Text

IR 05000498/2014005 & 05000499/2014005, October 4, 2014 Through December 31, 2014, South Texas Project, Units 1 and 2, Operability Determinations and Functionality Assessments, and Problem Identification and Resolution
	ML15042A396
Person / Time
Site:	South Texas
Issue date:	02/10/2015
From:	O'Keefe N; NRC/RGN-IV/DRP/RPB-B
To:	Koehl D; South Texas
	O'Keefe N
References
	IR 2014005
	Download: ML15042A396 (37)
	v • d • e

UNITED STATES ary 10, 2015

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION -

NRC INTEGRATED INSPECTION REPORT 05000498/2014005 AND 05000499/2014005

Dear Mr. Koehl:

On December 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your South Texas Project Electric Generating Station, Units 1 and 2, facility. On January 14, 2015, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. Additionally, one documented violation was determined to be Severity Level IV under the traditional enforcement process. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC 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 South Texas Project Electric Generating Station, Units 1 and 2, facility.

If you disagree with a cross-cutting aspect assignment 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 South Texas Project Electric Generating Station, Units 1 and 2, facility. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, 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/

Neil OKeefe, Branch Chief Project Branch B Division of Reactor Projects Docket Nos.: 50-498 and 50-499 License Nos.: NPF-76 and NPF-80

Enclosure:

Inspection Report 05000498/2014005 and 05000499/2014005 w/ Attachment: Supplemental Information

REGION IV==

Docket: 05000498, 05000499 License: NPF-76, NPF-80 Report: 05000498/2014005 and 05000499/2014005 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM 521 - 8 miles west of Wadsworth Wadsworth, Texas 77483 Dates: October 4 through December 31, 2014 Inspectors: A. Sanchez, Senior Resident Inspector N. Hernandez, Resident Inspector B. Baca, Reactor Inspector K. Clayton, Senior Operations Engineer P. Elkmann, Senior Emergency Preparedness Inspector G. Guerra, CHP, Emergency Preparedness Inspector D. Holman, Senior Physical Security Inspector J. Kramer, Senior Resident Inspector R. Kumana, Resident Inspector D. Proulx, Senior Project Engineer Approved By: Neil OKeefe Chief, Project Branch B Division of Reactor Projects-1- Enclosure

SUMMARY

IR 05000498/2014005, 05000499/2014005; 10/04/2014 - 12/31/2014; South Texas Project

Electric Generating Station, Units 1 and 2, Operability Determinations and Functionality Assessments, and Problem Identification and Resolution The inspection activities described in this report were performed between October 4 and December 31, 2014, by the resident inspectors at the South Texas Project and inspectors from the NRCs Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding. 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,

Aspects within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs 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 documented a self-revealing non-cited violation of 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly identify and correct a condition adverse to quality following an unexpected alarm on the train A emergency diesel generator. Specifically, after receiving the, E-5 Starting Air System Malfunction alarm, the licensee did not identify the correct cause of the alarm or take the necessary action to ensure the operability and reliability of the emergency diesel generator.

As a result, the train A emergency diesel generator was degraded for 20 days, and was later rendered inoperable and non-functional for approximately 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months when operators removed the only air start subsystem that remained unaffected from service. This issue was entered into the corrective action program as Condition Report 14-18639, and the cause was corrected.

Failure to identify the cause for the starting air system alarm and recognize that this degraded the starting function was a performance deficiency. This performance deficiency is more than minor because it affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to correctly identify and correct the cause of the E-5 Starting Air System Malfunction alarm resulted in the train A emergency diesel generator being degraded and later inoperable. Using NRC Inspection Manual 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance (Green) because it did not: 1) affect the design or qualification of a mitigating structure, system, or component; 2) represent a loss of system and/or function; 3) represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and 4) represent an actual loss of function of one or more non-technical specification trains of equipment designated as having high safety-significance. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with Evaluation because the licensee failed to thoroughly evaluate the issue to ensure that resolutions address the causes and extent of conditions commensurate with the safety significance. Specifically, the licensees failure to fully evaluate the cause of the starting air system alarm, and as a result, failed to recognize and correct the out-of-position valve before it rendered the system inoperable [P.2].

(Section 71111.15)

Cornerstone: Miscellaneous

SL-IV. The inspectors identified a non-cited violation of 10 CFR 50.71(e), Maintenance of Records, Making Reports, for the failure to update the Updated Final Safety Analysis Report with information on the installation and use of the ultrasonic feedwater flow measurement system to control reactor power and calibrate nuclear instruments, which was installed in both units by the end of 1999. This violation was entered into the corrective action program as Condition Report 15-420.

