IR 05000440/2014003

IR 05000440-14-003, on 04/01/2014 - 06/30/2014, Perry Nuclear Power Plant; Post-Maintenance Testing

ML14220A509
Person / Time
Site:	Perry
Issue date:	08/08/2014
From:	Michael Kunowski NRC/RGN-III/DRP/B5
To:	Harkness E FirstEnergy Nuclear Operating Co
References
IR-14-003
Download: ML14220A509 (50)

Text

ust 8, 2014

SUBJECT:

PERRY NUCLEAR POWER PLANT NRC INTEGRATED INSPECTION REPORT 05000440/2014003

Dear Harkness:

On June 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a baseline inspection at your Perry Nuclear Power Plant.

On July 16, the NRC inspectors discussed the results of this inspection with you and members of your staff. The inspectors documented the results of this inspection in the enclosed inspection report. The NRC inspectors documented one finding of very low safety significance (Green) in this report. The finding involved a violation of NRC r equirements. The NRC is treating this violation as a non-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violation or significance of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector Office at Perry Nuclear Power Plant. 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 Perry Nuclear Power Plant.

E. Harkness -2-

In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Rules of Practice," a copy of this letter and 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 Agencywide Documents Access and Management Sy stem (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Michael Kunowski, Chief Branch 5 Division of Reactor Projects

Docket No. 50-440 License No. NPF-58

Enclosure:

Inspection Report 05000440/2014003 w/Attachment: Supplemental Information

REGION III Docket No: 50-440 License No: NPF-58 Report No: 05000440/2014003 Licensee: FirstEnergy Nuclear Operating Company (FENOC) Facility: Perry Nuclear Power Plant, Unit 1 Location: North Perry, Ohio Dates: April 1 through June 30, 2014 Inspectors: M. Marshfield, Senior Resident Inspector J. Nance, Resident Inspector J. Jandovitz, Project Engineer J. Beavers, Reactor Inspector (Acting)

M. Phalen, Senior Health Physicist

Approved by: M. Kunowski, Chief Branch 5 Division of Reactor Projects

SUMMARY OF FINDINGS

Inspection Report 05000440/2014003, 04/01/2014 - 06/30/2014, Perry Nuclear Power Plant;

Post-Maintenance Testing. This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. One Green finding was identified by the inspectors. The finding was considered a non-cited violation (NCV) of NRC regulations. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, "Aspects Within the Cross-Cutting Areas," effective January 1, 2014. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy, dated July 9, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5.

Cornerstone: Mitigating Systems

Green.

A self-revealed finding of very low safety significance and associated non-cited violation (NCV) of 10 CFR, Part 50, Appendix B, Criterion XVI, "Corrective Action," was identified on May 7, 2014, for the failure to correct a condition adverse to quality.

Specifically, the licensee failed to correct a lube oil leak, identified by operations personnel on April 12, 2014, during the monthly run of the Division 2 Emergency Diesel Generator (EDG). As discussed in Condition Report (CR) 2014-06755, the leak was from a Swagelok fitting on the turbocharger supply line and at a rate of less than an ounce per hour. The CR was closed to a work order to complete repairs. On May 7, the next scheduled surveillance run of the Division 2 EDG occurred. The leak had not been repaired and, during the run, became progressively worse resulting in an unplanned (emergency) shutdown of the diesel and the diesel being declared inoperable. The leak was quantified as approximately a gallon per hour at the time of the shutdown (CR 2014-08487). The line was repaired and the diesel was returned to operable status on May 8. The licensee promptly evaluated the other EDGs and determined that a common cause condition did not exist. The failure was caused by fatigue cracking of the Swagelok fitting due to misalignment during installation. A root cause evaluation was conducted by the licensee.

The finding was determined to be more than minor 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. The finding was determined to be of very low safety significance because there was no design deficiency, no actual loss of safety function, and no single train loss of safety function for greater than the Technical Specification (TS)-allowed outage time. This finding has a cross-cutting aspect in the area of problem identification and resolution evaluation, for the failure to thoroughly evaluate the issue and ensure that the resolution addressed the cause and extent of condition when identified in April 2014 (P.2).

(Section 1R19)

3

REPORT DETAILS

Summary of Plant Status

The plant began the inspection period at 100 percent power. On May 16, 2014, at 10:00 p.m., Perry Nuclear Power Plant lowered power to 55 percent to support work on the 5B heater normal drain valve and other steam plant work. The reduction in power was to support dose reduction for the workers. Power was restored to 100 percent at 10:00 p.m. on May 20. On May 21, a steam leak in the secondary plant forced power to be lowered to 85 percent. Following repairs to the 6A and 6B feedwater heaters' feedwater relief valves, the plant was restored to full power at 3:52 a.m. on May 27. With the exception of minor reductions in power to support routine surveillances, the plant remained at full power for the remainder of the quarter.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Summer Seasonal Readiness Preparations

a. Inspection Scope

The inspectors performed a review of the licensee's preparations for summer weather for selected systems, including conditions that could lead to an extended drought. During the inspection, the inspectors focused on plant specific design features and the licensee's procedures used to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the Updated Safety Analysis Report (USAR) and performance requirements for systems selected for inspection and verified that operator actions were appropriate as specified by plant-specific procedures. Documents reviewed are listed in the Attachment to this report. The inspectors also reviewed corrective action program (CAP) items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into the CAP in accordance with station corrective action procedures. The inspectors' reviews focused specifically on the following plant systems:

• circulating water pumphouse ventilation system;

• steam tunnel cooling system;

• turbine building ventilation system, and;

• radwaste control room heating, ventilation, and air conditioning (HVAC) system. This inspection constituted one seasonal adverse weather sample as defined in Inspection Procedure (IP) 71111.01-05.

b. Findings

No findings were identified.

