IR 05000369/2014002: Difference between revisions

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=Text=
=Text=
{{#Wiki_filter:ril 30, 2014
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION ril 30, 2014


==SUBJECT:==
==SUBJECT:==
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On March 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your McGuire Nuclear Station Units 1 and 2. On April 10, 2014, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
On March 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your McGuire Nuclear Station Units 1 and 2. On April 10, 2014, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.


NRC inspectors documented three findings of very lo w safety significance (Green) in this report. Two of these findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violations or the significance of these findings, 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 the McGuire Nuclear Station. Also, if you disagree with a cross-cutting aspect assignment 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 II; and the NRC Resident Inspector at the McGuire Nuclear Station.
NRC inspectors documented three findings of very low safety significance (Green) in this report.


Additionally, as we informed you in the fourth quarter 2013 NRC integrated inspection report, cross-cutting aspects identified in the last six months of 2013 using the previous terminology were being converted in accordance with the cross-reference in Inspection Manual Chapter 0310. Section 4OA5 of the enclosed report documents the conversion of these cross-cutting aspects which will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review. 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 Agencywide Document Access and Managem ent System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Two of these findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violations or the significance of these findings, 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 the McGuire Nuclear Station. Also, if you disagree with a cross-cutting aspect assignment 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 II; and the NRC Resident Inspector at the McGuire Nuclear Station.
 
Additionally, as we informed you in the fourth quarter 2013 NRC integrated inspection report, cross-cutting aspects identified in the last six months of 2013 using the previous terminology were being converted in accordance with the cross-reference in Inspection Manual Chapter 0310. Section 4OA5 of the enclosed report documents the conversion of these cross-cutting aspects which will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review. 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 Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Sincerely,
Sincerely,
/RA/ Gerald J. McCoy, Chief Reactor Projects Branch 1 Division of Reactor Projects  
/RA/
 
Gerald J. McCoy, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-369, 50-370 License Nos.: NPF-9, NPF-17
Docket Nos.: 50-369, 50-370 License Nos.: NPF-9, NPF-17  


===Enclosure:===
===Enclosure:===
NRC Integrated Inspection Report 05000369/2014002 and 05000370/2014002 w/Attachment - Supplemental Information  
NRC Integrated Inspection Report 05000369/2014002 and 05000370/2014002 w/Attachment - Supplemental Information


REGION II==
REGION II==
 
Docket Nos.: 50-369, 50-370 License Nos.: NPF-9, NPF-17 Report Nos.: 05000369/2014002, 05000370/2014002 Licensee: Duke Energy Carolinas, LLC Facility: McGuire Nuclear Station, Units 1 and 2 Location: Huntersville, NC 28078 Dates: January 1, 2014, through March 31, 2014 Inspectors: J. Zeiler, Senior Resident Inspector J. Heath, Resident Inspector Approved by: Gerald McCoy, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
Docket Nos.: 50-369, 50-370  
 
License Nos.: NPF-9, NPF-17  
 
Report Nos.: 05000369/2014002, 05000370/2014002  
 
Licensee: Duke Energy Carolinas, LLC  
 
Facility: McGuire Nuclear Station, Units 1 and 2  
 
Location: Huntersville, NC 28078  
 
Dates: January 1, 2014, through March 31, 2014  
 
Inspectors: J. Zeiler, Senior Resident Inspector J. Heath, Resident Inspector  
 
Approved by: Gerald McCoy, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure  


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
IR05000369/2014-002, IR05000370/2014-002; 01/01/2014 - 03/31/2014; McGuire Nuclear Station, Units 1 and 2; Fire Protection and Follow-Up of Events and Notices of Enforcement Discretion
IR05000369/2014-002, IR05000370/2014-002; 01/01/2014 - 03/31/2014; McGuire Nuclear


The report covered a three month period of inspection by the resident inspectors. Three Green findings, two of which were determined to involve non-cited violations (NCVs) of NRC requirements, were identified. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within The Cross-Cutting Areas, dated December 19, 2013. 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.
Station, Units 1 and 2; Fire Protection and Follow-Up of Events and Notices of Enforcement Discretion The report covered a three month period of inspection by the resident inspectors. Three Green findings, two of which were determined to involve non-cited violations (NCVs) of NRC requirements, were identified. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within The Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs 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: Initiating Events===
===Cornerstone: Initiating Events===
: '''Green.'''
: '''Green.'''
A self-revealing finding (FIN) was identified for the licensee's failure to implement adequate design control measures for the rod control power supply modification which resulted in the loss of 24VDC power in the 1AC rod control power cabinet.
A self-revealing finding (FIN) was identified for the licensees failure to implement adequate design control measures for the rod control power supply modification which resulted in the loss of 24VDC power in the 1AC rod control power cabinet.


The inspectors determined that the licensee's failure to implement adequate design control measures was more than minor because it affected the Design Control attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective, in that, the insufficient margin in the rod control power supply OVP function caused a multiple drop rod event which resulted in a reactor trip. This finding was determined to have very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. A cross-cutting aspect was not assigned because the performance deficiency does not reflect current licensee performance. (Section 4OA3)  
The inspectors determined that the licensees failure to implement adequate design control measures was more than minor because it affected the Design Control attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective, in that, the insufficient margin in the rod control power supply OVP function caused a multiple drop rod event which resulted in a reactor trip. This finding was determined to have very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. A cross-cutting aspect was not assigned because the performance deficiency does not reflect current licensee performance. (Section 4OA3)


===Cornerstone: Mitigating Systems===
===Cornerstone: Mitigating Systems===
: '''Green.'''
: '''Green.'''
An NRC-identified NCV of the McGuire Unit 1 and Unit 2 Renewed Facility Operating License Condition 2.C.4, Fire Protection Program (FPP), was identified for the licensee's failure to adequately control the storage of transient combustibles in the 2A residual heat removal (ND)/containment spray (NS) heat exchanger room near safe shutdown equipment in accordance with the FPP requirements. The licensee initiated immediate corrective actions to evaluate the transient combustible fire loading and remove all the unapproved transient combustibles from the area. This condition was placed in the licensee's corrective action program (CAP).
An NRC-identified NCV of the McGuire Unit 1 and Unit 2 Renewed Facility Operating License Condition 2.C.4, Fire Protection Program (FPP), was identified for the licensees failure to adequately control the storage of transient combustibles in the 2A residual heat removal (ND)/containment spray (NS) heat exchanger room near safe shutdown equipment in accordance with the FPP requirements. The licensee initiated immediate corrective actions to evaluate the transient combustible fire loading and remove all the unapproved transient combustibles from the area. This condition was placed in the licensees corrective action program (CAP).


The licensee's failure to control the storage of transient combustibles in accordance with procedure NSD 313 was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective in that a fire involving transient combustibles could have affected nearby power cables and motor operator for valve 2ND-58A which provides a safe shutdown mitigation function. The finding was determined to have very low safety significance (Green) because it did not affect the ability of the reactor to reach and maintain cold shutdown condition. This finding had a cross cutting aspect of Teamwork in the Human Performance area because multiple groups were responsible for bringing the transient combustibles into the area and the individuals failed to effectively communicate and coordinate their activities to ensure that transient combustible control processes were appropriately implemented (H.4). (Section 1R05.1)
The licensees failure to control the storage of transient combustibles in accordance with procedure NSD 313 was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective in that a fire involving transient combustibles could have affected nearby power cables and motor operator for valve 2ND-58A which provides a safe shutdown mitigation function. The finding was determined to have very low safety significance (Green) because it did not affect the ability of the reactor to reach and maintain cold shutdown condition. This finding had a cross cutting aspect of Teamwork in the Human Performance area because multiple groups were responsible for bringing the transient combustibles into the area and the individuals failed to effectively communicate and coordinate their activities to ensure that transient combustible control processes were appropriately implemented (H.4). (Section 1R05.1)
: '''Green.'''
: '''Green.'''
An NRC-identified NCV of the McGuire Unit 1 and Unit 2 Renewed Facility Operating License Condition 2.C.4, FPP, was identified for the licensee's failure to adequately control the storage of transient combustibles in waste receptacles equipped with self-extinguishing fire lids in accordance with the FPP requirements. The licensee took actions to correct all waste receptacles in the plant that were filled beyond the manufacturer's specification or had loosely fitted lids. This condition was placed in the licensee's corrective action program.
An NRC-identified NCV of the McGuire Unit 1 and Unit 2 Renewed Facility Operating License Condition 2.C.4, FPP, was identified for the licensees failure to adequately control the storage of transient combustibles in waste receptacles equipped with self-extinguishing fire lids in accordance with the FPP requirements. The licensee took actions to correct all waste receptacles in the plant that were filled beyond the manufacturers specification or had loosely fitted lids. This condition was placed in the licensees corrective action program.


The licensee's failure to control the storage of transient combustibles in accordance with the requirements of NSD-313 was more than minor because it was associated with the  
The licensees failure to control the storage of transient combustibles in accordance with the requirements of NSD-313 was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective in that the self-extinguishing function was not retained which could allow the spread of the fire and adversely affect mitigating system equipment in the area. The finding was determined to be of very low safety significance (Green) because it did not affect the ability of the reactor to reach and maintain cold shutdown conditions. A cross-cutting aspect was not assigned because the performance deficiency does not reflect current licensee performance. (Section 1R05.2)
 
Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective in that the self-extinguishing function was not retained which could allow the spread of the fire and adversely affect mitigating system equipment in the area. The finding was determined to be of very low safety significance (Green) because it did not affect the ability of the reactor to reach and maintain cold shutdown conditions. A cross-cutting aspect was not assigned because the performance deficiency does not reflect current licensee performance. (Section 1R05.2)


=REPORT DETAILS=
=REPORT DETAILS=
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==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity  
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity


{{a|1R01}}
{{a|1R01}}
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====a. Inspection Scope====
====a. Inspection Scope====
Impending Adverse Weather Conditions: The inspectors reviewed the effectiveness of the licensee's cold weather protection program during extreme cold weather conditions experienced January 6-7, and January 21-23, 2014. This included field walkdowns to assess the functionality and reliability of risk significant freeze protection equipment associated with the Unit 1 and Unit 2 refueling water storage tank level instrumentation, Unit 1 and Unit 2 auxiliary feedwater instrumentation, and the "A," "B," and "C" fire pump rooms. The inspectors verified the implementation of applicable action required in procedure PT/0/B/4700/070, On Demand Freeze Protection Verification Checklist, and discussed the details of specific severe cold weather compensatory measures with operations and maintenance personnel. Documents reviewed are listed in the  
Impending Adverse Weather Conditions: The inspectors reviewed the effectiveness of the licensee's cold weather protection program during extreme cold weather conditions experienced January 6-7, and January 21-23, 2014. This included field walkdowns to assess the functionality and reliability of risk significant freeze protection equipment associated with the Unit 1 and Unit 2 refueling water storage tank level instrumentation, Unit 1 and Unit 2 auxiliary feedwater instrumentation, and the A, B, and C fire pump rooms. The inspectors verified the implementation of applicable action required in procedure PT/0/B/4700/070, On Demand Freeze Protection Verification Checklist, and discussed the details of specific severe cold weather compensatory measures with operations and maintenance personnel. Documents reviewed are listed in the
.
.


