IR 05000424/2012002: Difference between revisions

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| issue date = 04/30/2012
| issue date = 04/30/2012
| title = IR 05000424-12-002, 05000425-12-002; January 1, 2012 - March 31, 2012; Vogtle Electric Generating Plant, Units 1 and 2; Integrated Report
| title = IR 05000424-12-002, 05000425-12-002; January 1, 2012 - March 31, 2012; Vogtle Electric Generating Plant, Units 1 and 2; Integrated Report
| author name = Ehrhardt F J
| author name = Ehrhardt F
| author affiliation = NRC/RGN-II/DRP/RPB2
| author affiliation = NRC/RGN-II/DRP/RPB2
| addressee name = Tynan T E
| addressee name = Tynan T
| addressee affiliation = Southern Nuclear Operating Co, Inc
| addressee affiliation = Southern Nuclear Operating Co, Inc
| docket = 05000424, 05000425
| docket = 05000424, 05000425
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:April 30, 2012
[[Issue date::April 30, 2012]]


Mr. Tom Vice President - Vogtle Southern Nuclear Operating Company, Inc.
==SUBJECT:==
 
VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2012002 AND 05000425/2012002
Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830
 
SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2012002 AND 05000425/2012002


==Dear Mr. Tynan:==
==Dear Mr. Tynan:==
Line 48: Line 44:
SNC 2 In accordance with the 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response (if any) will be available electronically for public ins pection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
SNC 2 In accordance with the 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response (if any) will be available electronically for public ins pection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Sincerely,/RA/ Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects  
Sincerely,
/RA/ Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects  


Docket Nos.: 05000424, 05000425 License Nos.: NPF-68 and NPF-81  
Docket Nos.: 05000424, 05000425 License Nos.: NPF-68 and NPF-81  


===Enclosures:===
===Enclosures:===
Inspection Report 05000424/2012002 and 05000425/2012002  
Inspection Report 05000424/2012002 and 05000425/2012002 w/Attachment: Supplemental Information  
 
===w/Attachment:===
Supplemental Information  
 
cc w/encl: (See page 3)
 
_
ML12121A498 _______________________ X SUNSI REVIEW COMPLETE G FORM 665 ATTACHED OFFICE RIII:DRP RII:DRp RII:DRP RII:DRP RII:DRP SIGNATURE /RA/ /RA by FEhrhardt/ /RA /RA By-email/ /RA/ By E-mail/ NAME TLighty MMiller FEhrhardt MCain TChandler DATE 4/27/2012 4/27/2012 4/27/2012 4/27/2012 4/27/2012 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO SNC 3 cc w/encl: S. Kuczynski Chairman, President and CEO Southern Nuclear Operating Company, Inc.
 
Electronic Mail Distribution
 
D. G. Bost Chief Nuclear Officer Southern Nuclear Operating Company, Inc.
 
Electronic Mail Distribution
 
N. J. Stringfellow Licensing Manager Southern Nuclear Operating Company, Inc.
 
Electronic Mail Distribution
 
Paula Marino Vice President Engineering Southern Nuclear Operating Company, Inc.
 
Electronic Mail Distribution
 
J. L. Pemberton SVP & General Counsel-Ops & SNC Southern Nuclear Operating Company, Inc.
 
Electronic Mail Distribution
 
M. J. Ajluni Nuclear Licensing Director Southern Nuclear Operating Company, Inc.
 
Electronic Mail Distribution
 
B. D. McKinney, Jr.
 
Regulatory Response Manager Southern Nuclear Operating Company, Inc.
 
Electronic Mail Distribution
 
D. W. Daughhetee Licensing Engineer Southern Nuclear Operating Company, Inc.
 
Electronic Mail Distribution
 
Bradley J. Adams Vice President Fleet Operations Support Southern Nuclear Operating Company, Inc.
 
Electronic Mail Distribution T. D. Honeycutt Regulatory Response Supervisor Southern Nuclear Operating Company, Inc.
 
Electronic Mail Distribution
 
L. P. Hill Licensing Supervisor Southern Nuclear Operating Company, Inc.
 
Electronic Mail Distribution
 
L. L. Crumpton Administrative Assistant, Sr.
 
Southern Nuclear Operating Company, Inc.


Electronic Mail Distribution
REGION II==
 
David H. Jones Site Vice President Vogtle Units 3 and 4 Southern Nuclear Operating Company Electronic Mail Distribution
 
Hickox, T. Mark Vogtle Electric Generating Plant Electronic Mail Distribution
 
S. C. Swanson Site Support Manager Vogtle Electric Generating Plant Electronic Mail Distribution
 
Senior Resident Inspector U.S. Nuclear Regulatory Commission Vogtle Electric Generating Plant U.S. NRC 7821 River Road Waynesboro, GA 30830
 
Arthur H. Domby, Esq.
 
