IR 05000266/2011004

IR 05000266-11-004, 05000301-11-004, on 7/01/2011 - 9/30/2011; Point Beach Nuclear Plant, Units 1 and 2; Follow-Up of Events; Component Design Bases Inspection

ML11306A264
Person / Time
Site:	Point Beach
Issue date:	11/02/2011
From:	Michael Kunowski NRC/RGN-III/DRP/B5
To:	Meyer L Point Beach
References
IR-11-004
Download: ML11306A264 (61)

Text

November 2, 2011

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2, NRC INTEGRATED INSPECTION REPORT 05000266/2011004; 05000301/2011004

Dear Mr. Meyer:

On September 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Point Beach Nuclear Plant, Units 1 and 2. The enclosed report documents the results of this inspection, which were discussed on October 4, 2011, with you and members of your staff. The inspection 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. Based on the results of this inspection, two findings of very low safety significance were identified by the NRC. The findings involved violations of NRC requirements. However, because of their very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) in accordance with Section 2.3.2 of the NRC Enforcement Policy. If you contest the subject or severity of any 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 a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Point Beach Nuclear Plant. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Point Beach Nuclear Plant. In accordance with 10 CFR 2.390 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 NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's document system (ADAMS).

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

Sincerely,

/RA/ Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27

Enclosure:

Inspection Report 05000266/2011004; 05000301/2011004 w/Attachment: Supplemental Information

REGION III Docket Nos: 05000266; 05000301 License Nos: DPR-24; DPR-27 Report No: 05000266/2011004; 05000301/2011004 Licensee: NextEra Energy Point Beach, LLC Facility: Point Beach Nuclear Plant, Units 1 and 2 Location: Two Rivers, WI Dates: July 1, 2011, through September 30, 2011 Inspectors: S. Burton, Senior Resident Inspector M. Thorpe-Kavanaugh, Resident Inspector K. Barclay, Kewaunee Resident Inspector E. Sanchez-Santiago, Reactor Engineer M. Phalen, Senior Health Physicist B. Palagi, Senior Operations Engineer D. Oliver, Operations Engineer J. Beavers, Emergency Preparedness Inspector D. Reeser, Operations Engineer B. Jose, Senior Reactor Engineer Approved by: Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000266/2011004, 05000301/2011004; 7/01/2011 - 9/30/2011; Point Beach Nuclear Plant, Units 1 and 2; Follow-Up of Events; Component Design Bases Inspection. This report covers a three-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. Two Green findings were identified by the inspectors. The findings were considered non-cited violations (NCVs) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

A. NRC-Identified

and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding of very low safety significance and an associated NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the licensee's failure to perform an operability evaluation as required by procedure when degraded/non-conforming conditions were identified during a surveillance of the rod drive control system. Specifically, on December 10, 2010, the licensee documented rod trouble alarms in condition report 01401564, but did not identify the degraded/non-conforming condition or evaluate the condition relative to support functions for technical specifications (TSs) 3.1.4 and 3.1.6. The licensee entered this issue into its corrective action program for evaluation and development of corrective actions. The finding was determined to be more than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," dated December 24, 2009, because it was associated with the Mitigating Systems Cornerstone attribute of equipment performance and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to identify the degraded/non-conforming condition and assess the impact on operations and TS requirements resulted in latent conditions that had the potential to be of greater safety significance, and in this case resulted in the failure to evaluate the degraded/non-conforming condition relative to TSs 3.1.4 and 3.1.6. This finding has a cross-cutting aspect in the area of human performance, decision-making, because the licensee did not use conservative assumptions during related decision-making that adopted a requirement to demonstrate that the proposed action was safe in order to proceed (H.1(b)). (Section 4OA3.2)

Green.

The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," involving the licensee's failure to ensure tornado missile protection for two of the emergency diesel generator (EDG) exhaust stacks, which were considered Class I components. The licensee entered this issue into the Corrective Action Program as AR 01678709.

The licensee's failure to ensure tornado missile protection for EDGs G01 and G02 exhaust stacks was a performance deficiency. The performance deficiency was determined to be more than minor because there was reasonable doubt the EDG exhaust stacks would remain functional to support EDG operation in the event tornado-induced missiles damaged the exhaust stacks The finding screened as very low safety significance because the finding was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. This finding was determined not to have a cross-cutting aspect. (Section 1R21.1.b.(1))

B. Licensee-Identified Violations

A violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and corrective actions are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at 100 percent power throughout the entire inspection period with the exception of an unplanned power reduction on July 20, 2011, to 94 percent power, for auxiliary feedwater pump testing.

Unit 2 began the period continuing to ascend to the new extended power uprate power level and then operated at the new 100 percent reactor power level for the remainder of the inspection period with small power reductions during routine surveillance testing.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Condition - High Wind Conditions

a. Inspection Scope

Since high winds were forecast in the vicinity of the facility for September 29 and 30, 2011, the inspectors reviewed the licensee's overall preparations/protection for the expected weather conditions. The inspectors walked down the protected area and structures, in addition to the licensee's emergency alternating current (AC) power systems, because their safety-related functions could be affected or required as a result of high winds or the loss of offsite power. The inspectors evaluated the licensee staff's preparations against the site's procedures and determined that the staff's actions were adequate. During the inspection, the inspectors focused on plant-specific design features and the licensee's procedures used to respond to specified adverse weather conditions. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. Additionally, the inspectors reviewed the Final Safety Analysis Report (FSAR)and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. The inspectors also reviewed a sample of corrective action program (CAP) items to verify that the licensee identified adverse weather issues at an appropriate threshold and dispositioned them through the CAP in accordance with station corrective action procedures. Documents reviewed are listed in the Attachment to this report. This inspection constituted one readiness for impending adverse weather condition sample as defined in Inspection Procedure (IP) 71111.01-05.

b. Findings

No findings were identified.

4 Enclosure

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

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

• G04 emergency diesel generator (EDG);

• service water (SW) ring header;

• direct current (DC) bus 105 in-service when removing DC bus 305 for testing; and

• SW systems including the supply to the EDG with the gas turbine generator out-of-service. The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the systems and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, FSAR, Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report. These activities constituted four partial system walkdown samples as defined in IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• fire zone 552, SW pump room;

• fire zone 553, circulating water pump room;

• fire zone 554, circulating water pump room corridor; and

• fire zone 555, circulating water pump house valve gallery. The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded, or inoperable fire protection equipment, systems, or features in accordance with the licensee's fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event.