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====a. Inspection Scope====
====a. Inspection Scope====
Partial Walkdowns: The inspectors performed a partial walkdown of the following four systems to assess the operability of redundant or diverse trains and components when safety equipment was inoperable. The inspectors focused on discrepancies that could impact the function of the system and potentially increase risk. The inspectors reviewed applicable operating procedures and walked down control systems components to verify selected breakers, valves, and support equipment were in the correct position to support system operation. Documents reviewed are listed in the Attachment.
Partial Walkdowns: The inspectors performed a partial walkdown of the following four systems to assess the operability of redundant or diverse trains and components when safety equipment was inoperable. The inspectors focused on discrepancies that could impact the function of the system and potentially increase risk. The inspectors reviewed applicable operating procedures and walked down control systems components to verify selected breakers, valves, and support equipment were in the correct position to support system operation. Documents reviewed are listed in the Attachment.
* 2A ND pump while the 2B ND pump was out of service for scheduled maintenance
* 2A ND pump while the 2B ND pump was out of service for scheduled maintenance
* 1B emergency diesel generator (EDG) while the 1A EDG was out of service for scheduled maintenance and testing
* 1B emergency diesel generator (EDG) while the 1A EDG was out of service for scheduled maintenance and testing
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====a. Inspection Scope====
====a. Inspection Scope====
Fire Protection Walkdowns: The inspectors walked down accessible portions of the following five plant areas to determine if they were consistent with the Updated Final Safety Analysis Report (UFSAR) and the fire protection program for defense in depth features. The features assessed included the licensee's control of transient combustible material and ignition sources, fire detection and suppression capabilities, firefighting equipment, and passive fire features such as fire barriers. The inspectors also reviewed the licensee's compensatory measures for fire deficiencies to determine if they were commensurate with the significance of the deficiency. The inspectors reviewed the fire plans for the areas selected to determine if they were consistent with the fire protection program and presented an adequate firefighting strategy. Documents reviewed are listed in the Attachment.
Fire Protection Walkdowns: The inspectors walked down accessible portions of the following five plant areas to determine if they were consistent with the Updated Final Safety Analysis Report (UFSAR) and the fire protection program for defense in depth features. The features assessed included the licensees control of transient combustible material and ignition sources, fire detection and suppression capabilities, firefighting equipment, and passive fire features such as fire barriers. The inspectors also reviewed the licensees compensatory measures for fire deficiencies to determine if they were commensurate with the significance of the deficiency. The inspectors reviewed the fire plans for the areas selected to determine if they were consistent with the fire protection program and presented an adequate firefighting strategy. Documents reviewed are listed in the Attachment.
* 1A and 1B EDG rooms (Fire Areas 5 and 6)
* 1A and 1B EDG rooms (Fire Areas 5 and 6)
* Auxiliary building elevation 767 (Fire Area 25)
* Auxiliary building elevation 767 (Fire Area 25)
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=====Introduction:=====
=====Introduction:=====
An NRC-identified Green NCV of the McGuire Unit 1 and Unit 2 Renewed Facility Operating License Condition 2.C.4, Fire Protection Program (FPP), was identified for the licensee's failure to adequately control the storage of transient combustibles in the 2A ND/NS heat exchanger room near safe shutdown equipment in accordance with the FPP requirements.
An NRC-identified Green NCV of the McGuire Unit 1 and Unit 2 Renewed Facility Operating License Condition 2.C.4, Fire Protection Program (FPP), was identified for the licensees failure to adequately control the storage of transient combustibles in the 2A ND/NS heat exchanger room near safe shutdown equipment in accordance with the FPP requirements.


=====Description:=====
=====Description:=====
During a walkdown of Unit 2 auxiliary building room 785 (Fire Area 14) containing the 2A ND/NS heat exchangers and other safety-related safe shutdown equipment, the inspectors observed more than 15 pounds of transient combustibles in the room within about 3 feet of the power cables and motor operator for valve 2ND-58A which provides a flowpath for cold leg recirculation during design basis accident conditions. The transient combustibles included several bags of cloth rags, overfilled waste receptacles, nylon and plastic bags, plastic tools and containers, rolls of duct tape, electronic equipment and energized power strips, and an assortment of other combustible rubber and cloth waste materials. The ongoing work activity in the room involved multiple licensee departments and each was responsible for bringing various transient combustibles into the room to support the activities. Procedure NSD 313, Control of Transient Fire Loads, Rev. 14, required that work related ordinary transient combustibles be stored in established temporary housekeeping zones and if the quantity of these combustibles was greater than 15 pounds (the fire hazard analysis limit) or not separated by prescribed distances (in this case, 3 feet) from plant equipment susceptible to fire damage, a transient fire load evaluation must be completed and approved by the site fire protection engineer. The inspectors identified that a housekeeping zone was not established for the work activities in the room and a transient fire load evaluation had not been completed and approved by the fire protection engineer. The licensee initiated immediate corrective actions to evaluate the transient combustible fire loading and remove all the unapproved transient combustibles from the area.
During a walkdown of Unit 2 auxiliary building room 785 (Fire Area 14)containing the 2A ND/NS heat exchangers and other safety-related safe shutdown equipment, the inspectors observed more than 15 pounds of transient combustibles in the room within about 3 feet of the power cables and motor operator for valve 2ND-58A which provides a flowpath for cold leg recirculation during design basis accident conditions. The transient combustibles included several bags of cloth rags, overfilled waste receptacles, nylon and plastic bags, plastic tools and containers, rolls of duct tape, electronic equipment and energized power strips, and an assortment of other combustible rubber and cloth waste materials. The ongoing work activity in the room involved multiple licensee departments and each was responsible for bringing various transient combustibles into the room to support the activities. Procedure NSD 313, Control of Transient Fire Loads, Rev. 14, required that work related ordinary transient combustibles be stored in established temporary housekeeping zones and if the quantity of these combustibles was greater than 15 pounds (the fire hazard analysis limit) or not separated by prescribed distances (in this case, 3 feet) from plant equipment susceptible to fire damage, a transient fire load evaluation must be completed and approved by the site fire protection engineer. The inspectors identified that a housekeeping zone was not established for the work activities in the room and a transient fire load evaluation had not been completed and approved by the fire protection engineer. The licensee initiated immediate corrective actions to evaluate the transient combustible fire loading and remove all the unapproved transient combustibles from the area.


=====Analysis:=====
=====Analysis:=====
The licensee's failure to control the storage of transient combustibles in the 2A ND/NS heat exchanger room without the proper evaluation in accordance with procedure NSD 313 was a performance deficiency (PD). The PD was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective in that a fire involving transient combustibles could have affected nearby power cables and motor operator for valve 2ND-58A which provides a safe shutdown mitigation function. The finding was screened in accordance with NRC Inspection Manual (IMC) 0609, Significance Determination Process, dated June 2, 2011, Attachment 4, Initial Characterization of Findings, dated June 19, 2012. Using the guidance in IMC 0609, Appendix F, Attachment 1, Fire Protection SDP Phase 1 Worksheet, dated September 20, 2013, the finding was assigned a category of Fire Prevention and Administrative Controls. The inspectors determined the finding to be of very low safety significance (Green) because it did not affect the ability of the reactor to reach and maintain cold shutdown condition, in that, a postulated fire in the 2A ND/NS heat exchanger room did not present the possibility of impacting more than one train of safe shutdown equipment. This finding had a cross cutting aspect of Teamwork in the Human Performance area because multiple groups were responsible for bringing the transient combustibles into the area and the individuals failed to effectively communicate and coordinate their activities to ensure that transient combustible control processes were appropriately implemented (H.4).
The licensees failure to control the storage of transient combustibles in the 2A ND/NS heat exchanger room without the proper evaluation in accordance with procedure NSD 313 was a performance deficiency (PD). The PD was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective in that a fire involving transient combustibles could have affected nearby power cables and motor operator for valve 2ND-58A which provides a safe shutdown mitigation function. The finding was screened in accordance with NRC Inspection Manual (IMC)0609, Significance Determination Process, dated June 2, 2011, Attachment 4, Initial Characterization of Findings, dated June 19, 2012. Using the guidance in IMC 0609, Appendix F, Attachment 1, Fire Protection SDP Phase 1 Worksheet, dated September 20, 2013, the finding was assigned a category of Fire Prevention and Administrative Controls. The inspectors determined the finding to be of very low safety significance (Green) because it did not affect the ability of the reactor to reach and maintain cold shutdown condition, in that, a postulated fire in the 2A ND/NS heat exchanger room did not present the possibility of impacting more than one train of safe shutdown equipment.
 
This finding had a cross cutting aspect of Teamwork in the Human Performance area because multiple groups were responsible for bringing the transient combustibles into the area and the individuals failed to effectively communicate and coordinate their activities to ensure that transient combustible control processes were appropriately implemented (H.4).


=====Enforcement:=====
=====Enforcement:=====
McGuire Nuclear Station Unit 1 and 2 Renewed Facility Operating License Condition 2.C.4, Fire Protection, required the licensee to implement and maintain in effect all provisions of the approved FPP as described in Section 9.5.1 of the UFSAR. UFSAR Section 9.5.1.2.1, (General) Program Description, stated, in part, that FPP administrative controls are included in NSDs to manage control of flammable and combustible materials. Procedure NSD 313, Control of Transient Fire Loads, required that work related ordinary transient combustibles be stored in established temporary housekeeping zones and if the quantity of these combustibles is greater than 15 pounds or not separated by prescribed distances from plant equipment susceptible to fire damage, a transient fire load evaluation must be completed and approved by the site fire protection engineer. Contrary to the above, on January 17, 2014, the licensee did not adequately implement the FPP as required by NSD 313, in that, a housekeeping zone was not established for work activities and a transient fire load evaluation was not completed and approved by the site fire protection engineer for greater than 15 pounds of ordinary transient combustibles in close proximity to important safety equipment in the 2A ND/NS heat exchanger room. Because this failure to adequately implement and maintain fire protection administrative controls regarding the storage of transient combustibles is of very low safety significance and was entered into the licensee's CAP as PIPs M-14-00487 and M-14-01862, this violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy, and is identified as NCV 05000370/2014002-01, Failure to Adequately Control Transient Combustible Materials in Accordance with the Fire Protection Program.
McGuire Nuclear Station Unit 1 and 2 Renewed Facility Operating License Condition 2.C.4, Fire Protection, required the licensee to implement and maintain in effect all provisions of the approved FPP as described in Section 9.5.1 of the UFSAR. UFSAR Section 9.5.1.2.1, (General) Program Description, stated, in part, that FPP administrative controls are included in NSDs to manage control of flammable and combustible materials. Procedure NSD 313, Control of Transient Fire Loads, required that work related ordinary transient combustibles be stored in established temporary housekeeping zones and if the quantity of these combustibles is greater than 15 pounds or not separated by prescribed distances from plant equipment susceptible to fire damage, a transient fire load evaluation must be completed and approved by the site fire protection engineer. Contrary to the above, on January 17, 2014, the licensee did not adequately implement the FPP as required by NSD 313, in that, a housekeeping zone was not established for work activities and a transient fire load evaluation was not completed and approved by the site fire protection engineer for greater than 15 pounds of ordinary transient combustibles in close proximity to important safety equipment in the 2A ND/NS heat exchanger room. Because this failure to adequately implement and maintain fire protection administrative controls regarding the storage of transient combustibles is of very low safety significance and was entered into the licensees CAP as PIPs M-14-00487 and M-14-01862, this violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy, and is identified as NCV 05000370/2014002-01, Failure to Adequately Control Transient Combustible Materials in Accordance with the Fire Protection Program.


