in this report. NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy because of the very low safety significance of the violation and because it is entered into your corrective action program. If you contest this

STP Nuclear Operating Company -2-non-cited violation, 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 South Texas Project, Units 1 and 2, Station.

In accordance with 10 CFR 2.390 of the NRCs 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 component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Michael C. Hay, Chief Technical Support Branch Division of Reactor Safety Dockets: 50-498, 50-499 Licenses: NPF-76, NFP-80

Enclosure:

NRC Inspection Report 05000498/201006; 05000499/2010006 w/attachments:

1. Supplemental Information 2. Information Request

REGION IV==

Dockets: 05000498, 05000499 Licenses: NPF-76, NPF-80 Report: 05000498/2010006 and 05000499/2010006 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM521 - 8 miles west of Wadsworth Wadsworth, Texas 77483 Dates: August 30 through September 16, 2010 Inspectors: D. Proulx, Senior Project Engineer, Projects Branch A (Team Leader)

B. Tharakan, Resident Inspector, Projects Branch A P. Jayroe, Project Engineer, Projects Branch D I. Anchondo, Reactor Inspector, Plant Support Branch 2 M. Williams, Reactor Inspector, Plant Support Branch 2 Approved By: Michael Hay, Chief Technical Support Branch Division of Reactor Safety-1- Enclosure

SUMMARY OF FINDINGS

IR 05000498/2010006; 05000499/2010006; 08/30/10 - 09/16/10; South Texas Project Units 1 and 2: Identification and Resolution of Problems.

This report covered a 2-week period of inspection performed by a resident inspector and four region-based inspectors. The significance of most findings is indicated by their color (Green,

White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC managements review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Identification and Resolution of Problems Overall, the team concluded that the licensee was effective in identifying, evaluating, and correcting problems. The team also determined that the procedures and program controls associated with the corrective action program were well established. However, these implementing processes were not consistently followed and corrective actions were not always completed in a timely manner.

The team noted that the bases for some operability evaluations were not clear and adequately supported. Additionally, the team noted that the licensees process for correcting deficient conditions allowed a 22-month time limit. This process resulted in a number of degraded conditions not being addressed in a timely manner such as during the next available outage.

Overall, the team determined that the licensee had appropriately evaluated industry operating experience for relevance to the facility, and had entered applicable items in the corrective action program. However, once this information was disseminated, the reviews and other actions associated with or generated as part of the condition report actions were not being completed in a timely manner. Quality assurance audits and other self-assessment activities have been effective in identifying issues and areas for improvement.

Overall, the team concluded that there was a safety conscious work environment in place at South Texas Project. The team determined that the many of the individuals questioned lacked familiarity with the Employee Concerns Program coordinators because of a lack of visibility in the facility.

NRC-Identified and Self-Revealing Findings

No findings were identified.

Licensee-Identified Violations

A violation of very low significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. The violation and corrective actions are listed in Section 4OA7 of this report.

REPORT DETAILS

4OA2 Problem Identification and Resolution

The team based the following conclusions, in part, on a review of issues that were identified in the assessment period, which ranged from August 14, 2008, (the last biennial problem identification and resolution inspection) to the end of the on-site portion of the inspection on September 16, 2010 a. Assessment of Corrective Action Program Effectiveness

(1) Inspection Scope The team reviewed items selected across the seven cornerstones of safety to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. Specifically, the team selected and reviewed approximately 235 condition reports from approximately 30,000 conditions that had been issued between August 2008 and September 16, 2010. The team also performed field walkdowns of selected systems and equipment. Additionally, the team reviewed a sample of self assessments, trending reports and metrics, system health reports, and various other documents related to the corrective action program.

The team evaluated condition reports, work orders, and operability evaluations to assess the licensees threshold for identifying problems, entering them into the corrective action program, and the ability to evaluate the importance of adverse conditions. Also, the licensees efforts in establishing the scope of problems were evaluated by reviewing selected logs, work requests, self-assessments results, audits, system health reports, action plans, and results from surveillance tests and preventive maintenance tasks. The team also reviewed work requests and attended the licensees daily Condition Review Group meetings to assess the reporting threshold, prioritization efforts, and significance, as well as observing the interfaces with the operability assessment and work control processes.