Using the documents listed in the Attachment to this report, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and that fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's CAP. Documents reviewed are listed in the Attachment to this report. These activities constituted four quarterly fire protection inspection samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

On August 4, 2011, the inspectors observed a fire brigade activation for training. Based on this observation, the inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies, openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were:

• proper wearing of turnout gear and self-contained breathing apparatus;

• proper use and layout of fire hoses;

• employment of appropriate fire-fighting techniques;

• sufficient firefighting equipment brought to the scene;

• effectiveness of fire brigade leader communications, command, and control;

• search for victims and propagation of the fire into other plant areas;

• smoke removal operations;

• utilization of pre-planned strategies;

• adherence to the pre-planned drill scenario; and

• drill objectives. Documents reviewed are listed in the Attachment to this report.

6 Enclosure These activities constituted one annual fire protection inspection sample as defined in IP 71111.05-05.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review

a. Inspection Scope

On July 6, 2011, the inspectors observed a crew of licensed operators in the plant's simulator during licensed operator requalification training (LORT) to verify that operator

performance was adequate, evaluators were identifying and documenting crew performance problems, and that training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• licensed operator performance;

• crew's clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of abnormal and emergency procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications. The crew's performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report. This inspection constituted one quarterly licensed operator requalification program sample as defined in IP 71111.11.

b. Findings

No findings were identified.

.2 Annual Operating Test Results

a. Inspection Scope

The inspectors reviewed the overall pass/fail results of the Annual Operating Test, administered by the licensee from July 25 through August 31, 2011

, required by 10 CFR 55.59(a). The results were compared to the thresholds established in Inspection Manual Chapter (IMC) 0609, Appendix I, "Licensed Operator Requalification Significance Determination Process (SDP)," to assess the overall adequacy of the licensee's LORT program to meet the requirements of 10 CFR 55.59. This inspection constituted one biennial licensed operator requalification inspection sample as defined in IP 71111.11B.

7 Enclosure

b. Findings

No findings were identified.

.3 Biennial Review

a. Inspection Scope

The following inspection activities were conducted during the weeks of August 1, 2011, and August 8, 2011, to assess: 1) the effectiveness and adequacy of the facility licensee's implementation and maintenance of its systems approach to training (SAT)based LORT program, put into effect to satisfy the requirements of 10 CFR 55.59; 2) conformance with the requirements of 10 CFR 55.46 for use of a plant referenced simulator to conduct operator licensing examinations and for satisfying experience requirements; and 3) conformance with the operator license conditions specified in 10 CFR 55.53. Documents reviewed are listed in the Attachment to this report.

• Facility Operating History and Licensee Training Feedback System (10 CFR 55.59(c); SAT Element 5 as Defined in 10 CFR 55.4): The inspectors evaluated the licensee's ability to assess the effectiveness of its LORT program and the ability to implement appropriate corrective actions to maintain its LORT program up-to-date. The inspectors reviewed documents related to the plant's operating history and associated responses (e.g., plant issue matrix (PIM) and performance review (PPR) reports; recent examination and inspection reports; and licensee event reports (LERs)). The inspectors reviewed the use of feedback from operators, instructors, and supervisors, as well as the use of feedback from plant events and industry experience information. The inspectors reviewed the licensee's quality assurance oversight activities, including licensee training department self-assessment reports.

• Licensee Requalification Examinations (10 CFR 55.59(c); SAT Element 4 as Defined in 10 CFR 55.4): The inspectors reviewed the licensee's program for development and administration of the LORT biennial written examination and annual operating tests to assess the licensee's ability to develop and administer examinations that were acceptable for meeting the requirements of

10 CFR 55.59(a).

- The inspectors reviewed the methodology used to construct the examination, including content, level of difficulty, and general quality of the examination and test materials. The inspectors also assessed the level of examination material duplication from week-to-week for both, the operating tests conducted during the current year, as well as the written examinations administered in 2010. The inspectors reviewed a sample of the written examinations and associated answer keys to check for consistency and accuracy;

- The inspectors observed the administration of the annual operating test to assess the licensee's effectiveness in conducting the examinations, including the conduct of pre-examination briefings, evaluations of individual operator and crew performance, and post-examination analysis. The inspectors evaluated the performance of one crew in parallel with the facility evaluators during two dynamic simulator scenarios, and evaluated various licensed crew 8 Enclosure members concurrently with facility evaluators during the administration of several job performance measurements; and

- The inspectors assessed the adequacy and effectiveness of the remedial training conducted since the last requalification examinations and the training planned for the current examination cycle to ensure that they addressed weaknesses in licensed operator or crew performance identified during training and plant operations. The inspectors reviewed remedial training procedures and individual remedial training plans;

• Conformance with Examination Security Requirements (10 CFR 55.49)

The inspectors observed and reviewed the licensee's overall licensed operator requalification examination security pr ogram related to examination physical security (e.g., access restrictions and simulator considerations) and integrity (e.g., predictability and bias) to verify compliance with 10 CFR 55.49, "Integrity of Examinations and Tests." The inspectors also reviewed the facility licensee's examination security procedure and the implementation of security and integrity measures (e.g., security agreements, sampling criteria, bank use, and test item repetition) throughout the examination process.

• Conformance with Simulator Requirements (10 CFR 55.46): The inspectors assessed the adequacy of the licensee's simulation facility (simulator) for use in operator licensing examinations and for satisfying experience requirements.

The inspectors reviewed a sample of simulator performance test records (e.g., transient tests, malfunction tests, scenario-based tests, post-event tests, steady state tests, and core performance tests), simulator discrepancies, and the process for ensuring continued assurance of simulator fidelity in accordance with 10 CFR 55.46. The inspectors reviewed and evaluated the discrepancy corrective action process to ensure that simulator fidelity was being maintained.

Open simulator discrepancies were reviewed for importance relative to the impact on 10 CFR 55.45 and 55.59 operator actions as well as on nuclear and thermal hydraulic operating characteristics.

• Conformance with Operator License Conditions (10 CFR 55.53)

The inspectors reviewed the facility licensee's program for maintaining active operator licenses and to assess compliance with 10 CFR 55.53(e) and (f). The inspectors reviewed the procedural guidance and the process for tracking on-shift hours for licensed operators, and which control room positions were granted watch-standing credit for maintaining active operator licenses. Additionally, medical records for 12 licensed operators were reviewed for compliance with 10 CFR 55.53(i). This inspection constituted one biennial licensed operator requalification inspection sample as defined in IP 71111.11B.

b. Findings

(1) Unresolved Item Potential Failure to Correctly Implement a Systems Approach to Training (SAT) for the Licensed Operator Requalification Program.

Introduction:

The inspectors identified an Unresolved Item (URI) of compliance with 10 CFR 55.59(c), "Requalification Program Requirements." The inspectors were unable 9 Enclosure using available documentation to verify the implementation of the analysis and training elements of the Commission-approved SAT-based Licensed Operator Continued Training (LOCT) program.

