ML16021A316

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Iir 2015-04 Residents Report
ML16021A316
Person / Time
Site: Mcguire, McGuire  Duke Energy icon.png
Issue date: 01/21/2016
From: Frank Ehrhardt
Division Reactor Projects II
To: Capps S
Duke Energy Carolinas
References
IR 2015004
Download: ML16021A316 (27)
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Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 January 21, 2016 Mr. Steven D. Capps Site Vice President Duke Energy Carolinas, LLC McGuire Nuclear Station MG01VP/12700 Hagers Ferry Road Huntersville, NC 28078

SUBJECT:

MCGUIRE NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000369/2015004 AND 05000370/2015004

Dear Mr. Capps:

On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your McGuire Nuclear Station Units 1 and 2. On January 14, 2016, 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 NRC-identified Severity Level IV violation with no associated finding under the traditional enforcement process. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violation or significance of this NCV, 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 II; the Director, Office of Enforcement, U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the McGuire Nuclear Station.

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 NRC's Agencywide Document Access and Management System (ADAMS).

S. Capps 2 ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Frank Ehrhardt, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-369, 50-370 License Nos.: NPF-9, NPF-17

Enclosure:

NRC Integrated Inspection Report 05000369/2015004 and 05000370/2015004 w/Attachment - Supplementary Information cc: distribution via ListServ

_____ML16021A316_______ SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:DRS RII:DRP RII:DRP SIGNATURE JXZ REC3 MKM3 JGW1 FJE NAME J. Zeiler R. Cureton M. Meeks J. Worosilo F. Ehrhardt DATE 1/19/2016 1/19/2016 1/15/2016 1/19/2016 1/21/2013 1/ /2016 1/ /2016 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO S. Capps 3 Letter to Steven D. Capps from Frank Ehrhardt dated January 21, 2016

SUBJECT:

MCGUIRE NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000369/2015004 AND 05000370/2015004 DISTRIBUTION:

D. Gamberoni, RII L. Gibson, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMMcGuire Resource

U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket Nos.: 50-369, 50-370 License Nos.: NPF-9, NPF-17 Report No.: 05000369/2015004 and 05000370/2015004 Licensee: Duke Energy Carolinas, LLC Facility: McGuire Nuclear Station, Units 1 and 2 Location: Huntersville, NC 28078 Dates: October 1, 2015 through December 31, 2015 Inspectors: J. Zeiler, Senior Resident Inspector R. Cureton, Resident Inspector M. Meeks, Senior Operations Engineer (Section 1R11.3)

Approved by: Frank Ehrhardt, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY

OF FINDINGS IR05000369/2015004 and IR05000370/2015004; 10/01/2015 - 12/31/2015; McGuire Nuclear Station, Units 1 and 2; Follow-Up of Events and Notices of Enforcement Discretion The report covered a 3-month period of inspection by resident inspectors and one regional inspector. There was one NRC identified non-cited violation (NCV) documented in this report.

The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, (SDP) dated April 29, 2015. The cross-cutting aspects are determined using IMC 0310, Aspects Within The Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated February 4, 2015. The NRC's program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision (Rev.) 5.

Other Findings

  • SL IV: An NRC identified Severity Level (SL) IV non-cited violation (NCV) of 10 CFR 50.72(b)(3)(iv)(A) was identified for the licensees failure to make a required NRC event notification within eight hours for an unplanned valid actuation of the auxiliary feedwater (CA) system. The unplanned valid actuation occurred during main turbine and main feedwater pump safety injection (SI) train trip function testing with Unit 2 in Mode 4 on October 7, 2015. The licensee entered this issue into their corrective action program and subsequently reported this CA actuation to the NRC on October 15, 2015.

The failure to submit an event notification to the NRC within eight hours of occurrence of an unplanned valid CA system actuation in accordance with 10 CFR 50.72(b)(3)(iv)(A) was a performance deficiency (PD). Since the failure to submit an event report within the time requirements may impact the ability of the NRC to perform its regulatory oversight function, this PD was dispositioned under the traditional enforcement process and was determined to be a SL IV violation. Because this SL IV violation was not repetitive or willful, and did not have an underlying technical violation that would be considered more-than-minor, a cross-cutting aspect was not assigned to this violation.

(Section 4OA3.1)

REPORT DETAILS Summary of Plant Status Unit 1 operated at approximately 100 percent rated thermal power (RTP) for the entire inspection period.

Unit 2 was shutdown for a scheduled refueling outage at the beginning of the inspection period.

The unit was placed back online on October 9 and was returned to 100 percent power on October 14. The unit was operated at essentially full power for the remainder of the inspection period.

1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity 1R01 Adverse Weather Protection (71111.01)
a. Inspection Scope

.1 Seasonal Extreme Weather Conditions The inspectors conducted a detailed review of the stations adverse weather procedures written for extreme low temperatures. The inspectors verified that weather-related equipment deficiencies identified during the previous year had been placed into the work control process and/or corrected before the onset of seasonal extremes. The inspectors evaluated the licensees implementation of adverse weather preparation procedures and compensatory measures before the onset of seasonal extreme weather conditions.

Documents reviewed are listed in the attachment.

The inspectors evaluated the following risk-significant systems:

  • Unit 1 and 2 freeze protection for refueling water storage tank level instrumentation
  • Unit 1 and 2 interior/exterior doghouses
  • Unit 1 and 2 main feedwater flow transmitter compartments

.2 Readiness to Cope with External Flooding The inspectors evaluated the licensee's implementation of flood protection procedures and compensatory measures during the impending conditions of flooding or heavy rains.

