IR 05000413/2006002: Difference between revisions

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{{#Wiki_filter:May 12 , 2006 Duke Energy Co rporation ATTN: Mr. D. Site V ice P resid ent Catawba N uclear Stati on 4800 Concord Road York, SC 29745 SUB JEC T: CATAW BA NUCLEAR STATION - NRC INTEGRAT ED INSPECTION REPORT 05000413/2006 002 AND 05 000414/200600
{{#Wiki_filter:==SUBJECT:==
CATAWBA NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000413/2006002 AND 05000414/2006002


==Dear Mr. Jamil:==
==Dear Mr. Jamil:==
On March 31 , 2006, the U.S. Nuclear Re gulatory Commis sion (NRC)
On March 31, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Catawba Nuclear Station Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on April 12, 2006, with you and other members of your staff.
completed an inspection at your Cata wba Nucl ear Station U nits 1 and 2. The enclos ed inspecti on report documen ts the inspection results, wh ich were discussed on April 12, 2006, wi th you and other members of yo ur sta ff.The inspection examined activiti es conducted under your license as they rela te to safety and compli ance w ith th e Commi ssion's rul es and regula tions and w ith th e cond ition s of yo ur li cense. The inspectors re viewe d selected p rocedures and records, observ ed activi ties, and in terview ed personnel.


This report docume nts two NR C-identified fin dings of very low sa fety significance (Green) which were determi ned to be v iolations of NRC requirements.
The inspection 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.


Howeve r, because of thei r very l ow safety significanc e and becaus e these vi olations w ere entered i nto your corre ctive acti on program, the NR C is t reatin g these viol ation s as no n-cite d vi olati ons (N CVs) c onsis tent w ith Section VI.A.1 of the NRC En forcement Policy. If you contest any NCV in this repo rt, you should prov ide a respon se withi n 30 days of the date of this inspection report, with the basis for you r den ial , to t he N ucl ear R egul ator y C ommi ssi on, A TTN: Doc umen t Co ntro l De sk, Washington, D C, 205 55-000 1; wi th cop ies to the Re gional Admin istrat or Regi on II; t he Di rector, Office of Enforcement, United States Nuclear Regulatory Commiss ion, W ashington, DC, 20555-0001; an d the NRC R esident Inspe ctor at the Cataw ba Nuclear Station.In acco rdance wit h 10 C FR 2.3 90 of th e NRC's "Rul es of Pr actice ," a co py of t his l etter a nd its enclosure w ill be a vailabl e electronic ally for pub lic inspe ction in the NRC Publ ic Document DEC 2 Room or from the Publ icly Av ailable Records (PAR S) component of NR C's document system (ADAM S). AD AMS is ac cessi ble fro m the N RC Web site at www.nrc.gov/reading-rm/adams.ht ml (the Pu blic Elec tronic Readi ng Room).Sincere ly,/R A/D. Charles P ayne, Acti ng Chief Reactor Projects Branch 1 Divi sion of Reac tor Pro jects Docket Nos.: 50-413, 50-414 Licen se Nos.: NPF-35, NPF-5
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
 
This report documents two NRC-identified findings of very low safety significance (Green) which were determined to be violations of NRC requirements. However, because of their very low safety significance and because these violations were entered into your corrective action program, the NRC is treating these violations as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC, 20555-0001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC, 20555-0001; and the NRC Resident Inspector at the Catawba Nuclear Station.
 
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document
 
DEC   2 Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
 
Sincerely,
/RA/
D. Charles Payne, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52


===Enclosure:===
===Enclosure:===
Integrated Inspection Report 05000 413/2006002 and 0500041 4/2006002 w/Attachment: S upplemental Information
Integrated Inspection Report 05000413/2006002 and 05000414/2006002 w/Attachment: Supplemental Information
 
REGION II==
Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52 Report No.: 05000413/2006002 and 05000414/2006002 Licensee: Duke Energy Corporation Facility: Catawba Nuclear Station, Units 1 and 2 Location: 4800 Concord Road York, SC 29745 Dates: January 1, 2006 through March 31, 2006 Inspectors: E. Guthrie, Senior Resident Inspector A. Sabisch, Resident Inspector S. Walker, Acting Senior Resident Inspector N. Staples, Reactor Inspector (Section 4OA5)
Approved by: D. Charles Payne, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
 
=SUMMARY OF FINDINGS=
IR 05000413/2006-002, 05000414/2006-002; 1/1/2006 - 3/31/2006; Catawba Nuclear Station,
 
Units 1 and 2; Maintenance Risk Assessments and Emergent Work Evaluation and Other Activities The report covered a three-month period of inspection by three resident inspectors and a reactor inspector. Two Green NRC-identified non-cited violations (NCVs) were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, (ROP) Revision 3, dated July 2000.
 
===NRC-Identified and Self-Revealing Findings===
 
===Cornerstone: Mitigating Systems===
: '''Green.'''
An NRC-identified NCV was identified for the failure to adequately assess and manage the risk pertaining to a portion of the maintenance activities associated with the removal of the A train of nuclear service water (RN) from service for a planned 14-day outage as required by 10 CFR 50.65(a)(4).
 
The finding was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring that the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences is maintained.
 
The inspectors determined that the finding was of very low risk significance (Green),
based on the resulting magnitude of the calculated Incremental Core Damage Probability (5.8E-7/day), the length of time that the two A train diesels were unavailable (<18 hours) and that no actual loss of safety function of the 2B DG occurred. This finding involved the cross-cutting aspect of human performance. (Section 1R13)
: '''Green.'''
An NRC-identified NCV of Catawba Nuclear Station (CNS) Operating License Condition 2.C.5, Fire Protection Program (FPP), was identified. The licensee made a change to the approved fire protection program which had the potential to affect post-fire safe shutdown capability. Specifically, the licensee derated the time requirement for 43 battery powered emergency lighting units (ELUs) from 8 hours to 1.5 hours. The evaluation for this change was not adequate to ensure that derating the ELUs would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
 
This finding is more than minor because it had the potential to impact the licensees post-fire safe shutdown capability by delaying operator response in the event of a loss of power to normal lighting during a fire. The finding was of very low risk significance (Green) because operators would likely be able to accomplish the actions with the use of flashlights. (Section 4OA5.1)
 
===Licensee-Identified Violations===
 
None
 
=REPORT DETAILS=
 
===Summary of Plant Status===
 
Unit 1 began the inspection period operating at 100 percent (%) Rated Thermal Power (RTP).
 
Power was reduced to 65% RTP on March 25 to support swapping main turbine lube oil coolers due to a tube leak that had increased on the in-service cooler. The unit was returned to 100%
power on March 26 and remained there through the end of the inspection period.
 
Unit 2 began the inspection period operating at 100% RTP. End-of-cycle power coast down commenced on March 14. Power was reduced to 94% on March 15 to conduct main steam safety relief valve testing and remained there until the unit was removed from service for a planned refueling outage on March 18. The unit remained off-line through the end of the inspection period.
 
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
 
{{a|1R04}}
==1R04 Equipment Alignment==
 
====a. Inspection Scope====
Partial System Walkdowns. The inspectors walked down the following five system alignments to verify that critical portions of equipment alignments remained operable while the redundant trains for that system were inoperable. The inspectors reviewed plant documents to determine the correct system and power alignments, as well as the required positions of selected valves and breakers. The inspectors reviewed equipment alignment problems which could cause initiating events or impact mitigating system availability to verify that they had been properly identified and resolved. Documents reviewed are listed in the Attachment.
* The B Train of nuclear service water (RN) when the A Train was removed from service for the 14-day Limiting Condition for Operation (LCO) to clean, coat, replace and repair the RN piping
* The B Train of component cooling water (KC) when the A Train of KC was removed from service as part of the 14-day RN train LCO period
* The A Train of RN when the B Train was removed from service for the 14-day LCO to clean, coat, replace and repair the RN piping
* Cross-train alignment of the KC system in support of the B Train RN LCO Allowed Outage Time (AOT)
* B Train of RN in the RN pump house structure when the A Train of RN was removed from service for the 14-day LCO
 
====b. Findings====
No findings of significance were identified.
{{a|1R05}}
==1R05 Fire Protection==
 
====a. Inspection Scope====
Fire Protection Walkdowns. The inspectors walked down accessible portions of the following eight plant areas to assess the licensees control of transient combustible material and ignition sources, fire detection and suppression capabilities, fire barriers, and any related compensatory measures. The inspectors observed the fire protection suppression and detection equipment to determine whether any conditions or deficiencies existed which could impair the operability of that equipment. The inspectors selected the areas based on a review of the licensees safe shutdown analysis probabilistic risk assessment, sensitivity studies for fire-related core damage accident sequences, and summary statements related to the licensees 1992 Initial Plant Examination for External Events submittal to the NRC. Documents reviewed are listed in the Attachment.
* Unit 1 Exterior Doghouse
* Main Control Room
* Unit 2 Auxiliary Feedwater Pump Room
* Unit 1 Mechanical Penetration Room, 543 foot elevation
* Unit 1 Electrical Penetration Room, 560 foot elevation
* Unit 2 Mechanical Penetration Room, 577 foot elevation
* Unit 1 Spent Fuel Building Fan Room, 636 foot elevation
* Nuclear Service Water Pump House Fire Drill Observation. On March 3, the inspectors observed a shift fire drill simulating an oil fire in the Unit 1 Main Turbine Oil Tank room located on the 594 foot elevation of the turbine building. The purpose of this annual inspection was to: monitor the fire brigades use of protective gear and fire fighting equipment; verify that fire fighting pre-plan procedures and appropriate fire fighting techniques were used; and verify that the directions of the fire brigade leader were thorough, clear, and effective. The inspectors also attended the subsequent drill critique to assess whether it was appropriately critical, included discussions of drill observations, and identified any areas requiring corrective action. Documents reviewed are listed in the Attachment.
 
====b. Findings====
No findings of significance were identified.
{{a|1R11}}
==1R11 Licensed Operator Requalification==
 
====a. Inspection Scope====
Resident Quarterly Observation. The inspectors observed Active Simulator Exam Scenario 16 to assess the performance of licensed operators. The exercise included a loss of condenser vacuum, loss of 6.9 kV bus, loss of a reactor coolant pump, loss of normal power to an essential train, an Anticipated Transient without a Scram, and a steam line break outside of containment. The inspection focused on high-risk operator actions performed during implementation of the emergency operating procedures, emergency plan implementation and classification, and the incorporation of lessons-learned from previous plant events. Through observations of the critique conducted by training instructors following the exam session, the inspectors assessed whether appropriate feedback was provided to the licensed operators regarding identified weaknesses.
 
====b. Findings====
No findings of significance were identified.
{{a|1R12}}
==1R12 Maintenance Effectiveness==
 
====a. Inspection Scope====
The inspectors reviewed the licensees effectiveness in performing the two following routine maintenance activities. This review included an assessment of the licensees practices pertaining to the identification, scope, and handling of degraded equipment conditions, as well as common cause failure evaluations and the resolution of historical equipment problems. For those systems, structures, and components (SSCs) scoped in the maintenance rule per 10 CFR 50.65, the inspectors verified that reliability and unavailability were properly monitored, and that 10 CFR 50.65 (a)(1) and (a)(2)classifications were justified in light of the reviewed degraded equipment condition.
 
Documents reviewed are listed in the Attachment.
* Repair of a through-wall leak found on the B Train RN supply header between manways #8 and #9
* Repairs of the 1B Spent Fuel Pool Cooling Pump
 
====b. Findings====
No findings of significance were identified.
{{a|1R13}}
==1R13 Maintenance Risk Assessments and Emergent Work Evaluation==
 
====a. Inspection Scope====
The inspectors reviewed the licensees assessments concerning the risk impact of removing from service those components associated with the eight emergent and planned work items listed below. This review primarily focused on activities determined to be risk significant within the maintenance rule. The inspectors also assessed the adequacy of the licensees identification and resolution of problems associated with maintenance risk assessments and emergent work activities. The inspectors reviewed Nuclear System Directive (NSD) 415, Operational Risk Management (Modes 1-3) and NSD 403, Shutdown Risk Management (Modes 4,5,6, and No Mode), for appropriate guidance to comply with 10 CFR 50.65 (a)(4). Documents reviewed are listed in the
.
* Entry and day-to-day activities related to the A Train of RN outage
* Entry and day-to-day activities related to the B Train of RN outage
* Schedule review and evaluation of planned/in-progress work following the discovery of a potential RN header leak
* Schedule review and evaluation of planned/in-progress work following the discovery of a potential RN header leak between manholes #8 and #9
* Schedule review and assessment of planned activities with Orange grid status due to problems at Belews Creek Steam Station
* Schedule review and assessment of planned activities on Unit 2 following the failure of the primary Digital Feedwater Control System controller and unexpected replacement of a pressurizer level transmitter
* Review and assessment of rescheduled major Unit 2 refueling outage activities due to failure of the Containment Closure Test
* Review and assessment of rescheduled major outage activities due to maintenance on 2B Spent Fuel Cooling Pump prior to core offload, failure of the Unit 1 Reactor Trip Breaker during surveillance testing, and a turbine lube oil transfer pipe leak
 
====b. Findings====
 
=====Introduction.=====
A Green NCV of 10 CFR 50.65(a)(4) was identified by the inspectors for the licensee failing to adequately assess and manage the risk pertaining to a portion of the maintenance activities associated with the removal of the A Train of nuclear service water (RN) from service for a planned 14-day outage.
 
=====Description.=====
On January 5, the A Train of nuclear service water (RN) was removed from service to allow for the header to be drained, inspected and refurbished due to ongoing degradation of the piping. The removal of the A Train of RN from service resulted in other equipment and systems being rendered inoperable including the 1A and 2A emergency diesel generators (DG). As part of the licensee amendment that granted a one-time extension of the normal 72-hour LCO allowed outage time (AOT) to 14 days, the licensee committed to implement a number of actions to manage the elevated risk created by this activity. These included providing temporary cooling to the DG via the fire protection system during the period the RN header was out of service and to protect equipment on the opposite train; i.e., the B Train and protecting the opposite train equipment when one train of RN was removed from service.
 
The A Train of RN was removed from service at approximately 2100 on January 5 and the 1A and 2A DGs were declared inoperable at that time. Installation of the temporary cooling lines from the fire protection system to the diesel jacket water heat exchangers did not commence until the morning of January 6, 2006 and was not worked continuously until completed (approximately 1300 for the 1A diesel and 1500 for the 2A diesel). The initial efforts were directed at restoring the 1A DG; however, the 2A DG was required for the operation of the 1A DG because the 2A DG powered the A fire pump which would be required to provide cooling to the A Train DGs on a loss of offsite power. This sequence requirement had not been identified by the licensee in scheduling the installation of the temporary cooling to the DGs prior to enter the 14-day LCO.
 
