IR 05000440/2013008: Difference between revisions
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{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532 | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532 | ||
-4352 October 3, 2013 Mr. Ernest Harkness Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P. O. Box 97, 10 Center Road, A-PY- | -4352 October 3, 2013 Mr. Ernest Harkness Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P. O. Box 97, 10 Center Road, A-PY-A 290 Perry, OH 44081 | ||
-0097 | -0097 | ||
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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. | 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. | ||
The NRC-identified | The NRC-identified t wo findings of very low safety significance involving violations of NRC requirements. One of the findings was associated with a traditional enforcement Severity Level IV violation. | ||
However, because of the very low safety significance and because the issues were entered into your Corrective Action Program, the NRC is treating the issue s as Non-Cited | However, because of the very low safety significance and because the issues were entered into your Corrective Action Program, the NRC is treating the issue s as Non-Cited Violation s (NCV s) in accordance with Section 2.3.2 of the NRC Enforcement Policy. | ||
If you contes t the violations or significance of these NCVs | If you contes t the violations or significance of these NCVs | ||
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. In addition, if you disagree with the cross | . In addition, if you disagree with the cross | ||
-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at Perry Nuclear Power Plant | -cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at Perry Nuclear Power Plant | ||
. 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 Agencywide Documents Access and Management System (ADAMS) | . 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 Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading | ||
. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading | |||
-rm/adams.html (the Public Electronic Reading Room). | -rm/adams.html (the Public Electronic Reading Room). | ||
Sincerely,/RA/ Robert C. Daley, | Sincerely,/RA/ Robert C. Daley, Chie f Engineering Branch 3 Division of Reactor Safety Docket Nos. | ||
50-440 License Nos. NPF-58 | 50-440 License Nos. NPF-58 | ||
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Distribution via ListServŽ | Distribution via ListServŽ | ||
Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket No | Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-440 License No | ||
: 50-440 License No | |||
: NPF-58 Report No: | : NPF-58 Report No: | ||
05000440/2013008 Licensee: | 05000440/2013008 Licensee: FirstEnergy Nuclear Operating Company (FENOC) | ||
FirstEnergy Nuclear Operating Company (FENOC) | Facility: Perry Nuclear Power Plant, Unit 1 Location: Perry, Ohio Dates: July 8 through September 17, 2013 Inspectors: | ||
Facility: | |||
Perry Nuclear Power Plant, Unit 1 Location: | |||
Perry, Ohio Dates: July 8 through September 17, 2013 Inspectors: | |||
N. Féliz Adorno, Reactor Inspector (Lead) | N. Féliz Adorno, Reactor Inspector (Lead) | ||
J. Gilliam, Reactor Inspector I. Hafeez, Reactor Inspector Approved by: | J. Gilliam, Reactor Inspector I. Hafeez, Reactor Inspector Approved by: | ||
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety 1 Enclosure | Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety 1 Enclosure | ||
=SUMMARY= | =SUMMARY= | ||
IR 05000440/2013008; | IR 05000440/2013008; 0 7/08/20 1 3 - 0 9/17/201 3; Perry Nuclear Power Plant | ||
; Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications. | ; Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications. | ||
This report covers a two-week announced baseline inspection on evaluations of changes, tests, or experiments and permanent plant m odifications. The inspection was conducted by three Region III based engineering inspectors | This report covers a two-week announced baseline inspection on evaluations of changes, tests, or experiments and permanent plant m odifications. The inspection was conducted by three Region III based engineering inspectors | ||
. | . T wo findings of very low safety significance were identified by the inspectors. The findings were considered Non-Cited Violations (NCVs) of NRC requirements. One of the findings was associated with a traditional enforcement Severity Level IV violation. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). | ||
Cross-cutting aspects were determined using IMC 0310, "Components Within the Cross-Cutting Areas." Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. | Cross-cutting aspects were determined using IMC 0310, "Components Within the Cross-Cutting Areas." Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. | ||
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-1649, "Reactor Oversight Process," Revision 4, dated December 2006. | -1649, "Reactor Oversight Process," Revision 4, dated December 2006. | ||
A. N RC-Identified and Self-Revealed Findings | |||
and Self-Revealed Findings | |||
===Cornerstone: Initiating Events=== | ===Cornerstone: Initiating Events=== | ||
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Specifically, the licensee failed to provide a basis for not applying for a license amendment associated with the use of a freeze seal in the reactor coolant pressure boundary when its integrity was required to protect irradiated fuel | Specifically, the licensee failed to provide a basis for not applying for a license amendment associated with the use of a freeze seal in the reactor coolant pressure boundary when its integrity was required to protect irradiated fuel | ||
. The finding was entered into the licensee's Corrective Action Program with recommended actions to | . The finding was entered into the licensee's Corrective Action Program with recommended actions to , in part, revise the associated 10 CFR 50.59 documents. | ||
, in part, revise the associated 10 CFR 50.59 documents. | |||
The inspectors determined that the violation was more than minor because they could not reasonably determine the changes would not have ultimately required NRC prior approval. The finding affected the Initiating Events cornerstone attribute of equipment performance and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown | The inspectors determined that the violation was more than minor because they could not reasonably determine the changes would not have ultimately required NRC prior approval. The finding affected the Initiating Events cornerstone attribute of equipment performance and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown | ||
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Green: The inspectors identified a finding of very low safety significance and associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the failure to control drainage of the emergency core cooling system room sumps in a manner that prevents common mode flooding of these rooms. Specifically, procedures did not ensure appropriate controls to prevent backflow from the floor drain system. | Green: The inspectors identified a finding of very low safety significance and associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the failure to control drainage of the emergency core cooling system room sumps in a manner that prevents common mode flooding of these rooms. Specifically, procedures did not ensure appropriate controls to prevent backflow from the floor drain system. | ||
The licensee entered the issue into | The licensee entered the issue into the ir Corrective Action Program and revised procedures to prevent opening more than one emergency core cooling system room sump isolation valve at the same time | ||
. The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of protection against external factors and affected the cornerstone objective of ensuring the availability, reliability, and capability of the emergency core cooling system to respond to initiating events to prevent undesirable consequences. | . The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of protection against external factors and affected the cornerstone objective of ensuring the availability, reliability, and capability of the emergency core cooling system to respond to initiating events to prevent undesirable consequences. | ||
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[P.3(a)] (Section 4OA2 | [P.3(a)] (Section 4OA2 | ||
.1.b(1)) | .1.b (1)) | ||
===B. Licensee-Identified Violations=== | ===B. Licensee-Identified Violations=== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed four safety evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR) 50.59 to determine whether the evaluations were adequate and prior NRC | The inspectors reviewed four safety evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR) 50.59 to determine whether the evaluations were adequate and prior NRC-approval was obtained as appropriate. The minimum sample size of six safety evaluations were not achieved, because the licensee had only performed four safety evaluations during the sample period. The inspectors also reviewed 11 screenings and two applicability determinations where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if: | ||
-approval was obtained as appropriate | |||
. The minimum sample size of six safety evaluations were not achieved, because the licensee had only performed four safety evaluations during the sample period. The inspectors also reviewed 11 screenings and two applicability determinations where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if: | |||
the changes, tests, or experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required; the safety issue requiring the change, tests or experiment was resolved; the licensee conclusions for evaluations of changes, tests, or experiments were correct and consistent with 10 CFR 50.59; and the design and licensing basis documentation was updated to reflect the change. | the changes, tests, or experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required; the safety issue requiring the change, tests or experiment was resolved; the licensee conclusions for evaluations of changes, tests, or experiments were correct and consistent with 10 CFR 50.59; and the design and licensing basis documentation was updated to reflect the change. | ||
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-07, "Guidelines for 10 CFR 50.59 Implementation," Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments," dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, "10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments." | -07, "Guidelines for 10 CFR 50.59 Implementation," Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments," dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, "10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments." | ||
This inspection constituted four samples of evaluations and | This inspection constituted four samples of evaluations and 1 3 samples of screenings and/or applicability determinations as defined in Inspection Procedure (IP) 71111.17-04. | ||
IP) 71111.17-04. | |||
====b. Findings==== | ====b. Findings==== | ||
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=====Introduction:===== | =====Introduction:===== | ||
The inspectors identified a Severity Level IV, Non | The inspectors identified a Severity Level IV, Non-Cited Violation of 10 CFR 50.59, "Changes, Tests, and Experiments," | ||
-Cited Violation of 10 CFR 50.59, "Changes, Tests, and Experiments," | and an associated finding of very low safety significance (Green)for the licensee's failure to perform a written evaluation, 4 Enclosure which provided the bases for the determination whether a change did not require a license amendment. Specifically, the licensee failed to provide a basis for not applying for a license amendment associated with adding a freeze seal to the RCPB at a time where RCPB integrity was required. | ||
and an associated finding of very low safety significance (Green)for the licensee's failure to perform a written evaluation, which provided the bases for the determination whether a change did not require a license amendment. Specifically, the licensee failed to provide a basis for not applying for a license amendment associated with adding a freeze seal to the RCPB at a time where RCPB integrity was required. | |||
