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IR 05000334-11-005, 05000412-11-005, on 10/01/2011-12/31/2011; Beaver Valley Power Station, Units 1 & 2; Drill Evaluation
	ML12032A286
Person / Time
Site:	Beaver Valley
Issue date:	02/01/2012
From:	Hunegs G; NRC Region 1
To:	Harden P; FirstEnergy Nuclear Operating Co
	Hunegs G
References
	IR-11-005
	Download: ML12032A286 (28)
	v • d • e

UNITED STATES N UGLEAR REGU LATORY COMMISSION

REGION I

475 ALLENDALE ROAD

SUBJECT:

BEAVER VALLEY POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000334/201 1 005 AND 05000412t201 1005

Dear Mr. Harden:

On December 31 ,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Beaver Valley Power Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on January 24,2012, with Mr.

Raymond Lieb, Director of Site Operations, and other members of your staff.

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

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

This report documents one (1) self-revealing finding of very low safety significance (Green).

This finding was determined to be a violation of NRC requirements. However, because of its very low safety significance, and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRC Enforcement Policy. lf you contest this non-cited violation in this report, you should provide a written 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 l; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Beaver Valley Power Station. In addition, if you disagree with the cross-cutting aspect assigned to the finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the RegionalAdministrator, Region l; and the NRC Resident lnspector at the Beaver Valley Power Station.

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter and its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely, Gordon K. Hunegs, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-334, 50-412 License Nos: DPR-66, NPF-73

Enclosures:

Inspection Report 05000334/201 1005; 050004121201 1005 wi Attachment: Supplemental Information

REGION I Docket Nos. 50-334. 50-412 License Nos. DPR-66, NPF-73 Report Nos. 05000334/201 1005 and 0500041212011005 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Beaver Valley Power Station, Units 1 and 2 Location: Shippingport, PA 15Q77 Dates: October 1, 2011 through December 31, 2011 Inspectors: D. Spindler, Senior Resident Inspector E. Bonney, Resident Inspector D. Silk, Senior Operations Engineer Approved by: G. Hunegs, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure

TABLE OF CONTENTS suMMARy OF FlNDlNGS........... .........3 1. REACTOR SAFETY... ....................4 1R01 Adverse Weather protection .................4 1R04 Equipment Alignment. ..........4 1R05 Fire Protection............ ......... s 1R06 Flood Protection Measures ...................6 1R07 Heat Sink performance............... ..........6 1R12 Maintenance Effectiveness......... ..........9 1R13 Maintenance Risk Assessments and Emergent work control...... ............ g 1R15 operability Determinations and Functionality Assessments.......... ......... 10 1R19 Post-Maintenance Testing .................. 11 1R22 Surveillance Testing ..........11 1EPO Drill Evaluation........... ........12 4. OTHER ACTlVITlES.............. ...... 13 4OA1 Performance lndicator Verification ...... 13 4OA2 Problem ldentification and Resolution ..................i4 4OAO Meetings, Including Exit........... ...........17 ATTACHMENT: SUPPLEMENTARY INFORMATION ,,.....,...17 SUPPLEMENTARY INFORMATION........... ........A.1 KEy polNTS OF CONTACT........ ......A_1 LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED ....................A-1 LIST OF DOCUMENTS REVIEWED............ .,.....A-2 LtsT oF ACRONYMS.............. ..........A-8 Enclosure

SUMMARY OF FINDINGS

lR 0500033412011005, lR 0500041212011005; 1010112011-1213112011; Beaver Valley Power

Station, Units 1 & 2; Drill Evaluation This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. One self'revealing finding of very low safety significance (Green) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (lMC) 0609, "Significance Determination Process" (SDP). The cross-cutting aspects for the findings were determined using IMC 0310, "Components Within Cross-Cutting Areas." Findings for which the SDP does not apply may be Green, or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Emergency Preparedness

e

Green.

A Green, self-revealing non-cited violation (NCV) of 10 CFR 50.47(b)(2) to ensure timely augmentation of response capabilities is available was identified. Specifically,

FENOC failed to fully staff two primary Emergency Response Organization (ERO) positions during an unannounced activation drill. FENOC entered this issue into their corrective action program as CR 2011-04431.

