IR 05000220/2016004

Integrated Inspection Report 05000220/2016004 and 05000410/2016004 and NRC Office of Investigations Report 1-2016-007

ML17033B502
Person / Time
Site:	Nine Mile Point
Issue date:	02/01/2017
From:	Anthony Dimitriadis Reactor Projects Branch 1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
OI 1-2016-007 IR 2016004
Download: ML17033B502 (32)

Text

bruary 1, 2017

SUBJECT:

NINE MILE POINT NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000220/2016004 AND 05000410/2016004 AND NRC OFFICE OF INVESTIGATIONS REPORT 1-2016-007

Dear Mr. Hanson:

On December 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station, LLC (NMPNS), Units 1 and 2. On January 9, 2017, the NRC inspectors discussed the results of this inspection with Mr. Peter Orphanos, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

This inspection also reviewed actions regarding the failure to conduct quarterly fire brigade drills during the third quarter of 2015 as required by station procedures and Technical Specifications (TS) and the potential existed that this may have been a deliberate act. In response, the Region I Field Office, NRC Office of Investigations (OI), initiated investigation OI-1-2016-007 to determine whether a manager, employed by Exelon at Nine Mile Point, willfully and deliberately failed to implement those requirements. Based on testimonial and documentary evidence gathered during the investigation the investigators concluded that while violations of TS requirements had occurred, the actions of the manager were not determined to be willful or deliberate. The underlying violation, a failure to correctly implement the fire protection program, is documented in this report in Section 4OA7 as a licensee-identified violation of very low safety significance (Green). The NRC is treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of the NCV you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at NMPNS. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Anthony Dimitriadis Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 50-220 and 50-410 License Nos. DPR-63 and NPF-69

Enclosure:

Inspection Report 05000220/2016004 and 05000410/2016004 w/Attachment: Supplementary Information

REGION I==

Docket Nos. 50-220 and 50-410 License Nos. DPR-63 and NPF-69 Report Nos. 05000220/2016004 and 05000410/2016004 Licensee: Exelon Generation Company, LLC (Exelon)

Facility: Nine Mile Point Nuclear Station, LLC (NMPNS)

Units 1 and 2 Location: Oswego, New York Dates: October 1, 2016, through December 31, 2016 Inspectors: K. Kolaczyk, Senior Resident Inspector G. Stock, Resident Inspector J. DeBoer, Emergency Preparedness Inspector T. Fish, Senior Operations Engineer N. Floyd, Reactor Inspector S. McCarver, Physical Security Inspector R. Rolph, Health Physicist A. Siwy, Project Engineer A. Turilin, Project Engineer Approved by: Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY

Inspection Report 05000220/2016004 and 05000410/2016004; 10/01/2016 - 12/31/2016;

NMPNS, Units 1 and 2; Routine Integrated Inspection Report.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors documented one licensee-identified Green finding, which was a non-cited violation (NCV). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 4, 2014. All violations of U.S. Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated November 1, 2016. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 6.

Other Findings

A violation of very low safety significance that was identified by Exelon was reviewed by the inspectors. Corrective actions taken or planned by Exelon have been entered into Exelons corrective action program (CAP). This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On October 21, 2016, reactor power was reduced to 90 percent to perform maintenance on the number 11 recirculation pump.

Power was restored to 100 percent the same day. On October 22, reactor power was reduced to 95 percent power to remove the number 12 recirculation pump from service. Operators restored power to 100 percent the same day.

On December 10, operators manually scrammed Unit 1 and tripped the main turbine from 95 percent power per procedure when high vibrations occurred on the main turbine during a planned downpower maneuver. A subsequent Exelon investigation determined that the high vibrations were caused by a turbine rub, which developed from uneven heating of the high pressure turbine casing due to a steam leak that emanated from a sample line in the turbine doghouse area. The leak was repaired and the plant was restarted on December 12 and was placed on the grid on December 13. The plant achieved 100 percent power on December 14.

