IR 05000327/2011004

IR 05000327-11-004 & 05000328-11-004, on 07/01/2011 - 09/30/2011, Sequoyah Nuclear Plant, Unit 1 & 2, Operability Evaluations

ML113010444
Person / Time
Site:	Sequoyah
Issue date:	10/28/2011
From:	Scott Shaeffer Reactor Projects Region 2 Branch 6
To:	James Shea Tennessee Valley Authority
References
IR-11-004
Download: ML113010444 (35)

Text

October 28, 2011

SUBJECT:

SEQUOYAH NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000327/2011004, 05000328/2011004

Dear Mr. Shea:

On September 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Sequoyah Nuclear Plant, Units 1 and 2. The enclosed inspection report documents the inspection results discussed on October 4, 2011 with Mr. P. Simmons and other members of the Sequoyah 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.

This report documents one NRC-identified Severity Level IV violation of NRC requirements. However, because of its very low safety significance and because it has been entered into your corrective action program, the NRC is treating this issue as a non-cited violation (NCV), consistent with the NRC Enforcement Policy. If you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Sequoyah Nuclear Plant.

TVA 2 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 (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/ Scott M. Shaeffer, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-327, 50-328 License Nos.: DPR-77, DPR-79

Enclosure:

Inspection Report 05000327/2011004, 05000328/2011004 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-327, 50-328 License Nos.: DPR-77, DPR-79

Report Nos.: 05000327/2011004, 05000328/2011004 Licensee: Tennessee Valley Authority (TVA)

Facility: Sequoyah Nuclear Plant, Units 1 and 2 Location: Sequoyah Access Road Soddy-Daisy, TN 37379

Dates: July 1 - September 30, 2011 Inspectors: C. Young, Senior Resident Inspector W. Deschaine, Resident Inspector R. Hamilton, Senior Health Physicist (2RS5, 4OA6) A. Nielsen, Senior Health Physicist (2RS4) R. Kellner, Health Physicist (2RS7)

W. Pursley, Health Physicist (2RS6, 4OA1)

Approved by: Scott M. Shaeffer, Chief Reactor Projects Branch 6 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000327/2011004, 05000328/2011004; 7/1/2011 - 9/30/2011; Sequoyah Nuclear Plant, Units 1 and 2; Operability Evaluations

The report covered a three-month period of inspection by resident inspectors and announced inspections by regional inspectors. One Severity Level IV non-cited violation (NCV) of NRC requirements was identified. 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.

Cornerstone: Miscellaneous

• Severity Level IV. The inspectors identified a non-cited violation of 10 CFR 50.73, "Licensee Event Report System," for the licensee's failure to report an invalid system actuation. On May 5, 2011, a containment ventilation isolation (CVI) signal was inadvertently generated on Unit 2 while performing surveillance testing. This system actuation was not reported to the NRC as required by 10 CFR 50.73(a)(2)(iv) within 60 days of discovery of the event. This issue was entered into the licensee's corrective action program as PER 417453, and was reported to the NRC as EN #47249 on September 8, 2011.

This violation was determined to be applicable to traditional enforcement because of its potential to impact the ability of the NRC to perform its regulatory oversight function, and was therefore evaluated in accordance with the NRC Enforcement Policy. This issue was determined to be a Severity Level IV violation in accordance with Section 6.9.d.9 of the NRC Enforcement Policy. No cross-cutting aspect was assigned since traditional enforcement violations for which there are no associated ROP findings are not screened for cross-cutting aspects. (Section 1R15)

B. Licensee-Identified Violations

None.

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at or near 100 percent rated thermal power (RTP) until July 13, 2011, when power was reduced to 85 percent RTP to facilitate removal of one condenser circulating water (CCW) pump from service. On July 14, 2011, the CCW pump was restored to service, and the unit returned to 100 percent RTP. Unit 1 operated at or near 100 percent RTP until July 20, 2011, when Unit 1 experienced an automatic reactor trip due to a load rejection resulting from inadvertent closure of main turbine governor valves. Following repairs, Unit 1 achieved criticality on July 22, 2011, and reached 100 percent RTP on July 23, 2011. Unit 1 operated at or near 100 percent rated thermal power (RTP) until August 18, 2011, when Unit 1 experienced an automatic reactor trip due to a momentary reactor coolant pump (RCP) undervoltage condition sensed on two RCPs. Following repairs, Unit 1 achieved criticality on August 20, 2011, and reached 100 percent RTP on August 22, 2011, where it operated for the remainder of the inspection period.

