IR 05000305/2007004

IR 05000305-07-004; on 7/1/2007 - 9/30/2007; Kewaunee Power Station, Maintenance Risk Assessments and Emergent Work Control, Surveillance Testing, Followup of Events and Notices of Enforcement Discretion

ML073090271
Person / Time
Site:	Kewaunee
Issue date:	11/02/2007
From:	Jamnes Cameron NRC/RGN-III/DRP/RPB5
To:	Christian D Dominion Energy Kewaunee
References
IR-07-004
Download: ML073090271 (54)

Text

ber 2, 2007

SUBJECT:

KEWAUNEE POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000305/2007004

Dear Mr. Christian:

On September 30, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Kewaunee Power Station. The enclosed integrated inspection report documents the inspection findings, which were discussed on October 3, 2007, with Ms. L. Hartz and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

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

Based on the results of this inspection, there were two NRC-identified findings of very low safety significance which involved violations of NRC requirements. In addition, one issue was reviewed under the NRC traditional enforcement process and determined to be a Severity Level IV violation of NRC requirements. However, because these violations were of very low safety significance and because the issues were entered into your corrective action program, the NRC is treating these findings and issue as non-cited violations (NCVs),

in accordance with Section VI.A.1 of the NRC Enforcement Policy. Additionally, three licensee-identified violations are listed in Section 4OA7 of this report. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Kewaunee Power Station. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Jamnes L. Cameron, Chief Branch 5 Division of Reactor Projects Docket No. 50-305 License No. DPR-43 Enclosure: Inspection Report 05000305/2007004 w/Attachment: Supplemental Information cc w/encl: L. Hartz, Site Vice President C. Funderburk, Director, Nuclear Licensing and Operations Support T. Breene, Manager, Nuclear Licensing L. Cuoco, Esq., Senior Counsel D. Zellner, Chairman, Town of Carlton J. Kitsembel, Public Service Commission of Wisconsin State Liaison Officer, State of Wisconsin

SUMMARY OF FINDINGS

IR 05000305/2007004; 7/1/2007 - 9/30/2007; Kewaunee Power Station. Maintenance Risk

Assessments and Emergent Work Control, Surveillance Testing, Followup of Events and Notices of Enforcement Discretion.

This report covers a three-month period of inspection by resident inspectors and announced inspections by regional specialists. Two Green findings and one Severity Level IV violation, all associated with non-cited violations (NCVs), were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Initiating Events

Green.

The inspectors identified a finding of very low safety significance and an associated non-cited violation of 10 CFR 50.65(a)(1), Requirements for monitoring the effectiveness of maintenance at nuclear power plants.

Specifically, as of August 25, 2007, the licensee failed to implement the Maintenance Rule (a)(1) action plan which had been incorporated into plant procedure N-AS-01 to preclude a loss of the G air compressor. The licensee entered the issue into their corrective action program. Corrective actions have included implementation of the procedural requirements of N-AS-01 for both the G and F air compressors.

The finding is greater than minor because it relates to a licensee failure to implement prescribed significant compensatory measures to manage risk and implement the 10 CFR 50.65(a)(1) action plan. Additionally, the finding is associated with the equipment performance attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix A, Significance Determination Process, and determined that this finding is of very low safety significance by answering No to all questions in the Initiating Events Cornerstone column. (Section 1R13)

Cornerstone: Barrier Integrity

Green.

The inspectors identified a finding of very low safety significance and an associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V,

Instructions, Procedures, and Drawings, during plant preparations to perform Surveillance Procedure SP-23-100B, Train B Containment Spray Pump and Valve Test - IST. Specifically, the inspectors noted on August 8, 2007, that shortly prior to performing the surveillance procedure, the plant had hung safety tags on the containment spray system in order to perform repair activities on IDS-102, a check valve in that system. These tags required that normally open motor- operated valves IDS-202 and IDS-2B be cycled closed and tagged in order to isolate the check valve. Because these motor-operated valves were required to be stroke and time-tested during the performance of the surveillance procedure, and the effects of preconditioning on these valves was not considered prior to implementation of the maintenance activity, the inspectors determined that plant procedures were inadequate to assess preconditioning implications associated with station activities. The licensee entered the issue into their corrective action program. Corrective actions included completion of the surveillance procedure with acceptable results and a evaluation of the test results, which determined that the surveillance test was acceptable.

The finding is greater than minor because it was associated with the configuration control attribute of the Barrier Integrity Cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. The inspectors evaluated the finding using IMC 0609, Appendix A, Significance Determination Process, and determined that this finding is of very low safety significance by answering No to all questions in the containment barriers cornerstone column.

The inspectors also determined that the primary cause for this finding is related to the cross-cutting area of human performance. Specifically, under the component of resources, procedures to assess and prevent preconditioning of safety-related components were not complete, accurate, and up-to-date (H.2(c)).

(Section 1R22)

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding of very low safety significance for the licensee's failure to adequately update the Updated Safety Analysis Report (USAR) in accordance to 10 CFR 50.71, Maintenance of records, making of reports. The licensee failed to update the USAR to fully reflect changes and analyses made in response to license amendment 184. Once identified, the licensee entered this issue into its corrective action program.

Because this issue potentially impacted the NRC's ability to perform its regulatory function, this finding was evaluated using the traditional enforcement process. The finding is greater than minor because of the failure to provide complete licensing and design basis information in the USAR could result in either the licensee making an inappropriate licensing interpretation or the NRC making an inappropriate regulatory decision based on incomplete information in the USAR. The issue is of very low safety significance based upon a Phase 2 significance determination analysis of the associated technical issue. The issue was a NCV of 10 CFR 50.71(e), which required that the USAR be updated to include the effects of all safely evaluations performed by the licensee in support of requested license amendments. The primary cause of this violation is related to the cross-cutting area of problem identification and resolution because the extent of condition review performed for a recent and similar violation failed to identify the issue even though it was within the scope of the extent of condition review which had been performed (P.1(c)). (Section 4OA3.1)

Licensee-Identified Violations

Violations of very low safety significance, which were identified by the licensee, have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Kewaunee operated at full power for the entire inspection period except for brief downpowers to conduct planned surveillance testing activities with the following exception:

• on July 14, 2007, reactor power was reduced to 87 percent to facilitate repairs on transmission line R-304 and on heater drain pump B. Full power operation was resumed on July

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial walkdowns of accessible portions of trains of risk-significant mitigating systems equipment. The inspectors reviewed equipment alignment to identify any discrepancies that could impact the function of the system and potentially increase risk. Identified equipment alignment problems were verified by the inspectors to be properly resolved. The inspectors selected redundant or backup systems for inspection during times when equipment was of increased importance due to unavailability of the redundant train or other related equipment. Inspection activities included, but were not limited to, a review of the licensees procedures, verification of equipment alignment, and an observation of material condition, including operating parameters of equipment in-service. As part of this inspection, the documents listed in the Attachment were reviewed.

The inspectors selected the following equipment trains to assess operability and proper equipment line-up for a total of eight inspection samples:

• service water train A with service water train B out-of-service for maintenance;

• residual heat removal (RHR) system B following system testing;

• turbine-driven auxiliary feedwater after service water header flushing;

• instrument busses 2 and 3 and associated power supply following maintenance;

• emergency diesel generator B upon restoration from semiannual operability test;

• auxiliary feedwater pump B upon restoration from instrument testing;

• auxiliary feedwater pumps after B service water header flushing; and

• safety injection system B upon restoration from maintenance.

b. Findings

No findings of significance were identified.

.2 Complete System Walkdown

a. Inspection Scope

The inspectors performed a complete walkdown of equipment for one risk significant mitigating system. The inspectors walked down the system to review mechanical and electrical equipment line-ups, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of past and outstanding work orders was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that any system equipment alignment problems were being identified and appropriately resolved. As part of this inspection, the documents listed in the Attachment were reviewed.

