ML111300570: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(Created page by program invented by StriderTol)
 
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:May 10, 2011  Mr. M.E. Reddemann
{{#Wiki_filter:UNITED STATES
Chief Executive Officer
                                NUCLEAR REGULATORY COMMISSION
Energy Northwest
                                                  REGI ON I V
P.O. Box 968, Mail Drop 1023
                                        612 EAST LAMAR BLVD, SUITE 400
Richland, WA  99352
                                        ARLINGTON, TEXAS 76011-4125
-0968  Subject:  COLUMBIA GENERATING STATION
                                            May 10, 2011
- NRC INTEGRATED INSPECTION REPORT NUMBER 05000 397/2011002    Dear Mr. Reddemann
Mr. M.E. Reddemann
:  On March 26, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Columbia Generating Station.  The enclosed integrated inspection report documents the
Chief Executive Officer
inspection findings, which were discussed on March 31, 2011, with yourself, and other members of your staff.
  The inspections 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.
 
Based on the results of this inspection, the
NRC has determined that
one Severity Level IV violation of NRC requirements occurred.
The NRC has also identified one NRC identified issue that was evaluated under the risk significance determination process as having very low safety significance (Green).  The NRC has determined that a violation is
associated with this issue
.  However, because of the very low safety significance and because they were entered into your
corrective action program, the NRC is treating these findings as noncited violations , consistent with Section
2.3.2.a of the NRC Enforcement Policy.
 
If you contest the violation or the significance of the noncited violation, you should provide a response within 30
days of the date of this inspection report, with the basis for your denial, t
o the U.S. Nuclear Regulatory Commission, ATTN:  Document Control Desk, Washington, D.C.
20555-0001, with copies to the Regional Administrator, U.S.
Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd, Suite
400, Arlington, Texas, 76011
-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555
-0001; and the NRC Resident Inspector at the
facility.  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 IV, and the NRC Resident Inspector at the facility
. U N I T E D S T A T E S N U C L E A R R E G U L A T O R Y C O M M I S S I O N R E G I O N I V 6 12 EAST LAMAR BLVD
, S U I T E 4 0 0 A R L I N G T O N , T E X A S 7 6 0 1 1-4125 
Energy Northwest
Energy Northwest
- 2 - In accordance with 10 CFR 2.390 of the NRC's "Rules of
P.O. Box 968, Mail Drop 1023
Practice," a copy of this letter, its enclosure, and your response, if you choose to provide one for cases where a response is not required, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading
Richland, WA 99352-0968
-rm/adams.html
Subject: COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION REPORT
.  To the extent possible, your response should not include any personal, privacy or proprietary information so that it can be made available to the Public without redaction.
          NUMBER 05000397/2011002
  Sincerely, /RA/ Wayne C. Walker, Chief Project Branch
Dear Mr. Reddemann:
A Division of Reactor Projects
On March 26, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
  Docket: 
at your Columbia Generating Station. The enclosed integrated inspection report documents the
50-397 License:  NPF-21  Enclosure:
inspection findings, which were discussed on March 31, 2011, with yourself, and other members
NRC Inspection Report 05000 397/2011002  w/Attachment:  Supplemental Information
of your staff.
cc:  Distribution via ListServ for Columbia Generating Station
The inspections examined activities conducted under your license as they relate to safety and
 
compliance with the Commissions rules and regulations and with the conditions of your license.
  - 1 - Enclosure U.S. NUCLEAR REGULATORY COMMISSION
The inspectors reviewed selected procedures and records, observed activities, and interviewed
REGION IV Docket: 05000 397 License: NPF-21 Report: 05000 397/2011002 Licensee: Energy Northwest
personnel.
Facility: Columbia Generating Station
Based on the results of this inspection, the NRC has determined that one Severity Level IV
Location: Richland, WA
violation of NRC requirements occurred. The NRC has also identified one NRC identified issue
Dates: January 1, 2011
that was evaluated under the risk significance determination process as having very low safety
through March 26, 2011
significance (Green). The NRC has determined that a violation is associated with this issue.
Inspectors:
However, because of the very low safety significance and because they were entered into your
R. Cohen, Senior Resident Inspector
corrective action program, the NRC is treating these findings as noncited violations, consistent
M. Hayes, Resident Inspector
with Section 2.3.2.a of the NRC Enforcement Policy.
B. Larson, Senior Operations Engineer
If you contest the violation or the significance of the noncited violation, you should provide a
D. Strickland, Operations Engineer
response within 30 days of the date of this inspection report, with the basis for your denial, to
Approved By:
the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.
W. Walker, Chief, Project Branch
20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission,
A Division of Reactor Projects
Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of
   
Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the
  - 2 - Enclosure SUMMARY OF FINDINGS
NRC Resident Inspector at the facility. In addition, if you disagree with the cross-cutting aspect
  IR 05000 397/2011002; 01/01/2011
assigned to any finding in this report, you should provide a response within 30 days of the date
- 03/26/2011
of this inspection report, with the basis for your disagreement, to the Regional Administrator,
; Columbia Generating Station, Integrated Resident and Regional Report
Region IV, and the NRC Resident Inspector at the facility.
; Postmaintenance Testing, Identification and Resolution of Problems    The report covered a 3
 
-month period of inspection by resident inspectors and announced baseline inspection
Energy Northwest                                -2-
s by region-based inspector s. One Green noncited violation
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
of significance and one Severity Level IV violation were
enclosure, and your response, if you choose to provide one for cases where a response is not
identified.
required, will be made available electronically for public inspection in the NRC Public Document
  The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter
Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at
0609, "Significance
http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not
Determination Process."  The cross-cutting aspect is determined using Inspection Manual Chapter 0310, "Components Within the Cross
include any personal, privacy or proprietary information so that it can be made available to the
-Cutting Areas." Findings for which the significance determination process 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
Public without redaction.
-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
                                              Sincerely,
  A. NRC-Identified Findings and Self
                                              /RA/
-Revealing Findings
                                              Wayne C. Walker, Chief
    Cornerstone: Mitigating Systems
                                              Project Branch A
   Green.  The inspectors identified a noncited violation of 10 CFR Part 50 Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the
                                              Division of Reactor Projects
licensee's failure to consider the impact of preconditioning on the emergency core cooling systems during maintenance. Specifically, licensee personnel failed to consider the impact of scheduling keep fill pump maintenance prior to technical specification required surveillance testing. Licensee personnel reviewed three years worth of data on the emergency core cooling systems to ensure there was no degrading performance trend.  This issue was placed in the licensee's corrective action program as Action Request/Condition Report 23 6880.  The performance deficiency was more than minor because it affected the equipment performance attribute of the Mitigating Systems Cornerstone objective of ensuring the reliability of systems that respond to initiating events.  Using
Docket: 50-397
Inspection Manual Chapter 0609.04, Phase 1
License: NPF-21
- "Initial Screening and Characterization of Findings," the inspectors determined that this performance
Enclosure:
deficiency was of very low safety significance because this finding was confirmed to not result in a loss of operability
NRC Inspection Report 05000397/2011002
for the emergency core cooling systems.
  w/Attachment: Supplemental Information
Th e inspectors identified a cross
cc: Distribution via ListServ for Columbia Generating Station
-cutting issue in the area of human performance, work practices, because the licensee failed to effectively communicate expectations regarding procedural compliance
 
[H.4.b] (Section 1R19). Cornerstone:  Miscellaneous
                  U.S. NUCLEAR REGULATORY COMMISSION
    Severity Level IV. The inspectors identified a Severity Level IV violation of 10 CFR 50.72(b)(3)(v)(D) for the failure of the licensee to make a non
                                    REGION IV
-emergency 
Docket:      05000397
  - 3 - Enclosure event notification to the NRC. Specifically, on December
License:    NPF-21
20, 2010 , the licensee failed to report the low pressure core spray minimum flow valve failing to open on pump start, rendering the low pressure core spray system incapable of performing
Report:      05000397/2011002
its specified safety function during testing. The licensee made Event Notification 46604 on February 8, 2011, to report the identified condition. As a corrective action the licensee has informed all current shift managers, and plans to train future senior reactor operators, of the expectation to evaluate low pressure core spray system failures as a failure of a single train system to complete a safety function. This violation has been placed in the licensee's corrective action program as Action Request/Condition Report
Licensee:    Energy Northwest
23 6879.  The performance deficiency was more than minor because the NRC relies on licensees to identify
Facility:    Columbia Generating Station
and report conditions or events meeting the criteria specified in the regulations in order to perform its regulatory function. The inspectors determined that this finding was not appropriate to evaluate using the Significance Determination Process due to the finding only affecting the NRC's ability to perform its regulatory oversight function. As a result, this finding was evaluated for traditional enforcement in accordance with the NRC Enforcement Policy. This finding was determined to be a Severity Level IV violation in accordance with Section 6.9.d.9 of the NRC Enforcement Policy, dated September 30, 2010.  The inspectors determined that assigning a cross
Location:    Richland, WA
-cutting aspect was not applicable to this finding due to the finding being screened
Dates:      January 1, 2011 through March 26, 2011
exclusively using the traditional enforcement process (Section 4OA2).
Inspectors:  R. Cohen, Senior Resident Inspector
  B. Licensee-Identified Violations
            M. Hayes, Resident Inspector
  None       
            B. Larson, Senior Operations Engineer
  - 4 - Enclosure REPORT DETAILS
            D. Strickland, Operations Engineer
  Summary of Plant Status
Approved By: W. Walker, Chief, Project Branch A
  The plant began the inspection period at
            Division of Reactor Projects
100 percent power. The plant remained at 100 percent power for the remainder of the inspection period except for planned power reductions to support maintenance and testing.
                                    -1-              Enclosure
  1. REACTOR SAFETY
 
  Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness
                                    SUMMARY OF FINDINGS
  1R01 Adverse Weather Protection (71111.01)
IR 05000397/2011002; 01/01/2011 - 03/26/2011; Columbia Generating Station, Integrated
  Readiness for Seasonal Extreme Weather Conditions
Resident and Regional Report; Postmaintenance Testing, Identification and Resolution of
a. The inspectors performed a review of the adverse weather procedures for seasonal extremes (e.g., extreme high temperatures, extreme low temperatures, or hurricane season preparations). The inspectors verified that weather
Problems
-related equipment deficiencies identified during the previous year were corrected prior to the onset of
The report covered a 3-month period of inspection by resident inspectors and announced
seasonal extremes
baseline inspections by region-based inspectors. One Green noncited violation of significance
, and evaluated the implementation of the adverse weather preparation procedures and compensatory measures for the affected conditions before the onset of, and during, the adverse weather conditions.
and one Severity Level IV violation were identified. The significance of most findings is
Inspection Scope
indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609,
  During the inspection, the inspectors focused on plant
Significance Determination Process. The cross-cutting aspect is determined using Inspection
-specific design features and the procedures used by plant personnel to mitigate or respond to adverse weather conditions.  Additionally, the inspectors reviewed the FSAR and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant
Manual Chapter 0310, Components Within the Cross-Cutting Areas. Findings for which the
-specific procedures.  Specific documents reviewed during this inspection are listed in the attachment. The inspectors also reviewed corrective action program items to verify that plant personnel
significance determination process does not apply may be Green or be assigned a severity level
were identifying adverse weather issues at an appropriate threshold and entering them into their corrective action
after NRC management review. The NRC's program for overseeing the safe operation of
program in accordance with station corrective action procedures.  The inspectors' reviews focused specifically on the following plant systems:
commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
  February 25, 2011, diesel generator rooms, service water pump houses and circulating water pump houses
Revision 4, dated December 2006.
due to extreme low temperatures being forecasted for the day
A.     NRC-Identified Findings and Self-Revealing Findings
  These activities constitute completion of one readiness for seasonal adverse weather sample as defined in Inspection Procedure
        Cornerstone: Mitigating Systems
71111.01-05b. No findings were identified.
        *      Green. The inspectors identified a noncited violation of 10 CFR Part 50
Findings 
              Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the
  - 5 - Enclosure  1R04 Equipment Alignments (71111.04)
              licensees failure to consider the impact of preconditioning on the emergency
  Partial Walkdown
              core cooling systems during maintenance. Specifically, licensee personnel failed
a. The inspectors performed partial system walkdowns of the following risk
              to consider the impact of scheduling keep fill pump maintenance prior to
-significant systems: Inspection Scope
              technical specification required surveillance testing. Licensee personnel
  January 5, 2011, residual heat removal system C
              reviewed three years worth of data on the emergency core cooling systems to
  February 14, 2011, diesel generator 1
              ensure there was no degrading performance trend. This issue was placed in the
  The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected.  The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, FSAR, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable.  The
              licensees corrective action program as Action Request/Condition
inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of
              Report 236880.
mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization.  Specific documents reviewed during this inspection are listed in the attachment.
              The performance deficiency was more than minor because it affected the
  These activities constitute completion of two partial system walkdown sample
              equipment performance attribute of the Mitigating Systems Cornerstone objective
s as defined in Inspection Procedure
              of ensuring the reliability of systems that respond to initiating events. Using
71111.04-05. b. No findings were identified.
              Inspection Manual Chapter 0609.04, Phase 1 - "Initial Screening and
Findings  1R05 Fire Protection (71111.05)
              Characterization of Findings, the inspectors determined that this performance
   Quarterly Fire Inspection Tours
              deficiency was of very low safety significance because this finding was confirmed
a. The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk
              to not result in a loss of operability for the emergency core cooling systems. The
-significant plant areas:
              inspectors identified a cross-cutting issue in the area of human performance,
Inspection Scope
              work practices, because the licensee failed to effectively communicate
 
              expectations regarding procedural compliance [H.4.b] (Section 1R19).
  - 6 - Enclosure  January 6, 2011, fire area
        Cornerstone: Miscellaneous
RC-4, division 1 switch
        *      Severity Level IV. The inspectors identified a Severity Level IV violation of 10
gear room  January 10, 2011, fire area R
              CFR 50.72(b)(3)(v)(D) for the failure of the licensee to make a non-emergency
-8/1, low pressure core spray pump room
                                              -2-                                  Enclosure
  January 12, 2011, fire area R
 
-1/1, reactor building 522' elevation northwest quadrant  February 14, 2011, fire area
        event notification to the NRC. Specifically, on December 20, 2010, the licensee
DG-2, division 1 diesel generator room
        failed to report the low pressure core spray minimum flow valve failing to open on
  February 16, 2011, fire area R-5, residual heat removal pump 2A room
        pump start, rendering the low pressure core spray system incapable of
The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event.  Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed
        performing its specified safety function during testing. The licensee made Event
; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition.  The inspectors also verified that minor issues identified during the inspection were entered into the licensee's corrective action program. Specific documents reviewed during this inspection are listed in the attachment.
        Notification 46604 on February 8, 2011, to report the identified condition. As a
  These activities constitute completion of five quarterly fire
        corrective action the licensee has informed all current shift managers, and plans
-protection inspection sample
        to train future senior reactor operators, of the expectation to evaluate low
s as defined in Inspection Procedure
        pressure core spray system failures as a failure of a single train system to
71111.05-05. b. No findings were identified.
        complete a safety function. This violation has been placed in the licensees
Findings  1R11 Licensed Operator Requalification Program (71111.11)
        corrective action program as Action Request/Condition Report 236879.
.1 Quarterly Review
        The performance deficiency was more than minor because the NRC relies on
a.   On February 14, 2011, the inspectors observed a crew of licensed operators in the plant's simulator to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures.  The inspectors evaluated the following areas:
        licensees to identify and report conditions or events meeting the criteria specified
  Inspection Scope
        in the regulations in order to perform its regulatory function. The inspectors
 
        determined that this finding was not appropriate to evaluate using the
  - 7 - Enclosure Licensed operator performance
        Significance Determination Process due to the finding only affecting the NRCs
  Crew's clarity and formality of communications
        ability to perform its regulatory oversight function. As a result, this finding was
  Crew's ability to take timely actions in the conservative direction
        evaluated for traditional enforcement in accordance with the NRC Enforcement
 
        Policy. This finding was determined to be a Severity Level IV violation in
Crew's prioritization, interpretation, and verification of annunciator alarms
        accordance with Section 6.9.d.9 of the NRC Enforcement Policy, dated
  Crew's correct use and implementation of abnormal and emergency procedures
        September 30, 2010. The inspectors determined that assigning a cross-cutting
  Control board manipulations
        aspect was not applicable to this finding due to the finding being screened
 
        exclusively using the traditional enforcement process (Section 4OA2).
Oversight and direction from supervisors
B. Licensee-Identified Violations
  Crew's ability to identify and implement appropriate technical specification actions and emergency plan actions and notifications
  None
  The inspectors compared the crew's performance in these areas to preestablished operator action expectations and successful critical task completion requirements.  Specific documents reviewed during this inspection are listed in the attachment.
                                      -3-                                   Enclosure
 
 
These activities constitute completion of one quarterly licensed
                                        REPORT DETAILS
-operator requalification program sample as defined in Inspection Procedure
Summary of Plant Status
71111.11.  b. No findings were identified.
The plant began the inspection period at 100 percent power. The plant remained at 100 percent
Findings  .2 Biennial Inspection (71111.11B)
power for the remainder of the inspection period except for planned power reductions to support
  The licensed operator requalification program involves two training cycles that are
maintenance and testing.
conducted over a 2
1.    REACTOR SAFETY
-year period.  In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator scenarios.  In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comprehensive written examination.
      Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and
      Emergency Preparedness
1R01 Adverse Weather Protection (71111.01)
      Readiness for Seasonal Extreme Weather Conditions
  aInspection Scope
      The inspectors performed a review of the adverse weather procedures for seasonal
      extremes (e.g., extreme high temperatures, extreme low temperatures, or hurricane
      season preparations). The inspectors verified that weather-related equipment
      deficiencies identified during the previous year were corrected prior to the onset of
      seasonal extremes, and evaluated the implementation of the adverse weather
      preparation procedures and compensatory measures for the affected conditions before
      the onset of, and during, the adverse weather conditions.
      During the inspection, the inspectors focused on plant-specific design features and the
      procedures used by plant personnel to mitigate or respond to adverse weather
      conditions. Additionally, the inspectors reviewed the FSAR and performance
      requirements for systems selected for inspection, and verified that operator actions were
      appropriate as specified by plant-specific procedures. Specific documents reviewed
      during this inspection are listed in the attachment. The inspectors also reviewed
      corrective action program items to verify that plant personnel were identifying adverse
      weather issues at an appropriate threshold and entering them into their corrective action
      program in accordance with station corrective action procedures. The inspectors
      reviews focused specifically on the following plant systems:
      *      February 25, 2011, diesel generator rooms, service water pump houses and
              circulating water pump houses due to extreme low temperatures being
              forecasted for the day
      These activities constitute completion of one readiness for seasonal adverse weather
      sample as defined in Inspection Procedure 71111.01-05.
  b. Findings
      No findings were identified.
                                            -4-                                Enclosure
 