During the period of time in which the two A Train DGs were unavailable, a mobile crane traversed the roof area of the 2B DG on two occasions preparing to lift the 2A diesel room roof hatches. While the crane movement was done in accordance with an approved station procedure for the work on the 2A DG, the licensee did not consider the current plant condition; i.e., two of four DGs inoperable with both units in an Orange ORAM/SENTINEL risk condition. In addition, while the 2B DG itself had been posted with protected equipment signage, the roof area and support equipment such as the diesel lube oil storage tanks and the 2A/2B fire protection and carbon dioxide (CO2 )
headers had not been posted. As a result of not protecting these components and areas, the crane movement had the potential to render the 2B DG inoperable leaving the station with only one operable DG in the event normal AC power was lost. On January 5, the A Train of RN was removed from service to allow for the header to be drained, inspected and refurbished due to ongoing degradation of the piping. The removal of the A Train of RN from service resulted in other equipment and systems being rendered inoperable including the 1A and 2A emergency DGs. As part of the licensee amendment that granted a one-time extension of the normal 72-hour LCO AOT to 14 days, the licensee committed to provide temporary cooling to the DG via the fire protection system during the period the RN header was out of service and to protect equipment on the opposite train; i.e., the B Train.
 
=====Analysis.=====
Aspects of this maintenance work which demonstrated inadequate assessment and management during planned maintenance on the A Train of the RN system increased risk included the following:
The licensees risk assessment failed to fully consider risk significant SSCs and support systems that were unavailable during the maintenance activities.
* Restoring the DGs to available status was a commitment made as part of the licensee amendment request submitted by the licensee. Work to restore the 1A and 2A DGs to available status was not initiated promptly when appropriate conditions were established nor was the work performed on a continuous basis until complete. In addition, the correct sequence of restoring the 2 DGs (2A followed by 1A) was not implemented. These actions would have minimized the Incremental Core Damage Probability value that resulted from this portion of the planned LCO activities.
 
The licensees risk assessment failed to account for the possible unavailability of a single train of a system (primary or back-up) that provides a shutdown key safety function.
* The potential impact on the stations emergency AC power system due to movement of a mobile crane on the 2B DG roof in close proximity to support equipment was not considered in the risk assessment performed in support of the A Train RN LCO outage schedule nor once the outage.
 
The licensee failed to effectively implement or manage prescribed significant compensatory measures.
* As part of the license amendment request, the licensee committed to protect the 1B and 2B diesel generators during the A Train LCO outage to minimize the overall station risk exposure and developed a plan to post the equipment when the LCO was entered. However, the roof area and adjacent support equipment was not included within this protected equipment boundary and as a result, work was allowed to be performed in close proximity to equipment which had the potential to adversely impact the operability of the 2B DG.
* Changes in work scope and activities conducted in the vicinity of the 2B DG were not communicated back to Operations or Engineering to ensure that the changes were assessed in a timely manner and did not affect the overall station risk values.
 
The finding was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems which respond to initiating events to prevent undesirable consequences is maintained.
 
The inspectors determined that the finding is of very low risk significance (Green),based on the resulting magnitude of the calculated Incremental Core Damage Probability (5.8E-7/day), the length of time that the two A Train diesels were unavailable
(<18 hours) and that no actual loss of safety function of the 2B DG occurred. This finding involved the cross-cutting aspect of human performance.
 
=====Enforcement.=====
10 CFR65 (a)(4), Requirements for monitoring the Effectiveness of Maintenance at Nuclear Power Plants, requires in part, that prior to performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Contrary to the above, on January 5 and 6, 2006, the licensee failed to implement the requirements of 10 CFR 50.65(a)(4)to adequately assess and manage the increase in risk during the execution of planned maintenance associated with the A Train of RN, which placed the station in an Orange ORAM risk condition, and minimize the overall risk exposure as demonstrated through the following:
* The licensee failed to expeditiously install temporary cooling to the 1A and 2A DGs as committed to in the License Amendment Request (LAR) that allowed the 14-day LCO which resulted in unnecessary unavailability of the DGs, when the RN header was drained and the temporary cooling was being installed, by not starting the work as soon as conditions permitted or working the job on a continuous basis.
* The licensee failed to post the roof area above the 1B and 2B DGs and adjacent support equipment as protected equipment as committed to in the LAR to ensure the operability of the remaining safety-related equipment was not jeopardized.
* The licensee allowed a mobile crane to traverse the roof area above the 2B DG prior to restoring the 2A DG to available status to minimize the potential impact this movement could have on an operable piece of safety-related equipment.
* The licensee failed to properly sequence the actions taken in restoring the A Train diesel generators to available status to ensure the 2A diesel generator was returned first, which was required to provide cooling to both A Train DGs in the event of a LOOP.
* The licensee failed to effectively communicate the elevated risk associated with planned work activities to station personnel to ensure that changes in work scope or schedules were elevated to the appropriate personnel for review and assessment.
 
Because this finding is of very low safety significance and has been entered into the licensees corrective action program as PIP C-06-0057, this violation is being treated as an NCV consistent with Section VI.A.1 of the NRC Enforcement manual (NCV 05000413, 414/2006002-01, Inadequate Risk Assessment and Management Associated with Planned Nuclear Service Water System Maintenance).
{{a|1R14}}
==1R14 Operator Performance During Non-Routine Plant Evolutions and Events==
 
====a. Inspection Scope====
The inspectors observed operator performance during the shutdown of Unit 2 for the refueling outage. The inspectors observed licensed operators use of procedures, control room pre-evolution briefing, and plant equipment manipulations during the power reduction, manual reactor trip, and portions of the subsequent cooldown.
 
====b. Findings====
No findings of significance were identified.
{{a|1R15}}
==1R15 Operability Evaluations==
 
====a. Inspection Scope====
The inspectors reviewed five operability evaluations to verify that the operability of systems important to safety were properly established, that the affected components or systems remained capable of performing their intended safety function, and that no unrecognized increase in plant or public risk occurred. Operability evaluations were reviewed for the five issues listed below. Documents reviewed are listed in the
.
* 2B Chemical & Volume Control (NV) charging pump oil leak (PIPs C-05-7243 and C-06-0197)
* Non-conservative setpoints for the reactor coolant system (NC) flow instrument loop uncertainty calculations (PIP C-06-0061)
* Top left stud on 2B DG crankcase door 8R was broken during reinstallation of the cover (PIP C-06-1238)
* 2A DG room ventilation system damper found to have a broken weld affecting its operation (PIP C-06-0997)
* Operability Assessment to determine past operability/reportability of the FWST to ND suction valves when realigning from Residual Heat Removal (RHR) mode to Injection mode while in Mode 4 (PIP C-06-0809)
 
====b. Findings====
No findings of significance were identified.
{{a|1R19}}
==1R19 Post-Maintenance Testing==
 
====a. Inspection Scope====
The inspectors witnessed and/or reviewed six post-maintenance testing procedures and/or test activities, as appropriate, for selected risk significant systems to verify if:
: (1) testing was adequate for the maintenance performed;
: (2) acceptance criteria were clear and adequately demonstrated operational readiness consistent with design and licensing basis documents;
: (3) test instrumentation had current calibrations, range, and accuracy consistent with the application;
: (4) tests were performed as written with applicable prerequisites satisfied; and
: (5) equipment was returned to the status required to perform its safety function. Documents reviewed are listed in the Attachment.
* Verification of piping/flange integrity following completion of the B RN supply header 14-day LCO outage involving replacement of existing piping and addition of new cross-over connections
* Calibration and functional testing of B Train RN supply header annubar flow instrumentation
* Functional stroke testing of 2RN69B; B Train RN supply header isolation valve, following 14-day LCO outage work
* Operational testing of the 1B/2B RN pumps following the B Train RN LCO AOT
* Testing of the 1B RN pump strainer differential pressure switch following refurbishment of the strainer and associated instrumentation
* Functional test of the 1B RN pump strainer following refurbishment
 
====b. Findings====
No findings of significance were identified.
{{a|1R20}}
==1R20 Refueling and Outage Activities==
 
====a. Inspection Scope====
The inspectors evaluated Unit 2 refueling outage activities to verify that the licensee considered risk in developing and implementing outage schedules; adhered to administrative risk reduction methodologies developed to control plant configuration; developed mitigation strategies for losses of key safety functions; and adhered to operating license and TS requirements that ensure defense-in-depth. The following specific areas were reviewed. Documents reviewed are listed in the Attachment.
* Review of Outage Plan
* Monitoring of Shutdown Activities
* Licensee Control of Outage Activities
* Clearance Activities
* Reactor Coolant System Instrumentation
* Electrical Power
* Decay Heat Removal System Monitoring
* Spent Fuel Pool Cooling System Operation
* Inventory Control
* Reactivity Control
* Containment Closure
* Reduced Inventory and Mid-Loop Conditions
* Refueling Activities


REGION II Docket Nos.: 50-413, 50-414 Licen se Nos.: NPF-35, NPF-5 2 Report No.: 05000413/2006 002 and 050 00414/2006002 Licensee: Duke Energy Co rporation Facility: Catawba N uclear Stati on, Units 1 and 2 Location: 4800 Concord Road York, SC 29745 Dates: January 1, 2 006 through M arch 31, 2006 Inspectors:
====b. Findings====
E. Guthrie, Seni or Resident Inspector A. Sabisch, Resident Insp ector S. Walker, Acting Senior Resi dent Inspector N. Staples, R eactor Inspector (S ection 4OA5)
No findings of significance were identified.
Approved by: D. Charles P ayne, Acti ng Chief Reactor Projects Branch 1 Divi sion of Reac tor Pro jects 2 Enclo sure SUMMA RY OF F INDING S IR 05000413/2 006-002, 05000 414/2006-002; 1
{{a|1R22}}
/1/2006 - 3/31/20 06; Catawb a Nuclear S tation, Units 1 and 2; Main tenance Risk A ssessments and E mergent Work Evaluation and Other Activiti es The report cove red a three-month period of insp ection by three residen t inspectors an d a reactor inspecto r. Two Green N RC-identified non-cited v iolations (NCVs) we re identified.
==1R22 Surveillance Testing==


The sign ific ance of m ost f indin gs is indic ated by the ir col or (G reen , W hite , Yell ow, Re d) us ing I MC 0609, "Significance Dete rmination Process" (SDP).
====a. Inspection Scope====
The inspectors observed and/or reviewed the six surveillance tests listed below to verify that TS surveillance requirements and/or Select Licensee Commitment requirements were properly complied with, and that test acceptance criteria were properly specified.


Findings for which the SDP does not apply may be Green o r be as signed a sev erity lev el afte r NRC manageme nt rev iew. The N RC's program f or overseeing the safe oper ation of commerc ial nuclear power reactors is described in NUREG-1649, "R eactor Oversight Process," (ROP) Re vision 3, dated July 2000.A.NRC-Ide ntifi ed a nd S elf-R eve ali ng Fi ndi ngs Corner stone: Mi tigati ng Sys tems*Green. An NRC-i dentified NCV was id entified for the fail ure to adequatel y assess a nd manage the risk pertai ning to a porti on of the maintena nce activi ties associa ted with the removal of the A train of nucl ear service water (RN) from service for a p lanned 14-d ay outage as requi red by 10 CF R 50.6 5(a)(4).The finding was more than minor because it w as associated with the Equipment Performance attribute of the Mitigati ng Systems corne rstone and affected the corner stone objecti ve of e nsuri ng that the av aila bili ty, re liab ilit y and capab ilit y of sy stems that re spond to in itiat ing ev ents to prev ent un desir able consequ ences is mai ntain ed. The in specto rs dete rmined that th e findi ng was of ver y lo w ri sk signi ficance (Green), base d on the resu lti ng ma gnit ude of the cal cul ated Incr emen tal Core Dama ge Probability (5.8E-7/day), the length of time that the two A train diesels were unavailable (<18 hours) and that no actual loss of saf ety function of the 2B DG occur red. This findin g inv olve d the c ross-cu tting a spect o f human p erformanc e. (Se ction 1R13) *Green. An NRC-i dentified NCV of Catawba Nuclear Stati on (CNS) Operati ng License Condition 2.C.5, Fire Pro tection Program (FPP
The inspectors verified that proper test conditions were established as specified in the procedures, that no equipment preconditioning activities occurred, and that acceptance criteria had been met. Additionally, the inspectors also verified that equipment was properly returned to service and that proper testing was specified and conducted to ensure that the equipment could perform its intended safety function following maintenance or as part of surveillance testing. Documents reviewed are listed in the
), was ide ntified. The li censee made a change to the approv ed fire protec tion p rogram w hich had th e pote ntial to affect post-fire safe shutdown capabili ty. Speci fically, the licensee derated the time requirement for 43 battery p owered emergenc y lightin g units (ELUs) from 8 hours to 1.5 ho urs. The evaluati on for this change was not ad equate to ensure th at derating the E LUs woul d not adversely affect the ability to achiev e and maintai n safe shutdow n in the ev ent of a fire.
.
Surveillance Tests
* Flow balance of the A Train of RN following completion of the 14-day LCO AOT
* 1RN-28A; 1A RN pump discharge isolation valve, inservice test
* 2A DG EQC System Time Delay and Undervoltage Relay Calibration In-Service Tests
* Quarterly In-Service Test for motor operated valve 1RN-63A; RN header A return to Standby Nuclear Service Water Pond Ice Condenser Surveillance Tests
* MP/0/7/7150/006, Ice Condenser Lower Inlet Doors Inspection and Testing (As Found), Rev. 24
* MP/0/A/7150/005; Ice Basket Weight Determination (Unit 2, Bay 4, Baskets 6-9, 7-9, 8-9 and 9-9); Rev. 24


This finding is more than minor because it had the potential to impact the licensee's post-fire safe shutdow n capabil ity by delayin g operator response in the ev ent of a loss o f power to n ormal lightin g during a fire. The find ing was of v ery low risk significance (Green) because o perators wou ld likely be able to accomplish the actions w ith the use of flashlights. (Secti on 4OA5.1)
====b. Findings====
B.Licensee-Iden tified Viol ations None 3 Enclo sure REPORT D ETA ILS Summary of Plan t Status Unit 1 began the in specti on per iod o perati ng at 10 0 perc ent (%) Rated Thermal Pow er (RTP). Powe r was reduc ed to 6 5% RTP o n Ma rch 25 to sup port sw appin g main t urbin e lub e oil cool ers due to a tube leak that had increased on the in-serv ice cooler.
No findings of significance were identified.
{{a|1R23}}
==1R23 Temporary Plant Modifications==