Traditional enforcement does not apply because the issue did not have an actual safety consequence or the potential for impacting NRC's regulatory function, and was not the result of any willful violation of NRC requirements. The inspectors determined that the finding was not similar to the examples for minor deficiencies contained in IMC 0612, Appendix E,

"Examples of Minor lssues." The finding is more than minor because it affects the Emergency Preparedness cornerstone, The finding is associated with the ERO readiness attribute of the Emergency Preparedness cornerstone to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency.

In accordance with IMC 0609, Appendix B, Sheet 1, "Failure to Comply" flowchart, the performance deficiency screens to green because it is considered a degraded planning standard function.

The cause of this NCV relates to the cross-cutting aspect of Human Performance, Work Practices, in that FENOC personnel did not effectively communicate expectations regarding drill participation and staff did not respond in the required time for ERO positions they had accepted in the call out system H.4(b). (Section 1EP6)

REPORT DETAILS

Summarv of Plant Status Unit 1 began the inspection period at 100 percent power and remained at or near 100 percent power throughout the inspection period.

Unit 2 began the inspection period at 100 percent power and remained at or near 100 percent power throughout the inspection period.

1,

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier lntegrity

1R01 Adverse Weather Protection (71111,01 - 1 sample)

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors performed a review of the Beaver Valley Power Station's readiness for the onset of seasonal cold temperatures. The review focused on external storage tanks and associated piping and the emergency diesel generators (EDGs). The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), technical specifications, control room logs, and the corrective action program to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Beaver Valley personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including Beaver Valley's seasonal weather preparation procedure and applicable operating procedures. 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. Findinqs No findings were identified.

1R04 EquipmentAlionment

.1 Partial Svstem Walkdowns (71111.04Q

- 3 samples)a. lnspection Scope The inspectors performed partial walkdowns of the following systems:

.

Unit 1, 'B' Low head safety injection system (LHSI) during 'A' LHSI pump testing on October 18 o Unit 1, 'A' Outside recirculation spray system during 'B' outside recirculation spray pump maintenance on October 25

.

Unit 1, 1-2 Emergency diesel generator (EDG) fuel oil, air start, and cooling during 1-1 EDG testing on November 9 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, technical specifications, work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems 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 licensee staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.

b. Findinos No findings were identified.

.2 Full Svstgm Walk@wn (71111.04S

- 1 sample)

a. Inspection Scope

On November 21, the inspectors performed a complete system walkdown of accessible portions of the Unit 1 quench spray system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hangar and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.

Additionally, the inspectors reviewed a sample of related condition reports and work orders to ensure FENOC appropriately evaluated and resolved any deficiencies.

b. Findinos No findings were identified.

1R05 Fire Protection

.1 Resident lnspector Quarterlv Walkdowns (71111.05Q

- 5 samples)a. lnspection 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 FENOC 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 seryice, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

.

Unit 1, Process rack room, CR-04 on October 27

.

Unit 1, Cable tray mezzanine, CS-1 on October 27 o Unit 1, West cable vault, CV-1, on November 15

.

Unit 2, Main feed regulating valve room, SB-5, on November 8 o Unit 2, Normal switchgear room, SB-4, on November I b. Findinqs No findings were identified.

1R06 Flood Protection Measures (71111.06 - partial sample)

.1 Annual Review of Cables Located in Underqround Bunkers/Manholes

a. Inspection Scope

The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could disable risk-significant equipment. The inspectors performed walkdowns of risk-significant areas, including manholes 1EMH8A and 1EMH8B, which contain service water and river water cables. lnspectors verified that the cables were not submerged in water, that cables appeared intact, and observed the condition of cable support structures. The inspectors verified proper sump pump operation and verified level alarm circuits were set in accordance with station procedures to ensure that the cables will not be submerged.

b. Findinqs No findings were identified.

1R07 Heat Sink Performancs F1111 1.07A - 1 sample)

a. lnspection Scope The inspectors reviewed the Unit 2 'A' primary component cooling water heat exchanger (2CCP-E21A) to determine its readiness and availability to perform its safety functions.

The inspectors reviewed the design basis for the component and verified FENOC commitments to NRC Generic Letter 89-13. The inspectors reviewed the results of previous inspections of 2CCP-821A and similar heat exchangers. The inspectors discussed the results of the most recent inspection with engineering staff. The inspectors verified that FENOC initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchanger supports an operable but degraded status of the heat exchanger, limited by river water temperature.

b. Findinqs No findings were identified.

