Text

IR 05000445-13-005, 05000446-13-005; 9/26/2013 - 12/31/2013; Comanche Peak Nuclear Power Plant, Units 1 and 2 Integrated Resident and Regional Report; Operability Evaluations and Functionality Assessments, Plant Modifications
	ML14036A060
Person / Time
Site:	Comanche Peak
Issue date:	02/04/2014
From:	Webb Patricia Walker; NRC/RGN-IV/DRP
To:	Flores R; Luminant Generation Co
References
	IR-13-005
	Download: ML14036A060 (40)
	v • d • e

UNITE D S TATE S NUC LEAR RE GULATOR Y C OMMI S SI ON RE G IO N I V 1600 EAST LAMAR BLVD AR L INGTON , TEXAS 760 11 - 4511 February 4, 2014 Rafael Flores, Senior Vice President and Chief Nuclear Officer Luminant Generation Company, LLC Comanche Peak Nuclear Power Plant P.O. Box 1002 Glen Rose, TX 76043 Subject: COMANCHE PEAK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000445/2013005 AND 05000446/2013005

Dear Mr. Flores:

On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Comanche Peak Nuclear Power Plant, Units 1 and 2. On January 9, 2014, the NRC inspectors discussed the results of this inspection with Mr. K. Peters, Site Vice President, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

One of these findings involved a violation of NRC requirements. Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating these violations as non-cited violations (NCVs)

consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Comanche Peak Nuclear Power Plant, Units 1 and 2.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the Comanche Peak Nuclear Power Plant, Units 1 and 2. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents 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, Branch Chief Project Branch A Division of Reactor Projects Docket Nos.: 05000445, 05000446 License Nos.: NPF-87, NPF-89

Enclosure:

Inspection Report 05000445/2013005 and 05000446/2013005 w/Attachments: 1. Supplemental Information 2. Request for Information - O

REGION IV==

Docket: 50-445, 50-446 License: NPF-87, NPF-89 Report: 05000445/2013005 and 05000446/2013005 Licensee: Luminant Generation Company LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: FM-56, Glen Rose, Texas Dates: September 26 through December 31, 2013 Inspectors: J. Kramer, Senior Resident Inspector R. Kumana, Resident Inspector L. Carson II, Senior Health Physicist J. Dixon, Senior Reactor Inspector P. Elkmann, Senior Emergency Preparedness Inspector N. Greene, PhD, Health Physicist N. Okonkwo, Reactor Inspector D. Strickland, Operations Engineer Approved By: Wayne Walker, Chief, Project Branch A Division of Reactor Projects-1- Enclosure

SUMMARY

IR 05000445/2013005, 05000446/2013005; 9/26/2013 - 12/31/2013; Comanche Peak Nuclear

Power Plant, Units 1 and 2 Integrated Resident and Regional Report; Operability Evaluations and Functionality Assessments, Plant Modifications The inspection activities described in this report were performed between September 26, 2013, and December 31, 2013, by the resident inspectors at the Comanche Peak Nuclear Power Plant and six inspectors from the NRCs Region IV office. Two findings of very low safety significance (Green) are documented in this report. One of these findings involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White,

Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC s Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, for the failure to follow instructions and maintain appropriate housekeeping and cleanliness controls when performing an inspection in the containment emergency sump. As a result, the four sections of tape that were attached to the wheels of the robot, used to perform the inspection, fell off and remained in the sump for an operating cycle. The licensee entered the finding into the corrective action program as Condition Report CR-2013-005097.

The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee did not follow documented instructions and ensure no foreign material remained in the sump after the inspection. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The finding has a human performance cross-cutting aspect associated with resources, in that, the licensee failed to ensure the work instruction was adequate for the inspection activity H.2(c)(Section 1R15).

Green.

The inspectors reviewed a self-revealing finding for the failure of maintenance personnel to follow work instructions. Specifically, maintenance personnel failed to follow instructions and cut the wrong cable during a transformer modification. As a result, one offsite power source to both units was unavailable during the repair of the damaged cable. The licensee entered the finding into the corrective action program as Condition Report CR-2013-011124.

The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609,

Appendix A, The Significance Determination Process for Findings At Power, the finding was determined to be of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The finding has a human performance cross-cutting aspect associated with work practices in that the licensee personnel failed to use human performance error prevention techniques such as self and peer checking when cutting cables H.4(a)(Section 1R18).