Troutman Sanders Electronic Mail Distribution
 
(cc w/encl cont'd - See page 4)
SNC 4 cc w/encl cont/d: Sandra Threatt, Manager Nuclear Response and Emergency Environmental Surveillance Bureau of Land and Waste Management Department of Health and Environmental Control Electronic Mail Distribution
 
Division of Radiological Health TN Dept. of Environment & Conservation 401 Church Street Nashville, TN 37243-1532
 
Richard Haynes Director, Division of Waste Management Bureau of Land and Waste Management S.C. Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201
 
Lee Foley Manager of Contracts Generation Oglethorpe Power Corporation Electronic Mail Distribution
 
Mark Williams Commissioner Georgia Department of Natural Resources Electronic Mail Distribution
 
Chuck Mueller Manager Policy and Radiation Program Georgia Department of Natural Resources Electronic Mail Distribution
 
Cynthia A. Sanders Radioactive Materials Program Manager Environmental Protection Division Georgia Department of Natural Resources Electronic Mail Distribution James C. Hardeman Environmental Radiation Program Manager Environmental Protection Division Georgia Department of Natural Resources Electronic Mail Distribution
 
Mr. Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia Electronic Mail Distribution
 
Reece McAlister Executive Secretary Georgia Public Service Commission Electronic Mail Distribution
 
Office of the Attorney General 40 Capitol Square, SW Atlanta, GA 30334
 
Office of the County Commissioner Burke County Commission Electronic Mail Distribution
 
Director Consumers' Utility Counsel Division Governor's Office of Consumer Affairs 2 M. L. King, Jr. Drive Plaza Level East; Suite 356 Atlanta, GA 30334-4600
 
Amy Whaley Resident Manager Electronic Mail Distribution SNC 5 Letter to Tom from Frank Ehrhardt dated April 30, 2012.
 
SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2012002 AND 05000425/2012002
 
Distribution w/encl:
C. Evans, RII EICS L. Douglas, RII EICS RIDSNRRDIRS PUBLIC RidsNrrPMVogtle Resource Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION II  


Docket Nos.: 50-424, 50-425  
Docket Nos.: 50-424, 50-425  
Line 504: Line 403:


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
==Section 1R01: Adverse Weather Protection==
===Procedures===
: 11877-1 Rev. 22.1, Cold Weather Checklist, Unit 1
: 11877-2 Rev. 20.1, Cold Weather Checklist, Unit 2
==Section 1R04: Equipment Alignment==
===Procedures===
: 11744-2 Rev. 14.3, Essential Chilled Water System Alignment 11146-1 Rev. 7.1, Diesel Generator Fuel Oil Transfer System Alignment
: 11145-1 Rev. 15.1, Diesel Generator Alignment
: 11150-1 Rev. 18.0, Nuclear Service Cooling Water System Alignment
: 11405-2 Rev. 6.1, 125V DC 1E Electrical Distribution System Alignment
===Drawings===
: 2X4DB221 Rev. 25.0, P&I Diagram Safety Related (Essentia
l) Chillers, Unit 2 Trains A&B, System No. 1592
: 2X4DB233 Rev. 24.0, P&I Diagram Essential Chilled Water Cooling Coils, Unit 2 Train A, System No. 1592
: 2X4DB234 Rev. 25.0, P&I Diagram Essential Chilled Water Cooling Coils, Unit 2 Train B, System No. 1592
: 1X4DB170-2 Rev. 45.0, P&I Diagram Diesel Generator System Train B System No. 2403
: 1X4DB170-1 Rev. 45, P&I Diagram Diesel Generator System, Train A System No. 2403
: 1X4DB133-1 Rev. 53, P&I Diagram Nuclear Service Cooling Water System, System No. 1202
: 1X4DB133-2 Rev. 59, P&I Diagram Nuclear Service Cooling Water System, System No. 1202
: 1X4DB134 Rev. 31, P&I Diagram Nuclear Service Cooling Water System, System No. 1202
: 1X4DB135-1 Rev. 29, P&I Diagram Nuclear Service Cooling Water System, System No. 1202
: 1X4DB135-2 Rev. 34, P&I Diagram Nuclear Service Cooling Water System, System No. 1202
: 2X3D-AA-G01A Rev. 7.0, Main One Line Class 1E 125V DC and 120V Vital AC Systems
: System Health Reports System Health Report, Vogtle Emergency Diesel Generator Systems 2403, 2
nd QTR 2011
==Section 1R05: Fire Protection==
===Procedures===
: 2000-C Rev. 224.0, Fire Protection Program
: 2005-C Rev. 29.4, Fire Response Procedure
: NMP-TR-425 vers ion 5.0, Fire Drill Program 17103A-C Rev. 36.0, Annunciator Response Procedures for the Fire Alarm Computer
: 2749-2 Rev. 1.0, Zone 49 - Auxiliary Building - Level 1, Train "A" ACCW Hx Room Fire Fighting Preplan
: 2752-2 Rev. 1.0, Zone 52 - Auxiliary Building - Level 1, Train "B" ACCW Hx Room Fire Fighting Preplan
: 2862-2 Rev. 1.1, Zone 162 - Diesel Generator Building Fire Fighting Preplan
: 2864-2 Rev. 0.2, Zone 164 - Diesel Generator Building - Train B DFO Day Tank Fire Fighting Preplan Attachment
: 92832-1 Rev. 6.1, Zone 132 - Fuel Handling Building - Level A Fire Fighting Preplan 92729-1 Rev. 3.1, Zone 29 - Fuel Handling Building - Levels B, A, and 1 Electrical Chase - Train B Fire Fighting Preplan
: 2832-2 Rev. 2.1, Zone 132 - Fuel Handling Building - Level A, SFPHX & Pipe Pen. Fire Fighting Preplan
: 2729-2 Rev. 1.0, Zone 29 - Fuel Handling Building - Electrical Chase - Train B Fire Fighting Preplan
: 2791-2 Rev. 3.2, Zone 91 - Control Building - Level A Fire Fighting Preplan
: 2792-2 Rev. 3.1, Zone 92 - Control Building - Level A Fire Fighting Preplan
: 2798-2 Rev. 2.2, Zone 98 - Control Building - Level A Fire Fighting Preplan
: 2803-2 Rev. 2.2, Zone 103 - Control Building - Level A Fire Fighting Preplan
: 2797-2 Rev. 2.2, Zone 97 - Control Building - Level A Fire Fighting Preplan
: 2704-2 Rev. 2.0, Zone 4 - Auxiliary Building - Level D, Containment Spray Pump "A" Fire Fighting Preplan
: 2705-2 Rev.3.0, Zone 5 - Auxiliary Building - Level D, Containment Spray Pump "B" Fire Fighting Preplan
: 2709-2 Rev.2.2, Zone 9 - Auxiliary Building - Level D, Fi re Fighti ng Preplan 92710-2 Rev.2.2, Zone 10 - Auxiliary Building - Level D, Fi re Fighti ng Preplan
==Section 1R07: Heat Sink Performance==
===Procedures===
: 83309-C Rev. 6.4, Safety-Related Heat Exchanger Inspection 
===Work Orders===
: SNC 132697 
===Condition Reports===
: CR 355096
: Other EPRI
: NP-7552, Heat Exchanger Performance Monitoring Guidelines
==Section 1R11: Licensed Operator Requalification Program==
: Lesson Plans
: V-RQ-PP-39000-011, Intro to PRA, Enhanced (a)4, and Risk Managed Technical Specifications
: V-RQ-PP-29102-003, Containment HVAC Systems Review
==Section 1R12: Maintenance Rule Effectiveness==
===Procedures===
: 50028-C Rev. 18.1, Engineering Maintenance Rule Implementation 
===Condition Reports===
and Action Items
: CR 2007108257
: CR 2006103407
: CR 2006101282
: CR 2005111460
: AI 2007206326 
: Attachment Work Orders
: MWO 2081874001
: MWO 2081874101
: Other Records System 1821-2, Safety Features Sequencer System 2011 health reports Maintenance Rule Implementation record dated November 11, 2011
: System 1201-2, Reactor Coolant System 2011 health reports Maintenance Rule Implementation record dated August 08, 2011
==Section 1R15: Operability Evaluations==
===Condition Reports===
: SNC385878
: SNC400312
: SNC400851
: SNC405658 
: SNC411376
: SNC414015
: SNC404401
: Other Records
: TE 309973
: TE 316317
: TE 321825
==Section 1R18: Plant Modifications==
===Procedures===
: NMP-ES-054-001 Rev. 1.0, Temporary Modification Processing
: NMP-ES-054-001 Rev. 1.1, Temporary Modification Processing 
===Work Orders===
: SNC357635 
: SNC345044
==Section 1R19: Post Maintenance Testing==
===Procedures===
: 13744B-1 Rev. 8, Train B Essential Chilled Water System 14825-2 Rev. 89.1, Quarterly Inservice Valve Test
: 13011-2 Rev. 64.2, Residual Heat Removal System
: 14980B-1 Rev. 23.5, Diesel G
enerator 1B Operability Test 25717-C Rev. 38.1, Torquing Electrical Type Connections
: 13610-2 Rev. 46, Auxiliary Feedwater System 14980A-1 Rev. 23.4, Diesel G
enerator 1A Operability Test 
===Work Orders===
: SNC125468 
: SNC125854 
: SNC128307 
: Attachment
: SNC125852 
: SNC359763 
: SNC337135 
: SNC367372 
: SNC363250
==Section 1R22: Surveillance Testing==
===Procedures===
: 14805B-2 Rev. 3, Train B Residual Heat Removal Pump IST and Response Time Test
: 14421-2 Rev 40, Solid State Protection System Train B Operability Test 13435-C Rev. 40.1, Circuit Breaker Racking Procedure
: 14980B-1 Rev 23.5, Diesel Generator 1B Operability Test 24797-1 Rev. 20.1, Steam Pressure Loop 4 (Protection I) 1P-544 Channel Operational Test and Channel Calibration
: 14980B-2 Rev 22.5, Diesel Generator 2B Operability Test 14810-2 Rev. 41, TDAFW Pump Operability, Response Time and Check Valve IST 
===Work Orders===
: SNC311907 
: SNC333062 
: SNC367372
: Other Records Basic Cause Determination for CR 407192
==Section 4OA1: Performance Indicator (PI) Verification==
===Procedures===
: 00163-C, Rev. 14.2, NRC Performance Indicator and Monthly Operating Report Preparation and Submittal
==Section 4OA2: Identification and Resolution of Problems==
===Work Orders===
and Technical Evaluations
: TE313934
: SNC362170
: SNC362171
: TE314864
: TE314653
: SNC362950
: SNC362952
: SNC362954
: TE314988
: TE314768
: TE314777
: TE315011
: TE315013
: TE316077
: TE316553
: SNC367077 
: Attachment


==Section 4OA3: Event Follow-up==
: Procedures/Calculations/Engineering Documents Temporary Modifications
: 1102221001 and
: 2012221301 
===Condition Reports===
and Action Items:
: CR 2010113375
: SNC353533
: SNC374623 
===Work Orders===
: MWO 1102198301
}}
}}

Revision as of 00:00, 29 June 2019

IR 05000424-12-002, 05000425-12-002; January 1, 2012 - March 31, 2012; Vogtle Electric Generating Plant, Units 1 and 2; Integrated Report
ML12121A498
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 04/30/2012
From: Frank Ehrhardt
NRC/RGN-II/DRP/RPB2
To: Tynan T
Southern Nuclear Operating Co
References
IR-12-002
Download: ML12121A498 (27)


Text

April 30, 2012

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2012002 AND 05000425/2012002

Dear Mr. Tynan:

On March 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vogtle Electric Generating Plant, Units 1 and 2. The enclosed integrated inspection report documents the inspection results which were discussed on April 23, with S. Bargeron and other members of your staff.