1R04 Equipment Alignments (71111.04)
    Partial Walkdown
   a. Inspection Scope
    The inspectors performed partial system walkdowns of the following risk-significant
    systems:
    *      January 5, 2011, residual heat removal system C
    *      February 14, 2011, diesel generator 1
    The inspectors selected these systems based on their risk significance relative to the
    reactor safety cornerstones at the time they were inspected. The inspectors attempted
    to identify any discrepancies that could affect the function of the system, and, therefore,
    potentially increase risk. The inspectors reviewed applicable operating procedures,
    system diagrams, FSAR, technical specification requirements, administrative technical
    specifications, outstanding work orders, condition reports, and the impact of ongoing
    work activities on redundant trains of equipment in order to identify conditions that could
    have rendered the systems incapable of performing their intended functions. The
    inspectors also inspected accessible portions of the systems to verify system
    components and support equipment were aligned correctly and operable. The
    inspectors examined the material condition of the components and observed operating
    parameters of equipment to verify that there were no obvious deficiencies. The
    inspectors also verified that the licensee had properly identified and resolved equipment
    alignment problems that could cause initiating events or impact the capability of
    mitigating systems or barriers and entered them into the corrective action program with
    the appropriate significance characterization. Specific documents reviewed during this
    inspection are listed in the attachment.
    These activities constitute completion of two partial system walkdown samples as
    defined in Inspection Procedure 71111.04-05.
  b. Findings
    No findings were identified.
1R05 Fire Protection (71111.05)
    Quarterly Fire Inspection Tours
  a. Inspection Scope
    The inspectors conducted fire protection walkdowns that were focused on availability,
    accessibility, and the condition of firefighting equipment in the following risk-significant
    plant areas:
                                          -5-                                   Enclosure
 
      *      January 6, 2011, fire area RC-4, division 1 switch gear room
      *      January 10, 2011, fire area R-8/1, low pressure core spray pump room
      *      January 12, 2011, fire area R-1/1, reactor building 522 elevation northwest
              quadrant
      *      February 14, 2011, fire area DG-2, division 1 diesel generator room
      *      February 16, 2011, fire area R-5, residual heat removal pump 2A room
      The inspectors reviewed areas to assess if licensee personnel had implemented a fire
      protection program that adequately controlled combustibles and ignition sources within
      the plant; effectively maintained fire detection and suppression capability; maintained
      passive fire protection features in good material condition; and had implemented
      adequate compensatory measures for out of service, degraded or inoperable fire
      protection equipment, systems, or features, in accordance with the licensees fire plan.
      The inspectors selected fire areas based on their overall contribution to internal fire risk
      as documented in the plants Individual Plant Examination of External Events with later
      additional insights, their potential to affect equipment that could initiate or mitigate a
      plant transient, or their impact on the plants ability to respond to a security event. Using
      the documents listed in the attachment, the inspectors verified that fire hoses and
      extinguishers were in their designated locations and available for immediate use; that
      fire detectors and sprinklers were unobstructed; that transient material loading was
      within the analyzed limits; and fire doors, dampers, and penetration seals appeared to
      be in satisfactory condition. The inspectors also verified that minor issues identified
      during the inspection were entered into the licensees corrective action program.
      Specific documents reviewed during this inspection are listed in the attachment.
      These activities constitute completion of five quarterly fire-protection inspection samples
      as defined in Inspection Procedure 71111.05-05.
  b. Findings
      No findings were identified.
1R11 Licensed Operator Requalification Program (71111.11)
.1    Quarterly Review
   a. Inspection Scope
   a. Inspection Scope
  To assess the performance effectiveness of the licensed operator requalification  
      On February 14, 2011, the inspectors observed a crew of licensed operators in the
program, the inspectors conducted personnel interviews, reviewed both the operating tests and written examinations, and observed ongoing operating test activities.  
      plants simulator to verify that operator performance was adequate, evaluators were
  The inspectors interviewed four licensee personnel, consisting of instructors and training  
      identifying and documenting crew performance problems, and training was being
management, to determine their understanding of the policies and practices for administering requalification examinations. The inspectors also reviewed operator performance on the written exams and operating tests. These reviews included observations of portions of the operating tests by the inspectors. The operating tests
      conducted in accordance with licensee procedures. The inspectors evaluated the
  - 8 - Enclosure observed included six job performance measures and three scenarios that were used in the current biennial requalification cycle. These observations allowed the inspectors to assess the licensee's effectiveness in conducting the operating test to ensure operator mastery of the training program content. The inspectors also reviewed medical records of six licensed operators for conformance to license conditions and the licensee's system for tracking qualifications and records of license reactivation for two operators.
      following areas:
  The results of these examinations were reviewed to determine the effectiveness of the licensee's appraisal of operator performance and to determine if feedback of performance analyses into the requalification training program was being accomplished.
                                            -6-                                  Enclosure
The inspectors interviewed members of the training department and reviewed six  
 
Licensee Event Reports to assess the responsiveness of the licensed operator requalification program to incorporate the lessons learned from plant events. In addition,  
    *      Licensed operator performance
the inspectors reviewed examination security measures, a sample of simulator performance test records (transient and steady
    *      Crews clarity and formality of communications
-state tests, malfunction tests, and scenario-based tests), simulator fidelity and existing logs of simulator deficiencies.  
    *      Crews ability to take timely actions in the conservative direction
  Examination results were assessed to determine if they were consistent with the guidance contained in NUREG
    *      Crews prioritization, interpretation, and verification of annunciator alarms
1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1, and NRC Manual Chapter
    *      Crews correct use and implementation of abnormal and emergency procedures
0609, Appendix I, "Operator Requalification Human Performance Significance Determination Process."
    *      Control board manipulations
  The inspectors completed one inspection sample of the biennial licensed operator requalification program.
    *      Oversight and direction from supervisors
  b. Findings No findings were identified.
    *      Crews ability to identify and implement appropriate technical specification
 
            actions and emergency plan actions and notifications
    The inspectors compared the crews performance in these areas to preestablished
    operator action expectations and successful critical task completion requirements.
    Specific documents reviewed during this inspection are listed in the attachment.
    These activities constitute completion of one quarterly licensed-operator requalification
    program sample as defined in Inspection Procedure 71111.11.
b. Findings
    No findings were identified.
.2  Biennial Inspection (71111.11B)
    The licensed operator requalification program involves two training cycles that are
    conducted over a 2-year period. In the first cycle, the annual cycle, the operators are
    administered an operating test consisting of job performance measures and simulator
    scenarios. In the second part of the training cycle, the biennial cycle, operators are
    administered an operating test and a comprehensive written examination.
a.  Inspection Scope
    To assess the performance effectiveness of the licensed operator requalification
    program, the inspectors conducted personnel interviews, reviewed both the operating
    tests and written examinations, and observed ongoing operating test activities.
    The inspectors interviewed four licensee personnel, consisting of instructors and training
    management, to determine their understanding of the policies and practices for
    administering requalification examinations. The inspectors also reviewed operator
    performance on the written exams and operating tests. These reviews included
    observations of portions of the operating tests by the inspectors. The operating tests
                                          -7-                                   Enclosure
 
    observed included six job performance measures and three scenarios that were used in
    the current biennial requalification cycle. These observations allowed the inspectors to
    assess the licensee's effectiveness in conducting the operating test to ensure operator
    mastery of the training program content. The inspectors also reviewed medical records
    of six licensed operators for conformance to license conditions and the licensees
    system for tracking qualifications and records of license reactivation for two operators.
    The results of these examinations were reviewed to determine the effectiveness of the
    licensees appraisal of operator performance and to determine if feedback of
    performance analyses into the requalification training program was being accomplished.
    The inspectors interviewed members of the training department and reviewed six
    Licensee Event Reports to assess the responsiveness of the licensed operator
    requalification program to incorporate the lessons learned from plant events. In addition,
    the inspectors reviewed examination security measures, a sample of simulator
    performance test records (transient and steady-state tests, malfunction tests, and
    scenario-based tests), simulator fidelity and existing logs of simulator deficiencies.
    Examination results were assessed to determine if they were consistent with the
    guidance contained in NUREG 1021, "Operator Licensing Examination Standards for
    Power Reactors," Revision 9, Supplement 1, and NRC Manual Chapter 0609,
    Appendix I, "Operator Requalification Human Performance Significance Determination
    Process."
    The inspectors completed one inspection sample of the biennial licensed operator
    requalification program.
b. Findings
    No findings were identified.
1R12 Maintenance Effectiveness (71111.12)
1R12 Maintenance Effectiveness (71111.12)
a. The inspectors evaluated degraded performance issues involving the following ris
  a. Inspection Scope
k- significant systems:
    The inspectors evaluated degraded performance issues involving the following risk-
Inspection Scope
    significant systems:
  February 22, 2011, TSP
    *        February 22, 2011, TSP-TURB-G001, "Turbine Overspeed Protection Valve
-TURB-G001, "Turbine Overspeed Protection Valve Disassembly and Inspection" March 2, 2011, Action Request/Condition Report 234859, "CRD
              Disassembly and Inspection"
-HCU-1843 scram outlet valve leaks by
    *        March 2, 2011, Action Request/Condition Report 234859, CRD-HCU-1843
March 2, 2011, Review of 10 CFR 50.65(a)(3) evaluation
              scram outlet valve leaks by"
The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and
    *        March 2, 2011, Review of 10 CFR 50.65(a)(3) evaluation
  - 9 - Enclosure independently verified the licensee's actions to address system performance or condition problems in terms of the following:
    The inspectors reviewed events such as where ineffective equipment maintenance has
  Implementing appropriate work practices
    resulted in valid or invalid automatic actuations of engineered safeguards systems and
  Identifying and addressing common cause failures
                                          -8-                                   Enclosure
 
 
Scoping of systems in accordance with 10 CFR 50.65(b)  
    independently verified the licensee's actions to address system performance or condition
 
    problems in terms of the following:
Characterizing
    *        Implementing appropriate work practices
system reliability issues for performance
    *        Identifying and addressing common cause failures
 
    *        Scoping of systems in accordance with 10 CFR 50.65(b)
Charging unavailability for performance
    *        Characterizing system reliability issues for performance
 
    *        Charging unavailability for performance
Trending key parameters for condition monitoring
    *        Trending key parameters for condition monitoring
  Ensuring proper classification in accordance with 10
    *        Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)
CFR 50.65(a)(1) or  
    *        Verifying appropriate performance criteria for structures, systems, and
-(a)(2)   Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1)
              components classified as having an adequate demonstration of performance
 
              through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the
              requiring the establishment of appropriate and adequate goals and corrective
inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.
              actions for systems classified as not having adequate performance, as described
 
              in 10 CFR 50.65(a)(1)
These activities constitute completion of three quarterly maintenance effectiveness sample s as defined in Inspection Procedure
    The inspectors assessed performance issues with respect to the reliability, availability,
71111.12-05. b. No findings were identified.
    and condition monitoring of the system. In addition, the inspectors verified maintenance
Findings 
    effectiveness issues were entered into the corrective action program with the appropriate
    significance characterization. Specific documents reviewed during this inspection are
    listed in the attachment.
    These activities constitute completion of three quarterly maintenance effectiveness
    samples as defined in Inspection Procedure 71111.12-05.
  b. Findings
    No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a. The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk
  a. Inspection Scope
-significant and safety
    The inspectors reviewed licensee personnel's evaluation and management of plant risk
-related equipment listed below to verify that the appropriate risk assessments were  
    for the maintenance and emergent work activities affecting risk-significant and safety-
performed prior to removing equipment for work:
    related equipment listed below to verify that the appropriate risk assessments were
Inspection Scope
    performed prior to removing equipment for work:
 
                                          -9-                                 Enclosure
  - 10 - Enclosure February 3, 2011, Action Request 233580, "500 KV Relay Set 1 Spurious Trip Tone Signals" March 1, 2011, Yellow risk due to I&C testing and removal of the 500 KV north bus from service
 
  March 7, 2011, Yellow
    *        February 3, 2011, Action Request 233580, "500 KV Relay Set 1 Spurious Trip
risk due to stator cooling water pump maintenance
              Tone Signals"
  The inspectors selected these activities based on potential risk significance relative to  
    *        March 1, 2011, Yellow risk due to I&C testing and removal of the 500 KV north
the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel
              bus from service
performed risk assessments as required by 10
    *        March 7, 2011, Yellow risk due to stator cooling water pump maintenance
CFR 50.65(a)(4) and that the assessments were accurate and complete. When licensee personnel  
    The inspectors selected these activities based on potential risk significance relative to
performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.
    the reactor safety cornerstones. As applicable for each activity, the inspectors verified
  These activities constitute completion of three maintenance risk assessments and emergent work control inspection sample
    that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)
s as defined in Inspection Procedure 71111.13-05.
    and that the assessments were accurate and complete. When licensee personnel
b. No findings were identified.
    performed emergent work, the inspectors verified that the licensee personnel promptly
Findings  1R15 Operability Evaluations (71111.15)
    assessed and managed plant risk. The inspectors reviewed the scope of maintenance
a. The inspectors reviewed the following issues:
    work, discussed the results of the assessment with the licensee's probabilistic risk
Inspection Scope
    analyst or shift technical advisor, and verified plant conditions were consistent with the
  January 5, 2011, Action Request/Condition Report 231738, "Diesel Generator 2  
    risk assessment. The inspectors also reviewed the technical specification requirements
Breaker Closing Spring will not DischargeJanuary 25, 2011, Action Request/Condition Report 232917, "Post Seal Cracks discovered on HPCS
    and inspected portions of redundant safety systems, when applicable, to verify risk
-B1-DG3February 1, 2011, Action Request/Condition Report 233290, "Emergency Siren  
    analysis assumptions were valid and applicable requirements were met. Specific
D-2 is Not Communicating" February 24, 2011, Action Request/Condition Report 234537, "Circuit Breaker Case is Cracked"
    documents reviewed during this inspection are listed in the attachment.
  - 11 - Enclosure February 28, 2011, Action Request/Condition Report 234766, "DMA
    These activities constitute completion of three maintenance risk assessments and
-FN-31 Electrical Phase Imbalance Noted at Motor Starter
    emergent work control inspection samples as defined in Inspection
The inspectors selected these potential operability issues based on the risk
    Procedure 71111.13-05.
significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred.
  b. Findings
  The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and FSAR to the licensee personnel's
    No findings were identified.
evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the  
1R15 Operability Evaluations (71111.15)
inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.
  a. Inspection Scope
  These activities constitute completion of five operability evaluations inspection samples
    The inspectors reviewed the following issues:
as defined in Inspection Procedure
    *        January 5, 2011, Action Request/Condition Report 231738, Diesel Generator 2
71111.15-04 b. No findings were identified.
              Breaker Closing Spring will not Discharge
Findings  1R18 Plant Modifications (71111.18)
    *        January 25, 2011, Action Request/Condition Report 232917, Post Seal Cracks
   a. Temporary Modifications
              discovered on HPCS-B1-DG3
To verify that the safety functions of important safety systems were not degraded, the  
    *        February 1, 2011, Action Request/Condition Report 233290, "Emergency Siren
inspectors reviewed the temporary modification identified as Temporary Modification TMR-11-008, "Crack in Weld Down Stream of BS
              D-2 is Not Communicating"
-V-52A" Inspection Scope
    *        February 24, 2011, Action Request/Condition Report 234537, "Circuit Breaker
  The inspectors reviewed the temporary modification
              Case is Cracked"
and the associated safety
                                          - 10 -                               Enclosure
-evaluation screening against the system design bases documentation, including the  
 
FSAR and the technical specifications, and verified that the modification
    *        February 28, 2011, Action Request/Condition Report 234766, DMA-FN-31
did not adversely affect the system operability/availability. The inspectors also verified that the installation and restoration were consistent with the modification documents and that configuration control was adequate. Additionally, the inspectors verified that the temporary modification was identified on control room drawings, appropriate tags were placed on the affected equipment, and licensee personnel evaluated the combined effects on mitigating systems and the integrity of radiological barriers.
              Electrical Phase Imbalance Noted at Motor Starter
  These activities constitute completion of  
    The inspectors selected these potential operability issues based on the risk significance
one sample for temporary plant modifications as defined in Inspection Procedure
    of the associated components and systems. The inspectors evaluated the technical
71111.18-05.  
    adequacy of the evaluations to ensure that technical specification operability was
  - 12 - Enclosure b. No findings were identified.
    properly justified and the subject component or system remained available such that no
Findings  1R19 Postmaintenance Testing (71111.19)
    unrecognized increase in risk occurred. The inspectors compared the operability and
a. The inspectors reviewed the following postmaintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
    design criteria in the appropriate sections of the technical specifications and FSAR to the
Inspection Scope
    licensee personnels evaluations to determine whether the components or systems were
  January 3, 2011, WO 01126278, E
    operable. Where compensatory measures were required to maintain operability, the
-CB-8/3, "Detailed Inspecti
    inspectors determined whether the measures in place would function as intended and
on of MOC Switch" February 3, 2011, Work Order 01192825, "LPCS
    were properly controlled. The inspectors determined, where appropriate, compliance
-P-2 - Replace Pump Power FrameFebruary 28, 2011, Work Order 01195224, " DG3 DMA-Fan-31 Post Maintenance TestingMarch 3, 2011, Work Order 01169668, "Replace FPC
    with bounding limitations associated with the evaluations. Additionally, the inspectors
-M-P/1AMarch 10, 2011, Work Request
    also reviewed a sampling of corrective action documents to verify that the licensee was
02000086, "SCW-P-2 Postmaintenance Testing" March 21, 2011, Work Request 29086232, "SEIS
    identifying and correcting any deficiencies associated with operability evaluations.
-RSA-1 Amber and Red Lights Will Not Reset" The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following:
    Specific documents reviewed during this inspection are listed in the attachment.
  The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed
    These activities constitute completion of five operability evaluations inspection samples
  Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate
    as defined in Inspection Procedure 71111.15-04
The inspectors evaluated the activities against the technical specifications, the FSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic  
  b. Findings
communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with postmaintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in  
    No findings were identified.
the attachment.
1R18 Plant Modifications (71111.18)
 
