IR 05000498/2012002

IR 05000498-12-002, 05000499-12-02, on 01/01/2012 - 03/30/2012, South Texas Project Electric Generating Station, Units 1 and 2, Integrated Resident and Regional Report

ML12124A109
Person / Time
Site:	South Texas
Issue date:	04/30/2012
From:	Webb Patricia Walker NRC/RGN-IV/DRP/RPB-A
To:	Richards K South Texas
Walker W
References
IR-12-002
Download: ML12124A109 (65)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I V 1600 EAST LAMAR BLVD ARLINGTON, TEXAS 76011-4511 April 30, 2012 Mr. Kevin President and Chief Executive Officer STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483 Subject: SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000498/2012002 AND 05000499/2012002

Dear Mr. Richards:

On March 30, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your South Texas Project Electric Generating Station, Units 1 and 2, facility. The enclosed inspection report documents the inspection results which were discussed on April 5, 2012, with Mr. G. Powell, Vice President, Generation, Units 1 and 2, and other members of your staff.

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

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

No NRC-identified or self-revealing findings were identified during this inspection.

However, licensee-identified violations which were determined to be of very low safety significance are listed in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest these non-cited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the South Texas Project Electric Generating Station, Units 1 and 2, facility.

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 (PARS) component of NRCs 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/

Wayne C. Walker, Chief Project Branch A Division of Reactor Projects Docket Nos.: 05000498, 05000499 License Nos.: NPF-76, NPF-80 Enclosure: Inspection Report 05000498/2012002 and 05000499/2012002 w/Attachment 1: Supplemental Information w/Attachment 2: Document Request for Occupational and Public Radiation Safety Inspection cc w/Enclosure: Distribution via Listserv

SUMMARY OF FINDINGS

IR 05000498/2012002, 05000499/2001202; 01/01/2012 - 03/30/2012; South Texas Project

Electric Generating Station, Units 1 and 2, Integrated Resident and Regional Report.

The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by region-based inspectors. Two licensee-identified 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 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.

NRC-Identified Findings and Self-Revealing Findings

None.

Licensee-Identified Violations

Violations of very low safety significance or severity level IV that were identified by the licensee have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and associated corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power and remained there until March 29, 2012, when the unit was down powered to 37 percent rated thermal power as a result of shutdown bank A rod M-14 dropping into the core during monthly rod control surveillance testing. Rod M-14 was recovered to the full-out position later the same day and operators increased power to approximately 70 percent and remained there for the duration of the inspection period.

Unit 2 began the inspection period in Mode 5, cold shutdown and remained there for the duration of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness to Cope with External Flooding

a. Inspection Scope

During the week of March 19, 2012, the inspectors evaluated the design, material condition, and procedures for coping with the design basis probable maximum flood.

The evaluation included a review to check for deviations from the descriptions provided in the UFSAR for features intended to mitigate the potential for flooding from external factors. As part of this evaluation, the inspectors checked for obstructions that could prevent draining, checked that the roofs did not contain obvious loose items that could clog drains in the event of heavy precipitation, and determined that barriers required to mitigate the flood were in place and operable. Additionally, the inspectors performed an inspection of the protected area to identify any modification to the site that would inhibit site drainage during a probable maximum precipitation event or allow water ingress past a barrier. The inspectors also reviewed the abnormal operating procedure for mitigating the design basis flood to ensure it could be implemented as written. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one external flooding sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignments

Partial Walkdown

a. Inspection Scope

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

• January 27, 2012, Unit 1, component cooling water system train A

• February 9, 2012, Unit 1, auxiliary feedwater system train D

• February 10, 2012, Unit 2, residual heat removal system train A 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, UFSAR, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three 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:

• February 9, 2012, Unit 1, essential cooling water train A, Fire Zone Z600

• February 9, 2012, Unit 2, residual heat removal train A, Fire Zone Z226

• February 16, 2012, Unit 1, centrifugal charging pump 1A, Fire Zones Z108 and Z123

• February 16, 2012, Unit 1, safety injection pump cubicles, Fire Zones Z305 - Z307 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 the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees corrective action program.

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

These activities constitute completion of four 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 February 28, 2012, the inspectors observed a crew of licensed operators in the plants simulator during high intensity training. The inspectors assessed the following areas:

• Licensed operator performance

• The ability of the licensee to administer the evaluations and the quality of the training provided

• The modeling and performance of the control room simulator

• The quality of post-scenario critiques

• Follow-up actions taken by the licensee for identified discrepancies The inspectors compared the crews performance in these areas to preestablished operator action expectations and successful critical task completion requirements.