1R1 1 Licensed Operator Requalification Prosram (71111.11 - 2 samples)

.1 Biennial Review of Ooerator Licensinq Requalification Proqram

a. Inspection Scope

The following inspection activities were performed using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1, Inspection Procedure Attachmenl71111.11, "Licensed Operator Requalification Program," Appendix A "Checklist for Evaluating Facility Testing Material," and Appendix B "Suggested Interview Topics."

A review was conducted of recent operating history documentation found in inspection reports and the licensee's corrective action program. The inspectors also reviewed specific events from the licensee's corrective action program which indicated possible training deficiencies, to verify that they had been appropriately addressed. The senior resident inspector was also consulted for insights regarding licensed operators' performance. These reviews did not detect any operational events that were indicative of possible training deficiencies.

The operating tests for the week of October 17,2011, were reviewed for quality and performance.

On November 9, 2011, the results of the biennial written exam and the annual operating tests for year 2011 for Beaver Valley Units 1 and 2 were reviewed to determine if pass fail rates were consistent with the guidance of NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1, and NRC Manual Chapter 0609, Appendix l, "Operator Requalification Human Performance Significance Determination Process (SDP)." The review verified the following:

For Unit 1

.

Crew pass rates were greater than 80 percent. (Pass rate was 100 percent.)

o lndividual pass rates on the dynamic simulator test were greater than 80 percent, (Pass rate was 100 percent.)

r Individual pass rates on the job performance measures of the operating exam were greater than 80 percent. (Pass rate was 100 percent.)

r Individual pass rates on the written examination were greater than 80 percent.

(There was no biennial written examination this year for Unit 1 operators.)

o More than 75 percent of the individuals passed all portions of the exam, (100 percent of the individuals passed all portions of the operating examination.)

For Unit 2

.

Crew pass rates were greater than 80 percent. (Pass rate was 100 percent.)

o lndividual pass rates on the dynamic simulator test were greater than 80 percent.

(Pass rate was 93.5 percent,)

r Individual pass rates on the job performance measures of the operating exam were greater than 80 percent. (Pass rate was 100 percent.)

r Individual pass rates on the written examination were greater than 80 percent. (Pass rate was 100 percent.)

o More than 75 percent of the individuals passed all portions of the exam.

(93.5 percent of the individuals passed all portions of the operating examination.)

Observations were made of the dynamic simulator exams and job performance measures (JPM) administered during the week of October 17, 2011. These observations included facility evaluations of crew and individual performance during the dynamic simulator exams and individual performance of five JPMs, Written and operating examination material was reviewed to ensure excessive overlap did not exist among examination items.

The remediation plans for one crew and nine individual written quiz failures were reviewed to assess the effectiveness of the remedial training.

Seven operator license re-activations were reviewed to ensure that 10 CFR 55.53 license conditions and applicable program requirements were met.

Four operators were interviewed for feedback on their training program and the quality of training received.

Simulator performance and fidelity were reviewed for conformance to the reference plant control room.

A sample of records for requalification training attendance, program feedback, reporting, and medical examinations were reviewed for compliance with license conditions, including NRC regulations. Proficiency watch records for Unit 2 operators were also reviewed for the third quarter 2011.

b.

Findinos No findings were identified.

.2 Quarterlv Review of Licensed Operator Req ualification Testinq and Trainino (7 1111

. 11Q

- 1 sample)a. Inspection Scooe The inspectors observed licensed operator simulator training on October 6,2011, which included a fire in the 1DF switchgear, loss of an emergency diesel, and a loss of primary containment. 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 I

and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the technical specification action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findinqs No findings were identified

1R12 Maintenance Effectiveness

Main article: IP 71111.12

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on SSC performance and reliability. The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that FENOC was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2)performance criteria established by FENOC staff was 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 FENOC staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

r Unit 2, Fire protection early warning panel failures on December 15,2011

.

Unit 1 and 2, Maintenance rule program Periodic Assessment Review of September 2009 through February 2011 o Unit 1 and 2, 8A Manhole sump pump failures on December 12,2011 b. Findinss No findings were identified.