    Temporary Modifications
  - 13 - Enclosure These activities constitute completion of six postmaintenance testing inspection sample s as defined in Inspection Procedure
   a. Inspection Scope
71111.19-05. b. Introduction
    To verify that the safety functions of important safety systems were not degraded, the
: The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the failure to consider the  
    inspectors reviewed the temporary modification identified as Temporary Modification
impact of preconditioning on the emergency core cooling systems during keep fill pump maintenance in the work management process.
    TMR-11-008, "Crack in Weld Down Stream of BS-V-52A"
Findings  Description: On February 3, 2011, the inspectors identified that the work schedule for the keep fill pump maintenance performed on December 20, 2010, could have resulted in the unacceptable preconditioning of the low pressure core spray system. The licensee was scheduled to start the low pressure core spray pump to perform Surveillance Procedure SOP
    The inspectors reviewed the temporary modification and the associated safety-
-LPCS-SP, "LPCS Suppression Pool Mixing," to support keep fill pump maintenance on the low pressure core spray system. During low pressure core spray pump start, the minimum flow valve strokes open to protect the pump from damage. The low pressure core spray minimum flow valve is scoped into the licensee's inservice testing program; which requires the licensee to test the valve in an  
    evaluation screening against the system design bases documentation, including the
    FSAR and the technical specifications, and verified that the modification did not
    adversely affect the system operability/availability. The inspectors also verified that the
    installation and restoration were consistent with the modification documents and that
    configuration control was adequate. Additionally, the inspectors verified that the
    temporary modification was identified on control room drawings, appropriate tags were
    placed on the affected equipment, and licensee personnel evaluated the combined
    effects on mitigating systems and the integrity of radiological barriers.
    These activities constitute completion of one sample for temporary plant modifications as
    defined in Inspection Procedure 71111.18-05.
                                          - 11 -                               Enclosure
 
  b. Findings
    No findings were identified.
1R19 Postmaintenance Testing (71111.19)
  a. Inspection Scope
    The inspectors reviewed the following postmaintenance activities to verify that
    procedures and test activities were adequate to ensure system operability and functional
    capability:
    *      January 3, 2011, WO 01126278, E-CB-8/3, "Detailed Inspection of MOC Switch"
    *      February 3, 2011, Work Order 01192825, LPCS-P-2 - Replace Pump Power
            Frame
    *      February 28, 2011, Work Order 01195224, " DG3 DMA-Fan-31 Post Maintenance
            Testing
    *      March 3, 2011, Work Order 01169668, Replace FPC-M-P/1A
    *      March 10, 2011, Work Request 02000086, "SCW-P-2 Postmaintenance Testing"
    *      March 21, 2011, Work Request 29086232, "SEIS-RSA-1 Amber and Red Lights
            Will Not Reset"
    The inspectors selected these activities based upon the structure, system, or
    component's ability to affect risk. The inspectors evaluated these activities for the
    following:
    *      The effect of testing on the plant had been adequately addressed; testing was
            adequate for the maintenance performed
    *      Acceptance criteria were clear and demonstrated operational readiness; test
            instrumentation was appropriate
    The inspectors evaluated the activities against the technical specifications, the FSAR, 10
    CFR Part 50 requirements, licensee procedures, and various NRC generic
    communications to ensure that the test results adequately ensured that the equipment
    met the licensing basis and design requirements. In addition, the inspectors reviewed
    corrective action documents associated with postmaintenance tests to determine
    whether the licensee was identifying problems and entering them in the corrective action
    program and that the problems were being corrected commensurate with their
    importance to safety. Specific documents reviewed during this inspection are listed in
    the attachment.
                                        - 12 -                               Enclosure
 
  These activities constitute completion of six postmaintenance testing inspection samples
  as defined in Inspection Procedure 71111.19-05.
b. Findings
  Introduction: The inspectors identified a noncited violation of 10 CFR Part 50, Appendix
  B, Criterion V, Instructions, Procedures, and Drawings, for the failure to consider the
  impact of preconditioning on the emergency core cooling systems during keep fill pump
  maintenance in the work management process.
  Description: On February 3, 2011, the inspectors identified that the work schedule for
  the keep fill pump maintenance performed on December 20, 2010, could have resulted
  in the unacceptable preconditioning of the low pressure core spray system. The
  licensee was scheduled to start the low pressure core spray pump to perform
  Surveillance Procedure SOP-LPCS-SP, LPCS Suppression Pool Mixing, to support
  keep fill pump maintenance on the low pressure core spray system. During low
  pressure core spray pump start, the minimum flow valve strokes open to protect the
  pump from damage. The low pressure core spray minimum flow valve is scoped into the
  licensees inservice testing program; which requires the licensee to test the valve in an
  as-found condition without preconditioning of the valve prior to inservice testing.
  Preconditioning, as defined in the licensees inservice testing program, is the
  manipulation of the physical condition of a component before technical specification
  surveillance testing. Unacceptable preconditioning is further defined to be
  preconditioning that alters one or more attributes of components which results in
  acceptable test results. The licensees definition of unacceptable preconditioning goes
  on to further state that any activity performed prior to an inservice test which results in
  acceptable test results, but may have adversely affected the ability to monitor the
  component for degradation. Once the keep fill pump maintenance was completed, the
  licensee was scheduled to complete the required technical specification surveillance test
  on the low pressure core spray system. This technical specification surveillance test is
  used to test the time the low pressure core spray minimum flow valve takes to stroke
  from fully closed to fully open, among other attributes of the low pressure core spray
  system. This test is performed to ensure the low pressure core spray system can meet
  its specified design function, and to detect a degrading performance trend before
  operability is challenged.
  The inspectors reviewed the licensees technical position on preconditioning within its
  inservice testing program plan to determine what the licensee had defined to be
  unacceptable preconditioning. The inspectors identified that one of the examples of
  unacceptable preconditioning listed in the licensees inservice testing program was the
  exercising of a motor-operated valve other than for test configurations or normal system
  operation prior to a surveillance test on the valve. The inspectors also reviewed NRC
  Inspection Manual Chapter 9900, "Maintenance-Preconditioning of Structures, Systems,
  and Components Before Determining Operability." The inspectors noted that
  preconditioning could mask the actual as-found condition of components and possibly
  result in an inability to verify the operability of components. The inspectors also noted in
  the NRC technical guidance, that the scheduling of apparently unrelated activities could
                                          - 13 -                              Enclosure
 
result in unacceptable preconditioning. The inspectors determined that the scheduling of
the keep fill pump maintenance, which requires the starting of the low pressure core
spray system and the cycling of the minimum flow valve, prior to technical specification
surveillance testing constituted unacceptable preconditioning by the licensee.
The inspectors reviewed keep fill pump maintenance scheduling records for the previous
three years and noted the following additional occurrences of unacceptable
preconditioning on emergency core cooling systems:
*  4/22/2008 high pressure core spray system started for keep fill pump maintenance.
    4/25/2008 high pressure core spray system started for technical specification
    surveillance testing.
*  7/14/2008 high pressure core spray system started for keep fill pump maintenance.
    7/18/2008 high pressure core spray system started for technical specification
    surveillance testing.
*  10/7/2008 high pressure core spray system started for keep fill pump maintenance.
    10/8/2008 high pressure core spray system started for technical specification
    surveillance testing.
*  11/23/2009 low pressure core spray system started for keep fill pump maintenance.
    11/27/2009 low pressure core spray system started for technical specification
    surveillance testing.
*  5/17/2010 high pressure core spray system started for keep fill pump maintenance.
    5/19/2010 high pressure core spray system started for technical specification
    surveillance testing.
*  8/11/2010 high pressure core spray system started for keep fill pump maintenance.
    8/14/2010 high pressure core spray system started for technical specification
    surveillance testing.
*  9/8/2010 high pressure core spray system started for keep fill pump maintenance.
    9/8/2010 high pressure core spray system started for technical specification
    surveillance testing.
*  2/2/2011 residual heat removal system, train C, started for keep fill pump
    maintenance.
    2/3/2011 residual heat removal system, train C, started for technical specification
    surveillance testing.
The inspectors determined, through interviews with the licensees staff, the licensee did
not have clear guidance on how to avoid preconditioning of components during the
scheduling of work or how to resolve issues of preconditioning when identified.
Analysis: The failure to consider preconditioning during the work scheduling process is
a performance deficiency. This performance deficiency is more than minor because it
                                  - 14 -                                  Enclosure


as-found condition without preconditioning of the valve prior to inservice testing.  Preconditioning, as defined in the licensee's inservice testing program, "is the manipulation of the physical condition of a component before technical specification
    affects the equipment performance attribute of the Mitigating Systems Cornerstone
surveillance testing."  Unacceptable preconditioning is further defined to be preconditioning that alters one or more attributes of components which results in acceptable test results.  The licensee's definition of unacceptable preconditioning goes on to further state that "any activity performed prior to an inservice test which results in acceptable test results, but may have adversely affected the ability to monitor the component for degradation."  Once the keep fill pump maintenance was completed, the
    objective of ensuring the reliability of systems that respond to initiating events.
licensee was scheduled to complete the required technical specification surveillance test on the low pressure core spray system.  This technical specification surveillance test is used to test the time the low pressure core spray minimum flow valve takes to stroke from fully closed to fully
    Specifically, the improper scheduling of maintenance and surveillance activities could
open, among other attributes of the low pressure core spray system.  This test is performed to ensure the low pressure core spray
    mask a degraded condition such that systems would be unable to perform their intended
system can meet its specified design function, and to detect a degrading performance trend before operability is challenged.
    safety function when called upon. Using Inspection Manual Chapter 0609.04,
  The inspectors reviewed the licensee's technical position
    Phase 1 - Initial Screening and Characterization of Findings, the inspectors
on preconditioning within its inservice testing program plan to determine what the licensee had defined to be unacceptable preconditioning.  The inspectors identified that one of the examples of unacceptable preconditioning listed in the licensee's inservice testing program was the exercising of a motor
    determined this performance deficiency was of very low safety significance because the
-operated valve other than for test configurations or normal system operation prior to a surveillance test on the valve.  The inspectors also reviewed NRC
    finding was confirmed to not result in a loss of operability for the emergency core cooling
Inspection Manual Chapter 9900, "Maintenance
    systems. During interviews with plant personnel the inspectors identified a cross-cutting
-Preconditioning of Structures, Systems, and Components Before Determining Operability
    issue in the area of human performance, work practices, because the licensee failed to
."  The inspectors noted that preconditioning could mask the actual as
    effectively communicate expectations regarding procedural compliance. In that, the
-found condition of components and possibly result in an inability to verify the operability of components.  The inspectors also noted in the NRC technical guidance, that the scheduling of apparently unrelated activities could 
    licensee failed to give clear guidance to work week managers in preparing work
  - 14 - Enclosure result in unacceptable preconditioning.  The inspectors determined that the scheduling of the keep fill pump maintenance, which requires the starting of the low pressure core spray system and the cycling of the minimum flow valve, prior to technical specification surveillance testing constituted unacceptable preconditioning by the licensee.
    schedules [H.4.b].
  The inspectors reviewed keep fill pump maintenance scheduling records for the previous three years and noted the following additional occurrences of unacceptable preconditioning on emergency core cooling systems:
    Enforcement: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,
  4/22/2008 high pressure core spray system started for keep fill pump maintenance.
    and Drawings, requires, in part, that activities affecting quality shall be prescribed by
4/25/2008 high pressure core spray system started for technical specification surveillance testing.
    documented procedures of a type appropriate to the circumstance and shall be
  7/14/2008 high pressure core spray system started for keep fill pump maintenance.
    accomplished in accordance with those procedures. Contrary to this, from 2008 through
7/18/2008 high pressure core spray system started for technical specification
    2010, the licensee failed to ensure aspects of preconditioning are considered during
surveillance testing.
    scheduling of work as specified in Procedure 1.3.68, Work Management Process. This
  10/7/2008 high pressure core spray system starte
    caused the licensee to fail to realize the scheduling of emergency core cooling systems
d for keep fill pump maintenance.
    keep fill pump maintenance prior to quarterly scheduled surveillance testing constituted
10/8/2008 high pressure core spray system started for technical specification
    unacceptable preconditioning. This violation was identified on February 3, 2011.
surveillance testing.
    Because this finding was determined to be of very low safety significance and was
  11/23/2009 low pressure core spray system started for keep fill pump maintenance.
    entered into the licensees corrective action program as Action Request/Condition
11/27/2009 low pressure core spray system started for technical specification
    Report 236880, this violation is being treated as a noncited violation consistent with
surveillance testing.
    Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000397/2011002-01, Failure to
  5/17/2010 high pressure core spray system started for keep fill pump maintenance.
    Ensure Unacceptable Preconditioning is Considered During the Work Management
5/19/2010 high pressure core spray system started for technical specification
    Process.
surveillance testing.
  8/11/2010 high
pressure core spray system started for keep fill pump maintenance.
8/14/2010 high pressure core spray system started for technical specification
surveillance testing.
  9/8/2010 high pressure core spray system started for keep fill pump maintenance.
9/8/2010 high pressure core spray system started for technical specification
surveillance testing.
  2/2/2011 residual heat removal system, train
C , started for keep fill pump maintenance.
2/3/2011 residual heat removal
system, train
C , started for technical specification surveillance testing.
The inspectors determined , through interviews with the licensee's staff ,  the licensee did not have clear guidance on how to avoid preconditioning of components during the scheduling of work or how to resolve issues of preconditioning when identified.
  Analysis:  The failure to consider preconditioning during the work scheduling process is a performance deficiency.  This performance
deficiency is more than minor because it 
  - 15 - Enclosure affects the equipment performance attribute of the Mitigating Systems Cornerstone objective of ensuring the reliability of systems that respond to initiating events. Specifically, the improper scheduling of maintenance and surveillance activities could mask a degraded condition such that systems would be unable to perform their intended safety function when called upon. Using Inspection Manual Chapter 0609.04, "Pha se 1 - Initial Screening and Characterization of Findings," the inspectors determined this performance deficiency was of very low safety significance because the finding was confirmed to not result in a loss of operability for the emergency core cooling systems. During interviews with plant personnel t
he inspectors identified a cross
-cutting issue in the area of human performance, work practices, because the licensee failed to  
effectively communicate expectations regarding procedural compliance. In that, the  
licensee failed to give clear guidance to work week managers in preparing work schedules [H.4.b].
  Enforcement: Title 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part , that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstance and shall be accomplished in accordance with those procedures. Contrary to this, from 2008 through 2010, the licensee failed to ensure aspects of preconditioning are considered during scheduling of work as specified in Procedure 1.3.68, "Work Management Process". This caused the licensee to fail to realize the scheduling of emergency core cooling systems
keep fill pump maintenance prior to quarterly scheduled surveillance testing constituted unacceptable preconditioning. This violation was identified on February 3, 2011. Because this finding was determined to be of very low safety significance and was entered into the licensee's corrective action program as Action Request/Condition  
Report 23 6880, this violation is being treated as a noncited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000397/2011002
-01, "Failure to Ensure Unacceptable Preconditioning is Considered During the Work Management  
Process.
1R22 Surveillance Testing (71111.22)
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
  a. Inspection Scope
The inspectors reviewed the FSAR , procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the  
    The inspectors reviewed the FSAR, procedure requirements, and technical
following:
    specifications to ensure that the surveillance activities listed below demonstrated that the
  Preconditioning
    systems, structures, and/or components tested were capable of performing their
 
    intended safety functions. The inspectors either witnessed or reviewed test data to
Evaluation of testing impact on the plant
    verify that the significant surveillance test attributes were adequate to address the
 
    following:
Acceptance criteria
    *        Preconditioning
 
    *        Evaluation of testing impact on the plant
  - 16 - Enclosure Test equipment
    *        Acceptance criteria
  Procedures
                                          - 15 -                                 Enclosure
  Jumper/lifted lead controls
 
 
*      Test equipment
Test data   Testing frequency and method demonstrated technical specification operability
*      Procedures
  Test equipment removal
*      Jumper/lifted lead controls
 
*      Test data
Restoration of plant systems
*      Testing frequency and method demonstrated technical specification operability
  Fulfillment of ASME Code requirements
*      Test equipment removal
 
*      Restoration of plant systems
Updating of performance indicator data
*      Fulfillment of ASME Code requirements
  Engineering
*      Updating of performance indicator data
evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct
*      Engineering evaluations, root causes, and bases for returning tested systems,
 
      structures, and components not meeting the test acceptance criteria were correct
Reference setting data
*      Reference setting data
 
*      Annunciators and alarms setpoints
Annunciators and alarms setpoints
The inspectors also verified that licensee personnel identified and implemented any
  The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.  
needed corrective actions associated with the surveillance testing.
  January 5, 2011, Work Order 01194716, OSP
*      January 5, 2011, Work Order 01194716, OSP-RHR/IST-Q704, RHR Loop C
-RHR/IST-Q704, "RHR Loop C Operability Test"
      Operability Test
  January 5, 2011, OSP
*      January 5, 2011, OSP-RHR-M103, "Fill Verification RHR-C System"
-RHR-M103, "Fill Verification RHR
*      January 24, 2011, Work Order 01194381, ISP-RFW-Q401, "Feedwater/Turbine
-C System" January 24, 2011, Work Order 01194381, ISP
      Trip Reactor Level 8 Channel Functional Test
-RFW-Q401, "Feedwater/Turbine Trip Reactor Level 8 Channel Functional Test
*      February 2, 2011, ISP-MS-Q935, "Division 2 Channel D Isolation Actuation on
February 2, 2011, ISP
      Reactor Level 2 - CFT/CC"
-MS-Q935, "Division 2 Channel D Isolation Actuation on Reactor Level 2
*      February 7, 2011, Work Order 01194835, ISP-RCIC-Q903, RCIC Isolation on
- CFT/CC" February 7, 2011, Work Order 01194835, ISP
      RCIC Steam Supply Flow High DIV 2 - CFT/CC
-RCIC-Q903, "RCIC Isolation on RCIC Steam Supply Flow High DIV 2  
*      February 8, 2011, Work Order 01194837, "RCIC Isolation on RCIC Steam Supply
- CFT/CCFebruary 8, 2011, Work Order 01194837, "RCIC Isolation on RCIC Steam Supply  
      Flow High Division 1 - Channel Functional Tests and Channel Calibration"
Flow High Division 1  
*      February 22, 2011, Work Order 01193731, "Control Rod Settle Time Test"
- Channel Functional Tests and Channel Calibration" February 22, 2011, Work Order 01193731, "Control Rod Settle Time Test"
                                    - 16 -                             Enclosure
  - 17 - Enclosure Specific documents reviewed during this inspection are listed in the attachment.
 
