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{{#Wiki_filter: | {{#Wiki_filter: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 | |||
-4125 | |||
. | |||
Energy Northwest | 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- | |||
s | 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 | |||
-significant | 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 | |||
* 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-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 | |||
a. | 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: | |||
* 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 | ||
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 | ||
identifying and documenting crew performance problems, and training was being | |||
management, to determine their understanding of the policies and practices for administering requalification examinations. | conducted in accordance with licensee procedures. The inspectors evaluated the | ||
following areas: | |||
-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. | * 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 | ||
* 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) | 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 | |||
-TURB-G001, "Turbine Overspeed Protection Valve Disassembly and Inspection" | Disassembly and Inspection" | ||
-HCU-1843 scram outlet valve leaks by | * March 2, 2011, Action Request/Condition Report 234859, CRD-HCU-1843 | ||
scram outlet valve leaks by" | |||
* March 2, 2011, Review of 10 CFR 50.65(a)(3) evaluation | |||
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 | |||
* Scoping of systems in accordance with 10 CFR 50.65(b) | |||
* Characterizing system reliability issues for performance | |||
* Charging unavailability for performance | |||
* Trending key parameters for condition monitoring | |||
* Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2) | |||
* Verifying appropriate performance criteria for structures, systems, and | |||
-(a)(2) | 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. | 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) | |||
These activities constitute completion of three quarterly maintenance effectiveness | 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) | 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13) | ||
a. Inspection Scope | |||
-significant and safety | The inspectors reviewed licensee personnel's evaluation and management of plant risk | ||
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 | ||
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 | |||
the reactor safety cornerstones. | bus from service | ||
* March 7, 2011, Yellow risk due to stator cooling water pump maintenance | |||
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 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 | |||
b. No findings were identified. | 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 | |||
Breaker Closing Spring will not Discharge | and inspected portions of redundant safety systems, when applicable, to verify risk | ||
-B1-DG3 | analysis assumptions were valid and applicable requirements were met. Specific | ||
D-2 is Not Communicating" | documents reviewed during this inspection are listed in the attachment. | ||
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 | ||
Procedure 71111.13-05. | |||
b. Findings | |||
No findings were identified. | |||
1R15 Operability Evaluations (71111.15) | |||
inspectors determined whether the measures in place would function as intended and were properly controlled. | 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 | |||
a. | discovered on HPCS-B1-DG3 | ||
* 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" | * February 24, 2011, Action Request/Condition Report 234537, "Circuit Breaker | ||
Case is Cracked" | |||
- 10 - Enclosure | |||
FSAR and the technical specifications, and verified that the modification | * 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 | |||
one sample for temporary plant modifications as defined in Inspection Procedure | 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 | |||
-CB-8/3, "Detailed | inspectors determined whether the measures in place would function as intended and | ||
were properly controlled. The inspectors determined, where appropriate, compliance | |||
-P-2 | with bounding limitations associated with the evaluations. Additionally, the inspectors | ||
-M-P/1A | also reviewed a sampling of corrective action documents to verify that the licensee was | ||
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. | 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 | |||
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. | No findings were identified. | ||
the attachment. | 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 | ||
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" | ||
The inspectors reviewed the temporary modification and the associated safety- | |||
-LPCS-SP, | 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 | |||
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. | |||
-cutting issue in the area of human performance, work practices, because the licensee failed to | |||
effectively communicate expectations regarding procedural compliance. | |||
licensee failed to give clear guidance to work week managers in preparing work schedules [H.4.b]. | |||
Report | |||
-01, | |||
Process. | |||
1R22 Surveillance Testing (71111.22) | 1R22 Surveillance Testing (71111.22) | ||
a. Inspection Scope | |||
The inspectors reviewed the FSAR, procedure requirements, and technical | |||
following: | 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 | |||
* Annunciators and alarms setpoints | |||
The inspectors also verified that licensee personnel identified and implemented any | |||
needed corrective actions associated with the surveillance testing. | |||
* January 5, 2011, Work Order 01194716, OSP-RHR/IST-Q704, RHR Loop C | |||
-RHR/IST-Q704, | Operability Test | ||
* 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" | 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 | ||
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 | ||
RCIC Steam Supply Flow High DIV 2 - CFT/CC | |||
-RCIC-Q903, | * February 8, 2011, Work Order 01194837, "RCIC Isolation on RCIC Steam Supply | ||
- CFT/CC | 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" | - 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 | |||
These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05. | 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 | |||
-02, | Procedure 71114.06-05. | ||
6. | b. Findings | ||
No findings were identified. | |||
, to validate the accuracy of the submittals. | 4. OTHER ACTIVITIES | ||
4OA1 Performance Indicator Verification (71151) | |||
.1 Data Submission Issue | |||
one unplanned scrams per 7000 critical hours sample as defined in Inspection Procedure | a. Inspection Scope | ||
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 | ||
inconsistencies prior to its public release in accordance with Inspection Manual | |||
Chapter 0608, Performance Indicator Program. | |||
- 17 - Enclosure | |||
-02, | |||
, and NRC integrated inspection reports for the period of January 2010 through December 2010, to validate the accuracy of the submittals. | 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. | as such, did not constitute a separate inspection sample. | ||