===.2 Inadequate Control of Receptacles Equipped with UL Listed Self-Extinguishing Fire Lids===
===.2 Inadequate Control of Receptacles Equipped with UL Listed Self-Extinguishing Fire Lids===


=====Introduction:=====
=====Introduction:=====
An NRC-identified Green NCV of the McGuire Unit 1 and Unit 2 Renewed Facility Operating License Condition 2.C.4, FPP, was identified for the licensee's failure to adequately control the storage of transient combustibles in waste receptacles equipped with self-extinguishing fire lids in accordance with the FPP requirements.
An NRC-identified Green NCV of the McGuire Unit 1 and Unit 2 Renewed Facility Operating License Condition 2.C.4, FPP, was identified for the licensees failure to adequately control the storage of transient combustibles in waste receptacles equipped with self-extinguishing fire lids in accordance with the FPP requirements.


=====Description:=====
=====Description:=====
During a walkdown of several fire areas in the Unit 1 and 2 auxiliary buildings, the inspectors identified several 55 gallon waste receptacles, used to contain either general area waste or used radiological contaminated protective clothing, that were completely filled with materials and/or had lids that were either loose fitting or had gaps/openings between the receptacle and lid. The receptacles were equipped with self-extinguishing fire lids that had received certification by Underwriters Laboratories (UL) for their fire mitigating protection feature. These lids had specially contoured openings to direct the smoke and gas from a fire within the receptacle back into the combustion area, cutting off the air supply and extinguishing the flames. The licensee's fire protection transient combustible program allowed the permanent storage of receptacles with these lids in all fire areas and credits the fire mitigation feature of the lids in lieu of accounting for the transient combustible fire loading of the materials inside the receptacles. The inspectors reviewed the manufacturer's specifications for these lids and noted that there was both a 75 percent maximum fill requirement and a requirement that the lids be tight-fitting to its receptacle in order to ensure it retains its intended fire mitigation function. The inspectors reviewed procedure NSD 313, Control of Transient Fire Loads, Rev. 14, which specified that waste receptacles equipped with UL approved covers, such as a tight fitting lid or approved self-extinguishing or self-closing lid, shall be inspected on a regular basis and emptied as needed to prevent overfill. The inspectors determined that the licensee had failed to follow NSD 313, in that, waste receptacles fitted with these self-extinguishing lids were not being adequately inspected and emptied to ensure the manufacturer's lid tightness and fill requirements were met. The licensee took actions to correct all waste receptacles in the plant that were filled beyond the manufacturer's specification or had loosely fitted lids.
During a walkdown of several fire areas in the Unit 1 and 2 auxiliary buildings, the inspectors identified several 55 gallon waste receptacles, used to contain either general area waste or used radiological contaminated protective clothing, that were completely filled with materials and/or had lids that were either loose fitting or had gaps/openings between the receptacle and lid. The receptacles were equipped with self-extinguishing fire lids that had received certification by Underwriters Laboratories (UL) for their fire mitigating protection feature. These lids had specially contoured openings to direct the smoke and gas from a fire within the receptacle back into the combustion area, cutting off the air supply and extinguishing the flames. The licensee's fire protection transient combustible program allowed the permanent storage of receptacles with these lids in all fire areas and credits the fire mitigation feature of the lids in lieu of accounting for the transient combustible fire loading of the materials inside the receptacles. The inspectors reviewed the manufacturer's specifications for these lids and noted that there was both a 75 percent maximum fill requirement and a requirement that the lids be tight-fitting to its receptacle in order to ensure it retains its intended fire mitigation function. The inspectors reviewed procedure NSD 313, Control of Transient Fire Loads, Rev. 14, which specified that waste receptacles equipped with UL approved covers, such as a tight fitting lid or approved self-extinguishing or self-closing lid, shall be inspected on a regular basis and emptied as needed to prevent overfill. The inspectors determined that the licensee had failed to follow NSD 313, in that, waste receptacles fitted with these self-extinguishing lids were not being adequately inspected and emptied to ensure the manufacturers lid tightness and fill requirements were met. The licensee took actions to correct all waste receptacles in the plant that were filled beyond the manufacturers specification or had loosely fitted lids.


=====Analysis:=====
=====Analysis:=====
The licensee's failure to control the storage of transient combustibles in waste receptacles equipped with self-extinguishing fire lids in accordance with the requirements of NSD-313 was a PD. The PD was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective in that the self-extinguishing function was not retained which could allow the spread of the fire and  
The licensees failure to control the storage of transient combustibles in waste receptacles equipped with self-extinguishing fire lids in accordance with the requirements of NSD-313 was a PD. The PD was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective in that the self-extinguishing function was not retained which could allow the spread of the fire and adversely affect mitigating system equipment in the area. The finding was screened in accordance with IMC 0609, Significance Determination Process, dated June 2, 2011, 4, Initial Characterization of Findings, dated June 19, 2012. Using the guidance in IMC 0609, Appendix F, Attachment 1, Fire Protection SDP Phase 1 Worksheet, dated September 20, 2013, the finding was assigned a category of Fire Prevention and Administrative Controls. The inspectors determined the finding to be of very low safety significance (Green) because it did not affect the ability of the reactor to reach and maintain cold shutdown conditions, in that, a postulated fire in the receptacles observed by the inspectors to be overfilled or had lid tightness discrepancies, did not present the possibility of impacting more than one train of safe shutdown equipment. A cross-cutting aspect was not assigned because the performance deficiency does not reflect current licensee performance based on information that the self-extinguishing fire lids and existing procedural guidance had been placed in service in the 1990s and there was no recent industry operating experience that was missed nor other reason that would have prompted the licensee to re-evaluate their waste receptacle storage controls.
 
adversely affect mitigating system equipment in the area. The finding was screened in accordance with IMC 0609, Significance Determination Process, dated June 2, 2011, Attachment 4, Initial Characterization of Findings, dated June 19, 2012. Using the guidance in IMC 0609, Appendix F, Attachment 1, Fire Protection SDP Phase 1 Worksheet, dated September 20, 2013, the finding was assigned a category of Fire Prevention and Administrative Controls. The inspectors determined the finding to be of very low safety significance (Green) because it did not affect the ability of the reactor to reach and maintain cold shutdown conditions, in that, a postulated fire in the receptacles observed by the inspectors to be overfilled or had lid tightness discrepancies, did not present the possibility of impacting more than one train of safe shutdown equipment. A cross-cutting aspect was not assigned because the performance deficiency does not reflect current licensee performance based on information that the self-extinguishing fire lids and existing procedural guidance had been placed in service in the 1990's and there was no recent industry operating experience that was missed nor other reason that would have prompted the licensee to re-evaluate their waste receptacle storage controls.


=====Enforcement:=====
=====Enforcement:=====
McGuire Nuclear Station Unit 1 and 2 Renewed Facility Operating License Condition 2.C.4, Fire Protection, required the licensee to implement and maintain in effect all provisions of the approved FPP as described in Section 9.5.1 of the UFSAR. UFSAR Section 9.5.1.2.1, (General) Program Description, stated, in part, that FPP administrative controls are included in NSDs to manage control of flammable and combustible materials. The licensee implemented this requirement, in part, through procedure NSD 313, Control of Transient Fire Loads, which specified that waste receptacles containing trash and/or contaminated clothing shall be equipped with an a compatible UL listed or Fire Mutual approved cover such as a tight fitting lid or approved self-extinguishing or self-closing lid, and shall be regularly inspected and emptied as needed to prevent overfill. Contrary to the above, since the late 1990's, the licensee failed to adequately implement the transient combustible control program as required by NSD-313, in that, inspections and necessary empting of waste receptacles equipped with self-extinguishing fire lids were not being adequately performed. This resulted in conditions where waste receptacles were overfilled and/or had loosely fitted lids that could have prevented the lids from performing their design fire mitigation function.
McGuire Nuclear Station Unit 1 and 2 Renewed Facility Operating License Condition 2.C.4, Fire Protection, required the licensee to implement and maintain in effect all provisions of the approved FPP as described in Section 9.5.1 of the UFSAR. UFSAR Section 9.5.1.2.1, (General) Program Description, stated, in part, that FPP administrative controls are included in NSDs to manage control of flammable and combustible materials. The licensee implemented this requirement, in part, through procedure NSD 313, Control of Transient Fire Loads, which specified that waste receptacles containing trash and/or contaminated clothing shall be equipped with an a compatible UL listed or Fire Mutual approved cover such as a tight fitting lid or approved self-extinguishing or self-closing lid, and shall be regularly inspected and emptied as needed to prevent overfill. Contrary to the above, since the late 1990s, the licensee failed to adequately implement the transient combustible control program as required by NSD-313, in that, inspections and necessary empting of waste receptacles equipped with self-extinguishing fire lids were not being adequately performed. This resulted in conditions where waste receptacles were overfilled and/or had loosely fitted lids that could have prevented the lids from performing their design fire mitigation function.


Because this failure to adequately implement and maintain fire protection administrative controls is of very low safety significance and was entered into the licensee's CAP as PIP M-14-00487, this violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy, and is identified as NCV 05000369, 370/2014002-02, Failure to Adequately Control the Use of Self-Extinguishing Fire Lids.
Because this failure to adequately implement and maintain fire protection administrative controls is of very low safety significance and was entered into the licensees CAP as PIP M-14-00487, this violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy, and is identified as NCV 05000369, 370/2014002-02, Failure to Adequately Control the Use of Self-Extinguishing Fire Lids.
{{a|1R11}}
{{a|1R11}}
==1R11 Licensed Operator Requalification (LOR) Program and Licensed Operator Performance==
==1R11 Licensed Operator Requalification (LOR) Program and Licensed Operator Performance==


====a. Inspection Scope====
====a. Inspection Scope====
Quarterly Resident Inspector LOR Activity Review
Quarterly Resident Inspector LOR Activity Review: On February 26, 2014, the inspectors observed operators in the plants simulator during licensed operator requalification training. The training scenario involved a failed open pressurizer power operated relief valve, reactor coolant system leak on the chemical and volume control system letdown line, and a large steam line break inside containment. The inspectors assessed overall crew performance, clarity and formality of communications, use of procedures, alarm response, control board manipulations, group dynamics, and supervisory oversight. The inspectors observed the post-exercise critique to verify that the licensee identified deficiencies and discrepancies that occurred during the simulator training. Documents reviewed are listed in the Attachment.
: On February 26, 2014, the inspectors observed operators in the plant's simulator during licensed operator requalification training. The training scenario involved a failed open pressurizer power operated relief valve, reactor coolant system leak on the chemical and volume control system letdown line, and a large steam line break inside containment. The inspectors assessed overall crew performance, clarity and formality of communications, use of procedures, alarm response, control board manipulations, group dynamics, and supervisory oversight. The inspectors observed the post-exercise critique to verify that the licensee identified deficiencies and discrepancies that occurred during the simulator training. Documents reviewed are listed in the Attachment.