  These activities constitute completion of seven surveillance testing inspection sample s as defined in Inspection Procedure
      Specific documents reviewed during this inspection are listed in the attachment.
71111.22-05. b. No findings were identified.  
      These activities constitute completion of seven surveillance testing inspection samples
Findings  Cornerstone: Emergency Preparedness
      as defined in Inspection Procedure 71111.22-05.
1EP6 Drill Evaluation (71114.06)
  b. Findings
  Training Observations
      No findings were identified.
a. The inspectors observed a simulator training evolution for licensed operators on January 11, 2011, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the postevolution critique for the scenario. The focus of the inspectors' activities was to note any weaknesses and deficiencies in the crew's performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the attachment.
Cornerstone: Emergency Preparedness
Inspection Scope
1EP6 Drill Evaluation (71114.06)
 
      Training Observations
These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05. b. No findings were identified.
  a. Inspection Scope
Findings  4. OTHER ACTIVITIES
      The inspectors observed a simulator training evolution for licensed operators on January
4OA1 Performance Indicator Verification (71151)
      11, 2011, which required emergency plan implementation by a licensee operations crew.
.1 Data Submission Issue
      This evolution was planned to be evaluated and included in performance indicator data
a. The inspectors performed
      regarding drill and exercise performance. The inspectors observed event classification
a review of the performance indicator data submitted by the licensee for the fourth Quarter 2010 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, "Performance Indicator Program." Inspection Scope
      and notification activities performed by the crew. The inspectors also attended the
 
      postevolution critique for the scenario. The focus of the inspectors activities was to note
  - 18 - Enclosure This review was performed as part of the inspectors' normal plant status activities and, as such, did not constitute a separate inspection sample.  
      any weaknesses and deficiencies in the crews performance and ensure that the
  b. No findings were identified.  
      licensee evaluators noted the same issues and entered them into the corrective action
Findings  .2 Unplanned Scrams per 7000 Critical Hours (IE01)
      program. As part of the inspection, the inspectors reviewed the scenario package and
a. The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical hours performance indicator for the period from the first quarter 20 10 through the fourth quarter 20 10. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used
      other documents listed in the attachment.
definitions and guidance contained in NEI Document 99
      These activities constitute completion of one sample as defined in Inspection
-02, "Regulatory Assessment Performance Indicator Guideline," Revision  
      Procedure 71114.06-05.
6. The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports , and NRC integrated inspection reports for the period of January 2010
  b. Findings
through December 2010
      No findings were identified.
, to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.
4.   OTHER ACTIVITIES
Inspection Scope
4OA1 Performance Indicator Verification (71151)
  These activities constitute completion of  
.1   Data Submission Issue
one unplanned scrams per 7000 critical hours sample as defined in Inspection Procedure
  a. Inspection Scope
71151-05.
      The inspectors performed a review of the performance indicator data submitted by the
b. No findings were identified.
      licensee for the fourth Quarter 2010 performance indicators for any obvious
Findings  .3 Unplanned Scrams with Complications (IE02)
      inconsistencies prior to its public release in accordance with Inspection Manual
a. The inspectors sampled licensee submittals for the unplanned scrams with complications
      Chapter 0608, Performance Indicator Program.
performance indicator for the period from the first quarter 2010 through the fourth quarter 2010. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99
                                          - 17 -                               Enclosure
-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports
 
, and NRC integrated inspection reports for the period of January 2010 through December 2010, to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any  
      This review was performed as part of the inspectors normal plant status activities and,
problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are  
      as such, did not constitute a separate inspection sample.
described in the attachment to this report.
  b. Findings
Inspection Scope
      No findings were identified.
 
.2   Unplanned Scrams per 7000 Critical Hours (IE01)
  - 19 - Enclosure These activities constitute completion of  
  a. Inspection Scope
one unplanned scrams with complications sample as defined in Inspection Procedure
      The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical
71151-05. b. No findings were identified.
      hours performance indicator for the period from the first quarter 2010 through the fourth
Findings  .4 Unplanned Power Changes per 7000 Critical Hours (IE03)
      quarter 2010. To determine the accuracy of the performance indicator data reported
a. The inspectors sampled licensee submittals for the unplanned power changes per 7000 critical hours performance indicator for the period from the first quarter 2010 through the fourth quarter 2010. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99
      during those periods, the inspectors used definitions and guidance contained in NEI
-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator narrative logs, issue reports, maintenance rule records, event reports
      Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6.
, and NRC integrated inspection reports for the period of January 2010 through December 2010, to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data
      The inspectors reviewed the licensees operator narrative logs, issue reports, event
collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.
      reports, and NRC integrated inspection reports for the period of January 2010 through
Inspection Scope
      December 2010, to validate the accuracy of the submittals. The inspectors also
  These activities constitute completion of  
      reviewed the licensees issue report database to determine if any problems had been
one unplanned transients per 7000 critical hours sample as defined in Inspection Procedure
      identified with the performance indicator data collected or transmitted for this indicator
71151-05.
      and none were identified. Specific documents reviewed are described in the attachment
b. No findings were identified.
      to this report.
Findings  4OA2 Identification and Resolution of Problems (71152)
      These activities constitute completion of one unplanned scrams per 7000 critical hours
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency  
      sample as defined in Inspection Procedure 71151-05.
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection
  b. Findings
.1 Routine Review of Identification and Resolution of Problems
      No findings were identified.
a. As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety Inspection Scope
.3   Unplanned Scrams with Complications (IE02)
 
  a. Inspection Scope
  - 20 - Enclosure significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensee's corrective action program because of the inspectors' observations are included in the attached list of documents reviewed. These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during
      The inspectors sampled licensee submittals for the unplanned scrams with
the quarter and documented in Section 1 of this report.
      complications performance indicator for the period from the first quarter 2010 through
 
      the fourth quarter 2010. To determine the accuracy of the performance indicator data
b. No findings were identified.
      reported during those periods, the inspectors used definitions and guidance contained in
Findings  .2 Daily Corrective Action Program Reviews
      NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,
a. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow
      Revision 6. The inspectors reviewed the licensees operator narrative logs, issue
-up, the inspectors performed a daily screening of items entered into the licensee's corrective action program. The inspectors  
      reports, event reports, and NRC integrated inspection reports for the period of January
accomplished this through review of the station's daily corrective action documents.
      2010 through December 2010, to validate the accuracy of the submittals. The
Inspection Scope
      inspectors also reviewed the licensees issue report database to determine if any
  The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.
      problems had been identified with the performance indicator data collected or
  b. No findings were identified.
      transmitted for this indicator and none were identified. Specific documents reviewed are
Findings  .3 Selected Issue Follow
      described in the attachment to this report.
-up Inspection
                                          - 18 -                               Enclosure
a. During a review of items entered in the licensee's corrective action program, the inspectors recognized a corrective action item documenting the low pressure core spray system's minimum flow valve losing position indication during surveillance testing.
 
  The inspectors were concerned that the issue was reportable to the NRC and that the licensee had failed to do so.
      These activities constitute completion of one unplanned scrams with complications
Inspection Sc
      sample as defined in Inspection Procedure 71151-05.
ope  These activities constitute completion of one
  b. Findings
in-depth selected issue follow
      No findings were identified.
-up inspection
.4   Unplanned Power Changes per 7000 Critical Hours (IE03)
sample as defined in Inspection Procedure 7115
  a. Inspection Scope
2-05.  
      The inspectors sampled licensee submittals for the unplanned power changes per 7000
  - 21 - Enclosure b. Introduction: The inspectors identified a Severity Level IV violation of Title 10 CFR 50.72(b)(3)(v)(D) for the failure of the licensee to make a non
      critical hours performance indicator for the period from the first quarter 2010 through the
-emergency event notification to the NRC. Specifically, the licensee failed to report
      fourth quarter 2010. To determine the accuracy of the performance indicator data
the low pressure core spray minimum flow valve failing to open on December 20, 2010, rendering the low pressure core spray system incapable of performing its specified safety function, during testing. Findings  Description: On December 20, 2010, while performing Surveillance Procedure SOP
      reported during those periods, the inspectors used definitions and guidance contained in
-LPCS-SP, "LPCS Suppression Pool Mixing," in support of scheduled maintenance, the low pressure core spray minimum flow valve failed to open as expected. The low  
      NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,
pressure core spray minimum flow valve is a motor
      Revision 6. The inspectors reviewed the licensees operator narrative logs, issue
-operated valve which is required to open when the low pressure core spray system is started. This is done to establish a  
      reports, maintenance rule records, event reports, and NRC integrated inspection reports
flow path from the suppression pool, back to the suppression pool until a flow path can be established to the reactor vessel to prevent overheating and
      for the period of January 2010 through December 2010, to validate the accuracy of the
damage to the low pressure core spray pump and motor. The low pressure core spray system was  
      submittals. The inspectors also reviewed the licensees issue report database to
subsequently declared inoperable and an investigation team was assembled to determine the cause of the failure. The investigation team determined that two of th
      determine if any problems had been identified with the performance indicator data
e three fuses associated with the low pressure core spray motor starter showed internal melting and discoloration while the third fuse did not. The licensee replaced all three fuses and performed testing on the low pressure core spray motor starter and returned the low pressure core spray system to an operable status.
      collected or transmitted for this indicator and none were identified. Specific documents
  The inspectors questioned the licensee on whether the low pressure core spray system was capable of performing its specified safety function, at the time of discovery, when the minimum flow valve failed to open. The inspectors referred to NUREG
      reviewed are described in the attachment to this report.
-1022, "Event Reporting Guidelines 10 CFR 50.72 and 73," Revision 2, and noted the following under Section 3.2.7, "Event or Condition That Could Have Prevented Fulfillment of a Safety Function":
      These activities constitute completion of one unplanned transients per 7000 critical
   The intent of these criteria is to capture those events when there would have been a failure of a safety system to properly complete a safety function.
      hours sample as defined in Inspection Procedure 71151-05.
  These criteria cover an event or condition where structures, components, or trains of a safety system could have failed to perform their intended function because of: [-] equipment failures.
  b. Findings
  The event must be reported regardless of whether or not an alternate safety system could have been used to perform the safety function.
      No findings were identified.
  There are a limited number of single train systems that perform safety functions. For such systems, loss of the single train would prevent the fulfillment of the  
4OA2 Identification and Resolution of Problems (71152)
safety function of that system and, therefore, is reportable.
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
The inspectors presented their questions to the licensee on December 29, 2010. The licensee prepared a position paper that summarized the low pressure core spray system was not a single train system for reporting purposes, but that it was a redundant system
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical
  - 22 - Enclosure to both the residual heat removal system and the high pressure core spray system. Therefore, the reporting requirement would not be met due to the previously mentioned systems being able to provide the appropriate safety function. The licensee position paper was presented to the inspectors on January 6, 2011. The inspectors reviewed the FSAR and consulted with NRC regional, headquarters, and training staff to determine the treatment of the low pressure core spray system for reporting purposes. After review, the inspectors determined the low pressure core spray system was a single train system and the failure of the minimum flow valve to open was a reportable condition. The licensee submitted Event Notification 46604 to the Headquarters Operations Officer on February 8, 2011.
Protection
  Analysis: The failure to report a condition that could have prevented the fulfillment of a system's safety function is a performance deficiency. This finding is more than minor because the NRC relies on licensees to identify and report conditions or events meeting  
.1   Routine Review of Identification and Resolution of Problems
the criteria specified in the regulations in order to perform its regulatory function. Using Inspection Manual Chapter 0612, the inspectors determined that this performance  
  a. Inspection Scope
deficiency was not appropriate to evaluate using the NRC's Significance Determination Process due to the finding only affecting the NRC's ability to perform its regulatory oversight function. As a result, this performance deficiency was evaluated for traditional enforcement in accordance with the NRC Enforcement Policy. This performance deficiency was determined to
      As part of the various baseline inspection procedures discussed in previous sections of
be a Severity Level IV violation in accordance with Section 6.9.d.9 of the NRC Enforcement Policy, dated September 30, 2010. The inspectors determined that assigning a cross
      this report, the inspectors routinely reviewed issues during baseline inspection activities
-cutting aspect was not applicable to this performance deficiency due to the performance deficiency being screened exclusively using the traditional enforcement process.
      and plant status reviews to verify that they were being entered into the licensees
  Enforcement: Title 10 CFR 50.72(b)(3)(v)(D) requires, in part, that licensees shall notify the NRC within eight hours of the occurrence of an event or condition that
      corrective action program at an appropriate threshold, that adequate attention was being
at the time of discovery could have prevented the fulfillment of the safety function of systems that are needed to mitigate the consequences of an accident. Contrary to this requirement, on December 20, 2010, the licensee failed to report to the NRC a condition that could have, at the time of discovery, prevented the low pressure core spray system from fulfilling its  
      given to timely corrective actions, and that adverse trends were identified and
safety function. This violation was identified on December 28, 2010. The licensee made Event Notification 46604 on February 8, 2011. As a corrective action the licensee has informed all current shift managers, and plans to train future senior reactor operators, of  
      addressed. The inspectors reviewed attributes that included the complete and accurate
the expectation to evaluate low pressure core spray system failures as a failure of a single train system to complete a safety function. There w as no actual or potential safety consequences
      identification of the problem; the timely correction, commensurate with the safety
associated with this violation. Because this violation was placed into the licensee's corrective action program as Action Request/Condition Report 23 6879, compliance was restored within a reasonable amount of time, the violation was not repetitive, or willful, this Severity Level IV violation is being treated as a noncited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000397/2011002, "Failure to Make Required Event Notification"
                                          - 19 -                               Enclosure
.
 
   
      significance; the evaluation and disposition of performance issues, generic implications,
  - 23 - Enclosure .4 Assessment of Licensee Improvement Efforts
      common causes, contributing factors, root causes, extent of condition reviews, and
  a. The inspectors reviewed the following issue:
      previous occurrences reviews; and the classification, prioritization, focus, and timeliness
Inspection Scope
      of corrective actions. Minor issues entered into the licensees corrective action program
  March 2, 2011, Action Request/Condition Report 222076, Pride and  
      because of the inspectors observations are included in the attached list of documents
Performance Completion Sample  
      reviewed.
- Equipment Reliability , items 12 and 30
      These routine reviews for the identification and resolution of problems did not constitute
  The inspectors determined that the licensee has effectively identified systems and  
      any additional inspection samples. Instead, by procedure, they were considered an
components necessary to control reactor power, reactor pressure and reactor level and have accurately assessed the reliability of such systems and component
      integral part of the inspections performed during the quarter and documented in
s. These activities constitute completion of one
      Section 1 of this report.
in-depth problem identification and resolution sample as defined in Inspection Procedure 71152
  b. Findings
-05. b. No findings were identified.
      No findings were identified.
Findings  4OA3 Event Follow
.2   Daily Corrective Action Program Reviews
-up (71153)
  a. Inspection Scope
.1 (Closed) Licensee Event Report (LER) 05000397/2010
      In order to assist with the identification of repetitive equipment failures and specific
-002-00: LPCS Minimum Flow Valve Failed to Open Due to Premature Fuse Failure at the Solder Joint
      human performance issues for follow-up, the inspectors performed a daily screening of
  This LER documented a failure of the low pressure core spray minimum flow valve to open during surveillance testing, rendering the low pressure core spray system  
      items entered into the licensees corrective action program. The inspectors
inoperable and unable to perform its specified safety function. See Section 4OA5 of  
      accomplished this through review of the stations daily corrective action documents.
NRC Inspection Report 05000397/2011002 for a discussion of an NRC identified violation associated with this event. The inspectors completed a review of this LER and did not identify any other violations of regulatory requirements or findings associated with this event. This LER is closed.
      The inspectors performed these daily reviews as part of their daily plant status
 
      monitoring activities and, as such, did not constitute any separate inspection samples.
  b. Findings
      No findings were identified.
.3   Selected Issue Follow-up Inspection
  a. Inspection Scope
      During a review of items entered in the licensees corrective action program, the
      inspectors recognized a corrective action item documenting the low pressure core spray
      systems minimum flow valve losing position indication during surveillance testing. The
      inspectors were concerned that the issue was reportable to the NRC and that the
      licensee had failed to do so.
      These activities constitute completion of one in-depth selected issue follow-up inspection
      sample as defined in Inspection Procedure 71152-05.
                                            - 20 -                                 Enclosure
 