described in the attachment to this report. | b. Findings | ||
No findings were identified. | |||
.2 Unplanned Scrams per 7000 Critical Hours (IE01) | |||
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 | ||
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 | |||
-02, | 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 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 | |||
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 | ||
and none were identified. Specific documents reviewed are described in the attachment | |||
b. No findings were identified. | to this report. | ||
These activities constitute completion of one unplanned scrams per 7000 critical hours | |||
sample as defined in Inspection Procedure 71151-05. | |||
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection | 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 | |||
b. No findings were identified. | 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 | |||
-up, the inspectors performed a daily screening of items entered into the | reports, event reports, and NRC integrated inspection reports for the period of January | ||
accomplished this through review of the | 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. | |||
-up Inspection | - 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. | |||
-up inspection | .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 | |||
-emergency event notification to the NRC. | 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, | |||
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. | 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 | ||
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. | 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. | |||
-1022, | 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. | ||
b. Findings | |||
No findings were identified. | |||
4OA2 Identification and Resolution of Problems (71152) | |||
safety function of that system and, therefore, is reportable. | 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 | |||
the criteria specified in the regulations in order to perform its regulatory function. | a. Inspection Scope | ||
deficiency was not appropriate to evaluate using the | As part of the various baseline inspection procedures discussed in previous sections of | ||
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 | ||
corrective action program at an appropriate threshold, that adequate attention was being | |||
given to timely corrective actions, and that adverse trends were identified and | |||
safety function. | 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. | 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. | |||
- Equipment Reliability , items 12 and 30 | These routine reviews for the identification and resolution of problems did not constitute | ||
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 | integral part of the inspections performed during the quarter and documented in | ||
Section 1 of this report. | |||
b. Findings | |||
-05. | No findings were identified. | ||
.2 Daily Corrective Action Program Reviews | |||
-up (71153) | a. Inspection Scope | ||
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 | ||
items entered into the licensees corrective action program. The inspectors | |||
inoperable and unable to perform its specified safety function. | 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 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 | |||
-01)" | Heat Removal and Containment Spray Systems (NRC Generic Letter 2008-01)" | ||
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 | |||
system. This inspection effort counts towards the completion of TI 2515/177 which will | |||
be closed in a later inspection report. | |||
inspection should be considered proprietary. | - 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 | |||
-OPS Cold Weather Operations | 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 | |||
-Segregated Electrical Bus Failure | 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 | |||
-Hydraulic Fluid System | 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 | |||
-B1-DG3 6 | 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 | |||
-V-52A March 1, 2011 Section 1R19: | 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 233580 500 KV Relay Set 1 Spurious Trip Tone Signals February 3, | |||
2011 | |||
Energy Northwest Impact Statement, BPA Communication February 3, | |||
-P-2 December 20, 2010 Work Order | 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 | |||
-Year Inspection Interval | NUMBER TITLE REVISION / | ||
DATE | |||
ESP-B1DG3- 12 Month Battery Inspection of 125 VDC HPCS-B1-DG3 6 | |||
A101 | |||
A-3 Attachment | |||
2-CFT/CC | AR/CR 234537 Circuit breaker Case is Cracked February 24, | ||
2011 | |||
- Channel Functional Test and Channel Calibration | 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 | |||
- Equipment Reliability, items 12, 30 | OSP-FPC/IST- Fuel Pool Cooling System Operability Surveillance 24 | ||
Q701 | |||
-Up MISCELLANEOUS DOCUMENTS | 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 | |||
}} | }} |
Latest revision as of 00:52, 13 November 2019
ML111300570 | |
Person / Time | |
---|---|
Site: | Columbia |
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
- 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-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
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:
- 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
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"
- March 2, 2011, Review of 10 CFR 50.65(a)(3) evaluation
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
- Scoping of systems in accordance with 10 CFR 50.65(b)
- Characterizing system reliability issues for performance
- Charging unavailability for performance
- Trending key parameters for condition monitoring
- Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(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
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
- March 7, 2011, Yellow risk due to stator cooling water pump maintenance
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)
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"
- 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
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
- Annunciators and alarms setpoints
The inspectors also verified that licensee personnel identified and implemented any
needed corrective actions associated with the surveillance testing.
- January 5, 2011, Work Order 01194716, OSP-RHR/IST-Q704, RHR Loop C
Operability Test
- January 5, 2011, OSP-RHR-M103, "Fill Verification RHR-C System"
- January 24, 2011, Work Order 01194381, ISP-RFW-Q401, "Feedwater/Turbine
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"
- February 7, 2011, Work Order 01194835, ISP-RCIC-Q903, RCIC Isolation on
RCIC Steam Supply Flow High DIV 2 - CFT/CC
- February 8, 2011, Work Order 01194837, "RCIC Isolation on RCIC Steam Supply
Flow High Division 1 - Channel Functional Tests and Channel Calibration"
- February 22, 2011, Work Order 01193731, "Control Rod Settle Time Test"
- 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