.2 Readiness of Offsite and Alternate AC Power Systems

a. Inspection Scope

The inspectors verified that plant features and procedures for operation and continued availability of offsite and alternate alternating current (AC) power systems during adverse weather were appropriate. The inspectors reviewed the licensee's procedures affecting these areas and the communications protocols between the transmission system operator (TSO) and the plant to verify that the appropriate information was being exchanged when issues arose that could impact the offsite power system. Examples of aspects considered in the inspectors' review included:

• coordination between the TSO and the plant during off-normal or emergency events;

• explanations for the events;

• estimates of when the offsite power system would be returned to a normal state; and

• notifications from the TSO to the plant when the offsite power system was returned to normal. The inspectors also verified that plant procedures addressed measures to monitor and maintain availability and reliability of bot h the offsite AC power system and the onsite alternate AC power system prior to or during adverse weather conditions. Specifically, the inspectors verified that the procedures addressed the following:

• actions to be taken when notified by the TSO that the post-trip voltage of the offsite power system at the plant would not be acceptable to assure the continued operation of the safety-related loads without transferring to the onsite power supply;

• compensatory actions identified to be performed if it would not be possible to predict the post-trip voltage at the plant for the current grid conditions;

• re-assessment of plant risk based on maintenance activities which could affect grid reliability, or the ability of the transmission system to provide offsite power; and

• communications between the plant and the TSO when changes at the plant could impact the transmission system, or when the capability of the transmission system to provide adequate offsite power was challenged. Documents reviewed are listed in the Attachment to this report. The inspectors also reviewed CAP items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into the CAP in accordance with station corrective action procedures. This inspection constituted one readiness of offsite and alternate AC power systems sample as defined in IP 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

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

• high pressure core spray (HPCS) diesel generator (DG) system;

• emergency service water (ES W) 'A' train; and

• emergency closed cooling (ECC) system 'B' train. 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 system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, the USAR, Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports (CRs), 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 three partial system walkdown samples as defined in IP 71111.04-05.

b. Findings

No findings were identified.

.2 Semi-Annual Complete System Walkdown

a. Inspection Scope

On June 6, the inspectors performed a complete system alignment inspection of the standby liquid control system to verify the functional capability of the system. This system was selected because it was considered both safety significant and risk significant in the licensee's probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment lineups; electrical power availability; system pressure and temperature indications, as appropriate; component labeling; component lubrication; component and equipment cooling; hangers and supports; operability of support systems; and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and current WOs was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the CAP database to ensure that system equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the Attachment to this report. These activities constituted one complete system walkdown sample as defined in IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

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; 0FH-3 (Fuel Handling Building 620' Elevation);

• Fire Zone; 0IB-2 (Intermediate Building 599' Elevation);

• Fire Zone; CC-1A, 1B, & 1C (Control Complex 574' Elevation);

• Fire Zone; 1DG-1A & 1CC-3A (Division 2 Emergency Diesel Generator (EDG)

Room and Switchgear Room 620' Elevation); and

• Fire Zone; 1AB-2 (Auxiliary Building 599'). 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 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 five quarterly fire protection inspection samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R06 Flooding

a. Inspection Scope

The inspectors reviewed selected risk-important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the USAR, engineering calculations, and abnormal operating procedures, to identify licensee commitments. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the CAP with respect to past flood-related items to assess the adequacy of the corrective actions. The inspectors walked down the auxiliary building 574' level and auxiliary building sump system to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments. Documents reviewed are listed in the Attachment to this report. This inspection constituted one internal flooding sample as defined in IP 71111.06-05.

b. Findings

No findings were identified.

1R07 Annual Heat Sink Performance

a. Inspection Scope

The inspectors reviewed the licensee's testing of ECC heat exchanger 'A,' and residual heat removal 'B' and 'D' heat exchangers, to verify that potential deficiencies did not mask the licensee's ability to detect degr aded performance, to identify any common cause issues that had the potential to increase risk, and to ensure that the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspectors reviewed the licensee's observations and acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. Inspectors also verified that test acceptance criteria considered differences between test conditions, design conditions, and testing conditions. At the time of the inspection two calculations remained incomplete for review and subsequently documented in CR 2014-10498. Documents reviewed are listed in the Attachment to this document. This annual heat sink performance inspection constituted one sample as defined in IP 71111.07-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

On May 12, the inspectors observed a crew of licensed operators in the plant's simulator during licensed operator requalification training to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and 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 simulator sample as defined in IP 71111.11.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk

a. Inspection Scope

On May 21, the inspectors observed control room activities in response to a report made by maintenance personnel external to the plant of steam coming from the vents of the heater bay building. This was an activity that required heightened awareness or was related to increased risk. 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 (if applicable);

• correct use and implementation of procedures;

• control board (or equipment) manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications (evaluation indicated that none were required although several off-normal instructions were entered because of this event). The performance in these areas was compared to pre-established operator action expectations, procedural compliance, and task completion requirements. Documents reviewed are listed in the Attachment to this report. This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated degraded performance issues involving:

• R42 - direct current systems; and

• R43 - EDG engine, air and oil systems. 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 two 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

a. Inspection Scope

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

• ECC heat exchanger 'B' temperature control valve blown fuse during light bulb change caused ECC 'B' inoperability;

• hazardous environmental conditions associated with repairs to offgas brine cooling fluid replacement after leak during maintenance;

• reactor protection system shift to alternate power supply when motor generator set 'A' voltage output began to fail;

• emergent risk associated with steam leak indications in heater bay building; and

• emergent risk associated with reactor recirculating flow control valves lockup. 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 during this inspection 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 Functionality Assessments

a. Inspection Scope

The inspectors reviewed the following issues:

• loss of offsite power testing methodology for motor control center (MCC) determined to be incorrect for MCC switchgear and battery room ventilation exhaust systems (M23/M24);

• continued operation with offgas brine cooling system inoperable;

• ESW pump 'B' operability after smoke indications on shutdown; and

• Division 1 EDG potential for similar mode lube oil failure operability review.

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 risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and USAR 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 Attachment to this report. These operability inspections constituted four samples as defined in IP 71111.15-05.

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

The inspectors reviewed the following modifications:

• replacement of trichloroethylene in offgas brine cooling system; and

• temporary modification of discharge piping from feedwater heaters 6A and 6B feedwater relief valves on the downstream side. The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening against the design basis, the USAR, and the TSs, as applicable, to verify that the modification did not affect the operability or availability of the affected system(s). The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modifications were installed as directed and consistent with the design control documents; the modifications operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. Lastly, the inspectors discussed the plant modification with operations, engineering, and training personnel to ensure that the individuals were aware of how the operation with the plant modification in place could impact overall plant performance. Documents reviewed are listed in the Attachment to this report. This inspection constituted one temporary modification sample and one permanent plant modification sample as defined in IP 71111.18-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

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

• spent fuel pool cooling heat exchanger valve replacements;

• HVAC train 'B' system repairs;

• HPCS DG soakback pump replacement;

• EDG 'B' system retest after lube oil leak repairs;

• control room radiation monitor maintenance;

• Division 1 EDG system retest after lube oil pressure low trip repairs; and

• rod control information system post-maintenance retest. These activities were selected based upon the structure, system, or component's 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 USAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance 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 seven post-maintenance testing samples as defined in IP 71111.19-05.

b. Findings

Introduction:

A self-revealed finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," was identified on May 7, 2014, for a failure to correct a condition adverse to quality.