b. Findings
  Introduction: The inspectors identified a Severity Level IV violation of Title 10 CFR
  50.72(b)(3)(v)(D) for the failure of the licensee to make a non-emergency event
  notification to the NRC. Specifically, the licensee failed to report the low pressure core
  spray minimum flow valve failing to open on December 20, 2010, rendering the low
  pressure core spray system incapable of performing its specified safety function, during
  testing.
  Description: On December 20, 2010, while performing Surveillance Procedure SOP-
  LPCS-SP, LPCS Suppression Pool Mixing, in support of scheduled maintenance, the
  low pressure core spray minimum flow valve failed to open as expected. The low
  pressure core spray minimum flow valve is a motor-operated valve which is required to
  open when the low pressure core spray system is started. This is done to establish a
  flow path from the suppression pool, back to the suppression pool until a flow path can
  be established to the reactor vessel to prevent overheating and damage to the low
  pressure core spray pump and motor. The low pressure core spray system was
  subsequently declared inoperable and an investigation team was assembled to
  determine the cause of the failure. The investigation team determined that two of the
  three fuses associated with the low pressure core spray motor starter showed internal
  melting and discoloration while the third fuse did not. The licensee replaced all three
  fuses and performed testing on the low pressure core spray motor starter and returned
  the low pressure core spray system to an operable status.
  The inspectors questioned the licensee on whether the low pressure core spray system
  was capable of performing its specified safety function, at the time of discovery, when
  the minimum flow valve failed to open. The inspectors referred to NUREG-1022, Event
  Reporting Guidelines 10 CFR 50.72 and 73, Revision 2, and noted the following under
  Section 3.2.7, Event or Condition That Could Have Prevented Fulfillment of a Safety
  Function:
   *        The intent of these criteria is to capture those events when there would have
            been a failure of a safety system to properly complete a safety function.
  *        These criteria cover an event or condition where structures, components, or
            trains of a safety system could have failed to perform their intended function
            because of: [] equipment failures.
  *        The event must be reported regardless of whether or not an alternate safety
            system could have been used to perform the safety function.
  *        There are a limited number of single train systems that perform safety functions.
            For such systems, loss of the single train would prevent the fulfillment of the
            safety function of that system and, therefore, is reportable.
  The inspectors presented their questions to the licensee on December 29, 2010. The
  licensee prepared a position paper that summarized the low pressure core spray system
  was not a single train system for reporting purposes, but that it was a redundant system
                                        - 21 -                               Enclosure
 
to both the residual heat removal system and the high pressure core spray system.
Therefore, the reporting requirement would not be met due to the previously mentioned
systems being able to provide the appropriate safety function. The licensee position
paper was presented to the inspectors on January 6, 2011. The inspectors reviewed the
FSAR and consulted with NRC regional, headquarters, and training staff to determine
the treatment of the low pressure core spray system for reporting purposes. After
review, the inspectors determined the low pressure core spray system was a single train
system and the failure of the minimum flow valve to open was a reportable condition.
The licensee submitted Event Notification 46604 to the Headquarters Operations Officer
on February 8, 2011.
Analysis: The failure to report a condition that could have prevented the fulfillment of a
systems safety function is a performance deficiency. This finding is more than minor
because the NRC relies on licensees to identify and report conditions or events meeting
the criteria specified in the regulations in order to perform its regulatory function. Using
Inspection Manual Chapter 0612, the inspectors determined that this performance
deficiency was not appropriate to evaluate using the NRCs Significance Determination
Process due to the finding only affecting the NRCs ability to perform its regulatory
oversight function. As a result, this performance deficiency was evaluated for traditional
enforcement in accordance with the NRC Enforcement Policy. This performance
deficiency was determined to be a Severity Level IV violation in accordance with Section
6.9.d.9 of the NRC Enforcement Policy, dated September 30, 2010. The inspectors
determined that assigning a cross-cutting aspect was not applicable to this performance
deficiency due to the performance deficiency being screened exclusively using the
traditional enforcement process.
Enforcement: Title 10 CFR 50.72(b)(3)(v)(D) requires, in part, that licensees shall notify
the NRC within eight hours of the occurrence of an event or condition that at the time of
discovery could have prevented the fulfillment of the safety function of systems that are
needed to mitigate the consequences of an accident. Contrary to this requirement, on
December 20, 2010, the licensee failed to report to the NRC a condition that could have,
at the time of discovery, prevented the low pressure core spray system from fulfilling its
safety function. This violation was identified on December 28, 2010. The licensee made
Event Notification 46604 on February 8, 2011. As a corrective action the licensee has
informed all current shift managers, and plans to train future senior reactor operators, of
the expectation to evaluate low pressure core spray system failures as a failure of a
single train system to complete a safety function. There was no actual or potential
safety consequences associated with this violation. Because this violation was placed
into the licensees corrective action program as Action Request/Condition
Report 236879, compliance was restored within a reasonable amount of time, the
violation was not repetitive, or willful, this Severity Level IV violation is being treated as a
noncited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV
05000397/2011002, Failure to Make Required Event Notification.
                                      - 22 -                                   Enclosure
 
.4   Assessment of Licensee Improvement Efforts
  a. Inspection Scope
      The inspectors reviewed the following issue:
      *      March 2, 2011, Action Request/Condition Report 222076, Pride and
              Performance Completion Sample - Equipment Reliability, items 12 and 30
      The inspectors determined that the licensee has effectively identified systems and
      components necessary to control reactor power, reactor pressure and reactor level and
      have accurately assessed the reliability of such systems and components.
      These activities constitute completion of one in-depth problem identification and
      resolution sample as defined in Inspection Procedure 71152-05.
  b. Findings
      No findings were identified.
4OA3 Event Follow-up (71153)
.1   (Closed) Licensee Event Report (LER) 05000397/2010-002-00: LPCS Minimum Flow
      Valve Failed to Open Due to Premature Fuse Failure at the Solder Joint
      This LER documented a failure of the low pressure core spray minimum flow valve to
      open during surveillance testing, rendering the low pressure core spray system
      inoperable and unable to perform its specified safety function. See Section 4OA5 of
      NRC Inspection Report 05000397/2011002 for a discussion of an NRC identified
      violation associated with this event. The inspectors completed a review of this LER and
      did not identify any other violations of regulatory requirements or findings associated
      with this event. This LER is closed.
4OA5 Other Activities
4OA5 Other Activities
.1 NRC TI 2515/177, "Managing Gas Accumulation in Emergency Core Cooling Decay Heat Removal and Containment Spray Systems (NRC Generic Letter 2008
.1     NRC TI 2515/177, "Managing Gas Accumulation in Emergency Core Cooling Decay
-01)" As documented in Section 1R22 of Inspection Report 05000397/2010005 and 1R22 of Inspection
      Heat Removal and Containment Spray Systems (NRC Generic Letter 2008-01)"
Report 05000397/2011002, the inspectors confirmed the acceptability of the described actions for the residual heat removal system and the high pressure core spray system. This inspection effort counts towards the completion of TI 2515/177 which will  
      As documented in Section 1R22 of Inspection Report 05000397/2010005 and 1R22 of
be closed in a later inspection report.
      Inspection Report 05000397/2011002, the inspectors confirmed the acceptability of the
 
      described actions for the residual heat removal system and the high pressure core spray
  - 24 - Enclosure 4OA6 Meetings Exit Meeting Summary
      system. This inspection effort counts towards the completion of TI 2515/177 which will
The inspectors debriefed Messrs. John Bekhazi, Plant General Manager, James Moon, Training Manager, and other members of the staff on December 2, 2010. A telephonic exit of the results of the licensed operator requalification program inspection was conducted on March 1, 2011, between Messrs. Brian Larson, Lead Inspector, and Kevin Smart, Operations Training Supervisor. The inspector asked the licensee whether any materials examined during the  
      be closed in a later inspection report.
inspection should be considered proprietary. No proprietary information was identified.  
                                          - 23 -                               Enclosure
On March 31, 2011, the inspectors presented the inspection results to Mr. Mark Reddemann
 
, Chief Executive Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
4OA6 Meetings
 
Exit Meeting Summary
  A-1    Attachment
The inspectors debriefed Messrs. John Bekhazi, Plant General Manager, James Moon, Training
SUPPLEMENTAL INFORMATION
Manager, and other members of the staff on December 2, 2010. A telephonic exit of the results
KEY POINTS OF CONTACT  
of the licensed operator requalification program inspection was conducted on March 1, 2011,
Licensee Personnel     B. Sawatzke, Chief Nuclear Officer
between Messrs. Brian Larson, Lead Inspector, and Kevin Smart, Operations Training
B. MacKissock, Plant General Manager
Supervisor. The inspector asked the licensee whether any materials examined during the
C. King, Assistant, Plant General Manager
inspection should be considered proprietary. No proprietary information was identified.
D. Brown, Operations Manager
On March 31, 2011, the inspectors presented the inspection results to Mr. Mark Reddemann,
S. Wood, Organizational Effectiveness Manager
Chief Executive Officer, and other members of the licensee staff. The licensee acknowledged
D. Swank, Engineering General Manager
the issues presented. The inspector asked the licensee whether any materials examined during
D. Mand, Design Engineering Manager
the inspection should be considered proprietary. No proprietary information was identified.
J. Bekhazi, Maintenance Manager D. Gregoire, Acting Regulatory Affairs Manager
                                            - 24 -                            Enclosure
K. Christianson, Acting Licensing Supervisor
 
R. Garcia, Licensing Engineer
                              SUPPLEMENTAL INFORMATION
L. Williams, Licensing Engineer
                                  KEY POINTS OF CONTACT
P. Taylor, Operations Training Manager
Licensee Personnel
K. Smart, Operations Training Supervisor
B. Sawatzke, Chief Nuclear Officer
R. Hayden, Operations Training Specialist
B. MacKissock, Plant General Manager
  NRC Personnel
C. King, Assistant, Plant General Manager
  R. Cohen, Resident Inspector
D. Brown, Operations Manager
M. Hayes, Resident Inspector
S. Wood, Organizational Effectiveness Manager
  LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED  
D. Swank, Engineering General Manager
Opened None.   Opened and Closed
D. Mand, Design Engineering Manager
05000 397/2011 002-01 NCV Failure to Ensure Unacceptable Preconditioning is Considered During the Work Management Process (Section 1R19)
J. Bekhazi, Maintenance Manager
05000397/2011 002-02 NCV Failure to Make Required Event Notification (Section 4OA2)
D. Gregoire, Acting Regulatory Affairs Manager
Closed 05000397/2010
K. Christianson, Acting Licensing Supervisor
-0 0 2-00 LER LPCS Minimum Flow Valve Failed to Open Due to Premature Fuse Failure at the Solder Joint
R. Garcia, Licensing Engineer
(Section 4OA3)
L. Williams, Licensing Engineer
Discussed None.        
P. Taylor, Operations Training Manager
  A-2    Attachment
K. Smart, Operations Training Supervisor
LIST OF DOCUMENTS REVIEWED
R. Hayden, Operations Training Specialist
  Section 1RO1: Adverse Weather Protection
NRC Personnel
PROCEDURES
R. Cohen, Resident Inspector
NUMBER TITLE REVISION SOP-COLDWEATHER
M. Hayes, Resident Inspector
-OPS Cold Weather Operations
                    LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
16  Section 1RO4: Equipment Alignment
Opened
PROCEDURES
None.
NUMBER TITLE REVISION SOP-DG1-STBY Emergency Diesel Generator (Div 1) Standby Lineup
Opened and Closed
14  Section 1RO5: Fire Protection
05000397/2011002-01         NCV Failure to Ensure Unacceptable Preconditioning is Considered
MISCELLANEOUS DOCUMENTS
                                During the Work Management Process (Section 1R19)
NUMBER TITLE REVISION FSAR Columbia Generating Station Final Safety Analysis Report, Appendix F
05000397/2011002-02         NCV Failure to Make Required Event Notification (Section 4OA2)
60  Section 1R11: Licensed Operator Requalification Program
Closed
  MISCELLANEOUS DOCUMENTS
05000397/2010-002-00       LER LPCS Minimum Flow Valve Failed to Open Due to Premature
NUMBER TITLE REVISION Licensed Operator Requalifications Training LR002021
                                Fuse Failure at the Solder Joint (Section 4OA3)
0 TDI-08 Licensed Operator Requalification Program
Discussed
7 TDI-12 Shift Technical Advisor/Incident Advisor Program
None.
2 AR/CR 00230147 Licensee Medical Status Not Consistent with RIV Database
                                          A-1                                    Attachment
  LICENSEE EVENT REPORTS
 
397-10001 Failure of a Secondary Containment Isolation Valve to Fully Close 397-09005 Manual Reactor Scram due to Main Turbine DEH
                            LIST OF DOCUMENTS REVIEWED
Control System Fluid Leak
Section 1RO1: Adverse Weather Protection
397-09004 6.9 kV Non
PROCEDURES
-Segregated Electrical Bus Failure
        NUMBER                                   TITLE                         REVISION
397-09003-1 Manual Reactor Scram due to a Fire Stemming from a Turbine Lube Oil leak
SOP-COLDWEATHER-OPS Cold Weather Operations                                         16
 
Section 1RO4: Equipment Alignment
  A-3    Attachment
PROCEDURES
397-09002-1 Manual Reactor Scram due to Loss of Hydrogen Pressure in the Main Generator 397-09001-1 Reactor Scram due to Turbine Control System Trip Header Depressurization
  NUMBER                                   TITLE                             REVISION
Section 1R12: Maintenance Effectiveness
SOP-DG1-STBY         Emergency Diesel Generator (Div 1) Standby Lineup             14
  MISCELLANEOUS DOCUMENTS
Section 1RO5: Fire Protection
NUMBER TITLE REVISION / DATE TSP-TURB-G001 Turbine Overspeed Protection Valve Disassembly and Inspection
MISCELLANEOUS DOCUMENTS
April 19, 2007
  NUMBER                                     TITLE                             REVISION
Drawing M502
FSAR             Columbia Generating Station Final Safety Analysis Report,           60
Flow Diagram Main & Exhaust Steam System
                Appendix F
35 Drawing M959
Section 1R11: Licensed Operator Requalification Program
Flow Diagram Electro
MISCELLANEOUS DOCUMENTS
-Hydraulic Fluid System
  NUMBER                                     TITLE                             REVISION
15 ABN-DEH-LEAK DEH-System-Leak 2 Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
                Licensed Operator Requalifications Training LR002021                 0
MISCELLANEOUS DOCUMENTS  
TDI-08           Licensed Operator Requalification Program                             7
NUMBER TITLE REVISION / DATE AR 233580 500 KV Relay Set 1 Spurious Trip Tone Signals
TDI-12           Shift Technical Advisor/Incident Advisor Program                     2
February 3, 2011 Energy Northwest Impact Statement, BPA Communication Equipment February 3, 2011 WO 2000583
AR/CR           Licensee Medical Status Not Consistent with RIV Database
Investigate Spurious Tone 1 and Tone 2 Signals on 500 KV Relay Set 1
00230147
0 ABN-GENERATOR Main Generator Trouble
LICENSEE EVENT REPORTS
9 02000086-01 SCW-P-2 Replace power frame with rebuilt one
397-10001     Failure of a Secondary Containment Isolation Valve to Fully Close
February 28, 2011 Section 1R15: Operability Evaluations
397-09005     Manual Reactor Scram due to Main Turbine DEH Control System Fluid Leak
NUMBER TITLE REVISION / DATE ESP-B1DG3-A101 12 Month Battery Inspection of 125 VDC HPCS
397-09004     6.9 kV Non-Segregated Electrical Bus Failure
-B1-DG3 6
397-09003-1   Manual Reactor Scram due to a Fire Stemming from a Turbine Lube Oil leak
  A-4    Attachment
                                        A-2                                  Attachment
AR/CR 234537
 
Circuit breaker Case is Cracked
397-09002-1   Manual Reactor Scram due to Loss of Hydrogen Pressure in the Main
February 24, 2011 AR/CR 234766
              Generator
DMA-FN-31 Electrical Phase Imbalance Noted at Motor Starter February 28, 2011 ACTION REQUEST/CONDITION REPORTS
397-09001-1   Reactor Scram due to Turbine Control System Trip Header Depressurization
  232917 218082 228525 218980   Section 1R18: Plant Modifications
Section 1R12: Maintenance Effectiveness
NUMBER TITLE REVISION / DATE TMR-11-008 Crack in Weld Down Stream of BS
MISCELLANEOUS DOCUMENTS
-V-52A March 1, 2011 Section 1R19: Postmaintenance Testing
  NUMBER                                 TITLE                             REVISION /
MISCELLANEOUS DOCUMENTS
                                                                                DATE
NUMBER TITLE REVISION / DATE Action Request  
TSP-TURB-G001 Turbine Overspeed Protection Valve Disassembly and           April 19, 2007
234765 DMA-FN-31 Electrical
                Inspection
Phase Imbalance Noted at Motor Starter February 25, 2011 Action Request  
Drawing M502   Flow Diagram Main & Exhaust Steam System                         35
234766 DMA-FN-31 Phase Imbalance
Drawing M959   Flow Diagram Electro-Hydraulic Fluid System                       15
February 25, 2011 Work Order 01195224 DG3 Monthly Operability Testing  
ABN-DEH-LEAK   DEH-System-Leak                                                   2
February 25, 2011 OSP-FPC/IST-Q701 Fuel Pool Cooling System Operability Surveillance
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
24 18.1.22 FPC-P-1A IST Preservice Test
MISCELLANEOUS DOCUMENTS
1 Work Request 02000086 SCW-P-2 Postmaintenance Testing
  NUMBER                                 TITLE                             REVISION /
March 10, 2011 Work Request  
                                                                                DATE
29086232 SEIS-RSA-1 Amber and Red Lights Will Not Reset
AR 233580       500 KV Relay Set 1 Spurious Trip Tone Signals               February 3,
March 21, 2011 Work Order 0119282503
                                                                                2011
SP HP Support Replace Power Frame LPCS
                Energy Northwest Impact Statement, BPA Communication         February 3,
-P-2 December 20, 2010 Work Order 0119266501
                Equipment                                                        2011
OSP-LPCS/IST-Q702 Operability Testing
WO 2000583     Investigate Spurious Tone 1 and Tone 2 Signals on 500 KV           0
December 20, 2010 SWP-PRO-01 Description and Use
                Relay Set 1
of procedures and Instructions
ABN-           Main Generator Trouble                                             9
16
GENERATOR
  A-5    Attachment
02000086-01     SCW-P-2 Replace power frame with rebuilt one               February 28,
Section 1R18: Plant Modifications
                                                                                2011
NUMBER TITLE REVISION / DATE Inservice Testing Program Plan Third Ten
Section 1R15: Operability Evaluations
-Year Inspection Interval 2011 Action Request  
    NUMBER                                 TITLE                           REVISION /
234072 Energy Northwest Condition Evaluation
                                                                              DATE
  1.3.68 Work Management Process
ESP-B1DG3-     12 Month Battery Inspection of 125 VDC HPCS-B1-DG3                 6
22  Section 1R22: Surveillance Testing
A101
PROCEDURES
                                      A-3                                Attachment
NUMBER TITLE REVISION ISP-RFW-Q401 Feedwater/Turbine Trip reactor level 8 Channel Functional Test 11 ISP-MS-Q935 D ivision 2 Channel D Isolation Actuation on Reactor Level  
 