The team reviewed a sample of condition reports, apparent cause evaluations, and root cause evaluations performed during this period to ascertain whether the licensee properly considered the extent of cause and extent of condition for problems, as well as, assessing generic implications and previous occurrences. The team assessed the timeliness and effectiveness of corrective actions, completed or planned, and looked for additional examples of similar problems.

The team also conducted interviews with plant personnel to identify other processes that existed where problems may be identified and addressed outside the corrective action program.

A review of the essential cooling water system was performed for a 3-year period to determine whether problems were being effectively addressed. The team also conducted a walkdown of this system to assess the physical condition of equipment and to determine if problems were identified and entered into the corrective action process.

(2) Assessment Assessment - Effectiveness of Problem Identification The team concluded that problems were identified and documented in accordance with the requirements of the licensees corrective action program. The team also determined that the licensee was identifying problems at an appropriately low threshold, and that these conditions were assessed and ultimately corrected. The team determined that the procedures and program documents that implement the various aspects of the corrective action program were well established; however, the procedural requirements associated with this program were not always followed. Although the team did not identify any issues with problem identification, the team noted that three NRC-identified issues associated with problem identification were spread out over the 2-year assessment period.

The team concluded that these issues were not indicative of an adverse trend in problem identification.

Assessment - Effectiveness of Prioritization and Evaluation of Issues The team reviewed a sample of condition reports that involved operability issues to assess the adequacy and timeliness of the licensees operability determination process.

The team noted that in 2008 the licensee had implemented changes to the operability determination process to help improve problems that had been identified through corrective action program documents, self-assessments, and quality assurance audits.

Specifically, the licensee established procedure 0PGP03-ZO-9900, Operability Determinations and Functionality Assessments, and made modifications to procedure 0PGP04-ZA-0002, Condition Report Engineering Evaluation, to implement the guidance provided in NRC Regulatory Issue Summary 2005-20. In addition, the licensee implemented requirements in procedure 0POP01-ZQ-0022, Plant Operations Shift Routines to ensure that an operations shift manager or supervisor would review condition reports to ensure operability.

Overall, during the review period the licensee adequately implemented these programs to address conditions which challenged the operability of plant safety systems.

Although the licensee has made significant improvements to their operability review programs since 2008, the team identified that there were a few conditions where improvement was still needed to ensure that operability evaluations were thorough, accurate, and appropriately address the conditions. The licensee acknowledged this concern and wrote condition report 10-20052 to address this issue.

The team identified several examples where the licensees evaluations were not thorough, accurate, or appropriately addressed conditions.

The licensees Condition Report Engineering Evaluation procedure, 0PGP04-ZA-0002, required that each operability review be performed for all modes of operation that could be affected by the condition. The team noted two examples of operability reviews that did not consider all applicable modes of operation. Condition report 08-12812 identified a trouble alarm associated with the Unit 2 A train 125-volt DC emergency battery system. Unit 2 was operating in mode 1 at the time of the alarm, but later entered mode 5 and 6 before troubleshooting was completed and the corrective actions were implemented. The licensee did not evaluate the condition for applicability to mode 5-6.

The evaluation concluded that the system was operable in modes 1-4. When the team identified this issue to the licensee, the licensee reviewed the condition of the battery and determined that it was operable in modes 5-6, as well. The second example was identified in condition report 08-17803, which described a condition with the Unit 1 train A component cooling water isolation valve to the residual heat removal system heat exchanger that went open unexpectedly. The licensee did not list the mode 5-6 technical specification applicability of the component cooling water system requirements for the residual heat removal system. However, the operability determination addressed the potential impact to the residual heat removal system and the condition would not have prevented the systems from performing their safety functions, therefore the determination the systems were operable did not change. The licensee wrote condition report 10-20309 to address this issue.

Condition reports 06-7815 and 07-10159, identified boron deposits on the tubing of a Unit 1 reactor coolant system flow transmitter 1RCFT0419 indicative of an inactive leak.