Description:

The inspectors reviewed the licensee's procedures, training materials, and operator evaluation documentation pertaining to the LORT program to determine if the licensee was meeting the requirements of 10 CFR 55.59, "Requalification." The Point Beach Nuclear Plant Licensed Operator Continued Training Program Description (TPD) required the licensee to develop, maintain, and implement the

LOCT program using a SAT process as described in the TPD, to meet the requirements of 10 CFR 55.59(c). The TPD requires that the LOCT program content be composed of fixed and flexible components. Fixed components are defined by the TPD as tasks and/or topics that primarily address analyzed training needs and have been determined using the SAT process. The SAT process also determines on what frequency fixed tasks/topics should be taught, and the delivery method of the training.

Flexible components are those that are responsive to other identified training needs and are used to correct actual or potential weaknesses in the performance of licensed personnel. Plant design changes are one example of a flexible topic in the facility's TPD.

During the review of the licensee's Biennial and Long Range Training Plans, the inspectors identified that numerous fixed training tasks had been "exempted" to allow for scheduling constraints due to the licensee's extended power uprate project outages. The only documentation available suggests the tasks were exempted primarily due to time constraints with little regard to the effect of the exemptions on the remaining adequacy of the SAT-based program.

Site management contended that it was never their intent to remove the majority the "exempted" training tasks from the biannual training program and, in fact, had planned to return most if not all the material to the program. In support of this contention, the site developed a "white paper" explaining their decision making and included a list of 35 exempted topics/tasks that had already been trained on. Additionally, it was stated that all of the other exempted topics/tasks had now been rescheduled for completion.

This issue is a URI pending further NRC review of the licensee' s contention and to complete an adequate assessment of the statements in the "white paper" related to the exempted training, URI 05000266/2011004-01; 05000301/2011004-01, Potential Failure to Correctly Implement a Systems Approach to Training for the Licensed Operator Requalification Program.

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

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

• EDG G03 air start system;

• battery D305 testing; and

• SW system. The inspectors reviewed events, such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems, and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• implementing appropriate work practices;

• identifying and addressing common cause failures;

• scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

• characterizing system reliability issues for performance;

• charging unavailability for performance;

• trending key parameters for condition monitoring;

• ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

• verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1). The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report. This inspection constituted three quarterly maintenance effectiveness samples as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• maintenance risk with new probabilistic risk assessment (PRA) diesel compressor;

• risk management with the spent fuel pool (SFP) heat exchanger removed from service and the daily status reflecting the heat exchanger was in service and SW pump to be removed from service;

• risk management of uncompleted summer readiness items;

• risk management during unplanned gas turbine outage; and

• risk management following gas turbine (G05) work available for PRA risk but not for Appendix R. These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Documents reviewed are listed in the Attachment to this report. These maintenance risk assessments and emergent work control activities constituted five samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functional Assessments

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• operability evaluation of EDG G01 with temperature controller found out-of-specification;

• operability evaluation of check valve DA-318 failed to seat during surveillance IT-100;

• operability evaluation of battery D305;

• operability evaluation for SW pump increasing vibrations;

• LT-3317A found out-of-tolerance during performance of instrument control testing;

• operability evaluation for issues with the air amplifier (air supply tank for valve operation) for 1P-53, the Unit 1 motor-driven auxiliary feedwater pump;

• operability of 1P-29, the Unit 1 turbine-driven auxiliary feedwater (TDAFW) pump for bearing clearance issues;

• containment spray pump seal cooler pressure rating inconsistent with design; and

• operability of the main feedwater regulating valves (MFRVs) after the extended power uprate partial modification installation. The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in 12 Enclosure risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and FSAR to the licensee's evaluations to determine

whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report. This operability inspection constituted nine samples as defined in IP 71111.15-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

.1 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance (PM) activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

• post-maintenance testing (PMT) of TDAFW pump 2P-29 following pump overhaul (Unit 2);

• PMT of loss of FW turbine trip alarm (Unit 2); and

• PMT of MFRV circuitry work (Unit 2). These activities were selected based upon the SSCs' ability to impact risk. The inspectors evaluated these activities for the following (as applicable): the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test

documentation was properly evaluated. The inspectors evaluated the activities against TSs, the FSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to verify that t he test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with PM tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report. This inspection constituted three post-maintenance testing samples as defined in IP 71111.19-05.

13 Enclosure

b. Findings

No findings were identified.

1R21 Component Design Bases Inspection

.1 (Closed) Safety-Related Equipment Not Protected from Tornado Missiles;

URI 05000266/2006006-08; 05000301/2006006-08

a. Inspection Scope

The inspectors followed up on a URI concerning lack of tornado missile protection for the exhaust stacks associated with emergency diesel generators G01 and G02. During a Component Design Bases Inspection documented in Inspection Report 05000266/2006006, the inspectors discovered the exhaust stacks had not been analyzed for the effects of tornado missiles. The inspectors raised a concern that tornado-induced missiles could damage the exhaust stacks to a sufficient extent that the exhaust flow would be restricted and the EDGs would not be capable of performing their required safety function. At the time of the inspection, the issue was left unresolved pending resolution of differences in interpretation between the NRC and the licensee of the original licensing basis concerning tornado missile protection for Class I components. Subsequently, Region III inspectors, after consulting NRR and reviewing several regulatory as well as licensee-specific documents, developed a concurrence Task Interface Agreement (TIA) 2011-011 (ML11228A257). In the TIA, the staff concluded the licensee committed to have all components protected from the forces caused by tornadoes, which included tornado missiles.

b. Findings

(1) Failure to Ensure Tornado Missile Protection for EDGs G01 and G02 Exhaust Stacks

Introduction:

The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control,"

involving the licensee's failure to ensure tornado missile protection for two of the emergency diesel generator (EDG) exhaust stacks, which were considered Class I components. Specifically, the exhaust stacks of EDGs G01 and G02 were routed vertically from the EDG rooms, on the outside of the turbine building wall, with no tornado missile protection.

Description:

During the 2006 Component Design Bases Inspection (CDBI), the inspectors reviewed the design and configuration of the G01 and G02 EDGs.

These EDGs were considered one train for both Unit 1 and Unit 2 while the other EDGs (G03 and G04) were considered another train. The exhaust stacks for EDGs G01 and G02 were routed vertically from the EDG rooms, on the outside of the turbine building wall. The stacks are approximately 100 feet high and 26 inches in diameter. The inspectors discovered the exhaust stacks had not been analyzed for the effects of tornado missiles. The inspectors raised a concern that tornado-induced missiles could damage the exhaust stacks to a sufficient ex tent that the exhaust flow would be restricted and the EDGs would not be capable of performing their required safety function.