The inspection(s) examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

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

One self-revealing finding of very low safety significance (Green) was identified during this inspection.

This finding was determined to involve a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest this non-cited violation (NCV), you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the

Regional Administrato r, Region II; the Director, Office of Enforcemen t, United Stat es Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Vogtle Electric Generating Plant.

If you disagree with the cross-cutting aspect assigned in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the R egional Administra tor, Region II; and the NRC Re sident Inspector at the Vogtle Electric Generating Plant. The information you provide will be c onsidered in accordance with Inspection Manual Chapter 0305.

SNC 2 In accordance with the 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response (if any) will be available electronically for public ins pection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects

Docket Nos.: 05000424, 05000425 License Nos.: NPF-68 and NPF-81

Enclosures:

Inspection Report 05000424/2012002 and 05000425/2012002 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-424, 50-425

License Nos.: NPF-68, NPF-81

Report Nos.: 05000424/2012002 and 05000425/2012002

Licensee: Southern Nuclear Operating Company, Inc. (SNC)

Facility: Vogtle Electric Generati ng Plant, Units 1 and 2

Location: Waynesboro, GA 30830

Dates: January 1, 2012 through March 31, 2012

Inspectors: M. Cain, Senior Resident Inspector T. Chandler, Resident Inspector

Approved by: Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000424/2012002, 05000425/2012002; January 1, 2012 - March 31, 2012; Vogtle

Electric Generating Plant, Units 1 and 2; Integrated Report The report covered a three-month period of inspection by two resident inspectors. One non-cited violation (NCV) with very low safety significance (Green) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red)using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. The cross-cutting aspect was determined using IMC 0310, "Components Within The Cross-Cutting Areas." The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Rev 4 dated December 2006.

Cornerstone: Mitigating Systems

Green: A self-revealing NCV of technical specification (TS) 5.4.1 was identified for failure to properly implement approved maintenance procedures. Specifically, maintenance technicians failed to properly re-land control wires, as required by procedure, on the Unit 2 turbine-driven auxiliary feedwater (TDAFW) pump following preventive maintenance activities. Once the loose wire connections inside junction box 2CWJB2729 were identified, the licensee immediately tightened the connections per procedure. The licensee entered this issue into their corrective action program (CR 404401 and CR 407192).

The finding was considered more than minor because it impacted the Reactor Safety Mitigating System s Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating ev ents to prev ent undesirable consequences and affected the cornerstone attribute of equipment performance.

Specifically, loose wires in the control circuit for the TDAFW pump prevented the trip and throttle valve from operating correctly and caused the TDAFW pump to be declared inoperable for several hours. The inspectors used the Phase 1 Initial Screening and Characterization of Findings (IMC 0609.04 Exhibit 1) to characterize the finding. Since the inspectors answered "No" to all of the Table 4a Mitigating Systems Cornerstone questions, the inspectors concluded that the finding was of very low safety significance (Green). The inspectors determined that the cause of this finding was related to the Work Practices component of the Human Performance cross-cutting area due to failure to follow procedures. H.4(b) (Section 1R22)

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at essentially full rated thermal power (RTP) for the entire inspection period. Unit 2 operated at essentially full RTP for the entire inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

Impending Adverse Weather Condition Review.

On January 4, the inspectors reviewed licensee procedure 11877-1 and 11877-2, "Cold Weather Checklist," to verify the licensee had implemented actions to prepare the plant site for predicted severe weather conditions of sub-freezing temperatures. The inspectors walked down various safety-significant areas of the plant to verify the licensee's ability to respond to t he predicted adverse weather conditions.

b. Findings

No findings were identified.

1R04 Equipment Alignment

a. Inspection Scope

Partial System Walkdown. The inspectors performed partial walkdowns of the following three systems to verify correct system alignment for the existing plant conditions. The inspectors checked for correct valve and electrical power alignments by comparing positions of valves, switches, and breakers in the plant to positions listed in the system operating procedure. Additionally, the inspectors reviewed the condition report database to verify that equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the attachment.

  • Unit 2 train A engineered safety features (ESF) chiller system during t he Unit 2 train B ESF chiller maintenance outage
  • Unit 2 train A, B & D 125V DC 1E electrical distribution system while the train C battery charger 2CD1CA was out of service due to a planned maintenance outage Complete System Walkdown. The inspectors performed a complete walkdown of the Unit 1 train B emergency diesel generator (EDG) and fuel oil transfer system during the train A EDG allowed outage time (AOT). The inspectors performed a detailed check of valve positions, electrical breaker positions, and operating switch positions to evaluate the operability of the redundant trains or components by comparing t he required position in the system operating procedure to the actual position. The inspectors also reviewed control room logs, condition reports, and system health reports to verify that alignment and equipment discrepancies were being identified and appropriately resolved. The documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R05 Fire Protection

a. Inspection Scope

Fire Drill Observation. On February 2, inspectors observed a fire drill from the control room, the primary fire brigade locker, and the fire scene. The fire was simulated to be in the Unit 2 Turbine Plant Component Cooling Water (TPCCW) air compressor #2 located on the A level in the Turbine Building. The inspectors assessed the adequacy of the fire drill and fire brigade respons e using licensee procedures 92000-C, "Fire Protection Program," 92005-C, "Fire Response Procedure," NMP-TR-425, "F ire Drill Program," and 17103A-C, "Annunciator Response Procedures for the Fire Alarm Computer." The inspectors evaluated the fire brigade performance to verify that they responded to the fire in a timely manner, donned proper protective clothing, used self-contained breathing apparatus, and had the equipment necessary to control and extinguish the fire. The inspectors assessed the adequacy of the fire brigade's fire fighting strategy including entry into the fire area, communications, search and rescue, and equipment usage.