The unit w as returned to 1 00%power on March 26 and remained there through the e nd of the inspe ction period
====a. Inspection Scope====
.Unit 2 beg an th e insp ecti on per iod op erat ing a t 100% RT P. End-of-cyc le powe r coa st do wn commenced on M arch 14. Pow er was redu ced to 94% on March 15 to conduct main steam safety relie f valv e testi ng and remain ed the re unti l the unit w as remo ved fro m serv ice for a planned refuel ing outage on M arch 18. The un it remained o ff-line through the end of the inspection period.1.REA CTOR SAF ETY Corner stones: Initi ating E vents , Mi tigati ng Sys tems, B arrier Integri ty 1R04 Equipment Ali gnment a.Inspection Sc ope Partial Sy stem Walkdowns. The inspectors walked do wn the foll owing five system alignments to verify that crit ical portions of equipment alignments remained operable while the redundant tra ins for that sys tem were in operable. The inspectors rev iewed plant documents to determine th e correct syste m and powe r alignments, as well a s the required positi ons of selected valves and breakers. The inspectors rev iewed e quipment alignment probl ems which could cause initiati ng events or i mpact mitigating sy stem avai labi lity to ve rify th at they had b een pr operl y id entifi ed and resol ved. Docum ents revi ewed are l isted in th e Attac hment.*The B Train of nucl ear service water (RN) when the A Train w as removed from serv ice for the 14-day L imiting Condi tion for Operation (LCO) to clean, coat, replace and repair the RN piping*The B Train of compone nt cooling w ater (KC) wh en the A Train of KC was removed from service as part of the 14-day RN train L CO period*The A Tra in of R N wh en the B Trai n wa s remov ed from s ervi ce for th e 14-d ay LC O to clean, coat, re place and repair the RN piping*Cross-train al ignment of the KC sy stem in support of the B Train RN LCO Allow ed Outa ge Ti me (A OT)*B Train of RN i n the RN pu mp house structure when the A Train of RN w as removed from service for the 14-day LCO b.Fin din gs No findings of signi ficance were identified.
The inspectors reviewed the following two temporary plant modifications to determine whether the individual modification was properly installed; the modification did not affect system operability, drawings and procedures were appropriately updated; and post-modification testing was satisfactorily performed. Documents reviewed are listed in the
.
* Installation of temporary cooling to the lube oil heat exchanger and air compressor aftercoolers on the 1A and 2A DGs in support for the 14-day A Train RN outage.
* Bypassing the non-essential chiller trips on the B Train control room area (YC) chiller in support for the 14-day A Train RN outage.


4 Enclo sure 1R05 Fire Protecti on a.Inspection Sc ope Fire Protecti on Walkdowns. The inspectors walked do wn accessi ble portion s of the following eight plant areas to assess the licensee's control of transient com bustible material and ignition sou rces, fire detectio n and suppres sion capabi lities, fire b arriers, and any re lated compensa tory measures.
====b. Findings====
No findings of significance were identified.


The inspectors o bserved the fire protection suppression and detection equipment to dete rmine wheth er any con ditions or defici encie s exi sted w hich could impai r the o perabi lity of that equipme nt. The insp ectors selected the areas based on a review of the licensee's safe shutd own analysis probabili stic risk assessme nt, sensitiv ity studi es for fire-related core damage acciden t sequences, and s ummary statements rel ated to the l icensee's 1992 Initia l Plant Examinati on for External Events su bmittal to the NRC. Documen ts review ed are lis ted in the Attach ment.* Unit 1 Ex terior Doghouse
===Cornerstone: Emergency Preparedness===
* Main C ontrol Room
* Unit 2 Au xiliary Feedwate r Pump Room
* Unit 1 M echanical Penetration R oom, 543 foot elev ation * Unit 1 El ectrical Pen etration Room, 5 60 foot eleva tion* Unit 2 M echanical Penetration R oom, 577 foot elev ation* Unit 1 Sp ent Fuel Bu ilding Fan Room, 636 foot el evation* Nuclear Se rvice Water Pump House Fire Drill Observation. On March 3, the inspec tors observed a shift fire dril l simulati ng an oil fire i n the Unit 1 Main Turb ine Oil Tank roo m located on the 594 foot ele vation of the tur bine buil ding. The pur pose o f this a nnual insp ectio n wa s to: mo nitor the fire brigade's use of protective gear and fire fighting equipmen t; verify that fire fighting pre-plan procedu res and approp riate fire fighting techn iques were used; and v erify that the direc tions of the fi re bri gade l eader were thorou gh, cle ar, and effectiv e. The inspe ctors also attended the subsequent drill critique to assess whether it was appropriately critical, included discussi ons of drill obser vations, and identi fied an y areas re quirin g corr ective actio n. Doc uments revi ewed are l isted in th e Attac hment.b.Fin din gs No findings of signi ficance were identified.


1R11 Licensed Opera tor Requalificati on a.Inspection Sc ope Resident Quarte rly Observ ation. The inspectors observed Active Si mulator Exam Scenario 16 to assess the performance of license d operators. The exercise i ncluded a loss of condens er vacuum, l oss of 6.9 kV bus, l oss of a reactor co olant pump, l oss of normal pow er to an essen tial train, an Anticip ated Transient w ithout a Scra m, and a 5 Enclo sure steam line b reak outside of conta inment. The in spection focused on high-risk opera tor actions performed du ring implementati on of the emergency operating procedu res, emergency plan implementatio n and class ification, and the incorpora tion of lessons-lea rned from previou s plant ev ents. Through observ ations of the cri tique conducted by training ins tructors follow ing the exam session, the inspectors ass essed whether app ropriate feedback w as provid ed to the li censed operato rs regarding identified w eaknesses.
1EP6 Drill Evaluation a   Inspection Scope The inspectors observed and evaluated the licensees performance in the Control Room simulator and in the Technical Support Center during an emergency drill conducted on March 2. The NRCs assessment focused on the timeliness and location of classification, development of notification and protective action recommendations, and the licensees expectations of response. The performance of the emergency response organization was evaluated against applicable licensee procedures and regulatory requirements. The inspectors attended the post-exercise critique of the drill to evaluate the licensee's self-assessment process for identifying deficiencies related to individual and overall performance during the emergency drill. The inspectors assessed the drill for weaknesses and deficiencies in performance of classification and notification requirements.


b.Fin din gs No findings of signi ficance were identified.
====b. Findings====
No findings of significance were identified.


1R12 Maintena nce Effectiveness a.Inspection Sc ope The inspectors re viewe d the lice nsee's effectiven ess in performing the two follow ing routine maintenance activities. This review included an assessment of the licensee's practices pertai ning to the id entification, sc ope, and han dling of degraded e quipment conditions, as well as common cause failure eva luations an d the resoluti on of historical equipment problems.
==OTHER ACTIVITIES==
{{a|4OA2}}
==4OA2 Identification and Resolution of Problems==


For those systems, structu res, and components (SSCs)
===.1 Daily Review===
scoped in the maintenance rule per 10 CFR 50.65, the inspectors verified that reliabil ity and unavail ability were prop erly monito red, and that 10 CFR 50.65 (a)(1) and (a)(2)
class ificati ons w ere jus tified in l ight of th e rev iew ed degr aded e quipmen t cond ition. Docume nts rev iew ed are list ed in the At tachmen t.*Repair of a throu gh-wall l eak found on the B Train RN supp ly heade r between manways #8 and #9*Repai rs of the 1B Sp ent Fu el Po ol Co olin g Pump b.Fin din gs No findings of signi ficance were identified.


1R13 Maintena nce Risk Asses sments and Emergent Work Evaluati on a.Inspection Sc ope The inspectors re viewe d the lice nsee's asses sments concernin g the risk impact of removing from servi ce those compon ents associate d with th e eight emergent and planned w ork items listed below. This review primarily focused on acti vities d etermined to be risk signi ficant withi n the maintena nce rule. The inspectors al so assessed th e adequa cy of th e lic ensee's id entifi catio n and resol ution of prob lems a ssoci ated w ith maintenance ri sk assessments and emergent work activ ities. The i nspectors rev iewed Nuclear Sy stem Directiv e (NSD) 415, Operational R isk Management (Modes 1-3) and NSD 4 03, Sh utdow n Ris k Mana gement (M odes 4 ,5,6, a nd No Mode), for ap propri ate guidance to comp ly wi th 10 CFR 5 0.65 (a)(4). Docu ments review ed are lis ted in the Attach ment.
As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed screening of items entered into the licensees corrective action program. This was accomplished by reviewing copies of PIPs, attending some daily screening meetings, and accessing the licensees computerized database.


6 Enclo sure*Entr y an d da y-to-day acti vit ies rel ated to th e A T rain of RN outa ge*Entr y an d da y-to-day acti vit ies rel ated to th e B T rain of RN outa ge*Schedule re view and eval uation of plan ned/in-progress w ork following th e discove ry of a potential RN header leak*Schedule re view and eval uation of plan ned/in-progress w ork following th e discove ry of a potential RN header leak betwee n manholes #
===.2 Annual Sample Review===
8 and #9*Sched ule re view and a ssessme nt of pl anned activ ities wit h Orange grid st atus d ue to problems at Be lews Cre ek Steam Station
*Schedule re view and assessment o f planned acti vities o n Unit 2 foll owing the fai lure of the primary D igital Feedw ater Control S ystem controll er and unex pected replac ement of a pressuriz er level transmitter
*Revi ew a nd ass essmen t of resc hedul ed majo r Unit 2 refue ling o utage a ctiv ities due to failure of the Con tainment Clos ure Test*Review and assessmen t of rescheduled major outage activ ities due to maintenance on 2B Spent Fuel Cooling Pump prior to core off load, failure of the Unit 1 Reactor Trip Breaker during surv eillance testing, and a turbine lub e oil transfer p ipe leak b.Fin din gs Introduction. A Green NCV of 10 CFR 50.6 5(a)(4) was i dentified by the inspecto rs for the license e failing to ad equately ass ess and manage th e risk pertaini ng to a portion of the maintenance activiti es associated with the removal of the A Train of nucl ear service water (RN) from se rvice for a pl anned 14-day outage.Description. On January 5, the A Train of nuclear serv ice water (RN) was re moved from service to allow for the header to b e drained, i nspected and refurbished due to ongoing degradation of th e piping. The removal of the A Tra in of RN from service resulted in other equipment an d systems bei ng rendered ino perable in cluding the 1 A and 2A emergency dies el generators (DG).


As part of the li censee amendment that granted a one-time exte nsion of the no rmal 72-hour LC O allowe d outage time (AOT) to 1 4 days, the license e committed to i mplement a number of actions to manage the eleva ted risk created by th is activi ty. These in cluded prov iding temporary cooling to th e DG via the fire protection sy stem during the pe riod the RN header w as out of servi ce and to prote ct equipment on the opposite tr ain; i.e., the B Train and protect ing the opposite train equipment whe n one train of RN was re moved from servi ce.The A Train of RN was remov ed from service at approxi mately 2100 on January 5 and the 1A and 2 A DGs w ere de clare d ino perabl e at th at time. Insta llati on of th e tempo rary cooli ng lin es from th e fire p rotecti on sy stem to the di esel jacket w ater he at ex changer s did not commenc e until the morning of January 6, 2006 and was not worked continuousl y until completed (appro ximately 1300 for the 1A diesel an d 1500 for the 2A diesel). The initial effort s were directed at restoring the 1A DG; however, the 2A DG was r equire d for the opera tion o f the 1A DG bec ause t he 2A DG pow ered th e A fire pump w hich woul d be re quired to pro vide cool ing to the A Tr ain D Gs on a loss of offsite power. This sequence requir ement had not been identified by the licensee in scheduling the installa tion of the temporary cooling to th e DGs prior to enter the 14-day LCO.
====a. Inspection Scope====
The inspectors selected PIPs C-05-6471 and C-05-7516 for detailed review. Both involved increased outboard pump bearing temperatures on the 1B Spent Fuel Cooling pump. These PIPs were reviewed to determine whether the full extent of the issues were identified, an appropriate evaluation was performed, and appropriate corrective actions were specified and prioritized. The inspectors evaluated the PIPs against the requirements of the licensees corrective action program document and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.


7 Enclo sure During the peri od of time in w hich the tw o A Train DGs w ere unavai lable, a mob ile crane traversed the roof area of the 2B D G on two oc casions prep aring to lift the 2 A diesel room roof hatches. While the cran e movement w as done in accordance w ith an approved sta tion procedure for the work on th e 2A DG, the l icensee di d not consid er the curr ent p lan t con diti on; i.e., two of fou r DGs ino pera ble wi th bo th un its in a n Ora nge ORAM/SENTINE L risk conditi on. In addi tion, whi le the 2B D G itself had bee n posted with protec ted equipment si gnage, the roof area and support equipment such as the diesel lube oil storage tanks and the 2A/2B f ire protection and carbon dioxide (CO 2)headers had n ot been posted. As a resul t of not protecting thes e components an d areas, the crane movement had the potential to render the 2B DG inope rable leav ing the sta tion w ith on ly o ne ope rable DG in the ev ent no rmal A C pow er wa s lost. On January 5, th e A Train of RN was remov ed from service to allow for the header to be drained, in spected and re furbished due to ongoing degradation of the piping.
====b. Findings and Observations====
No findings of significance were identified.