Unit 2 operated at or near 100 percent rated thermal power (RTP) until July 13, 2011, when power was reduced to 85 percent RTP to facilitate removal of one condenser circulating water (CCW) pump from service. On July 14, 2011, the CCW pump was restored to service, and the unit returned to 100 percent RTP. Unit 2 operated at or near 100 percent RTP until September 11, 2011, when power was reduced to approximately 67 percent RTP to facilitate the planned replacement of a hotwell pump. Unit 2 returned to 100 percent RTP on September 16, 2011, where it operated for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Summer Readiness of Offsite and Alternate AC Power Systems

a. Inspection Scope

The inspectors performed the annual review of the licensee's readiness of offsite and alternate AC power systems prior to the onset of the high grid loading season. The inspectors reviewed procedures affecting these areas and the communications protocols between the transmission system operator and the licensee to verify that appropriate information is exchanged when issues arise that could impact the offsite power system. The inspectors walked down offsite power supply systems and emergency diesel generators, reviewed corrective action program documents, and interviewed appropriate plant personnel to assess deficiencies and plant readiness for summer high grid loading. Documents reviewed are listed in the Attachment. The inspectors completed one sample.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdown

a. Inspection Scope

The inspectors performed partial walkdowns of the following three systems to verify the operability of redundant or diverse trains and components when safety equipment was inoperable. The inspectors performed partial walkdowns of the following system to verify the operability of a risk-significant system or train that was recently realigned following an extended system outage, maintenance, modification, or testing. For all three systems, the inspectors focused on identification of discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, walked down control system components, and determined whether selected breakers, valves, and support equipment were in the correct position to support system operation. 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 corrective action program (CAP). Documents reviewed are listed in the Attachment. The inspectors completed three samples.

• 1A-A Motor Driven Auxiliary Feedwater Pump (MDAFW) while the 1B-B Motor Driven Auxiliary Feedwater Pump was inoperable for maintenance and a performance test

• 1B-B Motor Driven Auxiliary Feedwater Pump while the 1A-S Turbine Driven Auxiliary Feedwater Pump was inoperable for maintenance

• 2A-A Diesel Generator following realignment after a scheduled surveillance test

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Fire Protection Tours

a. Inspection Scope

The inspectors conducted a tour of the six areas important to safety listed below to assess the material condition and operational status of fire protection features. The inspectors evaluated whether: combustibles and ignition sources were controlled in accordance with the licensee's administrative procedures; fire detection and suppression equipment was available for use; passive fire barriers were maintained in good material condition; and compensatory measures for out-of-service, degraded, or inoperable fire protection equipment were implemented in accordance with the licensee's fire plan. Documents reviewed are listed in the Attachment. The inspectors completed six samples.

• Control Building Elevation 706 (Cable Spreading Room)

• Control Building Elevation 669 (Mechanical Equipment Room, 250 VDC Battery and Battery Board Rooms)

• Control Building Elevation 685 (Auxiliary Instrument Rooms)

• Auxiliary Building Elevation 714 (Corridor)

• Auxiliary Building Elevation 690 (Corridor)

• Auxiliary Building Elevation 653

b. Findings

No findings were identified.

1R06 Flood Protection Measures

.1 Internal Flooding

a. Inspection Scope

The inspectors performed one internal flood protection measures sample for the Units 1 and 2 containment spray pump rooms internal flood design. The inspectors verified that flood mitigation plans were consistent with the design requirements and risk analysis assumptions, and that equipment essential for reactor shutdown was properly protected from a flood caused by potential pipe breaks. Specifically, the inspectors reviewed the licensee's moderate energy line break flooding study to fully understand the licensee's flood mitigation strategy, reviewed licensee drawings and then verified that the assumptions and results remained valid. The inspectors walked down the Unit 1 and 2 containment spray pump rooms in the auxiliary building to verify the assumed flooding sources, adequacy of common area drainage, and flood detection instrumentation to ensure that a flooding event would not impact reactor shutdown capabilities. The inspectors completed one sample.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Operating Experience Smart Sample (OpESS) FY 2010-02, Sample Selections for Reviewing Licensed Operator Examinations and Training Conducted on the Plant-Reference Simulator