14 Enclosure At the time of the CDBI, the licensee believed that there were "-no explicit design criteria in the licensing basis for components to withstand tornado-induced missiles."

The inspectors disagreed with the licensee and documented the issue as a URI for further investigation.

Subsequently, Region III inspectors, after consulting NRR and reviewing several regulatory as well as licensee-specific documents, developed a concurrence Task Interface Agreement (TIA) 2011-011 (ML11228A257). In the TIA, the staff concluded the performance standards for electrical systems with respect to licensing bases were the same in both the Final Facility Description and Safety Analysis Report (FFDSAR, predecessor form the late 1960s-1970 to the Final Safety Analysis Report) and the Current Licensing Bases (CLB). Both require that components "-which are essential to the prevention and mitigation of the consequences of nuclear accidents, which could prevent undue risk to the health and safety of the public shall be designed, fabricated, and erected to performance standards that enable such systems and components to withstand, without undue risk to the health and safety of the public, the forces that might reasonably be imposed by the occurrence of an extraordinary natural phenomena such as earthquake, tornado-" The inspectors concluded the licensee committed to have all components protected from the forces caused by tornadoes, which includes tornado missiles. The statement in the operating license Safety Evaluation Report (SER), which only identified structures as being designed to withstand the consequences of tornado missiles, does not replace or supersede the commitment contained in the FFDSAR or the CLB. The licensee failed to fully evaluate and identify components required to withstand the forces exerted by natural phenomena located outside of structures that were designed to withstand tornado missiles.

This position is supported by the FFDSAR "Overall Plant Requirements (GDC 1 - GDC 5) which states that "-Similar measures are taken in the plant design to protect against high winds, flooding, and other natural phenomena-" where natural phenomena include tornadoes and tornado-generated missiles. With respect to the use of the Individual Pl ant Examination of External Events (IPEEE), the inspectors had several discussions with the NRR staff. In summary, the conclusions documented in the IPEEE regarding risk of a design or equipment performance attribute do not replace the need to meet a regulatory requirement or standard.

Analysis:

The inspectors determined the failure to ensure tornado missile protection for the EDGs G01 and G02 exhaust stacks was a performance deficiency.

The performance deficiency was determined to be more than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," dated December 24, 2009, because it was associated with the Mitigating Systems Cornerstone attribute of Equipment Performance, and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, there was reasonable doubt the EDG exhaust stacks would remain functional to support EDG operation in the event tornado-induced missiles damaged the exhaust stacks.

The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase I -

Initial Screening and Characterization of Findings," Table 4a, for the Mitigating System Cornerstone, dated January 18, 2008. The finding screened as very low safety 15 Enclosure significance (Green) because the finding was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. Specifically, the addition of EDGs G03 and G04 (1995-96) provided additional electrical redundancy such that the loss of the EDGs G01 and G02 would be of very low safety significance. The inspectors determined that the finding did not have a cross-cutting aspect as it was not reflective of licensee's current performance.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis, as defined in Part 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies, are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, since the early 1970s when both Units commended operation, the licensee's design control measures failed to meet the Class I design basis requirements for the EDGs G01 and G02 exhaust stacks. Specifically, the licensee failed to incorporate tornado missile protection for their EDGs G01 and G02 exhaust stacks, which are Class I components. Because this violation was of very low safety significance and because the issue was entered into the licensee's corrective action program, as AR 01678709, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000266/2011004-03; NCV 05000301/2011004-03; Failure to Ensure Tornado Missile Protection for EDGs G01 and G02 Exhaust Stacks). Documents reviewed are listed in the Attachment to this report.

This URI is closed.

1R22 Surveillance Testing

.1 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural

and TS requirements:

• seat leakage test of EDG air compressor discharge check valve;

• battery D305 terminal checks;

• EDG G-03 monthly surveillance;

• Unit 2 train B high head safety injection (SI) pumps and valves (inservice testing (IST));

• Unit 1 quarterly containment isolation valve (CIV) surveillance; and

• reactor coolant system (RCS) leakage calculation for back-leakage from Unit 1 chemical and volume control system valve, 1CV-355. The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

• did preconditioning occur;

• were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;

• were acceptance criteria clearly stated, demonstrated operational readiness, and consistent with the system design basis;

• plant equipment calibration was correct, accurate, and properly documented;

• as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the FSAR, procedures, and applicable commitments;

• measuring and test equipment calibration was current;

• test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;

• test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;

• test data and results were accurate, complete, within limits, and valid;

• test equipment was removed after testing;

• where applicable for IST activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers (ASME) Code, and reference values were consistent with the system design basis;

• where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;

• where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;

• where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;

• prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

• equipment was returned to a position or status required to support the performance of its safety functions; and

• all problems identified during the testing were appropriately documented and dispositioned in the CAP.

Documents reviewed are listed in the Attachment to this report. This inspection constituted three routine surveillance testing samples, one inservice testing sample, one containment isolation valve testing sample, and one reactor coolant system leak detection inspection sample as defined in IP 71111.22, Sections -02 and

-05.

b. Findings

No findings were identified.

17 Enclosure Cornerstone: Emergency Preparedness

1EP2 Alert and Notification System Evaluation

.1 Alert and Notification System Evaluation

a. Inspection Scope

The inspectors held discussions with Emergency Preparedness (EP) staff regarding the operation, maintenance, and periodic testing of the Alert and Notification System (ANS) in the Point Beach plume pathway Emergency Planning Zone. The inspectors reviewed monthly trend reports and siren test failure records from November 2009 through August 2011. Information gathered during document reviews and interviews was used to determine whether the ANS equipment was maintained and tested in accordance with Emergency Plan commitments and procedures. Documents reviewed are listed in the Attachment to this report. This alert and notification system inspection constituted one sample as defined in IP 71114.02-05.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Augmentation Testing

.1 Emergency Response Organization Augmentation Testing

a. Inspection Scope

The inspectors reviewed and discussed with plant EP staff the emergency plan commitments and procedures that addressed the primary and alternate methods of initiating an Emergency Response Organization (ERO) activation to augment the on shift ERO as well as the provisions for maintaining the plant's ERO emergency telephone book. The inspectors also reviewed reports and a sample of corrective action program records of unannounced off-hour augmentation tests, which were conducted between November 2009 through August 2011, to determine the adequacy of post-drill critiques and associated corrective actions. The inspectors also reviewed a sample of the EP training records, approximately 12 records for ERO personnel, who were assigned to key and support positions, to determine the status of their training as it related to their assigned ERO positions. Documents reviewed are listed in the Attachment to this report. This ERO augmentation testing inspection constituted one sample as defined in IP 71114.03-05.

b. Findings

No findings were identified.