The remov al of th e A Trai n of RN from serv ice re sulte d in o ther equ ipment and s ystems being rendered inoperable includi ng the 1A and 2A emergency D Gs. As part of the lice nsee a mendmen t that gr anted a one-time ex tensi on of th e norma l 72-h our LC O AOT to 14 d ays, the li censee commit ted to provi de temp orary cool ing to the DG via the fire protection sy stem during the pe riod the RN header w as out of servi ce and to prote ct equipment on the opposite trai n; i.e., the B Train.Analysis. Aspe cts of th is mai ntenan ce wo rk whi ch demo nstrate d ina dequate assessment and manag ement during planned maintena nce on the A Train of the RN sys tem i ncre ased ris k inc lud ed th e fol low ing: The li censee's ri sk asse ssment failed to full y con sider risk si gnifica nt SSC s and suppo rt systems that w ere unavai lable duri ng the maintenanc e activi ties.*Restoring the DGs to avail able status w as a commitment made as part of the l icensee amendme nt reque st subm itted by th e lic ensee. Work to resto re the 1A and 2A DGs to avai labl e statu s was not i nitia ted pro mptly whe n appr opria te con ditio ns we re establ ished nor w as the work p erformed on a c ontin uous b asis u ntil comple te. In addition, the correct sequence of restoring the 2 DGs (2A follow ed by 1A)
{{a|4OA5}}
was not impl emen ted. Thes e ac tion s w oul d ha ve m ini miz ed th e Inc reme ntal Cor e Da mage Probabili ty valu e that resulted from this portion of the planned LCO activi ties.The li cen see's ris k as ses sme nt f ai le d to acc oun t fo r th e p oss ib le un av ai la bi li ty of a single train of a sy stem (pr imary or bac k-up) th at prov ides a shut down key sa fety function.*The potential impact on the station's emergenc y AC pow er system due to movement of a mobile cran e on the 2B DG roof in close proximity to support equi pment was n ot considered in the risk assessme nt performed in support of the A Train RN LCO outage schedule nor once the outage.The licensee failed to effectiv ely impl ement or manage presc ribed significa nt compensatory mea sures.*As part of the li cense amendment re quest, the licen see committed to p rotect the 1B 8 Enclo sure and 2B diesel generators during t he A Train LCO outage to minimize the overall station risk ex posure and de veloped a plan to p ost the equipment when the LCO was entered. How ever, the roo f area and adjacen t support equipmen t was not i ncluded within this protected equipment bounda ry and as a result, w ork was all owed to b e performed in clos e proximity to equipment w hich had the potential to adversel y impact the op erabi lity of the 2 B DG. *Changes in w ork scope and ac tivities conducted i n the vic inity of the 2B DG were not communi cated back to Operati ons or Engin eerin g to ens ure tha t the c hanges were assessed in a timely ma nner and di d not affect the ove rall station risk value s.The finding was more than minor because it w as associated with the Equipment Performance attribute of the Mitigati ng Systems corne rstone and affected the corner stone objecti ve of e nsuri ng the a vail abil ity, relia bili ty, an d capa bili ty of sy stems whi ch resp ond to init iatin g even ts to p reven t unde sirab le co nsequen ces is mainta ined. The in specto rs dete rmined that th e findi ng is o f very low risk si gnifica nce (Gre en), base d on the resu lti ng ma gnit ude of the cal cul ated Incr emen tal Core Dama ge Probability (5.8E-7/day), the length of time that the two A Train diesels were unavailable (<18 hours) and that no actual loss of saf ety function of the 2B DG occur red. This finding invo lved the cross-cutting aspec t of human performance.
==4OA5 Other Activities==


Enforcement. 10 CFR65 (a)(4), "Requirements for monitoring the Effectiv eness of Maintena nce at Nucl ear Power Plants," requires in part, that pri or to performing maintenance ac tivities , the licens ee shall assess and man age the increase in risk that may re sult fro m the pr opose d main tenanc e acti viti es. Co ntrary to the abov e, on J anuary 5 and 6, 200 6, the licen see failed to implement the re quirements of 10 CFR 50.65(a)(4)
===.1 (Closed) URI 05000414/2004007-03: Derating Selected Emergency Lighting Units Required===
to adequately assess and manage the increa se in risk duri ng the executi on of planned main tena nce asso cia ted w ith the A Trai n of R N, w hic h pl aced the stat ion in a n Ora nge ORAM ris k con diti on, a nd mi nimi ze t he o ver all ris k ex posu re as demo nstr ated thro ugh the fo llo wi ng:*The licensee failed to ex peditiousl y instal l temporary c ooling to the 1A and 2A DGs as committed to in the License Amendm ent Request (LAR) that allowed the 14-day LCO which res ulted in u nnecessary unavail ability of the DGs, whe n the RN he ader was drained and the temporary cooling w as being ins talled, by not starting the w ork as soon as cond itions permi tted or workin g the job on a c ontinuous ba sis.*The licensee failed to pos t the roof area abo ve the 1B and 2B DGs a nd adjacent support equipment as protected equi pment as committed to in the LA R to ensure th e operabili ty of the remaini ng safety-related e quipment was not jeopardiz ed.*The licensee allow ed a mobile crane to trav erse the roof area a bove the 2 B DG prior to restoring the 2A DG to available status to m inimize the potential impact this moveme nt cou ld ha ve on an op erabl e pie ce of sa fety-re lated equip ment.*The licensee failed to properly sequenc e the actions taken in restoring the A Train diesel genera tors to avai lable status to ensure the 2A diesel generator was returned fir st, wh ich wa s re qui red to pro vi de coo li ng t o b oth A Tr ai n D Gs i n th e e ve nt o f a LOOP.*The li censee faile d to effec tive ly c ommuni cate th e ele vated risk as socia ted w ith planned w ork activiti es to station personnel to ensure that cha nges in wo rk scope or 9 Enclo sure schedu les w ere el evate d to th e appr opria te pers onnel for rev iew and a ssessme nt. Because this finding is of v ery low safety significan ce and has b een entered i nto the licensee's corrective action program as PIP C-06-005 7, this vi olation i s being treated as an NCV consistent with Section VI.A.1 of the NRC Enfo rcement manual (NCV 05000413, 414
/2006002-01, Ina dequate Risk Asse ssment and M anagement Associ ated with Plan ned Nu clear Serv ice Water Sy stem M ainte nance).1R14 Operato r Perform ance D uring N on-Rou tine P lant E volu tions and E vents a.Inspection Sc ope The inspectors o bserved ope rator performance durin g the shutdow n of Unit 2 for the refueling outage. The i nspectors observ ed license d operators' u se of procedures, control room pre-e volution briefing, and pl ant equipment mani pulations d uring the pow er reduct ion, ma nual reacto r trip, and p ortion s of the subsequ ent co oldow n. b.Fin din gs No findings of signi ficance were identified.


1R15 Operability Evaluati ons a.Inspection Sc ope The inspectors re viewe d five operab ility e valuatio ns to veri fy that the opera bility of systems importan t to safety w ere properly establishe d, that the affected compon ents or systems remaine d capable of performing their inten ded safety functio n, and that no unreco gnize d inc rease in pl ant or publi c risk o ccurre d. Oper abil ity e valu ation s wer e review ed for the five i ssues listed below. Documents rev iewed a re listed i n the Attach ment.*2B Chemical & Volume Control (NV) charging pum p oil leak (PIPs C-05-7243 and C-06-0197)*Non-conserva tive setpoi nts for the reactor coo lant system (N C) flow in strument loop uncertainty calculatio ns (PIP C-06-0 061)*Top left stud on 2B DG crankcase door 8R was b roken during reins tallation of the cover (PIP C-06-1238)*2A DG r oom ve ntila tion s ystem damper found t o hav e a bro ken we ld affect ing it s operation (PIP C-06-0997)
for Post-Fire Safe Shutdown
*Operability Assessment to deter mine past operability/reportability of the FW ST to ND suction va lves w hen realigni ng from Residual H eat Removal (RHR) mode to Injection mode whil e in Mo de 4 (PIP C-0 6-0809)b.Fin din gs No findings of signi ficance were identified.


10 Enclo sure 1R19 Post-Main tenance Testing a.Inspection Sc ope The inspectors w itnessed and
====a. Inspection Scope====
/or review ed six p ost-maintenance testing procedures and/or test a ctiv ities , as ap propri ate, for selec ted ri sk signi ficant s ystems to ve rify i f: (1) tes ting w as ade quate for the mai ntenan ce per formed; (2) accep tance criter ia w ere clear and ad equately demon strated operatio nal readin ess consisten t with de sign and licensing b asis documents; (3) test instrumenta tion had curre nt calibrati ons, range, and accura cy co nsiste nt wi th the appli catio n; (4) t ests w ere pe rformed a s wri tten w ith applicabl e prerequisites satisfied; and (5) equipment wa s returned to the status required to perfo rm its s afety fun ction. Docu ments re view ed are list ed in the At tachmen t.*Verification o f piping/flange integrity followin g completion of the B RN suppl y header 14-day LCO outage invol ving replac ement of existi ng piping and addition o f new cross-over con nections*Calibratio n and functiona l testing of B Train RN suppl y header a nnubar flow instrumentation
The inspectors preformed an in-office review of the documents listed in the Attachment to determine if the ability to achieve and maintain safe shutdown (SSD) was adversely affected.
*Functional stroke testing of 2RN69B
; B Train RN supply h eader isola tion val ve, follow ing 14-day LCO ou tage w ork*Operati onal testin g of the 1 B/2B R N pump s follo win g the B Train R N LCO A OT*Testing of the 1B RN pump strainer differential pressure switch fol lowing refurbishment of the strai ner and assoc iated instrumen tation*Functi onal test of th e 1B R N pump strai ner fol low ing refur bishme nt b.Fin din gs No findings of signi ficance were identified.


1R20 Refueling and Outa ge Activiti es a.Inspection Sc ope The inspectors e valuated Unit 2 refueli ng outage activi ties to ve rify that the l icensee consi dered risk in deve lopi ng and imple mentin g outage schedu les; a dhered to administrativ e risk reduction methodologies develope d to control p lant configuration
====b. Findings====
;deve loped mitiga tion s trategi es for l osses of key s afety fun ction s; and adher ed to operating lic ense and TS requi rements that ensure defense-in-depth.


The followi ng speci fic area s wer e rev iew ed. Do cuments revi ewed are l isted in th e Attac hment.*Review of Outage Plan
=====Introduction.=====
*Monitori ng of Shutdown Activiti es*Licensee C ontrol of Outage Activ ities*Clearance A ctivitie s*Reactor Cool ant System Ins trumentation
The inspectors identified a Green NCV of CNS operating License Condition 2.C.5, Fire Protection Program. The licensee made a change to the approved FPP which had the potential to affect post-fire safe shutdown capability. Specifically, the licensee derated the time requirement for 43 battery-powered ELUs from 8 hours to 1.5 hours. The licensees evaluation for this change did not adequately demonstrate that the change would not adversely affect the ability to achieve and maintain SSD in the event of a loss of power to normal lighting during a fire.
*Electrical Power*Decay He at Removal System M onitoring*Spent Fuel Pool Cool ing System Opera tion 11 Enclo sure*Inventory Control*Reactivi ty Control
*Contai nment C losur e*Reduced Inv entory and Mid-Loop Condition s*Refueling Activ ities b.Fin din gs No findings of signi ficance were identified.


1R22 Surveill ance Testing a.Inspection Sc ope The in spe cto rs o bse rv ed and/or rev ie we d th e si x s urv ei ll anc e te sts li ste d b el ow to ve rif y that TS surve illa nce re quireme nts an d/or Se lect L icens ee Com mitment requir ements were prope rly c ompli ed w ith, a nd tha t test a ccepta nce cri teria were prope rly s pecifi ed. The inspectors v erified that prop er test conditi ons were e stablished as specified i n the procedures, that n o equipment preco nditionin g activitie s occurred, and that acceptance criteria had been met. Addi tionally , the inspecto rs also ve rified that equipme nt was proper ly re turned to ser vice and th at prop er test ing w as spe cified and c onduc ted to ensure that the equipment could perform its intend ed safety function followin g maintenance or as part of survei llance testi ng. Documents rev iewed a re listed i n the Attach ment.Surve illa nce Tes ts*Flow bala nce of th e A Trai n of RN follo win g compl etion of the 1 4-day LCO AO T*1RN-28A; 1A RN pump dis charge isolati on valv e, inservi ce test*2A DG EQC Sy stem Time Delay and Underv oltage Relay Calibrati on In-Serv ice Tes ts*Quarter ly In-Serv ice Tes t for moto r opera ted v alve 1RN-6 3A; RN heade r A retu rn to Standby N uclear Serv ice Water Pond Ice Co ndens er Surv eill ance Te sts*MP/0/7/7150/006, Ice Condenser Lower Inlet Doors Inspection and Testing (As Found), Rev. 24*MP/0/A/7150
=====Description.=====
/005; Ice Basket Weight Determinatio n (Unit 2, B ay 4, Baskets 6-9, 7-9, 8-9 and 9-9); R ev. 24 b.Fin din gs No findings of signi ficance were identified.
The licensee derated the time requirement for 43 battery-powered ELUs from 8 hours to 1.5 hours by minor modification CE-70695. These ELUs were credited for illumination of access/egress pathways or equipment for local manual operator actions associated with alternative shutdown. This change to the FPP was not consistent with the licensing basis, which stated that 8-hour battery-powered emergency lights would be provided. The justification for derating selected ELUs credited for post-fire SSD was provided in calculation CNC-1435.00-00-0018. The calculation stated that derating selected SSD ELUs was acceptable because access, operator activities, and egress could occur well within 30 minutes. However, as discussed in NRC Inspection Report 05000413, 05000414/2004007, the abnormal procedures in effect at the time of that inspection may not have activated the standby shutdown facility (SSF) within the 30-minute or 1.5-hour timeframes for fire events which may require activation of the SSF. Instead, the procedures directed operators to remain in the control room until it became uninhabitable or became incapable of maintaining primary or secondary inventory. Then the procedures directed operators to go to the alternate shutdown panel, in a lower level of the auxiliary building, and remain there until the controls there were determined to be inadequate to maintain safe plant conditions. Only then did abnormal procedures direct operators to activate the SSF. The delays in activating the SSF were not addressed in Calculation CNC-1435.00-00-0018 nor the 10 CFR 50.59 safety evaluation performed for minor modification CE-70695 and the associated Updated Final Safety Analysis Report (UFSAR) revision for this change.


12 Enclo sure 1R23 Temporary Plan t Modificati ons a.Inspection Sc ope The inspectors re viewe d the follow ing two tempora ry plant mod ifications to d etermine whether the indivi dual modificati on was p roperly i nstalled; the modification d id not affect syste m opera bili ty, dr awi ngs and proce dures were appro priate ly u pdated; and p ost-modification testi ng was sati sfactorily performed.
=====Analysis.=====
This finding is more than minor because it had the potential to impact the licensees post-fire safe shutdown capability by delaying operator response in the event of a loss of power to normal lighting during a fire. Access, operator activities, and egress may occur at later times than assumed in the calculation for the derated ELUs.


Documents rev iewed a re listed i n the Attach ment. *Installation of temporary cool ing to the lub e oil hea t exchanger an d air compresso r aftercoolers on the 1A and 2A DGs in supp ort for the 14-day A Train RN outage.*Bypassin g the non-essenti al chill er trips on the B Train control room area (YC)
The finding was of very low safety significance (Green) because the inspectors determined that operators would likely be able to accomplish the actions with the use of flashlights.
chiller in support for the 14-day A Trai n RN outage.


b.Fin din gs No findings of signi ficance were identified.
=====Enforcement.=====
Operating License Condition 2.C.5 requires that the licensee implement and maintain in effect all provisions of the approved FPP, as described in the UFSAR, as amended, for the facility and as approved in the Safety Evaluation Report (SER)through Supplement 5. Branch Technical Position (BTP) CMEB 9.5-1, which incorporated the guidance of Appendix A to BTP ASB 9.5-1 and the technical requirements of Appendix R to 10 CFR Part 50, established the regulatory and licensing requirements for the FPP at CNS. The CNS FPP was reviewed against and approved for conformance with BTP CMEB 9.5-1 in the SER through Supplement 5. BTP CMEB 9.5-1, Item C.5.g.(1), states, in part, that lighting is vital to safe shutdown and emergency response in the event of fire. In addition, fixed self-contained lighting consisting of fluorescent or sealed-beam units with individual 8-hour minimum battery-power supplies be provided in areas that must be manned for safe shutdown and for access and egress routes to and from all fire areas.