Fire Area Tours. The inspectors walked down the following five plant areas to verify the licensee was controlling combustible materials and ignition sources as required by procedures 92015-C, "Use, Control, and Storage of Flammable/Combustible Materials,"

and 92020-C, "Control of Ignition Sources." The inspectors assessed the condition of fire detection, suppression, and protection systems and reviewed the licensee's fire protection limiting condition for operation log and condition report (CR) database to verify that the corrective actions for degraded equipment were identified and appropriately prioritized. The inspectors also reviewed the licensee's fire protection program to verify the requirements of Updated Final Safety Analysis Report Section 9.5.1, "Fire Protection Program," and Appendix 9A, "Fire Hazards Analysis," were met. Documents reviewed are listed in the Attachment.

  • Unit 2 auxiliary component cooling water (ACCW) heat exchanger rooms
  • Unit 1 and Unit 2 fuel handling building level A spent fuel pool heat exchanger and piping penetration rooms

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

Annual Review. The inspectors reviewed the licensee's records of the performance tests conducted on the Unit 2 B train EDG Jacket Water (JW) heat exchanger. The inspectors reviewed EPRI NP-7552, "Heat Exchanger Performance Monitoring Guidelines" to ensure that the licensee's testing procedures were appropriate. Additionally, the inspectors reviewed the licensee's corrective action program (CAP) for heat exchanger performance issues to ensure that discrepancies were being identified and appropriately resolved. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification

a. Inspection Scope

Resident Quarterly Observation of Operator Requalification Activities. The inspectors observed license requalification training conducted in the classroom. The inspectors observed the following lessons taught on March 20:

  • V-RQ-PP-39000-011, introduction to PRA, enhanced (a)4, and risk managed technical specifications
  • V-RQ-PP-29102-003, containment HVAC systems review

Documents reviewed are listed in the Attachment. The inspectors specifically assessed the following areas:

  • Proper implementation of systematic approach to training
  • Clarity and formality of communications
  • Proper use of training aids
  • Proper questing techniques used by the evaluators Resident Quarterly Observation of Operator Performance In-Plant. The inspectors observed operator performance in the main control room on January 25, during startup and testing of the 1A EDG following a 13-day outage. Documents reviewed are listed in the Attachment. The inspectors specifically assessed the following areas:
  • Operator compliance and use of plant procedures, including procedure entry and exit, performing procedure steps in the proper sequence, procedure place keeping, and technical specification entry and exit
  • Control board component manipulations
  • Communications between crew members
  • Use and interpretation of plant instruments, indications and alarms
  • Use of human error prevention techniques, such as pre-job briefs and peer checking
  • Documentation of activities, including initials and sign-offs in procedures, control room logs, and technical specification entry and exit
  • Management and supervision of activities, including risk management and reactivity management

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated the equipment issues described in the CRs listed below to verify the licensee's effectiveness in performing corresponding preventive or corrective maintenance associated with structures, systems, and components (SSCs), to evaluate the effectiveness of the licensee's treatment of equipment performance problems, and to verify the licensee's maintenance practices met the requirements of 10 CFR 50.65 (the Maintenance Rule) and licensee procedure 50028-C, "Engineering Maintenance Rule Implementation." The reviews included adequacy of the licensee's failure characterization, establishment of performance criteria or 50.65(a)(1) performance goals, and adequacy of corrective actions. Other documents reviewed during these inspections included control room logs, system health reports, the maintenance rule database, and maintenance work orders. The inspectors also interviewed system engineers and the maintenance rule coordinator to assess the accuracy of identified performance deficiencies and extent of condition.

  • 2007108257, safety features sequencer system functional failures

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation

a. Inspection Scope

The inspectors reviewed the following five work activities to verify plant risk was properly assessed by the licensee prior to conducting the activities. The inspectors reviewed risk assessments and risk management controls implemented for these activities to verify they were completed in accordance with procedure 00354-C, "Maintenance Scheduling," and 10 CFR 50.65(a)(4). The inspectors also reviewed the CR database to verify that maintenance risk assessment problems were being identified at the appropriate level, entered into the corrective action program, and appropriately resolved.

  • Week of 1/9: operability te sting on the 2B EDG concurrent with the maintenance outage on Unit 2 NSCW pump #5
  • Week of 2/6: failure and subsequent troubleshooting of the Unit 2 turbine-driven auxiliary feedwater pump concurrent with testing of the solid stat e protection system
  • Week of 2/13: corrective maintenance being performed on the Unit 1 loop 1 main feed regulation valve concurrent with high-risk work being performed in the high voltage switchyard
  • Week of 3/12: operability te sting on the 1A EDG concurrent with high-risk work being performed in the low voltage switchyard

b. Findings

No findings were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following six evaluations to verify they met the requirements of procedure NMP-GM-002, "Corrective Action Program," and NMP-GM-002-001, "Corrective Action Program Instructions." The scope of this inspection included a review of the technical adequacy of the evaluations, the adequacy of compensatory measures, and the impact of the equipment condition on continued plant operation.