The licensees Condition Reporting Process procedure required that the corrective action program supervisor promptly screen the condition for operability. It goes on further to state that conditions that have or may have an impact on the operability of technical specification related structure, system, or component (SSC), or may be or are, reportable; shall be screened as yes or indeterminate. The condition was identified by radiation protection personnel and screened by a radiation protection corrective action program supervisor as operability review not required. The licensee corrected the condition by cleaning and tightening the fitting. No documented evidence that an operability evaluation was performed by operations personnel was found. The licensee wrote condition report 10-20098 to address this issue.

In 2008, the condition reappeared on flow transmitter 1RCFT0419; and is documented in condition report 08-12797. At this time, an immediate operability determination was performed by operations personnel followed by a prompt operability determination performed by engineering personnel that was reviewed and accepted by operations management. The potential leak was determined to be on the high pressure side of the flow transmitter and if the tubing failed it would impact all three flow channels in that loop and could result in a low reactor coolant flow trip of the unit. The condition was determined to be operable because any failure of the tubing would not result in a leak greater than the makeup capability of the charging pumps. When the team reviewed the engineering evaluation for determining operability, the team noted that the

justification for determining immediate operability relied upon a 2004 engineering evaluation for a condition that was not similar to and did not bound the flow transmitter 1RCFT0419 leak. Therefore, the team identified that the immediate operability determination did not adequately justify that the flow transmitter was operable. The licensee wrote condition report 10-20208 to address this issue.

The team also reviewed root cause investigations conducted for significant conditions adverse to quality and apparent cause evaluations that were completed for station level conditions adverse to quality. The team reviewed the procedures, the investigator and evaluator manuals, as well as recent examples of both types of activities. The team concluded that the licensee had acceptable root cause investigation and apparent cause evaluation processes that were adequately implemented. Appropriate corrective actions were identified to address the causes, and operating experience and offsite expertise were appropriately utilized during these evaluations. However, the team noted a significant number of apparent cause evaluations and some root cause investigations that were completed using a common cause process. The licensees procedure for implementing the Corrective Action Program, 0PGP03-ZX-0002, Condition Reporting Process, did not include the use of a common cause analysis to resolve significant conditions adverse to quality or station level conditions adverse to quality. The team concluded that although the process to use common cause analyses was not adequately defined by procedures, the corrective actions to resolve the conditions identified were adequate for each apparent cause evaluation and root cause investigation that the team reviewed. The licensee wrote Condition Reports 10-19215 and 10-19678 to address this issue.

Assessment - Effectiveness of Corrective Actions The team reviewed plant records, primarily condition reports and work orders, to verify that corrective actions were appropriately developed and implemented, including corrective actions to address common cause or generic concerns. Additionally, the team reviewed a sample of condition reports that addressed past NRC-identified violations for each cornerstone to ensure that the corrective actions adequately addressed the issues identified in the respective inspection reports. The team also reviewed a sample of corrective actions closed to other condition reports, work orders, or tracking programs to ensure that the defined corrective actions had been appropriately implemented.

Overall, the team concluded that the licensee developed appropriate corrective actions to address specific problems, with some exceptions. The team had the following concerns with the thoroughness or timeliness of corrective actions that the team determined were indicative that the licensees program required improvement:

• The team identified that the licensee closed out Condition Report 09-0771 without documenting that the corrective actions were completed. This condition report was initiated to address NCV 2009-402-01. The team received additional information during this inspection indicating that remedial actions had been taken but not documented.

• The team identified that the licensee closed out Condition Report 08-16599 without adequately addressing corrective actions. This condition report was initiated to address NCV 2009003-02. The licensee did not adequately document remedial actions taken to address the failure to survey as identified in the condition report. The team received additional information during this inspection indicating that remedial actions had been taken but not documented.

• The licensee had failed to promptly identify and correct two degraded or nonconforming conditions in that the licensee deferred correction of a leaking emergency diesel generator air start receiver check valve for over six years, and the licensee deferred correction of loose or sheared emergency diesel generator turbocharger support bolts for over three years. This issue is considered a licensee-identified non-cited violation 10 CFR 50, Appendix B, Criterion XVI, with two examples.