Licensee-Identified Violations

A violation of very low safety significance that 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. This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.

PLANT STATUS

Unit 1 began the inspection period at approximately 100 percent power. On November 15, 2013, operators reduced power to approximately 75 percent for turbine valve testing. The unit returned to approximately 100 percent power the next day. On December 4, 2013, operators reduced power to approximately 95 percent in response to a loss of offsite power to the safety-related 6.9 kV buses. The unit returned to approximately 100 percent power the same day and operated at that power level for the remainder of the inspection period.

Unit 2 began the inspection period at approximately 100 percent power. On November 1, 2013, the unit experienced an automatic reactor trip during a solid state protection system relay test.

On November 3, 2013, operators performed a reactor startup and placed the unit on the grid.

The unit achieved approximately 100 percent power the following day. On December 4, 2013, operators reduced power to approximately 92 percent in response to a loss of offsite power to the safety-related 6.9 kV buses. The unit returned to approximately 100 percent power the same day and operated at that power level for the remainder of the inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On November 7, 2013, the inspectors completed an inspection of the stations readiness for seasonal extreme weather conditions. The inspectors reviewed the licensees adverse weather procedures for cold weather and evaluated the licensees implementation of these procedures. The inspectors verified that prior to cold weather the licensee had corrected weather-related equipment deficiencies identified during the previous season. The inspectors selected the following risk-significant systems that were required to be protected from the cold weather:

Fire protection system

Station service water system

Radiation monitoring system The inspectors reviewed the licensees procedures and design information to ensure the systems would remain functional when challenged by cold weather. The inspectors verified that operator actions described in the licensees procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the systems.

These activities constituted one sample of readiness for seasonal adverse weather as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On October 29, 2013, the inspectors performed a walkdown of the protected area to access the stations readiness for impending adverse weather conditions. The inspectors specifically looked for any loose debris that could become missiles during a high wind condition. In addition, the inspectors reviewed the licensees implementation procedure for high winds.

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

b. Findings

No findings were identified.

1R04 Equipment Alignment

Main article: IP 71111.04

.1 Partial Walkdown

a. Inspection Scope

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

October 16, 2013, Units 1 and 2 service water, transformer XST2, and Unit 2 alternate power diesel generators when transformer XST1 was unavailable during modification activities

November 20, 2013, Unit 2, diesel generator 2-01 when diesel generator 2-02 was unavailable for maintenance and modifications

December 5, 2013, Unit 2, diesel generator 2-02 when both sources of offsite power were unavailable and diesel generator 2-02 was supplying emergency power The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. The inspectors verified that critical portions of the systems were correctly aligned for the existing plant configuration.

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

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

The inspectors performed a complete system walkdown of the Unit 2 component cooling water system to verify the functional capability of the system. The inspectors walked down the system to review mechanical and electrical equipment line-ups, system pressure and temperature indications, component labeling, component lubrication, hangers and supports, and to ensure that ancillary equipment or debris did not interfere with equipment operation. The inspectors reviewed a sample of past and outstanding work orders to determine whether any deficiencies significantly affected the systems function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment problems were being identified and appropriately resolved.

These activities constitute completion of one complete system walkdown sample as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

Main article: IP 71111.05

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on the following plant areas important to safety:

October 15, 2013, fire zone SB8, Unit 1 safeguards building 810 corridor

November 18, 2013, fire area FP, fire protection pump house

December 14, 2013, fire zone 1SG10A, diesel generator 1-01 room

December 14, 2013, fire zone 1SI12A, diesel generator 1-02 room For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constitute completion of four quarterly inspection samples as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

Main article: IP 71111.11

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On October 21, 2013, the inspectors observed a simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the scenario.