The inspectors reviewed the updated final safety analysis report (UFSAR) and related flood analysis documents to identify those areas containing safety related equipment that could be affected by external flooding and their design flood levels. The inspectors walked down flood protection barriers, reviewed procedures for coping with external flooding, and reviewed corrective actions for past flooding events. The inspectors verified that the procedures for coping with flooding could reasonably be used to achieve

4 the desired results. For those areas where operator actions are credited, the inspectors assessed whether the flooding event could limit or prevent the required actions.

Documents reviewed are listed in the attachment.

The inspectors conducted walkdowns of the following plant areas containing risk-significant structures, systems, and components that are below flood levels or otherwise susceptible to flooding:

  • Northern earthen dike extension of the Cowans Ford Dam
  • Unit 1 and 2 yard drains inside the protected area
  • Unit 1 and 2 auxiliary building, service building, and fuel handling building rooftop drainage systems
b. Findings No findings were identified.

1R04 Equipment Alignment (71111.04)

a. Inspection Scope

.1 Partial Walkdown The inspectors verified that critical portions of the selected systems were correctly aligned by performing partial walkdowns. The inspectors selected systems for assessment because they were a redundant or backup system or train, were important for mitigating risk for the current plant conditions, had been recently realigned, or were a single-train system. The inspectors determined the correct system lineup by reviewing plant procedures and drawings. The inspectors observed whether there was indication of degradation, and if so, verified the degradation was being appropriately managed and entered into the licensees corrective action program. Documents reviewed are listed in the attachment.

The inspectors selected the following three systems or trains to inspect:

  • 2B motor driven CA pump while the 2A motor driven CA pump was out of service for testing
  • B train nuclear service water (RN) system and A train RN suction header from Lake Norman while the A train RN suction from the Standby Nuclear Service Water Pond (SNSWP) was unavailable because of inspection

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.2 Complete Walkdown The inspectors verified the alignment of the Unit 2 CA system. The inspectors selected this system because it is a risk-significant mitigating system. The inspectors determined the correct system lineup by reviewing plant procedures, drawings, the UFSAR, and other documents. The inspectors reviewed records related to the system design, maintenance work requests, and deficiencies. The inspectors verified that the selected system was correctly aligned by performing a complete walkdown of accessible components. The inspectors observed whether there was indication of degradation, and if so, verified the degradation was being appropriately managed in accordance with an aging management program and it had been entered into the licensees corrective action program.

To verify the licensee was identifying and resolving equipment alignment discrepancies, the inspectors reviewed corrective action documents, including condition reports and outstanding work orders. The inspectors also reviewed periodic reports containing information on the status of risk-significant systems, including maintenance rule reports and system health reports. Documents reviewed are listed in the attachment.

b. Findings No findings were identified.

1R05 Fire Protection (71111.05A)

a. Inspection Scope

.1 Quarterly Inspection The inspectors evaluated the adequacy of selected fire plans by comparing the fire plans to the defined hazards and defense-in-depth features specified in the fire protection program. In evaluating the fire plans, the inspectors assessed the following items:

  • control of transient combustibles and ignition sources
  • fire detection systems
  • fire suppression systems
  • manual firefighting equipment and capability
  • passive fire protection features
  • compensatory measures and fire watches
  • issu es related to fire protection contained in the licensees corrective action program The inspectors toured the following five fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the attachment.
  • Unit 2 upper and lower containment (fire areas 33 and 33A)

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  • Unit 2 electrical penetration room 733 elevation (fire area 10)
  • Unit 2 electrical penetration room 750 elevation (fire area 16)
  • Unit 1 CA pump room (fire areas 2 and 2A)
  • Unit 1 electrical penetration room 750 elevation (fire area 17)

.2 Annual Inspection The inspectors evaluated the licensees fire brigade performance during a drill on December 18, 2015 and assessed the brigades capability to meet fire protection licensing basis requirements. The inspectors observed the following aspects of fire brigade performance:

  • capability of fire brigade members
  • leadership ability of the brigade leader
  • use of turnout gear and fire-fighting equipment
  • team effectiveness
  • compliance with site procedures The inspectors also assessed the ability of control room operators to combat potential fires, including identifying the location of the fire, dispatching the fire brigade, and sounding alarms. The inspectors evaluated the licensees ability to declare the appropriate emergency action level and make required notifications in accordance with NUREG 0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (FEMA-REP-1) and Title 10 of the Code of Federal Regulations (10 CFR) Part 50.

The inspectors also observed the post-drill critique to assess if it was appropriately critical, included discussions of drill observations, and identified any areas requiring corrective actions.

Documents reviewed are listed in the attachment.

b. Findings No findings were identified.

1R06 Flood Protection Measures (71111.06)

a. Inspection Scope Internal Flooding The inspectors reviewed related flood analysis documents and walked down the area listed below containing risk-significant structures, systems, and components susceptible to flooding. The inspectors verified that plant design features and plant procedures for flood mitigation were consistent with design requirements and internal flooding analysis assumptions. The inspectors also assessed the condition of flood protection barriers

7 and drain systems. In addition, the inspectors verified the licensee was identifying and properly addressing issues using the corrective action program. Documents reviewed are listed in the attachment.

  • Unit 2 CA pump area
b. Findings No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance (71111.11)

a. Inspection Scope

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification On December 11, 2015, the inspectors observed an evaluated simulator scenario administered to an operating crew conducted in accordance with the licensees accredited requalification training program. The simulator scenario involved a failed power range nuclear instrument followed by a loss of condenser vacuum and subsequent steam generator tube rupture event.