Quarterly Resident Inspector Licensed Operator Performance Review: On March 22, 2014, the inspectors observed operators in the main control room and assessed their performance during reactor shutdown activities for the refueling outage. Documents reviewed are listed in the Attachment.
Quarterly Resident Inspector Licensed Operator Performance Review: On March 22, 2014, the inspectors observed operators in the main control room and assessed their performance during reactor shutdown activities for the refueling outage. Documents reviewed are listed in the Attachment.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the two activities listed below for items such as: 1) appropriate work practices; 2) identifying and addressing common cause failures; 3) scoping in accordance with 10 CFR 50.65(b) of the Maintenance Rule; 4) characterizing reliability issues for performance; 5) charging unavailability for performance; 6) balancing reliability and unavailability; 7) trending key parameters for condition monitoring; 8) classification  
The inspectors reviewed the two activities listed below for items such as: 1) appropriate work practices; 2) identifying and addressing common cause failures; 3) scoping in accordance with 10 CFR 50.65(b) of the Maintenance Rule; 4) characterizing reliability issues for performance; 5) charging unavailability for performance; 6) balancing reliability and unavailability; 7) trending key parameters for condition monitoring; 8) classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); and 9)appropriateness of performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified as (a)(1). The inspectors performed a detailed review of the problem history and surrounding circumstances, evaluated the extent of condition reviews as required, and reviewed the generic implications of the equipment and/or work practice problem. Documents reviewed are listed in the
 
and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); and 9) appropriateness of performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified as (a)(1). The inspectors performed a detailed review of the problem history and surrounding circumstances, evaluated the extent of condition reviews as required, and reviewed the generic implications of the equipment and/or work practice problem. Documents reviewed are listed in the  
.
.
* PIP M-13-09701, Potential transformer fuse failure in essential switchgear 2ETA bus
* PIP M-13-09701, Potential transformer fuse failure in essential switchgear 2ETA bus
* PIP M-14-00155, "H" diesel driven instrument air compressor failure to run
* PIP M-14-00155, H diesel driven instrument air compressor failure to run


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the licensee's risk assessments and the risk management actions used to manage risk for the plant configurations associated with the five activities listed below. The inspectors assessed whether the licensee performed adequate risk assessments, and implemented appropriate risk management actions when required by 10 CFR 50.65(a)(4). For emergent work, the inspectors verified that any increase in risk was promptly assessed, that appropriate risk management actions were promptly implemented, and that work activities did not place the plant in unacceptable configurations. Documents reviewed are listed in the Attachment.
The inspectors reviewed the licensees risk assessments and the risk management actions used to manage risk for the plant configurations associated with the five activities listed below. The inspectors assessed whether the licensee performed adequate risk assessments, and implemented appropriate risk management actions when required by 10 CFR 50.65(a)(4). For emergent work, the inspectors verified that any increase in risk was promptly assessed, that appropriate risk management actions were promptly implemented, and that work activities did not place the plant in unacceptable configurations. Documents reviewed are listed in the Attachment.
* Unplanned Yellow Risk on Unit 1 and Unit 2 due to Red grid condition generated as a result of low generation capacity reserve margin
* Unplanned Yellow Risk on Unit 1 and Unit 2 due to Red grid condition generated as a result of low generation capacity reserve margin
* Yellow Risk on Unit 2 while 2B EDG out of service for hot web deflection following 24-hr engine run
* Yellow Risk on Unit 2 while 2B EDG out of service for hot web deflection following 24-hr engine run
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* PIP M-13-11403, 2B containment spray (NS) suction pressure found pegged high
* PIP M-13-11403, 2B containment spray (NS) suction pressure found pegged high
* PIP M-14-00426, 2A RN strainer packing leak on strainer drum shaft
* PIP M-14-00426, 2A RN strainer packing leak on strainer drum shaft
* PIP M-14-01006, 1A ND heat exchanger KC outlet flow control valve (1KC-57A) travel stop handwheel position discrepancy
* PIP M-14-01006, 1A ND heat exchanger KC outlet flow control valve (1KC-57A)travel stop handwheel position discrepancy
* PIP M-14-01114, MDCA pump brake horsepower low margin
* PIP M-14-01114, MDCA pump brake horsepower low margin
* PIP M-14-02117, Unit 2 ice condenser baskets
* PIP M-14-02117, Unit 2 ice condenser baskets
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====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the six post-maintenance tests listed below to determine if procedures and test activities ensured system operability and functional capability. The inspectors reviewed the licensee's test procedures to determine if the procedures adequately tested the safety function(s) that may have been affected by the maintenance activities, that the acceptance criteria in the procedures were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedures had been properly reviewed and approved. The inspectors also witnessed the tests and/or reviewed the test data to determine if test results adequately demonstrated restoration of the affected safety functions. Documents reviewed are listed in the Attachment.
The inspectors reviewed the six post-maintenance tests listed below to determine if procedures and test activities ensured system operability and functional capability. The inspectors reviewed the licensees test procedures to determine if the procedures adequately tested the safety function(s) that may have been affected by the maintenance activities, that the acceptance criteria in the procedures were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedures had been properly reviewed and approved. The inspectors also witnessed the tests and/or reviewed the test data to determine if test results adequately demonstrated restoration of the affected safety functions. Documents reviewed are listed in the Attachment.
* 2B1 and 2B2 KC pump functional testing following ground fault relay replacement on 4160 volt switchgear breakers 2ETB-12 and 2ETB-13
* 2B1 and 2B2 KC pump functional testing following ground fault relay replacement on 4160 volt switchgear breakers 2ETB-12 and 2ETB-13
* 2A EDG room ventilation damper functional testing following fuse replacement for damper control solenoid valves SV-9190 and SV-9230
* 2A EDG room ventilation damper functional testing following fuse replacement for damper control solenoid valves SV-9190 and SV-9230
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* Observed portions of the cool down process to determine if TS cool down restrictions were followed
* Observed portions of the cool down process to determine if TS cool down restrictions were followed
* Walked down containment shortly after the shutdown to determine if there was indication of previously unidentified leakage from components containing reactor coolant
* Walked down containment shortly after the shutdown to determine if there was indication of previously unidentified leakage from components containing reactor coolant
* Reviewed the licensee's responses to emergent work and unexpected conditions to determine if configuration changes were controlled in accordance with the outage risk control plan
* Reviewed the licensees responses to emergent work and unexpected conditions to determine if configuration changes were controlled in accordance with the outage risk control plan
* Observed outage activities to determine if the licensee maintained defense-in-depth commensurate with the outage risk control plan for the key safety functions and applicable TS
* Observed outage activities to determine if the licensee maintained defense-in-depth commensurate with the outage risk control plan for the key safety functions and applicable TS
* Assessed outage activities that were conducted during short time-to-boil periods
* Assessed outage activities that were conducted during short time-to-boil periods
* During lowered reactor coolant system inventory conditions, the inspectors reviewed the licensee's commitments to NRC Generic Letter 88-17 to determine if they were still in place and adequate
* During lowered reactor coolant system inventory conditions, the inspectors reviewed the licensees commitments to NRC Generic Letter 88-17 to determine if they were still in place and adequate
* Observed fuel handling operations (offload) and other ongoing fuel handling activities to determine if those operations and activities were being performed in accordance with TS and licensee procedures.
* Observed fuel handling operations (offload) and other ongoing fuel handling activities to determine if those operations and activities were being performed in accordance with TS and licensee procedures.
* Reviewed selected system lineups and/or control board indications to determine if TS, license conditions, and other requirements, commitments, and administrative procedure prerequisites for mode changes were met prior to changing modes or plant configurations
* Reviewed selected system lineups and/or control board indications to determine if TS, license conditions, and other requirements, commitments, and administrative procedure prerequisites for mode changes were met prior to changing modes or plant configurations
* Reviewed/observed controls for establishing containment closure to determine if the NC system and containment boundaries were in place when necessary
* Reviewed/observed controls for establishing containment closure to determine if the NC system and containment boundaries were in place when necessary
* Reviewed items that had been entered into the licensee's CAP to determine if the licensee had identified problems related to outage activities at an appropriate threshold and had entered them into the CAP
* Reviewed items that had been entered into the licensees CAP to determine if the licensee had identified problems related to outage activities at an appropriate threshold and had entered them into the CAP


====b. Findings====
====b. Findings====
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No findings were identified.
No findings were identified.


===Cornerstone: Emergency Preparedness===
===Cornerstone: Emergency Preparedness===


1EP6 Drill Evaluation
1EP6 Drill Evaluation


====a. Inspection Scope====
====a. Inspection Scope====
Quarterly Site Emergency Preparedness Training Drill: On March 6, 2014, the inspectors evaluated the licensee's performance of a quarterly licensee emergency preparedness training exercise from the simulator control room and Technical Support Center. The exercise scenario involved a damaged fuel assembly in the spent fuel pool, steam generator tube leak/rupture, and steam line break outside containment. The inspectors assessed the licensee emergency procedure usage, emergency plan classifications, notifications, and protective action recommendation development. The inspectors attended the post-exercise critique for the drill to evaluate the adequacy of the licensee's self-assessment process for identifying potential exercise performance deficiencies and weaknesses. The inspectors verified that any deficiencies or weaknesses were entered into the licensee's CAP. Documents reviewed are listed in the Attachment.
Quarterly Site Emergency Preparedness Training Drill: On March 6, 2014, the inspectors evaluated the licensees performance of a quarterly licensee emergency preparedness training exercise from the simulator control room and Technical Support Center. The exercise scenario involved a damaged fuel assembly in the spent fuel pool, steam generator tube leak/rupture, and steam line break outside containment. The inspectors assessed the licensee emergency procedure usage, emergency plan classifications, notifications, and protective action recommendation development. The inspectors attended the post-exercise critique for the drill to evaluate the adequacy of the licensees self-assessment process for identifying potential exercise performance deficiencies and weaknesses. The inspectors verified that any deficiencies or weaknesses were entered into the licensees CAP. Documents reviewed are listed in the Attachment.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The inspectors sampled licensee data to confirm the accuracy of reported PI data for the six indicators during the periods listed below. To determine the accuracy of the PI data, the inspectors compared the licensee's basis in reporting each data element to the PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. 6. Documents reviewed are listed in the Attachment.
The inspectors sampled licensee data to confirm the accuracy of reported PI data for the six indicators during the periods listed below. To determine the accuracy of the PI data, the inspectors compared the licensees basis in reporting each data element to the PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. 6. Documents reviewed are listed in the Attachment.


Initiating Events Cornerstone
Initiating Events Cornerstone
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* Unplanned Scrams with Complications (Units 1 and 2)
* Unplanned Scrams with Complications (Units 1 and 2)
* Unplanned Power Changes per 7000 Critical Hours (Units 1 and 2)
* Unplanned Power Changes per 7000 Critical Hours (Units 1 and 2)
The inspectors sampled licensee submittals relative to the PIs listed above for the period January 1, 2013, through December 31, 2013. The inspectors independently screened Licensee Event Reports, TS narrative logs, and the licensee's CAP database to verify that the licensee had adequately identified the number of scrams and unplanned power changes greater than 20 percent that occurred during the period and compared this number to the number reported for the PI. The inspectors also reviewed the accuracy of the number of critical hours reported and the licensee's basis for determining that there were not complications for each of the reported reactor scrams. In addition, the inspectors interviewed licensee personnel associated with the PI data collection, evaluation, and distribution.
The inspectors sampled licensee submittals relative to the PIs listed above for the period January 1, 2013, through December 31, 2013. The inspectors independently screened Licensee Event Reports, TS narrative logs, and the licensees CAP database to verify that the licensee had adequately identified the number of scrams and unplanned power changes greater than 20 percent that occurred during the period and compared this number to the number reported for the PI. The inspectors also reviewed the accuracy of the number of critical hours reported and the licensees basis for determining that there were not complications for each of the reported reactor scrams. In addition, the inspectors interviewed licensee personnel associated with the PI data collection, evaluation, and distribution.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
Review of Items Entered into the CAP
Review of Items Entered into the CAP: As required by Inspection Procedure 71152, Problem Identification and Resolution, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed screening of items entered into the licensees CAP. This was accomplished by reviewing copies of condition reports, attending some daily screening meetings, and accessing the licensees computerized CAP database.
: As required by Inspection Procedure 71152, Problem Identification and Resolution, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed screening of items entered into the licensee's CAP. This was accomplished by reviewing copies of condition reports, attending some daily screening meetings, and accessing the licensee's computerized CAP database.