The plant remained at full power until December 25 when Unit 1 entered the planned end of fuel cycle power coast down period until the next refueling outage, which is planned for the first quarter of 2017. Reactor power was 97 percent at the end of the report period.

Unit 2 began the inspection period at 100 percent power. On October 10, operators lowered reactor power to 96 percent as directed by procedures when a turbine bypass valve opened when a pressure control valve in the moisture separator reheater (MSR) system began to close without operator action. Later in the day, operators reduced power further to 77 percent. Once troubleshooting of the valve and MSR system were complete, operators returned power to 100 percent on October 11. On October 19, operators reduced power to 65 percent to conduct a planned feedwater pump swap. Reactor power was restored to 100 percent the same day.

On November 23, operators reduced reactor power to 52 percent when they shutdown the A recirculation pump due to high vibrations. On November 24, operators removed the turbine from the electrical grid and shut down the reactor to conduct troubleshooting on the A recirculation pump. Unit 2 reached cold shutdown on November 25 and remained in cold shutdown until December 3, when the reactor was restarted and taken critical. The turbine was placed on the grid on December 4 and 100 percent power was achieved on December 6. The plant remained at 100 percent power for the remainder of the report period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors reviewed Exelon readiness for the onset of seasonal cold temperatures for Unit 1 and Unit 2. The review focused on the Unit 1 intake structure and service water (SW) pump area, and the Unit 2 SW system and emergency diesel generator (EDG)rooms. The inspectors reviewed the updated final safety analysis report (UFSAR),technical specifications (TS), control room logs, and the CAP to determine what temperatures or other seasonal weather could challenge the systems, and to ensure Exelon personnel had adequately prepared for these challenges. The inspectors reviewed procedures, including Exelon procedure WC-AA-107, Seasonal Readiness, Revision 17, and applicable operating procedures. The inspectors verified status of the operations departments cold weather preparation checklists contained in procedures N1-OP-64 and N2-OPO-102, Meteorological Monitoring, Revisions 01500 and 01900.

The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Partial System Walkdown (71111.04 - 1 sample)

a. Inspection Scope

The inspectors performed partial walkdowns of the following system:

• Unit 1 11 liquid poison system on October 29, 2016 The inspectors selected this system based on its risk-significance relative to the reactor safety cornerstones at the time it was inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TSs, work orders, condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the systems performance of its intended safety functions. The inspectors also performed field walkdowns of accessible portions of the system to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

1R05 Fire Protection

Resident Inspector Quarterly Walkdowns (71111.05Q - 4 samples)

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Exelon controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

• Unit 1 radioactive solidification and storage building (RSSB) fire zone RS2A on October 3, 2016

• Unit 1 RSSB truck loading area fire zone RS2B on October 3, 2016

• Unit 1 RSSB electrical equipment room fire zone RS1B on October 3, 2016

• Unit 1 screen house diesel generator room fire zone S2 on October 5, 2016

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Quarterly Review of Licensed Operator Requalification Testing and Training (2 samples)

a. Inspection Scope

The inspectors observed:

• Unit 1 licensed operator simulator exam scenario on October 4, 2016, that involved a leak in the reactor water cleanup non-regenerative heat exchanger, a temporary loss of offsite power line 4, a leak in the recirculation system, and failure of the high pressure coolant injection system and

• Unit 2 job performance measures conducted in the simulator on October 26, 2016, which involved withdrawing a control rod during a reactor plant startup and restoring the drywell high range radiation monitors to service following a loss of coolant accident.

The inspectors evaluated operator performance during the simulated event and verified completion of risk-significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the unit supervisor. The inspectors verified the accuracy and timeliness of the emergency classifications made by the shift manager and the TS action statements by the unit supervisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

(2 samples)

a. Inspection Scope

The inspectors observed:

• Unit 1 containment spray surveillance, and emergency cooling high steam flow isolation calibration, during motor generator set 167 maintenance on November 8, 2016, and

• Unit 2 during single rod scram time testing, stuck rod response, and return to 100 percent power for plant process computer testing on October 12, 2016, and during reactor manual control push button replacement and isolation valve testing on October 14, 2016.