Cornerstone: Emergenc y Preparedn ess 1EP6 Drill Ev aluation a Inspection Sc ope The inspectors o bserved and evaluate d the lice nsee's performance in the Contro l Room simulator and in the Techni cal Support Center during an emergency dril l conducted on March 2.
Contrary to the above, on June 25, 2004, the inspectors identified that the licensees evaluations failed to ensure that the derating of selected ELUs from 8 hours to 1.5 hours would not adversely affect the ability to achieve and maintain safe shutdown in the event of a loss of power to normal lighting during a fire. Procedural delays for activating the SSF were not addressed in either Calculation CNC-1435.00-00-0018 or the 10 CFR 50.59 safety evaluation performed for minor modification CE-70695. Access, operator activities, and egress may occur at times later than the 30 minutes or 1.5 hours assumed in the calculation for the derated ELUs. This condition has existed since May 2001. The licensee documented this violation in the corrective action program as PIP C-04-04276. The emergency light testing procedure, IP/0/B/3540/002, was changed from the 1.5-hour test period back to 8 hours. In addition, CNS also retested the derated ELUs for compliance with the 8-hour requirement. Twenty-three of the 43 ELUs provided less than the minimum 8-hour lighting requirement. The licensee replaced the batteries for the 23 ELUs. Because of the very low safety significance and the licensee has entered this violation into their corrective action program, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy and is identified as NCV 05000414/2006002-02, Derating Selected Emergency Lighting Units Required for Post-Fire Safe Shutdown.


The NRC's as sessment focused on the timeline ss and loca tion of classificatio n, develo pment of notification and protectiv e action reco mmendations, and the license e's expe ctations of respon se. The performance of the emergency respon se organi zati on w as ev aluat ed agai nst ap plic able lice nsee p rocedu res an d regul atory require ments. The in specto rs atte nded t he pos t-exe rcise criti que of the dril l to e valu ate the license e's self-assessment p rocess for identi fying deficienci es related to indivi dual and overall performance during the emergency drill. The inspectors assessed the drill for weaknesses an d deficienci es in performance of classification and notificati on requirements.
{{a|4OA6}}
==4OA6 Meetings==


b.Fin din gs No findings of signi ficance were identified.
===.1 Exit Meeting Summary===


13 Enclo sure 4. OTHER ACTIVIT IES 4OA2 Identi ficatio n and Resol ution of Prob lems.1 Daily Review As required by Inspection P rocedure 71152 , "Identification and Resolu tion of Problems,"
On April 12, the resident inspectors presented the inspection results to Mr. D. Jamil and other members of licensee management, who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection period.
and in order to h elp identi fy repetitiv e equipment failu res or specific human performance is sues for follow-up, the inspect ors perform ed screening of items entered into the licensee's corrective a ction program. This was accompl ished by review ing copies o f PIPs, attending some da ily screen ing mee tings, a nd acc essin g the l icens ee's compute rize d data base. .2 Annual Sa mple Revi ew a.Inspection Sc ope The in specto rs sel ected PIPs C-05-64 71 and C-05-7516 fo r detai led re view. Both involv ed increased outboard pump bearing temperatures on the 1B S pent Fuel C ooling pump. These PIPs were rev iewed to determine w hether the full extent of the i ssues were ident ified, an approp riate eval uation was p erfo rmed, and appro priate c orrect ive actions w ere specified a nd prioriti zed. The i nspectors ev aluated the PIPs against the requirements of the li censee's corre ctive acti on program document a nd 10 CFR 50, Appen dix B. Do cuments revi ewed are l isted in th e Attac hment.b. Findings and Observation s No findings of signi ficance were identified.


4OA5 Other Activi ties.1 (Closed) UR I 05000414/200 4007-03: Derati ng Selected E mergency Lightin g Units Required for Post-Fir e Saf e Shut down a.Inspection Sc ope The inspectors p reformed an in-office rev iew of the d ocuments liste d in the Atta chment to determine if the ability to achieve and maintain safe shutdown (SSD) was adversely affected.b.Fin din gs Introduction. The inspectors identified a Green NCV of CN S operating Li cense Condition 2.C.5, Fire Pro tection Program. The licensee mad e a change to th e approved FPP which had t he poten tial to af fect post-f ire saf e shutdo wn capabilit y. Specif ically, the li censee derate d the t ime re quireme nt for 43 batter y-pow ered E LUs from 8 hour s to 1.5 ho urs. Th e lic ensee's ev aluat ion for this change did n ot ade quatel y demo nstrate that the change w ould not ad versely affect the ability to achiev e and maintai n SSD in the event of a lo ss of power to normal lighti ng during a fire.
===.2 Annual Assessment Meeting Summary===


14 Enclo sure Description. The licensee derated the time req uirement for 43 batt ery-powered ELUs from 8 hours to 1.5 h ours by min or modification CE-70695. These ELUs we re credited for illuminati on of access/egress pa thways or equipment for loca l manual op erator actions assoc iated wi th alternativ e shutdown. This change to the FPP w as not consistent w ith the li censing basis , which stated that 8-hou r battery-pow ered emergency lights wou ld be prov ided. The jus tificat ion for derati ng sele cted E LUs cr edite d for po st-fire SSD wa s provide d in calcu lation CN C-1435.00-00-001 8. The calcul ation stated th at derating selecte d SSD ELU s was acc eptable beca use access, op erator activi ties, and egress could oc cur well within 30 minutes.
On April 26, the NRC's Acting Chief of Reactor Projects Branch 1 and the Resident Inspectors assigned to the CNS met with Duke Energy Corporation to discuss the NRC's ROP and the NRC's annual assessment of CNS safety performance for the period of January 1, 2005 - December 31, 2005. The major topics addressed were: the NRC's assessment program and the results of the CNS assessment. This meeting was open to the public. A listing of meeting attendees and information presented during the meeting are available from the NRC's document system (ADAMS) as accession number ML061170325.


Howeve r, as discusse d in NRC Inspection Report 050004 13, 05000414/2 004007, the ab normal procedure s in effect at the ti me of that inspecti on may not h ave activ ated the standb y shutdow n facility (SSF) wi thin the 30-minute or 1.5-hour timeframes for fire ev ents whic h may require activation of the SSF. Instead, the procedure s directed operators to rem ain in the control room until it became unin habit able or bec ame in capab le of ma intai ning p rimary or sec ondary inven tor y. The n the proc edur es dir ecte d oper ator s to g o to t he alt erna te sh utdo wn panel , in a low er lev el of th e aux ilia ry bu ildi ng, and remai n there until the co ntrols there were determined to be inadequate to ma intain safe plant conditions. Only then did abnormal proced ures direct op erators to activ ate the SSF.
ADAMS is accessible from the NRC Web site at www.nrc.gov/reading-rm/adams.html.


The delays in activ ating the SSF were not a ddressed in Calculati on CNC-1435
ATTACHMENT:
.00-00-0018 nor the 10 CFR 50.59 safety eval uation performed for min or modification CE-70695 and the associa ted Updated Fin al Safety An alysis Report (UFSAR) revisio n for this change.


Analysis. This finding i s more than mino r because it had the potenti al to impact the licensee's post-fire safe shutdo wn capabi lity by delayi ng operator respons e in the ev ent of a lo ss of po wer t o norma l li ghting d uring a fire. Access, opera tor activiti es, and egress m ay oc cur at later times t han as sumed i n the c alcul ation for the derate d ELU s. The find ing w as of v ery l ow sa fety si gnifica nce (Gre en) be cause the in specto rs determined that operators wo uld likely be able to accomplish the actions w ith the use o f flashlights.
=SUPPLEMENTAL INFORMATION=


Enforcement. Operating Lice nse Conditi on 2.C.5 requires that the li censee imple ment and maintain in effect all provisions of the approved FPP, as described in the UFSAR, as amended, for the facility and as approved in the Safety Evaluation Report (SER)
==KEY POINTS OF CONTACT==
through Supplemen t 5. Branch Tech nical Pos ition (BTP) CM EB 9.5-1, w hich incorporated th e guidance of Ap pendix A to BTP ASB 9
.5-1 and the tec hnical requirements of Append ix R to 10 CFR Part 50, establis hed the regulato ry and li censing requirements for the FPP at CNS. The CNS FPP w as review ed against and approved for confor mance with BTP CMEB 9.5-1 in the SER through Supplement 5. BTP CMEB 9.5-1, Item C.5.g.(1), states, i n part, that li ghting is vi tal to safe shutdo wn and emergency respon se in the e vent of fire. In ad dition, fixe d self-contained lighting consist ing of fluore scent or sealed-b eam unit s with individua l 8-hour minimum batter y-power supp lies be p rovided i n areas that must be manned for safe shu tdown and for access and egress routes to and from all fire areas.


Contrary to the above, on June 25, 2004, the inspector s identified that the licensee's eval uatio ns fail ed to e nsure that th e dera ting of s elect ed ELU s from 8 h ours to 1.5 ho urs would n ot adversel y affect the abil ity to ach ieve and maintain sa fe shutdown i n the even t of a loss of pow er to normal l ighting during a fire.
===Licensee Personnel===
: [[contact::K. Adams]], Human Performance Manager
: [[contact::E. Beadle]], Emergency Planning Manager
: [[contact::S. Beagles]], Chemistry Manager
: [[contact::W. Byers]], Security Manager
: [[contact::J. Ferguson]], Safety Assurance Manager
: [[contact::J. Foster]], Radiation Protection Manager
: [[contact::W. Green]], Reactor and Electrical Systems Manager
: [[contact::G. Hamrick]], Mechanical, Civil Engineering Manager
: [[contact::D. Jamil]], Catawba Site Vice President
: [[contact::R. Hart]], Regulatory Compliance Manager
: [[contact::A. Lindsay]], Training Manager
: [[contact::J. Pitesa]], Station Manager
: [[contact::L. Reed]], Modifications Engineering Manager
: [[contact::R. Repko]], Engineering Manager


Procedural delays for ac tivating the 15 Enclo sure SSF were not addressed in either Calculati on CNC-1435
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
.00-00-0018 or th e 10 CFR 50.5 9 safety eva luation pe rformed for minor modificatio n CE-70695.


Access, operat or acti viti es, an d egress may o ccur at times later than th e 30 mi nutes or 1.5 hours assumed in the calculati on for the derated ELUs. This conditi on has ex isted since May 2001. The li censee docume nted th is v iola tion i n the c orrecti ve ac tion p rogram as PIP C-04-04276. The emergency light testing procedure, IP/0/B/3540/002, w as changed from the 1.5-hour test pe riod back to 8 hours. In addi tion, CNS a lso retested th e derated ELUs for compliance w ith the 8-hour requirement. Twen ty-three of the 43 ELUs provided less than the minimum 8-hour lighting requirement.
Open and
===Closed===
: 05000413,414/2006002-01      NCV    Inadequate Risk Assessment and Management Associated With Planned Nuclear Service Water System Maintenance (Section 1R13)
: 05000414/2006002-02          NCV    Derating Selected Emergency Lighting Units Required for Post-Fire Safe Shutdown (Section 4OA5.1)


The license e replaced th e batteries for the 23 ELUs. Beca use of the very low sa fety significance and the li censee has entered thi s viola tion into th eir correctiv e action program, th is viol ation is b eing treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy and is ident ified as NC V 0500 0414/2 00600 2-02, D eratin g Sele cted E mergency Lighti ng Uni ts Required for Post-Fi re Safe Shutdow n.4OA6 Mee ting s.1 Exit Mee ting Su mmary On April 12 , the resident inspectors pres ented the in spection resul ts to Mr. D.
===Closed===
: 05000414/2004007-03          URI    Derating Selected Emergency Lighting Units Required for Post-Fire Safe Shutdown (Section 4OA5.1)