The failure to update the Updated Final Safety Analysis Report, as required by 10 CFR 50.71(e), with a description of the ultrasonic feedwater flow measurement system was a performance deficiency. The inspectors determined that this performance deficiency was not more than minor. However, because it had the potential to impact the NRCs ability to perform its regulatory oversight function, the inspectors assessed more the significance of the violation using traditional enforcement. Using the NRC Enforcement Policy to evaluate the significance, the violation was determined to be a Severity Level IV violation in accordance with Section 6.1.d.3, since the lack of information in the Updated Final Safety Analysis Report was not used to make an unacceptable change to the facility or procedures.

Cross-cutting aspects are not assigned to traditional enforcement violations.

(Section 4OA2.3)

PLANT STATUS

Units 1 and 2 operated at 100 percent power for the entire inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On November 12, 2014, 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 preparations and evaluated the licensees implementation of these procedures. The inspectors verified that prior to the onset of cold weather; the licensee had corrected weather-related equipment deficiencies identified during the previous cold weather season.

The inspectors selected one risk-significant system that was required to be protected from winter weather:

Unit 1 boric acid system

Unit 2 boric acid system The inspectors reviewed the licensees procedures and design information to ensure the system would remain functional when challenged by adverse 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 adverse weather protection features.

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 to Cope with External Flooding

a. Inspection Scope

On December 30, 2014, the inspectors completed an inspection of the stations readiness to cope with external flooding. After reviewing the licensees flooding analysis, the inspectors chose two plant areas that were susceptible to flooding:

Units 1 and 2, emergency diesel generator buildings

Units 1 and 2, mechanical auxiliary buildings

The inspectors reviewed plant design features and licensee procedures for coping with flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether credited operator actions could be successfully accomplished.

These activities constituted one sample of readiness to cope with external flooding, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Main article: IP 71111.04

Complete Walkdown

a. Inspection Scope

On December 21, 2014, the inspectors completed a complete system walk-down inspection of the Unit 2, electrical auxiliary building heating, ventilation, and air conditioning system. The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the existing plant configuration.

The inspectors also reviewed open condition reports tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

On December 30, 2014, the inspectors completed a complete system walk-down inspection of the Unit 2, 13.8 kV electrical system. The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the existing plant configuration. The inspectors also reviewed open condition reports tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constituted two complete system walk-down samples, as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

Main article: IP 71111.05

Quarterly Inspection

a. Inspection Scope

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

November 12, 2014, Unit 2, Fire Zones 084 and 003

November 20, 2014, Unit 1, Fire Zone Z042

November 20, 2014, Unit 1, Fire Zone Z026

November 20, 2014, Unit 1, Fire Zone Z016

November 21, 2014, Unit 2, Fire Zone Z053

November 21, 2014, Unit 2, Fire Zone Z004 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.

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator

Performance (71111.11)

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On December 3, 2014, the inspectors observed an annual requalification test for licensed operators. 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 requalification activities.

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

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

On December 17, 2014, the inspectors observed the performance of on-shift licensed operators in the plants main control room and in the plant. At the time of the observations, the plant was in a period of heightened activity due to lowering reactor power and performing a surveillance run of the turbine-driven auxiliary feedwater pump (train D equipment), while in a train A work week to prove operability of the pump.

In addition, the inspectors assessed the operators adherence to plant procedures, including 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.

b. Findings

No findings were identified.

.3 Annual Review of Requalification Examination Results

a. Inspection Scope

(Units 1 and 2)

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, the licensee was in the first part of the training cycle.

The inspectors reviewed the results of the examinations and operating tests for both units to satisfy the annual inspection requirements.

On December 15, 2014, the licensee informed the lead inspector of the following results for Units 1 and 2:

Fourteen of fifteen crews passed the simulator portion of the operating test

Ninety-four of ninety-six licensed operators passed the simulator portion of the operating test

Ninety-five of ninety-six licensed operators passed the Job Performance Measure portion of the examination All of the individuals that failed the applicable portions of the operating test were remediated, retested, and passed their retake operating tests prior to returning to shift.