The inspectors reviewed HU-AA-101, Human Performance Tools and Verification Practices, Revision 009, and verified that procedure use, crew communications, and coordination of plant activities among work groups similarly met established expectations and standards. Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.

b. Findings

No findings were identified.

.3 Biennial Review of Licensed Operator Requalification

a. Inspection Scope

The following Unit 1 inspection activities were performed using NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 10, and Inspection Procedure Attachment 71111.11, Licensed Operator Requalification Program and Licensed Operator Performance.

Written Examination Quality The inspectors reviewed a sample of biennial written exams that facility staff administered to Unit 1 operators October 2016 through December 2016.

Operating Test Quality The inspectors reviewed Unit 1 operating tests (scenarios and job performance measures) associated with the on-site examination week.

Licensee Administration of Operating Tests The inspectors observed Exelon training staff administer dynamic simulator exams and job performance measures during the week of October 24, 2016. These observations included facility evaluations of crew and individual operator performance during the simulator exams and individual performance of job performance measures.

Exam Security The inspectors assessed whether Exelon staff properly safeguarded exam material, and whether test item repetition was excessive.

Conformance with License Conditions License reactivation and license proficiency records were reviewed to ensure that 10 CFR 55.53 license conditions and applicable program requirements were met. The inspectors also reviewed a sample of records for requalification training attendance, and a sample of medical examinations for compliance with license conditions and NRC regulations.

Unit 1 Simulator Performance Simulator performance and fidelity were reviewed for conformance to the reference plant control room. A sample of simulator deficiency reports was also reviewed to ensure facility staff addressed identified modeling problems.

Problem Identification and Resolution The inspectors reviewed recent operating history documentation found in inspection reports, LERs, the Exelons CAP, NRC end of cycle reports, and the most recent NRC plant issues matrix. The resident staff was also consulted for insights regarding licensed operators performance. The inspectors focused on events associated with operator errors that may have occurred due to possible training deficiencies.

b. Findings

No findings were identified.

.4 Annual Review of Licensed Operator Requalifications

a. Inspection Scope

Unit 1 and Unit 2 requalification exam results for year 2016 were reviewed to determine if pass/fail rates were consistent with the guidance of NRC Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process. The review verified that the failure rate (individual or crew) did not exceed 20 percent.

Examination Results Unit 1 failure rate (operating test and biennial written exam)

• The overall individual operator failure rate was 1.9 percent

• The overall crew failure rate was 0 percent Unit 2 failure rate (operating test only)

• The overall individual operator failure rate was 6.0 percent

• The overall crew failure rate was 16.7 percent

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the sample listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance work orders (WOs), and maintenance rule basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the maintenance rule. For the sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.65 and verified that the (a)(2) performance criteria established by Exelon staff were reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Exelon staff were identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries. The inspectors also verified that parts installed in safety-significant systems that were purchased as commercial grade parts were dedicated prior to installation in a quality grade application.

• Unit 1 commercial grade dedication replacement of main steam tunnel differential temperature recorder on October 28, 2016 (Quality Control)

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Exelon performed the appropriate risk assessments prior to removing equipment from service. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Exelon personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Exelon performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

• Unit 1 risk mitigation management actions while EDG 103 was out of service for planned maintenance on October 11-12, 2016

• Unit 1 risk mitigation management actions while number 12 high pressure coolant injection system was out of service for motor inspection on October 19, 2016

• Unit 2 risk mitigation management actions during a reactor core isolation cooling on November 9, 2016

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions based on risk significance of the associated components and systems:

• Unit 2 division 2 diesel failed to start during monthly surveillance test on August 3, 2016,

• Unit 1 reactor building normal ventilation isolation dampers on November 3, 2016, and

• Unit 1 and Unit 2 flex pumps failures to start on December 9, 2016.