18 Enclosure

1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies

.1 Correction of Emergency Preparedness Weaknesses and Deficiencies

a. Inspection Scope

The inspectors reviewed a sample of Quality Assurance audits for 2009 and 2010 of the EP program to determine that these independent assessments met the requirements of 10 CFR 50.54(t). The inspectors also reviewed critique reports and samples of corrective action program records associated with the 2010 biennial exercise, as well as various EP drills conducted in 2010 and 2011, in order to determine that the licensee fulfilled its drill commitments and to evaluate the licensee's efforts to identify, track, and resolve concerns identified during these activities.

The inspectors reviewed a sample of EP items and corrective actions related to the facility's EP program and activities between November 2009 and July 2011 to determine whether corrective actions were completed in accordance with the sites corrective action program. Documents reviewed are listed in the Attachment to this report. This correction of emergency preparedness weaknesses and deficiencies inspection constituted one sample as defined in IP 71114.05-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on July 20, 2011, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the Technical Support Center, emergency offsite facility, and the simulator to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. Documents reviewed are listed in the Attachment to this report. This inspection constituted one emergency preparedness drill sample as defined in IP 71114.06-05.

b. Findings

No findings were identified.

19 Enclosure

.2 Training Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee tabletop emergency drill on August 31, 2011, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities.

The inspectors observed the tabletop drill to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. Documents reviewed are listed in the Attachment to this report. This inspection constituted one emergency preparedness drill sample as defined in IP 71114.06-05.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Occupational and Public Radiation Safety

2RS2 Occupational As-Low-As-Is-Reasonably-Achievable (ALARA) Planning and Controls

(71124.02) The inspection activities supplement those documented in Inspection Reports 05000266/2010002; 05000301/2010002; and 05000266/2010004; 05000301/2010004. This constituted one complete sample as defined in IP 71124.02-05.

.1 Source Term Reduction and Control (02.04)

a. Inspection Scope

The inspectors used licensee records to determine the historical trends and current status of significant tracked plant source terms known to contribute to elevated facility aggregate exposure. The inspectors assessed whether the licensee had made allowances or developed contingency plans for expected changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary

chemistry.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

This inspection constituted one complete sample as defined in IP 71124.07-05.

20 Enclosure

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the annual radiological environmental operating reports and the results of any licensee assessments since the last inspection to verify that the radiological environmental monitoring program was implemented in accordance with the TSs and Offsite Dose Calculation Manual (ODCM). This review included report changes to the ODCM with respect to environmental monitoring, commitments in terms of sampling locations, monitoring and measurement frequencies, land use census, inter-laboratory comparison program, and analysis of data. The inspectors reviewed the ODCM to identify locations of environmental monitoring stations. The inspectors reviewed the FSAR for information regarding the environmental monitoring program and meteorological monitoring instrumentation. The inspectors reviewed quality assurance audit results of the program to assist in choosing inspection "smart samples" and audits and technical evaluations performed on the vendor laboratory program. The inspectors reviewed the annual effluent release report and the 10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste," report, to determine if the licensee is sampling, as appropriate, for the predominant and dose-causing radionuclides likely to be released in effluents.

b. Findings

No findings were identified.

.2 Site Inspection (02.02)

a. Inspection Scope

The inspectors walked down select air sampling stations and thermoluminescent dosimeter (TLD) monitoring stations to determine whether they were located as described in the ODCM and to determine the equipment material condition.

Consistent with smart sampling, the air sampling stations were selected based on the locations with the highest X/Q, D/Q wind sectors, and TLDs were selected based on the most risk-significant locations (e.g., those that have the highest potential for public dose impact). For the air samplers and TLDs selected, the inspectors reviewed the calibration and maintenance records to verify that they demonstrated adequate operability of these components. Additionally, the review included the calibration and maintenance records of select composite water samplers. The inspectors performed an assessment of whether the licensee had initiated sampling of other appropriate media upon loss of a required sampling station. The inspectors observed the collection and preparation of environmental samples from different environmental media (e.g., ground and surface water, milk, vegetation, 21 Enclosure sediment, and soil) as available to verify that environmental sampling was representative of the release pathways as specified in the ODCM and that sampling techniques were in accordance with procedures. Based on direct observation and review of records, the inspectors assessed whether the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the FSAR, NRC Regulatory Guide 1.23, "Meteorological Monitoring Programs for Nuclear Power Plants," and licensee procedures. The inspectors assessed whether the meteorological data readout and recording instruments in the control room and, if applicable, at the tower were operable. The inspectors evaluated whether missed and/or anomalous environmental samples were identified and reported in the annual environmental monitoring report.

The inspectors selected events that involved a missed sample, inoperable sampler, lost TLD, or anomalous measurement to verify that the licensee has identified the cause and has implemented corrective actions. The inspectors reviewed the licensee's assessment of any positive sample results (i.e., licensed radioactive material detected above the lower limits of detection) and reviewed the associated radioactive effluent release data for released material. Inspectors selected SSCs that involve or could reasonably involve licensed material for which there was a credible mechanism for licensed material to reach ground water, and assessed whether the licensee had implemented a sampling and monitoring program sufficient to detect leakage of these SSCs to groundwater. The inspectors evaluated whether records, as required by 10 CFR 50.75(g), of leaks, spills, and remediation since the previous inspection were retained in a retrievable manner. The inspectors reviewed any significant changes made by the licensee to the ODCM as the result of changes to the land census, long-term meteorological conditions (3-year average), or modifications to the sampler stations since the last inspection.

They reviewed technical justifications for any changed sampling locations to verify that the licensee performed the reviews required to ensure that the changes did not affect its ability to monitor the impacts of radioactive effluent releases on the environment. The inspectors assessed whether the appropriate detection sensitivities with respect to TSs/ODCM were used for counting samples (i.e., the samples met the TSs/ODCM required lower limits of detection). The inspectors reviewed quality control charts for maintaining radiation measurement instrument status and actions taken for degrading detector performance. The inspectors reviewed the results of the licensee's inter-laboratory comparison program to verify the adequacy of environmental sample analyses. The inspectors assessed whether the inter-laboratory comparison test included the media/nuclide mix appropriate for the facility. The inspectors reviewed the licensee's determination of any bias to the data and the overall effect on the radiological environmental monitoring program.

b. Findings

No findings were identified.

22 Enclosure

.3 Identification and Resolution of Problems (02.03)

a. Inspection Scope

The inspectors assessed whether problems associated with the radiological environmental monitoring program were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee's CAP.