Annual Sample Review of Operator Workarounds (OWAs): The inspectors reviewed the licensee's list of identified OWAs, equipment deficiencies, and plant concerns to determine whether any new items since the previous review conducted in 2013 would adversely affect any mitigating system function or affect the operator's ability to implement abnormal or emergency operating procedures. The inspectors reviewed the classification assigned to the identified OWAs to ensure they were properly prioritized based on the licensee's program requirements. For high priority OWAs where compensatory actions were developed, the inspectors verified the feasibility of implementing these prescribed actions. The inspectors verified that long term corrective actions were developed to adequately address the underlying issues identified in the OWAs. In addition, the inspectors attended a quarterly OWA meeting between operations, engineering, and chemistry personnel to discuss the status of open OWAs and new OWA candidates. Documents reviewed are listed in the Attachment.
Annual Sample Review of Operator Workarounds (OWAs): The inspectors reviewed the licensees list of identified OWAs, equipment deficiencies, and plant concerns to determine whether any new items since the previous review conducted in 2013 would adversely affect any mitigating system function or affect the operators ability to implement abnormal or emergency operating procedures. The inspectors reviewed the classification assigned to the identified OWAs to ensure they were properly prioritized based on the licensees program requirements. For high priority OWAs where compensatory actions were developed, the inspectors verified the feasibility of implementing these prescribed actions. The inspectors verified that long term corrective actions were developed to adequately address the underlying issues identified in the OWAs. In addition, the inspectors attended a quarterly OWA meeting between operations, engineering, and chemistry personnel to discuss the status of open OWAs and new OWA candidates. Documents reviewed are listed in the Attachment.


Annual Sample Reviews: The inspectors reviewed the issue listed below in detail to evaluate the effectiveness of the licensee's corrective actions for important safety issues.
Annual Sample Reviews: The inspectors reviewed the issue listed below in detail to evaluate the effectiveness of the licensees corrective actions for important safety issues.
* PIP M-13-10176, 2A EDG emergency breaker failure to close The inspectors assessed whether the issue was properly identified; documented accurately and completely; properly classified and prioritized; adequately considered extent of condition, generic implications, common cause, and previous occurrences; adequately identified root causes/apparent causes; and identified appropriate and timely corrective actions. The inspectors evaluated the licensee documents against the requirements of the licensee's CAP and implementing procedures, and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.
* PIP M-13-10176, 2A EDG emergency breaker failure to close The inspectors assessed whether the issue was properly identified; documented accurately and completely; properly classified and prioritized; adequately considered extent of condition, generic implications, common cause, and previous occurrences; adequately identified root causes/apparent causes; and identified appropriate and timely corrective actions. The inspectors evaluated the licensee documents against the requirements of the licensees CAP and implementing procedures, and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
On November 14, 2013, Unit 1 was manually tripped from 100 percent RTP after a loss of primary and backup 24 volt direct current (VDC) power in the 1AC rod control cabinet. All safety equipment responded as expected and the reactor was stabilized in Mode 3 at normal operating pressure and temperature. The inspectors reviewed the subject LER, its supplement and PIP M-13-10440 to verify the accuracy of the LERs and appropriateness of corrective actions. The supplement to this LER documented completion of the licensee's causal analysis and included laboratory testing results reviewed by a third party that confirmed the original root cause.
On November 14, 2013, Unit 1 was manually tripped from 100 percent RTP after a loss of primary and backup 24 volt direct current (VDC) power in the 1AC rod control cabinet.
 
All safety equipment responded as expected and the reactor was stabilized in Mode 3 at normal operating pressure and temperature. The inspectors reviewed the subject LER, its supplement and PIP M-13-10440 to verify the accuracy of the LERs and appropriateness of corrective actions. The supplement to this LER documented completion of the licensees causal analysis and included laboratory testing results reviewed by a third party that confirmed the original root cause.


====b. Findings====
====b. Findings====


=====Introduction:=====
=====Introduction:=====
A self-revealing Green finding (FIN) was identified for the licensee's failure to implement adequate design control measures for the rod control power supply modification which resulted in the loss of 24VDC power in the 1AC rod control power cabinet.
A self-revealing Green finding (FIN) was identified for the licensees failure to implement adequate design control measures for the rod control power supply modification which resulted in the loss of 24VDC power in the 1AC rod control power cabinet.


=====Description:=====
=====Description:=====
On November 14, 2013, an instrumentation and electrical (IAE) crew was in the process of replacing a blown fuse for an out-of-service blower fan in rod control cabinet 1AC. When the new fuse was installed, the control room received a "Rod Control Non-Urgent Failure" alarm. Suspecting a problem with the backup -24VDC power supply (PS4), a work package was authorized to troubleshoot. Per the work package, the IAE crew removed the supply fuse to de-energize PS4. Upon removal of the PS4 supply fuse, the primary -24VDC power supply (PS3) tripped on overvoltage which resulted in a loss of DC power to the control rod drive mechanism for the rods associated with the 1AC cabinet causing ten rods to drop. Operators responded to the multiple rod drop by manually tripping the Unit 1 reactor as required by procedures.
On November 14, 2013, an instrumentation and electrical (IAE) crew was in the process of replacing a blown fuse for an out-of-service blower fan in rod control cabinet 1AC. When the new fuse was installed, the control room received a Rod Control Non-Urgent Failure alarm. Suspecting a problem with the backup -24VDC power supply (PS4), a work package was authorized to troubleshoot. Per the work package, the IAE crew removed the supply fuse to de-energize PS4. Upon removal of the PS4 supply fuse, the primary -24VDC power supply (PS3) tripped on overvoltage which resulted in a loss of DC power to the control rod drive mechanism for the rods associated with the 1AC cabinet causing ten rods to drop. Operators responded to the multiple rod drop by manually tripping the Unit 1 reactor as required by procedures.


In 1997, the licensee implemented power supply modification MGMM-8765 to replace the original PS3 and PS4 rod control power supplies without overvoltage protection to a new model with overvoltage protection. The design change included the configuration of the over voltage protection (OVP) setting by adding a trim jumper which increased the power supply's OVP sensitivity by approximately 1.5 volts greater. The addition of the trim jumper reduced the operating voltage margin for both PS3 and PS4 power supplies which increased the potential for a loss of -24VDC power in the rod control cabinet due to minor voltage transients. On November 14, 2013, the removal of the supply fuse to PS4 created a minor voltage transient that caused PS3 to trip on overvoltage.
In 1997, the licensee implemented power supply modification MGMM-8765 to replace the original PS3 and PS4 rod control power supplies without overvoltage protection to a new model with overvoltage protection. The design change included the configuration of the over voltage protection (OVP) setting by adding a trim jumper which increased the power supplys OVP sensitivity by approximately 1.5 volts greater. The addition of the trim jumper reduced the operating voltage margin for both PS3 and PS4 power supplies which increased the potential for a loss of -24VDC power in the rod control cabinet due to minor voltage transients. On November 14, 2013, the removal of the supply fuse to PS4 created a minor voltage transient that caused PS3 to trip on overvoltage.


McGuire Modification Manual, Section 5.0, Minor Modification Process, rev 5, required the modification originator to conduct a modification design review the to ensure that the design was adequate for its intended application. Section 5.4, Review and Approval, required an equally qualified Checker review that the actions taken by the originator, including the design approach, design assumptions, and design inputs, were technically correct. The inspectors determined that the licensee did not implement adequate design control measures during the modification process for the configuration of the OPV setting to ensure that the OVP function was reliable in that the redundant power supply would not trip when exposed to minor voltage transients.
McGuire Modification Manual, Section 5.0, Minor Modification Process, rev 5, required the modification originator to conduct a modification design review the to ensure that the design was adequate for its intended application. Section 5.4, Review and Approval, required an equally qualified Checker review that the actions taken by the originator, including the design approach, design assumptions, and design inputs, were technically correct. The inspectors determined that the licensee did not implement adequate design control measures during the modification process for the configuration of the OPV setting to ensure that the OVP function was reliable in that the redundant power supply would not trip when exposed to minor voltage transients.


=====Analysis:=====
=====Analysis:=====
The inspectors determined that the licensee's failure to implement adequate design control measures was a PD. The PD was more than minor because it affected the Design Control attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective, in that, the insufficient margin in the rod control power supply OVP function caused in a multiple drop rod event which resulted in a reactor trip. Using IMC 0609, dated June 2, 2011, this finding was determined to have very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. A cross-cutting aspect was not assigned because the performance deficiency does not reflect current licensee performance in that the modification review occurred in 1997.
The inspectors determined that the licensees failure to implement adequate design control measures was a PD. The PD was more than minor because it affected the Design Control attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective, in that, the insufficient margin in the rod control power supply OVP function caused in a multiple drop rod event which resulted in a reactor trip. Using IMC 0609, dated June 2, 2011, this finding was determined to have very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. A cross-cutting aspect was not assigned because the performance deficiency does not reflect current licensee performance in that the modification review occurred in 1997.


=====Enforcement:=====
=====Enforcement:=====
The rod control system is not safety-related equipment; therefore, no violation of NRC requirements occurred. Because this finding does not involve a violation or regulatory requirements, was of very low safety significance, and has been entered into the licensee's CAP as PIP M-13-10440, it is identified as FIN 05000369/2014002-03, Inadequate Design Control Measures for Rod Control Power Supply Modification.
The rod control system is not safety-related equipment; therefore, no violation of NRC requirements occurred. Because this finding does not involve a violation or regulatory requirements, was of very low safety significance, and has been entered into the licensees CAP as PIP M-13-10440, it is identified as FIN 05000369/2014002-03, Inadequate Design Control Measures for Rod Control Power Supply Modification.


{{a|4OA5}}
{{a|4OA5}}
==4OA5 Other Activities==
==4OA5 Other Activities==


===.1 Cross-Reference of 2013 Findings with Cross-Cutting Aspects to New Cross-Cutting Aspect Terminology===
===.1 Cross-Reference of 2013 Findings with Cross-Cutting Aspects to New Cross-Cutting===


The table below provides a cross-reference from the 2013 and earlier findings and associated cross-cutting aspects to the new cross-cutting aspects resulting from the common language initiative. These aspects and any others identified since January 2014, will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review. Finding Old Cross-Cutting Aspect New Cross-Cutting Aspect None N/A N/A
Aspect Terminology The table below provides a cross-reference from the 2013 and earlier findings and associated cross-cutting aspects to the new cross-cutting aspects resulting from the common language initiative. These aspects and any others identified since January 2014, will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review.


Finding            Old Cross-Cutting Aspect      New Cross-Cutting Aspect None                          N/A                            N/A
{{a|4OA6}}
{{a|4OA6}}
==4OA6 Meetings, Including Exits==
==4OA6 Meetings, Including Exits==
Line 346: Line 327:
On April 10, 2014, the resident inspectors presented the inspection results to Mr. Steven Capps and other members of his staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
On April 10, 2014, the resident inspectors presented the inspection results to Mr. Steven Capps and other members of his staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.