Specifically, the licensee failed to correct a lube oil leak on the Division 2 EDG identified on April 12, 2014, and subsequently during the next monthly surveillance run, the leak degraded and the EDG was declared inoperable.

Description:

On April 12, 2014, operators identified an oil leak on the turbocharger supply line at the completion of the monthly run of the Division 2 EDG. Condition Report 2014-06755 identified the leak as coming from a Swagelok fitting and quantified the leak as less than an ounce per hour. The CR was closed to a WO to complete repairs. On May 7, the next scheduled surveillance run of the Division 2 EDG occurred. The leak had not been repaired and during the run became progressively worse, resulting in an unplanned (emergency) shutdown of the diesel at 11:46 a.m. and the diesel being declared inoperabe. The leak was quantified as being approximately a gallon per hour at the time of the shutdown (CR 2014-08487). The lube oil line was subsequently repaired and the diesel was declared operable at 4:22 a.m. on May 8. The licensee promptly evaluated the other EDGs and determined that a common cause condition did not exist. The failure was subsequently identified as caused by fatigue cracking of the Swagelok fitting due to misalignment during installation. A root cause evaluation was conducted by the licensee.

As discussed in the root cause evaluation, the initial CR in April 2014 had been closed to a WO to complete the repairs. However, the WO was incorrectly screened and not given an appropriate priority for repairs: the work was scheduled for November 3, 2014, but should have been scheduled for work in the next week or so. The leak was not identified as being on "power block equipment" and therefore received no significant priority to be repaired. The root cause investigation determined that the root cause was tubing installation practices at Perry. A contributing cause was identified for the failure of the WO screening process when the leak was originally reported.

The inspectors determined that the licensee had correctly identified a condition adverse to quality on April 12 associated with the tubing on the Division 2 EDG. However, no actions were taken to correct the condition prior to the subsequent surveillance run on May 7 when the leak significantly increased and directly resulted in the EDG being declared inoperable. Repairs and retesting were completed and the EDG was declared operable on May 8.

Analysis:

The inspectors determined that the failure to correct a condition adverse to quality on the Division 2 EDG was a performance deficiency that could be evaluated using the SDP. The inspectors determined that this issue was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone 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, the failure to correct the Division 2 EDG lube oil leak resulted in an unplanned (emergency) shutdown of the diesel and the diesel being declared inoperable during a subsequent surveillance run, less than a month after the initial identification.

The inspectors determined that this issue impacted the Mitigating Systems cornerstone and utilized IMC 0609, "Significance Determination Process," Appendix A, Exhibit 2, dated June 19, 2012, to evaluate the significance. The finding was determined to be of very low safety significance (Green) because there was no design deficiency, no actual loss of safety function, and no single train loss of safety function for greater than the TS-allowed outage time. This finding has a cross-cutting aspect in the area of problem identification and resolution evaluation for the failure to thoroughly evaluate the issue and ensure that the resolution addressed the cause and extent of condition when identified in April 2014 (P.2).

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that conditions adverse to quality, such as deficiencies and non-conformances, are promptly identified and corrected.

Contrary to the above, from April 12 through May 7, 2014, the licensee failed to correct a condition adverse to quality. Specifically, a leak on the lube oil supply line to the Division 2 EDG turbocharger was identified by operations department personnel during a monthly surveillance run on April 12. The leak was entered into the CAP as CR 2014-06755 but not corrected until after further degradation of the leak during a subsequent monthly surveillance run on May 7 that resulted in an emergency shutdown of the EDG and the EDG being declared inoperable.

Because this violation was of very low safety significance and it was entered into the licensee's CAP (CR 2014-08487), it is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000440/2014003-01: Failure to Promptly Correct a Condition Adverse to Quality on Division 2 EDG). Corrective actions for this issue included immediate va lidation that the condition was not a common cause failure for the Division 1 EDG and repair of the cracked tubing with additional corrective actions to improve the site program for installing Swagelok fittings.

1R22 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:

• Surveillance Instruction (SVI)-E51-T2001; RCIC Pump and Valve Operability Test (inservice testing);

• SVI-E12-T2002; RHR (Residual Heat Removal) B Pump and Valve Operability Test (routine testing);

• SVI-C71-T0039; MSIV (Main Steam Isolation Valve) Closure Channel Functional (isolation valve testing);

• SVI-E22-T1319; Diesel Generator Start and Load Division 3 (routine testing); and

• SVI-E31-T0086-A; NUMAC LDM Calibration for 1E1-N700A (reactor coolant system leak detection inspection sample); The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

• did preconditioning occur;

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

• acceptance criteria were clearly stated, demonstrated operational readiness, and were 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 USAR, 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 inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers 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 two routine surveillance testing samples, one inservice testing sample, one reactor coolant system leak detection inspection sample, and one isolation valve sample as defined in IP 71111.22, Sections-02 and-05.

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

This inspection constituted one complete sample as defined IP 71124.01-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed all licensee performance indicators for the Occupational Radiation Safety Cornerstone for follow-up. The inspectors reviewed the results of radiation protection program audits (e.g., licensee's quality assurance audits or other independent audits). The inspectors reviewed any reports of operational occurrences related to occupational radiation safety since the last inspection. The inspectors reviewed the results of the audit and operational report reviews to gain insights into overall licensee performance.

b. Findings

No findings were identified.