=====Description:===== | =====Description:===== | ||
In 2001, the licensee performed Safety Evaluation (SE) 97 | In 2001, the licensee performed Safety Evaluation (SE) 97 | ||
-0079, "Installation of Piping Freeze Seal for SVI G33 | -0079, "Installation of Piping Freeze Seal for SVI G33 | ||
-T9131," to evaluate permanently allowing the use of a freeze seal when performing surveillance instruction SVI | -T9131 ," to evaluate permanently allowing the use of a freeze seal when performing surveillance instruction SVI | ||
-G33-T9131, "Type C Local Leak Rate Test of 1G33 Penetration P131." This surveillance instruction (SVI) fulfilled the Technical Specification (TS) Surveillance Requirement (SR) 3.6.1.1.1 and SR 3.6.1.3.9 for reactor water cleanup system (RWCU) penetration P131. The conclusion of SE 97 | -G33-T9131, "Type C Local Leak Rate Test of 1G33 Penetration P131." This surveillance instruction (SVI) fulfilled the Technical Specification (TS) Surveillance Requirement (SR) 3.6.1.1.1 and SR 3.6.1.3.9 for reactor water cleanup system (RWCU) penetration P131. The conclusion of SE 97 | ||
-0079 was that the use of a freeze seal during this SVI was acceptable because the RCPB would be isolated by the closure of valves 1 | -0079 was that the use of a freeze seal during this SVI was acceptable because the RCPB would be isolated by the closure of valves 1 | ||
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," to evaluate a revision of SVI | ," to evaluate a revision of SVI | ||
-G33-T9131 that allowed valve 1-G33-F0101 to remain open. As a result, the freeze seal location was changed to b e within the RCPB. The licensee concluded this change was acceptable because an operator would be dedicated to manually close the 1 | -G33-T9131 that allowed valve 1-G33-F0101 to remain open. As a result, the freeze seal location was changed to b e within the RCPB. The licensee concluded this change was acceptable because an operator would be dedicated to manually close the 1 | ||
-G33-F0101 valve if the freeze seal | -G33-F0101 valve if the freeze seal result ed in a pi pe rupture and, if the valve could n ot be closed, then the pipe would be crimped. This SVI revision was used on March 24 | ||
-25, 2009, without irradiated fuel in the upper pool or the reactor vessel, and on April 13 | -25, 2009, without irradiated fuel in the upper pool or the reactor vessel, and on April 13 | ||
-14, 2009, with irradiated fuel in the reactor vessel. | -14, 2009, with irradiated fuel in the reactor vessel. | ||
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The installation of freeze seals in piping represent s a risk of exposing piping to temperatures below this transition point. The inspectors also noted this phenomenon was recognized by procedure GMI | The installation of freeze seals in piping represent s a risk of exposing piping to temperatures below this transition point. The inspectors also noted this phenomenon was recognized by procedure GMI | ||
-0024, "Freeze Seals," in that it stated "Frozen pipe is subject to brittle fracture." Thus, the use of a freeze seal within the RCPB was contrary to the USAR descriptions and Evaluation 09 | -0024, "Freeze Seals," in that it stated "Frozen pipe is subject to brittle fracture." Thus, the use of a freeze seal within the RCPB was contrary to the USAR descriptions and Evaluation 09 | ||
-01526 did not address whether using the freeze seal within the RCPB would more than minimally increase the likelihood of a malfunction of the RCPB. In addition, the inspectors noted valve 1-G33-F0101, which was credited to be manually closed in case of RCPB failure, had not been exercised since as early as 2001. The inspectors were also concerned because the 2013 revision of Evaluation 09 | -01526 did not address whether using the freeze seal within the RCPB would more than minimally increase the likelihood of a 5 Enclosure malfunction of the RCPB. In addition, the inspectors noted valve 1-G33-F0101, which was credited to be manually closed in case of RCPB failure, had not been exercised since as early as 2001. The inspectors were also concerned because the 2013 revision of Evaluation 09 | ||
-01526 did not recognize the upper pool and steam dryer pool inventory would be affected if the RCPB at the freeze seal location were to rupture. Thus, performance of the SVI in this manner would be contrary to procedure IOI | -01526 did not recognize the upper pool and steam dryer pool inventory would be affected if the RCPB at the freeze seal location were to rupture. Thus, performance of the SVI in this manner would be contrary to procedure IOI | ||
-009, "Refueling," which state d "Operations with a potential for draining the dryer storage pool shall not be performed when irradiated assemblies are seated in the upper containment pool fuel racks." | -009, "Refueling," which state d "Operations with a potential for draining the dryer storage pool shall not be performed when irradiated assemblies are seated in the upper containment pool fuel racks." | ||
The licensee captured the inspectors | The licensee captured the inspectors | ||
' concerns in the Corrective Actions Program (CAP) as CR-2013-11377, CR | ' concerns in the Corrective Actions Program (CAP) as CR-2013-11377, CR-2013-11217, and CR | ||
-2013-11217, and CR | |||
-2013-10798 with recommended actions to update SVI | -2013-10798 with recommended actions to update SVI | ||
-G33-T9131 and associated 50.59 documents. | -G33-T9131 and associated 50.59 documents. | ||
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In this case, the inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings," dated June 19, 2012. Because the finding was associated with shutdown conditions, the inspectors used IMC 0609, Appendix G, "Shutdown Operations Significance Determination Process." The inspectors reviewed Table 1 of Appendix G, "Losses of Control," and determined that none of the conditions constituting a loss of control were met. | In this case, the inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings," dated June 19, 2012. Because the finding was associated with shutdown conditions, the inspectors used IMC 0609, Appendix G, "Shutdown Operations Significance Determination Process." The inspectors reviewed Table 1 of Appendix G, "Losses of Control," and determined that none of the conditions constituting a loss of control were met. | ||
The Region III Senior Reactor Analyst (SRA) reviewed Appendix G, Attachment 1, "Phase I Operational Checklists for Both PWRs and BWRs." The applicable checklist was Checklist 7, "BWR Refueling Operation with RCS Level > 23'." The SRA determined that the Phase I criterion was met so the risk evaluation progressed to Phase II. The SRAs reviewed Appendix G, Attachment 3, "Phase II Significance Determination Process Template for BWR during Shutdown," and determined the exposure time was less t han three days. Specifically, the dates the freeze seals were installed April 11 | The Region III Senior Reactor Analyst (SRA) reviewed Appendix G, Attachment 1, "Phase I Operational Checklists for Both PWRs and BWRs." The applicable checklist was Checklist 7, "BWR Refueling Operation with RCS Level > 23'." The SRA determined that the Phase I criterion was met so the risk evaluation progressed to Phase II. The SRAs reviewed Appendix G, Attachment 3, "Phase II Significance 6 Enclosure Determination Process Template for BWR during Shutdown," and determined the exposure time was less t han three days. Specifically, the dates the freeze seals were installed April 11 | ||
- 12, 2013, and April 13 | - 12, 2013, and April 13 | ||
- 14, 2009. | - 14, 2009. | ||
The SRA determined that a bounding risk evaluation could be performed addressing both exposure periods by assuming the more risk significant 2009 configuration. Considering the short exposure time and available mitigation features, the result was an estimated change in core damage frequency () of 6.2E-07/ | The SRA determined that a bounding risk evaluation could be performed addressing both exposure periods by assuming the more risk significant 2009 configuration. Considering the short exposure time and available mitigation features, the result was an estimated change in core damage frequency () of 6.2E-07/y ear. Thus, the finding was of very low safety significance (Green). | ||
In accordance with Section 6.1.d of the NRC Enforcement Policy this violation is categorized as Severity Level IV because the resulting changes were evaluated by the SDP as having very low safety significance (i.e., green finding). | In accordance with Section 6.1.d of the NRC Enforcement Policy this violation is categorized as Severity Level IV because the resulting changes were evaluated by the SDP as having very low safety significance (i.e., green finding). | ||
The inspectors did not identify a cross-cutting aspect associated with this finding because the finding was not confirmed to reflect current performance due to the age of the performance deficiency. Specifically, the licensee should have | The inspectors did not identify a cross-cutting aspect associated with this finding because the finding was not confirmed to reflect current performance due to the age of the performance deficiency. Specifically, the licensee should have evaluate d the addition of the freeze seal to the RCP B in 2009 when they revised SVI | ||
-G33-T9131. | -G33-T9131. | ||
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-compliance did not present an immediate safety concern because the SVI procedure was placed on hold until the concerns are resolved. | -compliance did not present an immediate safety concern because the SVI procedure was placed on hold until the concerns are resolved. | ||
This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was Severity Level IV and was entered into the licensee's corrective action program as CR-2013-10798, CR | This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was Severity Level IV and was entered into the licensee's corrective action program as CR-2013-10798, CR-2013-11217, and CR-2013-11377 (NCV 05000440/20132008 | ||
-2013-11217, and CR-2013-11377 (NCV 05000440/20132008 | |||
-01, 10 CFR 50.59 Evaluation Did Not Consider the Freeze Seal Effect to the RCPB). The associated finding was evaluated separately from the traditional enforcement violation; therefore, the underlying finding was assigned a separate tracking number (FIN 05000440/20132008 | -01, 10 CFR 50.59 Evaluation Did Not Consider the Freeze Seal Effect to the RCPB). The associated finding was evaluated separately from the traditional enforcement violation; therefore, the underlying finding was assigned a separate tracking number (FIN 05000440/20132008 | ||
-02, 10 CFR 50.59 Evaluation Did Not Consider the Freeze Seal Effect to the RCPB). | -02, 10 CFR 50.59 Evaluation Did Not Consider the Freeze Seal Effect to the RCPB). | ||
(2) Lack of Alternate Methods of Decay Heat Removal Introduction | 7 Enclosure (2) Lack of Alternate Methods of Decay Heat Removal Introduction | ||
: The inspectors identified an unresolved item (URI) regarding the unavailability of alternate methods of decay heat removal that could be credited to combat a loss of shutdown cooling resulting from emergency service water (ESW) inoperability and while in MODE 4 with high decay heat load. | : The inspectors identified an unresolved item (URI) regarding the unavailability of alternate methods of decay heat removal that could be credited to combat a loss of shutdown cooling resulting from emergency service water (ESW) inoperability and while in MODE 4 with high decay heat load. | ||
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10 CFR 50.59 evaluation (i.e., Evaluation 05 | 10 CFR 50.59 evaluation (i.e., Evaluation 05 | ||