The inspectors completed one inspection sample of the annual licensed operator requalification program.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12

a. Inspection Scope

The inspectors reviewed three instances of degraded performance or condition of safety-related structures, systems, and components:

October 14, 2014, Unit 1, train A emergency diesel generator failed to start following calibration of pressure switches in the starting air system

December 15, 2014, Unit 1, train A qualified display processing system due to recent Maintenance Rule function failures and unavailability

December 15, 2014, Unit 1, train B high head safety injection pump due to extended unavailability to rebuild pump seal in June 2014

The inspectors reviewed the extent of condition of possible common cause structure, system, and 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 structure, system, and component. 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 three 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 three risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

October 15, 2014, Unit 1, train A 125 Vdc battery E1A11 breaker replacement using a risk-informed allowed outage time

November 12, 2014, Unit 2, train D 125 Vdc battery E2D11 breaker replacement using a risk-informed allowed outage time

December 29, 2014, Unit 2, train C mechanical seal replacement of the high head safety injection pump 2C coincident with suction line flange gasket replacement of low head safety injection pump 2C 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.

The inspectors also reviewed the licensees actions for implementing the Configuration Risk Management Program for determining and implementing a risk-informed allowed outage time for the following emergent issues listed above: 1) Technical Specification 3.8.2.1.a for battery E1A11 DC breaker replacement, and 2) Technical Specification 3.8.2.1.a for battery E2D11 DC breaker replacement.

The inspectors also observed portions of three emergent work activities that had the potential to cause an initiating event, to affect the functional capability of mitigating systems, or to impact barrier integrity:

October 23, 2014, Unit 1, emergent card replacement in the train A qualified display processing system in a train B work week

November 19, 2014, Unit 2, unplanned extension of work window for train B component cooling water pump failing post-maintenance test concurrent with battery E2A-11 test discharge and breaker replacement

November 22, 2014, Unit 2, emergent failure of train A solid state protection system that required entry into a 24-hour shutdown action statement The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected structures, systems, and components.

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

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed six operability determinations and functionality assessments that the licensee performed for degraded or nonconforming systems, structures, and components:

October 14, 2014, operability determination of Unit 1, train A emergency diesel generator failure to start due to mispositioned turning gear interlock valve PSV-5439

October 21, 2014, functionality assessment of Units 1 and 2 low pressure turbines following identification of elevated seismic vibration due to rotor support system for the turbines

October 22, 2014, operability determination of Unit 2, train A essential chiller water pump 21A due to an oil analysis that indicated high wear particle concentration and high copper metal

December 17, 2014, operability determination of Unit 2, train D turbine-driven auxiliary feedwater pump due to declining trend in governor performance

December 23, 2014, functionality assessment of Unit 2 unit auxiliary transformer to auxiliary bus 2H supply breaker P-230 found with a sticking auxiliary contact switch

December 24, 2014, functionality assessment of Unit 1 centrifugal charging pump 1A for low recirculation flow rate

The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded system, structure, or component to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded system, structure, or component.

These activities constitute completion of six operability and functionality review samples, as defined in Inspection Procedure 71111.15.

b. Findings

Introduction.

The inspectors documented a Green self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly identify and correct a condition adverse to quality following an unexpected alarm on train A emergency diesel generator. Specifically, after receiving the E-5 Starting Air System Malfunction local alarm, the licensee did not identify the correct cause of the alarm or take the necessary action to ensure the operability and reliability of the emergency diesel generator. As a result, train A emergency diesel generator was inoperable and non-functional for approximately 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months .

Description.

On September 22, 2014, during a surveillance test of train A emergency diesel generator, operators unexpectedly received local alarm, E-5 Starting Air Malfunction, which would not clear. The alarm response procedure directed operators to verify the correct valve lineup for the starting air system. Operators completed the valve lineup with no discrepancies noted. The licensee incorrectly assumed that the cause of the alarm was one or more of the pressure switches associated with the turning gear interlock circuitry. This issue was documented in Condition Report 14-17053.

Calibration of starting air system pressure switches was tentatively scheduled for December 2014.

On September 27, 2014, train A emergency diesel generator was started to prove operability. The starting time was 8.12 seconds, approximately one second slower than the normal starting time, and local alarm E-5 Starting Air Malfunction, remained locked in. The licensee attributed the slower than normal start time to a starting air system relief valve which required work and was being tracked by Condition Report 14-17423.

On October 12, 2014, at 9:30 p.m., starting air receiver 11 redundant air supply to starting air receiver 12 was isolated and tagged out for planned maintenance. At this time the E-5 Starting Air Malfunction alarm was still locked in.