Jamil and other m embers of lice nsee ma nagemen t, wh o ackno wle dged th e findi ngs. The insp ectors confirmed that propri etary information was not provided or examined during the in spection period..2 Annua l Ass essmen t Mee ting Su mmary On April 26 , the NRC's A cting Chief of Reacto r Projects Branch 1 and the R esident Inspec tors as signed to the CNS m et wi th Duke Energy Corpo ration to di scuss the NR C's ROP and the N RC's annual assessment of CNS safety performance for the period of Janua ry 1, 2005 - Decem ber 31 , 2005. The ma jor top ics ad dresse d we re: the NRC's assessment program and the results o f the CNS assess ment. This meeting w as open to the publi c. A l istin g of meeti ng atten dees a nd in formatio n pres ented durin g the mee ting ar e avai labl e from the NRC's docume nt sy stem (A DAM S) as a ccessi on numb er ML061170325. ADAM S is a ccessi ble fro m the N RC Web site at www.nrc.go v/read ing-rm/adams.html.ATTACHM ENT: S UPPLE MEN TAL INF ORMA TION Attachment Attachment SUPPL EMENT AL INFORM AT ION KEY POINTS OF CONTACT Licensee Pe rsonnel K. Adams, Human Performance Mana ger E. Beadle, E mergency Plan ning Mana ger S. Beagles, Ch emistry M anager W. Byers, Sec urity M anager J. Ferguson, Safety Assurance M anager J. Foster, Radi ation Protecti on Manager W. Green, Reactor a nd Electrica l Systems M anager G. Hamrick, Mecha nical, Ci vil En gineering Ma nager D. Jamil, Ca tawba Si te Vice Pres ident R. Hart, Regulato ry Compli ance Man ager A. Lindsay , Training Ma nager J. Pitesa, Stati on Manager L. Reed, M odifications E ngineering M anager R. Repko, Enginee ring Manager LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Open and Cl osed 05000413,414/2 006002-01 NCV Inadequate Risk As sessment and M anagement Associated With Planne d Nuclear S ervice Water System Maintena nce (Section 1R13)05000414/2006 002-02 NCV Derating Sele cted Emergency L ighting Units R equired for Post-Fire Safe S hutdown (S ection 4OA5.1)
==LIST OF DOCUMENTS REVIEWED==
Closed 05000414/2004 007-03 URI Derating Sele cted Emergency L ighting Units R equired for Post-Fire Safe S hutdown (S ection 4OA5.1)
LIST OF DOCUMENTS REVIEWED Section 1R04:
Equipment A lignment OP/1/A/6400/005, R ev. 102; Co mponent Cooli ng System Section 1R05:
Fire Protection Pre-Fire Pl an for Fire Strategy Area 2; Aux iliary Building 5 43 foot eleva tion; Rooms 26 0 and 260A Pre-Fire Pl an for Fire Strategy Area 21; Aux iliary Building 5 94 foot eleva tion, Room 573 Pre-Fire Pl an for Fire Strategy Area 51; Ex terior Doghouse Pre-Fire Pl an for Fire Strategy Area 18; Aux iliary Building 5 77 foot eleva tion Pre-Fire Pl an for Fire Strategy Area 6; Aux iliary Building 5 60 foot eleva tion, Room 370 Pre-Fire Pl an for Fire Strategy Area 4; Aux iliary Building 5 43 foot eleva tion, Rooms 20 0 - 248 Pre-Fi re Pla n for Fi re Stra tegy A rea 30; RN P ump Str ucture Cataw ba Nuc lear S tation Fire Drill Scena rio 20 05-5 A-2 Attachment Attachment Catawba N uclear Stati on Fire Strate gy M, Uni t #1 Turbine B uilding, El evation 5 94'Nucle ar Sy stem Di rectiv e 112; Fire Brigad e Organi zati on, Trai ning a nd Res ponsi bili ties, Rev. 7 PIP C-0 5-0 807; Fi re b rig ade sce nar io s w ere con duc ted wi th i nsu ffic ie nt n umb er o f evaluators/c ontrollers to ensure adequacy of responders performance Section 1R12:
Maintenance Effe ctiveness Minor M odification C D500832; Rep airs of RN und erground supply header lea k identified on 2/22/06 Minor M odification V N CD500832 A; Repairs o f second RN und erground supply header lea k identified on 2/23/06 PIP C-06-1265
; Unplanned Tech Spec entry - RN 72 ho ur LCO due to u nderground leak i n the B train RN supply h eader PIP C-05-647 1, 1B S pent F uel P ool C ooli ng Pump outbo ard be aring t empera ture i n Hi a larm PIP C-05-7516, 1B KF Pump outboard pum p bearing temperatur e rose rapidly PIP C-06-079 8, 1B K F Pump rubbe d duri ng ali gnment a nd w ould not rot ate free ly d ue to improp er radi al ce nterin g follow ing reb uild ing pu mp PIP C-06-1583 , KF Pump 2A operational parameters are not as good as pri or to rebuil ding pump PIP C-06-1618 , The KF syste m is Mai ntenance Rul e status A1 ba sed on a Re peat Mai ntenance Preve ntabl e Func tiona l Fai lure o f 1B pum p Section 1R13:
Maintenance Ris k A ssessments and Emergent Work E valuation A Train of RN outage schedule B Train of RN outage schedule Dai ly wor k con trol cen ter s ched ule d w ork a ctiv iti es d urin g the A Tra in R N ou tage Dai ly wor k con trol cen ter s ched ule d w ork a ctiv iti es d urin g the B Tra in R N ou tage Emerging Issu e Training Packag e for the Nuclear Service W ater System 14 Day LCO Modificati on Work, Rev. 02 2006 LCO Rea diness Rev iew M atrix dated 12/30/05 SWP Readiness Assessment dated 01/03/06 Open Items List for the RN LCO dated 12/30/05 Criti cal E volu tion P lan for the 1A , 2A, 1 B and 2B DG R N pip ing rep laceme nt, Rev. 1 Critical E volution Plan for A &
B train RN modification C D500175; 1(2)R N67A and 1 (2)RN69B valv e repl acemen t, Rev. 1 SOER 9 1-01 In frequentl y Per formed Tes ts / Ev oluti on Pl an for th e A an d B RN train LCO AO T Critical Evolution Plan for Modification CD500063, addition of isolation valves and spools in RN discharge heade r Critical E volution Plan for the A
& B train RN supply header clea n and coat pro ject Criti cal E volu tion P lan for RN pu mp hous e LCO w ork on tr ain A and B , Rev. 3 Criti cal E volu tion P lan for A trai n RN r eturn h eader modific ation , Rev. 1 PIP C-05-7587
; Corrective actions from the S RG Independent Assessment Team Rea diness revie w of t he RN 1 4 day AO T wind ows B Train RN A OT Readiness A ction Register, dated 01/25/06 Catawba RN Outage NOED evaluation risk matr ix CNC-1535.00-0 0-0025; Sectio n 9.7, 14 day LCO assuming ba ckup YD cooli ng limitations PIP C-06-1221
; Inspect / repai r potential RN header l eak Work Week 8 sc hedu le (chan ges ma de fo llo wi ng id enti fica tion of po tent ial RN h eade r le ak)
A-3 Attachment Attachment Unit Threat Team repo rts associated with the underground lea k on the RN he ader MP/0/A/7300
/027, Mobi le Crane Opera tions Over S afety Related Structures, Sys tems or Components, Rev. 002 MP/0/A/7400
/056; Diesel Room Equipment Hatch Cove rs Removal and Replac ement, Rev. 01 0 Service Wa ter Project A Train Extended LCO Hi Level schedule Catawba N uclear Stati on Calcul ation 1139.13-02-0001, Crane loading ana lysis o f the diesel generator build ing roofs, Rev. 3 2 Work Order WO 98714306, Task 41, Remove and replace DG 1A roof hatch Work Order WO 98709781, Task 36, Remov e and repla ce DG 2A roof hatch Catawba N uclear Stati on, Units 1 and 2, Issuance of License Amen dments to all ow on a one-time basis, the removal of a nuclear serv ice water supply h eader from servic e for 14 days for system upgrades, d ated Novembe r 17, 2005 NSD 213; Ri sk Management Pro cess, Rev. 0 6 NSD 415; Opera tional Ri sk Management; Re v. 03 OMP 2-18; E quipment Protectio n and Quaranti ne, Rev. 06 6 Section 1R15:
Operability Evaluations WR 98367994; Inspect and rep air diesel generator damper 2D SF D CNS-1579.VD-0 0-0001, Dies el Build ing Ventila tion Design B asis Document WO 98721416; P erform inspection o f damper and hy dramotor on 2VD DA DSFD0 1 OAC traces for 2A d iesel room a mbient temperatures and outside air temperatures for di esel run dates Design Basis Specificatio n CNS-1579.V D-00-001; Die sel Buil ding Ventil ation Sys tem, Rev. 15 PIP C-06-1762
; Return air d ampers on the 2 A DG rom venti lation sy stem found to hav e gaps when the dampers were required to be full y closed PIP C-06-1762 , Document resul ts of extent of cond ition ins pection performed o n VD syste m damper s Section 1R19:
Post-Maintenance Testing MP/0/A/765 0/08 8; C ontr oll ing p roce dure for s yst ems p ress ure t esti ng of A SM E Se ctio n XI D uke Class A, B and C sys tems and componen ts; Rev. 031 Modificati on Test Plan for E ngineering Chan ge CD500175; U nit 2 RN Trai n B Modi ficatio n Test P lan for Engin eerin g Change CD50 0062; Rev. 3 TT/0/A/9100/100; Nucl ear Servic e Water pump annubar calib ration; Rev. 01 Emerson Process Management / D ietrich Stan dard field cal ibration rep ort for the Cataw ba Nuclear Stati on annubar 1 RNFE7510, 7 520 and 2RN FE7510, 7520 CNR-1 210.06-00-00 02, Tech nical Requi rements for RN pump di scharge flow elemen ts 1/2RN FE751 0, 752 0; Rev. 0 WO 98709787, Task 23
; Perform functional tes t of 2RN069B un der CD500174 PT/0/A/4400/022B; N uclear Serv ice Water Pump Train B Performance Test, Rev. 65, c hanges A and B PT/0/A/4400/008B; R N Flow balance, Train B, Rev. 4 4 IP/0/A/3112/002; C alib ration proce dure for RN sy stem ti me del ay re lays and s traine r press ure switches; Rev. 27 IP/0/A/3816/010; B arton model 58 0 and 581 D P switch calibration
; Rev. 27 WO 98755026; Task 42 , Calibrate RN pump strai ner DP sw itch WO 98755026; Task 28
; Functional ly test the 1B RN pump strainer durin g functional test o f the A-4 Attachment Attachment 1B RN pump Modi ficatio n Packa ge CD5 00062; Insta llati on and testi ng of RN syste m compo nents Section 1R20:
Refueling Outage PIP C-06-1876
; PIP documenti ng the results of the Unit 2 M ode 3 Inside Containment B oric Acid Check for 2E OC14 PIP C-06-1873
; PIP documenti ng the loss of reacto r coolant pump oil duri ng the Mode 3 walkd own PIP C-06-1890
; Main S team Isolation Valve 2S M-005 fail ed to fully close wh en the close pushbutton w as depressed Westinghouse presentation on presence of wh iskers on new fuel receiv ed for 2EOC14 PIP C-06-2062
; 2B KF pump outboard seal failure requiri ng seal repla cement prior to c ore offload PIP C-06-1959
; Critique comments on the Unit 2 cooldow n from Mode 3 to Mode 5 PIP C-06-2035
; Three incorrect b askets in the i ce condenser were emptie d due to ex pired data sheets being l eft in the ice condenser w ork book CN-06-006, 2E OC-14-IRT Outage Risk Ass essment Site D irecti ve 3.1.30, U nit Sh utdow n Confi guratio n Cont rol (M odes 4 ,5,6 or No M ode), R ev. 3 2, NSD 4 03, Sh utdow n Ris k Mana gement (M odes 4 , 5, 6 o r No M ode), R ev. 1 4, tagouts 05-2685, 26 86, 2692 and 2693 PT/2/A/4150/001H, In side Contai nment Boric Ac id Check PT/2/A/4350/003, El ectrical Pow er Source Al ignment Verificati on, Rev. 44
.PT/2/A/4200/002C, C ontainment Cl osure Verificati on (Part I); Rev. 62 PT/2/A/4200/002I, Co ntainment Clo sure Verificati on (Part II); Rev. 34 PT/2/A/4200/002J, C ontainment Cl osure Verificati on Penetratio n Status Chan ge; Rev. 12 PT/0/A/4 150/03 7, Fue l/Comp onent Mov ement A ccount ing; Re v. 6 PT/2/A/4550/001C, R efueling Communica tions Test; Rev. 15 PT/0/A/4150/017, Total Core Unlo ading; Rev.


32 PT/0/A/4 150/01 7, Total Core U nload ing Tai lgate B riefin g; Rev. PT/2/A/4550/001D; R eactor Buil ding Mani pulator Crane Load test; Re v. 12 PT/2/A/4 550/00 1E; Sp ent Fu el Bu ildi ng Ma nipul ator Cr ane Lo ad tes t; Rev. 7 Enclosure 4.2, Decreasing th e NC System Level; Enclosure 4.1 0, Requirements for Opera tion wi th the NC Sy stem Level Below 1 6%OP/2/A/6150/006, D raining The Rea ctor Coolant System, Rev. 68 OP/2/A/6200/005, S pent Fuel C ooling Sy stem, Rev. 61 OP/0/A/6100/014, P enetration Co ntrol for Mode s 5 and 6; R ev. 28 OP/1/A/6550/015; R eceipt, Inspecti on and Storage o f New Fuel , Rev. 30 OP/2/A/6550/006, Trans ferring Fuel w ith the Spen t Fuel M anipulator Crane Rev. 49 OP/2/A/6550/007, R eactor Buil ding Mani pulator Crane Operation; Rev. 24 OP/2/A/6550/008, F uel Transfer Syste m Operation; Rev. 9 MP/0/B/715 0/012, Refuel ing Ca nal C leanl iness; Rev. 6 Section 1R22:
Surveillanc e Testing PT/0/A/4200/013; RN Shared Val ves Inserv ice Test; Encl osure 13.11; 1R N-63A Valv e Inservice Test; Rev. 27 PT/0/A/4400/008A, R N Flow Balance Train A; Rev. 4 9 PT/1/A/4200/013C; R N Valve Inservice Test (Quarterly), Re v. 65 IP/2/A/3680/008A
; DG 2A EQC Sy s. Time Delay and Underv oltage Relay Calibrati on; Rev. 00 4 Complex E volution Plan asso ciated wi th the 2A DG P M work, da ted 2/7/06 PIP C-06-487; Retest on v alve 1R N-28A required following re work of the compone nt A-5 Attachment Attachment MP/0/A/7150
/006, Ice Conde nser Lower Inlet Doors Ins pection and Testing, Rev. 24 Section 1R23:
Temporary Plant Modifications PIP C-06-0460
; Temporarily raise the upp er operabil ity limi t on the YC chillers to 220F Design Change C D500733; Bl ock the non-essenti al A and B YC Chil ler Trips Minor Modification CD500308; Provide temporary cooling to the 1A and 2A diesel generator s in support of the A train RN LCO Minor Modification CD500309; Provide temporary cooling to the 1B and 2B diesel generator s in support of the B train RN LCO OMP 2-31, A ttachment 8.2; Increas ed survei llance she et for monitoring the Y C chille r during the 14 day LCO with several trips bypas sed YC chill er alarm respon se table for safety trips in o verride - d ated 01/02/06 AP/1/A/5500/007
; Enclosure 3 5, DG 1A loc al start durin g the 14 day LCO, Rev 47 AP/1/A/5500/007
; Enclosure 3 6, DG 1A loc al start durin g the 14 day LCO, Rev 47 AP/2/A/5500/007
; Enclosure 3 6, DG 2A loc al start durin g the 14 day LCO, Rev 46 AP/2/A/5500/007
; Enclosure 3 7, DG 2A loc al start durin g the 14 day LCO, Rev 46 CNC-1535.00-0 0-0025; Sectio n 9.7, 14 day LCO assuming ba ckup YD cooli ng limitations Section 4OA 2: Problem Iden tification and Re solution PIP C-06-158 3, K F Pu mp 2A ope rati onal para mete rs ar e no t as good as p rior to re bui ldi ng pump PIP C-02-968 , Elev ated b earin g oil tempera tures o n Uni t 2B K F pump PIP C-04-537 , Disc overe d 2B K F pump IB pum p bear ing oi l bub bler e mpty PIP C-04-567 , 2B K F pump inbo ard be aring o il bu bbler empty PIP C-04-858, KF pump beari ng house needs to be vente d PIP 03-1394, The 1A KF motor i nboard wa s found to be rub bed in ax ial direc tion PIP 04-3950, 2 A KF pump hi gh inboard motor b earing temperature Section 4OA 5: Other A ctivities AP/0/A/5500/045 , Plant Fire , Rev. 002 IP/0/B/3540/002, E mergency Battery Lighting (ELD) P eriodic M aintenance a nd Testing, Rev
.32 CNC-1 435.00-00-00 18, Ev aluat ion o f Battery Pow ered E mergency Lights , Rev. 1 PIP C-04-0427 6, URI discu ssed in the TFPI - Catawb a inspectio n issue UFSAR Cha pter 9.5.1, Fire Protection, date d 3/27/2003 W.O. 98705970-01 Emergency Battery Lighting (ELD) P eriodic M aintenance, 1 2-07-04.
}}
}}

Revision as of 19:34, 23 November 2019

IR 05000413-06-002, 05000414-06-002; 1/1/2006 - 3/31/2006; Catawba Nuclear Station, Units 1 and 2; Maintenance Risk Assessments and Emergent Work Evaluation and Other Activities
ML061350287
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 05/12/2006
From: Payne D
NRC/RGN-II/DRP/RPB1
To: Jamil D
Duke Energy Corp
Shared Package
ML061350287 List:
References
IR-06-002
Download: ML061350287 (25)
v • d • e


Text

SUBJECT:

CATAWBA NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000413/2006002 AND 05000414/2006002

Dear Mr. Jamil:

On March 31, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Catawba Nuclear Station Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on April 12, 2006, with you and other members of your staff.