ATTACHMENT:
ATTACHMENT:  


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=
Line 352: Line 333:
==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==


Licensee  
Licensee
: [[contact::B. Anderson]], Superintendent of Operations  
: [[contact::B. Anderson]], Superintendent of Operations
: [[contact::D. Black]], Security Manager  
: [[contact::D. Black]], Security Manager
: [[contact::S. Capps]], Vice President, McGuire Nuclear  
: [[contact::S. Capps]], Vice President, McGuire Nuclear
: [[contact::K. Crane]], Senior Licensing Specialist
: [[contact::K. Crane]], Senior Licensing Specialist
: [[contact::J. Gabbert]], Chemistry Manager  
: [[contact::J. Gabbert]], Chemistry Manager
: [[contact::J. Hicks]], Maintenance Superintendent  
: [[contact::J. Hicks]], Maintenance Superintendent
: [[contact::M. Kelly]], Outage and Scheduling Manager  
: [[contact::M. Kelly]], Outage and Scheduling Manager
: [[contact::S. Mooneyhan]], Radiation Protection Manager  
: [[contact::S. Mooneyhan]], Radiation Protection Manager
: [[contact::C. Morris]], Station Manager  
: [[contact::C. Morris]], Station Manager
: [[contact::J. Robertson]], Regulatory Compliance Manager  
: [[contact::J. Robertson]], Regulatory Compliance Manager
: [[contact::P. Schuerger]], Training Manager  
: [[contact::P. Schuerger]], Training Manager
: [[contact::S. Snider]], Engineering Manager  
: [[contact::S. Snider]], Engineering Manager


==LIST OF REPORT ITEMS==
==LIST OF REPORT ITEMS==
Line 371: Line 352:


NCV  
NCV  
: 05000370/2014002-01 Failure to Adequately Control Transient Combustible Materials in Accordance with the Fire Protection Program  
: 05000370/2014002-01               Failure to Adequately Control Transient Combustible Materials in Accordance with the Fire Protection Program (Section 1R05.1)
(Section 1R05.1)
NCV  
NCV  
: 05000369, 370/2014002-02 Failure to Adequately Control the Use of Self-Extinguishing Fire Lids (Section 1R05.2)  
: 05000369, 370/2014002-02         Failure to Adequately Control the Use of Self-
Extinguishing Fire Lids (Section 1R05.2)
FIN
: 05000369/2014002-03              Failure to Implement Adequate Design Control Measures for Rod Control Power Supply Replacement Resulting in Reactor Trip (Section 4OA3)


FIN
===Closed===
: 05000369/2014002-03 Failure to Implement Adequate Design Control Measures
for Rod Control Power Supply Replacement Resulting in
Reactor Trip (Section 4OA3)


===Closed LER===
LER  
: 05000369/2013-003-00, -01 Manual Reactor Trip and Auxiliary Feedwater Start due to Dropped Control Rods (Section 4OA3)  
: 05000369/2013-003-00, -01         Manual Reactor Trip and Auxiliary Feedwater Start due to Dropped Control Rods (Section 4OA3)


==DOCUMENTS REVIEWED==
==DOCUMENTS REVIEWED==


}}
}}

Revision as of 06:12, 4 November 2019

IR 05000369-14-002, IR 05000370-14-002; 01/01/2014 - 03/31/2014; McGuire Nuclear Station, Units 1 and 2; Fire Protection and Follow-Up of Events and Notices of Enforcement Discretion
ML14120A432
Person / Time
Site: Mcguire, McGuire  Duke Energy icon.png
Issue date: 04/30/2014
From: Gerald Mccoy
NRC/RGN-II/DRP/RPB1
To: Capps S
Duke Energy Carolinas
References
IR-14-002
Download: ML14120A432 (25)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ril 30, 2014

SUBJECT:

MCGUIRE NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000369/2014002 AND 05000370/2014002

Dear Mr. Capps:

On March 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your McGuire Nuclear Station Units 1 and 2. On April 10, 2014, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented three findings of very low safety significance (Green) in this report.

Two of these findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violations or the significance of these findings, 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 the McGuire Nuclear Station. Also, if you disagree with a cross-cutting aspect assignment 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 II; and the NRC Resident Inspector at the McGuire Nuclear Station.

Additionally, as we informed you in the fourth quarter 2013 NRC integrated inspection report, cross-cutting aspects identified in the last six months of 2013 using the previous terminology were being converted in accordance with the cross-reference in Inspection Manual Chapter 0310. Section 4OA5 of the enclosed report documents the conversion of these cross-cutting aspects which will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review. 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 Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

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

Enclosure:

NRC Integrated Inspection Report 05000369/2014002 and 05000370/2014002 w/Attachment - Supplemental Information

REGION II==

Docket Nos.: 50-369, 50-370 License Nos.: NPF-9, NPF-17 Report Nos.: 05000369/2014002, 05000370/2014002 Licensee: Duke Energy Carolinas, LLC Facility: McGuire Nuclear Station, Units 1 and 2 Location: Huntersville, NC 28078 Dates: January 1, 2014, through March 31, 2014 Inspectors: J. Zeiler, Senior Resident Inspector J. Heath, Resident Inspector Approved by: Gerald McCoy, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR05000369/2014-002, IR05000370/2014-002; 01/01/2014 - 03/31/2014; McGuire Nuclear

Station, Units 1 and 2; Fire Protection and Follow-Up of Events and Notices of Enforcement Discretion The report covered a three month period of inspection by the resident inspectors. Three Green findings, two of which were determined to involve non-cited violations (NCVs) of NRC requirements, were identified. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within The Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs 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: Initiating Events

Green.

A self-revealing finding (FIN) was identified for the licensees failure to implement adequate design control measures for the rod control power supply modification which resulted in the loss of 24VDC power in the 1AC rod control power cabinet.

The inspectors determined that the licensees failure to implement adequate design control measures was more than minor because it affected the Design Control attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective, in that, the insufficient margin in the rod control power supply OVP function caused a multiple drop rod event which resulted in a reactor trip. This finding was determined to have very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. A cross-cutting aspect was not assigned because the performance deficiency does not reflect current licensee performance. (Section 4OA3)

Cornerstone: Mitigating Systems

Green.

An NRC-identified NCV of the McGuire Unit 1 and Unit 2 Renewed Facility Operating License Condition 2.C.4, Fire Protection Program (FPP), was identified for the licensees failure to adequately control the storage of transient combustibles in the 2A residual heat removal (ND)/containment spray (NS) heat exchanger room near safe shutdown equipment in accordance with the FPP requirements. The licensee initiated immediate corrective actions to evaluate the transient combustible fire loading and remove all the unapproved transient combustibles from the area. This condition was placed in the licensees corrective action program (CAP).

The licensees failure to control the storage of transient combustibles in accordance with procedure NSD 313 was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective in that a fire involving transient combustibles could have affected nearby power cables and motor operator for valve 2ND-58A which provides a safe shutdown mitigation function. The finding was determined to have very low safety significance (Green) because it did not affect the ability of the reactor to reach and maintain cold shutdown condition. This finding had a cross cutting aspect of Teamwork in the Human Performance area because multiple groups were responsible for bringing the transient combustibles into the area and the individuals failed to effectively communicate and coordinate their activities to ensure that transient combustible control processes were appropriately implemented (H.4). (Section 1R05.1)

Green.

An NRC-identified NCV of the McGuire Unit 1 and Unit 2 Renewed Facility Operating License Condition 2.C.4, FPP, was identified for the licensees failure to adequately control the storage of transient combustibles in waste receptacles equipped with self-extinguishing fire lids in accordance with the FPP requirements. The licensee took actions to correct all waste receptacles in the plant that were filled beyond the manufacturers specification or had loosely fitted lids. This condition was placed in the licensees corrective action program.

The licensees failure to control the storage of transient combustibles in accordance with the requirements of NSD-313 was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective in that the self-extinguishing function was not retained which could allow the spread of the fire and adversely affect mitigating system equipment in the area. The finding was determined to be of very low safety significance (Green) because it did not affect the ability of the reactor to reach and maintain cold shutdown conditions. A cross-cutting aspect was not assigned because the performance deficiency does not reflect current licensee performance. (Section 1R05.2)

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at approximately 100 percent rated thermal power (RTP) for the entire inspection period.

Unit 2 operated at approximately 100 percent RTP until March 22, 2014, when the unit was shutdown for a refueling outage.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

Impending Adverse Weather Conditions: The inspectors reviewed the effectiveness of the licensee's cold weather protection program during extreme cold weather conditions experienced January 6-7, and January 21-23, 2014. This included field walkdowns to assess the functionality and reliability of risk significant freeze protection equipment associated with the Unit 1 and Unit 2 refueling water storage tank level instrumentation, Unit 1 and Unit 2 auxiliary feedwater instrumentation, and the A, B, and C fire pump rooms. The inspectors verified the implementation of applicable action required in procedure PT/0/B/4700/070, On Demand Freeze Protection Verification Checklist, and discussed the details of specific severe cold weather compensatory measures with operations and maintenance personnel. Documents reviewed are listed in the

.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

a. Inspection Scope

Partial Walkdowns: The inspectors performed a partial walkdown of the following four systems to assess the operability of redundant or diverse trains and components when safety equipment was inoperable. The inspectors focused on discrepancies that could impact the function of the system and potentially increase risk. The inspectors reviewed applicable operating procedures and walked down control systems components to verify selected breakers, valves, and support equipment were in the correct position to support system operation. Documents reviewed are listed in the Attachment.

  • 2A ND pump while the 2B ND pump was out of service for scheduled maintenance
  • 2B spent fuel pool (KF) pump while the 2A KF pump was out of service for scheduled maintenance
  • 2A EDG while the 2B EDG was out of service for scheduled maintenance and testing

b. Findings

No findings were identified.

1R05 Fire Protection

a. Inspection Scope

Fire Protection Walkdowns: The inspectors walked down accessible portions of the following five plant areas to determine if they were consistent with the Updated Final Safety Analysis Report (UFSAR) and the fire protection program for defense in depth features. The features assessed included the licensees control of transient combustible material and ignition sources, fire detection and suppression capabilities, firefighting equipment, and passive fire features such as fire barriers. The inspectors also reviewed the licensees compensatory measures for fire deficiencies to determine if they were commensurate with the significance of the deficiency. The inspectors reviewed the fire plans for the areas selected to determine if they were consistent with the fire protection program and presented an adequate firefighting strategy. Documents reviewed are listed in the Attachment.

  • 1A and 1B EDG rooms (Fire Areas 5 and 6)
  • Auxiliary building elevation 767 (Fire Area 25)
  • Auxiliary building elevation 750 (Fire Area 21)
  • 2A and 2B EDG rooms (Fire Areas 7 and 8)
  • Auxiliary building elevation 733 (Fire Area 14)

b. Findings

.1 Inadequate Control of Transient Combustible Materials in Fire Areas

Introduction:

An NRC-identified Green NCV of the McGuire Unit 1 and Unit 2 Renewed Facility Operating License Condition 2.C.4, Fire Protection Program (FPP), was identified for the licensees failure to adequately control the storage of transient combustibles in the 2A ND/NS heat exchanger room near safe shutdown equipment in accordance with the FPP requirements.

Description:

During a walkdown of Unit 2 auxiliary building room 785 (Fire Area 14)containing the 2A ND/NS heat exchangers and other safety-related safe shutdown equipment, the inspectors observed more than 15 pounds of transient combustibles in the room within about 3 feet of the power cables and motor operator for valve 2ND-58A which provides a flowpath for cold leg recirculation during design basis accident conditions. The transient combustibles included several bags of cloth rags, overfilled waste receptacles, nylon and plastic bags, plastic tools and containers, rolls of duct tape, electronic equipment and energized power strips, and an assortment of other combustible rubber and cloth waste materials. The ongoing work activity in the room involved multiple licensee departments and each was responsible for bringing various transient combustibles into the room to support the activities. Procedure NSD 313, Control of Transient Fire Loads, Rev. 14, required that work related ordinary transient combustibles be stored in established temporary housekeeping zones and if the quantity of these combustibles was greater than 15 pounds (the fire hazard analysis limit) or not separated by prescribed distances (in this case, 3 feet) from plant equipment susceptible to fire damage, a transient fire load evaluation must be completed and approved by the site fire protection engineer. The inspectors identified that a housekeeping zone was not established for the work activities in the room and a transient fire load evaluation had not been completed and approved by the fire protection engineer. The licensee initiated immediate corrective actions to evaluate the transient combustible fire loading and remove all the unapproved transient combustibles from the area.