.2 Radiological Hazard Assessment (02.02)

a. Inspection Scope

The inspectors determined if there have been changes to plant operations since the last inspection that may result in a significant new radiological hazard for onsite workers or members of the public. The inspectors evaluated whether the licensee assessed the potential impact of these changes and has implemented periodic monitoring, as appropriate, to detect and quantify the radiological hazard. The inspectors reviewed the last two radiological surveys from selected plant areas and evaluated whether the thoroughness and frequency of the surveys were appropriate for the given radiological hazard. The inspectors conducted walkdowns of the facility, including radioactive waste (radwaste) processing, storage, and handling areas, to evaluate material conditions, and performed independent radiation measurements to verify conditions. The inspectors selected the following radiologically risk-significant work activities that involved exposure to radiation:

• process/ship radwaste liners less than or equal to 10 milliRem/hour;

• fuel pool cooling/clean-up (FPCC) heat exchanger room, hold pump room, surge tanks, recirc pumps; and

• FPCC heat exchanger valve repairs. For these work activities, the inspectors assessed whether the pre-work surveys performed were appropriate to identify and quantify the radiological hazard and to establish adequate protective measures. The inspectors evaluated the radiological survey program to determine if hazards were properly identified, including the following:

• identification of hot particles;

• the presence of alpha emitters;

• the potential for airborne radioactive materials, including the potential presence of transuranics and/or other hard-to-detect radioactive materials (This evaluation may include licensee planned entry into non-routinely entered areas subject to previous contamination from failed fuel.);

• the hazards associated with work activities that could suddenly and severely increase radiological conditions and that the licensee had established a means to inform workers of changes that could significantly impact their occupational dose;

and

• severe radiation field dose gradients that could result in non-uniform exposures of the body. The inspectors observed work in potential airborne areas and evaluated whether the air samples were representative of the breathing air zone. The inspectors evaluated whether continuous air monitors were located in areas with low background to minimize false alarms and were representative of actual work areas. The inspectors evaluated the licensee's program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne.

b. Findings

No findings were identified.

.3 Instructions to Workers (02.03)

a. Inspection Scope

The inspectors selected various containers holding non-exempt licensed radioactive materials that could cause unplanned or inadvertent exposure of workers and assessed whether the containers were labeled and controlled in accordance with 10 CFR 20.1904, "Labeling Containers," or met the requirements of 10 CFR 20.1905(g), "Exemptions To Labeling Requirements." The inspectors reviewed the following radiation work permits (RWPs) used to access high radiation areas and evaluated the specified work control instructions or control barriers:

• RWP 140060; Process/Ship Radwaste Liners Less Than or Equal to 10 milliRem/hour; Revision 00;

• RWP 140065; FPCC Heat Exchanger Room, Hold Pump Room, Surge Tanks, Recirc Pumps; Revision 00; and

• RWP 140072; Fuel Pool Cooling/Clean-Up Heat Exchanger Valve Repairs; Revision 00. For these RWPs, the inspectors assessed whether allowable stay times or permissible dose (including from the intake of radioactive material) for radiologically significant work under each RWP were clearly identified.

The inspectors evaluated whether electronic personal dosimeter alarm setpoints were in conformance with survey indications and plant policy. The inspectors reviewed selected occurrences where a worker's electronic personal dosimeter noticeably malfunctioned or alarmed. The inspectors evaluated whether workers responded appropriately to the off-normal condition. The inspectors assessed whether the issue was included in the CAP and dose evaluations were conducted as appropriate. For work activities that could suddenly and severely increase radiological conditions, the inspectors assessed the licensee's means to inform workers of changes that could significantly impact their occupational dose.

b. Findings

No findings were identified.

.4 Contamination and Radioactive Material Control (02.04)

a. Inspection Scope

The inspectors observed locations where the licensee monitors potentially contaminated material leaving the radiological control area and inspected the methods used for control, survey, and release from these areas. The inspectors observed the performance of personnel surveying and releasing material for unrestricted use and evaluated whether the work was performed in accordance with plant procedures and whether the procedures were sufficient to control the spread of contamination and prevent unintended release of radioactive materials from the site. The inspectors assessed whether the radiation monitoring instrumentation had appropriate sensitivity for the type(s) of radiation present. The inspectors reviewed the licensee's criteria for the survey and release of potentially contaminated material. The inspectors evaluated whether there was guidance on how to respond to an alarm that indicated the presence of licensed radioactive material. The inspectors reviewed the licensee's procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters. The inspectors assessed whether or not the licensee has established a de facto "release limit" by altering the instrument's typical sensitivity through such methods as raising the energy discriminator level or locating the instrument in a high radiation background area. The inspectors selected several sealed sources from the licensee's inventory records and assessed whether the sources were accounted for and verified to be intact. The inspectors evaluated whether any transactions, since the last inspection, involving nationally tracked sources were reported in accordance with 10 CFR 20.2207.

b. Findings

No findings were identified.

.5 Radiological Hazards Control and Work Coverage (02.05)

a. Inspection Scope

The inspectors evaluated ambient radiological conditions (e.g., radiation levels or potential radiation levels) during tours of the facility. The inspectors assessed whether the conditions were consistent with applicable posted surveys, RWPs, and worker briefings. The inspectors evaluated the adequacy of radiological controls, such as required surveys, radiation protection job coverage (including audio and visual surveillance for remote job coverage), and contamination controls. The inspectors evaluated the licensee's use of electronic personal dosimeters in high noise areas as high radiation

area monitoring devices. The inspectors assessed whether radiation monitoring devices were placed on the individual's body consistent with the licensee's procedures. The inspectors assessed whether the dosimeter was placed in the location of highest expected dose or that the licensee properly employed an NRC-approved method of determining effective dose equivalent. The inspectors reviewed the application of dosimetry to effectively monitor exposure to personnel in high radiation work areas with significant dose rate gradients. The inspectors reviewed the following RWPs for work within airborne radioactivity areas with the potential for individual worker internal exposures:

• RWP 140060; Process/Ship Radwaste Liners Less Than or Equal to 10 milliRem/hour; Revision 00;

• RWP 140065; FPCC Heat Exchanger Room, Hold Pump Room, Surge Tanks, Recirc Pumps; Revision 00;

• RWP 140072; Fuel Pool Cooling/Clean-up Heat Exchanger Valve Repairs; Revision 00;

• RWP 140075; Remove/Install Four Bundle Rack (Lower Pool); Revision 00; and

• RWP 140076; Dry Cask Storage Project; Revision 00. For these RWPs, the inspectors evaluated airborne radioactive controls and monitoring, including potential for significant airborne levels (e.g., grinding, grit blasting, system breaches, entry into tanks, cubicles, and reactor cavities). The inspectors assessed barrier (e.g., tent or glove box) integrity and temporary high-efficiency particulate air ventilation system operation. The inspectors examined the licensee's physical and programmatic controls for highly activated or contaminated materials (i.e., nonfuel) stored within spent fuel and other storage pools. The inspectors assessed whether appropriate controls (i.e., administrative and physical controls) were in place to preclude inadvertent removal of these materials from the pool. The inspectors examined the posting and physical controls for selected high radiation areas and very high radiation areas to verify conformance with the occupational exposure control effectiveness performance indicator (PI).

b. Findings

No findings were identified.