These activities constitute completion of one quarterly licensed-operator requalification program sample as defined in Inspection Procedure 71111.11-05.

b. Findings

No findings were identified.

.2 Quarterly Observation of Licensed Operator Performance

a. Inspection Scope

On March 21, 2012, the inspectors observed the performance of on-shift licensed operators in the plants main control room in Unit 1. At the time of the observations, the plant was in a period of heightened activity and risk due to maintenance and testing on train C safety-related equipment. The inspectors observed the operators performance of the following activities:

• Auxiliary feedwater pump 13 post-maintenance testing, including the pre-job brief

• Standby diesel generator 13 surveillance testing, including the pre-job brief and corrective maintenance activities

• Reactor coolant system dilutions, including management oversight activities

• Reactor coolant pump 1C under-voltage and under-frequency calibrations

• High energy line break temperature switch calibrations In addition, the inspectors assessed the operators adherence to plant procedures, including the conduct of operations procedure and other operations department policies.

These activities constitute completion of one quarterly licensed-operator performance sample as defined in Inspection Procedure 71111.11-05.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

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

• March 23, 2012, Units 1 and 2, post-accident monitoring system [AM], including the qualified display processing system, anticipated transient without scram mitigating system actuation circuitry, and the auxiliary shutdown panel

• March 28, 2012, Units 1 and 2, essential chilled water system [CH]

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 licensees actions to address system performance or condition problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

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

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

• Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)

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

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

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

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed licensee personnels 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:

• November 29, 2011 - March 30, 2012, Unit 2, activities associated with Forced Outage 2F1102, including multiple residual heat removal pump rotations

• January 31 - February 2, 2012, Unit 1, partial loss of channel IV annunciators and excess letdown out of service; Furmanite compound catches fire during restoration of Unit 2 steam generator feed pump 21 non-return valve, FW-0063; and Unit 2 sulfuric acid spill from cation regeneration acid pump

• March 5 - 9, 2012, Unit 1, large train A work week, small amount of air in low head safety injection, one steam dump did not go fully closed after testing, auxiliary air lock would not manually open, and increased trip risk due to switchyard work that placed Unit 1 a single breaker away from a main generator trip

• March 27 - 30, 2012, Unit 1, emergent maintenance activities associated with extended range nuclear instrument NI-45 failed channel check, steam generator A power operated relief valve isolation valve MS-0021 failed to open, shutdown bank A rod M-14 dropped into the core (See Section 4OA3 for more information), and planned surveillance testing of steam driven auxiliary feedwater pump 14 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 licensees probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of 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 issues:

• January 6, 2012, Unit 1, safety injection system train C gas voids found during surveillance testing

• January 19, 2012, Unit 2, jacket water leak on turbocharger on standby diesel generator 21

• February 20, 2012, Units 1 and 2, subcritical rod worth measurement methodology to verify the as-loaded core is consistent with the as-designed core

• March 8, 2012, Unit 2, residual heat removal pumps 2A and 2C lower motor bearing equipment qualification life

• March 14, 2012, Unit 2, dealloying and through-wall leakage on essential cooling water train C valve FV-6937

• March 19, 2012, Unit 1, refueling water storage tank indications of leakage due to the identification of boric acid residues near the base of the tank 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 UFSAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.

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

b. Findings

No findings were identified.

1R18 Plant Modifications

Permanent Modifications

a. Inspection Scope

On March 20, 2012, the inspectors reviewed key parameters associated with energy needs, materials, replacement components, timing, heat removal, equipment protection from hazards, operations, flow paths, pressure boundary, structural, process medium properties, licensing basis, and failure modes for the permanent modification identified as Unit 2 essential cooling water system downstream flange replacement from the component cooling water heat exchanger 2A discharge return valve, EW-0027.

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 the attachment.

These activities constitute completion of one sample for permanent 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:

• January 27, 2012, Unit 2, essential cooling water pump 2A replaced with self-lubricating pump

• February 15, 2012, Unit 1, auxiliary feedwater pump 12 anti-rotation pin inspection and replacement

• March 21, 2012, Unit 1, auxiliary feedwater pump 13 anti-rotation pin inspection and replacement

• March 21, 2012, Unit 2, engineered safety features train B load sequencer power supply replacement The inspectors selected these activities based upon the structure, system, or components ability to affect risk. The inspectors evaluated these activities for the following (as applicable):

• The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed

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

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

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

The inspectors reviewed the outage safety plan and contingency plans for the Unit 2 Forced Outage 2F1102, which commenced on November 29, 2011, to confirm that licensee personnel had appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense in depth. During the forced outage, the inspectors observed portions of the shutdown and cooldown processes and monitored licensee controls over the outage activities listed below.