Additionally, they assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involved the radiological environmental monitoring program.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance Index - Emergency Alternating Current (AC) Power

Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI) - Emergency AC Power Systems performance indicator (PI) for Units 1 and 2 for the third quarter 2010 through the second quarter 2011. To determine the accuracy of the PI data, PI definitions and guidance contained in Nuclear Energy

Institute (NEI) document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, dated October 2009, were used. The inspectors reviewed the licensee's operator narrative logs, MSPI derivation reports, CRs, event reports, and NRC Integrated Inspection Reports (IRs) for the period July 2010 through June 2011 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's CAP to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report. This inspection constituted two MSPI emergency AC power system samples as defined in IP 71151-05.

b. Findings

No findings were identified.

23 Enclosure

.2 Mitigating Systems Performance Index - High Pressure Injection Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - High Pressure Injection Systems PI for Units 1 and 2 for the third quarter 2010 through the second quarter 2011. To determine the accuracy of the PI data, PI definitions and guidance contained in NEI 99-02 were used. The inspectors reviewed the licensee's operator narrative logs, CRs, MSPI derivation reports, event reports, and NRC Integrated IRs for July 2010 through June 2011 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's CAP to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report. This inspection constituted two MSPI high pressure injection system samples as defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Mitigating Systems Performanc

e Index - Heat Removal Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - Heat Removal Systems PI for Units 1 and 2 for the third quarter 2010 through the second quarter 2011.

To determine the accuracy of the PI data, PI definitions and guidance contained in NEI 99-02 were used. The inspectors reviewed the licensee's operator narrative logs, CRs, event reports, MSPI derivation reports, and NRC Integrated IRs for July 2010 through June 2011 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's CAP to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report. This inspection constituted two MSPI heat removal system samples as defined in IP 71151-05.

b. Findings

No findings were identified.

24 Enclosure

.4 Mitigating Systems Performance Index - Residual Heat Removal Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - Residual Heat Removal (RHR) Systems PI Units 1 and 2 for the third quarter 2010 through the second quarter 2011. To determine the accuracy of the PI data, PI definitions and guidance contained in NEI 99-02 were used. The inspectors reviewed the licensee's operator narrative logs, CRs, MSPI derivation reports, event reports, and NRC Integrated IRs for July 2010 through June 2011 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's CAP to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report. This inspection constituted two MSPI RHR system samples as defined in IP 71151-05.

b. Findings

No findings were identified.

.5 Mitigating Systems Performance I

ndex - Support Cooling Water Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - Cooling Water Systems PI Units 1 and 2 for the third quarter 2010 through the second quarter 2011. To determine the accuracy of the PI data, PI definitions and guidance contained in NEI 99-02 were used. The inspectors reviewed the licensee's operator narrative logs, CRs, MSPI

derivation reports, event reports, and NRC Integrated IRs for the period of July 2010 through June 2011 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's CAP to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report. This inspection constituted two MSPI cooling water system samples as defined in IP 71151-05.

b. Findings

No findings were identified.

25 Enclosure

.6 Reactor Coolant System (RCS) Specific Activity

a. Inspection Scope

The inspectors sampled licensee submittals for the RCS specific activity PI for Point Beach Nuclear Power Plant Units 1 and 2 for the first quarter 2010 through the second quarter 2011. The inspectors used PI definitions and guidance contained in NEI 99-02

to determine the accuracy of the PI data. The inspectors reviewed the licensee's RCS chemistry samples, TS requirements, CRs, event reports, and NRC Integrated IRs for the first quarter 2010 through the second quarter 2011 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's CAP to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. In addition to record reviews, the inspectors observed a chemistry technician obtain and analyze an RCS sample. Documents reviewed are listed in the Attachment to this report. This inspection constituted two reactor coolant system specific activity samples as defined in IP 71151-05.

b. Findings

No findings were identified.

.7 Occupational Exposure Control Effectiveness

a. Inspection Scope

The inspectors sampled licensee submittals for the occupational radiological occurrences PI for the first quarter 2010 through the second quarter 2011. The inspectors used PI definitions and guidance contained in NEI 99-02 to determine the accuracy of the PI data. The inspectors reviewed the licensee's assessment of the PI for occupational radiation safety to determine if indicator-related data was adequately assessed and reported. To assess the adequacy of the licensee's PI data collection and analyses, the inspectors discussed with radiation protection staff, the scope and breadth of its data review and the results of those reviews. The inspectors independently reviewed electronic personal dosimetry dose rate and accumulated dose alarms and dose reports and the dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized occurrences.

The inspectors also conducted walkdowns of numerous locked high and very high radiation area entrances to determine the adequacy of the controls in place for these areas. Documents reviewed are listed in the Attachment to this report. This inspection constituted one occupational exposure control effectiveness sample as defined in IP 71151-05.

b. Findings

No findings were identified.

26 Enclosure

.8 Radiological Effluent Technical Specification/Offsite Dose Calculation Manual

Radiological Effluent Occurrences

a. Inspection Scope

The inspectors sampled licensee submittals for the radiological effluent TS/ ODCM radiological effluent occurrences PI for the first quarter 2010 through the second quarter 2011. The inspectors used PI definitions and guidance contained in NEI 99-02 to determine the accuracy of the PI data. The inspectors reviewed the licensee's CAP and selected individual reports generated since this indicator was last reviewed, to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous effluent summary data and the results of associated offsite dose calculations for selected dates from the first quarter 2010 through the second quarter 2011 to determine if indicator results were accurately reported. The inspectors also reviewed the licensee's methods for quantifying gaseous and liquid effluents and determining effluent dose. Documents reviewed are listed in the Attachment to this report. This inspection constituted one Radiological Effluent Technical Specification/Offsite Dose Calculation Manual radiological effluent occurrences sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.9 Drill/Exercise Performance

a. Inspection Scope

The inspectors sampled licensee submittals for the Drill/Exercise PI for the fourth quarter 2010 through second quarter 2011. To determine the accuracy of the PI data, PI definitions and guidance contained in NEI 99-02 were used. The inspectors reviewed licensee records to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes, including procedural guidance on assessing opportunities for the PI, assessments of PI opportunities during predesignated control room simulator training sessions, performance during the 2010 biennial exercise, and performance during other drills. Documents reviewed are listed in the Attachment to this report. This inspection constituted one drill/exercise performance sample as defined in IP 71151-05.

b. Findings

No findings were identified.

27 Enclosure

.10 Emergency Response Organization Drill Participation

a. Inspection Scope

The inspectors sampled licensee submittals for the ERO Drill Participation PI for the period from the fourth quarter 2010 through second quarter 2011. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, dated October 2009, were used. The inspectors reviewed the licensee's records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI; performance during the 2010 biennial exercise and other drills; and revisions of the roster of personnel assigned to key emergency response organization positions. Documents reviewed are listed in the Attachment to this report. This inspection constituted one ERO drill participation sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.11 Alert and Notification System

a. Inspection Scope

The inspectors sampled licensee submittals for the ANS PI for the fourth quarter 2010 through second quarter 2011. To determine the accuracy of the PI data, PI definitions and guidance contained in NEI 99-02 were used. The inspectors reviewed licensee records to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI, and results of periodic ANS operability tests. Documents reviewed are listed in the Attachment to this report. This inspection constituted one alert and notification system sample as defined in IP 71151-05.

b. Findings

No findings were i d entified.