  • CR 385878 and TE 309973, packing gland hold down stud/nut missing on one side of unit 1 auxiliary spray to pressurizer isolation valv e (1-1208-U4-A11)
  • CR 400312 and TE 316317, bending radius violation on new replacement cable for 1RE0006
  • CR 405658, accumulator sample isolation valves leaking by
  • CR 411376 and TE 321825, TDAFW drain valve ALB16 D05 in solid - valve 2HV5178 is remaining open due to failure of 2LSH5178
  • CR 414015, unit 2 unexpected alarm on B SSMP and 2ND3B trouble
  • CR 404401, unit 2 TDAFW trip and throttle valve failure

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

Temporary Modification. The inspectors reviewed temporary modification SNC357635 and associated 10CFR50.59 screening criteria against the system design bases documentation and procedure NMP-ES-054-001, "Temporary Modification Processing" This modification was installed because one packing gland stud on the pressurizer auxiliary spray line isolation valve 11208U4A 11 is missing and the other gland stud is bent. This temporary modification installs an all threaded rod that takes the place of the missing stud and is designed to ensure the packing ring and follower remain in position.

The inspectors reviewed the implementation, engineering justification, and operator awareness of this temporary modification.

The inspectors reviewed temporary modification SNC345028 and associated 10CFR50.59 screening criteria against the system design bases documentation and procedure NMP-ES-054-001. This temporary modification installed a temporary pressure gauge and M&TE on several drain valves in the chemical and volume control system (CVCS) letdown system to determine the source of high back pressure on CVCS mixed bed demineralizer #2. The inspectors reviewed the implementation, engineering justification, and operator awareness for this temporary modification.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors either observed post-maintenance testing or reviewed the test results for the following six maintenance activities to verify that the testing met the requirements of

procedure 29401-C, "Work Order Functional Tests," for restor ing equipment operability and functional capability. The inspectors also reviewed the te st procedures to verify the acceptance criteria were sufficient to meet the Technical Specifications operability requirements.

  • Maintenance outage work orders: SNC125468 - temperature switch calibration, SNC125854 - clean/inspect/megger motor, lube bearings, SNC128307 - replace Train B ESF Chiller TDC sensor, and SNC125852 - B ESF chiller 002 channel calibration T-4193
  • MWO SNC359763 - correct dual indication on Unit 2 loop 1 atmospheric relief valve 2PV-3000
  • MWO SNC337135 - change upper motor bearing oil on 2B1205P6002
  • Maintenance outage for 1B diesel generator major inspection 2012
  • MWO SNC363250 - 1A EDG 7R & 7L cylinder replacements during the 1A EDG AOT
  • MWO SNC367372 - Unit 2 TDAFW trip and throttle valve will not open

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the following six test procedures and also either observed the testing or reviewed test results to verify that testing was conducted in accordance with the procedures and that the acceptance criteria adequately demonstrated that the equipment was operable. Additionally, the inspectors reviewed the CR database to verify that the licensee had adequately identified and implemented appropriate corrective actions for surveillance test problems.

Surveillance Tests

  • 14421-2 Rev. 40, solid st ate protection system train B operability test
  • 14980B-1 Rev. 23.5, diesel generator 1B operability test
  • 24797-1 Rev. 20.1, steam pressure loop 4 (Protection I) 1P-544 channel operational test and channel calibration
  • 14980B-2 Rev. 22.5, diesel generator 2B operability test In-Service Tests (IST)

b. Findings

Introduction.

A Green self-revealing non-cited violation (NCV) of technical specification 5.4.1 was identified for failure to properly implement approved maintenance procedures.

Specifically, maintenance mechanics failed to properly re-land control wires, as required by procedure, on the Unit 2 turbine-driven auxiliary feedwater (TDAFW) pump following preventive maintenance activities. As a result, the Unit 2 TDAFW pump was rendered inoperable for 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br />.

Description.

On February 9, 2012, during restoration of the Unit 2 TDAFW pump from a surveillance test, the trip and throttle valve (2PV15129) failed to automatically open after being reset using the hand switch in the control room. Subsequent inspection and troubleshooting identified eight loose wire connections inside junction box 2CWJB2729, which is mounted on the side of the TDAFW pump. Two of these eight loose connections were in the circuit that prevented the trip and throttle valve from opening once it was reset. Further investigation revealed that several connections inside junction box 2CWJB2729 had been lifted and re-landed during the 10-year preventive maintenance outage that had been performed in September 2011. A review of the completed preventive maintenance procedures indicate that even though the manipulated wires were re-landed to their proper terminal locations, they were not tightened as required by maintenance procedure 25717-C, "Torquing Electrical Type Connections." This fact was not identified at that time. However, the TDAFW pump operated normally and successfully passed all surveillance testing for approximately five months. The licensee has theorized that friction between the wire lugs and the terminal board was adequate to allow proper operation of the TDAFW pump during that time period. This theory is supported by the fact that when the wire bundle in the terminal box was moved during troubleshooting on February 9, 2012, the trip and throttle valve began to operate properly. Once the loose wire connections inside junction box 2CWJB2729 were identified, the licensee immediately tightened the connections per procedure. To check extent of condition, the licensee also verified that all connections in the corresponding junction box on the Unit 1 TDAFW pump were properly tightened. While the event investigation was taking place, the licensee issued a standing order to instruct the operators to locally declutch and open the trip and throttle valve if operation of the TDAFW pump was required.