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

• Clearance activities, including confirmation that tags were properly hung and equipment appropriately configured to safely support the work or testing.

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

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

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

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

• Controls over activities that could affect reactivity.

• Licensee identification and resolution of problems related to forced outage activities.

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

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

b. Findings

No findings were identified.

1R22 Surveillance Testing

.1 Surveillance Testing

a. Inspection Scope

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

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME Code requirements

• Updating of performance indicator data

• Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct

• Reference setting data

• Annunciators and alarms setpoints The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

• January 6, 2012, Unit 1, emergency core cooling system trains A, B, and C venting

• January 31, 2012, Unit 1, steam generator D power operated relief valve inservice testing

• February 8, 2012, Unit 1, emergency diesel generator 11 surveillance test

• March 29, 2012, Unit 1, auxiliary feedwater pump 14 inservice surveillance test Also, additional activities were performed during the review of safety injection system venting and valve verification that were associated with Temporary Instruction (TI) 2515/177, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems. This activity is described in bullet

.2 of this section.

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

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

b. Findings

No findings were identified.

.2 Surveillance Testing Associated with TI 2515/177, Managing Gas Accumulation in

Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems

a. Inspection Scope

When reviewing surveillance Procedure 0PSP03-SI-0014, ECCS Valve Checklist, Revision 14, the inspectors verified that the procedure was acceptable for void determination and elimination. The inspectors reviewed procedures used for conducting surveillances and determination of void volumes to ensure that the void criteria was satisfied and will be reasonably ensured to be satisfied until the next scheduled void surveillance (TI 2515/177, Section 04.03.a). Also, the inspectors reviewed procedures used for filling and venting following conditions which may have introduced voids into the subject systems to verify that the procedures acceptably addressed testing for such voids, and provided acceptable processes for their reduction or elimination (TI 2515/177, Section 04.03.b). Specifically, the inspectors verified that:

• Gas intrusion prevention, refill, venting, monitoring, trending, evaluation, and void correction activities were acceptably controlled by approved operating procedures (TI 2515/177, Section 04.03.c.1).

• Procedures ensured the system did not contain voids that may jeopardize operability (TI 2515/177, Section 04.03.c.2).

• Procedures established that void criteria were satisfied and will be reasonably ensured to be satisfied until the next scheduled void surveillance (TI 2515/177, Section 04.03.c.3).

• The licensee entered changes into the corrective action program, as needed, to ensure acceptable response to issues. In addition, the inspectors confirmed that a clear schedule for completion is included for corrective action program entries that have not been completed (TI 2515/177, Section 04.03.c.5).

• Procedures included independent verification that critical steps were completed (TI 2515/177, Section 04.03.c.6).

The inspectors verified the following with respect to surveillance and void detection:

• Specified surveillance frequencies were consistent with technical specification surveillance requirements (TI 2515/177, Section 04.03.d.1).

• Surveillance frequencies were stated, or when conducted more often than required by technical specifications, the process for their determination was described (TI 2515/177, Section 04.03.d.2).

• Surveillance methods were acceptably established to achieve the needed accuracy (TI 2515/177, Section 04.03.d.3).

• Surveillance procedures included up-to-date acceptance criteria (TI 2515/177, Section 04.03.d.4).

• Procedures included effective follow-up actions when acceptance criteria are exceeded or when trending indicates that criteria may be approached before the next scheduled surveillance (TI 2515/177, Section 04.03.d.5).

• Measured void volume uncertainty was considered when comparing test data to acceptance criteria (TI 2515/177, Section 04.03.d.6).

• Venting procedure and practice utilized criteria such as adequate venting durations and observing a steady stream of water (TI 2515/177, Section 04.03.d.7).

• An effective sequencing of void removal steps was followed to ensure that gas does not move into previously filled system volumes (TI 2515/177, Section 04.03.d.8).

• Qualitative void assessment methods included expectations that the void will be significantly less than allowed by acceptance criteria (TI 2515/177, Section 04.03.d.9).

• Venting results were trended periodically to confirm that the systems are sufficiently full of water and that the venting frequencies are adequate. The inspectors also verified that records on the quantity of gas at each location are maintained and trended as a means of preemptively identifying degrading gas accumulations (TI 2515/177, Section 04.03.d.10).