The inspectors assessed the following:

  • licensed operator performance
  • the ability of the licensee to administer the scenario and evaluate the operators
  • the quality of the post-scenario critique
  • simulator performance Documents reviewed are listed in the attachment.

.2 Resident Inspector Quarterly Review of Licensed Operator Performance in the Actual Plant/Main Control Room On October 8-9, 2015, the inspectors observed licensed operator performance in the Unit 2 main control room during reactor startup and reactor physics testing following the refueling outage.

The inspectors assessed the following:

  • use of plant procedures
  • control board manipulations
  • communications between crew members
  • use and interpretation of instruments, indications, and alarms
  • use of human error prevention techniques
  • documentation of activities

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  • management and supervision Documents reviewed are listed in the attachment.

.3 Annual Review of Licensee Requalification Examination Results On June 12, 2015, the licensee completed the annual requalification operating examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), Requalification Requirements, of the NRCs Operators Licenses. During the week of December 14, 2015, the inspectors performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, Licensed Operator Requalification Program.

These results were compared to the thresholds established in Section 3.02, Requalification Examination Results, of IP 71111.11.

b. Findings No findings were identified.

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope The inspectors assessed the licensees treatment of the two issues listed below to verify the licensee appropriately addressed equipment problems within the scope of the maintenance rule (10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants). The inspectors reviewed procedures and records to evaluate the licensees identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. The inspectors also interviewed plant personnel to assess the licensees treatment of performance deficiencies and extent of condition. Documents reviewed are listed in the attachment.
  • Action Request (AR) 01960759, Degraded B train control room air handling unit chill water condenser divider plate gasket following superflush
  • AR 01968367, Groundwater drainage (WZ) system level switch 2WZLS5060 found non-functional during routine calibration
b. Findings No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (711111.13)

a. Inspection Scope The inspectors reviewed the four maintenance activities listed below to verify that the

9 licensee assessed and managed plant risk as required by 10 CFR 50.65(a)(4) and licensee procedures. The inspectors assessed the adequacy of the licensees risk assessments and implementation of risk management actions. The inspectors also verified that the licensee was identifying and resolving problems with assessing and managing maintenance-related risk using the corrective action program. Additionally, for maintenance resulting from unforeseen situations, the inspectors assessed the effectiveness of the licensees planning and control of emergent work activities.

Documents reviewed are listed in the attachment.

  • Yellow risk on Unit 2 for planned reactor coolant system (RCS) lowered level inventory conditions following fuel reload, reactor vessel head installed, and A train safety-related equipment unavailable
  • Yellow risk associated with 1RN-296 (1A essential header return isolation valve) work
  • Yellow risk on Unit 1 and Unit 2 during critical activity plan for planned drainage and inspection of the A train RN suction valve from the SNSWP
  • Yellow risk associated with 2B EDG complex plan associated with maintenance on starting air solenoid valves
b. Findings No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15)

a. Inspection Scope Operability and Functionality Review The inspectors selected the five operability determinations or functionality evaluations listed below for review based on the risk-significance of the associated components and systems. The inspectors reviewed the technical adequacy of the determinations to ensure that technical specification operability was properly justified and the components or systems remained capable of performing their design functions. To verify whether components or systems were operable, the inspectors compared the operability and design criteria in the appropriate sections of the technical specification and updated final safety analysis report to the licensees evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with operability evaluations.

Documents reviewed are listed in the attachment.

  • AR 01955812, Leak chase caps found missing on several Unit 2 containment leak chase ports

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  • AR 01981232, Ice buildup on Unit 1 ice condenser intermediate deck doors
  • AR 01986214, SDSP1 Battery Cells 22 & 23 do not meet acceptance criteria
b. Findings No findings were identified.

1R18 Plant Modifications (71111.18)

a. Inspection Scope The inspectors verified that the three plant modifications listed below did not affect the safety functions of important safety systems. The inspectors confirmed the modifications did not degrade the design bases, licensing bases, and performance capability of risk significant structures, systems and components. The inspectors also verified modifications performed during plant configurations involving increased risk did not place the plant in an unsafe condition. Additionally, the inspectors evaluated whether system operability and availability, configuration control, post-installation test activities, and changes to documents, such as drawings, procedures, and operator training materials, complied with licensee standards and NRC requirements. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with modifications. Documents reviewed are listed in the attachment.
  • Permanent modification EC 109072, Unit 2 assured CA suction for extended station blackout per NRC Order EA-12-049
b. Findings No findings were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope The inspectors either observed post-maintenance testing or reviewed the test results for the maintenance activities listed below to verify the work performed was completed correctly and the test activities were adequate to verify system operability and functional capability.
  • Unit 2 lower ice condenser door functional testing following refueling outage ice

11 condenser preventive maintenance activities

  • 2B reactor coolant pump flow transmitter 2NCLP5030 functional test following emergent replacement due to erratic indication
  • 2A containment air return fan performance test following emergent repair of containment return air fan damper 2RAF-D-2
  • 1B residual heat removal (ND) pump performance test following planned calibration of mini-flow valve pressure switch 1NDPS5050
  • 1B CA pump performance test following planned replacement of pump motor breaker and other minor pump electrical preventive maintenance (PM)
  • 1B safeguards sequencer functional test following planned replacement of loss of voltage relays The inspectors evaluated these activities for the following:
  • acceptance criteria were clear and demonstrated operational readiness
  • effects of testing on the plant were adequately addressed
  • test instrumentation was appropriate
  • tests were performed in accordance with approved procedures
  • equipment was returned to its operational status following testing
  • test documentation was properly evaluated Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with post-maintenance testing. Documents reviewed are listed in the attachment.
b. Findings No findings were identified.