The inspectors selected the chemical volume and control system to assess operability and proper equipment line-up for a total of one inspection sample.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Quarterly Fire Zone Walkdowns

a. Inspection Scope

The inspectors walked down risk significant fire areas to assess fire protection requirements. The inspectors reviewed areas to assess whether the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and had implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events, or the potential to impact equipment which could initiate or mitigate a plant transient. The inspection activities included, but were not limited to, the control of transient combustibles and ignition sources, fire detection equipment, manual suppression capabilities, passive suppression capabilities, automatic suppression capabilities, compensatory measures, and barriers to fire propagation. As part of this inspection, the documents listed in the Attachment were reviewed.

The inspectors selected the following areas for review, for a total of 18 inspection samples:

• PFP-4, Screen House and Tunnel;

• PFP-5, 1A Diesel Generator and Diesel Generator Day Tank Rooms;

• PFP-6, 1B Diesel Generator and Diesel Generator Day Tank Rooms;

• PFP-7, CO2 Storage Tank Room;

• PFP-8, 480-Volt Switchgear Bus 1-51 and 1-52 Room;

• PFP-9, 480-Volt Switchgear Bus 1-61 and 1-62 Room and Auxiliary Feedwater Pump Area;

• PFP-11, Turbine Building Basement;

• PFP-12, Turbine Building Mezzanine;

• PFP-14, Turbine Building Operating Floor;

• PFP-16, Refueling Water Storage Tank and Containment Spray Pump Area;

• PFP-17, Charging Pump, Boric Acid Concentrate Pump and RHR Pump Pit Areas;

• PFP-19, Condensate Storage and Reactor Make Up Water Storage Room and Adjacent Areas;

• PFP-20, Materials Storage and Radiation Protection Office Areas;

• PFP-22, RHR Heat Exchanger, Component Cooling Water Pump, Letdown and Sealwater Filter Areas, and Refueling Water Storage Tank and Valve Gallery;

• PFP-24, Main Steam Line B Relief Header and Cable spreading Area;

• PFP-26, Control Room;

• PFP-28, Control Room Heating, Ventilation, Heating and Air Conditioning Equipment and Records Storage Room; and

• PFP-29, Auxiliary Building and Turbine Building Fan Rooms.

b. Findings

No findings of significance were identified.

.2 Annual Fire Drill Review

a. Inspection Scope

The inspectors reviewed fire drill activities to evaluate the licensees ability to control combustibles and ignition sources, the use of fire fighting equipment, and their ability to mitigate the event. The inspection activities included, but were not limited to, the fire brigades use of fire fighting equipment, effectiveness in extinguishing the simulated fire, effectiveness of communications amongst fire brigade members and the control room, command and control by the fire commander, and observation of the post-drill critique.

As part of this inspection, the documents listed in the Attachment were reviewed.

The inspectors observed the licensees fire brigade response to an announced fire drill in the main transformer area, for a total of one inspection sample.

b. Findings

No findings of significance were identified.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors performed an annual review of the licensees testing of heat exchangers.

The inspection focused on potential deficiencies that could mask the licensees ability to detect degraded performance, identification of any common cause issues that had the potential to increase risk, and ensuring that the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspection activities included, but were not limited to, a review of the licensees observations as compared against acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. Inspectors also verified that test acceptance criteria considered differences between test conditions, design conditions, and testing criteria. As part of this inspection, the documents listed in the Attachment were reviewed.

The inspectors selected the auxiliary building basement fan coil units, for a total of one inspection sample.

b. Findings

Auxiliary Building Heating and Ventilation Calculations Potentially Unconservative

Introduction:

The inspectors identified an unresolved item (URI) associated with potentially inoperable Technical Specification (TS) related equipment due to support system unavailability and related calculational issues.

Discussion: On August 17, 2007, the daily work schedule indicated that an administrative limiting condition for operation was planned for work associated with the auxiliary building fan coil units. The inspectors inquired about the basis for the administrative limiting condition for operation and found that the related calculations indicated that under certain post-accident combinations of pump and room cooler operation that the coolers may not be fully capable of removing the heat from the system. As a result, the inspectors selected the associated fan coil unit to review as a sample for heat sink performance.

During the inspectors reviews, it appeared that certain combinations of room coolers and equipment did not support operability of equipment as defined by TSs. Additionally, when the licensee was questioned about requirements for entry into related limiting conditions for operation, they referenced a letter to another licensee which Kewaunee had not made Kewaunee-specific through the 10 CFR 50.59 process or an amendment request. The inspectors concluded that the application of non-license specific information to the operation of Kewaunee was a performance deficiency. Additionally, the licensees related Calculation, C11157, Auxiliary Building Basement Post Accident Heat Gain, dated May 26, 2007, predated the specified letter, as such, the failure of the licensee to recognize the TS implications at the time of the development of the calculations was also a performance deficiency.

As a result of procedural changes that came about after the inspectors inquires and of other auxiliary building issues that existed with the mezzanine room coolers, the on-site safety review committee requested that engineering review all calculations for auxiliary building ventilation. Because the continuing reviews identified other room cooling issues that could impact the operability of safety-related equipment, the inspectors considered this issue unresolved pending the licensees finalization of related calculations and possible submittal of any related licensee event reports (LERs).

(URI 05000305/2007004-01)

1R11 Licensed Operator Requalification Program

a. Inspection Scope

The inspectors performed a quarterly review of licensed operator requalification training.

The inspectors assessed the licensees effectiveness in evaluating the requalification program, ensuring that licensed individuals operate the facility safely and within the conditions of their license, and evaluated licensed operator mastery of high-risk operator actions. The inspection activities included, but were not limited to, a review of high risk activities, emergency plan performance, incorporation of lessons-learned, clarity and formality of communications, task prioritization, timeliness of actions, alarm response actions, control board operations, procedural adequacy and implementation, supervisory oversight, group dynamics, interpretations of TSs, simulator fidelity, and licensee critique of performance. As part of this inspection, the documents listed in the were reviewed.

The inspectors observed a licensed operator requalification training crew during an evaluated simulator scenario that included a steam generator level control failure, a loss of nonsafety-related busses accompanied with a failure to trip the reactor, and a loss of feedwater to the steam generators, for a total of one inspection sample.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

.1 Quarterly Reviews of Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed systems to assess maintenance effectiveness, including maintenance rule activities, work practices, and common cause issues. Inspection activities included, but were not limited to, the licensee's categorization of specific issues, including evaluation of performance criteria, appropriate work practices, identification of common cause errors, extent of condition, and trending of key parameters. Additionally, the inspectors reviewed implementation of the Maintenance Rule (10 CFR 50.65) requirements, including a review of scoping, goal-setting, performance monitoring, short-term and long-term corrective actions, functional failure determinations associated with reviewed corrective action program documents, and current equipment performance status. As part of this inspection, the documents listed in the Attachment were reviewed.

The inspectors performed the following maintenance effectiveness reviews, for a total of four inspection samples:

C a function-oriented review of the chemical volume and control system because the licensee designated it as risk significant under the Maintenance Rule; C an issue/problem-oriented review of the main turbine generator system because the licensee designated it as risk significant under the Maintenance Rule and the system experienced hydrogen cooler leakage; C an issue/problem-oriented review of structures - auxiliary building roof because the licensee designated it as risk significant under the Maintenance Rule and the system experienced water leakage impacting the auxiliary building special ventilation zone; and C a function-oriented review of the heater drain pumps because the licensee designated it as risk significant under the Maintenance Rule.

b. Findings

No findings of significance were identified.