a. Inspection Scope

The inspectors performed one licensed operator requalification program review. The inspectors observed simulator sessions on July 8, 2001, and July 14, 2011. The training scenario involved a plant trip being complicated by an electrical fault and fire. The inspectors observed crew performance in terms of: communications; ability to take timely and proper actions; prioritizing, interpreting and verifying alarms; correct use and implementation of procedures, including the alarm response procedures; timely control board operation and manipulation, including high risk operator actions; oversight and direction provided by shift manager, including the ability to identify and implement appropriate Technical Specification (TS) action; and, group dynamics involved in crew performance. The inspectors also observed the evaluators' critique and reviewed simulator fidelity to verify that it matched actual plant response. Documents reviewed are listed in the Attachment. This activity constituted one inspection sample.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the maintenance activities, issues, and/or systems listed below to verify the effectiveness of the licensee's activities in terms of: appropriate work practices; identifying and addressing common cause failures; scoping in accordance with 10 CFR 50.65(b); characterizing reliability issues for performance; trending key parameters for condition monitoring; charging unavailability for performance; classification in accordance with 10 CFR 50.65(a)(1) or (a)(2); appropriateness of performance criteria for structure, system, or components (SSCs) and functions classified as (a)(2); and appropriateness of goals and corrective actions for SSCs and functions classified as (a)(1). Documents reviewed are listed in the Attachment. The inspectors completed three samples.

• Function 03-C and 30-D, Main control room and electric board room chillers

• Hydrogen recombiners Maintenance Rule a(1) plan

• Function 001-H, Steam Dumps

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the following activities to determine whether appropriate risk assessments were performed prior to removing equipment from service for maintenance. The inspectors evaluated whether 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 reviewed whether plant risk was promptly reassessed and managed. The inspectors also assessed whether the licensee's risk assessment tool use and risk categories were in accordance with Standard Programs and Processes Procedure NPG-SPP-07.1, "On-Line Work Management," Revision 3, and Instruction 0-TI-DSM-000-007.1, "Risk Assessment Guidelines," Revision 9. Documents reviewed are listed in the Attachment. The inspectors completed five samples.

• 2B Degraded Voltage and Load Shed Relay Testing

• Yellow PSA Risk - Unit 1 -Motor Driven Auxiliary Feedwater Pump 1B-B Maintenance & Performance Test per 1-SI-SXP-003-201.B

• Units 1 and 2 - CSST B out of service due to a differential relay actuating during the week of September 6 - September 9, 2011

• Unit 1 Yellow PSA Risk - Turbine Driven Auxiliary Feedwater Pump Testing

• 1A-A Emergency Diesel Generator planned outage for 12 year preventative maintenance (PM)

b. Findings

No findings were identified.

1R15 Operability Evaluations

a. Inspection Scope

For the three operability evaluations described in the PERs listed below, 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 risk occurred. The inspectors compared the operability evaluations to UFSAR descriptions to determine if the system or component's intended function(s) were adversely impacted. In addition, the inspectors reviewed compensatory measures implemented to determine whether the compensatory measures worked as stated and the measures were adequately controlled. The inspectors also reviewed a sampling of PERs to assess whether the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the Attachment. The inspectors completed three samples.

• PER 365170, Unit 2 A-train containment ventilation isolation

• PER 392572, Inverter 2-I failure

• PER 411572, Containment temperature analysis

b. Findings

Introduction.

The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.73, "Licensee Event Report System," for the licensee's failure to report the invalid actuation of a system as required by 10 CFR 50.73(a)(2)(iv) within 60 days of discovery of the event.

Description.

On May 5, 2011, an 'A' train containment ventilation isolation (CVI) signal was inadvertently generated on Unit 2 while performing surveillance testing. The CVI signal is a containment isolation signal generated by the engineered safety features actuation system (ESFAS) which functions to automatically close containment isolation valves in the containment purge ventilation system as well as the containment radiation monitoring system.

10 CFR 50.73(a)(2)(iv)(A) requires reporting of "any event or condition that resulted in manual or automatic actuation of any of the systems listed in paragraph (a)(2)(iv)(B)-" Paragraph (a)(2)(iv)(B)(2) lists "general containment isolation signals affecting containment isolation valves in more than one system-" Paragraph (a)(2)(iv)(A)(2) provides an exception to the reporting requirement in the case of an invalid actuation which "occurred after the safety function had been already completed."

On May 6, 2011, the licensee initiated PER 365170 to document the event in the CAP, including evaluation for potential reportability. This PER was closed without reporting the event, on the basis that the containment purge ventilation isolation valves were already closed at the time the CVI signal was actuated, and therefore only the radiation monitoring system containment isolation valves actually repositioned as a result of the CVI actuation. The inspectors challenged this conclusion on the basis that actuation of the CVI signal was a reportable system actuation since the safety function provided by the signal included containment isolation valves in more than one system. Since the actuation was invalid, the status of [any of] the affected valves being already closed at the time of the CVI actuation is potentially applicable in consideration of the above mentioned reporting exception, which would apply if the actuation occurred after the safety function had been already completed. The inspectors concluded that, in this case, since only the containment isolation valves in the containment purge ventilation system were already in their required closed positions (and not those in the radiation monitoring system), the CVI safety function had not already been completed, and thus the reporting exception did not apply.