The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to Exelons evaluations to determine whether the components or systems were operable. The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Exelon.

b. Findings

No findings were identified.

1R18 Plant Modifications

Permanent Modification

a. Inspection Scope

The inspectors evaluated Unit 1 ECP-16-000477, Unit 1 Emergency Diesel Generator Speed Sensing Panel Upgrade, Revision 0. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by this modification. In addition, the inspectors reviewed modification documents associated with the design changes.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with the information in the applicable licensing basis and/or design basis documents, and that the test results were properly reviewed and accepted and problems were appropriately documented. The inspectors also walked down the affected job site, observed the pre-job brief and post-job critique where possible, confirmed work site cleanliness was maintained, and witnessed the test or reviewed test data to verify quality control hold point were performed and checked, and that results adequately demonstrated restoration of the affected safety functions.

• Unit 1 EDG 103 monthly performance test following the completion of planned maintenance on October 12, 2016

• Unit 1 diesel fire pump following 5-year preventive maintenance on October 13, 2016

• Unit 1 EDG 102 following planned maintenance on October 16, 2016

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

The inspectors reviewed the stations work schedule and outage risk plan for the following forced outages:

• Unit 2 forced outage (N2F1601) which was conducted November 23 through December 4, 2016, and

• Unit 1 forced outage (N1F1601), which was conducted from December 10 through December 13, 2016.

The inspectors reviewed Exelons development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outages, the inspectors observed portions of the startup and cooldown processes and monitored controls associated with the following outage activities:

• Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable technical specifications when taking equipment out of service,

• Implementation of clearance activities,

• Monitoring of decay heat removal operations,

• Fatigue monitoring,

• Shutdown safety,

• Drywell cleanliness (Unit 2), and

• Plant shutdown and startup activities.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and Exelon procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations as well as the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance test:

• Unit 1 change via surveillance frequency control program for main steam isolation valves from 3 to 12 months on November 18, 2016.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

Exelon implemented various changes to the NMPNS Emergency Action Levels (EALs),emergency plan, and implementing procedures. Exelon had determined that, in accordance with 10 CFR 50.54(q)(3), any change made to the EALs, emergency plan, and its lower-tier implementing procedures, had not resulted in any reduction in effectiveness of the plan, and that the revised plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR Part 50 Appendix E.

The inspectors performed an in-office review of all EAL and emergency plan changes submitted by Exelon as required by 10 CFR 50.54(q)(5), including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential reductions in effectiveness of the emergency plan. This review by the inspectors was not documented in an NRC safety evaluation report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria. The specific documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Exelon entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended screening meetings. The inspectors also confirmed, on a sampling basis, that, as applicable, for identified defects and non-conformances, Exelon performed an evaluation in accordance with 10 CFR Part 21.

b. Findings

No findings were identified.

.2 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a semi-annual review of site issues to identify trends that might indicate the existence of more significant safety issues. As part of this review, the inspectors included repetitive or closely related issues documented by Exelon outside the normal CAP, in documents such as trend reports, performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or CAP backlogs. The inspectors also reviewed Exelons CAP database for the third and fourth quarters of 2016 to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed Exelons quarterly trend report for the second and third quarters of 2016, conducted under PI-AA-125-1005, Coding and Analysis Manual, Revision 0, to verify Exelon personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.

b. Findings and Observations

No findings were identified.

The inspectors evaluated a sample of issues and events that occurred in the third and fourth quarters of 2016 to objectively determine whether issues were appropriately considered or ruled as emerging or adverse trends. The inspectors verified that these issues were addressed within the scope of the CAP.