The safety function of the auxiliary feedwater (AFW) system is to supply water to the steam generators to remove decay heat and other residual heat by delivering at least the minimum required flow rate to the steam generators at pressures corresponding to the lowest steam generator safety valve set point plus 3%. In addition, the AFW system must supply enough makeup water to replace steam generator secondary inventory lost as the unit cools to Mode 4 conditions. The licensee concluded that because the trip and throttle valve is normally full open, and the loose wires only prevented the trip and throttle valve from being re-opened following a turbine trip, no loss of safety function

occurred. In addition, the operators always had the ability to open the trip and throttle valve locally.

Analysis.

The failure to properly re-land wires in junction box 2CWJB2729 following preventive maintenance activities on the TDAFW pump is a performance deficiency because the licensee failed to meet a standard (procedure 25717-C, "Torquing Electrical Type Connections") and the cause was reasonably within the licensee's ability to foresee and correct. The finding was considered more than minor because it impacted the Reactor Safety Mitigating Sy stems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences and affected the cornerstone attribute of equipment performance. Specifically, loose wires in the control circuit for the TDAFW pump prevented the trip and throttle valve from operating correctly and caused the TDAFW pump to be declared inoperable for 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> while troubleshooting was being performed.

The inspectors evaluated the finding using IMC 0609, Appendix A, "Determining the Significance of Reactor Inspection Findings for At-Power Situations" and used 0609.04, "Phase 1 Initial Screening and Characterization of Findings," to characterize the finding. Using Exhibit 1 Table 2, the inspectors determined that the finding affected the Mitigation Systems Cornerstone. Specifically, the finding degraded the short term heat removal systems. Since the inspectors answered "No" to all of the Exhibit 1, Table 4a Mitigating Systems Cornerstone screening questions, the inspectors concluded that the finding was of very low safety significance (Green).

The primary cause of the performance deficiency, as determined by the inspectors, was less than adequate procedure use and self-checking. The inspectors determined that the cause of this finding was related to the Work Practices component of the Human Performance cross-cutting area due to failure to follow procedures. H.4(b) Specifically, the maintenance technician failed to tighten the lugs after re-landing the wires as required by procedure.

Enforcement.

The inspectors determined that the finding represents a violation of regulatory requirements because it involved improper implementation of procedures associated with safety-related plant equipment. TS 5.4.1 requires that written procedures, specified in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, shall be established, implemented, and maintained. Regulatory Guide 1.33 states that maintenance activities that can affect the performance of safety-related equipment should be performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to the above, maintenance personnel failed to follow the approved maintenance procedures, and as a result, failed to properly re-land wires in the control circuitry of the Unit 2 TDAFW pump following preventive maintenance activities in September 2011. As a result of the violation, the Unit 2 TDAFW pump was rendered inoperable for 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> on February 9, 2012. Once the loose wire connections were identified, the licensee immediately tightened the connections per procedure. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program (ref. CR 404401 and CR 407192), this violation is being treated as an NCV, consistent with the Enforcement Policy. This finding will be tracked as NCV 05000425/2012002-01, Work Prac tice Error Renders Unit 2 TDAFW Pump Inoperable.

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors reviewed the facility activation exercise guide and observed the following emergency response activity to verify the licensee was properly classifying emergency events, making the required notifications, and making appropriate protective action recommendations in accordance with procedures 91001-C, "Emergency Classifications,"

and 91305-C, "Protective Action Guidelines."

On February 15, 2012, the licensee conducted an emergency pr eparedness drill which involved actuation of the TSC, the OSC, and the EOF. The drill scenario began with pressurizer pressure instrument 1PI-458 failing high with an anticipated transient without scram (ATWS). After operators successfully manually tripped the reactor, a large break loss of coolant accident (LBLOCA) and subsequent failure of the 1B safety injection pump discharge piping failure occurred.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors sampled licensee submittals for the listed PIs during the period from January 1, 2011 through December 31, 2011, for Unit 1 and Unit 2. The inspectors verified the licensee's basis in reporting each data element using the PI definitions and guidance contained in procedure 00163-C, "NRC Performance Indicator and Monthly Operating Report Preparation and Submittal," and Nuclear Energy Institute document NEI 99-02, "Regulatory Assessment Indicator Guideline."

The inspectors reviewed Unit 1 and Unit 2 operator log entries, the Vogtle Electric Generating Plant Unit 1 and Unit 2 NRC Mitigating System Performance Index Basis Document, the monthly operating reports and monthly PI summary reports to verify that the licensee had accurately submitted the PI data.

Mitigating Systems Cornerstone

  • Unplanned Scrams per 7,000 Critical Hours
  • Unplanned Scrams with Complications

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Daily Condition Report Review.

As required by inspection procedure 71152, "Identification and Resolution of Problems," and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's corrective action program. This review was accomplished by either attending daily screening meetings that briefly discussed major CRs, or accessing the licensee's computerized corrective action database and reviewing each CR.

.2 Focused Review

a. Inspection Scope

The inspectors performed a detailed review of the following CRs which address various issues identified during the extended maintenance outage (AOT) of the 1A EDG. The goal of the review was to verify that the full extent of the issues were identified, appropriate evaluations were performed, and appropriate corrective actions were specified and prioritized. The inspectors evaluated the CRs against the licensee's corrective action program as delineated in procedure NMP-GM-002, "Corrective Action Program," and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.