On October 14, 2014, at 12:06 a.m., the control room received a diesel generator trouble alarm and the following alarms locally at the emergency diesel generator:

Bypassed/Inoperable alarm, Starting Air Low Pressure alarm, and the DG Ready for Emergency light was extinguished. Operations immediately declared train A emergency diesel generator inoperable and non-functional and entered a 14-day limiting condition for operation action statement for Technical Specification 3.8.1.a. The issue was documented in Condition Report 14-18639 and an apparent cause investigation was initiated. The licensee then performed a calibration of the starting air system

pressure switches, however, none of the switches were out of tolerance enough to have caused the alarms that were received. On October 14, 2014, at 9:25 p.m., the licensee attempted to start emergency diesel generator 11 to prove operability. Train A emergency diesel generator failed to start.

Further troubleshooting identified that turning gear interlock valve PSV-5439, for starting air receiver 12, was out of position. The total travel for this valve is approximately 1/8 inch and was discovered to be 1/16 inch closed. In this position, PSV-5439 blocked air from starting air receiver 12 to the starting air crank valves. Based on that discovery, it became apparent that the train A emergency diesel generator had been degraded from September 22 until October 12 due to having only one functional starting air subsystem, and was rendered inoperable and non-functional from October 12 at 9:30 p.m. until October 14 at 12:06 a.m., a total of 26.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The failure to properly evaluate the cause of the starting air system alarm and recognize that PSV-5439 was out of position, as well as the failure to promptly confirm that the pressure switches were actually out of calibration as had been assumed resulted in taking the only unaffected starting air subsystem out of service for maintenance, rendering a degraded system inoperable. The issue also resulted in an unplanned entry into a limiting condition for operation, a Maintenance Rule functional failure, and a mitigating system performance indicator failure to start.

Analysis.

Failure to identify the cause for the emergency diesel generator starting air system alarm and recognize that this degraded the starting function was a performance deficiency. This performance deficiency is more than minor because it affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to correctly identify and correct the cause of the E-5 Starting Air System Malfunction alarm resulted in train A emergency diesel generator being degraded and later rendered inoperable.

Using NRC Inspection Manual 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance (Green) because it did not: 1) affect the design or qualification of a mitigating system, structure, or component; 2) represent a loss of system and/or function; 3) represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and 4) represent an actual loss of function of one or more non-technical specification trains of equipment designated as having high safety-significance. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with Evaluation because the licensee failed to thoroughly evaluate the issue to ensure that resolutions address the causes and extent of condition commensurate with the safety significance. Specifically, the licensee failed to fully evaluate the cause of the starting air system trouble alarm, and as a result, failed to recognize and correct the out-of-position valve before it rendered the system inoperable [P.2].

Enforcement:

Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to this requirement, the licensee failed to promptly identify and correct a condition adverse to quality. Specifically, after receiving a starting

air system malfunction alarm on train A emergency diesel generator, the licensee failed to identify and correct an out-of-position valve in the starting air system. Because this finding was determined to be of very low safety significance (Green) and was entered into the licensees corrective action program as Condition Report 14-18639, this violation is being treated as a non-cited violation in accordance with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000498/2014005-01, Failure to Identify a Condition Adverse to Quality on Train A Emergency Diesel Generator.

1R18 Plant Modifications

Main article: IP 71111.18

Permanent Modifications

a. Inspection Scope

On October 22, 2014, the inspectors reviewed a permanent plant modification for the replacement of the Class 1E 125 Vdc battery output breaker.

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. The inspectors verified that post-modification testing was adequate to establish the operability of the structure, system, or component as modified.

These activities constitute completion of one sample of permanent modifications, as defined in Inspection Procedure 71111.18

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed six post-maintenance testing activities that affected risk-significant structures, systems, and components:

October 15, 2014, Unit 1, train A 125 Vdc battery breaker 1EA11 following replacement

October 29, 2014, Unit 2, train A essential chiller water pump 21A following motor bearing replacement

October 30, 2014, Unit 1, train B emergency diesel generator following 5-year maintenance

November 6, 2014, Unit 1, train B emergency diesel generator following flood panel re-installation

November 22, 2014, Unit 2, train A solid state protection system following a fuse replacement

December 12, 2014, Unit 2, train C residual heat removal pump following pump seal replacement The inspectors reviewed licensing- and design-basis documents for the structures, systems, and 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, and components.