.6 Risk-Significant High Radiation Area and Very High Radiation Area Controls (02.06)

a. Inspection Scope

The inspectors discussed with the radiation protection manager the controls and procedures for high risk, high radiation areas and very high radiation areas. The inspectors discussed methods employed by the licensee to provide stricter control of very high radiation area access as specified in 10 CFR 20.1602, "Control of Access to Very High Radiation Areas," and Regulatory Guide 8.38, "Control of Access to High and Very High Radiation Areas of Nuclear Plants." The inspectors assessed whether any changes to licensee procedures substantially reduced the effectiveness and level of worker protection.

The inspectors discussed the controls in place for special areas that had the potential to become very high radiation areas during certain plant operations with first-line health physics supervisors (or equivalent positions having backshift health physics oversight authority). The inspectors assessed whether these plant operations required communication beforehand with the health physics group, so as to allow corresponding timely actions to properly post, control, and monitor the radiation hazards including re-access authorization. The inspectors evaluated licensee controls for very high radiation areas and areas with the potential to become very high radiation areas to ensure that an individual was not able to gain unauthorized access to the very high radiation areas.

b. Findings

No findings were identified.

.7 Radiation Worker Performance (02.07)

a. Inspection Scope

The inspectors observed radiation worker performance with respect to stated radiation protection work requirements. The inspectors assessed whether workers were aware of the radiological conditions in their workplace and the RWP controls/limits in place, and whether their performance reflected the level of radiological hazards present. The inspectors reviewed radiological problem reports since the last inspection that found the cause of the event to be human performance errors. The inspectors evaluated whether there was an observable pattern traceable to a similar cause. The inspectors assessed whether this perspective matched the corrective action approach taken by the licensee to resolve the reported problems. The inspectors discussed with the radiation protection manager any problems with the corrective actions planned or taken.

b. Findings

No findings were identified.

.8 Radiation Protection Technician Proficiency (02.08)

a. Inspection Scope

The inspectors observed the performance of the radiation protection technicians with respect to all radiation protection work r equirements. The inspectors evaluated whether technicians were aware of the radiological conditions in their workplace and the RWP controls/limits, and whether their performance was consistent with their training and qualifications with respect to the radiological hazards and work activities. The inspectors reviewed radiological problem reports since the last inspection that found the cause of the event to be radiation protection technician error. The inspectors

evaluated whether there was an observable pattern traceable to a similar cause. The inspectors assessed whether this perspective matched the corrective action approach taken by the licensee to resolve the reported problems.

b. Findings

No findings were identified.

.9 Problem Identification and Resolution (02.09)

a. Inspection Scope

The inspectors evaluated whether problems associated with radiation monitoring and exposure control were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee's CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involve radiation monitoring and exposure controls.

The inspectors assessed the licensee's process for applying operating experience to the plant.

b. Findings

No findings were identified.

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

This inspection constituted a partial sample as defined in IP 71124.02-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed pertinent information regarding plant collective exposure history, current exposure trends, and ongoing or planned activities in order to assess current performance and exposure challenges. The inspectors reviewed the plant's 3-year rolling average collective exposure. The inspectors reviewed the site-specific trends in collective exposures and source term measurements. The inspectors reviewed site-specific procedures associated with maintaining occupational exposures as-low-as-is-reasonably achievable (ALARA), which included a review of processes used to estimate and track exposures from specific work activities.

b. Findings

No findings were identified.

.2 Radiological Work Planning (02.02)

a. Inspection Scope

The inspectors selected the following work activities of the exposure significance.

• process/ship radwaste liners less than or equal to 10 milliRem/hour;

• FPCC heat exchanger room, hold pump room, surge tanks, recirc pumps;

• FPCC heat exchanger valve repairs;

• remove/install four bundle rack (lower pool); and

• dry cask storage project. The inspectors reviewed the ALARA work activity evaluations, exposure estimates, and exposure mitigation requirements. The inspectors determined whether the licensee reasonably grouped the radiological work into work activities based on historical precedence, industry norms, and/or special circumstances. The inspectors assessed whether the licensee's planning identified appropriate dose mitigation features, considered alternate mitigation features, and defined reasonable dose goals. The inspectors evaluated whether the licensee's ALARA assessment has taken into account decreased worker efficiency from use of respiratory protective devices and/or heat stress mitigation equipment (e.g., ice vests). The inspectors determined whether the licensee's work planning considered the use of remote technologies (e.g., teledosimetry, remote visual monitoring, and robotics) as a means to reduce dose and the use of dose reduction insights from industry operating experience and plant-specific lessons learned. The inspectors assessed the integration of ALARA requirements into work procedure and RWP documents.

b. Findings

No findings were identified.

.3 Verification of Dose Estimates and Exposure Tracking Systems (02.03)

a. Inspection Scope

The inspectors reviewed the assumptions and basis (including dose rate and man-hour estimates) for the current annual collective exposure estimate for reasonable accuracy for select ALARA work packages. The inspectors reviewed applicable procedures to

determine the methodology for estimating exposures from specific work activities and the intended dose outcome. The inspectors evaluated whether the licensee established measures to track, trend, and, if necessary, to reduce occupational doses for ongoing work activities. The inspectors assessed whether trigger points or criteria were established to prompt additional reviews and/or additional ALARA planning and controls. The inspectors evaluated the licensee's method of adjusting exposure estimates, or re-planning work, when unexpected changes in scope or emergent work were encountered. The inspectors assessed whether adjustments to exposure estimates (intended dose) were based on sound radiation protection and ALARA principles or if they were just adjusted to account for failures to control the work. The inspectors evaluated whether the frequency of these adjustments called into question the adequacy of the original ALARA planning process.

b. Findings

No findings were identified.

.4 Problem Identification and Resolution (02.06)

a. Inspection Scope

The inspectors evaluated whether problems associated with ALARA planning and controls were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee's CAP.