In response to the inspectors' observations, the licensee initiated PER 417453, which resulted in this event being reported to the NRC on September 8, 2011, as EN# 47249.

Analysis.

The licensee's failure to adequately evaluate the CVI system actuation for reportability against the reporting criteria of 10 CFR 50.73 was a performance deficiency. This violation was determined to be applicable to traditional enforcement because of its potential to impact the ability of the NRC to perform its regulatory oversight function, and was therefore evaluated in accordance with the NRC Enforcement Policy. This issue was determined to be a Severity Level IV violation in accordance with Section 6.9.d.9 of the NRC Enforcement Policy. No cross-cutting aspect was assigned since traditional enforcement violations for which there are no associated ROP findings are not screened for cross-cutting aspects.

Enforcement.

10 CFR 50.73(a)(1) required that the licensee shall either submit an LER or provide a telephone notification to report an invalid system actuation under 50.73(a)(2)(iv) within 60 days after the discovery of the event. 10 CFR 50.73 (a)(2)(iv) (B)(2) required the reporting of any event or condition that resulted in actuation of a general containment isolation signal affecting containment isolation valves in more than one system or multiple main steam isolation valves. Contrary to the above, on July 5, 2011, the licensee failed to either submit an LER or provide a telephone notification to report an invalid system actuation under 50.73 (a)(2)(iv) within 60 days after the discovery of the event. Specifically, an invalid CVI signal, which affected containment isolation valves in more than one system, was actuated on May 5, 2011, and was not reported within 60 days of discovery of the event. Because the finding was of very low safety significance and has been entered into the licensee's CAP as PER 417453, this violation is being treated as an NCV, consistent with the NRC Enforcement Policy: NCV 05000328/2011004-01, "Failure to Report System Actuation."

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance tests associated with the nine work orders (WOs) listed below to assess whether procedures and test activities ensured system operability and functional capability. The inspectors reviewed the licensee's test procedure to evaluate whether: the procedure adequately tested the safety function(s)that may have been affected by the maintenance activity; the acceptance criteria in the procedure were consistent with information in the applicable licensing basis and/or design basis documents; and the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed the test data to determine whether test results adequately demonstrated restoration of the affected safety function(s).

Documents reviewed are listed in the Attachment. The inspectors completed nine samples.

• WO 112341448, Unit 2 volume control tank divert valve position

• WO 112589517, Unit 1 turbine stop valve limit switch

• WO 112461652, Unplanned LCO 3.6.3.a for dual indication of 2-FSV-43-251

• WO 112672265, All three turbine runback lights are not lit on 1-L-262

• WO 112540627, Dual light indication of 2-FSV-43-250

• WO 111857373, 2-PI-EBT-250-731.0 120V Vital Inverter 2-I Functional Test

• WO 112589517, Unit 1 turbine stop valve limit switch

• WO 112341448, Unit 2 volume control tank divert valve position

• WO 112462177, Replace the batteries on the Diesel Fire Pump

b. Findings

No findings were identified.

1R20 Refueling and Outage Activities

.1 Unit 1 Forced Outage

a. Inspection Scope

Following the automatic reactor trip of Unit 1 on July 20, 2011, the licensee maintained Unit 1 in Mode 3 until conditions to support restart were established on July 22, 2011. The inspectors reviewed the licensee's mode change checklists to verify that appropriate prerequisites were met prior to changing TS modes. The inspectors observed containment entry controls and reviewed Procedure 0-SI-OPS-000-011.0, "Containment Access Control During Modes 1-4," for the associated containment entries to ensure that all items that entered containment were removed so nothing would be left that could affect performance of the containment sump. The inspectors observed portions of the plant startup including reactor criticality and power ascension. This inspection satisfied one inspection sample for Outage Activities.

b. Findings

No findings were identified.