These activities constitute completion of six post-maintenance testing inspection 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 three risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components were capable of performing their safety functions.

In-service tests:

December 17, 2014, Unit 2, train D auxiliary feedwater pump in-service test Other surveillance tests:

October 22, 2014, Unit 1, train B emergency diesel generator ultrasonic examination of the master connecting rods

October 31, 2014, Unit 2, train B 125 Vdc Class IE battery modified performance surveillance test 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 structure, system, and components following testing.

These activities constitute completion of three surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP7 Exercise Evaluation - Hostile Action Event

Main article: IP 71114.07

a. Inspection Scope

The inspectors observed the November 5, 2014, biennial emergency plan exercise to verify the exercise acceptably tested the major elements of the emergency plan, provided opportunities for the emergency response organization to demonstrate key skills and functions, and demonstrated the licensees ability to coordinate with offsite emergency responders. The scenario simulated the following to demonstrate the licensees capability to implement its emergency plan under conditions of uncertain physical security:

An armed attack on the site causing casualties among plant employees

Loss of Unit 1 circulating water

Trip of emergency diesel generator 12

Loss of control over the Unit 1 auxiliary feedwater system

A steam generator tube rupture on Unit 1

A radiological release to the environment through the steam generator power-operated relief valve During the exercise, the inspectors observed activities in the control room simulator and the following emergency response facilities:

Alternate Technical Support Center

Alternate Operations Support Center

Emergency Operations Facility

Central and/or Secondary Alarm Stations

Incident Command Post

Joint Information Center The inspectors focused their evaluation of the licensees performance on event classification, offsite notification, recognition of offsite dose consequences, development of protective action recommendations, staffing of alternate emergency response facilities, and the coordination between the licensee and offsite agencies to ensure reactor safety under conditions of uncertain physical security.

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 plant employees and emergency workers in an uncertain physical security environment; emergency repair evaluation and capability; and the overall implementation of the emergency plan to protect public health, 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 primary and alternate emergency response facilities, and procedures for the performance of associated emergency and security functions.

The inspectors attended the post-exercise critiques in each emergency response facility to evaluate the initial licensee self-assessment of exercise performance. The inspectors also attended a November 19, 2014, presentation of critique items to plant management.

The inspectors reviewed the scenarios of previous licensee drills conducted between January 2013 and October 2014 to determine whether the November 5, 2014, biennial exercise was independent of previous scenarios and avoided participant preconditioning, in accordance with the requirements of 10 CFR Part 50, Appendix E, IV.F(2)(g). The inspectors compared the observed exercise performance with corrective action program entries and after-action reports for drills and exercises conducted between January 2013 and October 2014 to determine whether previously-identified weaknesses had been corrected in accordance with the requirements of 10 CFR 50.47(b)(14) and 10 CFR Part 50, Appendix E, IV.F.

These activities constituted completion of one exercise evaluation sample as defined in Inspection Procedure 71114.07.

b. Findings

No findings were identified.

1EP8 Exercise Evaluation - Scenario Review

Main article: IP 71114.08

a. Inspection Scope

The licensee submitted the preliminary exercise scenario for the November 5, 2014, biennial exercise to the NRC in accordance with the requirements of 10 CFR Part 50, Appendix E, IV.F(2)(b). The inspectors performed an in-office review of the proposed scenario to determine whether it would acceptably test the major elements of the licensees emergency plan and provide opportunities for the emergency response organization to demonstrate key skills and functions.

b. Findings

No findings were identified.

The inspectors reviewed the licensees evaluated exercises and selected drill and training evolutions that occurred between July 2013 and September 2014 to verify the accuracy of the licensees data for classification, notification, and protective action recommendation opportunities. The inspectors reviewed a sample of the licensees completed classifications, notifications, and protective action recommendations to verify

their timeliness and accuracy. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.

These activities constituted verification of the drill/exercise performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.7 Emergency Response Organization Drill Participation (EP02)

a. Inspection Scope

The inspectors reviewed the licensees records for participation in drill and training evolutions between July 2013 and September 2014 to verify the accuracy of the licensees data for drill participation opportunities. The inspectors verified that all members of the licensees emergency response organization in the identified key positions had been counted in the reported performance indicator data. The inspectors reviewed the licensees basis for reporting the percentage of emergency response organization members who participated in a drill. The inspectors reviewed drill attendance records and verified a sample of those reported as participating. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.