The inspectors determined Exelon personnel were identifying trend issues at a low threshold and entering them into the CAP for resolution and were appropriately prioritizing investigation reviews. The inspectors noted minor adverse trends identified by Exelon staff associated with improper closure of corrective actions, as reviewed in CR 02689808 and degrading start times for the Division II EDG, as reviewed in CR 02689624.

There were no adverse safety consequences as a result of the trend issues stated above and the inspectors determined Exelon personnel had appropriately identified adverse trends at NMPNS before they became more significant safety problems. The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues, and determined these issues were of minor significance and, therefore, not subject to enforcement action in accordance with NRC Enforcement Policy.

.3 Annual Sample: Review of Corrective Actions in Response to NRC Information Notice

2011-20 for Structures Monitoring

a. Inspection Scope

The inspectors conducted an in-office review to follow up on Exelons corrective actions in response to NRC Information Notice (IN) 2011-20, Concrete Degradation by Alkali-Silica Reaction (ASR), which were documented in Exelons CAP under AR 02402406. The NRCs initial review of Exelons evaluation of IN 2011-20 was documented in an NRC inspection report, dated November 9, 2015 (ADAMS Accession No. ML15314A506). During this previous inspection, the Unit 2 secondary containment building was observed to have pattern-like cracking in localized areas of the exterior walls. Exelon staff removed a sample of concrete (i.e., core) from one wall and sent the sample to an independent laboratory to determine the causes, including whether the cracking was the result of ASR.

The inspectors performed an in-depth review of Exelons corrective actions, specifically the concrete core test report, to assess the cause of the cracking in the external wall.

The inspectors verified that all of the planned actions were completed and interviewed engineering personnel to discuss the test results. In addition, the inspectors reviewed the most recent structures monitoring report from Exelon staff walkdowns conducted in 2016 for the secondary containment building to verify that the enhanced walkdown procedure was being implemented.

b. Findings and Observations

No findings were identified.

Exelon staff identified an area of the external secondary containment wall that exhibited pattern-like cracking and some staining, characteristics that may be indicative of ASR degradation. Exelon staff then removed a core from the wall in the area of interest and sent it to a concrete testing laboratory. The purpose of this sample was to perform petrographic examinations to characterize the condition of the concrete and to determine the likely causes of the cracking, including determining whether the observed cracking was the result of ASR. The testing report documented that the concrete was in excellent condition and that the full-depth crack observed in the sample was not caused by ASR.

Exelon determined the cause was most likely related to thermal contraction/expansion of the concrete and/or attributable to drying shrinkage cracking, a phenomenon that occurs following concrete placement and the curing process.

The inspectors reviewed the test report and verified that the concrete testing was performed in accordance with the American Society of Testing and Materials C856, Standard Practice for Petrographic Examination of Hardened Concrete. The inspectors also independently reviewed the photographs of the sample and did not identify any additional issues. As discussed in IN 2011-20, ASR-induced degradation can only be confirmed by optical microscopy performed as part of petrographic examination of concrete core samples. The inspectors concluded that Exelon staff conducted an appropriate review to identify the likely causes of the concrete cracking.

The inspectors also reviewed the most recent walkdowns performed by Exelon staff as part of the structures monitoring program and determined that there had been no significant changes to the structures since the last detailed walkdown. The inspectors concluded Exelons response to IN 2011-20 was commensurate with the safety significance, was timely, and included appropriate followup actions.

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

.1 Plant Events

a. Inspection Scope

For the plant event listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant event(s) to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Exelon made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Exelons follow-up actions related to the events to assure that Exelon implemented appropriate corrective actions commensurate with their safety significance.

• Unplanned shutdown of Unit 2 'A recirculation pump followed by forced outage on November 23, 2016

• Unit 1 manual trip following high main turbine vibrations on December 10, 2016

b. Findings

No findings were identified.