1R13 Maintenance Risk Assessments and Emerqent Work kntrol (71111

.13 - 5 samples)

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 FENOC performed the appropriate risk assessments prior to removing equipment for work. 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 FENOC personnel performed risk assessments as required by 10 CFR 50.65(aX4) and that the assessments were accurate and complete. When FENOC performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

o Unit 2, 'B' System station service transformer (SSST) tap changer emergent repair on October 8 o Unit 2, Rescheduled maintenance on'A'SSST on October 13 o Unit 2, Emergent maintenance on service water system 2SWP-P21A, B, C seal water and motor cooling water strainer (2SWS-STRM48) on October 29 r Unit 1 and 2, Risk assessment for emergent work on 2-2 EDG on October 5

.

Unit 1 and 2, Risk assessment for emergent work on the Emergency Response Facility (ERF) EDG during the week of December 12 b. Findinqs No findings were identified.

1R15 Operabilitv Determinations and Functionalitv Assessments (71111

.15 -

5 samples)

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

.

Unit 1, Containment electrical penetration test gauges reading zero, CR 11-96117 on October 17 o Unit 2, A Service water supply header to 2-1 EDG through-wall leak, CR 2011-02562 on October 3 o Unit 2, Pinhole leak in fire protection piping DV-1FP-s, CR 2011-02362 on October 3 and 4 o Unit 2, 'B' Service water pump strainer packing failure, CR 2011-04562 on October 29 r Unit 2, 'A' Component cooling water heat exchanger, CR 2011-02159 on November 4 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification 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 technical specifications and UFSAR to FENOC's evaluations to determine whether the components or systems were operable.

Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by FENOC. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findinqs No findings were identified.

1R19 Pgst-Maintenance &stinq (71111

.19 - 7 samples)

a. lnsoection Scope The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

r Unit 1, Containment isolation valve, TV-1DA-1008, repair on October 11

.

Unit 1, 1-1 EDG air start system solenoid operated valve replacement on November 9

.

Unit 1,1-2 Battery bus supply breaker replacement on November 23 o Unit 2,2-2 EDG cylinder head test valve replacement on October 5

.

Unit 2, 'A' Component cooling water pump shaft and outboard bearing repair on October 14 o Unit 2, Steam driven auxiliary feedwater (AFW) pump steam supply header valve repair on December 9 o Unit 2,'C'steam supply isolation to the steam driven AFW PUMP [2MSS-SOV105C]

solenoid operator replacement on December 16 b, Findinqs No findings were identified.

1R22 Surveillance Testinq (71111.22 - 6 samples)

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 technical specifications, the UFSAR, and licensee 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 and 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 tests:

o Unit 1, l 03T-36

.1 , 1-1 EDG monthly test on October 1 1

o Unit 1, l 05T-6.24, Reactor coolant system inventory balance on October 14-18, (RCS leak rate)r Unit 1, lOST-30,1A, Auxiliary river water pump test on October 21 (in-service test)o Unit 2,2MSP-24.02-1, Loop 1 Narrow range steam generator water level channel I test on October 13 o Unit 2,2MSP-21.24-1, Loop 'B' Steamline pressure protection channel lV calibration, on November 4 o Unit 1 and 2,1l2OST-33.31, Fire brigade equipment test on November 26 b.. Findinqs No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06 - 2 samples)

.1 Emerqencv Preparedness Drill Observation

a. lnspection Scooq The inspectors evaluated the conduct of routine FENOC emergency drill on October 6 and unannounced activation drill on October 25 to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, technical support center, and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by FENOC staff in order to evaluate FENOC's critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program.

b. Findinos lntroduction: A Green, self-revealing non-cited violation (NCV) of 10 CFR 50.47(b)(2)to ensure timely augmentation of response capabilities is available was identified.

Specifically, FENOC failed to fully staff two primary Emergency Response Organization (ERO) positions during an unannounced activation drill.

Description:

On October 25, Beaver Valley Power Station failed an Emergency Response off-hours, unannounced activation drill. At 041 1, a simulated Alert was initiated by the control room as a site wide activation with all ERO responders required to report to assigned positions. Two primary ERO positions that augment on-shift personnel, Radiation Technician and Field Monitoring Driver, were not fully staffed within the required 60 minute activation per the Emergency Preparedness Plan, Section 5, Table 5.1, Minimum On-Shift Staffing Requirements. Four of the ten required Radiation Technician positions were not fully staffed until 69 minutes from drill declaration, and one of two required Field Monitoring Driver positions was not filled until 71 minutes after drill declaration. These positions are filled by personnel not required to carry pagers. All personnel were initially contacted via pager, followed by calls to home phones and/or cell phones. The automated callout system continues to contact personnel until all ERO positions are acknowledged by a callfrom the responder committing to report to the station within the required time.