.2 Maintenance Effectiveness Periodic Evaluation Periodic Evaluation

a. Inspection Scope

The inspectors examined the last two maintenance rule periodic evaluation reports completed for June 2004 through December 2004 and January 2005 through June 2006. The inspectors reviewed a sample of (a)(1) Action Plans, Performance Criteria, Functional Failures, and Condition Reports to evaluate the effectiveness of (a)(1) and (a)(2) activities. These same documents were reviewed to verify that the threshold for identification of problems was at an appropriate level and the associated corrective actions were appropriate. Also, the inspectors reviewed the maintenance rule procedures and processes. The inspectors focused the inspection on the following systems (samples):

C 4160-Volt Distribution; C Safety Injection; C Direct Current Supply and Distribution; C Chemical and Volume Control; and C Station and Instrument Air The inspectors verified that the periodic evaluations were completed within the time restraints defined in 10 CFR 50.65 (once per refueling cycle, not to exceed 24 months).

The inspectors also ensured that the licensee reviewed its goals, monitored Structures, Systems, and Components (SSCs) performance, reviewed industry operating experience, and made appropriate adjustments to the maintenance rule program as a result of the above activities.

The inspectors verified that:

C the licensee balanced reliability and unavailability during the previous cycle, including a review of high safety significant SSCs; C (a)(1) goals were met, that corrective action was appropriate to correct the defective condition, including the use of industry operating experience, and that (a)(1) activities and related goals were adjusted as needed; and C the licensee has established (a)(2) performance criteria, examined any SSCs that failed to meet their performance criteria, and reviewed any SSCs that have suffered repeated maintenance preventable functional failures including a verification that failed SSCs were considered for (a)(1).

In addition, the inspectors reviewed maintenance rule self-assessments and audit reports that addressed the maintenance rule program implementation.

This review represented five triennial inspection samples.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments (RAs) and Emergent Work Control

a. Inspection Scope

The inspectors reviewed maintenance activities to review RAs and emergent work control. The inspectors verified the performance and adequacy of RAs, management of resultant risk, entry into the appropriate licensee-established risk bands, and the effective planning and control of emergent work activities. The inspection activities included, but were not limited to, a verification that licensee RA procedures were followed and performed appropriately for routine and emergent maintenance, that RAs for the scope of work performed were accurate and complete, that necessary actions were taken to minimize the probability of initiating events, and that activities to ensure that the functionality of mitigating systems and barriers were performed. Reviews also assessed the licensee's evaluation of plant risk, risk management, scheduling, configuration control, and coordination with other scheduled risk significant work for these activities. Additionally, the assessment included an evaluation of external factors, the licensee's control of work activities, and appropriate consideration of baseline and cumulative risk. As part of this inspection, the documents listed in the Attachment were reviewed.

The inspectors observed maintenance or planning for the following activities or risk significant systems undergoing scheduled or emergent maintenance, for a total of seven inspection samples:

• work schedule change associated with the service water pretreatment filters;

• work schedule change and increased tagging activities for instrument air receivers A and C relief valves;

• risk management during charging pump trip;

• work schedule changes to replace service water pressure switch and traveling screen B2" work scope change;

• air compressor G inadvertent trip;

• risk profile change due to thunderstorm watch; and

• risk profile change due to vehicle in switch yard.

b. Findings

Failure to Implement Maintenance Rule (a)(1) Corrective Actions on the G Instrument Air Compressor

Introduction:

A finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR 50.65(a)(1), Requirements for monitoring the effectiveness of maintenance at nuclear power plants, was identified by the inspectors during discussions with plant personnel regarding a trip of the G air compressor, a component designated as risk significant in the plant probabilistic risk assessment (PRA) model.

Description:

The G air compressor is designated as risk significant in the plant PRA model. Additionally, the G air compressor is in Maintenance Rule (a)(1) status, in part, due to this air compressor tripping on high temperature. As a result, a maintenance rule (a)(1) action plan had been developed that included interim corrective actions to open the doors on the air compressor and to provide additional ventilation to support operation of the compressor. These interim corrective actions were incorporated into plant procedure N-AS-01, Station and Instrument Air System.

On the morning of August 22, 2007, plant engineering personnel advised operations personnel that the G instrument air compressor high pressure outlet air temperature was increasing and approaching the trip setpoint. Implementation of the interim corrective actions in procedure N-AS-01 to support operation of the air compressor was discussed at that time. In the afternoon of August 22, engineering personnel again contacted plant operations and advised them that the air temperature was nearing its trip setpoint. At that time, engineering personnel recommended that the interim corrective actions of N-AS-01 be implemented, or that the G air compressor be shutdown and the F air compressor be started, however these actions were not taken. On August 25, at approximately 11:30 a.m., the G air compressor tripped on high temperature and the standby F air compressor started and assumed load before the declining air system pressure affected reactor operations. The inspectors concluded that the failure to implement the interim corrective actions of N-AS-01 resulted in a high temperature trip of the G air compressor, increased plant operating risk, and was a failure to implement the 10 CFR 50.65(a)(1) action plan requirements established in procedure N-AS-01.

Analysis:

The inspectors determined that the licensees failure to implement the requirements of N-AS-01 for the G air compressor, which resulted in a high temperature trip of that air compressor, was a performance deficiency and a finding.

The inspectors concluded that the finding is greater than minor in accordance with Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 20, 2007, in that the finding relates to a licensee failure to implement prescribed significant compensatory measures to manage risk and implement the 10 CFR 50.65(a)(1) action plan. Additionally, the finding is associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the licensee failed to implement proceduralized interim corrective actions to prevent a high temperature trip of the G air compressor.

The inspectors evaluated the finding using Appendix A of IMC 0609, Significance Determination Process, and determined that this finding is of very low safety significance (Green) by answering No to all questions in the initiating events cornerstone column.

Enforcement:

10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance and nuclear power plants, paragraph (a)(1) states in part that When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken. Contrary to this, the licensee failed to implement appropriate corrective actions established in N-AS-01 to prevent a high temperature trip of the G air compressor, a component which was in maintenance rule (a)(1) status. The licensee entered this issue into the plant corrective action program as CR018623, Station and Instrument Air Compressor Fault; Air Compressor G HP Air Out Temp Hi Trip, and, as corrective action, subsequently implemented the procedural requirements of N-AS-01 on both the G and F air compressors. Because this violation was of very low safety significance and was entered into the licensees corrective action program, this violation is being treated as an NCV consistent with Section VI.A of the NRC enforcement policy (NCV 05000305/2007004-02).

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed operability evaluations that affected mitigating systems or barrier integrity to ensure that operability was properly justified and that the component or system remained available. The inspection activities included, but were not limited to, a review of the technical adequacy of the operability evaluations to determine the impact on TSs, the significance of the evaluations to ensure that adequate justifications were documented, and that risk was appropriately assessed. As part of this inspection, the documents listed in the Attachment were reviewed.

The inspectors reviewed the following operability evaluations for a total of three inspection samples:

• calculation assumptions exceeded for motor-operated valves;

• condensate storage tank interface with auxiliary feedwater pumps; and

• reasonable assurance for safety for the auxiliary building special ventilation zone.

b. Findings

No findings of significance were identified.

1R17 Permanent Plant Modifications

a. Inspection Scope

The inspectors review of permanent plant modifications focused on verification that the design bases, licensing basis, and performance capability of related SSCs were not degraded by the installation of the modification. The inspectors also verified that the modifications did not place the plant in an unsafe configuration. The inspection activities included, but were not limited to, a review of the design adequacy of the modification by performing a review, or partial review, of the modifications impact on plant electrical requirements, material requirements and replacement components, response time, control signals, equipment protection, operation, failure modes, and other related process requirements. As part of this inspection, the documents listed in the were reviewed.

The inspectors selected a modification to provide cooling water to the safety-related service water pumps from the plant equipment water system for review for a total of one inspection sample.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors verified that the post-maintenance test procedures and activities were adequate to ensure system operability and functional capability. Activities were selected based upon the SSC's ability to impact risk. The inspection activities included, but were not limited to, witnessing or reviewing the integration of testing activities, applicability of acceptance criteria, test equipment calibration and control, procedural use and compliance, control of temporary modifications or jumpers required for test performance, documentation of test data, system restoration, and evaluation of test data. Also, the inspectors verified that maintenance and post-maintenance testing activities adequately ensured that the equipment met the licensing basis, TSs, and USAR design requirements. As part of this inspection, the documents listed in the were reviewed.