2-CFT/CC 8 ISP-RCIC-Q903 RCIC Isolation on RCIC Steam Supply Flow High DIV 2  
AR/CR 234537     Circuit breaker Case is Cracked                     February 24,
- CFT/CC 15  RCIC Isolation on RCIC Steam Supply Flow High Division 1  
                                                                          2011
- Channel Functional Test and Channel Calibration
AR/CR 234766     DMA-FN-31 Electrical Phase Imbalance Noted at Motor February 28,
17 PPM 8.2.449
                Starter                                                  2011
Control Rod Settle Time Test
ACTION REQUEST/CONDITION REPORTS
ACTION REQUEST/CONDITION REPORT
232917           218082             228525           218980
01194620 01193731     Section 1EP6: Drill Evaluation
Section 1R18: Plant Modifications
MISCELLANEOUS DOCUMENTS
    NUMBER                                 TITLE                   REVISION /
NUMBER TITLE DATE Columbia Generating Station 2011 ERO Team D Training Drill January 11, 2011  
                                                                        DATE
  A-6    Attachment
TMR-11-008     Crack in Weld Down Stream of BS-V-52A                 March 1,
Section 4OA1: Performance Indicator Verification
                                                                        2011
MISCELLANEOUS DOCUMENTS
Section 1R19: Postmaintenance Testing
NUMBER TITLE REVISION / DATE NEI 99-02 Regulatory Assessment Performance Indicator Guideline
MISCELLANEOUS DOCUMENTS
Operator Logs
    NUMBER                                   TITLE                     REVISION /
  Energy Northwest and NRC Performance Indicator Data
                                                                          DATE
  Section 4OA2: Identification and Resolution of Problems
Action Request   DMA-FN-31 Electrical Phase Imbalance Noted at Motor February 25,
  ACTION REQUEST/CONDITION REPORTS
234765          Starter                                                  2011
  00233155 00233160 00233181 00233182 00233184 00233209 00233210 00233227 00233228 00233260 00232626 00233275 00233276 00233278 00233266 00233267 00233290 00233452 00233457 00233456 00233462 00233463 00233368 00233580 00233588 00233642 00233644 00233646 00233647 00233648 00233668 00233670 00233679 00233682 00233691 00233692 00233913 00233915 00233883 00233887 00233913 00233915 00233580 00233588 00233589 00233592 00233594 00233609 00233614 00233634 00233637 00233642 00233644 00233646 00233647 00233648 00233649 00233650 00233652 00233653 00231848 00231907 00231905 00231908 00231661 00231662 00231665 00231677 00231680 00231684 00231738 00231778 00231798 00231805 00231810 00231813 00231848 00231852 00234219 00234221 00234265 00234268 00234269 00234271 00233986 00233989 00234167 00234169 00234187 00234190 00234191 00234051 00234052 00234072 00234077 00234081 00234082 00234101 00234102 00234103 00234119 00234120 00234122 00234123 00234134 00234135 00234136 00234137 00234140 00234141 00234146 00234765 00234535 00234537 00234538 00234580 00234380 00234381 00234383 00234384 00234407 00234409 00234443 00234444 00234445
Action Request   DMA-FN-31 Phase Imbalance                           February 25,
  A-7    Attachment
234766                                                                    2011
00234446 00235404 00235405 00235522 00235523 00235525 00235526 00236261 00236264 00236265 00236306 00236307 00236311 00235994 00235996 00235997 00236022 00236023 00236024 00235660 00235661 00235640 00235654 00236339 00236340 00236343 00236453 00236454 00236455 00236473 00236474 00236488 00236489 00236500 00236501 00236502     MISCELLANEOUS DOCUMENTS
Work Order       DG3 Monthly Operability Testing                     February 25,
NUMBER TITLE REVISION / DATE AR/CR 222076 Pride and Performance Completion Sample  
01195224                                                                  2011
- Equipment Reliability, items 12, 30
OSP-FPC/IST-     Fuel Pool Cooling System Operability Surveillance         24
March 2, 2011  Section 4OA3: Event Follow
Q701
-Up MISCELLANEOUS DOCUMENTS
18.1.22         FPC-P-1A IST Preservice Test                               1
NUMBER TITLE REVISION / DATE LER 2010-002-00 LPCS Minimum Flow Valve Failed to Open Due to Premature Fuse
Work Request     SCW-P-2 Postmaintenance Testing                       March 10,
Failure at the Solder Joint
02000086                                                                  2011
February 18, 2011
Work Request     SEIS-RSA-1 Amber and Red Lights Will Not Reset         March 21,
29086232                                                                  2011
Work Order       SP HP Support Replace Power Frame LPCS-P-2             December
0119282503                                                              20, 2010
Work Order       OSP-LPCS/IST-Q702 Operability Testing                 December
0119266501                                                              20, 2010
SWP-PRO-01       Description and Use of procedures and Instructions         16
                                        A-4                        Attachment
 
Section 1R18: Plant Modifications
    NUMBER                                 TITLE                         REVISION /
                                                                              DATE
                Inservice Testing Program Plan Third Ten-Year Inspection       2011
                Interval
Action Request   Energy Northwest Condition Evaluation
234072
1.3.68           Work Management Process                                         22
Section 1R22: Surveillance Testing
PROCEDURES
    NUMBER                                   TITLE                           REVISION
ISP-RFW-Q401     Feedwater/Turbine Trip reactor level 8 Channel Functional       11
                Test
ISP-MS-Q935     Division 2 Channel D Isolation Actuation on Reactor Level       8
                2-CFT/CC
ISP-RCIC-Q903   RCIC Isolation on RCIC Steam Supply Flow High DIV 2 -          15
                CFT/CC
                RCIC Isolation on RCIC Steam Supply Flow High Division 1       17
                - Channel Functional Test and Channel Calibration
PPM 8.2.449     Control Rod Settle Time Test                                     3
ACTION REQUEST/CONDITION REPORTS
01194620         01193731
Section 1EP6: Drill Evaluation
MISCELLANEOUS DOCUMENTS
    NUMBER                                   TITLE                             DATE
                Columbia Generating Station 2011 ERO Team D Training       January 11,
                Drill                                                          2011
                                        A-5                                Attachment
 
Section 4OA1: Performance Indicator Verification
MISCELLANEOUS DOCUMENTS
  NUMBER                                 TITLE                           REVISION /
                                                                              DATE
NEI 99-02       Regulatory Assessment Performance Indicator Guideline           6
                Operator Logs
                Energy Northwest and NRC Performance Indicator Data
Section 4OA2: Identification and Resolution of Problems
ACTION REQUEST/CONDITION REPORTS
00233155       00233160           00233181         00233182         00233184
00233209       00233210           00233227         00233228         00233260
00232626       00233275           00233276         00233278         00233266
00233267       00233290           00233452         00233457         00233456
00233462       00233463           00233368         00233580         00233588
00233642       00233644           00233646         00233647         00233648
00233668       00233670           00233679         00233682         00233691
00233692       00233913           00233915         00233883         00233887
00233913       00233915           00233580         00233588         00233589
00233592       00233594           00233609         00233614         00233634
00233637       00233642           00233644         00233646         00233647
00233648       00233649           00233650         00233652         00233653
00231848       00231907           00231905         00231908         00231661
00231662       00231665           00231677         00231680         00231684
00231738       00231778           00231798         00231805         00231810
00231813       00231848           00231852         00234219         00234221
00234265       00234268           00234269         00234271         00233986
00233989       00234167           00234169         00234187         00234190
00234191       00234051           00234052         00234072         00234077
00234081       00234082           00234101         00234102         00234103
00234119       00234120           00234122         00234123         00234134
00234135       00234136           00234137         00234140         00234141
00234146       00234765           00234535         00234537         00234538
00234580       00234380           00234381         00234383         00234384
00234407       00234409           00234443         00234444         00234445
                                      A-6                                Attachment
 
00234446       00235404             00235405         00235522     00235523
00235525       00235526             00236261         00236264     00236265
00236306       00236307             00236311         00235994     00235996
00235997       00236022             00236023         00236024     00235660
00235661       00235640             00235654         00236339     00236340
00236343       00236453             00236454         00236455     00236473
00236474       00236488             00236489         00236500     00236501
00236502
MISCELLANEOUS DOCUMENTS
  NUMBER                                     TITLE                     REVISION /
                                                                            DATE
AR/CR 222076   Pride and Performance Completion Sample - Equipment       March 2,
                Reliability, items 12, 30                                   2011
Section 4OA3: Event Follow-Up
MISCELLANEOUS DOCUMENTS
    NUMBER                                   TITLE                     REVISION /
                                                                            DATE
LER 2010-002-00 LPCS Minimum Flow Valve Failed to Open Due to           February 18,
                Premature Fuse Failure at the Solder Joint                 2011
                                          A-7                          Attachment
}}
}}

Latest revision as of 00:52, 13 November 2019

IR 05000397-11-002; 01/01/2011 - 03/26/2011; Columbia Generating Station, Integrated Resident and Regional Report; Postmaintenance Testing, Identification and Resolution of Problems
ML111300570
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 05/10/2011
From: Webb Patricia Walker
NRC/RGN-IV/DRP/RPB-A
To: Reddemann M
Energy Northwest
References
IR-11-002
Download: ML111300570 (33)


See also: IR 05000397/2011002

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGI ON I V

612 EAST LAMAR BLVD, SUITE 400

ARLINGTON, TEXAS 76011-4125

May 10, 2011

Mr. M.E. Reddemann

Chief Executive Officer

Energy Northwest

P.O. Box 968, Mail Drop 1023

Richland, WA 99352-0968

Subject: COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION REPORT

NUMBER 05000397/2011002

Dear Mr. Reddemann:

On March 26, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Columbia Generating Station. The enclosed integrated inspection report documents the

inspection findings, which were discussed on March 31, 2011, with yourself, and other members

of your staff.

The inspections examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

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

personnel.

Based on the results of this inspection, the NRC has determined that one Severity Level IV

violation of NRC requirements occurred. The NRC has also identified one NRC identified issue

that was evaluated under the risk significance determination process as having very low safety

significance (Green). The NRC has determined that a violation is associated with this issue.

However, because of the very low safety significance and because they were entered into your

corrective action program, the NRC is treating these findings as noncited violations, consistent

with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violation or the significance of the noncited violation, 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, D.C.

20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission,

Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of

Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the

NRC Resident Inspector at the facility. 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 IV, and the NRC Resident Inspector at the facility.

Energy Northwest -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 you choose to provide one for cases where a response is not

required, will be made available electronically for public inspection in the NRC Public Document

Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not

include any personal, privacy or proprietary information so that it can be made available to the

Public without redaction.

Sincerely,

/RA/

Wayne C. Walker, Chief

Project Branch A

Division of Reactor Projects

Docket: 50-397

License: NPF-21

Enclosure:

NRC Inspection Report 05000397/2011002

w/Attachment: Supplemental Information

cc: Distribution via ListServ for Columbia Generating Station

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000397

License: NPF-21

Report: 05000397/2011002

Licensee: Energy Northwest

Facility: Columbia Generating Station

Location: Richland, WA

Dates: January 1, 2011 through March 26, 2011

Inspectors: R. Cohen, Senior Resident Inspector

M. Hayes, Resident Inspector

B. Larson, Senior Operations Engineer

D. Strickland, Operations Engineer

Approved By: W. Walker, Chief, Project Branch A

Division of Reactor Projects

-1- Enclosure

SUMMARY OF FINDINGS

IR 05000397/2011002; 01/01/2011 - 03/26/2011; Columbia Generating Station, Integrated

Resident and Regional Report; Postmaintenance Testing, Identification and Resolution of

Problems

The report covered a 3-month period of inspection by resident inspectors and announced

baseline inspections by region-based inspectors. One Green noncited violation of significance

and one Severity Level IV violation were identified. The significance of most findings is

indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609,

Significance Determination Process. The cross-cutting aspect is determined using Inspection

Manual Chapter 0310, Components Within the Cross-Cutting Areas. Findings for which the

significance determination process 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. NRC-Identified Findings and Self-Revealing Findings

Cornerstone: Mitigating Systems

  • Green. The inspectors identified a noncited violation of 10 CFR Part 50

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the

licensees failure to consider the impact of preconditioning on the emergency

core cooling systems during maintenance. Specifically, licensee personnel failed

to consider the impact of scheduling keep fill pump maintenance prior to

technical specification required surveillance testing. Licensee personnel

reviewed three years worth of data on the emergency core cooling systems to

ensure there was no degrading performance trend. This issue was placed in the

licensees corrective action program as Action Request/Condition

Report 236880.

The performance deficiency was more than minor because it affected the

equipment performance attribute of the Mitigating Systems Cornerstone objective

of ensuring the reliability of systems that respond to initiating events. Using

Inspection Manual Chapter 0609.04, Phase 1 - "Initial Screening and

Characterization of Findings, the inspectors determined that this performance

deficiency was of very low safety significance because this finding was confirmed

to not result in a loss of operability for the emergency core cooling systems. The

inspectors identified a cross-cutting issue in the area of human performance,

work practices, because the licensee failed to effectively communicate

expectations regarding procedural compliance H.4.b] (Section 1R19).

Cornerstone: Miscellaneous

CFR 50.72(b)(3)(v)(D) for the failure of the licensee to make a non-emergency

-2- Enclosure

event notification to the NRC. Specifically, on December 20, 2010, the licensee

failed to report the low pressure core spray minimum flow valve failing to open on

pump start, rendering the low pressure core spray system incapable of

performing its specified safety function during testing. The licensee made Event

Notification 46604 on February 8, 2011, to report the identified condition. As a

corrective action the licensee has informed all current shift managers, and plans

to train future senior reactor operators, of the expectation to evaluate low

pressure core spray system failures as a failure of a single train system to

complete a safety function. This violation has been placed in the licensees

corrective action program as Action Request/Condition Report 236879.

The performance deficiency was more than minor because the NRC relies on

licensees to identify and report conditions or events meeting the criteria specified

in the regulations in order to perform its regulatory function. The inspectors

determined that this finding was not appropriate to evaluate using the

Significance Determination Process due to the finding only affecting the NRCs

ability to perform its regulatory oversight function. As a result, this finding was

evaluated for traditional enforcement in accordance with the NRC Enforcement

Policy. This finding was determined to be a Severity Level IV violation in

accordance with Section 6.9.d.9 of the NRC Enforcement Policy, dated

September 30, 2010. The inspectors determined that assigning a cross-cutting

aspect was not applicable to this finding due to the finding being screened

exclusively using the traditional enforcement process (Section 4OA2).

B. Licensee-Identified Violations

None

-3- Enclosure

REPORT DETAILS

Summary of Plant Status

The plant began the inspection period at 100 percent power. The plant remained at 100 percent

power for the remainder of the inspection period except for planned power reductions to support

maintenance and testing.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and

Emergency Preparedness

1R01 Adverse Weather Protection (71111.01)

Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors performed a review of the adverse weather procedures for seasonal

extremes (e.g., extreme high temperatures, extreme low temperatures, or hurricane

season preparations). The inspectors verified that weather-related equipment

deficiencies identified during the previous year were corrected prior to the onset of

seasonal extremes, and evaluated the implementation of the adverse weather

preparation procedures and compensatory measures for the affected conditions before

the onset of, and during, the adverse weather conditions.

During the inspection, the inspectors focused on plant-specific design features and the

procedures used by plant personnel to mitigate or respond to adverse weather

conditions. Additionally, the inspectors reviewed the FSAR and performance

requirements for systems selected for inspection, and verified that operator actions were

appropriate as specified by plant-specific procedures. Specific documents reviewed

during this inspection are listed in the attachment. The inspectors also reviewed

corrective action program items to verify that plant personnel were identifying adverse

weather issues at an appropriate threshold and entering them into their corrective action

program in accordance with station corrective action procedures. The inspectors

reviews focused specifically on the following plant systems:

  • February 25, 2011, diesel generator rooms, service water pump houses and

circulating water pump houses due to extreme low temperatures being

forecasted for the day

These activities constitute completion of one readiness for seasonal adverse weather

sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

-4- Enclosure

1R04 Equipment Alignments (71111.04)

Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant

systems:

  • February 14, 2011, diesel generator 1

The inspectors selected these systems based on their risk significance relative to the

reactor safety cornerstones at the time they were inspected. The inspectors attempted

to identify any discrepancies that could affect the function of the system, and, therefore,

potentially increase risk. The inspectors reviewed applicable operating procedures,

system diagrams, FSAR, technical specification requirements, administrative technical

specifications, outstanding work orders, condition reports, and the impact of ongoing

work activities on redundant trains of equipment in order to identify conditions that could

have rendered the systems incapable of performing their intended functions. The

inspectors also inspected accessible portions of the systems to verify system

components and support equipment were aligned correctly and operable. The

inspectors examined the material condition of the components and observed operating

parameters of equipment to verify that there were no obvious deficiencies. The

inspectors also verified that the licensee had properly identified and resolved equipment

alignment problems that could cause initiating events or impact the capability of

mitigating systems or barriers and entered them into the corrective action program with

the appropriate significance characterization. Specific documents reviewed during this

inspection are listed in the attachment.