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation

This inspection constituted a partial sample as defined in IP 71124.05-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the plant USAR to identify radiation instruments associated with monitoring area radiological conditions, including airborne radioactivity, process streams, effluents, materials/articles, and workers. Additionally, the inspectors reviewed the instrumentation and the associated TS requirements for post-accident monitoring instrumentation, including instruments used for remote emergency assessment. The inspectors reviewed a listing of in-service survey instrumentation, including air samplers and small article monitors, along with instruments used to detect and analyze workers' external contamination. Additionally, the inspectors reviewed personnel

contamination monitors and portal monitors, including whole body counters, to detect workers' internal contamination. The inspectors reviewed this list to assess whether an adequate number and type of instruments were available to support operations. The inspectors reviewed licensee and third-party evaluation reports of the radiation monitoring program since the last inspection. These reports were reviewed for insights into the licensee's program and to aid in selecting areas for review ("smart sampling"). The inspectors reviewed procedures that governed instrument source checks and calibrations, focusing on instruments used for monitoring transient high radiological conditions, including instruments used for underwater surveys. The inspectors reviewed the calibration and source check procedures for adequacy and as an aid to smart sampling. The inspectors reviewed the area radiation monitor alarm setpoint values and setpoint bases as provided in the TSs and the USAR. The inspectors reviewed effluent monitor alarm setpoint bases and the calculational methods provided in the Offsite Dose Calculation Manual (ODCM).

b. Findings

No findings were identified.

.2 Walkdowns and Observations (02.02)

a. Inspection Scope

The inspectors selected portable survey instruments that were in use or available for issuance and assessed calibration and source check stickers for currency as well as instrument material condition and operability. The inspectors observed licensee staff performance as the staff demonstrated source checks for various types of portable survey instruments. The inspectors assessed whether high-range instruments were source checked on all appropriate scales. The inspectors walked down area radiation monitors and continuous air monitors to determine whether they were appropriately positioned relative to the radiation sources or areas they were intended to monitor. Selectively, the inspectors compared monitor response (via local or remote control room indications) with actual area conditions for consistency. The inspectors selected personnel contami nation monitors, portal monitors, and small article monitors and evaluated whether the periodic source checks were performed in accordance with the manufacturer's recommendations and the licensee's procedures.

b. Findings

No findings were identified.

.3 Calibration and Testing Program (02.03) Portal Monitors, Personnel Contamination Monitors, and Small Article Monitors

a. Inspection Scope

For each type of these instruments used onsite, the inspectors assessed whether the alarm setpoint values were reasonable under the circumstances to ensure that licensed material was not released from the site. The inspectors reviewed the calibration documentation for each instrument selected and discussed the calibration methods with the licensee to determine consistency with the manufacturer's recommendations.

b. Findings

No findings were identified.

Portable Survey Instruments, Area Radiation Monitors, Electronic Dosimetry, and Air Samplers/Continuous Air Monitors

a. Inspection Scope

The inspectors reviewed calibration documentation for at least one of each type of instrument. For portable survey instruments and area radiation monitors, the inspectors reviewed detector measurement geometry and calibration methods and had the licensee demonstrate use of its instrument calibrator, as applicable. The inspectors compared instrument readings with an NRC survey in strument if problems were suspected. As available, the inspectors selected portable survey instruments that did not meet acceptance criteria during calibration or source checks to assess whether the licensee had taken appropriate corrective action for instruments found significantly out of calibration (e.g., greater than 50 percent). The inspectors evaluated whether the licensee evaluated the possible consequences of instrument use since the last successful calibration or source check.

b. Findings

No findings were identified.

Instrument Calibrator

a. Inspection Scope

As applicable, the inspectors reviewed the current output values for the licensee's portable survey and area radiation monitor instrument calibrator unit(s). The inspectors assessed whether the licensee periodically measured calibrator output over the range of the instruments used through measurements by ion chamber/electrometer. The inspectors assessed whether the measuring devices had been calibrated by a facility using National Institute of Standards and Technology traceable sources and whether corrective factors for these measur ing devices were properly applied by the licensee in its output verification.

b. Findings

No findings were identified.

Calibration and Check Sources

a. Inspection Scope

The inspectors reviewed the licensee's 10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste," source term to assess whether calibration sources used were representative of the types and energies of radiation encountered in the plant.

b. Findings

No findings were identified.

.4 Problem Identification and Resolution (02.04)

a. Inspection Scope

The inspectors evaluated whether problems associated with radiation monitoring instrumentation were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee's CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involved radiation monitoring instrumentation.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and

Transportation (71124.08) This inspection constituted one complete sample as defined in IP 71124.08-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the solid radioactive waste system description in the USAR, the process control program, and the recent radiological effluent release report for

information on the types, amounts, and processing of radioactive waste disposed. The inspectors reviewed the scope of any quality assurance audits in this area since the last inspection to gain insights into the licensee's performance and inform the "smart sampling" inspection planning.

b. Findings

No findings were identified.

.2 Radioactive Material Storage (02.02)

a. Inspection Scope

The inspectors selected areas where containers of radioactive waste were stored and evaluated whether the containers were labeled in accordance with 10 CFR 20.1904, "Labeling Containers," or controlled in accordance with 10 CFR 20.1905, "Exemptions to Labeling Requirements," as appropriate. The inspectors assessed whether the radioactive material storage areas were controlled and posted in accordance with the requirements of 10 CFR Part 20, "Standards for Protection Against Radiation." For materials stored or used in the controlled or unrestricted areas, the inspectors evaluated whether they were secured against unauthorized removal and controlled in accordance with 10 CFR 20.1801, "Security of Stored Material," and 10 CFR 20.1802, "Control of Material Not in Storage," as appropriate. The inspectors evaluated whether the licensee established a process for monitoring the impact of long-term storage (e.g., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water) that was sufficient to identify potential unmonitored, unplanned releases or nonconformance with waste disposal requirements. The inspectors selected containers of stored radioactive material and assessed for signs of swelling, leakage, and deformation.

b. Findings

No findings were identified.