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

a. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity. The inspectors assessed the operators adherence to plant procedures and other operations department policies. The inspectors observed the operators performance of the following activities:

October 23, 2013, Unit 2, transfer of controlling channel of steam generator level instrumentation

October 30, 2013, Units 1 and 2, operator performance during unplanned inoperability of transformer XST1

November 2, 2013, Unit 2, operator performance following the Unit 2 reactor trip

December 5, 2013, Units 1 and 2, transfer of safety-related 6.9 kV bus power supply from the diesel generators to offsite power These activities constitute completion of one quarterly review of licensed operator performance sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Annual Inspection

The licensed operator requalification program involves two training cycles that are conducted over a 2-year period. In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator

scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comprehensive written examination. For this annual inspection requirement, Comanche Peak Nuclear Power Plant was in the first part of the training cycle.

a. Inspection Scope

The inspectors reviewed the results of the operating tests for the plant to satisfy the annual inspection requirements.

On January 2, 2014, the licensee informed the lead inspector of the results:

15 of 16 crews passed the simulator portion of the operating test

88 of 94 licensed operators passed the simulator portion of the operating test

92 of 94 licensed operators passed the job performance measure portion of the operating test All the failures were successfully remediated prior to being returned to licensed duties.

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

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12

a. Inspection Scope

The inspectors evaluated the degraded performance or condition of the following risk-significant structures, systems, or components:

Unit 2 safety injection accumulators

Units 1 and 2 plant computer system

Unit 1 reactor trip switchgear

Unit 2 diesel generators The inspectors reviewed the extent of condition of possible common cause structure, system, or component failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the structures, systems, or components. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of four maintenance effectiveness samples as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. Inspection Scope

The inspectors reviewed the licensees 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:

October 7, 2013, risk associated with 345 kV breaker maintenance

October 16, 2013, risk associated with transformer XST1 outage

December 5, 2013, risk associated with no offsite power available to the safety-related 6.9 kV buses The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

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

b. Findings

No findings were identified.

1R15 Operability Evaluations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed the following operability determinations that the licensee performed for degraded or nonconforming structures, systems, or components:

Condition Report CR-2013-005097, Unit 1, tape in containment sump

Condition Report CR-2013-008947, Units 1 and 2, containment airlock gauge classification

Condition Report CR-2013-010297 associated with unprotected ammeter wiring

Condition Report CR-2013-011425 associated with diesel generator 2-01 shutdown system activated light not illuminated

Condition Report CR-2013-011618, Units 1 and 2, post-accident sampling system containment isolation valves

Condition Report CR-2013-012209, Unit 2, atmospheric relief valve current to pressure (I/P) convertor failure The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded structures, systems, or components to be operable, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability.

The inspectors reviewed Operating Experience Smart Sample (OpESS) FY2007-01, PWR Containment Sump Recirculation Pipe Foreign Material Blockage, in the evaluation of Condition Report CR-2013-005097.

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

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to follow instructions and maintain appropriate housekeeping and cleanliness controls when performing an inspection in the containment emergency sump. As a result, the four sections of tape that were attached to the wheels of the robot, used to perform the inspection, fell off and remained in the sump for an operating cycle.

Description.

On April 16, 2013, the inspectors observed the performance of the Unit 1 containment sump inspection. The inspectors observed four circular sections of red tape inside the containment sump. The licensee had used red duct tape as a wheel cover for the inspection robot to prevent contamination. The four tape sections, observed by the inspectors, had fallen off the robot wheels during the previous inspection and remained inside the sump for the complete operating cycle, 18 months.

The licensee personnel performing the inspection also observed the tape in the sump and informed supervision of the observation. The licensee developed and implemented a plan to remove the tape. The inspectors ultimately questioned the licensee about the past operability of the tape in the sump. Based on the inspectors questioning, the licensee realized the tape had been in the sump for a complete operating cycle. The licensee contracted with a vendor to evaluate the effects of the tape on the plant equipment during the recirculation phase of an accident. The licensee concluded that the components and systems would remain capable of performing their intended safety function. The inspectors agreed with the licensees assessment and concluded that the evaluation was thorough.

The inspectors reviewed work order 3936127 that was used by the licensee personnel to perform the containment sump inspection. The inspectors observed that the work order directed that housekeeping zone II, cleanliness class B, be in effect in the immediate area of the containment spray and residual heat removal flue openings. The inspectors concluded that, although the necessary steps for housekeeping were included in the instructions, the instructions were not clearly organized.

Analysis.

The licensees failure to follow documented instructions when performing the containment sump inspection was a performance deficiency. The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee did not follow documented instructions and ensure no foreign material remained in the sump after the inspection. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The finding has a human performance cross-cutting aspect associated with resources, in that, the licensee failed to ensure the work instruction was adequate for the inspection activity H.2(c).