.2 Unit 1 Forced Outage

a. Inspection Scope

Following the automatic reactor trip of Unit 1 on August 18, 2011, the licensee maintained Unit 1 in Mode 3 until conditions to support restart were established on August 20, 2011. The inspectors reviewed the licensee's mode change checklists to verify that appropriate prerequisites were met prior to changing TS modes. The inspectors observed containment entry controls and reviewed Procedure 0-SI-OPS-000-011.0, "Containment Access Control During Modes 1-4," for the associated containment entries to ensure that all items that entered containment were removed so nothing would be left that could affect performance of the containment sump. The inspectors observed portions of the plant startup including reactor criticality and power ascension. This inspection satisfied one inspection sample for Outage Activities.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

For the seven surveillance tests identified below, the inspectors assessed whether the SSCs involved in these tests satisfied the requirements described in the TS surveillance requirements, the UFSAR, applicable licensee procedures, and whether the tests demonstrated that the SSCs were capable of performing their intended safety functions. This was accomplished by witnessing testing and/or reviewing the test data. Documents reviewed are listed in the Attachment. The inspectors completed seven samples.

In-Service Tests

• 1-SI-SXP-003-201.B, Motor Driven Auxiliary Feedwater Pump 1B-B Performance Test, Revision 15

• 2-SI-SXP-062-202.B, Boric Acid Transfer Pump 2B-B Performance Test, Revision 20 Routine Surveillance Tests

• 0-SI-OPS-085-011.0, Unit 2 Reactivity Control System Moveable Control Assemblies Functional Test at Full Power, Revision 33

• 1-SI-IFT-063-052.3, Functional Test of RWST Level Channel III Rack 10, Loop L-63-52 (L-915), Revision 6

• 0-SI-FPU-026-181.H, U0 Fire Hose Hydrostatic Test, Revision 10

• 1-SI-OPS-082-007.B, Electrical Power System Diesel Generator 1B-B, Revision 53

• 1-PI-NXX-085-001.0, Resetting Control Rod Fully Withdrawn Position, Revision 23

b. Findings

No findings were identified.

1EP6 Drill Evaluation

a. Inspection Scope

Resident inspectors evaluated the conduct of routine licensee emergency drills on July 19, 2011, and August 23, 2011, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation (PAR) development activities. The inspectors observed emergency response operations in the simulated control room to verify that event classification and notifications were done in accordance with EPIP-1, Emergency Plan Classification Matrix, Revision 46. The inspectors also attended the licensee critique of the drill to compare any inspector observed weakness with those identified by the licensee in order to verify whether the licensee was properly identifying deficiencies. The inspectors completed two samples.

b. Findings

No findings were identified.

RADIATION SAFETY

(RS)

Cornerstones: Occupational Radiation Safety (OS) and Public Radiation Safety (PS)

2RS4 Occupational Dose Assessment

a. Inspection Scope

External Dosimetry The inspectors reviewed National Voluntary Laboratory Accreditation Program (NVLAP) certification data (including thermoluminescent dosimeter (TLD) testing for neutron, gamma, and beta exposures) and discussed program guidance for storage, processing, and evaluation of results for active and passive personnel dosimeters currently in use. Comparisons between ED and TLD data were discussed in detail. The inspectors reviewed ED alarm logs and evaluated licensee assessment actions for selected alarm events. In addition, the inspectors toured the Independent Spent Fuel Storage Installation (ISFSI) and observed radiological controls, took independent surveys, and discussed neutron dose assessment with licensee staff.

Internal Dosimetry Program guidance (including derived air concentration (DAC)-hr tracking), instrument detection capabilities, and assessment results for internally deposited radionuclides were reviewed in detail. The inspectors reviewed selected in vivo (Whole Body Count) analyses from January 2011 to August 2011. Capabilities for collection and analysis of special bioassay samples were evaluated and discussed with licensee staff.

Special Dosimetric Situations The inspectors evaluated the licensee's use of multi-badging, extremity dosimetry, and dosimeter relocation within non-uniform dose rate fields and discussed worker monitoring in neutron areas with licensee staff. The inspectors also reviewed records of monitoring for declared pregnant workers from January 2010 to August 2011 and discussed monitoring guidance with dosimetry staff.

In addition, the adequacy of shallow dose assessments for selected Personnel Contamination Events occurring between January 2011 and August 2011 were reviewed and discussed.

Problem Identification and Resolution The inspectors reviewed and discussed selected Corrective Action Program (CAP) documents associated with occupational dose assessment. The inspectors evaluated the licensee's ability to identify and resolve the issues in accordance with procedure NPG-SPP-03.1, "Corrective Action Program", Rev. 2. The inspectors also discussed the scope of the licensee's internal audit program and reviewed recent assessment results.

Occupational dose assessment activities were evaluated against the requirements of UFSAR Section 12; TS Section 6; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in Section

2RS4 of the Attachment.

The inspectors completed 1 sample as required by IP 71124.04.