1R20 Refueling and Other Outage Activities (71111.20)

a. Inspection Scope For the Unit 2 refueling outage that completed October 14, 2015, the inspectors evaluated the following outage activities:
  • reactivity and inventory control
  • containment closure The inspectors verified that the licensee:
  • considered risk in developing the outage schedule
  • controlled plant configuration per administrative risk reduction methodologies
  • developed work schedules to manage fatigue

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  • developed mitigation strategies for loss of key safety functions
  • adhered to operating license and technical specification requirements The inspectors verified that safety-related and risk-significant structures, systems, and components not accessible during power operations were maintained in an operable condition. The inspectors also reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with outage activities. Documents reviewed are listed in the attachment.
b. Findings No findings were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope The inspectors reviewed the five surveillance tests listed below and either observed the test or reviewed test results to verify testing adequately demonstrated equipment operability and met technical specification and current licensing basis. The inspectors evaluated the test activities to assess for preconditioning of equipment, procedure adherence, and equipment alignment following completion of the surveillance.

Additionally, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with surveillance testing. Documents reviewed are listed in the attachment.

Routine Surveillance Tests

  • PT/0/A/4150/028, Initial Criticality and Zero Power Physics Testing, Rev. 67
  • PT/2/A/4350/055A, 2A Diesel Generator Slave Start Test, Rev. 27 Containment Isolation Valve
  • PT/2/A/4200/001C, Isolation Leak Rate Test, Rev. 110 (Enclosure 13.34, Test Sheet for Penetration M-360)

In-Service Tests (IST)

b. Findings No findings were identified.

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4. OTHER ACTIVITIES 4OA1 Performance Indicator Verification (71151)
a. Inspection Scope The inspectors reviewed a sample of the performance indicator (PI) data, submitted by the licensee, for the Unit 1 and Unit 2 PIs listed below. The inspectors reviewed plant records compiled between October 2014 and September 2015 to verify the accuracy and completeness of the data reported for the station. The inspectors verified that the PI data complied with guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Performance Indicator Guideline, and licensee procedures. The inspectors verified the accuracy of reported data that were used to calculate the value of each PI.

In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with PI data. Documents reviewed are listed in the attachment.

Cornerstone: Barrier Integrity

b. Findings No findings were identified.

4OA2 Problem Identification and Resolution (71152)

.1 Routine Review The inspectors screened items entered into the licensees corrective action program to identify repetitive equipment failures or specific human performance issues for follow-up.

The inspectors reviewed problem identification program reports, attended screening meetings, or accessed the licensees computerized corrective action database.

.2 Semi-Annual Trend Review

a. Inspection Scope The inspectors reviewed issues entered in 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 their review on repetitive equipment issues and human performance trends, but also considered the results of inspector daily problem identification program report screenings, licensee trending efforts, and licensee human performance results. The review nominally considered the 6-month period of July 2015 through December 2015, although some examples extended beyond those dates when the scope of the trend warranted. The inspectors compared their results with the licensees analysis of trends. Additionally, the inspectors reviewed the

14 adequacy of corrective actions associated with a sample of the issues identified in the licensees trend reports. The inspectors also reviewed corrective action documents that were processed by the licensee to identify potential adverse trends in the condition of structures, systems, and/or components as evidenced by acceptance of long-standing non-conforming or degraded conditions. Documents reviewed are listed in the attachment.

b. Findings and Observations No findings were identified.

.3 Annual Followup of Selected Issues

a. Inspection Scope The inspectors conducted a detailed review of AR 01961955 associated with the unexpected Unit 2 CA actuation during main turbine and main feedwater pump SI train trip function testing in Mode 4 on October 7, 2015.

The inspectors evaluated the following attributes of the licensees actions:

  • complete and accurate identification of the problem in a timely manner
  • evaluation and disposition of operability and reportability issues
  • consideration of extent of condition, generic implications, common cause, and previous occurrences
  • classification and prioritization of the problem
  • identification of root and contributing causes of the problem
  • identification of any additional condition reports
  • completion of corrective actions in a timely manner Documents reviewed are listed in the attachment.
b. Findings and observations No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153)

.1 Plant Events

a. Inspection Scope The inspectors reviewed the October 7, 2015, automatic actuation of the CA system that occurred with Unit 2 in Mode 4 while conducting main turbine and main feedwater pump SI train trip function testing. The inspectors compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. The inspectors verified that the

15 licensee made appropriate emergency classification assessment and reported the event in accordance with 10 CFR 50.72.

b. Findings

Introduction:

The inspectors identified a SL IV NCV of 10 CFR 50.72(b)(3)(iv)(A) for the licensees failure to submit an event notification to the NRC within eight hours of occurrence of an unplanned valid automatic actuation of the Unit 2 CA system.

Description:

On October 7, 2015, Unit 2 was in Mode 4 preparing to enter Mode 3 after completing scheduled refueling outage activities. As part of the surveillances required for entering Mode 3, the licensee was conducting A train solid state protection system (SSPS) testing to verify that the main turbine and main feedwater pumps trip upon actuation of a SI signal. At 6:55 a.m., during restoration from this testing, an inadvertent A train CA system auto start signal was generated when the operators returned the 2A CA pump Auto-Start-Defeat switch to the reset versus defeat position (since this was the original position prior to starting the test). This unblocked the CA auto start actuation circuitry and since both main feedwater pump trip signals were still present from the testing and had not been reset, the circuitry logic was made up to generate an actual CA auto start actuation. At the time of this CA actuation, the ND system was secured and the steam generators were being relied upon to provide RCS heat removal with both motor driven CA pumps in service providing feedwater to the steam generators. As a result of the actuation, the 2A CA pump received an auto start signal, the 2A CA flow control valves to the steam generators went to their full open positions, and the steam generator blowdown and nuclear sampling containment isolation valves closed. The operators recognized the unexpected CA actuation and took manual control of the 2A CA flow control valves and realigned them to their original throttled positions to maintain the desired steam generator levels. All systems functioned as designed from the actuation and there was no adverse impact to the unit.