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions. Work Order 3936127, used to perform a containment emergency sump inspection, an activity affecting quality, directed housekeeping zone II, cleanliness class B, be in effect in the immediate area of the containment spray and residual heat removal flue openings. Contrary to the above, on October 14, 2011, the licensee performed an activity affecting quality and failed to accomplish the activity in accordance with documented instructions. Specifically, the licensee failed to follow instructions and maintain appropriate housekeeping and cleanliness controls when performing an inspection on the containment emergency sump. As a result, the four sections of tape that were attached to the wheels of the robot, used to perform the inspection, fell off and remained in the sump for an operating cycle. After identification of the tape, the licensee removed the tape from the sump.

Since the violation was of very low safety significance and was documented in the licensees corrective action program as Condition Report CR-2013-005097, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000445/2013005-01, Failure to Follow Instructions for Containment Sump Inspection Results in Debris Left in the Sump.

1R18 Plant Modifications

Main article: IP 71111.18

a. Inspection Scope

The inspectors reviewed work instructions and condition reports associated with the plant modification of transformer XST1. The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event.

These activities constitute completion of one plant modifications inspection sample as defined in Inspection Procedure 71111.18.

b. Findings

Introduction.

The inspectors reviewed a Green self-revealing finding for the failure of maintenance personnel to follow work instructions. Specifically, maintenance personnel failed to follow instructions and cut the wrong cable during a transformer modification.

As a result, one offsite power source to both units was unavailable during the repair of the damaged cable.

Description.

On October 30, 2013, during the performance of work order 4651370, maintenance personnel inadvertently cut the neutral phase of the ground protection circuit for transformer XST1. During the activity, the first craftsman correctly identified the cable to be cut. The first craftsman shook the cable so the second craftsman, with the cutting tool, would be able to identify the cable needing to be cut. The first craftsman maintained his hand on the cable to further identify the cable to cut. The second craftsman observed movement in a different cable, grabbed the cable, and proceeded to cut the incorrect cable. The craftsmen were standing next to each other when the incorrect cable was cut and both failed to prevent the cutting of the incorrect cable.

The inspectors discussed the finding with the licensee and reviewed the licensees cause analysis. The inspectors determined that electricians performing the activity failed to use proper human performance error prevention techniques and cut the wrong cable.

Analysis.

The failure of maintenance personnel to follow instructions when cutting a cable was a performance deficiency. As a result, the incorrect cable was cut and one source of offsite power was unavailable to both units. The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 2 Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance (Green)because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The finding has a human performance cross-cutting aspect associated with work practices in that the licensee personnel failed to use human performance error prevention techniques such as self and peer checking when cutting cables H.4(a).

Enforcement.

This finding does not involve enforcement action because no violation of a regulatory requirement was identified. The licensee documented the finding in the corrective action program as Condition Report CR-2013-011124. Because the finding does not involve a violation and is of very low safety significance, it is being characterized as finding FIN 05000445/2013005-02; 05000446/2013005-02, Cutting Incorrect Cable Results in an Inoperable Offsite Power Source.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities that affected risk-significant structures, systems, or components:

October 2, 2013, Unit 1, positive displacement charging pump testing following flange gasket replacement

October 21, 2013, Unit 1, auxiliary feedwater flow instrument check following instrument manifold replacement

November 6, 2013, Unit 1, charging pump 1-01 testing following motor breaker control device replacement

November 15, 2013, Unit 1, steam generator narrow range level 0519 testing following lead/lag amplifier card replacement

December 3, 2013, Unit 1, diesel generator 2-02 auxiliary jacket water pump test following mechanical seal replacement

December 16, 2013, Unit 1, offsite sources operability following breaker control device replacement

December 17, 2013, Units 1 and 2, spent fuel pool cooing water pump X-02 post-maintenance check following pump and motor oil change The inspectors reviewed licensing and design basis documents for the structures, systems, or components and the maintenance and post-maintenance test procedures.

The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected structures, systems, or components.