• Surveillances were conducted at any location where a void may form, including high points, dead legs, and locations under closed valves in vertical pipes (TI 2515/177, Section 04.03.d.11).

• The licensee ensured that systems were not preconditioned by other procedures that may cause a system to be filled, such as by testing prior to the void surveillance (TI 2515/177, Section 04.03.d.12).

• Procedures included gas sampling for unexpected void increases if the source of the void is unknown and sampling is needed to assist in determining the source (TI 2515/177, Section 04.03.d.13).

The inspectors verified the following with respect to void control:

• Void removal methods were acceptably addressed by approved procedures (TI 2515/177, Section 04.03.f.1).

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

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on February 8, 2012, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors also observed the drill from the technical support center. The inspectors observed event classification and notification activities and attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the attachment.

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

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

This area was inspected to verify the licensee is assuring the accuracy and operability of radiation monitoring instruments that are used to:

(1) monitor areas, materials, and workers to ensure a radiologically safe work environment; and

(2) detect and quantify radioactive process streams and effluent releases. 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:

• Selected plant configurations and alignments of process, post-accident and effluent monitors with descriptions in the UFSAR and the Offsite Dose Calculation Manual

• Select instrumentation, including effluent monitoring instrument, portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks

• Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, post-accident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors

• Audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.05-05.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

This area was inspected to:

(1) ensure the gaseous and liquid effluent processing systems are maintained so radiological discharges are properly mitigated, monitored, and evaluated with respect to public exposure;

(2) ensure abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out of service, are controlled in accordance with the applicable regulatory requirements and licensee procedures;

(3) verify the licensees quality control program ensures the radioactive effluent sampling and analysis requirements are satisfied so discharges of radioactive materials are adequately quantified and evaluated; and

(4) verify the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors used the requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190; the Offsite Dose Calculation Manual; and licensee procedures required by the technical specifications as criteria for determining compliance. The inspectors interviewed licensee personnel and reviewed and/or observed the following items:

• Radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection, if any

• Effluent program implementing procedures, including sampling, monitor setpoint determinations and dose calculations

• Equipment configuration and flow paths of selected gaseous and liquid discharge system components, filtered ventilation system material condition, and significant changes to their effluent release points, if any, and associated 10 CFR 50.59 reviews

• Selected portions of the routine processing and discharge of radioactive gaseous and liquid effluents (including sample collection and analysis)

• Controls used to ensure representative sampling and appropriate compensatory sampling

• Results of the interlaboratory comparison program

• Effluent stack flow rates

• Surveillance test results of technical specification required ventilation effluent discharge systems since the previous inspection

• Significant changes in reported dose values, if any

• A selection of radioactive liquid and gaseous waste discharge permits

• 10 CFR Part 61 analyses and methods used to determine which isotopes are included in the source term

• Offsite Dose Calculation Manual changes, if any

• Meteorological dispersion and deposition factors

• Latest land use census

• Records of abnormal gaseous or liquid tank discharges, if any

• Groundwater monitoring results

• Changes to the licensees written program for indentifying and controlling contaminated spills/leaks to groundwater, if any

• Identified leakage or spill events and entries made into 10 CFR 50.75(g) records, if any, and associated evaluations of the extent of the contamination and the radiological source term

• Offsite notifications and reports of events associated with spills, leaks, or groundwater monitoring results, if any

• Audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.06-05.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

a. Inspection Scope

This area was inspected to:

(1) ensure that the radiological environmental monitoring program verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program;

(2) verify that the radiological environmental monitoring program is implemented consistent with the licensees technical specifications and/or Offsite Dose Calculation Manual, and to validate that the radioactive effluent release program meets the design objective contained in Appendix I to 10 CFR Part 50; and

(3) ensure that the radiological environmental monitoring program monitors non-effluent exposure pathways is based on sound principles and assumptions and validates that doses to members of the public are within the dose limits of 10 CFR Part 20 and 40 CFR Part 190, as applicable. The inspectors reviewed and/or observed the following items:

• Annual environmental monitoring reports and Offsite Dose Calculation Manual

• Selected air sampling and thermoluminescence dosimeter monitoring stations

• Collection and preparation of environmental samples

• Operability, calibration, and maintenance of meteorological instruments

• Selected events documented in the annual environmental monitoring report which involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement

• Selected structures, systems, or components that may contain licensed material and has a credible mechanism for licensed material to reach groundwater

• Records required by 10 CFR 50.75(g)