28 Enclosure

4OA2 Identification and Resolution of Problems

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

.1 Routine Review of Items Entered Into the CAP

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; timeliness was

commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue. Minor issues entered into the licensee's CAP as a result of the inspectors' observations are included in the Attachment to this report.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily CAP Reviews

a. Inspection Scope

To assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's CAP. This review was accomplished through inspection of the station's daily condition report packages. These daily reviews were performed by procedure as part of the inspectors' daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

29 Enclosure Selected Issue Follow-Up Inspection: EDG G03 Starting Air System

c. Inspection Scope

During a review of items entered in the licensee's CAP, the inspectors identified various corrective action documents (action requests (ARs)) related to the G03 EDG starting air system. The inspectors noted that AR 01666371 identified DA-318, "G-03 EDG T-171 A/B Start Air Receiver Inlet Check Valve," as a nonsafety-related valve although design basis documents listed this component as safety-related. The inspectors found that the licensee failed to identify that the system was inoperable because of seismic considerations; however, due to the licensee being in the limiting condition for operation at the time, no findings were identified. Also, the inspectors determine that although this component was incorrectly classified in the AR, the actions taken to correct the deficiency associated with this component were adequate. Documents reviewed are listed in the Attachment to this report. This review constituted one in-depth problem identification and resolution sample as defined in IP 71152-05.

d. Findings

No findings were identified.

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

.1 Feedwater System Leak

a. Inspection Scope

The inspectors reviewed the plant's response to a feedwater system leak in Unit 2 and associated non-code repair. Documents reviewed are listed in the Attachment to this report. This event follow-up review constituted one sample as defined in IP 71153-05.

b. Findings

No findings were identified.

.2 (Closed) Licensee Event Report (LER) 05000301/2010-003-00, "Technical Specification

Required Shutdown

"

Introduction:

The inspectors identified a finding of very low safety significance and an associated NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the licensee's failure to perform an operability evaluation when degraded/non-conforming conditions were identified relative to the Unit 2 rod drive control (RDC) system. Specifically , on December 10, 2010, condition report (CR) 01401564 identified rod failure alarms, but did not identify the degraded/non-conforming conditions or evaluate the condition relative to support functions for TSs 3.1.4 and 3.1.6.

30 Enclosure Discussion: On December 10, 2010, the licensee received rod control system alarms while performing TS surveillance TS-6, "Rod Exercise Test." Troubleshooting between December 10 and December 13, and an unsuccessful attempt to complete TS-6 on December 13, before expiration of the time period to complete the surveillance, resulted in the licensee's inability to satisfy the surveillance requirement. Subsequently, the licensee shut down Unit 2 because the RDC group alignment limits of TS 3.1.4 were not met.

The inspectors reviewed the licensee's evaluation of the issue and found that CR01401564 written on December 10 did not assess the degraded/non-conforming conditions until December 14, after Unit 2 was shut down. The inspectors found that the issue had been evaluated and documented in the station logs on December 11, but this evaluation did not identify or assess the cause of the alarms. The inspectors also found that TS 3.1.6, "Control Bank Insertion Limits," was applicable in the operational mode where the failure occurred. However, the licensee failed to evaluate the impact of the surveillance requirement on TS 3.1.6. Procedure PI-AA-205, "Condition Evaluation and Corrective Action," Revision 10, effective December 6, 2010, Step 4.4.1 states, in part, that, "If the CR evaluator determines that the condition represents a nonconforming/degraded condition to a Structure, System, or Component (SSC) that is either: 1. Required to be operable by Technical Specifications (TS) . . . then an Immediate Operability Determination (IOD)per EN-AA-203-1001 may also be required if additional supporting information is required." Considering the items not evaluated above, the inspectors concluded that an operability evaluation was not performed as required. The inspectors reviewed the corrective actions and root cause evaluation (RCE) for CR01401564 and CR01401858, "U2 Forced Outage after RDC Failure." The inspectors found that the corrective actions were adequate to address the cause of the condition. Corrective actions included multiple RDC logic card repairs, inspections of connections on the reactor head and nearby panel, repair of deficient connections, and the establishment of a repetitive task to periodically maintain the RDC logic cards and associated power supplies.

Analysis:

The inspectors determined that the failure to perform an operability evaluation for multiple conditions requiring an evaluation as required by procedure PI-AA-205 was a performance deficiency warranting further evaluation. The finding was determined to be more than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," dated December 24, 2009, because it was associated with the Mitigating Systems Cornerstone attribute of equipment performance and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to identify the degraded/non-conforming conditions (DNCs) and assess the degraded/non-conforming conditions' impact on operations and TS requirements resulted in latent conditions that had the potential to be of greater safety significance, and in this case resulted in the failure to evaluate the DNC relative to TS 3.1.6.

The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 Initial Screening and Characterization of Findings," Tables 3b and 4a for the Mitigating 31 Enclosure Systems Cornerstone, dated January 10, 2008. The inspectors answered "No" to all the screening questions in the SDP Phase 1 Screening Worksheet in the Mitigating Systems column; therefore, this finding screened as having very low safety significance (Green). This finding has a cross-cutting aspect in the area of human performance, decision-making, because the licensee did not use conservative assumptions during related decision-making that adopted a requirement to demonstrate that the proposed action was safe in order to proceed. The inspectors identified that CR01401564 did not contain an operability evaluation, that the logs contained an unidentified DNC, and the root cause evaluation did not evaluate the cause of the control rods dropping into the core; and that each of these documents were reviewed by multiple layers of the organization. Most significantly, none of these documents contained an evaluation that reviewed the acceptability and the impact of this activity on the note in TS 3.1.6. (H.1(b))

Enforcement:

Title 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," states, in part, that activities affecting quality shall be prescribed and accomplished in accordance with the procedures. Contrary to this, on December 10, 2010, when equipment problems occurred during a surveillance of the RDC system, an activity affecting quality, the licensee failed to perform an operability evaluation as required by procedure PI-AA-205, Step 4.4.1. Because this violation was of very low safety significance and was entered into the licensee's CAP, as CR01401564 and CR01401858, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000266/2011004-02; 05000301/2011004-02, Failure to Perform an Operability Evaluation for Rod Drive Control System Failures). Documents reviewed are listed in the Attachment to this report. This LER is closed.

This event follow-up review constituted one sample as defined in IP 71153-05.