.3 Radioactive Waste System Walkdown (02.03)

a. Inspection Scope

The inspectors walked down accessible portions of select radioactive waste processing systems to assess whether the current system configuration and operation agreed with the descriptions in the USAR, ODCM, and process control program. The inspectors reviewed administrative and/or physical controls (i.e., drainage and isolation of the system from other systems) to assess whether the equipment which was not in service or was abandoned in place would not contribute to an unmonitored release path and/or affect operating systems or be a source of unnecessary personnel exposure. The inspectors assessed whether the licensee reviewed the safety significance of systems and equipment abandoned in place in accordance with 10 CFR 50.59, "Changes, Tests, and Experiments." The inspectors reviewed the adequacy of changes made to the radioactive waste processing systems since the last inspection. The inspectors evaluated whether changes from what was described in the USAR were reviewed and documented in accordance with 10 CFR 50.59, as appropriate, and to assess the impact on radiation doses to members of the public. The inspectors selected processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers and assessed whether the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the process control program, and provided representative samples of the waste product for the purposes of waste classification as described in 10 CFR 61.55, "Waste Classification."

For those systems that provided tank recirculation, the inspectors evaluated whether the tank recirculation procedures provided sufficient mixing. The inspectors assessed whether the licensee's process control program correctly described the current methods and procedures for dewatering and waste stabilization (e.g., removal of freestanding liquid).

b. Findings

No findings were identified.

.4 Waste Characterization and Classification (02.04)

a. Inspection Scope

The inspectors selected the following radioactive waste streams for review:

• bead resin;

• dry active waste; and

• powder resin. For the waste streams listed above, the inspectors assessed whether the licensee's radiochemical sample analysis results (i.e., "10 CFR Part 61" analysis) were sufficient to support radioactive waste characterization as required by 10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste." The inspectors evaluated whether the licensee's use of scaling factors and calculations to account for difficult-to-measure radionuclides was technically sound and based on current 10 CFR Part 61 analysis for the selected radioactive waste streams. The inspectors evaluated whether changes to plant operational parameters were taken into account to:

(1) maintain the validity of the waste stream composition data between the annual or biennial sample analysis update; and

(2) assure that waste shipments continued to meet the requirements of 10 CFR Part 61 for the waste streams selected above. The inspectors evaluated whether the licensee established and maintained an adequate quality assurance program to ensure compliance with the waste classification and characterization requirements of 10 CFR 61.55 and 10 CFR 61.56, "Waste Characteristics."

b. Findings

No findings were identified.

.5 Shipment Preparation (02.05)

a. Inspection Scope

The inspectors observed shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness. The inspectors assessed whether the requirements of applicable transport cask certificate of compliance had been met. The inspectors evaluated whether the receiving licensee was authorized to receive the shipment packages. The inspectors evaluated whether the licensee's procedures for cask loading and closure procedures were consistent with the vendor's current approved procedures. The inspectors observed radiation workers during the conduct of radioactive waste processing and radioactive material shipment preparation activities. The inspectors assessed whether the shippers were knowledgeable of the shipping regulations and whether shipping personnel demonstrated adequate skills to accomplish the package preparation requirements for public transport with respect to:

• As appropriate, the licensee's response to NRC Bulletin 79-19, "Packaging of Low-Level Radioactive Waste for Transport and Burial," dated August 10, 1979; and

• Title 49 CFR Part 172, "Hazardous Materials Table, Special Provisions, Hazardous Materials Communication, Emergency Response Information, Training Requirements, and Security Plans," Subpart H, "Training."

b. Findings

No findings were identified.

.6 Shipping Records (02.06)

a. Inspection Scope

The inspectors evaluated whether the shipping documents indicated the proper shipper name; emergency response information and a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and United Nations number for the following radioactive shipments:

• 2014-1000; Radioactive Material Shipment Chemical Decontamination Resin;

• 2014-1001; Radioactive Waste Shipment Bead Resin;

• 2014-1002; Radioactive Waste Shipment Bead Resin;

• 2014-1003; Radioactive Material Shipment Drum Cask of Dry Active Waste; and

• 2014-1011; Radioactive Waste Shipment Powered Resin. Additionally, the inspectors assessed whether the shipment placarding was consistent with the information in the shipping documentation.

b. Findings

No findings were identified.

.7 Identification and Resolution of Problems (02.07)

a. Inspection Scope

The inspectors assessed whether problems associated with radioactive waste processing, handling, storage, and transportation were being identified by the licensee at an appropriate threshold, were properly characterized, and were properly addressed for resolution in the licensee's CAP. Additionally, the inspectors evaluated whether the corrective actions were appropriate for a selected sample of problems documented by the licensee that involved radioactive waste processing, handling, storage, and transportation. The inspectors reviewed results of selected audits performed since the last inspection of this program and evaluated the adequacy of the licensee's corrective actions for issues identified during those audits.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Occupational Radiation Safety, and Public Radiation Safety

4OA1 Performance Indicator Verification

.1 Safety System Functional Failures

a. Inspection Scope

The inspectors sampled licensee submittals for the Safety System Functional Failures performance indicator (PI) for the second quarter of 2013 through the first quarter of 2014. To determine the accuracy of the PI data reported, definitions and guidance contained in Nuclear Energy Institute (NEI) document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, were used. The inspectors reviewed the licensee's operator logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and NRC IRs to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database 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 one safety system functional failures (MS05) sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance

Index - Emergency AC Power System

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI) - Emergency AC (Alternating Current) Power System PI for the second quarter of 2013 through the first quarter of 2014. To determine the accuracy of the PI data reported, definitions and guidance contained in NEI 99-02 were used. The inspectors reviewed the licensee's operator logs, MSPI derivation reports, issue reports, event reports, and NRC IRs 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 since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database 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 one MSPI emergency AC power system (MS06) sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Mitigating Systems Performance Index - High Pressure Injection Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - High Pressure Injection System PI for the second quarter of 2013 through the first quarter of 2014. To determine the accuracy of the PI data reported, definitions and guidance contained in NEI 99-02 were used. The inspectors reviewed the licensee's operator logs, MSPI derivation reports, issue reports, event reports, and NRC IRs 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 since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database 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 one MSPI high-pressure injection system (MS07) sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.4 Reactor Coolant System-Specific Activity

a. Inspection Scope

The inspectors sampled licensee submittals for the reactor coolant system-specific activity PI for third quarter 2013 through the first quarter 2014. The inspectors used PI definitions and guidance contained in the NEI 99-02 to determine the accuracy of the PI data reported for this period. The inspectors reviewed the licensee's reactor coolant system chemistry samples, TS requirements, issue reports, event reports, and NRC Integrated IRs to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database 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 a reactor coolant system sample. Documents reviewed are listed in the Attachment to this report. This inspection constituted one reactor coolant sys tem-specific activity (BI01) sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.5 Occupational Exposure Control Effectiveness

a. Inspection Scope

The inspectors sampled licensee submittals for the Occupational Exposure Control Effectiveness PI for the third quarter 2013 through the first quarter 2014. The inspectors used PI definitions and guidance contained in NEI 99-02 to determine the accuracy of the PI data reported during this period. The inspectors reviewed the licensee's assessment of the PI for occupational radiation safety to determine if the indicator-related data were 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 sample for occupational exposure control effectiveness (OR01) as defined in IP 71151-05.

b. Findings

No findings were identified.