• Significant changes made by the licensee to the Offsite Dose Calculation Manual as the result of changes to the land census, or sampler station modifications since the last inspection

• Calibration and maintenance records for selected air samplers, composite water samplers, and environmental sample radiation measurement instrumentation

• Interlaboratory comparison program results

• Audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.07-05.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

This area was inspected to verify the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors used the requirements of 10 CFR Parts 20, 61, and 71, and Department of Transportation regulations contained in 49 CFR Parts 171-180 for determining compliance. The inspectors interviewed licensee personnel and reviewed the following items:

• The solid radioactive waste system description, process control program, and the scope of the licensees audit program

• Control of radioactive waste storage areas, including container labeling/marking and monitoring containers for deformation or signs of waste decomposition

• Changes to the liquid and solid waste processing system configuration, including a review of waste processing equipment that is not operational or abandoned in place

• Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides

• Processes for waste classification including use of scaling factors and 10 CFR Part 61 analysis

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest

• Audits, self-assessments, reports and corrective action reports, radioactive solid waste processing, and radioactive material handling, storage, and transportation performed since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.08-05.

b. Findings

No findings were identified.

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the licensee for the fourth quarter 2011 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.

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 attached list of documents reviewed.

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 followup, 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 motor operated valve pinion inspection results. The inspectors reviewed the licensees UFSAR, technical specifications, design basis documents, corrective action program, system health reports, and Maintenance Rule documents to understand the functions and health of the motor operated valves being inspected. The inspectors also reviewed the fatigue rule program requirements as the valves were being inspected on an increased frequency, and the system engineer was directing work on several of the inspections. The inspectors determined that the licensee did not follow their procedures and processes, but the resulting deficiencies did not challenge operability of the systems involved. The licensee performed an apparent cause evaluation to understand the breakdown in their process. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one in-depth problem identification and resolution sample as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

.4 In-depth Review of Operator Workarounds

a. Inspection Scope

During the week of February 13, 2012, the inspectors reviewed the Units 1 and 2 operator workarounds, as well as the cumulative effects of the workarounds to:

(1) determine if the functional capability of the system was affected;

(2) determine if multiple mitigating systems could be affected;

(3) evaluate the effect of the operator workaround on the operators ability to implement, and respond correctly and timely to abnormal or emergency operating procedures; and

(4) verify that the licensee had identified and implemented appropriate corrective actions associated with operator workarounds. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one in-depth problem identification and resolution sample for operator workarounds as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

4OA3 Followup of Events and Notices of Enforcement Discretion

.1 (Closed) Licensee Event Report 05000499/2010-005-00, -01, and -02, Startup

Feed Pump 24 Breaker Failure and Unit 2 Reactor Trip On November 3, 2010, Unit 2 was performing a partial discharge analysis preventative maintenance activity on startup feed pump 24. Approximately 4 seconds after the pump was started, the pump breaker tripped open as a result of catastrophic failure, creating a breaker cubicle explosion. Approximately 8 seconds after the pump breaker tripped the voltage on standby bus 2H, which provided power to the startup feed pump, dropped to near zero, resulting in reactor coolant pump 2C tripping and generating a reactor trip.

Standby bus 2H also provides offsite power to engineered safety features bus C. The near zero voltage condition resulted in standby diesel generator 23 starting and supplying power to engineered safety features bus C. Additionally, standby busses 2H and 2F are electrically connected through the X winding of the Unit 2 auxiliary transformer; this resulted in some train A loads being secured due to under-voltage conditions. The plant was stabilized in Mode 3 at normal operating pressure and temperature. The licensee made an Unusual Event declaration for Unit 2 due to the breaker cubicle explosion. The licensee has captured this event in the corrective action program as Condition Report 10-23832, and determined the most probable cause of the breaker failure was moisture induced contamination creating an internal short. The licensees corrective actions included alternating current high potential testing and velocity testing of applicable breakers. There were no personnel injuries, no offsite radiological releases, and no damage to safety-related equipment. The inspectors reviewed the licensee event report and root cause investigation, and determined that the event was not within the licensees ability to foresee and prevent. Therefore, no findings were identified and no violation of NRC requirements occurred. This licensee event report is closed.