Standby Diesel Generator 11 Air Start Receiver Check Valve On June 18, 2004, maintenance personnel identified that starting air receiver 11 check valve SD-0003A was leaking past its seat. This air receiver and check valve was a support system for starting Unit 1 standby diesel generator 11. The licensee entered this into the corrective action program as Condition Report 04-8770. Subsequent to the identification of this issue, the licensee did not perform either an immediate operability assessment or followed up with a prompt operability determination, and considered it a low priority item.

The license reprioritized Condition Report 04-8770 following changes to their processes. As a result of operational experience review, the licensee implemented the guidance of RIS 2005-20 in August 2008. The licensee revised Procedure 0PGP03-ZO-9900 Operability Determinations and Functionality Assessments, Revision 1, to recognize that structures, systems and components that were degraded or nonconforming items had a higher priority and must be corrected at the first available opportunity. The licensee inappropriately interpreted the NRC guidance in RIS 2005-20 as providing a blanket 22-month time frame (one cycle, plus outage preparation time) to correct degraded or nonconforming conditions, and documented this in Procedure 0PGP03-ZX-0002, Condition Reporting Process, Revision 38.

After revision of these procedures, the licensee reviewed open condition reports to determine if they had missed any degraded/nonconforming conditions. Condition Report 04-8770 was identified as one such issue.

In October 2008, the licensee determined that the leak of check valve SD-0003A was a degraded or nonconforming condition, and requested a functionality assessment, which was completed on February 17, 2009.

This functionality assessment concluded that, although the condition was

over four years old already, that additional delay was acceptable. The team noted several deficiencies with the licensees assessment of condition report 04-8770: (1), the licensee stated that check valve SD-0003A and its associated air receiver were not Technical Specifications items and were thus not significant. However, pressure in the air start receivers was a required support system to support operability of standby diesel generator 11. (2), Final Safety Analysis Report (FSAR) Section 9.6 stated that each of the two diesel air start receivers could each support 5 starts of the diesel without makeup (the air compressors were powered from a nonsafety-related bus). The functionality assessment did not discuss the ability to meet the FSAR five-start criterion, and

(3) the functionality assessment was also deficient in that it stated that the condition was not significant because there was a 100 percent redundant air receiver (air receiver 12) and check valve (valve SD-0004A). However, the licensee had identified that check valve SD-0004A was also leaking past its seat, rendering both air start receivers degraded, and invalidating the assumptions of the functionality assessment for Condition Report 04-8770.

The licensee continued to defer correcting the leak on check valve SD-0003A because of its low priority, planning, scheduling, parts, vacations, and the desire to work the component in conjunction with welding in a new isolation valve in the air start system. This condition was deferred several times past several refueling outages system maintenance outage windows. The condition had yet to be corrected by the end of the onsite inspection (September 16, 2010).

The failure to promptly identify and correct a known degraded nonconforming condition (i.e. leaking emergency diesel generator air start receiver check valve) at the first available opportunity was the first example of a licensee identified violation of 10 CFR 50, Appendix B, Criterion XVI.

Standby Diesel Generator 13 Turbocharger Support Bolts On February 1, 2007, maintenance craft initiated condition report 07-1696 to document that four of the six support bolts in the vertical axis for the standby diesel generator 13 Turbocharger were loose or not fully screwed in. The system engineer performed an inspection of the condition and identified that in actuality, two of the six support bolts in the vertical axis were loose and two additional bolts had sheared into two pieces. Although engineering evaluated the condition from a seismic perspective, the licensee considered this initially to be a minor material condition, and categorized Condition Report 07-1696 as no operability concerns, and thus, did not consider the loose and sheared support bolts to be a degraded or nonconforming condition, and was a low priority item.