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

Radiation Monitoring Instrumentation During walk-downs of the auxiliary building and the RCA exit point, the inspectors observed installed radiation detection equipment.

These included area radiation monitors (ARMs), liquid and gaseous effluent monitors, personnel contamination monitors (PCMs), small article monitors (SAMs), and portal monitors (PMs). The inspectors observed the physical location of the components and noted their material condition.

In addition to equipment walk-downs, the inspectors reviewed source checks of various portable and fixed detection instruments, including ion chambers, teletectors, PCMs, SAMs, PMs, and a whole body counter (WBC). The inspectors also observed the performance of a process monitor channel operational test. The inspectors reviewed calibration records and evaluated alarm setpoint values for PCMs, PMs, effluent monitors, an ARM, a SAM, and a WBC. This included a sampling of instruments used for post-accident monitoring such as a containment high-range radiation monitor and effluent monitors for noble gas and iodine. The radioactive source used to calibrate an effluent monitor was evaluated for traceability to national standards. Calibration stickers on portable survey instruments were noted during inspection of the storage area for ready-to-use equipment. The most recent 10 CFR Part 61 analysis for dry active waste (DAW) was reviewed to determine if calibration and check sources are representative of the plant source term. The inspectors also reviewed countroom calibration records for a gamma spectroscopy germanium detector and a liquid scintillation detector.

Effectiveness and reliability of selected radiation detection instruments were reviewed against details documented in the following: 10 CFR Part 20; NUREG-0737, Clarification of TMI Action Plan Requirements; UFSAR Chapters 11 and 12; and applicable licensee procedures. Documents reviewed during the inspection are listed in section RS05 of the Attachment.

Problem Identification and Resolution The inspectors reviewed selected PER reports in the area of radiological instrumentation. The inspectors evaluated the licensee's ability to identify and resolve the issues in accordance with procedure NPG-SPP-03.1, Corrective Action Program, Rev. 2. Documents reviewed are listed in section RS05 of the Attachment.

The inspectors completed one

(1) sample as required by IP 71124.05.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

Event and Effluent Program Reviews The inspectors reviewed the 2009 and 2010 Annual Radiological Effluent Release Report (ARERR) documents for consistency with the requirements in the Offsite Dose Calculation Manual (ODCM) and TS details. Routine and abnormal effluent release results and reports, as applicable, were reviewed and discussed with responsible licensee representatives. Status of the radioactive gaseous and liquid effluent processing and monitoring equipment and activities, and changes thereto, as applicable, described in the UFSAR and current ODCM were discussed with responsible staff.

Walk-Downs and Observations The inspectors walked-down selected components of the gaseous and liquid discharge systems to ascertain material condition, configuration and alignment. Walkdowns included visual inspections of Auxiliary Building Vent Monitor (0-RE-90-101B), Shield Building Vent Monitor (0-RE-90-400), Waste Disposal System Liquid Discharge Monitor (O-RE-90-122), Containment Building Lower Compartment (1-RE-90-106), Containment Building Upper Compartment (1-RE-90-112), Essential Raw Cooling Water Discharge Monitors (O-RE-90-133,140 and O-RE-90-134, 141), Condenser Air Ejector (0-RE-90-99 and 256). Output displays for all radiation monitors were observed in the control room. The inspectors observed the material condition of abandoned in place liquid waste processing equipment for indications of degradation or leakage that could constitute a possible release pathway to the environment.

The inspectors also observed the collection and analysis of a liquid effluent sample from the waste monitor tank (WMT). Inspectors observed activities associated with maintenance on Essential Raw Cooling Water Discharge Monitors (O-RE-90-134, 141).

Inspectors observed implementation of compensatory sampling in response to removal from service.

Sampling and Analyses In addition to observing the collection of the samples from the WMT the inspector observed the preparation of the samples for counting, administrative processing and implementation of the liquid effluent release permit. The inspector noted independent verification of the permit results and concurrent verification of equipment manipulations performed to allow the release. The results of the chemistry count room's inter-laboratory comparison program were reviewed and discussed with licensee personnel.

Dose Calculations The inspectors discussed recent changes in reported dose values relative to previous ARERR reporting periods with an emphasis placed on Carbon-14 radionuclide source term quantities and resultant doses. The inspectors reviewed and evaluated waste gas decay tank (WGDT) releases and observed a liquid effluent release. The evaluations included review and discussion of set point determinations and dose calculation summaries for the past 18 months. Updated results for the most recent land use census data were evaluated against assumptions used to calculate offsite dose results. In addition, the inspectors reviewed selected abnormal release data and resultant dose calculations for Calendar Years (CYs) 2010 and 2011.