Analysis:

The licensees failure to control the storage of transient combustibles in the 2A ND/NS heat exchanger room without the proper evaluation in accordance with procedure NSD 313 was a performance deficiency (PD). The PD was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective in that a fire involving transient combustibles could have affected nearby power cables and motor operator for valve 2ND-58A which provides a safe shutdown mitigation function. The finding was screened in accordance with NRC Inspection Manual (IMC)0609, Significance Determination Process, dated June 2, 2011, Attachment 4, Initial Characterization of Findings, dated June 19, 2012. Using the guidance in IMC 0609, Appendix F, Attachment 1, Fire Protection SDP Phase 1 Worksheet, dated September 20, 2013, the finding was assigned a category of Fire Prevention and Administrative Controls. The inspectors determined the finding to be of very low safety significance (Green) because it did not affect the ability of the reactor to reach and maintain cold shutdown condition, in that, a postulated fire in the 2A ND/NS heat exchanger room did not present the possibility of impacting more than one train of safe shutdown equipment.

This finding had a cross cutting aspect of Teamwork in the Human Performance area because multiple groups were responsible for bringing the transient combustibles into the area and the individuals failed to effectively communicate and coordinate their activities to ensure that transient combustible control processes were appropriately implemented (H.4).

Enforcement:

McGuire Nuclear Station Unit 1 and 2 Renewed Facility Operating License Condition 2.C.4, Fire Protection, required the licensee to implement and maintain in effect all provisions of the approved FPP as described in Section 9.5.1 of the UFSAR. UFSAR Section 9.5.1.2.1, (General) Program Description, stated, in part, that FPP administrative controls are included in NSDs to manage control of flammable and combustible materials. Procedure NSD 313, Control of Transient Fire Loads, required that work related ordinary transient combustibles be stored in established temporary housekeeping zones and if the quantity of these combustibles is greater than 15 pounds or not separated by prescribed distances from plant equipment susceptible to fire damage, a transient fire load evaluation must be completed and approved by the site fire protection engineer. Contrary to the above, on January 17, 2014, the licensee did not adequately implement the FPP as required by NSD 313, in that, a housekeeping zone was not established for work activities and a transient fire load evaluation was not completed and approved by the site fire protection engineer for greater than 15 pounds of ordinary transient combustibles in close proximity to important safety equipment in the 2A ND/NS heat exchanger room. Because this failure to adequately implement and maintain fire protection administrative controls regarding the storage of transient combustibles is of very low safety significance and was entered into the licensees CAP as PIPs M-14-00487 and M-14-01862, this violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy, and is identified as NCV 05000370/2014002-01, Failure to Adequately Control Transient Combustible Materials in Accordance with the Fire Protection Program.

.2 Inadequate Control of Receptacles Equipped with UL Listed Self-Extinguishing Fire Lids

Introduction:

An NRC-identified Green NCV of the McGuire Unit 1 and Unit 2 Renewed Facility Operating License Condition 2.C.4, FPP, was identified for the licensees failure to adequately control the storage of transient combustibles in waste receptacles equipped with self-extinguishing fire lids in accordance with the FPP requirements.

Description:

During a walkdown of several fire areas in the Unit 1 and 2 auxiliary buildings, the inspectors identified several 55 gallon waste receptacles, used to contain either general area waste or used radiological contaminated protective clothing, that were completely filled with materials and/or had lids that were either loose fitting or had gaps/openings between the receptacle and lid. The receptacles were equipped with self-extinguishing fire lids that had received certification by Underwriters Laboratories (UL) for their fire mitigating protection feature. These lids had specially contoured openings to direct the smoke and gas from a fire within the receptacle back into the combustion area, cutting off the air supply and extinguishing the flames. The licensee's fire protection transient combustible program allowed the permanent storage of receptacles with these lids in all fire areas and credits the fire mitigation feature of the lids in lieu of accounting for the transient combustible fire loading of the materials inside the receptacles. The inspectors reviewed the manufacturer's specifications for these lids and noted that there was both a 75 percent maximum fill requirement and a requirement that the lids be tight-fitting to its receptacle in order to ensure it retains its intended fire mitigation function. The inspectors reviewed procedure NSD 313, Control of Transient Fire Loads, Rev. 14, which specified that waste receptacles equipped with UL approved covers, such as a tight fitting lid or approved self-extinguishing or self-closing lid, shall be inspected on a regular basis and emptied as needed to prevent overfill. The inspectors determined that the licensee had failed to follow NSD 313, in that, waste receptacles fitted with these self-extinguishing lids were not being adequately inspected and emptied to ensure the manufacturers lid tightness and fill requirements were met. The licensee took actions to correct all waste receptacles in the plant that were filled beyond the manufacturers specification or had loosely fitted lids.

Analysis:

The licensees failure to control the storage of transient combustibles in waste receptacles equipped with self-extinguishing fire lids in accordance with the requirements of NSD-313 was a PD. The PD was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective in that the self-extinguishing function was not retained which could allow the spread of the fire and adversely affect mitigating system equipment in the area. The finding was screened in accordance with IMC 0609, Significance Determination Process, dated June 2, 2011, 4, Initial Characterization of Findings, dated June 19, 2012. Using the guidance in IMC 0609, Appendix F, Attachment 1, Fire Protection SDP Phase 1 Worksheet, dated September 20, 2013, the finding was assigned a category of Fire Prevention and Administrative Controls. The inspectors determined the finding to be of very low safety significance (Green) because it did not affect the ability of the reactor to reach and maintain cold shutdown conditions, in that, a postulated fire in the receptacles observed by the inspectors to be overfilled or had lid tightness discrepancies, did not present the possibility of impacting more than one train of safe shutdown equipment. A cross-cutting aspect was not assigned because the performance deficiency does not reflect current licensee performance based on information that the self-extinguishing fire lids and existing procedural guidance had been placed in service in the 1990s and there was no recent industry operating experience that was missed nor other reason that would have prompted the licensee to re-evaluate their waste receptacle storage controls.

Enforcement:

McGuire Nuclear Station Unit 1 and 2 Renewed Facility Operating License Condition 2.C.4, Fire Protection, required the licensee to implement and maintain in effect all provisions of the approved FPP as described in Section 9.5.1 of the UFSAR. UFSAR Section 9.5.1.2.1, (General) Program Description, stated, in part, that FPP administrative controls are included in NSDs to manage control of flammable and combustible materials. The licensee implemented this requirement, in part, through procedure NSD 313, Control of Transient Fire Loads, which specified that waste receptacles containing trash and/or contaminated clothing shall be equipped with an a compatible UL listed or Fire Mutual approved cover such as a tight fitting lid or approved self-extinguishing or self-closing lid, and shall be regularly inspected and emptied as needed to prevent overfill. Contrary to the above, since the late 1990s, the licensee failed to adequately implement the transient combustible control program as required by NSD-313, in that, inspections and necessary empting of waste receptacles equipped with self-extinguishing fire lids were not being adequately performed. This resulted in conditions where waste receptacles were overfilled and/or had loosely fitted lids that could have prevented the lids from performing their design fire mitigation function.

Because this failure to adequately implement and maintain fire protection administrative controls is of very low safety significance and was entered into the licensees CAP as PIP M-14-00487, this violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy, and is identified as NCV 05000369, 370/2014002-02, Failure to Adequately Control the Use of Self-Extinguishing Fire Lids.

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

a. Inspection Scope

Quarterly Resident Inspector LOR Activity Review: On February 26, 2014, the inspectors observed operators in the plants simulator during licensed operator requalification training. The training scenario involved a failed open pressurizer power operated relief valve, reactor coolant system leak on the chemical and volume control system letdown line, and a large steam line break inside containment. The inspectors assessed overall crew performance, clarity and formality of communications, use of procedures, alarm response, control board manipulations, group dynamics, and supervisory oversight. The inspectors observed the post-exercise critique to verify that the licensee identified deficiencies and discrepancies that occurred during the simulator training. Documents reviewed are listed in the Attachment.

Quarterly Resident Inspector Licensed Operator Performance Review: On March 22, 2014, the inspectors observed operators in the main control room and assessed their performance during reactor shutdown activities for the refueling outage. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the two activities listed below for items such as: 1) appropriate work practices; 2) identifying and addressing common cause failures; 3) scoping in accordance with 10 CFR 50.65(b) of the Maintenance Rule; 4) characterizing reliability issues for performance; 5) charging unavailability for performance; 6) balancing reliability and unavailability; 7) trending key parameters for condition monitoring; 8) classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); and 9)appropriateness of performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified as (a)(1). The inspectors performed a detailed review of the problem history and surrounding circumstances, evaluated the extent of condition reviews as required, and reviewed the generic implications of the equipment and/or work practice problem. Documents reviewed are listed in the

.

  • PIP M-13-09701, Potential transformer fuse failure in essential switchgear 2ETA bus
  • PIP M-14-00155, H diesel driven instrument air compressor failure to run

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensees risk assessments and the risk management actions used to manage risk for the plant configurations associated with the five activities listed below. The inspectors assessed whether the licensee performed adequate risk assessments, and implemented appropriate risk management actions when required by 10 CFR 50.65(a)(4). For emergent work, the inspectors verified that any increase in risk was promptly assessed, that appropriate risk management actions were promptly implemented, and that work activities did not place the plant in unacceptable configurations. Documents reviewed are listed in the Attachment.

  • Unplanned Yellow Risk on Unit 1 and Unit 2 due to Red grid condition generated as a result of low generation capacity reserve margin
  • Yellow Risk on Unit 2 while 2B EDG out of service for hot web deflection following 24-hr engine run
  • Yellow Risk on Unit 2 for planned maintenance and testing of the 2B ND and 2B component cooling water (KC) pumps
  • Green Risk on Unit 2 for planned maintenance and testing of valve 2RN-162B which supplies the assured safety-related water source to the 2B motor driven auxiliary feedwater (MDCA) pump
  • Yellow Risk on Unit 2 for emergent critical maintenance to enter pressurizer cavity to investigate possible leakage of the power operated relief valves

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed the five technical evaluations listed below to determine whether Technical Specification (TS) operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors reviewed any compensatory measures taken for degraded SSCs to determine whether the measures were in-place and adequately compensated for the degradation. For the degraded SSCs, or those credited as part of compensatory measures, the inspectors reviewed the UFSAR to determine whether the measures resulted in changes to the licensing basis functions, as described in the UFSAR, and whether a license amendment was required per 10 CFR 50.59. Documents reviewed are listed in the Attachment.

  • PIP M-14-01006, 1A ND heat exchanger KC outlet flow control valve (1KC-57A)travel stop handwheel position discrepancy
  • PIP M-14-01114, MDCA pump brake horsepower low margin
  • PIP M-14-02117, Unit 2 ice condenser baskets
(2) with projected ice mass trend close to TS minimum

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

The inspectors reviewed the following temporary modification to verify the adequacy of the modification packages and 10 CFR 50.59 screening. The modification was evaluated against the TS, UFSAR, and licensee design bases documents for the systems affected to ensure the modification did not adversely affect the availability, reliability, and functional capability of important SSCs. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the six post-maintenance tests listed below to determine if procedures and test activities ensured system operability and functional capability. The inspectors reviewed the licensees test procedures to determine if the procedures adequately tested the safety function(s) that may have been affected by the maintenance activities, that the acceptance criteria in the procedures were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedures had been properly reviewed and approved. The inspectors also witnessed the tests and/or reviewed the test data to determine if test results adequately demonstrated restoration of the affected safety functions. Documents reviewed are listed in the Attachment.