On August 20, 2008, (17 months following identification) after implementing the guidance of RIS 2005-20, the licensee recharacterized Condition Report 07-1696 as a degraded condition. The team identified that maintenance personnel deferred working this item immediately because of vacation, manpower and ownership issues. Licensee management took no action to expedite or reprioritze correcting this adverse condition. The licensee completed the operability determination on February 17, 2009, (over two years after the condition had been identified), and stated that the degraded standby diesel generator 13 turbocharger support bolts would be worked at the next convenient opportunity.

The team noted that the licensee conducted a major teardown of standby diesel generator 13 that lasted several days during the week of November 30, 2009, but because of inadequate planning and decision-making, did not correct the loose and sheared bolts on the standby diesel generator 13 turbocharger. After missing this opportunity to correct the condition, the licensee did not schedule its repair for the next train maintenance outage window or refueling outage (spring 2010). The licensee deferred repairing the loose and sheared bolts of the standby diesel generator 13 turbocharger until the next major overhaul of diesel generator 13, scheduled for 2014, over 7 years after this degraded condition was identified. The team noted that licensee had not determined the cause of the loose or sheared bolts, and had not examined the intact bolts, but made the decision that the condition could exist for an extended period of time.

The failure to promptly identify and correct a known degraded or nonconforming condition (i.e., loose and sheared standby diesel generator turbocharger bolts) at the first available opportunity was the second example of a violation of 10 CFR 50, Appendix B, Criterion XVI.

A licensee self-assessment performed in July 2010 identified that the licensees programs were inadequately implementing RIS 2005-20, in that a number of degraded or nonconforming conditions were not corrected at the first available opportunity, as documented in Condition Report 10-15962. This self-assessment also noted that licensee procedures inappropriately granted all nonconforming conditions a blanket 22-month time frame for correction. Condition Reports 04-8770 and 07-1696 were listed in condition report 10-15962 as inappropriately deferred. Thus, the two examples of failure to promptly identify and correct conditions adverse to quality was considered a licensee-identified non-cited violation of 10 CFR 50, Appendix B, Criterion XVI. The team evaluated the two examples of a finding using the Phase 1 worksheet in Inspection Manual Chapter 0609, "Significance Determination Process,"

and determined the finding to have very low safety significance because

the two examples were design or qualification deficiencies confirmed not to result in loss of operability or functionality.

b. Assessment of the Use of Operating Experience

(1) Inspection Scope The team examined the licensee's program for reviewing industry operating experience.

The team reviewed a sample of 18 operating experience notification documents that had been issued during the assessment period to determine whether the licensee had appropriately evaluated the notification for relevance to the facility. The team also examined whether the licensee had entered those items into their corrective action program and assigned actions to address the issues. The team reviewed a sample of root cause evaluations and significant condition reports to verify that the licensee had appropriately included industry operating experience.

(2) Assessment Overall, the team determined that the licensee had appropriately evaluated industry operating experience for relevance to the facility, and had entered applicable items in the corrective action program. The team noted however that there is a lack of prioritizing of the condition reports for operating experience that led to untimely corrective actions. All condition reports documenting operating experience were initially assigned as conditions not adverse to quality, the lowest level of classification in the corrective action program.

Condition reports were then screened for applicability, but there was no reprioritization or upgrading of the condition reports describing operating experience that was applicable to the plant.

Operating experience condition reports were left as conditions not adverse to quality regardless of their relevance. This resulted in delays in implementing actions in cases where operating experience led to recommendations. An example of this practice can be found in Condition Report 09-3902, which delineated necessary changes to emergency/abnormal procedures for manually resetting safety injections subsequent to a card failure. Another example was that the licensee was slow to implement NRC RIS 2005-20 Operability Determinations and Functionality Assessments for Resolution of Degraded or Non-Conforming Conditions Adverse to Quality or Safety in that the licensee took three years to implement the recommendations of RIS 2005-20, and then subsequently identified in July 2010, that their implementing procedures did not reflect industry practice as delineated in RIS 2005-20.

The lack of prioritization of operating experience condition reports was also identified by the previous NRC problem identification and resolution team inspection in August of 2008. The team did not identify safety issues associated with these delays. Once evaluated, assessments of the issues were appropriate. The team also determined that the licensee evaluated industry operating experience when performing root cause and apparent cause evaluations, as appropriate.

c. Assessment of Self-Assessments and Audits

(1) Inspection Scope The team reviewed a sample of 29 licensee self assessments and audits to assess whether the licensee was regularly identifying performance trends and effectively addressing them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas.