The inspectors reviewed post-maintenance activities associated with the following components for a total of eight inspection samples:

• post-maintenance testing of charging pumps A and C following maintenance;

• post-maintenance testing of traveling water screens following replacement of the drive hub

• post-maintenance testing of service water pump 1B following replacement of the cooling water pressure regulator;

• post-maintenance testing of spent fuel cooling water pump following maintenance;

• post-maintenance testing of the spent fuel pool cooling water heat exchanger following maintenance;

• post-maintenance testing of the reactor makeup water pump motor starter following restoration after preventative maintenance;

• post-maintenance testing of the battery room fan coil unit B following restoration after planned maintenance; and

• post-maintenance testing of control room air conditioning train A temperature controller following restoration after calibration.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed surveillance testing activities to assess operational readiness and to ensure that risk-significant SSCs were capable of performing their intended safety function. Activities were selected based upon risk significance and the potential risk impact from an unidentified deficiency or performance degradation that an SSC could impose on the Unit if the condition was left unresolved. The inspection activities included, but were not limited to, a review for preconditioning, integration of testing activities, applicability of acceptance criteria, test equipment calibration and control, procedural use, control of temporary modifications or jumpers required for test performance, documentation of test data, applicability to TSs, impact of testing relative to performance indicator (PI) reporting, and evaluation of test data. As part of this inspection, the documents listed in the Attachment were reviewed.

The inspectors selected the following surveillance testing activities for review for a total of six inspection samples:

• technical support center diesel generator monthly test;

• safety injection train A pump and valve test (inservice testing (IST));

• service water train A pump and valve test;

• 4160-Volt bus No. 6 undervoltage test;

• containment radiation monitors R-11 and R-12 testing (reactor coolant system (RCS) leakage); and

• containment spray train B pump and valve test (containment isolation valve).

b. Findings

Preconditioning of Safety-Related Motor-Operated Valves

Introduction:

A finding of very low safety significance (Green) and an associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors during plant preparations to perform Surveillance Procedure SP-23-100B, Train B Containment Spray Pump and Valve Test - IST.

Description:

On August 8, 2007, Surveillance Procedure SP-23-100B, Train B Containment Spray Pump and Valve Test - IST, was scheduled to be performed.

Shortly before the surveillance procedure was scheduled to be performed, the planning and scheduling group had scheduled safety tags to be hung on the containment spray system in order to repair IDS-102, a containment spray system check valve. These tags required that normally open motor-operated valves IDS-202 and IDS-2B be cycled closed and tagged in order to isolate the check valve. These motor-operated valves were also required to be stroke and time-tested during performance of the surveillance procedure. The inspectors were concerned that operation of these valves as part of the maintenance on the check valve could result in preconditioning of the valves prior to performance of the surveillance test on the valves and could invalidate the test results.

Plant General Nuclear Procedures, GNP-08-02-08, Work Order Planning, and GNP-08-02-11, "Online Maintenance Planning and Scheduling, required that When work orders are combined with a surveillance or ASME Code required testing, preconditioning should be considered when developing the work plan to prevent unacceptable preconditioning.

The inspectors determined, following review of plant procedures, interviews with plant management, and a review of NRC guidance on preconditioning, that plant procedures were not adequate to support proper consideration of preconditioning. These procedures did not discuss or provide a definition for acceptable versus unacceptable preconditioning, did not provide guidance on the scope of components which should be included in such consideration, and did not identify which personnel were responsible for the consideration of potential preconditioning. Therefore, the inspectors determined that, due to inadequate procedures, adequate consideration of preconditioning of IDS-202 and IDS-2B during maintenance activities was not given before the surveillance procedure that tested these valves was conducted.

Analysis:

The inspectors determined that the licensees failure to provide adequate guidance for preconditioning in General Nuclear Procedures GNP-08-02-08 and GNP-08-02-11 was a performance deficiency and a finding. Specifically, the licensees Quality Assurance Program Description (QAPD) describes the plants implementation of 10 CFR Part 50, Appendix B, and commits the plant to the provisions of Regulatory Guide 1.33, Revision 2, February 1978, Quality Assurance Program Requirements (Operation). Appendix A, Section 9a, of Regulatory Guide 1.33, states in part that Maintenance that can affect the performance of safety-related equipment, should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Therefore, the licensees failure to provide adequate procedures which could affect the performance of safety-related equipment was contrary to the requirements of the QAPD and subject to the requirements of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, which states, in part that, Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

The inspectors concluded that the finding is greater than minor in accordance with Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 20, 2007, in that the finding was associated with the configuration control attribute of the Barrier Integrity Cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the licensee failed to provide adequate procedures to support the consideration of preconditioning of motor-operated valves in the containment spray system prior to conducting a TS required surveillance test on that system. Additionally, the failure to provide adequate procedures, if left uncorrected, would become a more significant safety concern.

The inspectors evaluated the finding using Appendix A of IMC 0609, Significance Determination Process, and determined that this finding is of very low safety significance (Green) by answering No to all questions in the containment barriers cornerstone column.

The inspectors also determined that the primary cause for this finding is related to the cross-cutting area of human performance. Specifically, under the component of resources, procedures to assess and prevent preconditioning of safety-related components were not complete, accurate, and up-to-date (H.2(c)).

Enforcement:

10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that Activities affecting quality, shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to this, the inspectors identified that licensees procedures GNP-08-02-08, Work Order Planning, and GNP-08-02-11, "Online Maintenance Planning and Scheduling, were inadequate to support proper consideration of preconditioning of motor-operated valves in the containment spray system. The inspectors identified this when they found that motor-operated valves IDS-202 and IDS-2B had been closed (operated) as part of safety tags for repair of a check valve on the containment spray system shortly before a surveillance test was performed on the motor-operated valves. The licensee entered this issue into its corrective action program as condition reports CR017488, NRC Question Regarding Preconditioning of IDS-2B Prior to SP-23-100B, and CR018082, NRC Inspector Questions Adequacy of Preconditioning Prevention. Corrective actions included completion of the surveillance procedure with acceptable results and an evaluation of the test results that determined that the surveillance test was acceptable. Because this violation was of very low safety significance and was entered into the licensees corrective action program, this violation is being treated as an NCV consistent with Section VI.A of the NRC enforcement policy (NCV 05000305/2007004-03).

1R23 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed one temporary modification to assess the impact of the modification on the safety function of the associated system. The inspection activities included, but were not limited to, a review of design documents, safety screening documents, USAR, and applicable TSs to determine that the temporary modification was consistent with modification documents, drawings, and procedures. The inspectors also reviewed the post-installation test results to confirm that tests were satisfactory and the actual impact of the temporary modification on the permanent system and interfacing systems were adequately verified. As part of this inspection, the documents listed in the Attachment were reviewed.

The inspectors selected for review a temporary modification that disconnected cabling from a nonsafety-related cable tray that terminated in a safety-related power supply RR-104, for a total of one inspection sample.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors selected emergency preparedness exercises that the licensee had scheduled as providing input to the Drill/Exercise PI. The inspection activities included, but were not limited to, the classification of events, notifications to offsite agencies, protective action recommendation development, and drill critiques. Observations were compared with the licensees observations and corrective action program entries. The inspectors verified that there were no discrepancies between observed performance and PI reported statistics. As part of this inspection, the documents listed in the Attachment were reviewed.