Section (b)(3)(iv)(A) of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, requires that the licensee notify the NRC as soon as practical and in all cases within eight hours of occurrence any event or condition that results in valid actuation of certain specified systems (which includes the CA system),

except when the actuation results from and is part of a pre-planned sequence during testing or reactor operation. The licensee initially screened this event as not reportable pursuant to 10 CFR 50.72(b)(3)(iv)(A) because at the time of the event, the main feedwater pumps were not in service and not needed in lieu of the CA pumps providing feedwater cooling to the steam generators. The licensee concluded this was an invalid actuation of the CA system.

Based on review of the event circumstances and the guidance in NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73, Rev. 3, the inspectors did not agree with the licensees basis for concluding this was an invalid CA actuation. NUREG-1022, Section 3.2.6, System Actuation, states that valid actuations are those that result from valid signals or from intentional manual initiation unless it is part of preplanned testing.

The inspectors concluded that the actuation was valid because it was the result of actual plant conditions (valid main feedwater pump trip signals) and did not result from a

16 preplanned sequence during testing. Therefore, the actuation was reportable under 10 CFR 50.72(b)(3)(iv)(A), as well as 10 CFR 50.73(a)(2)(iv)(A). Based upon further review, the licensee determined the condition was reportable and reported the event pursuant to 10 CFR 50.72(b)(3)(iv)(A) at 10:18 p.m. on October 15, 2015. A Licensee Event Report (LER) (05000370/2015-001-00) was submitted pursuant to 10 CFR 50.73(a)(2)(iv)(A) on December 7, 2015, and was reviewed by the inspectors in Section 4OA3.2 of this inspection report.

Analysis: The inspectors determined that the licensees failure to submit an event notification to the NRC within eight hours of occurrence of an unplanned valid CA system actuation in accordance with 10 CFR 50.72(b)(3)(iv)(A) was a PD. Since the failure to submit an event report within the time requirements may impact the ability of the NRC to perform its regulatory oversight function, this PD was dispositioned under traditional enforcement and the violation was assessed using Section 2.2.4 of the NRCs Enforcement Policy. Using the example listed in Section 6.9.d.9, A licensee fails to make report required by 10 CFR 50.72, the issue was determined to be a SL IV violation. In accordance with IMC 0612, because this violation involved traditional enforcement and does not have an underlying technical violation that would be considered more-than-minor, a cross-cutting aspect is not assigned to this violation.

Enforcement: 10 CFR 5.72(b)(3)(iv)(A) required that the licensee notify the NRC as soon as practical and in all cases within eight hours of occurrence of any event or condition that results in valid actuation of certain specified systems (which includes the CA system), except when the actuation results from and is part of a pre-planned sequence during testing or reactor operation. Contrary to the above, on October 7, 2015, the licensee did not recognize that a valid actuation of the Unit 2 CA system occurred, which was not part of a pre-planned activity, and failed to notify the NRC within eight hours of the event occurrence. After NRC review of the event determined the CA actuation was valid, the licensee subsequently reported the event in accordance with 10 CFR 50.72 on October 15, 2015. Because this violation was of very low safety significance, was not repetitive or willful, and was entered into the licensees corrective action program as ARs 01961955 and 01965239, this issue is being treated as a SL IV NCV consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000370/2015004-01: Failure to Report Unit 2 Unplanned Valid Auxiliary Feedwater Actuation in Mode 4)

.2 (Closed) LER 05000370/2015-001-00, Auxiliary Feedwater Actuation While in Mode 4

a. Inspection Scope The inspectors reviewed the LER, causal evaluation and corrective actions, and discussed the issue with the licensee staff. The cause of the inadvertent CA actuation was determined to be an inadequate test procedure used to verify the SI trip functions for the main turbine and main feedwater pumps. Specifically, PT/2/A/4200/026A, Turbine and MFWPT Trips from SSPS, test restoration instructions did not clearly require either the reset of the main feedwater pump trip signals generated during the test or require the CA train auto start defeat switches to remain in the defeat position as part of the test restoration alignment. The inspectors concluded that this inadequate SSPS

17 surveillance test procedure was a violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requiring procedures affecting quality to be appropriate to the circumstances. Due to the fact that no actual loss of feedwater occurred during the incident and there was no adverse impact on plant operation, the failure to comply with this requirement constituted a violation of minor safety significance that was not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee entered this issue into their corrective action program as AR 01961955. LER 05000370/2015-001-00 is closed.

b. Findings No findings were identified.

4OA5 Other Activities Independent Spent Fuel Storage Installation (60855.1)

a. Inspection Scope The inspectors reviewed licensee procedures and observed aspects of loading and transporting casks associated with storing spent fuel in the Independent Spent Fuel Storage Installation (ISFSI) in accordance with IP 60855.1. The inspectors observed or reviewed documentation of selected licensee activities related to the loading of cask number 42 and 38, completed July 16, 2015, and November 16, 2015, respectively, to verify that they were performed in a safe manner and in compliance with the NAC-MAGNATOR Certificate of Compliance, Technical Specifications, and licensee approved procedures. Documents reviewed are listed in the Attachment.
b. Findings No findings were identified.