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

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

This report documents two NRC-identified findings of very low safety significance (Green) which were determined to be violations of NRC requirements. However, because of their very low safety significance and because these violations were entered into your corrective action program, the NRC is treating these violations as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC, 20555-0001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC, 20555-0001; and the NRC Resident Inspector at the Catawba Nuclear Station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document

DEC 2 Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

D. Charles Payne, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52

Enclosure:

Integrated Inspection Report 05000413/2006002 and 05000414/2006002 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52 Report No.: 05000413/2006002 and 05000414/2006002 Licensee: Duke Energy Corporation Facility: Catawba Nuclear Station, Units 1 and 2 Location: 4800 Concord Road York, SC 29745 Dates: January 1, 2006 through March 31, 2006 Inspectors: E. Guthrie, Senior Resident Inspector A. Sabisch, Resident Inspector S. Walker, Acting Senior Resident Inspector N. Staples, Reactor Inspector (Section 4OA5)

Approved by: D. Charles Payne, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000413/2006-002, 05000414/2006-002; 1/1/2006 - 3/31/2006; Catawba Nuclear Station,

Units 1 and 2; Maintenance Risk Assessments and Emergent Work Evaluation and Other Activities The report covered a three-month period of inspection by three resident inspectors and a reactor inspector. Two Green NRC-identified non-cited violations (NCVs) were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, (ROP) Revision 3, dated July 2000.

NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green.

An NRC-identified NCV was identified for the failure to adequately assess and manage the risk pertaining to a portion of the maintenance activities associated with the removal of the A train of nuclear service water (RN) from service for a planned 14-day outage as required by 10 CFR 50.65(a)(4).

The finding was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring that the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences is maintained.

The inspectors determined that the finding was of very low risk significance (Green),

based on the resulting magnitude of the calculated Incremental Core Damage Probability (5.8E-7/day), the length of time that the two A train diesels were unavailable (<18 hours) and that no actual loss of safety function of the 2B DG occurred. This finding involved the cross-cutting aspect of human performance. (Section 1R13)

Green.

An NRC-identified NCV of Catawba Nuclear Station (CNS) Operating License Condition 2.C.5, Fire Protection Program (FPP), was identified. The licensee made a change to the approved fire protection program which had the potential to affect post-fire safe shutdown capability. Specifically, the licensee derated the time requirement for 43 battery powered emergency lighting units (ELUs) from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The evaluation for this change was not adequate to ensure that derating the ELUs would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

This finding is more than minor because it had the potential to impact the licensees post-fire safe shutdown capability by delaying operator response in the event of a loss of power to normal lighting during a fire. The finding was of very low risk significance (Green) because operators would likely be able to accomplish the actions with the use of flashlights. (Section 4OA5.1)

Licensee-Identified Violations

None

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period operating at 100 percent (%) Rated Thermal Power (RTP).

Power was reduced to 65% RTP on March 25 to support swapping main turbine lube oil coolers due to a tube leak that had increased on the in-service cooler. The unit was returned to 100%

power on March 26 and remained there through the end of the inspection period.

Unit 2 began the inspection period operating at 100% RTP. End-of-cycle power coast down commenced on March 14. Power was reduced to 94% on March 15 to conduct main steam safety relief valve testing and remained there until the unit was removed from service for a planned refueling outage on March 18. The unit remained off-line through the end of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R04 Equipment Alignment

a. Inspection Scope

Partial System Walkdowns. The inspectors walked down the following five system alignments to verify that critical portions of equipment alignments remained operable while the redundant trains for that system were inoperable. The inspectors reviewed plant documents to determine the correct system and power alignments, as well as the required positions of selected valves and breakers. The inspectors reviewed equipment alignment problems which could cause initiating events or impact mitigating system availability to verify that they had been properly identified and resolved. Documents reviewed are listed in the Attachment.

  • The B Train of nuclear service water (RN) when the A Train was removed from service for the 14-day Limiting Condition for Operation (LCO) to clean, coat, replace and repair the RN piping
  • The B Train of component cooling water (KC) when the A Train of KC was removed from service as part of the 14-day RN train LCO period
  • The A Train of RN when the B Train was removed from service for the 14-day LCO to clean, coat, replace and repair the RN piping
  • Cross-train alignment of the KC system in support of the B Train RN LCO Allowed Outage Time (AOT)
  • B Train of RN in the RN pump house structure when the A Train of RN was removed from service for the 14-day LCO

b. Findings

No findings of significance were identified.

1R05 Fire Protection

a. Inspection Scope

Fire Protection Walkdowns. The inspectors walked down accessible portions of the following eight plant areas to assess the licensees control of transient combustible material and ignition sources, fire detection and suppression capabilities, fire barriers, and any related compensatory measures. The inspectors observed the fire protection suppression and detection equipment to determine whether any conditions or deficiencies existed which could impair the operability of that equipment. The inspectors selected the areas based on a review of the licensees safe shutdown analysis probabilistic risk assessment, sensitivity studies for fire-related core damage accident sequences, and summary statements related to the licensees 1992 Initial Plant Examination for External Events submittal to the NRC. Documents reviewed are listed in the Attachment.

  • Unit 1 Exterior Doghouse
  • Main Control Room
  • Unit 1 Mechanical Penetration Room, 543 foot elevation
  • Unit 1 Electrical Penetration Room, 560 foot elevation
  • Unit 2 Mechanical Penetration Room, 577 foot elevation
  • Unit 1 Spent Fuel Building Fan Room, 636 foot elevation
  • Nuclear Service Water Pump House Fire Drill Observation. On March 3, the inspectors observed a shift fire drill simulating an oil fire in the Unit 1 Main Turbine Oil Tank room located on the 594 foot elevation of the turbine building. The purpose of this annual inspection was to: monitor the fire brigades use of protective gear and fire fighting equipment; verify that fire fighting pre-plan procedures and appropriate fire fighting techniques were used; and verify that the directions of the fire brigade leader were thorough, clear, and effective. The inspectors also attended the subsequent drill critique to assess whether it was appropriately critical, included discussions of drill observations, and identified any areas requiring corrective action. Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification

a. Inspection Scope

Resident Quarterly Observation. The inspectors observed Active Simulator Exam Scenario 16 to assess the performance of licensed operators. The exercise included a loss of condenser vacuum, loss of 6.9 kV bus, loss of a reactor coolant pump, loss of normal power to an essential train, an Anticipated Transient without a Scram, and a steam line break outside of containment. The inspection focused on high-risk operator actions performed during implementation of the emergency operating procedures, emergency plan implementation and classification, and the incorporation of lessons-learned from previous plant events. Through observations of the critique conducted by training instructors following the exam session, the inspectors assessed whether appropriate feedback was provided to the licensed operators regarding identified weaknesses.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees effectiveness in performing the two following routine maintenance activities. This review included an assessment of the licensees practices pertaining to the identification, scope, and handling of degraded equipment conditions, as well as common cause failure evaluations and the resolution of historical equipment problems. For those systems, structures, and components (SSCs) scoped in the maintenance rule per 10 CFR 50.65, the inspectors verified that reliability and unavailability were properly monitored, and that 10 CFR 50.65 (a)(1) and (a)(2)classifications were justified in light of the reviewed degraded equipment condition.

Documents reviewed are listed in the Attachment.

  • Repairs of the 1B Spent Fuel Pool Cooling Pump

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation

a. Inspection Scope

The inspectors reviewed the licensees assessments concerning the risk impact of removing from service those components associated with the eight emergent and planned work items listed below. This review primarily focused on activities determined to be risk significant within the maintenance rule. The inspectors also assessed the adequacy of the licensees identification and resolution of problems associated with maintenance risk assessments and emergent work activities. The inspectors reviewed Nuclear System Directive (NSD) 415, Operational Risk Management (Modes 1-3) and NSD 403, Shutdown Risk Management (Modes 4,5,6, and No Mode), for appropriate guidance to comply with 10 CFR 50.65 (a)(4). Documents reviewed are listed in the

.

  • Entry and day-to-day activities related to the A Train of RN outage
  • Entry and day-to-day activities related to the B Train of RN outage
  • Schedule review and evaluation of planned/in-progress work following the discovery of a potential RN header leak
  • Schedule review and evaluation of planned/in-progress work following the discovery of a potential RN header leak between manholes #8 and #9
  • Schedule review and assessment of planned activities with Orange grid status due to problems at Belews Creek Steam Station
  • Schedule review and assessment of planned activities on Unit 2 following the failure of the primary Digital Feedwater Control System controller and unexpected replacement of a pressurizer level transmitter
  • Review and assessment of rescheduled major Unit 2 refueling outage activities due to failure of the Containment Closure Test
  • Review and assessment of rescheduled major outage activities due to maintenance on 2B Spent Fuel Cooling Pump prior to core offload, failure of the Unit 1 Reactor Trip Breaker during surveillance testing, and a turbine lube oil transfer pipe leak

b. Findings

Introduction.

A Green NCV of 10 CFR 50.65(a)(4) was identified by the inspectors for the licensee failing to adequately assess and manage the risk pertaining to a portion of the maintenance activities associated with the removal of the A Train of nuclear service water (RN) from service for a planned 14-day outage.

Description.

On January 5, the A Train of nuclear service water (RN) was removed from service to allow for the header to be drained, inspected and refurbished due to ongoing degradation of the piping. The removal of the A Train of RN from service resulted in other equipment and systems being rendered inoperable including the 1A and 2A emergency diesel generators (DG). As part of the licensee amendment that granted a one-time extension of the normal 72-hour LCO allowed outage time (AOT) to 14 days, the licensee committed to implement a number of actions to manage the elevated risk created by this activity. These included providing temporary cooling to the DG via the fire protection system during the period the RN header was out of service and to protect equipment on the opposite train; i.e., the B Train and protecting the opposite train equipment when one train of RN was removed from service.

The A Train of RN was removed from service at approximately 2100 on January 5 and the 1A and 2A DGs were declared inoperable at that time. Installation of the temporary cooling lines from the fire protection system to the diesel jacket water heat exchangers did not commence until the morning of January 6, 2006 and was not worked continuously until completed (approximately 1300 for the 1A diesel and 1500 for the 2A diesel). The initial efforts were directed at restoring the 1A DG; however, the 2A DG was required for the operation of the 1A DG because the 2A DG powered the A fire pump which would be required to provide cooling to the A Train DGs on a loss of offsite power. This sequence requirement had not been identified by the licensee in scheduling the installation of the temporary cooling to the DGs prior to enter the 14-day LCO.

During the period of time in which the two A Train DGs were unavailable, a mobile crane traversed the roof area of the 2B DG on two occasions preparing to lift the 2A diesel room roof hatches. While the crane movement was done in accordance with an approved station procedure for the work on the 2A DG, the licensee did not consider the current plant condition; i.e., two of four DGs inoperable with both units in an Orange ORAM/SENTINEL risk condition. In addition, while the 2B DG itself had been posted with protected equipment signage, the roof area and support equipment such as the diesel lube oil storage tanks and the 2A/2B fire protection and carbon dioxide (CO2 )

headers had not been posted. As a result of not protecting these components and areas, the crane movement had the potential to render the 2B DG inoperable leaving the station with only one operable DG in the event normal AC power was lost. On January 5, the A Train of RN was removed from service to allow for the header to be drained, inspected and refurbished due to ongoing degradation of the piping. The removal of the A Train of RN from service resulted in other equipment and systems being rendered inoperable including the 1A and 2A emergency DGs. As part of the licensee amendment that granted a one-time extension of the normal 72-hour LCO AOT to 14 days, the licensee committed to provide temporary cooling to the DG via the fire protection system during the period the RN header was out of service and to protect equipment on the opposite train; i.e., the B Train.

Analysis.

Aspects of this maintenance work which demonstrated inadequate assessment and management during planned maintenance on the A Train of the RN system increased risk included the following:

The licensees risk assessment failed to fully consider risk significant SSCs and support systems that were unavailable during the maintenance activities.

  • Restoring the DGs to available status was a commitment made as part of the licensee amendment request submitted by the licensee. Work to restore the 1A and 2A DGs to available status was not initiated promptly when appropriate conditions were established nor was the work performed on a continuous basis until complete. In addition, the correct sequence of restoring the 2 DGs (2A followed by 1A) was not implemented. These actions would have minimized the Incremental Core Damage Probability value that resulted from this portion of the planned LCO activities.

The licensees risk assessment failed to account for the possible unavailability of a single train of a system (primary or back-up) that provides a shutdown key safety function.

  • The potential impact on the stations emergency AC power system due to movement of a mobile crane on the 2B DG roof in close proximity to support equipment was not considered in the risk assessment performed in support of the A Train RN LCO outage schedule nor once the outage.

The licensee failed to effectively implement or manage prescribed significant compensatory measures.

  • As part of the license amendment request, the licensee committed to protect the 1B and 2B diesel generators during the A Train LCO outage to minimize the overall station risk exposure and developed a plan to post the equipment when the LCO was entered. However, the roof area and adjacent support equipment was not included within this protected equipment boundary and as a result, work was allowed to be performed in close proximity to equipment which had the potential to adversely impact the operability of the 2B DG.
  • Changes in work scope and activities conducted in the vicinity of the 2B DG were not communicated back to Operations or Engineering to ensure that the changes were assessed in a timely manner and did not affect the overall station risk values.