.2 (Closed) Licensee Event Report (LER) 05000220/2016-002-00: Isolation of Both

Emergency Condensers Due to Loss of Uninterruptible Power Supply (UPS) 162B On July 28, 2016, Unit 1 experienced a loss of UPS 162B, which resulted in the loss of Reactor Protection System (RPS) bus 11. Numerous half scram and half isolation signals were generated in addition to the isolation of both the 11 and 12 emergency condensers (ECs). Isolation of both ECs is reportable under 10 CFR 50.73(a)(2)(v)(B)as any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to control the removal of residual heat. The ECs were returned to standby within one hour after isolation.

Exelon determined that a capacitor in the UPS constant voltage transformer shorted.

The UPS voltage dropped but remained higher than the 60 volts alternating current (VAC) bypass power supply transfer setpoint. The UPSs protective relaying logic tripped the UPS loads prior to reaching the 60 VAC setpoint, resulting in de-energization of the RPS 11 instrument bus before the transfer could occur. The low voltage setpoint was reached and the UPS transferred to bypass power supply, thereby re-energizing the loads. The voltage transient on the bus affected the pressure transmitters for the EC high steam flow isolation signal, resulting in the isolation of both EC trains.

Corrective actions for this event include replacement of the failed capacitor and blown fuses, installation of new higher temperature rated capacitors, and adjustment of the low voltage bypass power transfer setpoint. No findings or violations of NRC requirements were identified.

4OA5 Other Activities

.1 NRC Office of Investigations Report 1-2016-007

a. Inspection Scope

On October 6, 2015, NRC inspectors identified a failure to meet fire protection program procedural requirements related to the conduct of required fire brigade drills and the potential existed that this may have been a deliberate act. In response, the Region I Field Office, NRC Office of Investigations, initiated an investigation on December 23, 2015, to determine whether an operations manager, employed by Exelon at NMPNS, willfully and deliberately failed to implement those requirements on September 30, 2015, when the manager cancelled a fire drill for crew A. Based on testimonial and documentary evidence gathered during the investigation, the investigators concluded that while violations of TS requirements had occurred, the actions of the manager were not determined to be willful or deliberate. The enforcement aspects of this issue are discussed in section 4OA7.

b. Findings

No findings were identified.

.2 Temporary Instruction (TI) 2515/192, Inspection of the Licensees Interim

Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems

a. Inspection Scope

The objective of this performance-based TI is to verify implementation of interim compensatory measures associated with an open phase condition (OPC) design vulnerability in electric power system for operating reactors. The inspectors conducted an inspection to determine if Exelon had implemented the following or equivalent interim compensatory measures. These compensatory measures are to remain in place until permanent automatic detection and protection schemes are installed and declared operable for OPC design vulnerability. The inspectors verified the following:

• Exelon had identified and discussed with applicable plant staff the lessons learned from the OPC events at the U.S. operating plants including the Byron Nuclear Generating Station OPC event and its consequences. This includes conducting operator training for promptly diagnosing, recognizing consequences, and responding to an OPC event.

• Exelon had updated applicable plant operating procedures to help operators promptly diagnose and respond to OPC events on off-site power sources credited for safe shutdown of the plant. As an example, procedures may include monitoring voltages on all three phases on a routine basis, or alternate monitoring methods, and additional monitoring following electrical equipment malfunctions, such as a trip of rotating equipment.

• Exelon had established and continues to implement periodic walkdown activities to inspect switchyard equipment such as insulators, disconnect switches, and transmission line and transformer connections associated with the offsite power circuits to detect a visible OPC.

• Exelon had ensured that routine maintenance and testing activities on switchyard components were implemented and maintained. Such activities may include visual inspections and routine thermography or thermal imaging of insulators, connections, and other components in high voltage switchyards. As part of the maintenance and testing activities, Exelon assessed and managed plant risk in accordance with 10 CFR 50.65(a)

(4) requirements.

b. Findings and Observations

No findings were identified. The inspectors verified the criteria had been met.