The inspectors selected an emergency preparedness exercise scheduled on July 10, 2007, Technical Support Center Evaluation 1b, for a total of one inspection sample.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2OS1 Access Control to Radiologically Significant Areas (71121.01)

.1 Review of Licensee Performance Indicators for the Occupational Exposure Cornerstone

a. Inspection Scope

The inspectors reviewed the licensees occupational exposure control cornerstone PIs to determine whether or not the conditions surrounding the PIs had been evaluated and identified problems had been entered into the corrective action program for resolution.

These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

.2 Plant Walkdowns and Radiation Work Permit Reviews

a. Inspection Scope

The inspectors reviewed licensee controls and surveys in the following two radiologically significant work areas within radiation areas, high radiation areas, and airborne radioactivity areas in the plant and reviewed work packages that included associated licensee controls and surveys of these areas to determine whether radiological controls including surveys, postings, and barricades were acceptable:

• Investigate inoperable level indication on the Spent Resin Storage Tank; and

• Containment At-Power Entry.

These reviews represented one inspection sample.

The inspectors walked down and surveyed (using an NRC survey meter) these areas to verify that the prescribed radiation work permit (RWP), procedure, and engineering controls were in place; that licensee surveys and that postings were complete and accurate; and that air samplers were properly located. These reviews represented one inspection sample.

The inspectors reviewed RWPs for airborne radioactivity areas with the potential for individual worker internal exposures of >50 mrem committed effective dose equivalent (CEDE). The inspectors verified barrier integrity and engineering controls performance (e.g., HEPA (high efficiency particulate air) ventilation system operation) for these selected airborne radioactive material areas, with a focus on any work areas with a history of, or the potential for, airborne transuranics. This review represented one inspection sample.

The adequacy of the licensees internal dose assessment process for internal exposures

>50 millirem CEDE was assessed. There were no internal exposures >50 millirem CEDE. These reviews represented one inspection sample.

The inspectors also reviewed the licensees physical and programmatic controls for highly activated and/or contaminated materials (non-fuel) stored within spent fuel or other storage pools. These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

.3 Problem Identification and Resolution

a. Inspection Scope

The inspectors reviewed the licensees self-assessments, audits, LERs, and special reports related to the access control program to verify that identified problems were entered into the corrective action program for resolution. These reviews represented one inspection sample.

The inspectors reviewed corrective action reports related to access controls and high radiation area radiological incidents (non-PIs identified by the licensee in high radiation areas <1R/hr). Staff members were interviewed and corrective action documents were reviewed to verify that follow-up activities were being conducted in an effective and timely manner, commensurate with their importance to safety and risk-based on the following:

• Initial problem identification, characterization, and tracking;

• Disposition of operability/reportability issues;

• Evaluation of safety significance/risk and priority for resolution;

• Identification of repetitive problems;

• Identification of contributing causes;

• Identification and implementation of effective corrective actions;

• Resolution of NCVs tracked in the corrective action system; and

• Implementation/consideration of risk significant operational experience feedback.

These reviews represented one inspection sample.

The inspectors evaluated the licensees process for problem identification, characterization, prioritization, and verified that problems were entered into the corrective action program and resolved. For repetitive deficiencies and/or significant individual deficiencies in problem identification and resolution, the inspectors verified that the licensees self-assessment activities were capable of identifying and addressing these deficiencies. These reviews represented one inspection sample.

The inspectors reviewed licensee documentation packages for all PI events occurring since the last inspection to determine whether of these PI events involved dose rates greater than 25 R/hr at 30 centimeters or greater than 500 R/hr at 1 meter. Barriers were evaluated for failure and to determine if there were any barriers left to prevent personnel access. Unintended exposures greater than 100 millirem total effective dose equivalent (or greater than 5 rem shallow dose equivalent or greater than 1.5 rem lens dose equivalent) were evaluated to determine whether there were any regulatory overexposures or if there was a substantial potential for an overexposure.

There were no PI events since the last inspection. These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

.4 Job-In-Progress Reviews

a. Inspection Scope

The inspectors observed the following two jobs that were being performed in radiation areas and high radiation areas for observation of work activities that presented the greatest radiological risk to workers:

• Investigate inoperable level indication on the Spent Resin Storage Tank; and

• Containment At-Power Entry.

The inspectors reviewed radiological job requirements for these activities including RWP requirements and work procedure requirements and attended As-Low-As-Is-Reasonably-Achievable (ALARA) job briefings. These reviews represented one inspection sample.

Job performance was observed with respect to RWP and procedural requirements to verify that radiological conditions in the work area were adequately communicated to workers through pre-job briefings and postings. The inspectors also verified the adequacy of radiological controls, including required radiation, contamination, and airborne surveys for system breaches; radiation protection job coverage that included audio and visual surveillance for remote job coverage; and contamination controls.

These reviews represented one inspection sample.

The inspectors reviewed the adequacy of radiological controls, radiation protection job coverage (including audio and visual surveillance for remote job coverage), and contamination controls during these job performance observations. This review represented one inspection sample.

The inspectors reviewed the application of dosimetry to effectively monitor exposure to personnel for high radiation work areas with significant dose rate gradients (factor of five or more). This review represented one inspection sample.

b. Findings

No findings of significance were identified.

.5 High Risk Significant, High Dose Rate High Radiation Area, and Very High Radiation

Area Controls

a. Inspection Scope

The inspectors held discussions with the Radiation Protection Manager concerning high dose rate/high radiation area and very high radiation area controls and procedures, including procedural changes that had occurred since the last inspection, to verify that any procedure modifications did not substantially reduce the effectiveness and level of worker protection. These reviews represented one inspection sample.

The inspectors discussed with Radiation Protection supervisors the controls that were in place for special areas that had the potential to become very high radiation areas during certain plant operations, to determine whether these plant operations required communication beforehand with the Radiation Protection group, so as to allow corresponding timely actions to properly post and control the radiation hazards.

These reviews represented one inspection sample.

The inspectors conducted plant walkdowns to verify the posting and locking of entrances to high dose rate high radiation areas, and very high radiation areas.

These reviews represented one inspection sample.

b. Findings

No findings of significance were identified

.6 Radiation Worker Performance

a. Inspection Scope

During job performance observations, the inspectors evaluated radiation worker performance with respect to stated radiation protection work requirements and evaluated whether workers were aware of the significant radiological conditions in their workplace, the RWP controls and limits in place, and that their performance had accounted for the level of radiological hazards present. These reviews represented one inspection sample.

The inspectors reviewed radiological problem reports that found that the cause of the event was due to radiation worker errors to determine if there was an observable pattern traceable to a similar cause and to determine whether this perspective matched the corrective action approach taken by the licensee to resolve the reported problems.

These problems, along with planned and taken corrective actions, were discussed with the Radiation Protection Manager. These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

.7 Radiation Protection Technician Proficiency

a. Inspection Scope

During job performance observations, the inspectors evaluated Radiation Protection Technician performance with respect to radiation protection work requirements and evaluated whether they were aware of the radiological conditions in their workplace, the RWP controls and limits in place, and whether their performance was consistent with their training and qualifications with respect to the radiological hazards and work activities. These reviews represented one inspection sample.

The inspectors reviewed radiological problem reports that found the cause of the event was radiation protection technician error to determine whether there was an observable pattern traceable to a similar cause and to determine whether this perspective matched the corrective action approach taken by the licensee to resolve the reported problems.

These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

a. Inspection Scope

The inspectors sampled the licensees submittals for the PIs listed below for the period indicated. The inspectors used PI definitions and guidance contained in Revision 5 of Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, to verify the accuracy of the PI data.

Cornerstone: Public Radiation Safety

• Radiological Effluent Technical Specification/Offsite Dose Calculation Manual Radiological Effluent Occurrence The inspectors reviewed the licensees corrective action database and selected individual reports generated since this indicator was last reviewed in April 2006, to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous effluent summary data and the results of associated offsite dose calculations for selected dates between June 2006 and July 2007 to determine whether indicator results were accurately reported. The inspectors also reviewed the licensees methods for quantifying gaseous and liquid effluents and determining effluent dose.