-04712, "Installation of ADHR System") which stated "The intent of the ADHR system is to assure TS compliance in MODE 4 by providing an additional alternate decay heat removal option that does not rely upon RHR or ESW." However, the inspectors noted its design was limited to a heat removal rate which bounds the approximate decay heat production rate of the core 24 hours after a scram from sustained 100 percent power. During normal shutdown conditions, the licensee transitions from 100 percent power to MODE 4 in a few hours. For instance, this transition occurred in about five hours during refueling outage 1R13. In addition, the licensee revised procedure ONI | -04712, "Installation of ADHR System") which stated "The intent of the ADHR system is to assure TS compliance in MODE 4 by providing an additional alternate decay heat removal option that does not rely upon RHR or ESW." However, the inspectors noted its design was limited to a heat removal rate which bounds the approximate decay heat production rate of the core 24 hours after a scram from sustained 100 percent power. During normal shutdown conditions, the licensee transitions from 100 percent power to MODE 4 in a few hours. For instance, this transition occurred in about five hours during refueling outage 1R13. In addition, the licensee revised procedure ONI | ||
-E12-2, "Loss of Decay Heat Removal," by adding Attachment 11, "Cold Shutdown Decay Heat Removal by Steaming." This attachment contained instructions to establish an alternate method of decay heat removal independent of ESW. However, the attachment included a note stating, "It will be necessary to validate the effectiveness of this attachment to maintain or reduce RPV temperature (by Engineering calculation or demonstration)if qualifying this as an alternate decay heat removal method per TS 3.4.9 and 3.4.10." As a result, the inspectors questioned the effectiveness of this approach given it had not been verified. The licensee consequently | -E12-2, "Loss of Decay Heat Removal," by adding Attachment 11, "Cold Shutdown Decay Heat Removal by Steaming." This attachment contained instructions to establish an alternate method of decay heat removal independent of ESW. However, the attachment included a note stating, "It will be necessary to validate 8 Enclosure the effectiveness of this attachment to maintain or reduce RPV temperature (by Engineering calculation or demonstration)if qualifying this as an alternate decay heat removal method per TS 3.4.9 and 3.4.10." As a result, the inspectors questioned the effectiveness of this approach given it had not been verified. The licensee consequently , performed a calculation that determined Attachment 11 was limited to a heat removal rate which bounds the approximate decay heat production rate of the core three days after a shutdown from sustained 100 percent power. The procedure contained other alternatives but these either relied on ESW or lacked enough capacity to serve as backup methods during periods of high decay heat loads. | ||
, performed a calculation that determined Attachment 11 was limited to a heat removal rate which bounds the approximate decay heat production rate of the core three days after a shutdown from sustained 100 percent power. The procedure contained other alternatives but these either relied on ESW or lacked enough capacity to serve as backup methods during periods of high decay heat loads. | |||
Based on this information, the inspectors were concerned the plant lacked two alternate methods of decay heat removal that have been verified to be effective should a loss of shutdown cooling result from ESW inoperability while in MODE 4 with high decay heat load. The inspectors were particularly concerned because this condition had occurred in the past at least twice. The licensee captured the inspectors | Based on this information, the inspectors were concerned the plant lacked two alternate methods of decay heat removal that have been verified to be effective should a loss of shutdown cooling result from ESW inoperability while in MODE 4 with high decay heat load. The inspectors were particularly concerned because this condition had occurred in the past at least twice. The licensee captured the inspectors | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed five permanent plant modifications that had been installed in the plant or modified during the last three years. This review included in | The inspectors reviewed five permanent plant modifications that had been installed in the plant or modified during the last three years. This review included in | ||
-plant walkdowns for portions of the alternate decay heat removal system installed in the low pressure core spray room; station battery and battery charger rooms; and division 1 emergency diesel generator | -plant walkdowns for portions of the alternate decay heat removal system installed in the low pressure core spray room; station battery and battery charger rooms; and division 1 emergency diesel generator. The modifications were selected based upon risk significance, safety significance, and complexity. The inspectors reviewed the selecte d modifications to determine if: | ||
. The modifications were selected based upon risk significance, safety significance, and complexity. The inspectors reviewed the | |||
the supporting design and licensing basis documentation was updated; the changes were in accordance with the specified design requirements; the procedures and training plans affected by the modification have been adequately updated; the test documentation as required by the applicable test programs has been updated; and post-modification testing adequately verified system operability and/or functionality. | the supporting design and licensing basis documentation was updated; the changes were in accordance with the specified design requirements; the procedures and training plans affected by the modification have been adequately updated; the test documentation as required by the applicable test programs has been updated; and post-modification testing adequately verified system operability and/or functionality. | ||
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This inspection constituted five permanent plant modification samples as defined in IP 71111.17-04. | This inspection constituted five permanent plant modification samples as defined in IP 71111.17-04. | ||
9 Enclosure | |||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
T he inspectors reviewed several corrective action process documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent p lant modifications and evaluations of changes, tests, or experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the to this report. | |||
====b. Findings==== | ====b. Findings==== | ||
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Rooms Introduction | Rooms Introduction | ||
: The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," | : The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," | ||
for the licensee's failure to control drainage of the ECCS room sumps in a manner that | for the licensee's failure to control drainage of the ECCS room sumps in a manner that prevent s common mode flooding of the ECCS rooms | ||
. Specifically, the licensee's procedures did not ensure appropriate controls to prevent backflow from the floor drain system, which was contrary to the licensee's design basis | . Specifically, the licensee's procedures did not ensure appropriate controls to prevent backflow from the floor drain system , which was contrary to the licensee's design basis | ||
. Description | . Description | ||
: On May 19, 2011, the licensee performed a test of the RHR 'B/C' water l eg pump while in MODE 5 following its replacement. During this test, the operators received an unexpected Auxiliary Building floor drain sump water level high alarm. | : On May 19, 2011, the licensee performed a test of the RHR 'B/C' water l eg pump while in MODE 5 following its replacement. During this test, the operators received an unexpected Auxiliary Building floor drain sump water level high alarm. | ||
Approximately four minutes later, the operators received sump high level alarms associated with the RHR 'A,' 'B | Approximately four minutes later, the operators received sump high level alarms associated with the RHR 'A,' 'B | ||
,' and 'C,' and reactor core isolation cooling (RCIC) pump rooms. The test was stopped and all drain paths to the Auxiliary Building sumps were closed. This incident resulted in water accumulation in each one of these rooms and | ,' and 'C,' and reactor core isolation cooling (RCIC) pump rooms. The test was stopped and all drain paths to the Auxiliary Building sumps were closed. This incident resulted in water accumulation in each one of these rooms and a n entry into Emergency Operating Procedure | ||
- 3, "Secondary Containment Control and Radioactive Release Control," for about an hour. This condition was captured in the CAP as CR 2011 | - 3, "Secondary Containment Control and Radioactive Release Control," for about an hour. This condition was captured in the CAP as CR 2011 | ||
-95107. In preparation for this inspection, the licensee performed Self | -95107. In preparation for this inspection, the licensee performed Self | ||
Line 281: | Line 268: | ||
-10119 on July 1, 2013, to document the missed opportunity to evaluate the potential flooding impact from this incident. Specifically, the licensee identified that CR 2011-95107 did not specify the water depth in the affected rooms and did not address the potential flooding impact to plant systems. | -10119 on July 1, 2013, to document the missed opportunity to evaluate the potential flooding impact from this incident. Specifically, the licensee identified that CR 2011-95107 did not specify the water depth in the affected rooms and did not address the potential flooding impact to plant systems. | ||
The licensee subsequently concluded that the maximum amount of water was within the design flood level. While reviewing a sample of corrective action process documents that identified or were related to plant modifications, the inspectors noted CR 2011 | The licensee 10 Enclosure subsequently concluded that the maximum amount of water was within the design flood level. While reviewing a sample of corrective action process documents that identified or were related to plant modifications, the inspectors noted CR 2011 | ||
-95107 and CR 2013 | -95107 and CR 2013 | ||
-10119 did not address the cause of the common mode flooding of the ECCS rooms via the floor drain system. The inspectors were concerned because common mode flooding of these rooms was contrary to the design basis of the plant. Specifically, USAR 9.3.3.2.1, "Floor Drains," state d "-common mode flooding of the ECCS equipment rooms (i.e., flooding in one room which results in flooding of redundant ECCS equipment in adjacent rooms)is precluded by the design of the drainage piping. | -10119 did not address the cause of the common mode flooding of the ECCS rooms via the floor drain system. The inspectors were concerned because common mode flooding of these rooms was contrary to the design basis of the plant. Specifically, USAR 9.3.3.2.1, "Floor Drains," state d "-common mode flooding of the ECCS equipment rooms (i.e., flooding in one room which results in flooding of redundant ECCS equipment in adjacent rooms)is precluded by the design of the drainage piping. | ||
Line 310: | Line 297: | ||
In accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings," Table 2 the inspectors determined the finding affected the Mitigating Systems cornerstone. As a result, the inspectors determined the finding could be evaluated using Appendix A, "The Significance Determination Process (SDP) for Findings At | In accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings," Table 2 the inspectors determined the finding affected the Mitigating Systems cornerstone. As a result, the inspectors determined the finding could be evaluated using Appendix A, "The Significance Determination Process (SDP) for Findings At | ||
-Power," Exhibit 2, "Mitigating Systems Screening Questions. | -Power," Exhibit 2, "Mitigating Systems 11 Enclosure Screening Questions. | ||
" The inspectors determined that the finding was of very low safety significance (Green) because it did not result in the loss of operability | " The inspectors determined that the finding was of very low safety significance (Green) because it did not result in the loss of operability n o r an actual loss or degradation of a function designed to mitigate flooding. Specifically, a review of recent plant history did not find an instance where the configuration of the floor drain system allowed common mode flooding of the ECCS rooms when operability of these systems was required. | ||
The inspectors determined that this finding had a cross | The inspectors determined that this finding had a cross | ||
Line 321: | Line 308: | ||
: Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Section 9.3.3.2.1 of the USAR states that common mode flooding of the ECCS rooms is precluded by the design of the drainage piping. Section 9.3.3.3 of the USAR state s flooding of the ECCS rooms by backflow through the floor drains was prevented by the installation of a normally closed shutoff valve in the floor drain line from each room. | : Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Section 9.3.3.2.1 of the USAR states that common mode flooding of the ECCS rooms is precluded by the design of the drainage piping. Section 9.3.3.3 of the USAR state s flooding of the ECCS rooms by backflow through the floor drains was prevented by the installation of a normally closed shutoff valve in the floor drain line from each room. | ||
Contrary to the above | Contrary to the above , from May 19, 2011 | ||
, from May 19, 2011 | , to July 16 , 2013, the licensee failed to translate the applicable design basis into procedures. Specifically, the licensee did not translate the common mode flooding prevention controls described in the USAR into procedure SOI | ||
, to July 16, 2013, the licensee failed to translate the applicable design basis into procedures. Specifically, the licensee did not translate the common mode flooding prevention controls described in the USAR into procedure SOI | |||
-G61. As an immediate corrective action, the licensee revised SOI | -G61. As an immediate corrective action, the licensee revised SOI | ||
-G61 to prevent opening more than one ECCS room sump valve at the same time. | -G61 to prevent opening more than one ECCS room sump valve at the same time. | ||
Becaus e this violation was of very low safety significance and was entered into the licensee's CAP as CR 2013-10825, this violation is being treated as a Non | |||
-Cited Violation, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000440/2013008 | -Cited Violation, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000440/2013008 | ||
- | -0 4 , Insufficient Controls to Prevent Common Mode Flooding of ECCS Rooms | ||
). | ). | ||
{{a|4OA6}} | {{a|4OA6}} | ||
Line 336: | Line 322: | ||
===.2 Interim Meeting Summary=== | ===.2 Interim Meeting Summary=== | ||
O n July 26 and August 28, 2013 , the inspector s presented the preliminary inspection results to Mr. D. Hamilton and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. | |||
, the inspector s presented the preliminary inspection results to Mr. D. Hamilton and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. | |||
The inspectors had outstanding questions that required additional review and a follow | The inspectors had outstanding questions that required additional review and a follow | ||
Line 344: | Line 329: | ||
===.1 Exit Meeting=== | ===.1 Exit Meeting=== | ||
Summary On September 17, 2013, the inspector s presented the inspection results to Mr. B. Huck and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content | Summary On September 17, 2013, the inspector s presented the inspection results to Mr. B. Huck and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that none of the potential report input discussed was considered proprietary. | ||
. The inspectors confirmed that none of the potential report input discussed was considered proprietary. | |||
ATTACHMENT: | ATTACHMENT: | ||
Line 355: | Line 339: | ||
T Licensee | T Licensee | ||
: [[contact::V. Kaminskas]], Site Vice | : [[contact::V. Kaminskas]], Site Vice | ||
President | President | ||
: [[contact::D. Hamilton]], Plant General Manager | : [[contact::D. Hamilton ]], Plant General Manager | ||
: [[contact::H. Hanson]], Performance Improvement Director | : [[contact::H. Hanson]], Performance Improvement Director | ||
: [[contact::T. Veitch]], Regulatory Compliance Manager | : [[contact::T. Veitch]], Regulatory Compliance Manager | ||
Line 363: | Line 347: | ||
: [[contact::B. Coad]], Engineering Analysis Supervisor | : [[contact::B. Coad]], Engineering Analysis Supervisor | ||
Nuclear Regulatory Commission | Nuclear Regulatory Commission | ||
: [[contact::R. Daley]], Chief, | : [[contact::R. Daley]], Chief, Engineering Branch 3, D | ||
Engineering Branch 3, D | |||
RS | RS | ||
: [[contact::M. Marshfield]], Senior Resident Inspector | : [[contact::M. Marshfield]], Senior Resident Inspector | ||
Line 393: | Line 376: | ||
-068, Change to the Structural Design Criteria for | -068, Change to the Structural Design Criteria for | ||
the Fuel Handling Building Crane and the Polar Crane | the Fuel Handling Building Crane and the Polar Crane | ||
10/5/2011 | 10/5/2011 05-04712 Installation of Alternate Decay Heat Removal System | ||
05-04712 Installation of Alternate Decay Heat Removal System | |||
2/20/2012 | 2/20/2012 | ||
09-01526 Type C Local Leak Rate Test of 1G33 Penetration P131 | 09-01526 Type C Local Leak Rate Test of 1G33 Penetration P131 | ||
2/24/2013 | 2/24/2013 09-01526 Type C Local Leak Rate Test of 1G33 Penetration P131 | ||
09-01526 Type C Local Leak Rate Test of 1G33 Penetration P131 | 4/15/2009 10-00208 HPI-K0008 Dry Active Waste | ||
4/15/2009 | and USAR Change 11-215 1/24/2012 10 CFR 50.59 SCREENINGS | ||
10-00208 HPI-K0008 Dry Active Waste | |||
and USAR Change 11 | |||
-215 1/24/2012 | |||
CFR 50.59 SCREENINGS | |||
Number Description or Tit | Number Description or Tit | ||
le Date or Revision | le Date or Revision | ||
08-04933 Equivalent Change for Div.1 and 2 Diesel Generator Crankcase High Pressure Trip Pressure Switches, 1R43N0711A/B | 08-04933 Equivalent Change for Div.1 and 2 Diesel Generator Crankcase High Pressure Trip Pressure Switches, 1R43N0711A/B | ||
2/16/2011 | 2/16/2011 10-04045 Upgrade the Existing 480V Motor Control Center (MCC) Automatic Transfer SW, and Relay in MCC F1C08 5/23/2011 10-04146 Delete the Mild Environment Equipment Qualification (EQ) Program | ||
10-04045 Upgrade the Existing 480V Motor Control Center (MCC) Automatic Transfer SW, and Relay in MCC F1C08 5/23/2011 | |||
10-04146 Delete the Mild Environment Equipment Qualification (EQ) Program | |||
11/16/2010 | 11/16/2010 | ||
10-05813 Transformer Sudden Pressure Alarm Relay 10/23/2012 | 10-05813 Transformer Sudden Pressure Alarm Relay 10/23/2012 | ||
10-03576 Freeze Seal Installation | 10-03576 Freeze Seal Installation | ||
4/19/2011 | 4/19/2011 11-01173 Loss of Decay Heat Removal | ||
11-01173 Loss of Decay Heat Removal | 3/14/2011 11-03570 TS Bases Change Notice 11 | ||
3/14/2011 | |||
11-03570 TS Bases Change Notice 11 | |||
-167 11/22/2011 | -167 11/22/2011 | ||
11-03807 SLC A/B Pump and Valve Operability Test | 11-03807 SLC A/B Pump and Valve Operability Test | ||
9/14/2011 | 9/14/2011 | ||
Attachment | Attachment | ||
CFR 50.59 SCREENINGS | CFR 50.59 SCREENINGS | ||
Line 426: | Line 399: | ||
le Date or Revision | le Date or Revision | ||
2-02810 Low Power Hydrogen Injection | 2-02810 Low Power Hydrogen Injection | ||
2/6/2012 | 2/6/2012 09-05025 RPV Control | ||
09-05025 RPV Control | |||
06/01/2012 | 06/01/2012 | ||
11-04961 Service Test Capacity | 11-04961 Service Test Capacity | ||
- Division 1 | - Division 1 | ||
01/05/2012 | 01/05/2012 | ||
11- | 11-00 340 Temporary Modification to remove time delay relay (PY | ||
-1E51Q7220) from service | -1E51Q7220) from service | ||
03/24/2011 | 03/24/2011 | ||
10-00208 HPI-K8/K9, RPI-1301,USAR update, Calc 3.2.19.1 | 10-00208 HPI-K8/K9, RPI-1301,USAR update, Calc 3.2.19.1 and.2 06/27/2013 | ||
and.2 06/27/2013 | |||
CALCULATIONS | CALCULATIONS | ||
Number Description or Title | Number Description or Title | ||
Line 451: | Line 422: | ||
- Documentation for OE Evaluation of IN | - Documentation for OE Evaluation of IN | ||
-2002-15 Could Not Be Located 7/3/2013 CR- 2013-10604 NRC ID 2013 50.59: RWCU FM Vessel DRN Suction Valve G33F0101 Erratic Readings | -2002-15 Could Not Be Located 7/3/2013 CR- 2013-10604 NRC ID 2013 50.59: RWCU FM Vessel DRN Suction Valve G33F0101 Erratic Readings | ||
7/11/2013 | 7/11/2013 CR- 2013-10798 NRC ID 50.59, LTA Controls and Evaluation for SVI-G33-T9131 for Irradiated Fuel in Upper Pool Storage Rack | ||
CR- 2013-10798 NRC ID 50.59, LTA Controls and Evaluation for SVI-G33-T9131 for Irradiated Fuel in Upper Pool Storage Rack | 7/15/2013 CR- 2013-10825 NRC ID 50.59, LTA SOI | ||
7/15/2013 | |||
CR- 2013-10825 NRC ID 50.59, LTA SOI | |||
-G61 Controls | -G61 Controls | ||
t o Prevent Cross Flooding | |||
of ECCS Rooms | of ECCS Rooms | ||
7/16/2013 | 7/16/2013 CR- 2013-10851 NRC ID 201 | ||
CR- 2013-10851 NRC ID 201 | |||
3-50.59, RAD Exemptions | 3-50.59, RAD Exemptions | ||
for R42 | for R42 SVI s Have Inadequate Justification | ||
7/16/2013 | 7/16/2013 CR- 2013-10862 NRC ID 2013 50.59, Observation RAD/Screen 7/16/2013 | ||
CR- 2013-10862 NRC ID 2013 50.59, Observation RAD/Screen 7/16/2013 | |||
Attachment | Attachment | ||
CORRECTIVE ACTION PROGRAM DOCUMENTS INITIATED DURING | CORRECTIVE ACTION PROGRAM DOCUMENTS INITIATED DURING | ||
Line 474: | Line 440: | ||
-04712, R/2 For ADHR Does Not Address Radiological Monitoring | -04712, R/2 For ADHR Does Not Address Radiological Monitoring | ||
of SW in Question 4.6 | of SW in Question 4.6 | ||
7/19/2013 | 7/19/2013 CR- 2013-11126 NRC ID 50.59 2013 | ||
CR- 2013-11126 NRC ID 50.59 2013 | |||
- Generic NRC Concern With ISS 2702, Freeze Seal | - Generic NRC Concern With ISS 2702, Freeze Seal | ||
7/19/2013 | 7/19/2013 CR- 2013-11217 NRC ID 50.59 2013 Deficiencies With 50.59 Evaluation 09 | ||
CR- 2013-11217 NRC ID 50.59 2013 Deficiencies With 50.59 Evaluation 09 | -01526 7/22/2013 CR- 2013-11377 NRC ID 2013 50.59: LTA 50.59 Evaluation 09 | ||
-01526 7/22/2013 | -01526 7/24/2013 CR- 2013-11430 NRC I D 50.59 2013 | ||
CR- 2013-11377 NRC ID 2013 50.59: LTA 50.59 Evaluation 09 | |||
-01526 7/24/2013 | |||
CR- 2013-11430 NRC | |||
- Prdc-0014 Revision 4 Errors Identified | - Prdc-0014 Revision 4 Errors Identified | ||
7/25/2013 | 7/25/2013 CR- 2013-11480 NRC ID 2013 50.59: Ability | ||
CR- 2013-11480 NRC ID 2013 50.59: Ability | |||
to Comply With | to Comply With | ||
TS 3.4.10 7/25/2013 | TS 3.4.10 7/25/2013 CR- 2013-11523 NRC ID 2013 50.59: 50.59 Screens May Not Provide Adequate Information | ||
CR- 2013-11523 NRC ID 2013 50.59: 50.59 Screens May Not Provide Adequate Information | |||
for Reaching Conclusions | for Reaching Conclusions | ||
7/26/2013 | 7/26/2013 CR- 2013-11524 NRC ID 2013 5059, Potential Lack | ||
CR- 2013-11524 NRC ID 2013 5059, Potential Lack | o f Systematic Approach | ||
to Address Changes | to Address Changes | ||
7/26/2013 | 7/26/2013 CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED | ||
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED | |||
Number Description or Title | Number Description or Title | ||
Date or Revision CR-2013-08813 FO-SA-2012-0031:50.59 Screen Justification is Inadequate | Date or Revision CR-2013-08813 FO-SA-2012-0031:50.59 Screen Justification is Inadequate | ||
6/6/2013 CR-2013-05391 Unsuccessful | 6/6/2013 CR-2013-05391 Unsuccessful , to Date, in Attempts | ||
, to Date, in Attempts | t o Procure A Crimping Tool | ||
4/8/2013 CR-2011-92480 PWIS Does Not Support All SVI C41 T2001 Activities | 4/8/2013 CR-2011-92480 PWIS Does Not Support All SVI C41 T2001 Activities | ||
4/7/2011 CR- | 4/7/2011 CR-2 011-95107 Auxiliary Building Flooded During | ||
RHR Water Leg Pump Test | RHR Water Leg Pump Test | ||
5/19/2011 | 5/19/2011 CR-2009-66216 Unable to Meet Tech Spec Action Statement Due to ESW B Inoperability | ||
CR-2009-66216 Unable to Meet Tech Spec Action Statement Due to ESW B Inoperability | |||
10/19/2009 | 10/19/2009 | ||
CR-2009-60977 NRC ID (FP Triennial): Non | CR-2009-60977 NRC ID (FP Triennial): Non | ||
-Conformance with Hot Shutdown Repair Requirements 6/24/2009 | -Conformance with Hot Shutdown Repair Requirements 6/24/2009 CR-2013-10217 FO-SA-2012-0031: LTA Organization Effectiveness for G33F0101 | ||
CR-2013-10217 FO-SA-2012-0031: LTA Organization Effectiveness for G33F0101 | 7/03/2013 CR-2010-77987 SN-SA-10-154: Evaluation 09 | ||
7/03/2013 | |||
CR-2010-77987 SN-SA-10-154: Evaluation 09 | |||
-01526 Clarifications | -01526 Clarifications | ||
6/09/2010 | 6/09/2010 CR-2013-01658 Rescreen Evaluation 10 | ||
CR-2013-01658 Rescreen Evaluation 10 | |||
-00208 6/27/2013 | -00208 6/27/2013 | ||
Attachment | Attachment | ||
DRAWINGS Number Description or Title | DRAWINGS Number Description or Title | ||
Line 522: | Line 474: | ||
206-013 Electrical One Line Diagram Generator | 206-013 Electrical One Line Diagram Generator | ||
V 302-0671-00000 Reactor Water Clean | V 302-0671-00000 Reactor Water Clean | ||
-up System | -up System AA 208-0158-00003 Generator Main Transformer (1 | ||