.6 Radiological Effluent Technical Specification/Offsite Dose Calculation Manual

Radiological Effluent Occurrences

a. Inspection Scope

The inspectors sampled licensee submittals for the Radiological Effluent Technical Specification (RETS)/ODCM radiological effluent occurrences PI for the fourth quarter 2013 through the first quarter 2014. The inspectors used PI definitions and guidance contained in NEI 99-02 to determine the accuracy of the PI data reported during this period. The inspectors reviewed the licensee's issue report database 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 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 to this report. This inspection constituted one sample of RETS/ODCM radiological effluent occurrences (PR01) as defined in IP 71151 05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of Items Entered into the Corrective Action Program

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 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 Corrective Action Program 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.

.3 Selected Issue Follow-Up Inspection:

Limited Apparent Cause Analysis of Division 1 EDG Trip Lube Oil Pressure

a. Inspection Scope

During a review of items entered in the licensee's CAP, the inspectors reviewed a corrective action item documenting a limited apparent cause evaluation of the Division 1 EDG Trip Lube Oil Pressure alarm in February 2014. The same alarm occurred again in May. The inspectors reviewed corrective actions scheduled and implemented as a part of the corrective actions for radiological work control and radiological work planning. The inspectors assessed whether adequate attention was being given to timely implementation of corrective actions. The inspectors evaluated whether attributes for the corrective action document itself included:

(1) a complete and accurate identification of the problem statement;

(2) timeliness of the licensee's review was commensurate with the safety significance;

(3) evaluation and disposition of performance issues was complete; and

(4) the licensee reviewed the issue for generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences. The response and corrective actions were found to be in process and compliance. This review constituted one in-depth problem identification and resolution sample as defined in IP 71152-05.

b. Findings

No findings were identified.

.4 Selected Issue Follow-Up Inspection:

Maintenance Rule Issue Analysis with Fire Protection System

a. Inspection Scope

During a review of items entered in the licensee's CAP, the inspectors reviewed CRs related to diesel fire pump issues, including an item documenting an underground piping failure of the fire water system during diesel fire pump testing in June 2014. The inspectors evaluated whether attributes for the corrective action document itself included identification and documentation of maintenance rule (10 CFR 50.65) evaluations when directed by the management review board. The inspectors also reviewed the licensee's maintenance rule characterization of the fire protection system as (a)(2), given documented concerns with the fire protection program by the licensee's oversight group and nuclear review board over the past 2 years. The fire protection system had been rated as white (acceptable) in the licensee's System Health Report since the 1 st quarter of 2011 with 10 functions identified by the maintenance rule. The response and corrective actions were found to be in process and compliance. This review constituted one in-depth problem identification and resolution sample as defined in IP 71152-05.

b. Findings

No findings were identified.

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

.1 Toxic Gas in the Offgas Building and Turbine Power Complex

a. Inspection Scope

The inspectors reviewed the plant's response to an Unusual Event declaration for toxic gas because of human performance errors during maintenance on several offgas cooling valves for the offgas charcoal bed cooling system. Maintenance personnel were adding packing to several valves, work which was planned to be done on a drained system, but was performed at the last minute without draining the system. The leak occurred due to ejection of in-place packing. The work force had completed similar work of adding packing in the past without isolation and did not question the process. The root cause identified that station personnel did not consider the packing ring addition as a system breach. The workers immediately left the area and the system was subsequently stabilized. Following controlled removal of all fluids from the system, the valves were repaired and several other leaks corrected, and the system was returned to service. In addition, significant corrective actions were put in place as a result of the root cause investigation, under CR 2014-06160, to improve licensee performance in the area of work preparation and execution. 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) 050004402014-001-00:

Failure to Comply with Technical Specification 3.4.11 - Reactor Coolant System Pressure/Temperature Limits This event was initially identified during an NRC Problem Identification and Resolution team inspection in November of 2013. The licensee was determined to have operated the reactor, during startups and heatups, not in compliance with TS 3.4.11, Reactor Coolant Pressure and Temperature Limits. The issue was determined to not be a significant safety concern but rather a non-compliance and failure of the licensee to submit a license amendment request to correct the deficiency in the TS. The plant initiated CR 2013-18689 and completed a full apparent cause review. The licensee issued a standing order to direct strict compliance with the current TS as written and on June 23, 2014, issued license amendment request L-14-150, "Request for Licensing Action to Amend Technical Specification 3.4.11, 'RCS Pressure and Temperature (P/T)

Limits,'" to improve the TS so that operations would be allowed to occur in the future at pressures below zero pounds per square inch gauge. The inspectors determined that no additional deficiencies were identified by the licensee. 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.

4OA6 Management Meetings

.1 Exit Meeting Summary

On July 16, 2014, the inspectors presented the inspection results to Mr. Harkness, the Site Vice-President, 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

On June 20, 2014, inspection results for the areas of radiological hazard assessment and exposure controls; occupational ALARA planning and controls; radiation monitoring instrumentation; radioactive solid waste processing and radioactive material handling, storage, and transportation; and reactor coolant system-specific activity, occupational exposure control effectiveness, and RETS/ODCM radiological effluent occurrences performance indicator verification were discussed with Mr. J. Ellis, Director of Maintenance. 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.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

E. Harkness, Site Vice-President

D. Hamilton, Site Operations Director

T. Brown, Performance Improvement Director

D. Reeves, Site Engineering Director

J. Ellis, Acting Maintenance Director

LIST OF ITEMS

Opened and Closed

05000440/2014003-01 NCV Failure to Promptly Correct a Condition Adverse to Quality

on Division 2 EDG

(Section 1R19)

Closed

050004402014-001-00 LER Failure to Comply with Technical Specification 3.4.11 -

Reactor Coolant System Pressure/Temperature Limits

(Section 4OA3.2)

Discussed

None

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