4OA6 Meetings, Including Exit On January 14, 2016, the resident inspectors presented the inspection results to Mr.

Steven Capps and other members of the licensees staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT: SUPPLEMENTARY INFORMATION

SUPPLEMENTARY INFORMATION KEY POINTS OF CONTACT Licensee B. Anderson, Superintendent of Operations D. Brenton, Maintenance Superintendent S. Capps, Vice President, McGuire Nuclear K. Crane, Senior Licensing Specialist J. Gabbert, Chemistry Manager J. Glenn, Organizational Effectiveness Manager M. Kelly, Outage and Scheduling Manager K. Kinard, Security Manager (Interim)

S. Mooneyhan, Radiation Protection Manager C. Morris, Station Manager J. Robertson, Regulatory Affairs Manager P. Schuerger, Training Manager S. Snider, Engineering Manager LIST OF REPORT ITEMS Opened and Closed 05000370/2015004-01 NCV Failure to Report Unit 2 Unplanned Valid Auxiliary Feedwater Actuation in Mode 4 (Section 4OA3.1)

Closed 05000370/2015-001-00 LER Auxiliary Feedwater Actuation While in Mode 4 (Section 4OA3.2)

DOCUMENTS REVIEWED Section 1R01: Adverse Weather Protection Seasonal Extreme Weather Conditions AD-WC-ALL-0230, Seasonal Readiness, Rev. 0 NSD 317, Freeze Protection Program, Rev. 4 and 5 PT/0/B/4700/038, Cold Weather Protection, Rev. 32 through 37 PT/0/B/4700/070, On Demand Freeze Protection Verification Checklist, Rev. 30 Action Register Update Details Reports (of freeze protection program from September -

December 2015)

Readiness to Cope with External Flooding UFSAR Section 2.4, Hydrology MCS-1465.00-00-0012, Design Basis Specification for Flooding from External Sources, Rev. 2 MCC-1100.00-00-0002, McGuire Probable Maximum Precipitation Flood Analysis, Rev. 0 MCC-1612.00-00-0002, 10CFR50.54.f Recommendation 2.3 Fukushima Near-Term Task Force Flood Walkdowns, Rev. 0 Attachment

2 MCM-1100.00-0001.001, McKim & Creed Probable Maximum Precipitation Flood Analysis, Rev.

0 Drawing No. MC-1022-01.00, Grading Plan, Plant Area, Rev. 51 AP/0/A/5500/044, Plant Flooding, Rev. 17 FG/0/A/FLEX/FSG-22, FLEX Sump Pump Operations, Rev. 0 Section 1R04: Equipment Alignment Partial Walkdown OP/1/A/6200/001B, Chemical and Volume Control System Charging, Rev. 71 OP/1/A/6200/001E, Chemical and Volume Control System Valve Checklists, Rev. 36 MCFD-1554-03.01, Flow Diagram of Chemical and Volume Control System (NV), Rev. 24 OP/2/A/6200/004, Residual Heat Removal System, Rev. 97 MCFD-2561-01.00, Flow Diagram of Residual Heat Removal System (ND), Rev. 25 Complete Walkdown OP/2/A/6250/002, Auxiliary Feedwater System, Rev. 097 Auxiliary Feedwater System Health Report Q2 2015 MCS-1592.CA-00-0001, Auxiliary Feedwater Design Basis, Rev. 34 MCFD-2592-01.01, Flow Diagram of Auxiliary Feedwater System (CA), Rev. 32 Section 1R05: Fire Protection Quarterly Inspection MCS-1465.00-00-0008, Design Basis Specification for Fire Protection, Rev. 19 MCS-1465.00-00-0022, Appendix R Safe Shutdown Analysis, Rev. 14 MCC-1435.00-00-0059, NFPA 805 - Appendix R Safe Shutdown Deterministic Analysis, Rev. 2 AD-EG-ALL-1520, Transient Combustible Control, Rev. 3 NSD 104, Material Condition/Housekeeping, Foreign Material Exclusion and Seismic Concerns, Rev. 37 NSD 316, Fire Protection Impairment and Surveillance, Rev. 16 FS/2/B/9000/033, Unit 2 Lower Annulus/Containment Fire Strategy #33, Rev. 1 FS/2/B/9000/033A, Unit 2 Upper Annulus/Containment Fire Strategy #33A, Rev. 0 FS/2/B/9000/016, Unit 2 750 Electrical Penetration Room Fire Strategy #16, Rev. 0 FS/2/B/9000/010, Unit 2 733 Electrical Penetration Room Fire Strategy #10, Rev. 1 FS/1/B/9000/017, 1ETA Room Fire Strategy #17, Rev. 0 FS/1/B/9000/017A, HVAC Room for 1ETA Fire Strategy #17A, Rev. 0 MFSD-015.017, 1ETA/750 Electrical Penetration Room, Rev. 0 MFSD-033, Unit 2 Lower Annulus/Containment, Rev. 0 MFSD-033A, Unit 2 Upper Annulus/Containment, Rev. 0 MFSD-010.0012, 2ETB/733 Electrical Penetration Room, Rev. 1 MFSD-016.018, 2ETA/750 Electrical Penetration Room, Rev. 0 MFSD-002, Unit 1 CA Pump Room, Rev. 0 Annual Inspection NSD 112, Fire Brigade Organization, Rev. 13 PT/0/B/4600/121, Fire Drill, Rev. 8 RP/0/A/5700/025, Fire Brigade Response, Rev. 19 MNS Fire Drill Scenario #17, SSF McGuire Nuclear Station Fire Strategy Number RB 4.1-1, (SSF)