The licensee conducted a root cause analysis of the failed activation drill. Several changes were made to the ERO automated call-out system that contacts ERO responders. More phone lines were dedicated to calling Radiation Technicians. The number of Radiation Technicians contacted for ERO positions required to respond to the site was increased from 10 to 20 personnel. The automated callout system now contacts personnel via home phone, cell phone, and pager, when positions remain unfilled after the initial call-out system transmission. A text message is also sent out with the initial page to cell phones.

Analvsis: The failure to fully staff the Radiation Technician positions and Field Monitoring Driver position within the required time is considered a performance deficiency. Traditional enforcement does not apply because the issue did not have an actual safety consequence or the potential for impacting NRC's regulatory function, and was not the result of any willful violation of NRC requirements. The inspectors determined that the finding was not similar to the examples for minor deficiencies contained in IMC 0612, Appendix E, "Examples of Minor lssues." The finding is more than minor because it affects the Emergency Preparedness cornerstone. The finding is associated with the ERO readiness attribute of the Emergency Preparedness cornerstone to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency.

ln accordance with IMC 0609, Appendix B, Sheet 1, "Failure to Comply" flowchart, the performance deficiency screens to green because it is considered a degraded planning standard function.

The cause of this NCV relates to the cross-cutting aspect of Human Performance, Work Practices, in that FENOC personnel did not etfectively communicate expectations regarding drill participation and staff did not respond in the required time for ERO positions they had accepted in the automated callout system tH.4(b)1.

Enforcement:

10 CFR 50.sa(q) requires that FENOC follow and maintain in effect emergency plans which comply with the standards of 10 CFR 50.47(bX2), to ensure timely augmentation of response capabilities is available. Contrary to the above, FENOC failed to filltwo primary ERO positions required by the Emergency Preparedness Plan during an off-hours, unannounced, activation drill. Because this deficiency is considered to be of very low safety significance (Green), and was entered into the corrective action program (CR 2011-04431), this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000334, 41212011005-01, Unannounced Emergency Response Organization Activation Drill Failure)

OTHER ACTIVITIES

4OA1 Performance lndicator Verification

(71 151)

.1 Mitiqatinq Svstems Performance Index (4 samples)

a. Inspection Scope

The inspectors reviewed FENOC's submittal of the Mitigating Systems Performance Index for the following systems for the period of October 1, 2010 through September 30, 2011:

o Unit 1 Emergency AC Power System

.

Unit 2 Emergency AC Power System

.

Unit 1 High Pressure Injection System

.

Unit 2 High Pressure Injection System To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance lndicator Guideline," Revision 6. The inspectors also reviewed operator narrative logs, condition reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findinos No findings were identified.

4c.42 Problem ldentification and Resolution (71152 - 4 samples)

.1 Routine Review of Problem ldentification and Resolution Activitigs

a. Inspection Scope

As required by Inspection Procedure71152, "Problem ldentification and Resolution," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that FENOC entered issues into the corrective action program 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 corrective action program and periodically attended management review board condition report screenings.

b. Findinqs No findings were identified.

,2 Annual Sample: Review of the Operator Workaround Prooram Inspection Scope The inspectors reviewed the cumulative effects of the existing operator workarounds, operator burdens, existing operator aids and disabled alarms, and open main control room deficiencies to identify any effect on emergency operating procedure operator actions, and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed operator workarounds as specified in FENOC procedure NOBP-OP-OO12, "Operator Work-Arounds, Burdens, and Control Room Deficiencies."

The inspectors reviewed FENOC's process to identify, prioritize and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these operator workarounds and recent self assessments of the program.

The inspectors also toured the control room and discussed the current operator workarounds with the operators to ensure the items were being addressed on a schedule consistent with their relative safety significance.

b. Findinos and Observations No findings were identified.

.3 Annual Sample: Deqradino Trend in Operations Procedure Content and Usaqe

a. Inspection Scope

The inspectors performed an in-depth review of FENOC's corrective actions associated with the full apparent cause for condition report CR 10-82360 and limited apparent cause for condition report CR 11-88214 regarding Operations procedure usage and content during the third and fourth quarters of 2Q10.