.2 (Closed) Licensee Event Report 05000498/2011-001-00, Technical Specification

Requirement Not Met Regarding Unborated Water Sources On April 30, 2011, during Refueling Outage 1RE16, Unit 1 was in Mode 5 with the reactor coolant system loops not filled when the licensee identified that Technical Specification 3.4.1.4.2.b requirements were not met because an unborated source of water was not properly secured from the reactor coolant system. During the pre-job review of a planned activity to transfer water from the boron recycle system recycle holdup tank 1B to the volume control tank, a senior reactor operator identified that two valves for the boron recycle system were not listed in the surveillance procedure used to ensure compliance with the technical specification. These valves, if left open, could have introduced unborated water from the demineralized water system into the reactor coolant system via the chemical volume and control system. The inspectors reviewed the root cause investigation, procedures, corrective action documents and interviewed station personnel. The enforcement aspects of this violation are discussed in Section 4OA7. This licensee event report is closed.

.3 Unit 1 Dropped Shutdown Bank A Rod M-14 During Monthly Surveillance Testing

a. Inspection Scope

The inspectors reviewed the licensees response to Unit 1 dropped shutdown bank A rod M-14 that occurred during surveillance testing.

Background On March 29, 2012, during the Unit 1 monthly surveillance test, shutdown bank A rod M-14 became misaligned from the rest of shutdown bank A. Group demand position was 256 steps and digital rod position indication was 240 steps. As a result, the licensee entered Technical Specification 3.1.3.1 for rod M-14 not within +/- 12 steps of group demand position. During the process of trying to restore rod M-14 to the full-out position of 252 steps on digital rod position indication, the rod dropped into the core.

The crew reduced reactor power to approximately 73 percent rated thermal power and performed the required technical specification actions, including shutdown margin verification. Prior to attempting to recover the dropped rod, the licensee reduced power to approximately 37 percent rated thermal power, per procedure. Later the same day, the licensee successfully recovered rod M-14 and restored it to the full-out position.

Since the rod was incorrectly aligned to the rest of shutdown bank A for greater than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, by procedure, the licensee was limited to restoring reactor power at 3 percent per hour. On March 30, 2012, at the end of the inspection period, the licensee returned the unit to approximately 70 percent rated thermal power. The most probable cause of the dropped rod was corrosion products around the movable gripper.

The inspectors observed and interviewed licensee personnel to ensure that all safety requirements were maintained and all procedures were correctly followed. The inspectors determined that the licensee appropriately followed procedures and maintained reactivity control.

b. Findings

No findings were identified.

4OA5 Other Activities

(Closed) TI 2515/177, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (NRC Generic Letter 2008-01)

a. Inspection Scope

The inspectors verified that the onsite documentation, system hardware, and licensee actions were consistent with the information provided in the licensees response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems. Specifically, the inspectors verified that the licensee has implemented or was in the process of implementing the commitments, modifications, and programmatically controlled actions described in the licensees response to Generic Letter 2008-01. The inspection was conducted in accordance with TI 2515/177, Managing Gas Accumulation in Emergency Core

Cooling, Decay Heat Removal, and Containment Spray Systems (NRC Generic Letter 2008-01) and considered the site-specific supplemental information provided by the Office of Nuclear Reactor Regulations to the inspectors.

Inspection Documentation The selected TI areas of inspection were licensing basis, design, testing, and corrective actions. The documentation of the inspection effort and any resulting observations are below.

Licensing Basis The inspectors reviewed selected portions of licensing basis documents to verify that they were consistent with the Office of Nuclear Reactor Regulations assessment report and that they were processed by the licensee. The licensing basis verification included the verification of selected portions of technical specifications, technical specification basis, UFSAR, and technical requirements manual. The inspectors also verified that applicable documents that described the plant and plant operation, such as calculations, piping and instrumentation diagrams, procedures, and corrective action program documents addressed the areas of concern and were changed if needed following plant changes. The inspectors also confirmed that the frequency of selected surveillance procedures were at least as frequent as required by technical specifications. Finally, the inspectors verified that the commitment to evaluate and implement the applicable changes that will be contained in the technical specification task force traveler was consistent with the commitment described in Office of Nuclear Reactor Regulations assessment report and that it addressed any comments provided by Office of Nuclear Reactor Regulations.

Design The inspectors reviewed selected design documents, performed system walkdowns, and interviewed plant personnel to verify that the design and operating characteristics were addressed by the licensee. Specifically:

• The inspectors verified that the licensee has identified the gas intrusion mechanisms that apply to the licensees plant. At the time of the inspection, the licensee completed evaluations for the suction piping of the subject systems; however, as of January 27, 2012, the licensees evaluation of the discharge piping was incomplete. The inspectors verified that corrective actions and dates to complete the evaluations were placed into the corrective action program. The inspectors also verified the licensee had identified the gas intrusion mechanisms associated with the operability evaluation of the Unit 2 high head safety injection pump 2C in an earlier inspection period. This additional activity counted towards the completion of this TI and was documented in NRC Inspection Report 05000498/2011002 and 05000499/2011002.