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

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors observed risk-significant surveillance tests and reviewed test results to verify that the tests adequately demonstrated that the structures, systems, and components were capable of performing their safety functions:

Routine Surveillance Testing

October 7, 2013, Unit 2, train A reactor trip breaker testing in accordance with Procedure OPT-447B, Mode 1, 3 and 4 Train A SSPS Actuation Logic Test, Revision 12

October 10, 2013, Unit 1, turbine driven AFW pump testing in accordance with Procedure OPT-206A, AFW System, Revision 29

October 10, 2013, Unit 1, turbine driven AFW check valve reverse flow testing in accordance with Procedure OPT-530A, AFW Check Valve Reverse Flow Test, Revision 4

December 2, 2013, Unit 2, steam generator 2-01 atmospheric relief valve testing in accordance with Procedure OPT-504B, MS Valve Testing, Revision 12 The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected structures, systems, and components following testing.

The inspectors utilized Operating Experience Smart Sample (OpESS) FY2009-02, Negative trend and Recurring Events Involving Feedwater Systems during the performance of the inspections for the turbine driven auxiliary feedwater pump testing and check valve testing.

These activities constitute completion of four surveillance testing inspection samples (four routine surveillance testing samples) as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP1 Drill Evaluation

Main article: IP 71114.01

a. Inspection Scope

The inspectors observed the biennial emergency plan exercise conducted October 9, 2013, to determine if the exercise acceptably tested major elements of the licensee emergency plan and provided opportunities to demonstrate key emergency response organization skills. The scenario simulated the following to demonstrate the licensee personnels capability to implement their emergency plan:

A ground-based attack on the plant protected area causing casualties among plant employees

Damage to the auxiliary boiler fuel oil storage tank with burning fuel oil entering the protected area

Catastrophic damage to two station transformers

Damage to Unit 1 diesel generators, resulting in a loss of power to Unit 1 vital electric buses

A loss of feedwater to Unit 1

Damage to the waste gas decay tanks causing a radiological release to the environment

An integrated law enforcement response to the licensees site and activation of an incident command post The inspectors evaluated exercise performance by focusing on the risk-significant activities of event classification, offsite notification, recognition of offsite dose consequences, and development of protective action recommendations, in the control room simulator and the following emergency response facilities:

Alternate Technical Support Center

Alternate Operations Support Center

Emergency Operations Facility

Incident Command Post.

The inspectors also assessed recognition of, and response to, abnormal and emergency plant conditions, the transfer of decision making authority and emergency function responsibilities between facilities, onsite and offsite communications, protection of emergency workers, coordination of physical security arrangements between the site security organization and offsite law enforcement agencies, and the overall implementation of the emergency plan to protect public health and safety and the environment. The inspectors reviewed the current revision of the facility emergency plan, emergency plan implementing procedures associated with operation of the licensees emergency response facilities, procedures for the performance of associated emergency functions, and other documents as listed in the attachment to this report.

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS2 Occupational ALARA Planning and Controls

Main article: IP 71124.02

a. Inspection Scope

The inspectors assessed licensee performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). During the inspection, the inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:

Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site-specific trends in collective exposures, and source-term measurements

ALARA work activity evaluations/postjob reviews, exposure estimates, and exposure mitigation requirements

The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies

Records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry

Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas by reviewing condition reports and performance audits

Audits, self-assessments, and corrective action documents related to ALARA planning and controls since the last inspection These activities constitute completion of one occupational ALARA planning and controls sample as defined in Inspection Procedure 71124.02.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

Main article: IP 71124.04

a. Inspection Scope

The inspectors verified the accuracy and operability of the licensees personnel monitoring equipment, verified the accuracy and effectiveness of the licensees methods for determining total effective dose equivalent, and verified that the licensee was appropriately monitoring occupational dose. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:

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

The technical competency and adequacy of the licensees internal dosimetry program

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

Audits, self-assessments, and corrective action documents related to dose assessment since the last inspection

These activities constitute completion of one occupational dose assessment sample as defined in Inspection Procedure 71124.04.

b. Findings

No findings were identified.

The inspectors sampled licensee submittals for the alert and notification system performance indicator for the period April 2012 through September 2013. The inspectors used definitions and guidance of Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, to determine the accuracy of the reported data. The inspectors reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator and the results of periodic alert notification system operability tests.