3 FS/1/B/9000/070, Unit 1 Outside Yard Fire Strategy #70, Rev. 0 Section 1R06: Flood Protection Measures Internal Flooding MCC-1206.47-69-100, Auxiliary Building Flooding Analysis, Rev. 16 MCS-1154.00-0004, Design Basis Specification for Auxiliary Building Structures, Rev. 13 AP/0/A/5500/44, Plant Flooding, Rev.18 PT/0/A/4973/007B, WZ Sump B, Pumps A and B Performance Test, Rev. 34 Section 1R11: Licensed Operator Requalification Program and Licensed Operator Performance Resident Inspector Quarterly Review of Licensed Operator Requalification AD-OP-ALL-1000, Conduct of Operations, Rev. 4 NSD 509, Site Standards in Support of Operational Focus, Rev. 6 SOMP 01-07, Control Room Oversight, Rev. 2 Active Simulator Examination Package (for described scenario)

AP/1/A/5500/016, Malfunction of Nuclear Instrumentation System, Rev. 27 AP/1/A/5500/023, Loss of Condenser Vacuum, Rev. 22 EP/1/A/5000/E-0, Reactor Trip or Safety Injection, Rev. 42 EP/1/A/5000/ES-0.1, Reactor Trip Response, Rev. 40 EP/1/A/5000/E-3, Steam Generator Tube Rupture, Rev. 43 RP/0/A/5700/000, Classification of Emergency, Rev. 24 Resident Inspector Quarterly Review of Licensed Operator Performance in the Actual Plant/Main Control Room AD-OP-ALL-1000, Conduct of Operations, Rev. 4 OMP 4-3, Use of Emergency and Abnormal Procedures and FLEX Support Guidelines, Rev. 42 NSD-509, Site Standards in Support of Operational Focus, Rev. 6 SOMP 01-07, Control Room Oversight, Rev. 2 OP/2/A/6100/001, Controlling Procedure for Unit Startup, Rev. 143 OP/2/A/6100/003, Controlling Procedure for Unit Operation, Rev. 170 PT/0/A/4150/021, Post Refueling Controlling Procedure for Criticality, Zero Power Physics, and Power Escalation Testing, Rev. 116 PT/0/A/4150/026, Power Escalation Testing, Rev. 18 PT/0/A/4150/028, Initial Criticality and Zero Power Physics Testing, Rev. 67 PT/0/A/4150/047, 1/M Monitoring During Startup, Rev. 6 Section 1R12: Maintenance Effectiveness AD-EG-ALL-1210, Maintenance Rule Program, Rev. 0 AD-EG-ALL-1204, Single Point Vulnerability Identification, Elimination and Mitigation, Rev. 2 AD-EG-ALL-1206, Equipment Reliability Classification, Rev. 2 AD-EG-ALL-1209, System, Component, and Program Health Reports and Notebooks, Rev. 3 AD-EG-ALL-1211, System Performance Monitoring and Trending, Rev. 3 SSC Function Scoping Database WZ System Health Report 3Q AR 01606494, Evaluate adding Maintenance Rule Function for Floor Drain Tank Sump level indication AR 01975118, C WZ Sump Pump A Motor Overload

4 Section1R13: Maintenance Risk Assessments and Emergent Work Control AD-WC-ALL-0410, Work Activity Integrated Risk Management, Rev. 1 NSD 415, Operational Risk Management (Modes 1-3) per 10 CFR 50.65(a)(4), Rev. 8 SOMP 02-02, Operations Roles in the Risk Management Process, Rev. 17 OMP 13-7, Operational Control of Protected Equipment, Rev. 7 AD-OP-ALL-0201, Protected Equipment, Rev. 1 91-01 risk management plan for lowered inventory Section1R15: Operability Determinations and Functionality Assessments AD-OP-ALL-0102, Operational Decision Making, Rev. 0 AD-OP-ALL-0105, Operability Determinations and Functionality Assessments, Rev. 2 Section 1R18: Plant Modifications EDM 601, Engineering Change Manual, Rev. 29 NSD 301, Engineering Change Program, Rev. 45 AD-EG-ALL-1132, Preparation and Control of Design Change Engineering Changes, Rev. 2 AD-EG-ALL-1110, Design Review Requirements, Rev. 1 OMP 10-2, Temporary Engineering changes, Rev. 14 SOMP 02-04, Engineering Change Implementation Process, Rev. 0 MCS-1592.CA-00-0001, Auxiliary Feedwater Design Basis, Rev. 34 MCC-1210.04-00-0043, Instrument Loop Uncertainty CA-RN Swapover Suction Pressure Switch Loops, Rev. 5 MCC-1223.42-00-0053, Documentation of Adequacy of the Assured Suction Sources to the Unit 1 CA Pumps, Rev. 2 MCC-1223.42-00-0054, Documentation of Adequacy of the Assured Suction Sources to the Unit 2 CA Pumps, Rev. 2 TT/2/A/EC109072/001, Post Modification Testing for EC109072, Assured CA Suction, Rev. 0 AR 01961749, 1RN-277B has ground Section 1R19: Post-Maintenance Testing NSD 408, Testing, Rev. 18 WPM 501, Post Maintenance Testing, Rev. 15 AD-EG-ALL-1155, Post Modification Testing, Rev. 1 PT/0/A/4200/032, Periodic Inspection of Ice Condenser Lower Inlet Doors, Rev. 21 IP/2/A/3000/022D, Reactor Coolant System Flow Calibration Loop B, Protection Channel 2NCLP5030, Rev. 11 PT/2/A/4450/006A, VX System Train 2A Performance Test, Rev. 54 WO 02198748, PT 1NDLP5050: RHR Pump B Min Flow Loop Calibration OP/1/A/6200/004, Residual Heat Removal System, Rev. 133 WO 02165123, PM 1ETA1 Breaker Replacement OP/1/B/6400/006, Auxiliary Feedwater System, Rev. 129 PT/1/A/4350/004, 4KV Loss of Voltage Trip Actuating Device Operational Test, Rev. 17 IP/0/A/4971/010, Brown Boveri ITE27D Relay Calibration, Rev. 12 Section1R20: Refueling and Other Outage Activities NSD 403, Shutdown Risk Management (Modes 4, 5, 6, and No-Mode) Per 10CFR50.65 (a)(4),