  • 395186 - energized heater at 1A diesel generator
  • 395873 - debris discovered in area of #7 cylinder
  • 396442 - 1A EDG came out of maintenance mode
  • 396593 - 1A diesel generator TD4 failure
  • 396599 - failure of 3-way valve discovered during 1A EDG functional test
  • 396744 - no clear direction for setting of power driven potentiometer limit switches
  • 396812 - meggering procedure 25736-C needs enhancing
  • 396866 - issues identified with procedure GEN 95 Chapter 46
  • 397023 - 1A EDG #7 rod bearing scoring
  • 397070 - 1A EDG paint chips found in oil system
  • 400096 - excessive leak by into 1A EDG jacket water stand pipe

The inspectors performed a detailed review of the following CR which addressed an increasing trend in the Unit 2 containment building radioactivity. The goal of the review was to verify that the full extent of the issue was identified, an appropriate evaluation was performed, and appropriate corrective actions were specified and prioritized. The inspectors evaluated the CR against the licensees corrective action program as delineated in procedure NMP-GM-002 and 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action." Documents reviewed are listed in the Attachment.

CR 393818 Unit 2 containment radioactivity indicates an increasing trend

b. Findings and Observations

No findings were identified.

4OA3 Event Follow-up

.1 (Closed) Licensee Event Report 05000424/2010-001-01:

Breaker Failure Results in 1B Train Containment Cooling System Being Declared Inoperable On October 24, 2010, the licensee attempted to manually start Containment Cooling Unit

  1. 8 in low speed during the performance of a Containment Cooling System Operability and Response Time Test and the cooling unit did not start. Work Order (WO)1102198301 investigation identified that the circuit breaker had two breaker cover mounting holes that were cracked. This allowed the top right hand side screw to come in contact with the breaker's closing mechanism, thus preventing the breaker from closing.

The inspectors reviewed the LER, the associated condition report and apparent cause determination, and subsequent action items. The enforcement aspects associated with this event were documented in NRC integrated inspection report 05000424,425/2010005 Section 4OA2. No other findings were identified. This LER is closed.

.2 (Closed) Licensee Event Report 05000425/2011-001:

Inoperable Core Exit Thermocouple Indicator on the B Train Remote Shutdown Panel October 27, 2011, the licensee discovered that mode changes had been made contrary to TS LCO 3.0.4. TS 3.3.4, Remote Shutdown System, limiting condition for operation (LCO) requires two channels of Core Exit Thermocouples (CETC) to be operable.

During startup from the refueling outage 2R15, one of the CETC channels credited for satisfying this requirement was inoperable but was not recognized as being inoperable until the unit was in mode 1. Since mode changes were made with only one of the two required CETC channels operable, the unit was operated in a condition contrary to TS LCO 3.0.4. The inspectors reviewed the LER, the associated condition report and apparent cause determination, and subsequent action items. The enforcement aspects associated with this event were documented in NRC integrated inspection report 05000424,425/2011005 Section 4OA7. No other findings were identified. This LER is closed.

.3 (Closed) Licensee Event Report 05000424/2011-003:

Control Room Air Damper Found Closed Results in Technical Specification Non-Compliance On September 22, 2011 at approximately 0155 hours0.00179 days <br />0.0431 hours <br />2.562831e-4 weeks <br />5.89775e-5 months <br />, the licensee discovered that the Control Room Normal Heating, Ventilation, and Air Conditioning (HVAC) damper AHV-12153 was closed. This stops all air flow through the control room radioactive gas monitors, rendering them inoperable. A subsequent review of the plant computer system showed the valve was closed on September 19, 2011 at 2029 hours0.0235 days <br />0.564 hours <br />0.00335 weeks <br />7.720345e-4 months <br />. Because the TS require the control room emergency filtration system (CREFS) to be placed in the emergency mode if the control room air intake radioactive gas monitors are inoperable for more than one hour, and this was not done, the units operated in a condition prohibited by the TS. The inspectors reviewed the LER, the associated condition report and apparent cause determination, and subsequent action items. The enforcement aspects associated with this event were documented in NRC integrated inspection report 05000424,425/2011004 Section 4OA7. No other findings were identified. This LER is closed.

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities.

b. Findings and Observations

No findings were identified.

.2 Institute of Nuclear Power Operations (INPO) Report Review

During this inspection period the final INPO Evaluation Report dated February 2012 was reviewed. The report contained no safety issues which were not already known by the NRC.

4OA6 Meetings, Including Exit

.1 Exit Meeting

On April 23, the resident inspectors presented the inspection results to Mr. S. Bargeron and other members of your staff, who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

S. Bargeron, Plant Manager
R. Brown, Training Manager
R. Collins, Chemistry Manager
D. Puckett, Performance Analysis Supervisor
R. Dedrickson, Plant Manager
K. Dyar, Security Manager
I. Kochery, Health Physics Manager
T. Tynan, Site Vice-President
D. McCary, Operations Manager
S. Swanson, Site Support Manager
S. Waldrup, Site Engineering Director

NRC personnel

F. Ehrhardt, Chief, Region II Reactor Projects Branch 2

LIST OF ITEMS

OPENED AND CLOSED

OPEN AND CLOSED

05000425/2012002-01 NCV Work Practice Error Renders Unit 2 TDAFW Pump Inoperable (Section 1R22)

CLOSED

05000424/2010-001-01 LER Breaker Failure Results in 1B Train Containment Cooling System Being

Declared Inoperable (Section 4OA3.1)

05000425/2011-001 LER Inoperable Core Exit Thermocouple Indicator on the B Train Remote Shutdown

Panel (Section 4OA3.2)

05000424/2011-003 LER Control Room Air Damper Found Closed Results in Technical Specification Non-

Compliance (Section 4OA3.3)

LIST OF DOCUMENTS REVIEWED