These activities constituted verification of the emergency response organization drill participation performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.8 Alert and Notification System Reliability (EP03)

These activities constitute completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.

b. Observations and Assessments The inspectors identified trends in licensed reactor operator knowledge and application of technical specifications, and operator knowledge of plant equipment issues.

The inspectors noted several instances where licensed operators demonstrated a lack of familiarity with technical specification requirements. Examples include:

On October 6, 2014, operators failed to recognize the need to enter a 24-hour shutdown action statement in Technical Specification 3.8.1.1.e, while the north bus was out of service and in an alternate offsite power alignment and being notified by the grid dispatcher that post-trip minimum grid voltage would not be met (the condition only lasted for two hours, therefore, no technical specification was violated).

On October 14, 2014, the Unit 1 shift manager briefed the oncoming shift on the plant status, but incorrectly reported that the train A emergency diesel generator was functional. The resident inspectors challenged the decision that the train was functional and later that day, the train A emergency diesel generator was

tested and shown to have been non-functional due to a starting air system problem.

On November 21, 2014, the Unit 2 shift manager incorrectly applied the time of discovery when the train A solid state protection system surveillance indicated a problem. The shift manager intended to enter the 24-hour shutdown action statement of Technical Specification 3/4.3.2, Table 3-3.4b after the full 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months allowed for testing expired, even though the train was recognized to be inoperable in the second hour.

On December 23, 2014, Unit 2 operators did not understand or question the condition of the degraded auxiliary contact switch 13.8kV supply breaker to the 2H bus, despite hanging a caution tag that stated that operating the breaker could result in a reactor trip.

The licensee has entered this trend into the corrective action program as Condition Report 14-23490.

c. Findings

No findings were identified.

.3 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected five issues for in-depth follow-up:

On July 10 and December 23, 2014, Unit 1 centrifugal charging pump 1A failed routine surveillances due to measured flow being outside of procedurally established acceptance criteria. This issue was documented in Condition Report 14-11791.

On September 15, 2014, Unit 2 fuel handling building, a small electrical fire occurred at a temporary power cord near its connection to a welding receptacle.

This issue was documented in Condition Report 14-16445.

On November 21, 2014, Unit 1 personnel air lock failed a post-maintenance test.

During performance of 0PSP11-XC-0009, Personnel Airlock Pneumatic Seal System Pressure Drop Test, an acceptable leakage rate could not be obtained for the outer door seals. This issue was documented in Condition Report 14-23005.

On November 25, 2014, the inspectors performed an in-depth follow-up of the Unit 1 cumulative effects of operator workarounds, operator burdens, and control board items to determine the reliability, availability, and potential for incorrect operation of systems or components.

In December 2013, the licensee discovered feedwater pipe wall thinning that affected the accuracy in the secondary side calorimetric, which directly affected reactor power. The issue was placed into the corrective action program as Condition Report 13-15806.

The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition. The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews, and compensatory and corrective actions to address the deficiency. The inspectors verified that the licensee appropriately prioritized the corrective actions and that these actions were adequate to correct the condition.

These activities constitute completion of five annual follow-up samples, which included one operator work-around sample, as defined in Inspection Procedure 71152.

b. Findings

Introduction.

The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.71(e), Maintenance of Records, Making Reports, for the failure to update the Updated Final Safety Analysis Report (UFSAR) with information on the installation and use of the ultrasonic feedwater flow measurement system to control reactor power level and calibrate nuclear instruments, which was installed in both units by the end of 1999. This violation was entered into the corrective action program as Condition Report 15-420.

Description.

In 1999, following receiving License Amendment 138 and 127, the licensee installed an ultrasonic feedwater flow measurement system in Units 1 and 2. The measurement system uses sound waves, transducers attached to the outside of the feedwater piping and computer software with an algorithm to calculate feedwater flow.

This flow measurement was more accurate in measuring feedwater flow as compared to the flow venturies that were original plant equipment. The feedwater flow measurement is important because it is one of the primary inputs to the plant calorimetric algorithm used to calculate reactor power. The venturies became a backup to the ultrasonic feedwater flow system, if the ultrasonic system should become unreliable or fail. This flow measurement system, along with improvements in increasing the accuracy of other plant measuring devices, allowed the licensee to obtain a license amendment request to increase the maximum reactor power. In 2002, both units were approved by the NRC to increase licensed thermal power limits by 1.4 percent to 3853 MW thermal.