The inspectors assessed FENOC's problem identification threshold, cause analyses, extent of condition reviews, and the prioritization and timeliness of FENOC's corrective actions to determine whether FENOC was appropriately identifying, characterizing, and correcting problems associated with the procedure usage by operations department personnel.

b. Findinqs and Observations No findings were identified.

FENOC's cause analyses identified that errors in procedures was a significant contributor to errors made by operations personnel. A significant backlog of procedural changes exists on site, and prior to the CR 10-82360, prioritization of procedure changes was not effectively managed. Operators were identifying procedure issues in the corrective action program, but procedure corrections were not being addressed in a timely manner commensurate with the frequency and safety importance of the procedure usage. FENOC is now actively managing the document change request list with a backlog reduction plan that includes weekly updates to management. Human performance was not recognized as a significant contributor in the analysis and corrective actions.

CR 11 -88214 assessed the human performance aspect of the errors that occurred in 2010. A decline in procedure adherence was identified in the analysis. The corrective actions directed management to reinforce standards to operations regarding the importance of procedural compliance. Operations human performance has started to decfine in the Clearance/Tagging Program, NOP-OP-1001, implementation, as evidenced by CR 2011-04088, "lnadvertent de-energization of MCC-2-14,"

CR 2011-01798 "Locking device not properly installed" and CR 2011- 02791"lncorrect clearance posting causes trip of 'C' chiller" in the fourth quarter af 2011. While not adversely affecting safety related equipment, human performance by Operations has not exhibited a high level of attention to detail to FENOC clearance program procedures, which are general field references. There has been an improvement in step-by-step procedure usage by Operations personnel in the fourth quarter of 2011.

.4 Annual Sample: Radiation Protection and Chemistrv Safetv Conscious Work

Environment 2010/201 1 Survev Results

a. Inspection Scope

The inspectors performed an in-depth review of FENOC's corrective actions associated with the full apparent cause for condition reports CR-10-83224 and 10-83492 regarding multiple negative responses in the 2010 Radiation Protection and Chemistry department safety conscious work environment (SCWE) survey.

The inspectors assessed FENOC's problem identification threshold, cause analyses, extent of condition reviews, and the prioritization and timeliness of FENOC's corrective actions to determine whether FENOC was appropriately identifying, characterizing, and correcting problems associated with the negative responses identified in the SCWE survey. The inspectors reviewed the 2011 and 2010 SCWE survey results for the site.

Interviews were conducted by inspectors to assess employees'willingness to raise safety concerns onsite. Condition reports generated by Radiation Protection and Chemistry personnelwere reviewed by inspectors. lnspectors also performed observations of site personnel response to issues discovered in the field, b. Findinqs and Observations No findings were identified.

FENOC identified several communication issues between Radiation Protection and Chemistry management and staff that is a potential driver of the negative responses in the annual SCWE survey. Based on inspector interviews and discussions with Radiation Protection and Chemistry personnel, the staff is aware of various means of raising safety concerns on site. The employee concerns program is consistently used throughout the year by FENOC employees.

2011 Chemistry SCWE survey results improved from the 2010 results. Radiation Protection SCWE survey results remained unchanged. Inspectors reviewed a sampling of condition reports to determine if Radiation Protection and Chemistry personnel were identifying issues through the corrective action process. Condition reports denote if the issue is identified by an individual, supervisor, oversight or is self-revealing. Based on a random sampling of thirty{hree condition reports generated in the past three months by the Radiation Protection group, over half were identified by individuals. Twenty-two condition reports generated by Chemistry personnel in the last three months were reviewed, with approximately 65% of issues identified by individuals. The inspectors determined that, combined with the inspectors'daily review of condition reports, issues are being raised by individuals on site.

40A6 Meetinqs. lncludinq Exit

.1 LicensedOperatorRequalification

On October 21,2011, the inspectors presented the inspection results of 1R1 1 to Chris Hynes, Training manager and other members of the FENOC staff at an exit meeting, The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

.2 Quarterlv Inspection Report Exit

On January 24,2012, the inspectors presented the inspection results to Mr, Raymond Lieb, Director of Site Operations, and other members of the FENOC staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

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