Rev. 34 MSD 585, Reactor Building Personnel Access and Material Control, Rev. 16

5 OP/2/A/6100/001, Controlling Procedure for Unit Startup, Rev. 143 OP/2/A/6100/003, Controlling Procedure for Unit Operation, Rev. 170 OP/2/A/6100/SO-1, Maintaining NC System Level, Rev. 50 OP/2/A/6100/SO-10, Controlling Procedure for LTOP Operation, Rev. 39 OP/2/A/6100/SU-1, Mode 6 and Core Alterations Checklist, Rev. 47 OP/2/A/6100/SU-3, Mode 5 Checklist, Rev. 28 OP/2/A/6100/SU-5, Filling the NC System, Rev. 57 OP/2/A/6100/SU-6, Venting the NC System, Rev. 34 OP/2/A/6100/SU-7, Fill and Vent Valve Checklist, Rev. 19 OP/2/A/6100/SU-8, Heatup to 200 Degrees F, Rev. 54 OP/2/A/6100/SU-9, Mode 4 Checklist, Rev. 75 OP/2/A/6100/SU-10, Heatup Checklist, Rev. 12 OP/2/A/6100/SU-13, Heatup to 350 Degrees F, Rev. 51 OP/2/A/6100/SU-14, Removing ND from Service, Rev. 33 OP/2/A/6100/SU-15, Mode 3 Checklist, Rev. 49 OP/2/A/6100/SU-16, Aligning ND System for Standby Alignment, Rev. 12 OP/2/A/6100/SU-19, Heatup to 557 Degrees F, Rev. 65 OP/2/A/6100/SU-20, Modes 1 and 2 Checklist, Rev. 40 PT/0/A/4150/026, Power Escalation Testing, Rev. 18 PT/0/A/4150/028, Initial Criticality and Zero Power Physics Testing, Rev. 67 PT/0/A/4150/046, Containment Walkdown, Rev. 4 PT/0/A/4150/047, 1/M Monitoring During Startup, Rev. 6 PT/2/A/4200/002C, Containment Closure, Rev. 72 PT/2/A/4600/003F, Containment Cleanliness and ECCS Operability Inspection, Rev. 20 Section 1R22: Surveillance Testing AD-EG-ALL-1202, Preventive Maintenance and Surveillance Testing Administration, Rev. 2 AD-WC-ALL-0250, Work Implementation and Completion, Rev. 0 AD-EG-ALL-1720, Inservice Testing (IST) Program Implementation, Rev. 0 Section 4OA1: Performance Indicator (PI) Verification AD-LS-ALL-0004, NRC Performance Indicators and Monthly Operating Report, Rev. 0 and 1 Technical Specification Action Item Logs Control Room Operator Logs Corrective Action Program Database Section 4OA2: Problem Identification and Resolution AD-PI-ALL-0100, Corrective Action Program, Rev. 3 AD-PI-ALL-0101, Root Cause Evaluation, Rev. 1 AD-PI-ALL-0102, Apparent Cause Evaluation, Rev. 1 AD-PI-ALL-0103, Quick Cause Evaluation, Rev. 1 AD-PI-ALL-0104, Prompt Investigation Response Team, Rev. 1 AD-PI-ALL-0105, Effectiveness Reviews, Rev. 1 AD-PI-ALL-0201, Corrective Action Program (CAP) Trending, Rev. 2 AD-PI-ALL-0300, Self-Assessment and Benchmark Programs, Rev. 2 AD-PI-ALL-1000, Conduct of Performance Improvement, Rev. 2

6 Section 4OA3: Follow-Up of Events and Notices of Enforcement Discretion AD-LS-ALL-0006, Notification/Reportability Evaluation, Rev. 0 AD-OP-ALL-0101, Event Response and Notifications, Rev. 4 PT/2/A/4200/026A, Turbine and MFWPT Trips From SSPS, Revs. 21, 20, and 19 Completed test records for PT/1/A/4200/026A and PT/2/A/4200/026A since 2011 Section 4OA5: Other Activities MP/0/A/7650/227, (ISFSI) Loading Spent Fuel Assemblies Into MAGNASTOR Casks, Rev. 14 MP/0/A/7650/231, (ISFSI) Operation of Dry Cask Transporter (MAGNASTOR Spent Fuel Casks), Rev. 8 AD-MN-ALL-0002, Foreign Material Exclusion, Rev. 4 OP/0/A/6550/011, Internal Transfer, Rev. 64 OP/0/A/6550/029, (ISFSI) MAGNASTOR Fuel Assembly Loading/Unloading Procedure, Rev. 7 MCC-1553.12-00-0046 (Dry Storage Certifications for ISFSI casks #42 and #38)

WO 02175939 (ISFSI Cask Load # 0FCTKN042)

WO 02175936 (ISFSI Cask Load # 0FCTKN038)

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