Effluent process and monitoring activities were evaluated against details and requirements documented in the UFSAR Sections 11 and 12; TS Sections 6.8 Procedures and Programs and 6.9 Reporting Requirements; ODCM Rev. 56; 10 CFR Part 20; 10 CFR, Appendix I to Part 50; and approved licensee procedures. In addition, ODCM and UFSAR changes since the last onsite inspection were reviewed against the guidance in NUREG-1301 and Regulatory Guide (RG) 1.109, RG 1.21, and RG 4.1.

Ground Water Protection Implementation The licensee's implementation of the Industry Ground Water Protection Initiative was reviewed for changes since the last inspection. Groundwater sampling results obtained since the last inspection were reviewed. Licensee response, evaluation, and follow-up to spills and leaks since the last inspection were reviewed in detail.

Problem Identification and Resolution The inspectors reviewed selected PER documents in the areas of effluent processing and groundwater protection. Specifically, inspectors reviewed an issue associated with excessive nitrogen use required to maintain GWD header pressure. The inspectors evaluated the licensee's ability to identify, characterize, prioritize, and resolve the identified issues in accordance with NPG-SPP-03.1, Corrective Action Program, Rev. 2 Documents reviewed are listed in Section

2RS6 of the Attachment.

The inspectors completed one

(1) sample as required by IP 71124.06.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program (REMP)

a. Inspection Scope

REMP Status and Results The inspectors reviewed and discussed recent changes applicable to Radiological Environmental and Meteorological Monitoring program activities detailed in the UFSAR, and ODCM. Environmental monitoring sample results presented in the Annual Radiological Environmental Operating Report (AREOR) documents issued for CYs 2009 and 2010 were reviewed and discussed. REMP vendor laboratory (Western Area Radiological Laboratory (WARL)) cross-check program results, and select current procedural guidance for offsite collection, processing and analysis of airborne particulate and iodine, broadleaf vegetation, and surface water samples were reviewed and discussed. Detection level sensitivities as documented within the AREOR for selected environmental media analyzed by the offsite environmental laboratory were reviewed. The AREOR environmental measurement results were reviewed for consistency with licensee ARERR data and evaluated for radionuclide concentration trends. Licensee actions for missed airborne monitoring samples were reviewed and discussed in detail.

Site Inspection The inspectors observed and discussed implementation of selected REMP monitoring and sample collection activities for atmospheric particulates and iodine, and observed locations of direct radiation measurements, broadleaf vegetation samples, and water and milk samples as specified in the current ODCM and applicable procedures. The inspectors observed equipment material condition and evaluated operability, including a review of flow rates and total sample volume results for the weekly airborne particulate filter and iodine cartridge change-outs at eight atmospheric sampling stations. In addition, the inspectors discussed broadleaf vegetation, milk, and surface water sampling for selected ODCM locations. Select surface water locations were verified and sample collection discussed. Thermo-luminescent dosimeter material condition and placement were observed at select ODCM locations. Monitoring and impact of licensee routine releases on offsite doses based on meteorological dispersion parameters and gardens locations identified in the most current land use census were reviewed in detail. Land use census results, actions for missed samples including compensatory measures, sediment sample collection/processing activities, and availability of replacement equipment were discussed with an environmental technician and knowledgeable licensee staff. In addition, sample pump calibration and maintenance records for selected environmental air samplers were reviewed.

The inspectors toured the primary meteorological tower and compared local data readouts with control room data. The inspectors observed the physical condition of the tower and associated instruments and discussed equipment operability, maintenance history, and backup power supplies with responsible licensee staff. For the meteorological measurements of wind speed, wind direction, and temperature, the inspectors reviewed applicable meteorological tower instrumentation semi-annual calibration records and evaluated meteorological measurement data recovery for CYs 2009 and 2010.

Procedural guidance, program implementation, quantitative analysis sensitivities, and environmental monitoring results were reviewed against 10 CFR Part 20; Appendix I to 10 CFR Part 50; TS Sections 6.8, 6.9, and 6.14; ODCM, Rev. 56; RG 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operation) - Effluent Streams and the Environment; and the Branch Technical Position, An Acceptable Radiological Environmental Monitoring Program - 1979. Licensee procedures and activities related to meteorological monitoring were evaluated against: ODCM; UFSAR Section 2; RG 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, and ANSI/ANS-2.5-1984, Standard for Determining Meteorological Information at Nuclear Power Sites. Documents reviewed are listed in Section 2RS07 of the Attachment.