AA 208-0158-00003 Generator Main Transformer (1 | |||
-PY-T) Trip Logic and Backup Relaying | -PY-T) Trip Logic and Backup Relaying | ||
T 208-0158-00004 Generator Unit Auxiliary Transformer (110 | T 208-0158-00004 Generator Unit Auxiliary Transformer (110 | ||
Line 544: | Line 495: | ||
2-0056-002 Rewire Control Room Ammeter (1P45 | 2-0056-002 Rewire Control Room Ammeter (1P45 | ||
-R010) To Prevent a Hot Short in the Ammeter Circuit from Tripping Switchgear | -R010) To Prevent a Hot Short in the Ammeter Circuit from Tripping Switchgear | ||
3/13/2012 | 3/13/2012 09-0081-001 Addition of 1Extra 2GN | ||
09-0081-001 Addition of 1Extra 2GN | |||
-15 Battery Cell to Make Division 1 Battery (1R42S0002) a 61 9/26/2011 | -15 Battery Cell to Make Division 1 Battery (1R42S0002) a 61 9/26/2011 | ||
Attachment | Attachment | ||
MODIFICATIONS | MODIFICATIONS | ||
Number Description or Title | Number Description or Title | ||
Date or Revision | Date or Revision | ||
Cell Unit | Cell Unit 1E51N0654 Slave Trip Unit: RCIC Suction Pressure | ||
1E51N0654 | -Low 1/24/2012 08-0470-001 Implement Changes for DIV 1 Diesel Engine Panel Nuisance Alarms | ||
Slave Trip Unit: RCIC Suction Pressure | |||
-Low 1/24/2012 | |||
08-0470-001 Implement Changes for DIV 1 Diesel Engine Panel Nuisance Alarms | |||
9/2/2011 09-0579-001 Install A Bypass Switch in the Division 1 Diesel Generator Control Panel | 9/2/2011 09-0579-001 Install A Bypass Switch in the Division 1 Diesel Generator Control Panel | ||
4/1/2010 PROCEDURES | 4/1/2010 PROCEDURES | ||
Line 573: | Line 519: | ||
- Division 2 (Unit 1) 10 PAP-1925 Shutdown Defense in Depth Assessment and | - Division 2 (Unit 1) 10 PAP-1925 Shutdown Defense in Depth Assessment and | ||
Management | Management | ||
IOI-9 Refueling | IOI-9 Refueling 31 ARI-H51-P054A Division 1 Diesel Engine Control Panel | ||
ARI-H51-P054A Division 1 Diesel Engine Control Panel | |||
Attachment | Attachment | ||
OTHER DOCUMENTS | OTHER DOCUMENTS | ||
Number Description or Title | Number Description or Title | ||
Date or Revision | Date or Revision | ||
200406791 | 200406791 (24M) Service Test of Battery Capacity | ||
- Division 1 (Unit1) | - Division 1 (Unit1) | ||
6/13/12 | 6/13/12 2 00406858 Performance Test of Battery Capacity | ||
-Division 1 (Unit1) | -Division 1 (Unit1) | ||
4/24/12 Order 200389587 | 4/24/12 Order 200389587 | ||
Freeze Seal for | Freeze Seal for SVI-G33T9132 5/9/2011 PERP0427 Replacement of Obsolete Gould Pumps 0 Order 200472262 | ||
SVI-G33T9132 5/9/2011 PERP0427 Replacement of Obsolete Gould Pumps 0 Order 200472262 | |||
Freeze Seal Order | Freeze Seal Order | ||
4/20/2013 | 4/20/2013 Order 200441630 | ||
Order 200441630 | |||
Install Temp Mod | Install Temp Mod | ||
11-0016-00 3/30/2011 | 11-0016-00 3/30/2011 CN 11-25 HPI-K0009, 50.59 Evaluation No. 10-00208 1/26/2012 CN 13-033 CR 2012-14936, ECP 09 | ||
CN 11-25 HPI-K0009, 50.59 Evaluation No. 10-00208 1/26/2012 | |||
CN 13-033 CR 2012-14936, ECP 09 | |||
-0579 2/27/2013 | -0579 2/27/2013 | ||
Attachment | Attachment | ||
LIST OF ACRONYMS USE | LIST OF ACRONYMS USE | ||
Line 633: | Line 572: | ||
USAR Updated Safety Analysis Report | USAR Updated Safety Analysis Report | ||
E. Harkness | E. Harkness | ||
-2- 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 Agencywide Documents Access and Management System (ADAMS) | -2- 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 Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading | ||
. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading | |||
-rm/adams.html | -rm/adams.html | ||
(the Public Electronic Reading Room). | (the Public Electronic Reading Room). | ||
Sincerely, | Sincerely, /RA/ Robert | ||
: [[contact::C. Daley]], Chie f Engineering Branch 3 | |||
: [[contact::C. Daley]], | |||
Division of Reactor Safety Docket Nos. | Division of Reactor Safety Docket Nos. | ||
50-440 License Nos. NPF-58 Enclosure: | 50-440 License Nos. NPF-58 Enclosure: | ||
Line 664: | Line 601: | ||
\PER 2013 008 MOD 50.59 DXS.docx | \PER 2013 008 MOD 50.59 DXS.docx | ||
-Publicly Available | -Publicly Available | ||
-Sensitive | -Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy | ||
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy | OFFICE RIII RIII NAME N FAdorno:ls RDaley DATE 9/19/13 10/03/13 OFFICIAL RECORD COPY | ||
OFFICE RIII RIII NAME | |||
RDaley DATE 9/19/13 10/03/13 OFFICIAL RECORD COPY | |||
}} | }} |
Revision as of 23:29, 13 July 2018
ML13276A131 | |
Person / Time | |
---|---|
Site: | Perry ![]() |
Issue date: | 10/03/2013 |
From: | Daley R C Engineering Branch 3 |
To: | Harkness E FirstEnergy Nuclear Operating Co |
Nestor Feliz Adorno | |
References | |
IR-13-008 | |
Download: ML13276A131 (23) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532
-4352 October 3, 2013 Mr. Ernest Harkness Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P. O. Box 97, 10 Center Road, A-PY-A 290 Perry, OH 44081
-0097
SUBJECT: PERRY NUCLEAR POWER PLANT - EVALUATION S OF CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000440/2013008
Dear Mr. Harkness:
On September 17, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications Inspection at your Perry Nuclear Power Plant. The enclosed inspection report (IR) documents the inspection results
, which were discussed on August 28 and September 17, 2013, with you 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.
The NRC-identified t wo findings of very low safety significance involving violations of NRC requirements. One of the findings was associated with a traditional enforcement Severity Level IV violation.
However, because of the very low safety significance and because the issues were entered into your Corrective Action Program, the NRC is treating the issue s as Non-Cited Violation s (NCV s) in accordance with Section 2.3.2 of the NRC Enforcement Policy.
If you contes t the violations or significance of these NCVs
, 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 a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission
- 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 Resident Inspector office at Perry Nuclear Power Plant
. In addition, if you disagree with the cross
-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at Perry Nuclear Power Plant
. 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 Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading
-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/ Robert C. Daley, Chie f Engineering Branch 3 Division of Reactor Safety Docket Nos.
50-440 License Nos. NPF-58
Enclosure:
Inspection Report 05000440/2013008
w/Attachment:
Supplemental Information cc w/encl:
Distribution via ListServŽ
Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-440 License No
- NPF-58 Report No:
05000440/2013008 Licensee: FirstEnergy Nuclear Operating Company (FENOC)
Facility: Perry Nuclear Power Plant, Unit 1 Location: Perry, Ohio Dates: July 8 through September 17, 2013 Inspectors:
N. Féliz Adorno, Reactor Inspector (Lead)
J. Gilliam, Reactor Inspector I. Hafeez, Reactor Inspector Approved by:
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety 1 Enclosure
SUMMARY
IR 05000440/2013008; 0 7/08/20 1 3 - 0 9/17/201 3; Perry Nuclear Power Plant
- Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications.
This report covers a two-week announced baseline inspection on evaluations of changes, tests, or experiments and permanent plant m odifications. The inspection was conducted by three Region III based engineering inspectors
. T wo findings of very low safety significance were identified by the inspectors. The findings were considered Non-Cited Violations (NCVs) of NRC requirements. One of the findings was associated with a traditional enforcement Severity Level IV violation. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP).
Cross-cutting aspects were determined using IMC 0310, "Components Within the 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.
A. N RC-Identified and Self-Revealed Findings
Cornerstone: Initiating Events
- The inspectors identified a finding of very low safety significance and associated Severity Level IV Non-Cited Violation of Title 10 Code of Federal Regulations (CFR) 50.59, "Changes, Test, and Experiments," for the failure to perform a written evaluation, which provided the bases for the determination that a change did not require a license amendment.
Specifically, the licensee failed to provide a basis for not applying for a license amendment associated with the use of a freeze seal in the reactor coolant pressure boundary when its integrity was required to protect irradiated fuel
. The finding was entered into the licensee's Corrective Action Program with recommended actions to , in part, revise the associated 10 CFR 50.59 documents.
The inspectors determined that the violation was more than minor because they could not reasonably determine the changes would not have ultimately required NRC prior approval. The finding affected the Initiating Events cornerstone attribute of equipment performance and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown
, as well as power operations.
The inspectors determined that the underlying technical issue was of very low safety significance (Green) using a Phase II evaluation
. The inspectors did not identify a cross-cutting aspect associated with this finding because it was not confirmed to reflect current performance due to the age of the performance deficiency. (Section 1R17.1.b(1))
Cornerstone: Mitigating Systems
Green: The inspectors identified a finding of very low safety significance and associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the failure to control drainage of the emergency core cooling system room sumps in a manner that prevents common mode flooding of these rooms. Specifically, procedures did not ensure appropriate controls to prevent backflow from the floor drain system.
The licensee entered the issue into the ir Corrective Action Program and revised procedures to prevent opening more than one emergency core cooling system room sump isolation valve at the same time
. The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of protection against external factors and affected the cornerstone objective of ensuring the availability, reliability, and capability of the emergency core cooling system to respond to initiating events to prevent undesirable consequences.
The finding was determined to be of very low safety significance (Green) because it did not result in either the loss of operability or an actual loss or degradation of a function designed to mitigate flooding. Specifically, a review of recent plant history did not find an instance where the configuration of the floor drain system allowed common mode flooding of the emergency core cooling system rooms when operability of this system was required.
The inspectors determined that this finding had a cross-cutting aspect in the area of problem identification and resolution because the licensee did not conduct a self-assessment of sufficient depth. Specifically, the licensee evaluated a flooding incident during a self-assessment conducted in 2013 and failed to thoroughly evaluate the cause that resulted in common mode flooding of the rooms.
P.3(a) (Section 4OA2
.1.b (1))
B. Licensee-Identified Violations
No violations were identified.
REPORT DETAILS
REACTOR SAFETY
Cornerstone:
Initiating Events, Mitigating Systems, and Barrier Integrity 1R17 Evaluation s of Changes, Tests, or Experiments and Permanent Plant Modifications (71111.17 T)
.1 Evaluation of Changes, Tests, or Experiments
a. Inspection Scope
The inspectors reviewed four safety evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR) 50.59 to determine whether the evaluations were adequate and prior NRC-approval was obtained as appropriate. The minimum sample size of six safety evaluations were not achieved, because the licensee had only performed four safety evaluations during the sample period. The inspectors also reviewed 11 screenings and two applicability determinations where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:
the changes, tests, or experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required; the safety issue requiring the change, tests or experiment was resolved; the licensee conclusions for evaluations of changes, tests, or experiments were correct and consistent with 10 CFR 50.59; and the design and licensing basis documentation was updated to reflect the change.