This review represented one inspection sample.

Cornerstone: Occupational Radiation Safety

• Occupational Exposure Control Effectiveness The inspectors reviewed the licensees assessment of the PI for occupational radiation safety to determine whether indicator related data were adequately assessed and reported during the previous four quarters. The inspectors compared the licensees PI data with the corrective action report database, reviewed radiological restricted area exit electronic dosimetry transaction records, and discussed data collection and analysis methods for PIs with licensee representatives.

This review represented one inspection sample.

Cornerstone: Barrier Integrity

• Reactor Coolant System Specific Activity The inspectors reviewed Chemistry Department records, including isotopic analyses for selected dates between June 2006 through July 2007 to determine whether the greatest dose equivalent iodine values determined during steady state operations corresponded to the values reported to the NRC. The inspectors also reviewed selected dose equivalent iodine calculations, including the application of dose conversion factors as specified in plant TSs. Additionally, the inspectors accompanied a chemistry technician and observed the collection and preparation of reactor coolant system samples to evaluate compliance with the licensees sampling procedures. Further, sample analyses and calculation methods were discussed with chemistry staff to determine their adequacy relative to TSs, licensee procedures, and industry guidelines.

This review represented one inspection sample.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the routine inspections documented in this inspection report, the inspectors verified that the licensee entered the problems identified during the inspection into their corrective action program. Additionally, the inspectors verified that the licensee was identifying issues at an appropriate threshold and entering them in the program, and verified that problems included in the program were properly addressed for resolution.

Attributes reviewed included: problems were completely and accurately identified; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews were proper and adequate; and classification, prioritization, and focus were commensurate with safety and sufficient to prevent recurrence of the issue.

b. Findings

No findings of significance were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

To assist with the identification of repetitive equipment failures and specific human performance issues for follow-up by the inspectors, the inspectors performed a daily screening of items entered into the licensees corrective action program. This review was accomplished by reviewing daily CAP summary reports and attending corrective action review board meetings.

b. Findings

No findings of significance were identified.

.3 Selected Issue Follow up (Annual Sample): Annual Sample of Operator Workarounds

a. Inspection Scope

The inspectors selected the licensees operator workaround list, and sampled procedures and corrective actions to assess the impact of operator workarounds to determine whether system functions were affected or the operators ability to implement abnormal or emergency procedures were affected. Included in this review was operator workarounds that may not be tracked as an operator workaround or may have been formalized as part of station procedures.

b. Findings

No findings of significance were identified.

4OA3 Followup of Events and Notices of Enforcement Discretion

.1 (Closed) LER 05000305/2005-012-00, Residual Heat Removal Pump Run-Out Upon

Loss of Instrument Air While Aligned for Sump Recirculation On June 10, 2005, based on review of emergency core cooling system (ECCS) pump analyses, the licensee identified that there was a potential for a RHR pump to be operated in a run-out condition when containment spray was aligned to take a suction from the RHR pump and the RHR system flow control valve failed open (such as upon a loss of instrument air). The licensee submitted a license amendment request to revise TSs to not require that containment spray have a flow path capable of taking suction from the containment sump, and revised emergency operating procedures to reduce the vulnerability associated with the identified potential run-out condition. The licensee documented the problem in corrective action program document CAP027287, RHR Pump Runout / Loss of IA to RHR-8A/B. This licensee-identified finding involved a violation of 10 CFR Part 50, Appendix B, Criteria III, Design Control. The enforcement aspects of the violation are discussed in Section 4OA7 of this report. During review of this issue, the inspectors identified a finding involving a violation of 10 CFR 50.71, Maintenance of Records, Making of Reports, which is discussed below. This LER is closed.

Introduction:

The inspectors identified a finding of very low safety significance (Green)and associated Severity Level IV of 10 CFR 50.71 when the licensee failed to update the USAR to reflect analyses performed in support of License Amendment 184.

Description:

Technical Specifications required that containment spray have an operable flow path capable of taking suction from the refueling water storage tank (RWST) and from the containment sump. As such, containment spray could not be considered operable with the potential to cause a run-out condition on a RHR pump while in the recirculation mode. On June 16, 2005, the licensee submitted a license amendment request to delete the reference to taking a suction from the containment sump from the containment spray operability section. As part of the request, the licensee identified that there was a potential to put a RHR pump in a run-out condition upon a loss of instrument air when containment spray was operated in the recirculation mode. The licensee noted that operation of containment spray in the recirculation mode was potentially detrimental to a loss of coolant accident (LOCA) response. The licensee noted that recent design basis accident analyses did not take credit for containment spray being used in the recirculation mode and that procedure changes would remove the potential detrimental scenario regarding the containment spray pumps. However, the licensee stated that the containment spray system recirculation mode would still be available for use as long as the RHR flow control valves were available to throttle RHR pump injection flow prior to supply suction to the containment spray pumps. The licensee further stated that run-out protection could be accomplished within the RWST changeover procedures by prohibiting the use of the containment spray system in the recirculation mode if the ability to throttle the flow being injected into the RCS loops was lost. The June 21, 2005, NRC safety evaluation report supporting TS Amendment 184, which addressed the licensees request, based acceptance, in part, on the licensees commitment to accomplish run-out protection within the RWST changeover procedures.

Section 6.4 of the USAR made multiple references to containment spray being operated in the recirculation mode. However, the April 2007 update of the USAR neither described the potential for RHR to run-out when containment spray was operated in the recirculation mode nor described the run-out protection provisions that the licensee had committed to for the RWST changeover procedures. The inspectors determined that a USAR change had not been processed to address the potential for run-out or address the commitments associated with the amendment.

On June 21, 2005, the licensee revised procedure ES-1.3, Transfer to Containment Sump Recirculation, to modify the steps involving the recirculation mode of containment spray. The revisions to the procedure steps included 1) limiting the use of containment spray to beyond design basis conditions where at least three containment fan coil units were not available, 2) ensuring that the RHR flow control valve was closed prior to using containment spray in the recirculation mode, and 3) monitoring RHR pump motor current for a potential run-out.

The inspectors noted that the procedure revision did not fully provide run-out protection.

Specifically, the procedure did not adequately address the potential case where loss of the ability to throttle the RHR system flow control valve occurred after the containment spray recirculation mode was established (such as upon the loss of instrument air).

There were no steps which identified a potential run-out condition upon loss of instrument air. In addition, the steps added to monitor RHR pump motor current for potential run-out conditions may not have been effective in that a pump motor trip or damage could occur due to run-out conditions before operators could recognize the condition and take appropriate corrective actions. The licensee did not have an analysis which showed operators could take appropriate actions in time. The licensee initiated condition reports CR015826, Caution Needed for ES-1.3 Step 28, and CR016145, Procedural Control of IDS in Recirculation Mode May be Inadequate, in response to procedural issues raised by the NRC. The inspectors concluded that had USAR changes with associated 10 CFR 50.59 screenings and/or evaluations been appropriately processed upon the discovery of the potential run-out condition and commitments associated with the TS amendment, the procedure issues identified by the inspectors would likely have been appropriately addressed.

In Inspection Report 05000305/2006016, dated January 26, 2007, the NRC previously identified a violation associated with another failure to update the USAR in accordance with 10 CFR 50.71(e). The licensee had placed this issue in their corrective action system under CAP039449, USAR Not Updated to Reflect Method of Evaluation in GL 96-06 Response. As part of the corrective actions (as documented by CA028714, USAR Not Updated to Reflect Method of Evaluation in GL 96-06 Response), the licensee conducted a review of the activities that may not have been appropriately reflected in USAR updates since June 1, 2003, including approved license amendment requests. The licensee closed the action on April 16, 2007. However, although TS amendment 184 was within the scope of the review, the licensee failed to identify the failure to update the USAR to reflect the run-out provisions which the licensee had committed to within the RWST changeover procedures.