These activities constitute completion of one alert and notification system sample as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

Main article: IP 71152

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semi-Annual Trend Review

Inspection Scope The inspectors reviewed the licensees corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused on the safety-related procurement engineering program backlogs. The inspectors reviewed documents and interviewed personnel to determine if the licensee completely and accurately identified problems in a timely manner commensurate with its significance, evaluated and dispositioned operability issues,

considered the extent of condition, prioritized the problem commensurate with its safety significance, identified appropriate corrective actions, and completed corrective actions in a timely manner commensurate with the safety significance of the issue.

These activities constitute completion of one semi-annual trend review sample as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

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

Main article: IP 71153

The following activities constitute completion of four follow-up of events and notices of enforcement discretion samples as defined in Inspection Procedure 71153.

.1 (Closed) Licensee Event Report 05000445/2012-001-00, Unanalyzed Condition

Discovered for the Normally Open Battery Room Fire and Cable Spread Room Doors Close on Momentary Loss of Power The inspectors reviewed the licensee event report that documented an issue where several battery room doors were held open with electromagnetic door devices. Without an uninterruptible power to the door mechanisms, the doors would close in a loss of offsite power event. Inadvertent closure of the doors following a momentary loss of power prevents the doors from performing the hydrogen venting function and providing tornado venting pathways in the building. The licensee initiated compensatory measures to secure the doors in the open position and initiated a roving fire watch to comply with the fire protection function of the doors. The licensee replaced the batteries for the electromagnetic door devices and created a maintenance activity to ensure the doors devices operate as designed. The inspectors reviewed Condition Report CR-2012-0002186 that documented the issue and the work orders that corrected the issue. In addition, the inspectors reviewed the licensees past operability evaluation.

The evaluation documented that the all structures, systems, and components remained operable for hydrogen generation and tornado venting concerns. The enforcement aspects of this finding are discussed in Section 4OA7. This licensee event report is closed.

.2 (Closed) Licensee Event Report 05000445/2012-002-00, Failure of Safety Related

Breaker Control Devices due to a Common Cause The licensee event report documented failures of safety related 6.9 kV circuit breaker control devices. The licensee hired a vendor to perform a failure analysis and the vendor concluded the failures of control devices were caused by a material weakness of the control device contact carrier frames as a result of a manufacturing defect. The licensees corrective actions included the replacement of the potentially affected safety-related breaker control devices and the development of a receipt inspection testing criteria to be used for the control devices. The inspectors reviewed the licensee event report. No findings or violations of NRC requirements were identified. This licensee event report is closed.

.3 (Open) Units 1 and 2 Loss of Offsite Power to the Safety-Related 6.9 kV Buses and

Notice of Enforcement Discretion 13-4-004 On December 4, 2013, the two required offsite circuits to both Units 1 and 2 safety-related 6.9 kV buses became inoperable during planned modification work to install an additional 138 kV transformer (XST1A). As a result of the event, the licensee declared an Unusual Event. The inspectors responded to the control room to access the operators performance, procedure usage, and proper emergency plan declaration. The inspectors performed a walkdown of the control boards to verify appropriate equipment response following the loss of offsite power. The inspectors discussed the event with licensee personnel and the control room staff.

Power was lost to the 345 kV transformer (XST2), which at the time was providing power to the 6.9 kV safeguards buses for both Units 1 and 2, when the licensee inadvertently cut into an energized 6.9 kV cable for transformer XST2, rather than the de-energized cable for transformer XST1. At 1:41 pm, both units entered Technical Specification 3.8.1, AC Sources - Operating, Condition C, Required Action C.2, restore one required offsite circuit to operable status with a completion time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . If the completion time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is not met, then both units would be required to enter Condition G and be in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The licensee requested a notice of enforcement discretion and an additional 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months to restore transformer XST1 or XST2, such that the completion time of Required Action C.2 would expire at 3:41 a.m. on December 6, 2013.

A notice of enforcement discretion was granted by the NRC staff at 1:00 p.m. on December 5, 2013. Consistent with NRC policy, the NRC agreed not to enforce compliance with the specific technical specifications in this instance, but will further review the cause(s) that created the apparent need for enforcement discretion to determine if there is a performance deficiency, if the issue is more than minor, or if there is a violation of requirements. This issue will be tracked as an unresolved item (URI)05000445/2013005-03; 05000446/2013005-03, Notice of Enforcement Discretion 13-4-004 for a Loss of Both Required Offsite Power Circuits.