The inspectors used, in part, Nuclear Energy Institute (NEI) 96
-07, "Guidelines for 10 CFR 50.59 Implementation," Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments," dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, "10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments."
This inspection constituted four samples of evaluations and 1 3 samples of screenings and/or applicability determinations as defined in Inspection Procedure (IP) 71111.17-04.
b. Findings
(1) 10 CFR 50.59 Evaluation Did Not Consider the Freeze Seal Effect to the Reactor Coolant Pressure Boundary (RCPB)
Introduction:
The inspectors identified a Severity Level IV, Non-Cited Violation of 10 CFR 50.59, "Changes, Tests, and Experiments,"
and an associated finding of very low safety significance (Green)for the licensee's failure to perform a written evaluation, 4 Enclosure which provided the bases for the determination whether a change did not require a license amendment. Specifically, the licensee failed to provide a basis for not applying for a license amendment associated with adding a freeze seal to the RCPB at a time where RCPB integrity was required.
Description:
In 2001, the licensee performed Safety Evaluation (SE) 97
-0079, "Installation of Piping Freeze Seal for SVI G33
-T9131 ," to evaluate permanently allowing the use of a freeze seal when performing surveillance instruction SVI
-G33-T9131, "Type C Local Leak Rate Test of 1G33 Penetration P131." This surveillance instruction (SVI) fulfilled the Technical Specification (TS) Surveillance Requirement (SR) 3.6.1.1.1 and SR 3.6.1.3.9 for reactor water cleanup system (RWCU) penetration P131. The conclusion of SE 97
-0079 was that the use of a freeze seal during this SVI was acceptable because the RCPB would be isolated by the closure of valves 1
-G33-F0101, F0102, F0103, F0106, and F0100.
The freeze seal location was outside this boundary.
In 2009, the licensee performed Evaluation 09
-01526, "Type C Local Leak Rate Test of 1G33 Penetration P131
," to evaluate a revision of SVI
-G33-T9131 that allowed valve 1-G33-F0101 to remain open. As a result, the freeze seal location was changed to b e within the RCPB. The licensee concluded this change was acceptable because an operator would be dedicated to manually close the 1
-G33-F0101 valve if the freeze seal result ed in a pi pe rupture and, if the valve could n ot be closed, then the pipe would be crimped. This SVI revision was used on March 24
-25, 2009, without irradiated fuel in the upper pool or the reactor vessel, and on April 13
-14, 2009, with irradiated fuel in the reactor vessel.
In 2013, the licensee revised Evaluation 09
-01526 to limit the performance of SVI-G33-T9131 to MODE 5 with fuel removed from the reactor vessel in order to prevent Operations with Potential to Drain the Reactor Vessel (OPDRV). The evaluation assumed the irradiated fuel would be stored in the upper containment pool fuel racks. The SVI was also updated to allow the use of a thaxton plug and repair clamp as a contingency if a pipe break occurs while using a freeze seal with the reactor core fully offloaded. This SVI revision was used on April 11
-12, 2013, with irradiated fuel in the upper pool.
Updated Safety Analysis Report (USAR) Section 3.1.2.2.5.1, "Evaluation Against Criterion 14," state d that, "In order to minimize the possibility of brittle fracture within the RCPB, the fracture toughness properties and the operating temperature of ferritic materials are controlled to ensure adequate toughness." In addition, USAR 3.1.2.4.2, "Compliance with General Design Criteria 31
- Fracture Prevention of Reactor Coolant Pressure Boundary," state d that, "The RCPB is designed, maintained
, and tested such that adequate assurance is provided that the boundary will behave in a non
-brittle manner throughout the life of the plant." The inspectors were concerned because ferritic steel breaks in a brittle rather than a ductile manner below certain temperature value s. The temperature limit for brittle behavior increases as a function of neutron exposure.
The installation of freeze seals in piping represent s a risk of exposing piping to temperatures below this transition point. The inspectors also noted this phenomenon was recognized by procedure GMI
-0024, "Freeze Seals," in that it stated "Frozen pipe is subject to brittle fracture." Thus, the use of a freeze seal within the RCPB was contrary to the USAR descriptions and Evaluation 09
-01526 did not address whether using the freeze seal within the RCPB would more than minimally increase the likelihood of a 5 Enclosure malfunction of the RCPB. In addition, the inspectors noted valve 1-G33-F0101, which was credited to be manually closed in case of RCPB failure, had not been exercised since as early as 2001. The inspectors were also concerned because the 2013 revision of Evaluation 09
-01526 did not recognize the upper pool and steam dryer pool inventory would be affected if the RCPB at the freeze seal location were to rupture. Thus, performance of the SVI in this manner would be contrary to procedure IOI
-009, "Refueling," which state d "Operations with a potential for draining the dryer storage pool shall not be performed when irradiated assemblies are seated in the upper containment pool fuel racks."
The licensee captured the inspectors
' concerns in the Corrective Actions Program (CAP) as CR-2013-11377, CR-2013-11217, and CR
-2013-10798 with recommended actions to update SVI
-G33-T9131 and associated 50.59 documents.
Analysis:
The inspectors determined that the failure to perform a written evaluation which provided the bases for the determination that a change did not require a license amendment was contrary to 10 CFR 50.59(d)(1) and was a performance deficiency. Specifically, the licensee failed to provide a basis for not applying for a license amendment associated with increasing the likelihood of RCPB failure due to subjectin g it to brittle fracture. The performance deficiency was determined to be more than minor because it was associated with the Initiating Events cornerstone attribute of equipment performance and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the RCPB was exposed to brittle fracture under conditions where RCPB integrity was required to protect irradiated fuel. In addition, the associated violation was determined to be more than minor because the inspectors could not reasonably determine the addition of the freeze seal to the RCPB would not have ultimately required NRC prior approval.
Violations of 10 CFR 50.59 are dispositioned using the traditional enforcement process instead of the significance determination process (SDP) because they are considered to be violations that potentially impede or impact the regulatory process. This violation is associated with a finding that has been evaluated by the SDP and communicated with an SDP color reflective of the safety impact of the deficient licensee performance. The SDP, however, does not specifically consider the regulatory process impact.
Thus, although related to a common regulatory concern, it is necessary to address the violation and finding using different processes to correctly reflect both the regulatory importance of the violation and the safety significance of the associated finding
.
In this case, the inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings," dated June 19, 2012. Because the finding was associated with shutdown conditions, the inspectors used IMC 0609, Appendix G, "Shutdown Operations Significance Determination Process." The inspectors reviewed Table 1 of Appendix G, "Losses of Control," and determined that none of the conditions constituting a loss of control were met.
The Region III Senior Reactor Analyst (SRA) reviewed Appendix G, Attachment 1, "Phase I Operational Checklists for Both PWRs and BWRs." The applicable checklist was Checklist 7, "BWR Refueling Operation with RCS Level > 23'." The SRA determined that the Phase I criterion was met so the risk evaluation progressed to Phase II. The SRAs reviewed Appendix G, Attachment 3, "Phase II Significance 6 Enclosure Determination Process Template for BWR during Shutdown," and determined the exposure time was less t han three days. Specifically, the dates the freeze seals were installed April 11
- 12, 2013, and April 13
- 14, 2009.
The SRA determined that a bounding risk evaluation could be performed addressing both exposure periods by assuming the more risk significant 2009 configuration. Considering the short exposure time and available mitigation features, the result was an estimated change in core damage frequency () of 6.2E-07/y ear. Thus, the finding was of very low safety significance (Green).
In accordance with Section 6.1.d of the NRC Enforcement Policy this violation is categorized as Severity Level IV because the resulting changes were evaluated by the SDP as having very low safety significance (i.e., green finding).
The inspectors did not identify a cross-cutting aspect associated with this finding because the finding was not confirmed to reflect current performance due to the age of the performance deficiency. Specifically, the licensee should have evaluate d the addition of the freeze seal to the RCP B in 2009 when they revised SVI
-G33-T9131.
Enforcement:
Title 10 CFR 50.59, "Changes, Tests, and Experiments," Section (d)(1) requires, in part, the licensee to maintain records of changes in the facility, of changes in procedures, and of tests and experiments made pursuant 10 CFR 50.59(c). It also requires that these records must include a written evaluation which provides a basis for the determination that the change, test, or experiment does not require a license amendment pursuant to10 CFR 50.59(c)(2)
. Contrary to the above, from April 2009 until August 28, 2013, the licensee did not provide a written evaluation, which provided the bases for determining that a change, test or experiment made pursuant to 10 CFR 50.59(c) did not require a license amendment. Specifically, the licensee made a change pursuant to 10 CFR 50.59(c) in that the licensee applied a freeze seal to the RCPB subjecting it to brittle fracture at a time where it's integrity was required to protect irradiated fuel. The licensee did not provide a written evaluation providing a basis for determining that applying the freeze seal to the RCPB would not result in more than a minimal increase in the likelihood of occurrence of a malfunction of an SSC. At the time of this inspection period, t he licensee was still evaluating its planned corrective actions. However, the inspectors determined that the continued non
-compliance did not present an immediate safety concern because the SVI procedure was placed on hold until the concerns are resolved.
This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was Severity Level IV and was entered into the licensee's corrective action program as CR-2013-10798, CR-2013-11217, and CR-2013-11377 (NCV 05000440/20132008
-01, 10 CFR 50.59 Evaluation Did Not Consider the Freeze Seal Effect to the RCPB). The associated finding was evaluated separately from the traditional enforcement violation; therefore, the underlying finding was assigned a separate tracking number (FIN 05000440/20132008
-02, 10 CFR 50.59 Evaluation Did Not Consider the Freeze Seal Effect to the RCPB).
7 Enclosure (2) Lack of Alternate Methods of Decay Heat Removal Introduction
- The inspectors identified an unresolved item (URI) regarding the unavailability of alternate methods of decay heat removal that could be credited to combat a loss of shutdown cooling resulting from emergency service water (ESW) inoperability and while in MODE 4 with high decay heat load.
Description:
On May 21, 2004, the 'A' ESW pump became inoperable due to a failure of the uppermost shaft coupling. Technical Specification Limiting Condition for Operation (LCO) 3.7.1, "ESW System
- Divisions 1 and 2," required the licensee to restore operability within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Because this action could not be met, TS required the licensee to be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. While performing plant shutdown, LCO 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System
- Cold Shutdown," became applicable. It required, in part, two shutdown cooling subsystems operable in MODE 4 when heat losses to the ambient were not sufficient to maintain average reactor coolant temperature below 200 oF. Because ESW is the heat sink of shutdown cooling, the 'A' train of shutdown cooling was also inoperable. With one or two shutdown cooling subsystems inoperable, TS 3.4.10, Required Action A.1, required the licensee to verify an alternate method of decay heat removal was available for each inoperable shutdown cooling subsystem within one hou r and once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter. The associated TS Basis described the alternate method as one that re
-establishes backup decay heat removal capabilities similar to the requirements of the LCO. However, the licensee was unable to identify an alternate method of decay heat removal to satisfy TS 3.4.10, Required Action A.1. Moreover, during repairs on the ESW 'A' pump, the licensee concluded that sufficient doubt existed regarding the ESW 'B' pump; thus, they declared the pump inoperable. Consequently, the 'B' train of shutdown cooling also became inoperable requiring two alternate methods of decay heat removal available. This incident resulted in an NCV which was documented in IR 05000440/2004011 and Licensee Event Report (LER) 05000440/2004
-001. On October 19, 2009, the 'B' ESW pump tripped off due to failure of the motor power supply cable. Again, the licensee was required to perform a plant shutdown by TS 3.7.1, declared the 'B' shutdown cooling train inoperable when TS 3.4.10 became applicable, and was unable to verify an alternate method of decay heat removal within one hour to satisfy TS 3.4.10, Required Action A.1. This incident was captured in the CAP as CR 2009-66216 and resulted in LER 05000440/2009003.