4OA6 Meetings, Including Exit

On January 9, 2017, the inspectors presented the inspection results to Mr. Peter Orphanos, Site Vice President, and other members of the NMPNS staff. The inspectors verified that no propriety information was retained by the inspectors or documented in this report.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.

Technical Specification 6.4.1 for Unit 1 and TS 5.4.1 for Unit 2 state that, Written procedures shall be established, implemented, and maintained covering the following activities: d. Fire Protection Program Implementation. Procedure OP-AA-201-003, Fire Drill Performance, implements portions of the Exelon fire protection program, and OP-AA-201-003 states fire drills shall be conducted quarterly for each shift fire brigade.

Contrary to the above, Exelon failed to correctly implement its fire brigade training program procedure. Specifically, Exelon failed to conduct fire drills for brigade teams A, C, and D for the third quarter 2015 as required by OP-AA-201-003 because of scheduling conflicts caused by emergent and planned work and station activities. For fire brigade A, the brigade was initially scheduled to perform a third quarter fire drill on July 22, 2015. However, that drill as well as subsequent drills which were scheduled to be performed on August 25, 2015, and September 30, 2015, respectively, were cancelled to facilitate other work activities. For fire brigade C, the third quarter drill which was scheduled for September 8, 2015 was cancelled because of station work load. For fire brigade D, a third quarter drill that was scheduled for September 24, 2015, was also canceled because of other work activities. On October 2, 2015, Exelon documented the missed quarterly drills in the CAP as IR 02564520. During the fourth quarter, crews A, C, and D each conducted a make-up drill as well as a regular quarterly drill. However on October 31, 2015, crew C failed its make-up drill. Crew C was remediated and passed a repeat drill on November 10, 2015.

The inspectors determined that the performance deficiency was more than minor in accordance with IMC 0612, Appendix B, Issue Screening, because if left uncorrected, it could lead to a more significant safety concern. The inspectors decision was informed by examples 3j and 3k in IMC 0612, Appendix E, Examples of Minor Issues. The examples refer to an issue not being minor if significant programmatic deficiencies were identified with the issue that could lead to worse errors if left uncorrected. Specifically, 60 percent of the NMPNS fire brigade teams had missed their quarterly fire drill requirement which is indicative of a programmatic issue and there is a reasonable concern as to the effectiveness of the fire brigade since the required training had not been completed and one crew subsequently failed its next drill. Based on IMC 0609, 4, Initial Characterization of Findings, findings that involve discrepancies with the fire brigade are directed to IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. From IMC 0609 Appendix A Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that a the final significance must be determined using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The finding was determined to have very low safety significance (Green) because a prior similar violations significance bounded this findings significance. The prior similar violation occurred at NMPNS, which was documented in inspection report 05000220/410/2009006-01 as an NCV.

Because this violation was determined to be of very low safety significance and entered into the CAP in IR 02564520, it is being treated as an NCV, consistent with section 2.2.3 of the NRC Enforcement Policy.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

P. Orphanos, Site Vice President

R. Kreider, Plant Manager

M. Busch, Director Site Operations

J. Gerber, Manager Site Chemistry, Environment and Radwaste

S. Homoki, Senior Engineer

P. Kehoe, Engineering Analyst

M. Khan, Senior Manager Engineering

B. Knowlton, Site Engineer

B. Koscielniak, Manager Engineering

K. Kristensen, Regulatory Principle Engineer

M. Kunzwiler, Manager Site Security

D. Moore, Manager Regulatory Assurance

R. Pritchard, Regulatory Assurance

A. Sterio, Director, Site Engineering

D. Tulowiecki, Manager Site Radiation Protection

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Closed

05000220/2016-002-00 LER Isolation of Both Emergency Condensers Due to Loss of UPS 162B (Section 4OA3)

05000220/410/TI 2515/192 TI Inspection of the Licensees Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems (Section 4OA5)