.4 Unit 2 Automatic Reactor Trip

a. Inspection Scope

On November 1, 2013, Unit 2 experienced an automatic reactor trip during a solid state protection system relay test. The inspectors responded to the control room to access the operators performance and procedure usage. The inspectors performed a walkdown of the control boards to verify appropriate equipment response following the trip. The inspectors discussed the trip with operations management and the control room staff.

b. Findings

No findings were identified.

4OA6 Meetings

Exit Meeting Summary

On August 29, 2013, the inspectors discussed the in-office review of the preliminary biennial exercise scenario with Mr. R. Kidwell, Manager, Emergency Preparedness, and other members of the licensees staff. The licensee acknowledged the issues presented.

On November 20, 2013, the inspectors presented the results of the onsite inspection of the licensees emergency preparedness exercise conducted October 9, 2013, to Mr. T. McCool, Vice President, Station Support, and other members of the licensees 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 December 17, 2013, the inspectors presented the radiation safety inspection results to Mr. T. McCool, Vice President, Station Support, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On December 31, 2013, the inspectors conducted a telephonic exit meeting with Ms. K. Faver, Manager, Emergency Preparedness, to verify that no changes to the licensee's emergency plan or implementing procedures requiring regulatory review according to the requirements of Inspection Procedure 71114.04 were submitted by the licensee between January and December 2013.

On January 6, 2014, the inspectors conducted a telephonic exit and presented the results of the licensed operator requalification program annual cycle inspection with Mr. G. Struble, Supervisor Operations Training. The inspectors did not review any proprietary information during this inspection.

On January 9, 2014, the inspectors presented the resident inspection results to Mr. K. Peters, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors acknowledged review of proprietary material during the inspection. No proprietary information was documented in the report.

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 meet the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation.

Title 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable design bases requirements are translated into procedures. Contrary to the above, from 1989 until March 1, 2012, the licensee failed to assure that applicable design bases requirements were translated into procedures. Specifically, the licensee failed to assure preventative measures were established to ensure the electromagnetic door devices for the battery room and cable spreading room would maintain their function. The finding was more than minor because it was associated with design control attribute of the Mitigating Systems

cornerstone and adversely affected the cornerstone objective to ensure the reliability and capability of systems that respond to initiating event to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power, the inspector determined that the violation is of very low safety significance (Green) because the finding did not result in a loss of operability or functionality of a structure, system, or component. The violation was entered into the licensees corrective action program as Condition Report CR-2012-0002186. This is the enforcement aspect of the licensee event report discussed in Section 4OA3.1.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Flores, Senior Vice President and Chief Nuclear Officer

K. Peters, Site Vice President

S. Bradley, Manager, Radiation Protection

D. Goodwin, Director, Work Management

T. Hope, Manager, Regulatory Affairs

K. Faver, Manager, Emergency Preparedness

F. Madden, Director, External Affairs

B. Mays, Vice President, Engineering

T. McCool, Vice President, Station Support

D. McGaughey, Director, Performance Improvement

B. Moore, Director, Nuclear Training

K. Nickerson, Director, Engineering Support

B. Patrick, Director, Maintenance

B. Reppa, Director, Site Engineering

S. Sewell, Plant Manager

M. Smith, Director, Nuclear Operations

K. Tate, Manager, Security

D. Wilder, Director, Plant Support

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000445/2013005-01 NCV Failure to Follow Instructions for Containment Sump Inspection Results in Debris Left in the Sump (Section 1R15)

05000445/2013005-02 FIN Cutting Incorrect Cable Results in an Inoperable Offsite

05000446/2013005-02 Power Source (Section 1R18)

Opened

05000445/2013005-03 URI Notice of Enforcement Discretion 13-4-004 for a Loss of

05000446/2013005-03 Both Required Offsite Power Circuits (Section 4OA3.3)

Closed

05000445/2012-001-00 LER Unanalyzed Condition Discovered for the Normally Open Battery Room Fire and Cable Spread Room Doors Close on Momentary Loss of Power (Section 4OA3.1)

05000445/2012-002-00 LER Failure of Safety Related Breaker Control Devices due to a Common Cause (Section 4OA3.2)

Attachment 1

LIST OF DOCUMENTS REVIEWED