Analysis:

Because violations of 10 CFR 50.71(e) potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the SDP. Typically, the Severity Level would be assigned after consideration of appropriate factors for the particular regulatory process violation in accordance with the NRC Enforcement Policy. However, the SDP is used, if applicable, in order to consider the associated risk significance of the finding prior to assigning a severity level.

Using IMC 0612, Appendix B, "Issue Dispositioning Screening," dated September 20, 2007, the inspectors determined that the finding is more than minor because of the potential to impact the regulatory process. Specifically, the failure to provide complete licensing and design basis information in the USAR could result in either the licensee making an inappropriate licensing interpretation or the NRC making an inappropriate regulatory decision based on incomplete information in the USAR. The inspectors determined that the finding was most closely associated with the Mitigating Systems Cornerstone because the issue involved potential malfunctions of the RHR pumps under certain conditions rather than the Barrier Integrity Cornerstone due to the involvement of the containment spray system. For the purpose of evaluating the risk significance associated with this finding, the inspectors assumed that one of two trains of the recirculation function of RHR would be affected due to the licensees procedures not fully providing run-out protection as specified by commitments made for TS amendment 184. This assumption was conservative because the potential for run-out of a RHR pump would only exist for beyond design basis events in which three or more containment air coolers had failed and the ability to throttle the RHR system flow valve would have been lost while containment spray was operated in the recirculation mode.

The inspectors performed a Phase 2 significance determination analysis of the associated technical issue and determined that the finding was of very low safety significance (Green) based on review of the NRC Risk-Informed Inspection Notebook for Kewaunee, Revision 2, worksheet for large break LOCAs. In accordance with the Enforcement Policy, the violation was classified as a Severity Level IV violation.

The inspectors determined that this issue was related to the cross-cutting area of problem identification and resolution because the licensee failed to throughly evaluate a previously identified problem such that the resolution fully addressed causes and extent of condition, as necessary, including conducting effectiveness reviews of corrective actions to ensure that the problem was resolved. Specifically, the extent of condition review performed for a recent and similar violation failed to identify that the USAR had not been appropriately updated to reflect commitments made for TS amendment 184 (P.1(c)).

Enforcement:

10 CFR 50.71(e) required, in part, that licensees periodically update the Final Safety Analysis Report (FSAR) to assure that it included the latest information developed. 10 CFR 50.71(e) further required that the submittal contain all changes made in the facility and all the changes necessary to reflect information and analyses submitted to the Commission by the licensee or prepared by the licensee pursuant to Commission requirement since the submission of the original FSAR or, as appropriate, the last updated FSAR. 10 CFR 50.71(e) required, in part, that the updated FSAR be revised to include the effects of all safety evaluations performed by the licensee in support of requested license amendments. By letter dated June 16, 2005, the licensee stated as part of the analyses in support of a license amendment request that RHR pump run-out protection could be accomplished within the RWST changeover procedures by prohibiting the use of the containment spray system in the recirculation mode if the ability to throttle the flow being injected into the RCS loops is lost.

Contrary to the above, as of July 13, 2007, the licensee had not updated the FSAR (at Kewaunee, the USAR) to reflect analyses performed in support of license amendment 184. Specifically, the USAR had not been updated to reflect that there was a potential to put a RHR pump in a run-out condition upon a loss of instrument air when containment spray was operated in the recirculation mode. Additionally, the USAR had not been updated to reflect that run-out protection was accomplished within the RWST changeover procedures by prohibiting the use of the containment spray system in the recirculation mode if the ability to throttle the flow being injected into the RCS loops was lost. Once identified, the licensee entered the issue in its corrective action program as CR015880, USAR May Not Have Been Updated as Required for License Amendment 184. The result of the violation was determined to be of very low safety significance; therefore, this violation of 10 CFR 50.71(e) was classified as a Severity Level IV violation. Because the finding was of very low safety significance and it was entered into the licensee's corrective action program (CR 015880), this violation is being treated as an NCV consistent with VI.A.1 of the NRC Enforcement Policy (NCV 05000305/2007004-04).

.2 (Closed) LER 05000305/2005-012-01, Residual Heat Removal Pump Run-Out Upon

Loss of Instrument Air While Aligned for Sump Recirculation. This LER was reviewed as part of the review for LER 05000305/2005-012-00 discussed in Section 4OA3.1 above. This LER is closed.

.3 (Closed) LER 05000305/2005-012-02, Residual Heat Removal Pump Run-Out Upon

Loss of Instrument Air While Aligned for Sump Recirculation. This LER was reviewed as part of the review for LER 05000305/2005-012-00 discussed in Section 4OA3.1 above. This LER is closed.

.4 (Closed) LER 05000305/2006-002-00, Safety-Related Relay Racks with Improper

Quality Classification of Foxboro Signal Conditioning Modules.

On April 18, 2006, the licensee identified that nonsafety-related Foxboro signal conditioning modules were installed in relay room racks for which safety-related modules were required. The licensee subsequently replaced the nonsafety-related units with units qualified as safety-related where required. In addition, the licensee evaluated the extent of condition. The inspectors verified the adequacy of the licensees extent of condition evaluation by reviewing the safety classification of components installed in a sample of relay racks. The inspectors concluded that the scope of the review performed by the licensee was adequate. This licensee-identified finding involved a violation of 10 CFR Part 50, Appendix B, Criterion III. The enforcement aspects of the violation are discussed in Section 4OA7 of this report. The inspectors identified a minor deficiency in that the LER had stated that an extent of condition was initiated to review all relay racks versus the relay racks containing Foxboro signal conditions units. However, based on review of corrective actions documents and discussions with site engineering personnel involved with the review, the inspectors determined that the extent of condition review performed was more limited than that discussed in the LER. Since the inspectors considered the scope of the extent of condition review to be adequate, the inspectors determined that the discrepancy was minor. The licensee initiated CR016242, Extent of Condition for Foxboro Relay Racks Quality Classification, to address the discrepancy. This LER is closed.

.5 (Closed) LER 05000305/2006-007-00, Reactor Coolant System Resistance

Temperature Detector (RTD) Cross Calibration Procedure Has the Potential to Exceed the TS Limiting Condition for Operation (LCO) Allowed Time Limit On June 13, 2006, licensee engineering personnel identified that performance of procedure SP-47-310, Reactor Coolant System RTD Cross Calibration, could result in exceeding the time allowed by TSs. Procedure SP-47-310 removed from service all four narrow range channels of reactor coolant system temperature instrumentation. The procedure was normally performed while the plant was in an intermediate shutdown condition. The steam line isolation signal for high steam flow and two of four low-low average temperature with safety injection were affected by removal of the instrumentation for performance of procedure SP-47-310. Technical Specification Table 3.5-4 item 2.b specified that if a minimum of one channel was not available, that the plant be in hot shutdown and, if minimum conditions were not met within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, that steps shall be taken to place the plant in a cold shutdown condition. Based on review of operator logs for when the surveillance procedure had last been performed (November 2004), the licensee was not able to determine whether the 24-hour LCO specified by TSs had been exceeded because times for specific steps of the procedure had not been recorded. The logs identified the procedure as having been in progress for 68.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. As such, the licensee assumed that TS 3.5 had not been met. In the LER, the licensee noted that, historically, performance times for specific steps of procedure SP-47-310 were not recorded and that precise durations of inoperability could not be determined. This licensee-identified finding involved a violation of TS 3.5 and TS Table 3.5-4. The enforcement aspects of the violation are discussed in Section 4OA7 of this report. The licensee revised procedure SP-47-310 to notify control room operators when the surveillance would place the plant in a 24-hour LCO. The procedure already had a step in place to notify control room operators when the LCO was no longer in effect. However, the inspectors determined that the licensees corrective actions were not wholly effective. The inspectors reviewed the control room logs for October 21-22, 2006, when the surveillance procedure had most recently been performed and determined a minor deficiency existed in that the duration of when the plant was in the LCO could not be determined. Log entries made once per shift indicated which LCOs were entered at the time of review, including the initiation of the 24-hour LCO at 2:36 p.m. on October 21. However, the time that the LCO was exited was not recorded. Based on review of shift logs, the inspectors were able to determine that the LCO was not in effect at 7:00 p.m. on October 22. As such, the inspectors were able to determine that the LCO had been in effect for less than 28.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, but were unable to confirm that the LCO had been in effect less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Because the shift logs provided evidence that control room operators were aware that the LCO was in place and were tracking LCOs in general, the inspectors concluded that the operators failed to log the LCO exit time, which is a minor deficiency, rather than exceeded the LCO time. The licensee initiated CR016069, TS LCO Tracking May Be Inadequate, to address the log keeping issue identified by the inspectors. This LER is closed.