Following these two incidents, the licensee installed the Alternate Decay Heat Removal (ADHR) system. During this inspection period, the inspectors reviewed the associated
10 CFR 50.59 evaluation (i.e., Evaluation 05
-04712, "Installation of ADHR System") which stated "The intent of the ADHR system is to assure TS compliance in MODE 4 by providing an additional alternate decay heat removal option that does not rely upon RHR or ESW." However, the inspectors noted its design was limited to a heat removal rate which bounds the approximate decay heat production rate of the core 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a scram from sustained 100 percent power. During normal shutdown conditions, the licensee transitions from 100 percent power to MODE 4 in a few hours. For instance, this transition occurred in about five hours during refueling outage 1R13. In addition, the licensee revised procedure ONI
-E12-2, "Loss of Decay Heat Removal," by adding Attachment 11, "Cold Shutdown Decay Heat Removal by Steaming." This attachment contained instructions to establish an alternate method of decay heat removal independent of ESW. However, the attachment included a note stating, "It will be necessary to validate 8 Enclosure the effectiveness of this attachment to maintain or reduce RPV temperature (by Engineering calculation or demonstration)if qualifying this as an alternate decay heat removal method per TS 3.4.9 and 3.4.10." As a result, the inspectors questioned the effectiveness of this approach given it had not been verified. The licensee consequently , performed a calculation that determined Attachment 11 was limited to a heat removal rate which bounds the approximate decay heat production rate of the core three days after a shutdown from sustained 100 percent power. The procedure contained other alternatives but these either relied on ESW or lacked enough capacity to serve as backup methods during periods of high decay heat loads.
Based on this information, the inspectors were concerned the plant lacked two alternate methods of decay heat removal that have been verified to be effective should a loss of shutdown cooling result from ESW inoperability while in MODE 4 with high decay heat load. The inspectors were particularly concerned because this condition had occurred in the past at least twice. The licensee captured the inspectors
' concerns in their CAP as CR 2013-11480. This issue is unresolved pending further review and determination of NRC actions to resolve the issue (URI 05000440/2013008
-03, Lack of Alternate Methods of Decay Heat Removal).
.2 Permanent Plant Modifications
a. Inspection Scope
The inspectors reviewed five permanent plant modifications that had been installed in the plant or modified during the last three years. This review included in
-plant walkdowns for portions of the alternate decay heat removal system installed in the low pressure core spray room; station battery and battery charger rooms; and division 1 emergency diesel generator. The modifications were selected based upon risk significance, safety significance, and complexity. The inspectors reviewed the selecte d modifications to determine if:
the supporting design and licensing basis documentation was updated; the changes were in accordance with the specified design requirements; the procedures and training plans affected by the modification have been adequately updated; the test documentation as required by the applicable test programs has been updated; and post-modification testing adequately verified system operability and/or functionality.
The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included as an Attachment to this report.
This inspection constituted five permanent plant modification samples as defined in IP 71111.17-04.
9 Enclosure
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
.1 Routine Review of Condition Reports
a. Inspection Scope
T he inspectors reviewed several corrective action process documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent p lant modifications and evaluations of changes, tests, or experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the to this report.
b. Findings
(1) Insufficient Controls to Prevent Common Mode Flooding of Emergency Core Cooling System (ECCS)
Rooms Introduction
- The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control,"
for the licensee's failure to control drainage of the ECCS room sumps in a manner that prevent s common mode flooding of the ECCS rooms
. Specifically, the licensee's procedures did not ensure appropriate controls to prevent backflow from the floor drain system , which was contrary to the licensee's design basis
. Description
- On May 19, 2011, the licensee performed a test of the RHR 'B/C' water l eg pump while in MODE 5 following its replacement. During this test, the operators received an unexpected Auxiliary Building floor drain sump water level high alarm.
Approximately four minutes later, the operators received sump high level alarms associated with the RHR 'A,' 'B
,' and 'C,' and reactor core isolation cooling (RCIC) pump rooms. The test was stopped and all drain paths to the Auxiliary Building sumps were closed. This incident resulted in water accumulation in each one of these rooms and a n entry into Emergency Operating Procedure
- 3, "Secondary Containment Control and Radioactive Release Control," for about an hour. This condition was captured in the CAP as CR 2011
-95107. In preparation for this inspection, the licensee performed Self
-Assessment FO-SA-2012-0031 that evaluated CR 2011
-95107 relative to its completeness.
After this review, the licensee initiated CR 2013
-10119 on July 1, 2013, to document the missed opportunity to evaluate the potential flooding impact from this incident. Specifically, the licensee identified that CR 2011-95107 did not specify the water depth in the affected rooms and did not address the potential flooding impact to plant systems.
The licensee 10 Enclosure subsequently concluded that the maximum amount of water was within the design flood level. While reviewing a sample of corrective action process documents that identified or were related to plant modifications, the inspectors noted CR 2011
-95107 and CR 2013
-10119 did not address the cause of the common mode flooding of the ECCS rooms via the floor drain system. The inspectors were concerned because common mode flooding of these rooms was contrary to the design basis of the plant. Specifically, USAR 9.3.3.2.1, "Floor Drains," state d "-common mode flooding of the ECCS equipment rooms (i.e., flooding in one room which results in flooding of redundant ECCS equipment in adjacent rooms)is precluded by the design of the drainage piping.
" In addition, USAR 9.3.3.3, "Safety Evaluation," state d "Flooding of the ECCS rooms by backflow through the floor drains from a rupture of non
-seismic designed fluid lines is prevented by the installation of a normally closed shutoff valve in the floor drain line from each of the six compartments.
" The shutoff valve for each compartment was controlled by Procedure SOI
-G61, "Liquid Radwaste Sumps.
" However, the inspectors noted the following procedure deficiencies:
The procedure allowed multiple ECCS room sump isolation valves to be open at the same time. This configuration did not prevent common mode flooding by backflow through the floor drains
. The compensatory actions to prevent or mitigate common mode flooding were only required by the procedure when a valve was open and the associated ECCS system was not isolated.
This prerequisite considered ECCS as the only potential flood source. That is, it did not consider a rupture of other fluid lines located in these rooms. The required compensatory actions were inadequate to prevent or mitigate common mode flooding. Specifically, one of the procedure options was to establish a 1
-hour flood watch. However, the inspectors noted backflow to multiple ECCS rooms occurred in a few minutes during the 2011 incident.
The licensee captured the inspectors
' concerns in their CAP as CR 2013-10825. The corrective actions were, in part, to revise SOI
-G61 to prevent opening more than one ECCS room sump isolation valve at the same time.
Analysis:
The inspectors determined that the failure to control drainage of the ECCS sumps in a manner that prevents common mode flooding of the ECCS rooms was contrary to 10 CFR Part 50, Appendix B, Criterion III, "Design Control,"
and was a performance deficiency.
The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of protection against external factors and affected the cornerstone objective of ensuring the availability, reliability, and capability of the ECCS to respond to initiating events to prevent undesirable consequences. Specifically, procedure SOI
-G61 did not ensure the availability of ECCS because it contained insufficient instructions to prevent common mode flooding of ECCS rooms by backflow through the floor drains.
In accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings," Table 2 the inspectors determined the finding affected the Mitigating Systems cornerstone. As a result, the inspectors determined the finding could be evaluated using Appendix A, "The Significance Determination Process (SDP) for Findings At
-Power," Exhibit 2, "Mitigating Systems 11 Enclosure Screening Questions.
" The inspectors determined that the finding was of very low safety significance (Green) because it did not result in the loss of operability n o r an actual loss or degradation of a function designed to mitigate flooding. Specifically, a review of recent plant history did not find an instance where the configuration of the floor drain system allowed common mode flooding of the ECCS rooms when operability of these systems was required.
The inspectors determined that this finding had a cross
-cutting aspect in the area of problem identification and resolution, self and independent assessments because the licensee did not conduct a self
-assessment of sufficient depth. Specifically, the licensee evaluated the problem captured in CR 2011-95107 during a self
-assessment
, but failed to thoroughly evaluate the causes that permitted multiple ECCS rooms to become flooded. P.3(a) Enforcement
- Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Section 9.3.3.2.1 of the USAR states that common mode flooding of the ECCS rooms is precluded by the design of the drainage piping. Section 9.3.3.3 of the USAR state s flooding of the ECCS rooms by backflow through the floor drains was prevented by the installation of a normally closed shutoff valve in the floor drain line from each room.
Contrary to the above , from May 19, 2011
, to July 16 , 2013, the licensee failed to translate the applicable design basis into procedures. Specifically, the licensee did not translate the common mode flooding prevention controls described in the USAR into procedure SOI
-G61. As an immediate corrective action, the licensee revised SOI
-G61 to prevent opening more than one ECCS room sump valve at the same time.
Becaus e this violation was of very low safety significance and was entered into the licensee's CAP as CR 2013-10825, this violation is being treated as a Non
-Cited Violation, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000440/2013008
-0 4 , Insufficient Controls to Prevent Common Mode Flooding of ECCS Rooms
).
4OA6 Meetings
.2 Interim Meeting Summary
O n July 26 and August 28, 2013 , the inspector s presented the preliminary inspection results to Mr. D. Hamilton and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
The inspectors had outstanding questions that required additional review and a follow
-up exit meeting.