• The inspectors verified that the licensees void acceptance criteria were consistent with Office of Nuclear Reactor Regulations void acceptance criteria.

Where Office of Nuclear Reactor Regulations acceptance criteria were not met, the inspectors verified that the licensee had justified the deviations. The inspectors also confirmed that:

(1) the licensee addressed the effect of pressure changes during system startup and operation since such changes could

significantly affect the void fraction from the initial value, and

(2) the range of flow conditions evaluated by the licensee was consistent with the full range of design basis and expected flow rates for various break sizes and locations. The inspectors also confirmed that the licensee used the void acceptance criteria when conducting an operability evaluation of the Unit 2 high head safety injection pump 2C in an earlier inspection period. This additional activity counted towards the completion of this TI and was documented in NRC Inspection Report 05000498/2011002 and 05000499/2011002.

• The inspectors selectively reviewed applicable documents, including calculations, engineering evaluations and vendor technical manuals with respect to gas accumulation in the subject systems. Specifically, the inspectors verified that these documents addressed venting requirements, aspects where pipes are normally void such as some spray piping inside containment, void control during system realignments, and the effect of debris on strainers in containment emergency sumps causing accumulation of gas under the upper elevation of strainers, and the impact on net positive suction head requirements.

• The inspectors conducted a walkdown of selected regions of Unit 1 high head safety injection and low head safety injection systems and the Unit 2 residual heat removal system in sufficient detail to assess the licensees walkdown. The inspectors also verified that the information obtained during the licensees walkdown was consistent with the items identified during the inspectors independent walkdown.

• In addition, the inspectors verified that the licensee had piping and instrumentation diagrams and isometric drawings that accurately describe the high head safety injection, low head safety injection, containment spray, and residual heat removal system configurations. The inspectors review of the selected portions of isometric drawings considered the following:

1. High point vents were identified.

2. High points that do not have vents were recognizable.

3. Other areas where gas can accumulate and potentially impact subject system operability, such as at orifices in horizontal pipes, isolated branch lines, heat exchangers, improperly sloped piping, and under closed valves were described in the drawings or in referenced documentation.

4. Horizontal pipe centerline elevation deviations and pipe slopes in nominally horizontal lines that exceed specified criteria were identified.

5. All pipes and fittings were clearly shown.

6. The drawings were up-to-date with respect to recent hardware changes, and that any discrepancies between as-built configurations and the drawings were documented and entered into the corrective action program for resolution.

• The inspectors also conducted a similar walkdown of selected portions of Unit 1 train A residual heat removal system in an earlier inspection period. This additional activity counted towards the completion of this TI and was documented in NRC Inspection Report 05000498/2011003 and 05000499/2011003.

Testing The inspectors reviewed selected surveillance, post-modification test, and post-maintenance test procedures and results to verify that the licensee has approved and was using procedures that were adequate to address the issue of gas accumulation and/or intrusion in the subject systems. This review included the verification of procedures used for conducting surveillances and determination of void volumes to ensure that the void criteria was satisfied and will be reasonably ensured to be satisfied until the next scheduled void surveillance. Also, the inspectors reviewed procedures used for filling and venting following conditions which may have introduced voids into the subject systems to verify that the procedures addressed testing for such voids and provided processes for their reduction or elimination. Earlier in the inspection period, the inspectors reviewed surveillance tests results for the Unit 1 emergency core cooling systems. This additional activity counted towards the completion of this TI and was documented in Section 1R22 of this inspection report. Additionally, inspectors reviewed surveillance test results for the Unit 2 residual heat removal train 2C system. This additional activity counted towards the completion of this TI and was documented in NRC Inspection Report 05000498/2010003 and 05000499/2010003.

Corrective Actions The inspectors reviewed selected licensees assessment reports and corrective action program documents to assess the effectiveness of the licensees corrective action program when addressing the issues associated with Generic Letter 2008-01. In addition, the inspectors verified that selected corrective actions identified in the licensees 9-month and supplemental reports were documented. The inspectors also verified that commitments were included in the corrective action program.

The documents reviewed are listed in the attachment to this report.