.3 (Closed) LER 05000301/2010-004-00, "Manual Reactor Trip During Startup

" On December 15, 2010, and prior to criticality, the licensee initiated a manual reactor trip for Unit 2 when multiple groups of control rods inserted unexpectedly into the reactor core (LER 05000301/2010-004-00). The licensee entered these conditions into its CAP and performed an RCE to determine the cause of the failure. The licensee determined that the cause of this event and the cause of the December 10 th event (Section 4OA3.1) were common and evaluated these events in CR01401564 and CR01401858. This LER identified that nonsafety-related portions of the RDC system had failed resulting in rods inserting unexpectedly into the core. Based on a review of the licensee's RCE, the inspectors determined that no performance deficiencies of violations of regulatory requirements of safety significance existed. The inspectors had no other concerns associated with this event. This LER is closed. Documents reviewed are listed in the Attachm ent to this report. This event follow-up review constituted one sample as defined in IP 71153-05.

4OA5 Other Activities

.1 (Closed) Temporary Instruction 2515/179, "Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10, Code of Federal Regulations, Part 20.2207

(10 CFR 20.2207)"

a. Inspection Scope

The inspectors confirmed that the licensee has reported the initial inventories of sealed sources pursuant to 10 CFR 20.2207 and verified that the National Source Tracking System database correctly reflected the Category 1 and 2 sealed sources in custody of the licensee. Inspectors interviewed personnel and performed the following:

• reviewed the licensee's source inventory;

• verified the presence of any Category 1 or 2 sources;

• reviewed procedures for and evaluated the effectiveness of storage and handling of sources;

• reviewed documents involving transactions of sources; and

• reviewed adequacy of licensee maintenance, posting, and labeling of nationally tracked sources.

b. Findings

No findings were identified.

.2 Extended Power Uprate

a. Inspection Scope

The Component Design Bases Inspection (CDBI) documented in NRC inspection report 05000266/2011009; 05000301/2011009 included two plant modification samples.

• Engineering Change EC-12070, "Unit 2 Main Steam and Feedwater Pipe Support,"

Revision 0; and

• EC-11795, "Unit 2 Containment Spray Piping Supports." This integrated report includes the following samples that can be credited to the EPU inspection procedure. Two samples are included in Section

1R15 - Operability Evaluations and Functional Assessments

.

• operability evaluation for issues with the air amplifier (air supply tank for valve operation) for 1P-53, the Unit 1 motor-driven auxiliary feedwater pump; and

• operability of the Unit 2 main feedwater regulating valves (MFRVs) after the extended power uprate partial modification installation.

33 Enclosure Two samples are included in Section

1R19 - Post-Maintenance Testing

.

• PMT of MFRV circuitry work (Unit 2);

• PMT of loss of FW turbine trip alarm (Unit 2).

b. Findings

Two findings were documented in the CDBI report 05000266/2011009; 05000301/2011009.

4OA6 Management Meetings

.1 Exit Meeting Summary

On October 4, 2011, the inspectors presented the inspection results to Mr. L. Meyer and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

.2 Interim Exit Meetings

Interim exits were conducted for:

• the results of the radiation safety inspection conducted July 18 through 22, 2011, with Plant General Manager, Mr. T. Vehec, on July 22, 2011;

• the results of the licensed operator requalification training program inspection with Mr. R. Harrsch, Operations Director (Acting Site Vice-President), on August 11, 2011;

• the licensed operator requalification training biennial annual operating test results with Mr. L. Germann, Operations Continuing Training Instructor, via telephone on September 7, 2011; and

• the results of the Emergency Preparedness program inspection were discussed with Mr. L. Meyer on September 15, 2011, and a subsequent interim exit was conducted with Mr. J. Schleif on September 29, 2011.

• the resolution of unresolved item URI 05000266/2006006-08; 05000301/2006006-08 on October 26, 2011, with Mr. Jim Costedio and others. The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee.

34 Enclosure

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) or Severity Level IV were identified by the licensee and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy, for being dispositioned as non-cited violations. Title 10 CFR 50, Appendix E, Section IV.B, states, in part, that, "emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis." Contrary to this, the 2009 annual Emergency Action Level (EAL) review was not conducted with State and local governmental authorities. This event was documented in the licensee's CAP as entry 1394643; 2009 Offsite EAL Review Not Completed. This finding is of very low safety significance because it does not affect any of the licensee's EALs or processes by which they are classified. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

T. Vehec, Plant Manager

C. Trezise, Engineering Director

R. Harrsch, Operations Director

J. Costedio, Licensing Manager

D. Craine, Radiation Protection Manager

R. Harrsch, Operations Director (Acting Site Vice-President)

R. Amundson, Operations Training General Supervisor

R. Bretton, Operations Training Supervisor

F. Flentje, Licensing Supervisor

C. Hill, Assistant Operations Manager-Training

D. Lauterbur, Training Manager

J. Pierce, Training

C. Riddings, Acting Maintenance Manager

J. Rogers, Operations Training Instructor

C. Sizemore, NextEra/FPL Fleet Operations Training Manager

G. Vickery, Work Management Manager (Acting Plant Manager)

Nuclear Regulatory Commission

M. Kunowski, Chief, Reactor Projects Branch 5

A. M. Stone, Chief, Engineering Branch 2, Division of Reactor Safety

Attachment

LIST OF ITEMS

Opened

05000266/2011004-01;

05000301/2011004-01 URI Potential Failure to Correctly Implement a Systems Approach to Training for the Licensed Operator

Requalification Program (Section 1R11.3)

05000266/2011004-02;

05000301/2011004-02 NCV Failure to Perform an Operability Evaluation for Rod Drive

Control System Failures (Section 4OA3.2)

05000266/2011004-03;

05000301/2011004-03; NCV Failure to Ensure Tornado Missile Protection for EDGs G01 and G02 Exhaust Stacks (Section 1R21)

Closed

05000266/2011004-02;

05000301/2011004-02 NCV Failure to Perform an Operability Evaluation for Rod Drive

Control System Failures (Section 4OA3.2)

05000301/2010-003-00 LER Technical Specification Required Shutdown (Section 4OA3.2)

05000301/2010-004-00 LER Manual Reactor Trip During Startup (Section 4OA3.3)

05000266/2006006-08;

05000301/2006006-08 URI Safety-Related Equipment Not Protected from Tornado Missiles (Section 1R21)

05000266/2011004-03;

05000301/2011004-03; NCV Failure to Ensure Tornado Missile Protection for EDGs G01 and G02 Exhaust Stacks (Section 1R21)

Discussed

None.

Attachment

LIST OF DOCUMENTS REVIEWED

The following is a partial list of documents reviewed during the inspection.

Inclusion on this list does not imply that the NRC inspector reviewed the documents in their entirety, but rather that