.1 Exit Meeting
Summary On September 17, 2013, the inspector s presented the inspection results to Mr. B. Huck and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
Attachment
SUPPLEMENTAL INFORMATION KEY POINTS OF CONTAC
T Licensee
- V. Kaminskas, Site Vice
President
- D. Hamilton, Plant General Manager
- H. Hanson, Performance Improvement Director
- T. Veitch, Regulatory Compliance Manager
- J. Tufts, Operations Manager
- B. Huck, Design Manager
- B. Coad, Engineering Analysis Supervisor
Nuclear Regulatory Commission
- R. Daley, Chief, Engineering Branch 3, D
RS
- M. Marshfield, Senior Resident Inspector
LIST OF ITEMS OPENED
AND CLOSED
Opened 05000440/2013008
-01 NCV 10 CFR 50.59 Evaluation Did Not Consider the Freeze Seal Effect to the RCPB (Section 1R17.1.b(1))
-02 FIN 10 CFR 50.59 Evaluation Did Not Consider the Freeze Seal Effect to the RCPB (Section 1R17.1.b(1))
-03 URI Lack of Alternate Methods of Decay Heat Removal
(Section 1R17.1.b(2))
-04 NCV Insufficient Controls to Prevent Common Mode Flooding of ECCS Rooms (Section 4OA2.1.b(1))
Closed 05000440/2013008
-01 NCV 10 CFR 50.59 Evaluation Did Not Consider the Freeze Seal Effect to the RCPB (Section 1R17.1.b(1))
-02 FIN 10 CFR 50.59 Evaluation Did Not Consider the Freeze Seal Effect to the RCPB (Section 1R17.1.b(1))
-04 NCV Insufficient Controls to Prevent Common Mode Flooding of ECCS Rooms (Section 4OA2.1.b(1))
Attachment
LIST OF DOCUMENTS REVIEWED The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
CFR 50.59 EVALUATIONS
Number Description or Title
Date or Revision
11-02431 USAR Change Notice (UCN) 11
-068, Change to the Structural Design Criteria for
the Fuel Handling Building Crane and the Polar Crane
10/5/2011 05-04712 Installation of Alternate Decay Heat Removal System
2/20/2012
09-01526 Type C Local Leak Rate Test of 1G33 Penetration P131
2/24/2013 09-01526 Type C Local Leak Rate Test of 1G33 Penetration P131
4/15/2009 10-00208 HPI-K0008 Dry Active Waste
and USAR Change 11-215 1/24/2012 10 CFR 50.59 SCREENINGS
Number Description or Tit
le Date or Revision
08-04933 Equivalent Change for Div.1 and 2 Diesel Generator Crankcase High Pressure Trip Pressure Switches, 1R43N0711A/B
2/16/2011 10-04045 Upgrade the Existing 480V Motor Control Center (MCC) Automatic Transfer SW, and Relay in MCC F1C08 5/23/2011 10-04146 Delete the Mild Environment Equipment Qualification (EQ) Program
11/16/2010
10-05813 Transformer Sudden Pressure Alarm Relay 10/23/2012
10-03576 Freeze Seal Installation
4/19/2011 11-01173 Loss of Decay Heat Removal
3/14/2011 11-03570 TS Bases Change Notice 11
-167 11/22/2011
11-03807 SLC A/B Pump and Valve Operability Test
9/14/2011
Attachment
CFR 50.59 SCREENINGS
Number Description or Tit
le Date or Revision
2-02810 Low Power Hydrogen Injection
2/6/2012 09-05025 RPV Control
06/01/2012
11-04961 Service Test Capacity
- Division 1
01/05/2012
11-00 340 Temporary Modification to remove time delay relay (PY
-1E51Q7220) from service
03/24/2011
10-00208 HPI-K8/K9, RPI-1301,USAR update, Calc 3.2.19.1 and.2 06/27/2013
CALCULATIONS
Number Description or Title
Date or Revision
PRDC-0014 Division 1, 125VDC System Load Evaluation, Voltage Drop, Battery/ Battery Charger Sizing Calculation
CORRECTIVE ACTION PROGRAM DOCUMENTS INITIATED DURING
INSPECTION
Number Description or Title
Date or Revision
CR-2013-10172 NRC ID 50.59 2013
- 50.59 Screen 11
-03807 Contains Incorrect CR Number
7/2/2013 CR- 2013-10226 NRC ID 2013 50.59
- Documentation for OE Evaluation of IN -2002-15 Could Not Be Located 7/3/2013 CR- 2013-10604 NRC ID 2013 50.59: RWCU FM Vessel DRN Suction Valve G33F0101 Erratic Readings
7/11/2013 CR- 2013-10798 NRC ID 50.59, LTA Controls and Evaluation for SVI-G33-T9131 for Irradiated Fuel in Upper Pool Storage Rack
7/15/2013 CR- 2013-10825 NRC ID 50.59, LTA SOI
-G61 Controls
t o Prevent Cross Flooding
of ECCS Rooms
7/16/2013 CR- 2013-10851 NRC ID 201
3-50.59, RAD Exemptions
for R42 SVI s Have Inadequate Justification
7/16/2013 CR- 2013-10862 NRC ID 2013 50.59, Observation RAD/Screen 7/16/2013
Attachment
CORRECTIVE ACTION PROGRAM DOCUMENTS INITIATED DURING
INSPECTION
Number Description or Title
Date or Revision
Description
CR- 2013-11071 NRC ID 2013 50.59, Evaluation 05
-04712, R/2 For ADHR Does Not Address Radiological Monitoring
of SW in Question 4.6
7/19/2013 CR- 2013-11126 NRC ID 50.59 2013
- Generic NRC Concern With ISS 2702, Freeze Seal
7/19/2013 CR- 2013-11217 NRC ID 50.59 2013 Deficiencies With 50.59 Evaluation 09
-01526 7/22/2013 CR- 2013-11377 NRC ID 2013 50.59: LTA 50.59 Evaluation 09
-01526 7/24/2013 CR- 2013-11430 NRC I D 50.59 2013
- Prdc-0014 Revision 4 Errors Identified
7/25/2013 CR- 2013-11480 NRC ID 2013 50.59: Ability
to Comply With
TS 3.4.10 7/25/2013 CR- 2013-11523 NRC ID 2013 50.59: 50.59 Screens May Not Provide Adequate Information
for Reaching Conclusions
7/26/2013 CR- 2013-11524 NRC ID 2013 5059, Potential Lack
o f Systematic Approach
to Address Changes
7/26/2013 CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number Description or Title
Date or Revision CR-2013-08813 FO-SA-2012-0031:50.59 Screen Justification is Inadequate
6/6/2013 CR-2013-05391 Unsuccessful , to Date, in Attempts
t o Procure A Crimping Tool
4/8/2013 CR-2011-92480 PWIS Does Not Support All SVI C41 T2001 Activities
4/7/2011 CR-2 011-95107 Auxiliary Building Flooded During
RHR Water Leg Pump Test
5/19/2011 CR-2009-66216 Unable to Meet Tech Spec Action Statement Due to ESW B Inoperability
10/19/2009
CR-2009-60977 NRC ID (FP Triennial): Non
-Conformance with Hot Shutdown Repair Requirements 6/24/2009 CR-2013-10217 FO-SA-2012-0031: LTA Organization Effectiveness for G33F0101
7/03/2013 CR-2010-77987 SN-SA-10-154: Evaluation 09
-01526 Clarifications
6/09/2010 CR-2013-01658 Rescreen Evaluation 10
-00208 6/27/2013
Attachment
DRAWINGS Number Description or Title
Date or Revision
206-013 Electrical One Line Diagram Generator
V 302-0671-00000 Reactor Water Clean
-up System AA 208-0158-00003 Generator Main Transformer (1
-PY-T) Trip Logic and Backup Relaying
T 208-0158-00004 Generator Unit Auxiliary Transformer (110
-PY-B) Trip Logic
S 208-0178-00001 Control Complex Chilled "A"
Z 208-0065-00008 High Pressure Core Spray System
P 208-0178-00012 Chiller "A" Controls B001A
RR 206-0017-00000 One Line Diagram Class 1E 4.16KV Bus EH11 and EH12 EE 206-00144-00000 One Line Diagram NON
-Class 1E 480V Bus XF1A TT 206-0036-00000 One Line Diagram NON
-Class 1E 480V Bus
F1C XXX 302-0347-00000 Standby Diesel
- Engine Control Panel
J 302-0355-00000 HPCS and Standby Diesel Generator Exhaust, Intake and Crankcas
e W 302-0346-00000 Standby Diesel Engine Mounted Piping
F 921-0617 ECCS Room Sump Drain System
11/21/2012
MODIFICATIONS
Number Description or Title
Date or Revision
2-0056-002 Rewire Control Room Ammeter (1P45
-R010) To Prevent a Hot Short in the Ammeter Circuit from Tripping Switchgear
3/13/2012 09-0081-001 Addition of 1Extra 2GN
-15 Battery Cell to Make Division 1 Battery (1R42S0002) a 61 9/26/2011
Attachment
MODIFICATIONS
Number Description or Title
Date or Revision
Cell Unit 1E51N0654 Slave Trip Unit: RCIC Suction Pressure
-Low 1/24/2012 08-0470-001 Implement Changes for DIV 1 Diesel Engine Panel Nuisance Alarms
9/2/2011 09-0579-001 Install A Bypass Switch in the Division 1 Diesel Generator Control Panel
4/1/2010 PROCEDURES
Number Description or Title
Date or Revision
NOBP-ER-3101 Large Transformers
R SVI-R42-T5202 Unit 1 Weekly 125V Battery Voltage and Category A Limits Check
GEI-0039 Full Battery Equalizing Charge for Lead
-Calcium Batteries
ONI-E12-2 Loss of Decay Heat Removal
ISS-2702 Freeze Seal Installation
GMI-0024 Freeze Seals 19 SVI-C41-T2001-A SLC A Pump and Valve Operability Test
SOI-G61 Liquid Radwaste Sumps
SVI-G33-T9131 Type C Local Leak Rate Test of 1G33 Penetration P131
SVI-R42-T5212 Service Test of Battery Capacity
- Division 2 (Unit 1) 10 PAP-1925 Shutdown Defense in Depth Assessment and
Management
IOI-9 Refueling 31 ARI-H51-P054A Division 1 Diesel Engine Control Panel
Attachment
OTHER DOCUMENTS
Number Description or Title
Date or Revision
200406791 (24M) Service Test of Battery Capacity
- Division 1 (Unit1)
6/13/12 2 00406858 Performance Test of Battery Capacity
-Division 1 (Unit1)
4/24/12 Order 200389587
Freeze Seal for SVI-G33T9132 5/9/2011 PERP0427 Replacement of Obsolete Gould Pumps 0 Order 200472262
Freeze Seal Order
4/20/2013 Order 200441630
Install Temp Mod
11-0016-00 3/30/2011 CN 11-25 HPI-K0009, 50.59 Evaluation No. 10-00208 1/26/2012 CN 13-033 CR 2012-14936, ECP 09
-0579 2/27/2013
Attachment
LIST OF ACRONYMS USE
D ADAMS Agencywide Documents Access and Management System
ADHR Alternate Decay Heat Removal
BWR Boiling Water Reactor
CAP Corrective Action Program
CDF Core Damage Frequen
cy CFR Code of Federal Regulations
CR Condition Report
ECCS Emergency Core Cooling System
ESW Emergency Service Water
FENOC FirstEnergy Nuclear Operating Company
FIN Finding IMC Inspection
Manual Chapter
IP Inspection Procedure
IR Inspection Report
LER Licensee Event Report
NCV Non-Cited Violation
NEI Nuclear Energy Institute
NRC U.S. Nuclear Regulatory Commission
OPDRV Operations with Potential to Drain the Reactor Vessel
PARS Public Available Records System
PWR Pressurized Water Reactor
RCIC Reactor Core Isolation Cooling
RCPB Reactor Coolant Pressure Boundary
RWCU Reactor Water Cleanup System
SDP Significance Determination Process
SE Safety Evaluation
SR Surveillance Requirement
SRA Senior Reactor Analyst
SVI Surveillance Instruction
TS Technical Specification
URI Unresolved Item
USAR Updated Safety Analysis Report
E. Harkness
-2- 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 Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading
-rm/adams.html
(the Public Electronic Reading Room).
Sincerely, /RA/ Robert
- C. Daley, Chie f Engineering Branch 3
Division of Reactor Safety Docket Nos.
50-440 License Nos. NPF-58 Enclosure:
Inspection Report 05000440/2013008 w/Attachment: Supplemental Information
cc w/encl:
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