Problem Identification and Resolution The inspectors reviewed selected CAP CR documents in the areas of environmental and meteorological monitoring. The inspectors evaluated the licensee's ability to identify, characterize, prioritize, and resolve the identified issues in accordance with NPG-SPP-03.1, Corrective Action Program, Rev. 0002 and NPG-SPP-03.1.4, Corrective Action Program Screening and Oversight, Rev.

0003.

The inspectors completed 1 sample as required by IP 71124.07.

b. Findings

No findings were identified.

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

Public Radiation Safety Cornerstone The inspectors reviewed the Radiological Control Effluent Release Occurrences PI results for the Public Radiation Safety Cornerstone from January 1, 2010, through July 31, 2011. For the assessment period, the inspectors reviewed cumulative and projected doses to the public and PIP documents related to Radiological Effluent Technical Specifications/ODCM issues including abnormal effluent releases. Documents reviewed are listed in sections

4OA1 and 2RS6 of the Attachment.

The inspectors completed one

(1) of the required samples for IP 71151.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Daily Review

a. Inspection Scope

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 CAP. This was accomplished by reviewing the description of each new PER and attending daily management review committee meetings.

b. Findings and Observations

No findings were identified.

4OA3 Event Follow-up

.1 Unit 1 Automatic Reactor Trip

a. Inspection Scope

On July 20, 2011, the inspectors responded to an automatic reactor trip of Unit 1 due to a load rejection caused by inadvertent closure of turbine governor valves. The inspectors evaluated plant status, mitigating actions, and the licensee's classification of the event, to enable the NRC to determine an appropriate NRC response. The inspectors discussed the trip with operations, engineering, and licensee management personnel to gain an understanding of the event and assess follow-up actions. The inspectors reviewed operator actions taken to determine whether they were in accordance with licensee procedures and TS, and reviewed unit and system indications to verify whether actions and system responses were as expected and designed. The inspectors also reviewed the initial licensee notifications to verify whether they met the requirements specified in NUREG-1022, "Event Reporting Guidelines." The event was reported to the NRC as event notification (EN) 47081 and documented in the licensee's corrective action program as PER 405141.

b. Findings

No findings were identified.

.2 Unit 1 Automatic Reactor Trip

a. Inspection Scope

On August 18, 2011, the inspectors responded to an automatic reactor trip of Unit 1 due to a momentary reactor coolant pump (RCP) undervoltage condition sensed on two RCPs. This was the result of the transfer of the 1A start bus to its alternate power source. The inspectors evaluated plant status, mitigating actions, and the licensee's classification of the event, to enable the NRC to determine an appropriate NRC response. The inspectors discussed the trip with operations, engineering, and licensee management personnel to gain an understanding of the event and assess follow-up actions. The inspectors reviewed operator actions taken to determine whether they were in accordance with licensee procedures and TS, and reviewed unit and system indications to verify whether actions and system responses were as expected and designed. The inspectors also reviewed the initial licensee notifications to verify whether they met the requirements specified in NUREG-1022, "Event Reporting Guidelines." The event was reported to the NRC as event notification (EN) 47169 and documented in the licensee's corrective action program as PER 419705.

b. Findings

No findings were identified.

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 review and inspection activities.

b. Findings

No findings were identified.

4OA6 Meetings

.1 Exit Meeting Summary

On October 4, 2011, the resident inspectors presented the inspection results to Mr. P. Simmons and other members of his staff, who acknowledged the findings. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.

On September 16, 2011, the inspectors discussed results of the onsite radiation protection inspection with Mr. J. Carlin, and other licensee representatives. The inspectors noted that proprietary information was reviewed during the course of the inspection but would not be included in the documented report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

J. Carlin, Site Vice President

S. Connors, Operations Manager

G. Cook, Site Licensing Manager

J. Cross, Chemistry Manager

A. Day, Radiation Protection Manager

R. Detwiler, Director, Safety and Licensing

C. Dieckmann, Manager, Maintenance

Z. Kitts, Licensing Engineer

K. Langdon, Plant Manager

A. Little, Site Security Manager

S. McCamy, Quality Assurance Manager

P. Noe, Site Engineering Director

P. Pratt, Assistant to Operations Manager

J. Reidy, Operations Superintendant

P. Simmons, Work Control Manager

D. Sutton, Licensing Engineer

N. Thomas, Licensing Engineer

C. Ware, Training Director

K. Wilkes, Operations Support Superintendent

NRC personnel

S. Lingam, Project Manager, Office of Nuclear Reactor Regulation

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000328/2011004-01 NCV Failure to Report System Actuation (Section 1R15)