Based on this review, the inspectors concluded that there is reasonable assurance that the licensee will complete all outstanding items and incorporate this information into the design basis and operational practices. Therefore, this TI is considered closed.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On January 26, 2012, the inspectors presented the inspection results for TI 2515/177 to Mr. D. Rencurrel, Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

On February 2, 2012, the inspectors presented the results of the radiation safety inspection to Mr. D. Rencurrel, Chief Nuclear Officer, 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 April 5, 2012, the inspectors presented the inspection results to Mr. G. Powell, Vice President, Generation, Units 1 and 2, 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.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by the licensee and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as non-cited violations.

.1 Technical Specification 3.4.1.4.2.b requires that, each valve or mechanical joint used to

isolate unborated water sources shall be secured in the closed position. Contrary to the above since 2003, when the recycle holdup tanks were used to fill the reactor coolant system, boron recovery system valves BR-204 and BR-205 were closed but not secured (locked). The inspectors used Manual Chapter 0609, Appendix G, and determined that the finding was of very low safety significance because there was no reactivity change that warranted a quantitative risk analysis. This item was entered into the corrective action program as Condition Report 11-7747.

.2 Technical Specification 6.8.1.a requires, in part, that written procedures shall be established,

implemented, and maintained covering the applicable procedures in Appendix A of Regulatory Guide 1.33, Revision 2. Regulatory Guide 1.33, Appendix A, Section 8(1) (dd)recommends procedures for surveillance tests. Procedure 0PSP03-MS-0001, Main Steam System Valve Operability Test, Revision 38, step 5.9.25 stated, PLACE SG PORV STATION BLACKOUT PWR PV-7441 in BYP position (EAB 10, Rm 015, ASP, ZLP-100).

Contrary to the above, on January 31, 2012, during a surveillance test on steam generator 1D power operated relief valve, a non-licensed operator failed to review and implement the procedure step as written. The finding was of very low safety significance because it did not result in a loss of system safety function; it was not inoperable for longer than its technical specification allowed outage time; and it was not risk significant due to seismic, flooding, or severe weather initiating event. This item was entered into the corrective action program as Condition Report 12-5448.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Aguilera, Manager, Health Physics

A. Barnett, Engineer, Systems Engineering

M. Berg, Manager, Design Engineering

C. Bowman, Manager, Technical

D. Bryant, Manager, Chemistry

J. Calvert, Manager, Training

S. Cameron, Supervisor, Quality Assurance

R. Dunn Jr., Manager, Fuels and Analysis

R. Engen, Site Engineering Director

T. Frawley, Manager, Operations

J. Hartley, Manager, Mechanical Maintenance

M. Hiatt, Sr. Engineer, Maintenance Engineering

G. Hildebrandt, Manager, Plant Protection

G. Janak, Manager, Unit 1 Operations

B. Jenewein, Manager, Systems Engineering

G. Kelton, Supervisor, Radioactive Material Controls Supervisor, Health Physics

J. Lovejoy, Manager, I&C Maintenance

J. Loya, Engineer, Licensing

G. MacDonald, Manager, Organizational Effectiveness

R. McNiel, Manager, Maintenance Engineering

J. Mertink, Plant Management Knowledge Transfer

J. Milliff, Manager, Unit 2 Operations

M.Murray, Manager Licensing

J. Paul, Engineer, Licensing Consultant

L. Peter, Plant General Manager

J. Pierce, Manager, Operations Training

G. Powell, Vice President, Generation, Units 1 and 2

M. Reddix, Manager, Security Training

D. Rencurrel, Chief Nuclear Officer

K. Richards, President and Chief Executive Officer

M. Ruvalcaba, Manager, Testing and Programs

R. Savage, Engineer, Licensing Staff Specialist

M. Schaefer, Manager, Maintenance

K. Scoggins; Supervisor, Metrology Lab

S. Sovizral, Manager, Security Operations

L. Spiess, Non-Destructive Examination

R. Stark, Supervisor, Performance Testing

C. Stone, General Supervisor Operations, Health Physics

D. Swett, General Supervisor Technical, Health Physics

K. Taplett, Senior Engineer, Licensing Staff

D. Zink, Supervising Engineering Specialist

Attachment 1

NRC Personnel

J. Dixon; Senior Resident Inspector

B. Tharakan, Resident Inspector

M. Young, Reactor Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed

05000499/2010-005-00 Startup Feed Pump 24 Breaker Failure and Unit 2

05000499/2010-005-01 LER Reactor Trip (Section 4OA3)

05000499/2010-005-02 Technical Specification Requirement Not Met Regarding

05000498/2011-001-00 LER Unborated Water Sources (Section 4OA3)