These activities constitute completion of two partial system walkdown samples as

defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection (71111.05)

Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability,

accessibility, and the condition of firefighting equipment in the following risk-significant

plant areas:

-5- Enclosure

  • January 6, 2011, fire area RC-4, division 1 switch gear room
  • January 10, 2011, fire area R-8/1, low pressure core spray pump room
  • January 12, 2011, fire area R-1/1, reactor building 522 elevation northwest

quadrant

  • February 14, 2011, fire area DG-2, division 1 diesel generator room

The inspectors reviewed areas to assess if licensee personnel had implemented a fire

protection program that adequately controlled combustibles and ignition sources within

the plant; effectively maintained fire detection and suppression capability; maintained

passive fire protection features in good material condition; and had implemented

adequate compensatory measures for out of service, degraded or inoperable fire

protection equipment, systems, or features, in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk

as documented in the plants Individual Plant Examination of External Events with later

additional insights, their potential to affect equipment that could initiate or mitigate a

plant transient, or their impact on the plants ability to respond to a security event. Using

the documents listed in the attachment, the inspectors verified that fire hoses and

extinguishers were in their designated locations and available for immediate use; that

fire detectors and sprinklers were unobstructed; that transient material loading was

within the analyzed limits; and fire doors, dampers, and penetration seals appeared to

be in satisfactory condition. The inspectors also verified that minor issues identified

during the inspection were entered into the licensees corrective action program.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five quarterly fire-protection inspection samples

as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program (71111.11)

.1 Quarterly Review

a. Inspection Scope

On February 14, 2011, the inspectors observed a crew of licensed operators in the

plants simulator to verify that operator performance was adequate, evaluators were

identifying and documenting crew performance problems, and training was being

conducted in accordance with licensee procedures. The inspectors evaluated the

following areas:

-6- Enclosure

  • Licensed operator performance
  • Crews clarity and formality of communications
  • Crews ability to take timely actions in the conservative direction
  • Crews prioritization, interpretation, and verification of annunciator alarms
  • Crews correct use and implementation of abnormal and emergency procedures
  • Control board manipulations
  • Oversight and direction from supervisors
  • Crews ability to identify and implement appropriate technical specification

actions and emergency plan actions and notifications

The inspectors compared the crews performance in these areas to preestablished

operator action expectations and successful critical task completion requirements.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one quarterly licensed-operator requalification

program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Biennial Inspection (71111.11B)

The licensed operator requalification program involves two training cycles that are

conducted over a 2-year period. In the first cycle, the annual cycle, the operators are

administered an operating test consisting of job performance measures and simulator

scenarios. In the second part of the training cycle, the biennial cycle, operators are

administered an operating test and a comprehensive written examination.

a. Inspection Scope

To assess the performance effectiveness of the licensed operator requalification

program, the inspectors conducted personnel interviews, reviewed both the operating

tests and written examinations, and observed ongoing operating test activities.

The inspectors interviewed four licensee personnel, consisting of instructors and training

management, to determine their understanding of the policies and practices for

administering requalification examinations. The inspectors also reviewed operator

performance on the written exams and operating tests. These reviews included

observations of portions of the operating tests by the inspectors. The operating tests

-7- Enclosure

observed included six job performance measures and three scenarios that were used in

the current biennial requalification cycle. These observations allowed the inspectors to

assess the licensee's effectiveness in conducting the operating test to ensure operator

mastery of the training program content. The inspectors also reviewed medical records

of six licensed operators for conformance to license conditions and the licensees

system for tracking qualifications and records of license reactivation for two operators.

The results of these examinations were reviewed to determine the effectiveness of the

licensees appraisal of operator performance and to determine if feedback of

performance analyses into the requalification training program was being accomplished.

The inspectors interviewed members of the training department and reviewed six

Licensee Event Reports to assess the responsiveness of the licensed operator

requalification program to incorporate the lessons learned from plant events. In addition,

the inspectors reviewed examination security measures, a sample of simulator

performance test records (transient and steady-state tests, malfunction tests, and

scenario-based tests), simulator fidelity and existing logs of simulator deficiencies.

Examination results were assessed to determine if they were consistent with the

guidance contained in NUREG 1021, "Operator Licensing Examination Standards for

Power Reactors," Revision 9, Supplement 1, and NRC Manual Chapter 0609,

Appendix I, "Operator Requalification Human Performance Significance Determination

Process."

The inspectors completed one inspection sample of the biennial licensed operator

requalification program.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk-

significant systems:

  • February 22, 2011, TSP-TURB-G001, "Turbine Overspeed Protection Valve

Disassembly and Inspection"

  • March 2, 2011, Action Request/Condition Report 234859, CRD-HCU-1843

scram outlet valve leaks by"

The inspectors reviewed events such as where ineffective equipment maintenance has

resulted in valid or invalid automatic actuations of engineered safeguards systems and

-8- Enclosure

independently verified the licensee's actions to address system performance or condition

problems in terms of the following:

  • Implementing appropriate work practices
  • Identifying and addressing common cause failures
  • Characterizing system reliability issues for performance
  • Charging unavailability for performance
  • Trending key parameters for condition monitoring
  • Verifying appropriate performance criteria for structures, systems, and

components classified as having an adequate demonstration of performance

through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as

requiring the establishment of appropriate and adequate goals and corrective

actions for systems classified as not having adequate performance, as described

in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability,

and condition monitoring of the system. In addition, the inspectors verified maintenance

effectiveness issues were entered into the corrective action program with the appropriate

significance characterization. Specific documents reviewed during this inspection are

listed in the attachment.

These activities constitute completion of three quarterly maintenance effectiveness

samples as defined in Inspection Procedure 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk

for the maintenance and emergent work activities affecting risk-significant and safety-

related equipment listed below to verify that the appropriate risk assessments were

performed prior to removing equipment for work:

-9- Enclosure

  • February 3, 2011, Action Request 233580, "500 KV Relay Set 1 Spurious Trip

Tone Signals"

  • March 1, 2011, Yellow risk due to I&C testing and removal of the 500 KV north

bus from service

The inspectors selected these activities based on potential risk significance relative to

the reactor safety cornerstones. As applicable for each activity, the inspectors verified

that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)

and that the assessments were accurate and complete. When licensee personnel

performed emergent work, the inspectors verified that the licensee personnel promptly

assessed and managed plant risk. The inspectors reviewed the scope of maintenance

work, discussed the results of the assessment with the licensee's probabilistic risk

analyst or shift technical advisor, and verified plant conditions were consistent with the

risk assessment. The inspectors also reviewed the technical specification requirements

and inspected portions of redundant safety systems, when applicable, to verify risk

analysis assumptions were valid and applicable requirements were met. Specific

documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three maintenance risk assessments and

emergent work control inspection samples as defined in Inspection

Procedure 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope

The inspectors reviewed the following issues:

  • January 5, 2011, Action Request/Condition Report 231738, Diesel Generator 2

Breaker Closing Spring will not Discharge

  • January 25, 2011, Action Request/Condition Report 232917, Post Seal Cracks

discovered on HPCS-B1-DG3

  • February 1, 2011, Action Request/Condition Report 233290, "Emergency Siren

D-2 is Not Communicating"

  • February 24, 2011, Action Request/Condition Report 234537, "Circuit Breaker

Case is Cracked"

- 10 - Enclosure

  • February 28, 2011, Action Request/Condition Report 234766, DMA-FN-31

Electrical Phase Imbalance Noted at Motor Starter

The inspectors selected these potential operability issues based on the risk significance

of the associated components and systems. The inspectors evaluated the technical

adequacy of the evaluations to ensure that technical specification operability was

properly justified and the subject component or system remained available such that no

unrecognized increase in risk occurred. The inspectors compared the operability and

design criteria in the appropriate sections of the technical specifications and FSAR to the

licensee personnels evaluations to determine whether the components or systems were

operable. Where compensatory measures were required to maintain operability, the

inspectors determined whether the measures in place would function as intended and

were properly controlled. The inspectors determined, where appropriate, compliance

with bounding limitations associated with the evaluations. Additionally, the inspectors

also reviewed a sampling of corrective action documents to verify that the licensee was

identifying and correcting any deficiencies associated with operability evaluations.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five operability evaluations inspection samples

as defined in Inspection Procedure 71111.15-04

b. Findings

No findings were identified.

1R18 Plant Modifications (71111.18)

Temporary Modifications

a. Inspection Scope

To verify that the safety functions of important safety systems were not degraded, the

inspectors reviewed the temporary modification identified as Temporary Modification

TMR-11-008, "Crack in Weld Down Stream of BS-V-52A"

The inspectors reviewed the temporary modification and the associated safety-

evaluation screening against the system design bases documentation, including the

FSAR and the technical specifications, and verified that the modification did not

adversely affect the system operability/availability. The inspectors also verified that the

installation and restoration were consistent with the modification documents and that

configuration control was adequate. Additionally, the inspectors verified that the

temporary modification was identified on control room drawings, appropriate tags were

placed on the affected equipment, and licensee personnel evaluated the combined

effects on mitigating systems and the integrity of radiological barriers.

These activities constitute completion of one sample for temporary plant modifications as

defined in Inspection Procedure 71111.18-05.

- 11 - Enclosure

b. Findings

No findings were identified.

1R19 Postmaintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed the following postmaintenance activities to verify that

procedures and test activities were adequate to ensure system operability and functional

capability:

  • January 3, 2011, WO 01126278, E-CB-8/3, "Detailed Inspection of MOC Switch"

Frame

Testing

Will Not Reset"

The inspectors selected these activities based upon the structure, system, or

component's ability to affect risk. The inspectors evaluated these activities for the

following:

  • The effect of testing on the plant had been adequately addressed; testing was

adequate for the maintenance performed

  • Acceptance criteria were clear and demonstrated operational readiness; test

instrumentation was appropriate

The inspectors evaluated the activities against the technical specifications, the FSAR, 10

CFR Part 50 requirements, licensee procedures, and various NRC generic

communications to ensure that the test results adequately ensured that the equipment

met the licensing basis and design requirements. In addition, the inspectors reviewed

corrective action documents associated with postmaintenance tests to determine

whether the licensee was identifying problems and entering them in the corrective action

program and that the problems were being corrected commensurate with their

importance to safety. Specific documents reviewed during this inspection are listed in

the attachment.

- 12 - Enclosure

These activities constitute completion of six postmaintenance testing inspection samples

as defined in Inspection Procedure 71111.19-05.

b. Findings

Introduction: The inspectors identified a noncited violation of 10 CFR Part 50, Appendix

B, Criterion V, Instructions, Procedures, and Drawings, for the failure to consider the

impact of preconditioning on the emergency core cooling systems during keep fill pump

maintenance in the work management process.

Description: On February 3, 2011, the inspectors identified that the work schedule for

the keep fill pump maintenance performed on December 20, 2010, could have resulted

in the unacceptable preconditioning of the low pressure core spray system. The

licensee was scheduled to start the low pressure core spray pump to perform

Surveillance Procedure SOP-LPCS-SP, LPCS Suppression Pool Mixing, to support

keep fill pump maintenance on the low pressure core spray system. During low

pressure core spray pump start, the minimum flow valve strokes open to protect the

pump from damage. The low pressure core spray minimum flow valve is scoped into the

licensees inservice testing program; which requires the licensee to test the valve in an

as-found condition without preconditioning of the valve prior to inservice testing.

Preconditioning, as defined in the licensees inservice testing program, is the

manipulation of the physical condition of a component before technical specification

surveillance testing. Unacceptable preconditioning is further defined to be

preconditioning that alters one or more attributes of components which results in

acceptable test results. The licensees definition of unacceptable preconditioning goes

on to further state that any activity performed prior to an inservice test which results in

acceptable test results, but may have adversely affected the ability to monitor the

component for degradation. Once the keep fill pump maintenance was completed, the

licensee was scheduled to complete the required technical specification surveillance test

on the low pressure core spray system. This technical specification surveillance test is

used to test the time the low pressure core spray minimum flow valve takes to stroke

from fully closed to fully open, among other attributes of the low pressure core spray

system. This test is performed to ensure the low pressure core spray system can meet

its specified design function, and to detect a degrading performance trend before

operability is challenged.

The inspectors reviewed the licensees technical position on preconditioning within its

inservice testing program plan to determine what the licensee had defined to be

unacceptable preconditioning. The inspectors identified that one of the examples of

unacceptable preconditioning listed in the licensees inservice testing program was the

exercising of a motor-operated valve other than for test configurations or normal system

operation prior to a surveillance test on the valve. The inspectors also reviewed NRC

Inspection Manual Chapter 9900, "Maintenance-Preconditioning of Structures, Systems,

and Components Before Determining Operability." The inspectors noted that

preconditioning could mask the actual as-found condition of components and possibly

result in an inability to verify the operability of components. The inspectors also noted in

the NRC technical guidance, that the scheduling of apparently unrelated activities could

- 13 - Enclosure

result in unacceptable preconditioning. The inspectors determined that the scheduling of

the keep fill pump maintenance, which requires the starting of the low pressure core

spray system and the cycling of the minimum flow valve, prior to technical specification

surveillance testing constituted unacceptable preconditioning by the licensee.

The inspectors reviewed keep fill pump maintenance scheduling records for the previous

three years and noted the following additional occurrences of unacceptable

preconditioning on emergency core cooling systems:

4/25/2008 high pressure core spray system started for technical specification

surveillance testing.

7/18/2008 high pressure core spray system started for technical specification

surveillance testing.

10/8/2008 high pressure core spray system started for technical specification

surveillance testing.

  • 11/23/2009 low pressure core spray system started for keep fill pump maintenance.

11/27/2009 low pressure core spray system started for technical specification

surveillance testing.

5/19/2010 high pressure core spray system started for technical specification

surveillance testing.

8/14/2010 high pressure core spray system started for technical specification

surveillance testing.

9/8/2010 high pressure core spray system started for technical specification

surveillance testing.

maintenance.

2/3/2011 residual heat removal system, train C, started for technical specification

surveillance testing.

The inspectors determined, through interviews with the licensees staff, the licensee did

not have clear guidance on how to avoid preconditioning of components during the

scheduling of work or how to resolve issues of preconditioning when identified.

Analysis: The failure to consider preconditioning during the work scheduling process is

a performance deficiency. This performance deficiency is more than minor because it

- 14 - Enclosure

affects the equipment performance attribute of the Mitigating Systems Cornerstone

objective of ensuring the reliability of systems that respond to initiating events.

Specifically, the improper scheduling of maintenance and surveillance activities could

mask a degraded condition such that systems would be unable to perform their intended

safety function when called upon. Using Inspection Manual Chapter 0609.04,

Phase 1 - Initial Screening and Characterization of Findings, the inspectors

determined this performance deficiency was of very low safety significance because the

finding was confirmed to not result in a loss of operability for the emergency core cooling

systems. During interviews with plant personnel the inspectors identified a cross-cutting

issue in the area of human performance, work practices, because the licensee failed to

effectively communicate expectations regarding procedural compliance. In that, the

licensee failed to give clear guidance to work week managers in preparing work

schedules H.4.b].

Enforcement: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,

and Drawings, requires, in part, that activities affecting quality shall be prescribed by

documented procedures of a type appropriate to the circumstance and shall be

accomplished in accordance with those procedures. Contrary to this, from 2008 through

2010, the licensee failed to ensure aspects of preconditioning are considered during

scheduling of work as specified in Procedure 1.3.68, Work Management Process. This

caused the licensee to fail to realize the scheduling of emergency core cooling systems

keep fill pump maintenance prior to quarterly scheduled surveillance testing constituted

unacceptable preconditioning. This violation was identified on February 3, 2011.

Because this finding was determined to be of very low safety significance and was

entered into the licensees corrective action program as Action Request/Condition

Report 236880, this violation is being treated as a noncited violation consistent with

Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000397/2011002-01, Failure to

Ensure Unacceptable Preconditioning is Considered During the Work Management

Process.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors reviewed the FSAR, procedure requirements, and technical

specifications to ensure that the surveillance activities listed below demonstrated that the

systems, structures, and/or components tested were capable of performing their

intended safety functions. The inspectors either witnessed or reviewed test data to

verify that the significant surveillance test attributes were adequate to address the

following:

  • Preconditioning
  • Evaluation of testing impact on the plant
  • Acceptance criteria

- 15 - Enclosure

  • Test equipment
  • Procedures
  • Jumper/lifted lead controls
  • Test data
  • Testing frequency and method demonstrated technical specification operability
  • Test equipment removal
  • Restoration of plant systems
  • Fulfillment of ASME Code requirements
  • Updating of performance indicator data
  • Engineering evaluations, root causes, and bases for returning tested systems,

structures, and components not meeting the test acceptance criteria were correct

  • Reference setting data

The inspectors also verified that licensee personnel identified and implemented any

needed corrective actions associated with the surveillance testing.

Operability Test

  • January 5, 2011, OSP-RHR-M103, "Fill Verification RHR-C System"

Trip Reactor Level 8 Channel Functional Test

  • February 2, 2011, ISP-MS-Q935, "Division 2 Channel D Isolation Actuation on

Reactor Level 2 - CFT/CC"

RCIC Steam Supply Flow High DIV 2 - CFT/CC

Flow High Division 1 - Channel Functional Tests and Channel Calibration"

- 16 - Enclosure

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of seven surveillance testing inspection samples

as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06)

Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on January

11, 2011, which required emergency plan implementation by a licensee operations crew.

This evolution was planned to be evaluated and included in performance indicator data

regarding drill and exercise performance. The inspectors observed event classification

and notification activities performed by the crew. The inspectors also attended the

postevolution critique for the scenario. The focus of the inspectors activities was to note

any weaknesses and deficiencies in the crews performance and ensure that the

licensee evaluators noted the same issues and entered them into the corrective action

program. As part of the inspection, the inspectors reviewed the scenario package and

other documents listed in the attachment.

These activities constitute completion of one sample as defined in Inspection

Procedure 71114.06-05.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151)

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the

licensee for the fourth Quarter 2010 performance indicators for any obvious

inconsistencies prior to its public release in accordance with Inspection Manual

Chapter 0608, Performance Indicator Program.

- 17 - Enclosure

This review was performed as part of the inspectors normal plant status activities and,

as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

.2 Unplanned Scrams per 7000 Critical Hours (IE01)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical

hours performance indicator for the period from the first quarter 2010 through the fourth

quarter 2010. To determine the accuracy of the performance indicator data reported

during those periods, the inspectors used definitions and guidance contained in NEI

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6.

The inspectors reviewed the licensees operator narrative logs, issue reports, event

reports, and NRC integrated inspection reports for the period of January 2010 through

December 2010, to validate the accuracy of the submittals. The inspectors also

reviewed the licensees issue report database to determine if any problems had been

identified with the performance indicator data collected or transmitted for this indicator

and none were identified. Specific documents reviewed are described in the attachment

to this report.

These activities constitute completion of one unplanned scrams per 7000 critical hours

sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.3 Unplanned Scrams with Complications (IE02)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned scrams with

complications performance indicator for the period from the first quarter 2010 through

the fourth quarter 2010. To determine the accuracy of the performance indicator data

reported during those periods, the inspectors used definitions and guidance contained in

NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 6. The inspectors reviewed the licensees operator narrative logs, issue

reports, event reports, and NRC integrated inspection reports for the period of January

2010 through December 2010, to validate the accuracy of the submittals. The

inspectors also reviewed the licensees issue report database to determine if any

problems had been identified with the performance indicator data collected or

transmitted for this indicator and none were identified. Specific documents reviewed are

described in the attachment to this report.