  • 2B1 and 2B2 KC pump functional testing following ground fault relay replacement on 4160 volt switchgear breakers 2ETB-12 and 2ETB-13
  • 2A EDG room ventilation damper functional testing following fuse replacement for damper control solenoid valves SV-9190 and SV-9230
  • 1A EDG control circuit timer functional testing following relay calibrations
  • 2B ND pump functional testing following planned preventive maintenance
  • 2A KF pump functional testing following planned preventive maintenance
  • 2B EDG functional testing following planned preventive maintenance

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

The inspectors conducted portions of the following inspection activities associated with the Unit 2 refueling outage that started March 22, 2014. Documents reviewed are listed in the Attachment.

  • Observed portions of the cool down process to determine if TS cool down restrictions were followed
  • Reviewed the licensees responses to emergent work and unexpected conditions to determine if configuration changes were controlled in accordance with the outage risk control plan
  • Observed outage activities to determine if the licensee maintained defense-in-depth commensurate with the outage risk control plan for the key safety functions and applicable TS
  • Assessed outage activities that were conducted during short time-to-boil periods
  • Observed fuel handling operations (offload) and other ongoing fuel handling activities to determine if those operations and activities were being performed in accordance with TS and licensee procedures.
  • Reviewed selected system lineups and/or control board indications to determine if TS, license conditions, and other requirements, commitments, and administrative procedure prerequisites for mode changes were met prior to changing modes or plant configurations
  • Reviewed/observed controls for establishing containment closure to determine if the NC system and containment boundaries were in place when necessary
  • Reviewed items that had been entered into the licensees CAP to determine if the licensee had identified problems related to outage activities at an appropriate threshold and had entered them into the CAP

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

For the five surveillance tests identified below, the inspectors witnessed testing and reviewed the test data, to determine if the SSCs involved in these tests satisfied the requirements described in the TS, the UFSAR, and applicable licensee procedures. In addition, the inspectors verified that the tests demonstrated that the SSCs were capable of performing their intended safety functions.

Surveillance Tests

  • PT/2/A/4252/001A, 2A CA Pump Performance Test, Rev. 90
  • PT/1/A/4401/001B, KC Train 1B Performance Test, Rev. 72
  • PT/0/A/4250/001, Main Steam Valve Setpoint Test Using Crosby Airset Device, Rev.

In-Service Tests

  • PT/1/A/4252/002B, CA Valve Stroke timing - Quarterly 1B Motor Driven Pump Flowpath, Rev. 46 Reactor Coolant System Leakage Testing

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

a. Inspection Scope

Quarterly Site Emergency Preparedness Training Drill: On March 6, 2014, the inspectors evaluated the licensees performance of a quarterly licensee emergency preparedness training exercise from the simulator control room and Technical Support Center. The exercise scenario involved a damaged fuel assembly in the spent fuel pool, steam generator tube leak/rupture, and steam line break outside containment. The inspectors assessed the licensee emergency procedure usage, emergency plan classifications, notifications, and protective action recommendation development. The inspectors attended the post-exercise critique for the drill to evaluate the adequacy of the licensees self-assessment process for identifying potential exercise performance deficiencies and weaknesses. The inspectors verified that any deficiencies or weaknesses were entered into the licensees CAP. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors sampled licensee data to confirm the accuracy of reported PI data for the six indicators during the periods listed below. To determine the accuracy of the PI data, the inspectors compared the licensees basis in reporting each data element to the PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. 6. Documents reviewed are listed in the Attachment.

Initiating Events Cornerstone

  • Unplanned Scrams per 7000 Critical Hours (Units 1 and 2)
  • Unplanned Scrams with Complications (Units 1 and 2)

The inspectors sampled licensee submittals relative to the PIs listed above for the period January 1, 2013, through December 31, 2013. The inspectors independently screened Licensee Event Reports, TS narrative logs, and the licensees CAP database to verify that the licensee had adequately identified the number of scrams and unplanned power changes greater than 20 percent that occurred during the period and compared this number to the number reported for the PI. The inspectors also reviewed the accuracy of the number of critical hours reported and the licensees basis for determining that there were not complications for each of the reported reactor scrams. In addition, the inspectors interviewed licensee personnel associated with the PI data collection, evaluation, and distribution.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

a. Inspection Scope

Review of Items Entered into the CAP: As required by Inspection Procedure 71152, Problem Identification and Resolution, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed screening of items entered into the licensees CAP. This was accomplished by reviewing copies of condition reports, attending some daily screening meetings, and accessing the licensees computerized CAP database.

Annual Sample Review of Operator Workarounds (OWAs): The inspectors reviewed the licensees list of identified OWAs, equipment deficiencies, and plant concerns to determine whether any new items since the previous review conducted in 2013 would adversely affect any mitigating system function or affect the operators ability to implement abnormal or emergency operating procedures. The inspectors reviewed the classification assigned to the identified OWAs to ensure they were properly prioritized based on the licensees program requirements. For high priority OWAs where compensatory actions were developed, the inspectors verified the feasibility of implementing these prescribed actions. The inspectors verified that long term corrective actions were developed to adequately address the underlying issues identified in the OWAs. In addition, the inspectors attended a quarterly OWA meeting between operations, engineering, and chemistry personnel to discuss the status of open OWAs and new OWA candidates. Documents reviewed are listed in the Attachment.

Annual Sample Reviews: The inspectors reviewed the issue listed below in detail to evaluate the effectiveness of the licensees corrective actions for important safety issues.

  • PIP M-13-10176, 2A EDG emergency breaker failure to close The inspectors assessed whether the issue was properly identified; documented accurately and completely; properly classified and prioritized; adequately considered extent of condition, generic implications, common cause, and previous occurrences; adequately identified root causes/apparent causes; and identified appropriate and timely corrective actions. The inspectors evaluated the licensee documents against the requirements of the licensees CAP and implementing procedures, and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

4OA3 Followup of Events and Notices of Enforcement Discretion (NOED)

.1 (Closed) Licensee Event Report (LER) 05000369/2013-003-00 and -01, Manual Reactor

Trip and Auxiliary Feedwater Start Due to Dropped Control Rods

a. Inspection Scope

On November 14, 2013, Unit 1 was manually tripped from 100 percent RTP after a loss of primary and backup 24 volt direct current (VDC) power in the 1AC rod control cabinet.

All safety equipment responded as expected and the reactor was stabilized in Mode 3 at normal operating pressure and temperature. The inspectors reviewed the subject LER, its supplement and PIP M-13-10440 to verify the accuracy of the LERs and appropriateness of corrective actions. The supplement to this LER documented completion of the licensees causal analysis and included laboratory testing results reviewed by a third party that confirmed the original root cause.

b. Findings

Introduction:

A self-revealing Green finding (FIN) was identified for the licensees failure to implement adequate design control measures for the rod control power supply modification which resulted in the loss of 24VDC power in the 1AC rod control power cabinet.

Description:

On November 14, 2013, an instrumentation and electrical (IAE) crew was in the process of replacing a blown fuse for an out-of-service blower fan in rod control cabinet 1AC. When the new fuse was installed, the control room received a Rod Control Non-Urgent Failure alarm. Suspecting a problem with the backup -24VDC power supply (PS4), a work package was authorized to troubleshoot. Per the work package, the IAE crew removed the supply fuse to de-energize PS4. Upon removal of the PS4 supply fuse, the primary -24VDC power supply (PS3) tripped on overvoltage which resulted in a loss of DC power to the control rod drive mechanism for the rods associated with the 1AC cabinet causing ten rods to drop. Operators responded to the multiple rod drop by manually tripping the Unit 1 reactor as required by procedures.

In 1997, the licensee implemented power supply modification MGMM-8765 to replace the original PS3 and PS4 rod control power supplies without overvoltage protection to a new model with overvoltage protection. The design change included the configuration of the over voltage protection (OVP) setting by adding a trim jumper which increased the power supplys OVP sensitivity by approximately 1.5 volts greater. The addition of the trim jumper reduced the operating voltage margin for both PS3 and PS4 power supplies which increased the potential for a loss of -24VDC power in the rod control cabinet due to minor voltage transients. On November 14, 2013, the removal of the supply fuse to PS4 created a minor voltage transient that caused PS3 to trip on overvoltage.

McGuire Modification Manual, Section 5.0, Minor Modification Process, rev 5, required the modification originator to conduct a modification design review the to ensure that the design was adequate for its intended application. Section 5.4, Review and Approval, required an equally qualified Checker review that the actions taken by the originator, including the design approach, design assumptions, and design inputs, were technically correct. The inspectors determined that the licensee did not implement adequate design control measures during the modification process for the configuration of the OPV setting to ensure that the OVP function was reliable in that the redundant power supply would not trip when exposed to minor voltage transients.

Analysis:

The inspectors determined that the licensees failure to implement adequate design control measures was a PD. The PD was more than minor because it affected the Design Control attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective, in that, the insufficient margin in the rod control power supply OVP function caused in a multiple drop rod event which resulted in a reactor trip. Using IMC 0609, dated June 2, 2011, this finding was determined to have very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. A cross-cutting aspect was not assigned because the performance deficiency does not reflect current licensee performance in that the modification review occurred in 1997.

Enforcement:

The rod control system is not safety-related equipment; therefore, no violation of NRC requirements occurred. Because this finding does not involve a violation or regulatory requirements, was of very low safety significance, and has been entered into the licensees CAP as PIP M-13-10440, it is identified as FIN 05000369/2014002-03, Inadequate Design Control Measures for Rod Control Power Supply Modification.

4OA5 Other Activities

.1 Cross-Reference of 2013 Findings with Cross-Cutting Aspects to New Cross-Cutting

Aspect Terminology The table below provides a cross-reference from the 2013 and earlier findings and associated cross-cutting aspects to the new cross-cutting aspects resulting from the common language initiative. These aspects and any others identified since January 2014, will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review.

Finding Old Cross-Cutting Aspect New Cross-Cutting Aspect None N/A N/A

4OA6 Meetings, Including Exits

On April 10, 2014, the resident inspectors presented the inspection results to Mr. Steven Capps and other members of his staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

B. Anderson, Superintendent of Operations
D. Black, Security Manager
S. Capps, Vice President, McGuire Nuclear
K. Crane, Senior Licensing Specialist
J. Gabbert, Chemistry Manager
J. Hicks, Maintenance Superintendent
M. Kelly, Outage and Scheduling Manager
S. Mooneyhan, Radiation Protection Manager
C. Morris, Station Manager
J. Robertson, Regulatory Compliance Manager
P. Schuerger, Training Manager
S. Snider, Engineering Manager

LIST OF REPORT ITEMS

Opened and Closed

NCV

05000370/2014002-01 Failure to Adequately Control Transient Combustible Materials in Accordance with the Fire Protection Program (Section 1R05.1)

NCV

05000369, 370/2014002-02 Failure to Adequately Control the Use of Self-

Extinguishing Fire Lids (Section 1R05.2)

FIN

05000369/2014002-03 Failure to Implement Adequate Design Control Measures for Rod Control Power Supply Replacement Resulting in Reactor Trip (Section 4OA3)

Closed

LER

05000369/2013-003-00, -01 Manual Reactor Trip and Auxiliary Feedwater Start due to Dropped Control Rods (Section 4OA3)

DOCUMENTS REVIEWED