In December 2013, while investigating why one of correction factors used in the feedwater flow had been changing, the licensee discovered that the feedwater pipe walls were thinning due to erosion. The ultrasonic feedwater flow measuring system was very sensitive to even the slightest changes in pipe wall thickness. The software assumed a constant pipe wall thickness. Initially, the licensee believed that the reactor might have been operating in excess of the licensed power operating limits, but it was later determined that the reactor was not operating in excess of licensed power limits.

The inspectors were following up on this issue (see discussion in Section 4OA3) and determined that the licensee had not described the installation and use of the ultrasonic

feedwater flow measurement system in the UFSAR. This impeded the regulatory process in that the UFSAR did not reflect the most current description of the plant or procedures. It also created the potential that future changes to the facility could be made as permitted by 10 CFR 50.59 without properly accounting for the missing information.

Analysis.

The failure to update the Updated Final Safety Analysis Report, as required by 10 CFR 50.71(e), with a description of the ultrasonic feedwater flow measurement system was a performance deficiency. The inspectors determined that this performance deficiency was not more than minor. However, because it had the potential to impact the NRCs ability to perform its regulatory oversight function, the inspectors assessed more the significance of the violation using traditional enforcement. Using the NRC Enforcement Policy to evaluate the significance, the violation was determined to be a Severity Level IV violation in accordance with Section 6.1.d.3, since the lack of information in the Updated Final Safety Analysis Report was not used to make an unacceptable change to the facility or procedures. Cross-cutting aspects are not assigned to traditional enforcement violations.

Enforcement.

Title 10 of the Code of Federal Regulations 50.71(e), Maintenance of Records, Making of Reports, states, in part, each person licensed to operate a nuclear power reactorshall update periodically, as provided in paragraphs (e)

(3) and

(4) of this section, the final safety analysis report (FSAR) originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed.

Contrary to the above, the licensee failed to update the UFSAR originally submitted as part of the application for the license, to assure that the information included in the report contained the latest information developed. Specifically, from 1999 through 2014, the licensee failed to update the UFSAR with detailed information associated with the installed ultrasonic feedwater flow measurement system and its use in determining reactor power and for calibrating power range nuclear instruments. This violation was entered into the corrective action program as Condition Report 15-420. Because this violation was a Severity Level IV violation and has been entered into the licensees corrective action program, this violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy:

NCV 05000498/2014005-02 and 05000499/2014005-02, Failure to Update the UFSAR for the Ultrasonic Feedwater Flow Measurement System.

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

Main article: IP 71153

(Closed) Licensee Event Report 05000498/2014-001-00 and 05000498/2014-001-01, Overpower Condition Relating to the Ultrasonic Flow Measurement System In December 2013, engineering was investigating a negative trend in the correction factors for the ultrasonic flowmeter (used to measure feedwater flow) and discovered that both units had experienced feedwater pipe wall thinning that was outside the software allowances for accuracy of the ultrasonic flowmeter. Reactor power was reduced to 99.6 percent in both Units 1 and 2. The average loss of feedwater pipe wall thickness near the ultrasonic flowmeter sensors was 60-80 mils (thousandths of an inch), compared to a nominal pipe wall thickness of 1.375 inches. Working with the vendor, new transducers were fabricated, installed, and tested and both units were

returned to 100 percent power. The licensee plans to replace the eroded pipe sections in each unit. This issue was placed into the corrective action program as Condition Report 13-15806.

The licensees initial evaluation of the feedwater pipe wall thinning and its effect on reactor power determined that both units were operated in excess of licensed thermal power limits (1.8 percent for Unit 1 and 1.4 percent for Unit 2) for approximately 2.5 years. The licensee further determined that Technical Specification 3.3.1 allowed outage time was exceeded for over temperature-delta temperature (OTDT) and primary reactor nuclear instrumentation high trip setpoint channels exceeding allowable values.

The licensee submitted Licensee Event Report 2014-001-00, Overpower Condition Relating to the Ultrasonic Flow Measurement System, on March 24, 2014. The licensee submitted Licensee Event Report 2014-001-01, which explains that independent, detailed studies were being conducted and that a second supplemental licensee event report would be submitted by June 24, 2014.