(2) Assessment The team concluded that the licensees self assessments, though limited in scope and breadth, were generally effective in recommending corrective actions for licensee processes and programs.

d. Assessment of Safety Conscious Work Environment

(1) Inspection Scope The team conducted three focus group sessions, each of a different department, with a total of 28 employees, representing a cross section of functional organizations, including supervisory and non-supervisory personnel. The interviews assessed whether conditions existed that would challenge an effective safety conscious work environment.

The team requested that attendees complete a Focus Group Feedback Form, either including their name or anonymous, for recommendations on how to improve the interview process. The team also interviewed two individuals from the quality assessment program, and reviewed several self-assessment documents supporting their quality program.

In addition, the team reviewed the licensees safety culture program. The team noted that South Texas Project was a pilot plant for the industrys initiative to self-assess the safety culture at nuclear facilities. The team interviewed licensee personnel and reviewed the results of the most recent safety culture meetings and documentation.

(2) Assessment Overall, the team concluded that a safety conscious work environment exists at the South Texas Project. Employees showed familiarity with various programs to raise safety concerns, and appeared comfortable with submitting any issues. There was some unfamiliarity, however, with individuals in the Employee Concerns Program, and their location on site. Some individuals stated that they did not write condition reports, but rather passed the comments along to supervisors who then write the condition reports.

The team concluded that the licensees safety culture pilot program was generally effective in identifying and correcting issues associated with a safety conscious work environment.

4OA6 Management Meetings

Exit Meeting On September 16, 2010, an onsite exit was conducted on the last day of the onsite inspection. The preliminary results of the inspection were discussed with Mr. D. Rencurrel, Senior Vice President, Units 1 and 2, and other members of the staff.

The licensee confirmed that no proprietary information was handled during this inspection.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy, for being dispositioned as an NCV.

Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XVI, states, in part, that conditions adverse to quality shall be promptly identified and corrected.

Contrary to this, the licensee failed to promptly identify and correct two examples of conditions adverse to quality. Specifically,

(1) between June 18, 2004, and August 20, 2010, the licensee identified that check valve SD-003A was degraded and leaking past its seat, and

(2) between February 1, 2007, and August 20, 2010, four of six hold-down bolts for the standby diesel generator 13 turbocharger were degraded in that two were loose and two were sheared, but the licensee failed to promptly correct these conditions.

These issues were entered into the licensees corrective action program as Condition Report 10-15962. These two examples of a finding were evaluated using the Phase 1 worksheet in Inspection Manual Chapter 0609, "Significance Determination Process,"

and determined the finding to have very low safety significance because the two examples were design or qualification deficiencies confirmed not to result in loss of operability or functionality.

s:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

C. Bowman, General Manager, Oversight

J. Calvert, Manager, Training

D. Cobb, Manager, Employee Concerns Program

J. Cook, Supervisor, Engineering Projects

R. Engen, Site Director, Engineering

W. Harrison, Manager, Licensing

B. Jenewein, Manager, Systems Engineering

G. Janak, Manager Operations Division - Unit 1

A. McGalliard, Manager, Performance Improvement

J. Mertink, Manager, Maintenance

L. Peter, Plant General Manager

J. Pierce, Manager, Operations Training

G. Powell, Vice President Engineering

D. Rencurrel, Senior Vice President, Units 1 and 2

M. Ruvalcaba, Manager, Testing and Programs

R. Savage, Engineering Licensing Staff

K. Taplett, Engineering Licensing Staff

NRC

M. Hay, Chief, Technical Support Branch, Division of Reactor Safety

J. Dixon, Senior Resident Inspector

D. Proulx, Senior Project Engineer

B. Tharakan, Resident Inspector

P. Jayroe, Project Engineer

I. Anchondo, Reactor Inspector

M. Williams, Reactor Inspector.

Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

None