The finding was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems which respond to initiating events to prevent undesirable consequences is maintained.

The inspectors determined that the finding is of very low risk significance (Green),based on the resulting magnitude of the calculated Incremental Core Damage Probability (5.8E-7/day), the length of time that the two A Train diesels were unavailable

(<18 hours) and that no actual loss of safety function of the 2B DG occurred. This finding involved the cross-cutting aspect of human performance.

Enforcement.

10 CFR65 (a)(4), Requirements for monitoring the Effectiveness of Maintenance at Nuclear Power Plants, requires in part, that prior to performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Contrary to the above, on January 5 and 6, 2006, the licensee failed to implement the requirements of 10 CFR 50.65(a)(4)to adequately assess and manage the increase in risk during the execution of planned maintenance associated with the A Train of RN, which placed the station in an Orange ORAM risk condition, and minimize the overall risk exposure as demonstrated through the following:

  • The licensee failed to expeditiously install temporary cooling to the 1A and 2A DGs as committed to in the License Amendment Request (LAR) that allowed the 14-day LCO which resulted in unnecessary unavailability of the DGs, when the RN header was drained and the temporary cooling was being installed, by not starting the work as soon as conditions permitted or working the job on a continuous basis.
  • The licensee failed to post the roof area above the 1B and 2B DGs and adjacent support equipment as protected equipment as committed to in the LAR to ensure the operability of the remaining safety-related equipment was not jeopardized.
  • The licensee allowed a mobile crane to traverse the roof area above the 2B DG prior to restoring the 2A DG to available status to minimize the potential impact this movement could have on an operable piece of safety-related equipment.
  • The licensee failed to properly sequence the actions taken in restoring the A Train diesel generators to available status to ensure the 2A diesel generator was returned first, which was required to provide cooling to both A Train DGs in the event of a LOOP.
  • The licensee failed to effectively communicate the elevated risk associated with planned work activities to station personnel to ensure that changes in work scope or schedules were elevated to the appropriate personnel for review and assessment.

Because this finding is of very low safety significance and has been entered into the licensees corrective action program as PIP C-06-0057, this violation is being treated as an NCV consistent with Section VI.A.1 of the NRC Enforcement manual (NCV 05000413, 414/2006002-01, Inadequate Risk Assessment and Management Associated with Planned Nuclear Service Water System Maintenance).

1R14 Operator Performance During Non-Routine Plant Evolutions and Events

a. Inspection Scope

The inspectors observed operator performance during the shutdown of Unit 2 for the refueling outage. The inspectors observed licensed operators use of procedures, control room pre-evolution briefing, and plant equipment manipulations during the power reduction, manual reactor trip, and portions of the subsequent cooldown.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed five operability evaluations to verify that the operability of systems important to safety were properly established, that the affected components or systems remained capable of performing their intended safety function, and that no unrecognized increase in plant or public risk occurred. Operability evaluations were reviewed for the five issues listed below. Documents reviewed are listed in the

.

  • 2B Chemical & Volume Control (NV) charging pump oil leak (PIPs C-05-7243 and C-06-0197)
  • Top left stud on 2B DG crankcase door 8R was broken during reinstallation of the cover (PIP C-06-1238)
  • 2A DG room ventilation system damper found to have a broken weld affecting its operation (PIP C-06-0997)

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors witnessed and/or reviewed six post-maintenance testing procedures and/or test activities, as appropriate, for selected risk significant systems to verify if:

(1) testing was adequate for the maintenance performed;
(2) acceptance criteria were clear and adequately demonstrated operational readiness consistent with design and licensing basis documents;
(3) test instrumentation had current calibrations, range, and accuracy consistent with the application;
(4) tests were performed as written with applicable prerequisites satisfied; and
(5) equipment was returned to the status required to perform its safety function. Documents reviewed are listed in the Attachment.
  • Verification of piping/flange integrity following completion of the B RN supply header 14-day LCO outage involving replacement of existing piping and addition of new cross-over connections
  • Calibration and functional testing of B Train RN supply header annubar flow instrumentation
  • Functional stroke testing of 2RN69B; B Train RN supply header isolation valve, following 14-day LCO outage work
  • Operational testing of the 1B/2B RN pumps following the B Train RN LCO AOT
  • Testing of the 1B RN pump strainer differential pressure switch following refurbishment of the strainer and associated instrumentation
  • Functional test of the 1B RN pump strainer following refurbishment

b. Findings

No findings of significance were identified.

1R20 Refueling and Outage Activities

a. Inspection Scope

The inspectors evaluated Unit 2 refueling outage activities to verify that the licensee considered risk in developing and implementing outage schedules; adhered to administrative risk reduction methodologies developed to control plant configuration; developed mitigation strategies for losses of key safety functions; and adhered to operating license and TS requirements that ensure defense-in-depth. The following specific areas were reviewed. Documents reviewed are listed in the Attachment.

  • Review of Outage Plan
  • Monitoring of Shutdown Activities
  • Licensee Control of Outage Activities
  • Clearance Activities
  • Electrical Power
  • Spent Fuel Pool Cooling System Operation
  • Inventory Control
  • Reactivity Control
  • Containment Closure
  • Reduced Inventory and Mid-Loop Conditions
  • Refueling Activities

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed and/or reviewed the six surveillance tests listed below to verify that TS surveillance requirements and/or Select Licensee Commitment requirements were properly complied with, and that test acceptance criteria were properly specified.

The inspectors verified that proper test conditions were established as specified in the procedures, that no equipment preconditioning activities occurred, and that acceptance criteria had been met. Additionally, the inspectors also verified that equipment was properly returned to service and that proper testing was specified and conducted to ensure that the equipment could perform its intended safety function following maintenance or as part of surveillance testing. Documents reviewed are listed in the

.

Surveillance Tests

  • Flow balance of the A Train of RN following completion of the 14-day LCO AOT
  • 1RN-28A; 1A RN pump discharge isolation valve, inservice test
  • 2A DG EQC System Time Delay and Undervoltage Relay Calibration In-Service Tests
  • Quarterly In-Service Test for motor operated valve 1RN-63A; RN header A return to Standby Nuclear Service Water Pond Ice Condenser Surveillance Tests
  • MP/0/7/7150/006, Ice Condenser Lower Inlet Doors Inspection and Testing (As Found), Rev. 24
  • MP/0/A/7150/005; Ice Basket Weight Determination (Unit 2, Bay 4, Baskets 6-9, 7-9, 8-9 and 9-9); Rev. 24

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed the following two temporary plant modifications to determine whether the individual modification was properly installed; the modification did not affect system operability, drawings and procedures were appropriately updated; and post-modification testing was satisfactorily performed. Documents reviewed are listed in the

.

  • Installation of temporary cooling to the lube oil heat exchanger and air compressor aftercoolers on the 1A and 2A DGs in support for the 14-day A Train RN outage.
  • Bypassing the non-essential chiller trips on the B Train control room area (YC) chiller in support for the 14-day A Train RN outage.

b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation a Inspection Scope The inspectors observed and evaluated the licensees performance in the Control Room simulator and in the Technical Support Center during an emergency drill conducted on March 2. The NRCs assessment focused on the timeliness and location of classification, development of notification and protective action recommendations, and the licensees expectations of response. The performance of the emergency response organization was evaluated against applicable licensee procedures and regulatory requirements. The inspectors attended the post-exercise critique of the drill to evaluate the licensee's self-assessment process for identifying deficiencies related to individual and overall performance during the emergency drill. The inspectors assessed the drill for weaknesses and deficiencies in performance of classification and notification requirements.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

4OA2 Identification and Resolution of Problems

.1 Daily Review

As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed screening of items entered into the licensees corrective action program. This was accomplished by reviewing copies of PIPs, attending some daily screening meetings, and accessing the licensees computerized database.

.2 Annual Sample Review

a. Inspection Scope

The inspectors selected PIPs C-05-6471 and C-05-7516 for detailed review. Both involved increased outboard pump bearing temperatures on the 1B Spent Fuel Cooling pump. These PIPs were reviewed to determine whether the full extent of the issues were identified, an appropriate evaluation was performed, and appropriate corrective actions were specified and prioritized. The inspectors evaluated the PIPs against the requirements of the licensees corrective action program document and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.

b. Findings and Observations

No findings of significance were identified.

4OA5 Other Activities

.1 (Closed) URI 05000414/2004007-03: Derating Selected Emergency Lighting Units Required

for Post-Fire Safe Shutdown

a. Inspection Scope

The inspectors preformed an in-office review of the documents listed in the Attachment to determine if the ability to achieve and maintain safe shutdown (SSD) was adversely affected.

b. Findings

Introduction.

The inspectors identified a Green NCV of CNS operating License Condition 2.C.5, Fire Protection Program. The licensee made a change to the approved FPP which had the potential to affect post-fire safe shutdown capability. Specifically, the licensee derated the time requirement for 43 battery-powered ELUs from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The licensees evaluation for this change did not adequately demonstrate that the change would not adversely affect the ability to achieve and maintain SSD in the event of a loss of power to normal lighting during a fire.

Description.

The licensee derated the time requirement for 43 battery-powered ELUs from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> by minor modification CE-70695. These ELUs were credited for illumination of access/egress pathways or equipment for local manual operator actions associated with alternative shutdown. This change to the FPP was not consistent with the licensing basis, which stated that 8-hour battery-powered emergency lights would be provided. The justification for derating selected ELUs credited for post-fire SSD was provided in calculation CNC-1435.00-00-0018. The calculation stated that derating selected SSD ELUs was acceptable because access, operator activities, and egress could occur well within 30 minutes. However, as discussed in NRC Inspection Report 05000413, 05000414/2004007, the abnormal procedures in effect at the time of that inspection may not have activated the standby shutdown facility (SSF) within the 30-minute or 1.5-hour timeframes for fire events which may require activation of the SSF. Instead, the procedures directed operators to remain in the control room until it became uninhabitable or became incapable of maintaining primary or secondary inventory. Then the procedures directed operators to go to the alternate shutdown panel, in a lower level of the auxiliary building, and remain there until the controls there were determined to be inadequate to maintain safe plant conditions. Only then did abnormal procedures direct operators to activate the SSF. The delays in activating the SSF were not addressed in Calculation CNC-1435.00-00-0018 nor the 10 CFR 50.59 safety evaluation performed for minor modification CE-70695 and the associated Updated Final Safety Analysis Report (UFSAR) revision for this change.

Analysis.

This finding is more than minor because it had the potential to impact the licensees post-fire safe shutdown capability by delaying operator response in the event of a loss of power to normal lighting during a fire. Access, operator activities, and egress may occur at later times than assumed in the calculation for the derated ELUs.

The finding was of very low safety significance (Green) because the inspectors determined that operators would likely be able to accomplish the actions with the use of flashlights.

Enforcement.

Operating License Condition 2.C.5 requires that the licensee implement and maintain in effect all provisions of the approved FPP, as described in the UFSAR, as amended, for the facility and as approved in the Safety Evaluation Report (SER)through Supplement 5. Branch Technical Position (BTP) CMEB 9.5-1, which incorporated the guidance of Appendix A to BTP ASB 9.5-1 and the technical requirements of Appendix R to 10 CFR Part 50, established the regulatory and licensing requirements for the FPP at CNS. The CNS FPP was reviewed against and approved for conformance with BTP CMEB 9.5-1 in the SER through Supplement 5. BTP CMEB 9.5-1, Item C.5.g.(1), states, in part, that lighting is vital to safe shutdown and emergency response in the event of fire. In addition, fixed self-contained lighting consisting of fluorescent or sealed-beam units with individual 8-hour minimum battery-power supplies be provided in areas that must be manned for safe shutdown and for access and egress routes to and from all fire areas.

Contrary to the above, on June 25, 2004, the inspectors identified that the licensees evaluations failed to ensure that the derating of selected ELUs from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> would not adversely affect the ability to achieve and maintain safe shutdown in the event of a loss of power to normal lighting during a fire. Procedural delays for activating the SSF were not addressed in either Calculation CNC-1435.00-00-0018 or the 10 CFR 50.59 safety evaluation performed for minor modification CE-70695. Access, operator activities, and egress may occur at times later than the 30 minutes or 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> assumed in the calculation for the derated ELUs. This condition has existed since May 2001. The licensee documented this violation in the corrective action program as PIP C-04-04276. The emergency light testing procedure, IP/0/B/3540/002, was changed from the 1.5-hour test period back to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. In addition, CNS also retested the derated ELUs for compliance with the 8-hour requirement. Twenty-three of the 43 ELUs provided less than the minimum 8-hour lighting requirement. The licensee replaced the batteries for the 23 ELUs. Because of the very low safety significance and the licensee has entered this violation into their corrective action program, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy and is identified as NCV 05000414/2006002-02, Derating Selected Emergency Lighting Units Required for Post-Fire Safe Shutdown.

4OA6 Meetings

.1 Exit Meeting Summary

On April 12, the resident inspectors presented the inspection results to Mr. D. Jamil and other members of licensee management, who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection period.

.2 Annual Assessment Meeting Summary

On April 26, the NRC's Acting Chief of Reactor Projects Branch 1 and the Resident Inspectors assigned to the CNS met with Duke Energy Corporation to discuss the NRC's ROP and the NRC's annual assessment of CNS safety performance for the period of January 1, 2005 - December 31, 2005. The major topics addressed were: the NRC's assessment program and the results of the CNS assessment. This meeting was open to the public. A listing of meeting attendees and information presented during the meeting are available from the NRC's document system (ADAMS) as accession number ML061170325.

ADAMS is accessible from the NRC Web site at www.nrc.gov/reading-rm/adams.html.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

K. Adams, Human Performance Manager
E. Beadle, Emergency Planning Manager
S. Beagles, Chemistry Manager
W. Byers, Security Manager
J. Ferguson, Safety Assurance Manager
J. Foster, Radiation Protection Manager
W. Green, Reactor and Electrical Systems Manager
G. Hamrick, Mechanical, Civil Engineering Manager
D. Jamil, Catawba Site Vice President
R. Hart, Regulatory Compliance Manager
A. Lindsay, Training Manager
J. Pitesa, Station Manager
L. Reed, Modifications Engineering Manager
R. Repko, Engineering Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Open and

Closed

05000413,414/2006002-01 NCV Inadequate Risk Assessment and Management Associated With Planned Nuclear Service Water System Maintenance (Section 1R13)
05000414/2006002-02 NCV Derating Selected Emergency Lighting Units Required for Post-Fire Safe Shutdown (Section 4OA5.1)

Closed

05000414/2004007-03 URI Derating Selected Emergency Lighting Units Required for Post-Fire Safe Shutdown (Section 4OA5.1)

LIST OF DOCUMENTS REVIEWED

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