- 18 - Enclosure

These activities constitute completion of one unplanned scrams with complications

sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.4 Unplanned Power Changes per 7000 Critical Hours (IE03)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned power changes per 7000

critical hours performance indicator for the period from the first quarter 2010 through the

fourth quarter 2010. To determine the accuracy of the performance indicator data

reported during those periods, the inspectors used definitions and guidance contained in

NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 6. The inspectors reviewed the licensees operator narrative logs, issue

reports, maintenance rule records, event reports, and NRC integrated inspection reports

for the period of January 2010 through December 2010, to validate the accuracy of the

submittals. The inspectors also reviewed the licensees issue report database to

determine if any problems had been identified with the performance indicator data

collected or transmitted for this indicator and none were identified. Specific documents

reviewed are described in the attachment to this report.

These activities constitute completion of one unplanned transients per 7000 critical

hours sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems (71152)

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical

Protection

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of

this report, the inspectors routinely reviewed issues during baseline inspection activities

and plant status reviews to verify that they were being entered into the licensees

corrective action program at an appropriate threshold, that adequate attention was being

given to timely corrective actions, and that adverse trends were identified and

addressed. The inspectors reviewed attributes that included the complete and accurate

identification of the problem; the timely correction, commensurate with the safety

- 19 - Enclosure

significance; the evaluation and disposition of performance issues, generic implications,

common causes, contributing factors, root causes, extent of condition reviews, and

previous occurrences reviews; and the classification, prioritization, focus, and timeliness

of corrective actions. Minor issues entered into the licensees corrective action program

because of the inspectors observations are included in the attached list of documents

reviewed.

These routine reviews for the identification and resolution of problems did not constitute

any additional inspection samples. Instead, by procedure, they were considered an

integral part of the inspections performed during the quarter and documented in

Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific

human performance issues for follow-up, the inspectors performed a daily screening of

items entered into the licensees corrective action program. The inspectors

accomplished this through review of the stations daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status

monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Selected Issue Follow-up Inspection

a. Inspection Scope

During a review of items entered in the licensees corrective action program, the

inspectors recognized a corrective action item documenting the low pressure core spray

systems minimum flow valve losing position indication during surveillance testing. The

inspectors were concerned that the issue was reportable to the NRC and that the

licensee had failed to do so.

These activities constitute completion of one in-depth selected issue follow-up inspection

sample as defined in Inspection Procedure 71152-05.

- 20 - Enclosure

b. Findings

Introduction: The inspectors identified a Severity Level IV violation of Title 10 CFR

50.72(b)(3)(v)(D) for the failure of the licensee to make a non-emergency event

notification to the NRC. Specifically, the licensee failed to report the low pressure core

spray minimum flow valve failing to open on December 20, 2010, rendering the low

pressure core spray system incapable of performing its specified safety function, during

testing.

Description: On December 20, 2010, while performing Surveillance Procedure SOP-

LPCS-SP, LPCS Suppression Pool Mixing, in support of scheduled maintenance, the

low pressure core spray minimum flow valve failed to open as expected. The low

pressure core spray minimum flow valve is a motor-operated valve which is required to

open when the low pressure core spray system is started. This is done to establish a

flow path from the suppression pool, back to the suppression pool until a flow path can

be established to the reactor vessel to prevent overheating and damage to the low

pressure core spray pump and motor. The low pressure core spray system was

subsequently declared inoperable and an investigation team was assembled to

determine the cause of the failure. The investigation team determined that two of the

three fuses associated with the low pressure core spray motor starter showed internal

melting and discoloration while the third fuse did not. The licensee replaced all three

fuses and performed testing on the low pressure core spray motor starter and returned

the low pressure core spray system to an operable status.

The inspectors questioned the licensee on whether the low pressure core spray system

was capable of performing its specified safety function, at the time of discovery, when

the minimum flow valve failed to open. The inspectors referred to NUREG-1022, Event

Reporting Guidelines 10 CFR 50.72 and 73, Revision 2, and noted the following under

Section 3.2.7, Event or Condition That Could Have Prevented Fulfillment of a Safety

Function:

  • The intent of these criteria is to capture those events when there would have

been a failure of a safety system to properly complete a safety function.

  • These criteria cover an event or condition where structures, components, or

trains of a safety system could have failed to perform their intended function

because of: [] equipment failures.

  • The event must be reported regardless of whether or not an alternate safety

system could have been used to perform the safety function.

  • There are a limited number of single train systems that perform safety functions.

For such systems, loss of the single train would prevent the fulfillment of the

safety function of that system and, therefore, is reportable.

The inspectors presented their questions to the licensee on December 29, 2010. The

licensee prepared a position paper that summarized the low pressure core spray system

was not a single train system for reporting purposes, but that it was a redundant system

- 21 - Enclosure

to both the residual heat removal system and the high pressure core spray system.

Therefore, the reporting requirement would not be met due to the previously mentioned

systems being able to provide the appropriate safety function. The licensee position

paper was presented to the inspectors on January 6, 2011. The inspectors reviewed the

FSAR and consulted with NRC regional, headquarters, and training staff to determine

the treatment of the low pressure core spray system for reporting purposes. After

review, the inspectors determined the low pressure core spray system was a single train

system and the failure of the minimum flow valve to open was a reportable condition.

The licensee submitted Event Notification 46604 to the Headquarters Operations Officer

on February 8, 2011.

Analysis: The failure to report a condition that could have prevented the fulfillment of a

systems safety function is a performance deficiency. This finding is more than minor

because the NRC relies on licensees to identify and report conditions or events meeting

the criteria specified in the regulations in order to perform its regulatory function. Using

Inspection Manual Chapter 0612, the inspectors determined that this performance

deficiency was not appropriate to evaluate using the NRCs Significance Determination

Process due to the finding only affecting the NRCs ability to perform its regulatory

oversight function. As a result, this performance deficiency was evaluated for traditional

enforcement in accordance with the NRC Enforcement Policy. This performance

deficiency was determined to be a Severity Level IV violation in accordance with Section

6.9.d.9 of the NRC Enforcement Policy, dated September 30, 2010. The inspectors

determined that assigning a cross-cutting aspect was not applicable to this performance

deficiency due to the performance deficiency being screened exclusively using the

traditional enforcement process.

Enforcement: Title 10 CFR 50.72(b)(3)(v)(D) requires, in part, that licensees shall notify

the NRC within eight hours of the occurrence of an event or condition that at the time of

discovery could have prevented the fulfillment of the safety function of systems that are

needed to mitigate the consequences of an accident. Contrary to this requirement, on

December 20, 2010, the licensee failed to report to the NRC a condition that could have,

at the time of discovery, prevented the low pressure core spray system from fulfilling its

safety function. This violation was identified on December 28, 2010. The licensee made

Event Notification 46604 on February 8, 2011. As a corrective action the licensee has

informed all current shift managers, and plans to train future senior reactor operators, of

the expectation to evaluate low pressure core spray system failures as a failure of a

single train system to complete a safety function. There was no actual or potential

safety consequences associated with this violation. Because this violation was placed

into the licensees corrective action program as Action Request/Condition

Report 236879, compliance was restored within a reasonable amount of time, the

violation was not repetitive, or willful, this Severity Level IV violation is being treated as a

noncited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV

05000397/2011002, Failure to Make Required Event Notification.

- 22 - Enclosure

.4 Assessment of Licensee Improvement Efforts

a. Inspection Scope

The inspectors reviewed the following issue:

  • March 2, 2011, Action Request/Condition Report 222076, Pride and

Performance Completion Sample - Equipment Reliability, items 12 and 30

The inspectors determined that the licensee has effectively identified systems and

components necessary to control reactor power, reactor pressure and reactor level and

have accurately assessed the reliability of such systems and components.

These activities constitute completion of one in-depth problem identification and

resolution sample as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

4OA3 Event Follow-up (71153)

.1 (Closed) Licensee Event Report (LER) 05000397/2010-002-00: LPCS Minimum Flow

Valve Failed to Open Due to Premature Fuse Failure at the Solder Joint

This LER documented a failure of the low pressure core spray minimum flow valve to

open during surveillance testing, rendering the low pressure core spray system

inoperable and unable to perform its specified safety function. See Section 4OA5 of

NRC Inspection Report 05000397/2011002 for a discussion of an NRC identified

violation associated with this event. The inspectors completed a review of this LER and

did not identify any other violations of regulatory requirements or findings associated

with this event. This LER is closed.

4OA5 Other Activities

.1 NRC TI 2515/177, "Managing Gas Accumulation in Emergency Core Cooling Decay

Heat Removal and Containment Spray Systems (NRC Generic Letter 2008-01)"

As documented in Section 1R22 of Inspection Report 05000397/2010005 and 1R22 of

Inspection Report 05000397/2011002, the inspectors confirmed the acceptability of the

described actions for the residual heat removal system and the high pressure core spray

system. This inspection effort counts towards the completion of TI 2515/177 which will

be closed in a later inspection report.

- 23 - Enclosure

4OA6 Meetings

Exit Meeting Summary

The inspectors debriefed Messrs. John Bekhazi, Plant General Manager, James Moon, Training

Manager, and other members of the staff on December 2, 2010. A telephonic exit of the results

of the licensed operator requalification program inspection was conducted on March 1, 2011,

between Messrs. Brian Larson, Lead Inspector, and Kevin Smart, Operations Training

Supervisor. The inspector asked the licensee whether any materials examined during the

inspection should be considered proprietary. No proprietary information was identified.

On March 31, 2011, the inspectors presented the inspection results to Mr. Mark Reddemann,

Chief Executive Officer, and other members of the licensee staff. The licensee acknowledged

the issues presented. The inspector asked the licensee whether any materials examined during

the inspection should be considered proprietary. No proprietary information was identified.

- 24 - Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

B. Sawatzke, Chief Nuclear Officer

B. MacKissock, Plant General Manager

C. King, Assistant, Plant General Manager

D. Brown, Operations Manager

S. Wood, Organizational Effectiveness Manager

D. Swank, Engineering General Manager

D. Mand, Design Engineering Manager

J. Bekhazi, Maintenance Manager

D. Gregoire, Acting Regulatory Affairs Manager

K. Christianson, Acting Licensing Supervisor

R. Garcia, Licensing Engineer

L. Williams, Licensing Engineer

P. Taylor, Operations Training Manager

K. Smart, Operations Training Supervisor

R. Hayden, Operations Training Specialist

NRC Personnel

R. Cohen, Resident Inspector

M. Hayes, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None.

Opened and Closed

05000397/2011002-01 NCV Failure to Ensure Unacceptable Preconditioning is Considered

During the Work Management Process (Section 1R19)05000397/2011002-02 NCV Failure to Make Required Event Notification (Section 4OA2)

Closed

05000397/2010-002-00 LER LPCS Minimum Flow Valve Failed to Open Due to Premature

Fuse Failure at the Solder Joint (Section 4OA3)

Discussed

None.

A-1 Attachment

LIST OF DOCUMENTS REVIEWED

Section 1RO1: Adverse Weather Protection

PROCEDURES

NUMBER TITLE REVISION

SOP-COLDWEATHER-OPS Cold Weather Operations 16

Section 1RO4: Equipment Alignment

PROCEDURES

NUMBER TITLE REVISION

SOP-DG1-STBY Emergency Diesel Generator (Div 1) Standby Lineup 14

Section 1RO5: Fire Protection

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION

FSAR Columbia Generating Station Final Safety Analysis Report, 60

Appendix F

Section 1R11: Licensed Operator Requalification Program

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION

Licensed Operator Requalifications Training LR002021 0

TDI-08 Licensed Operator Requalification Program 7

TDI-12 Shift Technical Advisor/Incident Advisor Program 2

AR/CR Licensee Medical Status Not Consistent with RIV Database

00230147

LICENSEE EVENT REPORTS

397-10001 Failure of a Secondary Containment Isolation Valve to Fully Close

397-09005 Manual Reactor Scram due to Main Turbine DEH Control System Fluid Leak

397-09004 6.9 kV Non-Segregated Electrical Bus Failure

397-09003-1 Manual Reactor Scram due to a Fire Stemming from a Turbine Lube Oil leak

A-2 Attachment

397-09002-1 Manual Reactor Scram due to Loss of Hydrogen Pressure in the Main

Generator

397-09001-1 Reactor Scram due to Turbine Control System Trip Header Depressurization

Section 1R12: Maintenance Effectiveness

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

TSP-TURB-G001 Turbine Overspeed Protection Valve Disassembly and April 19, 2007

Inspection

Drawing M502 Flow Diagram Main & Exhaust Steam System 35

Drawing M959 Flow Diagram Electro-Hydraulic Fluid System 15

ABN-DEH-LEAK DEH-System-Leak 2

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

AR 233580233580 500 KV Relay Set 1 Spurious Trip Tone Signals February 3,

2011

Energy Northwest Impact Statement, BPA Communication February 3,

Equipment 2011

WO 2000583 Investigate Spurious Tone 1 and Tone 2 Signals on 500 KV 0

Relay Set 1

ABN- Main Generator Trouble 9

GENERATOR

02000086-01 SCW-P-2 Replace power frame with rebuilt one February 28,

2011

Section 1R15: Operability Evaluations

NUMBER TITLE REVISION /

DATE

ESP-B1DG3- 12 Month Battery Inspection of 125 VDC HPCS-B1-DG3 6

A101

A-3 Attachment

AR/CR 234537 Circuit breaker Case is Cracked February 24,

2011

AR/CR 234766 DMA-FN-31 Electrical Phase Imbalance Noted at Motor February 28,

Starter 2011

ACTION REQUEST/CONDITION REPORTS

232917 218082 228525 218980

Section 1R18: Plant Modifications

NUMBER TITLE REVISION /

DATE

TMR-11-008 Crack in Weld Down Stream of BS-V-52A March 1,

2011

Section 1R19: Postmaintenance Testing

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

Action Request DMA-FN-31 Electrical Phase Imbalance Noted at Motor February 25,

234765 Starter 2011

Action Request DMA-FN-31 Phase Imbalance February 25,

234766 2011

Work Order DG3 Monthly Operability Testing February 25,

01195224 2011

OSP-FPC/IST- Fuel Pool Cooling System Operability Surveillance 24

Q701

18.1.22 FPC-P-1A IST Preservice Test 1

Work Request SCW-P-2 Postmaintenance Testing March 10,

02000086 2011

Work Request SEIS-RSA-1 Amber and Red Lights Will Not Reset March 21,

29086232 2011

Work Order SP HP Support Replace Power Frame LPCS-P-2 December

0119282503 20, 2010

Work Order OSP-LPCS/IST-Q702 Operability Testing December

0119266501 20, 2010

SWP-PRO-01 Description and Use of procedures and Instructions 16

A-4 Attachment

Section 1R18: Plant Modifications

NUMBER TITLE REVISION /

DATE

Inservice Testing Program Plan Third Ten-Year Inspection 2011

Interval

Action Request Energy Northwest Condition Evaluation

234072

1.3.68 Work Management Process 22

Section 1R22: Surveillance Testing

PROCEDURES

NUMBER TITLE REVISION

ISP-RFW-Q401 Feedwater/Turbine Trip reactor level 8 Channel Functional 11

Test

ISP-MS-Q935 Division 2 Channel D Isolation Actuation on Reactor Level 8

2-CFT/CC

ISP-RCIC-Q903 RCIC Isolation on RCIC Steam Supply Flow High DIV 2 - 15

CFT/CC

RCIC Isolation on RCIC Steam Supply Flow High Division 1 17

- Channel Functional Test and Channel Calibration

PPM 8.2.449 Control Rod Settle Time Test 3

ACTION REQUEST/CONDITION REPORTS

01194620 01193731

Section 1EP6: Drill Evaluation

MISCELLANEOUS DOCUMENTS

NUMBER TITLE DATE

Columbia Generating Station 2011 ERO Team D Training January 11,

Drill 2011

A-5 Attachment

Section 4OA1: Performance Indicator Verification

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

NEI 99-02 Regulatory Assessment Performance Indicator Guideline 6

Operator Logs

Energy Northwest and NRC Performance Indicator Data

Section 4OA2: Identification and Resolution of Problems

ACTION REQUEST/CONDITION REPORTS

00233155 00233160 00233181 00233182 00233184

00233209 00233210 00233227 00233228 00233260

00232626 00233275 00233276 00233278 00233266

00233267 00233290 00233452 00233457 00233456

00233462 00233463 00233368 00233580 00233588

00233642 00233644 00233646 00233647 00233648

00233668 00233670 00233679 00233682 00233691

00233692 00233913 00233915 00233883 00233887

00233913 00233915 00233580 00233588 00233589

00233592 00233594 00233609 00233614 00233634

00233637 00233642 00233644 00233646 00233647

00233648 00233649 00233650 00233652 00233653

00231848 00231907 00231905 00231908 00231661

00231662 00231665 00231677 00231680 00231684

00231738 00231778 00231798 00231805 00231810

00231813 00231848 00231852 00234219 00234221

00234265 00234268 00234269 00234271 00233986

00233989 00234167 00234169 00234187 00234190

00234191 00234051 00234052 00234072 00234077

00234081 00234082 00234101 00234102 00234103

00234119 00234120 00234122 00234123 00234134

00234135 00234136 00234137 00234140 00234141

00234146 00234765 00234535 00234537 00234538

00234580 00234380 00234381 00234383 00234384

00234407 00234409 00234443 00234444 00234445

A-6 Attachment

00234446 00235404 00235405 00235522 00235523

00235525 00235526 00236261 00236264 00236265

00236306 00236307 00236311 00235994 00235996

00235997 00236022 00236023 00236024 00235660

00235661 00235640 00235654 00236339 00236340

00236343 00236453 00236454 00236455 00236473

00236474 00236488 00236489 00236500 00236501

00236502

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

AR/CR 222076 Pride and Performance Completion Sample - Equipment March 2,

Reliability, items 12, 30 2011

Section 4OA3: Event Follow-Up

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

LER 2010-002-00 LPCS Minimum Flow Valve Failed to Open Due to February 18,

Premature Fuse Failure at the Solder Joint 2011

A-7 Attachment