The licensee contracted two independent engineering firms to perform further analyses concerning the issue to determine if either unit had operated in excess of licensed thermal power of 3853 MW. One firm was tasked to evaluate whether the accuracy of the ultrasonic flow meters was within their + 0.6 percent rated accuracy with a 95 percent confidence interval. The second firm was tasked to provide a thermal performance assessment of both reactors. The results were that the accuracy of the ultrasonic flow meters was within + 0.5 percent with a 95 percent confidence interval, and that there was no conclusive evidence that Unit1 and 2 reactors operated in excess of their license thermal power limits. The licensee contends that the pipe wall thinning caused an increase in actual feedwater flow, which led to an actual increase in power.

When the system was initially installed, the licensee assumed that the feedwater piping was smooth and was not subject to erosion. Inspection of the internal piping discovered that the feedwater piping was actually rough due to erosion. This resulted in an increase in indicated feedwater flow (not actual) so operations was required to reduce thermal power to restore indicated power within licensed limits. The net result of pipe wall thinning, which caused an actual increase in power, and the rough pipe wall, which caused an increase in indicated power, was that both reactors were operated at or below licensed power limits because operators responded to the indicated increase by reducing power.

As a result of the conclusions reached by the two evaluations that neither unit had operated above licensed thermal limits, the licensee retracted Licensee Event Reports 05000498/2014-001-00, and 05000498/2014-001-01. The licensee submitted a license amendment request to install a leading edge flow monitoring system, which will replace the current ultrasonic flow measurement system.

The inspectors reviewed the root cause evaluation. The licensee determined that they were not implementing vendor recommendations outlined in License Amendment Numbers 138 and 127, Units 1 and 2 respectively. Specifically, the licensee did not evaluate or monitor the feedwater piping for erosion, which can affect the secondary power calorimetric accuracy. The licensee was taking corrective action to modify their license amendment request process to include a formal review of plant specific requirements and recommendations from vendor supplied documents that are used as a basis for a license amendment in order to assure that the bases used to support the

amendment are identified and enforced by making them part of station programs. An NRC identified violation is discussed in Section 4OA2.

Licensee event reports 05000498/2014-001-00 and 05000498/2014-001-01 are closed.

These activities constitute completion of one event follow-up sample, as defined in Inspection Procedure 71153.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On October 7, 2014, the inspectors discussed the in-office review of the preliminary scenario for the 2014 biennial exercise with Mr. J. Enoch, Emergency Preparedness Supervisor, and other members of the licensee staff. The licensee acknowledged the issues presented.

On December 3, 2014, the inspectors presented the results of the on-site inspection of the biennial emergency preparedness exercise conducted November 5, 2014, to Mr. B. Eller, Manager, Corporate Communications, 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.

The licensed operator requalification inspector obtained the final annual examination results and telephonically exited with Mr. G. Janak, Operations Training Manager, on December 15, 2014.

The inspector did not review any proprietary information during this inspection.

On January 14, 2015, the inspectors presented the resident inspector inspection results to Mr. D. Koehl, President and Chief Executive Officer, 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.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Aguilera, Manager, Health Physics

C. Bowman, General Manager, Engineering

M. Crain, Manager, Emergency Response

R. Dunn Jr., Manager, Nuclear Fuel and Analysis

B. Eller, Manager, Corporate Communications

J. Enoch, Supervisor, Emergency Preparedness

T. Frahm, Manager, Operations, Unit Operations

T. Frawley, Manager, Plant Protection and Emergency Response

R. Gibbs, Manager, Operations, Production Support

G. Hildebrandt, Manager, Operations

G. Janak, Operations Training Manager

D. Koehl, President and Chief Executive Officer

J. Phelps, Manager, Cyber-Security

J. Pierce, Manager, Unit 1 Operations

F. Puleo, Licensing Staff Specialist

M. Reddix, Manager, Security Projects

M. Ruvalcaba, Manager, Strategic Projects

R. Scarborough, Manager, Quality Assurance

M. Schaefer, Plant General Manager

L. Sterling, Supervisor, Licensing

M. Uribe, Manager, Work Control

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000498/2014005-01 NCV Failure to Identify a Condition Adverse to Quality on Train A Emergency Diesel Generator (Section 1R15)

05000498/2014005-02 SL-IV Failure to Update the UFSAR for the Ultrasonic Feedwater Flow

05000499/2014005-02 Measurement System (Section 4OA2)

Closed

05000498/2014-001-00 LER Overpower Condition Relating to the Ultrasonic Flow

05000498/2014-001-01 Measurement System (Section 4OA3)

Attachment

LIST OF DOCUMENTS REVIEWED