.6 (Closed) LER 05000305/2006012-00, Automatic Reactor trip Due to Loss of Instrument

Bus On October 30, 2006, the reactor tripped from approximately 92 percent power, due to B steam generator steam flow/feed flow mismatch coincident with low water level in the B steam generator. Loss of the red instrument bus caused the plant transient that led to the reactor trip. All systems responded as designed with the following exceptions:

the steam supply inlet valve for the 1B reheater did not fully close resulting in the associated relief valve to lift, and the reserve auxiliary transformer breaker failed to close resulting in a loss of circulating water flow and condenser vacuum. Subsequent inspection of the red instrument bus inverter found that some of the static switch silicon controlled rectifiers had failed, ultimately causing the inverter to fail. The two sets of silicon controlled rectifiers and two circuit cards were replaced. The LER was reviewed by the inspectors and no findings of significance were identified and no violation of NRC requirements occurred. The licensee wrote CAP038921, CAP038970, and CAP038965, placing these issues into the corrective action program. This LER is closed.

.7 Personnel Performance During Non-Routine Plant Evolutions and Events

a. Inspection Scope

The inspectors reviewed personnel performance to planned and unplanned non-routine evolutions to review operator performance and the potential for operator contribution to the evolution, transient, or event. The inspectors observed or reviewed records of operator performance during the evolution. Reviews included, but were not limited to, operator logs, pre-job briefings, instrument recorder data, and procedures. As part of this inspection, the documents listed in the Attachment were reviewed.

The inspectors evaluated the following events and evolutions, for a total of six inspection samples:

• turbine generator hydrogen cooler leak;

• unexpected extremity dose;

• manual actions in fuel pool are not achievable;

• unplanned entry into technical specifications for the special ventilation zone and an associated 10 CFR 50.72 report;

• unplanned entry into TSs for the special ventilation zone and an associated 10 CFR 50.72 report; and

• roof preparations for lift of new auxiliary building crane trolley.

b. Findings

No findings of significance were identified.

4OA6 Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Ms. L. Hartz and other members of licensee management on October 8, 2007. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

.2 Interim Exit Meetings

Interim exits were conducted for:

• Maintenance Effectiveness Periodic Evaluation with Mr. B. Hoffner, Assistant Plant Manager on August 3, 2007

• An interim exit meeting was conducted for Access Control to Radiologically Significant Areas with Mr. T. Webb, on August 10, 2007

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by the licensee and are violations of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG - 1600, for being dispositioned as NCVs.

• 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures be established to assure applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Criterion III also requires, in part, that such design control measures provide for verifying or checking the adequacy of design. On May 10, 2005, the licensee identified that such measures were inadequate in that a RHR pump could run-out when containment spray was operated in recirculation mode taking suction from the RHR system. The licensee subsequently modified operating procedures to minimize this potential.

The licensee documented this problem in CAP027287. The inspectors identified a separate violation of 10 CFR 50.71(e) which is discussed in Section 4OA3.1.

This finding is of very low safety significance based on a Phase 2 significance determination evaluation. (Section 4OA3.1)

• 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures be established to assure applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Criterion III also requires, in part, that such measures include provisions to assure that appropriate quality standards are specified and included in design documents. On April 18, 2006, the licensee identified that such measures were inadequate in that nonsafety-related Foxboro signal conditioning units had been installed where safety-related units were required. The licensee subsequently replaced the nonsafety-related units with safety-related units where required. In addition, the licensee performed an extent of condition review. The licensee documented this problem in CAP033058 and CAP033059.

This finding is of very low safety significance because the deficiency was related to the qualification of the components and there was no evidence that functionality was adversely affected. (Section 4OA3.2)

• Technical Specification 3.5 and TS Table 3.5-4 required that instrumentation for the main steam isolation function upon high steam flow coincident with low-low average temperature (Tave) and safety injection have a minimum of one operable channel. If the minimum conditions were not met within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the TSs required that steps be taken to place the plant in a cold shutdown condition. On June 13, 2006, the licensee determined that the requirements of Table 3.5-4 had not been met in November 2004 in that a surveillance activity had disabled all of the Tave channels for a period in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee revised the surveillance procedure to ensure control room operators were aware of conditions that placed the plant in an LCO. The licensee documented this problem in CAP034520. This finding is of very low safety significance because the main steam lines were isolated at the time. (Section 4OA3.3)

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Adams, Health Physicist

L. Armstrong, Site Engineering Director

M. Bernsdorf, Chemistry

T. Breene, Nuclear Licensing Manager

M. Crist, Plant Manager

L. Hartz, Site Vice-President

W. Henry, Maintenance Manager

B. Lembeck, Radiation Protection Supervisor

J. Ruttar, Operations Manager

D. Shannon, Health Physics Operations Supervisor

R. Steinhardt, Site Maintenance Rule Coordinator

C. Tiernan, Corporate Maintenance Rule Coordinator

S. Wood, Emergency Preparedness Manager

Nuclear Regulatory Commission

J. Cameron, Chief, Division of Reactor Projects, Branch-5

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000305/2007004-01 URI Auxiliary Building Heating and Ventilation Calculations Potentially Unconservative (Section 1R07)

05000305/2007004-02 NCV Failure to Implement Maintenance Rule (a)(1) in Corrective Actions on the G Instrument Air Compressor (Section 1R13)

05000305/2007004-03 NCV Preconditioning of Safety-Related Motor-Operated Valves Prior to Performance of Technical Specification Required Surveillance Testing (Section 1R22)

05000305/2007004-04 NCV Failure to Update the Updated Safety Evaluation Report (Section 4OA3.1)

Attachment

Closed

05000305/2007004-02 NCV Failure to Implement Maintenance Rule (a)(1) in Corrective Actions on the G Instrument Air Compressor (Section 1R13)

05000305/2007004-03 NCV Preconditioning of Safety-Related Motor-Operated Valves Prior to Performance of Technical Specification Required Surveillance Testing (Section 1R22)

05000305/2007004-04 NCV Failure to Update the Updated Safety Evaluation Report (Section 4OA3.1)

05000305/2005012-00 LER Residual Heat Removal Pump Run-Out Upon Loss of Instrument Air While Aligned for Sump Recirculation (Section 4OA3.1)

05000305/2005012-01 LER Residual Heat Removal Pump Run-Out Upon Loss of Instrument Air While Aligned for Sump Recirculation (Section 4OA3.2)

05000305/2005012-02 LER Residual Heat Removal Pump Run-Out Upon Loss of Instrument Air While Aligned for Sump Recirculation (Section 4OA3.3)

05000305/2006002-00 LER Safety-Related Relay Racks with Improper Quality Classification of Foxboro Signal Conditioning Modules (Section 4OA3.4)

05000305/2006007-00 LER Reactor Coolant System Resistance Temperature Detector Cross Calibration Procedure has the Potential to Exceed the TS Limiting Condition for Operation Allowed Time Limit (Section 4OA3.5)

05000305/2006012-00 LER Automatic Reactor Trip Due to Loss of Instrument Bus (Section 4OA3.6)

Attachment